Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation Prepared for the European Commission – DG ENV Analysis report under the contract led by

10 May 2017

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation |

Contents Contents

1

Document information

2

Executive summary

3

Introduction

9

Who replied to the consultation?

11

1.

Number of respondents ............................................................11

2.

Types of organisations represented ............................................11

3.

Economic sectors represented ...................................................13

4.

Geographical scope ..................................................................16

Analysis of results 1.

19

Perception of the potential benefits of water reuse .......................19

1.1 Irrigation ................................................................................19 1.2 Aquifer recharge ......................................................................24 2.

Perception of the potential barriers of water reuse .......................28

2.1 Irrigation ................................................................................28 2.2 Aquifer recharge ......................................................................32 3.

Safety of reusing treated waste water ........................................36

3.1 Irrigation ................................................................................36 3.2 Aquifer recharge ......................................................................39 4.

EU minimum requirements for water reuse .................................43

4.1 Irrigation ................................................................................43 4.2 Aquifer recharge ......................................................................46 5.

Specific objectives of EU minimum requirements .........................51

5.1 Irrigation ................................................................................51 5.2 Aquifer recharge ......................................................................54 6.

Specific aspects of EU minimum requirements .............................56

6.1 Irrigation ................................................................................56 6.2 Aquifer recharge ......................................................................60 7.

Other uses to be covered by EU minimum requirements ...............65

7.1 Overview ................................................................................65 7.2 Detailed analysis .....................................................................65

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Contents

Document information

CLIENT

European Commission – DG ENV

CONTRACT NUMBER

N° 070201/2016/746936/SER/ENV.C.1, implementing framework contract N° ENV.F.1/FRA/2014/0063

DOCUMENT TITLE

Final report

PROJECT NAME

Analysis of data resulting from the open public consultation on policy options to set minimum quality requirements for reused water in the EU

DATE

May 2017

PROJECT TEAM

Deloitte, IEEP (Leader of the framework contract)

AUTHORS

Sarah Lockwood, Lidia Wisniewska, Sébastien Soleille (Deloitte)

KEY CONTACTS

Sarah Lockwood ([email protected]) Sébastien Soleille ([email protected])

DISCLAIMER

2

The project team does not accept any liability for any direct or indirect damage resulting from the use of this report or its content. This report contains an analysis of public consultation results and is not to be perceived as the opinion of the European Commission. The views expressed by public authorities do not necessarily represent the official views of the government of a selected country. Also note that the consultation relied on self-declaration.

Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Document information

Executive summary Since 2012 the European Commission has been actively exploring how to best optimise water reuse in the EU, as a way to help solve the issue of water scarcity and droughts and help deliver the objectives of the Water Framework Directive. In this context it has conducted several rounds of stakeholder consultation. The latest public consultation, which ran from 27.10.2016 to 27.01.2017 and followed by a stakeholders’ meeting in Brussels on 8 th of March, specifically focuses on the benefits, barriers and relevant EU instruments to foster water reuse in agriculture irrigation and aquifer recharge.

Who replied to the consultation In total, 344 respondents participated in the consultation. Responses were received on-line from 103 individuals (30% of respondents) and 239 stakeholders or experts (70% of respondents). Two additional responses were received by email after the deadline. Respondents represented a variety of stakeholders groups, economic sectors and countries: 





Type of stakeholders: Private companies, water utilities and providers and industry or trade associations represented more than a third of total respondents, a similar proportion to citizens. Public authorities represented 12% of respondents, respondents from academic/scientific/research field represented 9% and NGOs and international bodies represented less than 5% of respondents. Economic sector: Organisations involved in sanitation and/or drinking water sectors represented half of the respondents. About 20% of respondents reported to be involved in the environment and climate sectors, while only 10% represented the agriculture sector. Food industry, health and economics sector had even lower response rates compared to previous categories (each less than 5% of respondents), Countries: The large majority of responses were received from within the EU (98%). Half of the responses were provided by three Member States: Spain, France and Germany with particularly high contribution from Spain (more than one quarter of all participants). Twenty countries provided ten answers or fewer.

