CIS Guidelines on Water Reuse

CIS Guidelines on water reuse

Tracking table for comments received after May SCG and addressed for version of guidelines sent to Water Directors June 2016

Note that the following indicated that they had no further comments on the text:CY, DK, EUREAU, COPA-COGECA, CEEP.

Note suggested deletions are struck through and suggested additions are in red or blue.

No / Chapter/section title / Comment
Source / Comment / How addressed
General comments / NL / It is most important to check for consistency throughout the whole text. Because in our opinion the comments are addressed already somewhere in the document, but are maybe not too clear if you focus on some parts of the documents (not everybody is going to read the full 100 pages). Therefore consistency is very important. Let me give you two examples.
During the SCG some MS raised concerns about the possibility that solving the water scarcity problem might lead to water quality problems. This is already mentioned on page 14
“Solving quantitative problems of the WFD should not lead, for example, to producing problems of water quality.”
And it should be reflected throughout the whole document that the water which is to be reused must meet the specific user needs as well as ensure wider health and environmental protection. It is important that this aspect of ensuring wider health and environmental protection is a clear part of the definition of ‘fit for purpose’.
Furthermore during the SCG concerns were raised that the document should reflect that in light of reaching WFD goals, it is necessary to consider water reuse as a measure only if water scarcity is identified as a pressure / The text has been fully read through for consistency, etc., examining these points in particular and changes made, including for language editing, etc.
DE / In title and throughout document change ‘guidance’ to ‘guideline’ / This is done throughout the revised document – to ‘guidelines’
CZ / As was agreed at the last SCG meeting (May 8-9) keep in all parts of document that it´s “Guideline”. We will appreciate to include information that water reuse can contribute to achieving the objectives of the Water Framework Directive (WFD) especially in water scarce regions (eg. in newly drafted foreword). / Changed to ‘guidelines’ and focus on achieving WFD objectives and in water scarce regions in guidelines and further emphasised
Euro-med Irrigators Community (EIC) / we would like to stress that the access of reused water for irrigation promotes the rational management of our water resources.
Using reused water is beneficial for a whole society, thusthe cost of treatment should be charged to the user who generates the waste water, following the principle: "polluter pays".
In addition, when irrigation provides to urban user a higher quality water, irrigation should receive in return a reused water with sufficient quality to be used in crops, without incurring additional cost.
On the other hand, responsibility concerning the quality of reused water for irrigation purposes must be to waste water treatment authorities, who must guarantee the quality of reused water.
Finally, we believe that research on the potential health risks of using reused water for irrigation purposes should be promoted / These points are addressed in the document already, so the comments are taken as support to these points.
Title / NL / In this respect we consider it important to show a clear distinction in the guidelines of when you will need to consider water reuse in light of the WFD (in cases of water scarcity as a significant pressure) and when it is smart to consider it for other reasons (such as progression towards a circular economy). I think that this is already more or less reflected in the guidelines, but this could be made explicit. We believe this point should also be reflected in the title of the document and therefore propose to change the title to: CIS Guidelines on Integrating Water Reuse in Water Planning and Management in the context of the WFD. / The distinction in now clearer.
The title is changed.
BE / Change title from guidance to ‘policy paper’ / Title changed, but to ‘guidelines’
Foreword / New text added and commented on through a separate process.
Acronyms / FR / RDPs isn't present in the list of acronyms / Acronym is added in revised document
Executive summary / CZ / Remove from last sentence “2nd RBMPs” which are in most MS already adopted / Removed
CZ / In the 2nd paragraph is mentioned that there is no recommendation for any particular standard, we would like to see some additional information about planned activities of JRC in draft ToR Water Reuse point 2 (minimum quality requirements of water reuse) on EU level. Reuse of treated wastewater and it´s minimum quality requirements should be “hand in hand” keeping in mind different levels of wastewater treatment under UWWTD. / Further info on JRC activities will be provided within the ATG. The guidelines mention the JRC work and their relationship to the work, but further details will emerge in the future. Some clarification on scope of JRC work and scope of guidelines (which differ) is added to the document
EEB / The reuse of treated wastewater can be an important tool to contribute to achieving the objectives of the Water Framework Directive (WFD) and to contribute to a more resource efficient economy as well as to adaptation to climate change. / Point is added
EEB / The European Commission Communication “Closing the loop - An EU action plan for the Circular Economy” (COM(2015)0614). This stated that the Commission will take a series of actions to promote the reuse of treated wastewater. This CIS guidance takes forward one action considering the wide context of potential uses of reused water at Member State level and how this should be examined in appropriate planning (including planning under the WFD). Water reuse should contribute to the UN 2030 Sustainable Development Agenda and especially its target to “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”. / Point on the SDG is added, with further specific elaboration on the sub-target which includes reuse.
