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Norwegian Water BA

Norwegian Water (in Norwegian: Norsk Vann) is a national association representing Norway`s water industry.

Lobbying Activity

Response to Review of the Construction Products Regulation

11 Jul 2022

Norwegian Water is a national association representing Norway`s water industry. It acts on behalf of the members, which are mainly municipalities and companies owned by the municipalities. Norwegian Water in total represents approx. 320 municipalities, with 96 % of the population. Norwegian Water also has affiliated members like consultants, producers, suppliers and educational and research institution. Norwegian Water has been working for many years to improve and secure the quality of small wastewater treatment plants, including the operation of these plants. It has been shown through several studies that only 40 to 50 % of them are able to meet the required treatment performance standards, due to failure in construction, installation, operation and maintenance. This has a significant effect on water quality in many Norwegian water systems, also shown in several studies. The goals of the Water Framework Directive would be even more difficult to achieve in Norway if the quality of small wastewater treatment plants is reduced. CE-marking has been an important tool to control the quality of the systems. Exclusion from the Construction Product Regulation will probably result in the removal of requirement for product documentation and certification for these products. The possibility of non-compliant products entering the market will increase, due to a lack of market surveillance as these products will not be covered by the Construction Product Regulation. Norwegian Water are deeply concerned about the impact of the proposed change. An increase in pollution from these plants due to lack of certification system, would worsen the water quality in many small streams and lakes, and be in contradiction to the goals of the Water Framework Directive. Therefore, the effect of the proposed change may be a need for stricter regulations or voluntary quality standard, to ensure that small wastewater treatment plants availably on the Norwegian marked are meeting the necessary standards. Due to these considerations Norwegian Water ask that the proposal to exclude small wastewater treatment plants (sanitary appliances and systems treating waste water) not be implemented.
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Response to Revision of the Drinking Water Directive (RECAST 2017)

25 Mar 2018

Norwegian Water welcomes the revision of the DWD. The DWD is an important framework for the Norwegian drinking water regulations. Therefore it is crucial that the revision improves the DWD as a tool for the water works to deliver and guarantee wholesome and clean drinking water to consumers. For some parts of the revision, this is not the case. Norwegian Water is a member of EurEau, European Federation of National Associations of Water Services, and supports EurEau feedback with the reference F10615, submitted 22.03.2018. The classification of parameters should be based upon the purpose of the parameters. Otherwise it would cause confusion and misunderstanding about the use of parameters, and could be very challenging to communicate the meaning of any exceeding's to the public. Therefore, the lists as used in Annex I of the present directive (A: Microbiological parameters; B: Chemical parameters; C: Indicator parameters) should be maintained. It is a misunderstanding to delete the existing list of Indicator parameters (Annex I Part C present directive) and move a part of the parameters to the Microbiological parameters (new Annex I part A) and upgrade these to parameters which exceeding means a potential danger to human health. About art.12.3: For several parameters the values have been set based on the precautionary principle (pesticides, EDCs) and therefore exceedance doesn't cause automatically a danger to human health. Consequently, we don't support the proposal that any exceedances of values should be considered "automatically as potential danger to health". This undermines consumers' trust. Leakage reduction should be assessed locally and based on sound judgement taking full account of economic, social and environmental externalities. Any one size-fits-all solution should be avoided. Leakage should be assessed according to international frameworks and methodologies so that comparisons can be made; Water losses vary greatly across the EU. A set of recognized factors explain these results such as the age and maintenance of the system; the total length of mains; the number of connections; the local topography and thus hydraulic / pressure characteristics; the soil and climatic conditions; the water price at the point of abstraction and consumption and also the manner in which water is valued by society. Substantial leakage reduction programs are now underway in the majority of member states and are already delivering benefits. Long-term investment in maintenance and rehabilitation schemes in some member states has kept leakage levels low. About Art.14+Annex IV: We favour transparency. More information could lead to more interest from public and policy makers. It is unclear who has to carry out the obligation to ensure that information is made available online. If this were carried out by water suppliers or by competent authorities, extra resources would be required. The IA doesn't acknowledge it. Furthermore, we do not want to lose the focus on the information provided to consumers on water quality aspects, as in the scope of the current Dir. Annex IV (7) further definitions at Member State level will be needed for points (a), (d), (e), (g).
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