Deutsche Vereinigung für Wasserwirtschaft, Abwasser und Abfall

DWA

In der Deutschen Vereinigung für Wasserwirtschaft, Abwasser und Abfall e.

Lobbying Activity

Response to Revision of the Urban Wastewater Treatment Directive

14 Mar 2023

Harmful discharges of micropollutants into water bodies must be prevented, or at least reduced. The Commission's proposal to require more extensive so-called fourth treatment stages at wastewater treatment plants is fundamentally correct. However, in view of the high costs and the significant increase in energy requirements associated with this, it does not make sense to introduce them across the board. The right approach is to take a riskbased approach and to provide these treatment stages where they make a substantial contribution to water pollution control in terms of water bodies and uses. Prevention of harmful inputs is more sensible than their costly elimination, so accompanying measures with a holistic view of production chains and input pathways are essential. The development and implementation of extended producer responsibility for substances that cause problems in the water cycle is necessary and must be linked to requirements for micropollutants elimination. As requested by DWA in its position on the revision of the UWWTD (09/2021), the draft addresses precipitation water as a possible source of pollution. The water protection requirements for combined sewer overflows must refer to the co-discharged wastewater volume. The German water industry is striving for energy neutrality and, in a further step, climate neutrality. However, many plants are dependent on external energy sources. Renewable energy production there must be legally favored and flexibility of regulations is needed to achieve neutrality, e.g. by enabling participation in RE production.
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