Brussels, October 18, 2019

Since the publication of an EU action plan for the circular economy in 2015, the circular economy has been at the heart of the European Union's economic and environmental policies. As the reuse of treated wastewater is considered one of the most promising forms of circular economy, the European Commission has taken several measures to promote this practice in the European Union, including the drafting in 2018 of a Regulation on minimum requirements for water reuse. This Regulation was adopted in 2019 by the European Parliament and the Council with a very large number of amendments. In the coming weeks, negotiations in the trilogue are expected to lead to the adoption of the final version of the Regulation.

European Water Movement, most of whose members are confronted with projects to reuse treated wastewater on their territory, wishes to make several comments on the Regulation and more generally on the promotion of the reuse of treated wastewater, in particular for agricultural irrigation. It seems to us that every project must first be the subject of a study seriously assessing its impact on health, environmental and economic aspects. One of the European Commission's tasks should be to formalise this study as much as possible, in order to help Member States to implement only projects that are viable for these three aspects. The measures, including legislative measures taken so far by the European Commission on the reuse of treated wastewater, rather lead to simplification and weakening of the impact assessment, with a significant risk of implementing projects that go against some of the objectives of the circular economy.

The Regulation on minimum requirements for water reuse only addresses health aspects, leaving aside economic and environmental aspects. It is based on a highly questionable premise: reuse of treated wastewater would be limited in Europe partly because of "the lack of common Union environmental or health standards for water reuse". As noted in amendment 8 of the European Parliament, it is rather the "significant cost of wastewater reuse systems" that limits water reuse. The difference in the financing capacity of projects between or within Member States, coupled with a lax application of the full cost recovery (users of treated waste water pay little or nothing for water and the water reuse system, which is most often heavily subsidised by the competent authorities), leads to distortions of competition in the internal market. Surprisingly, the European Commission never refers to it but prefers to insist the relative risk that the absence of common health standards within the Union would pose to "the free movement of products irrigated with reclaimed water".

Treated wastewater leaving the treatment plant may pass through an additional treatment facility, a storage facility, a distribution network before reaching the end user. As the European Parliament has rightly pointed out (amendments 41 to 49), these different components of the wastewater reuse system can be operated by public or private operators, different from the operator of the treatment plant. Therefore, operators must be identified in the risk management plan. Points of compliance for water quality should be included in each component of the reuse system. The European Water Movement encourages the European Commission to take into account these considerations of the European Parliament, which clarify the roles and responsibilities of the various actors.

Annex I of the Regulation defines the minimum quality requirements for 4 classes of reclaimed water and authorizes for each class a crop category and an irrigation method. European Water Movement regrets that the minimum quality requirements focus on microbiological health risks (bacteria, viruses, parasites) at the expense of chemical health risks (heavy metals, pesticides, drug residues, emerging micropollutants). Chemical health risks are subject to additional requirements that may be defined by the competent authorities. The additional requirements therefore introduce a disparity between Member States that the Regulation was intended to eliminate. Minimum requirements are based on scientific data, most of which is more than 30 years old. The European Water Movement is surprised that more recent data have not been taken into account in the Regulation, such as the decrease in production of specific crops irrigated by treated waste water with a high concentration of sodium, potassium and chlorine.

According to the European Water Movement, a project to reuse treated wastewater for agricultural irrigation must meet several prerequisites. Water reuse can only take place at the head of the river basin if the ecological flow regime of the rivers is ensured all year round; otherwise, the treated wastewater must be returned to the rivers after adequate treatment for meeting this requirement. Treated wastewater should replace water withdrawn from rivers or aquifers in order not to foster water additional consumption. Treated wastewater should be provided primarily to farmers engaged in sustainable agriculture (climate-friendly crops, water-efficient farming practices, low use of pesticides and fertilizers, short circuits, food products) and not to those engaged in high value-added agriculture as unfortunately recommended by the European Commission. The fields irrigated by treated wastewater should not be too far from the treatment plant in order to limit the investment and operating costs of the treated wastewater reuse system.

The European Water Movement notes that the majority of current projects and experiments for the reuse of treated wastewater for agricultural irrigation do not meet the above-mentioned prerequisites. In the Languedoc-Roussillon, the projects mainly concern the irrigation of vines and golf courses and too rarely the irrigation of vegetables. In the Hautes-Pyrénées, a project financed by the region and the water agency will make it possible to irrigate maize by sprinkling despite the negative opinion of the regional health agency. In the Tajo Segura basin, the intensive agriculture will benefit from treated wastewater to irrigate, after depleting groundwater resources through mostly illegal catchments and surface water resources through massive water transfers, without questioning this disastrous mode of production for the environment.

The European Water Movement also considers the reuse of treated wastewater a very bad option to recharge groundwater supplying water for human consumption. Negative aspects related to these reuse projects can be already identified, such as the prohibitive costs of the most efficient technologies like reverse osmosis or pollution of most aquifers when conventional wastewater treatment technologies are used.

According to the European Commission and the governments of the Member States, circular economy will allow economic growth coupled with a sustainable use of natural resources. Thus, reuse of treated wastewater for irrigation will increase agricultural production while preserving water resources. This is an illusion since only 30% of the world economy can be "circularized". In parallel with the establishment of the circular economy, it will therefore also be necessary to radically change our production methods and to take the path of degrowth.

Contacts

Annelies Broekman - anneliesbroekman (at) gmail.com +34 6 87 51 07 82
David Sanchez - dsanchez (at) fweurope.org +34 6 16 20 69 42
Thierry Uso - eau34 (at) orange.fr +33 4 67 63 40 83