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European Commission public consultation on its proposal for a regulation on water reuse: comments by Nicolas Condom and Bruno Molle

Circular water economy: a growth weakened by the future EU regulation?

Note to the economic and institutional actors of the water cycle

N. CONDOM, PhD CEO Ecofilae and B. MOLLE, PhD- Irstea

 

Nicolas CONDOM, PhD. CEO Ecofilae – nicolas.condom@ecofilae.fr

Bruno MOLLE, PhD.- IRSTEA - bruno.molle@irstea.fr

France, 2018/06/25

 

On May 25th, 2018, the European commission has proposed a regulation on the reuse of treated wastewater (TWW) for agriculture. This proposal was the result of 4 years of work of the ATG Group in which we were a  part of. The proposed regulation incompletely reflects the State of art shared in this group. Over the past 10 years our actions were intended to promote and develop the reuse of controlled wastewater in Europe and in the Mediterranean by supporting involved actors (industry, waste water producers, end-users, OEMs, consultant study or public managers). Based on our expertise, we think that this regulation which concerns only agricultural irrigation, will refrain  all development of treated wastewater (TWW) recycling in Europe and any prospect of nutrients recovery in a circular economy perspective. Not to mention the heavy load of administrative documents  which will make the level of disinfection required exceed € 1 / m3 of treated water. Such unjustified health requirements for number of uses, will lead to a result, which is contrary to the objectives of the commission that aims to "stimulate and facilitate the reuse of wastewater treated in agriculture" (http://ec.europa.eu/environment/water/reuse.htm). We want, through this open letter, to alert the public and private sector’s actors and to answer the enquiry that is posted here.

The reuse of treated wastewater: a demonstrated potential

Domestic or industrial wastewater, once disinfected, are massive water deposits that can solve problems in numerous European regions and in the Mediterranean where there's a lack of water. Golf courses and agricultural crops can be safely irrigated with TWW, similarly, it can be used for recharging groundwater tables, cleaning roads and even producing drinking water. Many European research projects co-funded by the commission over the last 15 years have made such demonstrations.

As counterintuitive as it may seem, a great number of existing applications in the world show that recycling wastewater improves sanitary conditions, the quality of the surface water bodies, groundwater table or coastal waters while creating "green economy": providing attraction, jobs, and new business. It's a win-win process, on environmental, health, social and economic plans.

Feedback: Treated wastewater recycling as a synonym of sanitary improvement in current situations

Closing the loop of water and nutrients is a complex scheme requiring a co-construction involving all actors in the chain, each one with its own needs and capacities, using a wide range of skills and level of responsibility on the final result. Clearing the value of treated wastewater (that until then was considered a waste) is a delicate Alchemy which requires managing numerous factors simultaneously. A project will be viable if there are no health or environmental impacts, if it is technically feasible, profitable for the territory, acceptable for actors and organized in terms of responsibilities.

Based on the international literature (FAO, who, IWMI reports) and our feedback, we can affirm the following:

  • When comparing two situations: 1 - a project of TWW recycling, with 2 - a disposal of wastewater through sewage in rivers or in the sea, the situation is safer from a sanitary and environmental point of view in the reuse case. In others words, if all countries could pass to a circular water economy (where it is relevant!) , we would improve significantly sanitary and environmental conditions, even in the countries or European regions that have high equipped wastewater treatment plants (WWTP);
  • There are no proven health risks associated with controlled TWW recycling projects developed in countries with a less restrictive regulation than the one proposed. Furthermore, there are numerous impacts related to conventional irrigation by uncontrolled river waters;
  • Israel's regulation is one example of a strict and balanced law that has shown effectiveness since the 1970s, based on the construction of barriers of contamination at all levels of the TWW cycle, from the WWTP to the crop. That principles have been undertaken by the ISO TC282-Waste Water Reuse;

Unrealistic and biased regulation?

The draft proposed by the Commission to be reviewed by the Parliament seems to go against the objectives of Europe (http://ec.europa.eu/environment/water/reuse.htm)  which says that "the reuse of treated wastewater in safe and cost-effective terms is a valuable but under-used means of increasing water supply and alleviating pressure we over-exploited water resources in the EU”.

Any regulating effort will be beneficial to guide the actors to safe and viable projects. The commission launched a very strong signal by adopting the Circular Economy package on December 2nd, 2015 in which the reuse of wastewater was integrated. France, thanks to the publication of a regulation in 2010/2014/2016 paved the way for the development of water used projects. In 3 years, around fifty new projects were created.

If the proposed regulation is adopted in these terms, according to us, this will put a stop at a large majority of the developing projects. This would take away all benefits listed above and cited in the literature, in particular the improvement of the health and environmental situation of water bodies. We believe that a vast majority of the projects that have emerged following the 2014’s French regulation would not be viable anymore without the significant crowing on the investment in waste water treatment (WWT).

If the risk management approach is adopted, which we consider to be a good approach, it is important to take notice in these points:

  • This regulation proposal applies only to agriculture and does not address the urban green spaces, golf courses, the recharge of groundwater tables and others urban uses. This goes against the principle of circular economy which aims to apply several uses, prerequisite conditions to the profitability and sustainability of projects.
  • There is no mention of a cost benefit approach. With the proposed rebate rates, 11 of the 12 French projects, with the same level of risks, of which we are involved in would not be sustainable anymore. The cost of water per cubic meter would probably be more than 1€, thus it would not be profitable in agriculture, where the margin is not sufficient;
  • The pathogen reduction ratios are unrealistic, even in cases of the most advanced technologies;
  • There's no recognized association with the reduction of pathogens or reduction of risks and irrigation practices. For example, the simple irrigation technique sprinkling of effluent, without sun or tertiary treatment, causes a 2log reduction of pathogens. In addition, it takes 3 days to remove all traces of E. Coli from herbaceous plants.
  • The WWTP does not guarantee any regrowth of pathogens during the storage and distribution phase, though it is required to keep some control at the entrance of the field.

We call on all actors in the sector to think about the consequences of such regulation that seems to us to go against social as well as economic interests, in particular those of territories and the environment. The debate is still open. If you have any comments or suggestions, we could bring them back to the authorities.

 

Nicolas CONDOM et Bruno MOLLE