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Asociación Española de Abastecimientos de Agua y Saneamiento

AEAS

Founded in 1973, AGA/AEAS is the leading association of water service providers and enterprises responsible for the operation, maintenance, exploitation and management of urban water services, encompassing more than three quarters of the Spanish population.

Lobbying Activity

Response to Evaluation of the Fertilising Products Regulation

19 Sept 2025

For DAQUAS, the exclusion of sludge in EPR has significant impacts for urban water operators, as it represents a loss of valorization opportunities and it may discourage investment in advanced treatments and recovery technologies. Wastewater treatment plants recover essential nutrients (nitrogen, phosphorus, organic matter) that can replace imported mineral fertilisers and support the EU's circular economy, food security and climate goals. However, the current FPR framework still limits market access for many safe and effective recovered products. This situation could be an obstacle to the circular economy, as it limits the potential of sludge as a source of recycled nutrients to produce EU fertilizer products, despite the existence of established control and traceability systems. Further information in the attached doc
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Response to Evaluation of the Public Procurement Directives

7 Mar 2025

For The Spanish Water Association AGA-AEAS, the future regulatory revisions should ensure that criteria beyond price are genuinely considered and rewarded in procurement processes to maximize value for money. Furthermore, the current legal framework lacks an agile crisis-responsive mechanism especially in cases of sudden significant increases in the prices and market failures that result in shortages of essential goods and services. Finally, contracting authorities continue to require an extensive amount of documentation at the pre-tendering stage which has created challenges for bidders, particularly SMEs. More detailed explanation in attached file.
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Response to Commission Directive amending Annex III of the Nitrates Directive

17 May 2024

The Spanish Association of Water Supply and Sanitation (AEAS) expresses its concern regarding the draft act to amend the Nitrates Directive due to its potential impact on water resources, in particular those used for abstraction of water intended for human consumption. AEAS calls the Commission to carry out an accurate and thorough impact assessment of its proposal and utilise a clearly defined substitution approach when allowing for the use of RENURE fertilisers. Furthermore, it is relevant to take into consideration: 1. The definition of a maximum limit on the input of Kg N/ha in terms of assimilable Nitrogen and not total Nitrogen. 2. Measures should not be aimed at being subsequently fulfilled with mineral nitrogen sources, which is a nitrogen much more mobile/releasable in soils. 3. Codes of good practices must be defined to ensure proper use and environmental protection of water resources, with special attention those used for abstraction of water intended for human consumption. 4. Measures could be more ambitious and be applied to other sources than manure. For example, there is mention of struvite from manure, ignoring struvite from wastewater treatment plants. Further information in the attached file.
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Response to Revision of the Urban Wastewater Treatment Directive

14 Mar 2023

For AEAS, the proposal provides greater protection for EU citizens and ecosystems, as well as transparency and governance within the framework of digital transformation and aligning the industry with the European Green Deal. However, a sounder financing strategy, a deadline extension, a more decisive commitment to implement control at source measures and a deeper approach based on risk management need to be addressed before the approval, due to their implications so that new legislation is effectively implemented. AEAS welcomes the revised Urban Waste Water Treatment Directive and agrees with the European Commission that further progress, not only in terms of environmental protection but also regarding governance and funding, is a necessity to fulfil the UN Sustainable Development Goals (SDGs), as well as those laid down in the European Green Deal. AEAS is of the opinion that the submitted text constitutes a significant step forward from the current one and it is very important for the Spanish waste water sector. The objectives of this new draft directive are aimed at achieving greater protection for EU citizens and ecosystems from sources of pollution, as well as improving transparency and governance within the framework of digital transformation and aligning the industry with the European Green Deal. However, AEAS believes that the proposal comprises some aspects that shall be discussed before its adoption due to their implications so that new legislation is effectively implemented: Given its great economic impact, the Proposal should promote a sound financing strategy, while ensuring the affordability of water tariffs and better application of the Polluter Pays Principle, in relation to both users and those directly concerned with the principle of extended producer responsibility. A deadline extension is needed to meet many of the requirements, thus making them feasible. Otherwise, the collapse of the proposed measures is certain. A more decisive commitment should be made to implement control at source measures for pollutants, and not to place the solution to issues created earlier in the process in the hands of urban waste water treatment plants (WWTP). Measures should be taken to identify and reduce the sources of pollution when pollutants that pose a risk to treatment at WWTP, the health of sanitation workers or the receiving environment are identified at the inlet or outlet of WWTP. In order to prioritise necessary actions and increase efficiency, the proposal should focus on an approach based on risk management and the protection of receiving water bodies, to achieve good ecological status, rather than on establishing overly strict emission limit values for water quality parameters. More details in the attached file
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

