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Finnish Water Utilities Association

FIWA

Finnish Water Utilities Association (FIWA) is the co-operation and member association of the Finnish water and wastewater utilities.

Lobbying Activity

Response to Drinking water - conformity assessment procedure

15 Nov 2023

Finnish Water Utilities Association (FIWA) represents water supply and wastewater operators covering 90 % of the water services in Finland. We support the aim of the recast DWD to ensure the safety of materials in contact with the drinking water. In Article 11 of the draft regulation it is suggested that for products which are assessed to be in conformity with national hygiene requirements for products that come into contact with water intended for human consumption and for which the national conformity certificate is still valid on 31 December 2026, it shall apply from [OP please insert the date = the last day of the fourth year after the entry into force of this Regulation]. This would mean a transitional period until the end of the year 2028. With the same justification as for the Commissions implementing decision decision laying down rules for the application of Directive (EU) 2020/2184 of the European Parliament and of the Council by establishing the European positive lists of starting substances, compositions and constituents authorised for use in the manufacture of materials or products that come into contact with water intended for human consumption, Finland considers that the suggested transitional period is too short for the industry to develop, test, standardize take into use new low-lead or lead-free materials, and it interferes the functioning of the internal market. The transitional period should be the same as in the above mentioned Commissions implementing decision. The suitable transitional period for the industry and for compliance with the principles of the Circular Economy Action Plan and Green Deal would be until the end of year 2036. An absolute minimum time that Finland can comply is until the end of year 2032.
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Response to Drinking water - establishing the European Positive Lists of starting substances

15 Nov 2023

Finnish Water Utilities Association represents water supply and wastewater operators covering 90 % of the water services in Finland. We support the aim of the recast DWD to ensure the safety of materials in contact with the drinking water. FIWA request the inclusion of the dezincification resistant (DZR) brass materials presently approved for use in the Nordic countries and notified to ECHA in accordance with the DWD to the first positive list of metallic materials (Appendix II). The water quality in Finland is naturally soft and has lower pH than in most parts of the Europe. This requires the use of the DZR brass materials in water installations to avoid corrosion and ensure acceptable lifetime for the materials and installations. These DZR brass materials are used and needed in small numbers especially in water meter installations and in the household water installations. Despite the use of these DZR brass alloys, the lead concentrations in the Finnish drinking water are low, generally well below the DWD parametric value. According to the assessments conducted, 90 % of the lead in the Finnish drinking waters leaches from the materials used in water installations as the natural lead concentrations in raw waters are low. Thus, the allocation factor of lead (Appendix V page 293, second row, column 7) should be 90 % not 50 % and concentration (column 6) 4.5 not 2.5. FIWA supports the transition to low-lead and lead-free materials in water installations. However, it takes years to develop and bring into the market new materials to replace the presently used. It should also be noted, that the market in Finland (and Sweden) is small, which limits the interest of producers to develop materials suitable for our waters. Thus, a transition period until the end of 2036 is needed for the presently approved substances, compositions and constituents in Article 3. As a general comment, FIWA supports the full ban of all PFAS uses, including all PFAS starting substances in Annex I Table 1. The TOTAL PFAS parametric value under DWD is 500 ng/L. For the interim period before total ban of PFAS, it must be noted that accepted migration cant cause exceedance of the parametric value in drinking water. The Recital1 states that Sacrificial anodes, membranes and ions exchange resins are water treatment chemicals and/or filter media and are covered by Article 12 of DWD, therefore they are excluded of the scope of Article 11. Membranes and ion exchange resins are not treatment chemicals and/or filter media and not covered by their acceptance schemes or standardisation. Thus they should not be excluded from the scope of article 11.
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Response to Establishing harmonised marking to be used for products in contact with drinking water

13 Nov 2023

Finnish Water Utilities Association (FIWA) represents water supply and wastewater operators covering 90 % of the water services in Finland. We support the objective of the recast DWD to ensure the safety of the materials in contact with the drinking water. We call for a simple and clear marking (Annex §1) and a clear reference to the requirements to justify the product marking (Article 2 and annex §2) indicating the safe use in contact with drinking water. These are important aspects for the users of the products.
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Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur)

