Danish Environmental Technology Association
DETA
The objective of the Danish Environmental Technology Association is to put advanced solutions to global environmental challenges on the top of the political agenda nationally, in the EU and internationally.
ID: 951522826477-11
Lobbying Activity
Response to Evaluation of the Urban Waste Water Treatment Directive 91/271/EEC (UWWTD)
9 Nov 2017
The Urban Waste Water Treatment Directive has significantly improved the waste water treatment in Europe. The legislation is however more than 26 years old and technology innovation and development has evolved considerably beyond the scope of this directive.
While not compromising the overall purpose of the UWWTD the evaluation should seek to unlock the great potentials in relation to: cost-effective energy production based on waste water sludge, better use of energy efficient technologies and process management, recovery and reuse of valuable resources and new treatment steps for environmental harmful subsidies.
A widened scope including the suggested areas would be a direct vehicle to support the implementation of the EU circular economy package with concrete business cases based on reuse, recovery and upcycling of valuable and scarce resources.
A revised directive could furthermore give various positive spin offs to the overall EU-obligations in the Paris Agreement and the implementation and of the Sustainable Development Goals. In particular there is huge untapped potential in energy efficient water solutions. The EU water and waste water facilities are high energy consumers and water and wastewater treatment accounts for 30-50 % of the electricity bill in the municipalities [IEA 2016].
With existing cost-effective technology solutions, it is possible to transform the whole water cycle (drinking water and wastewater) into energy neutrality and significantly reduce the electricity bill and the CO2 footprint of municipalities.
Already existing waste water treatment plants can produce up to 160 % more energy than used for the wastewater treatment by converting waste water sludge in to bioenergy reducing the operating cost (OPEX) significantly.
Energy used in the water and wastewater segment will according to the UN be doubled in 2040, so ths potential is only increasing over time.
If the EU moves in the direction of transforming the waste water treatment sector into a net energy factory, meanwhile handling various environmental harmful subsidies, European municipalities could serve as export platforms for the expanding global market for smart city solutions.
This could stimulate export based growth, and create new jobs in all parts of Europe.
DETA’s suggest:
• Energy Production: A new urban waste water treatment directive should further encourage energy production and energy efficiency in the waste water sector setting common targets aiming for an energy neutral water cycle in the EU. Transparent benchmarking should be the first step.
• New treatment steps: The refit-evaluation should evaluate whether new treatment steps should be addressed by the UWWTD. New quality standards for environmental harmful subsidies such as pharmaceuticals from hospitals, endocrine disrupters in general and microplastics should at least be considered in a revised directive.
• Better monitoring: The refit-evaluation should envisage new possibilities for better monitoring of the discharged treated waste water taking in to account smart metering and continuous monitoring technology i.a.
• Water reuse: The obligation in the existing directive to encourage water re-use should be evaluated in order to accommodate new obligations setting up common standards for efficient use of treated technical water: car washing, cooling towers i.a.
• Adaptation to Climate change: Its should be evaluated how a new directive could tackle the big climate change challenges with heavy rain and sewer overflows as one severe consequence.
• Assesment of available technology solutions for implementing existing obligations and unlocking new innovative potentials.
Read full responseResponse to Fitness check of the EU Ambient Air Quality Directives
23 Aug 2017
DETA welcomes the European Commission’s initiative to undertake a Fitness Check of the EU Ambient Air Quality Directives. DETA agrees that it is urgent to assess the relevance, coherence, and effectiveness in addressing today’s most pressing air pollutants and setting new strong air quality standards to protect human health and ecosystems, in accordance with new scientific understanding and the WHO-guidelines.
DETA’s overall position is:
1) The AAQD should be revised so target values correspond with the WHO guidelines.
2) The measurement of exceedances should to a larger extend take in to account the pollution “peak hours” were the exposure of air pollutants is most harmful for EU citizens as a supplement to day and year average values.
3) The refit-evaluation should evaluate whether new pollutants should be addressed by the AAQ Directive. Ultra-fine particles should as a minimum be covered as recommended by the WHO-guidelines.
4) The Fitness Check should analyze the cost-effective technology solutions to meet the threshold values in the existing AAQD and possible new threshold values in a revised directive.
5) A possible revision should establish a new mechanism and format for the member states obligations to establish national air-quality plans covering the national, regional, and local levels and setting up timelines and concrete initiatives.
Specific comments to the roadmap
Section A.1: Purpose
It should be included that the overall purpose is to secure clean air in Europe for all European citizens both for the fitness check and in the directives in question.
Section A.2: Justification
The evaluation should take in to account latest relevant knowledge on the socioeconomic, health and environmental cost for EU-societies due to air-pollution and find better ways to present these data to decision makers at national, regional, and local level.
Section C.1: Topics Covered
It would be beneficial if the fitness check identified why the threshold values in the AAQ Directives are not met by the specific member states.
The fitness check should include a barometer/score list I relation to the questions starting with: “to what extend” making the challenges clear for decision-makers.
Read full responseResponse to Revision of the Drinking Water Directive
23 Mar 2017
1) Gerenal remarks: If the drinking water directive should be fit for purpose on the pathway to 2030 the scope in article 1 and 2 must be widened with a renewed focus on the protection of the available resources of drinking water and the most cost-effective measures of producing and supplying drinking water.
This double purpose goes hand in hand. 1) protecting the available drinking water resource-base and 2) the ability to ensure wholesome and clean drinking water. EU-water utilities cannot continuously supply clean, healthy and affordable drinking water for all, if the resource-base is depleted.
New provisions should only set measures strictly related to the production and distribution of drinking water respecting the provisions in WFD to protect the overall water resource-base in the EU.
2) List of parameter values: The updated list should support the implementation of a risk-based monitoring approach, which makes it easier to detect contaminated drinking water more quickly and efficient.
Parameters such as endocrine disrupters, pharmaceuticals and micro-plastic could be included on the list since they under certain circumstances pose a risk to the quality of the drinking water.
3) Risk based approach: A revised article 7 should promote the water safety plan approach laid down in the WHO Guidelines for Drinking Water Quality.
A revised article 7 and an adjusted Annex II should establish provisions for a new risk-based two-step monitoring regime. The first step should be a new instant monitoring system and the second step should be based on a sample-collection guided by the risk-evaluation in the first step.
The actual risk detected in step one should define the ratio of the following physical sample collection in step two.
The parameter values analyzed in step two should be based on an up-dated version of the existing parameters values.
Many water utilities in EU-member states already have similar monitoring regimes.
4) Water leakage: A new recital and a new article should address the link between protection of the drinking water resource-base and the potentials in reducing water leakage setting up new provisions to reduce water leakage.
New provisions in annex II should link the level of water leakages with levels of physical controls/sample collection of parameters connected to contamination of water from intrusion. If there is high-levels of water leakage, there should be obligations for more frequent control.
A three-step staircase model could be introduced as the basic principle: < 15 % leakage = XX controls/year: Between 15-20 % leakage= XX controls/ year, > 20 % leakage = XX controls/year.
This should be incorporated as a part of a new risk-based monitoring system.
5) Products in contact with drinking water: There should be one single standard for recognition of products in contact with drinking water. It should be the overall legal principle that a product recognized in one member state subsequently leads to mutual recognition in all other EU countries.
The standards of recognition should be based on the highest possible quality parameters to secure the best protection of the drinking water.
If there are certain local or regional circumstances, there should be a possibility to keep “higher” levels of protection against risk for contamination of drinking water.
Read full response