EEB / Determining the necessary treatment requirements and other requirements ensuring safe use and protection of the environment, including monitoring / The point is added, but to the step on control, rather than treatment requirements
EEB / This should include all of those potentially affected (positively or negatively). This helps to create an atmosphere transparency / Deleted
FR / Purpose : This paragraph presents the REUSE as a tool to contribute to achieving the objectives of WFD but I think you should first present the REUSE as a LOCAL solution to a water scarcity problem OR / AND a quality problem of the water resource (e.g. receiving water environment too much sensitive). / Text emphasising reuse as a local solution is added to the revised document
FR / The need for appropriate planning :
5. safe used (taking account the EU and local legislation)
8. funding sources (who really pays the upgrade of the treatment of the WWTP and who takes advantage of the upgrade)
At no time in this list, we ask the project manager to check whether his project complies with EU law on water. / Point on complying with EU and national law is added as well as point on who pays and who benefits in the revised document
FR / The role of water reuse in meeting water needs :
First bullet :I don’t think that the example is well appropriate because we said that the REUSE is the solution for the aquatic ecosystem restoration, so you promote a solution of compensation and not a solution of avoidance (objectives of the mitigation hierarch). Proposition : such as avoid an input of WWTP water in a sensitive resource like a river or a lake / The text in the revised document is amended to take account of this point.
BE / This CIS guidance takes forward one action considering the wide context of potential uses of reused water at Member State level and how this shouldcould be examined in appropriate planning (including planning under the WFD). / Change made in the revised document
BE / Planning: It should be made clear that the next step is depending on the answer of the previous step. If there is no significant water scarcity issue, then the steps 2 and following should not be investigated. The same applies for the rest. You might have a water scarcity issue, but if the appropriate measure is for example rainwater harvesting and use, then it is of no use to determine the treatment requirements and costs of treatment
Identify whether you have a significant water scarcity issue or any other reason to use treated wastewater, such as aquifer recharge to manage seawater intrusion, benefits to industry, etc.. Have all potentials for water saving according to the hierarchy been fully used?
Identify the appropriate measures or alternative water sources to meet the changing needs, identifying clearly how each option will address specific quantitative needs.
Final 2 steps should be deleted because they are part of the implementation process, not of the planning process / The steps are now clarified in the revised document
The text is now altered significantly, so that the amendment is no longer relevant
Change is made to the revised document
This is not accepted – they are implementation points (as are earlier steps), but they are also points to plan BEFORE starting with reuse.
DE / document provides information and assistanceguidance to relevant Member State / Change is made to the revised document
DE / The reuse of treated wastewater has been highlighted within EU water policy as one possible alternative water source in water scarce regions which may be appropriate to consider within water scarcity planning . It was also identified as a priority in the 2012 Water Blueprint and it is also a supplementary measure which Member States can adopt as part of the programme of measures required under Article 11(4) of the WFD. Reuse of treated wastewater is further emphasised in EU policy on resource efficiency, most notable in the 2015 Communication on the circular economy which states “in addition to water-efficiency measures, the reuse of treated wastewater in safe and cost-effective conditions is a valuable but under-used means of increasing water supply and alleviating pressure on over-exploited water resources in the EU”.
The European Commission Communication “Closing the loop - An EU action plan for the Circular Economy” (COM(2015)0614). This communication stated that the Commission will take a series of actions to promote the reuse of treated wastewater. This CIS guidanceGguideline takes forward one action considering the wide context of potential uses of reused water at Member State level and how this should be examined in appropriate planning (including planning under the WFD) / All these changes are made to the revised document
DE / Audience and scope
The intended audience for this guidanceguideline is policy makers, water resource planners, river basin managers and those in the water industry, irrigation associations, etc. The guidelineanceexploresillustrates the policy and planning context of reuse of treated wastewater. As no common EU standards are yet in place, this document does It neither explores nornot recommends particular treatment standards or particular technologies for treatment, forbut refers the which readers should refer to other sources for such information. Recognising this is an important issue in the planning process a review of the document is considered after minimum EU-standards have been established. Also, while the guidanceguidelinestrongly recognises the importance of engagement with the public, it is not itself written as a tool for such engagement (see CIS guidance No 8).
