OpenLobby.EU
Explore

Aqua Publica Europea

APE

Aqua Publica Europea represents public water and sanitation operators across Europe, promoting public water management and sharing best practices.

Lobbying Activity

Aqua Publica Europea urges clear sewage sludge quality standards

9 Oct 2025
Topic — The European Commission is consulting on the upcoming Circular Economy Act.
Message — The association calls for a revised Sewage Sludge Directive aligned with current scientific knowledge on contaminants. They also urge the creation of end-of-waste statuses for recovered resources to reduce red tape.12
Why — Clearer regulations would provide the legal certainty needed to unlock investments in recovery.3
Impact — Non-EU mineral fertilizer exporters lose dominance as recycled phosphorus gains competitive ground.45
Read full response

Meeting with Thomas Bajada (Member of the European Parliament)

17 Jul 2025 · PFAS contamination

Meeting with Thomas Bajada (Member of the European Parliament, Rapporteur)

9 Apr 2025 · Seminar on Financing Water Resilience: Reconciling Environmental Sustainability, Equity, and Efficiency in the Water Sector for the Future of Europe

Meeting with Axel Hellman (Cabinet of Commissioner Jessika Roswall)

7 Apr 2025 · Water management

Meeting with Jessika Roswall (Commissioner) and

27 Mar 2025 · Roundtable “Water, Agriculture, and the Food Supply Chain”

Meeting with Mirka Janda (Cabinet of Executive Vice-President Raffaele Fitto)

3 Mar 2025 · Water resilience

Meeting with Grégory Allione (Member of the European Parliament, Shadow rapporteur)

10 Feb 2025 · Réunion Aqua Publica Europea

Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and

5 Feb 2025 · Water Resilience

Meeting with Michalis Hadjipantela (Member of the European Parliament)

4 Feb 2025 · Follow up meeting

Meeting with Thomas Bajada (Member of the European Parliament, Rapporteur)

17 Jan 2025 · Meeting on Water Resilience Strategy

Meeting with Stine Bosse (Member of the European Parliament)

13 Jan 2025 · The hosting of an event on water resilience

Meeting with Michalis Hadjipantela (Member of the European Parliament)

4 Dec 2024 · Introductory Meeting

Meeting with Grégory Allione (Member of the European Parliament, Shadow rapporteur)

21 Nov 2024 · Réunion Aqua Publica Europea - association européenne des opérateurs publics de l'eau

Meeting with Hildegard Bentele (Member of the European Parliament, Shadow rapporteur)

21 Nov 2024 · EU water policy

Meeting with Sigrid Friis (Member of the European Parliament)

30 Oct 2024 · Water policies

Meeting with Bruno Tobback (Member of the European Parliament)

21 Oct 2024 · Water Resilience Strategy

Meeting with Radan Kanev (Member of the European Parliament)

15 Oct 2024 · Water Resilience in Europe

Meeting with Antonella Sberna (Member of the European Parliament)

10 Oct 2024 · Cohesion Policy for the Water Sector: Rainwater Management, Agricultural Practices, Sludge Management, and the Circular Economy Act

Meeting with Ana Vasconcelos (Member of the European Parliament)

26 Sept 2024 · Water Resilience Strategy

Meeting with Jeannette Baljeu (Member of the European Parliament)

9 Sept 2024 · EU water policy

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

4 Sept 2024 · meeting with Aqua publica

Meeting with Oliver Schenk (Member of the European Parliament)

2 Sept 2024 · Water resilience

Meeting with Yvan Verougstraete (Member of the European Parliament)

28 Aug 2024 · Qualité d'eau

Meeting with Michal Wiezik (Member of the European Parliament)

27 Aug 2024 · priorities in water policy

Aqua Publica Europea opposes higher nitrogen fertilizer limits

16 May 2024
Topic — The European Commission is consulting on updated rules for livestock manure-derived fertilizers.
Message — The group expresses strong concerns about allowing additional nitrogen limits from livestock manure. They warn that increasing limits would further deteriorate European water quality.1
Why — Preventing these changes avoids additional pollution of the water sources they manage.2
Read full response

