This position paper was prepared January 31st 2023, by:

Stockholm University Baltic Sea Centre
•    Associate Professor Bo Gustafsson, Director of Baltic Nest Institute
•    PhD Bärbel Muller Karulis
•    PhD Benoit Dessirier
•    Gun Rudquist, Head of Policy
•    Ellen Bruno, Policy Analyst

Stockholm University Department of Environmental Science
•    Professor Anna Sobek
•    Professor Christina Rudén
•    PhD Student Diana Kättström
•    Professor Ian Cousins
•    Assistant Professor Marlene Ågerstrand

Definition of micropollutants, Art 2 (16)

We believe that this definition is important and hence must include as many problematic substances as possible. We believe that the current definition fulfils this requirement as it refers to the CLP-regulation and Part 3 and 4 of Annex I, which include those substances that are hazardous to health and/or the environment. We would also like to emphasize the importance of using “CAN be considered hazardous.”
We would, however, like to point to the fact that many substances that are not hazardous on their own at environmental concentrations, may become toxic in mixtures. This effect is not included in the definition.
For an even more precautionary approach, micropollutants could be defined as any substances found in the recipient at levels above what can be expected in an unaffected environment.

Collecting systems, Art 3

We support all the suggestion for agglomerations with a p.e. of 2000 and above.

Individual systems, Art 4

In general, the inclusion of individual systems in the UWWTD is very important and we support this article but would like to underline the following.

When implementing the revised UWWTD it is important to consider that the environmental benefits of upgrading or replacing individual systems with connection to waste water treatment plants strongly depend on local hydrological conditions. Drainage pathways and potential retention, influenced e.g. by the surrounding topography, vegetation and soil characteristics, can entail vastly different levels of risk to receiving water bodies.

In order to combat eutrophication, individual system in areas with low retention/high leakage risk, draining to lakes and coastal waters with limited water turnover and high nutrient sensitivity, should be given high priority.
In individual systems, from a eutrophication perspective, focus should be on ensuring that toilet waste is properly treated. Less effort can be put on grey water (i.e. water from showers, dishing etc) because it does not contain much nutrients.

Integrated Urban Wastewater management plans, Art 5, Annex V

We support the establishment of integrated urban waste water plans, but it should be done quicker.

In Annex 5.C, measures increasing green infrastructures such as wetlands should be included and prioritized because they serve as treatment for both nutrients and micropollutants.

Secondary treatment, Art 6

We support increasing secondary treatment.

Regarding the monitoring/measurements of discharges (Table 1. in Annex 1); the proposal only suggests measuring BOD. We argue that nutrients (Tot-N and Tot-P) must be included in monitoring, at least for areas identified as sensitive in Annex II. HELCOM also uses the suggested BOD and requires a 70% reduction for P for all secondary treatment and 30% for N in N-sensitive areas.

Tertiary treatment, Art 7

We strongly support demanding tertiary treatment. It is an important and effective technique that is already in practice. However, from a Baltic Sea perspective, the suggested adaptation time for Member States is far too long since the HELCOM contracting parties agreed in 2007 to upgrade WWTPs according to similar standards as proposed here.

7.2 suggests establishing a list of areas sensitive to eutrophication. These do already exist as part of for instance the nitrates directive. Therefore, actions can be taken much faster than suggested. The definition of “sensitive area” should be expanded to include micropollutants, for instance in relation to limit values for priority substances. Expanding the scope of the meaning of sensitive areas and conditions for emitting wastewater in these areas under the UWWTD would enable directive contribute to reaching targets set under both the WFD and MSFD.

Annex 2, Art 2 describes the procedure of selecting the target nutrient(s) for tertiary treatment. The selection procedure is vague and seems to apply only for WWTPs serving between 10 000 and 1000 000 p.e., leaving the procedure for selecting nutrients to remove for WWTPs serving > 100 000 p.e. unclear.

