COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on minimum requirements for water reuse

EN EN
EUROPEAN
COMMISSION
Brussels, 13.6.2018
SWD(2018) 249 final/2
PART 1/3
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT
Accompanying the document
Proposal for a Regulation of the European Parliament and of the Council on minimum
requirements for water reuse
{COM(2018) 337 final} - {SEC(2018) 249 final} - {SWD(2018) 250 final}
Europaudvalget 2018
KOM (2018) 0337
Offentligt
TABLE OF CONTENT
INTRODUCTION............................................................................................................................ 1
1. PROBLEM DEFINITION.................................................................................................... 2
1.1. Policy context................................................................................................... 2
1.2. Problem definition............................................................................................ 6
1.2.1. Scope of the present impact assessment............................................... 8
1.3. What are the underlying causes of the problem? ........................................... 11
1.3.2. Factor 2 – Legal frameworks for water reuse exist only in few
Member States resulting in a perceived health risk and environmental
risk...................................................................................................... 13
1.3.3. Factor 3 – Possible trade barriers, i.e. trade bans for food products
irrigated with reclaimed water........................................................... 16
1.3.4. Factor 4 – Reuse perceived as more risky than beneficial................. 17
1.4. How will the problem evolve, all things being equal?................................... 19
1.5. Who is affected and how? .............................................................................. 20
2. WHY SHOULD THE EU ACT?........................................................................................ 21
2.1. Competence.................................................................................................... 21
2.2. Subsidiarity..................................................................................................... 22
3. OBJECTIVES – WHAT SHOULD BE ACHIEVED? .............................................................. 23
3.1. General objective............................................................................................ 23
3.2. Specific objectives.......................................................................................... 24
3.3. Operational objectives.................................................................................... 25
4. POLICY OPTIONS ......................................................................................................... 25
4.1. Baseline – “No new EU action”..................................................................... 25
4.2. Design of policy options ................................................................................ 26
4.2.1. Minimum quality requirements for water reuse to ensure health safety
of agricultural products irrigated with treated waste waterm which
are placed on the Internal Market...................................................... 27
4.2.1.1. "One-size-fits-all" approach............................................................... 28
4.2.1.2. "Fit-for-purpose" approach ............................................................... 28
4.2.1.3. Implementation of the requirements................................................... 29
4.2.1.4. Minimum requirements: regulated at EU-level or recommended by an
EU Guidance document...................................................................... 30
4.2.2. Minimum quality requirements to ensure protection of local public
health and of the environment – Risk Management Framework........ 30
4.2.3. Key Risk Management Framework principles included in a legal
instrument........................................................................................... 31
4.2.4. Risk Management Framework recommended by an EU Guidance
document ............................................................................................ 31
5. ANALYSIS OF IMPACTS................................................................................................ 31
5.1. Baseline.......................................................................................................... 31
5.2. Analysis of the impacts of the policy options for water reuse in agricultural
irrigation......................................................................................................... 32
5.2.1. Economic impacts .......................................................................................... 33
5.2.2. Environmental impacts................................................................................... 39
5.2.2.1. Adapting to climate change and preserving the quality of
natural resources ...................................................................... 39
5.2.2.2. Fostering the efficient use of resources .................................... 43
5.2.2.3. Sustainable consumption and production................................. 45
5.2.2.4. Minimising environmental risks................................................ 45
5.2.3. Social impacts..................................................................................... 46
6. COMPARING THE OPTIONS .......................................................................................... 48
6.1. Effectiveness of the policy options ................................................................ 49
6.2. Efficiency of the policy options ..................................................................... 51
6.3. Coherence of the policy options..................................................................... 52
6.4. Nature of the instrument................................................................................. 53
6.5. Preferred option.............................................................................................. 54
7. MONITORING AND EVALUATION ................................................................................. 55
1
INTRODUCTION
Water is already a limited resource, with one third of Europe experiencing water stress. The
growing needs of populations and climate change will make the availability of water in
sufficient quantity and quality even more of a challenge in Europe in the future. Water
scarcity is no longer confined to a few corners of Europe, and is already a concern across the
EU with significant environmental and economic consequences; projections suggest that the
situation will become much more pronounced in the coming years.
To respond to this problem, Europe's water resources should be managed more efficiently. In
addition to water savings, securing the supply of good quality water can help address water
scarcity in the context of an integrated approach to water management. Reusing water after
treatment constitutes an effective and sustainable alternative water supply, and so can be a
useful tool for managing water resources. For example, this can involve a treatment plant
receiving waste water from domestic uses and then treating it separately and providing it by
pipe to farmers, instead of returning it directly to a river. It extends its life cycle, thereby
helping to preserve water resources as part of an integrated approach to water management
and in full compliance with the circular economy objectives. Today, whilst water reuse in the
EU could obviously never by itself solve water scarcity problems, it falls far below its full
potential.
The Commission has been considering the issue of water reuse for a number of years and has
documented its findings to date in several steps. In the 2012 Communication "A Blueprint to
Safeguard Europe's Water Resources" (COM(2012) 673) water reuse for irrigation or
industrial purposes was found to have a lower environmental impact and potentially lower
costs than other alternative water supplies, whereas it is only used to a limited extent in the
EU. A Fitness check of EU Freshwater policy (SWD(2012) 393) published in November
2012, as a building block of the Blueprint, assessed the performance of the measures taken,
both in environment and in other policy areas, in achieving the objectives already agreed in
the context of water policy. It also identified the major gaps to be closed in order to deliver
environmental objectives more efficiently. In relation to waste water reuse, the Fitness Check
concluded that "alternative water supply options with low environmental impact need to be
further relied upon" in order to address water scarcity. A particular issue emphasised by
stakeholders in the public consultation of the Fitness Check was the lack of EU common
quality requirements for reuse of waste water in irrigation. Several policy options to promote
water reuse were considered in the impact assessment of the Blueprint (SWD(2012) 382)1
A
number of actions to promote water reuse were included in the Communication "Closing the
loop – An EU action plan for the circular economy" (COM(2015) 614), and in particular a
legislative proposal on minimum requirements for reused water for irrigation and
groundwater recharge. This proposal has also been included in the European Commission's
2017 Work Programme as it contributes to the political priorities set by the Commission to
promote a more circular economy. In addition, it may complement the planned future
modernisation of the Common Agricultural Policy.2
Finally, the initiative could contribute to
the EU's implementation of the Sustainable Development Goals (SDGs) and in particular
1
It concluded: "Regarding water re-use there is a need to ensure the effective operation of the Internal Market
to support investment and use of re-used water. The assessment, including stakeholder consultation, found that
this can only be achieved through the development of new regulatory standards at EU level. Therefore, the
preferred option is for the Commission to pursue appropriate health/environment protection standards for re-
use of water and, subsequently, to propose a new Regulation containing these subject to a specific impact
assessment."
2
To note in this context that reference to water reuse is made in a Commission Staff Working Document on
Agriculture and Sustainable Water Management in the EU (SWD(2017) 153final) as one of a number of
measures that has the potential to reduce negative impacts associated with over-abstraction.
2
SDG 6 on Clean Water and Sanitation, which sets a target of substantially increasing
recycling and safe reuse globally by 2030.
The intention to address water reuse with a new legislative proposal was noted with interest
by the Council, in its conclusions on the Commission's Communications on the Blueprint and
on Circular Economy and in its conclusions on Sustainable Water Management (11902/16).
Furthermore, the European Parliament, in its Resolution on the follow-up to the European
Citizens’ Initiative Right2Water in September 2015, encouraged the Commission to draw up
a legislative framework on water reuse, as well as the Committee of the Regions, in its
opinion on "Effective water management system: an approach to innovative solutions" in
December 2016.
The present document addresses the problem of a too limited application of water reuse in
order to contribute to alleviating water scarcity and analyses the modalities of creating an
enabling framework for increasing the uptake of water reuse, in particular for agricultural
irrigation and aquifer recharge. Setting appropriate minimum requirements together with a
risk assessment approach would ensure a level playing field for those engaged in water reuse
and those affected, ensure health and the environment are protected and thereby also increase
confidence in the practice of water reuse. Acting now by putting in place an enabling
framework would contribute to alleviating water stress where it is already a reality today in
the EU and also prepare operators and farmers to be ready to act also in those parts of the EU
which will experience increasing water stress in the coming years and decades.
1. PROBLEM DEFINITION
1.1. Policy context
This impact assessment analyses the potential of an EU initiative on water reuse in the
context of water scarcity being a serious problem today and a great concern amongst EU
Member States. Europe's freshwater resources are under increasing stress, with a mismatch
between the continuously increasing demand for, and the limited availability of, water
resources across the whole EU (EEA, 20123
). Water over-abstraction, for irrigation purposes
but also for industrial use and urban development, is one of the main threats to the EU water
environment, while availability of water of appropriate quality is a critical condition to
growth in water-dependent economic sectors and society in general. Empirical studies find
significant macroeconomic affects which vary with the assumed duration and severity of the
drought or water scarcity4
.
Water stress already affects one third of the EU territory all year round (EC, 20125
).
This is no longer only an issue for arid, densely populated regions that are prone to increasing
water stress; temperate areas with intense agricultural, tourism and industrial activities also
suffer from frequent water shortages and/or expensive supply solutions. While during summer
3
https://www.eea.europa.eu/themes/water/water-assessments-2012
4
The overall impacts on the economy due to the 2003 drought have been estimated at a minimum of EUR 8.7
billion (mainly concerning Mediterranean countries, France and the UK), measured as the estimated losses
directly resulting from the drought (EC, 2007). Immediate effects of droughts, such as damage to agriculture and
infrastructure, as well as more indirect effects, such as a reluctance to invest in an area at risk, can also have a
serious economic impact. A 1% increase in the area affected by drought can slow a country’s gross domestic
product (GDP) growth by 2.7% per year (Brown et al., 2013). In Catalonia, Spain, a simulation of the
macroeconomic impact of water restrictions to the Catalan economy for the year 2001 showed that restrictions
on non-priority water uses following a drought warning would have led to a loss of gross added-value of about
EUR 1.196bn (0.97% of Catalonia’s GDP), while extended restrictions in the case of an extreme drought would
have caused a loss of EUR 8.079bn, representing 6.52% of the GDP (Gonzalez et al., 2009).
5
http://ec.europa.eu/environment/water/quantity/pdf/COM-2012-672final-EN.pdf
3
months this is more pronounced in Southern European basins, water scarcity and droughts are
no longer issues confined to southern Europe. Regions in northern European countries,
including the United Kingdom and Germany, also face seasonal water stress.
As an effect of climate change, the frequency and intensity of droughts and their
environmental and economic damages have drastically increased over the past thirty years:
between 1976 and 2006 the number of areas and people affected by droughts went up by
almost 20% and the total costs of droughts amounted to EUR 100 billion (EC, 2012). A
concrete example related to the droughts of the summer of 2017 may further illustrate the
dimensions of economic loss; the Italian farming sector alone was predicting losses of EUR 2
billion6
. This trend is expected to continue, i.e. the average volume of water annually
available as streamflow is expected to decrease significantly in the South of Europe, to
slightly increase in the North, with a transition zone in between, where it is expected to
remain approximately stable (see Annex 4 for details on the assessment). However, the
temporal variability of available water is generally expected to increase, consistent with the
general increase in drought and flood hazards projected for Europe (Forzieri et al., 2014;
Forzieri et al., 2016)7
. So, even in the North of Europe there will be a need to better manage
water resources and to enable more tools.
As shown in Figure 1, even conservative climate scenarios would subject large parts of the
EU territory to significantly reduced quantities of water in rivers.
Figure 1: Water scarcity under a 2 degree climate scenario (Water Exploitation Index, WEI+ is the ratio of
consumed water versus availability; in the red areas more than 40% of all annual renewable freshwater is
consumed). Source: Bisselink & De Roo, 20178
[6]
6
http://www.bbc.com/news/world-europe-40803619
7
Forzieri, G., Feyen, L., Russo, S., Vousdoukas, M., Alfieri, L., Outten, S., Migliavacca, M., Bianchi, A., Rojas,
R., Cid, A. Multi-hazard assessment in Europe under climate change (2016) Climatic Change, 137 (1-2), pp.
105-119. DOI: 10.1007/s10584-016-1661-x; Forzieri, G., Feyen, L., Rojas, R., Flörke, M., Wimmer, F., Bianchi,
A.; Ensemble projections of future streamflow droughts in Europe (2014) Hydrology and Earth System Sciences,
18 (1), pp. 85-108. DOI: 10.5194/hess-18-85-2014
8
Figure 1 and 2 are produced using JRC’s LISFLOOD water resources model (De Roo et al, 2000). The 2
degree global temperature increase maps are an average of 5 climate models and simulate the consequences
when global temperature increase equals 2 degrees. Within an high emission scenario, without signification
climate mitigation (RCP8.5 world) this situation is already reached around 2040. In a milder emission world
(~RCP 4.5) this may be reached around 2055. When we would stay within the Paris agreement, we may be
getting close to this situation, but without ever reaching it, at least not in this century. The 2 degree assessment
includes projections of land use change (using JRC’s LUISA system) until 2050, GDP projections, population
projections and water demand projections until 2100 (Bisselink, De Roo, Bernhard, 2017). A comparison is
made between the ensemble means of the 2oC warming period and the baseline period (1981-2010).
4
Today's situation can be illustrated using an indicator of water stress due to possible over-
abstraction; the ratio of water demand to water availability. Using this indicator, Figure 2
shows how Europe’s rivers are already subject to significant pressure from abstractions (see
Annex 4 for details on the assessment). The indicator highlights that the challenge is not
limited to Southern Europe, but is also an issue in more central parts of Europe.
Figure 2: Water demand divided by water availability. Source: Bisselink & De Roo, 2017.
Farmers needing water for irrigation are obviously affected by this water pressure. Farmers
seeking reliable sources of water all year round may have several options for alternative water
supplies. These can, for example, include investment in water storage devices, using
groundwater reserves, desalination or transferring water from other river basins. In theory
alternative water supply options, especially desalination, can deliver unlimited amounts of
water. In practice, all the options have a lot of limitations in terms of costs and negative
economic, environmental and social impacts. These alternatives have been assessed within the
impact assessment of the Blueprint (see Annex 1a for details).
In some countries, farmers may also receive treated waste water from urban waste water
treatment plants, which can provide a reliable source of water, less dependent on precipitation
and in a quality adapted for this water to be reused for various purposes, e.g. for agricultural
irrigation. Water reuse generally has a lower environmental impact than other alternative
water supplies and offers a range of environmental, economic and social benefits (Annex 6).
While the evidence demonstrates the seriousness of water stress and its expected evolution,
the policy context for water reuse as a contribution to its alleviation has only started to be
developed. Another important angle is the impact of water scarcity in one Member State on
other Member States via the Internal Market. The differences in concepts, principles and
procedures between the water reuse laws of different Member States may impede the free
movement of agricultural products irrigated with treated waste water, create unequal
conditions of competition, and may thereby directly affect the functioning of the Internal
Market.
Water reuse has already been identified and encouraged in provisions of two existing EU
instruments, however, these instruments do not specify conditions for the reuse of treated
waste water:
5
 the Water Framework Directive (2000/60/EC, WFD); its Annex VI, part B mentions water
reuse as one of the possible supplementary measures;
 the Urban Waste Water Treatment Directive (91/271/EEC, UWWTD): its Article 12
stipulates, as part of the condition on wastewater discharges that "treated waste water
shall be reused whenever appropriate. Disposal routes shall minimize the adverse effects
on the environment.".
In the WFD, water scarcity is a key aspect of water management. This legislation sets inter
alia a central goal of attaining good status for Europe's waters by 2015. It requires Member
States to characterise the situation of their water in terms of pressures from human activities
and set 'programmes of measures' to achieve the good status objective. Those are part of River
Basins Management Plans, to be reviewed every 6 years. In 2007, the EU policy on water
scarcity and droughts (COM(2007) 414) (WS&D) elaborated on the integration of water
scarcity planning into River Basins Management Plans, including the use of appropriate water
pricing and ecological requirements for river flows. It spelled out the hierarchy of measures
Member States should consider in managing water scarcity and droughts, with priority for
water saving and efficiency measures, and with additional water supply infrastructures only to
be considered as an option when other options have been exhausted, including effective water
pricing policy and cost-effective alternatives. Water reuse is to be considered within such an
integrated water management approach. The Circular Economy Action Plan included a
number of actions on water reuse (one of which is subject of this impact assessment),
including also Guidelines on integrating water reuse into water planning and management in
the context of the WFD which were completed in 2016 and are expected to positively
contribute.
In 2012, the Commission conducted a series of assessments to check the adequacy of the
water legislation and its implementation. A 'Fitness Check' of freshwater policy looked into
the relevance, coherence, effectiveness and efficiency of water policy. A major evaluation of
the implementation of the WFD was carried out, assessing Member States' River Basin
Management Plans (RBMPs). A gap analysis of the Commission's 2007 policy on Water
Scarcity and Drought9
was also carried out, together with an assessment of how vulnerable
water resources are to climate change and other man-made pressures such as urbanisation and
land use. This included also an assessment of measures introduced by Member States in
different River Basins to address water scarcity and droughts. Such measures were, for
example, the development of drought management plans, considering additional water supply
infrastructure (including water reuse projects) and fostering water efficient technologies and
practices. The results showed that the legislative framework was largely complete and fit for
purpose. However, the overall objective of the WFD – good status for Europe's waters by
2015 – has not yet been fully achieved, neither the WS&D overall policy objective – to revert
the WS&D trends. Furthermore, better implementation and closer integration with other
related policies were clearly required, as well as the development of additional tools related to
water demand management and water availability.
The few identified gaps were discussed in the Communication "A Blueprint to Safeguard
Europe's Water Resources" (COM/2012/0673). As regards the alleviation of water scarcity
and reduction of vulnerability, the Impact Assessment of the Blueprint (SWD(2012) 382)
assessed a number of measures improving water efficiency and availability (e.g. desalination,
water transfers, rainwater harvesting, etc.). Beyond water efficiency measures, water reuse
was identified for its cost-effectiveness and its lower environmental impacts compared to
other supply options; the need for an EU action to address the barriers to its further
development was supported in public consultations (see Annex 2). As a result, the
9
http://ec.europa.eu/environment/water/quantity/pdf/COM-2012-672final-EN.pdf
6
Commission announced in the Blueprint it would consider developing a regulatory instrument
setting EU-wide minimum requirements for water reuse to improve the uptake of this
alternative water supply while maintaining health and environment safety.
A Fitness Check of EU environmental monitoring, which was carried out and presented by
the Commission in June 2017, includes an action plan to streamline environmental reporting
to be implemented in the coming years10
. Monitoring needs for the present initiative have
been elaborated according to the principles highlighted in this Fitness Check (see more details
in Section 7).
The Commission has been discussing water reuse with Member States and stakeholders on an
ongoing basis for the last number of years, both on the policy aspects and the development of
minimum requirements, taking account of existing national requirements and international
practice. The need to address the issue at EU level in the context of alleviating water scarcity
is broadly recognised and supported, including by the agricultural sector (see Annex 2).11
1.2. Problem definition
The problem this initiative seeks to address is that although the practice of water reuse, in
particular for agricultural irrigation and aquifer recharge, could contribute to alleviating
water stress in the EU (see projections in Section 1.1), the uptake of water reuse solutions
remains limited in comparison with their potential, which remains largely untapped. The
problem is relevant for the EU now due to the important consequences of the growing
scarcity affecting EU waters for the environment, the economy and society in general.
There is an important dimension related to the proper functioning of the Internal Market
for agricultural products irrigated with treated waste water.
Several factors contribute to the situation concerning water reuse today and any proposed
solution to the problem should be seen against this background. Firstly, existing water
resources in Europe are not always managed efficiently. There are many situations where
access to conventional water resources is insufficiently controlled by public authorities
resulting in both over allocation (abstraction permits going beyond available resources, incl.
situations where no maximum amount is set in permits) and illegal abstraction (when permits
are not enforced in particular because of no monitoring of actual abstractions). The same
conventional resources are generally under-priced, as fees imposed on self-abstractions
generally do not reflect the environmental and resource cost; the water price in collective
systems hardly covers infrastructure costs (cf. below Figure 3). Both issues can be considered
as an implementation failure as they contradict WFD provisions regarding the setting of
controls on permits, abstractions and water pricing. They can be addressed with e.g.
compliance and enforcement actions as appropriate, ensuring a proper implementation of the
WFD in Member States12
. These failures frequently result in a market failure: subsidised uses
of water are being practiced, even more detrimentally in situations of water scarcity, which
does not reflect their actual cost, leading to a reduction of the economic attractiveness of
water reuse projects (if only the latter are considered at their full cost, or if all available
10
Report "Actions to Streamline Environmental Reporting" (COM(2017)312) and Fitness Check evaluation
(SWD(2017)230)
11
Most recently, Member States expressed support at a meeting of Directors-General for Environment in Tallinn
on 23 October 2017. The latest meeting of the Member States' Common Implementation Strategy Ad-hoc Task
Group on Water Reuse was held on 6-7 November 2017 a number of Member States and stakeholders expressed
strong support for regulation of water reuse at the EU level, pledging for recognising the severity of water stress
that they are facing with all accompanying consequences.
12
In particular the Commission is assessing the updated River Basin Management Plans that Member States
were to adopt by December 2015 and will publish an implementation report by December 2018.
7
options are not compared on equal terms). As a consequence, improper investment decisions
made by water users and decision makers in terms of actual costs incurred and environmental
impacts, despite water reuse being more advantageous than other measures (e.g. use of
drinking water, desalination, lengthy water transfers, on stream storage facilities) in terms of
costs incurred and environmental impacts.
Figure 3: Cost-recovery levels in reviewed countries where irrigation water tariffs are in place, and in other
southern EU Member States (EEA, 2013)
Secondly, despite the existing provisions in both the WFD and UWWTD, water reuse has not
been systematically and sufficiently considered in integrated water management planning13
: a)
either as a practical solution in the broader water management or in the elaboration and
implementation of River Basin Management Plans or b) in the design and location of waste
water treatment plants. Cost of adaptation of existing plants and conveying water to places of
reuse is generally higher than if taken into consideration at the initial stage of building waste
water treatment plants and conveyance networks. The second public consultation identified
the distance between treatment plant and irrigation fields and the insufficient consideration for
water reuse in integrated management amongst the highest barriers (see Annex 2).
The Regulation on the Hygiene of Foodstuffs (EC) No 852/2004 refers to the concept of clean
water but does not include water quality requirements. An accompanying Guidance14
specifies, amongst others, the use of treated waste water for irrigation; it includes examples of
parametric values to ensure the protection of health but their application is voluntary.
Potential environmental risks associated with the use of treated waste water for irrigation are
not addressed.
Current water reuse practices diverge widely across Member States. In some, water reuse is
considered an integral and effective component of long-term water resources management due
to severe water scarcity (e.g. Cyprus, Greece, Italy, Malta, Portugal and Spain), while in other
Member States water reuse is not practised or water reuse projects are rather limited. An
overview of the current situation of water reuse in the EU Member States is provided in
Annex 6.
In 2015, the total volume of reused treated waste water in the EU was estimated at 1,100
million m3
/year (BIO, 201515
), accounting for 2.4% of the total volume of treated effluents
produced or 0.4% of annual EU freshwater withdrawals (237,660 million m3
/year in 2011).
The European countries with the highest reuse rates are presented in Figure 4a. However, as
presented in Figure 4b, rates even for water scarce Italy, Greece and Spain are much lower
than in a number of third countries which have invested a lot in this technology over the last
decades. The highest rate is Israel where 87% of treated waste water is presently reused, with
a target by 2022 of 90%. This confirms that overall in Europe and even in most European
13
mainly due to fragmentation of responsibilities for and authorities over different parts of the water cycle; and a
lack of communication and cooperation among stakeholders from different sectors involved in the whole water
cycle, in particular between water supply (incl. for irrigation) and sanitation stakeholders.
14
2017/C 163/01 of 23 May 2017
15
http://ec.europa.eu/environment/water/blueprint/pdf/BIO_IA%20on%20water%20reuse_Final%20Part%20I.pdf
8
countries with water reuse being an integral and effective component of long-term water
resources management, the potential of water reuse is far from being exploited.
Figure 4a: Effluent reclamation in Europe (Mekorot, 2017)
Country Cyprus Malta Italy Greece Spain Overall in EU
Effluent reclamation rate 89% 60% 5% 5% 12% 2,4%
Figure 4b: Effluent reclamation in third countries (Mekorot, 2017)
Country China USA Australia Singapore Israel
Effluent reclamation rate 14% 14% 15% 35% 87%
Compared to the current practice as summarised above, the potential for water reuse in the EU
is estimated to be much larger: a volume in the order of 6,000 million m3
/year by 2025 might
be achieved in the presence of a better enabling framework and suitable financial incentives at
the EU level (BIO, 2015). Reusing the total volume of treated wastewater in Europe could
cover nearly 44% of the agricultural irrigation demand and avoid 13% of abstraction from
natural sources (Defra, 2011) and could significantly contribute to alleviating water scarcity
The problem as set out above is resulting in an opportunity lost for EU citizens on the whole
and economic sectors such as agriculture, tourism, industry, energy and transport (see
footnote 2). This may in turn affect economic growth (in the case of reduced production due
to water scarcity) or competitiveness (in case of disadvantaged farmers due to differences in
input costs or due to unsafe products reaching the markets). The effects of water scarcity in
one Member State are also felt in others via the Internal Market and the tightly interconnected
European economies through impacts on trade in goods and services as well as investments.
This concerns in particular trade in agricultural products irrigated with treated waste water.
The important differences in relation to concepts, principles and procedures between the water
reuse laws of different Member States, these differences may in particular impede the free
movement of agricultural products irrigated with treated waste water, create unequal
conditions of competition, and may thereby directly affect the functioning of the Internal
Market. As the intra-EU share of trade in agricultural products by far exceeds the extra-EU
share, this aspect is significant. For fruits and vegetables, this amounted to EUR 33.4 billion
in intra-EU trade as compared to EUR 4.7 billion in extra-EU trade in 2015.16
Furthermore, technology providers in this sector are EU-scale companies17
. However,
differences in standards among Member States can prevent companies benefitting from
economies of scale and standardisation, which would support innovation and the development
of systemic solutions at lower costs. This was confirmed by the specific consultation of
experts in research and innovation (see Annex 8).
1.2.1. Scope of the present impact assessment
The scope of this impact assessment includes water reuse for agricultural irrigation and
aquifer recharge; the source of water for such purposes is limited to treated waste water
covered by the UWWTD.
This reflects the priority areas as set out in previous Commission documents. In the 2015
Communication ‘Closing the loop – An EU action plan for the Circular Economy’
(COM/2015/614) and subsequently in the Inception Impact Assessment of the EU water reuse
initiative at hand, agricultural irrigation and aquifer recharge were identified as main potential
sources of demand for reclaimed water having the greatest potential in terms of its higher
uptake, scarcity alleviation and EU relevance: agricultural irrigation as the biggest user of
16
http://ec.europa.eu/eurostat/statistics-explained/index.php/The_fruit_and_vegetable_sector_in_the_EU_-
_a_statistical_overview
17
https://www.ventureradar.com/search/ranked/Water%20AND%20Reuse/
9
treated waste water and the links with the Internal Market and aquifer recharge due to the
potential cross-border nature of many aquifers.
Beyond the uses analysed in this impact assessment, treated waste water may be used for a
wide variety of other purposes. For reference, these are also briefly summarised below and set
out in more detail in Annex 6.
Agricultural irrigation is by far the largest application of reclaimed water worldwide and in
Europe (Annex 6) and a significant use of water in Europe, overall accounting for around a
quarter of total freshwater abstracted. Abstraction for irrigation accounts for about 60% of
total freshwater abstraction in Southern and South Eastern Europe, and up to 80% in certain
River basin districts (RBDs). Water reuse in agriculture therefore has the highest potential for
an increased uptake of water reuse, and thus contributing to the alleviation of water scarcity in
Europe.
Artificial aquifer recharge aims at increasing the groundwater potential and it can help prevent
saline intrusion in depleted coastal aquifers. The lack of scientific and technical knowledge
(including lack of clarity of ownership and liability), coupled with low perception of this kind
of technique being an important water management instrument, contribute to the low uptake
at present (Escalante, 2014). The risks to health and the environment from pollutants such as
bacteria, viruses and emerging pollutants and priority substances such as those already
detected occasionally in discharges from water treatment plants (and in high concentrations)
are also perceived as an obstacle (Estévez et al., 2016; Estévez et al., 2012). In the first public
consultation, aquifer recharge was one of the uses for water reuse most frequently mentioned
that stakeholder found appropriate, in particular in order to prevent saline intrusion (see
Annex 2). Therefore water reuse for aquifer recharge has been analysed for potential
regulation at the EU level but the case for an EU intervention is not deemed proportionate, as
set out further in subsequent sections.
Whilst agricultural irrigation and aquifer recharge are in scope, a number of other areas are
outside the scope and so not considered further because of various reasons (e.g. they are
already covered by other legislation; the risks are being managed effectively and/or are not
linked to the internal market).
In terms of investment opportunities, water reuse projects currently suffer from a limited
economic attractiveness which is exacerbated by the unclear regulatory framework applying
to them and today, the level of investment into water reuse in the EU is limited and far below
its potential. This issue is being addressed in the Circular Economy Action Plan which
commits to maintain and increase the visibility of existing financial support to investments in
water reuse, e.g. with European Structural and Investment Funds. Therefore this topic will not
be pursued further in this IA.
A number of actions on improving implementation and enforcement of existing water
legislation will be taken independently of this initiative as they are not specific to water reuse.
Additionally, in the Circular Economy Action Plan, the Commission committed to develop a
series of non-regulatory actions to promote safe and cost-effective water reuse in 2016-2017
(see above).
Water reuse for municipal/landscape uses (e.g. irrigation of public parks, recreational and
sporting facilities, street cleaning, fire protection systems etc.) is outside the scope of this
Impact Assessment. Local conditions determine both the opportunities and risks, and no
significant health or environmental risk has been identified with current practices in the
Member States. The risks to the environment are generally very local and they are regulated
to a large extent by the existing EU legislative framework (e.g. WFD and UWWTD). Given
the visibility of this use to the public, often associated with access restrictions in urban areas
where water reuse is practised, the public perception of these risks needs to be adequately
10
managed (see the supporting studies of BIO and AMEC), taking into account the local
specificities of these uses. Therefore, authorities in the Member States need some flexibility
within the existing framework and no need for further legislative action has been identified.
Direct reuse of waste water from industrial sources for agricultural irrigation is outside the
scope of this impact assessment. The quality of industrial waste water is in general very
different from domestic waste water in terms of nature and magnitude of pollutants, in
particular chemicals. Because of the diversity of pollutants and of the potential harmful
effects to both health and the environment of some of these pollutants, these effluents pose
specific challenges in terms of safety and treatment technology. As regards the discharge of
industrial waste water into the environment, the Industrial Emission Directive only imposes
detailed quality requirements (emission limits) on large-size firms in a number of selected
sectors. Reuse and recycling of waste water from industrial sources are generally limited to
those for industrial purposes in the same or another industry; the conditions for such reuse or
recycling are very sector-specific. Best Available Techniques Reference Documents (BREFs)
developed under the Industrial Emissions Directive (2010/75/EU) address water use and reuse
for most sectors where this is relevant (29 out of 31; e.g. Food, drink and milk industries,
Industrial cooling systems, Rearing of poultry and pigs). The drafting of the EU Action Plan
on Circular Economy already considered that further promotion of water reuse in the
manufacturing industry will be more effectively addressed in the context of the development
and review of these BREFs for the relevant sectors.
Reuse of treated urban waste water for industrial purposes is not addressed by the present
initiative as its potential for a higher uptake is relatively modest (Annex 6) and rather a local
issue that requires a sufficient degree of flexibility at Member State level; therefore, at this
moment, any EU level action would not be proportionate.
The reuse of rainwater and grey water is also not included in the scope of this impact
assessment. The issue has been addressed in the impact assessment for the Blueprint (see
Annex 1a), which pointed out that environmental impacts related to the need of construction
and maintenance of the necessary infrastructure for rainwater harvesting may lead to negative
energy/treatment/GHG impacts. For water harvesting in agriculture the same negative effects
should be taken as those identified for water storage (dams and reservoirs). Furthermore, a
previous study18
conducted in preparation of the Blueprint Communication concluded that EU
policy on certification to promote rainwater harvesting and reuse in buildings could lead to
significant water savings but would be applicable only for major renovations or new
buildings. Therefore, it was found more appropriate to include such promotion in an
integrated manner in the development of Best Environmental Management Practices
(BEMPs)19
and in the context of the sustainable buildings policy20
.
As a result the source of water to be reused considered in this impact assessment is only the
waste water covered by the UWWTD, that is to say urban waste water defined as "domestic
waste water or the mixture of domestic waste water with industrial waste water, subject to the
relevant pre-treatment and/or run-off water".
18
Bio Intelligence and Cranfield University, 2012: Water Performance of Buildings, Study for the European
Commission, DG Environment.
http://ec.europa.eu/environment/water/quantity/pdf/BIO_WaterPerformanceBuildings.pdf
19
https://ec.europa.eu/jrc/en/research-topic/best-environmental-management-practice
In particular rainwater harvesting and greywater recycling are included as BEMP in the sectoral reference
document for Tourism (2013) and in the best practice report by JRC for Building and Construction (2012) and
Public Administration (2015)
20
http://susproc.jrc.ec.europa.eu/Efficient_Buildings/documents.html
11
1.3. What are the underlying causes of the problem?
The overall problem of "low uptake of water reuse compared to its potential resulting in
a suboptimal contribution to alleviate water scarcity" is the result of four factors
discussed below: (1) limited attractiveness, (2) environmental risks and perceived health risks
due to varying existing quality requirements or the lack thereof, (3) possible trade barriers and
(4) the resulting general view of risks outweighing benefits. However, this initiative is going
to address only factors 2 and 3, while factors 1 and 4 are not directly addressed by this
initiative.
The problem's underlying drivers and consequences as described in the present section are
displayed in a problem tree below. Both this section and the problem tree take as a point of
departure the problem definition in the impact assessment of the 2012 Blueprint (see Annex
1a) which already found that: "The main barrier to expansion of water re-use is the lack of
common standards at EU level, in particular in agriculture. While guidelines for agricultural
water re-use have been defined by the World Health Organisation, and by different countries,
such as the USA and Australia, a uniform solution for Europe is lacking. Establishing
standards for the functional operation of the single market is an appropriate EU level
response, taking into account EU Health, Agriculture and Energy policies. […] The lack of
common health/environmental standards threatens farmers using re-used water to irrigate
crops for export within the single market and prevents industry from making long-term
investment decisions. It also constitutes a barrier for innovation."
The second public consultation identified as the main barriers associated with legislation the
insufficient clarity in the regulatory framework, administrative burden for water operators,
users and public authorities, stringent national quality requirements, and, to a lesser extent,
the absence of national requirements for water reuse. The low price of freshwater compared to
the price of reclaimed water and the high cost of treatment were also identified among the
highest barriers (see Annex 2).
12
13
1.3.1. Factor 1 – Reused water is less attractive than freshwater
The WFD, in its Article 9, provides the legal definition of pricing water services and
stipulates the principle of cost recovery (including environmental and resource costs) as well
as the polluter-pays principle. The available evidence suggests that, at best, tariffs only take
account of the financial costs of water treatment and distribution and that few Member States
apply direct charges to polluters for the purification of their waste water as well as other
activities that impact on water quality, while charging for the resource costs of water
abstraction is rare (EEA, 2013). Furthermore, in agriculture, the rather low levels of cost
recovery (up to 80% but sometimes as low as 20%) point to heavy subsidisation of freshwater
use, even in water-scarce Mediterranean countries (EEA, 2013). Prices are frequently too low
to provide an adequate incentive to the efficient use of both freshwater and reused water.21
There are measures being undertaken to improve the implementation of Article 9 of the Water
Framework Directive so as to achieve better cost recovery22
. Therefore, the underlying drivers
of illegal abstraction and subsidised water prices for freshwater are outside of the scope of the
initiative and are not addressed in this impact assessment.
As demonstrated in the Impact assessment of the Blueprint, in areas where water is scarce,
reclaimed water can be a cost-effective solution compared to other supply options, especially
when all economic and environmental costs are considered. However, even in these cases,
reclaimed water is generally found less attractive than conventional water resources.
1.3.2. Factor 2 – Legal frameworks for water reuse exist only in few Member States
resulting in a perceived health risk and environmental risk
A range of potential risks is associated with reused water which is likely to contain pollutants
(organic, microbiological, chemical, etc.). These risks differ by type of reuse and entail
contamination of the environment (water resources, soil) and people (direct exposure,
ingestion of food products irrigated with reclaimed water, etc.). Health risks are partially
addressed by existing legislation concerning agricultural product safety, i.e. the Regulation on
the Hygiene of Foodstuffs; however, this legislation does not specify the requirements for
treated waste water used for irrigation of agricultural products23
. Environmental risks
associated with water reuse must be considered as well, e.g. chemical contaminants from
inorganic salts, nutrients, heavy metals and detergents can negatively affect the environment.
For heavy metals there are concerns that these substances can build-up in the soil over time.
Salinity of the water is also a risk to the environment and crops (in case of irrigation). There
are also growing concerns over the fate of the wide variety of compounds of emerging
contaminants (CECs), e.g. pharmaceuticals, which are present in sewage, often at trace levels,
and often unmonitored. Evidence remains limited as to how well treatment processes deal
with these pollutants. In general such risks can be addressed by applying suitable barriers, the
most important barrier being treatment of waste water and applying a risk based approach.
As displayed in Figure 5, these risks can be split into 2 categories associated with water reuse
in agricultural irrigation:
- the health risks to consumers of agricultural products irrigated with reclaimed water
and placed on the Internal Market; this category of risk includes those to health of
animals consuming crops irrigated with reclaimed water;
21
http://ec.europa.eu/environment/water/blueprint/pdf/EU_level_instruments_on_water-2nd-IA_support-
study_AMEC.pdf
22
These measures include enforcement actions launched by the Commission, bilateral meetings with MS on
RBMPs, CIS Guidance documents on Art. 9, CIS Peer review process, etc.
23
Guidance for the implementation of this Regulation introduces some standards for irrigation water, which also
covers treated waste water. These voluntary standards do not address all risks, as environmental risks are not
covered.
14
- the health risks to humans exposed to reclaimed water (workers, bystanders and
residents in nearby communities) and risks to the local environment (surface waters
and groundwaters, soil and depending ecosystems).
Figure 5: Health and environmental risks associated with water reuse in irrigation in the EU
Currently only 5 Member States (Cyprus, Greece, Spain, France and Italy) have developed
legislation that sets specific requirements on the reuse of waste water; Portugal has developed
non-regulatory standards on water quality. Some other Member States are interested in
enabling more reuse of water, but are wary of public perceptions seeing this as a "dirty"
technique and so are reluctant to take the initiative on their own to develop a legislative
framework. Informally, a number of Member States have indicated an interest in having such
a framework, and await to see it developed at European level as announced in the Blueprint as
it would be seen as having more standing. Furthermore, whilst 60% of river basins are
international, so far, rather countries that do not share river basins as well as those suffering
most from water stress have developed their own frameworks.
In the Member States currently with requirements, these vary significantly in their level of
stringency as illustrated in Figure 6; none of these national requirements are the same. While
there are local specificities, Figure 6 shows that different national approaches and
methodologies have been used to arrive at defining requirements to protect consumers' health.
In addition to these quality standards to address the potential health risks for consumers, some
Member States also apply to some extent a risk assessment approach (see Annex 6 –
Overview of MS requirements), however, environmental risks are not addressed adequately
and consistently in these existing frameworks. It is to be noted that a risk assessment approach
has been introduced on a voluntary basis in the amendment of the Annex of the Drinking
Water Directive in 2015 and some Member States (Hungary, the Netherlands and the United
Kingdom) have implemented it. The Commission's proposal for a Recast of the Drinking
Water Directive introduces the risk assessment approach on a compulsory basis.
This means that the same type of food product (e.g. a tomato), depending on where in Europe
it is grown, faces very diverging requirements as to the kind of reclaimed water allowed for
irrigation. Nevertheless, these tomatoes are traded across borders in different Member States
and are consumed throughout Europe. There is a lack of clarity on how food products are
irrigated, resulting in a health risk perception in large parts of the population / consumers / the
general public as confirmed by the public consultation outcome (see Annex 2).
15
Figure 6: Differences in maximum limit values for selected parameters considered in national quality
requirements for water reuse
Parameters Cyprus France Greece Italy Portugal Spain
E coli (cfu/100ml) 5-10
3
250-10
5
5-200 10 - 0-10,000
24
Faecal coliforms - - - - 100-10
4
-
TSS 10-30 15 2-35 10 60 5-35
Turbidity (NTU) - - 2-no limit - - 1-15
Biochemical oxygen
demand (BOD 5)
(mg/l)
10-70 - 10-25 20 - -
Chemical oxygen
demand (COD) (mg-l)
70 60 - 100 - -
Total nitrogen (mg/l) 15 - 30 15 - 10
Source: Reproduced from JRC, 2014. ‘-‘indicates that there is no value set for the parameter in the national
legislation
Moreover, there is a risk for the health of workers25
: those working on farms and workers in
the reclaimed water industry. While the workers may be exposed to potential contaminants
over longer periods than the public, the risks are not necessarily higher due to better
awareness and the implementation of risk control measures (e.g. protective equipment). The
literature does not report cases of occupational diseases caused by exposure to treated waste
water (BIO, 2015). However, general statistics show that there is an increasing trend
occurrence of one or more work-related health problems in the sector of agriculture, hunting
and forestry, namely 8% of the workforce in 2007 compared to 5% of the workforce in 1999.
In conclusion, even the few existing national quality requirements only attempt to address the
health risks to consumers, the second category of risks depicted in Figure 5 (health risks to
humans exposed to reclaimed water and risks to the local environment) are not being
addressed in an adequate manner.
Therefore, in the Member States where no quality requirements for water reuse are in place,
there is a lack of clarity in the regulatory framework to manage health and environmental
risks that need to be taken into account when issuing permits for reuse projects. However, in
Member States that have set such requirements, especially in terms of management practice,
stakeholders say that in practice the conditions are difficult to implement (e.g. conditions on
wind force or access control) or too stringent considering the intended use.
This also means that investors find diverging conditions to invest into water reuse production
or technology development across Europe, even as regards its use in growing the same type of
product, e.g. a tomato. According to the United Nations World Water Development Report
2017, the absence of suitable legal and regulatory frameworks is a critical barrier, creating
24
Note that this represents the range of different limits for different uses (e.g. crops, irrigation methods). For
E. coli, as indicated in RD 1620/2007, the limits are 0 for more stringent values, and 10.000 for less stringent.
25
General statistics from Eurostat show that there is an increasing trend occurrence of one or more work-related
health problems in the sector of agriculture, hunting and forestry, namely 8% of the workforce in 2007 compared
to 5% of the workforce in 1999. Moreover, the survey carried out by Eurostat in 2005 found that in the EU27,
8% of workers reported exposure to chemicals, dust, fumes, smoke, or gases (8%). The results of the survey in
2007 show that at least for a quarter of their working time, some persons were exposed to chemical products
(15%) and infectious materials (9%).
16
market uncertainties and discouraging investment into water reuse. This is particularly true as
regards irrigation in the EU for which:
 some national legislation26
requires water quality similar to drinking water whatever
the sensitivity of the crop and associated risks are;
 other sources of water used for irrigation (e.g. rivers, private wells) are not subject to
mandatory quality requirements.
1.3.3. Factor 3 – Possible trade barriers, i.e. trade bans for food products irrigated
with reclaimed water
As identified in the second public consultation, stakeholders in the agriculture sector and the
food industry are concerned about potential trade barriers for agricultural goods irrigated with
reclaimed water and put on the Internal Market. The Internal Market issue is already
significant. In 2015, the EU internal trade flows for fruits and vegetables was seven times
bigger in terms of value than external trade: EUR 33.4 billion vs EUR 4.7 billion27
. Farmers
thus depend crucially on intra-EU trade and will not use reused waste water as a source for
irrigation unless they know they will be able to sell their products on the Internal Market. The
current regulatory framework does not provide a way of demonstrating credibly that risks are
properly managed across the Internal Market.
The most extreme form of such a trade barrier would be in the form of a trade ban, when a
Member State bans the imports from another Member State of a certain agricultural product
irrigated with reclaimed water. This situation arises from diverging regulatory frameworks in
place in the different Member States, and also from a certain distrust about safety of
reclaimed water (see also the section below). The one case that such trade barriers have been
formally imposed within Europe for European producers, was the case of accusations in 2011
regarding possibly contaminated cucumbers from Spain as the cause of a deadly E. coli
outbreak (see Box 1 for details). This risk of a trade barrier is considered as an actual and
critical risk by a vast majority of stakeholders as shown in particular by the results of the
second public consultation, see Annex 2.
Furthermore, some studies28
suggest that farmers might face market restrictions due to
requirements from certification bodies, e.g. Quality Safety Association (QSGmbH) for fruits,
vegetables, and potatoes that are irrigated with treated waste water. In addition, some Member
States have on several occasions raised the issue of potential market restrictions of
agricultural products irrigated with treated waste water, applied by retailers and/or
supermarkets29
. In other words, perceptions about water reuse are claimed to lead some
retailers to disadvantage agricultural goods irrigated with reused water.
The Internal Market issue is triggered partially by the problem of low public acceptance.
Box 1: E.coli outbreak and accusations regarding cucumbers from Spain in 2011
The case of the E.coli outbreaks which affected 16 countries in Europe and North America in 2011, with more
than 4000 reported cases and 53 deaths in Germany, is an example of this situation. The outbreak was blamed on
cucumbers irrigated with treated wastewater30
imported from Spain and several Member States, including
Austria, Belgium, the Czech Republic, Denmark, Germany and the UK blocked or restricted the import of
Spanish products over concerns that these would have been contaminated during irrigation. It was subsequently
26
Italy
27
http://ec.europa.eu/eurostat/statistics-explained/index.php/The_fruit_and_vegetable_sector_in_the_EU_-
_a_statistical_overview
28
https://www.umweltbundesamt.de/publikationen/rahmenbedingungen-fuer-die-umweltgerechte-nutzung
29
http://www.globalgap.org/uk_en/who-we-are/governance/index.html
30
See the notification by the Commission through the Rapid Alert System for Food and Feed (RASFF)
http://europa.eu/rapid/press-release_IP-11-653_en.htm?locale=en
17
proven that the source of the E.coli contamination was not the cucumbers but rather sprouted seeds from a
German farm, and the fenugreek seeds involved were sourced from Egypt31
. It was estimated that this event cost
Spain EUR 200 million per week as orders were cancelled and contributed to cut agricultural income from the
Murcia region by 11.3 percent for the 2010-2011 growing season32
. This has been deterring investment in
processing food products irrigated with reclaimed water.
1.3.4. Factor 4 – Reuse perceived as more risky than beneficial
There are several risks associated with water reuse as shown in chapter 1.3.2. No evidence so
far could be found of significant pollution/contamination at large scale due to present
practices of wastewater reuse in the EU. However, as identified in the Impact Assessment of
the Blueprint and confirmed in further consultations on water reuse, there is low public
acceptance of reuse solutions and even strong opposition to allowing reclaimed water as a
source for drinking water. This is due to misconceptions on what ‘reclaimed water’ means
and a lack of knowledge about actual health and environmental risks.
The absence of a clear regulatory framework is also seen as a cause for a lack of confidence in
the health and environmental safety of water reuse practices. There are existing regulatory
standards concerning agricultural product safety, however, they do not explicitly regulate
requirements for treated waste water for agricultural irrigation, hence there is still a sense of
unease amongst consumers about food that has been irrigated with reused water.
Findings from the literature on the acceptability of water reuse amongst producers and
consumers are mixed. There are many factors which play a role in its acceptance, the most
important of which are the extent of “disgust” over the concept, the use for which recycled
water is intended, perceptions of risk from recycled water, the sources of recycled water,
choice between recycled and fresh water, trust of authorities and knowledge, attitudes towards
the environment, the cost of recycled water and sociodemographic factors (Po et al., 2004).
Furthermore, the degree of public acceptance is affected by many factors including the
political context of a country (Marks, 2005), local history, the recycling terminology used
with the public, the degree of public involvement in strategy development, the threat of
alternatives, such as dams, river development or ocean outfall, the degree to which potable
recycling is pushed as the primary option, the “not in my backyard” phenomenon, the degree
and nature of education provided (Queensland Government, 1999).
The perceptions of risks from the water reuse related to health, foremost among peoples'
worries are the safety of their children (Sydney Water, 1999). Water recycling can be more
easily accepted in areas with water shortages (Dishman et al., 1989). The acceptability of
recycled water decreases as the use moves from public areas (e.g. irrigation of parks) to house
(gardening) or to more personal uses, due to risk perception (ACIL Tasman, 2005;
Hurlimann, 2005). Socio-demographic factors appear to provide important information as to
which demographic groups are most likely to accept recycled water usage. McKay and
Hurlimann (2003) predicted that the greatest opposition to water reuse schemes would be
from people aged 50 years and over. Such findings on age are also reported by Tsagarakis and
Georgantzis (2003) who also found that educated people were more willing to use recycled
water.
At the same time both the general public and regulators appear to be insufficiently aware of
the benefits of water reuse. In addition to the most obvious benefits (mitigation of economic
risks related to water scarcity, conservation of the aquatic environment, cost savings for
utilities), there are a host of indirect benefits that stakeholders seem rather unaware of (e.g.
31
See report by EFSA: http://www.efsa.europa.eu/en/supporting/pub/en-176
32
See articles: http://www.reuters.com/article/us-germany-ecoli-idUSTRE74S12V20110531 and
http://www.foodsafetynews.com/2012/07/spanish-produce-paid-a-price-for-europes-o104-outbreak/
18
energy and carbon savings, reduced costs and environmental impacts associated with
synthetic fertilisers, local economic development).
The second public consultation provided evidence for the lack of consumers' trust in water
reuse as it identified this phenomenon as one of the most significant barriers (85% of the
respondents perceived this barrier as at least medium and 63% as high). At the same time a
large majority of respondents considered that treated wastewater is at least as safe as river
water as a source of water for agricultural irrigation or for aquifer recharge (30% even
considered it safer; see Annex 2). Furthermore, results of the second open public consultation
demonstrate a significantly larger share of respondents from Southern EU Member States
consider reused water as at least as safe, independently from the source of water it is
compared with.
 In comparison to groundwater: 65% of respondents from Southern EU Member States
also consider reused water as at least as safe, while 70% of respondents from Northern
and Eastern EU Member States consider reused water as less safe than groundwater,
 In comparison to rivers: 80% of respondents from Southern EU Member States perceive
reused water as at least as safe (with half of them considering it even safer), compared to
55% of respondents from Northern EU and only a third of respondents from Eastern EU
Member States.
There is larger consensus between respondents from Northern and Eastern EU Member States
about the opinion that reused water was less safe than groundwater, in comparison to water
sourced from rivers, which remains more controversial within each of these EU regions (see
Annex 2).
Figure 7: Safety perception – comparison between Southern EU, Northern EU and Eastern EU Member States
in the reuse of water for agricultural irrigation
As a result, this information failure leads to reluctance to consider reuse as an alternative
water supply option when relevant and cost-efficient. The Impact Assessment of the Blueprint
already identified this issue as well as the opportunity to develop awareness raising
campaigns and advisory services. A number of actions committed by the Commission in the
Circular Economy Action Plan (e.g. promotion of safe and cost-effective water reuse,
including support to research in further characterisation of emerging risks and to innovation
with demonstration projects) and a communication campaign are expected to improve the
provision of reliable information and rectify misperceptions of benefits and actual risks by
stakeholders and citizens. Additionally, studies show that public trust in water reuse is
strongly affected by personal experiences and trust in water reuse organisations and
regulatory authorities33
; it is in general specific to the local situation of water resources and
33
FP7 project DEMOWARE report:
http://demoware.eu/en/results/deliverables/deliverable-d5-2-trust-in-reuse.pdf
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
North
East
South
North
East
South
Using
water
from
rivers
Using
water
from
groundwater
safer than as safe as less safe than I don't know
19
management and better addressed at Member State level. Complementary to the above
actions, there are ongoing national or local information campaigns that inform about the water
reuse practice, e.g. in Spain, when a park is irrigated with treated waste water the relevant
information is available to the public at the park entrance.
This information failure will not be addressed in this initiative, apart from providing
information to the public on water reuse. However the absence of a clear regulatory
framework is addressed, which is an underlying driver and a cause of this lack of confidence
in the health and environmental safety of water reuse practices.
1.4. How will the problem evolve, all things being equal?
The current situation and future projections for water availability are set out in section 1.1
above; while water stress is present in many parts of Europe already today, the past trends in
water scarcity are expected to increase in frequency and intensity of droughts and their
environmental and economic damages are expected to continue. This later trend is mainly
due to climate change. At the same time, the current state of a mix of absent and un-
coordinated national legislation and approaches would continue, resulting in the continuation
of related barriers and little incentive to apply water reuse.
An improved implementation of the existing EU water policy framework, especially as
regards water pricing and control of abstractions, could positively influence the uptake of
water reuse, however, very likely much below its potential for development and benefits to
the economy and the environment (BIO 2015). According to the Blueprint, which was based
on the 2009 River Basin Management Plans, only 49% of these Plans34
intend to change the
water pricing system to foster a more efficient use of water. The barriers to water reuse related
to inadequate water pricing are therefore unlikely to change significantly.
It is likely that additional Member States would adopt their own water reuse standards in the
near future (e.g. Malta already has plans to develop its own standards). In those Member
States, such new standards are expected to provide more clarity to the stakeholders on the
required measures to manage health and environmental risks associated with water reuse.
However, in the absence of further EU action specific to water reuse, uncertainty on how to
apply the existing EU water legislation to manage risks of water reuse projects would persist
in the other Member States, while in the countries with the highest stringency of water reuse
standards (France and Italy), the situation is likely to remain unchanged in future years, i.e.
very few new water reuse projects.
Water reuse technologies are evolving relatively quickly, therefore a number of the technical
barriers identified are likely to be solved within the next ten years, either as a result of
research and development work conducted by the water industry or of publicly funded
research programmes. The evaluation and management of risks associated with emerging
pollutants is, however, a very complex issue and may require more significant efforts.
Finally, it is unlikely that national regulators can co-ordinate a harmonisation of their
regulatory requirements. A risk of potential trade barriers for food products irrigated with
reclaimed water would continue to persist hand in hand with the low public acceptance of
water reuse solutions. Consequently, the problem of the low uptake of water reuse would
intensify, and in particular in areas of Europe where water scarcity increases (see projections
of water scarcity in Section 1.1).
34
An assessment of 2015 RBMPs is ongoing, hence this figure will very likely change, as there are
developments in some Member States.
20
1.5. Who is affected and how?
The currently limited uptake of water reuse affects in particular the environment, economic
sectors, national/regional/local authorities, and European citizens and consumers.
Concerning the environment, increasing trends in water scarcity exacerbated by climate
change together with a low uptake of water reuse affect water resources which are over-
exploited by abstractions, in particular for irrigation, and also water-dependant ecosystems
which are not left with the necessary amount for them to thrive. In particular, coastal areas of
water-scarce regions where treatment plants discharge their effluents to the sea are affected by
the wastage of limited freshwater resources. However, it has to be stressed that discharge of
treated waste water to rivers can be a major component of river flows in dry seasons, up to
80% in extreme cases (Drewes, 201735
). In these cases reuse can also result in reducing the
flow beyond critical limits and have a negative impact on the river and associated ecosystems,
despite the fact that unplanned reuse takes already place de facto. The quality of water
resources is also affected by unnecessary discharge of nutrients into rivers. In addition, the
removal of nutrient in treatment plants, even though it is necessary in sensitive areas to
prevent eutrophication of water resources, is energy intensive, hence resulting in higher GHG
emissions and the same holds true for the production of chemical fertilizers for agriculture.
The lack of a consistent methodology to apply the risk assessment approach results in a
potential deterioration of the environment due to potential contamination of soils with metals,
CECs, etc. These environmental impacts clearly have a local dimension, however, 60% of the
EU's rivers run across borders of Member States (and non-Member States). If waters are low
in an upstream Member State, less water will reach any downstream Member State. Action
taken by a single or few Member States is therefore not sufficient in relation to quantitative
aspects of water management and so these environmental problems can be cross border.
A number of economic sectors are highly dependent on water supply, in terms of availability
and quality, such as agriculture (see also Annex 3a SME test), the food industry, the power
generation industry (e.g. for cooling processes and hydropower), tourism and the recreational
industry (e.g. golf courses), chemical, textile, pulp and paper industries and mining. A lack of
water reuse in the regions affected by water scarcity and related restrictions, e.g. bans to use
freshwater for certain types of uses like agricultural irrigation, both negatively affect their
production and increase costs. The water industry and their technology providers are affected
through foregone business opportunities in the area of treated waste water reuse. These
opportunities appear large as the global market for water reuse is expected (Global Water
Intelligence, 2015) to be fast-growing in the coming years. Between 2011 and 2018 capital
expenditure on advanced water re-use was estimated to have grown at a compound annual
rate of 20% as the global installed capacity of high quality water re-use plants grows from 7
km³/year to 26 km³/year. The limited uptake of water reuse technology negatively impacts the
potential for further innovation, demonstration and market development for innovative
technological and non-technological (organisational, managerial, governance) solutions for
water reuse whose market uptake can be negatively affected by the present legislative
framework.
From the perspective of National/regional/local public authorities, as alternative supply
options are generally more costly (considering both capital and operating costs, see Figure 8),
the limited development of water reuse tends to render more costly the reduction of water
scarcity and implementation of the River Basin Management Plans. It also represents missed
35
http://ec.europa.eu/environment/water/pdf/Report-UnplannedReuse_TUM_FINAL_Oct-2017.pdf
21
cost saving opportunities, e.g. by reducing drinking water supply production needs and
associated costs.
Figure 8: Cost comparison of different water scarcity solutions
For European citizens and society at large, the inefficient management of water resources
results in reduced water availability which, in areas of water scarcity and drought, has a direct
negative impact upon the EU economy and citizens. The free movement of safe and
wholesome food is an essential aspect of the Internal Market and contributes significantly to
the health and well-being of citizens, and to their social and economic interests. When there
are important differences in relation to concepts, principles and procedures between the water
reuse laws of the Member States, these differences may impede the free movement of
agricultural products irrigated with reused treated wastewater (see above Box 1 on the E. Coli
outbreak), create unequal conditions of competition, and may thereby directly affect the
functioning of the Internal Market. Furthermore, a 1% increase in the area affected by drought
can slow a country’s gross domestic product (GDP) growth by 2.7% per year (Brown et al.,
2013). For consumers, the lack of European minimum requirements for water reuse leads to
mistrust and misunderstanding about how agricultural products are irrigated and whether they
are safe if irrigated with reclaimed water.
2. WHY SHOULD THE EU ACT?
The problem this initiative sets out to address is relevant at EU-level, as concluded in the
analysis in section 1 above. With this initiative, EU action would aim at enabling a cost-
effective waste water reuse for agriculture, while ensuring a high level of protection of health
and the environment and contributing to the well-functioning of the Internal Market. Thereby,
the main problem drivers (diverging requirements in Member States, resulting in potential
trade barriers for agricultural products irrigated with reclaimed water, as set out in the
problem definition, section 1.3) would be addressed.
Acting now by putting in place an EU-level enabling framework would allow contributing to
alleviating water stress where it is already an important reality today in the EU and preparing
operators and farmers to be ready to act also in those parts of the EU which are expected to
experience increasing water stress in the coming years and decades, thereby helping prevent
the situation from deteriorating.
2.1. Competence
The EU competence to take action on water management derives from Article 191 of the
Treaty on the Functioning of the European Union related to the protection of the environment:
22
“Union policy on the environment shall contribute to pursuit of the following objectives:
 preserving, protecting and improving the quality of the environment,
 protecting human health,
 prudent and rational utilisation of natural resources,
 promoting measures at international level to deal with regional or worldwide
environmental problems, and in particular combating climate change.”.
Since in particular environmental risks of water reuse are not addressed by the Member
States, and there is a clear EU dimension to these risks, moreover the issues at stake are
directly related to the inefficient use of a natural resource and adapting to climate change, the
legal basis for a possible new EU legal instrument would therefore be Art. 191.
In addition, the EU competence to take action on safety of agricultural products irrigated with
reclaimed water is linked to Article 169 of the Treaty on the Functioning of the European
Union related to consumer protection:
"1. In order to promote the interests of consumers and to ensure a high level of consumer
protection, the Union shall contribute to protecting the health, safety and economic
interests of consumers, as well as to promoting their right to information, education and to
organise themselves in order to safeguard their interests.
2. The Union shall contribute to the attainment of the objectives referred to in paragraph 1
through:
(a) measures adopted pursuant to Article 114 in the context of the completion of the
internal market; […]"
This initiative is also expected to contribute to the free movement of goods in the Internal
Market.
2.2. Subsidiarity
Any new EU initiative on water reuse needs to comply with the principles of proportionality,
taking due account of subsidiarity considerations.
Concerning environmental protection, EU-level action on water management is also justified
because 60% of EU river basins are international, shared by between 2 and 19 countries
(Danube); action taken by a single or few Member States is therefore not sufficient, for
instance in relation to quantitative aspects of water management and cross border water
pollution. Moreover, if Member States act alone, the technical barriers to water reuse and
associated costs are likely to be unnecessarily high.
EU intervention on water reuse in particular for agricultural irrigation is justified to prevent
that different requirements in individual jurisdictions negatively affect the level playing field
(e.g. between farmers and growers) and cause obstacles to the Internal Market, especially for
primary agricultural products. Additionally, different requirements may also be used as an
argument to restrict the import of food products from Member States suspected of having
lower requirements, as exemplified in the E. Coli outbreak mentioned above (see Box 1). The
current situation does not guarantee a level playing field between food producers of different
countries; the current EU regulatory framework does not yet address the specific modalities of
agricultural products irrigated with treated waste water. Addressing such barriers is an
appropriate EU level response, taking into account EU food safety, health, agriculture and
energy policies.
EU action is further justified because different and changing requirements in individual
jurisdictions are a barrier to the creation of a level playing field for investments in innovation
and for water reuse. It is unlikely that national regulators can coordinate a harmonisation of
23
their regulatory requirements as the number of Member States involved is too large and
increasing.
The present document seeks to address the overall problem of a too limited application of
water reuse resulting in a suboptimal contribution to alleviating water scarcity and analyses
the modalities of creating an enabling framework for increasing the uptake of water reuse for
agricultural irrigation. Therefore as already defined by the Blueprint in 2012 in order to
ensure the safety of water reuse practises minimum requirements are developed, which would
need to be met if water reuse was practised in a Member State. Given the environmental legal
basis of a potential future instrument on water reuse, the instrument would allow those
Member States with more stringent national standards than the EU minimum level to keep
them in place or those wishing to introduce higher national standards to do so. In this context,
at the practical level, it should be noted that the proposed EU minimum criteria have been
developed together with Member States, stakeholders and the scientific community over the
past years and are broadly supported.
It is worth noting that in addition to the targeted discussions between the Commission,
Member States and stakeholders over the past years, also the public consultation activities
showed strong support for EU measures. In the first public consultation this was considered
by almost all of those who expressed an opinion as a legitimate component of EU action.
More than 90% of respondents from Member States with quality requirements for water reuse
indicated that legally binding EU level minimum requirements would be effective or very
effective for ensuring environmental and health safety of water reuse. The second public
consultation confirmed a very strong support to defining minimum requirements for water
reuse in agricultural irrigation and aquifer recharge, going much beyond Member States and
stakeholders in regions where this is currently a developed practice (see Annex 2).
A proportionality analysis of potential EU action on aquifer recharge demonstrates that there
is a clear local relevance of this practice, with a very limited cross-border dimension across
the EU territory. In addition, the Internal Market dimension which has been identified as a
crucial aspect for agricultural irrigation is lacking in the case of aquifer recharge. Finally, the
conclusions of the JRC technical report suggest that no minimum requirements at EU level
could be developed (see Annex 7). On this basis, this analysis leads to the conclusion that an
EU intervention would not be proportionate. The development of an EU Guidance is
proposed, however, legally binding intervention in this area should remain the competence of
the Member States. A more detailed analysis is included in Annex 11.
3. OBJECTIVES – WHAT SHOULD BE ACHIEVED?
3.1. General objective
The general objective is to contribute to alleviating water scarcity across the EU, in the
context of adaptation to climate change, by increasing the uptake of water reuse for
agricultural irrigation wherever this is relevant and cost-effective while ensuring the
maintenance of a high level of public health and environmental protection.36
This general objective corresponds to the overall problem which motivates this initiative (see
section 1.2). Clearly, water reuse will not by itself solve water scarcity, but the purpose of this
initiative is to make sure that it can be more widely used and is safe.
36
This general objective was identified as a priority in the Blueprint in 2012 and the Circular Economy Action
Plan in 2015.
24
This general objective is fully in accordance with the 7th
Environmental Action Programme37
and, at the global level, the United Nations’ 2030 Agenda for sustainable development and the
achievement of the sustainable development goal n°6 "Ensure access to water and sanitation
for all", in particular as regards the two following targets:
 By 2030, improve water quality by reducing pollution, eliminating dumping and
minimizing release of hazardous chemicals and materials, halving the proportion of
untreated wastewater and substantially increasing recycling and safe reuse globally;
 By 2030, substantially increase water-use efficiency across all sectors and ensure
sustainable withdrawals and supply of freshwater to address water scarcity and
substantially reduce the number of people suffering from water scarcity.
3.2. Specific objectives
The specific objectives aim at managing water resources more efficiently through creating an
enabling framework for and establishing a common approach to water reuse in agricultural
irrigation across the EU. They relate to the concrete factors 2 and 3 that together drive the
overall problem (see section 1.2). The goal is to promote water reuse as one of a range of
measures to alleviate abstraction pressure on vulnerable water resources in the context of
adaptation to climate change and integrated water management by setting a common
methodology so as:
 To ensure that water reuse practices in the EU are safe both to health and the
environment;
 To promote water reuse as a way of providing a secure source of water for irrigation
where it is economically advantageous to do so;
 To provide clarity, coherence and predictability to market operators who wish to
invest in treated wastewater reuse in the EU under comparable regulatory conditions;
 To stimulate business and innovation in water reuse by EU companies for internal and
external markets;
 To provide clarity and confidence to consumers regarding safety of agricultural
products irrigated with reclaimed water within the EU;
 To prevent trade barriers for agricultural primary products irrigated with reclaimed
water within the EU and thereby facilitating the free flow of agricultural goods.
There are strong inter-linkages between the environmental, trade and public health elements
of the objectives. In particular the Internal Market component is a key element of the initiative
and a key to its success. Farmers depend crucially on intra-EU trade and will not use reused
37
General Union Environment Action Programme to 2020 (Decision No 1386/2013/EU), and more especially its
following objectives:
 "To protect, conserve and enhance the Union’s natural capital", with actions ensuring that by 2020:
(b) the impact of pressures on transitional, coastal and fresh waters (including surface and ground waters) is
significantly reduced to achieve, maintain or enhance good status, as defined by the Water Framework
Directive;
(f) the nutrient cycle (nitrogen and phosphorus) is managed in a more sustainable and resource-efficient way;
 "To turn the Union into a resource-efficient, green and competitive low-carbon economy" with actions
ensuring that by 2020:
(b) the overall environmental impact of all major sectors of the Union economy is significantly reduced,
resource efficiency has increased, and benchmarking and measurement methodologies are in place. Market
and policy incentives that foster business investments in resource efficiency are in place, while green growth is
stimulated through measures to foster innovation;
(c) structural changes in production, technology and innovation, as well as consumption patterns and lifestyles
have reduced the overall environmental impact of production and consumption, in particular in the food,
housing and mobility sectors;
25
waste water as a source for irrigation unless they are confident that they will be able to sell
their products.
3.3. Operational objectives
The operational objectives are to define common minimum quality requirements for reused
water for agricultural irrigation together with a risk assessment framework, complementing
existing agricultural product safety standards, which ensure maintenance of a high level of
protection and address the risks of water reuse to:
 consumers of agricultural products irrigated with reclaimed water,
 workers and other public exposed to reclaimed water,
 the environment, in particular water resources and dependent ecosystems and soils.
These objectives are strongly supported by the public. Respondents to the second open public
consultation considered that specific objectives to be addressed by EU minimum quality
requirements for water reuse in agricultural irrigation should be safety of agricultural products
placed on the EU market (87% of respondents), protection of water resources and dependent
ecosystems (80%), protection of human health of public directly exposed to reclaimed water
(75%), protection of wider environment (75%). Other objectives, such as protection of
agricultural productivity are by far less supported (see Annex 2).
Such a policy would complement and be coherent (not lowering the applicable levels of
environmental protection) with the existing EU legislative framework on:
 water, notably the WFD, the Groundwater Directive, the Nitrates Directive, the
Environmental Quality Standards Directive (EQS) and the UWWTD,
 food safety, notably the Regulation on the Hygiene of Foodstuffs.
4. POLICY OPTIONS
4.1. Baseline – “No new EU action”
Under the baseline, the EU would not develop any new regulatory or non-regulatory action
specific to water reuse. Consequently, the current state of a mix of absent and un-coordinated
national legislation and approaches would persist. The barriers to and lack of proper
incentives for water reuse, as described in the problem definition, would largely remain in
place, as well as a potential risk of trade barriers to agricultural products irrigated with treated
waste water.
This scenario includes, however, a number of actions to improve the implementation and
enforcement of existing legislation on water that will be taken independently of the initiative
assessed in this Impact Assessment since they are not specific to water reuse (especially as
regards water pricing and control of abstractions)38
. Furthermore, a series of non-regulatory
actions to promote safe and cost-effective water reuse in 2016-2017 are committed by the
Commission in the Circular Economy Action Plan39
. These actions aim at improving
implementation and enforcement of existing legislation with a specific focus on water reuse.
They include Guidance on the integration of water reuse in water planning and management40
(adopted in June 2016), improved consideration for water reuse in the industry in relevant
38
In this context, it should be noted that in a number of Member States, important progress in particular on water
pricing was made through the related ex-ante conditionality, which made the availability of EU funding (regional
and agricultural) contingent upon meeting certain legal requirements of the WFD.
39
COM(2015) 614 final, Annex I
40
http://ec.europa.eu/environment/water/pdf/Guidelines_on_water_reuse.pdf
26
Best Available Techniques Reference documents (BREFs41
), and increased visibility for
support to innovation (through European Framework Programmes and R&I networks) and
investments (e.g. European Structural and Investment Funds). The baseline will serve as
benchmark for the other policy options defined in this section.
4.2. Design of policy options
This Impact Assessment assesses policy options for agricultural irrigation (Ir), as set out in
section 2 above. All policy options directly translate the set of specific objectives of this
initiative, as set out in section 2.2 above, into a concrete operational instrument for their
attainment. They are all designed to establish comparable regulatory conditions for water
reuse projects across the EU and to ensure the maintenance of a high level of public health
and environmental protection (see section 3 above), as well as contributing to the proper
functioning of the Internal Market by setting minimum requirements. The policy options
considered do not set any mandatory waste water reuse targets; the aim is, therefore, to
develop an instrument that would enable uptake of treated waste water reuse across the
Member States if and when they decide to adopt such a practice.
All options define a common methodology so as to address the two categories of risks
described in the problem definition and Figure 5, in the following way:
1) The health risks to consumers of agricultural products irrigated with reclaimed water:
These are translated in the options into minimum quality requirements in form of
standards and
2) The risks to the local environment (surface waters and groundwater, soil and depending
ecosystems) and to humans (workers, bystanders and residents in nearby communities)
exposed to reclaimed water: these are translated in the options into minimum quality
requirement in the form of a Risk Management Framework.
These two categories of risks are different in nature; however, the policy options propose to
address them together in setting minimum quality requirements for water reuse for
agricultural irrigation. The variation in the policy options considers the level of stringency of
the minimum quality requirements for the safety of agricultural products ('one-size-fits-all' or
'fit-for-purpose') and legislative nature of the proposal (mandatory legal instrument versus
voluntary guidance (see for details chapter 4.2.2). All policy options considered include the
Risk Management Framework as the only means to address the risks to the local environment
and to humans exposed to reclaimed water (see for details chapter 4.2.3).
The options for analysis assume either a new EU legal instrument or an EU-level Guidance.
The consideration of the latter non-regulatory approach has been based on thorough
consultations with Member-States and stakeholders, and taking into account the recently
published Guidance related to the Regulation on the Hygiene of Foodstuffs42
and international
practice. While the mandatory legal instrument (option Ir1 and Ir2) would include only the
Key Risk Management Principles as compulsory and an accompanying Guidance would be
elaborated with Member States to provide details on the practical application, option Ir3
would include a full Risk Management Framework. These different combinations are
summarised below in Figure 9.
41
https://circabc.europa.eu/sd/a/c2f004b6-4c4b-4bbc-8d7d-
37938c6c6390/Water%20reuse%20%26%20recycling%20within%20EU%20Reference%20Documents.pdf
42
2017/C 163/01 of 23 May 2017
27
Figure 9: Policy options analysed
Options Description
Baseline No new EU action
Policy options
for
agricultural
irrigation
Ir1 Legal instrument ensuring safety of agricultural products with a "one-size-fits-all"
approach (the most stringent minimum quality requirements set regardless of the food
crop category and irrigation technique) and protection of local public health and of
the environment (the Key Risk Management Framework Principles)
- an accompanying Guidance on the implementation of the Key Risk Management
Principles to be elaborated together with MS
Ir2 Legal instrument ensuring safety of agricultural products with a "fit-for-purpose"
approach (minimum quality requirements set depending on the food crop category
and irrigation technique) and protection of local public health and of the
environment (the Key Risk Management Framework Principles)
- an accompanying Guidance on the implementation of the Key Risk Management
Principles to be elaborated together with MS
Ir3 Guidance document on safety of agricultural products with a "fit-for-purpose"
approach (minimum quality requirements set depending on the food crop category
and irrigation technique) and protection of local public health and of the
environment (the Risk Management Framework)
4.2.1. Minimum quality requirements for water reuse to ensure health safety of
agricultural products irrigated with treated waste waterm which are placed on
the Internal Market
The current EU regulatory framework does not yet in particular address agricultural products
irrigated with treated waste water, apart from the limited voluntary requirements set in the
Guidance on the Hygiene of Foodstuffs. Potential trade barriers of agricultural products
irrigated with reused water are associated with claims and perceptions of health risks to their
consumers. The prevention of undue use of trade bans within the EU calls for common
requirements set at EU level on the quality of reclaimed water, designed to ensure the safety
of the relevant consumer products throughout Europe. This requires a legal instrument setting:
 Minimum quality parameters for water to be reused;
 Monitoring frequencies for these parameters;
 Limit values for these parameters to be complied with at the outlet of the (advanced)
treatment plant.
The definition of quality parameters (and their associated limit values and monitoring
frequencies) can follow two approaches resulting in a different stringency level. This can be
captured in two alternative approaches which can be included in the policy options, the "one-
size-fits-all" and the "fit-for-purpose" approach, further detailed below.
 Justification of the stringency of the quality criteria
The JRC report included in Annex 7, namely Tables 2, 3, 4 and 5, defines technical
parameters on water quality which need to be respected to a certain minimum level in case
treated waste water is reused for the purposes of agricultural irrigation. These minimum
requirements were developed in a comprehensive and inclusive process involving Member
States and stakeholder experts as well as the scientific community. During the development of
the proposal, a tiered approach for consultation was applied by the JRC. In the first tier, the
JRC invited a group of selected experts from academia, the water sector and WHO to provide
input and comments on the drafting work. In a second tier, Member States were formally
informed through the CIS Ad-hoc Task Group on Water Reuse and their comments were
28
taken into account. In the third tier, the specifically requested scientific opinions of the
independent Scientific Committee on Health, Environmental and Emerging Risks (SCHEER)
and the European Food Safety Authority (EFSA) have been taken into consideration.
Wherever the approach diverges from their advice, a justification has been provided. Experts
have been consulted to provide comments and input through critical discussion on the JRC
document along the process.
The internationally widely accepted approach to develop minimum quality requirements for
the safe use of reclaimed water for agricultural irrigation and aquifer recharge is the risk
management framework, as recommended by the World Health Organization WHO (2006).
These guidelines inter alia establish the level of “tolerable risk” of incurring a disease through
water consumption, which has been the basis for standards defined in the Drinking Water
Directive (98/83/EC amended by Directive 2015/1787). This risk management framework is
already applied in the water acquis; it is included in the Drinking Water Directive (Directive
2015/1787 that amends Directive 98/83/EC on the quality of water intended for human
consumption). Although the management of health risks is context-specific, the WHO
guidelines consider that the overall levels of health protection should be comparable for
different water-related exposures. Consequently, this “tolerable risk level” has also been taken
into account for JRC’s definition of the technical parameters reflecting the minimum quality
requirements on reclaimed water used in agricultural irrigation (detailed information in Annex
7, in section 4.3.1 and the technical background in section 4.4.2). Annex 7 also provides an
account of then monitoring requirements as well as of the exclusion of compounds of
emerging concern and the sensitivity analysis. It is important to note that no risk assessment
has been performed specifically for the establishment of the minimum quality requirements
and that the JRC bases its proposal on the validity of the risk assessment conducted by the
reference documents taken into consideration, namely the Australian Guidelines for Water
Recycling being internationally accepted as a key reference also for the specific EU situation.
4.2.1.1. "One-size-fits-all" approach
This approach requires the same quality for any reclaimed water to be used for irrigation of
agricultural products. It responds to the perceived health and environmental risks with the
most stringent approach without distinguishing between different needs of food crops and
irrigation technique. This approach implies that the required water quality has to be the most
stringent in order to prevent any risks of contamination even in the worst-case scenario. This
approach is the one adopted in the Italian legislation. This option is based on the quality
requirements, as detailed in Annex 7 for the most critical situation (quality class A - food
crops consumed raw produced with sprinkling irrigation).
4.2.1.2. "Fit-for-purpose" approach43
This approach consists in setting reclaimed water quality requirements that will provide the
appropriate level of safety for the crop to be irrigated. It considers contamination pathways
from irrigation water to the agricultural products, i.e. to which extent contaminants potentially
present in the treated effluent are likely to be transferred to the crop and eventually to affect
the consumer of the product. These contamination pathways differ according to crop types
and to irrigation methods. Indeed, several factors linked to the use of water in agriculture may
influence the risk of microbial contamination of the crops, such as: source of water; type of
irrigation (drip, sprinkler irrigation, etc.); whether the edible portion of the crops has direct
contact with irrigation water; application of a water treatment by the grower; the timing of
irrigation in relation to harvesting; possible access of animals to the source; etc. Water of
inadequate quality has the potential to be a direct source of contamination and a vehicle for
43
Terminology used in scientific literature and UN context
29
spreading localised contamination in the field, facility, or during transport. Wherever water
comes in contact with fresh produce, its quality impacts the potential for pathogen
contamination.
In particular, food crops more or less consumed raw (e.g. tomatoes, strawberries) require a
more stringent water quality to avoid microbial contamination (e.g. strawberries) than food
crops which will be cooked (e.g. potatoes) or crops which are not intended for human
consumption (e.g. pastures or energy crops). Similarly, irrigation methods interfere in this
contamination pathway as e.g. drip irrigation in orchards does not entail a direct contact of
irrigation water with fruits in contrast to sprinkling irrigation.
This approach is the one adopted in most of the existing regulations in Member States44
and
international guidelines. This option, like the other options entailing setting some form of
minimum quality requirements, is based on the JRC technical report (Annex 7) that was
developed to set minimum quality requirements for water reuse. All options would result in a
common methodology with minimum quality requirements differentiated against crop
categories and irrigation methods; detailed provisions of the options would be developed on
this technical basis.
4.2.1.3. Implementation of the requirements
Under both approaches, quality requirements would complement, but not decrease, the ones
laid down by the existing legislation, in particular the UWWTD and relevant European Case-
Law45
in particular as regards the quality of discharge effluents. Regardless of the approach
chosen, also when complying with the proposal (either legal instrument or Guidance),
reclaimed water at the outlet of the treatment plant would need to respect the criteria of "clean
water" as defined by the Regulation on the Hygiene of Foodstuffs (852/2004). So consistency
with other relevant legislation is ensured in either approach. More information is provided in
Annex 3.
The proposal would define a common methodology and set minimum requirements, and any
Member State (Member State B in Figure 10) could still adopt or retain more stringent
legislation for water reuse in its territory. This proposal would contribute to the proper
functioning of the Internal Market through the minimum harmonisation of the requirements
and the methodology for undertaking the risk management. Consequently, no trade barriers
could be feasible for food products irrigated with reclaimed water complying with the
minimum requirements set by the proposal ( Figure 10).
Figure 10: Trade of agricultural products irrigated with reclaimed water within the EU
44
e.g. ES, CY
45
ECJ Judgement cases C-119/2002, and C-335/07
30
4.2.1.4. Minimum requirements: regulated at EU-level or recommended by an
EU Guidance document
The EU can introduce the minimum requirements in a legal instrument rendering them
compulsory to water reuse projects in the EU, or, alternatively, the Commission can develop a
Guidance document recommending these minimum requirements for water reuse for
irrigation based on the JRC technical report (Annex 7) and would suggest a "fit-for- purpose"
approach on a voluntary basis. The Guidance document would build on the international
guidelines and long experience developed in third countries (e.g. California, Australia, Israel,
USA), and adapted to the specific context of the EU in terms of environmental and social
conditions and legislation; in particular it would take stock of experience and best practices
developed in the Member States. Such a Guidance document would be developed directly by
the Commission, in consultation with Member States and stakeholders (CIS).