Public Water Operators Seek Stricter Rules on Nitrate Pollution

6 Mar 2024
Topic — Evaluation of EU legislation protecting water quality from pollution caused by agricultural nitrates.
Message — The association requests extending protected zones to larger areas and introducing penalties for non-compliance. They propose an Extended Producer Responsibility scheme for synthetic fertiliser producers to apply the polluter-pays principle. They also advocate for stronger incentives for farmers to switch to organic and sustainable practices.123
Why — Water companies would avoid high costs and energy use for nitrate treatment.45
Impact — Fertiliser producers and conventional farmers would face higher costs and enforcement penalties.67
Read full response

Meeting with Daniela Rondinelli (Member of the European Parliament)

29 Nov 2023 · Water

Meeting with Arunas Ribokas (Cabinet of Commissioner Virginijus Sinkevičius)

15 Nov 2023 · To discuss the water resilience

Meeting with Lukas Visek (Cabinet of Vice-President Maroš Šefčovič)

15 Nov 2023 · Water resilience

Meeting with Witold Jan Waszczykowski (Member of the European Parliament)

8 Nov 2023 · Aqua Publica Europea's Manifesto for the EU 2024 Elections

Meeting with Deirdre Clune (Member of the European Parliament, Shadow rapporteur)

7 Nov 2023 · Urban Wastewater Treatment Directive

Meeting with Pernille Weiss-Ehler (Member of the European Parliament)

6 Nov 2023 · Blue Deal

Meeting with Maria Noichl (Member of the European Parliament, Rapporteur for opinion)

25 Oct 2023 · Soil health and Water

Meeting with Jordi Solé (Member of the European Parliament)

25 Oct 2023 · Aqua Publica Europea's Manifesto for the EU 2024 Elections

Meeting with Margrete Auken (Member of the European Parliament, Shadow rapporteur)

5 Jul 2023 · UWWTD

Aqua Publica Europea seeks flexible taxonomy for water operators

3 May 2023
Topic — The consultation defines environmental criteria for sustainable investment activities under EU law.
Message — The organization requests including catchment protection and reconsidering mandatory individual metering. They argue that any investment improving wastewater quality should be eligible for green funding.123
Why — Public operators would avoid losing investment eligibility due to specific local administrative setups.45
Impact — Rigid criteria could cause territorial inequality by misallocating financial resources across Europe.6
Read full response

Meeting with Deirdre Clune (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and

29 Mar 2023 · Stakeholder Consultation on Urban Waste Water Treatment Directive

Meeting with Deirdre Clune (Member of the European Parliament, Shadow rapporteur)

21 Mar 2023 · Urban Waste Water Treatment Directive

Aqua Publica Europea urges industry to pay for wastewater treatment

24 Feb 2023
Topic — The European Commission is revising rules for managing and treating urban wastewater.
Message — They urge keeping the extended producer responsibility scheme so polluting industries cover treatment costs. They also want flexibility to prioritize investments based on local ecological needs.12
Why — Public operators would avoid massive costs while securing EU funds for rural infrastructure.3
Impact — Industry producers of micro-pollutants face significant new financial obligations for advanced water cleaning.4
Read full response

Meeting with Jan Huitema (Member of the European Parliament, Rapporteur for opinion)

21 Feb 2023 · Urban Wastewater Treatment Directive

Meeting with Margrete Auken (Member of the European Parliament, Shadow rapporteur)

3 Feb 2023 · Recast of the UWWTD

Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur)

30 Jan 2023 · Urban waste water treatment

Meeting with Sara Cerdas (Member of the European Parliament)