9 Oct 2023 · UWWTD

Response to Revision of the Urban Wastewater Treatment Directive

14 Mar 2023

Vesilaitosyhdistys (VVY) on vesihuoltolaitosten toimialajärjestö. Jäseninämme on noin 300 vesihuoltolaitosta kattaen noin 90 % maamme vesihuollosta. Järjestetty vesihuolto kattaa tällä hetkellä talousveden osalta yli 90 % ja jätevesien johtamisen ja käsittelyn osalta yli 80 % Suomen väestöstä. Vesilaitosyhdistys nostaa 26.10.2022 julkaistuun luonnokseen uudesta direktiivistä tärkeimpinä huomioina seuraavat asiat: 1)Tulee varmistaa, että laajennettu tuottajavastuu tulee kattamaan mahdollisen kvartäärikäsittelyn investointikustannuksia. Laajennetulla tuottajavastuulla ohjataan painetta sille taholla, jolla on mahdollisuus kehittää ympäristöystävällisempiä tuotteita, eli tuotteen valmistajalle. 2) Ravinteiden poiston tehostaminen tulee kohdentaa sinne, missä se on kustannustehokkaasti ja vastaanottavan vesistön kannalta järkevää. Arviossa tulee ottaa huomioon viipymä vesistöissä ja sen aikainen typen luonnollinen poistuma sekä kylmien vesien erikoisolosuhteet. 3) Typenpoistovaatimukset tulee määrittää kohtuullisiksi, poistovaatimusta tulee alentaa ja huomioida kylmät erikoisolosuhteet. Kokoluokittain tulee lisäksi asettaa eri tasoiset vaatimukset. -Investointeja vaativia tavoiteaikoja tulee myöhentää vähintään 510 vuotta, jotta tuetaan realistista toteutusaikataulua ja kohtuullistetaan investoinneista aiheutuvia kustannuksia. 4) Mikroepäpuhtauksien poistovaatimuksiin indikaattoriaineiden poistoprosenttivaatimuksen vaihtoehtoiseksi sääntelyksi pitoisuusrajat lähtevälle jätevedelle. 5) Energianeutraaliustavoitteet tulee märittää yhteiskunnan kannalta järkevillä rajauksilla. Mahdollisuus ostaa vihreää energiaa sisällyttää mahdollisuus ostaa vihreää energiaa energiantuottajilta ja lisäksi ulkoistetun lietteen käsittelyn energiantuotanto sekä lämmön talteenotto tulee sisällyttää jätevedenpuhdistamon neutraaliuslaskentaan. 6) Esitetty näytteenottotiheys ei ole realistinen, eikä linjassa digitalisaatiotavoitteiden kanssa ja sitä tulee kohtuullistaa ja ohjata toiminnan automatisaation kehittämiseen
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Response to Revision of the Urban Wastewater Treatment Directive

5 Sept 2020

FIWA welcomes the initiative of the EC to revise the Urban Waste Water Treatment Directive. Finnish Water Utilities Association (FIWA) is the co-operation and member association of the Finnish water and wastewater utilities. FIWA's membership includes about 300 Finnish water utilities which cover about 90 % of water services in Finland. With efficient wastewater treatment good treatment results can be achieved for various parameters. Efficient nutrient and suspended solids removal correlate with, for example, efficient microplastics and harmful substances removal. UWWTD should guarantee good basic level for waste water treatment in all European countries. Most important and elemental issues should be regulated in the UWWTD. These requirements could then be complemented nationally to enable adaptation to local needs in relation to the EU sea- and water directives. Different approaches should be allowed,since both local conditions and practices vary in member states. Urban run-off and CSOs are recognized sources of pollution. We want to emphasize that holistic approach, including urban planning considerations is needed to solve challenges related to urban run-off and CSO. Advanced treatment processes for elimination of harmful substances exist, but they are expensive, energy intensive and often substance specific. Furthermore, harmful substances may end up in sludge, which is not supporting recycling of nutrients. During the impact assessment (IA) the above mentioned challenges should be analysed in detail, as well as the interactions between advanced level of treatment, energy consumption and Green House Gas emissions to avoid counterproductive measures in the context of the EU’s Green Deal and Circular Economy targets. We support the idea to look for opportunities to implement the Polluter Pays Principle through Extended Producer Responsibility (EPR). According to the IIA it seems that any options regarding discharges of industrial wastewater into collecting systems and urban WWTPs will not be analysed. This is a major shortage since industrial effluents may have substantial influence on both treatment process and effluent quality. We also advocate that polluter pays principle related to the trade effluents should be strengthened. The balance between output driven requirements under UWWTD, and other directives, particularly the Water Framework Directive, which are based on impacts should be analysed. This is particularly important since one-out-all-out - principle combined with the precautionary principle greatly hampers possibilities to get environmental permits for WWTPs and can lead to solutions which are not cost-efficient. Sewage sludge is a valuable source of organic matter and nutrients. In Finland sewage sludge is processed and utilized as an organic fertilizer. FIWA would like to see a clear supportive legislative environment to secure the different possibilities we currently have to manage sewage sludge as well as to encourage use of new solutions. Recovery of raw materials from sludge is widely studied, but many of these technologies are not yet mature. Reliable information for product quality, costs and environmental impacts (GHG emissions) is needed to support decision making. According to our view the first step towards energy efficiency is to start measuring and benchmarking. Energy audits allow taking into account the local circumstances and finding optimal actions for each situation. More knowledge is required on the possibilities to control GHG emissions from WWTPs.
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Response to Evaluation of the Sewage Sludge Directive 86/278/EEC