AEAS welcomes the Proposal for a Directive on energy efficiency (recast) (EED) and supports the role of circular economy and the life cycle approach. Water operators are moving towards energy neutrality, combining high energy efficiency and generation of renewable energy. The EED and the renewable energy directive (RED) must accompany and support this process, considering GHG emissions, as the link between both directives and climate policies is relevant to ensure sustainable investment decisions in the water sector. Water operators are minimising their energy consumption through different measures. However, there are elements beyond their control with a substantial impact on energy consumption: topography, population density/growth, climate change, new quality requirements for drinking and waste water. General targets would disadvantage those who have implemented far-reaching projects, and further measures could impact water tariffs and might not be technically feasible or economically justifiable. The aim of the water sector is to protect public health and the environment. Water operators may need to introduce additional treatment to reach new quality requirements despite this may lead to more energy consumption. Many water operators expect significant economic and population growth in the coming decades that will increase the demand for existing plants and may require new plants. Some regions will have to increase water reuse to cope with climate change impacts, but this is an energy intensive process. Hence, the generation and use of renewable electricity and/or bio-gas and bio-methane will be important to reduce GHG emissions. We would recommend not introducing a specific energy saving target for the water sector and expressing the energy efficiency of water services not in kWh/m3 or other units, but in terms of achieving individual cost-effective saving potential identified through energy and GHG emission audits, setting a baseline at facility level from which energy savings can be deducted. Recognising the need for the target for a final energy consumption reduction for the public sector, a specific saving target for the water sector would not be realistic, since its contribution will depend on the level of energy efficiency already achieved (and the cost effective savings potential) and the need for additional treatment steps to meet regulatory requirements. Further clarification would be needed to determine which water operators belong to the public sector and which buildings would be covered. This is not easily deductible from the definition of “public bodies”, given the different governance and management models of water services. The term ‘enterprise’ brings confusion on the entity to which the energy consumption threshold would apply. We suggest using facility or utility as more appropriate terms for the water sector. The UWWTD, which is expected to set energy-related requirements, is better placed to address energy efficiency of the wastewater sector as it will address all operators whereas the Proposal only refers to public bodies or enterprises. We support the mandatory energy audits for the largest energy users but energy efficiency and GHG emissions requirements should be defined in the revised UWWTD. The EED should clearly specify that these requirements only apply to energy users not covered by sectoral EU legal acts. We stresses the importance of considering the energy consumption breakdown per treatment step when identifying cost-effective savings potentials and determining GHG emissions, avoiding energy efficiency improvements that increase GHG emissions. Considering the current lack of investments in the water sector, further achieving energy efficiency in the water sector requires important investments that should benefit from EU sustainable funding, for example through access to the LIFE Clean Energy Transition sub-programme 2021-2027.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

AEAS welcomes the Proposal for a revised Renewable Energy Directive (RED III) but regrets it doesn’t specifically address the water sector, despite its contribution to the renewable energy targets and climate policies: generation of electricity from hydraulic turbines and from on-site wind mills/solar panels, biogas from sewage sludge, electricity and thermal energy from sewage sludge mono-incineration, heat pumps and thermal energy from wastewater. Biogas produced by the water sector can be consumed on site through cogeneration of heat and electricity or upgraded to biomethane for injection into the gas network or for vehicle fuel, becoming an alternative for transport, building and industrial sectors. Besides, the renewable energy produced in the water sector could be transformed into renewable hydrogen. The emissions of GHG from biogas production may lead to a trade-off between energy recovery and climate neutrality. The link between the RED III, the Energy Efficiency Directive (EED) and other climate regulations should be strengthened. The definition of biomass in the RED II 2018/2001 should be modified to duly recognise sewage sludge as a source of origin of biogas: “(24) biomass means the biodegradable fraction of products, waste and residues from biological origin from agriculture, including vegetal and animal substances, from forestry and related industries, including fisheries and aquaculture, as well as sewage sludge from waste water treatment and the biodegradable fraction of waste, including industrial and municipal waste of biological origin;” The cost-efficient recovery of energy from the water cycle enhances renewable energy production and circular economy; is aligned with RED III objectives in terms of targets and potential deployment of renewable energy; and improves the EU energy independence while minimising pollution. This justifies the development of support schemes to address the unequal renewable energy generation in the EU and to reach the highest cost-efficient renewable energy generation potential in the urban water cycle. This support should include regulatory aspects ensuring access to the energy grids for integration of renewable energy production in the energy system. Funding should cover innovation on renewable hydrogen production at WWTPs. We welcome the measures to support and improve the Guarantees of Origin and the Union Database. Using credit guarantees to reduce the financial risks associated with Power Purchase Agreements (PPA) might generate market distortions, so PPA should remain a market instrument. Barriers have been raised for electricity and biomethane discharge into grids and unjustified taxation has jeopardised the deployment of the renewable generation. This should be considered in the Proposal and in related legislation. The European state aid framework should be adjusted to ensure economically viable use of biogas without additional energy tax burdens. The water sector could contribute to the targets on district heating and cooling: thermal energy can be recovered from effluents in WWTPs or from incineration of sewage sludge. Biomethane from WWTPs could contribute to the Proposal’s targets for the transport sector. Sewage sledge is included as advanced biofuels in Annex IX-A. However, the additional costs of upgrading biogas to biomethane need increased financial support. The Taxonomy delegated act on climate mitigation discourages the use of biogas as sustainable vehicle fuel due to the “tailpipe principle”, which may result in reduced investments in biogas production facilities and in the upgrading of biogas to vehicle fuel. The EC should apply the technology-neutral well-to-wheels principle on emissions and consider the entire life cycle of both fuel and vehicles. The tailpipe principle should be changed from “the vehicle has zero direct (tailpipe) CO2 emissions” to “the vehicle has 75% less CO2 emissions calculated as well-to-wheels principle on emissions”.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