27 Apr 2022 · Água e pacote legislativo Fit for 55

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Aqua Publica Europea, the European Association of Public Water Operators, appreciates the opportunity to provide comments on the draft delegated regulation on the EU Taxonomy. We welcome the overall approach to promote sustainable finance, and in particular the fact that the sustainable use and the protection of water resources becomes a clear environmental objective under the Reg. 2019/2088, then translated in rigorous screening criteria for many economic sectors in the Delegated Act. Nevertheless, we express some serious concerns regarding the specific criteria proposed in the fields of drinking water, waste water and sludge management, in which APE’s members operate. These criteria are likely to limit investments to a sector which is entrusted with the public mission of managing and de-polluting water resources (and, in the case of public operators, without any profit-seeking objective), thus eventually hampering the achievement of Reg.2019/2088 objectives as established in particular in art. 9 and 12. In the contribution attached, we draw attention to: 1. The fact that the management of the water cycle is not an industrial activity like any other. It is a societal and environmental service whose mission is to safeguard water resources and treat pollution in drinking and waste water in order to protect human health and biodiversity. The primary missions of operators, carried out under the mandate of public authorities, are to increase and expand access to safe drinking water and to return treated waste water safely to nature; all of this with high legal standards. These imperatives often imply increased energy consumption for a better service to people and for a cleaner environment. We therefore warn against setting screening criteria that risk diverting financial resources from an already significantly under-financed sector and, eventually, accelerating rather than mitigating the deterioration of the environment. 2. Shortcomings of some of the specific criteria regarding water management operations in terms of effectiveness, fairness and coherence with EU legislation, which could be counter-productive for the sustainability objectives of the Taxonomy. We note in particular that some energy efficiency-related criteria do not take into account a set of considerations, such as local conditions, sources of energy or treatment requirements. If adopted, these criteria risk leading to an uneven geography of investments, diverting investments from territories that need investment more urgently (more polluted areas or smaller agglomerations, for example), and reducing incentives to extend networks to remote areas. Considering the issues stemming from the Delegated Act, we call upon the Commission to redraft its approach and outline a more effective and coherent framework that does not prevent investments in water, does not hamper efforts to achieve compliance under EU legislation, and does not produce distortive effects, but that considers different contexts and their variabilities. About Aqua Publica Europea Aqua Publica Europea (APE) is the European Association of Public Water Operators. It unites publicly owned water and sanitation services and other stakeholders working to promote public water management at both European and international level. APE is an operator-led association that looks for efficient solutions that serve the public rather than corporate interests.
Read full response

Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

As part of the European Commission’s Green Deal, Aqua Publica Europea, the European Association of Public Water Operators, welcomes the opportunity to comment on the Roadmap on the EU Action Plan “Towards a Zero Pollution Ambition for air, water and soil”. This new initiative goes in the right direction towards a non-toxic environment and supports the EU's leading role for a more sustainable future. Reducing water pollution is essential for human health and the state of our environment. It contributes to a more resilient, greener economy that facilitates circularity and fosters a fair transition for all. In this framework, we would like to emphasise the following elements for consideration: 1.We agree that first and foremost, it is necessary to strengthen implementation and enforcement of water policies, in particular the provisions of the Water Framework Directive, deemed fit-for-purpose. In this context, tools to support Member States are key – including through planning and guidance documents – and peer-to-peer capacity-building of professionals can support on-the-ground implementation. 2.Improving the acquis – including with the expected revision of the Urban Waste Water Treatment Directive – by focusing on sustainable approaches that consider: - The contribution of the legislation to meet the environmental objectives enshrined in the WFD, and impact on water bodies; - The entire pollution cycle and adopt a preventive approach, in line with the precautionary principle. We recall that it is altogether more efficient, less costly to users, more effective for a proper functioning of internal market and less energy consuming to prevent pollution than treat it once pollutants entered the water cycle. Reduction at-source should include bans of certain pollutants as well as improvement of production and disposal. - The impact of water pollution on the realisation of the circular economy which needs detoxification at source. - The effects of different alternatives in terms of costs and efficiency for citizens and in a long-term perspective. 3.The Roadmap rightly integrates the social impact of pollution, we highlight some additional considerations for a just approach: - Increasing treatment of pollution risks leading to higher costs - and, all other things equal, more CO2 emissions. In a context where investments needs are already significant, we call for the prioritisation of water in financial planning. - To prevent that the cost of pollutant removal is born disproportionately by households in water bills, we call for full implementation of the ‘polluter-pays’ principle and the establishment of Extended Producer Responsibility schemes (in combination with other policies). - Water investments are done in the long to very long term: decisions taken today need to consider sustainability to avoid transferring liabilities onto future generations. - Geographical differences between regions and contextual local characteristics need to be considered to ensure equity across the EU. 4.Governance. We draw attention to the fact that effectively tackling water pollution requires to fully integrate water objectives into the range of sectoral policies that affect water quality, including agriculture, industry, market or trade policy. Furthermore, as water quality is deeply connected to its local context, we call for coordination of decision-making at local and basin levels, going across administrative silos and with the participation of citizens to ensure adequate territorial planning. We call on the European Commission to consider these elements to effectively protect the natural quality of water from pollution, in a sustainable and fair manner, in its upcoming Action Plan. About Aqua Publica Europea unites 65 publicly-owned water and sanitation services from 13 countries in an operator-led association that seeks efficient water management solutions that serve the public rather than corporate interests. www.aquapublica.eu
Read full response

