Asociación Vertidos Cero; para la Prevención, Minimización y Eliminación de los Vertidos
VERTIDOSCERO
La Asociación Vertidos Cero se crea como respuesta a la inquietud social detectada por un grupo de profesionales preocupados por la incidencia de los vertidos sobre el entorno y, por tanto, sobre nuestra calidad de vida.
ID: 66614325870-38
Lobbying Activity
Response to Evaluation of the Urban Waste Water Treatment Directive 91/271/EEC (UWWTD)
6 Nov 2017
Our organization, Asociación Vertidos Cero consider that the Directive 91/271/CEE it has been a good tool to manage and improve the quality of waste water discharges.
In the case of Spain the Directive (brought into force in a spanish “Real Decreto”) has done that Spanish Administration invested a high quantity of money to build collecting systems and waste water treatment plants with secondary treatment for a lot of agglomerations. In spite of that, Spain hasn’t met the obligations and objectives of the Directive in many agglomerations as some verdicts of the Court of Justice of European Union has proven.
We consider that the Directive 91/271/CE has to adapt to the new regulation about quality water, and especially with the Frame Water Directive (Directive 2000/60/CE and other others). For this reason we suggest that the new Directive incorporate these points:
1. It’s important to clarify the definition of “treatment less stringent” and “appropriate treatment” in order to establish concentration values and/or percentage reduction and/or different kinds of waste water treatment that fits with these definition. We think that waste water treatment for little towns or cities as rotating biological contactor (RBC), macrophytes, and others could fit with these definitions. We assume that the concentration levels will be less restrictive than secondary treatment and treatment plants to sensitive areas.
2. In the article 12 and 14 said that the waste water and Sludge arising from waste water treatment shall be re-used whenever appropriate respectively. We thing that the climate change will produce more intensive droughts and water deficit in many Member States.
Besides the Circular Economy Package of European Union want to increase the value and use from all raw materials, products and waste through greater recycling and re-use.
For these reason we consider that the new Directive has to regulate these resource in different ways:
• Establish objectives of waste water re-utilization for different situations , for example depending of the water deficit in water bodies,
• Establish treatment and minimum levels of quality depending of the use of re-utilization waste water.
Spain is the Member State with more volume of waste water reutilization and has pass regulations about this topic (Royal Decree 1620/2007). Also there are ISO standards (ISO 16075/2015). As above there are different text where the Commission can study and apply.
• About sludge, we think that is necessary establish a minimum concentration level of different pollutants (like metals and microbiological pollutant) for different uses of this sludge.
3. The Directive 2008/105/EC modified for Directive 2013/39/EC establish the obligation of create an inventory of discharges with priority substances and take measures to reduce or stop the discharges of these substances. However we consider that the new Directive has to regulate different aspects about discharges with priority substances, in order to make sure that the chemical status will be good downstream. One way could be indicate that the Authorities have to implement concentration levels established in best available techniques (BAT) commission Implementing decision (EU) or maybe indicate a protocol or methodology to calculate the concentration levels of the pollutants in the discharge (mass balance or best methods).
4. The previous observation (methodology to calculate concentrations levels of pollutants) could be used again in order to regulate discharges that are a big pressure to the ecological status of the downstream water bodies.
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