24 Aug 2020

FIWA welcomes the initiative of the EC to evaluate the Sewage Sludge Directive (SSD). Finnish Water Utilities Association (FIWA) is the co-operation and member association of the Finnish water and wastewater utilities. FIWA's membership includes about 300 Finnish water utilities which cover about 90 % of water services in Finland. We need different opportunities for sewage sludge utilization Sewage sludge is a valuable source of organic matter and nutrients. The use of organic fertilizers, such as sewage sludge, improves the physical structure of the soil, providing greater porosity, structural stability, water retention capacity and ion exchange. In Finland sewage sludge is processed and utilized as an organic fertilizer. About 80 % of sewage sludge is digested and 60 % composted. About half of the biosolids is utilized in green areas and approximately 40 % in agriculture. Only a small fraction of sewage sludge is incinerated at the moment. Simultaneously various development projects are ongoing and looking for new options for sewage sludge treatment and nutrient recovery. FIWA would like to see a clear supportive legislative environment in order to secure the different possibilities we currently have to manage sewage sludge as well as to encourage the use of new solutions. Coherence with other policies With respect to sludge, there are indirect ways of protecting the quality of sludge through the EU’s REACH legislation. However, there is no clear line of sight between the protection of sludge quality and source control legislation. This is a major gap which should be closed, given the direction on circular economy and the range of reuses for sludge. Sewage sludge is legislated both trough waste legislation and SSD. It has been interpreted that even when sludge is processed and becomes an organic fertilizer (or biosolids) waste status still exists. This is not supportive and the situation will become even more imbalanced in the future when other organic fertilizers can reach the product status based on fertilizer regulation. We urge that this situation will be analysed in the evaluation of SSD and subsequently paths for organic sewage sludge fertilizer products will be created taking into account possible modification needs in the REACH regulation. Co-treatment of different organic materials by digesting or composting is often a locally sustainable solution. Legislation should not hinder but encourage co-treatment. SSD evaluation should recognise that co-treatment is a common practice and legislative coherence should be studied also from this perspective. Several new technologies for sewage sludge treatment and nutrient recovery are being developed. As these technologies become mature an appropriate legislative framework and a market is needed for further introduction. External study SSD evaluation will be supported by an external study. FIWA wants to point out that many of the mentioned information sources are made for other purposes and thus answer only partly to the questions that are relevant in the context of SSD evaluation. The roadmap indicates that the issue of pollutants is a key matter. FIWA has analysed the report ”Digestate and compost as fertilisers: Risk assessment and risk management options” and many shortcomings were found. Various information related for harmful substances as well as national risk assessments are available. Since pollutants are considered important, external study should use wider selection of sources related to this matter. To better control sludge management and its quality, risk assessments and risk management techniques are used, based on national legislation and voluntary quality assurance systems When comparing different treatment solutions and utilization alternatives, attention should be given to the emissions, costs and soundness.
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