Factual Summary Report for the Public Consultation on the Impact assessment of the Urban Waste Water Treatment Directive
This consultation was carried out as part of the Impact Assessment of the Urban Waste Water Treatment Directive (UWWTD). The Online Public Consultation (OPC) for the impact assessment of the UWWTD was conducted with the aim of gathering the opinion of the general public and experts on various topics relating to the revision of the UWWTD. This OPC was the second one conducted for the UWWTD in the span of two years. In 2018, the public consultation for the evaluation of the UWWTD was conducted, which received 608 replies where stakeholders expressed that the Directive’s key provisions had been very to somewhat effective and the cost-benefits were proportionate and justified, making the Directive efficient.
The questionnaire for the impact assessment was developed based on findings of the evaluation and information provided by the Commission outlining ideas and topics that should be addressed in the revision of the Directive. The results will inform the revision process, and the views collected will be considered in the impact assessment, especially when designing potential (regulatory and non-regulatory) measures to better collect and treat urban waste water and reduce the related environmental impact.
The OPC ran for 12 weeks, from April 28 to July 21 2021. A total of 285 responses were received, and 67 position papers were submitted. The general part of the questionnaire received 285 responses, and the targeted section 266.
The OPC was divided into five sections. After some initial questions regarding the profile of respondents, sections 2-3 were addressed to all respondents and covered respondents’ understanding of the UWWTD, their views on the problems relating to waste water pollution, and how to best address water pollution through waste water treatment processes. Section 4 was targeted at expert respondents and included more in-depth questions on specific measures to address in the revision of the Directive. Questions either required participants to score statements or proposed measures on a scale of one (least agreement/effective) to five (most agreement/effective). The responses are therefore presented as average scores. Finally, respondents could share additional relevant materials/publications and/or information in section 5.
1.1.1Who contributed?
A total of 285 responses were submitted, with 22 EU Member States represented, as well as six non-EU countries. Out of the 285 respondents, the most-represented country was Germany (n=77). This was followed by Spain (n=34), France (n=30), and Belgium (n=30), which had a similar number of respondents.
Primarily, respondents gave contributions as company/business organisations (n=61). However, this was closely followed by EU citizens (n=55) as well as Public Authorities (n=48), Business associations (n=42), and NGOs (n=30). There was also a number of respondents that identified themselves as ‘Other’ (n=23). When asked to specify, three respondents were associated with Horizon 2020 projects and five associations spanning scientific, water regulatory, and consumer groups. It should be noted that there was a reduced number of citizens respondents than previously observed in the evaluation (only 19% (55/285) of respondents rather than previous 55% (334/608)), which bodes caution for the interpretation of the results of this stakeholder group.
The 143 respondents were active in the waste water treatment sector and 139 in the water industry and/or management. These were followed by the public sector (n=75) and biodiversity and/or environment (n=69) sector active respondents. The waste water business is either managed by the public or private sector; 73% of respondents that identified as company stakeholders were active in waste water treatment (n=45), while for public authority respondents, only 60% were active in waste water treatment (n=29).
All 285 respondents indicated their level of knowledge and expertise regarding the UWWTD legal text, the implementation of the UWWTD in a practical sense, and the treating of urban waste water (with a specific focus on the respondents' technical knowledge of the subject). Almost half of the respondents identified themselves as having excellent technical knowledge on treating urban waste water. In general, there was a good distribution in expertise, with few respondents indicating that they had little to no knowledge on the subject areas (n <30 for all three).
1.1.2Key responses to questions on urban waste water pollution (Section I)
[Q1] In your country of residence, to what extent do you think that urban waste water, i.e., domestic waste water and similar water (Please rate your level of agreement on a scale of 1 to 5, 1 = not at all, 5 = very much)
Respondents were asked their opinion on three points relating to waste water processes. Respondents, in general, mostly agreed with the statement that waste water is correctly treated before discharge (average score 3.6). Regarding the current source of pollution to rivers and lakes, the agreement rates were relatively spread, showing 31% of stakeholders (n=87) with a significant agreement as well as 39% with a significant disagreement. When asked about urban waste water as an increasing source of pollution, stakeholders generally seemed to mostly disagree with that statement, with 59% (n=159) rating in disagreement.
[Q2] There are several risks associated with discharging urban waste water without appropriate treatment. How concerned are you about the possible risks listed below? Please rate your concerns on a scale of 1 to 5 (1 = not at all; 5 = very much).
The average highest score, indicated the highest level of agreement across respondents, was observed for risks of polluting surface waters and groundwaters (average score 4.0 In general, respondents indicated high levels of concern for all risks defined in the question.