Response to Revision of the Urban Wastewater Treatment Directive

8 Sept 2020

Aqua Publica Europea, the European Association of Public Water Operators, welcomes the European Commission’s Inception Impact Assessment on the Urban Waste Water Treatment Directive 91/271/EEC (UWWTD). Since its adoption, the Directive has proved to be a useful instrument to protect the environment and health, relying on the efforts of European waste water operators to remove pollution from water, hence contributing to the objectives of the overarching Water Framework Directive 2000/60/EEC (WFD) and the Bathing Water Directive 2006/7/EC. As it as been announced that the WFD will remain unchanged, a revision of the UWWTD will be an even more important tool to address new (and old) challenges, also in consideration of EU ambitions for a green – and blue – transition, and in particular the Green Deal. The COVID-19 pandemic has further shown the important role that the waste water sector plays within society both for efficient treatment to protect health - and thus benefitting well-being, as is also recognised in the United Nations’ Sustainable Development Goals – and also having the potential to support public health efforts through analysis of waste water for virus residue and early warning systems. The Impact Assessment and potential revision of the UWWTD provide an opportunity to ensure collective safety, address new challenges and contribute to EU ambitions. Based on the on-the-ground experience of 66 members, public utilities providing services to over 70 million people in Europe, Aqua Publica Europea would like to share the following contribution. 1. Only a life-cycle approach to pollution can protect health and the environment in an effective way 2. A coherent but flexible framework to tackle emerging global challenges 3. Financing a waste water sector that is fit for decades and fair for all 4. Addressing the potential for nature-based solutions 5. A legislation at the crossroads of many policies Aqua Publica Europea welcomes the European Commission’s work for more sustainable and more resilient waste water treatment for the next decades. In these efforts, we encourage the adoption of a few principles to guide the Impact Assessment: - Fairness to ensure proportionate contribution of all relevant actors to treatment upgrade and participation of the public in decision-making that directly impacts it; - Balance to seek the most cost-effective solutions to protect human health and the environment to high levels from pollution by fully evaluating different alternatives; - Flexibility to promote the solutions adapted to different contexts and that can work in the long-term; - Coherence with the range of objectives for a sustainable transition and in consideration of interlinked policies. About Aqua Publica Europea Aqua Publica Europea (APE) is the European Association of Public Water Operators. It unites publicly owned water and sanitation services and other stakeholders working to promote public water management at both European and international level. APE is an operator-led association that looks for efficient solutions that serve the public rather than corporate interests. Please see attached our contribution.
Read full response