4.2.2. Minimum quality requirements to ensure protection of local public health and
of the environment – Risk Management Framework
Risks to humans exposed to reclaimed water (e.g. farmers, workers on the fields) and to the
local environment are very specific to the local conditions and the design of the reuse scheme;
they vary greatly both in their nature and extent according to:
- Hazard, e.g. the quality of raw effluents discharged to the collecting system and
entering the treatment plant, mixing with other irrigation sources of different quality,
additional contamination during conveyance and storage;
- Exposure, e.g. distance from crop to waterways (especially if these are sensitive areas)
or to public spaces, irrigation method, crop type;
- Vulnerability, e.g. to what extent ecosystems, soil and plants are sensitive to pollutants
Because of their intrinsic site-specific nature, these risks cannot be addressed only with a
generic set of minimum quality parameters valid for any reclaimed water to be used for
agricultural irrigation in the EU. An effective management of these risks has to include a site-
specific assessment of those risks, and this assessment would form the basis for the selection
of the most appropriate mitigation measures, e.g. additional requirements necessary to ensure
a high level of protection of human health and the environment. Despite potentially diverging
additional requirements, the methodology to derive these would be harmonised at EU level,
thus ensuring a consistent approach across the EU, hence providing ensurance for internal
market operators.
The implementation of such a risk management framework is already recommended in some
Member States46
as well as numerous international guidelines and standards (e.g. by the
World Health Organisation, the International Standardisation Organisation, the USA
Environment Protection Agency). They have been developed in different socio-economic
contexts and without taking into account the existing EU legislative acquis which already sets
a number of requirements regarding the protection of the environment and health. Therefore,
Annex 7 presents the key principles of such a risk management framework both consistent
with these international guidelines and adapted to the European context.
With a view to defining comprehensive policy options in this Impact Assessment, two
approaches are considered regarding the implementation of such risk management
framework:
46
Italian guidelines for site-specific risk assessment for contaminated sites (Decreto legislative 152/06)
http://www.isprambiente.gov.it/files/temi/siti-contaminati-02marzo08.pdf
31
- The key Risk Management Framework principles included in a legal instrument and
thus made compulsory for operators and other relevant parties involved in water reuse
for agricultural irrigation (e.g. competent authorities in Member States, treatment plant
operator, farmers) and an accompanying Guidance that would be elaborated with
Member States to provide details on the practical application of the key RMF
principles;
- The Risk Management Framework recommended in the form of an EU guidance
document, based on the key RMF principles.
4.2.3. Key Risk Management Framework principles included in a legal instrument
The first approach would consist of including the key principles of a risk management
framework in a legal instrument, as part of the authorisation procedures and conditions of
granting permits to any water reuse project in the EU (as described in Annex 3). The key
principles would cover the different steps and operators of the water reuse system (urban
waste water collection and treatment, additional treatment if any, distribution, storage if any
and irrigation at farm level). In practice, the legal instrument would foresee that, before such a
permit can be authorised, the applicant of the permit has to perform a thorough identification
and assessment of risks specific to the project and its environment. Key requirements for this
risk assessment would be laid down based on description of the risk management framework
in Annex 7 (page 29).
The legal instrument would foresee that water reuse projects in the EU are regulated within a
risk management framework and would set the key principles to be complied with in the
permitting procedure. However, competent authorities in the Member States will retain the
responsibility of
- Ensuring and checking that the risk assessment carried out by the applicant is
appropriate considering the nature of the project and its environment, and
- Reflecting the outcome of the risk assessment in the permit conditions.
In order to ensure a common understanding on the detailed implications of the risk
management framework and a consistent implementation across the EU, the Commission
would develop a Guidance to translate the key principles into practise and to assist Member
States in sharing experiences and best practices, in the existing framework of the Common
Implementation Strategy for the WFD (CIS).
4.2.4. Risk Management Framework recommended by an EU Guidance document
As an alternative to making the key risk management framework principles compulsory to
water reuse projects in the EU, the Commission could develop a Guidance document on
implementation of the full-fledged risk management framework in the existing framework of
the Common Implementation Strategy for the WFD (CIS). The Guidance document would
build on best international practice within and outside the EU and would be part of the
Guidance document for the minimum quality requirements.
5. ANALYSIS OF IMPACTS
5.1. Baseline
Water reuse is not expected to increase significantly over the next years, if no further EU
regulatory action on water reuse is implemented, alongside the non-regulatory actions on
water reuse proposed in the context of the Circular Economy Package or improved
implementation of EU water legislation. Recently collected data shows, if no further EU
policy actions to promote water reuse are implemented, it is estimated (BIO (2015) that under
32
a Business As Usual scenario, a volume of around 1,700 million m3
/year could be reached by
202547
. This was based on the assumptions that the nationally set water reuse target for Spain
(1,200 million m3/year) is achieved by 2018 and no significant increases in water reuse would
take place in other Member States in comparison to the current situation.
Therefore, while water scarcity is expected to affect the EU more strongly and widely in the
coming decades, resulting in economic losses particularly for those sectors dependent on the
secure supply of water, as well as citizens, no significant increase in water reuse is foreseen
under a business-as-usual scenario.
It may be argued that such limited water reuse will be developed under the lowest costs
possible. Under the current quality standards for Spain it was estimated that a potential for
reuse of more than 6,600 million m3/year could be reached below 50 cents per cubic meter,
largely exceeding the baseline reuse volume. Therefore it is realistic to assume that the whole
volume reused under the baseline scenario would be available at costs below 50 cents per
cubic meter.
Water reuse schemes would remain relatively underdeveloped in the EU due to competing
demands for investments in infrastructure and - if left to compete on the basis of real costs
against subsidised alternatives - due to perceived low returns on investment. Nevertheless,
existing reuse schemes have benefited from subsidies to the water sector, but these subsidies
could be at odds with the need for cost recovery (as a means to provide adequate incentives
for users to use water resources efficiently) and financial sustainability in the water sector if
the necessary funding to provide for water related environmental policies is not secured via
alternative means. Clearly, as is the case with any investment, for every water investment that
requires an outlay of capital, the associated supplementary costs would have to be borne, or
shared, by either the state, the service providers, the water end users or the buyers of the
products. Given the existing structure and level of pricing for freshwater, as described in the
problem definition section (section 1.2), the policy measures to incentivise and support the
case for water reuse schemes will support the uptake of water reuse (i.e. boost the demand by
increasing the market security and regulatory security for the farmers) and will therefore help
with spreading the costs over a larger base.
Moreover, the heterogeneity of national requirements (including the lack of these) concerning
the management of health and environmental risks associated with water reuse would
continue to constitute a barrier with a potential to affect the EU-internal trade of agricultural
products irrigated with reclaimed water (BIO, 2015). Under a scenario of increasing water
scarcity exacerbated by climate change, as well as enforcement of water pricing and cost
recovery provisions of the WFD (as explained in the problem definition section), the financial
costs of securing freshwater supplies are likely to increase over time for agricultural
businesses, although few agricultural SMEs bear the cost of wastewater treatment directly
(BIO, 2015).
5.2. Analysis of the impacts of the policy options for water reuse in agricultural
irrigation
In line with the Commission's 'Toolbox for Better Regulation', as a first step, all the possible
impacts have been screened, and on that basis, several of them have subsequently been
subjected to a more detailed analysis48
. The analysis below discusses the costs of irrigation
47
A first rough estimate of the total EU water reuse volume in 2025 was developed for the purposes of this
study: under a Business As Usual (BAU) scenario, a volume of around 1,700 Mm3/y could be reached (i.e. total
volume of reclaimed water that would be reused in 2025 in the absence of further EU policy actions)
http://ec.europa.eu/environment/water/blueprint/pdf/BIO_IA%20on%20water%20reuse_Final%20Part%20I.pdf.
48
In particular using IA Tools #16-31, see http://ec.europa.eu/smart-regulation/guidelines/toc_tool_en.htm
33
with reused water and the benefits of it as modelled by the hydro-economic model by the JRC
(Annex 4) and some other impacts like administrative burden stemming from the requirement
to perform risk assessment under the different options. Environmental and social impacts are
also analysed. Wherever relevant, a clear distinction is made between expected impacts for
Member States which have national standards in place as compared to those who do not.
5.2.1. Economic impacts
The cost of waste water reuse is computed as the sum of the cost of: (1) the necessary
treatment of waste water for reuse; (2) building infrastructures for water storage and
distribution (pipelines and pumps); and (3) energy for reclaimed water pumping from the
waste water treatment plant to the neighbouring agricultural areas. The most important cost
factor is the transport cost and the underlying model-based assessment has therefore assumed
a maximum transport distance of 10 km between UWWTP and the irrigated land, in order to
keep costs at reasonable level.
The difference among the options is in the stringency of the water quality requirements,
which results in different treatment costs and therefore is a variable cost. The other cost
elements are not dependent on which option is chosen. Under Ir1 ("one-size-fits-all")
generally higher costs of treatment can be expected than under Ir2 ("fit-for-purpose"),
whereby different quality standards apply depending on the use conditions. Ir3 represents an
intermediate solution and is expected to end up in a situation where certain countries adopt Ir1
and others Ir2, therefore this option is not examined explicitly in the underlying modelling as
costs are falling into the range between the costs of the baseline scenario and the costs of
option Ir2. Quantifying the costs of treatment under Ir1 and Ir2 with high certainty is
impossible due to the inherent variability of investment and operating costs depending on the
initial level of treatment of plants. Moreover, it is impossible to anticipate with high certainty
the share of reclaimed water that may need the highest quality standards under Ir1. In order to
come to an estimate of the impacts of adopting Ir1 and Ir2 compared to the baseline scenario,
it has been assumed for modelling purposes that the treatment would require on an average a
depth filtration and disinfection process for Ir2, meaning treatment costs of EUR 0.08/m3 of
treated water, while under the Ir1 option, a membrane filtration process would be required to
achieve the most stringent standards, meaning treatment costs of EUR 0.23/m3. A more
detailed justification of these figures is provided in Annex 4.
The difference in the treatment costs under the two options reflects in a shift of total costs of
reclaimed water (including treatment and transport and incorporating investment and
operating costs), and consequently in a change in the volumes of reclaimed water that can be
distributed at a given cost. In terms of investments, the two policy options Ir1 and Ir2 may be
significantly different. Under option Ir2, investment costs of EUR 38/(m3/day) are estimated
while under Ir1 these raise to EUR 271/(m3/day). A justification of the underlying
assumptions is provided in Annex 4. Under Ir1, an investment of about EUR 600 million in
Europe would allow treating about 800 million m3 of waste water yearly with a total cost of
reclaimed water below 50 cents per cubic meter, while a slightly higher investment (less than
EUR 700 million) would allow treating more than 6,6 billion m3 yearly below the same cost
threshold under Ir2. When considering higher cost thresholds, uniformly applying the most
stringent water quality criteria (Ir1) in Europe would make investment costs surge in
comparison with the fit-for-purpose quality requirements (Ir2).
34
Figure 11: investments required to treat the available volumes of water at a given threshold total cost, under the
Ir1 and Ir2 policy options. Error bars represent the expected range of costs (see Annex 4). Modified from
Pistocchi et al., 201849
.
The direct costs of water reuse would be in principle borne by farmers, who would try to pass
these costs on to consumers. However, also today farmers are not bearing the full costs of
irrigation because of subsidies, and therefore a similar assumption could be made under the
different options. In such a case the costs would be borne by the society at large. Case studies
described in Annex 4 highlight a significant willingness to pay of households for a more
sustainable management of water resources. This may support the idea that a part of the costs
of water reuse could be borne by society/taxpayers and not only by the farmers alone, since
water reuse generates additional benefits to society. Nevertheless, there is an economic case to
bear the full costs of water reuse under certain circumstances as shown below.
Water shortages appear to be the main reason why farmers would be willing to use and pay
for the reused water; the higher the price farmers currently pay for fresh water supplies is, the
more they are willing to pay for the recycled water. It is also notable that freshwater supplies
for irrigation are not available in all river basins as demand exceeds available supply and so
some farmers are currently unable to source freshwater for irrigation, at least with any
security of supply. Furthermore, the pumping costs for groundwater, which are increasing
with the groundwater levels going down due to increasing water scarcity/droughts or impacts
of climate change, could be another significant driver for farmers to opt for reused water.
Therefore, the main argument for farmers to use reused water for irrigation purposes is the
fact that it would allow for a secure water supply, including during times of droughts when
other irrigation sources may not be available, however, fully respecting the principles of
sustainable management of water resources and adaptation to climate change. Existing
valuations of the impact of droughts50
on the overall welfare (farmers and consumers) suggest
the benefit of a secure water supply, as allowed by reuse, to be in the order of EUR 500-1000
49
Pistocchi, A., Aloe, A., Dorati, C., Alcalde Sanz, L., Bouraoui, F., Gawlik, B., Grizzetti, B., Pastori, M.,
Vigiak, O., The potential of water reuse for agricultural irrigation in the EU. A Hydro-Economic Analysis, EUR
28980 EN, Publications Office of the European Union, Luxembourg, 2018, ISBN 978-92-79-77210-8,
doi 10.2760/263713
50
The example of a particular Member State may further illustrate this point. The drought of the summer of 2017
resulted in an estimated loss of EUR 2 billion for the Italian farming sector (see above section 1). Italy currently
applies water reuse for irrigation to a very limited extent. Water reuse could, however, cover an estimated 47%
of all irritation demand in Italy (see below Figure 10), which would positively contribute to alleviating water
stress and avoiding economic loss.
35
million/year.51
,52
While this estimation is very rough, it at least shows that, in areas where
droughts are (or are likely to become) common, water reuse is clearly also beneficial from an
economic point of view. In other words farmers would be willing to pay the limited extra cost
of reused water in order to save their crops from severe water shortages and droughts as the
benefits would outweigh these limited extra costs.
Under all options those farmers growing crop which are consumed raw, so mainly fruit and
partially vegetable growing businesses, would be affected most. As costs would be in EUR/
m3, so proportionate to the amount of water used for irrigation, none of the options would
disproportionately affect SMEs. Therefore, no specific mitigation measures would be needed
under the different options. More details on how farmers would be affected are included
under the SME test (Annex 3a).
A distinction needs to be made between the economic impacts for countries which currently
have no national standards for water reuse in place and those who already have some. For the
latter, the analysis below takes account of the impacts both for Member States with currently
lower standards (ES, EL, CY) and those whose standards are currently more stringent than the
proposed EU level (IT, FR). A detailed comparison of the respective impacts is included in
Annex 12. The most important economic impacts for Member States aligning with the
proposed EU minimum quality requirements could be summarised as follows:
 Unless minimum quality requirements are too stringently set, the legally binding policy
options and the Guidance, if followed, will have positive impact on growth &
investments, as the new regulatory framework, with clearly established minimum quality
requirements for water reuse for agricultural irrigation, will boost research and
innovation, technological development in the sector, it will incentivise investments and
consequently it will be leading to new employment. According to the Territorial Impact
Assessment (Annex 9) the development of minimum quality requirements for reused
water in agricultural irrigation would have a positive effect of the overall economic
growth of all EU regions. Especially the Eastern European regions in the Baltic Sea and
the Black Sea and some regions in Greece could potentially benefit with a high positive
impact, most other regions would have a moderate impact.
 Water suppliers. Operators could face additional investments in waste water treatment,
storage and distribution and increased sampling costs in order to comply with the
minimum quality requirements while dealing with uncertain demand for the treated waste
water from the farmers. It was not possible to estimate to what extent monitoring costs
would increase due to the introduction of a risk assessment requirement. It is estimated
that the costs for water suppliers would be higher in case of policy options Ir1 due to the
necessity to achieve the most stringent (sometimes unnecessary) quality requirements,
51
A paper on the Po plain in Italy, Musolino et al. (2017) quantifies the impact of droughts on the overall welfare
(farmers+consumers) in the order of EUR 500-1000 million/year during drought years. The affected population
is more than 16 million persons. This may suggest a cost of about EUR 30-60/person during drought years and is
in fact in line with the figures on the willingness to pay provided above. The authors stress that farmers alone
benefitted from drought as the price increase was stronger than the production loss in the area. As reuse
contributes to water stress reduction in the order of 10%, we may assume an indirect benefit of EUR 50-100
million during drought years, for the Po plain alone. Considering a drought that simultaneously affects an area
10 times as big as the Po plain in Europe, the indirect benefits for the whole of Europe would go back to EUR
500-1000 million during a drought year. Source: Dario Musolino, Alessandro de Carli, Antonio Massarutto,
Evaluation of the socioeconomic impacts of the drought events: The case of the po river basin. Europ. Countrys.
· 1 · 2017 · p. 163-176 DOI: 10.1515/euco-2017-0010.
52
During summer 2017, a drought hit the whole territory of Italy causing losses to agriculture, that farmers
estimated at least at € 2bn (http://www.bbc.com/news/world-europe-40803619). Notably, also regions
traditionally not suffering from water scarcity were hit.
36
e.g. removal of nutrients that could otherwise be beneficial for the agricultural sector
(fertigation). Furthermore, the operators might face higher costs in relation to the
compulsory risk assessment approach that is part of Ir1 and Ir2, and for Ir3 if the
Guidance is followed by Member States. The alignment with the EU quality standards,
including the risk assessment framework would require existing waste water treatment
plants to submit an application to amend their permits. If the Member States with
relatively less stringent standards were to adopt the proposed EU minimum quality
requirements, then this would place a burden on businesses to update their permits
accordingly. Similarly, for Member States with no national legislation, the adoption of
the EU minimum quality requirements would lead to some burden on businesses to be
permitted / registered as required.
 Functioning of Internal Market, international trade and competition. Positive
impacts on the Internal Market, international trade with third countries and competition
would be expected through reduced differences in the requirements used in different
Member States. The European producers would rely on a safe and sustainable water
supply option leading to a more sustainable agricultural production. In addition,
European products could benefit from a comparatively good reputation as minimum
quality requirements would ensure adequate safety of the relevant EU products. A similar
approach for all EU Member States would contribute towards a more informed and safer
consumer choice, with positive impacts for the Internal Market. The impacts on
competition with imports from third countries are expected to be neutral. In addition,
developing standards at EU level will reinforce the EU stance in international standard
setting discussions on water reuse. Common EU standards could serve as a model for
third countries, and in particular our bilateral trade partners. Especially those countries
facing water scarcity and considering applying water reuse schemes could benefit from
the EU approach in addressing potential risks associated with water reuse. This would
reinforce bilateral co-operation and standard approximation with key exporting partners
of primary agricultural products. The likelihood that negative impacts could be expected
as a result of irrigation with treated waste water that is not subsidised, which would then
lead to an increase in the cost of agricultural production and as a consequence an increase
in the price of agricultural products (thereby rendering these products uncompetitive on
the market) is considered a very remote one, because farmers would simply avoid using
the costlier irrigation water option. They would instead continue using the already
existing irrigation source.
 Employment. As a means of better securing water availability, water reuse provides
further economic security to agricultural producers, and will build a water reuse expert
community to support water reuse business which translates into social benefits. This
enables jobs to be secured, created and providing benefits to local communities (EC,
2012) (BIO, 2015); According to the Territorial Impact Assessment (Annex 9), the
development of minimum quality requirements for reused water in agricultural irrigation
would definitely cause positive effects in all regions with agriculture depending on
irrigated land. In more detail, Spanish regions on the Mediterranean coast, Greek regions
on the Northern coast of the Aegean Sea and Italian regions around Torino could benefit
from a moderate positive effect. All other regions could gain a minor positive impact.
Also according to the Territorial Impact Assessment (Annex 9) the development of
minimum quality requirements for reused water in agricultural irrigation could improve
the public acceptance of reused water, which could open chances for employment,
especially in rural areas. Regions with a greater share of employment in agriculture and
forestry are likely to be more affected. This would lead to minor positive impacts on most
regions. Regions in the North and the South of Romania and several other regions could
gain a moderate positive impact if they took up the new options for reusing waste water.
37
 Economic impacts for public authorities. For those Member States with existing
national standards that might align with the EU minimum quality requirements, their
current systems (quality categories, quality parameters) would not need to be adapted in
terms of conceptual design, and it is estimated that upgrading the limits on some
parameters would not require significant administrative adjustments. However, for those
Member States with no national legislation, the burden on public authorities could be
important, in terms of setting up the administrative system to allow water reuse for
agricultural irrigation. For the risk assessment approach, Member States could benefit
from the experience with the risk assessment approach introduced by the Drinking Water
Directive on a voluntary basis (and is being considered as compulsory in the revision of
this Directive). Therefore, only limited additional costs might be expected (around EUR
2,244,176, see Annex 4 for a detailed calculation). However, it is to be noted that the EU
will not impose the water reuse practice on those Members States that do not wish to
promote it. Reporting under the proposed policy options would most likely entail the use
of existing reporting streams such as the reporting under the UWWTD or WFD. If
included, separate guidance could be provided in order to define the content and format
of information to be reported. There would be modest burden in adding further reporting
fields at the European level. At national level, reporting would be parallel to compliance
monitoring performed by the competent authorities and would also lead to modest
additional burden.
 Consumers: The trade of agricultural goods irrigated with reclaimed water would be
positively influenced (in terms of levelling the playing field) which could benefit
consumers. However, additional costs for water reclamation plants might imply increased
costs to water users including farmers, and hence to consumers should the farmers pass
on the increased costs. On the other hand a more stable and potentially increased food
supply due to reclaimed water and less variation in crop prices might positively affect
consumers.
 Innovation and research. The introduction of minimum quality requirement and a risk
assessment framework under all policy options would promote research on innovative
treatment technologies. For example, in the UK Water Industry Research recently
concluded a project entitled ‘Establishing a Robust Case for Water Reuse’53
which
showed that reuse is a technically viable water source in a range of applications,
geographies, and scales. Considering that water reuse is an emerging worldwide market, a
greater uptake of reuse at the EU level would provide a showcase for the relevance of
these technologies and skills of EU companies towards potential customers in third
countries. Impacts on competitiveness and innovation are expected to be positive as
removal of current barriers to investment is anticipated. It should be noted, however, that
innovation and economically viable changes would also take place without adoption of a
new legal instrument. A clear and consistent EU framework would allow economies of
scale and standardisation. This in turn would support innovation and development of
solutions at lower costs. The potential market for innovations in water reuse and
recycling, through implementing technological solutions and adoption of policy and
legislative measures, is expected to grow and develop significantly within and outside
Europe, particularly in highly water stressed regions. The Territorial Impact Assessment
(see Annex 9) points in the same direction.
53
Reports/90179/Water-Resources/90193/Water-Reuse/97338/Establishing-a-Robust-Case-for-Final-Effluent-
Reuse---An-Evidence-Base also quoted in
http://ec.europa.eu/environment/water/blueprint/pdf/EU_level_instruments_on_water-2nd-IA_support-
study_AMEC.pdf
38
 Benefits for the industry, EU competitiveness and innovation potential. There is a
rapidly growing world water technology market, which is estimated to be as large as
EUR 1 trillion by 2020. By seizing new and significant market opportunities, Europe can
increasingly become a global market leader in water-related innovation and technology
(EC, 2012). According to Global Water Intelligence the global market for water reuse is
one of the top growing markets, and it is on the verge of major expansion and going
forward is expected to outpace desalination. The EU water reuse sector is maturing both
technologically and commercially, albeit at a slow rate. Given the importance of the
water industry sector in the EU, the past and current spread of water reuse technologies in
the EU and worldwide has been a driver for the competitiveness of this industry sector,
and this situation is expected to continue over the next 10 years. Water supply and
management sectors already represent 32% of EU eco-industries’ value added and EU
companies hold more than 25% of the world market share in water management (EU,
2011) (BIO, 2015). Without any policy measures to incentivise / support the uptake of
water reuse schemes, it is unlikely that the EU water reuse sector would be maturing at a
faster rate. The absence of incentives for further water reuse would lead to no positive
impact on competitiveness and innovation related to water reuse technologies and their
application to agriculture. Considering the potential worth of this industry, this could lead
to a loss of opportunities for the European market to be a leader on this issue.
 ICT. Implementing the policy options would be facilitated by advances in the ICT water
sector, relevant to remote monitoring, sensors, automation control and decision support
systems.
Summary of economic impacts
The above indicated benefits would only be achieved if the minimum quality criteria set are
not too stringent and would not result in too high costs. Therefore while Ir1 has in general
positive economic impacts, these do not materialise at the assumed cost level of 50 cents per
cubic meter, but only at higher cost levels (see next section where it is shown that uptake of
this option is calculated to be lower than under the baseline at the assumed cost of 50 cents
per cubic meter). This is the reason why in the summary table Ir1 is assessed to have slightly
negative impacts.
Figure 12: Summary of economic impacts
2030 (50) Option Ir1
Legal instrument "one-
size-fits-all" approach
+ RMF
Option Ir2
Legal instrument "fit-
for purpose" approach
+ RMF
Option Ir3
Guidance "fit-for purpose"
approach + RMF
Growth &
investments Slightly negative Positive
Positive, if Guidance followed
Neutral, if Guidance not
followed
Public authorities Slightly negative Slightly negative Neutral
Sectorial
competiveness
Slightly negative Positive Positive
Facilitating SMEs
growth Slightly negative Positive
Positive, if Guidance followed
Neutral, if Guidance not
followed
Achievement of
Internal Market Slightly negative/neutral Positive
Positive, if Guidance followed
Neutral, if Guidance not
followed
Increased
innovation &
research
Positive Significantly positive
Positive, if Guidance followed
Neutral, if Guidance not
followed
39
It is worth noting that an economic safeguard exists in terms of use of water reuse being
voluntary. A wastewater treatment plant will only develop the practice (separate treatment and
piping infrastructure), if it can sell the water to farmers for irrigation. On their side, farmers
will only be willing to pay for the water for irrigation if it is competitive in pricing terms
(taking into account also that the security of supply may be higher). As such, option Ir2 will
have positive financial impacts for farmers by definition and indeed it is this economic
attractiveness that will decide the ultimate level of water reuse. This safeguard is weakened in
Option Ir1, where the one size fits all may mean some existing supplies need to be treated to a
higher level with resulting higher costs, even if future expansion was always financially
advantageous.
5.2.2. Environmental impacts
The main environmental impacts of the proposed policy options include: supporting
adaptation to climate change and preserving the quality of natural resources (in particular
through the reduction of water stress and nutrient pollution), fostering the efficient use of
resources, sustainable consumption and production; and minimising environmental risks.
5.2.2.1. Adapting to climate change and preserving the quality of natural
resources
All proposed policy options analysed are expected to contribute to the ability to adapt to
climate change and reducing pressure on the environment by shifting the demand from main
water supplies towards reused water of appropriate quality for irrigation. Annex 4 provides
information on the quantitative model-based assessments available. A short summary is
provided below.
Reclaimed water can take up a potentially significant share of the water demand for irrigation
in the EU. Figure 13 shows that water reuse has the potential to meet for Spain and Portugal
about 20% of irrigation demand, for Italy and France to about 45%, for Greece, Malta and
Romania to around 10%. In all other countries, due to the lower irrigation requirements, water
reuse is able to meet the whole demand unless irrigated agriculture is relatively too far from
wastewater treatment plants (Nordic countries, Slovakia, Bulgaria, Poland).
Figure 13: wastewater availability and potential contribution of reclaimed water to irrigation demand, by EU
Member State. Potential contribution to irrigation demand is computed as water that can be allocated,
regardless of costs, in the neighborhood of wastewater treatment plants within each country, divided by the total
irrigation demand estimated for the country. Source: Pistocchi et al., 2018.
Country
Availability at
WWTPs
Total that can be allocated near
WWTPs, regardless of cost
Potential contribution of reuse to
total irrigation demand
EE 80,710,881 0 0%
LU 42,159,474 291,747 >100%
LT 180,393,800 50,601 32%
LV 351,587,408 104,500 52%
IE 1,199,386,263 1,019,289 >100%
FI 320,255,823 304,968 55%
HR 254,634,919 1,716,665 72%
SI 63,329,276 7,864,075 >100%
CZ 830,070,479 28,279,623 >100%
Increased
international trade
& investments
Neutral Positive
Positive, if Guidance followed
Neutral, if Guidance not
followed
Specific regions
(TIA) Neutral Positive
Positive, if Guidance followed
Neutral, if Guidance not
followed
Consumers
Neutral Significantly positive
Positive, if Guidance followed
Neutral, if Guidance not
followed
40
BE 466,779,792 67,571,968 >100%
MT 3,248,802 3,248,802 11%
AT 831,719,537 78,986,625 >100%
SE 764,770,821 43,679,832 57%
GB 5,785,815,226 185,791,041 >100%
PL 2,028,581,131 59,899,677 70%
BG 1,163,546,557 63,463,880 64%
HU 692,694,899 125,040,578 >100%
NL 961,098,462 264,433,029 >100%
SK 191,797,107 54,429,211 41%
DK 609,431,705 199,487,876 66%
DE 6,759,616,101 624,227,536 >100%
RO 743,414,782 99,146,222 11%
PT 1,278,557,567 660,784,949 23%
FR 4,998,793,967 1,845,451,653 44%
EL 1,153,447,397 417,500,899 9%
IT 9,769,661,947 4,962,268,684 47%
ES 7,114,641,769 3,295,147,922 18%
TOTAL 48,640,145,892 13,090,191,851
However, not all water available at wastewater treatment plants can be deployed at acceptable
costs. Figure 14 shows the amounts of water that can be reclaimed and distributed at different
costs (total costs including investment and operation of both water treatment and its transport
to farmlands), based on the modelling work described in Pistocchi et al., 2018. Among the
largest irrigation demand countries, Greece shows the most favourable conditions for total
costs, with the majority of potential water reuse volumes available at reuse costs below 50
cents per cubic meter, followed by Portugal. France is the least favoured, while Italy and
Spain are facing an intermediate condition.
Figure 14: Amounts of reclaimed water that can be potentially deployed at different total costs for 27 EU
Member States (Cyprus not included due to missing irrigation estimates). “Unmet” represents irrigation
demand estimated for the Country, in excess of potentially reclaimed water. Costs shown include treatment costs
representative of the Ir2 option. Source: Pistocchi et al., 2018.
Figure 15 shows the estimated volumes of reclaimed water that can be deployed at costs
below 50, 75 and 100 cents per cubic meter with the treatment costs assumed under Ir1 and
Ir2. From these figures, it is apparent that under Ir1 less water is available to be reused for
41
irrigation below the cost of 50 cents per cubic meter than under the baseline option. Under Ir1
the minimum quality requirements are too stringent and are too costly to support water stress
reduction at the assumed cost of 50 cents per cubic meter. On the contrary, Ir2 allows
maintaining costs below 50 cents per cubic meter for a large part of the water available for
reuse.
Figure 15: cumulative volumes (m3/year) that can be allocated below or at a given cost in Europe, under
« variable quality » and « higher quality » requirements. We refer to total (investment, operation and
maintenance) costs. Source: Pistocchi et al., 2018.
Below EUR 0.5/m3 Below EUR 0.75/m3 Below EUR 1/m3
Under Ir2 6,633,811,238.00 10,438,686,582.00 11,571,593,978.00
Under Ir1 827,229,354.00 8,747,570,594.00 11,028,173,972.00
Baseline 1,700,000,000.00
The share of agricultural water abstractions is variable across Europe, averaging about 60% in
Southern countries, 11% in Eastern countries and 7% in Western countries54
. A first
approximation indicator of water stress reduction potentially allowed by reuse is the %
reduction of total abstractions (Figure 16). This ranges from 3.5% in the East, to more than
15% in the North, averaging around 10%55
. This indicative percentage summarizes a much
nuanced picture with significant variability not just among continental zones, but also within
countries and regions.
Figure 16: reduction of water abstraction potentially allowed by reuse in different European zones. Based on
EEA data, 2017.
Zone
(A) Total reuse potential,
regardless of cost
(km3/year)56
(B) Irrigation demand
(km3/year)
(C ) Agricultural
share of total
abstraction
(A*C/B) Indicative
potential % reduction
of water absraction
East 0.44 1.37 11% 3.5%
South 9.34 36.2 60% 15.4%
West 3.31 5.21 7% 4.2%
From a water quality point of view, water reuse allows diverting flows of nutrients, from
direct discharge to rivers to application to agricultural soils with irrigation. Fertigation
(simultaneous application of fertilizers and water to plants) may contribute to reduce nutrient
pollution if the application is efficient (i.e., nutrient leaching to groundwater is not increased)
and the mineral fertilizers used in agriculture are reduced proportionally to the nutrient flows
coming with reclaimed water. Figure 17 shows the nitrogen (N) that can be potentially
recovered from wastewater in the different EU Member States. This is a significant amount,
and water reuse in itself would enable recovering up to the amounts corresponding to N in
treated wastewater. However, the potentials shown in Figure 17 do not take account of the
54
These percentages are the average of figures for the years 2000s and latest available year collected by
EUROSTAT and reported by the European Environment Agency (EEA): https://www.eea.europa.eu/data-and-
maps/indicators/use-of-freshwater-resources-2/assessment-2. Countries are grouped as follows: East: Bulgaria,
Czech Republic, Estonia, Latvia, Lithuania*, Hungary, Poland, Romania, Slovenia, Slovakia; South: Greece,
Spain, Italy, Cyprus, Malta, Portugal; West: Belgium, Denmark, Germany, Ireland*, France, Liechtenstein,
Luxembourg, the Netherlands, Austria, Finland, Sweden, England and Wales, Iceland, Norway, Switzerland.
55
Arithmetic average 7.7%, irrigation volume-weighted average 13.7%, average of the two 10.7%.
56
Reuse potential is computed for the three zones by aggregating the volumes shown by country in Figure 13.
42
costs involved and thus constitute a maximum estimate. The amount of N recovered under the
different options would depend on the volumes of m3 of water reuse estimated under the
different options. Therefore benefits in fertigation would be highest under option Ir2, but
would be practically negligible under Ir1 if we assume a maximum acceptable cost for
reclaimed water of 50 cents per cubic meter. Under this assumption, while Ir2 would enable
reclaiming about 6.6 billion m3/year of water, Ir1 would enable only 0.8 billion m3/year
(Figure 15).
Figure 17: comparison of N from wastewater and mineral N fertilizer. N from water reuse is the load of N in
treated wastewater, while the additional N recovery. “Unmet” refers to the amount of mineral N fertilizers in
excess of potential N recovery. Source: modified from Pistocchi et al., 2018.
The benefits of reusing water, while clear in principle, depend very much on the local
conditions where reuse is to be made. As reuse is meant to reduce irrigation water abstractions
from surface and groundwater bodies, in principle it should be implemented only where the
benefits from reducing abstractions exceeds the benefits of discharging treated wastewater in
the environment. In some cases, especially when treatment standards are high, discharges of
treated wastewater may represent a positive input to the receiving water bodies, as they could
sustain the flow regime while compensating other possibly existing hydrological alterations.
In many cases, however, it is preferable to use treated wastewater in irrigation while reducing
irrigation abstractions, because in this way the flow regime of water bodies is least disturbed,
and nutrients conveyed by treated wastewater may be taken up by crops57
instead of ending
up in water bodies.
Valuing the benefits that may stem from water reuse is overwhelmingly complex in general
terms. One proxy of benefits is the willingness to pay of farmers for reclaimed water, which is
extremely variable (for instance, Birol et al., 200758
estimate a willingness to pay higher than
EUR 0.6 /m3 in Cyprus, while Tziakis et al., 200959
, indicate less than EUR 0.1/m3 for
57
This requires that nutrients in reused water are taken into account in the planning of crop fertilization, and that
fertilization is efficient. If these conditions are not met, reuse may simply contribute to transfer pollution from
surface water bodies (where wastewater is typically discharged) to soil and aquifers where fertilizers may leach.
58
Birol, E., P. Koundouri, and Y. Kountouris (2007), Farmers’ demand for recycled water in Cyprus: A
contingent valuation approach, in Wastewater Reuse––Risk Assessment, Decision-Making and Environmental
Security, edited by M. K. Zaidi, pp. 267–278, Springer, Dordrecht, Netherlands.
59
Tziakis, I., I. Pachiadakis, M. Moraittakis, K. Xideas, G. Theologis and K. P. Tsagarakis (2009), Valuing
benefits from wastewater treatment and reuse using contingent valuation methodology, Desalination, 237, 117–
125.
43
Crete), see Annex 4 for further details on the range of different studies and estimations for the
value of 1 m3 of water. These examples in the Annex highlight the large variability in
valuation of water used to reduce water stress, and the uncertainty due to their high case-
specificity. In this assessment, based on the above estimations on willingness to pay, the
benefit of water reuse can be estimated in the magnitude of EUR 0.5 /m3, which is in the mid-
lower end of the cases examined above, and may be argued to represent a first approximation
of the combined market and non-market value of water reuse in Europe, provided it
contributes to reducing water stress. Therefore it can be argued that there is an economic case
for water reuse as in general there would be willingness to pay where water reuse costs do not
exceed EUR 0.5 /m3.
According to the above modelling overall a water stress reduction of more than 5% could be
achieved in Europe under option Ir2, corresponding to a benefit of about EUR 3 billion/year
for the whole EU assuming a willingness to pay about EUR 0.5/m3 for preserving natural
flows in rivers and aquifers. This is based on the calculation that Ir2 would enable reusing
more than 50% of the total volume theoretically allocated for agricultural irrigation; the total
available volume would enable a water stress reduction of approximately 10%. Consequently
Ir2 would enable a water stress reduction of more than 5%. Furthermore, most of the
alternative water supply options (e.g. desalination, water transfers) are related to the intensive
use of energy. Among them the most energy consuming is desalination. If the energy is
generated using fossil fuels, this will increase GHG emissions. This is linked to the higher
amounts of energy needed to desalinate water (between 3.5 and 24 kWh/m3
according to the
technology), especially with thermal processes. On the basis of an average European fuel mix
for power generation, it has been estimated that a reverse osmosis plant produces 1.78 kg of
CO2/m3
of water, while thermal multi stage flash leads to 23.41 kg CO2/m3
and multiple
effect distillation to 18.05 kg CO2/m3
(Ecologic 2008). Consequently, all proposed policy
options would contribute to cutting CO2 emissions in case the water reuse is used instead of
desalination plants, with the "fit-for purpose" options Ir2 having the highest benefits due to
the lower energy consumption for the treatment of wastewater for the identified purpose
compared to Options Ir1 due to possibly too stringent and unnecessary treatment for some
purposes, e.g. more stringent water quality that could otherwise be required for food crops
which will be cooked.
Box 2 Example from Spain: it was estimated the desalination installation at Carboneras – Europe’s largest
reverse osmosis plant - uses one third of the electricity supplied to Almeria province. The more than 700
Spanish desalination plants produce about 1.6 million m3
of water per day. According to the estimates (1.78 kg
of CO2 per m3
of water) on CO2 production from desalination, this translates into about 2.8 million kg CO2 per
day. It can be argued therefore that desalination is contributing significantly to Spain’s overall GHG emissions
of XX per year, which have increased to +19.4% in 2015 compared to 1990 levels60
. This may be a foretaste of
the dilemmas and choices between different adaptation options that Member States will face in future years as
the impacts of climate change are felt increasingly widely (Ecologic 2008).
5.2.2.2. Fostering the efficient use of resources
Policy options Ir2 and Ir3 (if followed) are expected to contribute to the implementation of
SDG 6 which sets a target of substantially increasing recycling and safe reuse globally by
2030 insofar as they would increase water efficiency through the uptake of water reuse.
Policy options Ir2 and Ir3 (if followed) are expected to foster a more efficient use of water
resources, as a clear framework for the water reuse would promote public and user confidence
in reclaimed water and provide the possibility to water managers to prioritise various supply
options taking into account the local needs of the society and environment. It is estimated that
60
http://ec.europa.eu/eurostat/web/environment/air-emissions-inventories/main-tables
44
these two options would result in an increased demand for treated wastewater for irrigation, as
the water managers would have a solid basis to encourage/promote the application of water
reuse in the planning of the use of water resources in given river basins, as well as farmers
would have a confidence in the quality of treated wastewater for the identified purpose. It is
anticipated that a regulatory framework on water reuse would result in a decrease of illegal
abstractions of groundwater, thus positively impacting the status of groundwater and
associated ecosystems. However, for Ir1 the uptake is estimated to be negative at the assumed
cost of EUR 0,5/m3 resulting in a supply of water reuse which is lower than the baseline,
therefore this would mean less efficient use of water resources.
The assessment undertaken on territorial impacts (see Annex 9) has confirmed that most
benefits from setting minimum quality requirements for the reuse of wastewater would mostly
concentrate on regions suffering from water scarcity, which are mainly regions also
endangered by droughts. In relation to reducing water scarcity the assessment concludes that
about 24% of the regions could gain a moderate positive impact situated in the South of
Europe (Portugal, Spain, the Mediterranean coast of France, Italy, Greece, Cyprus), in the
East of Europe (Eastern Poland, Southern Hungary, parts of Romania and Bulgaria) and in
central France and 1% of the regions located in the South of Portugal, in the very South of
Italy and Haute-Corse could gain a high impact. The majority of 75% of the regions would
face a minor impact. This assessment, however, was conducted only on this option and on the
basis of the current situation on water scarcity and did not take account of the likely
aggravation of water scarcity due to climate change and is therefore a conservative approach
of the potential from water reuse.
Under policy options Ir1, Ir2 and Ir3, if followed, water reuse may result in a more efficient
energy use in the water supply and wastewater treatment sector in those Member States
adopting the minimum quality requirements. Several reports and studies have looked into
comparing use of energy from water reuse and other alternative sources such as desalination,
in particular in Californian literature, where both options are often considered. On average, a
water treatment plant uses 2,500 kWh per million gallons of water treated61
. The energy use
varies based on the characteristics of the water being treated, the distance and elevation of the
treatment plant and the distribution system. In comparison, desalination of sea water (in
particular processes based on thermal distillation or membrane filtration technologies which
are energy intensive) requires from 9,780-16,500 kWh/ million gallons). Further comparisons
are presented in Figure 18 below.
Figure 18: Overview of energy use per water source in California
Type of water source Average energy use in kWh per MG
Waste water treatment
plant
2,500
Seawater desalination 9,786-16,500
Groundwater desalination 3,900-9,750
Source: California’s Water-Energy Relationship
In addition, the use of treated waste water for irrigation would require an equivalent or
increased level of waste water treatment depending on the policy option. This would result in
equivalent or increased energy consumption and costs associated with water treatment. In
particular, different treatment technologies allow different levels of water quality to be
achieved, with technologies such as dual membrane tertiary treatment processes that combine
micro-filtration and reverse osmosis allowing the highest quality of treated water to be
achieved. Such treatment processes are energy intensive. However, whilst there would be
61
California’s Water-Energy Relationship, 2005
http://www.energy.ca.gov/2005publications/CEC-700-2005-011/CEC-700-2005-011-SF.PDF
45
additional energy use, this would to some degree be offset by avoided energy consumption
associated with freshwater abstraction, treatment and distribution. In particular, reusing
treated wastewater (as opposed to discharging it and abstracting and treating freshwater anew)
can result in net energy savings. However, it should be noted that the net energy savings or
increases will depend on the current levels of treatment and particularities of water supply,
and the extent of increases in wastewater treatment where applicable.
For the sake of modelling, the same energy cost has been assumed for all 3 options and these
potential costs savings due to more energy efficient water management could not be
quantified. In general it can be concluded that these cost savings would depend on the ability
of each option to reduce water stress and proportionate to the reduction the water stress levels.
This means that it would be most beneficial under option Ir2, less beneficial but still positive
under Ir3, depending on to what extent guidance is followed. Furthermore higher overall
energy costs for water management can be estimated for option Ir1 as water stress would even
increase under this options in case of the assumed water costs of 0,5 EUR / m3.
5.2.2.3. Sustainable consumption and production
Policy options Ir1, Ir2 and Ir3 (if followed) are expected to significantly contribute to
sustainable consumption and production62
through the recycling of treated wastewater of high
quality, which would be otherwise discharged into receiving streams. Considering the effort
spent in producing this high quality product, reusing part of this investment for beneficial
purposes directly contributes to the sustainable development. While options Ir2 is expected to
have positive impacts on the sustainable consumption and production, option Ir1 could
represent potential negative impacts due to the removal of nutrients that could otherwise be
beneficial for the agricultural sector (fertigation) and it would increase water stress.
5.2.2.4. Minimising environmental risks
Options Ir1 and Ir2 would ensure that environmental risks are sufficiently tackled since a risk
assessment would be needed to be performed on a binding basis in all cases water reuse is
considered for agricultural irrigation. Option Ir3 due to its voluntary character would only
ensure to some extent that environmental risks of water reuse are tackled, depending on to
what extent Member States would follow the guidance.
Waste water reuse not only reduces the demands of freshwater, but can also reduce the
discharge of nutrients to rivers, other surface water bodies and groundwater. On the other
hand, increased uptake of treated waste water reuse in agricultural irrigation would need to
ensure adequate controls of potential environmental risks including managing chemical
contaminants, nutrients, heavy metals and micro pollutants that can negatively affect the
environment and or may lead to human health problems (water-borne diseases and skin
irritations). For heavy metals there are concerns that these substances can accumulate in the
soil over time. Salinity of the water is also a risk to the environment and to crops. While using
treated water containing nutrients for irrigation can constitute an environmental benefit
whereby the nutrients are used by the crop rather than being discharged into water bodies,
careful management is needed to ensure minimised risks of nutrient run-off and increased
eutrophication, by ensuring an adequate type of treatment of the reclaimed wastewater
according the areas of application (e.g. sensitive areas or their catchments). Finally, there are
also growing concerns over the fate of the wide variety of contaminants of emerging concern
(e.g. pharmaceuticals), which are present in sewage, often at trace levels, and which are often
62
http://www.thesourcemagazine.org/the-role-of-water-in-the-circular-economy/
46
unmonitored. Evidence remains limited as to how well treatment processes deal with these
pollutants.
Figure 19: Summary of environmental impacts (assuming the costs of EUR 0.50/m3)
5.2.3. Social impacts
The same social impacts are anticipated as under the baseline for the Member States without
national standards, if they retain the current status (no water reuse requirements in place). In
any instance where Member States with more stringent national requirements choose to align
with the minimum EU standards, i.e. lower their national standards, some adverse impacts in
terms of compromised public acceptance could be anticipated.
By contrast, adoption of the new EU wide standards (by the Member States without national
standards) or alignment of less stringent national standards with more stringent EU wide
recommendations would positively impact on promotion of public acceptance.
Social impacts associated with the Member States without national standards adopting the EU
wide recommendations and Member States with less stringent standards aligning these with
the proposed standards for water reuse in agricultural irrigation would include:
 Public and occupational health. In those Member States with national legislation, the
proposed policy options are expected to bring little additional benefits with regard to
public and occupational health with the exception of Member States with less stringent
national standards aligning these with the proposed EU wide requirements. For Member
States with no legislation but which adopt the minimum water quality standards, this
would provide a framework for protection of human health and safety of
individuals/populations. The legally binding policy options and the Guidance if followed
would also decrease the likelihood of health risks due to exposure to dangerous
substances; Results of the second open public consultation show a large consensus (75%
of respondents) about the need for the minimum quality requirements to address the
protection of human health of public directly exposed to reused water (e.g. workers; see
Annex 2).
 Employment. The establishment of an EU framework together with improved
communication on actual risks and benefits of water reuse is expected to have a positive
impact on confidence of the general public in the quality of the reused water and,
therefore, on acceptance of water reuse as a water management tool. More jobs would be
created in the water and agri-food industry as well as in innovation and research sectors.
Other sectors are expected to be influenced indirectly. For instance, in Greece, data
2030 (50) Option Ir1
Legal instrument
"one-size-fits-all"
approach
+ RMF
Option Ir2
Legal instrument
"fit-for purpose"
approach
+ RMF
Option Ir3
Guidance "fit-for
purpose" approach +
RMF
1- Fighting climate change
and preserving the quality of
natural resources
Slightly negative Significantly positive
In the range of neutral to
significantly positive
depending on to what
extent it is followed
2- Fostering the efficient use
of resources
Slightly negative Positive
Neutral-positive
3- Sustainable consumption &
production
Slightly negative Positive
Neutral-positive
4- Minimising environmental
risks
Positive Significantly Positive
Positive-Significantly
positive
47
available suggests that investments in wastewater reuse have a growth and employment
multiplier of 3.563
providing a positive contribution for employment;
 Governance and good administration. In Member States where no legal framework
currently exists governing wastewater reuse for agricultural irrigation, the opportunity to
fill the existing gap in the national legal system by adopting these EU wide standards is
present. The Territorial Impact Assessment (Annex 964
) shows that setting minimum
quality requirements could improve government effectiveness. Eastern European regions
in Latvia, Lithuania, Poland, Romania and Bulgaria as well as Italian and Greek regions
and some Spanish regions could gain a moderate to high positive impact on government
effectiveness. Most of the other regions would gain a highly positive impact. Many
developers are aware that stakeholder participation is a key success factor for the
development and efficient operation of water reuse schemes. In order to build trust and
get support, developers and local authorities therefore need to initiate stakeholder
awareness raising actions, consultation and collaboration activities during the
development of new water reuse schemes. In most cases, the development of water reuse
projects is thus an opportunity to enhance good governance practices and public
participation (BIO, 2015). Compared to the baseline, this would be considered as a lost
opportunity.
 Public acceptance. Adoption of the EU wide minimum quality requirements as well as
aligning less stringent national requirements with the proposed EU wide standards would
contribute to consumer protection by ensuring an appropriate quality of treated
wastewater used for irrigation and hence of agricultural products on the market. An EU
action would also bring more confidence to the public on the safety of the practice having
a positive impact on the public perception of using recycled water for irrigation. The type
of application for which water is reused is an important factor for public acceptance.
Public acceptance decreases when public health is at stake or when there is a risk of
contact or ingestion of reclaimed water. For instance, public acceptance of reusing water
to irrigate crops that are intended to be eaten or to wash clothes can be low while reusing
water for bioenergy cropping will not cause serious public concerns (IEEP et al., 2012).
Public acceptance is difficult to achieve as long as citizens are not fully aware of the need
to reuse treated wastewater to alleviate water scarcity and droughts, associated potential
risks and adopted risk management strategies and consider it an efficient solution to
address water scarcity and to reserve high quality water supplies for drinking water
purposes. The first stage of acceptance of the use of reclaimed water is the acceptance by
the community of the need. In this case, the use of reclaimed water becomes a solution to
a problem and this, in turn, is an important driver of public perception (UK Water
Research Industry, 2003). According to WSSTP (2013), growing confidence in
technologies such as ultrafiltration, reverse osmosis, membrane bioreactors, and ultra-
violet disinfection, has also reduced public health concerns about reuse (BIO, 2015);
therefore currently public acceptance is greater in countries where water reuse is already
taking place, for instance in Spain.
The results of the second public consultation show a relative consensus among respondents
about reused water in irrigation as being at least as safe as compared to water abstracted from
rivers. This perception is more controversial regarding groundwater. There is a large
consensus among respondents representing different economic sectors about the safety of
reused water compared to water from rivers, as nearly 70% of them (in each sector but
63
Appendix D of AMEC study, Processed data by the authors
64
It is to be noted that the TIA has been concluded before the JRC modelling has been completed, hence there is
a potential discrepancy regarding the available data.
48
agriculture, where this figure is closer to 60%) consider reused water as at least as safe. There
is also a consensus between different types of stakeholders, as more than 60% of respondents
from each group indicate that they perceive reused water as at least as safe as using water
from rivers, with private companies having a particularly favourable opinion. The large
majority of respondents from Southern EU Member States and others in high water stress also
report a positive perception of the safety of reused water in agriculture compared to
freshwater. On the other hand, the results of the consultation show a more negative perception
from respondents of the safety of reused water compared to groundwater, as nearly 50% of
respondents perceive it as not as safe. This is particularly true for respondents from Northern
EU Member States and for respondents from the health sector, for which this figure raises to
nearly 70%.
Figure 20: Summary of social impacts
6. COMPARING THE OPTIONS
This section compares the policy options to the baseline in terms of their effectiveness,
efficiency and coherence, as well as their environmental, economic and social impacts (see
overview in Figure 21 below). The comparison of the policy options is done in the context of
their respective abilities to meet the general and specific objectives of the initiative, as set out
in section 2.2 above.
2030 (50) Option Ir1
Legal instrument
"one-size-fits-all"
approach
+ RMF
Option Ir2
Legal instrument
"fit-for purpose"
approach
+ RMF
Option Ir3
Guidance "fit-for
purpose"
approach + RMF
Employment Positive Positive Neutral
Public and occupational health Positive Positive Neutral
Governance & good administration Positive Positive Neutral
Public acceptance Significantly positive Positive Neutral
49
Figure 21: Summary of environmental, economic and social impacts
Policy option
Category of
Impacts,
Effectiveness,
Efficiency &
Coherence
Agricultural irrigation
Ir1
Legal instrument
"one-size-fits-all"
approach + RMF
Ir2
Legal instrument "fit-
for- purpose"
approach + RMF
Ir3
Guidance "fit-for purpose" approach +
RMF
Environmental Slightly negative
Positive/Significantly
positive
In the range of neutral to significantly
positive depending on to what extent it
is followed
Economic
In the range of
slightly negative to
neutral
Positive/Significantly
positive
Positive, if Guidance is followed
Neutral, if Guidance not followed
Social Positive Positive
Positive, if Guidance is followed
Neutral, if Guidance not followed
Effectiveness Negative Positive
Positive, if Guidance is followed
Neutral, if Guidance not followed
Efficiency Negative Positive
Positive, if Guidance is followed
Neutral, if Guidance not followed
Coherence Neutral/Negative Positive
Positive, if Guidance is followed
Neutral, if Guidance not followed
6.1. Effectiveness of the policy options
In sum, based on modelling results, the different policy options contribute to the objectives of
reducing water stress and nutrient pollution in proportion to the additional amount of reused
water available at the assumed acceptable costs of of 50 cents per cubic meter. Figure 22
below (also in above section 5.2.2.2 Adapting to climate change) provides a comparison with
the baseline, where it is assumed that approximately 600,000 m3/year of additional water will
be reused, i.e. from the current 1,100 million m3 to 1,700 million m3 (see Section 1.4.2).
Therefore the baseline would not significantly reduce the water stress level, and alleviate
water scarcity, so it would not significantly contribute to effectively achieving the objectives
set. In comparison with the baseline scenario, option Ir1 would achieve even less water stress
reduction than the baseline at a total cost below 50 cents per cubic meter, so would not be
effective. Option Ir2 would be very effective as it would lead to a significantly higher uptake
of water reuse at acceptable costs. Ir3 would be effective to the degree to which Member
States would implement the Guidance.
Figure 22: cumulative volumes (m3/year) that can be allocated below or at a given cost in Europe, under
« variable quality » and « higher quality » requirements. We refer to total (investment, operation and
maintenance) costs. Source: Pistocchi et al., 2018.
Below EUR 0.5/m3 Below EUR 0.75/m3 Below EUR 1/m3
Under Ir2 6,633,811,238.00 10,438,686,582.00 11,571,593,978.00
Under Ir1 827,229,354.00 8,747,570,594.00 11,028,173,972.00
Baseline 1,700,000,000.00
Policy option Ir2 would be effective in relation to the specific objective as it sets a common
methodology for defining requirement for reuse of treated wastewater used for agricultural
irrigation. It would be effective as it addresses the underlying driver 2 (see chapter 1.3.2) on
50
the uneven regulatory framework at Member States and the two sets of risks defined in Figure
5. Moreover, it would reduce the risk of potential trade barriers as there would be certainty on
how the food products were irrigated and that this practise is safe both for consumers, the
workers on the field and the environment. Therefore this policy option does address those
drivers of the problem that the initiative intended to address, namely driver 2 and 3 (see
chapters 1.3.2 and 1.3.3.).
Given the fact that under Ir1 the quality requirements are too stringent and therefore Ir1
would rather inhibit the uptake of water reuse than supporting it, it is not effective in
achieving the overall objective, even if Ir1 would meet the specific objective of setting a
common methodology as regards defining minimum quality requirements for reused water.
Option Ir3 would only be partially effective as those Member States who decided to apply the
guidance would follow a common methodology for defining minimum quality requirement
for water reuse, however overall the approach would continue to be fragmented.
As the overall objective on increasing the uptake of water reuse also depends on other factors,
for instance the underlying driver 1 (on reused water being less attractive than conventional
water resources) and 4 (on lack of consumer trust) shown in the problem definition, these
factors can pose a limitation to achieving the overall objective and to reaching the uptake
volumes shown in Figure 23. These factors are not addressed by this initiative and are outside
of its scope, as already stated in the problem definition (see chapter 1.3.1 and.1.3.4).
However, there are actions being undertaken (i.e. improving the implementation of the Water
Framework Directive, organising information campaign to inform the public about water
reuse) also on these external factors, but not in the remit of this impact assessment and
initiative. Nonetheless, options Ir1, Ir2 and to some extent Ir3 would result in improved
consumers' trust in relation to water reuse because there would be more certainty on the safety
of water reuse practises due to common minimum quality requirements within Europe.
Moreover, effectiveness of the options also depends on the extent to which farmers would
have an incentive to apply water reuse for irrigation purposes. Even if the above factors 1 and
4 pose a limitation to achieving the overall objective, they are not likely to significantly
undermine the effectiveness of this initiative, because the analysis of impacts (see chapter
5.2.2.1) has shown that it is reasonable to assume willingness to pay for the availability of
reclaimed water for agricultural irrigation at the assessed cost of 50 cents per cubic meter in
water stressed areas. In other words farmers would be willing to pay the limited extra cost of
reused water in order to save their crops from severe water shortages and droughts as in these
cases the benefits would outweigh these limited extra costs.
Furthermore, the degree of effectiveness in reaching the general policy objective will vary
depending on the policy option and water reuse practices currently adopted in different
Member States in terms of the use of treated wastewater:
No new action – Baseline for treated waste water reuse for agricultural irrigation would not be
effective in reaching the overall objective. As highlighted in Section 1.4.2, estimated treated
wastewater reuse potential under the baseline (in the absence of further policy developments)
is estimated at 1,700 million m3
/year by 2025 (compared against 1,100 million m3
/ year in
2015).
The effectiveness of policy option Ir3 (if followed) would vary across the Member States due
to its non-binding nature:
 Member States with existing national standards for the reuse of treated wastewater (six
Member States in total) are likely to retain their own national systems or to introduce
marginal changes. At the same time, introduction of EU wide Guidance on the reuse of
51
treated wastewater might support the progress of existing national standards aiming to
increase reuse of treated wastewater, through positively affecting public acceptance and
providing further reassurance about the safety of such a use of treated wastewater. On the
other hand, if a Member State with currently more stringent national reuse standards were
to decide to align (lower) the national system with the proposed EU requirements, this
might result in a lower level of treatment required, subsequently, lower costs of treatment,
but at the same potential compromised public acceptance;
 A large number of Member States (22) do not currently have national standards on the
reuse of treated waste water. Taking into consideration these two factors, this policy
option is not expected to significantly increase uptake in treated waste water reuse or to
contribute significantly to addressing the key barriers to waste water reuse discussed in
Section 1.
The implementation of policy options Ir2 and Ir3 (if followed) is expected to result in higher
uptake of treated wastewater reuse across the Member States where water scarcity is
identified as a significant pressure and water reuse is deemed an effective measure. As
indicated by BIO (2015), a volume in the order of 6,000 million m3/year by 2025 might be
achievable in the case of both stronger regulatory and financial incentives at the EU level. The
effectiveness of these policy options would vary across the Member States depending on the
existence of any national standards and their relative stringency in comparison to the
proposed minimum quality requirements and risk assessment approach. In general terms, the
effectiveness is anticipated to be higher in those Member States for which the absence of a
clear legislative framework is seen as a major obstacle to water reuse and Member States
whose national standards are lower in stringency than the proposed minimum requirements
(see also Annex 6).
In particular, depending on the relative stringency of the existing national standards for the
reuse of treated wastewater in the six Member States with standards in place, in comparison to
the proposed EU minimum requirements and a risk assessment approach, and their choice
regarding retaining or aligning the national standards, these Member States would see an
increased or decreased stringency of requirements (notwithstanding that member states with
more stringent existing regimes could retain these, rather than reduce the level of protection).
For instance, in Cyprus and Greece, the legally binding option could perform better in terms
of improvement of public perception and raising confidence, removing a fragmented
framework for agricultural irrigation using treated wastewater across Europe and resulting in
lower treatment costs.
Crucially, the Member States that do not currently have national standards on the reuse of
treated wastewater and which are not interested in implementing use of treated wastewater
would not be affected. The proposed EU minimum requirements and a risk assessment
approach considered in this assessment for water reuse in agricultural irrigation does not
interfere with the Member States’ decision on whether or not to develop water reuse and the
extent to which water reuse should be encouraged.
6.2. Efficiency of the policy options
The degree of efficiency in reaching the general policy objective is assessed in terms of the
respective costs involved. It will vary depending on the policy option and water reuse
practices currently adopted in different Member States regarding the use of treated
wastewater:
52
No new action – the Baseline for agricultural irrigation is not cost-effective as it involves
many lost opportunities in terms of cost savings, and in terms of business development for the
EU water industry (BIO, 2015).
Figure 22 above clearly shows that option Ir2 provides more volume of treated waste water,
hence more benefits, than option Ir1 at any given cost, and is therefore more efficient. The
efficiency of option Ir3 depends on the extent to which Member States would follow the
Guidance and is therefore considered less efficient than option Ir2.
Policy options Ir3 (if followed) – development and promotion of a non-binding Guidance
would involve limited additional treatment, monitoring and administrative costs. In particular,
Member States that have national requirements in place already are most likely to retain these,
while Member States that do not have such national requirements at present will retain the
freedom to decide whether to engage in treated wastewater reuse practices and under what
conditions. The policy options, however, would not contribute towards development of
consistent quality requirements across the EU Member States.
The implementation of all policy options Ir1, Ir2 and Ir3 (if followed) would involve some
administrative costs associated with development and adoption of the EU intervention, as well
as its implementation and enforcement in the Member States that would choose to adopt
treated wastewater reuse practices:
 Member States which do not currently have national standards would benefit from having
a clear regulatory framework for managing health and environmental risks of reuse if they
choose to adopt the practice. At the same time, Member States that do not anticipate
engaging in treated waste water reuse practices would not incur administrative costs of
transposition, in case the proposed instrument is a Regulation. In case a Directive is
proposed, additional administrative burden is expected due to the required transposition,
in particular in those Member States who do not make use of water reuse and do not
intend to engage in such a practice.
 Member States with existing national standards that are relatively more stringent than the
minimum quality requirements proposed are either anticipated to incur no additional costs
or benefits if they choose to retain their national standards or would incur lower costs of
treatment if they choose to align their national standards with relatively less stringent
minimum requirements under the EU proposal (while not the intended objective of the
proposed EU wide standards, this constitutes an available choice to this group of the
Member States). In selected cases where Member States national standards were found to
be less stringent, the countries would incur marginal increases in monitoring costs due to
the higher number of parameters to be monitored.
6.3. Coherence of the policy options
All policy options have to ensure they are fully coherent with other EU policies, supporting,
in particular, the achievement of the objectives set by the WFD and its associated Directives,
and by the Marine Strategy Framework Directive.
As options Ir2 and Ir3 (if followed) would reduce water stress levels, these policy options
would contribute to the implementation of several other EU policies, in particular the EU
climate change adaptation and disaster prevention policies, the EU biodiversity strategy, the
resource-efficient Europe initiative, and the EU policy framework on phosphorus (BIO,
2015). Option Ir1 would not be coherent under the assumed cost of 50 cents per cubic meter,
because it would lead to higher water stress levels than the baseline, so it would undermine
other policies like the EU climate change adaptation strategy.
53
In addition, options Ir1, Ir2 and Ir3 (if followed) would support the achievement of EU food
safety legislation, by addressing upstream safety issues and, in the case of agricultural
irrigation, promote addressing the Internal Market and possible trade barriers, and would be
fully coherent with the existing Regulation on the Hygiene of Food Stuff.
Further information on the coherence of the preferred option with the existing legislation is
included in Annex 3.
6.4. Nature of the instrument
As set out in the above analysis, the purpose of the new instrument on water reuse for
agricultural irrigation would be to facilitate the uptake of water reuse wherever it is
appropriate and cost-efficient, thereby creating an enabling framework for those Member
States who wish to practice water reuse. This impact assessment considers the full array of
legal instruments, namely amending one of the existing Directives, a new Directive or
Regulation, as well as the non-binding form of a Guidance
Most of the existing EU legislative framework on water is composed of Directives (e.g. WFD
and its associated Directives, Drinking Water Directive, UWWTD, Bathing Water Directive,
Marine Strategy Framework Directive). This choice of instrument not only reflects the need
for EU legislation to accommodate pre-existing national institutional arrangements and
legislation in Member States but, among other things, also the intrinsic nature of water
management which has to adapt to highly varying situations in terms of natural characteristics
of water resources and of the human activities impacting their status.
Also for water reuse practices there is a wide variation across the EU (see Annex 6) but there
are much less pre-existing institutional arrangements at national level. When considering new
legislation on water reuse, it should be noted that the legal instrument of a Directive would
easily be able to accommodate the fact that Member States may wish to either keep existing
national standards (in case they are more stringent than the EU minimum requirements) or
introduce more stringent national standards if a Member State finds this more appropriate.
One possibility is to amend an existing legal framework where water reuse is already
mentioned, in particular the UWWTD. However, an amended or new Directive would require
transposition into national legislation by all Member States. While water reuse is certainly a
promising option for many Member States, it needs to be considered that at present only 6
Member States (CY, EL, ES, FR, IT, PT) can build on specific coverage in their legislation or
in national non-regulatory standards. The transposition obligation applies for all Member
States, whether they intend to reuse water or not. This would result in the burden of
introducing fully new legislation which may not be proportionate.
The possibility of allowing for an opt-out from a possible new Directive has been considered.
Such opt-outs can only occur by way of negotiation after a Directive has been adopted by the
co-legislators. The opt-out possibility is generally envisaged for more permanent situations65
.
In the case of water reuse, however, a more flexible possibility for phase-in is appropriate in
case certain Member States decide to introduce the practice at a later stage; this possibility
would be better provided by the legal form of a Regulation.
Moreover, an amended or new Directive would necessarily leave flexibility in transposition of
the requirements. While this would accommodate for differences across the EU, this would
pose a limitation in meeting the objectives set, in particular as regards the Internal Market and
65
For example, Malta opted out of a Directive on the interoperability of the rail system within the European
Union because it has no railway system and no plans to introduce one.
54
in setting a common level playing field. This limitation was already identified in the impact
assessment of the Blueprint in which a Regulation was eventually the only regulatory policy
option assessed in detail.
While the two open public consultations demonstrated a broad support by all categories of
stakeholders for a binding approach (i.e. a Directive or Regulation), several comments from
respondents in the second consultation expressed a preference for a Directive, either explicitly
or implicitly in view of its binding character together with its flexibility allowing adaptation
to local contexts and needs, but this could be achieved with other tools, notably the suggested
introduction of the risk assessment approach (see Annex 2). It is true that flexibility is
necessary in order to address adequately the risks to local public health and to the local
environment. However, it is equally true that a rather uniform approach is needed for the
relevant health risks for food products placed on the Internal Market. This should be the main
consideration in choosing between amending an existing Directive or introducing a new
Directive/Regulation or Guidance.
Requirements linked to the Internal Market are frequently introduced by way of a Regulation
to ensure direct applicability to operators. While the main objective of the new initiative is
environmental (contributing to alleviating water scarcity), as discussed above, the Internal
Market dimension is a crucial link in the intervention logic of the initiative and must be
addressed at the same time in order for the initiative to reach its main objective.
On the basis of the above analysis on the most appropriate legal form, both a Directive or a
Regulation may be chosen, each with certain advantages and disadvantages.
6.5. Preferred option
On the basis of the above analysis in terms of the efficiency, effectiveness and coherence of
the policy options for agricultural irrigation, both the "fit-for-purpose" approach and the
baseline are expected to better address the objectives of the initiative than the "one-size-fits-
all" approach; the "fit-for-purpose" approach can deliver significantly more benefits than the
baseline. Considering all environmental, economic and social implications, a legal
instrument applying the "fit-for-purpose" approach (Ir 2) is the preferred option rather
than a Guidance document because it is able to provide the highest volume of treated waste
water at an affordable cost level combined with additional economic and social benefits.
It would enable reusing more than 50% of the total water volume theoretically available for
irrigation from wastewater treatment plants in the EU and avoid more than 5% of direct
abstraction from water bodies and groundwater, resulting in a more than 5% reduction of
water stress overall. This would be a considerable contribution to alleviating water stress in
the EU and thereby correspond to the overall objective of the initiative.
The proposed EU legal instrument would have an enabling function and provide for a timely
reaction to a growing EU-wide problem. Its implementation is expected to (1) raise
awareness, (2) provide reassurance that experts have transparently analysed what is actually
safe for all EU citizens and (3) ensure a level playing field and thereby provide an incentive
for farmers, industry, citizens and others to explore the opportunities stemming from water
reuse. This could include purchasing agricultural products that were currently not chosen by
certain consumers; it could also mean further research, technology development and
investments, as well as job creation.
For the choice of legal instrument, the possibilities of a Directive or a Regulation are both
considered suitable, each with certain advantages and disadvantages. While a Regulation
would cater better to the enabling nature of the initiative, a Directive may allow for easier
55
flexibility in terms of setting more stringent national requirements (while at the same time
imposing a transposition burden on all Member States, including those who do not wish to
practice water reuse at the present moment).
7. MONITORING AND EVALUATION
Consistent with the objectives of this initiative, its monitoring will aim at evaluating policy
effectiveness in the EU in terms of:
- the evolution of water scarcity,
- the development of water reuse for agricultural irrigation,
- compliance of water reuse practices with the minimum requirements, including the
risk management approach.
A Fitness Check of EU environmental monitoring was carried out and presented by the
Commission in June 2017; it includes an action plan to streamline environmental reporting to
be implemented in the coming years66
. Monitoring needs for the present initiative have been
elaborated according to the principles highlighted in this Fitness Check, in particular:
- efficiency of reporting with a moderate, justified and proportionate administrative
burden, by avoiding overlaps and streamlining with existing reporting obligations,
both in terms of content, timing and frequency;
- relevance in content, by focusing on information that is strategic, quantitative and
regulation-driven, and limiting the amount of textual information
- EU added value, by making available comparable and consistent data available at
national level complemented with active dissemination of relevant information at
national level.
Existing reporting obligations for Member States under the WFD (Article 15) and the
UWWTD (Articles 15, 16 and 17) already include the necessary information on indicators
relevant to measure the success of this initiative, In particular, under the WFD, Member
States are to report every six years for each of their river basins67
:
- quantitative status of groundwater bodies;
- surface water and groundwater bodies subject to a significant pressure from
abstractions, and the main responsible sector(s);
and, in case water abstraction has been identified as a significant pressure in the basin:
o Water Exploitation Index (WEI+)
o annual volume of water used by sector (consumptive uses)
o annual volume of reused water;
- whether water reuse has been included in the river basin management plan as a
measure in terms of managing water resources.
Under the UWWTD, Member States are to report every two years, inter alia, for each of their
agglomerations (and associated urban waste water treatment plant) whether at least part of the
effluent is reused and for which purpose.
Information reported by Member States to the Commission is the basis for the elaboration of
periodic Implementation reports by the Commission to the European Parliament and the
Council. Recent steps have been taken to improve the quality of reporting on existing
66
Report "Actions to Streamline Environmental Reporting" (COM(2017)312) and Fitness Check evaluation
(SWD(2017)230)
67
WFD reporting guidance 2016
56
provisions to water reuse and more accurate information is expected to be available as of the
next implementation reports under the two Directives in 2018. Taking into account these on-
going improvements, existing reporting streams under the WFD and UWWTD will mostly be
sufficient to inform progress as regards the evolution of water scarcity and development of
water reuse for agricultural irrigation in the EU and only limited additional monitoring and
reporting requirement will be developed to this regards.
The monitoring requirements will primarily be imposed to the operators of the reclamation
plants and the Member States shall ensure that the information is made available online to the
public. The proposed Regulation would include additional monitoring requirements on the
quality of reclaimed water. Member States would need to verify compliance with the permit
conditions based on monitoring data obtained pursuant to the legal instrument on water reuse,
the Water Framework Directive and the Urban Waste Water Treatment Directive and other
relevant information.
Detailed reporting obligations will be developed with consultation of experts in Member
States taking into account experience gained in the Fitness Check on environmental reporting
and follow-up actions, in particular as regards the use of advanced information and
communication technologies (ICT).
Given the expected evolution both in knowledge and in the policy framework as regards
contaminants of emerging concern the legal instrument shall include a review clause within 6
years after its entry into force.


EN EN
EUROPEAN
COMMISSION
Brussels, 13.6.2018
SWD(2018) 249 final/2
PART 2/3
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT
Accompanying the document
Proposal for a Regulation of the European Parliament and of the Council on minimum
requirements for water reuse
{COM(2018) 337 final} - {SEC(2018) 249 final} - {SWD(2018) 250 final}
Europaudvalget 2018
KOM (2018) 0337
Offentligt
1
TABLE OF CONTENT
ANNEXES .................................................................................................................................... 2
Annex 1 – Procedural information ................................................................................. 2
Annex 1a – Water reuse in impact assessment of Blueprint (excerpt)......................... 13
Annex 2 - Synopsis report on consultation activities................................................... 29
Annex 3 - Who is affected by the initiative and how................................................... 40
Annex 3a –SME test..................................................................................................... 48
Annex 4 - Analytical models used in preparing the impact assessment....................... 52
References ........................................................................................................ 74
Annex 5 - Problem tree................................................................................................. 77
Annex 6 - The purposes and benefits of reusing water - situation in selected Member
States .............................................................................................................. 78
2
ANNEXES
Annex 1 – Procedural information
Lead DG: DG ENV Agenda planning/WP reference: 2017/ENV/006
Organisation and timing
Work on this impact assessment started in August 2013, when DG ENV signed a contract
with an external contractor to further analyse the possibilities for the maximisation of water
reuse in the EU, and to assess the impact of the possible measures.
Taking over a pre-existing Inter-Service Group an Impact Assessment Steering Group (IASG)
led by DG ENV was set up and met 9 times, between December 2014 and September 2017.
The Directorates-General (DGs) of the Commission SG, SJ, AGRI, CLIMA, CNECT,
ECFIN, GROW, JRC, MARE, MOVE, REGIO, RTD, SANTE, and TRADE were invited to
participate in the work of this group; all nominated representatives. AGRI, SANTE, JRC,
RTD and SG were the DGs that contributed the most actively to the work of the IASG. All
nominated members of the group were regularly consulted and informed on progress.
Consultation of the Regulatory Scrutiny Board (RSB)
[NB: section to be replaced in the final draft after RSB "formal" consultation, to briefly
explain how the Board's recommendations have led to changes compared to the earlier draft.
This will include a table with the first column identifying the Board's recommendation and the
second column how the IA Report has been modified in response).]
A meeting between all members of the RSB and DG ENV was held on 13 February 2017,
also attended by members of SG and JRC, aiming at providing early feedback on the main
expectations of the Board regarding this initiative. The table below summarises the comments
raised by the RSB in the meeting and how they were followed-up:
Preliminary points raised by the RSB on
13 February 17
Follow-up in the present draft IA report
The upcoming IA will need a clearly
presented and thorough problem definition. It
would be important to identify the main
issues, where problems occur, the sectors and
the member states it mostly affects, the
magnitude of the problem, and how it would
develop in the absence of additional action. It
should demonstrate that this is a problem
present at the EU level, potentially examining
the problems at the level of member states.
This in turn could be efficiently used to
demonstrate the need to act at the EU level,
and should feed into the discussion on
subsidiarity and proportionality. A good
problem definition would also enable DG
ENV to better identify potential benefits.
The problem definition elaborates on the
issues affecting the different Member States
and sectors. Scope and magnitude of the two
main objectives (reuse of treated wastewater
for irrigation purposes and for maintaining
groundwater supply) has been clarified. It is
explained why this scope has been chosen
and other areas for water reuse, e.g. industrial
use have not been considered. Particular
attention was paid to subsidiarity and
proportionality issues. Different sets of
options were developed for these two areas
also to take account of proportionality.
3
The IA should clarify the scope of the
initiative and the (possibly different)
magnitude of each of the two main
objectives: reuse of treated wastewater for
irrigation purposes and for maintaining
groundwater supply.
Potential obstacles and bottlenecks should be
well presented and backed up by evidence
(e.g. the problems for the functioning of the
Internal Market described in the inception
IA).
There was one case where direct evidence
exists on this matter. Otherwise the initiative
tackles the perceived health risk and
environmental risks associated with a
fragmented framework at EU level.
DG ENV mentioned that they believe there is
only a limited possibility for quantification,
especially concerning the uptake of water
reuse. The RSB pointed out that DG ENV
could examine other possibilities of providing
a convincing justification. This could include
evidence from well-designed and well-
presented consultations.
In addition to results from modelling
evidence from extensive stakeholder
consultation has been sought and included in
the present report. In order to maintain the
robustness of modelling, the amounts of
water that become available under the
different options has been quantified in order
to reduce water stress, but the value of this
water has not been monetised as no coherent
and conclusive evidence exists on this matter.
The report summarises several studies in this
field and their diverging conclusions on the
value of water in terms of reduced water
stress.
The IA should also analyse the possibilities
and challenges presented by the quick
evolution of technology. If the uptake of
water reuse is not known, the IA could look
at different scenarios (high/low) explaining
the assumptions made. The IA should also
explain conditions that would make this
initiative useful and proportionate to the costs
generated.
The hydro-economic modelling by the JRC
has followed this approach. Moreover an
assessment of territorial impacts has been
carried out, so as to triangulate the
information as far as possible and to arrive at
more solid conclusions.
Shaping the public perception (or
misperception) seems to be an important
issue. DG ENV should therefore also pay
attention to communication related to reused
water and consider non-legislative actions.
Health-related problems do not currently
seem to be addressed in the main objectives,
but seem to be implicitly in the problem
definition. This dimension should be included
in the IA.
The problem definition identifies explicitly a
perceived health risk and environmental risks
which are resulting from the uneven
framework existing in the EU to regulate
water reuse.
EU action on common quality requirements is
expected to positively contribute to public
perception on water reuse and to tackle both
risks above.
If the initiative intends to differentiate in the The initiative aims at setting minimum
4
application of standards between Member
States, the reasons should be well
substantiated.
quality requirements, so in case a Member
State intends to allow this practice, it needs to
comply with these as a minimum, but is free
to develop more stringent requirements. The
approach does not differentiate between
Member States in relation to possible cross-
border health and environmental impacts.
It leaves flexibility to Member States to
manage risks associated with reuse on the
local public and environment. Reasons for
this are linked to the local nature and extent
of these risks and application of the
subsidiarity principle; they are substantiated
in the report.
The "fear" and "uncertainty" dimensions
seem to be important for this initiative. The
IA should address the question of how to
generate more confidence. This does not
necessarily require legislation. If results from
consultations indicate that there is a strong
demand for higher standards, this could
provide the basis of a strong argument to
accept the higher costs associated with them.
As part of the Circular Economy Action Plan
beyond this initiative the Commission already
committed to provide support to further
knowledge and technological development in
order to reduce uncertainty related to water
reuse practices.
Consultation activities have confirmed the
demand for legislation to secure EU-internal
trade of agricultural products irrigated with
treated waste water.
The scientific work underlying the proposed
minimum quality requirements including the
check by EFSA and SCHEER ensure that
these requirements are sound and safe. So the
pure existence of such requirements
contributes already to reducing uncertainty
and fear as consumers can be sure about the
safety of European irrigated food products
and aquifer recharge practises.
Impacts on irrigation water cost have been
addressed in the report.
The RSB discussed the Impact Assessment report on 25 October 2017. A negative opinion,
requesting a resubmission of the Impact Assessment report, was issued on 27 October 2017.
The table below summarises the main and further considerations and adjustment requirements
raised by the RSB in its opinion and how they were followed-up:
Main points raised by the RSB in its
opinion of 27 October 2017
Follow-up in the revised draft IA report
(B) Main considerations
(1) The report identifies water scarcity as the
main issue but does not clearly document this
problem's size, geographical scope or likely
Relevant projections on water scarcity and
climate change scenarios were introduced in
Section 1.1. Further information
5
evolution. It does not explain whether this is
an immediate problem or an issue for the
future as a result of climate change.
underpinning the projections is available in
Annex 4.
(2) The justification for intervention at the
EU level is weak. The report does not
substantiate lack of consumers' trust in the
safety of agricultural products sold between
Member States. Neither does it demonstrate
the need for EU standards on reused water to
alleviate water scarcity, to preserve the
internal market for agricultural products, to
protect consumers' health or to promote
innovation in the circular economy.
The over-arching objective of the EU
initiative on water reuse is to increase an
uptake of water reuse as a measure
contributing to the alleviation of water
scarcity in the EU while maintaining the
safety of health and addressing environmental
risks associated with water reuse practices.