For the purpose of the analysis, respondents were grouped according to several factors in order to show similarities and differences between various groups: 

   

Types of stakeholders: Authorities (national and local/regional), water providers (utilities/providers), private companies, industry and trade associations, NGOs and others (NGO, academics, international bodies and others) as well as citizens, EU region: Southern, Eastern or Northern EU, Water stress situation (based on WEI+ indicator), Countries with a high share of irrigation, Countries with effective water reuse schemes.

It is to be noted that public consultations are not representative surveys. They naturally include bias, as some categories of respondents will participate more compared to others and may inherently represent different weight (e.g. representatives of associations compared to individual respondents). Results must therefore be considered with caution.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Executive summary

Water reuse in agriculture irrigation and aquifer recharge: why is there a need to act (at EU level)? Perception of benefits There is a wide perception of the benefits of reusing water for irrigation or aquifer recharge purposes with regards to the availability of water resources, in the context of water stress or scarcity, unsustainable abstractions and climate change (perception from more than 70% of respondents across and within different categories of respondents). The potential contribution of water reuse to the quality of water bodies, through preserving groundwater from salinisation and reducing pollution discharge from urban waste water treatment plants, into rivers, is perceived by a large number of respondents as well. Furthermore, water reuse is also perceived by a number of respondents as a means to increase resource efficiency, foster innovation and contribute to soil fertilisation, although these benefits were considered more moderate compared to the former ones. Several respondents - in particular from the health, environment and agriculture sectors expressed their concern about the difficulty for water users (in particular farmers) to accurately estimate the amounts of nutrients present in the reused water to fully benefit from nutrient recycling and prevent risks of environmental contamination. Comments from respondents generally highlighted their support for one or the other of the listed benefits or their indirect benefits, rather than allowed to identify new benefits. On the other hand, respondents are much less inclined to perceive cost savings for authorities, increased revenues, or energy and carbon savings as benefits of water reuse. The analysis per category of respondents shows in particular that:  

countries regularly exposed to water stress and countries from Southern EU perceive significantly more and higher benefits than other categories of respondents, large consensus is found about these benefits within the respondents from the sanitation, drinking water, environment and economics sectors.

The results related to the perception of benefits of water reuse in irrigation are in line with the results of the consultation carried out in 2014, for water reuse in general. Similar conclusions can be observed both for most and least perceived benefits, with even stronger recognition of the benefit of adaptation to climate change (nearly 40% of respondents in 2014 perceived this benefit as high and over 50% in 2016 (nearly 60% in the case of irrigation). On the contrary, perception about the benefits of energy and carbon savings is lower in the present consultation (53% of respondents in 2014 compared to less than 40% in 2016). Views on job creation remain similar in both consultations.

Perception of barriers The main barriers to water reuse as identified by respondents are similar for water reuse in irrigation and aquifer recharge. They primarily include: 

the negative perception of issues around water reuse (perceived as a high or medium barrier by about 80% of respondents),



barriers related to policy or governance, including insufficient clarity in the regulatory framework to manage risks associated with water reuse or insufficient consideration for water reuse in integrated water management (nearly 90% of respondents perceived them as high or medium regarding irrigation and over 80% regarding aquifer recharge), economic barriers, including the low price of freshwater compared to that of reused water (especially in countries not affected by water scarcity) and the high cost of treatment for production of reused water (perceived as a high or medium barrier by about 80% of respondents) and fear of potential trade barriers in the case of water reuse for irrigation.