AEAS welcomes the Delegated Act supplementing Regulation 2020/852 to establish criteria for determining the conditions to qualify as contributing substantially to climate change mitigation or adaptation and whether the economic activity causes no significant harm to other environmental objectives, due to the relevance of climate change on water services and the need of a holistic approach under the Green Deal. Despite the need of common criteria to access sustainable financing, some aspects in the Proposal may jeopardise the contribution of water services (WS) to climate change mitigation/adaptation, to circular economy and, ultimately, to sustainable development. Water supply services (WSS), according to Art. 12.1.b of Regulation 2020/852, are contributing substantially to the sustainable use and protection of water by protecting human health from the adverse impact of pollution of water intended for human consumption. To fulfil this goal, complying with the future DWD requires energy-intensive processes: ultrafiltration, granular activated carbon filters, ozonation, advanced oxidation. Energy consumption of WSS is conditioned by factors as the origin/type of raw water, orography of their location (gravity or pumping) and meteorological conditions that should be considered when qualifying WSS, as well as the origin of energy being used (shouldn’t qualify the same way using renewable energy as fossil fuel sources). We suggest disaggregating the indicator by each of the stages of WSS: collection, treatment and supply. The ILI indicator defined seems rather premature, and ambitious, if considering that the future DWD has established a period of 5 years to study the most efficient value to be achieved ILI, which could lead to an important economic impact. It would be convenient to define the perimeter of the renewal of WSS to avoid applying the energy performance and network efficiency indicators to the entire system, but rather only to those parts being renewed. Waste water services (WWS - collection and treatment), also depend on the orography and climate conditions. Net-Zero-Energy use in WWS can be challenging, especially in smaller ones. It will require further promotion and implementation of anaerobic digestion of sewage sludge and of cogeneration, as well as considering the use of biogas for other uses than cogeneration (production of vehicular biomethane, hydrogen production, injection of biomethane to the gas network) in its final balance. The investment needs of Spanish WS (€ 2,221 million/year for infrastructure renewal and € 4,900 million/year for new infrastructure until 2033 to meet wastewater treatment objectives, conserve existing heritage and adapt to future requirements -higher quality, adaptation to circular economy, reinforcing action against climate change-) and the age of infrastructure are the main challenges the sector is facing. The required improvements related to renewal of WS can limit the efforts the sector is making. The role of WS in a circular economy should be further considered, as a means to contribute to mitigation of and adaptation to climate change. Sewage sludge management and water reuse should have a bigger role in qualifying as sustainable activities, as they contribute to efficient use of resources, nutrient recovery and energy efficiency. When analysing climate change mitigation, measuring it in terms of carbon footprint, instead of energy consumption, would allow for also including the use of renewable/green energy in the equation. Different thresholds for indicators should be defined for existing and new assets, as well as a transition period, including a transition of the thresholds. The Delegated Act should help promoting sustainability of WS instead of limiting it, bringing policy coherence and avoiding getting stuck in a spiral where WS cannot become more sustainable because they cannot access financing as they are not sustainable enough, and avoiding excessive costs for cizens.
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Response to New EU Soil Strategy - healthy soil for a healthy life