The problem definition has been revised
accordingly. The potential contribution of an
EU legal instrument on water reuse towards
reducing water scarcity is presented in
Section 5 and further data is available in
Annex 4. The Internal market dimension is
now better presented in Section 1.3.3.
(3) The report lacks a clear analysis of the
different situations across Member States
with regard to quality requirements for reused
water, and how the initiative would affect
these respectively. The report does not
adequately describe Member States' and
consumer groups' views on this.
The IA report, as well as the JRC technical
report is based on thorough analysis and
consultation of Member States. Comparison
of current standards on water reuse in
selected Member States versus the JRC
proposal on water reuse has now been
included in Annex 6. The Member States
views have been updated with recent
information of the last CIS ATG on Water
Reuse that took place on 6-7 November 2017.
Consumer groups' views are covered by the
results of the open public consultations,
which are presented in Annex 2.
(4) The report does not adequately show how
the initiative would be effective. It lacks a
clear analysis of links to price setting and
clean water prices.
The initiative has been put in the context of
water pricing policy; information that was
presented in Annex 5a in the previous version
has been introduced in the main text. The
main reference is Art. 9 of the WFD and its
implementation and enforcement. Relevant
information is presented in Section 1, and in
particular Section 1.3.1 Factor 1. However, it
has to be noted that water pricing as such is
not going to be addressed by the initiative on
water reuse, as there are other means already
in place. The effectiveness of the initiative
has now been further elaborated, i.e.
information that was presented in Annexes in
the previous version has been moved to
Section 6.
(C) Further considerations and adjustment requirements
(1) Clarify problem and need for
intervention. The report should define from
the outset the water reuse that falls within the
The language in the scope definition has been
improved. Aquifer recharge has been
discarded based on the subsidiarity
6
scope of the proposal. In particular, it should
explain why the initiative deals only with
irrigation and aquifer recharge. It should
present projections of water scarcity across
the EU, and explain why the problem needs
to be addressed at the EU level. The report
should make clear to what extent existing
regulatory standards concerning agricultural
product safety fail to create consumer trust
needed for a free flow of agricultural goods,
and how EU minimum standards for reused
water would solve this problem.
assessment (see Annex 11), consequently, no
detailed impact assessment is included.
Relevant projections on water scarcity and
climate change scenarios were introduced in
Section 1.1. Further information
underpinning the projections is available in
Annex 4. The interplay between existing
standards and potential new EU minimum
standards especially for agricultural irrigation
and their expected impact has been set out in
more detail.
(2) Clarify the choice of objectives. The
report should present clear links between the
objectives and the main problems. It should
explain whether addressing water scarcity is
the higher level objective, to which targets for
water reuse in agriculture and for aquifer
recharge contribute. It should detail how
achieving these objectives might conflict with
the free flow of agricultural goods. The report
should clarify the interlinkage and trade-offs
between trade, environmental and public
health objectives.
The intervention logic has been clarified. The
different levels of objectives have been made
more explicit and linked directly to the
problem definition.
(3) Stakeholder views should be more fully
presented. Evidence of Member State
support for standardisation should be
provided and argued against stakeholder
resistance and the current different national
levels of requirements for quality of reused
water. In the context of stakeholder support,
it would be helpful to show more evidence of
consumer perception of a problem and how
minimum standards would contribute to
greater trust.
Stakeholders' views based on the open public
consultation are presented in the revised
report, making a reference to Annex 2 when
relevant.
(4) Subsidiarity issues. Given big climate
differences across the EU, the justification for
EU intervention should explain whether
minimum standards would be helpful for all
or if they might disadvantage some Member
States. The report should clarify whether the
legal base to act is an environmental
objective or a single market base. It should
explain why the regulation of a risk
assessment framework for aquifer recharge is
not discarded up front, as the report already
on page 25 states that aquifer recharge does
not directly entail any issue linked with the
placement of products on the internal market.
The intention of this initiative is to introduce
an enabling framework for water reuse
practices for those Member States who wish
to implement them. Those who are not
affected by water scarcity exacerbated by
climate change will not be obliged to pursue
any water reuse practice. Given the
environmental legal basis, explicitly stated in
Section 2.1, those Member States would be
able to maintain/apply more stringent
requirements. Aquifer recharge is now
discarded upfront based on the subsidiarity
assessment (more information in Annex 11).
(5) Choice of the legal instrument. The The nature of the instrument is now placed in
7
report should explain why minimum
standards would be best enforced by a
Regulation rather than a Directive, especially
when the case of subsidiarity is not clear and
the proposal covers minimum standards with
possibility for derogation. The report should
explain why "relevant health risks for food
products placed on the Internal Market" (p.
20) justify the choice of a Regulation,
although other water related EU acts,
including drinking water, are Directives.
Stakeholders also broadly appear to favour a
Directive. The report should make clear that
Member States with more restrictive limits
will have to justify derogations from
minimum standards. It should consider the
implications of lowering existing standards in
such cases
Section 6, in which arguments both in favour
or against a Directive or Regulation are listed.
The conclusions of the Blueprint were the
departure point for this impact assessment,
hence a Regulation has been identified as
preferred option. However, following further
consideration, the possibility of a Directive is
analysed as well in more detail.
(6) The preferred option Regulation "fit-
for-purpose" and the development of
standards in collaboration with Member
States. The preferred option, with a
collaborative setup with Member States,
should be more clearly explained. The report
needs to explain how minimum standards
would result in greater reuse of water for
irrigation. The report should discuss what
motivates farmers to substitute reused water
for fresh water for irrigation. It should point
out that the willingness to pay for reused
water will differ across regions, depending on
differences in freshwater pricing. It should
indicate that costs for the supply of reused
water may be greater than the assumed
willingness to pay of 0.5 €/m3. The report
should explain that this qualifies the
calculation of uptake and consequent
benefits.
Section 5 has been revised to better reflect the
willingness to pay based on the modelling
data included in Annex 4.
(7) The lack of trust issues in the safety of
agricultural products sold between
Member States The report needs to spell out
how standards will protect public health and
the extent of scientific evidence supporting
them. The report should provide evidence
that reuse of water for irrigation leads to
marketing problems for agricultural goods. It
should critically discuss how minimum
standards for reused water have to
complement agricultural product safety
standards. The impact assessment should
This has now been clarified in the problem
definition, Section 1.3.
8
critically discuss whether minimum
standards, with the possibility of more
stringent national or regional standards,
overcome the problem of consumers
discriminating between products from
different regions.
The RSB received a revised version of the draft Impact Assessment report on 1 December
2017. A positive opinion with reservations was issued on 19 January 2018. The table below
summarises the main and further considerations and adjustment requirements raised by the
RSB in its opinion and how they were followed-up:
Main points raised by the RSB in its
opinion of 19 January 2018
Follow-up in the revised draft IA report
(B) Main considerations
The context section of the report does not
sufficiently reflect the shift in emphasis from
water management to environmental
standards for trade in agricultural goods.
Information about parallel EU initiatives and
alternatives in this area has not been
sufficiently detailed in the problem definition
of this initiative.
The context section 1.1. (pg. 4) was modified
accordingly to ensure coherence with the
main objective of this initiative, i.e.
addressing water scarcity through an
increased uptake of water reuse wherever it is
relevant and cost-efficient, as well as
contributing to the better functioning of the
internal market through creating an enabling
framework for water reuse. The problem
definition section was modified accordingly
(pg. 8).
(C) Further considerations and adjustment requirements
(1) The problem definition and the scope
consider reuse of waste water in the context
of an integrated approach to water
management. The report could provide
additional information on the potential of
reused water and the alternatives. It could
comment further on the proportionality of this
proposal in light of other initiatives. This
might strengthen the case for the scope of the
initiative and in particular for the creation of
an enabling framework for increased uptake
of water reuse, in particular for agricultural
irrigation. The report does not refer to the
Fitness Check of EU environmental
monitoring until very late in the report. The
report could use an early reference to all
relevant information for a good
understanding of the EU context and scope of
the initiative.
The information included on alternatives to
water reuse has been expanded to make
clearer what alternatives could exist and how
they would compare to water reuse.
Reference to the Fitness Check of EU
environmental monitoring introduced in
Section 1.1.
(2) The report states that Member States'
inaction to address the problem of
environmental risks of water reuse results in a
Single Market issue. The report could
Section 4.2 modified accordingly to reflect
the contribution of the proposed action to the
functioning of the Single Market.
9
strengthen this argument by highlighting how
the options include the Single Market
dimension and how the Single Market will
function despite diverging quality
requirement limits in Member States.
(3) The report now makes a more robust case
for the EU to act. It explains the level of
support among most Member States. The
subsidiarity analysis added in Annex 11
justifies discarding the measure about aquifer
recharge, while also documenting substantial
stakeholder interest in the issue. To clarify
the EU intervention, the report could include
further specific reference to the most EU-
relevant problem drivers in section 2.1.
Section 2.1 slightly modified.
(4) The report has appropriately adjusted the
objectives to the changed scope. If there is a
corresponding shift in operational objectives,
the report might explain what the
implications would be for future monitoring
and evaluation. This would include changes
to the intervention logic, indicators for
monitoring and benchmarks that those
indicators would be monitored against.
(5) The report could be made more reader-
friendly by incorporating the problem tree
into the main text, conventionally labelling,
numbering and footnoting tables and figures,
and more sparing use of bolding, underlining
and italics.
The problem tree was incorporated in the
main report (pg. 11, Section 1.3). The
formatting was improved.
The Board takes note of the quantification of
the various costs and benefits associated to
the preferred options of this initiative, as
assessed in the report considered by the
Board and summarised in the attached
quantification tables.
Some more technical comments have been
transmitted directly to the author DG.
Following the revision of the JRC modelling,
the quantification of the various costs and
benefits associated to the preferred options of
this initiative has been revised accordingly.
(D) RSB scrutiny process
The attached quantification tables may need
to be adjusted to reflect changes in the choice
or the design of the preferred option in the
final version of the report.
Following the revision of the JRC modelling,
the quantification of the various costs and
benefits associated to the preferred options of
this initiative has been revised accordingly.
Sources used in the impact assessment
The main information sources for this Impact Assessment are the preceding impact
assessment (2012) and subsequent supporting studies as well as the scientific basis developed
by JRC (minimum quality requirements), together with a hydro-modelling by JRC. Moreover,
10
by teaming up with other Directorate-Generals (DG REGIO and DG RTD) specific aspects
have been assessed, namely the impacts on innovation and territorial impacts.
Quality of the information collected: Significant effort was put into the collection of
evidence and where possible, triangulation was performed to cross check the validity and
robustness of information. Nevertheless, it was not feasible to arrive at monetised and
quantified impacts on all aspects. In these cases, a qualitative assessment was performed. The
Impact Assessment builds on detailed data on water scarcity and droughts in Europe, as well
as future projections and a cost-benefit analysis of the use of treated waste water for
agricultural irrigation. The modelling assumptions were based on expert judgements. The
choice of options and the underlying scientific work developing minimum quality
requirements was discussed with Member States and stakeholders in the context of the
Common Implementation Strategy under the Water Framework Directive, and adapted
accordingly.
Usefulness of the information collected. The underlying scientific work of developing the
minimum quality requirements, the data collected and the modelling for the Impact
Assessment are a useful basis for further decision-making.
COM(2012) 672, Report on the Review of the European Water Scarcity and Droughts
Policy
COM(2012) 673, Impact Assessment for the Blueprint
BIO-Deloitte (2014), Optimising water reuse in the EU
COM/2015/614, Communication on Closing the loop - An EU action plan for the Circular
Economy, Annex I
SWD (2015) 50, Report on the progress in implementation of the Water Framework
Directive Programmes of Measures: The Water Framework Directive and the Floods
Directive: Actions towards the ‘good status’ of EU water and to reduce flood risks
SWD(2017) 153, Commission SWD on Agriculture and Sustainable Water Management in
the EU
Forzieri, G., Feyen, L., Rojas, R., Flörke, M., Wimmer, F., Bianchi, A.
Ensemble projections of future streamflow droughts in Europe (2014) Hydrology and Earth
System Sciences, 18 (1), pp. 85-108. DOI: 10.5194/hess-18-85-2014
JRC (2014) Water Reuse in Europe: Relevant guidelines, needs for and barriers to
innovation
Forzieri, G., Feyen, L., Russo, S., Vousdoukas, M., Alfieri, L., Outten, S., Migliavacca, M.,
Bianchi, A., Rojas, R., Cid, A. Multi-hazard assessment in Europe under climate change
(2016) Climatic Change, 137 (1-2), pp. 105-119. DOI: 10.1007/s10584-016-1661-x
11
Amec Foster Wheeler Environment & Infrastructure (2016) UK Ltd, IEEP, ACTeon,
IMDEA and NTUA, EU-level instruments on water reuse
CIS Guidelines on Integrating Water Reuse into Water Planning and Management in the
context of the Water Framework Directive (2016)
http://ec.europa.eu/environment/water/pdf/Guidelines_on_water_reuse.pdf
COM (2016)105, Eighth Report on the Implementation Status and the Programmes for
Implementation (as required by Article 17) of Council Directive 91/271/EEC
concerning urban waste water treatment
Alberto Pistocchi, Alberto Aloe, Chiara Dorati, Laura Alcalde Sanz, Bernard Bisselink,
Fayçal Bouraoui, Bernd Gawlik, Emiliano Gelati, Bruna Grizzetti, Marco Pastori, Ine
Vandecasteele, Olga Vigiak, Hydro-economic analysis of the water reuse potential for
agricultural irrigation in the EU. JRC Science for Policy Reports, 2017 (draft).
REGIO (2017) Assessment of territorial impacts
RTD (2017) Assessment of impacts on research and innovation
JRC (2017) Development of minimum quality requirements for water reuse in
agricultural irrigation and aquifer recharge
SCHEER (2017) Scientific advice on proposed EU minimum quality requirements for
water reuse in agricultural irrigation and aquifer recharge
https://ec.europa.eu/health/sites/health/files/scientific_committees/scheer/docs/scheer_o_010.
pdf
EFSA (2017) Technical report on proposed EU minimum quality requirements for water
reuse in agricultural irrigation and aquifer recharge
http://onlinelibrary.wiley.com/doi/10.2903/sp.efsa.2017.EN-1247/epdf.
Report on Water reuse and recycling within EU reference documents
https://circabc.europa.eu/sd/a/c2f004b6-4c4b-4bbc-8d7d-
37938c6c6390/Water%20reuse%20%26%20recycling%20within%20EU%20Reference%20D
ocuments.pdf
Characterization of unplanned water reuse in the EU (Final Report 2017), Jörg E. Drewes,
Uwe Hübner, Veronika Zhiteneva, Sema Karakurt , TUM
http://ec.europa.eu/environment/water/pdf/Report-UnplannedReuse_TUM_FINAL_Oct-
2017.pdf
Report by FP7 project DEMOWARE: http://demoware.eu/en/results/deliverables/deliverable-
d5-2-trust-in-reuse.pdf
WHO Guidelines for the safe use of wastewater, excreta and greywater
http://www.who.int/water_sanitation_health/wastewater/wwuvol2intro.pdf
CDPH (2014) Regulations related to recycled water. California Code of Regulations.
California Department of Public Health, Sacramento, California, USA.
12
EEA (2012) Towards efficient use of water resources in Europe. EEA report No 1/2012.
European Environment Agency, Copenhagen, Denmark.
13
Annex 1a – Water reuse in impact assessment of Blueprint (excerpt)
The Commission has been considering the issue of water reuse for a number of years and has
documented its findings to date in several steps. In the 2012 Communication "A Blueprint to
Safeguard Europe's Water Resources" (COM(2012) 673) water reuse for irrigation or
industrial purposes was found to have a lower environmental impact and potentially lower
costs than other alternative water supplies, whereas it is only used to a limited extent in the
EU. A Fitness check of EU Freshwater policy (SWD(2012) 393) published in November
2012, as a building block of the Blueprint, assessed the performance of the measures taken,
both in environment and in other policy areas, in achieving the objectives already agreed in
the context of water policy. It also identified the major gaps to be closed in order to deliver
environmental objectives more efficiently. In relation to wastewater reuse, the Fitness check
concluded that "alternative water supply options with low environmental impact need to be
further relied upon" in order to address water scarcity. A particular issue emphasised by
stakeholders in the public consultation of the Fitness Check was the lack of EU common
quality requirements for reuse of wastewater in irrigation. Several policy options to promote
water reuse were considered in the impact assessment of the Blueprint (SWD(2012) 382)
The following are more detailed excerpts from the relevant sections of the above mentioned
documents, including the major gaps identified, whose closure can be partly addressed with
increased water reuse:
Fitness Check of EU Freshwater Policy – SWD/2012/3931
2.3. Gaps - Managing water demand and availability
Moreover, alternative water supply options with low environmental impact such as water re-
use need to be further relied upon. In this context, a particular issue that was emphasised by
industry stakeholders in the public consultation was the lack of EU standards for re-use of
waste water in irrigation. The concern expressed is that the lack of EU-level standards could
inhibit free movement of agricultural produce in the single market and inhibit investment by
the water industry.
2.5. Appropriateness of Policy instruments
The slow progress in relation to water efficiency in buildings and agriculture or on alternative
water supply sources such as water re-use also raises questions about the relevance of
continued reliance on voluntary approaches.
5.2. Coherence within EU water policy
It should be noted that the issue of re-use of waste water for different purposes (such as
irrigation or industrial uses) is not specifically addressed by EU water policy through EU
wide re-use standards (public consultation and stakeholder workshop). Although relevant to
the Urban Waste Water Treatment Directive, this is not an issue of coherence between water
legislation, but rather a gap in the policy framework (see section on relevance).
1
http://ec.europa.eu/environment/water/blueprint/pdf/SWD-2012-393.pdf
14
A Blueprint to Safeguard Europe's Water Resources - COM(2012) 673
2.4. The vulnerability of EU waters: problems and solutions
In the stakeholder consultations leading to the Blueprint, one alternative supply option – water
re-use for irrigation or industrial purposes – has emerged as an issue requiring EU attention.
Re-use of water (e.g. from waste water treatment or industrial installations) is considered to
have a lower environmental impact than other alternative water supplies (e.g. water transfers
or desalinisation), but it is only used to a limited extent in the EU. This appears to be due to
the lack of common EU environmental/health standards for re-used water and the potential
obstacles to the free movement of agricultural products irrigated with re-used water. The
Commission will look into the most suitable EU-level instrument to encourage water re-use,
including a regulation establishing common standards. In 2015, it will make a proposal,
subject to an appropriate impact assessment, to ensure the maintenance of a high level of
public health and environmental protection in the EU.
Table 4
Blueprint's proposed action Who will take it? By when?
Propose (regulatory) instrument on standards for water re-
use.
Commission 2015
3. CONCLUSIONS AND OUTLOOK FOR EU WATER POLICY
The Commission will consider developing a regulatory instrument setting EU-wide standards
for water re-use, thereby removing obstacles to the widespread use of this alternative water
supply. This would help alleviate water scarcity and reduce vulnerability.
Impact Assessment (IA) of the Blueprint - Executive summary (SWD/2012/381)2
1. PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES
[…] Overall, stakeholders were supportive of non-legislative EU action to tackle water
problems. […] Some legislative options were also supported, such as a possible new
regulation on water re-use standards. […]
2. POLICY CONTEXT, PROBLEM DEFINITION AND SUBSIDIARITY
Second, there is a risk that the WFD goals will not be achieved because of a lack of
integration and coherence with other policy areas […], further support is needed:
[…](7) for the uptake of water re-use through common EU standards.
2
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52012SC0381R(01)
15
5. IDENTIFYING THE PREFERRED OPTIONS PACKAGE AND ITS IMPACTS
The assessment of the options can be considered as a screening of the various approaches for
each of the 12 issues identified. On the basis of the assessment performed, it appears that in
most of the cases, the most appropriate options fall under a guidance approach. The regulatory
approach is recommended for only 3 issues (water efficiency in appliances/water related
products, water re-use and knowledge dissemination) as the current policy context, in
particular with respect to the implementation of the WFD and the MFF, leads to postponing
most of the regulatory and conditionality policy options to a later stage. The preferred options
are those in red and underlined in table 1.
Table 1: List of options considered in the Impact Assessment - options in red and underlined
are retained
Approaches
specific objective a) Voluntary b) Regulation
c)
Conditionality
d) Priority in funding
7 Water reuse
CIS
Guidance
CEN
standard
Regulation n/a Under CSF &
EIBloans
Impact Assessment (IA) of the Blueprint - SWD/2012/3823
 Impact Assessment report (Part I)
2.4 Problem definition for the Blueprint (pg. 18)
2.4.2. Lack of policy integration in support to specific measures
Even if a proper implementation of economic and communication instruments can help for a
further uptake of measures that can provide a cost-efficient response to water resource
problems, there are cases for which additional support from policy and funding instruments is
needed:
…
 The lack of common EU standards for water re-use for agriculture and industrial
uses limits a potentially important alternative water source - especially for water
stressed areas where this option could be cheaper than desalinisation or transfers19.
The lack of common health/environmental standards threatens farmers using re-used
water to irrigate crops for export within the single market and prevents industry from
making long-term investment decisions. It also constitutes a barrier for innovation.
2.7 The need to act at EU level (pg. 29, 31)
Lack of integration of water issues into other policies (pg. 31)
3
http://eur-lex.europa.eu/legal-content/fr/TXT/?uri=CELEX:52012SC0382
16
 The main barrier to expansion of water re-use is the lack of common standards at EU
level, in particular in agriculture. While guidelines for agricultural water re-use have
been defined by the World Health Organisation36, and by different countries, such as
the USA37 and Australia, a uniform solution for Europe is lacking. Establishing
standards for the functional operation of the single market is an appropriate EU level
response, taking into account EU Health, Agriculture and Energy policies.
4. Policy options (pg. 36)
4.7 Water re-use (pg. 39)
The problem analysis highlighted that a critical problem to address in the Blueprint is that
there are no common standards for waste water reuse. Taking account of the detailed problem
analysis and baseline, the following options were identified to be assessed within the Impact
Assessment:
 develop CIS guidance on certification schemes for water re-use (Option 7a1),
 the Comité Européen de Normalisation (CEN) to adopt standards water re-use (Option
7a2),
 an EU Regulation establishing standards for water re-use (option 7b), and
 provision of funding through Cohesion Funds and/or EIB loans (Option 7d).
5. Analysis of the impacts of the options (pg. 41)
5.7 Water re-use (pg. 44)
The options concerned with water re-use all seek to stimulate the re-use of waste water in
agriculture as a means of providing an alternative water supply and so reduce the pressure on
surface and ground water sources and provide a stable supply to users in times of scarcity and
drought. The impacts of water re-use are, therefore, common to all of the options and largely
only differ to the extent that the options would be effective at stimulating water re-use.
The primary economic benefits of water re-use are to the agriculture sector and water industry
sector. Water re-use ensures to farmers and horticulturalists a more reliable water supply, less
dependant on precipitations, as it benefits from the priority given to drinking water in periods
of drought, leading to more certainty in economic investment. Furthermore, farmers can
benefit from nutrients contained in waste water, so reducing their costs for the use of
fertilisers. The water industry sector benefits from alternative water treatment requirements,
which can be less stringent and, therefore, less costly than requirements for treatment for
discharge to surface waters.
The economic benefits translate into social benefits. Security of the agricultural producers
enables jobs to be secured, providing benefits to local communities. Furthermore, it can
enable traditional agricultural production to continue in water stressed areas that would
otherwise be under threat from water scarcity and so maintain cultural traditions. However,
health concerns do arise from the re-use of water for agricultural products. Therefore, the
standards proposed to be adopted for options 7a, 7b1 and 7b2 would all be required to meet
the necessary health standards. Furthermore, funding (option 7d) should only be provided to
schemes which guarantee health standards are to be complied with.
The environmental benefits are proportional to the reduction in pressure on surface and
ground waters from supply of re-used water as an alternative to abstraction. Ecological flows
are more likely to be maintained, protecting aquatic ecosystems and, therefore, helping to
meet WFD requirements. Furthermore, diversion of waste water to agriculture may result in
less discharge of nutrients, etc., to surface waters.
17
The extent of these impacts is proportional to the effectiveness of the options. The primary
problem facing water re-use is the lack of EU-level standards which could result in different
standards across the Member States, leading to barriers in the trade of agricultural products.
Voluntary standards (option 7a1) developed at EU level would provide a basis for a common
approach, but the option cannot prevent Member States adopting a different approach and,
therefore, cannot prevent barriers in the internal market. CEN standards (option 7a2) might be
more likely to be adopted by Member States, but they suffer the same flaw as option 7a1. A
Regulation (option 7b) does not have this problem and would guarantee that internal market
barriers would not arise. The development of each of these options has similar costs, although
the direct applicability of a Regulation would have lower burdens on Member States as it
would not require transposition. The public consultation and stakeholder views all show more
support for a binding Regulation as the effective means to overcome the problem compared to
the other options. The option would be fully coherent with other EU water law and policy.
Option 7d (funding) is not an alternative to the other options, but can accompany any of the
other options. Given public and private expenditure constraints, investment in water treatment
and distribution for irrigation is constrained in some regions. Areas eligible for Cohesion
Funds and EIB loans can benefit from additional investment support. The effectiveness of this
option (and the resulting economic, social and environmental impacts) would be directly
proportional to the level of available investment.
6. Identifying the preferred options package and its impacts (pg. 48)
6.1 Proposed package (pg. 49)
 Regarding water re-use there is a need to ensure the effective operation of the internal
market to support investment and use of re-used water. The assessment, including
stakeholder consultation, found that this can only be achieved through the development of
new regulatory standards at EU level. Therefore, the preferred option is for the
Commission to pursue appropriate health/environment protection standards for re-use of
water and, subsequently, to propose a new Regulation containing these subject to a
specific impact assessment.
 Annex to the Impact Assessment report (Part II)
2.2. Measures improving water availability (pg. 35)
2.2.1. Description
Desalination is the specialised treatment method used to remove dissolved minerals and
mineral salts (demineralisation) from the feed-water (fresh water, brackish water, saline
water, but mainly from sea water) and thus to convert it to fresh water mainly for domestic,
irrigation or industrial use. In Europe, several countries have turned to desalination
technologies, especially in the southern more water scarce areas. Several Member States use
desalination as an alternative water supply source to remedy water stress situations. In 2008
Spain had the largest desalination capacity in the EU with up to 713 Mm3/day. Malta had a
desalination capacity of 14 Mm3/day (more than 45% of its total water needs), while Italy
reached around 0,75 Mm3/day, and Cyprus around 0,093 Mm3/day (TYPSA 2012). More and
18
more Northern European Countries also use this option. For example, in the UK, the company
Thames Water has built a desalination plant for meeting the future water demands of the
London metropolitan area.
Water transfers – are used to transfer water from one river basin where water is considered
abundant to another one where water is scarce. The interbasin transfer of water, when
implemented on a large scale, is one of the most significant human interventions in natural
environmental processes. Water transfer has potential for substantial beneficial effects
through alleviation of water shortages that impede continuing development of regions without
adequate local water supplies. But transfer also has potential to limit future development of
the area of the transfer's origin and to produce other negative effects.
Groundwater recharge is a hydrologic process where water moves downward from the soil
surface towards groundwater. Recharge occurs both naturally (through the water cycle) and
man-induced (i.e. artificial groundwater recharge), where rainwater, surface water and/or
reclaimed water is routed to the subsurface. Artificial groundwater recharge aims at the
increase of the groundwater potential. This is done by artificially inducing large quantities of
surface water (from streams or reservoirs) to infiltrate the ground. It is commonly done at
rates and in quantities many times in excess of natural recharge. The number of aquifer
recharge and re-use schemes in Europe, and around the world, has expanded in recent years.
The primary driver for this expansion has been the increasing demand for water to meet
agricultural, industrial, environmental, and municipal needs. In southern Europe, the uptake is
predominantly motivated by agricultural and municipal water needs, whereas in Northern
Europe groundwater recharge is mostly found in densely populated areas for use in
households (e.g. Berlin, The Netherlands).
Dams and reservoirs for water storage can be potentially used in most water scarce areas,
where water efficiency measures can't fully resolve the problem. A dam is a barrier that
produces changes in the hydro-morphological and physico-chemical conditions of the
impounded river. River damming is one of the most ancient techniques used for water supply.
Large dams have long been promoted as providing "cheap" hydropower and water supply,
reducing also flood impacts to populated floodplains. A reservoir is natural or artificial pond
or lake used for the storage and regulation of water. Reservoirs may be created in river valleys
by the construction of a dam or may be built by excavation in the ground or by conventional
construction techniques. These measures, in general, are considered more expensive and
might have significant negative impacts to the environment.
There are two types of water re-use: direct and indirect. Direct wastewater re-use is treated
wastewater that is piped into a water supply system without first being incorporated in a
natural stream or lake or in groundwater. Indirect wastewater re-use involves the mixing of
reclaimed wastewater with another water supply source before re-use. The mixing occurs for
example when the groundwater is too saline and needs to be improved by the treated waste
water. Re-use of treated wastewater is a valuable resource for water supply in areas where
water is limited. It has the potential to become an alternative source of water after relevant
treatment. It could be used for irrigation in agriculture, industrial uses and specific uses in
buildings provided that all relevant safety standards are respected. Re-use of treated
wastewater is an accepted practice in several European countries with limited rainfall and
very limited water resources, where it has become already an integral effective component of
long term water resources management. However, only a few countries developed
comprehensive reuse standards. Strict quality controls to minimise the risk of environmental
19
contamination and human health problems due to water re-use. In addition, proper household
metering and water pricing strategies are important drivers for the implementation of water
reuse systems.
Rainwater harvesting is the process of collecting, diverting and storing rainwater from an
area (usually roofs or another surface catchment area) for direct or future use. This is a
technology that can be used to supply water to agriculture, households and industry.
2.2.2. Key information on the cost-effectiveness (risks and benefits)
In theory alternative water supply options, especially desalination, can deliver unlimited
amount of water. In practice all the options have a lot of limitations in terms of costs and
negative economic, environmental and social impacts. Cost-effectiveness of the options is as
follow:
Desalination plants involve high capital costs, maintenance and operational costs and
recurrent costs, because of its reliance on high energy requirements and if its location is far
from urban areas a distribution network needs to be installed to transfer desalinated water to
the mains water supply. It affects the cost-effectiveness of desalination bringing high
desalination costs (0,21 – 1,06 Euro/m3). Distribution costs of desalinated water: to transport
1 m3 of water is estimated at 0.037 € per 100 m of vertical transport and 0.043 € per 100 km
of horizontal transport. Other costs, related to the pre-treatment and the concentrate disposal,
has to be also considered within the desalination process. Miller (2003) estimates pre-
treatment costs to account for up to 30% of O&M costs while Younos (2004) estimates the
costs of brine disposal between 5 to 33% of total desalination costs (Ecologic, 2008).
Development of the water transfer infrastructure involves very high costs. Example from
England: the capital cost of water transfer infrastructure (to meet demand for water in south
east England) is estimated to be between £8 million to £14 million per megaliter, which is 4
times more than developing new resources in south east. To transport 1 m3 of water is
estimated at 0.037 € per 100 m of vertical transport and 0.043 € per 100 km of horizontal
transport (EA 2006).
Concerning water recharge costs of water supply are lower than in the case of desalination or
water transfers. It is mainly owing to lower investment, treatment and distribution costs. In the
Belgian case study cost of producing water from ground water recharge was estimated to be
0.5 €/m³, which was cheaper than transferred water from outside the region (0.77 €/m³) (in
2007) (TYPSA 2012). There is no need of large storage structures to store water. Structures
required are mostly small and cost-effective and less evaporation losses are produced. An
extensive and expensive tertiary treatment is required for using waste water to recharge
ground waters (although in most situations in the EU these are in place in any case). Strict
quality controls to minimise the risk of environmental contamination and human health
problems are needed, what entails costs, which should be taken into consideration.
Costs effectiveness of storage reservoirs seems to be the most expensive water supply option.
In UK costs of winter storage reservoirs are calculated as follows: lay-lined reservoirs:
€3.20/m3 to 6,70 EUR/m3, Reservoirs with a synthetic liner: 4,90 EUR/m3 to 15,80 EUR/m3,
including energy (CO2) from pumping twice (from borehole/river to reservoir; and from
reservoir to field) (BIO 2012). In Australia case study expanding reservoir capacity costs were
estimated on AUD 2,40/ kL (OECD 2011). However overall benefit (to farmers) of moving to
20
irrigation reservoirs is estimated at 14 EUR/m3 to 27 EUR/m3 as well as additional (non-
monetised) benefits associated with improved security and flexibility of supply (case study
from UK) (BIO 2012). Those benefits should be taken into account while considering water
supply alternatives.
One of the most cost promising water supply alternatives is water recycling. The capital costs
are low to medium for most wastewater re-use systems and are recoverable in a very short
time. Experience from Australia: cost of recycling urban storm water (for non potable) – AUD
1,20-2,00 /kL; (for potable) – AUD 1,30-1,70 /kL; recycling treated sewage water – non-
potable AUD 1,90/kL; potable AUD 2,50/kL (OECD 2011). Costs of waste water irrigation
even tend to be lower than for groundwater irrigation, because the pumping effort needed is
lower. However wastewater re-use may not be economically feasible if it requires an
additional distribution network and storage facilities. Strict quality controls to minimise the
risk of environmental contamination and human health problems are needed, what entails
costs, which should be taken into consideration.
Total treated wastewater life cycle cost converted into €/m3 (TYPSA 2012):
Reuse alternative Recommended treatment
process
Annual costs (€/m³)a, b
Agriculture Activated sludge4
0.16-0.44
Livestock Trickling filter 0.17-0.46
Industry and power
generation
Rotating biological contactors 0.25-0.47
Urban irrigation – landscape Activated sludge, filtration of
secondary effluent
0.19-0.59
Groundwater recharge –
spreading basins
Infiltration – percolation 0.07-0.17
Groundwater recharge –
injection wells
Activated sludge, filtration of
secondary effluent, carbon
adsorption,
reverse osmosis of advanced
wastewater treatment effluent
0.76-2.12
Cost effectiveness of rain water harvesting is related to the need of financing the capital
investments and operation/maintenance costs for relatively large storage tanks in situations
where there is a poor rainfall distribution. These cost are relatively high as presents
experiences from different countries: Australia - cost of rain water tanks – AUD 3,75/kL
(OECD 2011); in Belgium a RWHS for private households requires a large investment and
the price reaches the value of around €1.8 to 4/m³ of RW used. The regulation specifies
minimum requirements that aim at a cost-efficient introduction of RWHS. On the other hand,
the savings amount to €1.7/m³ for avoided use of mains water. As with current regulations,
the costs for sewage and sewage treatment are recovered on the basis of m³ of mains water
used, the RW user benefits from an additional €2/m³ for avoided costs for sewage and sewage
treatment; in Malta the estimated cost of using the water produced by a RWH system reaches
the value of €5 to 11/m³ depending on the varying construction costs.
4
Could also be natural low-cost treatment systems such as stabilisation ponds, constructed wetlands, or
other like trickling filter, rotating biological contactor (footnote 16 in the IA of the Blueprint).
21
According to expertise the water saving potential for measures which are associated with rain
water harvesting (rain water flowing from a roof is transferred via a pipe to a container in
order to be used, for example, for gardening or car wash activities) is expected to meet up to
80% and 50% of households needs in France and UK, respectively (ACTeon et al., 2012).
Concerning water harvesting in agriculture the overall benefit (to farmers) of moving to
irrigation reservoirs can be estimated at 14 EUR/m3 to 27 EUR/m3 (discounted over 25 years
at 4%), or annualised benefits of 0,80 EUR/m3 to 1,55 EUR/m3 per year (BIO 2011).
Economic impacts
 Provision of adequate and reliable water supply in urban areas encourages general
economic development;
 Guarantee of water supply during peak water demand periods (e.g. the tourist season),
and because of its reliability it can support other and new economic activities;
 High investment and O&M costs related to treatment and distribution.
 In case of water storage reservoirs the need to devote a land, which otherwise could be
used for some economic activities should be considered. The location of desalination
plants also implies land-use planning issues: they are mostly located in coastal zones
(already densely populated), and have impact on the value of land – “not in my back
yard”.
 In case of water reuse there are some additional positive economic impacts:
o Reusing the total volume of treated wastewater in Europe could cover nearly
44.14% of the agricultural irrigation demand and avoid 13.3% of abstraction
from natural sources (Defra 2011). In Israel of all sewage that is treated, 75.5%
(358 Mm³) is used for irrigation, representing 40% of the total water use in
agricultural irrigation. Recently assessments point that the percentage had risen
to 87% by 2007 and the objective is to reach 95% of reclaimed water by the
end of the decade (Defra 2011).
o use of the nutrients of the wastewater (e.g. nitrogen and phosphate) resulting to
the reduction of the use of synthetic fertilizer and, reduction of treatment costs
(reclaimed water, can be used for agricultural irrigation, landscape irrigation,
industry, and non-potable urban uses). However there are some technological
restraints related to crop type, presence of chemicals/nutrients not
synchronized with crop requirements in using treated wastewater.
The potential of the water reuse source hasn't been exploited so far in Europe: by 2006 the
total volume of reused treated wastewater in Europe was 964 Mm³/yr, which accounted for
2.4% of the treated effluent. The treated wastewater reuse rate was high in Cyprus (100%) and
Malta (just under 60%), whereas in Greece, Italy and Spain treated wastewater reuse was only
between 5 % and 12 % of their effluents. Nevertheless, the amount of treated wastewater
reused was mostly very small (less than 1%) when compared with a country’s total water
abstraction (TYPSA 2012).
Water reuse and desalinisation require a continue enhancement of technologies in order to
lower the use of energy and minimize environmental impacts on the aquatic environment.
This is, therefore, an area for investment in innovation to ensure the cost-effectiveness of
measures. Unlike water transfers, that increase water supply in one basin, at the expense of
other basins, desalination has the advantage of decoupling water production from the
hydrometeorological cycle.
22
Rainwater harvesting can have strong economic impact by reducing water costs paid by
households, agriculture or industry to pay for mains water supply. The economic potential of
this supply option is estimated very high. Rainwater harvesting could save 20 to 50% of the
total potable water use in a standard home, whereas grey water recycling could save 5 to 35%,
as seen in the UK experience (Bio Intelligence et al., 2012). In Bedfordshire, one of the drier
parts of England, the MAAF study showed that one hectare of roof area might theoretically
provide sufficient water to irrigate 2,5 hectares of potatoes (at 80% efficiency).
Environmental impacts
All alternative sources of water supply reduce the demand on mains water supplies and reduce
pressure on environment.
Most of alternative supply options are related to the intensive use of energy. Among them the
most energy consuming is desalination. If the energy is from using the use of fossil fuels, this
will increase GHG emissions. This is linked to the higher amounts of energy needed to desalt
water (between 3.5 and 24 kWh/m3 according to the technology), especially with thermal
processes. On the basis of an average European fuel mix for power generation, it has been
estimated that a revers osmosis plant produces 1.78 kg of CO2 per m3 of water, while thermal
multi stage flash leads to 23.41 kg CO2/m3 and multiple effect distillation to 18.05 kg
CO2/m3 (Ecologic 2008).
Example from Spain: it was estimated the desalination installation at Carboneras – Europe’s
largest RO plant - uses one third of the electricity supplied to Almeria province. The more
than 700 Spanish desalination plants produce about 1.6 million m3 of water per day.
According to the estimates (1.78 kg of CO2 per m3 of water) on CO2 production from
desalination, this translates into about 2.8 million kg CO2 per day. It can be argued therefore
that desalination is contributing significantly to Spain’s overall GHG emissions, which have
been skyrocketing to +52.3% in 2005 compared to 1990 levels – moving Spain well beyond
its European burden sharing target of +15%. This may be a foretaste of the dilemmas that will
face other Member States in future years as the impacts of climate change are felt increasingly
widely (Ecologic 2008).
Other environmental impacts of desalination varying severity depending on local conditions
are on the aquifer and on the marine environment as a result of the concentrated brine
management and water treatment and plant maintenance activities, water intake activities, and
noise.
Water transfers and water supply projects, such as the construction of reservoirs and dams or
irrigation schemes have significant negative environmental impacts in terms of biodiversity,
wetlands, water availability and environmental flow. There are big uncertainties regarding
how much water will be able to be transferred in the future.
Additionally construction of reservoirs and dams or irrigation schemes, can have negative
consequences on biodiversity, especially in water scarce areas. As an example, planned
irrigation schemes in the water poor Ebro basin in Spain were linked to significant declines in
bird distribution (ACTeon et al., 2012). It is contributing as well to the discontinuity along the
river, impeding fish species to reach their spawning grounds and is responsible for blocking of
sediment transport to the sea is the main responsible of deltas and beaches regression.
23
Groundwater recharge reduces the threat of over-exploitation of existing aquifers, and
decreases the risks of seawater intrusion into aquifers at or near the coast. It guarantees
available for both the economy and the environment surface and groundwater resources
during summer and drought periods. Fewer evaporation losses are produced, contrary to dam
or impoundment alternatives, that in southern countries could reach levels up to 1m/year
(TYPSA 2012). In the contrary it reduces pressure on water bodies from reduction in summer
abstractions.
Waste water reuse not only reduces the demands of freshwater, but can also reduce the
pollution of rivers and groundwater by nutrients. From another side if there is no strict quality
controls, there could be the risk of environmental contamination and human health problems
(water-borne diseases and skin irritations).
The direct waste water reuse in households results in increased GHG emissions in existing
homes, whereas its installation in new homes, alongside with other water efficiency measures,
shows net carbon benefits. Different biological and bio-mechanical systems apply to single
residential dwellings, commercial buildings or multi-use buildings. These systems have
different operational energy and carbon intensities. For grey water reuse, the latter range from
0.6 kWh/m3 for short-retention to 3.5 kWh/m3 for small membrane bioreactors (Bio
Intelligence et al., 2012).
The same environmental impact concerns rain water harvesting. The need of construction and
maintenance of the necessary infrastructure may lead to negative energy/treatment/GHG
impacts. The retrofitting of household rainwater harvesting results in increased GHG
emissions in existing homes, whereas its installation in new homes, alongside with other
water efficiency measures, shows net carbon benefits. Different biological and biomechanical
systems apply to single residential dwellings, commercial buildings or multi-use buildings.
These systems have different operational energy and carbon intensities. For rainwater
harvesting, the latter range from 1.0 kWh/m3 for direct feed to 1.5 kWh/m3 for header tank
(Bio Intelligence et al., 2012). For water harvesting in agriculture the same negative effects
should be taken as those identified for water storage (dams and reservoirs).
The positive environmental impact of rain water harvesting is the reduction of the amount of
urban storm runoff due to its buffering effect on storm events, which in turn reduces the
amount of pollutants being washed into surface waters that are used to recharge shallow
groundwaters.
Social impacts
In general alternative water supply alternatives provide adequate and reliable water supply in
urban areas and encourage general economic development and job creation.
Water transfers provide right distribution of benefits between the area of transfer origination
and area of water delivery. However by contributing to the development of regions without
adequate local water supplies it may limit future development (economic productivity) in the
area of the transfer's origin. It can cause problems of inter-regional or international fights for
water rights, as drought extreme events are complex to manage.
Water storage change land use in the region, which can lead to low social acceptance.
24
The general public or specific groups may refuse to consume products that are associated with
the waste water re-use – the so called “yuk” factor.
There is the potential for impacts on health arising from these options (which would be
stronger with a regulatory approach). These impacts would depend on whether building
standards included requirements for re-use of water within the buildings (which would,
therefore, need to be subject to subsequent IA if this were proposed). Reduced water flows
can result stagnate in pipes, leading to microbial growth, although this concern is largely
theoretical at present and currently design and control have reduced this problem. With regard
to rainwater harvesting and to grey water reuse health issues are linked especially to
installation, maintenance and operation of these sources. Stored rainwater can be
contaminated with Enterococci (EUREAU 2011b). Also, back-wash systems (as part of the
design of a reuse system for maintenance and cleaning) could contaminate drinking water
supplies.
Having said this, public perceptions of possible health impacts are a barrier. Actions to
control water quality include health codes, procedures for approval of service, regulations
governing design and construction specifications, inspections, and operation and maintenance
(US EPA, 2004) and standards have been adopted in national law (e.g. France, Spain and UK)
for rainwater harvesting and grey water re-use to address this issue.
Poorer families will not have the financial resources to invest in the technology of water
harvesting, and reap the benefits of lower water costs. The same concerns tenants who will
not have the opportunity to reap the benefits of lower household water costs, as landlords do
not benefit from this type of investment.
2.2.3. Barriers for implementation
Market failures, regulatory and policy support
There is the lack of the application of best practices in integrated water management by water
managers at a national or basin level to produce RMBPs that are coherent and cost effective.
In general at a national or basin level the institutional or administrative structures are not in
place. It causes problems in the development and implementation of an integrated water
resource management plan for the administration, management, protection and sustainable
development of the raw water resources at a basin and water body level.
The existing RMBPs hardly apply the principles of: polluter pays, cost recovery, cost
effectiveness and disproportionate costs. It means that they do not meet society’s overall
water objectives for quality and quantity i.e. a RBMP that is harmonized with socioeconomic
development objectives resulting in water bodies that will achieve good ecological status.
There is the lack of coherence between the RBMPs and other sectorial plans resulting in
inability of basin mangers to fully evaluate the costs and benefits between measures in order
to select the most cost effective ones for society. For example: there is lack of sufficient
linkage with related policies such as CAP, land-use planning; artificial water storage very
often is not in line with rural development rules and existing legislation (too strict existing
standards).
25
There is a general lack of clear institutional roles between water resource managers
(responsible for quantity and quality) and competent authorities for environment whose focus
is on water quality and the environment. The efficient and cost effective management of water
resources requires the management and implementation of measures that are for the common
and cost effective good of multiple users and are not solely linked to one user or user group.
This requires an institutional framework with the capacity to administrate, evaluate, select and
manage the implementation of common water resource.
Lack of full cost recovery of water services, including financial, environmental and resource
costs makes difficult to take economically and environmentally sound decisions on the choice
of best water supply option.
There is lack of guidelines or criteria for water reuse taking into account regional
characteristics. The absence of an EU regulatory framework presents a significant barrier as
standards commonly agreed terminology are the basis for the success of water reuse projects.
The lack of standards has caused administrations to take a rather conservative approach and
has led to mistrust and misunderstandings regarding users who do not have of trust, credibility
and confidence, especially in the agricultural sector. In some countries the governing
standards put unnecessary limits on the use of the treated waste water or led to illegal uses.
Lack of financing is considered the single most significant barrier to wider use of reclaimed
wastewater.
Reclaimed water is not the only source available for groundwater recharge, also water excess
due to floods or wet periods are available to be naturally (ponds) or artificially (wells)
injected. When treated wastewater (expensive tertiary treatment is needed) is used for
groundwater recharging there is a need to have strict controls to ensure that no pollution
problems to the groundwater bodies appear.
Financing sources
Lack of financial incentives and of sufficient information on the available techniques, best
practices and the benefits of using treated waste water or harvested rain water put limits to the
use of these alternative water sources.
Important barrier to the implementation of alternative water sources are the high costs
associated with them. When current water supply is provided from cheap local sources
(groundwater or surface water), water produced by desalination or ground water recharge are
likely to be more costly. In these cases it is not financially obvious to introduce these water
supply options, especially if the current water prices do not reflect all the economic costs, nor
the environmental and resource costs. Costs per m³ water produced may be very different for
similar technologies or supply options in the different Member States that implies that the
barriers for implementation vary country by country.
Lack of implementation and coordination
There is a need of a high quality monitoring system and quality assurance for consumer's
acceptance (concerns especially water reuse, water recharge and rain water harvesting).
26
Desalination can be a replacement for potable water supply purposes, although its supply
regime is rigid and inflexible, and so is best suited for supplying a fixed amount of water
(according to its design specifications). There are, particular environmental and economic
concerns about the high energy requirements of the desalination process, meaning that
mitigation measures are needed to either improve efficiency or incorporate the use of
renewable energy resources. In addition, there are also concerns about the impact on the
environment of disposing brine – meaning that adequate mitigation measures have to be
incorporated to deal with brine disposal. These concerns are an opportunity to develop new
technologies, that more efficient, with less environmental impact.
There are problems to find available land for construction of big desalination plants.
Knowledge base
In the context of river basin planning, water reuse options tend to be excluded or forgotten as
stakeholders are not well informed about the link between water supply and wastewater
treatment. As such, research results from feasibility studies on water use have not been taken
up in practice, especially in areas where water supply and wastewater are managed by
different companies or agencies.
Interbasin water transfer proposals needs thorough evaluation to determine if they are justified
considering all associated impacts. There are uncertainties concerning water availability in the
future (how much water will be available to be transferred).
Investments in artificial water storage and the creation of new resources should be based on
economic analysis. They usually bore high investment, maintenance and operation costs, long
investment procedures and significant potential impacts on the environment that have to be
taken into consideration. They should be considered as an option when other options to
improve water efficiency, including the application of economic instruments have been
implemented.
2.2.4. Degree of implementation as reflected by the RBMPs
The development or upgrade of reservoirs or other water regulation works is included in about
30% of the RBMPs, development or upgrade of water transfer schemes in 23%. Measures to
foster aquifer recharge are included in 33% of the plans.
The development or upgrade of desalination plants (in about 1% of the plans) and the
establishment of water rights markets or schemes to facilitate water reallocation (in about 2%
of the plans) are the least considered.
There is little quantitative information on the waste water reuse. While at EU level water
reuse amounts to less than 1% of the countries' total water abstraction, in Cyprus and Malta
the treated wastewater reuse rate of their effluents is high (respectively 100% and 60%)
(TYPSA 2012). This currently under-exploited measure has a high potential. Nevertheless
treated waste water reuse and rainwater harvesting are not identified as main measures in the
RBMPs. According to the preliminary analysis of RBMPs there were no measures related to
WWR and RWH included in almost 50% of the assessed RBMPs.
2.2.5. Key EU policy instruments that would unlock / guide the implementation
27
EU Policy instruments related to use of economic instruments
Economic incentives could help in ''unlocking'' the measures. This supposes the proper
implementation of the WFD economic principles of polluter-pays principle, the principle of
cost recovery, including environmental and resource costs. Alternative water supply is more
costly than conventional sources, especially if water prices do not cover all costs. It may be
difficult to introduce the measures without economic incentives such as temporarily applied
subsidies.
While choosing the best water supply option economic analysis taking into account full cost
recovery of water services, including financial, environmental and resource costs should be
the base to take economically and environmentally sound decision.
EU Policy instruments related to governance and integration
To strengthen the “quantitative dimension” of the WFD implementation by establishment of
systematic water balance assessment/water accounts at sub-catchment level and the dynamic
modelling of water resources for the preparation of next RBMP. This will provide information
on where and how water efficiency can be improved and which alternative water supply
sources should be developed in a cost-effective way.
Water reuse:
The key recommendation of the Mediterranean Component of the EU Water Initiative (MED
EUWI) Wastewater Reuse Working Group is to develop a commonly agreed European and
Mediterranean guidance framework for treated wastewater reuse planning, water quality
recommendations, and applications.
Awareness raising campaigns and advisory services could improve the public and user
awareness and acceptance of the water reuse. Improve implementation of cost recovery and
provision of economic incentives to promote and make water reuse cost effective.
Other sources:
The application of desalination and artificial recharge could be facilitated by improving the
political and public acceptance. Prior to starting such type of new investment an awareness
raising campaign and extensive consultation with the stakeholders and public should be
carried out. This should be combined with a high quality monitoring system for ensuring their
safe use and improving consumers' acceptance.
Since desalination facilities might have significant negative impact on the environment the
inclusion of these facilities under the scope of the IED (2010/75/EU) and EIA (85/337/EEC)
Directives should be considered.
EU Policy instruments related to funding
28
Implementation of alternative water supply measures requires high investment costs, so
potentially they can enter to the scope of EU funds financing. As they can trigger substantial
economic, environment and social impacts, there should be introduced strict assessment
procedures to allow their implementation and financing, only while efficiency measures are
fully addressed and can't resolve water shortage problems.
EU Policy instruments related to knowledge base
Further research and innovation activities:
 To get cost efficient and more environmental friendly techniques and technologies
available for desalination technologies.
 To develop available techniques, best practices and the benefits of using treated waste
water or harvested rain water.
 To adapt water markets.
29
Annex 2 - Synopsis report on consultation activities
I. Introduction
The consultation process for a possible new EU initiative on water reuse began in 2012 and
continued until July 2017 in various forms, both organised and ad hoc. The implementation of
the consultation strategy involved collecting and analysing input from a wide range of
stakeholders as well as two online public consultations with the aim to:
(1) Provide an opportunity to express views on the present and potential development of water
reuse in the EU, on the opportunity to further promote water reuse in different kinds of sectors
and on possible/desirable actions that could be taken at EU level;
(2) Gather specialised input (data and factual information, expert views) on specific aspects of
the benefits and barriers affecting the development of water reuse (e.g. available treatment
techniques and related costs, existing and planned legislation in Member States, risk
management approaches etc.) with the aim of filling the data and information gaps in view of
refining the policy options and preparing the impact assessment.
The following identified stakeholders' categories have been targeted in consultation activities:
 Scientific Committees [European Food Safety Agency (EFSA) and Scientific Committees
Scientific Committee on Health, Environmental and Emerging Risks (SCHEER)])
 EU Member States and public authorities responsible for water management
 Water users, in particular representatives of the farming sector
 Water industry, both water supply and sanitation and suppliers of technology
 NGOs active in the water area
 Academia and experts, research and innovation organisations
 Citizens and the general public;
 As well as other EU institutions
This document summarises the various contributions received5
and, based on the analysis of
this input, identifies issues that stakeholders regard as priorities when further developing
water reuse at EU level. These findings have been used in the preparation of the impact
assessment and the updating of the scientific basis of the proposal (the JRC report in Annex 7)
and will further be used to inform the decision-making process in view of a new instrument to
regulate specific aspects of water reuse at EU level (agricultural irrigation and aquifer
recharge).
In the consultation process, stakeholders also put forward a number of suggestions going
beyond the current scope of a possible instrument on water reuse at EU level and these will be
taken into consideration in future exercises addressing other aspects of water reuse.
5
http://ec.europa.eu/environment/water/reuse.htm
30
II. Consultation results by activities and stakeholder group
Scientific Committees
To ensure the proposal will be based on up-to-date scientific knowledge and will provide the
appropriate level of safety as regards human health and the environment, EFSA and SCHEER
were consulted on the penultimate version of the technical report developed by the JRC
(December 2016) which is mentioned above.
EFSA approved its technical report on 22 May 2017. It reviewed whether the methodology
used was appropriate, the defined food crop categories were appropriate, the proposed
minimum quality requirements were sufficient, and any risks had been overlooked.
Following its analysis, EFSA issued recommendations6
.
SCHEER delivered its scientific advice on 9 June 2017. It examined four questions: Is the
methodology used by the JRC considered appropriate? Do the proposed minimum quality
requirements provide sufficient protection against environmental risks that may be associated
with water reuse for agricultural irrigation and aquifer recharge? Do the proposed minimum
quality requirements provide sufficient protection against human health risks that may be
associated with water reuse for aquifer recharge? And have any risks been overlooked? The
SCHEER concluded that, while the methodology chosen was appropriate and the report
considers many important elements, the document is deficient in key details7
.
The opinions of the two scientific Committees have been duly taken into account in the
finalisation of the technical content of the proposal and its assessment in terms of health and
environmental impacts.
Consultation of experts in Member States and stakeholder organisations
Consultation took place in the framework of the Common Implementation Strategy (CIS) for
the implementation of the Water Framework Directive (WFD). Water reuse was discussed in
6 meetings of the former Working Group on the Programmes of Measures (September and
November 2013, March and October 2014, March and October 2015). A dedicated activity on
water reuse and an Ad-hoc Task Group (ATG) was included in the CIS work programme for
2016-2018 to accompany the development of related actions.8
EU Member States and public authorities responsible for water management
6
The EFSA opinion published on 10 July 2017 is available at
http://onlinelibrary.wiley.com/doi/10.2903/sp.efsa.2017.EN-1247/epdf
7
https://ec.europa.eu/health/sites/health/files/scientific_committees/scheer/docs/scheer_o_010.pdf
8
Information on the status of water reuse in EU Member States was collected and participants were invited to
feedback on draft versions of the IA support studies elaborated by consultants. A technical workshop on possible
minimum quality requirements on water reuse at EU level was organised by DG ENV and JRC in June 2015.
Meetings were held in March 2016, October 2016 and June 2017 and specifically discussed draft versions of the
JRC technical report. Draft elements of the impact assessment were also presented in order to collect feedback
and gather additional information. Expert Groups on the Groundwater Directive, the EQS Directive, the
UWWTD and on the Drinking Water Directive were also consulted.
31
During the detailed discussions held with Member States' experts, broad support for the
concept of water reuse was overall apparent, with some notable exceptions. Representatives
of those Member States currently already practicing water reuse in the relevant areas
(agricultural irrigation and aquifer recharge) have generally been more in favor. These include
notably Spain9
and Italy10
but also others (Cyprus, Malta, Portugal, and Bulgaria). France has
also expressed its support for an EU legal instrument.
Despite the political support expressed by the Council (see above), some Member State
representatives at technical level have expressed certain reservations about the initiative.
These include Germany11
, Austria12
and the Netherlands13
. At the latest meeting of the CIS
ATG on Water reuse, broad support for the EU initiative on water reuse was expressed.
Support for a legal instrument was particularly strong from Member States currently already
facing water scarcity and severe impacts of droughts and climate change. There were also
some positions expressed concerning the type of EU instrument, and a few Member States
seemed to prefer a Guidance document to an EU legal instrument as a starting point.
Consultation of water users (in particular farmers)
The farmers' association at EU level (COPA-COGECA) participated in the expert group
exchanges and issued a position in writing and participated in various conferences. They were
overall appreciative of the concept, stating that it will contribute to a more resilient farming
sector, help overcome pressures deriving from climate change and, in upcoming years, be not
only an alternative supply option but rather the most important source of clean water.
Challenges highlighted were the need to identify the right quality of water, whereby the
minimum quality requirements must take into account specific local needs and give
flexibilities to the regions and Member States. Reclaimed water for irrigation should be
nutrient-free as well as particle-free. Affordability of the proposed water reuse schemes
should be carefully considered. COPA-COGECA further indicated that the compliance should
be at the point where reclaimed water is discharged by the treatment plant. Finally, any new
9
Spain indicated its support and noted that as the objective is to promote rather than to prevent water reuse, the
legislation should be safe but also practical and manageable; in particular, there is a need to properly reflect on
the feasibility of the proposed minimum quality requirements. According to the Spanish experience setting limit
values for chemicals is challenging, also for those which can be crop nutrients. This should not prevent but
incentivise their recycling. The validation requirement proposed by the JRC for quality class A is considered
unrealistic; the proposed parameter is not technically appropriate and would also strongly disincentive existing
water reuse practices in ES.
10
Italy expressed support while indicating that the final instrument has to be realistic. Italy informed that there is
currently no practice with aquifer recharge, however a strong interest for the future. In relation to minimum
quality requirements for this purpose, parameters for chemicals (CECs) should be introduced as there is a risk of
contamination. The JRC report was considered a very good basis for a potential EU instrument on water reuse.
11
Germany indicated that water reuse is currently not an important issue in Germany (there are as of yet only 2
sites where water reuse for irrigation is practiced) and considers there is no need for a binding instrument on risk
management at this stage. The practical implementation of the instrument on water reuse was unclear. For
aquifer recharge a guidance document would be sufficient. For agricultural irrigation, the current minimum
standards proposed by JRC were not stringent enough.
12
Austria felt that for obvious reasons water reuse is not high on the agenda in Austria and it is considered that
the existing water acquis is currently sufficient to address this issue. Concerning the risk management
framework, a guidance document was considered as the most appropriate response and in relation to CECs,
Austria supported very much a holistic approach beyond the specific issue of water reuse.
13
The Netherlands referred to existing legislation being sufficient enough to address the problem; the EC
initiative not fully complying with the Better regulation principles and finally the scope of the initiative being too
narrow, whereas the Netherlands would rather appreciate a focus on integrated water management.
32
instrument should be light and not inflict administrative burden. It should only apply to those
practicing reuse.
Water industry, both operators of water services (water supply and sanitation) and suppliers
of technology for water treatment
The initiative is of interest to both operators of water services (water supply and sanitation)
and suppliers of technology for water treatment – e.g. European federation of national
associations of drinking water suppliers and waste water services (EUREAU), Water supply
and sanitation technology platform (WSSTP), European Centre of Employers and Enterprises
providing Public services (CEEP), European Irrigation Association (EIA), European Water
Association (EWA);
Positions taken by industry representatives have generally been supportive; they were aware
of the potential of harmonizing quality standards on water reuse for technological and
economic development. Water reuse is already happening in many countries and the demand
for reused water will continue growing due to climate change. Technologies exist to provide
safe reused water and scientific evidence shows that potential negative impacts can be
mitigated. In this respect, proper risk assessment and monitoring are key tools to ensure water
reuse safety. Private companies were by far the most positive across types of stakeholders
about the safety of water reused compared to other sources of freshwater (groundwater or
water from rivers).
The industry has, however, also highlighted a number of challenges, particularly potential
legal constraints and administrative burden related to the development of water reuse, as well
as the cost of implementation. They also mentioned the low price of freshwater compared to
reused water. For example, EUREAU, while overall supportive of the work on water reuse,
felt that possible EU requirements cannot be a “one size fits all” solution and must not be
imposed on Member States. In particular, they must reflect different water quality levels
depending on the intended use of treated water. It must remain economically viable on top of
protecting human health and the environment. Industry has also requested that the issue of
liability be clarified in a possible new instrument.
NGOs active in the water area (including European Environmental Bureau; WWF)
NGOs were generally supportive of the concept and work. They were, however, concerned
with the safety of reclaimed water and felt that a possible new EU instrument would need to
set minimum criteria that are stringent enough to ensure the needed protection of the
environment, as well as human health.
Consultation of academia and experts, research and innovation organisations
Within the European Innovation Partnership (EIP) on Water, several action groups set up in
recent years address water reuse, such as: Industrial Water Reuse and Recycling (InDuRe),
Water & Irrigated agriculture Resilient Europe (WIRE), Real Time Water Quality Monitoring
(RTWQM), Verdygo - modular & sustainable wastewater treatment. The European
Technology Platform for Water (WssTP) initiated by the Commission is also very active on
water reuse with a dedicated multi-stakeholders working group on water reuse. These groups
have been regularly informed about the initiative and invited to provide feedback on the
technical development of the proposal.
33
Representatives of academia and experts were strongly in favour of EU action for water reuse
for agricultural irrigation; however an EU action on aquifer recharge has not been supported
by all. They demonstrated particular interest in the approach that would be chosen concerning
risk perception and the proper protection of public health and the environment. A preference
for a risk-based approach as a key element to build trust and confidence was also voiced.
Other important elements were management practices, transparency and involvement of the
public.
Representatives of the research and innovation community had a preference for mandatory
EU minimum quality requirements which were seen as innovation-friendly if certain
conditions, such as the balanced scope of water quality parameters and stringency of limit
values, are met. They would boost R&I at all phases driven by the needs to demonstrate
technical performance, efficiency and reliability of conventional and new technologies
(filtration, disinfection, membranes, advanced oxidation, etc.), economic viability of water
reuse projects, and social and environmental benefits. In addition, new and innovative ways of
monitoring would be stimulated.
EU institutions
The Commission communicated to the Council and the Parliament its intention to address
water reuse with a new initiative in two Communications (COM(2012)673) and
COM(2015)614). The Council provided feedback in its conclusions on these two
Communications. It further elaborated on its expectations as regards the proposal in its
Conclusions on Sustainable Water Management (11902/16) under the Slovak Presidency (17
October 2016) which state that the Council
"EMPHASISES that water re-use, in addition to other water saving and efficiency measures,
can be an important instrument to address water scarcity and to adapt to climate change as
part of integrated water management; CALLS ON the Members States to take measures to
promote water re-use practices, taking into account regional conditions where appropriate and
whilst ensuring a high level of protection for human health and the environment, as water re-
use can also deliver benefits in terms of economic savings, environmental protection,
stimulating investments in new technologies and creating green jobs; STRESSES that well-
treated urban waste water can be re-used for a variety of purposes in the agricultural sector,
industrial applications, sustainable urban development and protection of ecosystems; and
NOTES with interest the intention of the Commission to present in 2017 a proposal on
minimum quality requirements for reused water in the EU;"
The Parliament expressed expectations as regards the initiative in its resolution14
on the
follow-up to the European Citizens’ Initiative Right2Water of 8 September 2015. Like the
Council, it expressed overall support to the concept of water reuse and the Commission's
intention to develop a dedicated instrument; the Parliament notably "72. Encourages the
Commission to draw up a European legislative framework for the reuse of treated effluent in
order, in particular, to protect sensitive activities and areas". A number of events were also
organised in the European Parliament by Members to discuss water reuse and the opportunity
of a new EU legislation15
.
14
http://www.europarl.europa.eu/sides/getDoc.do?type=REPORT&reference=A8-2015-0228&language=EN
15
e.g.: Breakfast meeting "The contribution of Water to Circular Economy – Practices of reuse across Europe”
in January 2016 by the EP Intergroup on “Climate Change, Biodiversity and Sustainable Development”; EP
34
The initiative was also considered by the Committee of the Regions, which, in its opinion16
on "Effective water management system: an approach to innovative solutions" of February
2017, states that it " supports the Commission's intention to put forward, in 2017 – as part of
the implementation of the Action Plan for the Circular Economy – a proposal for minimum
requirements regarding the reuse of water […], ensuring that there are no disproportionate
negative effects on other sectors, such as agriculture; The Committee of the Regions also
stressed that differences between regions in terms of water availability must be taken into
account. There should be no obligation to reuse water unless this can be
justified.Communication on the development of the initiative
A roadmap on the initial initiative "Maximisation of water reuse in the EU" was published in
September 2015 which was further elaborated and focussed in an inception impact assessment
published in April 2016. Both documents were provided with an on-line mechanism inviting
to provide feedback, but none has been received.
Dedicated Internet pages have been developed on DG ENV's Website providing information
on the policy context and the implementation of the action plan to promote water reuse in the
EU. Both pages reference all available information (e.g. IA support studies) and are regularly
updated. A functional mailbox ENV-WATERREUSE@ec.europa.eu was created and has
been used to communicate with citizens and stakeholders.
A public relations campaign was launched in January 2017 with the aim to effectively inform
about, explain, promote and increase awareness and support of the EU initiative on water
reuse as part of the circular economy (CE) package. This campaign was targeted to a few EU
Member States selected for their interest (countries already practicing water reuse) and
influence (countries that are active in the process of defining an EU action on water reuse
with regard to the initiative, tentatively: Belgium, Cyprus, France, Germany, Greece, Italy,
Malta, the Netherlands, Portugal and Spain. The target audiences are policy-makers and key
stakeholders (water service operators, farmers and operators in the food supply chain, water
intensive industries, NGOs etc.).
A Green Week session on Water Reuse took place on 5 June 2014 with the aim to present the
Commission work on water reuse, the US Guidelines on water reuse, the agricultural sector's
view on water reuse and the innovation potential of water reuse practices. Water reuse was
showcased again in the Green Week 2017 in a session focusing on green jobs and skills in the
water sector, with the objective to demonstrate how development and implementation of EU
environmental policies benefits people and the economy by creating green jobs.
III. Horizontal assessment
This section is a horizontal assessment of the views of those consulted on the need for EU
action and the scope and level of ambition of a potential new EU-level instrument, mainly
based on the results of the two online public consultations.
A first internet-based public consultation ran from 30 July to 7 November 2014 to gather
wider feedback from the interested public and the expert practitioners across the EU. In total,
506 respondents participated in the consultation. This included: 224 individual respondents,
Water Group Plenary Session ‘Water in the Circular Economy’ in January 2016; EP Water Group meeting
"Water Reuse Models" in October 2013
16
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52016IR3691&from=EN
35
222 companies and organisations, 43 public authorities and 17 other respondents. Twelve
stakeholders uploaded additional documents and eight sent more detailed responses or
position papers via email. Participation was particularly high in four Member States (France,
Spain, Italy and Germany), which together made up more than 65% of total responses. About
95% of total answers were obtained from Member States’ organisations, 3% from EU-level
organisations and 2% from other countries. Among private companies, nearly equal share of
respondents represented large companies and Small and Medium Enterprises (SMEs).
A second internet-based public consultation ran from 28 October 2016 to 27 January 2017
and focused on the more detailed policy options to set minimum requirements for reused
water for irrigation and groundwater recharge.
In total, 344 respondents participated in the consultation. Responses were received on-line
from 103 individuals (30% of respondents) and 239 stakeholders or experts (70% of
respondents). Respondents represented a variety of stakeholders groups, economic sectors and
countries:
 Type of stakeholders: Private companies, water utilities and providers and industry or
trade associations represented more than a third of total respondents, a similar proportion
to citizens. Public authorities represented 12% of respondents, respondents from
academic/scientific/research field represented 9% and NGOs and international bodies
represented less than 5% of respondents.
 Economic sector: Organisations involved in sanitation and/or drinking water sectors
represented half of the respondents. About 20% of respondents reported to be involved in
the environment and climate sectors, while only 10% represented the agriculture sector.
Food industry, health and economics sector had even lower response rates compared to
previous categories (each less than 5% of respondents),
 Countries: The large majority of responses were received from within the EU (98%).
Half of the responses were provided by three Member States: Spain, France and Germany
with particularly high contribution from Spain (more than one quarter of all participants).
Twenty countries provided ten answers or fewer.
After both online consultations a dedicated stakeholder meeting was held (on 4 December
2014 and in March 2017); draft results of the analysis were discussed with stakeholders and
additional contributions were collected. The reports on the public consultations are available
at the Website of the initiative mentioned above.
A. The need for EU action
Perceived benefits of water reuse
There is a wide perception among respondents of the benefits of reusing water for irrigation or
aquifer recharge purposes with regards to the availability of water resources, in the context of
water stress or scarcity, unsustainable abstractions and climate change (perception from more
than 70% of respondents across and within different categories of respondents). The potential
contribution of water reuse to the quality of water bodies, through preserving groundwater
from salinization and reducing pollution discharge from urban waste water treatment plants,
into rivers, is perceived by a large number of respondents as well. Furthermore, water reuse is
also perceived by a number of respondents as a means to increase resource efficiency, foster
36
innovation and contribute to soil fertilisation, although these benefits were considered more
moderate compared to the former ones. Several respondents - in particular from the health,
environment and agriculture sectors - expressed their concern about the difficulty for water
users (in particular farmers) to accurately estimate the amounts of nutrients present in the
reused water to fully benefit from nutrient recycling and prevent risks of environmental
contamination.
On the other hand, respondents are much less inclined to perceive cost savings for authorities,
increased revenues, or energy and carbon savings as benefits of water reuse.
The analysis per category of respondents shows in particular that:
 countries regularly exposed to water stress and countries from Southern EU perceive
significantly more and higher benefits than other categories of respondents,
 large consensus is found about these benefits within the respondents from the
sanitation, drinking water, environment and economics sectors.
Perceived barriers
The main barriers to water reuse as identified by respondents are similar for water reuse in
irrigation and aquifer recharge. They primarily include:
 the negative connotation of water reuse (perceived as a high or medium barrier by about
80% of respondents), including lack of awareness of costs and benefits of reuse schemes
 barriers related to policy or governance, including insufficient clarity in the regulatory
framework to manage risks associated with water reuse or insufficient consideration for
water reuse in integrated water management (nearly 90% of respondents perceived them
as high or medium regarding irrigation and over 80% regarding aquifer recharge),
 economic barriers, including the low price of freshwater compared to that of reused water
(especially in countries not affected by water scarcity) and the high cost of treatment for
production of reused water (perceived as a high or medium barrier by about 80% of
respondents) and fear of potential trade barriers in the case of irrigation.
In the specific case of irrigation, the distance between waste water treatment plants and
irrigation fields is also seen as a key barrier (2nd
most pointed out by respondents). In addition
to recognising different barriers listed in the consultation, some respondents or participants to
the Stakeholder meeting also expressed their concerns regarding potential risks for the
environment of reusing water for irrigation, through the perturbation of environmental flows
(e.g. limitation of river flows in regions affected by water scarcity) and the potential
salinization through the reuse of waste water. In the case of aquifer recharge, additional
concerns were expressed regarding risks of contamination of the aquifers and its
irreversibility, due to the difficulty to remove pollutants from this water body.
On the other hand, significantly fewer respondents perceive awareness and availability of
technical solutions to produce safe water as barriers, except in Eastern EU Member States.
Most barriers are perceived by respondents from Southern EU Member States and countries
facing regular water stress, which practically experienced water reuse and often have stringent
water reuse schemes in place.
37
Perceived safety of treated water reuse
There is an overall consensus amongst respondents about the safety of reused water compared
to water from rivers, as nearly 70% of respondents (amongst those who had an opinion)
consider reused water as at least as safe, both for irrigation and for aquifer recharge. In
comparison, the safety of reused water compared to groundwater is more controversial, as
50% of respondents consider it less safe for irrigation and 44% for aquifer recharge.
These overall statistics hide in reality very different perceptions from specific categories of
respondents. Some categories of respondents have a particularly positive or negative
perception of reused water depending on their economic sector, type of organisations,
situation of water stress or EU regions:
 respondents from Southern EU Member States and countries facing regular water stress
are significantly more inclined to consider reused water for both irrigation and aquifer
recharge as being at least as safe as alternative sources (rivers or groundwater) than
respondents from Eastern and Northern countries, which tend to consider reused water as
less safe in the same proportions;
 respondents from some economic sectors also have a particular negative perception of
reused water safety, such as the health sector, for which 70% of respondents perceive
reused water as less safe than groundwater for irrigation purposes;
 on the contrary, respondents from private companies show by far the most positive
perception of reused water safety compared to other types of organisations, keeping in
mind that they are involved at 68% in drinking and sanitation sectors.
The perception of reused water safety may also significantly differ within categories of
respondents, as it is the case within the agriculture, food and environment sectors, for which
no clear position could be seen based on the public consultation.
Justification of EU-level instrument
Although in the online public consultations in 2016 and 2014 over 60% to 80% of all
respondents were in favour of an EU regulatory framework, there is no clear consensus across
all types of respondents on the most suitable type of EU instrument - as listed in the
questionnaire - to promote water reuse in irrigation and in aquifer recharge. In addition, more
than 80% of respondents to the online public consultation held in 2014 considered legally
binding EU minimum standards as effective to ensure the environmental and health safety of
water reuse practices.
The respondents which are mostly in favour of the instrument of an EU regulation, in both
cases, are representatives from private companies, from the sanitation, drinking water, food
industry and environment sectors, and/or from Southern countries. Respondents from
agriculture and economics sectors17
as well as industry or trade associations show less
consensus on supporting this policy option.
Overall, the option of the instrument of a Commission recommendation is the 2nd
preferred
policy option within and across most categories of respondents, although CEN standards are
generally preferred by respondents from agriculture, food and health sectors for water reuse in
irrigation. The highest level of support for the use of Commission recommendations comes
from water providers/utilities and public authorities as well as respondents from Eastern EU
Member States.
17
i.e. any industrial sectors other than food, drinking water and sanitation
38
These results should be considered with caution, as many comments - from respondents who
selected the EU regulation or Commission recommendations - pointed to the preference for an
EU Directive, which was perceived to provide both sufficient level of protection to reach its
objectives and adaptability to be relevant to local contexts and needs. However, this was not
listed in the closed list of policy options from the public consultation and also the impact
assessment did not consider a Directive as an option as it would impose requirements also on
Member States which otherwise don't intend to reuse water.
B. Scope and level of ambition
Objectives of the EU minimum quality requirements for water reuse
Respondents to the public consultation identify in their vast majority (>70%) the following
objectives as key for the EU minimum quality requirements for water reuse:
 For irrigation, the protection of human health of consumers through the safety of
agricultural products placed on the EU market, of human health of public directly exposed
to reused water, of water resources and dependent ecosystems, and of the wider
environment.
 For aquifer recharge, the protection of water resources and dependent ecosystems, of
human health of the public directly exposed to reused water and of future users of water
abstracted from the aquifer.
These objectives are largely supported by the civil society and public authorities and are
shared within and across economic sectors. They are also mostly shared within and across EU
regions, except for the protection of human health of public directly exposed to water reuse in
the case of irrigation, which was recognised as an objective by a lower share of Eastern EU
Member States compared to other EU regions (50% vs. 70% for other EU regions).
In comparison, in the specific case of irrigation, the protection of agricultural productivity is
not given as much importance (40% of respondents only think it should be covered). Yet, a
large majority of respondents from the agriculture sector still considers it as an objective to be
addressed by EU minimum quality requirements for irrigation (75% of respondents). A
significantly higher share of respondents from Eastern EU Member States also identified it as
an objective compared to other EU regions.
Specific aspects to be covered by minimum quality requirements for water reuse
Priority aspects to be covered by minimum quality requirements for water reuse in irrigation
include: microbiological contaminants, monitoring, and other chemicals addressed by EU
legislation, both for irrigation and groundwater recharge purposes. While these aspects are
generally subject to large consensus within and across key categories of respondents
(economic sectors, types of organisation), the following differences can be noted:
 Respondents from the agricultural sector are less favourable to including aspects related to
monitoring, while there is strong support from most other sectors,
 Respondents from the food, drinking water and sanitation sectors are also the least
inclined to identify additional chemicals as aspects as needing to be included.
Other aspects are more controversial within and across categories of respondents, such as
risk-based management or the question of nutrients. Risk-based management approaches were
considered by many respondents and participants as relevant to ensure adequate protection of
health and the environment, but their practical implementation was subject to extensive
discussions. They can be perceived as costly, time-consuming and requiring specific
expertise. The question of nutrients is considered as a priority aspect to be covered when
39
reusing water for aquifer recharge while interest for such an aspect is more moderate for
irrigation purposes. There, it can be seen both as a benefit from a recycling perspective and a
key barrier for ends-users like farmers, with high risks of environmental contamination
(nutrient surplus and leakage to the aquifer, eutrophication). Yet, this aspect is, in both cases,
of very high interest to the health sector (73% in the case of irrigation and 79% in the case of
aquifer recharge). Some respondents were concerned that water reuse, if not well regulated,
may contribute to pollution of aquifers and soils, although to a lesser extent.
Other uses which are out of the scope of this initiative
A large majority of respondents considers the possibility or even the need for other types of
uses than irrigation and aquifer recharge to be covered by EU minimum quality requirements.
The limitation of the scope is described in section 1.2.1 of the IA report.
In particular, there is a large consensus, namely half of the respondents (and in particular
within the health and the environment sectors) on the possibility or need to expand EU
minimum requirements beyond agricultural irrigation to the irrigation of sport fields and
urban green spaces.
The idea to expand EU minimum requirements particularly to industrial uses as well as to
other urban uses is slightly more debated across respondents. Twenty percent and fifteen
percent (respectively) of respondents would not like these uses to be covered by EU
requirements (compared to 10% for both other uses), while 40% of respondents think they
should be included. Comments from some respondents on industrial uses highlighted a
possible confusion with regards to the scope of the water reuse initiative for irrigation and
aquifer recharge: they put forward initiatives from the industry in terms of recycling and reuse
of their own waste water, while the waste water considered in this initiative must be covered
by the UWWTD.
40
Annex 3 - Who is affected by the initiative and how
This Annex sets out how the new legal instrument would function in practice in the Member
States.
As indicated in the description of the policy options, the legislative instrument will require
that any water reuse scheme is subject to a permit delivered by competent authorities in
Member States; EU minimum quality requirements will apply to those permits. It will in no
case be imposed on Member States to develop or promote water reuse in their territory.
The key principles of a risk management framework would be compulsory as part of the
authorisation procedures and conditions of granting permits to any water reuse project in the
EU (as described in section 4.2). The key principles would cover the different steps and
operators of the water reuse system (urban waste water collection and treatment, additional
treatment if any, distribution, storage if any and irrigation at farm). In practice, the legal
instrument would foresee that, before such a permit can be authorised, the applicant of the
permit has to perform a thorough identification and assessment of risks specific to the project
and its environment. Key requirements for this risk assessment would be laid down based on
description of the risk management framework in Annex 7 and would cover:
- description of the water reuse system;
- identification of hazards and risk assessment, in particular:
o additional characterisation and monitoring of pollutants in raw effluent (source
control);
o characterisation of human exposure and of the local environment vulnerability;
- determination of preventive measures to limit risks, e.g. including requirements on
wastewater treatment, restrictions on crops and irrigation techniques, access to fields,
buffer zones etc.
- operational procedures to ensure the system will deliver the appropriate safety,
including verification of water quality and management of incidents and emergencies,
need for advanced additional mitigation measures regarding treatment, access to
fields, buffer zones etc.
Reflecting the outcome of the risk assessment, the permit to be delivered by competent
authorities in the Member States would include additional conditions to the minimum
requirements ensuring safety of agricultural products, in terms of:
- additional quality criteria (parameters and limit values) to be complied with, at the
outlet of the (advanced) treatment plant or in more appropriate location in the system;
- monitoring frequencies for these quality criteria;
- additional preventive measures conditions;
- management plan and procedures to be followed when operating the water reuse
system.