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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Executive summary

In the specific case of irrigation, the distance between waste water treatment plants and irrigation fields is also seen as a key barrier (2nd barrier the most pointed out by respondents). In addition to recognising different barriers listed in the consultation, some respondents or participants to the Stakeholder meeting also expressed their concerns regarding potential risks for the environment of reusing water for irrigation, through the perturbation of environmental flows (e.g. limitation of river flows in regions affected by water scarcity) and the potential salinisation of the reused water. In the case of aquifer recharge, additional concerns were expressed regarding risks of contamination of the aquifers and its irreversibility, due to the difficulty to remove pollutants from this water body. On the other hand, significantly fewer respondents perceive awareness and availability of technical solutions to produce safe water as barriers, except in Eastern EU countries. Most barriers are perceived by respondents from Southern EU countries and countries facing regular water stress, which practically experienced water reuse and often have stringent water reuse schemes in place. The results related to barriers are in line with the results of the consultation carried out in 2014, about water reuse in general. Similar conclusions can be observed concerning the overall ranking of barriers. In 2016, there is higher perception as barriers (~10%) of the price of water (low price of freshwater and high costs of treated water) and scientific uncertainties regarding potential risks. Interestingly, in 2014, the low perception of economic benefits of water reuse was already explained by the general lack of awareness and the lack of economic analyses covering the whole range of costs and benefits of reuse schemes. On the other hand, perception of barriers is lower (~10%) regarding the insufficient awareness of benefits, insufficient control on freshwater abstraction, and negative perception of water reuse. These conclusions are similar for water reuse for irrigation and for aquifer recharge.

Perception of safety of treated water reuse There is an overall consensus amongst respondents about the safety of reused water compared to water from rivers, as nearly 70% of respondents (amongst those who had an opinion) consider reused water as at least as safe, both for irrigation and for aquifer recharge. In comparison, the safety of reused water compared to groundwater is more controversial, as 50% of respondents consider it less safe for irrigation and 44% for aquifer recharge. These overall statistics hide in reality very different perceptions from specific categories of respondents. Some categories of respondents have a particularly positive or negative perception of reused water depending on their economic sector, type of organisations, situation of water stress or EU regions: 





respondents from Southern EU countries and countries facing regular water stress are significantly more inclined to consider reused water for both irrigation and aquifer recharge as being at least as safe as alternative sources (rivers or groundwater) than respondents from Eastern and Northern countries, which tend to consider reused water as less safe in the same proportions; respondents from some economic sectors also have a particular negative perception of reused water safety, such as the health sector, for which 70% of respondents perceive reused water as less safe than groundwater for irrigation purposes; on the contrary, respondents from private companies show by far the most positive perception of reused water safety compared to other types of organisations, keeping in mind that they are involved at 68% in drinking and sanitation sectors.

The perception of reused water safety may also significantly differ within categories of respondents, as it is the case within the agriculture, food and environment sectors, for which no clear position could be seen based on the public consultation.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Executive summary

What should be the objectives and scope of EU minimum quality requirements for water reuse? Objectives of the EU minimum quality requirements for water reuse Respondents to the public consultation identify in their vast majority (>70%) the following objectives as key for the EU minimum quality requirements for water reuse: 

for irrigation: o o o o



protection of human health of consumers through the safety of agricultural products placed on the EU market, protection of human health of public directly exposed to reused water, protection of water resources and dependent ecosystems, and protection of the wider environment.

for aquifer recharge: o o

protection of water resources and dependent ecosystems, protection of human health of public directly exposed to reused water.

These objectives are largely supported by the civil society and public authorities and are shared within and across economic sectors. They are also mostly shared within and across EU regions, except for the protection of human health of public directly exposed to water reuse in the case of irrigation, which was recognised as an objective by a lower share of Eastern EU countries compared to other EU regions (50% vs. 70% for other EU regions). Many of the additional objectives proposed by respondents in the case of water reuse for irrigation can be regrouped within the objective “protection of the wider environment”, such as mitigation of climate change impact, protection against soil erosion or maintaining a good water balance in rivers. In comparison, in the specific case of irrigation, the protection of agricultural productivity is not given as much importance (40% of respondents only think it should be covered). Yet, a large majority of respondents from the agriculture sector still considers it as an objective to be addressed by EU minimum quality requirements for irrigation (75% of respondents). A significantly higher share of respondents from Eastern EU countries also identified it as an objective compared to other EU regions. Should the protection of agricultural productivity be set as a primary objective of future EU minimum requirements or not, the impact on the agricultural productivity of the future policy instrument for water reuse will need to be carefully assessed.