Response to Evaluation of the Sewage Sludge Directive 86/278/EEC

25 Aug 2020

Aqua Publica Europea, the European Association of Public Water Operators, welcomes the European Commission’s initiative to evaluate the Sewage Sludge Directive 86/278/EEC (SSD) after almost thirty-five years of existence. A comprehensive review will allow identifying shortcomings and solutions to develop a sustainable framework for sludge management that correspond to on-the-ground realities, whilst ensuring protection of health and the environment and fitting objectives for a true circular economy. In response to the public consultation on its Roadmap, we would like to support the Commission’s evaluation by suggesting the consideration of a series of elements: • The Sewage Sludge Directive is more relevant today than ever, as a key instrument to create a sustainable framework for sludge reuse in a circular economy and in the wake of the COVID-19 pandemic. The SSD provides great opportunities for safe recycling of sludge, reduction of pollution in the environment and protection of human health, all the whilst fostering EU independence for nutrients and food production, lowering the reliance on chemical fertilisers, and playing a key role in supporting a localised, short circuit approach. • Through the years, Member States moved away from the requirements spelled out in the Directive and adopted stricter and different rules. This has created uncertainty for waste water operators, as well as other economic operators in the sludge disposal chain, and affected the functioning of sludge recycling, sometimes resulting in transport to different regions/ countries for disposal. • The analysis of costs and benefits of the SSD should factor in recycling of sludge for agriculture, including comparisons between biological and industrial fertilisers for farmers, as well as total costs of alternative solutions to agricultural spreading that would impact both society and the internal market. • Sludge recycling aligns fully with Green Deal and circular economy objectives. The Directive itself interlinks with many pieces of EU legislation, with potential trade-offs and diverging approaches that risks hampering the benefits offered by sludge recycling. Considering sludge as a valuable resource, and fostering its transition to a product rather than waste, across the board in different EU laws, would unlock its full potential. Furthermore, it is particularly important to ensure full coordination with the parallel evaluation of the Urban Waste Water Treatment Directive, notably in terms of calendar and objectives. • An ambitious Directive is critical for the protection of human health and the environment throughout the EU. Without it, it is likely that sludge spreading will continue to be banned from traditional or organic agriculture, thus leading to alternatives both for sludge disposal and agriculture that risk creating an uneven framework. Complementarily, a comprehensive, effective approach should include acting on pollution through its life-cycle, primarily at the source, also in line with EU Treaties and specific Green Deal initiatives. • Any decision regarding sludge management needs to integrate science-based evidence. Therefore, it is essential that the study to be conducted builds on robust sources and research. • Due to its nature, sludge management, and its disposal in particular, needs to be considered as a collective responsibility therefore highlighting the role of all the actors and comprehensively including all stakeholders in the evaluation process. Towards a more sustainable framework, in the attached contribution, European public water operators call for: 1. Moving towards end-of-waste and circularity: a paradigm shift for a sustainable future 2. Preventing pollution at the source for more high quality by-products with less treatment 3. A harmonised approach for local management of sludge 4. Enabling confident use and valorisation of sludge 5. Considering the time necessary to implementing new solutions
Read full response

Response to Farm to Fork Strategy

13 Mar 2020

The upcoming Farm-to-Fork Strategy announces high ambitions for sustainable food systems, with an approach that addresses the entire supply chain, taking into account health, fairness, environment and food security considerations. In this context, we emphasise that our production and consumption habits deeply affect the environment, and notably water resources in terms of quality and quantity. Aqua Publica Europea, the European Association of Public Water Operators, represents 65 publicly-owned utilities providing water and sanitation services to over 70 million people throughout Europe. Based on their technical expertise and on-the-ground knowledge, we share a set of proposals for consideration in the discussions in view of the publication of a Farm-to-Fork Strategy. In attachment is our full contribution.
Read full response

Response to A new Circular Economy Action Plan

20 Jan 2020

Aqua Publica Europea welcomes the European Commission’s New Circular Economy Action Plan objectives which tackle growing challenges affecting resources and waste. Considering that water is limited yet essential, it is paramount to protect and preserve our natural heritage. Aqua Publica Europea represents public water operators providing water and sanitation services to over 70 million people in Europe, driven by the overarching mission to provide high quality services. Based on their expertise and on-the-ground understanding of the pressures on water, we would like to highlight a set of suggestions that should strengthen ambitions for more circularity. Preventing waste and promoting sustainable alternatives: recycling needs to be a final resort and waste reduction the first objective with uptake of sustainable, zero-waste solutions as the main priority. In practice, high volumes of plastic pollution can be prevented by adopting and fostering more environmentally-friendly habits, such as opting for tap water. APE members are already doing their part by, on the one hand, supplying high quality water and, in addition, committing to the promotion of tap water as drinking water. Preventing pollution at source through both control and greener design is key to reduce pressure on the environment and support the reuse of biological materials. Bioresources have great potential in a circular economy, including for energy and nutrient recovery from sludge resulting from waste water treatment. In practice, however, safety concerns about the reuse of sludge, unstable outlet markets for recovered resources, contribute to a linear situation where disposal consists growingly of incineration and landfill. As we will continue to produce such material, it is paramount to address the issue: setting adequate EU-wide quality standards and regulation whilst also controlling what enters into the water system in the first place, also by taking into consideration trade and imports, would support trust in resources and help overcome difficulties. A true circular economy needs to look at the entire picture to efficiently bridge gaps. Promoting a cross-sectoral approach, which carefully considers each sector’s economic conditions and needs, can facilitate the management of trade-offs whilst it is also essential to give responsibility to all actors throughout product life-cycles. In this context, political ambition, citizen participation and empowerment and adequate financing mechanisms are indispensable elements to a system that benefits from an enabling environment for circularity.
Read full response