10 Dec 2020

Sewage sludge is the main residue obtained in the treatment of urban wastewater and, at the same time, it is the second major waste of municipal origin (after urban solid wastes). According to data of a survey carried out by AEAS, in 2018 the production of sewage sludge was of around 1,057,000 tons of dry matter. In addition, this amount continues to increase due to the construction of new waste water treatment plants and the application of new tertiary treatments. The most common uses for sewage sludge in Spain are land application in agriculture (78%), incineration (15%) and landfill disposal (7%). The nutrient content of the sewage sludge varies depending on the type of wastewater and the treatment that has been applied. These nutrients give an agronomic value to the sludge and justify its use as a fertilizer, thus allowing the recycling of waste, resulting in a highly advisable practice from the point of view of energy and resource saving and, therefore, for sustainability and self-sufficiency. The Nitrogen content of the sludge is one of the main factors in favour of its use as a fertilizer, as some nitrogenous compounds are easily and quickly assimilated and other nitrogenous compounds can also represent a reserve in the medium term. The Phosphorus content in sludge is also significant, and it must be taken into account that it is a limited resource with world reserves being depleted, which makes saving and recycling strategies more necessary. Potassium is the nutrient with the lowest content in the sludge due to its high solubility, since it is removed with the water in the dewatering processes. The agricultural sector also needs to ensure a supply of organic matter (humus) to compensate for losses that occur in harvesting and grazing activities, as well as leakage to surface and groundwater and to the atmosphere. Sludge contains organic matter, as well as the above mentioned nutrients, and therefore can act as a supplier of all them to the soil and crops. Organic matter is a complex mixture of proteins, humic and fulvic acids and other essential components for the good condition of the soil, crops and biomass. The current use of agricultural soils is leading to an impoverishment of organic matter, especially in the countries of the Mediterranean area. This fact has been highlighted in various communications and studies that demonstrate an urgent need to restore the levels of organic matter in agricultural soils and the use of organic fertilizers, such as treated sewage sludge, can contribute to this objective, thus improving the physical structure of the soil, providing better porosity, structural stability and improving the capacity of water retention and cation exchange. In conclusion, it can be stated that appropriately treated sewage sludge can be valued (and is valuable) for agronomic uses, providing important benefits to both crops and soils. This use is considered the priority for sludge management since it allows to harmonize in a very satisfactory way the optimal management of the sludge with the fertilization of crops and the improvement of the soils, leading to a sustainable practice and recovery of resources. To date, there is no alternative solutions to the agricultural destination of sludge in Spain because the landfill solution is banned by the EU and there are no incineration and/or drying facilities, not even for a 10 % of the sludge production.
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Response to Revision of lists of pollutants affecting surface and groundwaters

17 Nov 2020

Drinking water and waste water services have an essential mission: ensure the supply of high quality drinking water and effectively treat waste water thus contributing to the protection of human health and the environment. We welcome the opportunity to share our views on the revision of the lists of pollutants affecting surface and ground waters. This initiative should be based on art.191.2 TFEU and its principles: the precautionary principle, the principle that preventive action should be taken and that environmental damage should, as a priority, be rectified at source, and the principle that the polluter should pay. Given the various pathways through which pollution reaches the environment, water resources protection is only effective if preventive action is taken and the source-control approach implemented: the latter is also instrumental to achieve a truly Circular Economy for water, the Zero Pollution ambition and the Climate neutrality by 2050. That is why we support coherence in the EU legislation and Green Deal strategies. To ensure the supply of high quality drinking water to citizens, the protection of surface water and ground water resources from pollution is paramount, as recognised in the WFD, whose objectives should be mainstreamed in other sectoral policies. The wording of art.7.3 of the WFD is clear but it is not yet implemented: “Member States shall ensure the necessary protection for the bodies of water identified for the abstraction of water for human consumption or intended for such future use, with the aim of avoiding deterioration in their quality in order to reduce the level of purification treatment required in the production of drinking water “. The revision of the lists of pollutants should fully align with the ambition of the Chemicals Strategy for sustainability and the Zero Pollution Action Plan. Thus groups of substances and mixtures should be regulated according to a hierarchy of pollutants based on criteria such as CMR, PMT, PBT and EDC, and on the relative ECHA’s work, giving priority to those pollutants (or their metabolites/degradation products) that are relevant for drinking water resources protection and for the protection of ecosystems. We expect that new Drinking Water Directive parameters are considered when revising the water resources protection legislation (EQSD, GWD). It is fundamental, however, that sectoral legislation (pharmaceuticals, cosmetics, detergents, pesticides, biocides and other chemicals and agriculture legislation) contribute to reach water policy objectives. At the same time the Commission should speed up the implementation of the measures proposed in the Strategy on Pharmaceuticals in the Environment so that pharmaceuticals residues pollution is controlled as much as possible at the source. On the Priority Substances list we welcome the intention to consider PFAS as a group of substances: for these substances we support a strict restriction based on essential-uses. We are available to engage further with the Commission and Member States on the identification of other substances. We would support a wider revision of the EQSD in order to take into account of mixtures and the effect-based monitoring. Concerning the Annexes I and II of the Ground Water Directive we support the inclusion of the 10 PFAS substances and other substances (pharmaceuticals) identified by Member States authorities. We would also favour the inclusion of the “Sum of 20 PFAS” and “total PFAS” parameters (new Drinking Water Directive) to ensure consistency. In the last-resort case water service providers need to implement additional costly treatments in order to remove micropollutants and microplastics to fulfil legal requirements and in order to preserve the affordability of the water services, the extra-treatment costs have to be covered according to the polluter-pays principle through various tools, included extended producer responsibility (EPR) schemes.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