Other uses to be covered by EU minimum quality requirements for water reuse A large majority of respondents considers the possibility or even the need for other types of uses than irrigation and aquifer recharge to be covered by EU minimum quality requirements. The relevance of considering several types of uses beyond agriculture irrigation and aquifer recharge was highlighted, for water managers and suppliers to be able to maximise water reuse and optimise investments returns. In particular, there is a large consensus (in particular within the health and the environment sectors) on the possibility or need to expand EU minimum requirements to the irrigation of sport fields and urban green spaces. Half of the respondents consider that these uses should be covered by EU minimum quality requirements for water reuse. The idea to expand EU minimum requirements particularly to industrial uses as well as to other urban uses is slightly more debated across respondents. Twenty percent and fifteen percent (respectively) of respondents would not like these uses to be covered by EU requirements 6

Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Executive summary

(compared to 10% for both other uses), while 40% of respondents think they should be included. Comments from some respondents on industrial uses highlighted a possible confusion with regards to the scope of the water reuse initiative for irrigation and aquifer recharge: they put forward initiatives from the industry in terms of recycling and reuse of their own waste water, while the waste water considered must be covered by the Urban Waste Water Treatment Directive. Overall, respondents from Southern and Eastern EU countries as well as from countries facing water stress are more inclined than respondents from Northern EU countries to expand EU requirements to other types of uses.

Towards a suitable policy instrument for EU minimum quality requirements for water reuse EU minimum requirements for water reuse Although over 60% of all respondents are in favour of an EU regulatory framework, there is no clear consensus across all types of respondents on the most suitable type of EU instrument - as listed in the questionnaire - to promote water reuse in irrigation and in aquifer recharge. The respondents which are mostly in favour of the instrument of an EU regulation, in both cases, are representatives from private companies, from the sanitation, drinking water, food industry and environment sectors, and/or from Southern countries. Respondents from agriculture and economics sectors1 as well as industry or trade associations show less consensus on supporting this policy option. Overall, the option of the instrument of a Commission recommendation is the 2nd preferred policy option within and across most categories of respondents, although CEN standards are generally preferred by respondents from agriculture, food and health sectors for water reuse in irrigation. The highest level of support for the use of Commission recommendations comes from water providers/utilities and public authorities as well as respondents from Eastern EU countries. These results should be considered with caution, as many comments - from respondents who selected the EU regulation or Commission recommendations - pointed to the preference for an EU Directive, which was not listed in the closed list of policy options from the public consultation. Many respondents call for an instrument providing both sufficient level of protection to reach its objectives and adaptability to be relevant to local contexts and needs. If the choice of an EU Directive were retained, there will be a need to carefully assess the impacts of non-harmonised national legislations on the perception of consumer safety in a shared European market as well as on the development of aquifer recharge in transboundary aquifers. The results related to EU minimum requirements for water reuse are in line with the results of the consultation carried out in 2014, about water reuse in general. Already in 2014, nearly 80% of respondents called for a legally binding instrument on EU minimum standards to promote water reuse. In addition, more than 80% of respondents considered legally binding EU minimum standards as effective to ensure the environmental and health safety of water reuse practices.

1

7

i.e. any industrial sectors other than food, drinking water and sanitation Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Executive summary

Specific aspects to be covered by minimum quality requirements for water reuse Priority aspects to be covered by minimum quality requirements for water reuse in irrigation include: microbiological contaminants, monitoring, and other chemicals addressed by EU legislation, both for irrigation and groundwater recharge purposes. While these aspects are generally subject to large consensus within and across key categories of respondents (economic sectors, types of organisation), the following differences can be noted:  

respondents from the agricultural sector are less favourable to including aspects related to monitoring, while there is strong support from most other sectors, respondents from the food, drinking water and sanitation sectors are also the least inclined to identify other chemicals as aspects as needing to be included.