1.1.3Key responses to questions on potential measures and their impact (Section II)
[Q3] To what extent is it important that the revised legislation addresses the following topics? Please rate each topic on a scale of 1 to 5 (1 = not at all important; 5 = very important).
The topic ranked as the highest importance to be addressed in the upcoming revision was the improved implementation of the polluter pays principle (average score 4.5). Sixty-eight percent of respondents felt that this was a very important topic (score 5). In total, less than 5% of respondents ranked the polluter pays principle as low importance. Closely following is the promotion of monitoring and tracking of industrial release to urban waste water, where 80% (n=221) of respondents ranked it as important (4 or 5 scores). The by far lowest-ranked subject for revision was the requirement for UWWTP’s to produce energy (average score 3.1). Only 16% (n=74) of respondents felt strongly about the importance of energy production, while on the other hand, 13% (n=36) also ranked it as the lowest importance. Improving energy performance was ranked higher (average score 3.8), with 27% (n=74) of respondents indicating the highest level of importance, and only 2% (n=5) indicating it as the lowest importance. The importance of reducing greenhouse gas emissions also fared better on average than energy production (average score 3.6). The most neutral response was observed for addressing pollution from individual appropriate systems (IAS), where 31% (n=87) of respondents voted a score of three.
[Q4] To what extent is it important that Nature-based solution (NBS) play an increased role in managing urban waste water where possible? Please rate on a scale of 1 to 5 (1 = not at all important; 5 = very important).
On average, respondents indicated that NBS needs to play an increasing role in managing urban waste water (average score 4.2). Over 70% (n=185) of respondents ranked NBS as either very important (5) or important (4). Only 5% (n=11) of respondents felt NBS had little (2) to no importance (1) in the future management of waste water.
[Q5] Even after urban waste water is treated, it can still contain contaminants. How important is it to step up the monitoring and removal of the below contaminants from treated urban waste water? Please rate each contaminant on a scale of 1 to 5 (1 = not at all important; 5 = very important).
On average, all contaminants were ranked with similar importance. Endocrine disruptors and other pollutants from industrial installations had an average score of 3.2, closely followed by pharmaceutical residues, excess nutrients, and pesticides (average score 3.1). While microplastics had 37% of respondents ranking it as very important, similar to excess nutrients and pharmaceuticals, the general distribution of responses (in particular 24% (n=7) of respondents who were neutral) was more widely spread and therefore had on average the lowest rate of importance (average score 2.8).
[Q6] Which measures do you think could be efficient in removing and/or limiting the release of micropollutants into urban waste water? (Select all that apply)
In this question, stakeholders had the chance to select one or more of the measures that they agree with in order to address micropollutants in waste water. A total of 275 responses were received. Increasing consumer awareness on micropollutants received double the number of votes than any other measure (n=225). Considering that 275 responses were received, this means that 81% of all respondents agreed that increasing consumer awareness was one of the efficient methods to address micropollutants. All other measures showed a fairly equal number of votes, which indicates that they are seen as similarly efficient in addressing micropollutants.
[Q7] Would you be willing to pay higher charges for urban waste water treatment to improve facilities and implement technologies to help reduce pollution? For example, to help put in place additional treatments before the water is discharged.
In total, over 50% of respondents (n=143) voted yes; they would be willing to pay more to help put in place additional treatments. Notably, 18% (n=47) were willing to pay 15% or more in order to support the facilities.
[Q8] Which groups should help to reduce the pollution caused by micropollutants passing through urban waste water treatment plants? They could contribute physically (i.e., by actively removing and/or reducing the release of micropollutants), administratively, or financially. For each source of contaminants, please select the group(s) you believe should be responsible for addressing pollution caused by micropollutants.
The responses show that respondents felt that manufacturers and producers were responsible for addressing pollution of most contaminants. Industrial waste water contaminants had the highest rate of agreement with 91% (n=97) of respondents, indicating that this is the responsibility of manufacturers and producers. The exception is an urban run-off, where 69% of respondents felt the responsibility lies with the municipality (n=71). Household waste had the most significant split, where responsibility to reduce pollution was split between manufacturers and producers (n=38, 46%) and end-users/beneficiaries of the products (n=30, 37%).
[Q9] The EU has committed to achieving the transition towards climate neutrality by 2050. How do you see urban waste water collection processes and treatment plants contributing to this transition? Please rate on a scale of 1 to 5 which measures would be more efficient (1 = not at all efficient; 5 = very efficient).