Response to Evaluation of the impact of the CAP on water

26 Nov 2018

Aqua Publica Europea, the European Association of Public Water Operators, welcomes the European Commission’s initiative to assess the impact of the Common Agricultural Policy on water. The water and agricultural sectors are intrinsically linked, and public water operators are confronted daily with the impact of agricultural activities on water supply and waste water treatment. According to the European Environmental Agency study “European waters – Assessment of status and pressures 2018”, agriculture is among the main pollution pressures on surface water, the main cause for groundwater’s failure to achieve good chemical status due nitrates and pesticides pollution and among the most significant pressures to achieve good quantitative status. At the same time, agriculture can positively contribute to water quality by, for example, preventing erosion and retaining water. Also, agriculture is at the centre of food production and thus essential for life. The relation between agriculture and water management needs to be addressed within a coherent legislative framework, linking the CAP and water legislations and pursuing a common ambitious environmental objective, the reduction of water pollution. A first way to enable the CAP to deliver positive outcomes for water management is to ensure the application of the polluter pays principle. Today the lack of rigorous monitoring of the implementation of “cross-compliance measures” - as it has been reported by the European Court of Auditors (ECA Special Report 26/2016) -affects the correct application of this principle. European public water operators, APE members, provide drinking water to more than 70 million citizens in Europe and are subject to EU environmental law, which sets clear targets for the quality of the drinking water provided to citizens. In most cases, the presence of pesticides and nitrates requires the treatment of water prior to its supply to households. The nature of the pollution that finds its origin in agriculture makes it currently impossible to exactly trace back each farmer’s responsibility. Thus, the treatment cost is born by the final consumer –and not the polluter. Better monitoring and implementation of cross-compliance could thus help limit water pollution and, consequently, ensure a better application of the polluter-pays principle. Then, the CAP can contribute to actively promote upstream approaches. European public water operators have since long implemented examples of voluntary approaches, by establishing effective and long-lasting partnerships with farmers operating on and around their catchment areas. These payment for ecosystem services (PES) schemes are based on a close cooperation between the water operator and the farmer, the latter committing to specific results in exchange for a payment. Such approaches have thus trigger reduction of pollution at source and allowed water operators to make significant savings by reducing the level of water treatment. However, misinterpretations of State Aid obligations sometimes hamper the possibility for operators to compensate farmers for their ecosystem service. More generally, voluntary approaches are most effective within a flexible framework. The new mechanism foreseen for the Future CAP incentivising farmer to develop organic production - for instance goes in the right direction but their management appear a bit too “rigid” as the mechanism is centralised at Member States level. The future CAP must foster the reduction of agriculture’s current pressure on European waters quality, through the increase of green measures, the focus on quality (nutritional, health and environmental) rather than on performance, and the promotion of local solutions. The payments for environmental services could be introduced in the first pillar to push for the development of new ways of production which answer to environmental and climate challenges instead of promoting intensive and unsustainable agricultural methods.
Read full response

Response to Proposal for a Regulation of the European Parliament and of the Council on minium requirements for water reuse