26 Oct 2020

AEAS welcomes the opportunity to share its views on the Zero pollution action plan for water, air and soil. We agree with the action plan be based on the art.191.2 TFEU and its principles: the precautionary principle, the principle that preventive action should be taken and that environmental damage should, as a priority, be rectified at source, and the principle that the polluter should pay. Drinking water and waste water services have an essential mission: the protection of human health and the environment. To ensure the supply of high quality drinking water to citizens, the protection of water resources from pollution is paramount, as recognised in the WFD, whose objectives should be mainstreamed in other sectoral policies (as confirmed by the fitness check). Given the various pathways through which pollution reaches the environment, water resources protection is only effective if preventive action is taken and the source-control approach implemented: the latter is also instrumental to achieve a truly circular economy. The most sustainable and preferred solution remains to prevent pollutants and contaminants of emerging concern (CECs) from entering the water cycle in the first place since they can directly or indirectly enter the water cycle and, once there, they can pose a risk to water resources. Current technologies used in water treatment plants are not entirely capable of removing them, although the removal of microplastics is generally good. This is true in particular with PMT substances: we call on the Commission and Member States to define mobility as a criterion according to which substances can be restricted. The action plan for the phase out of non-essential uses of PFAS accompanying the Chemicals Strategy should be implemented swiftly. Extra-treatment of pollutants by water operators may be part of the solution as a means of last resort according to the polluter-pays principle polluters should then bear the costs of extra treatment. This could be done for instance by developing extended producer’s responsibility schemes. The Zero Pollution action plan should set up a hierarchy of pollutants based on criteria such as CMR, PMT, PBT and EDC, and on the relative ECHA’s work, giving priority to those pollutants (or their metabolites/degradation products) that are relevant for drinking water resources protection. At the same time it is fundamental that a life-cycle approach is considered for all pollutants emitted in the environment (water, air, soil) in order to protect ecosystems. We are available to further assist the Commission in this process. We support coherence in the EU legislation and strategies. We expect that new Drinking Water Directive parameters are considered when revising the water resources protection legislation (EQSD, GWD). Sectoral legislation (pharmaceuticals, cosmetics, detergents, pesticides, biocides and other chemicals and agriculture legislation) should contribute to reach water policy objectives. We think that the important, but still rarely implemented, mechanism included in the Pesticides Regulation - by which Member States shall review an authorisation, where it is concluded that the objectives of the WFD on the reduction of pollution in surface water and ground water and allowing for the reduction of the level of purification treatment necessary for the production of drinking water, cannot be met - could be replicated in other sectoral legislation. These source-control actions are intended to limit pollutants entering the water cycle thus favouring the development of the circular economy: the less waste water is polluted, the easier it is to use reclaimed water or sludge. The WFD adopted in 2000 aims at establishing a framework for the protection of EU waters but 20 years later its objectives have not been reached yet: the Zero Pollution Action Plan, including the elements mentioned above, must play a role in fulfilling the WFD objectives and the protection of all water bodies.
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Response to Revision of the Urban Wastewater Treatment Directive

7 Sept 2020

AEAS (Spanish Association of Water Supply and Sanitation), representing almost all water service providers in Spain, welcomes the IIA on the revision of the UWWTD in order to address new societal and environmental challenges and highlights the need of policy coordination with other directives: WFD, IED, SSD and water reuse regulation, and the role of the UWWTD regarding the European Green Deal. Emerging contaminants. The best approach for this complex problem should be a previous characterization and risk assessment in coherence with the list of priority substances and the EQSD. Besides, each country can define river basin specific pollutants related to their local conditions. The programmes of measures of each RBMPs must define the best cost effective options. Pathogens. Removal of pathogens should be considered to limit the spread of potential diseases, especially for downstream applications of the treated waste water (bathing, reuse, drinking water, etc.). Nutrients. Removal of nutrients should be required according to the characteristics of the receiving environment (sensitive areas) and the uses of the water. The reduction of N and P limits has strong economic, energy and salinization implications due to the increase in reagents consumption. Industrial discharges. According to the IIA, discharges of industrial wastewater into collecting systems and urban WWTPs will not be considered. This is a major shortage since industrial effluents may have substantial influence on both treatment process and effluent quality. Compulsory and effective control of industrial discharges of all stakeholders (including local authorities) is essential. We support strengthening the polluter pays principle regarding trade effluents, including extended producer responsibility. Small agglomerations. WWTP below 2000 p.e. and individual treatment systems must be considered within the assessment options, including the resilience and sustainability of these small WWTW, along with their operation and maintenance. The IIA must also look at the consequences of treatment or lack of treatment in rural areas. Storm water overflows and urban run-off. They are important sources of pollution and must be treated appropriately. The UWWTD is unclear and incomplete on its requirements for sewerage systems. As sewerage systems must achieve multiple objectives any revision on collection system requirements cannot be solely on the basis of pollution objectives. We emphasize the need of a holistic approach, including urban and comprehensive planning of the sanitation system (sewerage+treatment) together with risk assessment and management in coherence with the WFD and other directives (bathing waters). Circular economy. Sewage sludge is a valuable source of organic matter and nutrients. In Spain 80% of sewage sludge is processed and used as an organic fertilizer to fight against desertification. Water reuse is essential to reduce the water footprint and fight against water scarcity. We would welcome a clear supportive legislative framework to secure the current different possibilities to manage sewage sludge and to enhance water reuse in agriculture and other areas, including the reuse of treatment by-products: struvite, sands and ashes. Energy. Energy efficiency requires measuring and benchmarking. Energy audits are favourable measures as they allow considering local circumstances and finding optimal actions for each situation. It is important to minimize WWTP energy consumption and increase production. More knowledge is required to control GHG emissions from WWTPs and consider their role as emission sinks. Cost. It is a priority to consider the needs for investment and public and private financing to achieve full compliance with the current Directive and maintain and renew existing infrastructures, considering the effects of climate change and population growth. Water tariffs must be adapted to the necessary investments.
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Response to Evaluation of the Sewage Sludge Directive 86/278/EEC