A water reuse scheme involves a number of operators, respectively in charge of collection and
treatment of urban waste water, additional treatment for achieving the required quality for
reuse (as necessary), possible storage, distribution to farms and to irrigated fields, application
to crops etc. Designs of water reuse schemes are very diverse in Member States and
distributions of roles and responsibilities differ widely; as a result holders of existing permits
for water reuse may be any of the above operators, or any association of those.
Application of the "fit-for-purpose" approach
The legislative proposal requires different levels of quality depending on the crops and
irrigation techniques. As a result, in the design of a water reuse scheme, a quality class will be
targeted, and the treatment technology will be installed and operated accordingly. When this
41
quality is lower than the most stringent one in the legislative proposal (class A) irrigation will
be allowed only for certain crops and with certain irrigation techniques, as detailed in the
legislation proposal. The "fit-for-purpose" requirements allow for certain flexibility in
adapting the level of treatment to the actual use in irrigation:
- in farming areas where only crops with low sensitivity are grown with irrigation technique
that prevent contact with edible part of the crop, a less stringent water quality will be allowed,
thus saving treatment costs;
- where crops with different sensitivities are grown in different periods, the level of treatment
can be adapted and changed between periods, e.g. by turning off or by-passing the most
advanced disinfection treatment
- when crops with different sensitivities are grown in different areas with separated
distributions systems, the level of treatment and the quality of reclaimed water can be adapted
and different in the different distribution systems.
Application to existing water reuse schemes
Existing legislations in Member States already require water reuse schemes to be subject to an
authorisation. Existing legislations and authorisations will need to be reviewed and possibly
revised to comply with the new EU legislation. The legal instrument would set a transition
period [2 years] for existing legislations and water reuse schemes to be made compliant.
As regards quality criteria, in many cases the ones imposed by existing legislations in
Member States, are more comprehensive and more stringent than the ones required by the
future legislative proposal. In a few cases where existing legislations and authorisations
impose less stringent quality criteria, these will need revision, e.g. microbiological criteria for
validation of the most stringent quality class (irrigation of crops consumed raw which edible
part are in direct contact with reclaimed water) in Spain. This will impact on both the
competent authorities (revision of legislation and existing permits) and holders of permits
(adaptation of the level of treatment, with possible increase in treatment cost).
In many cases quality criteria in the new EU legislation will be less stringent than required by
the national legislation. As the EU legislation will set only minimum requirements, Member
States will not be obliged to change their legislation to align with the EU standards. However
it is expected that this EU legislation will trigger discussion in Member States regarding the
evidence base and relevance of national legislation. This would lead to some revision of
existing national legislation, and be reflected in less costly treatment requirements.
Additionally existing authorisations in Member States are usually granted on the basis of an
ex ante assessment of impacts; permit conditions are set to mitigate identified risks and
impacts. This process (ex ante impact assessment and mitigation measures) fulfils to a certain
extent the risk management framework required by the future legislative proposal. However
in most cases part of this risk assessment will be missing, e.g. as regards accumulation of
pollutants in soils. In those cases additional assessment and possibly additional conditions to
the permit will be needed to comply with the new legislative instrument. Additional
conditions will mostly consist of additional monitoring, and additional treatments. Depending
on the decision by competent authorities in Member States this additional assessment and
additional measures is likely to be at the expenses of the permit holder. As this additional risk
assessment will further ascertain and quantify risks, it is expected that it will also contribute to
fit existing conditions to actual risks, and in particular allow for less costly monitoring and
treatment requirements.
42
Beyond possible specific changes to the treatment facility, it is expected that the new EU
Legislation will not require any further change into the existing infrastructure, in particular as
regards storage and conveyance of reclaimed water to farms, and a farm level.
Application to new water reuse schemes
Any new water reuse scheme shall be subject to a permit delivered by competent authorities
in Member States and complying with the EU minimum quality requirements. This permit
will be granted on the basis of a risk assessment by the applicant complying with the EU
requirements. Permit conditions will include at least the minimum quality criteria of the new
EU legislation and additional conditions as deemed necessary to manage the identified risks.
In Member States with no legislation in place, no new and specific legislation will be needed
to regulate new projects as the EU legal instrument will provide a full-fledged legislative
framework that can be directly implemented by competent authorities and applicants of
permits.
In Member States where existing legislation already regulate water reuse, revision will be
required within a transition period, on aspects for which the EU requirements are more
stringent. For aspects where the EU legislation is less stringent, no revision will be legally
required but some can be expected as result of discussion trigged by the new EU legislation.
When a new water reuse scheme is developed in an area where irrigation does not exist and/or
when this project will convey water to farms or fields which were not irrigated before,
investment will be necessary to develop the infrastructure downstream of the urban waste
water treatment plant, both off-farm (facilities for additional water treatment, storage,
distribution) and on-farm (distribution to field, irrigation material). The impact of the project
is likely to increase the abstraction pressure on water resources. In those cases, it will be the
responsibility of the competent authorities in Member States to check that this new / increased
pressure will not impair the status of the water body, as required by the WFD, before issuing
any such permit.
When a new water reuse scheme is developed to bring reclaimed water to farms which were
already practicing irrigation before with individual access to water, investment will be
necessary to develop an off-farm infrastructure downstream of the urban waste water
treatment plant, both off-farm (facilities for additional water treatment, storage, distribution)
but it is expected that on-farm equipment will not require significant additional investment. In
cases where the farming area depends on a collective access to irrigation, it is expected that
most of the distribution and storage infrastructure can also be used for reclaimed water; new
investment will be limited to the additional treatment (if necessary) and conveyance from the
urban waste treatment plant to the collective distribution system. In both cases the new water
supply can be used either to substitute or to increase the volume of irrigation water. It will be
the responsibility of the competent authorities in Member States to check that the project will
not impair the status of the water body, as required by the WFD, before issuing any such
permit. It is expected that, for most projects developed in water scarce areas, the volume of
reclaimed water will result in a full or partial substitution of existing abstractions on over-
exploited resources (and revision of existing abstraction permits accordingly), with a positive
impact on those resources. However it could also result in the opposite impact with increased
irrigation and increased negative impact on water resources, similarly to the "rebound effect"
of water saving technologies which tends to increase (rather than decrease) the rate of water
consumption (cf. Blueprint). The actual impact on water resources will ultimately depend on
the decision of the competent authority that will have the possibility to condition the permit
for a new water reuse scheme to a reduction of existing abstraction permits.
43
Coherence with other EU legislation
Quality requirements would complement, but not decrease, the ones laid down by the
UWWTD and relevant European Case-Law18
in particular as regards the quality of discharge
effluents. When complying with the new legal instrument, reclaimed water at the outlet of the
treatment plant would need to respect the criteria of the "clean water" as defined by the
Regulation on the Hygiene of Foodstuffs (852/2004). Hence consistency with other relevant
legislation is ensured in either approach. It is to be noted that this "clean water" definition
pertains to its envisaged use in primary production and regarding the safety of foodstuffs. It
does not prejudge its possible impact on water resources and ecosystems19
. In practice the
proposed legal instrument would foresee that whenever reclaimed water is used for
agricultural irrigation in an EU Member State, this is subject to a permit. In any case the urban
waste water treatment plant would still be subject to the application of the UWWTD, taking
into account the nature of the area where the irrigation will take place, and farmers would
retain the responsibility to maintain this status of clean water and of other duties laid by
Regulation 852/2004 (as for any other irrigation sources). Member States competent
authorities would be responsible for enforcing the permit and carrying out inspections as
necessary.
As depicted in Figure 10 (see section 4.3.3 above), the legal instrument would set minimum
requirements, and any Member State (Member State B in the Figure) could still adopt or
retain more stringent legislation for water reuse in its territory. However, no Member State
could ban imports of food products irrigated with reclaimed water in another Member State
(Member State A in the Figure) enforcing the legal instrument.
Figure 10: trade of agricultural products irrigated with reclaimed water within the EU
18
ECJ Judgement cases C-119/2002, and C-335/07
19
E.g. nutrient content of reclaimed water is not specifically addressed in these requirements because of their
safety to foodstuffs, while they may negatively affect the trophic status of receiving waters.
44
As illustrated by Figure 10, the proposed instrument would complement existing legislation
and address specific risks in the context of water reuse projects typically composed of:
- an urban waste water treatment plant
- a possible advanced treatment plant
- infrastructure conveying reclaimed water from the (advanced) treatment plant to farms
irrigated fields, possibly with intermediary storage facilities.
Figure 23: Existing EU legislation and proposed instrument for water reuse
45
In this system, all impacts on surface waters, ground waters and dependent ecosystems are
subject to provisions of existing water law, in particular the WFD, the Groundwater Directive
and the Environment Quality Standards Directive. The UWWTD also sets requirements on
the collection and treatment of urban wastewater and on the quality of effluent discharged to
the environment, including specific requirements for discharges into sensitive areas and/or
their catchments, nutrients removal and other treatments such as disinfection. These
requirements also apply to water that will be reused. Given its nutrient content, reclaimed
water is to be considered as a fertilizer and its application on agricultural land is subject to the
provisions of the Nitrates Directive (91/676/EEC), in particular as regards periods when the
land application of fertilizers is prohibited and balanced fertilization measures, such as the
inclusion in fertilizer plans and in the records of fertiliser use, and also of the UWWTD if the
irrigated lands are sensitive areas or their catchments, which require nutrients removal.
Detailed interpretation of these requirements is provided in the “Guidelines on Integrating
Water Reuse into Water Planning and Management in the context of the WFD”.
On the other hand, as mentioned above, the use of reclaimed water in irrigation for primary
production of food products is subject to the requirements of the Regulation on the Hygiene of
Foodstuffs. According to its Annex I / Part A setting hygiene provisions for primary
production and associated operations:
2. As far as possible, food business operators are to ensure that primary products are protected against
contamination, having regard to any processing that primary products will subsequently undergo. […]
4. Food business operators rearing, harvesting or hunting animals or producing primary products of animal
origin are to take adequate measures, as appropriate:[…]
(d) to use potable water, or clean water, whenever necessary to prevent contamination; […]
Therefore as any other irrigation water source, reclaimed water for irrigation should comply
with the definition of "clean water" at the point of use, i.e. water "that does not contain
micro-organisms, harmful substances in quantities capable of directly or indirectly affecting
the health quality of food" according to article 2 of Regulation 852/2004. This "clean water"
46
requirement is not translated into a set of quality standards in the Regulation. Further details
on implementation on grounds of this requirement are given in the Commission Notice on
"Guidance document on addressing microbiological risks in fresh fruits and vegetables at
primary production through good hygiene" (2017/C 163/01 of 23 May 2017).
Figure 24: Overview of benefits and costs
I. Overview of Benefits (total for all provisions) – Preferred Option(s)
Description Amount Comments
Direct benefits
Reduction of water stress more than 5%, corresponding to a
benefit of about EUR 3 billion/year
for the whole EU assuming a
willingness to pay of about EUR
0.5/m3 for preserving natural flows
in rivers and aquifers.
Ir2 would enable reusing more than
50% of the total volume
theoretically allocated for
irrigation; the total available
volume would enable a water stress
reduction of ca.10%, Ir2 would
enable a reduction of more than 5%
(see section 5.2.1)
Reduction of nutrient pollution more than 5% of agricultural
mineral fertilizers
Ir2 would enable reusing more than
50% of the total volume that can be
theoretically allocated for
irrigation; as the total volume
would enable reducing the use of
mineral fertilizers in agriculture by
about 10%, Ir2 would enable a
reduction of more than 5% (see
section 5.2.1)
Indirect benefits
Increased reliability of water
supply for agricultural irrigation
and therefore more sustainable
production of agricultural products.
Not quantified at EU scale, but in
the order of 1 billion/drought year.
In the Po plain, Italy, costs were
quantified inEUR 500-1000 million
during a drought year.20
Reuse would enable farmers to
depend less on freshwater
resources, whose use may be more
severely restricted during droughts.
II. Overview of costs – Preferred option(s)
Citizens/consumers Businesses Administrations
One-
off
Recurrent One-off Recurrent One-off Recurrent
20
In a paper on the Po plain in Italy, Musolino et al. (2017) quantify an impact of droughts on the overall welfare
(farmers+consumers) in the order of EUR 500-1000 million/year during droughts. The affected population is
more than 16 million persons. This may suggest a cost of about 30-60 Euro/person during drought years and is in
fact in line with the figures on the willingness to pay provided above. The authors stress that farmers alone
benefitted from drought as the price increase was stronger than the production loss in the area. As reuse
contributes to water stress reduction in the order of 10%, we may assume an indirect benefit of 50-100 million
Euro during drought years, for the Po plain alone. Considering a drought that simultaneously affects an area 10
times as big as the Po plain in Europe, the indirect benefits for the whole of Europe would go back to 500-1000
million Euro during a drought year. Source: Dario Musolino, Alessandro de Carli, Antonio Massarutto,
Evaluation of the socioeconomic impacts of the drought events: The case of the po river basin. Europ. Countrys.
· 1 · 2017 · p. 163-176 DOI: 10.1515/euco-2017-0010.
47
Water reuse
development21
Direct
costs
- Top-up of
farmers’
payment
for reused
water:
EUR 0.25
/m3
Investment for
reuse system
infrastructure
(treatment+
transport): EUR
700 million22
Farmers’
payment
for reused
water EUR
0.25 /m3;
Monitoring
by the
reclaimed
water
provider23
Monitoring
results
review,
inspections
Indirect
costs
Risk
assessment24
Direct
costs
Studies to support
risk quantification
Administra
tive
procedure
for risk
assessment
technical
work for
risk quanti
fication
review
Indirect
costs
Managing
public
access to
information
21
For the sake of this Impact Assessment, and without prejudice for future specific assessments in other
contexts, the calculations assume a total levelized cost of reused water of EUR 0.5 /m3, of which approximately
50% is paid by the farmer and 50% by the citizens in exchange of the corresponding environmental benefits.
22
These costs are part of the estimated recurrent costs.
23
The total costs of water reuse are assumed to correspond to 0.5 Eur/m3. In principle, these costs should be
covered by the water user, but in many cases there may be a more general interest in water reuse because of the
broad benefits it may bring for water stress reduction. Consequently, it is possible that part of the costs be
subsidized through taxpayers' money or passed on to consumers through increases in prices. In this table,
exclusively for the sake of providing a first quantification, we assume that the cost of reused water be equally
shared between farmers and taxpayers (or consumers), 0.25 Eur/m3 each
24
Costs not quantified
48
Annex 3a –SME test
(1) Preliminary assessment of businesses likely to be affected
A total of roughly 11 million farms operated in the EU-28 in 2013. All the farms of the
European Union are micro or small following the definition of the EU enterprises. Very few
farms are small and the wide majority are micro enterprises25
.
The total number of jobs in agriculture is 8.7 million jobs in terms of Annual Working Units
(AWU) when in irrigated farms is 20% according to Eurostat. The production value is 26%
in irrigated farms on the total Standard Output. The number of irrigated farms is in total 1.7
million, 16% of total farms.
In 2013 the total irrigated area in the EU was 10.2 million hectares, accounting for 5.9% of
the total Utilised Agricultural Area (UAA). Southern European countries like Spain, France,
Italy, Greece and Portugal show the highest amounts of irrigated land. Indeed, in Southern
Europe agriculture accounts for more than 50% of water abstractions: Spain (60%), Greece
(88%). Together, these countries account for 86% of the total. On the other side, in Denmark
and the Netherlands irrigated UAA makes up less than 3% of the total UAA.
(2) Consultation with micro and small enterprises representatives
The farmers' association at EU level (COPA-COGECA) was overall appreciative of the
concept, stating that it will contribute to a more resilient farming sector, help overcome
pressures deriving from climate change and, in upcoming years, be not only an alternative
supply option but rather the most important source of clean water. Challenges highlighted
were the need to identify the right quality of water, whereby the minimum quality
requirements must take into account specific local needs and give flexibilities to the regions
and Member States. Reclaimed water for irrigation should be nutrient-free as well as
particle-free. Affordability of the proposed water reuse schemes should be carefully
considered. COPA-COGECA further indicated that the compliance should be at the point
where reclaimed water is discharged by the treatment plant. Finally, any new instrument
should be light and not inflict administrative burden. It should only apply to those practicing
reuse.
(3) Measurement of the impact on SMEs
Farmers are affected in proportion to the volume used of reclaimed water and therefore
micro enterprises are not affected differently than bigger farms. Moreover, it is by crop type
grown that requirements in stringency differ, for instance for so called energy crops the
minimum requirements are much lower than for fruit and vegetables. Therefore fruit and
vegetable growers are more significantly affected in case they irrigate with reclaimed water
than farmers growing energy crops.
25
http://ec.europa.eu/growth/smes/business-friendly-environment/sme-definition_en
49
As regards water costs for irrigation paid by farmers in 2013, on the basis of FADN (Farm
Accountancy Data Network) for agriculture, the ratio of water costs for irrigation on total
intermediate consumption (specific costs and farming overheads), the situation by Member
State is the following:
MS In % 2013 MS In % 2013
Belgium 0,32 Lithuania 0,44
Bulgaria 0,70 Luxembourg 2,13
Cyprus 2,72 Latvia 0,08
Czech Republic 0,46 Malta 0,71
Denmark 0,32 Netherlands 0,24
Germany 0,71 Austria 0,24
Greece 3,08 Poland 0,51
Spain 4,42 Portugal 0,27
Estonia 0,07 Romania 0,99
France 0,94 Finland 0,42
Croatia 1,11 Sweden 0,25
Hungary 0,51 Slovakia 0,26
Ireland 0,48 Slovenia 0,94
Italy 1,53 United Kingdom 0,79
The incidence of costs for irrigation is generally low in comparison with the total
intermediate consumption. It appears to be more important in Spain, Greece, Cyprus, Italy,
Luxembourg and Croatia. In Spain the incidence of water cost on the output per group of
crops is measured at 4.1% for field crops, 4.2% for horticulture and 4.9% for permanent
crops. The same indicator amounts to 1.2% on field crops, 0.3% for horticulture, 0.9% for
permanent crops in Italy, while in Greece the water costs paid compared to output are at
2.7% for field crops, 1.5% for horticulture and 1.9% for permanent crops.
However these prices paid for water do not reflect the real water costs of irrigation as often
these prices are subsidised and are therefore borne by society and the environment.
The impact assessment calculates the amount of reclaimed water which could be made
available to farmers at the cost of 0.5 €/m3. In water scarce areas 0.5 €/m3 is a competitive
price given the fact that prices for conventional water are in the same order of magnitude in
areas of severe water stress and would not raise irrigation costs significantly compared to
50
total intermediate consumption. For instance according to Custodio (2015) common prices
for groundwater in Spain range between 0.3 and 0.5 €/m3 (and can be higher depending on
conjoint use and the cost of energy for pumping). In the Canary Islands usual prices are
around 0.5 €/m3 though during peak demand they can go beyond 1 €/m3. Existing irrigation
freshwater tariffs range significantly across Greece (0.02-0.70 €/m3)26
. (For more
information please see in Annex 4 the sections for some selected MS.)
Moreover estimations of the Commission show that by 2030 important spring and summer
droughts are expected in Southern and Centre of Europe to a degree that competition among
sectors for water is expected to raise water prices. Under these conditions reclaimed water
becomes progressively more competitive compared to other water sources used for
irrigation.
Reclaimed water can be of major interest for farmers when urgent irrigation interventions in
water stress conditions for crops is necessary (e.g. the case of summer 2017 when some of
the crops' production was lost due to drought). Farmers could be interested to pay a higher
price to save crops at risk of total or partial loss. Moreover farmers can benefit from a secure
water supply if relying on reclaimed water for irrigation purposes, compared to the risk of
unavailability of freshwater for irrigation purposes in case of water bans in water scarce
areas in periods of severe water shortages. Increased reliability of water supply for
agricultural irrigation and therefore more sustainable production of agricultural products
could add up to benefits of EUR 500-1000 million during a drought year. Under these
circumstances the cost of reclaimed water would be offset by these indirect benefits27
. While
this estimation is very rough, it at least shows that, in areas where droughts are (or are likely
to become) common, water reuse is clearly also beneficial from an economic point of view.
Therefore farmers are motivated to substitute freshwater sources with reused water in areas
with water stress, so areas where freshwater and other sources of water become unavailable
(e.g. droughts and potentially resulting bans to use the available water for irrigation
purposes) or too costly (e.g. increasing energy costs for pumping of the groundwater due to
lowering of groundwater levels).
Willingness to pay for reused water will differ across regions depending on differences in
water stress, availability of other conventional water sources and their price. Studies on
26
(Pinios case study, Annex 4)
27
In a paper on the Po plain in Italy, Musolino et al. (2017) quantify an impact of droughts on the overall welfare
(farmers+consumers) in the order of EUR 500-1000 million/year during droughts. The affected population is
more than 16 million persons. This may suggest a cost of about 30-60 Euro/person during drought years and is in
fact in line with the figures on the willingness to pay provided in Annex 4. The authors stress that farmers alone
benefitted from drought as the price increase was stronger than the production loss in the area. As reuse
contributes to water stress reduction in the order of 10%, we may assume an indirect benefit of 50-100 million
Euro during drought years, for the Po plain alone. Considering a drought that simultaneously affects an area 10
times as big as the Po plain in Europe, the indirect benefits for the whole of Europe would go back to 500-1000
million Euro during a drought year. Source: Dario Musolino, Alessandro de Carli, Antonio Massarutto,
Evaluation of the socioeconomic impacts of the drought events: The case of the po river basin. Europ. Countrys.
· 1 · 2017 · p. 163-176 DOI: 10.1515/euco-2017-0010.
51
willingness to pay (see Annex 4 for more details) show that willingness to pay is extremely
variable (for instance, Birol et al., 200728
estimate a willingness to pay higher than EUR 0.6
/m3
in Cyprus, while Tziakis et al., 200929
, indicate less than EUR 0.1/m3 for Crete), see
Annex 4 for further details on the range of different studies and estimations for the value of
1 m3
of water. These examples in the Annex highlight the large variability in valuation of
water used to reduce water stress, and the uncertainty due to their high case-specificity. In
this assessment, we adopt a benefit of water reuse of EUR 0.5 /m3
, which is in the mid-lower
end of the cases examined above, and may be argued to represent as a first approximation of
the combined market and non-market value of water reuse in Europe, provided it contributes
to reducing water stress. Therefore it can be concluded that in areas of high water stress it is
a reasonable assumption that there would be an overall willingness to pay by farmers and
society for the set 0,5 €/m3
cost of reclaimed water, for which this impact assessment
calculates the uptake of water reuse at this given cost.
4) Assess alternative options and mitigating measures
There are no mitigating measures necessary given the fact that micro enterprises and SMEs
are not disproportionately affected.
28
Birol, E., P. Koundouri, and Y. Kountouris (2007), Farmers’ demand for recycled water in Cyprus: A
contingent valuation approach, in Wastewater Reuse––Risk Assessment, Decision-Making and Environmental
Security, edited by M. K. Zaidi, pp. 267–278, Springer, Dordrecht, Netherlands.
29
Tziakis, I., I. Pachiadakis, M. Moraittakis, K. Xideas, G. Theologis and K. P. Tsagarakis (2009), Valuing
benefits from wastewater treatment and reuse using contingent valuation methodology, Desalination, 237, 117–
125.
52
Annex 4 - Analytical models used in preparing the impact assessment
This annex provides a description of the models used for certain aspects of this impact
assessment:
 The model developer and nature (public/private/open source) of the model;
 Model structure and modelling approach with any key assumptions, limitations and
simplifications;
 Intended field of application and appropriateness for the specific impact assessment
study presented;
 Model validation and peer review with relevant references;
 The extent to which the content of the model and input data have been discussed with
external experts;
 Explanation of the likely uncertainty in the model results and the likely robustness of
model results to changes in underlying assumptions or data inputs;
 Explanation as to how uncertainty has been addressed or minimised in the modelling
exercise with respect to the policy conclusions; and
 The steps taken to assure the quality of the modelling results presented in the IA.
We make use of a hydro-economic model to estimate the demand of water for irrigation, and
the costs of treating and deploying reclaimed water to agricultural land within a distance of 10
km from existing wastewater treatment plants. On this basis, we conduct the analysis of
volumes and costs of reclaimed water under the two policy options “one size fits all” (Ir1) and
“fit for purpose” (Ir2) considered in the Impact Assessment.
The key elements of the models are summarized in Table 1. In the following, we first
introduce the models in more details, and then describe the main assumptions and sources of
data used for the assessment. The material presented here is based on Pistocchi et al., 201830
.
In addition to describing the models used in this assessment, we provide details on (1) the
quantification of the benefits from water reuse; and (2) the calculation of the administrative
burden of the proposed instrument.
General aspects of the models used in the Impact assessment
The key assumptions and data sources are described in this Annex. The assessment refers to a
conventional baseline where reuse is a negligible source of water for irrigation in Europe in
the absence of specific policies, because of the lack of a clear legal framework enabling
steady investment in this area. For the rest, we assume the water legislation (and particularly
the Urban Wastewater Treatment Directive) to be correctly implemented across Europe.
The most critical aspect of the assessment is the evaluation of costs of reclaimed water. The
cost of wastewater reuse is computed as the sum of the cost of: 1) treatment of water for
reuse; 2) building infrastructures for water storage and distribution (pipelines and pumps); and
3) energy for reclaimed water pumping from the wastewater treatment plant to the
neighboring agricultural areas (Figure 1).
30
Pistocchi, A., Aloe, A., Dorati, C., Alcalde Sanz, L., Bouraoui, F., Gawlik, B., Grizzetti, B., Pastori, M.,
Vigiak, O., The potential of water reuse for agricultural irrigation in the EU. A Hydro-Economic Analysis, EUR
28980 EN, Publications Office of the European Union, Luxembourg, 2018, ISBN 978-92-79-77210-8,
doi 10.2760/263713
53
Figure 1 – scheme of the costs considered in this assessment.
Although both investment and operation costs of water reuse are highly dependent on
conditions such as the level of treatment already existing at a plant and the size of the plant,
mean levelized treatment costs31
are pragmatically assumed to be constant across Europe.
This assumption still enables analyzing the difference of the two policy options considered in
the Impact Assessment, without the need for a representation of the variability of wastewater
treatment plant conditions at European scale. Such representation would be anyway rather
challenging to develop, due to the extreme sensitivity of investment and operation costs to
local conditions. At the same time, while variable, the impact of treatment cost variability is
attenuated by the variability of water transport costs that is, on the contrary, more predictable
as it depends on distance, elevation differences and other relatively simple parameters (as also
shown in the global sensitivity analysis exercise reported below). Therefore, in this
assessment we refer to the mid-range of treatment costs provided by Iglesias et al., 2010. We
assume option Ir2 to correspond to an intermediate treatment requirement corresponding to
disinfection and depth filtration, and Ir1 to an advanced treatment with membrane filtration
and disinfection.
In order to evaluate the potential of reusing reclaimed water, we estimate the cost of treatment
and the cost of transport of water, which requires defining a source and a destination of
reclaimed water in order to quantify a transport distance and an elevation difference for
pumping. We assume that water sources coincide with wastewater treatment plants as
depicted in the WaterBase – Wastewater v. 4.0 dataset made available at the European
Environment Agency32
. Moreover, we distribute in space the estimated irrigation demand
assuming that all agricultural land excluding pastures is potentially irrigated, thus neglecting
the actual distribution of irrigation infrastructure. We conduct appropriately aggregated
calculations using the elementary sub-basins of the CCM2 database33
as a mapping unit,
without disaggregating results therein. A major source of uncertainty is represented by the
spatial scale and resolution of the analysis. The assumptions made and the data used as input
do not enable any conclusion on specific situations, but suggest only general trends valid at
European scale. All conclusions of this assessment must be considered indicative at a broad
strategic level, and can by no means serve the purposes of case-specific assessments.
Particularly, the assessment cannot be regarded as a pointwise evaluation of the potential of a
specific wastewater treatment plant, but as yielding representative frequency distributions of
31
In analogy with the case of energy, the levelized cost is the net present value of the unit-cost of water over the
lifetime of a generating asset.
32
https://www.eea.europa.eu/data-and-maps/data/waterbase-uwwtd-urban-waste-water-treatment-directive-4
33
http://inspire-geoportal.ec.europa.eu/demos/ccm/
Cost of
treating
water for
reuse
Cost of
infrastructure
Cost of
pumping
(energy)
Total cost
54
costs at a regional scale, such as EU NUTS2 level or river basins. Results are consistently
presented at resolutions not finer than these.
The results of the EPIC model, while uncertain, have less critical implications for the
conclusions of the study and were not subjected to specific uncertainty analysis. Their
uncertainties are discussed on a qualitative basis, when necessary, in the specific sections of
this document. EPIC has been calibrated using data publicly available from EUROSTAT and
EEA.
This assessment is based on the current wastewater treatment plant system in the EU, as well
as on current estimated irrigation requirements and fertilizer use. We do not make
assumptions on other macroeconomic, socio-economic conditions nor policies and measures,
as the scope is limited to quantifying a possible cost distribution for reuse of wastewater.
Information on wastewater treatment plants in Europe is derived from the European
Environment Agency’s Waterbase dataset, v. 4. Additional details on models, data, and the
estimation of water quantity and quality at wastewater treatment plants are given in a JRC
report accompanying this Impact Assessment.
Model and
model
type
Developer Intended field of
application/appropr
iateness
Validation
and peer
review
Discussed
with
external
experts
Quality
control and
uncertainty
EPIC
agronomic
model
USDA
(open
source)
Simulation of crop
yields, nutrient and
water requirements;
appropriate for irrigation
demand estimation and
the corresponding yields
Illustrated in
this annex
EPIC model
included in
JRC Blueprint
study. No
specific
discussion.
Illustrated in
this annex
Hydro-
economic
model
JRC Calculation of costs of
water treatment and
distribution; appropriate
to extend simple cost
calculations to the
various contexts in
Europe based on the
spatial relationships of
wastewater treatment
plants and agriculture
FEASIBLE
model
equations
endorsed by
OECD. No
specific
validation.
FEASIBLE
model used
for other EC
studies. No
specific
discussion.
Informal
checks on
compatibility
of the
results of
equations
with
common
experience;
global
sensitivity
analysis
Table 1 – models used in the assessment
Hydro-economic model
The equations used for the assessment of costs were developed specifically for the present
assessment, following engineering assumptions widely adopted in practice, and are presented
in a specific section of this report. The cost appraisal equations used for the assessment derive
from the literature, and particularly from the FEASIBLE model (OECD, 2004) for what
55
concerns the cost of pipelines and pumping stations these were already used in previous
assessments at the European Commission (e.g. European Commission, 2010); for the costs of
storage, we follow the assumptions made in Maton et al., 2010.
For the cost calculations, apart from the sensitivity analysis conducted on purpose to address
uncertainties, comparisons have been drawn with costs reported from experts referring to real
cases in Europe or comparable contexts. For the purposes of this assessment, we assume the
costs indicated by Iglesias et al., 2010, to be representative of the whole European context. It
must be stressed that the costs considered here are additional to those required anyway to
comply with the legislation on urban wastewater treatment.
For policy option Ir2 (“fit-for-purpose”), we assume treatment costs for a reference condition
where effluent standards for reclaimed water can be obtained by a treatment consisting of
depth filtration and disinfection, for which Iglesias et al., 2010, report a mean investment cost
in the range of 28-48 €/(m3/day) and an operation cost in the range 0.06-0.09 €/m3. Under
option Ir2, in fact, it is possible that water is reused with lower treatment costs as well as
higher treatment costs (the latter only for the share of water volumes requiring the highest
standards). As it is currently impossible to assume how much of the water volume available
for reuse will be treated at which level of quality, adopting a lower-middle level of treatment
costs appears a reasonable pragmatic assumption. The range of levelized costs of treatment
(LCOWt) is computed assuming a discount rate of 5% and a depreciation period of 20 years,
as:
LCOWt = (LCOWt, min +LCOWt, max)/2
with
LCOWt, min=0.06 + 28 / pva(0.05, 20)/365
LCOWt, max=0.09 + 48 / pva(0.05, 20)/365
and with pva(r, n), representing the present value of investment cost annuity, defined in
Equation 15 below. For policy option Ir1, we consider that membrane filtration and
disinfection are required to achieve the quality standards. For this case, Iglesias et al., 2010,
provide a mean investment cost in the range of 185-398 €/(m3/day) and an operation cost in
the range 0.14-0.20 €/m3. We compute the levelized costs of treatment as:
LCOWt, min=0.14 + 185 / pva(0.05, 20)/365
LCOWt, max=0.20 + 398 / pva(0.05, 20)/365
Table 7 summarizes the adopted levelized costs.
Option LCOWt cost (min) LCOWt(max) LCOWt
Ir1 € . € . € .
Ir2 € . € . € .
Table 7 – water treatment costs assumed for the two policy options
The treatment costs are the only difference between the two policy options considered in this
assessment. On the contrary, it is assumed that the infrastructure to distribute reclaimed water
from wastewater treatment plants does not presently exist and needs to be developed.
56
The model adopted to calculate the cost of water distribution refers to the spatial support
represented by the sub-basins of the CCM2 dataset34
. Table 8 summarizes the attributes of
sub-basins considered for model calculations.
Symbol Description Source
i Sub-basin identifier -
(xp,i, yp,i,
zp,i)
Coordinates of the center of mass of WWTPs
present in the SB
Computed with Equation 1 using the
capacity of WWTPs (PE) as masses;
coincides with WWTP coordinates if only
one WWPT is present
(xi, yi, zi) Coordinates of the center of mass of agricultural
areas present in the SB
Computed with Equation 2. Agricultural
areas are all pixels in CLC2012 with level 1
code=2, excluding level 3 code 231
(pastures)
Ai Extent of agricultural area in the SB See above
Ri Radius of inertia (dispersion) of the agricultural
area in the SB
Computed with Equation 3. See above
𝜑 Porosity (share of the SB accessible for pipelines) Computed with Equation 4 using Open
Street Map roads layer, agricultural land
(including pastures) and slope from SRTM
100 m DEM
𝜏 Tortuosity Computed from porosity using Equation 5
Qi output discharge of the WWTPs present in the SB From EEA UWWTP database v.4 as revised
by Vigiak et al., 2017
𝛼 fraction of discharge Qi that is reclaimed Set to default of 1
LCOWt Cost of water treatment at the WWTPs present in
the SB
See § 6.2
Ii irrigation demand in the SB Estimated from EPIC under the “baseline”
scenario, and from EPIC results with
Equation 28 under the “potential” scenario
Ti Duration of the irrigation period in the SB Set to a default value of 4 months (120
days).
𝜓 Cost of energy in the SB Set to default of 0.10 €/kWh
Table 8 – summary of attributes of each sub-basin used in the calculation (SB=sub-basin)
For the generic i-th sub-basin, we define an equivalent WWTP with coordinates of the centre
of mass of all WWTPs in the sub-basin, computed as:
xp,i=
∑ 𝑃 𝜉𝑝
=
∑ 𝑃
=
yp,i=
∑ 𝑃 𝑝
=
∑ 𝑃
=
zp,i=
∑ 𝑃 𝑝
=
∑ 𝑃
=
Equation 1
where mi is the number of WWPs in the i-th sub-basin, Pk the capacity (PE) of the k-th
WWTP in the sub-basin, and (𝜉 , , ) its coordinates along the horizontal axes and
elevation, respectively. We define an equivalent agricultural area in the sub-basin, with an
extent equal to the total agricultural area Ai within the sub-basin, with coordinates of the
centre of mass computed as
xi=
∑ 𝜉
=
Equation 2
34
http://inspire-geoportal.ec.europa.eu/demos/ccm/
57
yi=
∑ =
zi=
∑ =
where ni is the number of agricultural pixels in the i-th sub-basin, and (𝜉 , , ) the
coordinates of the k-th pixel along the horizontal axes and elevation, respectively. The
dispersion of agricultural pixels around their center of mass is represented by the radius of
inertia computed as:
Ri =
∑ √ 𝜉 − + − + −
=
Equation
3
Each sub-basin is characterized by a porosity, meant as the share of its area where water can
be in principle transported through pipelines. The latter is assumed to coincide with the
ensemble of:
- A buffer of 100 m around all road infrastructure
- Agricultural land with terrain slope below 35°.
Porosity is defined as:
𝜑 =
𝑒 𝑒 𝑒 −
𝑒 −
.
Equation
4
In the analysis of costs of water reuse, we compute the length of pipelines assuming a
Euclidean distance, hence a homogeneously accessible sub-basin, while in reality the actual
length will tend to be higher depending on the tortuosity of its trail. We quantify the tortuosity
using the theoretical model of Bruggeman (1935; see also Tjaden et al., 2016) for two-
dimensional porosity:
𝜏 = (
𝜑
) Equation 5
Where a is a parameter depending on the geometry of the pores. For a space filled by
cylinders, a=1 while, for a space filled by spheres, a=0.5. The higher a, the higher the
tortuosity for a given porosity. In practice, a needs to be fitted to the specific case. In this
exercise, we set a=0.5 by default. Moreover, we do not allow 𝜏 to exceed the value of 3.
Water potentially reclaimed at a given wastewater treatment plant may be transported for
reuse within the plant’s sub-basin (i.e. “at the source”), or towards other “receptor” sub-
basins. In this exercise, we assume that water cannot be conveniently transported to sub-
basins more than 10 km away (on a straight line) nor to sub-basins with elevation differences
representing an excessive pumping requirement. For the latter, we assume that sub-basins
featuring an elevation range above 200 m would require excessive pumping efforts and we
regard them as “inaccessible”. We exclude from this set those sub-basins corresponding to the
valleys of relatively large rivers (those with Strahler order > 4 in the CCM2 database), where
it is assumed that the valley bottoms may still host infrastructure despite the potentially high
elevation ranges on the hillsides.
58
Within a “source” sub-basin, the flow of reclaimed water to agriculture (m3/day) is computed
as:
, = min 𝛼 ,
Equation
6
where (m3/day) is the output discharge of the WWTP, 𝛼 (-) is the fraction of this
discharge that is reclaimed (by default, 𝛼 =1), and (m3/day) is the irrigation demand in the
sub-basin.
The length of the pipeline required to transport this flow to the agricultural area in the sub-
basin is given by:
𝐿 , = √( − , ) + ( − , ) +( − , ) Equation 7
while the diameter of the pipeline (m) is computed using the Hazen-Williams formula as:
, =
. , .
.
Equation 8
where J is the friction loss rate and C is a friction coefficient. We assume C=120 (-), valid for
steel pipes, and J=0.005 (-). Under these assumptions, with Fi,i in m3/day, Equation 8 can be
written as:
Di,i = 0.0104Fi,i
0.3803
In addition to the transport of reclaimed water to the agricultural area, we account for the
distribution of this water within the agricultural area itself. The radius of inertia Ri represents
the average distance of agricultural areas from their centre of mass. We assume the
investment in the infrastructure for distribution to the farms to be independent of the water
reuse investment, while we compute the energy cost of distributing the reused water within
the agricultural area of a sub-basin, as this contributes directly to the levelized cost of water.
The expenditure for a pipeline with diameter  is given in €/m by35
:
 = {
.  .
+ . 𝑖  ≤ .
.  .
+ . 𝑖  > .
Equation 9
as from the FEASIBLE model (OECD, 2004). This expenditure function is used to compute
( , ).
35
The functions are provided by OECD (2004) in US$/m. In 2004, the exchange rate of € against US $ was
about 0.83. However, given the indicative value of the functions and the relative stability of the prices, we
assume a unit exchange rate. This applies to all expenditure functions from the FEASIBLE model when values
are given in US$.
59
The energy required to transport and distribute the reclaimed water within the sub-basin
(kWh/year) is computed as:
Ψ , =
,
∗ (max , − , + 𝜏 𝐿 , + ) Equation 10
where g is the acceleration of gravity (9.81 m/s2) and is the efficiency of pumping. We
assume =0.75. The power installation requirement (kW) of an equivalent pumping station
for the transport and distribution of the reclaimed water flow is:
, =
Ψ ,
∗
Equation 11
where Ti (days) is the duration of the irrigation period in the sub-basin. The expenditure for a
pumping station of power S (€) is computed from the FEASIBLE model as:
E’ S = S 0.559
Equation 12
The storage volume required for use of water in irrigation is computed as:
Wi,i=365Fi,i −
𝑇
Equation 13
The cost of the storage volume is:
E(Wi,i)=iWi
Equation 14
with i set to default of 5 €/m3 in line with Maton et al., 2010. Cost of storage is extremely
variable. For natural storage (e.g. in floodplains), Grygoruk et al., 2013 report a value above
8 €/m3.
The expenditure for an investment can be converted into an equivalent annual cost by the
“present value of annuity” factor:
𝑣𝑎 𝑟, =
−
+ 𝑟
𝑟
Equation 15
where r is the annual interest rate and n is the number of years of useful life (or depreciation
period) of the investment. We assume n=50 years for pipelines and storage, and n=15 for
pumping stations, while r=0.05 (5%).
The total equivalent annual cost of water transport and distribution (€/year) is given by:
, =
( , )𝜏 𝐿 , + E W ,
𝑣𝑎 . ,
+
′ ,
𝑣𝑎 . ,
+ 𝜓 Ψ , Equation 16
Where 𝜓 is the cost of energy (€/kWh) in the sub-basin. In this exercise, we assume a
constant value 𝜓 =0.10 €/kWh. The cost of energy for industrial use reported by
EUROSTAT is provided in Table 9, suggesting the assumed value to be plausible for large
industrial users across Europe.
60
Country
Consumption (MWh/year)
20 500 2000 20000 70000 150000 >150000
Belgium € 0.18 € 0.15 € 0.11 € 0.10 € 0.08 € 0.07 € 0.06
Bulgaria € 0.10 € 0.10 € 0.08 € 0.07 € 0.06 € 0.06 € 0.06
Czech Republic € 0.16 € 0.12 € 0.08 € 0.07 € 0.07 € 0.07
Denmark € 0.18 € 0.10 € 0.09 € 0.09 € 0.08 € 0.08
Germany € 0.22 € 0.18 € 0.15 € 0.13 € 0.11 € 0.10
Estonia € 0.11 € 0.10 € 0.09 € 0.08 € 0.07 € 0.07
Ireland € 0.20 € 0.16 € 0.13 € 0.11 € 0.09 € 0.09
Greece € 0.21 € 0.17 € 0.12 € 0.10 € 0.08 € 0.05
Spain € 0.27 € 0.15 € 0.11 € 0.10 € 0.08 € 0.07 € 0.06
France € 0.15 € 0.12 € 0.10 € 0.08 € 0.07 € 0.06
Croatia € 0.13 € 0.11 € 0.09 € 0.08 € 0.06 € 0.06
Italy € 0.27 € 0.19 € 0.16 € 0.15 € 0.13 € 0.10 € 0.08
Cyprus € 0.18 € 0.17 € 0.15 € 0.13 € 0.13 € 0.12
Latvia € 0.16 € 0.13 € 0.12 € 0.11 € 0.10 € 0.09
Lithuania € 0.13 € 0.11 € 0.10 € 0.10 € 0.09 € 0.08
Luxembourg € 0.17 € 0.11 € 0.09 € 0.06 € 0.05
Hungary € 0.11 € 0.10 € 0.09 € 0.08 € 0.08 € 0.08 € 0.08
Malta € 0.22 € 0.17 € 0.16 € 0.14 € 0.12 € 0.11
Netherlands € 0.16 € 0.12 € 0.09 € 0.08 € 0.07 € 0.07 € 0.06
Austria € 0.16 € 0.13 € 0.10 € 0.09 € 0.08 € 0.07 € 0.06
Poland € 0.15 € 0.11 € 0.08 € 0.07 € 0.07 € 0.06 € 0.06
Portugal € 0.19 € 0.15 € 0.12 € 0.10 € 0.09 € 0.08
Romania € 0.11 € 0.10 € 0.08 € 0.07 € 0.06 € 0.06
Slovenia € 0.14 € 0.10 € 0.08 € 0.07 € 0.07 € 0.06
Slovakia € 0.20 € 0.14 € 0.11 € 0.10 € 0.09 € 0.09 € 0.07
Finland € 0.09 € 0.08 € 0.07 € 0.07 € 0.05 € 0.05
Sweden € 0.14 € 0.07 € 0.06 € 0.06 € 0.05 € 0.04
United Kingdom € 0.17 € 0.15 € 0.14 € 0.13 € 0.12 € 0.12 € 0.12
Table 9 – Electricity prices per kWh, for industrial consumers, excluding VAT and other
recoverable taxes and levies – average of bi-annual data 2014-16 (source: EUROSTAT)
The levelized cost of reclaimed water within the sub-basin (€/m3) is:
𝐿 𝑊, =
,
,
+ 𝐿 𝑂𝑊𝑡 Equation 17
The flow of reclaimed water potentially supplied from the i-th source sub-basin to the j-th
receptor sub-basin (m3/day) is computed in a similar way. First of all, the shortest path
connecting the i-th source to the j-the receptor is identified. If a receptor is not adjacent to the
source but there are one or more sub-basins in between, the path is forced to pass through the
center of mass of agriculture in each of these sub-basins. When a sub-basin does not contain
agriculture, its centroid is considered instead. Each receptor sub-basin can be therefore
characterized with the shortest path length to reach it from the i-th source (Lij), and in addition
with the shortest path length to reach its neighbor immediately closer to the source (Λ , ). The
shortest-path lengths between two generic nodes are computed as the Euclidean distances,
61
multiplied by the tortuosity factor of the origin node. On a par, each receptor sub-basin can be
characterized by the potential flow from the i-th source basin:
, = min max( , −𝛼 , ) , max( , − , ) . Equation
18
as well as the flow to its neighbor immediately closer to the source, which we denote as Φ , .
The pipeline connecting the i-th source to the j-th receptor requires a diameter to convey ,
for the length 𝐿 , − Λ , . In addition it needs the infrastructure, already sized to convey flow
to its neighbors closer to the source, to be appropriately upsized. In this exercise, we assume
that costs of pumping stations are additive (i.e., for each receptor basin there may be a
dedicated pumping station in line with the modularity principles often adopted in design). The
upsizing costs of pipelines are estimated as if the whole length Λ , were designed for flow
Φ , , and need to be adjusted now to the total flow , − Φ , . The cost of transport of water
between the i-th source and the j-th receptor can be then computed, in analogy with what
outlined above, as:
, =
( , )(𝐿 , − Λ , ) + ( , ) − ( 𝑒
, ) Λ , + E W ,
𝑣𝑎 . ,
+
′ ,
𝑣𝑎 . ,
+ 𝜓 Ψ ,
Equation
19
Where we posit:
, = . ( , + Φ , )
.
𝑒
, = . Φ ,
.
, = . F ,
.
Equation
20
And where E(*) is the expenditure function introduced before (Equation 9). Moreover, we
have:
Ψ , =
,
∗ (max , , − , , − , + 𝜏 𝐿 , + ) Equation
21
Where now , is the height of the expected obstacle to be met when crossing sub-basin
divides between the i-th and j-th sub-basins. We consider the 75th
percentile of catchment
elevation for each sub-basin on the shortest path between the i-th and j-th sub-basins, and we
assume that , is the maximum of these elevations.
, =
Ψ ,
∗
Equation
22
Wi,j=365Fi,j −
𝑇
Equation 23
The levelized cost of water from the i-th source sub-basin potentially used in the j-th sub-
basin is then given by:
𝐿 𝑊, =
,
,
+ 𝐿 𝑂𝑊𝑡 Equation24
62
Table 10 summarizes the attributes computed for each sub-basin, related to the transfer of
reclaimed water from the i-th to the j-th sub-basin.
Symbol Description Calculation
Fi,j Potential Flow of reclaimed water within the SB Equation 6,
Equation 18
Li,j Length of the pipeline for transport to the SB’s agricultural area Equation 7
Di,j Diameter of the pipeline for transport to the SB’s agricultural area Equation 8,
Equation 20
E(Di,j) Cost per unit length of the pipeline for transport to the SB’s agricultural area Equation 9
Wi,i Storage volume Equation 13,
Equation 23
E(Wi,i) Cost of storage volume Equation 14
Ψ , Energy required for transport and distribution of reclaimed water Equation 10,
Equation 21
, Power requirement for pumping Equation 11,
Equation 22
E’ , ) Cost of pumping stations for distribution within the SB Equation 12
, Cost of water distribution within the SB Equation 16,
Equation 19
𝐿 𝑊, Levelized cost of water within the SB Equation 17,
Equation 24
Table 10 – summary of computed attributes of each pair of related sub-basin (SB=sub-basin).
The above equations allow calculating the levelized cost of water for each potential source-
receptor link. In order to allocate a given water availability at a source, receptors need to be
ranked on the basis of cost criteria. The levelized cost as a function of the cumulative volume
of reclaimed water potentially allocated from a source is the so called source’s water-marginal
cost curve (WMCC). The WMCC is a tool used for investment strategy decision support in
the field of water infrastructure (McKinsey, 2009).
The actual volume of potentially reclaimed water at a source sub-basin that can be allocated to
the receptor sub-basins is the minimum between reclaimed water availability at the source and
irrigation demand in its neighborhood. The difference of these two terms represents the local
surplus or deficit of reclaimed water with respect to irrigation requirements. Demands of
receptors entailing a cost above a given threshold can be excluded.
The amount allocated from a source to any of its cost-ranked receptors is computed as the
potential flow, if the sum of all potential flows up to the receptor’s rank does not exceed
availability, else it is calculated as the difference between availability and the sum of potential
flows for all receptors featuring lower cost.
A receptor sub-basin may belong to the neighborhood of, hence be allocated water from, more
than one source sub-basin. In this case, a surplus may result from the sum of allocations. A
surplus may occur also when restricting potential flows with a cost threshold.
In this assessment, we refer to three cost scenarios:
(1) case when reuse requires developing all infrastructure from scratch (pipelines,
pumping stations and water storage);
63
(2) case when pipelines and pumping stations must be built, but storage can be made
using existing infrastructure;
(3) case when all infrastructure exists, and the costs are limited to treatment and energy.
For each of the above cases, we rank receptors based on the corresponding costs. For each
source sub-basin considered in the EU, the calculation yields the demand in the
neighbourhood that can be met under no restriction on costs, and with costs not exceeding a
threshold of 0.25, 0.50, 0.75, 1.00 Euro/m3
, in addition to the corresponding local surplus or
deficit.
Based on the above assumptions, we compute the variables summarized in Table 12.
Cost scenario # costs included target variable meaning
1 total costs source demand demand in the neighborhood
1 total costs source Cost1demand25 demand that can be met with costs <=0.25Euro/m3
1 total costs source Cost1demand50 demand that can be met with costs <=0.5Euro/m3
1 total costs source Cost1demand75 demand that can be met with costs <=0.75Euro/m3
1 total costs source Cost1demand100 demand that can be met with costs <=1Euro/m3
1 total costs receptor Cost1alloc supply that can be allocated
1 total costs receptor Cost1alloc25 supply that can be allocated with costs <=0.25Euro/m3
1 total costs receptor Cost1alloc50 supply that can be allocated with costs <=0.5Euro/m3
1 total costs receptor Cost1alloc75 supply that can be allocated with costs <=0.75Euro/m3
1 total costs receptor Cost1alloc100 supply that can be allocated with costs <=1Euro/m3
1 total costs receptor Cost1surplus surplus of receptor after allocation at 1 Euro/m
2 total costs - storage source Cost2demand25 demand that can be met with costs <=0.25Euro/m3
2 total costs - storage source Cost2demand50 demand that can be met with costs <=0.5Euro/m3
2 total costs - storage source Cost2demand75 demand that can be met with costs <=0.75Euro/m3
2 total costs - storage source Cost2demand100 demand that can be met with costs <=1Euro/m3
2 total costs - storage receptor Cost2alloc supply that can be allocated
2 total costs - storage receptor Cost2alloc25 supply that can be allocated with costs <=0.25Euro/m3
2 total costs - storage receptor Cost2alloc50 supply that can be allocated with costs <=0.5Euro/m3
2 total costs - storage receptor Cost2alloc75 supply that can be allocated with costs <=0.75Euro/m3
2 total costs - storage receptor Cost2alloc100 supply that can be allocated with costs <=1Euro/m3
2 total costs - storage receptor Cost2surplus surplus of receptor after allocation at 1 Euro/m
3 only energy and treatment receptor Cost3demand25 demand that can be met with costs <=0.25Euro/m3
3 only energy and treatment receptor Cost3demand50 demand that can be met with costs <=0.5Euro/m3
3 only energy and treatment receptor Cost3demand75 demand that can be met with costs <=0.75Euro/m3
3 only energy and treatment receptor Cost3demand100 demand that can be met with costs <=1Euro/m3
3 only energy and treatment receptor Cost3alloc supply that can be allocated
3 only energy and treatment receptor Cost3alloc25 supply that can be allocated with costs <=0.25Euro/m3
3 only energy and treatment receptor Cost3alloc50 supply that can be allocated with costs <=0.5Euro/m3
3 only energy and treatment receptor Cost3alloc75 supply that can be allocated with costs <=0.75Euro/m3
3 only energy and treatment receptor Cost3alloc100 supply that can be allocated with costs <=1Euro/m3
3 only energy and treatment receptor Cost3surplus surplus of receptor after allocation at 1 Euro/m
Table 12 – variables considered in the assessment of reuse costs.
The above cost model makes assumptions on the following parameters:
64
- Cost of energy
- Cost of storage
- Duration of the irrigation period
- Discount rate
- Depreciation period of pipelines
- Depreciation period of storage
- Depreciation period of pumping stations
- Incidence of O&M costs of pipelines
- Incidence of O&M costs of storage
- Incidence of O&M costs of pumping stations.
In addition, the model assumes a roughness coefficient and an energy gradient in the Hazen-
Williams formula used for the sizing of pipes. As these are typical, and largely conventional,
engineering assumptions, we ignore these two parameters in the sensitivity analysis. In order
to estimate a plausible upper and lower range for the computed levelized costs of water, we
consider two scenarios, which we label as “more favorable” and “less favorable” respectively.
In the former, we change the parameters from the base assumptions to values which
systematically reduce costs; in the latter, on te contrary, we alter the base values so to increase
the costs. Table 11 shows the values considered in the exercise.
Parameter Units Base value More favorable Less favorable
Cost of energy €/kWh 0.1 0.05 0.15
Cost of storage €/m3 5 2 8
Duration of the irrigation period Days 120 180 70
Discount rate % 5 2 7
Depreciation period of pipelines Years 50 75 25
Depreciation period of storage Years 50 75 25
Depreciation period of pumping
stations
Years 15 20 10
Incidence of O&M costs of
pipelines
% 3 1 5
Incidence of O&M costs of
storage
% 1 0.5 1.5
Incidence of O&M costs of
pumping stations.
% 1.5 0.5 2.5
Table 11 – alteration of model parameters in the global sensitivity analysis.
With reference to the two scenarios, we conducted a simplified global sensitivity analysis of
the cost model by computing the levelized costs of water for each source-receptor link
identified as detailed above. Figure 7, Figure 8 and Figure 9 show the scatter plots of costs
under base and altered conditions, including all costs (Figure 7), all costs excluding storage
(Figure 8) and only energy and treatment costs (Figure 9). From the plots, it is apparent that
65
the overall ranking of source-receptor links does not change appreciably, the dispersion of
points being always very narrow. This indicates that the cost analysis is sufficiently robust
with respect to the identification of priorities for water allocation.
Figure 3 – Levelized costs including pipelines, pumping stations, storage, energy and
treatment: comparison of the base case and altered values (orange=less favorable ;
blue=more favorable), using parameters as per Table 11.
66
Figure 4 – Levelized costs including pipelines, pumping stations, energy and treatment:
comparison of the base case and altered values (orange=less favorable; blue=more
favorable), using parameters as per Table 11.
Figure 5 – Levelized costs including energy and treatment: comparison of the base case and
altered values (orange=less favorable; blue=more favorable), using parameters as per Table
11.
Absolute costs may change significantly (especially when energy and treatment costs are
considered alone) but in a very predictable way as per the narrow scattering. When total costs
are considered, considering a more favorable alteration is practically equivalent to reducing
costs of about 0.25 Euro/m3 while a less favorable alteration increases costs of about 0.5
Euro/m3 (Figure 7). The alteration of energy and treatment costs alone is practically
equivalent to halving (for more favorable conditions) or multiplying by 1.5 (for less favorable
conditions) the levelized costs (Figure 9). When total costs excluding storage are considered,
the alterations have much less apparent effects (Figure 8).
Crop model
The EPIC model (Sharpley and Williams, 1990) was originally developed by the US
Department of Agriculture, and is now maintained and developed by the Texas A&M
University. It is an open-source code extensively used worldwide for crop simulations. The
model has been widely used for the simulation of crop yields, nitrogen and phosphorus
balances, and water requirements. The existing EPIC setup is used by the JRC in the context
of other European scale assessments. The EPIC model has been validated against independent
yield data (see § 4). EPIC model simulations have been used extensively in the last years for a
67
number of assessments by the JRC, including a study supporting the Impact Assessment of
the Water Blueprint in 2012 (de Roo et al., 2012).
Demand is estimated on the basis of calculated irrigation water requirements. We selected the
biophysical model EPIC because it simulates crop production under different farming
practices and operations including fertilization and irrigation application rates and timing and
because it considers nutrient losses to the environment (N leaching and runoff) (Figure 3). In
addition, it has been thoroughly evaluated and applied from local to continental scale
(Gassman et al. 2005) and used in global assessments (Liu et al. 2007). The model has been
applied for irrigation scheduling assessment (Wriedt et al. 2009), and biofuels production
(Van der Velde et al. 2009).
Figure 6. The EPIC model structure.
Furthermore the model is already integrated in a GIS system working at European scale
(Bouraoui et al. 2007). The GIS system includes all the data required for EPIC modelling
(meteorological daily data, soil profile data, landuse data with crop distribution and
agriculture management data) and all necessary sets of attributes required to simulate different
strategies, management and scenarios.
Wheat, barley, maize, rapeseed, oats, rye are major crops grown in Europe, while other crops
are more important in specific regions such as olive and fruit trees in southern Europe or
potatoes and sugar beet in Central and Northern Europe. There are many different cultivars
adapted to different climate and environments and characterized by peculiar growth properties
and productivity. Specific information on crop cultivars are not easily available at European
scale but these information are important in order to represent this spatial variability in the
model.
In this assessment, we make use of the results of the EPIC model setup at European scale
available at the JRC corresponding to “baseline” conditions, i.e. supposed to reflect the actual
SoilProfile
Inorg transf.
Nitrification
Volatilisation
Denitrification
P reaction
Org transf.
Pesticides
SurfaceResidues
Subsoilresidues
Humus
Soilproperties Management Weather
PlantGrowth
Above Gr
Below Gr
Harvest
Erosion
Gaseous
losses
Runoff
Runoff
Leaching
Leaching
Soilmoisture
SoilT
Soildensity
68
current levels of irrigation. Under this scenario, crop water requirements (m3/year) were
estimated at the cells of a regular 5km x 5 km grid across Europe.
The model setup used to estimate the average irrigation requirements is based on crop
distribution statistics defined at 5km resolution derived from the combination of CAPRI
(Britz, 2004), SAGE (Monfreda et al., 2008) and GLC (Bartholomé and Belward, 2005). The
amount of manure and mineral fertilization applied were retrieved from the Common
Agricultural Policy Regionalized Impact (CAPRI) agro-economic model (Britz and Witzke,
2008) and crop production optimized according to EUROSTAT statistics at NUTS2 level
(EUROSTAT, 2010a). Extension of irrigated land by crop was derived according to MIRCA
dataset (Portmann, 2011) and applied irrigated volume were validated at country level by
using EUROSTAT 2010 statistics (EUROSTAT, 2010b). Landuse and crop management is
assumed constant for the whole period of simulation.
First we identified 4 main regions in Europe, by performing a Cluster Analysis considering
the main parameters potentially influencing crop growth, such as climate (precipitation,
temperature, evapotranspiration, etc..), soil type (texture, organic matter content, drainage,
water storage capacity, etc. ) landuse and crop management (irrigation, fertilization plans,
etc.). The initial cluster included 9 regions (Figure 4) that were reduced to four macro regions.
The crop parameters were adapted for these four macro-regions.
Figure 7 . Main clusters and selected regions for Europe detailed (left) and simplified (right).
The parameters affecting crop growth that were modified to customize EPIC to specific
regional conditions included the optimal and base temperatures, the biomass growth rate
parameter and the harvest index.
In our approach the optimization aimed at minimizing the differences between simulated and
reported yields (EUROSTAT data) in different macro regions. We used the Multi Objective
Genetic Algorithm (MOEA) library by Udías (2011) to optimize the selected set of
parameters controlling the crop growth and productivity.
69
A comparison between simulated and reported annual yields (for last reporting period)
aggregated at NUTS 2 level for all Europe is presented in Figure 5. The simulated yields
compare well with the reported ones for all major crops, keeping in mind that the reported
statistical data are not available for all the years considered (2008-2011) and that in some
cases only data at country level is available. This analysis demonstrated the capability of the
model to capture the spatial and annual variability of yields.
Figure 8. Scatter plots with means simulated yields versus reported regional crop yields for
some major cereals, forage crops in Europe.
The EPIC model calculates annual crop water requirements, expressed in m3 per grid cell of
25 km2 (Figure 9). For each grid cell, we computed the hectares of agricultural land as the
number of pixels of the 100 m x 100 m CLC 2012 map classified as “agricultural” (CLC
2012 level 1 code =2, with exclusion of level 3 code 231 – pastures) falling within the cell.
Dividing the crop water requirements by the number of hectares allowed estimating a crop
water requirement per unit area (unit requirement). Each sub-basin was attributed the unit
requirement from the grid cells intersecting it, in proportion to the area of the grid cells on a
sub-basin. The crop water requirement per sub-basin, Ii, was finally estimated as the unit
requirement multiplied by the number of 100 m x 100 m agricultural CLC 2012 pixels falling
within the sub-basin.
It should be stressed that we consider irrigation demand merely as the water required by
crops. In reality, more water may be required for irrigation than what is actually used by
crops. This water includes the losses along canals and pipelines, as well as the water
evaporating or leaching below the root zone during field applications. We do not make a
distinction here between crop water requirements and the actual amount required for
irrigation. The latter is assumed to coincide with the former, i.e. we assume irrigation
0
2
4
6
8
10
12
0 2 4 6 8 10 12
Simulated
[tons
ha-1]
Reported [tons ha-1]
Wheat
0
1
2
3
4
0 1 2 3 4
Simulated
[tons
ha-1]
Reported [tons ha-1]
Rape
0
2
4
6
8
0 2 4 6 8
Simulated
[tons
ha-1]
Reported [tons ha-1]
Rye
70
efficiency to be 100%, compatibly with the objective of this work which is an indicative
comparison between requirements and availability. This aspect should be considered
particularly when interpreting the results with reference to highly inefficient irrigation
systems.
Figure 9- average irrigation water requirement used in this assessment, as computed with the
EPIC model.
Quantification of the benefits from reuse.
Valuing the benefits that may stem from water reuse is overwhelmingly complex in general
terms. One proxy of benefits is the willingness to pay of farmers for reclaimed water, which is
extremely variable (for instance, Birol et al., 2007[1]
estimate a willingness to pay higher than
0.6 Euro/m3 in Cyprus, while Tziakis et al., 2009[2]
, indicate less than 0.1 Euro/m3 for
Crete).
Mattheiss and Zayas, 2016[3]
analyse a case study in Braunschweig, Germany and another one
in Sabadell, Spain. In Braunschweig, a survey has identified a willingness to pay of about 3 to
5 million euro/year for about 7 million m3/year of water reused to recharge aquifers, which
[1]
Birol, E., P. Koundouri, and Y. Kountouris (2007), Farmers’ demand for recycled water in Cyprus: A
contingent valuation approach, in Wastewater Reuse––Risk Assessment, Decision-Making and
Environmental Security, edited by M. K. Zaidi, pp. 267–278, Springer, Dordrecht, Netherlands.
[2]
Tziakis, I., I. Pachiadakis, M. Moraittakis, K. Xideas, G. Theologis and K. P. Tsagarakis (2009), Valuing
benefits from wastewater treatment and reuse using contingent valuation methodology, Desalination, 237,
117–125.
[3]
Mattheiss, V., Zayas, I., Social and environmental Benefits of water reuse schemes – economic considerations
for two case studies. DEMOWARE project deliverable 4.4, 2016. http://demoware.eu
71
could be interpreted as a valuation of water to improve flow regimes between 0.4 and 0.7
Euro/m3. In Sabadell, the willingness to pay of households for irrigation of green areas and
street cleaning is estimated to exceed 5.5 million Euro/year, and the water demand for these
activities is estimated at 1.1 million m3/year, indicating a value of water in the order of 5
Euro/m3.
Arborea et al., 2017, quantify the benefits of reusing water for irrigation in Puglia in the order
of slightly less than 0.5 Euro/m3, including the direct and option benefits for the farmers and
the benefits of maintaining good groundwater status.
Molinos_Senante et al., 2011[4]
, quantify the benefits of reuse using shadow prices of
pollutants (suspended solids, nutrients and Chemical Oxygen Demand) not being discharged
to rivers (therefore assuming the impact of such pollutants through irrigation would be
negligible). In addition, they consider a sale price of reclaimed water of 0.9 Euro/m3. The
total net benefits summing these components are estimated at a mean value of 1.22 Euro/m3
for 13 wastewater treatment plants in Spain.
Maton et al., 2010, conduct a cost-benefit analysis for water reuse in western Crete, and show
that net benefits of reuse depend significantly on the level of stress on water resources; for
cases of high water stress, net benefits range between 0.35 and 1.92 Euro/m3. Alcon et al.,
2010[5]
, estimate the Segura river basin population’s willingness to pay for irrigation reuse at
about 0.3 Euro/m3, which is presented as the non-market value of reused water. This should
be summed to the willingness to pay of farmers or market value of reclaimed water, so that
the overall value of reclaimed water can be arguably around 0.5 Euro/m3. Birol et al., 2009[6]
present an estimate of the willingness to pay for aquifer recharge by local residents in Cyprus
of about 1.3 Euro/m3.
In the context of the AQUAMONEY EU-funded project[1]
, the willingness to pay of the
public has been assessed for different actions improving water quality, safety and security in a
few case studies across Europe (Table below – case studies). The case studies highlight a
significant willingness to pay of households for a more sustainable management of water
resources. This may support the idea that a part of the costs of water reuse could be borne by
society/taxpayers and not only by the farmers alone, since water reuse generates additional
benefits to society.
Case Motivation Willingness to pay
Vienna (AT) Reduce flooding frequency and
improve water quality
About 52 to 78
€/household/year
Hungary Reduce flooding frequency and
improve water quality
About 35 to 54
€/household/year
[4]
Molinos-Senante, M., Hernandez Sancho, F., Sala Garrido, R., Cost-benefit analysis of water reuse projects
for environmental purposes: a case study for Spanish wastewater treatment plants. Journal of Environmental
Management, 92 (2011) 3091-3097. DOI: 10.1016/j.jenvman.2011.07.023
[5]
F. Alcon, F. Pedrero, J. Martin-Ortega, N. Arcas, J. J. Alarcon, and M. D. de Miguel, The non-market value of
reclaimed wastewater for use in agriculture: a contingent valuation approachSpanish Journal of Agricultural
Research 2010 8(S2), S187-S196. URL: www.inia.es/sjar
[6]
Birol, E., P. Koundouri and Y. Kountouris (2009), Assessing the economic viability of alternative water
resources in water scarce regions: The roles of economic valuation, cost–benefit analysis and discounting, paper
presented at 27th International Association of Agricultural Economists Conference, Beijing, 16–22 Aug.
[1]
http://www.ivm.vu.nl/en/research-new/environmental-economics/projects/aquamoney/project-
deliverables/index.aspx
72
Braila (RO) Reduce flooding frequency and
improve water quality
About 9 to 22
€/household/year
Odense (DK) Reduce flooding frequency and
improve water quality
About 57 to 192
€/household/year
Po and Reno river basins (IT) Ensure water availability for
different sectors (agriculture,
industry, energy,… and the
environment
About 10 to 40
€/household/year
Serpis (Jucar) river basin (ES) Ensure domestic water supply and
improve/maintain ecological status
297 €/household/year for
supply; 64 to 104 for
ecological status
Lesvos (EL) Ensure domestic water supply and
improve/maintain ecological status
287 €/household/year for
supply; 44 to 253 for
ecological status
These examples highlight the large variability in valuation of water used to reduce water
stress, and the uncertainty due to their high case-specificity. If a benefit of water reuse of 0.5
Euro/m3 was assumed, which is in the mid-lower end of the cases examined above, and may
be argued to represent as a first approximation the combined market and non-market value of
water reuse in Europe, provided it contributes to water stress reduction, there would be
willingness to pay the assumed costs of water reuse.
73
Calculation of administrative burden for policy options for water reuse for agricultural irrigation (Ir1, Ir2 and Ir3, if followed) and aquifer recharge (Re1, if
followed and Re2).
Minimum quality requirements for water reuse for irrigation and aquifer recharge
Tariff
(€ per
hour)
TIme
(minutes)
Price
(per
action)
Freq
(per year)
Nbr
of
entities
Total
number
of
actions
Equipment
costs
(per entity
& per year)
Outsourcin
g
costs
(per entity
& per year)
Total
Administra
tive Costs
Business
As Usual
Costs
(% of
AC)
Total
Administrative
Burdens
(AC - BAU)
No. Art.
Orig.
Art.
Type of obligation
Description of
required action(s)
Target group
1
Application for individual
authorisation or
exemption for water
reuse for agricultural
irrigation
Producing new data
water operators
would need to
perform risk
assessment and
adjust/ issue
permits at
UWWTP level
for water reuse
for agricultural
irrigation
32 1.200,00 641 1 3.50036
3.500 2.244.176 0% 2.244.176
2
Application for individual
authorisation or
exemption for water
reuse for aquifer
recharge
Producing new data
water operators
would be
required to
perform risk
assessment for
water reuse for
the 220 sites of
aquifers which
could be
potentially
recharged with
reclaimed water
32 1.200,00 641 1 22037
220 141.063 0% 141.063
36
The number of UWWTPs estimated as a percentage similar to the ratio of volume that can be allocated at costs <0.5 euro/m3, divided by total volume available at WWTPs
(see Figure 10 in Section 5 of the Impact assessment report). This is about 13%, therefore 0.13 x 25,000 = 3250.
37
The estimated number of aquifers in the EU (see Annex 6)
74
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EN 77
Annex 5 - Problem tree
Factor 4: Reuse
perceived as
more risky than
beneficial
Low uptake of reuse
compared to its potential
Continued water scarcity
Missed business
opportunities for water
companies & innovation
Vulnerability of
water uses
Deterioration of
WB status
Low supply of
water to be reused
Low demand of
water to be reused
Factor 1: Reused water is less attractive
than conventional water resources
Abstraction of
conventional
water resources:
- insufficiently
controlled
- under-priced
Factor 2:
No/unclear/complex
legal framework for
water reuse in MS
resulting in
perceived health &
environmental risks
PROBLEM
CONSEQUENCES
DRIVERS
Unnecessary
treatments
Unnecessary removal of
nutrients from waste water
Missed opportunity for
recycling as fertilisers
Information failure
Regulatory failure
Market failure
ket failure
Factor 3: Possible
trade barriers for
food products
reusing water
Lack of
information
about actual
risks
Again factor 2:
Different quality
requirements for water
reuse across MS
Lack of
understanding
of benefits
Reuse not
integrated
in water
managem
ent
Lack of
enabling
investment
environme
nt
Technological
limitations
Issue addressed in
the initiative
78
Annex 6 - The purposes and benefits of reusing water - situation in selected Member
States
In this report, the term "water reuse" is used interchangeably with the terms "reuse of treated
wastewater" and "use of reclaimed water". They all stand for the use of water which is
generated from wastewater and which, after the necessary treatment, achieves a quality that is
appropriate for its intended uses (taking account of the health and environment risks and local
and EU legislation). Unless it is specified otherwise, the source of reclaimed water is urban
wastewater in accordance with the Urban Waste Water Directive. "Water reuse" refers to
planned or intended water reuse, namely water reuse schemes that are developed with the
goal of beneficially reusing a recycled water supply. Water reuse for irrigation typically
allows substituting abstractions from depleted aquifers with reclaimed water which would
otherwise be discharged to rivers. In contrast, unplanned water reuse refers to uncontrolled
reuse of treated wastewater after discharge. An example of unplanned reuse of wastewater is
when effluents from a wastewater treatment plant are discharged upstream in a river while
river water is abstracted downstream for the production of drinking water or for irrigation.
Treated wastewater may be used for a wide variety of purposes, and there is continuing
innovation in potential uses. These include:
 Contributing to environmental objectives/making water available for future uses such as
aquatic ecosystem restoration or creation of new aquatic environments, stream
augmentation (especially in dry seasons), aquifer recharge (e.g. for saline intrusion
control or later abstraction for use such as the further uses below).
 Agricultural/horticulture uses such as irrigation of crops (food and non-food), orchards
and pastures.
 Industrial uses such as cooling water, process water, aggregate washing, concrete
making, soil compaction, dust control etc.
 Municipal/landscape uses such as irrigation of public parks, recreational and sporting
facilities, private gardens, road sides, street cleaning, fire protection systems, vehicle
washing, toilet flushing, dust control.
79
Figure 25: Global water reuse after advanced (tertiary) treatment: Market share by application
Reusing water for aquifer recharge
Aquifer recharge is a hydrological process where water moves downward from the soil
surface towards groundwater. Recharge occurs both naturally (through the water cycle) and
man-induced (i.e. artificial aquifer recharge), where rainwater, surface water and/or reclaimed
water is routed to the subsurface. Artificial groundwater recharge aims at increasing the
groundwater potential and it can effectively help preventing saline intrusion in depleted
coastal aquifers. The lack of scientific and technical knowledge (including lack of clarity of
ownership and liability), coupled with low perception of this kind of technique being an
important water management instrument, contribute to the low uptake at present (Escalante,
2014). The barriers identified for aquifer recharge specifically include: the limited
knowledge on the receiving waters, in particular the impacts on water quality due to the
mixing; technical problems associated with the design and choice of the recharge technique;
poor quality of water used for the recharge (often of lesser quality than potable water or with
presence of emerging pollutants -pharmaceuticals, industrial chemicals, pesticides and
degradation products) resulting in a potential to degrade the receiving groundwater;
downstream impacts on environment and other users; and socio-economic challenges
(Escalante, 2014). The risks to health and the environment from pollutants such as bacteria,
viruses and emerging pollutants and priority substances such as those already detected
occasionally in discharges from water treatment plants (and in high concentrations) are also
perceived as an obstacle (Estévez et al., 2016; Estévez et al., 2012). However, in the first
public consultation, aquifer recharge was one of the most often mentioned additional
appropriate uses, in particular in order to prevent saline intrusion.
As illustrated in Figure 26, managed aquifer recharge (MAR) is a practice relatively
widespread in Europe. In a comprehensive but non-exhaustive review FP7 project DEMEAU
80
could identify about 270 sites (220 being still active), with a spatial distribution covering
most of the European countries. Different water sources can be used for MAR. River and lake
water and groundwater have been the most commonly used influent so far, while treated
waste water has remained rather limited (12 sites out of 270 in the DEMEAU catalogue, in
Belgium, Germany, Italy, Greece and Spain). In most case recharge with reclaimed water is
done via surface spreading and more limitedly injection (4 sites).
Figure 26: spatial distribution of MAR sites in Europe and primary source of water
(Hannappel et.al, 2014)
In addition to the benefits in terms of freshwater availability, there is a wide range of
environmental benefits associated with reuse schemes, in particular:
 Reducing pressure on water bodies, maintaining ecological flows and
protecting aquatic ecosystems;
 Preserving high-quality groundwater for more sensitive uses (e.g. drinking
water production);
 Decreasing the nutrient pollution load directly discharged to rivers or other
waterbodies, and the associated risks of eutrophication;
 Improving the quality of irrigation water and bathing waters. Currently,
irrigation water sources should comply with the definition of "clean water" at
the point of use, i.e. water "that does not contain micro-organisms, harmful
substances in quantities capable of directly or indirectly affecting the health
quality of food" according to Article 2 of Regulation 852/2004. Further details
on implementation of this requirement are given in the Commission Notice
2017/C 163/0138
"Guidance document on addressing microbiological risks in
fresh fruits and vegetables at primary production through good hygiene";
38
2017/C 163/01 - http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ%3AC%3A2017%3A163%3ATOC
81
 Restoring or enhancing biodiversity and the various ecosystem services
associated with wetlands;
 Protecting groundwater resources from saline intrusion, particularly in islands
and coastal areas (through groundwater recharge);
 Reducing the amount of organic fertilisers applied to irrigated fields, thereby
contributing to conserving natural resources of phosphorus and reducing
environmental impacts associated with fertilisers’ manufacture;
 Decreasing the level of purification/treatment necessary for discharging
wastewater, thereby reducing energy consumption associated with water
treatment, while guaranteeing compliance with all the relevant legislation.
In the second open public consultation, a majority of respondents (more than 70% across
and within different categories of respondents) perceive the environmental benefits of
reusing water for agricultural irrigation for:
 reducing pressure on resources that are over-abstracted,
 reducing water scarcity, and
 thereby adapting to climate change.
These potential benefits are particularly highlighted by respondents from the sanitation,
drinking water and environment/climate sectors as well as respondents from countries in
regular situation of water stress or more generally from Southern EU (over 80% of
respondents within each of these categories).
A large number of respondents (more than 70% of all respondents) also identify the
following environmental benefits:
 increased resource efficiency,
 enhanced innovation potential in the water industry, and
 reduced pollution discharge from urban wastewater treatment plants into rivers.
In this respect, a utility provider recognised that capture of effluents currently
discharged in coastal areas would benefit the environment. An academic
representative noted that the increased stringency on water treatment plants to
produce high quality reused water would indirectly benefit the environment by
enhancing the global quality of water discharged.
82
Figure 27: Overview on potential benefits of water reuse in agricultural irrigation, for all respondents
A large share of respondents (more than 70%) perceive the environmental benefits of reusing
water in aquifer recharge for:
 reducing pressure on resources that are over-abstracted: an industry association
representing French water companies highlighted in particular the benefits of the
limited evaporation allowed by water storage in the aquifer,
 reducing water scarcity, and
 protecting coastal aquifers against salt intrusion.
In addition, water reuse is perceived by a significant number of respondents across all sectors
(over 70%) to contribute to fostering the innovation potential in the water industry.
A large proportion of respondents also considers adaptation to climate change and reduced
pollution discharge into rivers as benefits of reusing water for aquifer recharge, although they
are considered slightly more moderate than the first ones and appear less consensual across
sectors and categories of stakeholders. Several respondents commented on the benefits of
aquifer recharge to reduce pollution discharge, e.g. by reducing water exposure to various
contaminations and eutrophication occurring at the surface of the earth and through filtering
services from the soils.
0% 20% 40% 60% 80% 100%
Cost savings for public authorities
Energy and carbon savings (in waste water treatment and irrigation)
Job creation
Contribution to soil fertilisation
Increased revenues for other sectors (due to higher water availability)
Increased revenues and/or reduced costs for the agricultural sector
Innovation potential in the water industry
Increased resource efficiency (nutrients recycling
Reduced pollution discharge from urban waste water treatment…
Adaptation to climate change
Reducing of water scarcity
Reduced pressure on over-abstracted water resources
High Medium Low I don't consider this as a potential benefit I don’t know
83
Figure 28: Views on potential benefits of water reuse in aquifer recharge
Because the uptake of water reuse solutions will remain very limited at the EU level in the
baseline scenario, these other benefits are unlikely to materialise at a wide scale across the
EU.
On the other hand, environmental risks potentially associated with treated wastewater reuse,
such as chemical contaminants from inorganic salts, nutrients, heavy metals and micro
pollutants, e.g. detergents, would also remain minimal. Emerging pollutants, such as
pharmaceutical products and their metabolites, personal care products, household chemicals,
food additives, etc., in particular, represent a growing environmental concern. At the moment,
however, there is not yet full scientific consensus on the actual level of risks associated with
many of these various substances and further research is thus required.
Current status of water reuse in the EU – selected Member States
In 2006, the total volume of reused treated wastewater in the EU amounted to 964 million
m³/year, accounting for 2.4% of the treated urban wastewater or less than 0.5% of annual EU
freshwater abstraction (Hochstrat et al., 2006). No complete and harmonised data are
available on the current volume of treated wastewater being reused in the EU; however the
current volume of reused treated wastewater in the EU can be estimated at 1,100 million
m3
/year or 0.4% of annual EU freshwater abstractions (BIO, 2015).
In 2006, Spain and Italy jointly accounted for about 60% of the total EU treated wastewater
reuse volume, predominantly for agricultural irrigation and for urban or environmental
applications. Other countries are reusing much less, and the reuse figures broadly decline the
further north one goes. In relative terms (i.e. in comparison to treated wastewater volume
generated in each of the Member States), reuse was considered significant in Cyprus and
Malta where 89% and about 60% of treated wastewater treatment plant effluents are being re-
used respectively for various purposes. In other countries, such as Greece, Italy and Spain
reuse of treated wastewater constituted between 5% and 12% of total treated effluent from
wastewater treatment plants. Figure 29 below presents the amount of reused treated
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Cost savings for public authorities
Energy and carbon savings
Job creation
Increased revenues and/or reduced costs for…
Innovation potential in the water industry
Reduced pollution discharge from urban waste water…
Improved resilience/adaptation to climate change
Protection of (coastal) aquifers against salt intrusion
Reduced water scarcity
Reduced pressure on over-abstracted water resources
High Medium Low I don't consider this as a potential benefit I don’t know
84
wastewater in European countries, as estimated by FP5 project AQUAREC in 2006, relative
to the spatial distribution of water stress.
