APE raises concerns over the ENVI Committee’s draft report on the Urban Wastewater Treatment Directive
Aqua Publica Europea expresses reservations on several provisions of the Committee on Environment, Public Health and Food Safety's draft report on the recast Urban Wastewater Treatment Directive (UWWTD), particularly with respect to the dilution of the polluter-pays principle, technical challenges, and threats to water affordability.
Aqua Publica Europea, the European association of public water operators, welcomes the commitment to further reduce pollution, enhance water quality and improve the efficiency of the wastewater sector in the draft report on the recast Urban Wastewater Treatment Directive (UWWTD) adopted today by the European Parliament’s Committee on Environment, Public Health and Food Safety (ENVI). We express, however, strong reservations on several provisions that raise significant concerns, particularly with respect to the dilution of the polluter-pays principle, technical challenges, and threats to water affordability.
One of our main concerns lies in the introduction of a provision allowing for the allocation of up to 20% of national financing to complement the Extended Producer Responsibility (EPR) scheme to cover the upgrade of urban wastewater treatment plants to remove micro-pollutants. This measure would undermine the polluter-pays principle, introduce inconsistencies across Member States and increase water tariffs for households in a period of inflationary pressures.
The ENVI Committee’s proposed changes to treatment requirements for urban wastewater are also a source of concern. The provision that both nitrogen and phosphorus parameters (table 2) apply to large wastewater treatment plants, in particular, could lead to substantial costs without necessarily bringing environmental benefits. The introduction of a 3rd category of substances (table 3) that should be removed by quaternary treatment also raises concerns of potential legal inconsistencies that could undermine the EPR scheme and introduce uncertainties during the implementation phase.
We do, however, support new provisions allowing for the inclusion of green energy generated by wastewater treatment plant operators off-site in the energy neutrality balance. The possibility for Member States to purchase renewable energy from external sources up to a maximum of 25% also presents a positive step forward towards achieving energy neutrality within the sector by 2040. Whilst the aspiration of reaching climate neutrality by 2050 is commendable, we have however strong reservations regarding the wastewater sector’s technical feasibility to meet this new target unless more stringent control-at-source measures are implemented.
The draft report finally expands requirements on collecting systems and secondary treatment down to agglomerations with a p.e. of 750. This extension is expected to necessitate substantial investments in smaller agglomerations where the costs associated with collection systems and secondary treatment can only be distributed among a limited number of users. We are concerned this move may further exacerbate the urban-rural divide while offering marginal environmental benefits.
We call upon Members of the European Parliament to address these concerns before the plenary vote scheduled for October and create an enabling regulatory framework that embraces ambitious environmental and public health objectives while safeguarding water affordability and preventing territorial cleavages.