Revison af EU's Drikkevandsdirektiv

Høringssvar fra Dansk Miljøteknologi (eng)

Danish Environment Technology Association position the revision of the EU Drinking Danish Environment Water Directive

The REFITT-evaluation has shown the following overarching needs for a revision of the directive:

  1. Revision of the quality standards and values is needed in order to keep up to speed with new challenges and new technology
  2. The need to attain a more risk based approach – more attention to the parameters coursing troubles less attention on parameters coursing no troubles:
  3. The consumers access to transparent information on drinking water quality is not good enough.
  4. Article 10 requirements for materials in contact with drinking water is to flexible for member states and hinders the free movement of goods in the internal market.

DETA Positions

The overall purpose of DWD

EU took a leading role in the negotiations of the new 2030 agenda for sustainable development and especially in the design of the new SDG 6 on water.

In the latest EC-communication on the 2030 agenda for sustainable development the EC commits to deliver on the full 2030 package including SDG 6.

SDG 6 on water states: “By 2030, [we should] achieve universal and equitable access to safe and affordable drinking water for all; and by 2030 substantially increase water-use efficiency across all sectors and ensure sustainable withdrawals and supply of freshwater to address water scarcity and substantially reduce the number of people suffering from water scarcity”

The purpose of the DWD “to protect human health from the adverse effects of any contamination of water intended for human consumption by ensuring that it is wholesome and clean” is far too narrow to steer this legislation to the achievement of the SDG 6 in 2030.

DETA suggest:
If the drinking water directive should be fit for purpose on the pathway to 2030 the scope in article 1 and 2 must be widened with a renewed focus on the protection of the available resources of drinking water and the most cost-effective measures of producing and supplying drinking water.

This double purpose goes hand in hand. 1) protecting the available drinking water resource-base and 2) the ability to ensure wholesome and clean drinking water. EU-water utilities cannot continuously supply clean, healthy and affordable drinking water for all, if the resource-base is depleted.

New provisions should only set measures strictly related to the production and distribution of drinking water respecting the provisions in WFD to protect the overall water resource-base in the EU. 

Revision of the quality-standards
The REFITT-evaluation of concludes that parameters and the limit values have not been updated according to the latest research and new parameters should be added to the list.

DETA Suggest:
The updated list should support the implementation of a risk-based monitoring approach, which makes it easier to detect contaminated drinking water more quickly and efficient.

Parameters such as endocrine disrupters, pharmaceuticals and micro-plastic could be included on the list since they under certain circumstances pose a risk to the quality of the drinking water.

Risk based monitoring and Consumers access to information
The current directive introduced a risk based monitoring approach but as the REFITT-evaluation showed the full potential is far from realized.

Today, the monitoring regime is based on time consuming physical sample-tests of specific parameters with a fixed ratio of controls. In many cases, it will take several weeks from a contamination is occurred until it is detected. And sometimes you will never detect the contamination because it occurs in between two fixed control-events.

This is in many ways not the most effective way to secure public health nor is it the most cost-effective method to monitor drinking water quality.

Implementation of better risk-based monitoring systems, could significantly reduce the expensive and time consuming physical sample tests to a minimum and at the same time lead to a more efficient detection of contaminated drinking water.

New cost-effective technology solutions with frequent instant monitoring is now available on the market. Implementation of such risk-based monitoring at large scale could reduce costs because more comprehensive physical sample testing to specify the nature of the contamination, origin etc. only should be carried out if the initial instant monitoring indicates contamination of the drinking water.

At the same time, it will offer the consumers the most timely and reliable information on the water quality as possible.

Physical sample test will still be an important tool in the overall monitoring system i.a. for the use as evidence in the court of law.

DETA Suggests:
A revised article 7 should promote the water safety plan approach laid down in the WHO Guidelines for Drinking Water Quality.

A revised article 7 and an adjusted Annex II should establish provisions for a new risk-based two-step monitoring regime. The first step should be a new instant monitoring system and the second step should be based on a sample-collection guided by the risk-evaluation in the first step.

The actual risk detected in step one should define the ratio of the following physical sample collection in step two.

The parameter values analyzed in step two should be based on an up-dated version of the existing parameters values.

Many water utilities in EU-member states already have similar monitoring regimes.

New parameters for water leakage
According to a EC case-study from 2015 there is a big challenge in the EU when it comes to water leakage. In some areas of Europe more than 60 % of the drinking water (abstracted and produced) in a supply zone is lost, mainly because of outdated infrastructure and leaking pipes.

At the same time, we see increased problems with water scarcity especially in the southern parts of Europe. This leaves the EU with a tremendous moral and economic obligation to protect the existing resource-base. There is a huge untapped economical potential if leakage rates are reduced. When you lose clean drinking you also lose all the energy used for the production and distribution. Reducing water leakage also leads to significant energy efficiency savings.

Since no regulation in the EU addresses water leakage there has so far been no formal regulatory incentives to alleviate water leakage. If the there is no provisions in EU-regulation it is difficult to get EU-funding to support larger infrastructure projects. New provisions on water leakages in the regulation would also give better incentives for the development of benchmarking and guidelines for best practice.

New provisions in the DWD related to water leakage would create new funding possibilities reducing water leakage and closing the enormous infrastructure investment gab in some parts of the EU.

In relation to the health aspect of DWD there is also a clear correlation between water leakage and contamination of drinking water.
Special parameters linked to contamination from leaking pipes could be developed as part of a new riskbased monitoring regime.

DETA suggest
A new recital and a new article should address the link between protection of the drinking water resourcebase and the potentials in reducing water leakage setting up new provisions to reduce water leakage.

New provisions in annex II should link the level of water leakages with levels of physical controls/sample collection of parameters connected to contamination of water from intrusion. If there is high-levels of water leakage, there should be obligations for more frequent control.

A three-step staircase model could be introduced as the basic principle: < 15 % leakage = XX controls/year: Between 15-20 % leakage= XX controls/ year, > 20 % leakage = XX controls/year.
This should be incorporated as a part of a new risk-based monitoring system.

Standards for materials and products in contact with drinking water
The various national approval procedures and standards for products in contact with drinking water is a significant obstacle for the full functioning of the internal market (potentially costing the industry over half a billion EUR per year, according to EC).

One unified common European approach is needed when it comes to procedures and standards for products in contact with drinking water. Now there is two legislative legal bases for standards for materials and products in contact with drinking water, which courses tremendous legal ambiguity leading to markets failures.

DETA suggest:
There should be one single standard for recognition of products in contact with drinking water. It should be the overall legal principle that a product recognized in one member state subsequently leads to mutual recognition in all other EU countries.

The standards of recognition should be based on the highest possible quality parameters to secure the best protection of the drinking water.

If there are certain local or regional circumstances, there should be a possibility to keep “higher” levels of protection against risk for contamination of drinking water.