Other aspects are more controversial within and across categories of respondents, such as risk-based management or the question of nutrients. Risk-based management approaches are considered by many respondents and participants to the Stakeholder meeting as relevant to ensure adequate protection of health and the environment in various contexts, but their practical implementation is subject to extensive discussions. They can be perceived as costly, timeconsuming and requiring specific expertise. The question of nutrients is considered as a priority aspect to be covered when reusing water for aquifer recharge while interest for such an aspect is more moderate for irrigation purposes. There, it can be seen both as a benefit from a recycling perspective and a key barrier for ends-users like farmers, with high risks of environmental contamination (nutrient surplus and leakage to the aquifer, eutrophication). Yet, this aspect is, in both cases, of very high interest to the health sector (73% in the case of irrigation and 79% in the case of aquifer recharge). Beyond these priorities in aspects to be included for irrigation and aquifer recharge lies the concern from some respondents that water reuse, if not well regulated, may contribute to pollution of aquifers and soils, although to a lesser extent. Respondents express less interest in general for including technical aspects in an instrument, such as wastewater management or aquifer recharge techniques. In this respect, the sanitation and drinking water sectors – which are both directly concerned by this aspect, reach a large consensus about not including this aspect. Similarly, less interest is shown by respondents in including the handling of treated water at farm level in EU minimum quality requirements for irrigation, although respondents from the health and agriculture sectors - which are the most directly concerned by this issue - showed slightly more interest. This was explained by the willingness to allow the use of a variety of practices which can be more or less relevant to different local contexts and to keep the door open to innovations.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Executive summary

Introduction Since 2012 the European Commission has been actively exploring how to best optimise water reuse in the EU, as a way to help solve the issue of water scarcity and droughts (Figure 1). In this context it has conducted several rounds of stakeholder consultation. The latest public consultation, which ran from 27.10.2016 to 27.01.2017 and followed by a stakeholders’ meeting in Brussels on 8th of March, specifically focuses on the benefits, barriers and relevant EU instruments to foster water reuse in agriculture irrigation and aquifer recharge2. The Commission will use the outcomes of this overall consultation exercise as a key input to the Impact Assessment of the most suitable EU policy options and to the design of the upcoming legislative proposal on minimum requirements for water reuse, to be tabled by the end of 2017. Maximisation of water reuse mentioned as a specific objective in the

Legislative proposal setting EU

“Blueprint to safeguard Europe’s water resources” Communication to

minimum requirements for water reuse

Water reuse actions were included in the

Circular Economy Action Plan

support the Water Framework Directive

CIS Guidelines on water reuse May 2017

2013 2012

2013

2014

2016

2015

2017

2018

Impact assessment activity Inception impact assessment

1st EU public consultation

on whether and how to promote water reuse in the EU

for a legislative proposal

Ad-hoc task group on water reuse created in the Water Framework Directive Common Implementation Strategy programme 2016-2018

Opinion of the Regulatory Scrutiny Board on

the impact assessment report

2nd EU public consultation, on water

reuse in irrigation and aquifer recharge (from 27.10.2016 to 27.01.2017)

Figure 1: Key milestones of the water reuse initiative

This document presents the results of this 2016-2017 public consultation exercise, in light of previous results from the 2014 EU public consultation on more generic aspects of water reuse. It is broken down into four main sections: 



Executive summary: this section aims to synthesise key messages from the consultation and answer to the following questions: o Why is there a need to act (at EU level)? o What should be the objectives and scope of EU minimum quality requirements for water reuse? o What would be the most suitable policy instrument for EU minimum quality requirements for water reuse? Who replied to the consultation?