Figure 29: Reuse of reclaimed water in Europe (Hochstrat et al., 2006)
The literature suggests that some countries have little or no evidence of any water reuse
schemes; this is understandably the case in countries with high water availability and low
drought risk, such as Ireland or Finland. However, some Member States that have
experienced severe water stress recently are also in this situation, including some Baltic
countries (e.g. Latvia and Lithuania), as well as Eastern European countries (Romania,
Bulgaria, Slovakia, Slovenia, and Hungary). It is important to highlight that the southern and
Baltic states usually have efficient urban waste water treatment plants, hence there is
potential for reusing reclaimed water. Such potential is more limited in Eastern European
states, where many treatment plants are not yet equipped with appropriate treatment
technologies at present. However the need for upgrade and refurbishment of these treatment
plants to comply with the UWWTD also provides an opportunity for considering water reuse
as a possible solution at lesser costs than would be needed to integrate water reuse at a later
stage.
Member States in which water reuse is being practiced include Scandinavian countries
(Sweden, Denmark), southern European states (Spain, Cyprus, Malta, Italy, Greece, Portugal)
as well as North-Western countries (France, Belgium, UK, Luxembourg, the Netherlands). In
Luxembourg, Sweden and Denmark, water reuse is driven by high water prices and
ecological concerns, especially during the summer. For instance, several Danish industries
recycle wastewater, while in Sweden treated wastewater is used for irrigation purposes.
Reuse of water for agricultural activities is also very widespread in southern European
countries, although it must also be highlighted that water reuse in these countries is also
driven by tourism, for example for irrigation of golf courses and parks. In European regions
that are not water-scarce but experience episodic drought events, water recycling is becoming
much more widespread and being implemented in the agricultural, urban and industrial
sectors. This is the case for countries such as the UK and France, where competition for
increasingly limited water resources during peak demand periods is driving interest in
alternative sources. Even short dry spells in humid or temperate countries can trigger
temporary restrictions in freshwater abstraction.
85
Furthermore, interest in water reuse implementation can be evaluated by considering the
number and geographical spread of projects in Europe. Such an analysis was conducted in
2005 during the AQUAREC project (Figure 30). In the course of this Impact Assessment
updated and consistent data on water reuse projects in Europe has been collected, in
particular as concerns information already reported by Member States to Eurostat and to the
Commission under the WFD and UWWTD. Given the relatively recent interest for these
technologies in a number of Member States only very limited data is available at this stage
and suggests the possible need for adapting existing reporting tools in the future for
monitoring and evaluation of this policy area (Chapter 7).
Figure 30: Identified water reuse projects in Europe, incl. their size and intended use (Bixio et al., 2005)
All information sources agree on the significant potential for further development of water
reuse projects in the EU. Climate change pressures are likely to increase the level of interest
in such solutions for both mitigating wastewater disposal impacts and episodic drought
effects (Falloon et al., 2010). Moreover, a number of countries are developing the policy and
– for those that do not possess suitable wastewater treatment technology – technical
capacities needed to promote the uptake of water reuse solutions.
The global market for water reuse is expected (Global Water Intelligence, 2015) to be fast-
growing in the coming years. Between 2011 and 2018 capital expenditure on advanced water
re-use was expected to have grown at a compound annual rate of 20% (cf. Figure 31 as the
global installed capacity of high quality water re-use plants grows from 7 km³/yr to
26 km³/yr.
86
Figure 31: Global water resources development market 2011–2018 (GWI, 2015)
As confirmed by the number of projects funded by the EU on this topic in the last decade and
by experts in a dedicated workshop (cf. Annex 8) water reuse is an active field for research
and innovation.
Details on the current state of water resources and treated wastewater reuse in agricultural
irrigation and aquifer recharge in selected Member States are presented in the section below.
The selection covers Spain, Italy, Greece, Cyprus, France and Romania representing a wide
range of Member States including countries with and without existing national standards on
treated wastewater reuse, major and small users of treated wastewater in the EU as well as
Member States where significant share of treated effluent from wastewater treatment plants is
being reused.
Spain
In terms of water reuse, all of RBDs in Spain already consider water reuse in their RBMPs.
Current data from the second cycle of RBMPs (all River Basin Districts included except
Catalonia and Canary Islands, where the most updated data from the river basin authority
have been used) shows that reclaimed water in Spain reached 413 hm3
/yr in 2013. Their
estimations at the plan submission date approached 520 hm3
/yr for 2015 with extended
projections in 2021. Should these projections and regional plans for water reuse – e.g. Madrid
and Catalonia, be factored in, the total estimated volume would soar up to 1,150 hm3
/yr,39
showing what actually a potential upper bound is if all planned investments are in fact
implemented.
Total volumes disclosed in the Survey of Water Supply and Sanitation, according to official
data from the Office for National Statistics (INE, 2015a) differ from the RBMPs data, with a
total volume of water reuse of 531 hm3
per annum in 2013. Disparities may be due to
differing criteria on the year used as a “current reference” within RBMPs. The total amount
of reclaimed wastewater was 11% of the total volume of wastewater treated in 2013. This
share remained steady (10-12%) from 2007, when the Spanish water reuse regulation came
into force. Before 2007, the average value was lower than 8%. Again, the situation was
39
According to the draft National Plan for Water Reuse (MARM 2010a), which was not further developed and
implemented as such
87
especially remarkable in SE Spain (including Segura and Júcar River Basin Districts, plus the
Balearic Islands), where 62%, 55% and 48% of wastewater treated was reused in 2013,
respectively (INE, 2015a).
Additional information is available from non-official sources. AEAS (Spanish Association of
Water Supply and Sanitation Services) (2014) reported that the use of reclaimed wastewater
in 2012 was around 9.7% of treated wastewater. 77.3%, as above, were reused in agriculture,
10.2% in other forms of irrigation (leisure areas), 9.7% to undetermined uses, 2.2% in
manufacturing, and 0.6% for cleaning. Updated information produced by AEAS and reported
by iAgua (2016) shows significant changes in these shares: irrigated agriculture (41%), other
irrigation uses (31%), industrial (12%) and other undetermined uses (16%).
In turn, FENACORE (National Federation of Irrigation Districts) have recently projected
water reuse in Spain in 2016 on the basis of information reported to the Commission in the
second cycle of river basin management plans. This yields a rough estimate of 400 million
m³/year of reused water out of a total urban wastewater volume of 3,500 million m³/year.
The cost of water reuse treatments are asymmetric depending on the treatment used to meet
legal water quality requirements: the upfront investment cost can vary from 5 €/m3
produced/day (filtration) to 736 €/m3
produced/day (chemical treatment with a lamella
settling system, ultrafiltration, reverse osmosis) and operational and maintenance costs may
vary from 0.04 €/m3
(filtration, and disinfection or depth filtration) to 0.35-0.45 €/m3
/day
(with lamella/double depth chemical precipitation, ultrafiltration, RO/EDR desalination and
disinfection). A specific example of costing in a region with a consolidated capacity of
reclaimed wastewater reuse (Valencia, see Molinos-Senante et al., 2013) shows an average
opex for secondary treatment of 0.26 €/m3
, 0.32 €/m3
for tertiary treatment, and 0.57 €/m3
for
advanced treatments such as osmosis or ultrafiltration.
The legal framework for water reuse is quite an advanced one at EU level. Nationwide, water
reuse is regulated by Royal Decree 1620/2007 (December 7th
), which establishes quality
criteria (maximum acceptable values, presence-absence for certain parameters according to
the type of water use) as well as risk management measures including inter alia both for reuse
of treated wastewater in agricultural irrigation and aquifer recharge.
The Decree expressly forbids reclaimed water for the following uses:
- Human consumption, with the exception of a catastrophic event;
- Food industry, except process and cleaning waters, as in Art 2.1b) of Royal Decree
140/2003;
- Hospitals and alike;
- Filter-feeding molluscs aquaculture;
- Bathing waters (recreational uses);
- Cooling towers and evaporation condensers, with exemption criteria for some
industrial uses;
- Fountains and ornamental plates in public or interior spaces of public buildings; and
- Any other use public health or environmental authorities may consider as a risk,
whatever the time when the risk or the damage are perceived.
88
Hence, allowed uses are urban irrigation or other uses (section 1), agricultural irrigation
(section 2), industrial uses (section 3), recreational uses (section 4), and environmental uses
(i.e. aquifer recharge inter alia) (section 5).
Additional related regulations / guidelines / planning instruments include a) the already
mentioned water reuse planning instrument, still in a stagnant, draft stage (the National Water
Reuse Plan, MARM, 2010a); b) all the 2nd
River Basin Management Plans already adopted
(i.e. main RBDs, Balearic Islands, Galicia Coast and Andalusian RBDs (see BOE 2016a;
2016b) as they contemplate water reuse measures, and c) an official specific document
containing guidelines for the application of Royal Decree 1620/2007 (MAGRAMA, 2010b).
As per water reuse in agriculture, Appendix I.A. of the Decree sets up water quality criteria
for intestinal nematodes, Escherichia coli, suspended soils, turbidity, and additional criteria
such as Legionella spp., Taenia, and complying with Environmental Quality Standards
regarding several pollutants. Regarding water reuse for aquifer recharge, similar criteria are
defined and others are added, such as nitrogen and NO3, both for recharge through surface
infiltration (indirect recharge) or injection (direct recharge). In terms of monitoring,
Appendix I.B of the Royal Decree 1620/2007in turn establishes the minimum sampling and
testing frequencies for each quality parameter.
Agricultural irrigation
Conventional agriculture, dominated by extensive crops with low returns per hectare (cereals
yield in 2012 amounted 2,843 kg/ha, average for both rain-fed and irrigated fields)
(MAGRAMA, 2014), dependent on public infrastructure and EU subsidies (i.e. CAP)
contrasts with a dynamic, intensive and highly productive agriculture driven by market
stimulus and competitive advantages, with limited financial support either from the local
government or the EU (if at all). The largest examples can be found in the Castile and León
region, in central Spain, with an average size of 57.7 ha, while those in the southeast are
amongst the smallest, with an average size between 5.07 and 11.72 ha (INE, 2014).
The overriding traditional model of agriculture requires limited labour and manufactured
inputs; management practices do not demand sophisticated commercial and financial
services; and output does not feed complex industrial processes or supply chains. In contrast,
the relatively modern and thriving agriculture that dominates water-scarce Mediterranean
basins requires increasingly more sophisticated inputs and labour skills, follows modern
entrepreneurial practices, and supplies basic commodities for a complex and competitive
agro-food manufacturing and logistics industry.
Whereas apparent productivity in the regions of Castile and León (central Spain) and
Andalusia (southern Spain) is the same (0.56 €/m403
), indirect water productivity in Andalusia
is actually larger (1.75 €/m3
) than that of Castile and León (1.65 €/m3
), showing that the
40
Value of agricultural output (EUR) per m3
of water added
89
Andalusian agriculture has more relevant forward linkages with the rest of the economy
(Pérez et al., 2010).
In regions like Andalusia and Murcia the direct contribution of agriculture to the regional
output and employment (4.2% and 4.5%, respectively) might be low (although higher than
average), but its indirect and induced impact over the whole production chain makes it the
central piece of the existing income and employment opportunities.
According to de Stefano et al. (2015), estimated water demand (surface and groundwater
sources) for agriculture amounts to approximately 25,000 million m³/year (or 79% of total
water demand). Groundwater abstraction is estimated at circa 6,125-6,925 million m³/year
(19-22% of Spain´s total water demand) out of which 70-72% (4,300-5,000 million m³/year)
is used for around one third of irrigated land (0.9 million hectares, on the basis of 3.3 million
of irrigated ha). Following INE (2015), available water for irrigation in Spain comes from
surface sources (77%), groundwater (21%), and desalination or reuse (2%). Arable crops
account for 56% of water for irrigation whereas 16% is for fruit trees, 10% for olive trees and
vineyards, 9% for other crops and 8% for potatoes and vegetables. Irrigation techniques have
moved away from gravity (still 37%) towards drop irrigation (37% also) and sprinkler (26%).
It is of paramount importance to highlight groundwater prices in areas of the country with
high water scarcity, since this is critical to understanding some of the variables for further
penetration of water reuse for agriculture. According to Custodio (2015) common prices for
groundwater in SE Spain range between 0.3 and 0.5 €/m3
(and can be higher depending on
conjoint use and the cost of energy for pumping). In the Canary Islands usual prices are
around 0.5 €/m3
though during peak demand they can go beyond 1 €/m3
.
Aquifer recharge
According to the last implementation report of the WFD (EC, 2015), the number of
delineated groundwater bodies (GWB) in Spain is 748, with an average size of 482 km2
and a
total area of more than 355,564 km2
. De Stefano et al. (2015) estimated that groundwater
abstraction is around 6,125-6,925 million m³/year i.e. around 22% of the total water demand.
Agriculture is the main groundwater user (70-72%), followed by domestic supply (23-22%)
and industry (6-5%) and, to a lesser extent, recreational uses (0.4%). The chemical status of
GWB (% by number of bodies) was good for 66.0%, poor for 32.9% and unknown for 1.1%.
On quantitative grounds, the status was good for almost three quarters (71.3%), poor for
27.3% and unknown for 1.5%.
Estimates from the DINA-MAR Research Project (Escalante, 2014) show that managed
aquifer recharge (MAR) in Spain hits 380 million m³/year. According to the DEMEAU
Project (Hannappel et al., 2014), 25 out of the 270 European known MAR sites (9%) are in
Spain, most of them (López-Vera, 2012) in Mediterranean regions.
At European scale, Spain is the European country where MAR for irrigation is most common.
Environmental uses (e.g. to restore the hydraulic gradient to mitigate seawater intrusion at the
Llobregat aquifer in Barcelona – by means of injection wells/ infiltration through infiltration
90
ponds, and Marbella) are also common (as in other European countries such as Germany and
the Netherlands). In Spain, in practice all MAR schemes are implemented in fluvial deposits.
Main types of MAR are Aquifer Storage and Recovery (ASR) and Aquifer Storage Transfer
and Recovery (ASTR) and infiltration ponds, followed by flooding and, to a lesser extent, by
others such as pits and excess irrigation, riverbed scarification, and ditch and furrow.
There is no information available within the second cycle of RBMPs about specific volumes
of treated wastewater used for aquifer recharge.
The mean investment cost ratio (€/m3
) differs according to the implemented MAR technique.
Escalante (2014) provides examples on the basis of implemented projects: 9.75 €/m3
for
ponds; 0.80 €/m3
for dams; 0.23–0.58 €/m3
for deep boreholes (deep injection); 0.36 €/m3
for
medium-deep boreholes and 0.21 €/m3
for surface MAR facilities (ponds, channels). 16% of
the analysed area in the country (Iberian Peninsula and Balearic Islands, Canary Islands
excluded: circa 500,000 km2
) has the potential for being used for MAR (i.e. 134,000 million
m3
, i.e. 2 million m3
/km2
).
Cyprus
Cyprus, as far as natural water resources are concerned, depends solely on rainfall. The total
annual water supply is 3030 million m3
/year, 89% of which is lost in evapotranspiration,
leaving 321 million m3
/year as useable water. Historically, droughts occur every two-to-three
years due to the decline in rainfall. In the last fifty years, however, drought incidences have
increased both in magnitude and frequency. Reuse of treated wastewater (known in Cyprus as
“recycled water”) provides additional drought-proof water supply.
In terms of water stress, Cyprus is the most affected country of the European Union, with a
water stress index of approximately 66%41
. Domestic water use and agricultural irrigation are
the two main sources of water demand in Cyprus.
In Cyprus, water reuse provides additional drought-proof water supply, favours a more local
sourcing of water and avoids the use of drinking water quality water where such high quality
is not needed. The potential for water reuse depends on the availability and accessibility of
wastewater (i.e. the wastewater infrastructure) and the acceptability by potential end-users
and consumers. Cyprus has adopted a ’Not a Drop of Water to the Sea’ policy encouraging
the maximum capture of run-off by dam construction and handling of wastewater.
Almost 9042
% of treated wastewater is reused, primarily for the irrigation of agricultural land,
parks, gardens and public greens. In 2011, 12 million m³/year of recycled water is given for
irrigation and about 2,2 million m³/year for artificial recharge of aquifers.
41
Eurostat tsdnr310 | Publication date: 19 February 2016, CET (Water Exploitation Index - Percentage)
42
For 2004-2013 – 89.32% according to competent authority communication
91
Figure 32: Overview of uses of treated effluent in Cyprus
Source: Ministry of Agriculture, Natural Resources and Environment Water Development
Department River Basin Management Plan, April 2011
However, a significant increase in the amounts of treated wastewater available in the future is
expected. The capacity of the new Waste Water Treatment Plants was expected to reach up to
85 million m³/year for long term (2025)43
.
Cyprus is one of the Member States where water reuse provisions are fully integrated into the
legislation on urban wastewater treatment and discharge (State Law N.106(I)/2002, as
amended). Quality criteria for the treated wastewater take the specific conditions of Cyprus
into account. In particular, conventional secondary treatment has been preferred to
stabilisation ponds in some areas because of the high cost of land (coastal areas) or for
protection of environmental and aesthetic amenities for tourism. Different uses of treated
wastewater require different levels of treatment and, by extension, costs.
Agricultural irrigation
In Cyprus, the use of recycled water has mostly been for irrigation and to mitigate the
overdependence of agriculture on groundwater44,45
. In Cyprus about 25 million m³/year of
wastewater is collected and used for irrigation after tertiary treatment. It is anticipated that
most of the recycled water, about 55 to 60%, is used for amenity purposes such as hotel
gardens, parks and golf courses. Most treated wastewater (12 million m³/year) is used directly
43
Ministry of Agriculture, Natural Resources and Environment Water Development Department River Basin
Management Plan, April 2011
44
Pashiardis, S. Trends of precipitation in Cyprus rainfall analysis for agricultural planning. In Proceedings of
the 1st Technical Workshop of the Mediterranean Component of CLIMAGRI Project on Climate Change and
Agriculture, Rome, Italy, 25–27 September 2002
45
Eighth Report on the Implementation Status and the Programmes for Implementation (as required by Article
17) of Council Directive 91/271/EEC concerning urban waste water treatment
92
for irrigation with orchards being the most irrigated crops, such as citrus and olive trees, but
water is also used for fodder crops.
According to information made available by the Water Development Department (WDD), the
acceptance of using recycled water from farmers was initially slow (period 2002-2005) but in
time it has increased significantly.
Separate regulation, i.e. Cyprus Regulation K.D.269/2005 specifies the reclaimed water
quality criteria for treated wastewater produced from agglomerations with less than 2,000
population equivalent. For agglomerations of more than 2,000 population equivalent (p.e.),
the quality characteristics that must be met for the use of the treated effluent are specified
within Wastewater Discharge Permits, issued by the Ministry of Agriculture for the Sewerage
Boards and the Water Development Department.
The prevailing treatment technology was, until recently, conventional activated sludge
treatment with secondary clarifiers followed by sand filtration and chlorination. However,
most new projects under planning (new wastewater treatment plants as well as extension of
existing ones) are considering advanced technologies such as membrane application, e.g.
bioreactor technology (Larnaca, Limassol, and Nicosia) or reverse osmosis.
Cyprus adopted water quality standards for wastewater reuse in 2005 and is prohibiting the
irrigation of treated wastewater for vegetables that are consumed raw, crops for exporting,
and ornamental plants.
Yearly water needs of irrigation amounts to an average of 178.5 million m³/year; however, as
this demand is rarely satisfied, the actual water consumption in agriculture fluctuates around
150 million m³/year. Irrigated agriculture accounts for 88% of this amount (or 132 million m3
of water per year) while accounting for only 28% of the total area under crops. Agricultural
sector accounts for around 60% of total Cyprus’ water consumption46
.
In Cyprus, the current nationally set objective is to replace 40% of agricultural freshwater
requirements by reclaimed water.
Costs for construction and operation of municipal wastewater collection and treatment
infrastructure are funded by the local communities through the sewerage rates. Tertiary
treatment and reclaimed water distribution networks are financed and operated by the
government, through the Water Development Department. Customers are charged different
prices for reclaimed water depending on the end use.
Reused water tariffs in Cyprus range from 33%-44% of freshwater rates, ratios which appear
typical for the EU Mediterranean islands47
. The price reflects the application of substantial
subsidies to reclaimed water supplies to encourage wider uptake, which may be at odds with
the need for greater cost recovery in water treatment and management (BIO, 2015). Although
such subsidised price structures have been in place for many years to incentivise take-up,
price rates are usually based on intuitive judgements by utilities of the level of willingness to
accept reclaimed supplies amongst different groups rather than empirical evidence of the
46
Arcadis, et al. (2012). The Role of Water Pricing and Water Allocation in Agriculture in Delivering
Sustainable Water Use in Agriculture.
47
Hidalgo & Irusta, 2005
93
price at which users would begin to accept these supplies over conventional freshwater. (BIO,
2015)
Research focused on irrigation of forage and citrus revealed no adverse impacts on using
treated wastewater on either soil physicochemical properties or heavy metal content, nor on
the heavy metal content of agricultural products. Similarly, research results concerning
wastewater irrigation of tomato crops showed no accumulation of heavy metals in tomatoes,
whereas total coliforms and faecal coliforms were not quantified in tomato flesh or peel; and
E.coli, Salmonella spp and Listeria spp were not detected in tomato homogenates. Research
on pharmaceutical compounds detected traces of these compounds in treated effluent but
further research is on-going to assess whether they are being taken up by plants under field
conditions. (Appendix D of AMEC study- case study for Cyprus)
Aquifer recharge
In Cyprus almost all the aquifers are over-exploited and, for many of them, water quality has
deteriorated due to seawater intrusion. In particular, characterising water bodies according to
requirements of the WFD, around 80% of the groundwater bodies had been assessed as being
at risk of failing to achieve a "good status" by 2015. This is mainly due to over-pumping,
saltwater intrusion, high nitrate concentrations caused by agricultural activities48
.
Further action, therefore, is required for reducing aquifer extraction to a level which will
allow the aquifers to recover. This can be achieved with very careful management that is
focused mainly in two methods: first with the drastic reduction of pumping to sustainable
levels and second with the increase of their recharge with natural and artificial methods.
Managed Aquifer Recharge (MAR) is becoming an increasingly attractive water management
option, especially in semi-arid areas. Artificial recharge using treated wastewater in depleted
aquifers, via deep boreholes, is an internationally acceptable practice, which is compatible
with Directive 2000/60/EC and may contribute to cover a part of irrigation needs, as well as
the sustainable water resources management in many areas49
. It does, however, have a
number of limitations; with the degradation of subsurface environment and groundwater due
to the transport of pathogenic viruses with the recycled water being the main environmental
issue associated with artificial recharge. Furthermore, the clogging effect of boreholes caused
by suspended solids, bacterial and recharge water is a phenomenon that limits the viability of
artificial recharge.
In Cyprus, the lack of suitable site selection is one of the limiting factors in applying
groundwater recharge. The process of selecting suitable locations includes: hydrogeological
conditions, availability and quality of wastewater, possible benefits, economic evaluation and
environmental considerations 27
. The wastewater should be pre-treated to improve its
physico-chemical characteristics. The pre-treatment includes ultrafiltration and/or inverse
osmosis. Membrane techniques are successful in producing wastewater with low values of
TDS and nutrient content. The lack of field studies on the fate and transport of priority
substances, heavy metals and pharmaceutical products within the recharged aquifer is also an
important consideration.
48
MANRE,2005
49
Voudouris, K.; Diamantopoulou, P.; Giannatos, G.; Zannis, P. Groundwater recharge via deep boreholes in
Patras industrial area aquifer system (NW Peloponnesus, Greece). Bull. Eng. Geol. Environ. 2006, 65, 297-308.
94
On the other hand, important advantages of aquifer recharge include:
- Seawater intrusion being controlled;
- Provision of storage of effluent water for subsequent retrieval and reuse;
- The aquifer serving as an eventual natural distribution system;
- Further purification of effluent water (reduced biological load); and
- Saving of equal quantities of fresh water for domestic use.
In Cyprus, four candidate regions have been selected on the basis of water scarcity/ shortage
or deficiency and aridity of the area, social and economic characteristics and the complexity
of the water system. Recycled water is used to recharge depleted aquifers and reduce sea-
water intrusion. This is the method used in Paphos, where the Ezousa aquifer is recharged
artificially with 2–3 million m³ treated wastewater per year, which is then re-abstracted for
irrigation50
,51
.
France
Although France does not experience serious water stress (with its Water Exploitation Index
being around 15.5% for the period 2008-2012 (Eurostat)), the analysis of natural flows in
France shows that low water periods are getting more frequent and more serious in the last 40
years (1970-2010), particularly affecting the South of France (ONEMA, 2011). The
consumption of water for farming is growing particularly strongly in South-Western France
and in the Paris region (TYPSA, 2013).
In addition to the growing demand for water for agricultural purposes, some irrigated crops
(such as corn) have become more widespread and periodic droughts have occurred. Over the
last 20 years droughts events affected the regions traditionally considered to be the wettest, in
Western and North-Western France. In more than one-third of the country, water tables are
falling as the autumn and winter rains are no longer making up for the amounts drawn up in
spring and summer. Faced with this situation, the authorities have occasionally imposed
restrictions on water use, a very unusual practice in France. It is also worth recalling that
around fifteen French departments are situated in an area with a Mediterranean climate
similar to that of Northern Spain and Italy, well-suited to market gardening, fruit farming and
mass tourism.
In France, water reuse systems are already in place, and legally binding standards for reuse
are in place for the agricultural sector and water reuse for green and recreational areas.
There are no recent data on the total volume of reused water in France but the latest data from
a 2007 report indicate that water reuse was 19,200 m3
/day corresponding to about 7 million
m3
/year (according to Jimenez et al.52
). At present, there are about 40 reuse schemes in
France, most of which are dedicated to irrigation (agriculture, public areas, golf courses and
50
Water Scarcity in Cyprus: A Review and Call forIntegrated Policy, Anastasia Sofroniou and Steven Bishop
51
Eighth Report on the Implementation Status and the Programmes for Implementation (as required by Article
17) of Council Directive 91/271/EEC concerning urban waste water treatment
52
However, the yearly estimate must be taken as indicative (or as a maximum potential yearly production), as it
is calculated taking the daily production and multiplying it by 365. However, it must be noted that reused water
is used mostly during the summer period.
95
racecourses) (SYNTEAU, 2014). Latest available data indicate that around 55 reuse schemes
are now in place in the country53
.
Agricultural irrigation
Agriculture is the main user of water in France (48% of the water used in 200454
). The total
agricultural area equipped for irrigation amounts to 27.7 million hectares; however, in 2010,
it was reported that irrigation actually occurred on 1.6 million hectares, corresponding to a
total water use of 2.7 billion m3
per year.
The irrigated area by type of crop is illustrated in the Figure below55
.
Figure 33: Irrigated area by type of crop (2010)
The reuse of wastewater for irrigation purposes is still little developed in France. On the one
hand, France is hardly facing water scarcity issues – and when it does, scarcity events unfold
at the local scale. In fact, water reuse for irrigation is limited to particular regions, such as
islands or areas with a high water demand and uses possibly conflicting with potable use. On
the other hand, the price of reused water is higher than the price of conventional water, so
there is no economic incentive to switch to reused water. In particular, in France, both
volumetric and mixed tariffs are applied to the provision of irrigation water. The EEA (2013)
reports flat tariffs ranging between 38 and 157 EUR/year, combined with volumetric rates
ranging between 0.06 and 0.09 EUR/m3
. Tariffs paid by farmers cover 100% of operation and
53
Communication from French competent authority
54
France Nature Environnement, 2008.
55
France Nature Environnement, 2008.
96
maintenance costs, but they do not fully cover investment costs: depending on the area,
revenues from tariffs cover from 15% to 95% of investments costs (55% on average)56
.
At the end of the 1990s, only around twenty water reuse projects could be found in France;
all projects were set up for irrigation of crops, green spaces and golf courses. The largest
water recycling project provides irrigation water to 2,300 ha57
. More updated data are not
available, although it seems that few additional projects have been set up since then.
According to an ongoing study by CEREMA, the number of operating water reuse projects
has more than doubled since 201058
.
The French population already eats fruits and vegetables imported from countries where
water reuse for irrigation is frequent (e.g. Spain). Despite this, a third of the French
population declared themselves not ready to eat fruits and vegetables irrigated with recycled
water (CGDD, May 2014).
Aquifer recharge
The volume of groundwater in France is estimated at 2000 billion m3
per year, of which 100
billion m3
per year flow through springs and water courses. About 7 billion m3
per year are
extracted from groundwater through the exploitation of springs, wells and drillings. Half of
the water is used for drinking water59
, covering two thirds of the demand for drinking water
(BRGM, 2016).
Of the 646 groundwater bodies in France, 90.6% were in a good quantitative status in 2013.
Water bodies with less than good status are mainly situated in the South-East and the centre,
the Mediterranean region as well as the islands Réunion and Mayotte. The main reasons for
not reaching good status are overexploitation of the aquifers compared to their recharge, but
also salt water intrusion (Réunion, Mediterranean region).
There are no official statistics on artificial groundwater recharge in France. An inventory
from the year 2013 (Casanova et al., 2013) listed 75 sites of artificial groundwater recharge
on the French national territory. The status of 48 out of them is known with certainty, without
certainty for 8 and unknown for 19. Two-thirds of the sites for which the status is known are
situated in the (former) regions Nord-Pas-de-Calais, Midi-Pyrénées and PACA. Only about
20 of them are still active today (Casanova et al., 2013). The techniques applied are either
indirect injection (infiltration basins) or direct injection (via drilling) (BRGM, 2016).
In most of the known cases of artificial groundwater recharge in France, the primary
objective is to support an overexploited groundwater body. The second objective is the
improvement of the quality of the groundwater bodies through significantly diminishing the
concentrations of certain chemicals by dilution (e.g. nitrates, pesticides). The latter allows for
56
EEA, 2013. Assessment of cost recovery through pricing of water. Technical report No 16/2013.
http://www.eea.europa.eu/publications/assessment-of-full-cost-recovery
57
http://www.ecoumenegolf.org/XEauXLAZAROVA.pdf
58
The ongoing CEREMA study aims to establish an assessment of reuse in France and the relevant places to
develop the reuse. Information on the original study could not be found, this information was provided by
French Competent Authority (personal communication).
59
http://www.eaufrance.fr/comprendre/les-milieux-aquatiques/eaux-souterraines
97
the application of simpler and more economic final treatments to make the water suitable for
drinking water purposes (Casanova et al., 2013).
In almost all cases which are currently active in France, surface water is the source of water
used for artificial recharge. This is mainly due to the availability of the resource. Artificial
recharge with treated wastewater is not prohibited. However, this is not regulated by existing
legislation, as quality requirements and allowed uses of treated wastewater are only regulated
for irrigation of crops and green areas60
.
While direct injection of treated wastewater in the aquifer has never taken place in France,
two research projects on indirect infiltration of treated effluent have been carried out by
BRGM – the public service provider for the quantitative groundwater management in France
– and the company Veolia until 2011 (REGAL and RECHARGE) (BRGM, 2016).
Greece
In Greece the theoretical long-term annual freshwater availability is 72,000 million m3
/year61
.
Due to a range of technical and economic reasons the amount of freshwater which is readily
available for abstraction and use is much lower. The annual freshwater abstractions constitute
only 13% of the theoretical availability and are estimated at 9,539 million m3
/year 1
. The
major water user in Greece is irrigated agriculture, which accounts for 84% of the total water
use.
Half of the Greek RBDs (7 out of 14) face water scarcity issues (Water Exploitation Index
(WEI62
)+>20%) with these 7 RBDs being among the twenty most water-scarce RBDs of
Europe63
.
Wastewater reuse in Greece is being regulated by JMD 145116/2011 (GG B 354) and JMD
191002/2013 (GG B 2220), which aims to promote wastewater reuse and protect public
health by establishing criteria and standards on its practice. Their scope extends to urban and
conventional industrial wastewater (included in JMD 5673/400/97), for restricted and
unrestricted irrigation in agriculture, urban and peri-urban use, aquifer recharge (including
protected aquifers) and industrial use.
The reported estimates for the current and potential volumes of reused wastewater differ
significantly. The average daily wastewater reuse is estimated at 28,000 m3
/day (or 10.2
60
Arrêté du 2 août 2010 relatif à l'utilisation d'eaux issues du traitement d'épuration des eaux résiduaires
urbaines pour l'irrigation de cultures ou d'espaces verts
https://www.legifrance.gouv.fr/affichTexte.do?cidTexte=JORFTEXT000022753522&dateTexte=&categorieLie
n=id
61
Eurostat data, Water statistics, Agricultural statistics, Crop statistics, Agri-environmental indicators,
Agricultural Census in Greece.
62
The water exploitation index (WEI) in a country is the mean annual total demand for freshwater divided by
the long-term average freshwater resources. The following threshold values/ranges for the water exploitation
index have been used to indicate levels of water stress: (a) non-stressed countries < 10%; (b) low stress 10 to <
20%; (c) stressed 20% to < 40%; and (d) severe water stress ≥ 40%. (EEA, 2015.
http://www.eea.europa.eu/data-and-maps/indicators/water-exploitation-index)
63
ETC/ICM, 2016. Use of freshwater resources in Europe 2002–2012. Supplementary document to the
European Environment Agency’s core set indicator 018. ETC/ICM Technical Report 1/2016, Magdeburg:
European Topic Centre on inland, coastal and marine waters, 62 pp
98
million m3
/year)64
, while in the AQUAREC project the average annual wastewater reuse was
estimated at 23 million m3
/year 65
. The future potential for wastewater reuse in Greece (2025)
was modelled at 57 million m3
/year 66
in the AQUAREC project, while another study
estimated it at 242 million m3
/year 67
.
When compared to the total water use in the country, wastewater reuse in Greece accounts for
less than 1%). Furthermore, the share of reclaimed wastewater, when compared to the total
treated effluent is below 5%68
. In addition, a water balance analysis has revealed that over
83% of the treated effluent from wastewater treatment plants are produced in regions with a
water deficit. Furthermore, over 88% of the effluents from WWTP are discharged at less than
5 km from available farmland, which implies that the additional cost for wastewater reuse in
irrigation could possibly be technically and economically affordable69
.
Agricultural irrigation
The reuse of treated urban wastewater for agricultural irrigation may require differentiation
depending on the type of crops (e.g. food crops to be eaten raw, food crops to be cooked or
processed, non-food crops, ornamental flowers), the irrigation equipment (sprinklers used or
not) and the status of access for the public and for animals (restricted or unrestricted).
It is estimated that 84% of the total water use in Greece is taken up by irrigated agriculture
(3,897 million m3
/year). The average irrigation intensity is 3,800 m3
/ha, which is the 6th
highest in Europe70
.
Irrigation water in Greece is billed in a number of ways with the average price ranging
between 0.02-0.70 €/m3 71
for volumetric billing, 73-286.3 €/ha 72
for flat rates by crop type
and 45-243.1 €/ha for flat rates by irrigation system73
. There are no abstraction or pollution
charges. The price of self-abstracted groundwater can be roughly approximated using the
electricity consumption for pumping. For an expected range of depths it could range between
0.02-0.03 €/m3 3
. The price of desalination water is 0.3-0.7 €/m3 74
.Since the monetary cost of
(usually illegal) self-abstracted on-farm surface water and groundwater is very low (<0.03
€/m3
), these users are unlikely to be interested in using reclaimed water. At least 32% of the
64
Kellis M., Kalavrouziotis, I.K., and Gikas, P., 2013. Review of wastewater reuse in the Mediterranean
countries, focusing on regulations and policies for municipal and industrial applications. Global NEST Journal,
Vol. 15, No. 3, pp. 333-350.
65
Hochstrat et al., 2006. Report on integrated water reuse concepts. Deliverable D19, AQUAREC project.
66
Hochstrat et al., 2006. Report on integrated water reuse concepts. Deliverable D19, AQUAREC project
67
Tsagarakis, K.P., Tsoumanis, P., Chartzoulakis, K., Angelakis A.N., 2001. Water resources status including
wastewater treatment and reuse in Greece: Related problems and prospectives. Water International, 26, 2, pp.
252–258
68
TYPSA, 2012. Wastewater reuse in the European Union. Service contract for the support to the follow-up of
the Communication on Water Scarcity and Droughts, Report for DG ENV.
69
BIO by Deloitte, 2015. Optimising water reuse in the EU, Final report prepared for the European Commission
(DG ENV), Part I. In collaboration with ICF and Cranfield University
70
Eurostat data, Agri-environmental indicators
71
Kalligaros, D., 2004. The cost of irrigation water in Greece, Postgraduate Thesis, Environmental Studies
Department, University of the Aegean.
72
OECD, 2010. Agricultural Water Pricing: EU and Mexico, http://www.oecd.org/eu/45015101.pdf
73
OECD, 2010. Agricultural Water Pricing: EU and Mexico, http://www.oecd.org/eu/45015101.pdf
74
Zotalis, K., Dialynas, E., Mamassis, N., and Angelakis, A.N., 2014. Desalination Technologies: Hellenic
Experience, Water, 6, 1134-1150; doi:10.3390/w6051134
99
total holdings rely on self-abstracted groundwater. Taking into account the price of
desalination water (0.3-0.7 €/m3
) it is concluded that wastewater reuse might be more cost-
efficient than desalination in coastal areas and islands with existing WWTPs. It is also
expected that reclaimed water would be appealing to users of off-farm water supply, which
account for nearly 63% of the total irrigation water users. Given that the existing irrigation
freshwater tariffs range significantly across the country (0.02-0.70 €/m3
) and reported price of
reclaimed water ranges from 0 (Salonica case study) to 0.12-0.30 €/m3
(Pinios case study),
there is not sufficient data to make the comparison between the two types of water.
Over recent years at least 9 wastewater reuse projects for crop irrigation have been
implemented in Greece with EYATH in Salonica (2,500 ha; corn, cotton, sugarbeet, rice,
alfalfa) being the most important project75
.
Overall, technical, economic and social reasons will continue to block faster uptake of
wastewater reuse for agricultural irrigation in the baseline. Additional wastewater reuse might
come from the WWTPs where it is already implemented and potentially from some more new
sites in Crete76
. A conservative estimate is that wastewater reuse in irrigated agriculture
would increase by 10-20% up to 2025 (Appendix D of AMEC study - case study for Greece).
Aquifer recharge
In Greece, the average annual groundwater availability for abstraction is reported at 3,550
million m3
/year77
. When considering actual water abstraction in Greece, groundwater
resources account for 38% of the total water abstraction. Groundwater is a primary source for
drinking water in rural areas and for the industrial sector. It is also a significant source of
water for irrigated agriculture, which covers 84% of total water use. Almost 80% of the
Greek groundwater bodies are in a good state. Only 17% of them are in bad quantitative
state78
.
The reuse of treated urban wastewater for aquifer recharge is differentiated depending on the
type of aquifer (potable or non-potable water resources) and the applied method (direct
injection in boreholes and wells or surface spreading and infiltration). It should be
highlighted that direct injection of reclaimed water is not allowed for aquifers with potable
water resources. Additionally, a hydrogeological study is required in all cases.
Reported data on aquifer recharge were not found in Eurostat or in the “National Program for
the Management and Protection of Water Resources”79
. After communication with the
75
Ilias, A., Panoras, A., and Angelakis, A., 2014. Wastewater Recycling in Greece: The Case of Thessaloniki.
Sustainability, 6, pp. 2876-2892; doi:10.3390/su6052876
76
Agrafioti, E., Diamadopoulos, E., 2012. A strategic plan for reuse of treated municipal wastewater for crop
irrigation on the Island of Crete, Agricultural Water Management, 105, 57-64
77
Eurostat data, Water statistics, Agricultural statistics, Crop statistics, Agri-environmental indicators,
Agricultural Census in Greece.
78
COM, 2015. WFD implementation report on River Basin Management Plans, MS: Greece, Commission Staff
Working Document accompanying the document Communication from the Commission to the European
Parliament and the Council: "The Water Framework Directive (WFD) and the Floods Directive (FD): Actions
towards the ‘good status’ of EU water and to reduce flood risks”, European Commission, Brussels.
79
Koutsoyiannis, D., Andreadakis, A., Mavrodimou, R., Christofides, A., Mamassis, N., Efstratiadis, A.,
Koukouvinos, A., Karavokiros, G., Kozanis, S., Mamais, D., and Noutsopoulos, K., 2008. National Program
for the Management and Protection of Water Resources. Support to the development of the national program for
100
Special Secretariat for Water, the Greek authorities could not provide additional information
on similar projects. Literature review revealed only two cases of aquifer recharge in Greece.
Both were/are conducted in the context of research projects and serve as pilot sites. It is
interesting that both of them are actually wastewater reuse projects.
For a WWTP of 4,000 m3
/day the estimated cost for aquifer recharge is at least 0.17 €/m3
to
2.12 €/m3
. When using treatment with microfiltration or reverse osmosis, the cost of
electricity could be 0.15 €/m3
. A newer abstraction from the recharged aquifer for indirect use
would require an additional cost for pumping. Hence, the whole chain of costs would increase
further. On the other hand, wastewater reuse in agricultural irrigation could cost 0.44 €/m3 36
(a range of 0.123-0.304 €/m3
is reported at one of the sites (see Appendix for the Greek case
study). Generally there is a lack of concrete economic data, but reuse for aquifer recharge
seems to be less mature and less competitive than reuse for agricultural irrigation in Greece.
Overall, very limited expansion is expected for aquifer recharge using reclaimed water under
the baseline.
Italy
Despite an average annual rainfall of 1 000 mm/year, well above the European average,
average freshwater availability for the population (2 900 m3
/capita) is one of the lowest
among OECD countries, due to high evapotranspiration, rapid run-off and limited storage
capacity (OECD, 2013). In addition, available resources are distributed very unevenly across
the national territory: 59.1% are in fact in the North, whereas the rest is shared by the Centre
(18.2%), the South (18.2%) and the islands (4.5%).
With annual water abstraction making up 31% of available water resources, Italy is classified
as a medium-high water-stressed country (OECD, 2013).
Under the Law-decree n. 152, a new legislative set of rules was promulgated on June 12th,
2003 (Ministry Decree, D.M. no 185/03) under which recycled water can be used for (APAT,
2008):
- Irrigation of crops for human and animal consumption, as well as non-food crops.
Irrigation of green and sport areas;
- Urban uses: street washing, heating and cooling systems, toilet flushing; and
- Industrial uses: fire control, processing, washing, thermal cycles of industrial
processes (recycled water must not get in contact with food, pharmaceutical products
or cosmetics).
- Treated wastewater is used mainly for agricultural irrigation. However, the controlled
reuse of municipal wastewater in agriculture is not yet developed in most Italian
regions and has decreased due to the low quality of water.
the management and conservation of water resources, 748 pages, Department of Water Resources and
Environmental Engineering, National Technical University of Athens, Athens.
101
Average costs, as calculated by ISPRA in a survey of several Italian recycling plants
(different plants for different uses: urban, industrial, agriculture) range between 0.083 and
0.48 EUR/m3
. As a comparison, the costs of abstracting water from rivers and groundwater
bodies is estimated at 0.015-0.2 EUR/m3
. The high cost of recycled water is generally
indicated as one of the main barriers to water reuse80
.
Agricultural irrigation
Nearly 50% of water abstraction is attributed to the agricultural sector.
Irrigated areas are unevenly distributed across the country: 66% of irrigated area is, in fact,
concentrated in the relatively water-abundant North, whereas the rest is shared between the
Centre (6%) and the South (28%). The three major irrigated crops are maize, rice and
vegetables (ISTAT, 2010). Although the irrigated agricultural area only accounts for 19% of
the total Utilised Agricultural Area (UAA) (ISTAT, 2010), in terms of production, irrigated
agriculture accounts for 50% of total production and 60% of total value added of the
agricultural sector, and its products constitute 80% of agricultural exports (Althesys, 2013).
The use of untreated wastewater has been practiced in Italy at least since the beginning of this
century, especially on the outskirts of small towns and near Milan. Reuse of untreated
wastewater is prohibited in Italy: the legislation requires that all discharges comply with
normative standards. Therefore, the reuse of untreated wastewater is illegal and, as such,
subject to penal and administrative sanctions. Treated wastewater is used mainly for
agricultural irrigation. However, the controlled reuse of municipal wastewater in agriculture
is not yet developed in most Italian regions.
Aquifer recharge
Groundwater makes up almost 50% of water abstracted for domestic water supplies (ISTAT,
2012b). Overexploitation has been reported in the North, in the lower reaches of the Po plain
and around Venice, due to industrial and agricultural uses as well as gas and oil extraction.
Water availability differs significantly from Northern to Southern Italy. In the North, water is
relatively abundant, due to stable and abundant flows in water courses throughout the year. In
addition, out of 13 billion m3
of groundwater available annually, over 70% is located in the
North, and particularly in the Po river plain. In contrast, the South of Italy is often subject to
long periods without precipitation, resulting in droughts and water rationing (OECD, 2013).
Over 52% of GWBs are assessed as having good quantitative status, according to Italy’s
reporting; however, the status is unknown for almost 32%.
At present, artificial aquifer recharge interventions are not common in Italy, and current
practice focuses mainly on pilot experimental sites (Regione Emilia Romagna, 200881
;
confirmed by other sources up to 2015,). Existing examples of artificial aquifer recharge are
being implemented thanks to EU LIFE and FP7 funding:
80
ISPRA, 2009. L’ottimizzazione del servizio di scarico urbane: massimissazione dei recuperi di risorsa (acque e fanghi) e riduzione dei
consumi energetici. Rapporto 93/2009. http://www.isprambiente.gov.it/it/pubblicazioni/rapporti/l2019ottimizzazione-del-servizio-di-
depurazione
81
http://ambiente.regione.emilia-romagna.it/acque/informazioni/documenti/studio-sulla-ricarica-artificiale-
delle-falde-in-emilia-romagna/view
102
LIFE+ AQUOR (ended in May 15): implementation of artificial aquifer recharge in the
Province of Vicenza - http://www.lifeaquor.org/en ;
LIFE+ TRUST (ended in December 2011): research in the aquifer recharge area in the
Veneto plain (rivers Isonzo, Tagliamento, Livenza, Piave, Brenta and Bacchiglione)
http://www.lifetrust.it/cms/ ;
LIFE+ WARBO (ended in March 2015): testing of artificial aquifer recharge methods (from
rainwater) in the Po Delta and in the Pordenone province - http://www.warbo-life.eu/it ; and
MARSOL – FP7 (on-going): Demonstrating Managed Aquifer Recharge as a Solution to
Water Scarcity and Drought – Pilot sites in Italy: Brenta (Veneto) and Serchio (Liguria) -
http://www.marsol.eu/6-0-Home.html .
A recent modification to the Environmental Act – Art. 24, comma 1, Law 97/2013 – clarified
some important technical and permitting aspects of aquifer recharge. In particular, these
interventions can be authorised provided that they are executed in compliance with the
criteria to be established by the Ministry of Environment through a specific Decree –
Ministerial Decree 2 May 2016, n.100.
According to Legislative Decree 152/06, wastewater discharge into groundwater bodies is
forbidden with some exceptions. Such exceptions include artificial aquifer recharge,
provided that his does not compromise the achievement of the environmental objectives
established for the specific groundwater body. Aquifer recharge is established and regulated
by the RBMPs and the Water Protection plan.
Artificial aquifer recharge is also subject to Environmental Impact Assessment (LIFE
AQUOR, 201582
).
Artificial aquifer recharge was also included in the National Operational Programme
“Governance and systemic actions – European Social Fund 2007-2013 – Axis E Institutional
Capacity, Specific Objective 5.5 Reinforce and Integrate the environmental governance
system, Action 7A Horizontal actions for environmental integration”, as part of models and
tools for water resource management (natural water retention measures, aquifer recharge and
participatory systems)83
.
At present, no testing of artificial groundwater recharge with treated effluents has been
reported: this practice is forbidden in Italy84
.
Romania
Romania's water resources are relatively poor and unevenly distributed in time and space
with about 40 billion m3
being available for use per year. Water demand in Romania in 2014
was 7.21 billion m3
/year.
82
http://www.lifeaquor.it/file/649-A6_linee_guida_tecnico_operative_I.pdf
83
http://www.pongas.minambiente.it/pubblicazioni/misura-7a/pubblicazioni/news/studio-di-settore-modelli-e-
strumenti-di-gestione-e-conservazione-delle-risorse-idriche-sistemi-naturali-di-ritenzione-idrica-ricarica-
artificiale-delle-falde-e-processi-partecipativi
84
The Ministerial Decree 2 May 2016, n.100 indicates the sources for groundwater recharge, which do not
include wastewater.
103
In 2013, the Water Exploitation Index was 15.2 (Eurostat), which is below the EEA’s
threshold of 20% for water stress85
.
The balance between water availability and the expected trends for water demand shows no
deficit at state level or in the 11 sub-basins; there are only a few river sections with deficits in
the Prut - Bârlad basin that should be carefully considered in the future86
.
Currently treated wastewater reuse is not being practiced in Romania for either irrigation or
aquifer recharge. Wastewater reuse in irrigation was launched experimentally as part of
research projects, but it is not a mainstream practice. In regard to aquifer recharge, this is
currently a prohibited practice, as the Waters Law prohibits injections of wastewater into
groundwater.
Furthermore, given decreasing water consumption, lack of irrigated agriculture and adequate
natural recharge of the most aquifers in Romania, there is low demand for the use of treated
wastewater overall.
Agricultural irrigation
The total irrigated area in Romania is 2.99 million ha with 85% of the area being irrigated
from the River Danube. In reality, (functional) irrigated land accounted for less than 300,000
ha (less than 1% of the total arable land) in the last 5 years (2011-2015), consuming about 1
million m3
per year.
Although Romanian legislation does not forbid the use of treated wastewater in irrigation,
there are no specific regulations and standards that govern water reuse. Additionally, the low
number of users that are connected to the irrigation system and the relatively low water
volume that is used for irrigations at national level does not currently act as an incentive to
invest in further technologies.
In the long run, the interest in treated water reuse for irrigation might increase, as forecasts
predict a significant increase of the number of users connected to the irrigation system, while
research has begun to study the conditions under which treated wastewater could be used in
agriculture at experimental level.
Aquifer recharge
The groundwater potential in Romania is estimated at 9.6 billion m3
/year. In general terms,
groundwater is not overexploited in Romania. In fact, data for 2014 showed that surface
water abstraction accounted for around 10 times the volume of water abstracted from
groundwater resources.
Furthermore, aquifer recharge using treated wastewater is currently a prohibited practice in
Romania with the Waters Law explicitly prohibiting injections of wastewater into
85
The water exploitation index (WEI) in a country is the mean annual total demand for freshwater divided by
the long-term average freshwater resources. The following threshold values/ranges for the water exploitation
index have been used to indicate levels of water stress: (a) non-stressed countries < 10%; (b) low stress 10 to <
20%; (c) stressed 20% to < 40%; and (d) severe water stress ≥ 40%. (EEA, 2015.
http://www.eea.europa.eu/data-and-maps/indicators/water-exploitation-index)
86
Romanian Waters
104
groundwater. The current potential for treated wastewater reuse in aquifer recharge, therefore,
is effectively non-existent.
Comparison of MS regulations/guidelines on water reuse for agriculture and the
proposed minimum quality requirements
The minimum quality requirements for water reuse in agricultural irrigation are compared
with the national regulations from MS that have the most comprehensive standards developed
specifically for water reuse practices including agricultural uses: Cyprus, France, Greece,
Italy, Portugal and Spain. The regulations of Cyprus, France, Greece, Italy and Spain are
included as regulations in the national legislation. In Portugal, the standards on water reuse
are guidelines, but they are taken into consideration by the national government when issuing
any water reuse permits in the country.
This comparison is not exhaustive but includes the following points:
 Parameters (microbiological and physico-chemical) and limit values
 Category of crops
 Irrigation method
 Risk management framework
The following tables (Table 1, 2, 3, 4 and 5) show different quality categories included in the
minimum quality requirements and the MS standards for the reclaimed water quality.
Table 1. Category of reclaimed water quality for agricultural irrigation in MS standards and the minimum
quality requirements proposed by JRC.
Analytical parameters/
Category of use
JRC Cyprus France Greece Italy Portugal Spain
CATEGORY A
Verification monitoring
Escherichia coli
(cfu/100ml)
≤10;
≤100
≤5 ≤250 ≤5;
≤50
≤10;
≤100
≤100;
≤1,000
Fecal coliforms
(cfu/100ml)
≤100
Legionella sp. (cfu/l)(a)
≤1,000 ≤1,000
Salmonella sp. absence absence
(c)
Intestinal helminth eggs
(eggs/l)
≤1(b)
absence ≤0.1 ≤0.1
TSS
(mg/l)
≤10 ≤10 ≤15 ≤10 ≤10 ≤60 ≤20
BOD5 (mg/l) ≤10 ≤10 ≤10 ≤20
COD (mg/l) ≤70 ≤60 ≤100
Turbidity (NTU) ≤5 ≤2
median
≤10
Validation monitoring
Escherichia coli
(log10 reduction)
≥5
105
Analytical parameters/
Category of use
JRC Cyprus France Greece Italy Portugal Spain
Total coliphages/F-
specific
coliphages/somatic
coliphages
(log10 reduction)
≥6
Clostridium perfringens
spores/Sulphite-reducing
bacteria spores
(log10 reduction)
≥5
Fecal enterococci
(log10 reduction)
≥4
F-specific RNA
bacteriophages
(log10 reduction)
≥4
Sulphite-reducing bacteria
spores
(log10 reduction)
≥4
less stringent than JRC more stringent than JRC
(a): Only if there is risk of aerosolization. (b): When irrigation of pastures or fodder for livestock. (c): after certain monitoring results is
compulsory to conduct analysis of Salmonella.
JRC: 90% samples, maximum value in 10% samples. Cyprus: 80% of the samples. Greece: 80% samples and 95% samples. Italy: 80%
samples, maximum value in 20% samples. Spain: 90% samples, maximum value in 10% samples.
The requirements of this Category 1 (Table 1) are to be applied for the irrigation of all types
of crops, including food crops consumed raw with reclaimed water in direct contact with
edible parts of the crop, and using any irrigation method. The only exceptions are described
by Cyprus which indicates that it is forbidden the irrigation of leafy vegetables and bulbs
consumed raw, and by Portugal that allows irrigation of vegetables consumed raw only by
drip irrigation.
Table 2. Category of reclaimed water quality for agricultural irrigation in MS standards and the minimum
quality requirements proposed by JRC.
Analytical parameters/
Category of use
JRC Cyprus France Greece Portugal Spain
CATEGORY B
Verification monitoring
Escherichia coli
(cfu/100ml)
≤100;
≤1,000
≤50 ≤10,000 ≤200 ≤1,000;
≤10,000
Fecal coliforms
(cfu/100ml)
≤1,000
Legionella sp. (cfu/l)(a)
≤1,000
Salmonella sp. absence(d)
Intestinal helminth eggs
(eggs/l)
≤1(b)
absence ≤0.1 ≤0.1
Taenia saginata and
Taenia solium (egg/l)
≤1(b)
TSS
(mg/l)
(c) ≤10 (c) (c) ≤60 ≤35
BOD5 (mg/l) (c) ≤10 (c) (c)
COD (mg/l) ≤70
Validation monitoring
Fecal enterococci
(log10 reduction)
≥3
F-specific RNA
bacteriophages
(log10 reduction)
≥3
106
Analytical parameters/
Category of use
JRC Cyprus France Greece Portugal Spain
Sulphite-reducing bacteria
spores
(log10 reduction)
≥3
less stringent than JRC more stringent than JRC
(a): Only if there is risk of aerosolization. (b): When irrigation of pastures or fodder for livestock. (c): According to Directive 91/271/EEC.
(d): after certain monitoring results is compulsory to conduct analysis of Salmonella.
JRC: 90% samples, maximum value in 10% samples. Cyprus: 80% of the samples. Greece: median. Italy: 80% samples. Spain: 90%
samples, maximum value in 10% samples.
The requirements of this Category 2 (Table 2) are to be applied for the irrigation of food
crops consumed raw where the edible portion is produced above ground and is not in direct
contact with reclaimed water, processed food crops, and non-food crops including crops to
feed milk-or meat-producing animals. All irrigation methods are allowed. The exceptions are
the following: Greece does not allow the use of sprinkler irrigation for this category, France
only allows irrigation of cut flowers by drip irrigation within this category.
Table 3. Category of reclaimed water quality for agricultural irrigation in MS standards and the minimum
quality requirements proposed by JRC.
Analytical parameters/
Category of use
JRC Cyprus France Portugal Spain
CATEGORY C
Verification monitoring
Escherichia coli
(cfu/100ml)
≤1,000;
≤10,000
≤200 ≤100,000 ≤10,000;
≤100,000
Fecal coliforms
(cfu/100ml)
≤10,000
Legionella sp. (cfu/l)(a)
≤1,000 ≤100
Intestinal helminth eggs
(eggs/l)
≤1(b)
absence ≤0.1 ≤0.1
TSS
(mg/l)
(c) ≤35 (c) ≤60 ≤35
BOD5 (mg/l) (c) ≤25 (c)
COD (mg/l) ≤125
Validation monitoring
Fecal enterococci
(log10 reduction)
≥2
F-specific RNA
bacteriophages
(log10 reduction)
≥2
Sulphite-reducing bacteria spores
(log10 reduction)
≥2
less stringent than JRC more stringent than JRC
(a): Only if there is risk of aerosolization. (b): When irrigation of pastures or fodder for livestock. (c): According to Directive 91/271/EEC.
JRC: 90% samples, maximum value in 10% samples. Cyprus: 80% of the samples. Greece: median. Italy: 80% samples; maximum value.
Spain: 90% samples, maximum value in 10% samples.
The requirements of this Category 3 (Table 3) are to be applied for the irrigation of processed
food crops and non-food crops using only drip irrigation, and industrial, energy and seeded
crops using all irrigation methods. It has to be noticed that Cyprus and Portugal allow all type
of irrigation methods, while France only allows the irrigation of orchards, ornamental
flowers, fodder, and cereals but all these food crops have to be irrigated only by drip
irrigation. Spain allows the irrigation of orchards, ornamental flowers, nurseries and
greenhouses only by drip irrigation.
107
Table 4. Category of the minimum quality requirements for agricultural irrigation proposed by JRC.
Analytical parameters/
Category of use
JRC
CATEGORY D
Escherichia coli
(cfu/100ml)
≤10,000
Legionella sp. (cfu/l)(a)
≤1,000
Sulphite-reducing bacteria spores
(log10 reduction)
Intestinal helminth eggs
(eggs/l)
≤1(b)
F-specific RNA bacteriophages
(log10 reduction)
TSS
(mg/l)
(b)
BOD5 (mg/l) (b)
COD (mg/l)
(a): Only if there is risk of aerosolization. (b): According to Directive 91/271/EEC.
JRC: 90% samples, maximum 100,000 in 10% samples.
The requirements of this Category 4 (Table 4) are to be applied for the irrigation of industrial,
energy and seeded crops with all irrigation methods allowed.
The risk management framework is not mentioned in the MS regulations as a tool to be
applied by MS. But some elements of the RMF are sometimes included (Table 5).
Supplementary physico-chemical parameters appear in some MS regulations, mainly
agronomic parameters, while the minimum quality requirements proposed are recommending
the application of a risk assessment according to local conditions to derived additional
requirements for monitoring (Table 5).
Justification for the selected minimum quality requirements with references to MS
regulations/guidelines are provided in the technical report (section 4.4).
Table 5. Additional requirements included in MS standards and in the proposed minimum requirements for
water reuse in agricultural irrigation.
JRC Cyprus France Greece Italy Portugal Spain
ALL CATEGORIES
Application of
elements from a
risk management
framework
Yes Yes Yes Yes No Yes Yes
Elements
applied
All
elements
Multiple
barrier
Multiple
barrier,
validation
monitoring
Multiple
barrier
Multiple
barrier
Multiple
barrier
Additional
physico-chemical
parameters and
limit values
Depending
on risk
assessment
results
Yes No Yes Yes Yes Yes
Parameters
Heavy
metals,
nutrients
Heavy
metals,
nutrients,
organic
substances
Heavy
metals,
nutrients,
organic
substances
Heavy
metals,
nutrients,
organic
substances
Heavy
metals,
nutrients


EN EN
EUROPEAN
COMMISSION
Brussels, 13.6.2018
SWD(2018) 249 final/2
PART 3/3
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT
Accompanying the document
Proposal for a Regulation of the European Parliament and of the Council on minimum
requirements for water reuse
{COM(2018) 337 final} - {SEC(2018) 249 final} - {SWD(2018) 250 final}
Europaudvalget 2018
KOM (2018) 0337
Offentligt
1
TABLE OF CONTENT
Annex 7 - JRC Technical Report on the development of minimum quality
requirements for water reuse in agricultural irrigation and aquifer proposed.. 2
Annex 7a - Non-technical summary of JRC technical report on the development of
minimum quality requirements for water reuse in agricultural irrigation and
aquifer proposed............................................................................................. 67
Annex 8 - Assessment of impacts on Research and Innovation................................... 71
Annex 9 - Assessment of territorial impacts ................................................................ 85
Annex 10 - International trade dimension.................................................................. 147
Annex 11 – Subsidiarity assessment of potential EU-level regulation of water reuse for
aquifer recharge............................................................................................ 149
Annex 12 – Comparison of impacts per policy options and per different group of
Member States.............................................................................................. 150
Annex 13 – Abbreviations and Glossary.................................................................... 152
2
Annex 7 - JRC Technical Report on the development of minimum quality requirements
for water reuse in agricultural irrigation and aquifer proposed
Minimum quality requirements for water reuse in agricultural irrigation and aquifer recharge
Towards a legal instrument on water reuse at EU level
Alcalde-Sanz, L. and Gawlik, B.M
This publication is a Science for Policy report by the Joint Research Centre (JRC), the
European Commission’s science and knowledge service. It aims to provide evidence-based
scientific support to the European policymaking process. The scientific output expressed does
not imply a policy position of the European Commission. Neither the European Commission
nor any person acting on behalf of the Commission is responsible for the use that might be
made of this publication.
Contact information
Name: Bernd Manfred Gawlik
Address: EC – Joint Research Centre, Directorate D, Via Enrico Fermi 2749, I-21027 Ispra
(Va)
Email: bernd.gawlik@ec.europa.eu
Tel.: +39 0332 78 9487
JRC Science Hub
https://ec.europa.eu/jrc
JRC109291
EUR 28962 EN
Print ISBN 978-92-79-
77176-7
ISSN 1018-
5593
doi:
10.2760/887727
PDF
ISBN 978-92-79-
77175-0
ISSN 1831-
9424
doi:
10.2760/804116
Luxembourg: Publications Office of the European Union, 2017
3
© European Union, 2017
Reuse is authorised provided the source is acknowledged. The reuse policy of European
Commission documents is regulated by Decision 2011/833/EU (OJ L 330, 14.12.2011, p. 39).
For any use or reproduction of photos or other material that is not under the EU copyright,
permission must be sought directly from the copyright holders.
How to cite this report: L. Alcalde-Sanz, B. M. Gawlik, Minimum quality requirements for
water reuse in agricultural irrigation and aquifer recharge -Towards a legal instrument on
water reuse at EU level, EUR 28962 EN, Publications Office of the European Union,
Luxembourg, 2017, ISBN 978-92-79-77176-7, doi 10.2760/887727, PUBSY No.109291
All images © European Union 2017, except: Cover picture, The city of Milan, the WWTP of
Nosedo and the fields towards Chiaravalle Abbay, 5 June 2012, Photo commissioned by
MilanoDepur S.p.A-Via Lampedusa 13 Milano, with courtesy of Ing .Roberto Mazzini
(President)
Title Minimum quality requirements for water reuse in agricultural irrigation and
aquifer recharge
Abstract
As an input to the design of a Legal Instrument on Water Reuse in Europe, this report
recommends minimum quality requirements for water reuse in agricultural irrigation and
aquifer recharge based on a risk management approach.
Printed in Italy
4
Contents
Acknowledgements .................................................................................................................... 5
Executive summary.................................................................................................................... 6
1 Introduction.................................................................................................................. 8
2 Scope of the document............................................................................................... 10
3 Framework for water reuse management................................................................... 12
4 Management of health and environmental risks for water reuse in agricultural
irrigation..................................................................................................................... 15
4.1 Agricultural irrigation uses............................................................................. 15
4.2 Risk management framework for agricultural irrigation................................ 15
Assembly of a risk management team................................................ 16
4.2.1
Description of the water reuse system................................................ 16
4.2.2
Identification of hazards and hazardous events, and risk assessment 16
4.2.3
4.2.3.1 Health risks ............................................................................... 16
4.2.3.2 Environmental risks .................................................................. 17
Determination of preventive measures to limit risks.......................... 19
4.2.4
Development of operational procedures............................................. 21
4.2.5
Verification of water quality and receiving environments................. 23
4.2.6
Validation of processes and procedures ............................................. 24
4.2.7
Management of incidents and emergencies........................................ 24
4.2.8
4.3 Minimum reclaimed water quality criteria and preventive measures ............ 24
4.4 Justification for the selected quality requirements......................................... 28
Health and environmental risks considered for agricultural irrigation
4.4.1
............................................................................................................ 28
Tolerable risk for human health ......................................................... 29
4.4.2
Reference pathogens........................................................................... 30
4.4.3
Performance targets............................................................................ 31
4.4.4
Microbiological parameters for monitoring ....................................... 32
4.4.5
Water quality criteria.......................................................................... 35
4.4.6
Physico-chemical parameters for monitoring..................................... 38
4.4.7
5 Management of health and environmental risks for water reuse in aquifer recharge 41
5.1 Aquifer recharge uses..................................................................................... 41
5.2 Risk management framework for managed aquifer recharge ........................ 42
5.3 Justification for the selected requirements..................................................... 44
6 Compounds of emerging concern .............................................................................. 46
6.1 Knowledge and gaps ...................................................................................... 46
6.2 Anti-microbial resistances.............................................................................. 47
6.3 Measurements and testing .............................................................................. 48
7 Conclusions................................................................................................................ 50
References ................................................................................................................................ 51
List of abbreviations and definitions........................................................................................ 58
List of figures ........................................................................................................................... 62
List of tables............................................................................................................................. 63
Annex 64
5
Acknowledgements
The authors gratefully acknowledge the useful comments and suggestions provided by the
experts consulted Anders Daalsgard (University of Copenhagen, WHO representative on
water reuse issues for the EC), Jörg E. Drewes (Technological University of Munich, Chair of
the IWA Specialist Group Water Reuse), Valentina Lazarova (SUEZ Environnement),
Gertjan Medema (Water Cycle Research Institute (KWR)), Alfieri Pollice (Water Research
Institute, Italian National Research Council (IRSA-CNR)), Jaroslav Slobodnik
(Environmental Institute), Thomas Ternes (German Federal Institute of Hydrology (BfG)),
and Thomas Wintgens (University of Applied Science and Arts Northwestern Switzerland
(FHNW)).
6
Executive summary
At present, the uptake of water reuse solutions remains limited in comparison with their
potential, which remains largely untapped. In the 2015 Communication ‘Closing the loop –
An EU action plan for the Circular Economy’ (COM/2015/614) and in the Inception Impact
Assessment of the EU, water reuse initiative at hand, agricultural irrigation and aquifer
recharge were identified as main potential sources of demand for reclaimed water. This is
because both applications have the greatest potential in terms of its higher uptake, scarcity
alleviation and EU relevance: agricultural irrigation as the biggest user of treated wastewater
and the links with the Internal Market and aquifer recharge due to the cross-border nature of
many aquifers. A primary goal is hence to encourage efficient resource use and reduce
pressures on the water environment, in particular water scarcity, by fostering the development
of safe reuse of treated wastewater. As an input to the design of an EU Legal Instrument
aiming at these two water reuse applications, this report recommends minimum quality
requirements for water reuse in agricultural irrigation and aquifer recharge based on a risk
management approach.
Policy context
This report provides the scientific support for the development of a Legal Instrument on
minimum quality requirements for water reuse at EU level for two specific uses, agricultural
irrigation and aquifer recharge. This document has been requested by DG ENV and developed
with additional inputs from experts in the water reuse field.
The opportunity to take action at EU level with a view to increasing water reuse was already
identified in the 2012 Commission Communication "A Blueprint to Safeguard Europe's Water
Resources" (COM(2012)673). This initiative would contribute to the achievements of some
key objectives under the 7th
EU Environment Action Programme to 2020 (i.e. protecting,
conserving and enhancing the Union’s natural capital and turning the Union into a resource-
efficient economy). In the Communication "Closing the loop – An EU action plan for the
circular economy" (COM(2015)614), the Commission already committed to develop a series
of non-regulatory actions to promote safe and cost-effective water reuse. The Commission
published in April 2016 an Inception Impact Assessment on “Minimum quality requirements
for reused water in the EU (new EU legislation)” stating that the initiative of a regulation on
minimum quality requirements for reused water in agricultural irrigation and aquifer recharge
will encourage efficient resource use and reduce pressures on the water environment, provide
clarity, coherence and predictability to market operators, and complement the existing EU
water policy, notably the Water Framework Directive and the Urban Wastewater Treatment
Directive.
The intention to address water reuse with a new legislative proposal was noted with interest
by the Council in its conclusions on Sustainable Water Management (11902/16). Furthermore,
the European Parliament, in its Resolution on the follow-up to the European Citizens’
Initiative Right2Water in September 2015, encouraged the Commission to draw up a
legislative framework on water reuse, as well as the Committee of the Regions, in its opinion
on "Effective water management system: an approach to innovative solutions" in December
2016.
7
Key conclusions
The development of minimum quality requirements for water reuse in agricultural irrigation
and aquifer recharge is based on a risk management framework, which is recommended to
tackle health and environmental risks and assure a safe use of reclaimed water for agriculture
and aquifer recharge. The minimum requirements defined here ensure an appropriate health
and environmental protection and thus provide public confidence in reuse practices. This
document will contribute to establish a common approach on water reuse across the EU
providing clarity, coherence and predictability to market operators, who wish to invest in
water reuse in the EU under comparable regulatory conditions.
Additional guidance on the application of a risk management framework is identified as a
need to complement a future regulation on water reuse.
Main findings
The document recommends specific minimum requirements for reclaimed water quality
taking into consideration the health and environmental risks related to water reuse practices.
A risk management framework has to be applied to water reuse systems to assure a safe use of
reclaimed water for agriculture and aquifer recharge, following the World Health
Organization recommendation. Therefore, the main elements to implement a risk management
framework are established, including the steps to develop health and environmental risks
assessments. The related EU legislation has been always considered when appropriate.
Minimum quality requirements including microbiological and physico-chemical parameters,
associated limit values and monitoring frequencies are established for agricultural irrigation.
Preventive measures to be adopted are also defined.
The Groundwater Directive is the overarching framework for aquifer recharge with reclaimed
water, and this Directive is embedded in the risk management framework to be applied.
Flexibility is given to Member States to define more stringent limits and to assess risks
considering site specific conditions, especially for environmental risks.
Related and future JRC work
The JRC report “Water Reuse in Europe: Relevant guidelines, needs for and barriers to
innovation. A synoptic overview” is an antecedent to the present document, also related to the
water reuse topic. JRC support to forthcoming guidance on water reuse may be expected as a
follow-up from this report, as a complement to a future legal instrument on water reuse.
Quick guide
Water reuse is defined as the use of treated wastewater for beneficial use. Synonymous to
water reuse are also water reclamation and water recycling. A risk management framework
involves identifying and managing risks in a proactive way, being a dynamic and practical
system that, applied to water reuse, incorporates the concept of producing reclaimed water of
a quality that is ‘fit-for-purpose’. It is also a systematic management tool that consistently
ensures the safety and acceptability of water reuse practices. A central feature is that it is
sufficiently flexible to be applied to all types of water reuse systems.
8
1 Introduction
More and more Europe's water resources are increasingly coming under stress, leading to
water scarcity and quality deterioration. Pressures from climate change, droughts and urban
development have put a significant strain on freshwater supplies (EEA, 2012). In this context,
Europe’s ability to respond to the increasing risks to water resources could be enhanced by a
wider reuse of treated wastewater. As stated in COM (2015)614: “Closing the loop – An EU
action plan for the circular economy” the Commission will take a series of actions to promote
the reuse of treated wastewaters, including development of a regulatory instrument on
minimum quality requirements for water reuse in agricultural irrigation and aquifer recharge.
Information sources agree on the significant potential for further development of water reuse
projects in the EU (BIO, 2015). Water reuse can help lower the pressure on freshwater
resources. Other benefits include decreasing wastewater discharges, even if sometimes, during
the summer period, the discharges are needed to achieve the ecological flow, and reducing
and preventing pollution of surface water. In addition, development of reuse in the EU is a
market opportunity for the water industry and other industries with a strong eco-innovation
potential in terms of technologies and services around water recycling in industry, agriculture
and domestic water systems. It will provide new and significant opportunities for Europe to
become a global market leader in water-related innovation and technology.
Water reuse needs to be considered as a measure within the context of the water policy
hierarchy. The EC Communication on Water Scarcity and Droughts (COM (2007)414) sets
out the water hierarchy of measures that Member States (MS) should consider in managing
water scarcity and droughts. This communication states that water saving must become the
priority and all possibilities to improve water efficiency must therefore be explored. Policy
making should be based on a clear water hierarchy. Additional water supply infrastructures
should be considered as an option when other options have been exhausted, including
effective water pricing policy and cost-effective alternatives. Water uses should also be
prioritised: it is clear that public water supply should always be the overriding priority to
ensure access to adequate water provision. It also states that in regions where all prevention
measures have been implemented according to the water hierarchy (from water saving to
water pricing policy and alternative solutions) and taking due account of the cost-benefit
dimension, and where demand still exceeds water availability, additional water supply
infrastructure can in some circumstances be identified as a possible other way of mitigating
the impacts of severe drought.
Although the use of reclaimed water is an accepted practice in several EU countries
experiencing water scarcity issues (e.g. Cyprus, Greece, Italy, Malta, Portugal, Spain), where
it has become a component of long-term water resources management, overall a small
proportion of reclaimed water is currently reused in the EU, even in those countries. Hence,
there is significant potential for increased uptake of water reuse solutions in countries with
several regions of water scarcity (Hochstrat et al., 2005).
One of the main barriers identified is the lack of harmonization in the regulatory framework to
manage health and environmental risks related to water reuse at the EU level, and thus a lack
of confidence in the health and environmental safety of water reuse practices.
The health and environmental safety conditions under which wastewater may be reused are
not specifically regulated at the EU level. There are no guidelines, regulations or good
management practices at European Union (EU) level on water quality for water reuse
purposes. In the Water Framework Directive (WFD) (2000/60/EC), reuse of water is
9
mentioned as one of the possible measures to achieve the Directive’s quality goals: Part B of
Annex VI refers to reuse as one of the “supplementary measures” which Member States
within each river basin district may choose to adopt as part of the programme of measures
required under Article 11(4). Besides that, Article 12 (4) of the Urban Wastewater Treatment
Directive (91/271/EEC) concerning the reuse of treated wastewater states that “treated
wastewater shall be reused whenever appropriate”.
Even though the lack of common water reuse criteria at the EU level, several Member States
(MS) have issued their own regulations, or guidelines for different water reuse applications.
However, after an evaluation carried out by the EC on the water reuse standards of several
MS it was concluded that there are important divergences among the different regulations
regarding the permitted uses, the parameters to be monitored, and the limiting values allowed
(JRC, 2014). This lack of harmonization among water reuse standards within the EU might
create some trade barriers for agricultural goods irrigated with reclaimed water. Once on the
common market, the level of safety in the producing MS may not be considered as sufficient
by the importing countries.
The relevance of EU action on water reuse was identified in the Impact Assessment of the
“Blueprint to Safeguard Europe's Water Resources” published in November 2012. The
Blueprint made clear that one alternative supply option- water reuse for irrigation or industrial
purposes- has emerged as an issue requiring EU attention (COM(2012)673). Reuse of
appropriately treated wastewater is considered to have a lower environmental impact than
other alternative water supplies (e.g. water transfers or desalination), but it is only used to a
limited extent in the EU. This appears to be due to the lack of common EU
environmental/health standards for water reuse and the potential obstacles to the free
movement of agricultural products irrigated with reclaimed water (COM(2012)673).
After the 2015 Communication “Closing the loop - An EU action plan for the Circular
Economy” the Commission published in April 2016 an Inception Impact Assessment on
“Minimum quality requirements for reused water in the EU (new EU legislation)” stating that
the initiative of a regulation on minimum quality requirements for reused water in agricultural
irrigation and aquifer recharge will encourage efficient resource use and reduce pressures on
the water environment, provide clarity, coherence and predictability to market operators, and
complement the existing EU water policy, notably the Water Framework Directive and the
Urban Wastewater Treatment Directive.
To support this initiative the EC (DG ENV) asked its science and knowledge service, the Joint
Research Centre (JRC) to develop a technical proposal for the minimum quality requirements
for water reuse in agricultural irrigation and aquifer recharge.
Considering the sensitivity of the health and environmental issue and public confidence in
water reuse practice, the scientific advice of the independent Scientific Committee on Health,
Environmental and Emerging Risks (SCHEER) and the European Food Safety Authority
(EFSA) has been be requested and taken into consideration in the final document.
10
2 Scope of the document
The purpose of this document is to propose minimum quality requirements for water reuse for
two specific water reuse applications: agricultural irrigation and aquifer recharge. These
requirements should ensure appropriate health and environmental protection and thus provide
public confidence in reuse practices in order to enhance water reuse at EU level. This
technical document is expected to support the proposal of EU legislation on water reuse.
The only source of wastewater considered in this document is the urban wastewater covered
by Directive 91/271/EEC (Urban Wastewater Treatment Directive UWWTD) where urban
wastewater is defined as domestic wastewater or the mixture of domestic wastewater with
industrial wastewater and/or run-off rain water. The industrial wastewater considered is from
the industrial sectors listed in Annex III of the UWWTD, which are the following:
— Milk-processing
— Manufacture of fruit and vegetables products
— Manufacture and bottling of soft drinks
— Potato-processing
— Meat industry
— Breweries
— Production of alcohol and alcoholic beverages
— Manufacture of animal feed from plant products
— Manufacture of gelatin and of glue from hides, skin and bones
— Malt-houses
— Fish-processing industry
This document does not deal with reclaimed water from other industrial sources: industrial
wastewaters may have very particular characteristics in relation to quality and they may
require specific quality criteria.
A water reuse system, as defined in this document, includes the following:
— Raw wastewater entering the wastewater treatment plant (WWTP)
— The wastewater treatment technologies included in the WWTP
— The additional treatments to produce reclaimed water of the required quality for reuse
— The storage and distribution systems
— The irrigation system (in case of agricultural irrigation), or the recharge method (in case of
managed aquifer recharge)
For the purposes of developing the present work, a review of the available scientific, technical
and legal knowledge on water reuse in agricultural irrigation and aquifer recharge has been
carried out. Specifically, the documents that have been the basis to establish the minimum
quality requirements for agricultural irrigation and aquifer recharge are the following:
— The regulatory framework at EU level on health and environmental protection
11
— The MS water reuse legislations and guidelines in place, along with their experience in
water reuse systems
— Worldwide reference guidelines and regulations on water reuse
— Additional scientific references considered relevant for the topic
Selected experts in water reuse, whose contributions are gratefully acknowledged, have been
consulted to provide comments and input through critical discussion on the document along
the process. However, the content of this document has not been endorsed by these experts
and reflects only the scientific opinion of the JRC. It is important to note that no risk
assessment specifically for the establishment of the minimum quality requirements has been
performed.
12
3 Framework for water reuse management
The approach to develop minimum quality requirements for the safe use of reclaimed water
for agricultural irrigation and aquifer recharge is a risk management framework, as
recommended by the World Health Organization WHO (WHO, 2006) and included in the
Directive 2015/1787 that amends Directive 98/83/EC on the quality of water intended for
human consumption.
The WHO, in order to tackle the health and environmental risks caused by microbiological
and chemical contaminants potentially present in water, recommends to implement the
principles of a risk management framework (WHO, 2001). The WHO suggests that a risk
management approach should be applied to drinking water, reclaimed water, and recreational
water. A risk management approach provides the conceptual framework for the WHO
Guidelines for Drinking Water Quality (WHO, 2004 and 2011), and the Guidelines for the
Safe use of Wastewater, Excreta and Greywater (WHO, 2006). A risk management approach
involves identifying and managing risks in a proactive way, rather than simply reacting when
problems arise being a dynamic and practical system that, applied to water reuse, incorporates
the concept of producing reclaimed water of a quality that is ‘fit-for-purpose’.
The Guidelines for the Safe Use of Wastewater, Excreta and Greywater (WHO, 2006) are
divided into four volumes, devoted to different topics: Volume I, Policy and regulatory
aspects; Volume II, Wastewater use in agriculture; Volume III, Wastewater and excreta use in
aquaculture; and Volume IV, Excreta and greywater use in agriculture.