Respondents rated all measures proposed (i.e. increasing use of renewable energy source, monitoring energy consumption, improving the operational management) equally high, with an average score of 4.1 for increasing the use of renewable energy and monitoring energy consumption and an average of 4.0 for improving operational management.
[Q10] Marginalized and vulnerable groups (e.g., homeless people) can lack access to water and related sanitation services. This can be improved by ensuring access to toilets and/or showers. Should a revised UWWTD require EU countries to improve access to sanitation for vulnerable and marginalised groups?
Although 43% of respondents (n=113) indicated yes, there was still a large portion that voted no (n=99, 33%). In addition, a significant number also did not know or had no opinion on the matter (n=58,22%).
[Q11] Regarding your local UWWTP, what kind of information would you be interested in accessing? Please select all that apply
Quality of rivers, lakes, and seas where waste water is discharged and the compliance of the UWWTP with the EU, national and regional laws were the two most highly yes-voted information subjects at 77% (n= 205) and 72% (n=192), respectively. The least interesting information appeared to be real-time information on water quality after treatment as well as sources for funding, which had 34% of respondents voting no and 23% did not know/no opinion. Across the other information points, there was generally an interest in over 50% of respondents, and throughout all options, there were around 20% of respondents that did not know or had no opinion.
1.1.4Responses to questions of the targeted consultation (Section III)
Measures for minimising pollution through storm water overflows and urban run-off
Mandatory reporting of overflows was considered the least appropriate measure, particularly by public authorities and businesses (average scores 2.9 and 3.2, respectively). Public authorities generally did not feel strongly about any of the presented measures. Indeed, their highest score was for the ‘Other’ option (4.7). Businesses showed the highest preferences for measures relating to obligations for agglomerations to adopt a strategic planning approach of the management and prevention of storm water overflows and urban run-off, implementation of NBS, and risk-based approaches in line with the Water Framework Directive (WFD) objectives (4.3, 4.0, 4.0, respectively). Citizens showed a similar preference in terms of agglomerations and NBS but ranked providing guidance strategies to manage pollution higher (4.1) than businesses and public authorities.
Measures for addressing urban waste water pollution originating from small agglomerations
The highest-rated response was once again the combination of several measures, where particularly NGOs felt strongly about it (4.8) as well as the increase in collection and treatment (4.1). Public authorities were mostly in support of combined measures (4.0) and ranked increasing collection and treatment least (3.1). For improving the definition of agglomerations, citizens ranked it the highest (4.0).
Measures for improving the use of IAS and reducing pollution coming from these systems
Academics were most supportive of reviewing the EU-wide standards for IAS (4.8) and generally felt that the measures presented were appropriate. Businesses were particularly in favor of ensuring connection to public sewer systems (4.1), providing guidance on IAS technologies (4.0), and reviewing the definition of IAS (4.0). Citizens were generally supportive of the measures presented but showed a lower average response for reporting to the EC (3.4) and requiring countries to keep an IAS registry.
Measures for improving the designation and protection of 'sensitive areas'
In terms of presented measures, providing EU-level guidance had the overall most positive response across stakeholder groups (4.2). Overall, respondents ranked improving the designation of sensitive areas (4.1) the introduction of additional obligations in bathing, drinking and shell fishing sites highly (4.0). NGOs, citizens, and academics generally had a positive response to all measures presented, giving most measures an average score above 4. Businesses and public authorities generally ranked presented measures lowly. Businesses felt positive about providing EU-level guidance (4.2) and improving the way sensitive areas are designated (4.1).
Measures for addressing micropollutants under the UWWTD
The measure to set an obligation for extended producer responsibility (EPR) to fund upgrades of UWWTPs had by far the most positive response across all stakeholder groups (4.3) and was also the highest-ranked option within each group. All stakeholder groups felt strongly positive about the EPR measure (>4), with the exception of businesses (3.9), indicating that there is a wider distribution in responses. Particularly public authorities responded more positively to the EPR measure compared to their responses to other measures (4.2).
Measures for addressing the presence of microplastics
The highest voted measure to address micropollutants was focused on incentivizing EU countries to take measures to reduce the microplastics at source. It is the first measure that received higher rating (4.5) that the ‘combine several types of measures’ (4.2) and the ‘other’ option (3.8). Across all stakeholder groups, reducing pollution at source was ranked on average above 4, where NGOs and citizens showed the most positive response (4.9 and 4.8 respectively).
