OpenLobby.EU
Explore

AQUAWAL

Aquawal is the federation of public water operators in Wallonia, Belgium.

Lobbying Activity

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

27 Mar 2018

We have to regret that the impact assessment established in the frame of this revision included a lot of methodological problems, including wrong figures and assumptions. Moreover, the final proposal includes some costs that were not taken into account in the IA. This revision proposal is currently more costly that was initially expected. We urge the Commission to assess the real costs of this proposal with the help of water suppliers and MS. We also think that the proposal integrates some mistakes, and can be strongly improved to better reach the goal it is designed for. - It does not make sense to impose different rules according to the size of the water supplier. It would make more sense to apply it according to the size of the supply zone, especially regarding supply hazard assessment. - This list of parameters must be split as it was in the current Directive (98/83) with parametric values and indicator parameters, some parameters having no link with health. - It is important maintain to maintain the possibility for derogations for the new parameters included in the Directive. - 3 EDC’s: Proposed standards are very low and have nothing to do with health. It is therefore out of the scope (article 2). - Chlorate/chlorite: this new value will be very costly as it involves some time to change the treatment process of disinfection. This cost was not included in the impact assessment. Moreover the guideline set by WHO is 0.7 mg/l. We advocate for this standard. - Lead: we advocate for no change in lead standard as explained in the paper attached. - Legionella: monitoring should be based on a risk assessment with a focus on vulnerable building. Only legionella pneumophilia should be monitored and only if the water temperature exceeds 30°C. - Risk-based approach : We propose to adopt a different timeline for the three components of the RBA : 6 years for all suppliers for hazard assessment of water bodies and for supply risk assessment, 10 years for domestic distribution risk assessment and no time limit for individual dwellings. If we had to do this in 3 years, we would have to recruit 14.000 people for controlling dwellings ! Art. 10 : Aquawal supports Europwide hygienic requirements for products in contact with drinking water, especially lead-free materials. §2c : water suppliers do not have to modifiy water composition to avoid quality deterioration due to indoor installations. Art 11 : The proposed sample frequency is not realistic for all parameters in list A and B and contradictory to the principle of a risk-based management. Moreover, this will induce a lot of supplementary analysis costs without any gain in water quality. We then ask for restoration of the proportionality principle as it is the case in the current Directive. EC must also reintroduce the concept of water supply zones and adapt monitoring according to their size. Art 12 : We do not support the idea that any exceedance in the current list of parameters should be considered automatically a potential danger to human health. Art 13 : Access to water is a crucial point and we are totally in favor of promoting drinking water amongst the population. Regarding physical access, we have to underline that implementation of this article can be difficult and we suggest that the European Commission in collaboration with Member States gives guidelines on the methodology and indicators needed to fulfill this prescription. §1c is too unprecise. These points are crucial for promoting such water and we would like an obligation for restaurants, canteens, administrations... to offer free tap water to people attending these buildings. Art 14 : Annual performance of water services: The energy consumption is not a performance indicator. The Linear loss index is more relevant than leakage rate. Data must be framed and explained to consumers. Number of complaint is a complicated topic. §2 : the amount of data will make invoices unreadable.
Read full response