The questionnaire and the presentation and minutes of the stakeholders meeting can be downloaded from CIRCA BC: https://circabc.europa.eu/w/browse/10a7bc3e-4021-4d5b-bee5-f5640a1eaa4f 2

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Introduction



Analysis of results: this section presents the results for each of the seven questions of the public consultation questionnaire: 1. Perception of benefits 2. Perception of barriers 3. Perception of safety of reused water 4. Instrument to set EU minimum quality requirements 5. Specific objectives of EU minimum quality requirements 6. Specific aspects to be covered by EU minimum quality requirements 7. Other uses to be covered by EU minimum quality requirements For each question, an overview of key messages is provided along with further insights on responses (overall responses and analysis per category of respondents), for irrigation on the one hand and aquifer recharge on the other hand.



Annexes (separated from this document): the annexes provide access to the full quantitative analysis of responses through diagrams.

Please note that public consultations are not representative surveys. Their results provide valuable information on drivers for - and main concerns about - water reuse and feedback on the feasibility and relevance of policy options. As a convention for the present study, the notion of “consensus” was used to reflect at least 70% of similar responses within a same category of respondents. Yet, these results are not representative of all EU stakeholders and must be considered with caution.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Introduction

Who replied to the consultation? 1.

Number of respondents

In total, 344 respondents participated in the consultation. Responses were received on-line from 103 individuals (30% of respondents) and 239 stakeholders or experts (70% of respondents). Two additional responses were received by email after the deadline3. Respondents represented a variety of organisations, economic sectors and countries. It is to be noted that public consultations are not representative surveys and naturally include bias. For instance: 

responses from associations represent the same weight in the analysis as any other individual responses, while they may in reality represent many members, likewise, responses made for the EU will have the same weight as responses made for individual Member States, responses from respondents who selected at least two different sectors will count in as many categories of respondents, some categories of respondents represent a low number of responses, such as some economic sectors (e.g. health), organisations (e.g. NGOs), or countries (e.g. Eastern EU), some categories of respondents are interdependent (e.g. 68% of respondents from private companies come from the drinking water and sanitation sector, while trade or industry associations reflect various sectors), which may affect the observed level of consensus.

   

The questionnaire was available in 23 out of the 24 official EU languages. Amongst participants who responded on-line, the English version was used by 109 respondents and other language versions were used by 233 respondents. Respondents indicated their preference for confidentiality of their contribution: 

51% their 35% 14%

 

of respondents indicated they agreed with the publication of their answers, including name and organisation, indicated their answers could be published anonymously, of respondents refused for their responses to be published.

The participation was lower than in the consultation carried out in 2014 (-37%, 544 responses received in 2014). In addition, the profile of respondents (individuals or organisations) changed – 15% more experts/stakeholders than individuals participated in the present consultation. In comparison, the average number of responses for EU public consultations in 2016 amounted to 407 contributions4.

2.

Types of organisations represented

Figure 2 highlights the types of organisations and the number of individuals that responded to the consultation: 



123 responses (i.e. 36% of the total responses) came from companies and associations, including private companies (56 responses), utility / providers (39 responses) and industrial or trade associations (28 responses), 103 responses came from individuals (citizens),

These two additional responses could not be included in the quantitative analysis of results, however the qualitative comments were taken into account in the synthesis. 4 Calculated based on 20 of the consultations published in 2016 for which figures are already available. 3

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Who replied to the consultation?



 

40 responses (i.e. 12%) came from public authorities, including regional/local authorities (26 responses) and national authorities (14 responses). National authorities represented the 9 following Member States: Bulgaria, Cyprus, Czech Republic, Germany, Hungary, Ireland, Poland, Portugal, and Spain, 31 responses (i.e. 9%) came from the academic/scientific/research field, 45 responses came from other categories: NGOs (9 responses), international bodies (2 responses), 23 from other associations and 11 unclassified5.

Private companies, water utilities or providers and industry or trade associations represented nearly a third of responding organisations6. Public authorities, NGOs and international bodies represented together about 20% of responding organisations. Please note as a caveat to the analysis:  

the fact that respondents were asked to select themselves the category of stakeholders they represented, and the overlaps between the following categories: private companies, water utilities or providers and industry or trade associations.