The guidanceguideline focuses on the reuse of collected wastewater that achieves, after treatment as necessary, a quality standard that is appropriate for its intended use (taking account of the health and environmental risks and local and EU legislation). The present guidanceguidelinefocuses on urban waste water. Reuse also includes the reuse of industrial wastewater for applications off the industrial site (e.g. by other users). Water reuse by industry itself is included in relation to planning as it is important to understand the potential for reuse by industry within water management planning. The reuse of rainwater and of greywater (e.g. for domestic purposes such as toilet flushing) is not within the scope of the guidanceguideline. / All these changes are made to the revised document
DE / Need for planning:
1.Identify whether you have a significant water scarcity issue or any other reason to use treated wastewater, such as aquifer recharge to manage seawater intrusion, benefits to industry, etc..Have all and ifwhether all potentials for water saving according to the hierarchy been fully used?
2.Identify the relevant water needs in a clear quantitative way. These needs may be for irrigation, urban use, environmental purposes, aquifer recharge needs etc, including downstream users. It also important to identify how these needs might change or fluctuate and options to address this (also see CIS Guidance 34 on water balances).
6.Identify the different costs (and energy requirement, externalities) associated with treatment of the different wastewater sources and the costs associated with delivery of treated wastewater to the different identified users.
10.Systems for control and monitoring should be established to ensure safe use of the treated wastewater for people and the environment. / Changes adapted in fully revised combined step 1 and 2 in revised document
Changes included in revised document
Change included in revised document
DE / •Municipal/landscape uses such as irrigation of public parks, recreational and sporting facilities, private gardens, road sides, street cleaning, fire protection systems, vehicle washing, toilet flushing, air conditioners, dust control / Change included in revised document
DE / This guidanceguideline does not recommend any particular standard (chemical, microbiological, physical, etc.). However, legally binding standards for water reuse have been developed by several Member States and some third countries and international organisations have also developed specific standards which they recommend. For Member States where legally binding standards have been adopted, it is necessary to ensure they are complied with. EU-standards are currently developed. After these standards are set a review of this document will undergo a revisionbe revised. is considered.
It is important for competent authorities to ensure that information about relevant standards is communicated to those to whom they apply. Where standards for the reuse of treated wastewater are included in a permit, it is essential that the holder of the permit is fully informed as to what legal obligations they are under and how they have to ensure that these legal obligations are to be fulfilled. However it needs to be taken into consideration that many standards and laws often do not sufficiently address environmental protection. Thus additional requirements may be needed to prevent adverse effects. / The sense of this change is included in the revised document, in an expanded text
This is deleted from the revised document
DE / Measures within RBMPs. Active engagement and ambitiousadequate treatment standards raises the public’s understanding of an issue and is particularly helpful at overcoming misperceptions of an issue / Change included in revised document
1 / Introduction / IT / As already specified by Italy during the last SCG meeting, we would like to include in the text a sentence indicating that the case studies may not be provided by individual Member State to which they refer to but are in many cases taken from existing literature or from research, demonstration projects and pilot experiences. .Thissentencemay be added the box on page 12:
Throughout this guidance examples are provided of practical application of water reuse to illustrate particular points. It is important to note that these examples are provided for information, but it is not possible to state whether they are, or are not, fully compliant with the WFD, GWD and other relevant EU law. Moreover, the examplesare not necessarily provided bythe Member State concerned, but, in several cases, they are taken from the existing literature or illustrate the outputs of research and demonstration projects and pilot experiences. / The sentence is added to the box
1.1 / Policy background and purpose of these guidelines / NL / During the SCG concerns were raised that the document should reflect that in light of reaching WFD goals, it is necessary to consider water reuse as a measure only if water scarcity is identified as a pressure. We think this is reflected on page 14 of the document already:
“While water reuse is a measure to be used to meeting WFD objectives, it is important that the assessment and planning processes of the WFD (and drought management planning consistent with this as promoted by the Communication on water scarcity and droughts) forms the framework within which water reuse schemes are considered. The WFD Art.5 analysis of pressures provides a coherent overview of all pressures on water bodies and how they affect water status. This, therefore, provides the core information on water use and demand. Based on these pressures and how they affect objectives, programmes of measures are developed. It is important to consider water reuse as a measure that could alleviate water scarcity in areas where over-abstraction is identified as a significant pressure. By addressing this pressure, water reuse can contribute to achieving WFD objectives. However, it is important to ensure that diversion of treated waste water for reuse does not lead to problems in the flows of water bodies to which the water would otherwise be discharged. It is also possible that diversion of discharges to reuse can alleviate contaminant pressure on some water bodies.