Following the risk management approach, the Australian government developed the
Australian Guidelines for Water Recycling and the Australian Drinking Water Guidelines
(NHMRC-NRMMC, 2011). The Australian Guidelines for Water Recycling provide a generic
framework for management of reclaimed water quality and use that applies to all
combinations of reclaimed water and end uses, including agricultural irrigation and aquifer
recharge. These guidelines are structured in two phases. Phase I document (NRMMC-EPHC-
AHMC, 2006) provides the scientific basis to assist and manage health and environmental
risks. The three Phase II documents cover the specialized requirements for augmentation of
drinking water supplies (NRMMC-EPHC-NHMRC, 2008), storm water harvesting and reuse,
and managed aquifer recharge (NRMMC-EPHC–NHMRC, 2009). It is to note that the
Australian Guidelines for Water Recycling are currently under a review that will draw on the
advances and implementation of water recycling schemes.
The comprehensive risk management approach in the WHO Guidelines for Drinking Water
Quality is termed “Water Safety Plan (WSP)” (WHO, 2009). The elements of a WSP build on
many of the principles and concepts from other systematic risk management approaches, in
particular the multiple-barrier approach and the hazard analysis and critical control points
(HACCP) system (WHO, 2011). The WHO, and also the Australian guidelines, recommends
the implementation of a risk management plan including a risk assessment for water reuse
systems. For this purpose, the WHO has launched a Sanitation Safety Planning (SSP) manual
as guidance on implementation of the WHO guidelines for water reuse (WHO, 2015). A SSP
is a step-by-step health risk based approach for managing, monitoring and improving
sanitation systems. The SSP is in line with the concept of the WSPs manual issued for
drinking water supply systems (WHO, 2009).
The United States Environmental Protection Agency (USEPA) issued, in 2012, the last
version of the Guidelines for Water Reuse (USEPA, 2012). These guidelines include a wide
range of reuse applications (e.g. agricultural irrigation and aquifer recharge) and apply a
13
similar approach as described in the WHO and the Australian guidelines for controlling health
and environmental risks.
In 2015, the International Organization for Standardization (ISO) published the Guidelines for
treated wastewater use for irrigation projects, including agricultural irrigation (ISO 16075,
2015). These ISO guidelines provide guidance for healthy, environmentally and
hydrologically good operation, monitoring, and maintenance of water reuse projects for
unrestricted and restricted irrigation of agricultural crops, gardens, and landscape areas using
treated wastewater. The guidelines are divided into four parts: The basis of a reuse project for
irrigation, that considers climate, soils, design, materials, construction, and performance (Part
1); Development of the project (Part 2) that includes water quality requirements like
microbiological and chemical parameters, potential barriers and potential corresponding water
treatments; and Components of a reuse project for irrigation (Part 3) that includes
recommendations for irrigation systems, and distribution and storage facilities, and
Monitoring (Part 4). The ISO guidelines include recommended parameters and limit values
that are elaborated on the basis of international regulations, like the WHO and the USEPA
guidelines, to assure health and environmental safety of water reuse projects in irrigation.
The State of California has been a pioneer in issuing water reuse regulations and the water
quality requirements that California establishes have become a global benchmark, and they
have provided a basis for the development of water reuse regulations worldwide. The State of
California regulatory approach on water reuse is based on stringent treatment technology
targets with specific performance requirements for several uses, including also agricultural
irrigation. Statutes and regulations related to water reuse in California are based on a risk
assessment and the multiple-barrier principle and are included in the California Health and
Safety Code, the California Water Code, and the California Code of Regulations. In the last
update of the water reuse regulations, the Division of Drinking Water (DDW) (formerly
known as CDPH) included also indirect potable reuse considering aquifer replenishment by
surface and subsurface application (CDPH, 2014).
In EU countries, the most comprehensive water reuse regulations and recommendations
issued by MS (i.e. Cyprus, France, Greece, Italy, Portugal, Spain) (DM, 2003; NP, 2005; RD,
2007; CMD, 2011; JORF, 2014; KDP, 2015) are based on the referenced guidelines and
regulations cited above, all of them including several modifications for some uses
(Paranychianakis et al., 2014).
A risk management framework is a systematic management tool that consistently ensures
the safety and acceptability of water reuse practices. A central feature is that it is sufficiently
flexible to be applied to all types of water reuse systems, irrespective of size and complexity.
The risk management framework incorporates several interrelated elements, each of which
supports the effectiveness of the others. Because most problems associated with reclaimed
water schemes are attributable to a combination of factors, these factors need to be addressed
together to ensure a safe and sustainable supply of reclaimed water. The elements, based on
the recommendations of international guidelines (WHO, 2004, 2009 and 2011; NRMMC-
EPHC-AHMC, 2006) are the following:
— Assembly of a risk management team.
— Description of the water reuse system.
— Identification of hazards and hazardous events, and risk assessment.
14
— Determination of preventive measures to limit risks.
— Development of operational procedures.
— Verification of the water quality and the receiving environment.
— Validation of processes and procedures.
— Management of incidents and emergencies.
In this context, it is of paramount importance that MS apply the principles of a risk
management framework for the safe use of reclaimed water for agricultural irrigation and
aquifer recharge.
15
4 Management of health and environmental risks for water reuse in agricultural
irrigation
This section includes the definition of the key elements of a risk management framework that
MS have to apply to manage health and environmental risks when reclaimed water is used in
agricultural irrigation. It also includes the definition of common (not site specific) minimum
quality requirements and preventive measures to be applied to all EU water reuse projects for
agricultural irrigation, with the associated justification.
Regarding the source of wastewater to be reclaimed, as a minimum requirement, it has to be
stressed that the Directive 91/271/EEC (UWWTD) that concerns the collection, treatment and
discharge of urban wastewater, establishes quality requirements that have to be satisfied by
discharges from urban wastewater treatment plants (UWWTP) including also specific
requirements for discharges in sensitive areas (Annex I of UWWTD). Water from wastewater
treatment plants destined for reuse is considered a discharge under the UWWTD at the point
where it leaves the water treatment plant (after treatment) (EC, 2016). Therefore, as the only
source of wastewater considered in this document is the wastewater covered by the UWWTD,
all treated wastewater potentially considered for reclamation and reuse (i.e. wastewater
coming from an UWWTP) has to comply, at least, with the quality requirements specified in
the UWWTD Annex I, table 1 and, when applicable, with the requirements from Annex I,
table 2 for sensitive areas.
In order to assure that wastewater that enter a UWWTP is included in the Annex III of the
Directive 91/271/EEC, thus, it is necessary to establish source control programs and oversight
of industrial and commercial discharges to the sewer systems connected to a wastewater
treatment plant.
4.1 Agricultural irrigation uses
Agricultural irrigation is defined in this document as irrigation of the following types of
crops:
— Food crops consumed raw: crops which are intended for human consumption to be eaten
raw or unprocessed.
— Processed food crops: crops which are intended for human consumption not to be eaten
raw but after a treatment process (i.e. cooked, industrially processed).
— Non-food crops: crops which are not intended for human consumption (e.g. pastures,
forage, fiber, ornamental, seed, energy and turf crops).
These definitions are based on the categories of use described in water reuse guidelines and
some MS legislations (NRMMC-EPHC-AMHC, 2006; WHO, 2006; USEPA, 2012; JRC,
2014). Definitions included in EC food safety regulations 178/2002 and 852/2004 also apply
to these classification.
4.2 Risk management framework for agricultural irrigation
It is recommended that MS have to apply the following elements of a risk management
framework to manage health and environmental risks derived from the use of reclaimed water
for agricultural irrigation.
16
4.2.1 Assembly of a risk management team
This step involves assembling a multidisciplinary team of individuals with adequate
experience and expertise in protecting public and environmental health that understands the
components of the water reuse system and is well placed to assess the associated risks.
4.2.2 Description of the water reuse system
The aim of this element is to provide a detailed understanding of the entire water reuse system
from source to end use. A definition of a water reuse system is provided in Section 2. It is
necessary to assess the historical water quality data, taking into account the variability, and to
construct a flow diagram of the water reuse system from the source to the application or
receiving environments.
4.2.3 Identification of hazards and hazardous events, and risk assessment
This element involves identifying all hazards and hazardous events of the water reuse scheme,
and assessing the level of risk they pose to health and the environment.
Risk assessment can be defined as a characterization and estimation of potential adverse
effects on health and environmental matrices associated with the intended use of reclaimed
water. Different approaches to risk assessment are proposed in water reuse guidelines with
varying degrees of complexity and data requirements. The risk assessment process can
involve a quantitative or semi-quantitative approach, comprising estimation of
likelihood/frequency and severity/consequence, or a qualitative approach (NRMMC–EPHC–
AHMC, 2006; WHO, 2009 and 2015).
4.2.3.1 Health risks
Minimum quality requirements for the safety of human and animal health when crops are
irrigated with reclaimed water, derived following a human health risk assessment, and
considering animal health protection, are defined in Section 4.3 to be applied to all EU water
reuse projects for agricultural irrigation independently of the site specific conditions.
Additional microbiological or physico-chemical parameters may be included as quality
requirements by MS after a health risk assessment has been performed to justify this
modification. Guidance on health risk assessment to be performed by MS is given below.
Health risk assessment includes the following steps:
— Hazard identification: identification of hazards that might be present in wastewater and
the associated adverse effects to health.
Health hazards to be considered are associated with the agricultural uses, thus including
human and animal health.
Biological (pathogens) and chemical hazards are to be assessed. Therefore, a
characterization of the reclaimed water to be used for irrigation has to be performed to
identify the concentrations of the health hazards present. Variations in hazards
concentration are to be considered. Historical data may be of additional use to establish
the concentration variation of a specific hazard.
— Dose-response: establishment of the relationship between the dose of the hazard and the
incidence or likelihood of illness.
17
A dose-response model specific for each of the pathogens selected as a risk has to be used,
based on the scientific knowledge (e.g. Haas et al., 1999; Messner et al., 2001; Teunis et
al., 2008).
Chemical compounds are evaluated by defining the NOAEL (No Observed Adverse Effect
Level), the LOAEL (Lowest Observed Adverse Effect Level), and the RfD (Reference
Dose) according to scientific knowledge.
— Exposure assessment: determination of the size and nature of the population exposed to
the hazard, and the route, amount and duration of exposure.
The route of exposure, exposure volumes and frequency of exposure of the hazards has to
be defined considering local conditions. Scientific knowledge is limited, thus some
conservative values are sometimes use, if no other data is available in the literature
(NRMMC-EPHC-AHMC, 2006; WHO, 2006).
— Risk characterisation: integration of data on hazard presence, dose-response and
exposure obtained in the first three steps.
The tolerable health risk defined in this document is 10–6
DALYs per person per year. For
microbiological hazards, performance targets for the reference pathogens selected and
water quality targets for indicator organisms are to be determined as health-based targets.
For chemical hazards, most frequently, health-based targets are water quality targets,
taking the form of chemical guideline values. A chemical guideline value is the
concentration of a chemical component that, over a lifetime of consumption, will not lead
to more than 10–6
DALYs per person per year.
The WHO performed a health risk assessment to derive maximum concentrations in soils
for a set of organic and inorganic chemicals based on human health risks (WHO, 2006)
and this data may be taken as a guidance if no updated scientific data is available.
4.2.3.2 Environmental risks
It is recommended that MS have to assure that the use of reclaimed water for agricultural
irrigation has no adverse effects on environmental matrices (soil, groundwater, surface water,
and dependent ecosystems, including crops to be irrigated) and that reclaimed water use is in
compliance with the related EU directives for environmental protection.
Regulatory requirements of related EU Directives for environmental protection have to be
always fulfilled. MS have to ensure that water reuse system does not compromise the
objectives for surface water, groundwater, and dependent ecosystems established by the
following EU directives:
— Directive 2000/60/EC (Water Framework Directive (WFD)).
— Directive 2008/105/EC (Environmental Quality Standards Directive (EQSD)) amended by
Directive 2013/39/EU.
— Directive 2006/118/EC amended by Directive 2014/80/EE (Groundwater Directive
(GWD)).
— Directive 91/271/EEC (Urban Wastewater Treatment Directive (UWWTD)).
— Directive 91/676/EEC (Nitrates Directive).
— Other related EU Directives that may apply.
18
In order to comply with these EU directives, MS have to establish, on a case-by-case basis,
minimum quality requirements for parameters included in the related EU directives to be
complied with by the reclaimed water effluent and to be included for verification monitoring.
The guidance documents produced by the Common Implementation Strategy (CIS) of the
WFD to assist MS to implement the WFD are to be use as tools to characterize the existent
quality status of the surface water, groundwater, and related ecosystems that may be affected
by reclaimed water used for irrigation. Guidance documents are intended to provide an overall
methodological approach, but these will need to be tailored to specific circumstances of each
MS.
Environmental risks related to nutrients from agricultural irrigation with reclaimed water are
in great part to be controlled and reduced by MS through codes of good agricultural practices
and Action Programmes established under the Nitrates Directive (91/676/EEC). These must
contain, at least, provisions covering the items mentioned in Annex II and Annex III of the
Directive including measures concerning balanced fertilization. The prevention of nitrate
pollution via run-off from agricultural irrigation needs to be ensured especially in the
designated Nitrate Vulnerable Zones.
In addition to the parameters of the related EU directives, other microbiological and physico-
chemical hazards may also affect surface water, groundwater and dependent ecosystems
according to the wastewater effluent to be treated for reuse, and the site specific conditions.
Therefore, MS have to establish, according to the outcome of an environmental risk
assessment, minimum quality requirements for additional parameters not included in the
related EU Directives to be complied with by the reclaimed water effluent and to be included
in the reclaimed water quality criteria.
Furthermore, MS have to perform an environmental risk assessment to protect soils, and
dependent ecosystems, including crops to be irrigated, on a case-by-case basis according to
site specific conditions, and establish, according to the outcome of the risk assessment,
minimum quality requirements to be complied with by the final reclaimed water effluent and
to be included in the reclaimed water quality criteria. Guidance on environmental risk
assessment to be performed by MS is given below.
Environmental risk assessment includes the following steps:
— Hazard identification: identification of hazards that might be present in wastewater and
the associated adverse effects to the environment.
Environmental hazards are to be considered according to the environmental matrices that
may be exposed to reclaimed water, which are soil, groundwater, surface water, and
related biota (e.g. plants).
The physico-chemical hazards to be evaluated for preventing adverse effects on surface
water, groundwater, and related ecosystems are additional to the parameters defined in
the related EU Directives mentioned above. The physico-chemical hazards also to be
evaluated are hazards for preventing adverse effects on soils, and related ecosystems
including crops (agronomic parameters) that include salinity related parameters, metals,
nutrients, and trace elements. Indicative agronomic parameters are included in different
guidelines (FAO, 1985; WHO, 2006; USEPA, 2012; ISO 16075, 2015).
— Estimate the likelihood of a hazardous event: estimate the likelihood that an
environmental endpoint will be exposed to the hazard in sufficient concentrations to cause
a detrimental effect.
19
Once the physico-chemical hazards concentrations are determined, it has to be established
the likelihood that these concentrations will pose an adverse effect on the environmental
matrices.
The concentrations of the agronomic parameters evaluated have to be assess to establish if
they can have adverse effects on soils, crops and dependent ecosystems. For this purpose,
soils and crops have to be characterized. Soil characterization includes the determination
of the agronomic parameters, including texture, hydraulic conductivity, water retention
capacity, and organic matter content. The specific crop requirements and toxicity to the
physico-chemical hazards found in reclaimed water has to be evaluated in order to avoid
phytotoxicity. Data related to crops and soils tolerance according to site specific
conditions has to be used. Examples of limit values for agronomic parameters to protect
soils and crops are also included in international guidelines (FAO, 1985; NRMMC-
EPHC-AHMC, 2006; WHO, 2006; ISO 16075, 2015). The Directive 86/78/EEC (Sludge
Directive) on the protection of the environment, and in particular of the soil, when sewage
sludge is used in agriculture establishes limit values for heavy metals in soils, and the
maximum limit values of heavy metals amounts which may be added annually to
agricultural land based on a 10 year average (Annex I A and C of Directive 86/78/EEC).
These values may be taken into account as a reference in order to do not damage the soil
quality. However, since the adoption of the Directive 86/78/EEC, several MS have
enacted and implemented stricter limit values for heavy metals and set requirements for
other contaminants. The Sludge Directive is now under a revision process and any update
should be considered accordingly.
— Estimate the consequences of the hazardous event: determine the consequences (or
impacts) of exposure to a hazard by considering the specific conditions of the
environmental endpoint.
If additional hazards to the ones considered in the EU related Directives to prevent
adverse effects on surface water, groundwater, and dependent ecosystems are defined, it is
necessary to estimate the adverse impact that these hazards may pose. This has to be
established based on scientific knowledge.
The consequences of the adverse effects to be posed to crops and soils by the agronomic
parameters evaluated has to be determined based on scientific knowledge.
— Characterize the overall risk: characterize the risk by integrating the data on hazards,
hazardous events, likelihood and consequences, obtained through the steps described
above.
The characterization of the overall risk has to be determined by combining the hazards
and hazardous events with their likelihood and consequences. This can be done using a
risk assessment matrix that rates risks from “low” to “very high”. An example of this
procedure is found in the Australian guidelines (NRMMC-EPHC-AHMC, 2006).
Based on the results obtained, MS have to establish water quality requirements to be
included in the reclaimed water quality criteria, defining also possible preventive
measures to be applied, as good agricultural practices.
4.2.4 Determination of preventive measures to limit risks
Safe use of reclaimed water requires the implementation of preventive measures (barriers) to
reduce hazards and exposure to hazards by the following actions:
20
— Preventing hazards from entering reclaimed water.
— Removing them using treatment processes.
— Reducing exposure, either by using preventive measures at the site of use or by restricting
uses.
Identification and implementation of preventive measures should be based on the multiple
barrier principle. According to this principle, multiple preventive measures or barriers are
used to control the risks posed by different hazards, thus making the process more reliable.
The strength of this principle is that a failure of one barrier may be compensated by effective
operation of the remaining barriers, thus minimizing the likelihood of contaminants passing
through the entire system and being present in sufficient amounts to cause any harm to human
health or environmental matrices. Many control measures may contribute to control more than
one hazard, whereas some hazards may require more than one control measure (WHO, 2011).
Water treatment processes prevent or reduce the concentration of hazards in the reclaimed
water effluent and are the most important barrier to eliminate or minimize health and
environmental risks of water reuse practices.
On-site controls are additional preventive measures that can prevent or minimise public
exposure to hazards and can also minimise the impact on receiving environments.
The preventive measures that MS have to consider in order to reduce potential adverse effects
on health and the environment, according to site specific conditions, are the following:
— Wastewater treatment technologies: treatment technologies are an essential barrier to
prevent health and environmental risks. Untreated raw wastewater and secondary treated
wastewater effluents (complying with UWWTD) are forbidden to be used directly for
irrigation purposes. Therefore, an additional treatment is always needed in order to use
urban wastewater for agricultural irrigation.
— Crops characteristics: the characteristics of crops (i.e. crops eaten raw, processed, with
inedible skin) are taken into account as a barrier to reduce health risks to consumers.
Selection of crops has to be made according to crop tolerance (e.g. salt and specific ion
tolerance), reclaimed water quality and soil properties to produce satisfactory yields.
— Irrigation method: the different irrigation methods considered reflect the reduction in
exposure to health hazards that specific irrigation methods present (i.e. drip irrigation) and
the greater risks that other irrigation methods pose due to aerosols formation (i.e. sprinkler
irrigation).
— Drinking water sources protection: the vulnerability of existing drinking water sources
to the use of reclaimed water for irrigation has to be assessed. Article 7 of the WFD
requires that MS shall ensure the necessary protection for waters used for the abstraction
of drinking water, or intended for such use, with the aim of avoiding deterioration in their
quality, establishing safeguard zones for those bodies of water, if necessary.
— Control of the storage and distribution system: within the distribution system, that may
include storage (open and closed reservoirs), reclaimed water for irrigation may suffer
changes that affect its chemical and biological quality (e.g. microbial regrowth,
nitrification, algae growth, natural decay of microorganisms). Thus, management
21
strategies, including monitoring, have to be undertaken in order to prevent the
deterioration of reclaimed water quality. Maintaining good water quality in the
distribution system will depend on the design and operation of the system and on
maintenance and survey procedures to prevent contamination. Control of short-circuiting
and prevention of stagnation in both storage and distribution, including use of backflow
prevention devices, maintaining positive pressure throughout the system and
implementation of efficient maintenance procedures are strategies to maintain the quality
of reclaimed water within the storage and distribution system. Reclaimed water can be
mixed with water from natural sources to correct for certain parameters.
— Irrigation schedule: reclaimed water application rates need to be controlled so that
irrigation is consistent in providing maximum benefit, while minimising impacts on
receiving environments (including soils, groundwater and surface water). Irrigation
systems should be installed and operated to minimise surface ponding and to control
surface run-off.
— Access control, buffer zones (security distances) and withholding periods: these
measures should be established as necessary to minimize exposure to health hazards to
humans and animals. It is needed to consider access control for on-site workers, general
public, and animals, and define specific withholding periods for livestock to be fed with
irrigated pastures or fodder.
The establishment of access control, buffer zones (security distances) and withholding
periods has to be evaluated considering the reclaimed water quality used, the irrigation
method, and the site specific conditions (e.g. windy situations). On-site workers access
should ensure compliance with related occupational health and safety regulations in place.
— Education and training: education and training of on-site workers and managers
involved in agricultural irrigation are of principal importance as components of
implementing and maintaining preventive measures. Personnel should be kept fully
informed on the use of reclaimed water. Agricultural workers are especially vulnerable,
and a range of human exposure measures (e.g. personal protective equipment,
handwashing and personal hygiene) are also to be implemented. Occupational health
related EU Directives and national regulations from MS should apply.
— Signage: accidental exposure to reclaimed water can be reduced through the use of
measures such as signage at irrigation sites, indicating that reclaimed water is being used
and is not suitable for drinking.
Recommendations for the assessment and implementation of these preventive measures in
water reuse schemes for agricultural irrigation are included in the ISO guidelines (ISO 16075,
2015) and other water reuse guidelines (NRMMC-EPHC-AHMC, 2006; WHO, 2006;
USEPA, 2012). However, MS must always consider site specific conditions for selection and
implementation of preventive measures.
The selection of common preventive measures (barriers) already considered by this document
to develop the common minimum quality requirements in Section 4.3 have been the
wastewater treatment technology, the crops characteristics, the irrigation method and the
withholding periods and access control for livestock.
22
4.2.5 Development of operational procedures
MS have to assure the appropriate performance of the water reuse system to deliver the
requested level of reclaimed water quality. It is necessary to develop an operational
monitoring protocol to define operational procedures for all activities and process applied
within the whole water reuse system to ensure that all preventive measures implemented to
control hazards are functioning effectively.
MS have to develop an operational monitoring protocol to assess and confirm that the
performance of preventive measures of the water reuse system ensures reclaimed water of an
appropriate quality to be consistently provided. A water reuse system in Section 2 of this
document is defined as follow:
— Raw wastewater entering the wastewater treatment plant (WWTP).
— The wastewater treatments included in the WWTP.
— The additional treatments to produce reclaimed water of the required quality for reuse.
— The storage and distribution systems.
— The irrigation system.
Figure 1. Decision support tree to identify critical control points in a water reuse system.
Source: JRC, 2014.
Critical control points of the water reuse system have to be determined as they are the focus of
the operational monitoring. The identification of critical control points is system specific and
it can be done by applying a decision tree shown in Figure 1.
The operational monitoring protocol has to include parameters that can be readily measured
and provide an immediate indication of performance of the preventive measures to enable a
Ques on 1:
Do preven ve measure exist to reduce the
hazard risk to an acceptable level?
•If no, iden fy preven ve measures
Ques on 2:
Is the preven ve measure specifically
designed to substan ally reduce the risk
presented by the hazard?
•If no, not a cri cal control point
Ques on 3:
Can opera on of the preven ve measure
be monitoried and correc ve ac ons be
applied in a mely fashion?
•If no, not a cri cal control point
Ques on 4:
Would failure of the preven ve measure
lead to immediate correc ve ac on or
possible cessa on of supply? •If no, not a cri cal control point
CRITICAL
CONTROL
POINT
23
rapid response (e.g. disinfectant residuals and other disinfection-related parameters). On-line
monitoring with real-time data reporting is strongly recommended when technologically
feasible (see informative Annex). Operational parameters have to be associated with target
limits and critical limits to define effectiveness and detect variations in performance.
Observational manual checking of preventive measures is also part of the operational
monitoring.
Operational monitoring protocol has also to include procedures for corrective actions to be
implemented when operational parameters are deviated from the critical limit. Operational
monitoring protocols are described in several guidelines (NRMMC-EPHC-AHMC, 2006;
WHO, 2006).
Examples of operational monitoring requirements for the preventive measure of wastewater
treatment processes are shown in Table 1.
Table 1. Examples of operational monitoring for several treatment processes.
Treatment process Operational monitoring Indicative frequency
Secondary treatment (activated sludge) Flow rate
Nitrate, nitrites
BOD5
Suspended solids, solids retention time
Dissolved oxygen
Hydraulic retention time
Continuous (on-line) for flow rate, dissolved
oxygen
Weekly for other parameters
Low-rate biological systems (stabilization
ponds)
Flow rate
BOD5, (facultative and maturation ponds)
Algal levels
Continuous (on-line) for flow rate
Weekly for other parameters
Soil-aquifer treatment Flow rate
Total Organic Carbon (TOC)
Total Nitrogen, nitrates, nitrites
Continuous (on-line)
Weekly for other parameters
Media filtration system Flow rate
Turbidity
Continuous (on-line)
Membrane bioreactor (MBR) pH
Turbidity
Suspended solids, solids retention time
Dissolved oxygen
Hydraulic retention time
Transmembrane pressure
Continuous (on-line) for parameters such as
pH, turbidity, dissolved oxygen,
transmembrane pressure
Weekly for other parameters
Membrane filtration technology Transmembrane pressure
Turbidity
Electrical conductivity
Continuous (on-line)
Ultraviolet light disinfection (UV) Flow rate
Turbidity upstream
UV intensity and/or calculated dose
UV transmissivity
Continuous (on-line)
Ozone/Biological Activated Carbon Ozone dose
Temperature
Continuous (on-line)
Chlorination Free chlorine residual, Ct*
pH
Temperature
Continuous (on-line)
(*) Ct means the product of residual disinfectant content (mg/l) and disinfectant contact time (min).
Source: WHO, 2006; NRMMC-EPHC-AHMC, 2006; USEPA, 2012.
24
4.2.6 Verification of water quality and receiving environments
This element comprises verification of the overall performance of the water reuse treatment
system, the ultimate quality of reclaimed water being supplied, and the quality of the
receiving environment. Verification monitoring is the use of methods, procedures or tests, in
addition to those used in operational monitoring, to assess the overall performance of the
treatment system, the compliance with regulatory requirements of the ultimate quality of the
reclaimed water being supplied, and the quality of the receiving environment.
MS have to perform a routine monitoring to verify that the reclaimed water effluent is
complying with the requested quality criteria included in Section 4.3 and the additional
quality requirements that MS decide to include as quality criteria derived from EU related
Directives and risk assessment outcomes according to site specific conditions.
MS have to implement monitoring programs of the environmental matrices at risk to control
the effect of reclaimed water irrigation as part of the verification monitoring. A monitoring
program for soils, crops, groundwater and surface water, and dependent ecosystems has to be
established, on a case-by-case basis, according to the identified risks. Recommendations for
monitoring programs of environmental matrices when reclaimed water is used for agricultural
irrigation are described in the ISO guidelines (ISO 16075, 2015).
Analytical methods used for monitoring shall comply with the requirements included in the
related Directives (i.e. WFD (2000/60/EC), DWD (98/83/EC), GWD (2006/118/EC) to
conform to the quality control principles, including, if relevant, ISO/CEN or national
standardized methods, to ensure the provision of data of an equivalent scientific quality and
comparability.
4.2.7 Validation of processes and procedures
Validation aims to ensure that processes and procedures control hazards effectively and that
the water reuse system is capable of meeting its design requirements. One of the objectives of
validation monitoring is to prove that the water reuse system can deliver the expected water
quality specified for the intended use. Therefore, validation monitoring includes also
operational and verification monitoring parameters, discussed above.
Validation monitoring has to be conducted when a reclamation system is established
(commissioned) and put in operation, when equipment is upgraded or new equipment or
processes are added. Once the setup of the whole water reuse system has been validated, it is
generally sufficient with the operational and verification monitoring.
MS have to perform, as part of the validation monitoring, the requested performance targets
defined in Table 5.
4.2.8 Management of incidents and emergencies
This element deals with responses to incidents or emergencies that can compromise the
quality of reclaimed water. MS have to establish incident and emergency protocols, and to
develop and document response plans. Such responses protect public and environmental
health, and help to maintain user confidence in reclaimed water.
Following the aforementioned key principles for a risk management framework, minimum
reclaimed water quality criteria and preventive measures to manage human and animal health
25
risks from consuming crops irrigated with reclaimed water have been derived to be
implemented to all water reuse projects at EU level. The justification for this selected
requirements is presented in Section 4.4.
4.3 Minimum reclaimed water quality criteria and preventive measures
Following the aforementioned key principles for a risk management framework, minimum
reclaimed water quality criteria and preventive measures to manage human and animal health
risks from consuming crops irrigated with reclaimed water have been derived to be
implemented to all water reuse projects at EU level. The justification for this selected
requirements is presented in Section 4.4.
The reclaimed water quality criteria are defined in Table 2. The classes of reclaimed water
quality, and the associated use according to the barriers considered is shown in Table 3. The
frequencies for monitoring the final reclaimed water effluent are defined in Table 4.
Table 2. Reclaimed water quality criteria for agricultural irrigation.
Reclaimed
water quality
class
Indicative
technology
target
Quality criteria
E. coli
(cfu/100 ml)
BOD5
(mg/l)
TSS
(mg/l)
Turbidity
(NTU)
Additional criteria
Class A Secondary
treatment,
filtration, and
disinfection
(advanced water
treatments)
or below
detection
limit
Legionella spp.: , cfu/l
when there is risk of
aerosolization.
Intestinal nematodes (helminth
eggs): egg/l when irrigation
of pastures or fodder for
livestock.
Class B Secondary
treatment, and
disinfection
100 According to
Directive
91/271/EEC
According to
Directive
91/271/EEC
-
Class C Secondary
treatment, and
disinfection
1,000 According to
Directive
91/271/EEC
According to
Directive
91/271/EEC
-
Class D Secondary
treatment, and
disinfection
, According to
Directive
91/271/EEC
According to
Directive
91/271/EEC
-
Source: JRC analysis.
Table 3. Classes of reclaimed water quality, and the associated agricultural use and irrigation
method considered.
Crop category Minimum reclaimed
water quality class
Irrigation method
All food crops, including root crops consumed raw and food crops
where the edible portion is in direct contact with reclaimed water
Class A All irrigation methods allowed
26
Crop category Minimum reclaimed
water quality class
Irrigation method
Food crops consumed raw where the edible portion is produced
above ground and is not in direct contact with reclaimed water
Class B All irrigation methods allowed
Class C Drip irrigation only
Processed food crops Class B All irrigation methods allowed
Class C Drip irrigation only
Non-food crops including crops to feed milk- or meat-producing
animals
Class B All irrigation methods allowed
Class C Drip irrigation only
Industrial, energy, and seeded crops Class D All irrigation methods allowed
Source: JRC analysis.
Table 4. Minimum frequencies for reclaimed water monitoring for agricultural irrigation.
Minimum monitoring frequencies
Reclaimed water
quality classes
E. coli BOD5 TSS Turbidity Legionella spp.
(when
applicable)
Intestinal
nematodes
(when
applicable)
Class A Once
a week
Once
a week
Once
a week
Continuous Once
a week
Twice a month
or frequency
determined
according to
the number of
eggs in
wastewater.
Class B Once
a week
According to
Directive
91/271/EEC
According to
Directive
91/271/EEC
-
Class C Twice a month According to
Directive
91/271/EEC
According to
Directive
91/271/EEC
-
Class D Twice a month According to
Directive
91/271/EEC
According to
Directive
91/271/EEC
-
Source: JRC analysis.
The reclaimed water quality criteria will be considered compliant with the requirements
shown in Table 2 if the analytical controls meet all of the following criteria:
— Values for criteria of E. coli and Legionella and intestinal nematodes (Table 2) must be
conformed at 90% of the samples. Samples cannot exceed the maximum deviation limit of
1 log unit from the indicated value for E. coli and Legionella, and 100% of the indicated
value for intestinal nematodes.
— Values for criteria of BOD5, TSS, and turbidity in Class A (Table 2) must be conformed at
90% of the samples. Samples cannot exceed the maximum deviation limit of twice the
value defined in Table 2.
27
Reclaimed water must comply with the quality criteria at the outlet of the treatment plant. The
reclaimed water has to follow the same procedures as for any other irrigation water source
once the water is delivered to the final user. The European Commission notice on guidance
document on addressing microbiological risks in fresh fruits and vegetables at primary
production through good hygiene is a guidance document to be considered (Notice 2017/C
163/01).
MS have to perform a routine monitoring to verify that the reclaimed water effluent is
complying with the requested quality criteria and to be included in the verification procedures
of the water reuse system.
Validation monitoring is mandatory for MS for the most stringent reclaimed water quality
class, Class A, which relies only on the treatment technologies in place to meet the minimum
quality requirements. The Class A allows irrigation of food crops eaten raw even when the
reclaimed water is in contact with the edible parts of the crop and root crops eaten raw.
Validation for Class A is required to assess that the performance targets (log10 reduction) are
complied with by the water reuse system. Validation monitoring entails the monitoring of the
indicator microorganisms associated to each group of pathogens (bacteria, virus and
protozoa). The indicator microorganisms selected are E. coli for pathogenic bacteria, F-
specific coliphages, somatic coliphages or coliphages for pathogenic viruses, and Clostridium
perfringens spores or spore-forming sulfate-reducing bacteria for protozoa. Performance
targets and monitoring frequencies required are shown in Table 5.
It has to be noticed that the reference pathogens used to define the log removals (see section
4.4.4), Campylobacter, rotavirus and Cryptosporidium, can always be used for monitoring
purposes instead of the proposed indicators.
Performance targets (log10 reduction targets) for the selected indicator microorganisms are to
be met considering the concentrations of the raw wastewater effluent entering the UWWTP as
the initial point, and the concentrations of the final reclaimed water effluent at the outlet of the
additional treatment processes as the final point.
Validation monitoring has to be performed before the reuse scheme is put into place, when
equipment is upgraded, and when new equipment or processes are added.
Table 5. Validation monitoring of the treatment performance for agricultural irrigation.
Reclaimed
water quality
class
Indicator microorganisms Performance targets for the treatment train
(log10 reduction)
Class A E. coli .
Total coliphages/F-specific coliphages/ somatic
coliphages*
.
Clostridium perfringens spores/spore-forming
sulphite-reducing bacteria**
.
(*)Total coliphages is selected as the most appropriate viral indicator. However, if analysis of total coliphages is
not feasible, at least one of them (F-specific or somatic coliphages) has to be analyzed.
(**)Clostridium perfringens spores is selected as the most appropriate protozoa indicator. However, spore-
forming sulfate-reducing bacteria is an alternative if the concentration of Clostridium perfringens spores does
not allow to validate the requested log10 removal.
Source: JRC analysis.
28
Analytical methods used for monitoring shall comply with the requirements included in the
related Directives (i.e. WFD (2000/60/EC), DWD (98/83/EC), GWD (2006/118/EC) to
conform to the quality control principles, including, if relevant, ISO/CEN or national
standardized methods, to ensure the provision of data of an equivalent scientific quality and
comparability.
MS have to comply with common specific preventive measures for any water reuse project
regardless of the site specific conditions (Table 6).
Table 6. Specific additional preventive measures for health protection to be complied with by MS
for any site specific condition.
Reclaimed
water quality
class
Specific additional preventive measures to be complied with by MS
Class A - Pigs must not be exposed to fodder irrigated with reclaimed water unless there is sufficient data to
indicate the risks for a specific case can be managed.
Class B - Prohibition of harvesting of wet irrigated or dropped produce.
- Exclude lactating dairy cattle from pasture until pasture is dry.
- Fodder has to be dried or ensiled before packaging.
- Pigs must not be exposed to fodder irrigated with reclaimed water unless there is sufficient data to
indicate the risks for a specific case can be managed.
Class C - Prohibition of harvesting of wet irrigated or dropped produce.
- Exclude grazing animals from pasture for five days after last irrigation.
- Fodder has to be dried or ensiled before packaging.
- Pigs must not be exposed to fodder irrigated with reclaimed water unless there is sufficient data to
indicate the risks for a specific case can be managed.
Class D - Prohibition of harvesting of wet irrigated or dropped produce.
Source: JRC analysis.
The reclaimed water quality requirements and preventive measures are an integral part of the
risk management framework for water reuse in agriculture. It is clearly emerging that the
more "site-specific" risks, which are mostly related to environmental issues, are handled
either under the umbrella of the Water Framework Directive and its Daughter Directives or
subject to the development of specific risk assessments considering local conditions.
4.4 Justification for the selected quality requirements
The quality requirements have been established following the risk management approach.
This framework is recommended by the WHO Guidelines for the Safe Use of Wastewater,
Excreta and Greywater (WHO, 2006) and it has been applied and further detailed in the
Australian Guidelines for Water Recycling (NRMMC–EPHC–AHMC, 2006).
There was no specific risk assessment with European data performed for the present
document to evaluate water reuse schemes for agricultural irrigation. The selection of the
minimum quality requirements established is based on existing water reuse guidelines and MS
regulations, and on the health and environmental risks considered by them.
29
The health and environmental risks related to water reuse in agricultural irrigation are
associated to the potential presence of pathogens and physico-chemical constituents that may
pose a risk to human and animal health, and to environmental matrices.
4.4.1 Health and environmental risks considered for agricultural irrigation
Health risks considered in this document are established based on the exposure scenarios
recommended by WHO guidelines (WHO, 2006), which are the following:
— Ingestion of irrigated crops by consumers.
— Ingestion of droplets (produced by sprinkler irrigation) by workers, bystanders and
residents in nearby communities.
— Inhalation of aerosols (produced by sprinkler irrigation) by workers, bystanders and
residents in nearby communities.
— Dermal exposure by workers, bystanders and residents in nearby communities.
— Ingestion of soil particles by workers, bystanders and residents in nearby communities.
— Ingestion of pastures and fodder by milk- or meat-producing animals (human and animal
health).
— Contamination of drinking water sources.
The environmental risks considered are based on the principle of no adverse effects to be
caused to environmental matrices, according to their present status, in compliance with the
related EU directives for environmental protection mentioned above. In complementarity, specific
environmental risks assessments related to water reuse for agricultural irrigation established in
different guidelines for the environmental matrices (soil, groundwater, surface water, plants,
and dependent ecosystems) (WHO, 2006; NRMMC–EPHC–AHMC, 2006) have been also
considered. These guidelines include risks of salinization, eutrophication, toxicity, and soil
structure decline, among others.
4.4.2 Tolerable risk for human health
The definition of a tolerable risk as a health-outcome target is required by the risk
management framework to develop the other health-based targets (performance targets and
water quality targets).
Although the management of health risks is context specific, the WHO guidelines consider
that the overall levels of health protection should be comparable for different water-related
exposures (i.e. drinking water, reclaimed water irrigation of foods).
The WHO Guidelines for Drinking Water Quality (WHO, 2004 and 2011) establish the
tolerable burden of disease (caused by either a chemical or an infectious agent) as an upper
limit of 10–6
Disability Adjusted Life Years (DALYs) per person per year (pppy). This upper
limit DALY is approximately equivalent to a 10−5
excess lifetime risk of cancer (i.e. 1 excess
case of cancer per 100 000 people ingesting drinking-water at the water quality target daily
over a lifetime that is used in the guidelines to determine guideline values for the maximum
concentration of genotoxic carcinogens in drinking water), or an annual diarrhoeal risk of
disease of 10-3
(i.e. one illness per 1000 people or 1 in 10 lifetime risk). These figures
correspond closely to the 70-year lifetime waterborne cancer risk of 10-5
per person accepted
30
by the USEPA (Mara, 2011). The tolerable burden of disease of 10–6
DALYs corresponds
approximately to an infection risk of 10–3
ppy for rotavirus or Cryptosporidium and 10-4
ppy
for Campylobacter (WHO, 2006; Mara, 2008).
In the context of reclaimed water use, since food crops irrigated with reclaimed water,
specially those eaten uncooked, are also expected to be as safe as drinking water by those who
eat them, the WHO Guidelines for the Safe Use of Wastewater, Excreta and Greywater
(WHO, 2006) also recommend the same tolerable level of risk of 10–6
DALYs. The tolerable
risk adopted in the Australian Guidelines for Water Recycling (NRMMC–EPHC–AHMC,
2006) is the same as the one selected by the WHO guidelines (WHO, 2006).
The 10–6
DALYs tolerable risk has been also selected for the Directive (98/83/EC) of water
for human consumption (Drinking Water Directive (DWTD)) that considers as tolerable
health risk a 10−5
excess lifetime risk of cancer, as recommended by the WHO.
The other often referred benchmark level of acceptable risk is the one defined by the USEPA
that considers one infection per 10000 individuals in a given year (≤10−4
pppy) as a
reasonable level of safety for drinking water and also reclaimed water use (USEPA, 1989 and
2012). This number was derived in 1987 by determining the waterborne disease burden
already tolerated in the United States. The USEPA does not use the DALYs metric, and the
tolerable risk of infection selected can be considered similar to the WHO guidelines tolerable
risk, although comparisons are difficult due to the assumptions applied to derive them.
It is important to notice that the current tolerable risk levels of WHO and USEPA guidelines
have been questioned and they have been considered too stringent (Haas, 1996; Mara, 2011).
Haas (1996) has said that it became apparent that some key factors used for computing of the
1:10,000 level of acceptable risk in USEPA guidelines may not be accurate thus considering
that the current benchmark may be far too stringent. The computation of the currently used
risk level from the late 1980s appears to have risen partly because, at that time, the perceived
waterborne disease rate was 1 case per 10,000 people per year. But more recent assessments
show that the actual burden of waterborne disease associated with water treatment practices
appear to be much higher (Haas, 1996; Colford et al., 2006). This would suggest that an
annual risk of infection of 1 in 1,000, or even a less strict risk level, is more appropriate than
the current approach. Mara (2011) states that the current maximal additional burden of
disease (10-6
DALYs pppy) should be lowered to 10-4
DALYs pppy, based on a critical
analysis of the basis from which the current benchmark is derived, the 70-lifetime waterborne
cancer risk of 10−5
per person per year.
Therefore, in view of these considerations, the tolerable risk of 10-6
DALYs pppy used in this
document is considered safe enough to be applied at EU level.
4.4.3 Reference pathogens
Reference pathogens have been selected to be able to determine the performance targets (log10
reductions). It is impractical, and there are insufficient data, to set performance targets for all
waterborne pathogens potentially present in wastewater, particularly since this would require
information on concentrations, dose-response relationships, and disease burdens that is often
not available. A more practical approach is to identify reference pathogens that represent
groups of pathogens taking into account variations in characteristics, behaviours and
31
susceptibilities of each group to different treatment processes. Typically, different reference
pathogens will be identified to represent bacteria, viruses, protozoa and helminths (NRMMC-
EPHC-AMHC, 2006; WHO, 2006; USEPA, 2012). It is to note that controlling reference
pathogens implies controlling all pathogen risks that are covered by the reference pathogen.
The reference pathogens selected are the ones recommended by the WHO guidelines for
water reuse and drinking water, which are Campylobacter for bacteria, rotavirus for viruses
and Cryptosporidium for protozoa (WHO, 2006 and 2011). These are also the reference
pathogens used by the DWD.
Campylobacter compared with other bacterial pathogens, has the infective dose relatively low
and is relatively common, and waterborne outbreaks have been recorded. This selection is in
agreement with the bacterial reference pathogens recommended by Australian guidelines for
water reuse and drinking water (NRMMC–EPHC–AHMC, 2006; NHMRC-NRMMC, 2011).
Rotavirus is used as reference pathogen for pathogenic enteric viruses because they represent
a major risk of viral gastroenteritis, they have a relatively high infectivity compared with
other waterborne viruses and a dose-response model has been established (Havelaar and
Melse, 2003). Adenoviruses have been detected in very high numbers in raw wastewater, and
they appear to be the most resistant to water treatment technologies. Data gathered on
rotavirus, norovirus and adenovirus indicated that prevalence in raw wastewater of these three
viruses could be similar (NRMMC–EPHC–AHMC, 2006). Due to these considerations, the
reference pathogen for pathogenic viruses selected by the Australian guidelines is an amalgam
of rotavirus and adenovirus, using dose-response data for rotavirus and occurrence data for
adenovirus.
Nevertheless, the use of rotavirus has been complicated by the development and use of a
rotavirus vaccine that over time will change the incidence and severity of disease outcomes
from this pathogen (Gibney et al., 2014). On this basis, norovirus seems that it would be
selected instead of rotavirus in the future potable reuse WHO guidelines and the future new
revision of the Australian guidelines as reference pathogen. A dose response model has been
published for norovirus (Teunis et al., 2008) and a disease burden has been determined
(Gibney et al., 2014). However, these risk assessments are not published yet and there is no
evidence that these considerations would change the final log10 reduction requested for
viruses applied by the Australian guidelines.
Cryptosporidium is reasonably infective (Teunis et al., 2002), is resistant to chlorination and
is one of the most important waterborne human pathogens in developed countries (NRMMC–
EPHC–AHMC, 2016). Although Giardia may be another candidate, as it is typically present
in raw wastewater at some 10–100 times the concentration of Cryptosporidium (Yates and
Gerba, 1998), and may be marginally more infective (Rose et al., 1991), it is more readily
removed by treatment processes and is more sensitive to most types of disinfection than
Cryptosporidium (NRMMC–EPHC–AHMC, 2016). Therefore, Cryptosporidium is preferred
as the reference pathogen for protozoa. This selection is also in agreement with the reference
pathogens selected by the Australian guidelines for water reuse and drinking water
(NRMMC–EPHC–AHMC, 2006; NHMRC-NRMMC, 2011).
It has not been selected a reference pathogen for helminths, since helminth infections are not
endemic in EU countries, there is limited information on occurrence in water and there is no
32
human dose-response model. However, for protection of human health, the protozoan
reference pathogen can be used as a reference for helminths. Helminths are likely to be
present in lower numbers than protozoa in sources of reclaimed water, and they will be
removed more readily by physical treatment processes such as filtration and stabilization
ponds as they are larger than protozoa (NRMMC–EPHC–AHMC, 2006).
4.4.4 Performance targets
No risk assessment has been performed specifically for this work, therefore, the performance
targets have been established following the approach used by the Australian guidelines for
water reuse practices (NRMMC–EPHC–AHMC, 2006) to establish performance and water
quality targets. This approach consist on the translation of a tolerable risk level to
performance targets. The Australian guidelines have been selected as the most appropriate
scientific-based document to be used. They apply the tolerable risk of 10-6
DALYs pppy
recommended by the WHO guidelines and considered safe enough for the development of the
minimum quality requirements at EU level, and they also deploy the risk assessment carried
out to derived the performance targets (log10 reductions) for human health risks control.
Although there are some similarities with the log10 reductions defined by the WHO
guidelines, it is considered that assumptions made by Australian guidelines reflect more
accurately the situation in MS, also considering the fact that the WHO guidelines include
assumptions from developing countries in the development of the risk assessment.
Pathogen concentration in raw wastewater can vary over a wide range, Campylobacter
concentration can vary from 102
to 105
cfu/l, rotavirus can also vary from 102
to 105
pfu/l, and
Cryptosporidium may vary between 0 and 104
oocysts/l according to several sources cited in
Australian guidelines (NRMMC–EPHC–AHMC, 2006) which are in line with concentrations
reported in WHO and EPA guidelines (WHO, 2006; EPA, 2012). Due to these variations, 95th
percentiles are therefore used in determining the performance targets. The 95th
percentiles of
organisms per litre in raw wastewater used for the reference pathogens were 7000 for
Campylobacter, 8000 for rotavirus and 2000 for Cryptosporidium. These concentrations are
consistent with international data, according to Australian guidelines. The assumptions made
to apply the risk assessment model (e.g. exposure per event, dose-response constants, ratio of
desease/infection ratios, susceptibility fraction) are further detailed in Appendix 2 of the
Australian guidelines (NRMMC–EPHC–AHMC, 2006).
The log10 reductions established have been calculated considering the worst-case scenario of
the irrigation of lettuce when edible parts are in contact with reclaimed water (i.e. sprinkler
irrigation) and the only barrier to reduce risk to a tolerable level is the wastewater treatment
(secondary treatment, filtration and disinfection). The log10 defined reductions are the
following:
— Campylobacter: 5 log10 reduction
— Rotavirus: 6 log10 reduction
— Cryptosporidum: 5 log10 reduction
These results are consistent with the higher disease risk for viruses relative to other enteric
pathogens generally obtained when a Quantitative Microbial Risk Assessment (QMRA) is
performed for different classes of pathogens (De Keuckelarre et al., 2015).
33
According to the multiple-barrier approach included in the risk management framework, these
log10 reductions can be obtained using several water treatment options alone or in
combination with other non-treatment options (e.g. type of crop to be irrigated, irrigation
method, post-harvest processing).
These log10 reductions are then applied as log10 reductions of the microbiological indicators
selected for each reference pathogen (E. coli, F-specific bacteriophages and Clostridium
perfringens spores) for monitoring purposes. The justification for the selection of these
indicators is in Section 4.4.5.
4.4.5 Microbiological parameters for monitoring
The justification for the microbiological parameters selected for monitoring purposes is
presented below, for each group of microorganisms (bacteria, viruses and protozoa):
Bacteria: Escherichia coli (E. coli) and Legionella spp.
E. coli is the most suitable indicator of faecal contamination, and it is a traditional
bacterial indicator for monitoring purposes in water treatment. Although some guidelines
and regulations utilize thermotolerant (faecal) or total coliforms as bacterial indicators for
agricultural irrigation (WHO, 2006; USEPA, 2012; CDPH, 2014), E. coli is considered
more specific of fecal contamination and reflects better the behaviour of the pathogenic
enteric bacteria (Ashbolt et al., 2001; NRMMC–EPHC–AHMC, 2006). E. coli is the first
organism of choice in monitoring programmes including surveillance of drinking-water
quality (WHO, 2011), as well as the most commonly used bacterial indicator in national
water reuse legislations of MS (JRC, 2014). In addition, E. coli is considered an
appropriate indicator for the presence/absence of Campylobacter in drinking water
systems (WHO, 2016). The ISO guidelines establish that E. coli and thermotolerant
coliforms can be both used for water quality monitoring as the difference in values is not
considered significant (ISO 16075, 2015).
Legionella spp. is selected as bacterial parameter following the ISO recommendations
(ISO 16075, 2015). Legionella pneumophila is a non-conventional opportunistic
waterborne pathogen, as it is not transmitted orally. Transmission is through mechanical
means, which generate aerosols including sprinklers. Legionella pneumophila is on the
USEPA Candidate Contaminant List for drinking water purposes as an important
pathogen. It is commonly encountered in freshwater environments and in wastewater and
there is a potential of growth in distribution systems of reclaimed water in warm climates
where suitable temperatures and conditions for their multiplication may be provided
(Jjemba et al., 2015). No legionellosis outbreak has been linked to reclaimed water yet,
but it is recommended as a reference pathogen for pathogens able to grow in water
distribution systems in the revision of Annex I of the Directive 98/83/EC on the quality of
water intended for human consumption performed by the WHO (WHO, 2016), although
no recommendations for monitoring are made. The ISO guidelines recommend monitoring
of Legionella spp. only for green houses irrigation with risk of aerosolization (ISO 16075,
2015). Legionella spp. is only recommended for monitoring of agricultural irrigation
practices in the Spanish regulations, and only when there is risk of aerosolization.
Viruses: Total coliphages/F-specific coliphages/somatic coliphages
34
Generally, viruses are more resistant to environmental conditions and treatment
technologies, including filtration and disinfection, than bacteria (WHO, 2011). Therefore,
due to the limitations of bacterial indicators, there has been significant research into
determining a viral indicator that may be adopted for water quality monitoring. Two
groups of bacteriophages that infect E. coli, somatic coliphages and F-specific coliphages,
are the major groups that have been used as viral indicators of pathogenic viruses for
many years, as they share many properties with human viruses, notably composition,
morphology, structure and mode of replication (AWPRC, 1991; Armon et Kott, 1996;
Grabow, 2001, Jofre, 2007). Furthermore, regulatory authorities in different parts of the
world are beginning to consider coliphages as viral indicators concerning reclaimed water
(QEPA, 2005; NCDENC, 2011), biosolids used in agriculture (DEC, 2011) and
groundwater (USEPA, 2006).
However, issues such as their potential replication in natural water environments, the
cumbersome detection and enumeration methods, a lack of definition concerning which of
the two groups should be included in future regulations, and the lack of a clear correlation
between coliphages and human viruses and health risks in different water settings remain
controversial. Jofre et al. (2016) is a recent review article that attempts to shed some light
on these contentious issues.
The conclusions of this review article are that: supposing that they can replicate in some
natural water settings, the contribution of coliphages replicated outside the gut will not
affect the numbers contributed by fecal pollution and detected by strains recommended for
standardized methods; there are easy, fast, and cost-effective methods that can be used in
routine laboratories after a little training (Méndez et al., 2002); the low correlation of
coliphages with human viruses and health risks is no worse than the correlation between
different human viruses; perhaps the best option is to determine both groups in a single
step. A general conclusion is that coliphages are likely to be better indicators of viruses
than the current bacterial indicators (i.e. E. coli and enterococci).
In general, somatic coliphages outnumber F-specific coliphages. However, regarding
reclaimed water, F-specific coliphages have been observed to be more resistant than
somatic coliphages to UV radiation, thus F-specific coliphages surpassing numbers of
somatic coliphages. This trend is also observed in clayey sediments, and groundwater
from certain aquifers (Jofre et al., 2016).
Coliphages (i.e. somatic coliphages) are recommended for monitoring of high-exposure
water reuse schemes in the Australian guidelines, and the WHO guidelines stay that, under
certain circumstances, bacteriophages may be included for monitoring to overcome E. coli
limitations as indicator (NRMMC–EPHC–AHMC, 2006; WHO, 2006).
The USEPA guidelines recognize that alternative indicators to E. coli may be adopted in
the future for water quality monitoring (e.g. bacteriophages), but they do not include any
specific viral indicator in their recommendations (USEPA, 2012). However, regarding
indirect potable reuse for surface spreading or direct injection, the USEPA guidelines state
that log10 removal credits for viruses can be based on challenge tests (spiking) or the sum
of log10 removal credits allowed for individual treatment processes, although monitoring
for viruses is not required.
35
California regulations include F-specific bacteriophages as a performance target (99.999%
removal/inactivation from raw wastewater) for food crops irrigation (CDPH, 2014). In
addition, US state regulations of North Carolina adopt coliphages as water quality target
for irrigation of food crops not processed (USEPA, 2012).
MS regulations for agricultural irrigation do not include coliphages, or any viral indicator,
for monitoring, with the exception of the French regulation that includes F-RNA
coliphages as performance target for validation monitoring in agricultural irrigation (JRC,
2014).
Due to the different characteristics and behaviour of F-specific coliphages and somatic
coliphages, it is recommended the use of total coliphages as viral indicators. However, if
this is not feasible, at least one of them must be analyzed.
Protozoa: Clostridium perfringens spores/spore-forming sulfate-reducing bacteria
Giardia cysts and Cryptosporidium oocysts have been found in reclaimed water (Huffman
et al., 2006; USEPA, 2012). This triggered considerable concern regarding the occurrence
and significance of Giardia and Cryptosporidium in water reuse schemes.
E. coli is more readily removed by disinfection methods than protozoa, which are mainly
removed by filtration systems. Protozoa also survive longer than bacteria in groundwater.
Clostridium perfringens spores and spore-forming sulfate-reducing bacteria have been
suggested as indicators of protozoan removal and effectiveness of filtration processes.
Clostridium perfringens spores have an exceptional resistance to disinfection processes
and other unfavourable environmental conditions, its spores are smaller than protozoan
(oo) cysts, and hence more difficult to remove by physical processes (NRMMC–EPHC–
AHMC, 2006; WHO, 2006; WHO, 2011).
Protozoan indicators (i.e. Clostridium perfringens spores) are recommended for
monitoring of high-exposure water reuse schemes in the Australian guidelines, and the
WHO guidelines state that, under certain circumstances, additional indicators to E. coli
may be included for monitoring (NRMMC–EPHC–AHMC, 2006; WHO, 2006). The
DWD and also the draft from the WHO on the revision of Annex I of the DWD include
Clostridium perfringens spores monitoring for treatment control for disinfection-resistant
pathogens such as Cryptosporidium (WHO, 2016).
The USEPA guidelines do not include any specific protozoan indicator in their
recommendations (USEPA, 2012). As regards of aquifer recharge for potable uses
(indirect potable reuse) using surface spreading or direct injection, the USEPA guidelines
state that log10 removal credits for Giardia and Cryptosporidium can be based on
challenge tests (spiking) or the sum of log10 removal credits allowed for individual
treatment processes, although monitoring for these pathogens is not required (USEPA,
2012).
State regulations of North Carolina have specific water quality limits for Clostridium for
non-processed food crops, and Florida requires monitoring of Giardia and
Cryptosporidium for food crops irrigation (USEPA, 2012).
MS regulations for agricultural irrigation do not include protozoan indicator for
monitoring, with the exception of the French regulation that requests monitoring of spores
36
of sulphite-reducing bacteria as performance target for validation in agricultural irrigation,
but this indicator was selected because it was more abundant in wastewater than spores of
Clostridium (JRC, 2014).
It is recommended to use Clostridium perfringens spores as indicator, although spore-
forming sulfate-reducing bacteria may be an alternative if the concentration of
Clostridium perfringens spores does not allow to validate the requested log10 removal.
Helminth eggs, intestinal nematodes specifically, are selected to be monitored when reclaimed
water is used to irrigate crops to feed livestock in order to control animal health risks. These
pathogens are included in Table 2, and the associated justification is shown in Section 4.4.6.
4.4.6 Water quality criteria
The E. coli concentrations to be complied with by the reclaimed water effluent for monitoring
(Table 2) are established considering the concentration of E. coli present in raw wastewater
and the log10 reduction to be achieved by the microbiological indicator, taking into account
the log10 reductions to be achieved by the treatment train and by the type of crop to be
irrigated, and the reduction achieved by applying different irrigation systems and withholding
periods(Table 2). The log10 reductions effectiveness of this barriers is established by several
guidelines (NRMMC–EPHC–AHMC, 2006; WHO, 2006; USEPA, 2012; ISO 16075, 2015).
Class A has been defined to be able to be applied on the highest health risks which consist on
irrigation of crops eaten raw when reclaimed water comes into direct contact with edible parts
of the crop, and irrigation of root crops (WHO, 2006). This worst-case scenario only
considers the treatment technologies in place as a preventive measure (barrier). Thus, the
natural pathogen die-off on crop surfaces that may be from 0.5 to 2 log10 unit reduction per
day (NRMMC–EPHC–AHMC, 2006; WHO, 2006) is not considered, as this reduction
depends on several variables like type of pathogen, climate conditions (i.e. temperature,
sunlight intensity, humidity), time interval, and type of crop.
The reduction of 1 log10 unit that may be achieved when crops are washed with clean water
has not been taken into account to define the water quality targets in this document as this is a
process that cannot be controlled by the responsible managers.
Class B, C and D consider the characteristics of the type of crop to be irrigated as a barrier,
and also the possibility of using irrigation methods that provide exposure reductions, thus
allowing the use of less stringent water quality targets.
The irrigation of pastures and fodder crops with reclaimed water may potentially pose a risk
to the health of both livestock and humans through the consumption of animal products. The
“species barrier” means that many human pathogens, including human enteric viruses, are not
of significant concern for livestock health and, in addition, reduction of bacteria, viruses and
protozoa includes also reduction of pathogens for livestock. However, pathogens like
helminth parasites eggs such as those of Taenia saginata and Taenia solium may be present in
raw wastewater, especially if slaughterhouses wastewater is present in the urban wastewater
treatment plant, although this type of wastewater usually undergoes a treatment before
arriving to a WWTP.
37
A limitation in approaching the livestock health risks associated with reclaimed water is that
virtually no dose-response models are available for infection in animals, therefore, water
quality targets cannot be derived using a QMRA. Therefore, a practical approach has been
proposed following recommendations from the Australian guidelines (NRMMC–EPHC–
AHMC, 2006).
The control of Taenia saginata in reclaimed water that is to be used in contact with livestock
has previously been prescribed through either 25 days of hydraulic retention time in waste
stabilization ponds or equivalent treatment (NHMRC and ARMCANZ, 2000). This has been
effective management of the risk posed by T. saginata. However, there is no guidance on
what constitutes an “equivalent treatment”. Using the empirical model described by Ayres et
al. (1992), relating the percentage removal of helminth eggs with detention time in days, a
mean hydraulic retention time of 25 days is equal to approximately 4 log10 reduction of
helminth eggs. This is the target that alternative treatment processes to stabilization ponds
should meet if Taenia saginata requires specific management. The concentration of helminth
eggs in raw wastewater is in a range of 0 to 104
eggs per litre, therefore a limit values of 1
egg/l is selected to be achieved when reclaimed water is used to irrigate pastures or fodder
crops. This limit value is also recommended by the WHO to protect human health,
considering epidemiological data as there is not sufficient data available to perform a QMRA.
In addition, when health risks for livestock were evaluated in a recent study, using reclaimed
water for irrigation that complied with the WHO recommendations for water quality none of
the animals showed signs of infection or of disease (Bevilacqua et al., 2014). There was also
no evidence to suggest any resulting health risk to humans from the consumption of milk from
animals fed with reclaimed-water-irrigated forage crops.
This limit value is similar to the value recommended by the ISO standards and is in agreement
with the Spanish regulation that includes the same limit values for Taenia saginata and
Taenia solium when milk- or meat-producing animals are to be fed with pastures irrigated
with reclaimed water.
Taenia solium ova can infect pigs, causing cysticercus, which may result in human infection
with the pig tapeworm if undercooked meat is consumed. T. solium infection can cause a
severe neurological disease in humans (neurocysticercosis), therefore it has been
recommended in Australian guidelines a prohibition of use of reclaimed water for pig fodder
due to the severity of the disease, unless there is sufficient data to indicate the risks for a
specific case can be managed (NRMMC–EPHC–AHMC, 2006).
The use of reclaimed water can potentially contaminate milk and pose risk to human health
when used for dairy cattle. Therefore, a withholding period should be implemented for
lactating dairy cattle when pastures are irrigated with reclaimed water (NRMMC–EPHC–
AHMC, 2006).
Dermal exposure to microorganisms is also possible, but there is a lack of evidence of health
impacts through this route and it is considered unlikely to cause significant levels of infection
or illness in the normal population (NRMMC–EPHC–AHMC, 2006). Accidental ingestion of
soil particles by agricultural workers or children is a route of exposure that has been
considered to be under the tolerable risk applying the WHO limit values recommended, thus
38
for a more stringent values the risk should be also defined as tolerable (WHO, 2006; Mara et
al., 2007).
The limit values for E. coli are in line with the values established by the ISO guidelines for
water reuse in irrigation, which are based on the WHO and USEPA guidelines (ISO 16075,
2015). MS regulations present differences regarding the E. coli limit value, and only the
Spanish regulation is similar.
Validation monitoring (Table 5) is required only for the most stringent reclaimed water
quality criteria, Class A, as this class allows irrigation of food crops consumed raw with
edible parts in contact with reclaimed water (using sprinkler irrigation), and without relying
on the pathogen die-off due to time interval between last irrigation and harvesting, which is
the highest exposure risk scenario. The California regulations also include a log10 reduction to
be complied with by F-specific coliphages for irrigation of food crops eaten raw when
reclaimed water comes into contact with edible parts of the crop (CDPH, 2014).
The frequencies for water quality criteria monitoring are based on the monitoring frequencies
for similar quality classes recommended by Australian guidelines and are also in line with the
monitoring frequencies recommended by the ISO guidelines. However, it has to be noted that
the ISO guidelines recommend a range of frequencies, stating that the monitoring programme
should be adapted to local conditions. MS regulations that apply similar requirements have
similar monitoring frequencies (e.g. Spain).
Health outcome targets are based on a defined tolerable burden of disease or level of risk that
is considered acceptable. Disability Adjusted Life Years (DALYs) are a measure of burden of
disease that is used mainly for microbiological hazards. For chemical hazards, the health
outcome target is based on no-observed-adverse-effect levels derived from international
chemical risk assessments. Although the application of DALYs to chemical parameters is
likely to expand, however, unlike pathogens, there are insufficient data to develop DALYs for
most chemical hazards, thus expressing health-based targets for chemical hazards using the
DALYs approach has been limited in practice (WHO, 2011).
Regarding chemical compounds in wastewater, the document considers that wastewater from
UWWTP that comply with the Directive 91/271/EEC. Therefore, wastewater from industries
not included in the UWWTD are not considered. This limits the potential concentration of
toxic chemicals in reclaimed water. The evidence of direct health impacts from chemical
compounds associated with water reuse in agriculture is very limited (WHO, 2006) probably
due to the nature of chemical toxicity. The concentrations of most chemicals in reclaimed
water or reclaimed water irrigated products will almost never be high enough to result in acute
health effects. Chronic health effects that may be associated with exposure to chemicals (e.g.
cancer) usually occur only after many years of exposure and may also result from a variety of
other exposures not related to the agricultural use of reclaimed water (WHO, 2006). The use
of reclaimed water for irrigation may introduce toxic chemical compounds into soils, and
pollutants accumulated in the soils may subsequently be uptaken by crops and pose health
risks to humans and animals. A major health concern is due to metals as they can be found in
any municipal wastewater effluent. Many of them are biologically beneficial in small
quantities but become harmful at high levels of exposure. Plant uptake of heavy metals is
highly dependent on soil conditions. Cobalt, copper, and zinc are not likely to be absorbed by
irrigated crops in sufficient quantities to prove harmful to consumers and are toxic to plants
far before reaching a content that is toxic to humans. However, there WHO guidelines
39
recommend a maximum concentration limit for hexavalent chromium, because it is rapidly
reduced to trivalent chromium, which forms a less soluble solid phase in wastewater or soils.
Cadmium is the metal that causes the largest risk. Its uptake can increase with time,
depending on soil concentration, and is toxic to humans and animals in doses much lower
than those that visibly affect plants (WHO, 2006).
Specific considerations on health risks from compounds of emerging concern (CECs) are
shown in Section 6.
4.4.7 Physico-chemical parameters for monitoring
The justification for the physico-chemical parameters selected for monitoring purposes is
presented below:
Biochemical Oxygen Demand (BOD5): this parameter acts as an indication of
biological treatment effectiveness and indirect potential for bacterial regrowth in
distribution systems. BOD5 can be considered a surrogate for performance related to
pathogen reduction (NRMMC–EPHC–AHMC, 2006).
BOD5 appears in the Australian and USEPA guidelines for agricultural irrigation, as
well as in other guidelines (NRMMC–EPHC–AHMC, 2006; USEPA, 2012; ISO 16075,
2015). Some MS include BOD5 in their water reuse legislations for agricultural
irrigation (Cyprus, Greece and Italy).
Total suspended solids (TSS): this parameter indicates effectiveness of sedimentation
and it is also related with filtration and disinfection efficacy. The removal of suspended
matter is linked to pathogen removal, as many pathogens are particulate-associated, and
both bacteria and viruses can be shielded from disinfectants such as chlorine and UV.
Furthermore, materials in suspension are listed as pollutants which input has to be
limited in Annex VIII of the WFD.
TSS is included in the USEPA guidelines for monitoring of processed food crops and
non-food crops irrigation (USEPA, 2012). The Australian guidelines follow a similar
pattern (NRMMC–EPHC–AHMC, 2006). The ISO guidelines include TSS for
agricultural irrigation monitoring (ISO 16075, 2015).
MS regulations include TSS for agricultural irrigation (JRC, 2014).
Turbidity: it is a traditionally used parameter to indicate filtration effectiveness and
suitability for disinfection, and can be a surrogate for protozoa removal, and viruses.
Turbidity is an important factor both as parameter reflecting the potential of
breakthrough of small particles, including pathogens, and because particulate matter in
water may shield pathogens from disinfectants, rendering disinfection less effective.
Turbidity appears in the USEPA guidelines for food crops eaten raw and aquifer
recharge, similarly to the Australian guidelines (NRMMC–EPHC–AHMC, 2006;
USEPA, 2012). The ISO guidelines include turbidity for irrigation of food crops eaten
raw (ISO 16075, 2015). Turbidity is included in the Greek and Spanish water reuse
legislations for specific categories of use for agricultural irrigation.
Monitoring of these parameters is compulsory in order to control environmental risks to
soils, plants, surface waters and groundwaters associated with reclaimed water use for
agricultural irrigation (e.g. salinity, phytoxicity).
Agronomic parameters are included in all guidelines for water reuse (WHO, 2006;
NRMMC–EPHC–AHMC, 2006; USEPA, 2012; ISO 16075, 2015) and also in water
reuse regulations from MS. The specific agronomic parameters and the associated limit
values comprised in guidelines and regulations are adapted from the recommendations
40
made by the Food and Agriculture Organization of the United Nations (FAO) (FAO,
1985). The FAO recommendations are a worldwide reference document that provides a
guide to making an initial assessment of agronomic parameters for application of
reclaimed water in agriculture. They emphasize the long-term influence of water quality
on crop production, soil properties and farm management.
However, almost all water reuse guidelines and regulations have applied some
modifications to the FAO recommendations due to their basic assumptions and
comments and the number of variables that are site specific when establishing
agronomic parameters and values (e.g. soil characteristics, climate conditions, crop
variety, cultivation practices like the irrigation method and the hydraulic loading).
MS have to specify minimum quality requirements on a case-by-case basis taking into
account site specific conditions, to be complied with by reclaimed water effluent and to
be included for monitoring.
Physico-chemical parameters from related EU Directives, some of them included also in
the FAO guidelines, are to be complied with by the reclaimed water effluent. As regards
MS legislations, the Spanish water reuse legislation states that the use of reclaimed
water for agricultural irrigation must respect the EQSD, and the Italian legislation
includes some organic contaminants for monitoring in reclaimed water. The Greek
regulation for water reuse includes a list of the priority substances from the EQSD, with
some modifications, that has to be complied with for reclaimed water quality for all
categories of use.
According to the qualitative and quantitative environmental risk assessments described in
several guidelines (FAO, 1985; NRMMC–EPHC–AHMC, 2006; WHO, 2006; USEPA, 2012;
ISO 16075, 2015), and the experience gathered by MS on agricultural irrigation with
reclaimed water, there are key environmental hazards associated to environmental risks that
are identified (mostly agronomic adverse impacts), which are salinization, sodicity, toxicity,
and nutrient imbalance.
Salinization of soils irrigated with reclaimed water is one of the most important risks. The
presence of soluble salts in reclaimed water may lead to accumulation of salts in soils
(especially in dry climates), the release of cadmium from soils due to increased chlorine
content, reduced rates of plant growth and productivity, water stress due to plants'
susceptibility to osmotic effects, changes in native vegetation, groundwater salinization
affecting dependent ecosystems, and increased salinity in surface water aquatic systems.
A high proportion of sodium (Na+
) ions relative to calcium (Ca2+
) and magnesium (Mg2+
) ions
in soil or water (sodicity) could degrade soil structure by breaking down clay aggregates,
which makes the soil more erodible, causing surface sealing and preventing the movement of
water (permeability) and air (anoxia) through the soil, thus reducing plant growth.
The effect of specific toxicity of certain ions to plants (e.g. chloride, boron, sodium, and some
trace elements) may lead to reduced crop yields. Some ions may prejudice the microbial
activity of the soil, and aquatic biota. In addition, heavy metals and other toxic compounds
present in reclaimed water can accumulate in soils or/and in crops, and may reach
groundwater or surface water bodies causing their deterioration.
Unbalanced supply of nutrients may result in crop deficiencies and toxicities. Macronutrients
like nitrogen, phosphorus and potassium in reclaimed water may be higher than the needs of
41
the crop, or not supplied at an optimal rate for the crop. Excess of nutrients may lead to
groundwater deterioration, and surface waters eutrophication.
The limit values for BOD5, TSS and turbidity established for Class A are based on the ISO
guidelines as the most stringent class. This is in line with the water reuse guidelines and MS
regulations that apply BOD5 and TSS values usually in the range of the requirements of the
UWWTD, with more stringent requirements only for some uses, like irrigation of food crops
eaten raw (NRMMC-EPHC-AHMC, 2006; USEPA, 2012; JRC, 2014). Frequencies defined
for all classes are based on Australian and ISO guidelines recommendations.
42
5 Management of health and environmental risks for water reuse in aquifer recharge
This section includes the definition of the requirements to manage health and environmental
risks when reclaimed water is used IN aquifer recharge, following a risk management
approach, and the associated justification.
Regarding the source of wastewater to be reclaimed, as a minimum requirement, it has to be
stressed that, as for agricultural irrigation, the Directive 91/271/EEC (UWWTD) that concerns
the collection, treatment and discharge of urban wastewater, establishes quality requirements
that have to be satisfied by discharges from urban wastewater treatment plants (UWWTP)
including also specific requirements for discharges in sensitive areas (Annex I of UWWTD).
Water from wastewater treatment plants destined for reuse is considered a discharge under the
UWWTD at the point where it leaves the water treatment plant (after treatment) (EC, 2016).
Therefore, as the only source of wastewater considered in this document is the wastewater
covered by the UWWTD, all treated wastewater potentially considered for reclamation and
reuse (i.e. wastewater coming from an UWWTP) has to comply, at least, with the quality
requirements specified in the UWWTD Annex I, table 1 and, when applicable, with the
requirements from Annex I, table 2 for sensitive areas.
In order to assure that wastewater that enter a UWWTP is included in the Annex III of the
Directive 91/271/EEC, thus, it is necessary to establish source control programs and oversight
of industrial and commercial discharges to the sewer systems connected to a wastewater
treatment plant.
5.1 Aquifer recharge uses
Aquifer recharge refers, in the present document, to managed aquifer recharge, leaving
incidental aquifer recharge out of the scope of this document.
There is no definition at EU level of managed aquifer recharge (MAR), thus, a common
definition of MAR at EU level is needed. In this regard, the definition considered is the one
included in the Australian Guidelines for Water Recycling: Managed Aquifer Recharge
(NRMMC–EPHC–NHMRC 2009). Managed aquifer recharge (MAR) is defined as the
intentional recharge of water (reclaimed water in this document) to aquifers for subsequent
recovery or environmental benefit.
Although the WFD provides a definition for “aquifer” that applies to this document, the
difficulties in physically delimiting an aquifer, especially in the case of fractured karstic
subsoil should be acknowledged.
The purposes for managed aquifer recharge considered in this document are the following:
— Establish saltwater intrusion barriers in coastal aquifers.
— Provide storage for the recharged water for subsequent retrieval and reuse.
— Maintain groundwater dependent terrestrial and aquatic ecosystems.
— Dilute saline or polluted aquifers.
— Control or prevent ground subsidence.
43
All types of aquifers are contemplated in this document for potentially being recharged with
reclaimed water. This document considers that all freshwater aquifers are potentially
exploitable as potable water source. Furthermore, different aquifers may be connected,
especially in karstic areas. Therefore, the present document doesn't differentiate quality
requirements according to the present or future use of the aquifer but only according to its
present quality and environmental objective under the WFD.
It is to be noted that the present document includes indirect potable reuse as a potential use of
managed aquifer recharge. However, this document does not intend to promote water reuse
for direct drinking water purposes.
All existing recharge methods for managed aquifer recharge are allowed when using
reclaimed water. Recharge methods can be grouped in two main categories: surface spreading
and direct injection (NRMMC-EPHC–NHMRC, 2009; USEPA, 2012; CDPH, 2014). MS
water reuse regulations that include aquifer recharge with reclaimed water apply this
distinction between surface spreading and direct injection (JRC, 2014).
Surface spreading is a method of recharge whereby the water moves from the land surface to
the aquifer by infiltration and percolation through the vadose zone (Regnery et al., 2013).
Direct injection recharge is achieved when water is pumped directly into the groundwater
zone (i.e. saturated zone), usually into a well-confined aquifer (USEPA, 2012).
Article 11.3(j) of the WFD includes a ‘prohibition of direct discharges of pollutants into
groundwater’ as a basic measure. Water reuse schemes, therefore, should be designed so as
not to allow direct discharges of pollutants into groundwater. This prohibition should be seen
as complementary to the above mentioned controls imposed by Article 11.3(f) and the
requirements of Article 6 of the Groundwater Directive. It follows that reuse of treated
wastewater for recharge of aquifers can contribute to the achievement of WFD objectives, as
long as the water is of sufficient quality. It follows that neither the WFD nor the GWD
excludes, in principle, a direct injection of treated wastewater for managed aquifer recharge
which is permitted in accordance with Article 11.3(f) of the WFD.
5.2 Risk management framework for managed aquifer recharge
MS have to apply the elements of a risk management framework described in Section 4.2 to
manage health and environmental risks derived from the use of reclaimed water for managed
aquifer recharge.
The required reclaimed water quality criteria for managed aquifer recharge has to be defined
on a case-by-case basis because it is considered site specific. As stated above, quality
requirements, for managed aquifer recharge are only differentiated, in this document,
according to the existing groundwater quality and the environmental objectives under the
WFD. Therefore, a site-by-site approach is necessary. In addition, due to the range of aquifer
characteristics that come into play, it is difficult to use performance at one aquifer recharge
site to predict performance at another.
Groundwater protection is the overarching aspect when aquifer recharge is performed. In this
regard, the Directive 2006/118/EC amended by Directive 2014/80/EU (Groundwater
Directive (GWD)) complements the WFD and the objective of the GWD is to protect
44
groundwater against pollution and deterioration through the establishment of specific
measures to prevent and control groundwater pollution. MS must assure that the quality of
reclaimed water for managed aquifer recharge does not compromise the objectives of the
GWD and related Directives. MS have to establish, if necessary, minimum quality
requirements for the parameters included in the related EU directives on a case-by-case basis
to be complied with by the reclaimed water effluent and to be included for reclaimed water
criteria in the verification monitoring.
An aquifer characterization has to be performed following the requirements established in the
GWD in accordance with Article 5 of the WFD. Advanced modelling tools are advised to be
used. Guidance documents and technical reports have been produced by the Common
Implementation Strategy (CIS) of the WFD to assist MS to implement the WFD, and some of
them are tools to support aquifer characterisation as they provide guidance on, for instance,
establishing groundwater monitoring programmes for status and trend assessment (EC, 2007a;
EC, 2007b; EC, 2009). Guidance documents are intended to provide an overall
methodological approach, but these will need to be tailored to specific conditions of each
case. Furthermore, the Environmental Impact Assessment Directive (2014/52/EU) (amending
Directive 2011/92/EU) requires that managed aquifer recharge schemes where the annual
volume of water recharged is equivalent to or exceeds 10 million m3
have to undergo an
environmental impact assessment.
Considering the risks from chemical substances, the GWD (Article 6) demands establishment
of measures to prevent or limit inputs of pollutants into groundwater. These measures have to
prevent inputs of any hazardous substances, in particular taking into account hazardous
substances belonging to the families or groups of pollutants referred to in points 1 to 9 of
Annex VIII of the WFD, where these are considered to be hazardous (including priority
hazardous substances of the EQSD). The measures also have to limit inputs of pollutants from
Annex VIII of the WFD which are not considered hazardous and any other non-hazardous
substances not listed in Annex VIII considered to present an existing or potential risk of
pollution, so as to ensure that such inputs do not cause deterioration or significant and
sustained upward trend in the concentration of pollutants in groundwater. According to the
GWD (amended by Directive 2014/80/EU) MS have to establish threshold values for
groundwater pollutants and indicators of pollution on a national, river basin district or other
appropriate level having regard dependent ecosystems and regional or even local conditions.
Besides the parameters of the GWD, additional hazards may also affect groundwater, and
dependent ecosystems according to the potential hazards of the wastewater effluent to be
treated for reuse and site specific conditions. In addition, when surface spreading is used as a
recharge method, MS have to avoid adverse effects to the soil and related dependent
ecosystems where reclaimed water is spread. Therefore, following an environmental risk
assessment, MS have to establish, if necessary, minimum quality requirements for additional
parameters not included in the GWD to be complied with by the reclaimed water effluent and
to be included in the reclaimed water quality criteria in order to avoid adverse effects on
groundwater and soils and related dependent ecosystems.
MS have to implement monitoring programs of the environmental matrices at risk to control
the effect of managed aquifer recharge with reclaimed water irrigation as part of the
45
verification monitoring. A monitoring program has to be established, on a case-by-case basis,
according to the identified risks.