31 Jul 2020

AEAS (Spanish Association of Water Supply and Sanitation) comments to the Roadmap of the evaluation of Sewage Sludge Directive 86/278/EEC. The Value of Sludge More than half of the soils in Southern Europe and the Mediterranean Basin are very poor in organic matter, with a content of less than 1.7% of TOC, and they are at high risk of desertification. In Spain 80 % of the sludge is being applied in agriculture since decades ago providing high benefit to soils with chronic lack of organic matter. The use of organic fertilizers, such as sewage sludge, improve the physical structure of the soil, providing greater porosity, structural stability, water retention capacity and ion exchange. These soils have high pH and low heavy metal content, which makes them ideal for the application of this type of organic amendment. Agricultural application is always carried out based on the limiting element that is usually Nitrogen, in this way the contribution of heavy metals to the soil is very low compared to the limitations set in the Directive. This can be an element to introduce in the new Directive (dosage by nitrogen in addition to heavy metals). To avoid the problem of emerging substances, the precautionary principle should work with the effective implementation of the REACH Regulation. In general pollution in soils due to metals or other organic pollutants have not been a problem until now after many years of application. The agricultural application of the sludge fits perfectly with other environmental policies of the EU, such as those related to Circular Economy, Emission Control, Carbon Footprint, and Nutrient Recycling (Especially Phosphorus given the limitations of its availability). The anaerobic treatment of the sludge generates biogas that effectively contributes to reducing the energy dependence of the treatment facilities and their carbon footprint. We understand that the agricultural application of sludge must be regulated by a Risk Management policy, where the treatments required for sludge are based on the crops for which they are intended. For example, there are crops that are large receivers of sludge such as dry land cereals that do not require especial treatments, and on the contrary, the cultivation of vegetables for consumption in crude must have the maximum guarantees against pathogens.
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Response to Sustainable use of pesticides – revision of the EU rules

31 Jul 2020

AEAS (Spanish Association of Water Supply and Sanitation) welcomes the intention of the Commission to review the sustainable use of pesticides Directive (SUD). Pesticides impact on water quality across the EU (impacts from agriculture are amongst the most significant pressures identified by Member States in most RBDs as posing potential risk of deterioration or non-achievement of the environmental objectives, as stated in the 2019 Report from the Commission to The European Parliament and The Council on the implementation of the Water Framework Directive (2000/60/EC)) and a failure of the SUD implementation has an impact on water intended for human consumption, posing both a risk for the environment and human health. The European Parliament resolution of 12 February 2019 concluded that “preventing pesticides entering freshwater systems is more cost-effective than removal technologies”. SUD implementation is key for the development of the European Green Deal, the Farm to Fork Strategy, the Zero Pollution Strategy, the achievement of the environmental objectives of the Water Framework Directive and the One Health European Joint Programme. One of the main problems is that Integrated Pest Management (IPM) implementation relies on decisions made at Member State (MS) level, rather than at EU-level (EFSA). Notable asymmetries were found in the Scandinavian countries due to the treatment given by each MS. A need for improving the permeability between the decisions of MS could improve IPM implementation. The automatic mutual recognition procedure between MS could be based on a selection of core parameters according to technical and scientific criteria. Another problem is that the uncertainty in the approval of active substances (AS) and product authorization (PA) may increase costs and deadlines. This uncertainty jeopardizes the implementation of the IPM. New requirements, once the Completeness Check is concluded, delays the deadline (from 2.5-3.5 years up to 10 years) and increases costs, that may exceed 1.2-1.5 M€. Applicants may attempt to recover the investment in AS approval and PA dossiers. Therefore, the scope and objectives of an AS approval dossier must be clearly defined from the beginning. E.g. the revised endocrine disruption identification scheme (ECHA&EFSA-2018) has recently been implemented for the approval of AS, such as PPP (EFSA) or biocides (ECHA). It implies delays and high costs that can slow down the introduction of new products in the market. In addition, limited incentives for pesticide users to switch to alternative methods of pest control under the Common Agricultural Policy (CAP) can restrain IPM implementation. PPP contamination of raw water generates external costs. The removal of these compounds implies processes like advanced oxidation (AOP), powdered (PAC) or granular activated carbon (GAC). Cost estimation varies from 20.2 to 69.5 €/1000 m3 depending on the advanced oxidation process applied. Adsorption techniques (PAC or GAC) have a cost from 17.7 to 42.5 €/1000 m3. CAP could take measures to boost alternative IPM, solving lack of research (Barbosa-2016) regarding the removal of several PPP. Hence, the revision of the SUD is key for the development and improved implementation of the European Green Deal, the Farm to Fork Strategy, the Zero Pollution Strategy, the Water Framework Directive and the One Health European Joint Programme, as well as for strengthening the water-energy-food nexus, if impact of pesticides on water quality is considered.
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Response to EU Strategy on Adaptation to Climate Change

