SGI Europe Paper on the revision of the Urban Wastewater Treatment Directive

Summary

• SGI Europe welcomes the fact that the European Commission intends to anchor the Extended Producer Responsibility (EPR) scheme and the Polluter-Pays Principle in the new legislative proposal. SGI Europe hence calls on the European Parliament and Council to support the Commission's proposal and ensure that a strong EPR system is implemented through this directive.
• SGI Europe is of the opinion that all control at-source measures must have priority over one-sided end-of-pipe measures. It makes economically and ecologically more sense to avoid pollution at the source instead of removing substances once they have entered the water cycle, which is difficult and costly for wastewater treatment plants.
• SGI Europe generally supports the approach for additional treatment stages for Wastewater Treatment Plants, but in a realistic manner.
  • It must be ensured that further treatment stages are designed to be practical and give the operators the necessary planning and investment security. Official permit granting procedures are tight and there is a massive shortage of staff at the wastewater treatment plant side.
  • Additionally, the financial burden on wastewater customers resulting from further treatment costs and the proposed energy neutrality efforts must not be overlooked. In doing so, the broader framework conditions and challenges facing the wastewater industry need to be taken into account before imposing further measures.
• SGI Europe supports the coherent approach by the European Commission to reach the overall climate ambition, yet we remind that the goal of energy neutrality must be in line with the European water protection goals and the new requirements for the energy neutrality of UWWTP must not impede this goal.
• SGI Europe oppose the inclusion of delegated act (4:3), binding technical requirements at the European level and underlines that small agglomerations are an adequate solution for the treatment of wastewater and should be regulated within the Member States, where requirements account for local and regional conditions and the local pressure on the environment.
• SGI Europe deems it as crucial to implement an exemption for the construction and expansion of treatment plants in growing regions or cities due to the effects of the Weser Ruling. The revised UWWTD has to be fit for the future and should ensure coherence between different EU water legislations. The consequence without such an exemption in the revised UWWTD will be that cities, with already high standard wastewater treatment in place and not yet the highest ecological and chemical status in the receiving water, otherwise will have to stop their population growth.
• SGI Europe calls to revise the UWWTD accordingly to address the labour shortage in the wastewater treatment sector by launching initiatives that specifically promote the training and integration into the wastewater sector of European skilled workers.