Considering risks from health hazards (i.e. pathogens) these have to be prevented or limited
from entering the aquifer considering the existing groundwater quality following the principle
of no deterioration. No additional treatment has to be applied to the recovered water to
comply with the water quality required for the intended use compare to the groundwater
quality before recharge. Since the indirect potable use is always to be considered, a
Quantitative Microbial Risk Assessment (QMRA) is always needed.
When establishing reclaimed water quality parameters for managed aquifer recharge, it has to
be considered the recharge method. Managed aquifer recharge by surface spreading will
provide added benefits to reclaimed water quality that direct injection is unable to, due to the
natural attenuation capacity of the vadose zone. Surface spreading makes reclaimed water to
pass through the vadose zone (i.e. unsaturated zone), hence allowing mechanisms that may
result in attenuation or degradation of substances and microorganisms content, as filtration,
adsorption, precipitation, volatilisation, biodegradation, and microbial assimilation to take
place (Van Houtte and Verbauwhede, 2008, NRMMC-EPHC–NHMRC, 2009). The GWD
states that processes in the vadose zone that result in attenuation or degradation of substances
may be taken into account when considering measures to prevent or limit input into
groundwater. It also indicates that the natural attenuation capacity of the unsaturated zone
may be taken into account when defining measures for both the preventing and limiting
objective. For limiting even processes taking place in the saturated zone may be considered.
MS must assess the removal capacity of the vadose zone, on a case-by-case basis, in order to
establish less stringent reclaimed water quality requirements for managed aquifer recharge by
surface spreading, if applicable. However, as stated above, the adverse effects on soils and
dependent ecosystems over the time have to be assess.
Removals in aquifers are primarily related to the residence time of the recharge water, the
activity of the indigenous groundwater microorganisms, the redox state of the aquifer, and the
temperature. Residence time in the aquifer induce an attenuation of human pathogens and
selected organic chemicals. MS have to evaluate the variables that may contribute to the
removal of hazards. However, there are considerable challenges in validating and continually
demonstrating the attenuation of pathogens in aquifers. The scientific literature demonstrating
the removal of pathogens in managed aquifer recharge is limited, only a few pathogens have
been studied, and in many cases these are not the worst-case target pathogen (NRMMC-
EPHC–NHMRC, 2009; USEPA, 2012).
Reclaimed water must comply with the quality criteria established by MS at the outlet of the
treatment plant.
Analytical methods used for monitoring shall comply with the requirements included in the
related Directives (i.e. WFD (2000/60/EC), DWD (98/83/EC), GWD (2006/118/EC) to
conform to the quality control principles, including, if relevant, ISO/CEN or national
standardized methods, to ensure the provision of data of an equivalent scientific quality and
comparability.
46
MS may use the Australian guidelines for managed aquifer recharge (NRMMC-EPHC–
NHMRC, 2009) as a guidance to assess and manage environmental risks for managed aquifer
recharge, as the risk management framework is applied in that guidelines.
Following the same approach as for agricultural irrigation, MS have to develop an operational
monitoring protocol to assess and confirm that the performance of preventive measures of the
water reuse system ensures reclaimed water of an appropriate quality to be consistently
provided. Examples of operational monitoring requirements for the preventive measure of
wastewater treatment processes are shown in Table 1 and are described in the Australian
guidelines for managed aquifer recharge (NRMMC-EPHC–NHMRC, 2009).
5.3 Justification for the selected requirements
The case-by case approach selected for managed aquifer recharge quality requirements is
recommended by the Australian guidelines for managed aquifer recharge (NRMMC-EPHC–
NHMRC, 2009), the USEPA guidelines (USEPA, 2012) and the California regulations
(CDPH, 2014). The USEPA guidelines and the California regulations establish specific
quality requirements for indirect potable reuse through managed aquifer recharge, similar to
drinking water quality requirements, as they differentiate between potable and non-potable
aquifers.
The GWD is the EU Directive most directly related to managed aquifer recharge. Considering
the hazards potentially present in wastewater, microbiological and chemical hazards, a risk
assessment is to be performed to assess additional hazards not contemplated in the GWD that
may represent a health or environmental risk. This is also in line with guidelines and
regulations that include managed aquifer recharge with reclaimed water as site specific for
managing risks (NRMMC-EPHC–NHMRC, 2009; USEPA, 2012; CDPH, 2014).
This situation of a highly site-specific framework of boundary conditions to be considered for
aquifers makes it very challenging to establish EU-wide parametric values to be implemented.
47
6 Compounds of emerging concern
This section addresses the subject of the compounds of emerging concern related to the use of
reclaimed water for agricultural irrigation and aquifer recharge.
6.1 Knowledge and gaps
With the advance of analytical techniques a number of chemical compounds, which are not
commonly regulated, have been detected in drinking water, wastewater, or the aquatic
environment, generally at very low levels. This broad and growing group of chemicals is
termed Compounds of Emerging Concern (CECs) (or sometimes in a misleading way
emerging pollutants). The concern is due to either a knowledge gap about the relationship of
the substances' concentrations and possible (eco)toxicological effects – usually due to chronic
exposure, or the lack of understanding how such substances interact as chemical mixture.
CECs are not necessarily new compounds and might have been present in the environment for
a longer time, while their presence and significance are only recognised now. While the Water
Framework Directive addresses the issue through a process of structured prioritization, no
precises relationship is established between the occurrences and levels of CECs in (treated)
wastewater and the acceptable level in the aquatic environment.
CECs include groups of compounds categorized usually by end use (e.g. pharmaceuticals,
non-prescription drugs, personal care products, household chemicals, food additives, flame
retardants, plasticizers, disinfection-by-products, and biocides), by environmental and human
health effects (e.g. hormonally active agents, endocrine disrupting compounds [EDCs]), or by
type of compound (e.g. chemical vs. microbiological, antibiotic resistance gens, phenolic vs.
polycyclic aromatic hydrocarbons), as well as transformation products resulting from various
biotic and abiotic processes, and mixtures of chemicals (WHO, 2011; USEPA, 2012).
It is commonly accepted that today a frequent monitoring for every potential chemical
substance is neither feasible nor plausible. Research is focusing on the development of a
science-based framework to guide the identification of CECs that should be monitored or
otherwise regulated, including the context of reclaimed water use, especially for potable use
(Drewes et al., 2013). A sound selection framework is needed that can provide a short list of
meaningful indicator measurements that can address both human health relevance and
assurance of proper performance of water treatment processes in addition to routine
monitoring for compliance with guidelines and/or regulations.
As presented by Paranychianakis et al. (2014) in a review paper, a few studies have shown
that the uptake, translocation and the accumulation of a wide range of emerging chemicals in
crop tissues is in overall low and does not pose significant risks for public health. Moreover,
plants possess metabolic pathways that might transform and degrade organic pollutants
further decreasing the potential risks.The health risks resulting from the ingestion of food
exposed to 22 chemicals revealed a safety margin greater than 100 for all the substances
identified in the irrigation water, except gemfibrozil. The risks related to the direct use of
pesticides applied to crops appear to be of greater importance. Paranychianakis et al., 2014
continues hence that the concern regarding CECs focuses on potable reuse applications.
Considering the wide diversity of organic chemical structure, some are relatively easy to
attenuate, while others are more recalcitrant (Paranychianakis et al., 2014). Aquifer recharge
through infiltration can be highly effective in the removal of many contaminants, though some
can persist into the underlying groundwater (Laws et al., 2011).
48
While a broad range of publications have investigated the occurrence of CECs, the role of
CECs in agricultural systems is poor, reason for which the Organisation for Economic
Cooperation and Development (OECD) investigated the issue through a high-level expert
team (OECD, 2012). The report carefully assesses the state-of-the-art and identifies and
suggests measures for risk mitigation. It is noteworthy that the report does not identify or
mention the use of treated wastewater for agricultural irrigation as a significant entry
pathway. However, it also states that it is possible that important pathways would have been
overlooked and identifies a list of priority actions to fill knowledge gaps.
Among, these the lack of long-term exposure data to trace organics constrains the accurate
quantification of the health risks (Paranychianakis et al., 2014). The available data show great
temporal and spatial variations in the concentration of organics as a result of the source
concentrations and treatment processes.
It should be noted that the existing data are not sufficient to set ecological limits for most
organics. Critical information is required for many disciplines to obtain a better understanding
of the ecological impacts of water reuse on aquatic organisms of CECs and their mixtures on
biodiversity, biogeochemical cycles of nutrients, ecosystems functions and services, and their
resilience to environmental stressors (Paranychianakis et al., 2014).
Most of the scientific literature regarding the assessment of CECs' uptake by plants is focused
on experiments on plant uptake and bioavailability in artificially amended soils or
contaminated growing media and biosolids (Fatta-Kassinos et al., 2016). The same authors
conclude that the agricultural use of biosolids is a significantly greater reservoir for plant
uptake of CECs than irrigation with treated wastewater.
Prosser and Sibley (2015) carried out an assessment that indicates that the majority of
individual pharmaceuticals and personal care products (PPCPs) in the edible tissue of plants
due to biosolids or manure amendment or wastewater irrigation represent a de minimis risk to
human health. Assuming additivity, the mixture of PPCPs could potentially present a hazard.
Further work needs to be done to assess the risk of the mixture of PPCPs that may be present
in edible tissue of plants grown under these three amendment practices (Prosser and Sibley,
2015).
6.2 Anti-microbial resistances
Among the CECs the issue of antimicrobial resistance (AMR) is of growing concern. AMR
threatens the effective prevention and treatment of an ever-increasing range of infections
caused by bacteria, parasites, viruses and fungi. In 2014, WHO has published a first global
assessment on the current status of surveillance and information on AMR, in particular
antibacterial resistance (ABR), at country level worldwide (WHO, 2014). In a joint report, the
European Food Safety Authority and the European Centre for Disease Prevention and Control
(EFSA and ECDC, 2015) looked into the antimicrobial resistance data on zoonotic and
indicator bacteria in 2013, submitted by 28 EU MS. Resistance in zoonotic Salmonella and
Campylobacter species from humans, animals and food, and resistance in indicator
Escherichia coli and enterococci, as well as data on meticillin-resistant Staphylococcus
aureus, in animals and food were addressed. Although mentioning that the bacterial resistance
to antimicrobials occurring in food-producing animals can spread to people not only via food-
borne routes, but also by routes such as water or environmental contamination (e.g. at
49
slaughter) no further information is provided on the relevance of treated wastewater use as a
possible pathway.
However, the spreading of antibiotic resistance genes (ARG) due to water reuse practices
such as irrigation of crops and landscapes, and augmentation, conservation or restoration of
surface water bodies has being received particular concern in the last years. Since the
discovery of antibiotics and their wide spread use in medicine, stockbreeding and aquaculture,
the occurrence of ARG in the environment has been increasing. Thanner et al. (2016) looked
more specifically into the issue of AMR in agriculture and clearly state that a proper risk
analyses regarding ARB "require comparable data across different biomes: soil, plant,
animal, humans, water". A conclusive risk assessment is currently virtually impossible, a
situation which according to the same authors has created great differences within the
scientific community.
It appears also that more information is required to obtain a clear picture of the risks
associated with water reuse applications. The adoption of (meta)genomic approaches which
provide information on the whole microbial community and not only to the culturable portion
of microorganisms will improve our understanding on the mechanisms responsible for the
induction of ARG, their spreading and how they differ among the different taxa.
On the other hand, no difference in the abundance of ARG among fresh and recycled water
irrigated soils was detected in a study carried out in Israel (Negreanu et al., 2012) suggesting
that the majority of resistant to antibiotics bacteria entering the soils cannot survive. The high
abundance of ARGs in the soil reported often is probably indicative of native antibiotic
resistance associated with the soil microbiome (Negreanu et al., 2012). This argument finds
confirmation in other findings emphasizing the importance of natural environment in
antibiotic resistance (Wellington et al. 2013, Paranychianakis et al., 2014).
Although a great deal of information, amongst others compiled by the COST NEREUS
action, indicate that domestic wastewater is amongst a likely major environmental reservoirs,
the issue of antimicrobial resistance (AMR) has to be addressed in a general context of
wastewater sanitation rather than specifically for reuse schemes. Evidence seems actually to
indicate that a reuse for irrigation leads to a removal of AMR, since most of the resistant
bacteria cannot survive in the receiving soils. A respective minimum requirement for AMR is
hence neither justified, nor feasible to the lack of inconclusive and comparable data.
6.3 Measurements and testing
Although great progress has been made in developing novel tools and approaches to "grasp"
better CECs including AMR through their (eco) toxicological effects, these tools remain at a
pre-market level or have not even reached such a maturity. This vicious circle of "not-being-
measured", "no limit value" and "not-inclusion in legislation" can only be broken by further
targeted research.
The EU Technical Report on aquatic effect-based monitoring tools (EC, 2014b) presents, in
the context of the WFD, a range of effect-based tools (e.g. biomarkers, bioassays) that could
be used in the context of different monitoring programmes, and that might be able to take
account of the presence of several known and unknown compounds with similar effects.
Effect-based tools could be used as a screening and prioritisation tool for subsequent chemical
analysis. Nevertheless, there is still significant uncertainty regarding the role of effect-based
50
tools in a regulatory context and developments in bioanalytical science should be examined to
identify validated bioassay candidates.
Similar considerations apply for AMR/ARG dimension, where the scientific community is far
from having reached a consensus on reference and indicator resistances and a (commercially
viable) way to quantify them.
51
7 Conclusions
Water is a limited resource and hydric stress an increasing challenge at EU and global level.
Linked with growing needs of the population and regionally aggravated by climate change,
water scarcity is fast becoming a concern across the EU. Existing water resources in Europe
are not always managed efficiently. Treated water from urban wastewater treatment plants can
provide a source for a reliable water supply Water reuse needs to be considered as a measure
within the context of the water policy hierarchy.
Although the use of reclaimed water is an accepted practice in several EU countries, the
uptake of water reuse solutions remains limited in comparison with their potential. One of the
main barriers identified is the lack of harmonization in the regulatory framework to manage
health and environmental risks related to water reuse at the EU level, and thus a lack of
confidence in the health and environmental safety of water reuse practices. The development
of minimum quality requirements for water reuse for agricultural irrigation and aquifer
recharge at EU level have the aim of helping to overcome this barrier.
A risk management framework has been selected for the establishment of the minimum
quality requirements. This framework is recommended by the WHO as the most suitable
approach to control health and environmental risks of water reuse practices. The key
principles of the risk management framework are defined and minimum quality requirements
are settled for agricultural irrigation and aquifer recharge. Monitoring recommendations are
also included.
For agricultural irrigation, different crop categories are established, and microbiological and
physico-chemical parameters are selected. According to the multiple barrier approach, and the
health risk assessments developed in international guidelines, specific limit values are defined
according to the tolerable risk (burden of disease) of 10-6
DALYs pppy. Environmental risks
are recommended to be considered on a case-by-case basis taking into consideration site-
specific characteristics. The national regulations and guidelines on water reuse already issued
by some Member States where also taken into consideration.
For aquifer recharge, the Groundwater Directive is the overarching document to be complied
with for groundwater protection. In addition, MS have to apply a risk assessment to control
health and additional environmental risks that may arise from the use of reclaimed water.
It is of paramount importance to develop further guidance on the health and environmental
risk assessment and the establishment of a risk management framework in general.
52
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59
List of abbreviations and definitions
ABR Antibacterial Resistance
AHMC Australian Health Ministers’ Conference
AMR Antimicrobial Resistance
ANZECC Australian and New Zealand Environment and Conservation Council (Note: in
2001, the functions of ARMCANZ and ANZECC were taken up by the
Environment Protection and Heritage Council and the Natural Resource
Management Ministerial Council)
APHA American Public Health Association
Aquifer A subsurface layer or layers of rock or other geological strata of sufficient
porosity and permeability to allow either a significant flow of groundwater or
the abstraction of significant quantities of groundwater (according to Directive
2000/60/EC).
ARG Antibiotic Resistance Genes
ARMCANZ Agricultural and Resource Management Council of Australia and New Zealand
(Note: in 2001, the functions of ARMCANZ and ANZECC were taken up by
the Environment Protection and Heritage Council and the Natural Resource
Management Ministerial Council)
bdl Below Detection Limit
BOD5 5 day Biochemical Oxygen Demand
CAC Codex Alimentarius Commission
CCR California Code of Regulations
CDPH California Department of Public Health
CECs Compounds of Emerging Concern
CEN European Committee for Standardization
cfu colony forming unit
CIS Common Implementation Strategy
COD Chemical Oxygen Demand
COM Communication from the Commission
Critical A prescribed tolerance that distinguishes acceptable from unacceptable
limit performance.
Ct The product of residual disinfectant concentration (C) in milligrams per litre
and the corresponding disinfectant contact time (t) in minutes.
DALYs Disability Adjusted Life Years
DG ENV Directorate General Environment (European Commission)
60
Domestic Wastewater from residential settlements and services which originates
wastewater predominantly from the human metabolism and from household activities
(according to Directive 91/271/EEC).
Dose– The quantitative relationship between the dose of an agent and an effect
response caused by the agent.
DWD Drinking Water Directive
EC European Commission
ECDC European Centre for Disease Prevention and Control
EDC Endocrine Disrupting Compound
EDCs Endocrine Disrupting Compounds
EEA European Environment Agency
EFSA European Food Safety Authority
EPHC Environment Protection and Heritage Council
EQSD Environmental Quality Standards Directive
EU European Union
Exposure The estimation (qualitative or quantitative) of the magnitude, frequency,
assessment duration, route and extent of exposure to one or more contaminated media.
FAO Food and Agriculture Organization
Further Treatment processes, beyond secondary or biological processes, which
treatment further improve effluent quality, such as filtration and disinfection processes.
GWD Groundwater Directive
HACCP Hazard Analysis and Critical Control Points
Hazard A biological, chemical, physical or radiological agent that has the potential to
cause harm to people, animals, crops or plants, other terrestrial biota, aquatic
biota, soils or the general environment.
Hazardous An incident or situation that can lead to the presence of a hazard.
event
Indirect Discharge of reclaimed water directly into a suitable environmental buffer
potable (groundwater or surface water) with the intent of augmenting drinking water
reuse supplies, thus preceding drinking water treatment.
Industrial Any wastewater which is discharged from premises used for carrying on any
wastewater trade or industry, other than domestic wastewater and run-off rain water
(according to Directive 91/271/EEC).
ISO International Organization for Standardization
61
JRC Joint Research Centre (European Commission)
Log10 Used in reference to the physical-chemical treatment of water to remove,
removal kill, or inactivate microorganisms such as bacteria, protozoa and viruses (1
log10 removal = 90% reduction in density of the target organism, 2 log10
removal = 99% reduction, 3 log10 removal = 99.9% reduction, etc).
Managed The intentional recharge of water (reclaimed water in this document) to
aquifer aquifers for subsequent recovery or environmental benefit (according to
recharge NRMMC–EPHC–NHMRC, 2009).
MAR Managed Aquifer Recharge
More Includes treatment beyond secondary treatment processes (N- and/or P
stringent removal) for discharges from urban waste water treatment plants to
treatment sensitive areas which are subject to eutrophication. One or both parameters
may be applied depending on the local situation (according to Directive
91/271/EEC).
MS Member States
NHMRC National Health and Medical Research Council
no Number
NRC National Research Council
NRMMC Natural Resource Management Ministerial Council
NTU Nefelometric Turbidity Unit
NWRI National Water Research Institute of the United States
OECD Organisation for Economic Cooperation and Development
PDT Pressure Decay Test
pfu plaque forming unit
Population The organic biodegradable load having a five-day biochemical oxygen
equivalent demand (BOD5) of 60 g of oxygen per day.
PPCs Pharmaceuticals and personal care products
pppy per person per year
Preventive Any action and activity that can be used to prevent or eliminate a health and
measure environmental hazard, or reduce it to an acceptable level.
Primary Treatment of urban wastewater by a physical and/or chemical process
treatment involving settlement of suspended solids or other processes in which the BOD5
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% (according to Directive 91/271/EEC).
62
QMRA Quantitative Microbial Risk Assessment
Raw Wastewater that has not undergone any treatment, or the wastewater
wastewater entering the first treatment process of a wastewater treatment plant.
Reclaimed Urban wastewater that has been treated to meet specific water quality
water criteria with the intent of being used for a range of purposes. Synonymous with
recycled or reused water.
Risk The likelihood of identified hazards causing harm in a specified timeframe,
including the severity of the consequences.
SAR Sodium Adsorption Ratio
SCHEER Scientific Committee on Health, Environmental and Emerging Risks
Secondary Treatment of urban wastewater by a process generally involving biological
treatment with a secondary settlement or other process in which the requirements
established in Table 1 of Annex I of Directive 91/271/EEC are respected.
SSP Sanitation Safety Planning
Target Performance goals to provide early warning that a critical limit is being
criteria approached.
TOC Total Organic Carbon
TSS Total Suspended Solids
Urban Domestic wastewater or the mixture of domestic wastewater with industrial
wastewater wastewater and/or run-off rain water (according to Directive 91/271/EEC).
USEPA United States Environmental Protection Agency
UV Ultraviolet
UWWTD Urban Wastewater Treatment Directive
Water reuse Use of treated wastewater for beneficial use. Synonymous with water
reclamation and water recycling.
WFD Water Framework Directive
WHO World Health Organization
WSP Water Safety Plans
WWTP Wastewater Treatment Plant
63
List of figures
Figure 1. Decision support tree to identify critical control points in a water reuse system. ... 22
64
List of tables
Table 1. Examples of operational monitoring for several treatment processes....................... 23
Table 2. Reclaimed water quality criteria for agricultural irrigation....................................... 25
Table 3. Classes of reclaimed water quality, and the associated agricultural use and irrigation
method considered.................................................................................................................... 25
Table 4. Minimum frequencies for reclaimed water monitoring for agricultural irrigation.... 26
Table 5. Validation monitoring of the treatment performance for agricultural irrigation....... 27
Table 6. Specific additional preventive measures for health protection to be complied with by
MS for any site specific condition............................................................................................ 28
65
Annex
Informative Annex
The Continuous1
Water Quality Monitoring (CWQM) approach
Research and innovation on continuous physico-chemical and microbiological monitoring is
rapidly advancing, often funded by EU innovation programmes. Nowadays, the water quality
parameters recommended for the verification of reclaimed water can be continuously
monitored for most chemical and physical parameters. Turbidity and TSS are already
available with commercial probes. The continuous monitoring of bacterial indicators, as E.
coli, has been recently demonstrated2
, and BOD5 related monitoring devices are almost ready
to market (applying direct or indirect measurement methods).
Regarding the CWQM technologies for microbiological parameters, there are available
devices with two different approaches: detection and measuring. Detection devices are
suitable for applications where just the simple presence of microorganisms represents an early
warning (drinking water applications, process water for food industry). However, in reclaimed
water use for irrigation and aquifer recharge, concentrations of microorganisms below a
threshold are allowed for some practices. Thus, in several applications, simple detection will
not be suitable if not combined with other measures, and measuring the concentration will be
required.
The traditional approach, based on manual sampling and standardized analytical methods,
defined for verification monitoring provides the results after 1 to 4 days, depending on the
target parameter. Such delay makes the obtained results not suitable for early warning
purposes, neither for process control and optimization (operational monitoring). When
reclaimed water is reused to irrigate crops, it will be distributed and utilized far before
analysis results will be available. In case of a pollution event, the microbial contamination
will have spread along the irrigation infrastructure, and the crops could be not anymore
suitable for the market. The availability of proven CWQM devices, providing the results in
shorter timeframes, will definitely help to close the gap between operational needs and
verification monitoring.
In this sense, the CEN/SABE ENV Team (Environmental Monitoring Strategy Team) is
preparing a Strategic Position Paper on “Standardization needs in continuous water quality
monitoring”, to be delivered by the end of 20173
. The paper analyses the added-value of
CWQM devices, the barriers to their adoption, and the measures to encourage a more rapid
uptake of the innovations, as the ISO/CEN standardization. Additionally in 2014 SABE
adopted a position paper4
on water reuse which identified recommendations on water reuse
and implications for future standardization. However, standardization might become a long
process for potentially excellent CWQM technologies that may find difficulty penetrating the
market.
In order to provide independent verification of the performance of environmental technologies
that cannot be fully assessed through certification or labels, and to improve the penetration of
these technologies into the EU and global markets, the EC launched the EU Environmental
Technologies Verification5
pilot programme (ETV) in December 2011. The ETV is a suitable,
faster and more affordable process to assess performance of CWQM devices compared to the
66
traditional methods and make results available for the whole EU. “This opens up the water
directives for scientifically validated technologies, either lab-based or online, and eliminates
the need to address requirements for monitoring technologies in the directive itself, with the
risk of being outdated shortly after each revision“6
. Summing up, the CWQM sector is fast
moving at the pace of new technologies, therefore whatever standardization or regulation need
to be open enough to do not block ongoing innovation.
67
1
The ‘continuous’ concept refers to real time, but also to semi-continuous or near real time, providing
measurements at a given frequency.
2
http://r3water.eu/wp-content/uploads/2014/04/R3Water-Final-Brochure-2017_online.pdf
3
https://www.cencenelec.eu/News/Brief_News/Pages/TN-2017-006.aspx
4
https://www.cencenelec.eu/news/policy_opinions/PolicyOpinions/ReplyWasteWater2014Nov.pdf
5
https://ec.europa.eu/environment/ecoap/etv_en
6
https://www.eipwater.eu/sites/default/files/AG100%20RTWQM%20water%20legislation_whitepaper_v2_15
0714_def.pdf (Sections 3.3, 3.4 and 4)
With courtesy of EIP Water – Action Group (AG100) Real Time Water Quality Monitoring
(RTWQM).
68
Annex 7a - Non-technical summary of JRC technical report on the development of
minimum quality requirements for water reuse in agricultural irrigation and aquifer
proposed
Overall non-technical summary of the JRC report
The objective of the JRC report is to define at European level common minimum
requirements on water quality, which ensure safety for health and the environment in case that
water is reused for agricultural irrigation or for aquifer recharge. This scientific report from
the JRC defines these technical parameters on water quality which are as a minimum to be
respected in case that treated wastewater is reused for the purposes of agricultural irrigation or
for aquifer recharge. Therefore these criteria on water quality make sure that all agricultural
products in Europe which were irrigated with treated wastewater are safe for health and for
the environment. It does not establish any target for levels or quantity of water to be reused
and it allows Member States to establish more stringent criteria, if they see a need for it.
The only source of treated wastewater considered in this proposal was the urban wastewater
covered by Directive 91/271/EEC (Urban Wastewater Treatment Directive UWWTD) where
urban wastewater is defined as domestic wastewater or the mixture of domestic wastewater
with industrial wastewater and/or run-off rain water. The document does not deal with
reclaimed water from other industrial sources: industrial wastewaters may have very
particular characteristics in relation to quality and they may require specific quality criteria.
For the purposes of developing the proposal, the JRC carried out as a first step a review of the
available scientific, technical and legal knowledge on water reuse in agricultural irrigation and
aquifer recharge. The documents that have been the basis to establish the proposal for
minimum quality requirements included:
 the regulatory framework at EU level on health and environmental protection;
 the MS water reuse legislations and guidelines in place, along with their experience in
water reuse systems;
 world-wide reference guidelines and regulations on water reuse;
 additional scientific references considered relevant for the topic.
During the development of the proposal a tiered approach for consultation was applied by the
JRC. In the first tier, the JRC asked a group of selected experts from academia, the water
sector and WHO to provide input and comment on the drafting work. In a second tier,
Member States were formally informed through the Ad-hoc Group on Water Reuse, where
JRC presented a three occasions the respective versions. Comments received in writing from
the MS were documented and replies from JRC were disseminated. In addition, the JRC
presented at several public events as well as scientific meetings the progress of work. These
presentations included amongst others the Water Group of the European Parliament, the EIP
Water Action Group on Water Reuse, 11th
IWA International Conference on Water
Reclamation and Reuse as well as the COST NEREUS Action on New and Emerging
Challenges and Opportunities in Wastewater Reuse.
Considering the sensitivity of the health and environmental issue and public confidence in
water reuse practice, in the third tier, the scientific opinions of the independent Scientific
Committee on Health, Environmental and Emerging Risks (SCHEER) and the European Food
Safety Authority (EFSA) have been requested and taken into consideration in the finalisation
of the document or if not, a justification has been provided.
69
The experts, whose contributions are gratefully acknowledged, have been consulted to
provide comments and input through critical discussion on the document along the process.
However, the content of this document has not been endorsed by these experts and reflects
only the scientific opinion of the JRC. It is important to note that no risk assessment
specifically for the establishment of the minimum quality requirements has been performed
and the JRC bases its proposal on the validity of the risk assessment conducted by the
reference documents taken into consideration.
The approach to develop minimum quality requirements for the safe use of reclaimed water
for agricultural irrigation and aquifer recharge is a risk management framework, as
recommended by the World Health Organization WHO (2006) and included in the Directive
2015/1787 that amends Directive 98/83/EC on the quality of water intended for human
consumption.
A risk management framework is a systematic management tool that consistently ensures the
safety and acceptability of water reuse practices. A central feature is that it is sufficiently
flexible to be applied to all types of water reuse systems, irrespective of size and complexity.
The risk management framework proposed by the JRC in conjunction with specific numerical
values for some water quality parameters, incorporates several interrelated elements, each of
which supports the effectiveness of the others. Because most problems associated with
reclaimed water schemes are attributable to a combination of factors, these factors need to be
addressed together to ensure a safe and sustainable supply of reclaimed water.
In EU Member States, the most comprehensive water reuse regulations and recommendations
issued by MS (i.e. Cyprus, France, Greece, Italy, Portugal, Spain) (DM, 2003; NP, 2005; RD,
2007; CMD, 2011; JORF, 2014; KDP, 2015) are based on the referenced guidelines and
regulations cited above, all of them including several modifications for some uses.
Justification of the stringency of the quality criteria
The assumed tolerable health risk for the proposed quality criteria is based on the WHO
Guidelines for Drinking Water Quality (WHO, 2004 and 2011), which establishes the
tolerable burden of disease (caused by either a chemical or an infectious agent) as an upper
limit of 10–6
Disability Adjusted Life Years (DALYs) per person per year. Although the
management of health risks is context specific, the WHO guidelines consider that the overall
levels of health protection should be comparable for different water-related exposures (i.e.
drinking water, reclaimed water irrigation of foods).
In the context of reclaimed water use, since food crops irrigated with reclaimed water,
especially those eaten uncooked, are also expected to be as safe as drinking water by those
who eat them, the same tolerable level of risk of 10–6
DALYs is proposed by the WHO
Guidelines for the Safe Use of Wastewater, Excreta and Greywater (WHO, 2006). It is
noteworthy that the analogue tolerable risk has been also applied under the Directive
(98/83/EC) of water for human consumption (Drinking Water Directive (DWD)).
Justification of exclusion of compounds of emerging concern
With the advance of analytical techniques a growing number of chemical compounds, which
are not commonly regulated, have been detected in drinking water, wastewater, or the aquatic
environment, generally at very low levels. This broad group of chemicals is termed
Compounds of Emerging Concern (CECs). The concern is due to either a knowledge gap
about the relationship of the substances' concentrations and possible (eco)toxicological effects
70
– usually due to chronic exposure, or the lack of understanding how such substances interact
as chemical mixture. CECs are not necessarily new compounds and might have been present
in the environment for a longer time, while their presence and significance are only
recognised now. At EU-level, currently there is no precise relationship between the
occurrences and levels of CECs in (treated) wastewater and the acceptable level in the aquatic
environment. It is also commonly accepted that today a frequent monitoring for every
potential chemical substance is neither feasible nor plausible.
In general, most of the few studies available have shown that the uptake, translocation and the
accumulation of a wide range of emerging chemicals in crop tissues is overall low and does
not pose significant risks for public health. The risks related to the direct use of pesticides
applied to crops appear to be of greater importance. While a broad range of publications have
investigated the occurrence of CECs, the role of CECs in agricultural systems is poorly
investigated, reason for which OECD investigated the issue through a high-level expert team
(OECD 2012). The report carefully assessed the state-of-the-art and identified measures for
risk mitigation. The report did not identify or mention the use of treated wastewater for
agricultural irrigation as a significant entry pathway. The same study concluded that the
agricultural use of biosolids such as treated or untreated manure from pig, poultry or cattle is a
significantly greater reservoir for plant uptake of CECs than irrigation with treated
wastewater.
Although a great deal of information indicate that domestic wastewater is amongst a likely
major environmental reservoirs for antimicrobial resistance (AMR), but it was concluded that
this has to be addressed in a more general context of wastewater sanitation rather than
specifically for reuse schemes. This is underpinned by evidence indicating that water reuse for
irrigation leads to a removal of AMR, since most of the resistant bacteria cannot survive in the
receiving soils.
It was therefore concluded that specific limits for CECs would create at present an unjustified
burden of control. However, the evolution and improvement of the current knowledge base,
both regarding the effects of CECs, but also regarding the introduction of novel measurement
techniques grasping better the chemical reality stemming from a mixture of chemicals, e.g.
through the use of novel bioanalytical techniques require to be monitored regularly as to be
able to take account of scientific developments.
Sensitivity analysis
The scope of the sensitive analysis is to ensure whether a higher or lower value for a selected
parameter leads actually to a change of the result. The proposed minimum requirements rely
on a series of key parameters commonly used to define the quality of wastewater before and
after various treatments. The selected key parameters must hence ensure that a.) together they
cover the risk framework and b.) they are as stringent as necessary, but not more.
The quality requirements considered have been established following a risk management
approach. Although no specific risk assessment with European data was performed the
selection of the minimum quality requirements is related to existing water reuse guidelines
and MS regulations, and on the health and environmental risks considered by those.
Besides a series of recommendations, the minimum quality requirements provide specific
limit values for E. coli (as an microbiological indicator), biological oxygen demand (a
surrogate for the degree of organic pollution), total suspended solids (TSS) and turbidity (both
describing efficiency of water filtration applied). These parameters are commonly used to
71
describe the degree of cleanness of treated wastewater after a primary and secondary
treatment and are commonly used in national regulations and guidelines.
For E.coli, the parametric values for the best reclaimed water quality on food crops consumed
raw set in Cyprus, France, Greece, Italy and Spain range from ≤5 cfu/100 ml to ≤250 cfu/100
ml. The proposed minimum requirement of ≤10 cfu/100 ml is hence in line with existing
national standards, while aiming at a EU high quality for this most critical application of food
crops consumed raw.
For TSS a minimum quality criterion of ≤10 mg/l is proposed, which is in line with levels
already established in Cyprus, Greece and Italy and slightly more stringent than the limits
established in France (≤15 mg/l), Portugal (≤60 mg/l) and Spain (≤20 mg/l).
For the complementary parameter of turbidity only Greece and Spain have established
thresholds, which are in line with the proposed minimum of 5 NTU.
The proposed subsequent reclaimed water quality classes are then in line with the
requirements stemming from the Urban Wastewater Treatment Directive for TSS, BOD and
turbidity and follow a logarithmic scale for E. coli.
These universal parameters are in line with those thresholds implemented already in some
countries with a proven water reuse experience, but are sufficiently high to aim at an overall
necessary standard at EU level. The level of stringency can hence be seen as appropriate and
as protective if the respective risk management framework is applied properly.
72
Annex 8 - Assessment of impacts on Research and Innovation
DG RTD Initiative on Integration of the Innovation Principle
into New EU Policy Initiatives:
Application of R&I Tool for Better Regulation
Report from the Workshop
on "Water Reuse and Research and Innovation"
31 May 2017
1. INTRODUCTION
The European Commission is preparing a new legislative instrument on minimum quality
requirements for water reuse in agricultural irrigation and aquifer recharge. This is one of
several policy measures to stimulate reuse of reclaimed water in water management, industry,
agriculture and municipal sectors1
. Water reuse is an integral element of EU Circular
Economy, Water and Climate Change Adaptation policies as it can help protect natural
resources, bring economic savings and alleviate water scarcity problems.
In the context of the Better Regulation policy of the European Commission the Directorate-
General for Research and Innovation (DG RTD) intends to scrutinise all new policy proposals
for their impact on innovation. To this end it developed the R&I Tool for Better regulation – a
guidance on how to assess the impact on innovation and how to improve legislative proposals
so the potential impact on innovation is positive rather than negative.
This report is the result of the application of the R&I Tool to the new policy initiative on
water reuse in the impact assessment phase. The objective is to extend the usual assessment of
economic, social and environmental impacts to include the impact on innovation. It is
expected that this will contribute to the sound selection of preferred policy options and
provide recommendations on how the policy should be formulated so that it will not hamper
innovation but rather stimulate innovation as much as possible.
It should be noted that this application of the R&I tool is the first pilot application and thus a
learning exercise both for DG RTD and the lead service (in this case DG ENV). The
methodological approach includes a wider scope of policy options than the options assessed in
the Impact Assessment report as the exact options to be included in the impact assessment
were not yet defined when the methodology was decided. Moreover, DG RTD intended to test
the R&I Tool on a wider range of generic policy options and obtain experience on how
practical and useful the R&I tool is.
1
For more information on water reuse policy initiative please see the document “Closing the loop - An EU action plan for the
Circular Economy”, COM/2015/0614
73
Once the lead service develops a legislative draft this report may be followed by
recommendations on legislative techniques that can make the legislative proposal more
innovation friendly.
2. PROCESS
The methodology for this assessment is based on the application of the R&I Tool for Better
Regulation and, in particular, of the set of questions on different aspects of innovation
included in the Tool. These questions were presented to experts in the water reuse field to
gather their expert opinion, compile and organise it with the aim to provide as an assessment
of innovation friendliness as comprehensive as possible.
In order to obtain expert opinions in the short time period available for this exercise, DG RTD
organised a workshop with water reuse experts on 31 May 2017. The invited experts were
selected from the projects financed by the EU Framework Programme for Research and
Innovation (these include both ongoing projects financed by the Horizon 2020 as well as
finished projects financed from the 6th
and 7th
Framework programmes). Thirteen experts
accepted the invitation and took part in the workshop.
The experts have provided their opinions both orally during the workshop and through written
input after the workshop. The input received from the experts has been compiled and
transformed into this report. The draft report was sent back to experts to verify that it
accurately represents their opinion.
Policy options that have been assessed
When the methods of this assessment were developed and the workshop was organised, the
options as they are formulated in the Impact Assessment report were not yet known.
Therefore, the options discussed at the workshop were a combination of generic options that
are applicable for all EU policy initiatives and specific options corresponding to possible
elements of policy as identified by preparatory studies (e.g. in the Initial Impact Assessment
and the JRC study) and discussed in the Impact Assessment Steering Group meetings. It can
be concluded that the main options assessed below correspond to the main options of the
Impact Assessment Report. These options included:
 mandatory measures, i.e. Member States are obliged to comply with the legal
requirements stipulated in the law; or
 voluntary measures, i.e. Member States are advised or incentivised to implement certain
measures but are not strictly obliged to do so. They usually take the form of EU
recommendations, guidance or communications.
Specific options:
1. Targets for Member States, e.g. what proportion of treated waste water should be
reclaimed for further reuse;
2. Measures to prevent trade barriers (harmonization of rules or mutual recognition of
national rules);
74
3. Limit values for control of hazardous substances in the reclaimed water for reuse.
These can be set to protect either public health, e.g. microbiological pathogens or
hazardous substances that may enter food chain, or prevent environmental damage, e.g.
overload of nutrients that may cause eutrophication of surface water bodies, degradation
of soil or pollution by hazardous substances that have negative impact on terrestrial and
aquatic ecosystems.
4. Measures to address public health risks by the application of risk management systems
(public health risk management requirements);
5. Measures to address environmental risks by risk management systems (environmental
risk management requirements);
6. Governance and economic aspects, i.e. who is responsible for delivery of the
requirements and who pays for what and how much;
7. Technology, e.g. is any particular technology or technique required (explicitly or
implicitly).
At the workshop the above specific options were discussed first and experts selected the most
relevant ones. As the result the workshop focused mainly on options 3, 4 and 5 and the links
among them. Option 1 was immediately eliminated as not acceptable at the EU level and
option 2 was included as an overarching component of options 3 and 4. Options 6 and 7 have
been also assessed but were commented by experts.
An analysis of the impact on innovation of these options is presented below.
3. ANALYSIS ON THE IMPACT TO RESEARCH AND INNOVATION
3.1. Option – EU Minimum quality requirements (limit values) + additional MS
requirements
3.1.1 Voluntary EU minimum quality requirements (limit values set for selected water
quality parameters) reflect the current fragmented situation in the EU. They will not drive or
stimulate innovation that would have EU-wide impacts.
Voluntary minimum requirements will lead to:
 Fragmentation of the setting of parameters and their limit values among different
countries;
 A water reuse market governed by local drivers and local initiatives of end-users;
 Specialised, almost tailor-made local technological products that are not seen as replicable
elsewhere;
 Different technological products for every different application;
 Different quality limit values that will create difficulties to compare research results and
innovative solutions. It will create obstacles for data bases structures;
 Disintegration and sectionalisation of R&D infrastructures;
 A limited pool of choices and R&D investment opportunities;
 Less efficiency, efficacy and competitiveness of the industry;
 Possibly negative cooperation between public and corporate R&D; and
 Less cooperation for innovative solutions and EU-wide incentives to facilitate and
enhance water reuse.
75
Voluntary limit requirements may be accompanied with the EU guidance but the experts were
not convinced that it could have an added value for R&I. For example, the updated voluntary
WHO water reuse guidance introduced in 2006 did not stimulate any development of new
water reuse projects in the EU.
3.1.2 Mandatory EU minimum quality requirements (limit values)
Mandatory EU minimum quality requirements are seen as innovation-friendly if certain
conditions, such as the balanced scope of water quality parameters and stringency of limit
values, are met:
 This policy option can stimulate and drive R&I in technologies and solutions that will
help to reach the limit values of defined parameters. They will boost R&I at all phases
driven by the needs to demonstrate technical performance, efficiency and reliability of
conventional and new technologies (filtration, disinfection, membranes, advanced
oxidation, etc.), economic viability of water reuse projects, and social and environmental
benefits.
 New and innovative ways of monitoring will be stimulated, in particular online
(continuous) monitoring, development of new microbiological and chemical indicators.
New analytical methods will be developed for instance for pathogens (based on RNA-
ribonucleic acid analysis) or effect based analysis for chemicals (bioassays). Setting
standards for online monitoring techniques will produce an incentive to bring more R&D
results to the market.
 Minimum quality requirements will establish a stable market and speed up application of
innovative solutions and exploiting existing results;
 The harmonization of quality requirements (parameters and limit values) and procedures
will provide innovative companies the opportunity to scale up.
 This option will reduce compliance costs and time for the development of innovative
technologies/solutions due to the need to meet the challenges within the deadlines set by
the legislation.
 It will positively affect cooperation between public and corporate R&D throughout
Europe. Large demonstration projects applying results of public and private research will
be necessary to validate water reuse schemes’ performances;
 It will also stimulate social innovation, better cooperation between stakeholders,
multidisciplinary research, improved public education, integrated and holistic approach to
water resource management, sustainable development and the application of the circular
economy concept in the water sector.
Experts supported these impacts by the following comments:
The above-mentioned positive impacts will only realise if a balanced scope of parameters and
appropriate stringency of limit values is found. If too many parameters and very stringent
limit values become obligatory this can discourage application of water reuse and the driving
effect for innovation would disappear. If these are too low and easy to achieve with the
conventional technology it will not provide additional drivers for innovation compared to the
current situation. On setting the balanced scope of parameters and stringency of limit values
the following comments were made:
76
 The balanced scope of parameters related to health concerns could be based on FAO
recommendations and the recent DG SANTE guidance document2
(the guidance
document to support the implementation of Regulation 852/2004). Parameters of
environmental concern should be identified on a case by case basis and adopted at local
level for the local water reuse schemes in specific local environmental conditions related
to soil and local water bodies.
 The experts expect that the majority of new water reuse projects will start at local level as
at small scale – on average 500-3000 m3/day – and end-users and local municipalities will
not be able to afford excessively expensive and complex technology and monitoring
systems.
 On the other hand the monitoring requirements should be based on advanced scientific
knowledge. Traditional monitoring frequencies (once per week or per month) are
hampering the development and application of new smart sampling strategies and thus
new innovative solutions3
while preventing the application of innovative online
monitoring technologies. At the same time the traditional monitoring based on low
frequency sampling and limited laboratory analysis is not sufficient to ensure a high level
of health protection and provide public confidence in reuse practices. Also, a European
Innovation Partnership for Water Action Group RTWQM4
survey concluded that the
current standard water sampling strategies not properly representing the real status of the
water bodies and the efficacy of treatment processes5
.
 Quality requirements for additional parameters should be left at the discretion of each MS
or regional and local authorities to allow for the consideration of local conditions.
Additional prevention measures, such as those recommended by WHO guidelines and in
the ISO 16075 standard, could be included, for water categories with lower quality
depending on health risks on a case to case basis as part of a risk management plan.
Actions recommended:
The positive effects stated above will only be achieved if the legislative proposal succeeds in
setting a balanced scope of water quality parameters and the appropriate stringency of limit
values. Experts suggested that the parameters and limit values should be reviewed on a
periodic basis according to the challenges and the development of the scientific knowledge.
3.2. OPTION – MEASURES TO ADDRESS REAL OR PERCEIVED PUBLIC
HEALTH RISKS (RISK MANAGEMENT REQUIREMENTS)
The experts concluded that in general, the promotion of the risk management approach
(whether mandatory or voluntary at EU level but assuming that risk management will be
required at national, regional or local level) will have a positive impact on innovation:
 The application of a health risk management at any scale will facilitate the introduction of
future innovative solutions to address the risks identified. These solutions will be cost-
2
SANTE/10470/2016 – Guidance Document on Addressing microbiological risks in fresh fruits and vegetables
at primary production through good hygiene
3
Example: see AQUABIO and AQUATRACK in http://r3water.eu/techniques-for-reuse-of-water/
4
EIP Water AG 100 – Real Time Water Quality Monitoring
5
https://www.eip-water.eu/sites/default/files/AG100%20RTWQM%20WaterReuse-ConceptNote-v2.pdf
77
effective as they reduce the need for monitoring and avoid unnecessary or inefficient
measures.
 Health risk management naturally stimulates multi-disciplinary scientific research and
brings together specialists in microbiology, chemistry, ecology, IT and other areas.
The main difference between the voluntary and mandatory approach at EU level is in the scale
of application of new solutions with all implications on economy of scale, sharing of data and
knowledge, building of research infrastructure and collaboration between different actors.
3.2.1 Risk management approach addressing health issues (RMA-H) – voluntary
measures:
Voluntary RMA-H measures have a very limited potential to drive innovation.
 This option will result in fragmented local applications of different risk management
systems and will not drive the generation of new RMA-H ideas at EU level.
 The cooperation on R&I will be limited only to the areas where the same risk management
requirements exist.
 These measures will lead to the fragmentation of information and knowledge, to localised
data and consequently to small-scale innovation development, applicable only for a
certain area.
 It will negatively affect the incentives for companies to scale up in Europe due to the
limited area of application of RMA at local level.
 The overall compliance costs and time for the development of innovative RMA-H
solutions will increase.
However, experts pointed out that despite the fragmented and localised development of
innovation in the case of voluntary approach (assuming the RMA is promoted at MS or
regional level) there may be a positive impact on innovation:
 RMA-H application at any scale will facilitate the introduction of future innovative
solutions to address the risks identified and these solutions can be cost effective as they
reduce the need for monitoring and unnecessary of inefficient measures.
 RMA-H naturally stimulate multi-disciplinary scientific research and bring together
specialists in microbiology, chemistry, ecology, IT and other areas.
3.2.2 Risk management approach addressing health issues (RMA-H) – mandatory
measures:
Mandatory RMA-H measures will have a positive impact on the development and scale-up of
innovative approaches to health risk management and solutions to address the risks related to
water reuse. They will:
78
 Facilitate the realisation of the methodology for the development of Water Safety Plans
for each water reuse scheme, e.g. as already demonstrated by the DEMOWARE project6
;
 Ensure a strong cooperation and a substantial participation of industrial partners and end-
users, enhancing public and corporate R&D to develop leading-edge EU innovative health
risk management tools;
 Stimulate multidisciplinary scientific research, such as ecotoxicology, chemistry,
microbiology, parasitology, and develop a holistic approach to water reuse risks;
 Positively affect innovation dynamics of specific markets such as those for treatment
technologies, monitoring equipment, analytical techniques for identification and detection
of relevant pollutants;
 Facilitate spreading knowledge and information leading to well-informed stakeholders
which are able to make sound decisions. It is expected that risk management measures
will be better implemented and more effective. The cost of risk management systems, and
of risk prevention measures and technologies, will be reduced due to the efficiencies
related to the scale. Also administrative costs can be reduced due to harmonisation and
standardisation of RMA procedures;
 Enhance the development of more robust and less risky technologies that will be further
promoted by regularly evaluating the risks of water reuse;
 Facilitate the adaptation of R+D infrastructures to the new approach;
 Produce great potential for companies to scale up, and to apply large business models
which will ensure the successful commercialization of the systems developed. At the same
time it will create markets for highly specialized SMEs;
 The dynamic and repetitive character of RMA will allow introducing new findings and
innovations in the successive revisions of the Water Safety Plans for the specific water
reuse schema in a more dynamic way.
However, a mandatory RMA-H may also:
 Create administrative burdens and increase costs related to initial testing, piloting or
demonstrating RMA-H approach;
Experts pointed out that the positive effects above will materialize only if the mandatory
requirements for RMA are sensible and balanced and do not entail high costs. Setting these
requirements will also include the decision whether qualitative or quantitative methods of
RMA will be promoted. Some experts were of the opinion that the RMA should be based on
the qualitative approach such as the WHO Water Reuse Safety Plans. The EU regulation
could stimulate the development of a methodology how such plans should be constructed and
applied including practical tools. According to these experts the quantitative microbial or
chemical risk assessment is neither applicable nor affordable for each water reuse project and
is characterised by a number of important disadvantages such as the lack of scientific
evidence and consensus on the assumptions on the choice of representative pathogens, its
infection dose, vulnerability of the population, etc.
6
http://demoware.eu/en/results/deliverables. Deliverables D3.1 - "Appropriate and user friendly methodologies
for RA_LCA_WFP" and D3.2 – "Show case of the environmental benefits and risk assessment of reuse
schemes", are of a special interest.
79
Actions recommended:
The positive effects described above will again depend on a proper definition of the RMA
requirements (e.g. RMA methodology). An assessment of feasibility and costs of the preferred
methodologies should be performed to ensure that the requirements do not hamper the
application of the RMA. The legislation should be dynamic and reflect R&D progress while
taking into consideration future assessments.
3.3. OPTION – MEASURES TO ADDRESS REAL OR PERCEIVED
ENVIRONMENTAL RISKS (RISK MANAGEMENT REQUIREMENTS)
The application of environmental risk management in relation to water reuse, both on
voluntary and mandatory basis, will stimulate multi-disciplinary scientific research reacting to
the need to assess environmental pressures (on receiving water bodies and soil) and the
vulnerability of ecosystems, to set requirements for quality of reclaimed water and
monitoring, and define mitigation measures.
The optimal way to manage the environmental risks related to water reuse will very much
depend on the local conditions, including hydrological regime and characteristics of local
water bodies, soil composition, climate, local ecosystems, etc. It is therefore difficult to define
the best risk management approach that would be equally effective at all locations across
Europe. A mandatory system to manage environmental risks of water reuse can only be
prescribed in general terms with a lot of discretion for action at local level. Therefore the
mandatory and voluntary approaches may not differ significantly under the assumption that
the voluntary approach will mean that national, regional or local authorities will mandate or
effectively promote risk management at local level.
3.3.1 Risk management approach addressing environmental protection (RMA-E) –
voluntary measures:
The voluntary RMA-E corresponds to a large extent to the current situation and therefore the
impact on innovation and research is limited.
Nevertheless, RMA-E voluntary measures would have an impact on the generation of new
ideas and their adaptation and application, because:
 The relation between wastewater treatment, disposal and reuse would arise and require
new ways to manage waste and reclaimed water disposal;
 There will be a need to share knowledge in order to develop and apply risk management
tools;
 The basic knowledge will likely be generated in public research institutions, while
practical application tends to be performed at the corporate actors.
 Risk management approaches create new objectives and lead to new ways in the
establishing of R&D infrastructures for water reuse.
 If properly performed, innovation in RMA-E field would reduce costs (less analysis,
fewer costly mistakes) and save time.
However, voluntary RMA-E
80
 May lead to small and scattered areas of different standard application and may present
obstacles for any pertinent development;
 Will not create incentives for companies to scale up in Europe, due to limited area of
application, since these differences in requirements may lead to unacceptable costs;
 May limit cooperation only to the areas where the same standards exist. In other areas
different needs call for different solutions and thus localise again the circulation of data
and ideas;
 May produce higher costs due to local specialised RMA-E approaches and focus on
particular technologies and measures.
 The voluntary approach will likely not lead to improving the capacity of small private
users of reclaimed waters (e.g. farmers) to apply risk management in their operations. It
will only be larger companies and public bodies who will have the capacity to develop and
properly apply environmental risk management.
3.3.2 Risk management approach addressing environmental protection – mandatory
measures:
Mandatory RMA-E will enhance R&I:
 It will drive the generation of new risk assessment solutions, their adaptation and
application and it will boost the industrial base;
 It will enhance the R&D of more robust technologies and will be greatly promoted
together with the evaluation of the acceptability of reuse and recycling options to end-
users.
 It will develop capacity and methods for assessing, mapping and valuing multiple water
reuse and recycling technologies, across space and time for informed integrated
management
 It prevents both over- and under-engineering solutions;
 It will ensure a substantial participation of industrial partners and end-users, enhancing
public and corporate R&D;
 It will affect the application of innovation dynamics of specific water reuse market
fostering innovative solutions in the area of monitoring, new analytical techniques, and
bioassays at the same time coinciding with the advancement of new technologies for water
treatment for reuse.
 Via multi-disciplinary scientific research it will stimulate social equity, economic
efficiency, and environmental integrity.
 It will contribute to the thriving EU economic water reuse sector producing a great
potential for the companies to scale up applying large-scale business models which will
ensure the successful commercialisation;
 A unified regulatory environment having similarly assessed the risks and opportunities
across Europe will then correspondingly boost R&D investments and could help maintain
the leading position of the EU in the field of research on emerging substances and
bioassays.
81
 Across Europe, it will result in lowered costs for risk assessment and for risk mitigation
measures.
However, if the mandatory RMA-E is too complicated it could:
 Make the implementation more expensive and slow down the development of innovative
technologies and solutions of water reuse schemes; and
 Increase administrative burden.
Actions recommended:
Again, positive effects will only be achieved if the measures proposed will be defined in a
balanced and adequate way in order to avoid excessive administrative burden or costs. The
mandatory approach should still give room for a wide range of solutions that make use of
local structures and resources, as long as they prevent the environmental risks for the specific
case.
Introduction of mandatory risk management in relation to water reuse should be consistent
with the planned revision of the Urban Waste Water Treatment Directive that may introduce
similar requirements for the management of risks related to the discharge of treated
wastewater to the environment.
3.4. ANALYSIS OF IMPACTS OF POSSIBLE REQUIREMENTS ON
GOVERNANCE AND ECONOMIC ASPECTS AND ON TECHNOLOGY
3.4.1 Governance and economic aspects
No specific options for governance set-up were proposed but the experts discussed in general
terms the impact of governance of water reuse schemes7
on innovation:
 One of the main market barriers for water reuse is the fragmentation of the urban water
cycle. The management of the water value chain is often distributed among different
actors, resulting in a lack of a holistic view and poor synergies. Individual actors hesitate
to innovate until other stakeholders do.
 Any mandatory EU policy should include a clarification of the role and responsibility for
meeting the mandatory requirements of each actor involved (producer of reclaimed water,
end user, reuse management authority), the permitting procedure and monitoring
programs. Assigning responsibility to these actors can motivate them to look for effective
solutions including innovative and cost effective ways to meet the mandatory
requirements.
 There is a need for some degree of flexibility in allocating the responsibility because
mandating exclusive responsibility either to “point of use” or “point of treatment” might
hamper the development of alternative innovative business models.
7
A water reuse scheme is a system consisting of UWWTP, distribution system and the system for application of
reclaimed water for irrigation or groundwater recharge.
82
 Although the point of treatment is well defined and allows creating specific rules and
regulations, the definition of point of use is not always clear and it remains difficult to
comply with requirements due to the lack of real control of reclaimed water quality after
the point of treatment. Therefore new solutions to coordinate the reclaimed water quality
between the point of treatment and the point of use are needed.
 New water reuse schemes are hampered by several economic factors that impede a
broader adoption through the EU, including:
o doubts about the economic sustainability of the current business models; and
o pricing strategies.
 Subsidising current technological solutions might hamper the development of more cost-
effective innovative solutions. Cost-effective innovation relies on users paying the true
costs of resources. On the other hand to improve the economic viability of water reuse
schemes economic stimuli for actors may be needed, e.g. in the form of sharing the costs
and benefits between the utility that provides the reclaimed water, distribution system and
final users (farmers). For example, it was indicated that innovative solutions based on
“win-win” approaches which will not rely on the farmers paying all reclamation and reuse
costs should be considered according to the FAO book issued in 2010 on the economy of
reuse.
 There is still need for R&I on the economic sustainability of the reclaimed water services,
business models and pricing strategies.
 In order to improve public trust in use of reclaimed waste water the regulatory and risk
management measures should be accompanied with public awareness and communication
measures.
3.4.2 Technology
No specific options for technology requirements were proposed but the experts discussed in
general terms the impact of setting technology requirements on innovation:
 The Urban Wastewater Treatment Directive contributed to a high growth of R&I on new
treatment technologies, in particular for nutrient removal. The same effect on R&I could
be expected with the new Water Reuse legislation.
 The measure should not be limited to a parametric approach (meeting output requirements
only) but it should be coupled with defining minimum suitable treatment processes. These
recommended processes should be indicative, leaving room for novel alternatives (such as
green and/or grey infrastructures) achieving similar results.
 Promoting strongly specific established technologies might hamper the development of
new more effective technologies.
 The choice of the appropriate reuse and recycling technology is the most important step in
planning an effective and efficient water reuse system. It is the key element in decreasing
the potential risk comprising technical, economic, environmental and social parameters. In
order to choose a technology pertinent for an area or region, it is possible to build on
successful results of certain European projects in this domain.
 The problem is not the lack of treatment techniques and technologies, but rather how such
schemes may become more efficient and implementable in conjunction with integrated
water resources management. Currently there are no decision-making tools available to
enable decision-makers and water resource users to view, assess and value different reuse
83
and recycling technologies and approaches, and consider their respective advantages and
disadvantages.
 New more efficient and reliable treatment technologies are being developed. Membrane
technologies, such as MBR, UF, MF, etc. are a proven and efficient barrier to pathogens,
but their investment and O&M costs are very high. In addition to the requirement for
affordable cost and easy maintenance, the new treatment technologies for reclamation and
irrigation should be adapted for intermittent operation only during the period of irrigation,
which is not the case of the majority of the available technologies nowadays. For example,
the MARSOL (FP7) project8
demonstrated an application of a sound, safe and sustainable
strategy of Managed Aquifer Recharge (MAR) and shown that it can be applied with great
confidence. The MAR approach demonstrated that the use of reclaimed water and other
alternative water sources in MAR can optimize water resources management in times of
water shortage.
 The further development of optimal technologies for the main categories of water reuse
application still needs significant R&I efforts and in-situ demonstration. Due to the small
scale of the majority of water reuse projects for irrigation and aquifer recharge the
investment in the development limited.
 Monitoring, and in particular online monitoring of reclaimed water quality, presents major
challenges. Affordable and easy to maintain sensors should be developed for monitoring
of conventional parameters (turbidity, chlorine residual, conductivity, etc.),
microbiological parameters (E. coli, coliphages, etc.) and emerging parameters and
pathogens including surrogate monitoring and methods for broad spectrum analysis.
4. CONCLUSIONS AND RECOMMENDATIONS
4.1. Conclusions and Recommendations concerning the new legislative instrument
on minimum quality requirements for water reuse in agricultural irrigation
and aquifer recharge
In addition to the assessments as set out in section 3, experts also drew the following
conclusions and recommendations:
 The EU has the potential to become a leader in the water reuse field, instead of following
foreign developments. It would contribute to the EU competitiveness, innovation, and
global technological leadership.
 For the development of an efficient and widely applicable European legislation in the field
of water reuse three criteria should be met: effectiveness from the perspective of the
protection of public health and the environment, the affordability of practical application
and the implementation of the latest advance in science and practice.
 There is a need to have an innovation-friendly legislation. Minimum quality requirements
for reclaimed water are likely to incentivise further innovation in this field. However too
stringent quality requirements can be counterproductive and kill water reuse practice and
related market opportunities.
8
www.marsol.eu / www.eip-water.eu/MAR_Solutions, with the application of MAR in eight demonstration sites
in six countries around the Mediterranean (Portugal, Spain, Italy, Greece, Malta, Israel)
84
 A combination of limit values for selected quality parameters and risk management is the
way to go. The decision which aspects of reclaimed water quality will be regulated
through parametric limit values and which well be subject of risk management will be
critical to the effectiveness and efficiency of the legislation.
 Limit values and the scope of parameters should be dynamic and allow for adaptation to
progress in scientific knowledge and technological development.
 Risk management should be effectively promoted by the new legislation. The legislation
should set essential requirements of risk management system for water reuse but the
application and adaptation to the local conditions has to be left to local actors.
 The discussion also pointed to a communication challenge and experts recommend using
the terms "reclaimed water" rather than "treated waste water" which are too negatively
connoted.
 Due to the lack of information on health or environmental risks of the existing water reuse
projects in Europe and worldwide it will be difficult to establish a realistic baseline for
evaluation of the impacts of this initiative. To retrieve reliable and up-to-date information
from existing and planned water reuse schemes new R&I projects should be considered.
Specific recommendation for drafting the legislative text:
 Introduce flexible and dynamic requirements for regulating selected parameters and their
limit values, e.g. through the regular review mechanism;
 Set essential requirements for RMA-H and RMA-E and dynamic requirements for specific
requirements, e.g. through the review mechanism;
 Set the dynamic minimum technology requirements and foresee their review to adapt
them to technological development;
 Set the dynamic monitoring requirements that will open the possibility for the online
monitoring techniques provided that the online method has proven its equivalency e.g.
through Environmental Technology Verification (ETV). Remove suboptimal monitoring
methods in the future, e.g. by a sunset clause;
 Establish the requirement for a Life-Cycle Assessment (LCA) for each water reuse
scheme and in particular the requirement to demonstrate environmental benefits by
providing Key Performance Indicators (KPI).
4.2. Broader Policy Recommendations
In addition to the assessment of options for the future EU legislative instruments analysed for
their innovation friendliness, the experts made, in the course of discussion, the following
general recommendations on the broader policy context in which this new legislative will be
implemented:
 When addressing water reuse a holistic approach is needed. The whole value chain of
water reuse should be considered from a systemic point of view, looking beyond
environmental, health and trade aspects.
85
 Any water reuse initiative needs to be also put in the context of the interaction of water
policy with other policy areas. For example, the relationship water-energy (nexus) should
also be considered.
 The present water reuse legislative initiative focuses on the use of reclaimed water in
agriculture and groundwater recharge. In the future it will be equally important to address
water reuse for other purposes such as urban uses, industrial uses, etc.
 Water reuse legislation will interact with other legislative instruments such as the Urban
Waste Water Directive and the Environmental Quality Standards Directive. Water reuse
needs to be considered in the upcoming review of different pieces of EU water legislation.
 Emerging pollutants should be regulated at appropriate level. Parameters like antibiotic
resistance, microplastics, nanoparticles, etc. are not of specific concern for water reuse
and should be identified in the context of other, more global EU legislation, e.g. the Water
Framework Directive and its daughter directives.
 To support the implementation of this new EU legislation, there is a need to develop an
EU network or a platform to valorise and exploit European R&I projects’ results and to
facilitate practical application of projects as currently their uptake and upscaling is very
low.
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Annex 9 - Assessment of territorial impacts9
Territorial Impact Assessment Report
Development of Minimum Quality Requirements for Reused Water
in Agricultural Irrigation and Aquifer Recharge
Based on workshop carried out using ESPON TIA tool
24/04/2017
This territorial impact assessment report is the outcome of an expert workshop organised by
Directorate General of Regional and Urban Policy (DG REGIO) in collaboration with
Directorate General for Environment (DG ENV) within the framework of the Better
Regulation, applying tool No. 29 from the Better Regulation toolbox, in particular the TIA
tool of the ESPON 2020 Cooperation Programme, partly financed by the European Regional
Development Fund.
The ESPON TIA Tool is designed to support the quantitative assessment of potential
territorial impacts according to the Better Regulation guidelines. It is an interactive web
application that can be used to support policy makers and practitioners with identifying, ex-
ante, potential territorial impacts of new EU Legislations, Policies and Directives (LPDs).
This report documents results of the territorial impact assessment expert workshop on the
development of minimum quality requirements for reused water in agricultural irrigation and
aquifer recharge. It serves for information purposes only. This report and the maps represent
views and experiences of the participants of the workshop. It is meant to be used for decision
support only and does not necessarily reflect the opinion of the members of the ESPON 2020
Monitoring Committee as well as DG REGIO and DG ENV.
The ESPON EGTC is the Single Beneficiary of the ESPON 2020 Cooperation Programme.
The Single Operation within the programme is implemented by the ESPON EGTC and co-
financed by the European Regional Development Fund, the EU Member States and the
Partner States, Iceland, Liechtenstein, Norway and Switzerland.
Authors
Erich Dallhammer and Bernd Schuh, ÖIR GmbH
9
The TIA has been completed before the JRC modelling report (Annex 4), therefore there could be some
differences in these reports in particular as regards the data availability.
87
Eleftherios Stavropoulos, DG REGIO
Institutions and organisations involved in the territorial impact assessment on the Deve-
lopment of Minimum Quality Requirements for Reused Water in Agricultural
Irrigation and Aquifer Recharge
European Commission (DG REGIO, DG ENV, DG SANTE, DG AGRI); European
Committee of the Regions, ESPON EGTC.
Experts taking part in the TIA workshop
Denis Bonvillain (SUEZ), Steffen Ochs (Bavarian State Ministry of the Environment and
Consumer Protection), Ioannis Kalavrouziotis (School of Science and Technology, Hellenic
Open University), Manuel Herrera Artilles (Canaria Environmental Health Service), Pilar
Megia Rico (City of Murcia), Marcos Calderon Asenjo (Spanish Ministry of Agriculture,
Food and Environment), Adriano Battilani (Canale Emiliano Romagnolo), Anabela Rebelo
(Portuguese Environment Agency), Ruzandra Balaet (Ministry of Water and Forests of Ro-
mania), Pedro Simon (Regional Government of Murcia), Claire Baffert (EUROCITIES),
Nicolas Condom (European Irrigation Association), Liliana Rastocka (Department of River
Basin Management and Flood Protection, Ministry of Environment of the Slovak Republic),
Bertand Vallet (EurEau), Thomas Petitguyot (DG ENV), Angelo Innamorati (DG AGRI),
Christof Mainz (DG ENV), Petra Kleininger (DG ENV), Dagmar Kaljarikova (DG ENV),
Zeljka Zgaga (DG REGIO), Marielle Riche (DG REGIO), Peter Takacs (DG REGIO), Sylvie
Coulon (DG SANTE), Oliver Heiden (CoR).
Information on ESPON and its projects can be found on www.espon.eu.
The web site provides the possibility to download and examine the most recent documents
produced by finalised and ongoing ESPON projects.
This delivery exists only in an electronic version.
© ESPON, 2017
Printing, reproduction or quotation is authorised provided the source is acknowledged and a
copy is forwarded to the ESPON EGTC in Luxembourg.
Contact: info@espon.eu
88
Table of contents
List of Figures .......................................................................................................................... 89
List of Maps ............................................................................................................................. 90
Abbreviations ........................................................................................................................... 92
1 Introduction................................................................................................................ 93
1.1 The initiative of the Commission................................................................... 93
1.2 The approach of the ESPON TIA quick check .............................................. 93
2 The ESPON TIA Quick Check workshop – identifying potential effects on the
territory....................................................................................................................... 95
2.1 Identifying the effects considering economy, society, environment and
governance related indicators – drafting a conceptual model........................ 95
2.2 Identifying the types of regions potentially affected...................................... 96
2.3 Picturing the potential territorial effects through relevant indicators ............ 96
2.4 Judging the intensity of the effects................................................................. 98
2.5 Calculating the potential “regional impact” – Combining the expert
judgement with the regional sensitivity ......................................................... 98
2.6 Mapping the potential territorial impact......................................................... 99
3 Results of the TIA quick check: Potential territorial impact considering environment
aspects ...................................................................................................................... 100
3.1 The potential territorial impact based on agriculture depending on irrigated
land............................................................................................................... 100
3.2 The potential territorial impact on regions based on the facing danger of
droughts........................................................................................................ 101
3.3 The potential territorial impact on regions facing heat waves ..................... 104
3.4 The potential territorial impact based on pollutants in soil and ground/surface
water indicator.............................................................................................. 105
4 Results of the TIA quick check: Potential territorial impact considering the economy
aspects ...................................................................................................................... 107
4.1 The potential territorial impact based on the added value in agriculture and
forestry ......................................................................................................... 107
4.2 The potential territorial impact based on the economic growth................... 110
4.3 The potential territorial impact based on the R&D Climate ........................ 112
5 Results of the TIA quick check: Potential territorial impact based on society aspects
.................................................................................................................................. 114
5.1 The potential territorial impact based on the employment in agriculture and
forestry ......................................................................................................... 114
89
5.2 The potential territorial impact based on out-migration/brain
drain/“shrinking” of regions......................................................................... 117
5.3 The potential territorial impact based on healthy life expectancy................ 120
6 Results of the TIA quick check: Potential territorial impact based on governance
aspects ...................................................................................................................... 123
6.1 The potential territorial impact on government effectiveness...................... 123
7 Conclusions and policy implications ....................................................................... 126
7.1 Findings based on the results of the TIA Quick check ................................ 126
7.2 Findings and recommendations from the expert discussion ........................ 128
Annex 1: Territorial impact assessment workshop agenda.................................................... 130
Annex 2: Description of the indicators used and regional sensitivity.................................... 131
Annex 3: The situation on the ground. Collection of replies of experts to questionnaire on
waste water practices.............................................................................................................. 135
90
List of Figures
Figure ‎
1.1: Workshop Discussion............................................................................... 94
Figure ‎
2.1: Workshop findings: Conceptual model of the effects of the development of
minimum quality requirements for reused water in agricultural irrigation and aquifer recharge
on the development of regions .................................................................................... 95
Figure ‎
2.2: Exposure x territorial sensitivity = territorial impact ............................... 98
Figure ‎
3.1: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
agriculture depending on irrigated land .................................................................... 100
Figure ‎
3.2: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
agriculture depending on irrigated land in rural regions........................................... 100
Figure ‎
3.3: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on regions
facing danger of droughts.......................................................................................... 102
Figure ‎
3.4: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on rural
regions facing danger of droughts............................................................................. 102
Figure ‎
3.5: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on regions
facing heat waves ...................................................................................................... 105
Figure ‎
3.6: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on rural
regions facing heat waves ......................................................................................... 105
Figure ‎
3.7: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements on pollutants in soil and ground/surface water........................ 106
Figure ‎
3.8: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements on pollutants in soil and ground/surface water in rural regions106
Figure ‎
4.1: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on added
value in agriculture and forestry................................................................................ 107
Figure ‎
4.2: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on added
value in agriculture and forestry in rural regions ...................................................... 107
Figure ‎
4.3: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
economic growth....................................................................................................... 110
Figure ‎
4.4: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
economic growth in rural regions.............................................................................. 111
91
Figure ‎
4.5: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on R&D
Climate (R&D expenditure)...................................................................................... 112
Figure ‎
4.6: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on R&D
Climate (R&D expenditure) in rural regions............................................................. 113
Figure ‎
5.1: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
employment in agriculture and forestry .................................................................... 114
Figure ‎
5.2: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
employment in agriculture and forestry in rural regions........................................... 114
Figure ‎
5.3: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on out-
migration/brain drain/“shrinking” of regions............................................................ 118
Figure ‎
5.4: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on out-
migration/brain drain/“shrinking” of rural regions ................................................... 118
Figure ‎
5.5: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on healthy
life expectancy........................................................................................................... 121
Figure ‎
5.6: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on healthy
life expectancy in rural regions ................................................................................. 121
Figure ‎
6.1: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
government effectiveness.......................................................................................... 123
Figure ‎
6.2: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge
government effectiveness in rural regions ................................................................ 123
List of Maps
Map ‎
3.1: Result of the expert judgement: Agriculture depending on irrigated land affected by
the development of minimum quality requirements for reused water in agricultural irrigation
and aquifer recharge – expert judgement: weak advantageous effect....................... 101
Map ‎
3.2: Result of the expert judgement: Regions facing danger of droughts affected by the
development of minimum quality requirements for reused water in agricultural irrigation and
aquifer recharge – expert judgement: weak advantageous effect.............................. 103
Map ‎
3.3: Result of the expert judgement: Rural regions facing danger of droughts affected by
the development of minimum quality requirements for reused water in agricultural irrigation
and aquifer recharge – expert judgement: strong advantageous effect ..................... 104
92
Map ‎
4.1: Result of the expert judgement: Added value in agriculture and forestry affected by
the development of minimum quality requirements for reused water in agricultural irrigation
and aquifer recharge – expert judgement: weak advantageous effect....................... 108
Map ‎
4.2: Result of the expert judgement: Added value in agriculture and forestry in rural
regions affected by the development of minimum quality requirements for reused water in
agricultural irrigation and aquifer recharge – expert judgement: strong advantageous effect
................................................................................................................................... 109
Map ‎
4.3: Result of the expert judgement: Economic growth affected by the development of
minimum quality requirements for reused water in agricultural irrigation and aquifer recharge
– expert judgement: weak advantageous effect......................................................... 112
Map ‎
5.1: Result of the expert judgement: Employment in agriculture and forestry affected by
the development of minimum quality requirements for reused water in agricultural irrigation
and aquifer recharge – expert judgement: weak advantageous effect....................... 116
Map ‎
5.2: Result of the expert judgement: Employment in agriculture and forestry affected by
the development of minimum quality requirements for reused water in agricultural irrigation
and aquifer recharge – expert judgement: strong advantageous effect ..................... 117
Map ‎
5.3: Result of the expert judgement: Out-migration/brain drain/“shrinking” of regions
affected by the development of minimum quality requirements for reused water in agricultural
irrigation and aquifer recharge – expert judgement: weak advantageous effect....... 119
Map ‎
5.4: Result of the expert judgement: Out-migration/brain drain/“shrinking” of rural
regions affected by the development of minimum quality requirements for reused water in
agricultural irrigation and aquifer recharge – expert judgement: strong advantageous effect
................................................................................................................................... 120
Map ‎
6.1: Result of the expert judgement: Government effectiveness affected by the
development of minimum quality requirements for reused water in agricultural irrigation and
aquifer recharge – expert judgement: weak advantageous effect.............................. 125
Map ‎
7.1: Result of the expert judgement: Agriculture depending on irrigated land affected by
the development of minimum quality requirements for reused water in agricultural irrigation
and aquifer recharge – expert judgement: weak advantageous effect....................... 126
Map ‎
7.2: Result of the expert judgement: Regions facing danger of droughts affected by the
development of minimum quality requirements for reused water in agricultural irrigation and
aquifer recharge – expert judgement: weak advantageous effect.............................. 127
93
Abbreviations
CoR European Committee of the Regions
DG ENV European Commission – Directorate General for Environment
DG REGIO European Commission – Directorate General for Regional and Urban
Policy
DG SANTE European Commission – Directorate General for Health and Food
Safety
EC European Commission
ESPON
ETKC
European Territorial Observatory Network
European Territorial Knowledge Center
EU European Union
GDP
GVA
Gross Domestic Product
Gross Value Added
IA Impact Assessment
IPCC
JRC
Intergovernmental Panel on Climate Change
Joint Research Center
LPDs Legislations, Policies and Directives
NATURA
2000
European ecological network aimed at promoting the conservation of
natural sites and wildlife habitats while taking into account the
economic, social and cultural needs and the particular regional and local
features of each Member State. The network is the result of several
directives on the conservation of habitats and species, adopted by the
European Commission in the wake of the 1992 Rio Conference to deal
with the worrying decline in biodiversity.
NUTS Nomenclature des unites territoriales
Common classification of territorial units for statistical purposes
ÖIR Österreichisches Institut für Raumplanung/ÖIR GmbH
PM10 Particulate Matter
R&D Research & Development
TIA Territorial Impact Assessment
UK United Kingdom
UWWTD
WWTP
Urban Wastewater Treatment Directive
Waste Water Treatment Plant
94
1 INTRODUCTION
1.1 The initiative of the Commission10
The European Commission is currently conducting an Impact Assessment (IA) for an EU
initiative on the Development of Minimum Quality Requirements for Water Reuse in
Agricultural Irrigation and Aquifer Recharge in order to contribute to reducing water scarcity.
The IA focuses on the reuse of treated wastewater covered by the Directive 91/271/EEC
concerning urban waste water treatment.
The only source of wastewater considered in this document is the wastewater covered by the
Urban Wastewater Treatment Directive (UWWTD) (91/271/EEC). Thus, the wastewater
considered is urban wastewater defined as domestic wastewater or the mixture of domestic
wastewater with industrial wastewater and/or run-off rain water, according to Directive
91/271/EEC). The industrial wastewater considered is from the industrial sectors listed in
Annex III of the UWWTD.
The health and environmental safety conditions under which wastewater may be reused are
not specifically regulated at the EU level. There are no guidelines, regulations or good
management practices defined at European Union (EU) level on water quality for water reuse
purposes.
Because of an unclear regulatory framework across EU MS water reuse projects suffer from
limited economic attractiveness. This creates difficulties for businesses operating cross-border
and also limits the possibility to standardise technologies and benefit from economies of
scale. The initiative of the EU Commission shall reduce these barriers and define under which
conditions, minimum quality requirements, the use of reused water for agricultural irrigation
and aquifer recharge is safe.
1.2 The approach of the ESPON TIA quick check
The concept of territorial impact assessment (TIA) aims at showing the regional
differentiation of the impact of EU policies. The ESPON TIA Tool11 is an interactive web
application that can be used to support policy makers and practitioners with identifying, ex-
ante, potential territorial impacts of new EU legislations. The “ESPON TIA quick check”
approach combines a workshop setting for identifying systemic relations between a policy and
its territorial consequences with a set of indicators describing the sensitivity of European
regions. It helps to steer an expert discussion about the potential territorial effects of an EU
initiative by discussing all relevant indicators in a workshop setting. The results of the guided
expert discussion are judgments about the potential territorial impact of an EU policy
considering different thematic fields (economy, society, environment, governance) for a range
of indicators. These results are fed into the ESPON TIA Quick Check web tool.
The web tool translates the combination of the expert judgments on exposure with the
different sensitivity of regions into maps showing the potential territorial impact of EU policy
10
The text of this chapter is based on the background paper for the TIA Workshop “Territorial Impact
Assessment (TIA) on the on the Development of Minimum Quality Requirements for Water Reuse in
Agricultural Irrigation and Aquifer Recharge” developed by the European Commission DG for Environment and
DG for Regional and Urban Policy.
11
https://www.espon.eu/main/Menu_ToolsandMaps/TIA/
95
on NUTS3 level. These maps serve as starting point for the further discussion of different
impacts of a concrete EU policy on different regions. Consequently, the experts participating
in the workshop provide an important input for this quick check on potential territorial effects
of an EU initiative.
The workshop on the development of minimum quality requirements for reused water in
agricultural irrigation and aquifer recharge was held on 5 April 2017 in Brussels and brought
together 24 experts representing different stakeholders, as e.g. national, regional and local
authorities, NGOs and environmental institutions and European institutions such as the
European Commission (DG REGIO, DG ENV, DG SANTE, DG AGRI) and the European
Committee of the Regions.
Two moderators from the ÖIR, provided by ESPON, prepared and guided the workshop and
handled the ESPON TIA tool.
Figure 1.1: Workshop Discussion
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017 © ÖIR
96
2 THE ESPON TIA QUICK CHECK WORKSHOP – IDENTIFYING POTENTIAL EFFECTS ON
THE TERRITORY
2.1 Identifying the effects considering economy, society, environment and governance
related indicators – drafting a conceptual model
In the first step of the TIA workshop the participating experts discussed about the potential
effects at regional level of the development of minimum quality requirements for reused water
in agricultural irrigation and aquifer recharge. This discussion revealed potential territorial
impacts of the development of minimum quality requirements in the fields of economy,
society, environment and governance. The participants identified potential linkages between
the different effects on regions including interdependencies and feed-back-loops between
different effects (see figure below).
Figure 2.1: Workshop findings: Conceptual model of the regional effects of the development
of minimum quality requirements for reused water in agricultural irrigation and aquifer
recharge
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017 © ÖIR
Environment
 The initiative could contribute to reduce the lack of water in those regions that are
suffering from water scarcity. It could be one component to mitigate the effects of
climate change connected to water scarcity and draughts.
 However, low ambitions of the initiative may lead to low environmental standards and
consequently to negative environmental impacts, especially for ground water.
 The re-use of waste water may increase energy consumption.