This resulted in a lack of clarity between the results obtained for these three profiles. Figure 3 indicates the number and share of participants responding as organisations.

Figure 2: Share of respondents by type

Examples of types of organisations classified in this category include standardisation organisation, organisations in charge of European project, independents consultants, regulatory organisation and other organisations that did not know how to declare themselves in any other of the previous categories. 6 Among private companies, 68% declared representing sanitation and/or drinking water sectors. Some water providers/utilities registered as private companies. 5

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Who replied to the consultation?

Private company (56) Utility / provider (39) Academic/scientist/research (31)

Industrial or trade association (28) Local/regional authority (26) Other associations (23) National authority (14)

Other (11) NGO (9) International body (2) 0%

5%

10%

15%

20%

25%

Figure 3: Number and share of responding organisations (excluding individuals)

In addition to the split of respondents between categories presented above and used in the analysis of responses, categories in the consultation were classified according to the stakeholders’ groups such as defined in the consultation strategy from the European Commission. They are presented the Table 1 below and their share in total responses was quantified and presented in Figure 4. Table 1: categories in the consultation can be classified according to stakeholders’ groups

Stakeholders’ groups

Corresponding categories from the 2016 consultation

EU member States responsible for water management

National authorities

Local/regional authorities

Regional/local water authorities

Water users (Agriculture Food sector incl. irrigators)

&

Industrial or trade associations (agriculture + food industry + irrigators) + private company (agriculture + food industry + irrigators) + relevant others/other associations

Water users (Others)

Other industrial and private (than Drinking water (DW), Wastewater (WW) and agriculture/food) + relevant others/other associations

Water industry

Utility/providers + Private companies (DW +WW) + Industrial associations (DW + WW) + relevant others/other associations

NGOs

NGOs

Academia

Academia + relevant others/other associations

Citizen

Interested individuals

Others

Other + Other associations

International body

International body

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Who replied to the consultation?

Member States (4%)

LEVEL OF INFLUENCE

NGOs (3%) International body (1%)

Water users 10% (incl. farmers and irrigators 8%)

Water industry (24%)

Citizens (30%)

Local authorities (9%)

Academia and research institutes (10%)

LEVEL OF INTEREST Figure 4: Share of different groups of stakeholders in total responses, depending on their expected policy influence and interest in water reuse (as defined in the consultation strategy from the European Commission)

On the figure, the share of responses for each category is indicated according to their participation to the consultation (the larger the character size, the larger the share of respondents) – categories indicated in small characters can be considered as less represented compared to other categories. All relevant categories as identified in the European Commission’s consultation strategy participated to the consultation, although to various degrees. For example, NGOs and international bodies regarded as influential stakeholders are in fact less represented in the consultation. Similarly, water users, in particular farmers and irrigators, which are influential and very interested in the topic, are not well represented compared to other categories of respondents such as citizens or respondents from the Water industry.

3.

Economic sectors represented

Stakeholders represented a variety of economic sectors7,8 as shown in Figure 5. Companies, organisations and authorities involved in sanitation and/or drinking water sectors represented half of the respondents. About 20% of respondents reported to be involved in the environment and

Respondents other than individuals had a possibility to select several options for the economic sector. Examples of types of organisations that declared themselves in category “Other” include for example national golf federations, energy production, ferrous and non-ferrous metals, as well as cross-sectoral organisations. 7 8

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Who replied to the consultation?

climate sectors, while 10% represented the agriculture sector9. Comparatively, food industry, health and economics10 sector had rather low response rates (each less than 5% of responding organisations). Due to this difference in number of respondents, the results should be considered with caution.

