ESPP input to the European Commission public consultation on the evaluation of the Urban Waste Water Treatment Directive (UWWT) 1991/271/EEC suggesting that the explicit, command-and-control, treatment requirements and discharge limits fixed by this Directive (and by the Nitrates Directive) should be maintained as key “backstops” within the more holistic and ambitious Water Framework Directive. ESPP noted that the UWWT Directive has led to large improvements in sewage collection and treatment in many Member States, often following EU verification and infringement procedures. Nonetheless, phosphorus losses to waters remain a major environmental challenge across Europe, and this will be accentuated with climate change. Further action will be needed, including in some cases lower phosphorus discharge consents for sewage works. ESPP underlined the potential for flexible permitting, e.g. catchment nutrient discharge trading systems, to achieve phosphorus loss reductions cost-effectively. ESPP noted the need to clarify the UWWT Directive definitions of “agglomeration”, of “appropriate treatment” (smaller sewage works) and of “sensitive areas” (take into account climate change). ESPP also emphasised that the UWWT Directive’s scope should be widened to ensure appropriate management of sewage sludge and valorisation, including nutrient recovery or recycling and valorisation of organic carbon.
ESPP input to the EU public consultation on the “Evaluation of the Urban Waste Water Treatment Directive”, 19th October 2018 www.phosphorusplatform.eu/regulatory
Note that a further EU consultation “Fitness Check of the Water Framework Directive and the Floods Directive” is open to 4th March 2019 at https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2017-5128184/public-consultation_en