97
 Additionally to the use of wastewater for agriculture irrigation, it could also be used for
watering green areas in cities. This could increase the quality of live in urban areas and
reduce CO2 emissions.
Economy
 The reuse of water and the compliance with quality standards could require
infrastructure investments. This could be a trade barrier compared with non-EU
countries that do not foresee such quality standards. However, this could also be a
chance for stimulating regional economic growth.
 Society
 The effect on employment can be twofold. On one hand there is the chance to increase
employment in the “new green sectors”. On the other hand, when there is a lack of cost
effectiveness, employment in agriculture sector could also decrease.
 The development of minimum quality requirements for water reuse in agricultural
irrigation and aquifer recharge could improve the public acceptance of reused water,
which could create chances for development, especially in rural areas. Employment
opportunities could contribute to stabilize rural society and reduce the decrease of
population in rural areas.
Governance
 The public could interpret a complicate regulation with long lists linking different
quality standards to different types of use of wastewater as a sign that the reuse of water
is environmentally dangerous. This could cause a problem with its public acceptance.
 A complicated regulation could be too demanding for its implementation in islands
considering the administrative capacity of the public services there. Consequently
islands would have competitive disadvantages related to other regions.
 Some countries have quite high water quality standards, already. There is the fear that
the new minimum quality requirements will get in conflict with existing standards and
could reduce the level of quality in some MS.
2.2 Identifying the types of regions potentially affected
The ESPON TIA tool provides several regional typologies12 for analysis taking under
consideration the types of territories mentioned in the Lisbon Treaty §174: urban/metropolitan
regions; rural regions; sparsely populated regions; regions in industrial transition; cross-
border regions; mountainous regions; islands and coastal regions. The experts agreed that in
general all regions would be affected by the modification of this Commission initiative.
Additionally, it was agreed that in some aspects especially rural regions could be affected
differently.
2.3 Picturing the potential territorial effects through relevant indicators
In order to assess the potential effects pictured in the conceptual model suitable indicators
need to be selected related to the economy, environment, society and governance parameters
that the experts discussed. The availability of data for all NUTS 3 regions of the EU is posing
certain limitations to indicators that can be used. From the available indicators that the
12
https://www.espon.eu/main/Menu_ToolsandMaps/ESPONTypologies/index.html
98
ESPON TIA Quick Check web tool offers The experts chose the following indicators to
describe the identified effects.
Indicators picturing environmental effects
 Agriculture depending on irrigated land
 Regions facing danger of droughts
 Regions facing heat waves
 Pollutants in soil and ground/surface water
Indicators picturing economic effects
 Economic growth
 R&D Climate
 Added value in agriculture and forestry
Indicators picturing societal effects
 Employment in agriculture and forestry
 Out-migration/brain drain/“shrinking” of regions
 Healthy life expectancy
Indicators picturing governance effects
 Government effectiveness
Data availability poses limitations to availability of indicators. The experts discussed that the
set of provided indicators do not cover all effects that are caused by the development of
minimum quality requirements for reused water in agricultural irrigation and aquifer recharge.
Moreover, the set of indicators is too high level and too generic and the correlation between
the initiative and the indicators are generally weak (e.g. there is only a weak link between
indicator on R&D climate of a region and whether there are common quality standards for
water reuse). Therefore the set of indicators do not mirror the supposed effects, but provide an
indication only on effects.
Therefore, experts were called upon to identify a “wish list“ of other indicators, which
represent better the potential effects from the development of minimum quality requirements
for reused water in agricultural irrigation and aquifer recharge:
 population density
 amount of treated waste water
 output from agriculture from irrigated land
 employment in irrigation technologies
 water exploitation index at water basin level
 ratio crop water requirement and incoming water/satisfaction level
 indicators on water bodies status
 water prices
 energy balance for water reuse
 trade flows (agriculture)
 compliance on UWWTD
However, as data at NUTS 3 level on the above indicators aren't available, these indicators
have not been used.
Nevertheless, DG REGIO and DG ENV will explore with EUROSTAT and with JRC in the
framework of the Territorial Knowledge Centre how in the future this gap can be filled since
99
these indicators and the necessary data will be important also for monitoring the effective
implementation of the upcoming regulation.
2.4 Judging the intensity of the effects
The participants of the workshop were asked to estimate the effects deriving from the
development of minimum quality requirements. They judged the effect on territorial welfare
along the following scores:
 ++ strong advantageous effect on territorial welfare (strong increase)
 +weak advantageous effect on territorial welfare (increase)
 O no effect/unknown effect/effect cannot be specified
 - weak disadvantageous effect on territorial welfare (decrease)
 - - strong disadvantageous effect on territorial welfare (strong decrease)
2.5 Calculating the potential “regional impact” – Combining the expert judgement
with the regional sensitivity
The ESPON TIA Quick Check combines the expert judgement on the potential effect of the
development of minimum quality requirements (exposure) with indicators picturing the
sensitivity of regions resulting in maps showing a territorial differentiated impact. This
approach is based on the vulnerability concept developed by the Intergovernmental Panel on
Climate Change (IPCC). In this case, the effects deriving from a particular policy measure
(exposure) are combined with the characteristics of a region (territorial sensitivity) to
produce potential territorial impacts (cf. following figure).
 “Territorial Sensitivity” describes the baseline situation of the region according to its
ability to cope with external effects. It is a characteristic of a region that can be
described by different indicators independently of the topic analysed.
 “Exposure” describes the intensity of the potential effect caused by the development of
minimum quality requirements on a specific indicator. It is the effect of the
development of minimum quality requirements. Exposure illustrates the experts’
judgement, i.e. the main findings of the expert discussion at the TIA workshop.
Figure 2.2: Exposure x territorial sensitivity = territorial impact
100
Source: ÖIR, 2015.
2.6 Mapping the potential territorial impact
The result of the potential territorial impact assessment is presented in maps. The maps
displayed below show the potential territorial impact based on a combination of the expert
judgement on the exposure with the territorial sensitivity of a region, described by a indicator
on NUTS3 level. Whereas expert judgement is a qualitative judgement (strong advantageous
effect on territorial welfare/weak advantageous effect/no effect/weak disadvantageous
effect/strong disadvantageous effect), the sensitivity is a quantitative indicator. (The detailed
description is provided in the annex.).
101
3 RESULTS OF THE TIA QUICK CHECK: POTENTIAL TERRITORIAL IMPACT CONSIDERING
ENVIRONMENT ASPECTS
3.1 The potential territorial impact based on agriculture depending on irrigated land
The experts agreed that the development of minimum quality requirements for reused water in
agricultural irrigation and aquifer recharge would definitely cause positive effects in all
regions with agriculture depending on irrigated land. Five experts voted for a strongly
advantageous effect, eleven for a weakly advantageous effect. Just two experts expert saw a
negative effect. When focusing only on rural regions, the expert judgement was quite similar.
Figure 3.1: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
agriculture depending on irrigated land
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
Figure 3.2: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
agriculture depending on irrigated land in rural regions
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
The sensitivity of agriculture depending on irrigated land is measured by the indicator “share
of irrigated land”. It is assumed that a higher share of irrigated land makes a region more
sensitive towards policies influencing the conditions of irrigation.
5
11
4
1 1
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Agriculture depending on irrigated land – all regions
++ strong advantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strong disadvantageous
6
12
4
0
1
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Agriculture depending on irrigated land – rural regions
++ strong advantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strong disadvantageous
102
The following map shows the potential territorial impact of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
agriculture depending on irrigated land. It combines the overall expert judgement of a weakly
advantageous effect with the given sensitivity of regions. Spanish regions on the
Mediterranean coast, Greek regions on the Northern coast of the Aegean Sea and Italian
regions around Torino could benefit from a moderate positive effect. All other regions could
gain a minor positive impact.
Map 3.1: Result of the expert judgement: Agriculture depending on irrigated land affected by
the development of minimum quality requirements for reused water in agricultural irrigation
and aquifer recharge – expert judgement: weak advantageous effect
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
3.2 The potential territorial impact on regions facing danger of droughts
The experts estimated that the implementation of the EU initiative setting minimum quality
requirements for reused water in agricultural irrigation and aquifer recharge could contribute
to reduce the lack of water in those regions that are suffering from water scarcity. According
to the experts it could be a component to mitigate the effects of climate change connected to
water scarcity and droughts. A majority of the experts estimated that this would bring weak or
103
even strong advantageous effects on regions facing danger of droughts. However, we should
note that a substantial number thought that it will have neutral effects. Only two experts
judged the effects as disadvantageous. When focusing only on rural regions, the expert
judgement was quite similar.
Figure 3.3: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
regions facing danger of droughts
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
Figure 3.4: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on rural
regions facing danger of droughts
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
The indicator picturing the sensitivity of a region facing danger of droughts is measured by
the probability of forest fires. This indicator was criticized by several experts, because they
judged the cause-effect relation between the additional options for irrigation reducing the
negative effects of droughts for agriculture and the concrete sensitivity indicator (probability
of forest fires) as too weak. Consequently, eight experts did not see any effect of the initiative
on this indicator and 3 experts considered that this indicator was not relevant at all.
The following map shows the potential territorial impact on regions facing danger of droughts
by combining the expert judgement of the weak advantageous effect with the corresponding
sensitivity. Based on that regions which could gain a moderate positive impact are situated in
6 6
8
1 1
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Regions facing danger of droughts
++ strong advantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strong disadvantageous
5
6
8
1 1
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Rural regions facing danger of droughts
++ strong advantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strong disadvantageous
104
the South of Europe (Portugal, Spain, the Mediterranean coast of France, Italy, Greece,
Cyprus) in the East of Europe (East of Poland, South of Hungary, parts of Romania and
Bulgaria) and in the centre of France. Some regions in the South of Portugal and the very
South of Italy and Haute-Corse could gain even a highly positive impact. For the other
regions there would be only a minor impact.
In case of the expert judgement of a strong advantageous effect the impact on the regions
would be respectively higher, up to a very high impact for regions in the South and East of
Europe.
Map 3.2: Result of the expert judgement: Regions facing danger of droughts affected by the
development of minimum quality requirements for reused water in agricultural irrigation and
aquifer recharge – expert judgement: weak advantageous effect
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
105
Map 3.3: Result of the expert judgement: Rural regions facing danger of droughts affected by
the development of minimum quality requirements for reused water in agricultural irrigation
and aquifer recharge – expert judgement: strong advantageous effect
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
3.3 The potential territorial impact on regions facing heat waves
In the workshop the experts judged that the development of minimum quality requirements
for reused water in agricultural irrigation and aquifer recharge would bring advantageous
effects on regions facing heat waves. No one voted for a negative effect.
The indicator picturing the sensitivity of a region facing heat waves was measured by the
number of days over 30 °C. This indicator was criticized by several experts, because they
judged the cause-effect relation between the additional options for irrigation reducing the
negative effects of heat waves for agriculture and the concrete sensitivity indicator as too
106
weak. Consequently, a large group of experts did not see any effect of the EU initiative on this
indicator. Due to this judgement, it was decided as not useful to picture this voting in maps.
Figure 3.5: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
regions facing heat waves
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
Figure 3.6: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on rural
regions facing heat waves
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
3.4 The potential territorial impact based on pollutants in soil and ground/surface
water indicator
The experts’ opinion on the potential effects of the EU initiative based on the indicator
pollutants in soil and ground/surface water was quite diverging. A majority of them judged
the effects as strongly advantageous (6 for all regions, 7 for rural regions) or weakly
5
3
11
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Regions facing heat waves
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
3
7
9
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Rural regions facing heat waves
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
107
advantageous (3 for all regions, 4 for rural regions). However, a minority judged the effects
weakly or even strongly disadvantageous. About one third of the experts judged the effects as
neutral or unknown. Consequently, no clear effect of the EU initiative on pollutants in soil
and ground/surface water can be given.
Figure 3.7: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements on pollutants in soil and ground/surface water
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
Figure 3.8: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements on pollutants in soil and ground/surface water in rural regions
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
The sensitivity of a region towards policies affecting the pollution of soil and ground and
surface water is measured by a proxy indicator taking into account the population density and
the employment density. As this indicator is more responding to pollutants caused by urban
developments than by agricultural land use, a map could lead to wrong interpretations. Taking
into account the weak validity of the indicator measuring effects caused by agriculture and the
quite inhomogeneous expert judgement, no further analysis and mapping seems to be useful.
6
3
7
3
1
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Pollutants in soil and ground/surface water – all regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
7
4
6
4
2
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Pollutants in soil and ground/surface water – rural
regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
108
4 RESULTS OF THE TIA QUICK CHECK: POTENTIAL TERRITORIAL IMPACT CONSIDERING
THE ECONOMY ASPECTS
4.1 The potential territorial impact based on the added value in agriculture and
forestry
There was a clear agreement of the experts that the development of minimum quality
requirements for reused water in agricultural irrigation and aquifer recharge would definitely
have a positive effect on the on the added value in agriculture and forestry. When looking at
all regions, nine experts judged the effects as strongly advantageous, twelve judged them as
weakly advantageous and only two as weakly disadvantageous.
Figure 4.1: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
added value in agriculture and forestry
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
Figure 4.2: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
added value in agriculture and forestry in rural regions
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
9
12
1
2
0
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Added value in agriculture and forestry – all regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
13
8
1 1
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Added value in agriculture and forestry – rural regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
109
When focusing on rural regions, a majority of 13 experts judged the effects of this initiative
as strongly advantageous, eight judged them as weakly advantageous and one judged them as
strongly disadvantageous.
The sensitivity of regions is measured by the indicator “gross value added in agriculture and
forestry”. Regions where agriculture and forestry have an important share of the total regional
gross value added are expected to benefit more from the EU initiative stimulating the added
value of agriculture and forestry than others. The following maps show the potential territorial
impact of setting minimum quality requirements for reused water in agricultural irrigation and
aquifer recharge by combining the expert judgement with the given sensitivity.
Taking into account the potential effects on all regions, the majority of the experts presumes a
weakly advantageous effect. This would lead to minor positive impacts on most regions.
When they can use the new options for reusing sewage water, regions with a high economic
importance of agriculture could gain a moderate positive impact as e.g. in Romania, Bulgaria,
the North of Greece, the North East of Poland, the centre of Spain and the South of Portugal.
For rural regions the majority of the experts presumes a strongly advantageous effect. When
they can use the new options for reusing sewage water rural regions with a high economic
importance of agriculture rural regions could gain a very high positive impact as e.g. in
Romania, Bulgaria, the North of Greece, the North East of Poland, South of Madrid and in the
South of Portugal.
Map 4.1: Result of the expert judgement: Added value in agriculture and forestry affected by
the development of minimum quality requirements for reused water in agricultural irrigation
and aquifer recharge – expert judgement: weak advantageous effect
110
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
Map 4.2: Result of the expert judgement: Added value in agriculture and forestry in rural
regions affected by the development of minimum quality requirements for reused water in
agricultural irrigation and aquifer recharge – expert judgement: strong advantageous effect
111
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
4.2 The potential territorial impact based on the economic growth
The experts identified a positive effect of the development of minimum quality requirements
for reused water in agricultural irrigation and aquifer recharge on the overall economic growth
of all regions. Three voted for a strongly advantageous effect, fourteen for a weakly
advantageous effect. Just one expert saw a weakly disadvantageous effect.
When focusing on rural regions the judgement was even more positive: In this case seven
voted for a strongly advantageous effect and twelve for a weakly advantageous effect.
Figure 4.3: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
economic growth
112
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
Figure 4.4: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
economic growth in rural regions
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
The sensitivity of the regions is measured by the indicator “GDP per capita”. Regions with
lower GDP per capita are expected to benefit more from the EU initiative (like the one on
reuse of water) aimed at GDP growth increase and that inadvertently harm economic growth.
The following map shows the potential territorial impact of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on the
economy growth by combining the judgement of the majority of the experts (weakly
advantageous effect) with the corresponding sensitivity.
It is assumed that especially the Eastern European regions in the Baltic Sea and the Black Sea
and some regions in Greece could potentially benefit with a high positive impact from the EU
initiative. Most other regions would have a moderate impact.
3
14
5
1
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements Economic growth – all regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
7
12
3
0
1
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Economic growth – rural regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
113
Map 4.3: Result of the expert judgement: Economic growth affected by the development of
minimum quality requirements for reused water in agricultural irrigation and aquifer
recharge – expert judgement: weak advantageous effect
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
4.3 The potential territorial impact based on the R&D Climate
The experts assumed that new possibilities for using new technologies could arise in
connection with the reuse of water in agricultural irrigation and aquifer recharge, which could
stimulate the development of technologies in this field. Consequently, the experts saw an
advantageous effect of the EU initiative on the R&D climate: Five voted for a strongly
advantageous effect, eleven for a weakly advantageous effect. This result was the same for all
regions as well as for rural regions.
Figure 4.5: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on R&D
Climate (R&D expenditure)
114
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
Figure 4.6: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on R&D
Climate (R&D expenditure) in rural regions
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
The sensitivity of regions related to the R&D climate is measured by the indicator “R&D
expenditure”. Regions with an already highly innovative climate and with a greater share of
enterprises engaged in product and/or process innovation activities are considered to be more
sensitive to EU initiatives influencing innovation than others. Combining the expert
judgement of the weakly advantageous effect with the corresponding sensitivity results in a
quite equal distribution of a minor positive impact in most European regions.
5
11
5
1
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements R&D Climate – all regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
5
11
5
1
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
R&D Climate – rural regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
115
5 RESULTS OF THE TIA QUICK CHECK: POTENTIAL TERRITORIAL IMPACT BASED ON
SOCIETY ASPECTS
5.1 The potential territorial impact based on the employment in agriculture and
forestry
The development of minimum quality requirements for reused water in agricultural irrigation
and aquifer recharge could improve the public acceptance of reused water, which could
open chances for development, especially in rural areas. Consequently, the participants
judged the effects on the employment in agriculture and forestry as positive. When looking at
all regions13
, four experts judged the effects as strongly advantageous and ten as weakly
advantageous.
Figure 5.1: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
employment in agriculture and forestry
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
When focusing the judgement on rural regions a majority of eleven experts judged the effects
of this initiative as strongly advantageous and additionally ten experts judged them as weakly
advantageous.
Figure 5.2: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
employment in agriculture and forestry in rural regions
13
5 out of the 24 experts thought that this indicator is not relevant when considering all regions and therefore
chose not to vote for it.
4
10
4
1
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Employment in agriculture and forestry – all regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
116
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
The sensitivity of the regions related to agriculture and forestry is measured by the indicator
“share of employment” in these sectors. Regions with a greater share of employment in
agriculture and forestry are likely to be more affected from changes in the level of
employment in this sector induced by the Commission initiative.
The following maps show the potential territorial impact of setting minimum quality
requirements for reused water in agricultural irrigation and aquifer recharge on the
employment in agriculture and forestry by combining the expert judgement with the
sensitivity.
11
10
1 1
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements Employment in agriculture and forestry – rural regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
117
Map 5.1: Result of the expert judgement: Employment in agriculture and forestry affected by
the development of minimum quality requirements for reused water in agricultural irrigation
and aquifer recharge – expert judgement: weak advantageous effect
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
Taking into account the effects on all regions the majority of the experts presumes a weakly
advantageous effect. This would lead to minor positive impacts on most regions. Regions in
the North and the South of Romania could gain a moderate positive impact if they can use the
new options for reusing waste water
118
Map 5.2: Result of the expert judgement: Employment in agriculture and forestry in rural
regions affected by the development of minimum quality requirements for reused water in
agricultural irrigation and aquifer recharge – expert judgement: strong advantageous effect
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
Focusing on rural regions the majority of the experts voted for a strongly advantageous effect.
If they can use the new options for reusing waste water regions as enabled by the proposal of
DG ENV to improve agricultural land use, several regions could potentially gain a high or
very high positive impact, as e.g. in Lithuania, Finland, Poland, Romania, the South of Italy,
Portugal and Spain.
5.2 The potential territorial impact based on out-migration/brain drain/“shrinking” of
regions
According to the experts’ opinion the improved possibilities for agriculture and related
employment possibilities in agriculture could reduce out-migration in currently shrinking
119
regions. Twelve experts voted for a weakly advantageous effect in all regions and two experts
voted even for a strongly advantageous effect. Focusing on rural regions14
the effect was seen
even more positively: Six experts voted for a strongly advantageous effect, four experts for a
weakly advantageous effect. However, a few participants saw a weakly disadvantageous
effect on out-migration.
Figure 5.3: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on out-
migration/brain drain/“shrinking” of regions
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
Figure 5.4: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on out-
migration/brain drain/“shrinking” of rural regions
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
14
The effect of outmigration to rural regions should be taken with cautiousness since 9 out of the 24 experts did
not consider this indicator as relevant and therefore chose not to vote
2
12
3
4
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Out- igratio /brai drai / shri ki g of regio s
all regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
6
4 4
1
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Out- igratio /brai drai / shri ki g of regio s
rural regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
120
The sensitivity of the regions related to out migration is measured by the indicator “net
migration balance” (i.e. immigration minus out-migration on total population). The
underlying hypothesis for describing the sensitivity of the regions towards out migration is
that regions experiencing out-migration and brain drain will benefit more from actions aimed
at their reduction or suffer more from their exacerbation. The following map shows the
potential territorial impact of the proposal of DG ENV taking under consideration out-
migration and brain drain by combining the expert judgement of the weakly advantageous
effect with the corresponding sensitivity. If the regions can benefit from the new possibilities
to reuse waste water in agricultural irrigation and aquifer recharge most of them could get a
moderately positive impact reducing out migration. Some regions mainly located at the
European external borders could gain even a highly positive impact.
Map 5.3: Result of the expert judgement: Out-migration/brain drain/“shrinking” of regions
affected by the development of minimum quality requirements for reused water in agricultural
irrigation and aquifer recharge – expert judgement: weak advantageous effect
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
121
Based on the fact that 9 out of the 24 experts did not consider this indicator relevant (and
therefore did not vote for it) and the fact that 4 voted for a neutral effect we consider that the
strongly advantageous effect registered by those that actually vote should be taken very
cautiously. Assuming that this initiative could lead to a very highly positive impact in rural
regions using wastewater in agricultural irrigation and aquifer recharge (See the following
map) has limitations.
Map 5.4: Result of the expert judgement: Out-migration/brain drain/“shrinking” of rural
regions affected by the development of minimum quality requirements for reused water in
agricultural irrigation and aquifer recharge – expert judgement: strong advantageous effect
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
5.3 The potential territorial impact based on healthy life expectancy
The majority of the participants saw a weak advantageous effect of the development of
minimum quality requirements for reused water in agricultural irrigation and aquifer recharge
122
on the health of the population measured by the healthy life expectancy indicator. However, a
minority was afraid that this new proposal for DG ENV could lead to a weakly
disadvantageous effect on health.
Figure 5.5: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
healthy life expectancy
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
Figure 5.6: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
healthy life expectancy in rural regions
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
Regions in which the life expectancy is lower are expected to benefit more from policy
measures effecting its increase and more negatively influenced by those which decrease it.
This indicator was not considered as suitable by several experts, because they judged the
cause-effect relation between the additional options for irrigation having positive effects on
life expectancy as too weak. Consequently, a large group of experts did not see any effect of
setting minimum quality requirements for reused water in agricultural irrigation and aquifer
1
7
6
3
0
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Healthy life expectancy – all regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
1
11
7
2
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Healthy life expectancy – rural regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
123
recharge based on this indicator. Due to this judgement, it was decided not useful to picture
this voting in maps.
124
6 RESULTS OF THE TIA QUICK CHECK:
POTENTIAL TERRITORIAL IMPACT BASED ON GOVERNANCE ASPECTS
6.1 The potential territorial impact on government effectiveness
The experts considered that an efficient and correct implementation of the proposal to set
minimum quality requirements for reused water in agricultural irrigation and aquifer recharge
could contribute to reduce administrative burdens. However, if the implementation of the
initiative is too complicated, its implementation could be very demanding for some regions as
e.g. for islands. This diverging approach was reflected in the experts’ votes on the effects of
government effectiveness: A majority of experts is expecting positive effects but there is a
quite large group that did not see any effects on government effectiveness, and a minority of
experts that judged the effect as disadvantageous.
Figure 6.1: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
government effectiveness
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
Figure 6.2: Workshop findings: Expert judgement: Effect of the development of minimum
quality requirements for reused water in agricultural irrigation and aquifer recharge on
government effectiveness in rural regions
5 5
8
2
1
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Government effectiveness – all regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
4
7
8
3
0
2
4
6
8
10
12
14
16
18
20
number
of
expert
judgements
Government effectiveness – rural regions
++ strongadvantageous
+ weak advantageous
o neutral/unknown
- weak disadvantageous
-- strongdisadvantageous
125
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
The sensitivity of government effectiveness is measured by the indicator being part of the
Regional Competiveness Index. Regions with low government effectiveness will benefit more
from the implementation of new standards of administration than regions that already have
high standards of their administration.
The following map shows the potential territorial impact of setting minimum quality
requirements for reused water in agricultural irrigation and aquifer recharge on government
effectiveness combining the expert judgement of the weakly advantageous effect with the
corresponding sensitivity. Eastern European regions in Latvia, Lithuania, Poland, Romania
and Bulgaria as well as Italian and Greek regions and some Spanish regions could gain a
moderate to high positive impact on government effectiveness. Most of the other regions
would gain a minor positive impact.
126
Map 6.1: Result of the expert judgement: Government effectiveness affected by the
development of minimum quality requirements for reused water in agricultural irrigation and
aquifer recharge – expert judgement: weak advantageous effect
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
127
7 CONCLUSIONS AND POLICY IMPLICATIONS
7.1 Findings based on the results of the TIA Quick check
The effects of setting minimum quality requirements for reused water in agricultural irrigation
and aquifer recharge will mainly concentrate on regions with an important share of agriculture
depending on irrigated land, and considering the experts expectation of a weakly
advantageous effect, only 4.8% of the regions could generate a moderate or highly positive
impact: Spanish regions on the Mediterranean coast, Greek regions on the Northern coast of
the Aegean Sea and Italian regions around Torino. All other regions could gain just a minor
positive impact.
Map 7.1: Result of the expert judgement: Agriculture depending on irrigated land affected by
the development of minimum quality requirements for reused water in agricultural irrigation
and aquifer recharge – expert judgement: weak advantageous effect
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
128
More benefits from setting minimum quality requirements for the reuse of wastewater and
aquifer recharge would probably mainly concentrate on regions suffering from water scarcity,
which are mainly regions endangered by droughts. The majority of experts expected positive
effects for such regions. The map combining the expert judgement of a weak advantageous
effect with the corresponding sensitivity of regions facing droughts shows that about 24% of
the regions could gain a moderate positive impact. They are situated in the South of
Europe (Portugal, Spain, the Mediterranean coast of France, Italy, Greece, Cyprus) in
East of Europe (East of Poland, South of Hungary, parts of Romania and Bulgaria) and
in the centre of France. Only 1% of the regions located in the South of Portugal, in the
very South of Italy and Haute-Corse could gain a high impact. The majority of 75% of
the regions would face only a minor impact.
Map 7.2: Result of the expert judgement: Regions facing danger of droughts affected by the
development of minimum quality requirements for reused water in agricultural irrigation and
aquifer recharge – expert judgement: weak advantageous effect
Source: Territorial impact assessment expert workshop, Brussels, 5 April 2017
129
Taking into account that only 5% of regions with agriculture depending on irrigated land and
about 25% of regions in danger of droughts are at least moderately impacted by setting
minimum quality requirements for reused water in agricultural irrigation and aquifer recharge,
it is quite clear, that only a minority of NUTS 3 regions in Europe are currently
challenged. These regions are mainly located in the South and the East of Europe.
However one should consider that the predictions for water scarcity and droughts are
such that the situation will become more severe and the effects in the future could
concern more parts of Europe.
When looking at other potential territorial effects of setting minimum quality requirements for
reused water in agricultural irrigation and aquifer recharge it has to be taken into account that
these effects have been always considered under the presumption that the proposal will be
actually applied for agriculture irrigation and aquifer recharge:
 The experts judged most effects of the development of minimum quality requirements
for the reuse of wastewater and aquifer recharge weakly or even strongly advantageous.
Just in a few cases negative effects were expected.
 Regions with a high economic importance of agriculture could gain positive effects on
the GVA in agriculture as e.g. in Romania, Bulgaria, the North of Greece, the north East
of Poland, in the centre of Spain and in the south of Portugal.
 Some peripheral regions mainly located at the European external borders could gain a
highly positive impact reducing out-migration.
 Eastern European regions and some regions in Greece could potentially benefit with a
highly positive impact on GDP growth.
 If the EU initiative is implemented efficiently and effectively, the regions in Latvia,
Lithuania, Poland, Romania and Bulgaria as well as Italian and Greek regions and some
Spanish regions could gain a moderate to high positive impact on government
effectiveness.
 Outermost regions could benefit from catching up effects as e.g. considering economic
growth or from the improvement of government effectiveness. However, a complicated
regulation could be too demanding for its implementation considering the administrative
capacity of the public services there.
7.2 Findings and recommendations from the expert discussion
Based on the maps showing potential territorial impact from the development of minimum
quality requirements by linking the results of the expert judgements on the effects with the
sensitivity of the regions towards these effects the experts discussed on conclusions and
policy implications:
 Initiative contributes to strengthen European cohesion
It was agreed that the EU initiative would definitely contribute to strengthen cohesion in EU,
as it gives especially regions in the South and East of Europe the chance to gain positive
effects on e.g. economy or government effectiveness. However, the positive effects will not
be felt in the short term in regions where water is not scarce at the moment.
 Quality standards
It was noted that the EU initiative must not lead to a reduction of existing ambitious water
goals. The EU initiative would provide the possibility to opt for higher quality standards,
130
especially in Member States with already existing higher water quality standards. It was
clarified that the EU initiative will not undermine the standards set in the Urban Waste Water
Treatment Directive and the Water Framework Directive. Is was proposed to think about a
regional differentiation of the EU initiative.
 Implementation
When the goal is to increase the reuse of wastewater especially for agricultural irrigation the
standard setting alone will not be sufficient. Additionally, subsidies for investment into
irrigation could be relevant.
 Public acceptance
The setting of minimum quality requirements for reused water in agricultural irrigation and
aquifer recharge could improve the public acceptance of reused water, which could open
chances for development, especially in rural areas. However, the EU initiative should be kept
simple. The public would interpret a complicated regulation with long lists linking different
quality standards to different types of use of wastewater as a sign that the reuse of water is
environmentally dangerous. This could cause a problem with its public acceptance.
131
Annex 1: Territorial impact assessment workshop agenda
Territorial impact assessment expert workshop
Development of Minimum Quality Requirements for Reused Water in Agricultural Irrigation and
Aquifer Recharge
Brussels, 5 April 2017
09.30 – 10:00 Registration and Welcome Coffee
10:00 – 10:05 Welcome and introduction into the Territorial Impact Assessment
Eleftherios Stavropoulos Unit, Inclusive Growth, Urban and Territorial
Development, DG REGIO
10:05 – 10:30 Presentation of the Development of Minimum Quality Requirements for
Reused Water in Agricultural Irrigation and Aquifer Recharge – Main
issues – Policy Options
Thomas Petiguyot, DG ENV
10:30 – 10:45 ESPON TIA Quick Scan tool
Erich Dallhammer, Austrian Institute for Regional Studies and Spatial Planning
10:45 – 12:30 Interactive discussion on potential benefits of Developing Minimum Quality
Requirements for Reused Water in the EU with respect to the development
of regions?
§ Dealing with cause/effect chains
§ Defining the types of regions affected and estimating the intensity of the
regional exposure
12:30 – 13:30 Lunch Break
13:30 – 14:30 Interactive discussion on potential benefits of Developing Minimum Quality
Requirements for Reused Water in Agricultural Irrigation and Aquifer
Recharge with respect to the development of regions?
§ Discussion on the findings, results and hypothesis
14:30 – 15:30 Policy recommendations
15:30 – 15:45 Summing up the results, feedback, discussion on options for further
improvements
132
Annex 2:
Description of the indicators used and regional sensitivity
Following the interactive discussion among experts, the following indicators were selected and
introduced into the ESPON TIA Quick Check model:
Agriculture depending on irrigated land
Definition of sensitivity Regions where agriculture is depending stronger on irrigation are
expected to be more sensitive towards policy proposals changing
the precondition for irrigation.
Description Share of irrigated land of utilized agricultural area
Source EUROSTAT
Reference year 2005
Original Indicator
Spatial Reference
NUTS2, 2006
Regions facing danger of droughts
Definition of sensitivity Regions showing a higher danger of droughts are expected to be
more sensitive towards policy proposals aiming at reducing
negative effects of water scarcity.
Description The sensitivity of a region facing danger of droughts is measured by the
probability of forest fires.
Source ESPON project 1.3.1 “Spatial effects of natural and technological
hazards.”
Reference year 1997 – 2003
Original Indicator
Spatial Reference
NUTS2, 2006
Regions facing heat waves
Definition of sensitivity Regions showing a higher chance of heat waves are expected to
be more sensitive towards policy proposals aiming at reducing
negative effects of heat waves than others.
Description days over 30 °C per year
Source E-OBS
Reference year 1995
Original Indicator
Spatial Reference
NUTS2, 2006
Pollutants in soil and ground/surface water
Definition of sensitivity The sensitivity of a region towards policies affecting the pollution
of soil and ground and surface water is measured by a proxy
indicator taking into account the population density and the
employment density. Regions showing a higher density of land
use are expected to be more sensitive towards policy proposals
aiming at a reduction of soil and water pollution.
Description Population plus employment divided by the area of a NUTS Region is used
as a proxy for high density land use
Source EUROSTAT; ÖIR calculation
Reference year 2011
Original Indicator
Spatial Reference
NUTS3, 2010
133
Added value in agriculture and forestry
Definition of sensitivity Regions where agriculture and forestry have an important share
of the GVA are expected to benefit more from directives
stimulating the added value in agriculture and forestry than
others.
Description Share of agriculture and forestry in GVA
Source EUROSTAT
Reference year 2010
Original Indicator
Spatial Reference
NUTS2, 2006
Economic growth
Definition of sensitivity Regions with lower GDP per capita were expected to benefit more
from directives aimed at GDP growth increase and that
inadvertently harm economic growth. Sensitivity is thus inversely
proportional to the level of GDP per capita
Description Gross domestic product (GDP) at current market prices; Purchasing
Power Standard per inhabitant
Source EUROSTAT
Reference year 2011
Original Indicator
Spatial Reference
NUTS3, 2010
R&D Climate
Definition of sensitivity Regions with greater share of enterprises engaged in product
and/or process innovation activities are considered to be more
sensitive to directives influencing innovation.
Description Total intramural R&D expenditure (GERD), all sectors as a percentage of
the GDP
Source EUROSTAT
Reference year 2011
Original Indicator
Spatial Reference
NUTS3, 2010
Employment in agriculture and forestry
Definition of sensitivity Regions with a greater share of employment in agriculture and
forestry are likely to be more affected from changes in the level of
employment in this sector of employment resulting from a
directive.
Description share of employment in the sectors agriculture and forestry
Source EUROSTAT, LFS, ÖIR calculation
Reference year 2014/15
Original Indicator
Spatial Reference
NUTS2, 2006
134
Healthy life expectancy at birth
Definition of sensitivity Regions in which the life expectancy is lower are expected to
benefit more from policy measures effecting its increase and
more negatively influenced by those which decrease it.
Description Life expectancy at a given age (less than one year)
Source EUROSTAT
Reference year 2012
Original Indicator
Spatial Reference
NUTS3, 2010
Out-migration/brain drain/“shrinking” of regions
Definition of sensitivity Regions experiencing Out-migration/brain drain/“shrinking” of
regions will benefit more from actions aimed at their reduction or
suffer most from their exacerbation.
Description net migration balance (i.e. immigration minus out-migration on total
population).
Source EUROSTAT
Reference year 2012
Original Indicator
Spatial Reference
NUTS3, 2010
Government effectiveness
Definition of sensitivity Regions with low government effectiveness as measured by the
Regional Competiveness Index will benefit more from the
implementation of new standards of administration than regions
that already have high standards of their administration.
Description EU Regional Competiveness Index 2013
Source DG Regio project on QoG
Reference year 2009
Original Indicator
Spatial Reference
NUTS3, 2010
Definition of additional indicators
During the TIA quick check it is possible to identify additional fields of exposure, which are affected by
the policy proposal and which are not provided by the tool as standard. Whereas the exposure caused
by the policy proposal could be judged by the experts during the workshop, a valid indicator for
describing the sensitivity of regions needs to be defined in advance. The TIA quick check offers the
possibility to upload new indicators. It provides a template, where for each NUTS 3 regions the values
of the indicator can be to be filled in.
For the new indicator it has to be defined, whether the exposure field needs to be evaluated as being
either harmful (“cost”) or favourable (“benefit”) for the regions welfare. Then the tool will automatically
transform the experts rating into numbers for further calculation (= normalisation).
135
Normalisation of indicators
The normalisation follows a linear procedure. Normalised values range from 0.75 up to 1.25. Basically,
normalized sensitivity indicators represent coefficients that can increase (if greater than 1) or decrease
(if lower than 1) each policy proposal’s impact on a specific field.
Methodology for normalisation of regional sensitivity values
Source: ESPON TIA Quick Check Moderator’s Guide and Methodological Background
136
Annex 3: The situation on the ground. Collection of replies of
experts to questionnaire on waste water practices
Following the interactive discussion among experts during the workshop a series of questions
were addressed in written afterwards to the participants in an effort to get a better idea
regarding the situation on the ground around Europe regarding the:
 experience with water scarcity and water reuse
 potential for further uptake of water reuse and identified barriers
The following replies were received in written and are input from only a few of the experts
that participated in the TIA workshop and represent their expert opinion and provide us a
better idea of the situation on the ground. We observe that there is consistency between the
input we got from the experts as reply to the detailed questionnaire and the conclusions of the
TIA.
Experience with water scarcity and water reuse
 Does your country/region/city face drought and water scarcity issues? What are
the impacts, which are the impacted water uses and associated costs on water uses?
In Greece approximately every 4-5 years there is a strong water stress on regional level in
agricultural areas of Thessaly and Macedonia. The impacts are expressed in terms of yield
decrease, and underground water losses due to considerable lowering of the water level, with
the serious losses of the farmers income.
In Spain and especially in Murcia the climate characteristics with high temperatures all year
round and the decrease of rainfall which is less than 4 hundred millimetres per year will
intensify water scarcity. Murcia Region is in permanent drought. Annual rainfall is 300-350
mm, which is very low. The impact is very high, because agriculture is one of the most
important sectors in the region.
Murcia has a complicated orography, because most of the territory is in a flat valley, and there
are more than 180 pumping stations consuming energy to gather or collect sewage water and
there are 15 Waste Water Treatment Plants and a long network of sewage pipes (1500 km).
These are the reasons why water in Murcia is more expensive than in the rest of Spain, with
prices being at a similar level as in the Canary Islands.
The Algarve region in Portugal occasionally faces scarcity situations owing the precipitation
regime. According the Water Exploitation Index (WEI+), the region presents a moderate
scarcity (27%). The storage capacity, namely in dams, allows the region to face droughts
without significant impacts on socioeconomic activities except in specific situations of
extreme droughts. The last extreme event was in 2005 and at that time it was necessary to
restrict the water abstraction for agriculture irrigation. Other measures are also to reduce the
water consumption in public supply and tourism activities. The impacts were not higher since
the year 2006, which was a rainy one which allowed the natural aquifer recharge and the
augmentation of surface storage.
The cost impact in 2005 for Algarve was significant due to the construction of infrastructures
that ensured the use of several water sources for public supply and the increase of the
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treatment costs since some lower quality water sources had to be used. Other impacts were the
reduction of some crop production due to irrigation constraints.
The general weather pattern in Romania is 2 dry years in a period of 10 years, but this pattern
is changing due to the global climate change. So Romania is facing drought and water scarcity
issues more often. Even in the normal weather years, there are areas confronted with local
drought and water scarcity. Impacts are low water on the big rivers, including Danube,
sometimes no water at all in the small rivers and lowering of the water table in the shallow
aquifers. The impacted water uses are agriculture, drinking water supply, industrial water
supply and ecosystems. The associated costs on the agricultural sector are calculated by the
assurance companies and can be quite high, but the other water uses are not yet calculated.
The problem of draughts and water scarcity is of less importance in Germany that uses just
13% of its available water resources on average and is thus overall not facing water scarcity.
Due to sufficient precipitation in the major part of the country there is also little need for
irrigation – only around 1.5% of the overall water abstractions has been used for irrigation in
2012. In some regions, especially in the North-East of Lower Saxony, water scarcity is a
crucial issue for agriculture. Experience with water reuse is available in the area of
Braunschweig and Wolfsburg in the Lower Saxony. Agriculture is interested in realizing
further projects of water reuse.
Despite this, potential additional water needs for irrigation on a local level are addressed by
efficiency measures (e.g. technical measures or adaptations in cultivation practices) or by
adaption of irrigation schemes. Periods of water scarcity causing impacts to human uses are
rare in Germany. No costs and impacts are known on a national scale.
 How do you foresee this situation will evolve in the medium term?
Taking into account the climate changes and the increase of irrigated agriculture, the problem
is expected to become more acute in Greece and Spain.
In Algarve/Portugal in a medium term significant impacts from water scarcity are not
expected as a result of the construction of a new dam in 2012 that improved water availability
in the region with an augmentation of 157 hm3 in storage volume. With this volume increase
and the current management practices the regional authorities do not anticipate significant
impacts from water scarcity, However, all agree that some uncertainties are related to this
situation such as the climate change scenarios with prevalence to extreme events and
abnormal increasing of water consumption due to a change in the dynamic of economic
activities (e.g. increase in tourism rates and agriculture production).
In Romania there are some climate change scenarios developed by the National Institute for
Hydrology and Water Management which show that in 30, 50 and 100 years period the
extremes will accentuate (floods and droughts more severe).
Germany’s water supply is considered secured in the long run. Nevertheless due to climatic
changes the duration and frequencies of draughts can regionally increase in the future. This
may lead to higher irrigation needs or challenges for cooling water supply in the energy
sector. Overall water usage in Germany has been continually declining in the last years, with
the exception of irrigation. In some regions, irrigation of agricultural products will increase.
 Which are the measures presently implemented or planned for the close future in
your country/region/city? Do these measures include development of additional
water supply infrastructures and which are these? Are these measures included in
a water scarcity plan?
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One basic measure in Greece is the gradual abandonment of the old traditional methods of
irrigation and their replacement by drip irrigation of crops. The construction of small dams
and small basins in drought afflicted areas such as in the islands for water collection, the use
of resistant varieties to water stress. And all these measures are included in the water scarcity
plan.
In Spain Portugal and Germany more attention is paid to managing the water demand and take
measures to increase savings, water efficiency and promote good practices.
According to the experts from the city of Murcia they pay more attention to managing the
water demand and take measures to increase savings, water efficiency and promote good
practices as a way to anticipate droughts. Before applying water supply solutions to deal with
water scarcity, all opportunities for managing and reducing demand must be exhausted. The
city of Murcia contributes by making more efficient use of water. In order to avoid the risk
that a more efficient use will result in a greater demand for the resource, it is imperative that
measures to increase efficiency are accompanied by measures that ensure the sustainability of
water use by ensuring that the water saved remains in the natural systems .
 Improvements in the water distribution network. Having a hydraulic yield of 86%.
 Promotion of the reuse of waste water, reducing pressure on watersheds. Reused waters
should not be considered new resources but alternative resources.
 Establish an urban irrigation network with regenerated water from the WWTP, thus
avoiding the depletion of the surface aquifer of Vega Media del Segura.
The city of Murcia has an emergency plan in case of drought situations and for the future they
aim at
 A reuse of waste water for the irrigation of parks and gardens of the City of Murcia.
Achieving a recovery in the surface aquifer of the Vega Media of Murcia, avoiding
desalted water consumption with greater environmental impact and high energy use.
 Plan more green areas in the city as sustainable urban development.
 Continue to work on leaks, to achieve the highest possible yield in the distribution
network.
 Reuse of waste water in agriculture, promote this measure, so that irrigators see the
benefit and stop using desalinated water for irrigation, which is inefficient and costly.
Murcia region uses all the water sources that are available (Surface water, groundwater, water
from other basins, reclaimed water, desalinated water). Most of the Waste Water Treatment
Plants (WWTPs) in the region have tertiary treatment and there is also a big desalination
plant. The region will need to build tertiary treatments for all WWTP and build more
desalination plants.
In Algarve/Portugal the core existent and previewed measures are related with the water
demand management, through the promotion of an efficient water use, reduction of losses and
public campaigns to improve the consumption. The construction of new infrastructure (dams)
is not foreseen. However, some investments are to optimize the existent ones and to integrate
the existent uses of ground and surface water sources. These measures are described in several
plans at national level (such as the National Program for the Water Efficient Use PNUEA and
the Strategic Plan PENSAAR 2020) and at regional level (such as the River Basin
Management Plans and contingency plans from the water supply management company). In
addition the use of other sources, such as water reuse, is increasing with potential to improve
its uptake and is included in the River Basin Management Plans.
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In Romania emphasis is put in water saving campaigns developed by municipalities; and
implementing new water supply infrastructures, mainly in rural areas. In addition water
supply restrictions plan is activated during water deficit periods, approved by ministerial
order.
In Germany water abstraction requires legal permit. Register of water rights and monitoring
schemes for water level control are in place. Increasing water demand is mostly met by
demand management, especially measures to increase efficiency.
According to the German climate adaptation strategy the following measures can be
considered following a thorough assessment
 usage of grey water, rain water or process water for technical and industrial purposes
not requiring drinking water quality
 further development of water saving methods especially in commercial and industrial
production processes
 prevention of water losses in the distribution network
 more efficient cooling in power station
 reduction of water losses in agricultural irrigation
 use of highly treated waste water that is safe for health and environment for irrigation
The focus of administration bodies of Germany is on demand management measures. Private
activities may include additional infrastructures such as advanced irrigation techniques or
rainwater storage. For public water supply alternative strategies are considered for potential
water shortages (e.g. contingency interconnections of separate water supply networks,
redundant distribution of water abstraction sites, use of groundwater close to surface).
There is no national water scarcity plan in Germany. Local low water management plans are
in place in some regions and they are based on a prioritisation of water uses. Measures depend
on local circumstances.
 How equipped with waste water treatment facilities is your country/region/city? To
which extent and for which uses?
There seems to be fairly good infrastructure for waste water treatment in the EU. For example
in Greece currently about 320 Waste Water Treatment Plants operate at a national level where
the wastewater is being treated at the second degree.
In the region of Murcia in Spain WWTR cover 99,3% of the population and in the City of
Murcia in Spain there are 54 small population centers that are interconnected by a sewage
network of 1,800 km and 15 waste water treatment plants. The municipal sewage treatment
plants of Murcia have biological treatments, MBR treatments and as tertiary disinfection is
used in some of them, achieving limits suitable for the uses named in the REAL DECREE
1620/2007, of December 7, establishing the legal regime for the reuse of purified water.
Current uses are agricultural, recreational, environmental use and public stream.
Portugal has a high level of urban waste water treatment facilities which cover 90,3% of the
population. Algarve region has one the highest rate of urban treatment facilities, about 95% of
the population is covered by drainage and treatment facilities. The industrial wastewater
production in Algarve is not significant and the majority of these are related with services and
commercial activities connected to urban systems.
In Romania they are working to implement Water Treatment Directive for all the localities
over 2000 equivalent inhabitants, but still we have a tremendous work to do in order to
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provide secondary and tertiary treatment facilities for urban waste water treatment,
particularly in rural areas where the level of endowment with waste water facilities is quite
low. On the other hand, food and other industries are obliged by law to treat their waste water
in order to retain pollutants, so they are well equipped.
Germany has a very high level of waste water treatment. More than 91% of the installed
treatment capacities can be attributed to large treatment plants serving more than 10000
population equivalents. Compliance with UWTTD 100% (Art 3 and 5), 99.9% for Art 4.
Phosphorous and nitrogen removal of German WWTP exceed the requirements of the
UWWTD. Wastewater treatment is almost exclusively through biological waste water
treatment (> 95% activated sludge process and removal of nitrogen and phosphorous).
Some Länder have added a so-called fourth treatment level in the UWWTP to eliminate micro
pollutants, e.g. in sensitive areas. On a national level a micro pollutant strategy is in progress
which will likely encourage further extension of treatment plants with additional treatment.
 Do you already engage in regional cooperation for this issue? Would smaller
municipalities consider entering into an agreement with larger municipalities
within the same region for the collection and handling of waste water?
Some smaller communities in Greece may cooperate with larger municipalities for the
processing of the wastewaters.
The regional government in Murcia/Spain created ESAMUR, the public body of regional
government which mainly guarantee the right operation of the waste water treatment plants in
the whole region of Murcia. There is a high regional cooperation. Primary network drinkable
water in all the region is managed by a public Company, and the same for WWTP.
This was already done in Algarve region in Portugal (Study “Algarve Saneamento Básico
anos 2000”), where, near the coastline, the smaller urban systems were included in larger
sewage treatment plants. However, in the inland municipalities with a low population rate,
due to the distance and n.º of inhabitants the system integration is not feasible. On the other
hand, some of these small wastewater treatment plants are located near agricultural areas and
local solutions for the treated wastewater reuse may present best options.
In Romania regional operators for drinking water supply and urban waste water treatment are
established and working.
In Germany facilitation of co-operation and - in some occasions - of fusion of WWTPs is part
of the counseling and funding activities of some regional governments.
 How informed are citizens in your region regarding the reuse of waste water?
What is their perception about this practice?
The wastewater reuse in Greece is in the process of experimentation. For the time being
Greece has sufficient water to cover the various uses for crop irrigation, industrial use,
domestic use etc. However the periodic water stress appearing rings the bell for the near
future increased water demand, and therefore, the research that is currently in progress aims at
establishing the basis for the safe waste water and environmentally oriented research on
wastewater reuse.
The Greek citizens have not so far systematically been informed regarding reuse. No serious
effort so far has been put towards this direction, since the reuse of the wastewater in Greece is
not included in the irrigation practices. However, it must be mentioned that the treated
wastewater has occasionally been reused for irrigation of non-food crops, such as for cotton at
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the periods of water stress in the plain of Thessaloniki, which corresponds to a very small
percentage in relation to the total amount of natural water used for irrigation. This practice
necessitates only the users.
The citizens of Murcia are very aware of any issue related to water, these are informed by
both the City Council and the Autonomous Community of anything that has to do with
scarcity and reuse of water. Farmers are most knowledgeable regarding the reuse of waste
water issues. The farmers in Murcia ask for their concessions of reuse water to the
administration. Currently of the 15 WWTP managed by Aguas de Murcia, 9 of them have a
reuse concession, although the volume is low because the treatment plants that have adequate
treatment are very small.
The level of information in Algarve/Portugal may not be high but according the
characteristics of the region, from a general point of view, the reuse practice is well accepted.
However, at local circumstances, namely in some touristic activities in the coastline, the
perception could be negative when other water sources are available (e.g. groundwater with a
low price compared with the treated wastewaters, which has transport and monitoring costs
for end-users).
The level of information to citizens regarding reuse of waste water in Romania is low. It is
mentioned however during the water saving campaigns. The perception is not favourable
particularly due to the health safety concerns.
Due to the fact that in Germany - apart from two sites reuse of water - reuse of water is not
practiced it is difficult to assess the perception of citizens. As there is no need for alternative
water sources on a large scale, it can be expected that acceptance by citizens is limited (this
was also evident in pilot studies e.g. KLIMZUG NORD).
Potential for further uptake of water reuse and identified barriers (to be addressed
separately for agriculture irrigation and aquifer recharge)
 Do you see a potential for further uptake of water reuse in your
country/region/city for agriculture irrigation/aquifer recharge? For other uses?
Who would be the beneficiaries? Can you provide an estimate for this potential
and the related benefits?
There seems to be a future increased potential in Greece for uptake of wastewater reuse in
agricultural areas, since reused water is a good source of plant nutrients and therefore it can
replace the fertilizers. The increase of demand for irrigation water and expected extension of
the irrigated agriculture results from the ever increasing demand for agricultural products and
especially biological products. In addition the reuse of aquifer recharges can be useful during
the water stress periods when the level of the underground water is being lowered in Greece.
It is anticipated that in Greece the beneficiaries will be the farmers, the consumers and of
course the environment. For the time being, an estimate could be misleading due to the lack of
actual data.
The reuse of water in Spain/Murcia is one of the axes of the development of the circular
economy. Freshwater resources are increasingly low, with a disturbing mismatch between
demand and availability of water resources at both a temporal and geographical level. In this
context, the ability to respond to increasing risks of water scarcity and drying could be
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enhanced through greater reuse of treated wastewater. Adopting a series of measures to
promote the reuse of treated wastewater, such as agriculture irrigation and also for garden
areas, golf courses, urban uses and groundwater recharge, as well as investing in tertiary
treatments to obtain water quality according to the EU minimum requirements are important.
The total water consumption in the Algarve region is about 200 hm3
per year and the annual
urban wastewater production as average around 40 hm3
, with the major production volumes in
dry season, when the water demand is higher. However, the potential increase for water reuse
should be more related with urban and recreational uses according the population distribution
and the touristic character of the region. The aquifer recharge in Portugal is not foreseen since
is not allowed according the Portuguese law. At national level, there is a potential for further
uptake of water reuse for agriculture irrigation but in other regions rather than Algarve.
In Romania they foresee good potential for water reuse for agriculture irrigation of not eatable
crops (textile and biofuel crops) and for cities green areas irrigation within dry periods.
Romania has good quality groundwater bodies (in large aquifers), in good quantity status,
used as drinking water sources, and they are very careful to preserve their status.
Beneficiaries in Romania will be not only farmers, but all citizens, because the reused water
quantities will reduce restrictions during droughts.
In Germany there is no general need for alternative water resources in irrigation and aquifer
recharge. An analysis showed that in most German regions the agricultural irrigation demand
can be covered by available water resources without compromising the quantitative
groundwater status. There are only a few districts in the Luneburg Heath and Upper Rhine
lowlands that could benefit from additional irrigation with treated wastewater to stabilize their
quantitative groundwater status (Seis et al, 2016).
Considering the potential risks of waste water reuse, the focus is on increased efficiency in
case of temporary and regional shortages.
Since irrigation water is partly taken from surface waterbodies it already contains some of the
treated waste water released into these river courses. Germany is focusing on a good waste
water quality, so that the waste water can be discharged in surface water again. Releasing
treated wastewater into rivers and streams provides for ecological minimum flows even in
periods with low water levels.
The shift from combined sewer to separate wastewater/rainwater sewers introduced by federal
law in 2010 leads to new opportunities to deal with collected rainwater in a way that also
supports the local water cycle.
 Which barriers to a wider uptake of water reuse solutions for agriculture
irrigation/aquifer recharge do you identify in your country/region/city? Can you
rank them according to their importance?
The reluctance of the Greek public opinion towards the reuse due to perceived health risk
effect and the fact that there is currently a relative sufficiency of irrigation water available in
the country due to other techniques (river dams, artificial lakes for the collection of rain water
etc). According to the experts from Murcia if the new minimum requirements would be more
restrictive than the previous ones this will result that in some regions of the EU there will be a
need to invest in existing and new waste water reuse treatments to reach the new
requirements, which will lead to adoption of extraordinary charges for the local communities.
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In Murcia region they perceive as the main barrier for agricultural irrigation the perception of
other EU countries consumers, that don´t have confidence in the reclaimed water quality
because of lack of knowledge about it .
In Murcia City they perceive as barrier the new investment that they anticipate as needed to
comply with the new minimum quality requirements for reused water
in agricultural irrigation and aquifer recharge that according to their estimates would amount
to 870,000 € per 1 Hm3/year. At this cost they add the infrastructures needed to bring the
reused water from the plant to the gardens (building a new irrigation network for water urban
gardens: 5.950.000€.)
In Algarve/Portugal the following barriers have been identified:
 Distances between the point of production and point of end-use;
 Public authorities acceptance (e.g. health, agriculture and municipal authorities);
 Costs associated with some need to increase the treatment level and monitoring;
 Public acceptance (namely, when other water sources are available at a lower price,
such as groundwater).
From a Romanian point of view a legislative barrier may arise since the prevention principle
is basic for both environmental and health legislation (minimum quality requirements for
water reuse should reflect this concern and guarantee the safety of reuse). On the other hand
WFD do not allow the injection of waste water into the aquifers. In addition they consider the
price as potential economic barrier. Good quality water should be available at a low price.
Water monitoring costs will increase. Last but now least according to the Romanian expert
citizen’s acceptance (as consumer of goods irrigated with reused water and drinking water
from the aquifers) is very low.
As there is no general need for water reuse in Germany, one cannot speak about “barriers” to
its uptake. There is a lack of assessment criteria for unregulated substances that might be
present in wastewater such as pollutants or microbiological contaminants that can impose a
threat to groundwater quality when used for recharge or might adversely affect the soil. No
quality standards for agricultural products irrigated with reclaimed water are in place.
 Are there minimum quality requirements for water reuse that apply to
agricultural irrigation/aquifer recharge in your country/region/city? Do you
consider them appropriate as regards health and environment safety? Do you
consider them a barrier to a wider uptake of water reuse and why?
In Greece there are no official minimum quality requirements for reused water. The ones that
exist are far from being minimum. The existing guidelines cannot help the farmer to
accomplish the so called “safe reuse” as the health risk so far, has not been possible to be
faced successfully. For the time being the wastewaters are not used for aquifer recharge in
Greece. The minimum requirements, especially with regard to the wastewater heavy metal
concentration are not considered appropriate as regards health and environmental protection.
Spain already has a regulation to regulate the requirements of the purified water for its reuse
according to the different uses, called Royal Decree that establishes the legal regime of the
reutilization of reclaimed waters. According to the Murcia Region expert the requirements
they have are considered adequate to assure health and environment safety, because to their
knowledge there were no epidemiological problems in all these years anywhere. They believe
that stricter conditions - if they are affordable - can improve the consumers' confidence. The
min. quality requirements may become a barrier if they are stricter that the ones already in
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place in Spain since the treatment price will become a barrier, but food health is also
important according to the Murcia Region expert.
In Portugal there are national standards for waste water but they are not binding. However, a
permit is needed for water reuse and in that procedure binding quality standards are applied in
a case-by-case approach according the use, the barriers in presence, the
vulnerability/sensitivity of the surrounding environment (soils and water bodies) and the risks
to public health and environment (and crops in agriculture irrigation). In resume, binding
values are defined in permits through a fit-for-purpose approach.
There no minimum quality requirements for water reuse that apply to agricultural
irrigation/aquifer recharge in Romania. For the time being there is no treated waste water
reuse in agriculture irrigation and aquifer recharge in Romania and there are no minimum
quality requirements in place. At this stage (JRC study) Romania considers setting quality
requirements for reuse of waste of water as problematic/not appropriate as regards health and
environment safety, especially concerning aquifer recharge.
In Germany precautionary principle and prohibition of deterioration (WFD, GWD) are
guiding principles for water resource management. There are no explicit quality requirements
for water reuse as there is no overall need for this practice. There are norms for hygienic
aspects of any irrigation water (DIN 19650) not specifically addressing reclaimed water.
For groundwater recharge quality thresholds of the Groundwater Ordinance (GrwV) would be
the yardstick. Groundwater recharge would need a permit complying with national and federal
water rights. In due course of issuing a permit, § 48 WHG and local circumstances will
require an in-depth assessment and will lead to individual preconditions for the recharge
activity.
The Federal Soil Protection Act and the Federal Soil Protection and Contaminated Sites
Ordinance have the purpose to sustainably secure or restore soil functions. Negative effects on
soil must be avoided, and such negative effects on soils must be rehabilitated.
 Does size and geographic location of the municipalities/regions provide barriers to
effective enforcement of the minimum requirements? How is your region/city
handling the requirement of certifying the quality of the waste water and
monitoring the respect of the minimum requirements, if any?
According to the Greek expert the size of the Municipality could provide barriers for effective
enforcement of the minimum requirement. If is something that the expert from Murcia Region
shares as an opinion since for a small WWTPs is difficult to guarantee too strict requirements.
A differentiated approach for small size WWTPs should be taken into account. In addition
according to the Greek expert the geographic location may impose barriers if the waste water
treatment plant is far away from the site of wastewater application as it may increase the cost
of transportation.
In Spain the minimum requirements are controlled by the Health Authority and also Regional
Sanitation Authority controls the correct operation of the facilities.
Size of municipalities and geographic location of waste water treatment plants in Romania
were not studied related to water reuse.
 Do you think the difference in minimum quality requirements across the EU is a
barrier to a wider uptake of water reuse? If so, why do you consider differences in
minimum quality requirements between Member States as a barrier?
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The Murcia city and region experts in Spain consider that differences in the requirements for
reuse of reclaimed water can be an important barrier to the export of agricultural products and
therefore agree with the proposal of DG ENV to set EU min. quality requirements. The same
applies for Romania.
Algarve/Portugal consider that the difference in minimum quality requirements across the EU
could only be a barrier to some public perception, since, for someone this aspect could present
a suspicion about lower quality practices. This aspect also is a concern in Romania.
In Germany there is no wider uptake of reuse due to the low necessity.
 Do you see a need for complementary measures, like information campaigns to
inform citizens to reach better acceptance of water reuse?
Greek, Spanish and Portuguese and Romanian experts consider necessary to inform the
society about the reuse of wastewater by organizing systematic campaigns. Citizens are able
to understand everything if they are well explained. Information campaigns for general public
and dedicated campaigns/technical workshops for specific public (such as end-users, public
authorities, NGO) could be delivered to improve knowledge and subsequently a better
understanding of the practice and its acceptance. Citizens visits to wastewater treatment plants
where they can see the work and the quality of the reclaimed water can change their
perception of it.
According to the Murcia experts the inclusion of the word minimum in the title of the new
initiative should be reconsidered mainly for two reasons:
 The new draft is more restrictive than the majority of state legislations for the reuse of
reclaimed waters, so they would not be minimum requirements.
 The citizen's perception of the word minimum does not generate enough confidence,
and would be detrimental to the necessary awareness and support of citizens to reuse
water.
In Germany they do not consider any need for any complimentary measures due to lack of
need to use reused water.
Impact of an EU initiative to promote water reuse (to be addressed separately for
agriculture irrigation and aquifer recharge)
 What do you think would be the best appropriate approach(es) of the European
Union to promote water reuse in the EU ( please rank them):
_ Impose water reuse to Member States, e.g. by setting targets to be achieved
_ Establishing a common approach to water reuse across the EU by setting
common minimum quality requirements
_ Provide recommendations and guidance but leave Member States the entire
responsibility to decide on the development of water reuse and minimum quality
requirements
According to the Greek, the Algarve and Romanian experts the best appropriate approach for
the EU would be to provide recommendations and guidance but leave Member States the
entire responsibility to decide on the development of water reuse and minimum quality
requirements according to their needs, tradition and social habits, Specific parameters and
monitoring requirements need to be determined according the location and the purpose.
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Therefore, the opportunity to deliver specific conditions at a River Basin level or at a case-by-
case are required.
The German expert also considers option 3 as the most appropriate. As there is no acceptance
for imposing water reuse – the necessity for it, its risks and conditions differ highly within the
EU, thus implementing reuse should be decided within member states on the basis of
necessity and site-specific conditions. Recommendations and guidance might help in regions
with more frequent water scarcity issues. A guidance document that outlines a common
approach to set appropriate minimum quality requirements that takes into account site-specific
risks is more appropriate from a German point of view. However considering inter-European
trade of agricultural products minimum requirements would have to meet a high standard to
preserve food safety.
For the Murcia Region expert the best would be to establishing a common approach to water
reuse across the EU by setting common minimum quality requirements. If this is not possible
their second preferred option would be as in the case of Greek and Portuguese expert the
option where the EU provides recommendations and guidance but leaves to Member States
the entire responsibility to decide on the development of water reuse and minimum quality
requirements.
In the case of option 2 the German expert underlined the need for very ambitious standards
which should exceed existing legislation to ensure that reuse is safe for health and
environment within the whole EU (including emission limit values!). Attention needs to be
given to the highly differing quality of urban waste water (e.g. due to the share of industrial
waste water being released into UWWTP and due to the level of treatment).
 To which extent do you think EU Minimum Quality Requirements for Water
Reuse in Agricultural Irrigation/Aquifer Recharge would help increase the uptake
of water reuse in your country/region/city?
According to the Greek expert to a relative extent since the requirements to his opinion will
not help essentially to minimize the health risk effect, especially if the allowed levels for
example of heavy metals remain high
According to the Algarve/PT expert the definitions of wide requirements instead of very strict
values with guidelines and helpful campaigns would increase the confidence on the practice
and promote its appliance.
The uptake will increase in Romania , but its extent is difficult to be foreseen. From a German
point of view the uptake is related to the need and therefore since the need is low to zero EU
minimum quality requirements will not have an impact on the need for water reuse.
 To which extent do you think the above options, in particular the EU Minimum
Quality Requirements for Water Reuse in Agricultural Irrigation/Aquifer
Recharge would be a cost-effective means to increase the uptake of water reuse
and therefore to tackle water scarcity in your country/region/city?
Algarve/PT same as above.
Murcia region expert considers that there is a close correlation between the price of the
necessary treatments. The Greek expert was not able to reply on this due to the lack of
available data. In Romania the relationship of cost/efficiency is not clearly defined concerning
Minimum Quality Requirements for Water Reuse in Agricultural Irrigation/Aquifer Recharge.
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No impact is expected according to the German expert. Cost-effectiveness of reuse will
mostly occur, if at all, in the long run since distribution networks would have to be built from
the scrap. Due to the precautionary principle, aquifer recharge would require such a high
quality of the reclaimed water that there is no overall cost- effectiveness expected at all.
 In what way would EU Minimum Quality Requirements for Water Reuse in
Agricultural Irrigation/Aquifer Recharge affect your country/region/city?
According to the Algarve/PT expert if the EU Minimum Quality Requirements and the
monitoring procedures are too strict and too long, respectively, the costs involved could be
very high and difficult to support. Also the definition of long lists of parameters and strict
values may cause some suspicion about the risk of the practice and jeopardize public
acceptance.
Same concern was expressed by the Murcia City and Region experts that underlined that if the
requirements are not affordable and their tertiary treatments aren´t able to get these values, the
uptake will be lower due to price.
From a Romania perspective if DG ENV proposes a directive, it must be transposed and
implemented by every MS, so national authorities could be forced to approve reuse in every
case when minimum quality requirements are met, and this could jeopardize the objectives of
other directives (Water Framework Directive, Groundwater Directive, Drinking Water
Directive, Nitrates Directive).
From a German point of view this depends on the level of the requirements. Higher uptake of
reuse could pose a threat of increased environmental pollution of soils and groundwater unless
there are strict and ambitious standards for water reuse. Past experience with waste water
earth catch areas (“Rieselfelder”) show high levels of contamination of soils and agricultural
plants grown there.
 How would citizens react to EU Minimum Quality Requirements in Agricultural
Irrigation/Aquifer Recharge?
According to the Greek expert probably positively. But as far as Greece is concerned, since
reuse waste water is not a routine this question cannot be accurately addressed.
According to the Algarve/PT expert if there is a long lists of parameters and strict values are
presented that may cause some suspicion about the risk of the practice and jeopardize public
acceptance. But some wide requirements with guidelines and helpful campaigns would
increase confidence in the practice.
The Murcia Region expert assumes that it will depend on the values of the requirements, with
the necessary price for the treatments and the information campaigns to explain the changes
about the actual situation.
Negative reactions are to be expected in Romania. In Germany reactions would depend on the
level of standards, the kind of legal instrument and local conditions. In general little
acceptance within the citizenship is expected.
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Annex 10 - International trade dimension
Today, the planned used of treated wastewater is a common practice in countries of the
Middle East and North Africa, Australia, the Mediterranean, as well as in Mexico, China and
the USA (AQUASTAT, n.d.b.). However, there is no comprehensive inventory of the extent
of treated or untreated wastewater used in agriculture, apart from the incipient efforts by
institutions like AQUASTAT (n.d.b.). Inadequate wastewater treatment and the resulting
large-scale water pollution suggest that the area irrigated with unsafe wastewater is probably
ten times larger than the area using treated wastewater (Drechsel and Evans, 2010)15
.
Many different approaches are practiced to mitigate potential health risks resulting from
treated wastewater used for irrigation. WHO Guidelines for the Safe Use of Wastewater,
Ecreta and Greywater in Agriculture (WHO, 2006a) acknowledge the potential health risks of
wastewater with no or inadequate treatment, and the necessity to reduce such risks. However,
in developing countries, strict water quality standards for reuse are often perceived as
unaffordable and therefore fail in practice.
Setting minimum quality requirements and a risk assessment approach for water reuse at the
EU level is assumed to result in positive impacts on the international trade with third
countries, as the European producers would rely on a safe and sustainable water supply option
leading to a more sustainable agricultural production. In addition, European products could
benefit from a comparatively good reputation as minimum quality requirements would ensure
adequate safety of the products. A harmonised approach for all EU Member States would
contribute towards a more informed and safer consumer choice, with positive impacts for both
the Internal Market and internationally. The impacts on competition with imports from third
countries are expected to be neutral, however, assuming absence of "subsidisation" for reused
water, negative impacts could be expected where the price of agricultural production increases
as a result of water reuse.
There is a rapidly growing world water technology market, which is estimated to be as large
as EUR 1 trillion by 2020. By seizing new and significant market opportunities, Europe can
increasingly become a global market leader in water-related innovation and technology (EC,
2012). According to Global Water Intelligence the global market for water reuse is one of the
top growing markets, and it is on the verge of major expansion and going forward is expected
to outpace desalination. The EU water reuse sector is maturing both technologically and
commercially, albeit at a slow rate. Given the importance of the water industry sector in the
EU, the past and current spread of water reuse technologies in the EU and worldwide has been
a driver for the competitiveness of this industry sector, and this situation is expected to
continue over the next 10 years. Water supply and management sectors already represent 32%
of EU eco-industries’ value added and EU companies hold more than 25% of the world
market share in water management (EU, 2011) (BIO, 2015). Without any policy measures to
incentivise / support the uptake of water reuse schemes, it is unlikely that the EU water reuse
sector would be maturing at a faster rate. The absence of incentives for further water reuse
would lead to no positive impact on competitiveness and innovation related to water reuse
technologies. Considering the potential worth of this industry, this could lead to a loss of
opportunities for the European market to be a leader on this issue.
15
The United Nations World Water Development Report 2017 "Wastewater the untapped resource".
149
Figure 34: Evolution of 20 top EU Agri-food imports from Extra EU 28, 2012 – 2016
Figure 35: Top EU Agri-food imports from Extra EU 28 in 2016
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Annex 11 – Subsidiarity assessment of potential EU-level regulation of water reuse for
aquifer recharge
As for agricultural irrigation, the use of reclaimed water for aquifer recharge is subject to
existing requirements in EU legislation, in particular:
- the UWWTD, applied to the discharge of urban waste treatment plants to the
environment (sensitive areas, catchments of sensitive areas, non-sensitive areas);
- the WFD, in particular Article 11(3)(f) which requires that artificial recharge or
augmentation of groundwater bodies be subject to prior authorisation and that such
actions do not compromise the achievement of objectives for the groundwater body;
Article 11(3)(j) imposes the ‘prohibition of direct discharges of pollutants into
groundwater’; Article 7 imposes specific protection of water bodies used for the
abstraction of drinking water;
- the Groundwater Directive, in particular Article 6 which states that the inputs of
pollutants that are result of artificial recharge or augmentation of bodies of groundwater
authorised in accordance with Article 11(3)(f) of the WFD may be exempted from
measures to prevent inputs into groundwater of any hazardous substances, provided
efficient monitoring of the bodies of groundwater concerned is in place;
- the EIA Directive, when the capacity of the urban wastewater treatment plant exceeds
150 000 population equivalent, or if the annual volume of water recharged exceeds 10
million cubic meters, or if artificial groundwater recharge is subject to an Environmental
Impact Assessment in application of article 4(2) of Directive 2011/92/EU in the Member
State.
The crucial difference of aquifer recharge relative to agricultural irrigation is that it does not
directly entail any issue linked with the Internal Market.
The associated risks are very much dependent of the nature of the project (characteristics of
the urban waste water to be reclaimed, technique for aquifer recharge) and the characteristics
of the local environment (in particular of the aquifer in terms of its capacity to further
improve reclaimed water quality). Therefore it has been found impossible to derive science-
based minimum quality requirements for water reuse for aquifer recharge in terms of quality
criteria (parameters and limit values) that would need to apply to every project in the EU in
addition to the requirements from the existing legislative framework (cf. Annex 7). However,
similarly to agricultural irrigation, when it comes to ensuring health and environmental
protection, a risk management framework is widely considered the appropriate regulatory
approach for water reuse projects for aquifer recharge, as it can ensure the desired level of
protection against risks while leaving flexibility to adapt to specific conditions.
Based on the above, the most appropriate EU level response is Guidance on the
implementation of a risk management framework for water reuse for aquifer recharge. Given
the local nature of the aquifer recharge practices, the regulation of water reuse for aquifer
recharge should remain the competence of Member States, while ensuring full compliance
with the relevant existing legislation.
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Annex 12 – Comparison of impacts per policy options and per different group of Member States
Options for agricultural
irrigation
Member States with national standards Member States without national standards
National standards more stringent
than proposed
National standards less stringent / different
parameters than proposed
Adoption of proposed EU
standards
Retaining status quo
Baseline (agricultural
irrigation & aquifer
recharge)
Environmental: 0 (increased uptake in Spain but not in other MSs)
Economic/Administrative: - /0 (increased costs of droughts in MSs affected if no action taken)
Social: -/0
Environmental: 0
Economic/Administrative: 0
Social: -/0
Ir3 – Guidance
"fit-for-purpose"
Anticipated uptake:
LOW
If MS choose to retain national
standards
Environmental: 0
Economic/ Administrative: 0
Social: 0
If MS choose to align i.e. lower
national standards
Environmental: +/0
(potential for increased uptake due to
less stringent requirements)
Economic/ Administrative: 0
Social: 0/-
(public acceptance potentially
compromised)
If MS choose to retain national standards
Environmental: 0
Economic/ Administrative: 0
Social: 0
If MS choose to align i.e. increase national
standards
Environmental: +/-
(reduced risks associated with environmental
pollutants present in treated wastewater; Potentially
reduced uptake due to more stringent standards
depending whether cost is passed on to farmer)
Economic: -/+
(increased costs of treatment if more advanced
processes are needed; improved trade and business
opportunities/
Administrative
Risk assessments to be performed but less
monitoring costs potentially)
Social: + (public acceptance boosted)
Environmental: +/0
(increased water availability +
reduced risks associated with
environmental pollutants present in
treated wastewater /no change)
Economic: -/+
(increased costs to farmers or
WWTP operators/ potential for
increased uptake / improved trade
and business opportunities)
Administrative:
administrative burden due to system
to be set up for water reuse
permitting
Social: +
(promotion of public acceptance)
Environmental: 0
Economic/ Administrative: 0
Social: 0
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Options for agricultural
irrigation
Member States with national standards Member States without national standards
National standards more stringent
than proposed
National standards less stringent / different
parameters than proposed
Adoption of proposed EU
standards
Retaining status quo
Ir1 – Legal
instrument
"one-size-fits-all"
Anticipated uptake:
NEGATIVE (under
0,50 Eur/m3 scenario)
If MS choose to retain national
standards
Environmental: 0
Economic/Administrative: 0
Social: 0
If MS choose to align i.e. lower
national standards
Environmental: +/0
(potential for increased uptake
volume due to less stringent
requirements)
Economic/Administrative: +/0
(possible treatment or monitoring
costs savings)
Social: 0/- (public acceptance
potentially compromised)
MS align i.e. increase national standards
Environmental: ++/- -
(reduced risks associated with environmental
pollutants present in treated wastewater;
Reduced uptake volume due to more stringent
standards)
Economic/ Administrative: - -/+ +
(increased costs of treatment if more advanced
processes are needed; improved trade and business
opportunities)
Social: +
(public acceptance boosted)
Environmental: +/0
(increased water availability/
reduced risks associated with
environmental pollutants present in
treated wastewater/ no change)
Economic/Administrative: - -/+ +
(increased costs to farmers/
increased costs for WWTP and
farmers / improved trade and
business opportunities)
Social: +
(promotion of public acceptance)
Environmental: 0
Economic/ Administrative: 0
Social: 0
Ir2 – Legal
instrument
"fit-for-purpose"
Anticipated uptake:
HIGH
If MS choose to retain national
standards
Environmental: 0
Economic/Administrative: 0
Social: 0
If MS choose to align i.e. lower
national standards
Environmental: ++/0
(potential for increased uptake
volume due to less stringent
requirements)
Economic/Administrative: +/0
(possible treatment or monitoring
costs savings)
Social: 0/-
(public acceptance potentially
compromised)
MS align i.e. increase national standards
Environmental: ++/- -
(reduced risks associated with environmental
pollutants present in treated wastewater;
Reduced uptake volume due to more stringent
standards)
Economic/ Administrative: - -/+ +
(increased costs of treatment if more advanced
processes are needed; improved trade and business
opportunities)
Social: +
(public acceptance boosted)
Environmental: +/0
(increased water availability/
reduced risks associated with
environmental pollutants present in
treated wastewater/ no change)
Economic/Administrative: - -/+ +
(increased costs to farmers/
increased costs for WWTP and
farmers / improved trade and
business opportunities)
Social: +
(promotion of public acceptance)
Environmental: 0
Economic/ Administrative: 0
Social: 0
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Annex 13 – Abbreviations and Glossary
Agricultural irrigation The application of controlled amounts of water to plants at
needed intervals
Aquifer An underground layer of water-bearing permeable rock, rock
fractures or unconsolidated materials from which groundwater
can be extracted
Aquifer recharge A hydrological process where water moves downward from the
soil surface towards groundwater. Recharge occurs both
naturally (through the water cycle) and man-induced (i.e.
artificial aquifer recharge), where rainwater, surface water
and/or reclaimed water is routed to the subsurface. Artificial
groundwater recharge aims at increasing the groundwater
potential and it can effectively help preventing saline intrusion
in depleted coastal aquifers.
Associated Directives (to the Water Framework Directive) Groundwater Directive and
Priority Substances Directive
Blueprint Commission Communication "A Blueprint to safeguard
Europe's water resources COM(2012) 393
BREF Best Available Technique Reference Document developed
under the Industrial Emissions Directive
BWD Bathing Water Directive
CAP Common Agricultural Policy
Catchment area Any area of land where precipitation collects and drains off into
a common outlet, such as into a river, bay, or other body
CEC Contaminant of emerging concern
CEN European Committee for Standardization
Circular Economy Action Plan Commission Communication "Closing the loop – an EU
action plan for the circular economy COM(2015) 614
CIS Common Implementation Strategy for the Water Framework
Directive and Floods Directive
Discharge The volume of water flowing through a river channel at any
given point (measured in cubic metres per second)
Drought A period of below-average precipitation in a given region,
resulting in prolonged shortages in the water supply, whether
atmospheric, surface water or ground water
DWD Drinking Water Directive
Effluent Wastewater - treated or untreated - that flows out of a treatment
plant, sewer, or industrial outfall. Generally refers to wastes
discharged into surface waters
EC European Commission
EEA European Environment Agency
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EFSA European Food Safety Authority
EIA Directive Environmental Impact Assessment Directive
EU European Union
Fertigation Irrigation with nutrient rich water but free from other pollutants
GHG emissions Green House Gas emissions
ICT Information and communication technology
IED Industrial Emissions Directive
Internal Market EU single market in which the free movement of goods,
services, capital and persons is assured, and in which citizens
are free to live, work, study and do business.
Ir Irrigation
JRC Joint Research Centre (European Commission)
Membrane bioreactor Specific water treatment technology
Micro-filtration Specific water treatment technology
MSFD Marine Strategy Framework Directive
N Nitrogen
NUTS2 Nomenclature of territorial units for statistical purposes -
second level regions
Reverse osmosis Specific water treatment technology
RBD River Basin District
RBMP River Basin Management Plan
Saline intrusion The movement of saline water into freshwater aquifers, which
can lead to contamination of drinking water sources and other
consequences
SCHEER Scientific Committee on Health, Environmental and Emerging
Risks
SDGs Sustainable Development Goals
SME Small and Medium Sized Enterprise
Streamflow The flow of water in rivers, streams and other channels
TIA Territorial Impact Assessment
Ultrafiltration Specific water treatment technology
Ultra-violet disinfection Specific water treatment technology
Water abstraction The process of taking water from a ground or surface source,
either temporarily or permanently.
Water appropriation The capture, impounding, or diversion of water from its natural
course or channel and its actual application to some beneficial
use to the appropriator to the exclusion of other persons
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Water reuse The use of water which is generated from wastewater and
which, after the necessary treatment, achieves a quality that is
appropriate for its intended uses (taking account of the health
and environment risks and local and EU legislation).
Water scarcity The lack of sufficient available water resources to meet water
needs within a region.
Water stress The demand for water exceeding the available amount during a
certain period or poor quality restricting its use.
WEI+ Water Exploitation Index
WFD Water Framework Directive
WHO World Health Organization
WS&D Water Scarcity and Droughts
WSSTP Water Supply and Sanitation Technology Platform
UWWTD Urban Wastewater Treatment Directive