9 Aug 2018

Aqua Publica Europea, the European Association of Public Water Operators, welcomes the Commission’s proposal for a Regulation on minimum requirements for water reuse as it provides a clear legal framework for reclamation plant operators, thus facilitating the practice in areas affected by water scarcity but without setting an unnecessary EU-wide obligation. Nevertheless, to guarantee that water reuse is appropriately addressed in the proposal, APE members have identified several points to be clarified. 1. A clearer consideration of all of the proposal’s environmental implications As the EU moves towards a circular economy model, water reuse can be an effective practice to tackle droughts and support agriculture. However, potential environmental impacts of water reuse should be better addressed in the proposal: the risk of overconsumption and potential negative effects on ecological flows are in fact partially overlooked. Therefore: - The Regulation should include clear references to the Water Framework Directive (articles 1.b, 5.1 and 8.1.i.) to take into account long-term sustainability. - The effects of water reuse on the environment, including benefits and risks, should be thoroughly evaluated based on the Water Framework Directive and integrated in the risk management plan, also to ensure the sustainable use of water. 2. A more appropriate distribution of responsibilities for the risk management plan To ensure the safety of the water to be reused, article 5 (Risk management) of the proposal rightly introduces an obligation to develop risk management plans. However, by putting this responsibility entirely on reclamation plant operators, the proposal misses the fact that operators do not have the power to carry out some of the tasks outlined: - operators can ensure compliance with the quality requirements for treated water at plant level but do not have the competence to carry out a risk assessment on the health and environmental impacts of water reuse, as this depends on the actual use of the water. - water operators are not the most appropriate actors to promote stakeholders engagement, especially when stakeholders include controlling authorities. Therefore: - As only public authorities hold the legitimacy to take decisions in the pursuit of the general interest, they should be responsible for promoting stakeholders engagement and for coordinating the development of the risk management plan, based on water operators’ technical support. - The risk management plan should include an overall environmental and human health risk assessment and define the relevant quality class to be applied. - Public authorities should also be responsible for arbitrating between potential competing water needs and decide on the distribution of costs between different types of users, should the compliance with new quality requirements imply additional investments for water operators. 3. New requirements should be incorporable into existing permit systems As Member States have their own systems for granting environmental permits, the proposal should clearly provide the possibility to incorporate the permits for water reuse in national processes, thus also avoiding institutional uncertainty. 4. A proportionate approach to quality requirements Whilst APE strongly welcomes the suggested subdivision of water quality requirements into different classes depending on final use, adequately defining the actual parameters will be necessary to guarantee that they are effectively fit-for-purpose. The proposal should also indicate the body in charge of specifying the class to be applied and when this decision should be made. Further, monitoring frequency obligations should be defined according to both quality class and amount of water treated.
Read full response

Response to Revision of the Drinking Water Directive (RECAST 2017)

29 Mar 2018

Aqua Publica Europea, the European Association of Public Water Operators, welcomes the European Commission’s proposal for a recast of the Drinking Water Directive as a needed step towards a more holistic approach to secure high quality tap water for all EU citizens. The proposal designs an innovative framework, which should ensure a more integrated, transparent, cost-effective and context-sensitive approach to water resource management for drinking water. Since we fully align with the intention of the proposal, we highlight some inconsistencies in the proposed text that risk undermining the achievement of its objectives and propose alternatives for a seamless implementation. A thorough application of the risk-based approach based on a robust framework We strongly welcome the introduction of a source-to-tap risk-based approach (RBA) for improved water quality in Europe. We regret the proposal focuses only on monitoring regimes and not also management of risk. Imposing restrictions for any exceedance whatsoever of minimum parametric values (art. 12.3) is unreasonable, contradicts with other provisions in art. 12, may result in unnecessary alarmism and obliges to always opt for additional treatment over preventive measures, even when it is not required by health protection considerations. The source-to-tap RBA requires a robust governance framework. Realising source-to-tap risk assessment will require changes to the current governance of the water management system in several Member States. Whilst the reference to stakeholder engagement is welcomed, as APE members advocate, the proposal needs to establish a clearer link between responsibilities and competences to carry out hazard assessment and preventive/remedial action especially for water bodies and domestic distribution. Prioritising interventions where risks are higher. The new classification of small/large/very large suppliers may lead to inconsistencies in applying the RBA. We propose to reintroduce the previous classification based on supply zone size, or alternatively, to align and extend the timeline for applying the RBA to six years for all, thus allowing for prioritising action where risks are higher. Particularly rigid monitoring requirements may lead to disproportionate costs. A transitory period between the current and the new regime until the risk-assessment is performed should be foreseen. Because threshold values for certain parameters are well beyond WHO recommendations, the cost impact should be assessed in the light of the objectives in art.13. For a comprehensive approach to access to water We welcome the inclusion of provisions promoting the access to tap water for all (art. 13). However, we believe that physical access cannot be separated from affordability, and both should be considered along with cost-recovery and water efficiency requirements. For example, we propose a more thorough enforcement of the polluter-pays principle for emerging pollutants, also as a way to finance the measures foreseen in art.13. Further, art. 13 fails to clarify the allocation of responsibilities for the realisation and the financing of required actions. Achieving transparency: broadening the scope, increasing flexibility We fully support the objective to increase information and transparency with a view to boost consumer trust and improve water governance. However, whilst some provisions in art. 14 and annex IV are too specific and therefore not applicable to all contexts, other important aspects of transparency (especially on financial flows) are neglected. We therefore propose to outline comprehensive, general principles and allow Member States to take responsibility for detailed regulation. What about climate change? The proposal is silent on long-term climate adaptation strategies, which should be explicitly promoted. We call for the Commission to strengthen the proposal through clarifications and increased coherence to fully produce its impacts.
Read full response