Measures for addressing concerns on industrial pollutants in urban waste water due to industrial discharge
A very positive response across all stakeholders was recorded for the measure requiring pre-treatment at industrial installations before waste water is discharged into UWW collection systems (4.6). This was closely followed by the ‘combined measures’ option (4.5). All respondents strongly disagreed with the statement that no action was needed (1.7). Notably, neither businesses nor public authorities felt on average negative about the options presented, with all options receiving an average score above 3. NGOs, citizens and academics ranked options presented highly (average scores > 4.0).
EPR schemes
Over half of the respondents (n= 156, 60%) felt that EPR schemes would incentivize the development of less harmful products and/or foster innovation. As a follow up question, respondents were asked how feasible would it be to apply EPR to tackle micropollutants from certain products in urban waste water. In total 38% (n=98) of respondents felt that EPR was very feasible to address micropollutants from specific products (rating 5). Overall, more than 50% of respondents (n=142) felt that EPR could be a feasible measure (> 3). While 19% ranked the feasibility at 3 out of 5 (n=50), 17% indicated they did not know or had no opinion (n=43). Generally, however, it can be seen that only few respondents felt that EPR is unfeasible to tackle micropollutant (only 9%, n=23, voted <3).
Measures for improving UWWTPs' energy use and emissions intensity
Proposed measures to address energy use and emissions were generally not as highly rated as other measures in previous sections. The on average highest rated measure was related to introducing an obligatory energy audit in larger plants (3.8), which was rated highest by academics, citizens and NGOs.
Measures for building a more circular waste water treatment sector
Businesses and public authorities generally felt positively towards introducing more stringent requirements for tracking and preventing pollution at source when sludge is produced (average 4.0). In regards to water reuse, academics, citizens and NGOs were the most in favor of encouraging related measures (>4.0). Nonetheless, businesses and public authorities did not indicate an opposition to the measure, still averaging over 3.5 in their ratings.
Measures for reducing greenhouse gas emissions from the urban waste water system
Determining a benchmark for GHG emissions was generally ranked as the most effective measure (overall average of 4.0). However, while most stakeholder groups were positive regarding benchmarking, the average score for public authorities was rather low (3.4), indicating that the average response was less in favor of this measure. Setting emission targets of any form was generally not ranked highly appropriate, but particularly businesses showed opposition to the measure (2.6 for both).
Measures regarding the sampling frequency and monitoring standards set out in the UWWTD
Overall measures proposed relating to sampling frequency and monitoring were not rated particularly highly, with the majority scoring below 4 on average. Providing guidelines for normal operating conditions was generally considered the most feasible measure (average 4.0). The least rated option was to replace chemical oxygen demand (COD) measurements with total organic carbon across all stakeholder groups (average 2.6).
Measures regarding the reporting requirements for a revised UWWTD
Respondents rated the use of European Environment Agency (EEA) data availability as the highest option with 57% of respondents ranking it 4 or above, indicating that the interest in providing further information to the public is of general interest to all stakeholder groups. While the “combination” option got the highest 5 scores (n=118, 48%), all options presented had an overall high ranking with more than 50% of respondents rating them with a score > 3.0.
Waste water surveillance
Almost 40% of respondents felt that heath authorities should bear the additional costs of waste water surveillance, with the general public shortly following after with 37% of respondents voting for them. In a follow up question, we asked respondents to provide their inputs on measures that they deem feasible for incorporating waste water surveillance in the UWWTD. Here, providing guidelines for collaboration between UWWTPs and health authorities was overall ranked the highest (average 4.0). EU-wide binding standards saw an equal distribution across ratings but had an overall 45% of respondents (n=114) rating it positively (>3.0).
Innovation/adaptation to technological progress
The first question focused specifically on the integration of EU spatial data services (e.g., CORINE landcover, satellite images for water characteristics, and other remote sensing tools) to improve monitoring and reporting. The question had a large portion of respondents who did not know or had no opinion on the matter (n=74, 28%).
The second question was formulated more general and asked participants if provisions should be taking on adapting to technological advancements and progress. The statement received high support, with 33% (n=87) agreeing very much (5) with the statement and 29% agreeing (4), totaling over 60% of support for the statement.
Late implementation
Measures for addressing late implementation had a clear pattern of preference, where over 50% of respondents (n=134) agreed with the measure to adjust planning/reporting to link better with obligations/reporting with enabling conditions to access EU funds (average score of 4.1).
Costs and benefits
The highest number of votes (n=166, 24%) were received for improving storm water overflows and urban run-off management. Improving IAS management was perceived as the least cost-effective way to go, with only 5% of respondents (n=35) voting the measure.
