Party for the Animals | SO Input Note: Revision of the Urban Wastewater Directive

January 19, 2023

Party for the Animals members have taken note of the revision of the Urban Wastewater Directive. They have read interesting points in the European Commission’s proposal and the government’s response to it.

Animal Party members are pleased with the fact that there will be a mandatory extended product liability (UPV) system for human pharmaceuticals and cosmetics. These members are wondering if it is also possible to take medicine for animals with them, as they also end up in the environment. Can the government respond to that and say how this can be taken into account? In addition, these members want to know how the government will ensure that the EPR is not weakened by corporate interests.

The Cabinet notes that the national analysis of water quality shows that there is still a task for WFDs (wastewater treatment plants) to achieve WFD targets. Animal Party members support this analysis. These members therefore find it incomprehensible that the government would choose to advocate for 70% lower removal efficiencies in Europe rather than the 80% currently proposed by the committee, and a later implementation date for Phase IV treatment than 2035. These members want to know if the government Willing to give up this position, because we must aim for the highest possible removal efficiency. Is the Minister prepared to consider what is possible to the fullest extent, for example a phased regime for removal efficiencies of 70% in 2030 and 90% in 2035? This also makes it possible to relate as closely as possible to the objectives of World Food Day. According to these members, the current government position is based on postponement. What are the adverse effects on water quality and the Water Framework Directive to postpone that the government intends to? Why would the government choose not to do everything possible to prevent the problems that would arise if the goals of World Food Day were not met? This will have major social implications.

Animal Party members read that the government is criticizing the committee’s proposal to monitor (wastewater) and effluents (treated sewage) from sewage treatment plants in order to discover sources of pollution and take targeted measures. In addition, they read that the government is also critical of the accompanying plan to review and, if necessary, review mandatory permits for indirect discharges every six years. According to these members, the argument that the obligation to permit indirect discharge is not in line with environmental law and that this is accompanied by an increase in administrative burden is incorrect with regard to environmental problems and water pollution. The ZZS policy and assessment have indicated that there is no insight into discharges under the general rules and that the current approach leaves much to be desired. So Berenschot and Arcadis explain that “for example, there is currently no (integrated) monitoring system aimed at the prevalence of ZZS in the living environment”.[1]Therefore the requirement to obtain a permit for indirect discharges, as suggested by the committee, could be a solution. Therefore, it is remarkable that the government indicated its unwillingness to assume the obligations related to monitoring and reviewing permits, as this would lead to additional administrative burdens. This while obviously there is hardly any idea of ​​all the discharges. How would the Cabinet wish to gain insight into the discharge of all the ZZS polluting our waters? Can the government explain that? As far as these members are concerned, this whole process should actually be prevented up front. Animal faction party members don’t understand why we allow leakage into the environment. Wouldn’t it make more sense to prevent environmental damage by not allowing these discharges? So long as this remains permitted, all exit permits must be reviewed at least every two years. Are you ready to change your vision and advocate for an exit ban, and even then a review of exit permits every two years?

[1]ZZS Emissions Policy Assessment 2016-2021, p. 42

Leave a Comment