Response to Fitness Check of the Water Framework Directive and the Floods Directive

17 Nov 2017

Aqua Publica Europea, the European association of public water operators, welcomes the opportunity to comment on the evaluation roadmap concerning the fitness check of the Water Framework Directive (WFD) and Floods Directive. Today, EU water policy is taken as a reference worldwide, with the WFD as its centre-piece. Through the definition of River Basin Management Plans, which should be developed through a multi-stakeholders process, the WFD sets the basis for an integrated approach to water resources management. Nevertheless, other aspects of the Directive may need to be improved, including its internal coherence and the consistency between the objectives of the WFD and other water-related and sectoral legislation. We therefore invite the Commission to take account of the following issues when performing its evaluation of the WFD and Floods Directive: - WFD Art. 7 requires EU Member States to provide “necessary protection” for water bodies used for the abstraction of drinking water by, for example, establishing safeguard zones. This “at source” protection of water bodies has been essential in ensuring quality and affordable drinking water for all under Directive 98/83/EC (the DWD) by reducing the need for treatment. Therefore, the relationship between the DWD and the WFD should also be taken into account in this evaluation, especially in the light of a possible introduction of the risk-based approach in the new DWD. - WFD Art. 9 establishes a cost-recovery principle based on an adequate contribution of the different water uses and on the polluter-pays principle. While the cost-recovery principle is today largely applied by water operators, the financial contribution of some economic sectors and the application of the polluter-pays principle are not yet satisfactory. This generates economic and environmental inefficiencies, and has negative effects on the affordability of water services for domestic users. Both issues (the inefficiencies generated by the lack of application of the polluter-pays principle across all uses, and its impact on the affordability of water services for households) should be considered in this evaluation. - More generally, the evaluation should help ascertain whether the current WFD (and specifically its Art. 9) allow for the simultaneous achievement of three equally important goals: the recovery of management and resource costs, the affordability of water services and the realization of the right to water, and the efficient use and protection of water resources. Reconciling those three dimensions is more central to the objectives of the WFD than the eventual impact of the WFD measures on businesses. - Art. 14 of the WFD on public information and consultation has been a key instrument in introducing the principles of the Aahrus Convention into water policy-making in the EU Member States. Its relevance and effectiveness should be considered in this evaluation, also in relation to the revision of the DWD and the WWTD. - In addition, water management is today increasingly impacted by different challenges, namely the effects of climate change (with increasing extreme events such as floods and droughts). The review should show whether the current governance structures are fit to enable relevant authorities and actors to adequately address the risks generated by those new pressures through effective preventive and mitigation measures, supported by appropriate economic instruments when needed. More generally, the capacity of the WFD to promote long-term integrated strategic planning (including planning of investments) should also be assessed. - Finally, and especially in the light of the implementation of the polluter-pays principle, the specific coherence between the WFD and other sectoral legislation (agriculture, industrial emissions, fertilizers and plant-protection products, etc.) should also be considered.
Read full response