26 Jun 2020

AEAS (Spanish Association of Water Supply and Sanitation) welcomes the intention of the Commission to come up with a new and more ambitious climate change adaptation strategy. We support the need for further mainstreaming of adaptation considerations into EU legislation and instruments. The tangible impact of climate change include higher temperatures and too little or too much water. Climate change directly threatens the provision of water services in Europe due to more frequent or intense periods of drought, heat waves or storms and flooding. It will have many (in)direct effects on the quality and quantity of available water resources, the operation of water infrastructure, and the management of the (urban) water cycle. The protection of water resources should be prioritised in the new Adaptation Strategy. With a changing climate it is essential to increase the robustness of the water system by better managing and preserving our water resources. It is time for the EU to become more strategic on how to achieve this. Safeguarding water resources with a changing climate is also essential to guarantee resilient water services. Well-functioning drinking water supply and waste water treatment is a Human Right and essential for the EU economy and the health of citizens. A special focus on the resilience and protection of water resources in the new Adaption Strategy could incentivise all levels of governments to take the right measures to develop appropriate policy supporting water operators and make necessary climate resilient investments. While annual precipitation and total runoff increases may improve the water supply situation in some regions, the drinking water operators will have to adapt to a seasonally or intermittently reduced availability of water resources due to: • the non-existence of alternative water sources and sufficiently flexible local abstraction facilities allowing utilities to respond to a (temporary) loss of individual abstraction types/catchment areas; • the existence of competing water uses and their increasing significance (especially agricultural irrigation); • higher peak demands for drinking water due to increased watering of private gardens and pool fillings. At the same time the rising sea levels lead to the intrusion of saline water into coastal aquifers used for drinking water, as well as intrusion of saline water in sewers, impacting the effectiveness of the biological treatment in waste water treatment plants (WWTP) or impacting the efficiency of the sewage pumping stations located on low-lying coastal areas. Waste water treatment operators will have to adapt: • to the increasing number and intensity of heavy rainfall events ; • to the effect of droughts on dilution in receiving water bodies of WWTP effluent. Certain solutions may be identified in the operations of water services. For drinking water, adaptation measures focus on improving: • Water allocation mechanisms, whilst prioritising water supply; • Management and protection of water resources; • Investments in abstraction, treatment and operation of the supply network; • Sustainable use and demand of water. For urban drainage systems and waste water treatment we see the following adaptation areas: • Tackling combined sewer overflows; • Preventing top much water from reaching the sewers during have rains; • Reducing the impact of effluent temperatures on the receiving water; • Encouraging measures for water reuse and foster the circular economy; Wider application of blue-green infrastructures. The adaptation capacity of water suppliers and waste water operators is also defined by general legal and political parameters, along with financing arrangements agreed locally or regionally within MS. A new EU Climate Adaptation Strategy focusing on the improved management of water resources could certainly contribute to accelerate the transition of water services towards climate resilience.
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Response to Revision of the Drinking Water Directive (RECAST 2017)