Quaternary treatment, Art 8

We very much welcome the inclusion of the Quaternary treatment step into the Directive. Urban wastewater treatment plants are important collection points for many chemical contaminants which are widespread in the aquatic environment. The Water Framework Directive (WFD) and the Marine Strategy Framework Directive (MSFD) set requirements for defining and assessing the status of European fresh and marine waters, and UWWTD is specifically mentioned in these directives as a measure to achieve good ecological and environmental status.

We hence welcome the linkage between requirement for treatment with environmental statutes of the recipient for plants between 10 and 100 000 p.e.

List of Indicator substances to be removed by at least 80%, Annex 1, Table 3

The list of indicator substances needs to include some indicator PFAS (e.g., perfluorooctane sulfonate (PFOS), perfluorooctanoic acid (PFOA), perfluorohexanoic acid (PFHxA), and perfluorobutane sulfonates (PFBS)), which are common legacy and replacement PFAS representing a range of perfluoroalkyl chain lengths (short and long chains) and thus partitioning behavior. By not including PFAS the directive seriously risks steering towards techniques that will miss many problematic micropollutants with special/unusual partitioning behavior.  Many studies show that there is a need for a combination of techniques in order to treat both PFAS and pharmaceuticals in treatment plans.

Extended producer responsibility, Art 9

We welcome the inclusion of an extended producer responsibility to the Directive. The Polluter Pay Principle should be a key principle underlying EU environment legislation and policies, as set out in Article 191(2) of the Consolidated Version of the Treaty on the Functioning of the European Union (europa.eu).

We also understand the rationale behind choosing the cosmetics and pharmaceutical sectors, as all their products and substances will end up in sewage treatment plants. We would however like to argue that there is a case to include also the textile industry as many of the substances used and added to textiles are released during washing and ends up in waste water treatment plants. Notable substances include PFAS, permethrin (insecticide), azo dyes, and phthalates.

Energy neutrality of urban waste water treatment plants, Art 11

We support this article, suggesting the establishment on energy audit are carried out.

Local climate conditions, Art 13

Art 13 requires UWWTPs to be designed to handle wastewater loads under normal local climatic conditions, but we suggest that climate change, in particular its implications for hydrological extremes, also be considered.

Discharges of non-domestic wastewater, Art 14

We welcome that authorities are encouraged to take measures to identify, prevent and reduce as far as possible the sources of pollution in non-domestic wastewater.

We also welcome the connection between identified problematic substances through the monitoring system in Art 21, with the possibility for authorities to stop industries wanting to connect to the sewage system. We believe that this upstream approach gives industries incentives to reduce pollutants at the source.

Sludge, Art 20

We think that the present sludge directive has little relevance for environmental protection and circular economy and should therefore be revised. A new directive must focus not only on preventing harmful effects on soil, vegetation, animals and people, but also must focus on preventing harmful effects on drinking water, freshwater and the marine environment, by leakage of nutrient, pollutants, pharmaceuticals or microplastics from application of sludge.

A new directive should not consider the spread of sludge as the only solution, but should also be open to new techniques that can extract nitrogen and phosphorus and limit the spread of hazardous substances (e.g. heavy metals and persistent organic pollutants), pharmaceuticals and microplastics.

Untreated sludge should never be allowed to be spread on agricultural land, not even if it is injected or incorporated into the soil.

Monitoring of substances, Art 21

Monitoring of the influx of N and P loads must be included in Table 1 in Annex 1.

We welcome the updated requirements for monitoring of priority substances and micro plastics and the established connection to the WFD Daughter Directives.

There is a risk of solely relying on lists of priority compounds for monitoring as it will miss the large majority of chemicals in commerce as well as potential mixture effects on aquatic life. Use of chemical screenings that take account of a wide range of pollutants is therefore an important complement, as is effect screening and mixture toxicity assessments based on a wide range of analysed chemicals.

Reporting of monitoring results, Art 22

We welcome that datasets with results from monitoring will be made available to the Commission and the EEA, but would like to stress, not the least in the interest of research, that results from monitoring should also be made public.