23 Mar 2018

AEAS welcomes the revision of the DWD, as Spanish water services strive to guarantee wholesome and clean drinking water Art2: We note that the definition of water suppliers should be by service/system supplied and not just by the amount of people/m3 supplied (some suppliers provide water to several services/systems) and that the group “large supplier” includes rather small ones Art5+AnnexI: We suggest to embrace the WHO recommendations for parametric values and/or grant extra time (15 years) after the deadline for transposition, to adapt and attain them. These values should be based on health effects on humans. Turbidity should only have a limit in Annex I for the compliance point Art7+AnnexII: We support the introduction of RBA, but as drafted it lacks definition of responsibilities. It is also contradictory with such a high frequency of sampling (especially for supply zones producing more than 10.000 m3/day), that would highly impact on the costs of sampling and monitoring, and would lead to an increase in the water price. These issues are not considered in the IA as highlighted by the RSB opinion: http://bit.ly/2tAkQOI The supply risk assessment should be carried out by all suppliers, without distinctions, by 6 years after the end-date for transposition, and its review/update whenever necessary, not with a fixed periodicity Art8.3.a is inconsistent with art7.3 of WFD. Art8.5 also conflicts with the responsibilities on water resources management under WFD Art10: We regret the deletion of art10 of 98/83/EC Dir. The introduction of a “domestic distribution risk assessment” is appreciated, but the proposed provisions do not ensure that EU-wide hygienic requirements for materials and products in contact with DW will be established for ALL products in contact with DW (public water supply infrastructure and domestic distribution systems). We would favour the wording of art10 of 98/83/EC Dir, adding elements to strengthen it Art12.3: We don’t support the deletion of art9 “Derogations” nor the proposal that any exceedances of values should be considered automatically as potential danger to health. Especially with regards to parameters where values have been set based on the precautionary principle (pesticides, EDCs) and the new “microbiological” parameters (formerly considered indicators), an exceedance doesn’t cause an automatic danger to human health. Art12.3 contradicts Art12.2. The competent health authorities should participate in the decision process when the public has to be informed on exceedances and remedial actions Art13: We support the ambition to promote the provision of tap water and to put measures in place that allow vulnerable groups gain access to water. But any schemes need to consider where the responsibility for maintenance, hygiene and installation will lie, as this will likely be outside the remit of water suppliers. Art13.1.b should specify hygiene and costs responsibility at the consumption point Art14+AnnexIV: More transparency and information could lead to more confidence from consumers, but providing raw data would not be helpful and could lead to more confusion rather than clarification, due to specificities of each supply system; extra resources would be needed which could represent extra costs (IA doesn’t acknowledge this). It is unclear who has to ensure that information is made available online. In order to provide really relevant information to consumers to enhance confidence in tap water and water services, a thorough review of information requested in the proposal is needed (lack of homogeneity in definitions and not contextualized information could lead to a pernicious benchmarking exercise). Probably the DWD is not the best instrument to regulate information about the drinking water services, especially if considering the UWWTD may require the same information about sanitation, which will mean losing the holistic approach of water services, so the focus should be kept in water quality
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Response to Evaluation of the Urban Waste Water Treatment Directive 91/271/EEC (UWWTD)

8 Nov 2017

AEAS, the Spanish Association of Water Supply and Sanitation, welcomes the initiative of the European Commission to evaluate the Urban Waste Water Treatment Directive (UWWTD). UWWTD is the central pillar of the waste water services in Europe and has successfully created a level playing field for environmental standards and economic investment by setting baseline requirements for urban waste water treatment. UWWTD is a powerful driver: - to enhance the protection of European waterbodies - to implement the polluter pays principle and to create a high value market of works and services by building and by operating numerous assets for collection and treatment of urban waste water across the EU - to increase scientific knowledge and technical innovation The costs and benefits of the UWWTD implementation should be evaluated. The UWWTD is one of the most expensive European directives as its implementation required heavy and long investments, which are in some places still on-going. It would be very useful investigating the reasons for non-compliance and to carefully assess what can be achieved in the future, especially considering the framework of the sustainable development goals. We emphasize that the main issue for waste water operators across Europe is to manage, refit or renew the ageing assets that require huge and urgent investments. We stress the need for better policy coordination by updating coherence between UWWTD and the European water laws. This will allow that new challenges such as emerging pollutants, management of by-products and water reuse in a more circular economy, adaptation to climate change or evolution towards less energy consuming assets, would be sustainably addressed. We consider that water industry has a role to play in the circular economy. Evaluation of UWWTD directive provides the opportunity to clarify and align the approach for sewage sludge, possibly through adaptation of other regulations, as well as consideration of and alignment with the EU legislation on water reuse being developed currently. Sustainability of services, to keep the water environment clean and to safeguard water resources for human health, requires the polluter pays principle being clarified in many cases and the extended producer responsibility being incorporated. But, taking into the urban dimension of the Directive, it should also consider the user pays principle, in order to help implementation of the cost recovery principle of the WFD, promoting also in this way policy coherence. The evaluation must consider compliance with industrial waste water requirements. Industry should develop responsible solutions to reduce harmful impact of their products on the environment and waste water assets. We consider that control at source is a sustainable way to avoid the release of many pollutants, with end-of-pipe treatment remaining the last option. We believe that for resilient cities, an early integration of the water cycle in city planning and real estate projects has to be addressed to achieve better climate adaptation by reducing urban runoff, discharges from all types of sewer networks and the effects of urban flooding or drought events. Because of the universal nature of water we consider that EU-added value is relevant for management of water and waste water even if implementation may be achieved by locally different enforcement solutions depending on natural or human conditions. We welcome the evaluation as an opportunity for innovation, to enable improvements in performance and efficiency of the waste water sector and creating a more sustainable & resilient approach in the future. We have significant knowledge and expertise in waster services, and therefore, we look forward to sharing our expertise to support the European Commission in the UWWTD evaluation process.
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