Figure 5: Responding organisations by sector

It should be noted that respondents other than individuals had a possibility to select several options to indicate the economic sector / activity they represent. Table 2 below shows the share of organisations that declared representing different numbers of sectors. Table 2: Responding organisations by type Number of different sectors declared by respondents

Share of respondents

1

42,3%

2

34,7 %

3

12,1%

4

7,1%

5

2,5%

6

0,4%

7

0,4%

8

0,4%

Over 77% of respondents declared themselves as representing only one or two sectors. In particular:  

67% of organisations replied as being involved in the “Sanitation” sector or “Drinking Water” sector, with 50% having selected both choices, amongst the 48 organisations which declared being involved in the “Agriculture” sector (15% of all respondents), 18 also represented “Food industry”. Twenty respondents from the

The issue of low number of responses from the agricultural sector was raised by a participant during the Stakeholder meeting on the EU public consultation held on 8th March 2017 in Brussels. Reasons invoked for low participation included the difficulty for farmers to access EU documentation and the lack of direct relevance of the questionnaire. 10 The category “Economics” represents any other industrial sectors than food, drinking water and sanitation. 9

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Who replied to the consultation?

agriculture sector are from the private sector (six are private companies involved in the agriculture business, as fertilisers providers, etc.), compared to 12 issued from public authorities, it is also worth noting that 91 (19% of total stakeholders) respondents declared being involved in the environment sector, among which 24 declared being specifically only involved in this sector. Seven private companies were in this specific pool of respondents.



4.

Geographical scope

About 94% of responses were received from the level of EU Member States, 4% from EU level organisations and 2% from other countries (Norway, Brazil). Half of responses were provided by respondents in three Member States: Spain, France and Germany, with particularly high representation from Spain (more than one quarter of all participants). Twenty countries provided ten answers or fewer. Similarly to economic sectors, respondents could select more than one country they represented. Figure 6 presents the number of respondents per country. 35%

30% 25% 20% 15% 10%

5% 0%

Figure 6: Number of respondents by country

From a geographical perspective, the type of participation to the consultation carried out in 2014 was similar to the present consultation. Most of respondents were also located in EU Member States (about 95%), 3% of responses were obtained from EU level organisations and 2% from other countries. At the time, respondents from France, Spain, Italy and Germany also made up more than 60% of total responses. For the purpose of the analysis, respondents were grouped in three EU regions (see Figure 7), based on the Member States they were responding from:   

Southern EU (Italy, Portugal, France, Spain, Greece, Cyprus and Malta), Eastern EU (Poland, Croatia, Slovakia, Slovenia, Bulgaria, Hungary, Czech Republic and Romania), and Northern EU (other States), with significantly more responses for the latter category.

Figure 7 also highlight Member States in situation of water stress (as measured by the WEI+ indicator based on 2013 data). Figure 8 indicates the share of respondents from the three regions. Nearly half of responses were provided by participants responding from Southern EU Member States, showing the high level of interest for water reuse from stakeholders and citizens from southern Europe. Comparatively, respondents from Eastern countries contributed only in a small proportion (9% of responses). Due to this difference in number of respondents for each EU region, the results of the analysis should be considered with caution.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Who replied to the consultation?

Figure 7: Repartition of respondents per countries per geographical location Countries facing regular water stress based on WEI+: Cyprus, Greece, Portugal, Spain and UK (Source: 2013 Eurostat data. Countries with WEI+ index >20% in summer) Countries with standards in water reuse 60%

57%

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30%

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9%

10% 0% Southern EU countries (195)

Northern EU countries (101)

Eastern EU countries (30)

Figure 8: Share of respondents by country location in Europe

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Who replied to the consultation?

Analysis of results 1.

Perception of the potential benefits of water reuse

1.1 Irrigation 1.1.1 Overview A majority of respondents (more than 70% of respondents across and within different categories of respondents) perceive the environmental benefits of reusing water for:   

reducing pressure on resources that are over-abstracted, reducing water scarcity, and adapting to climate change.

These potential benefits are particularly highlighted by respondents from the sanitation, drinking water and environment/climate sectors as well as respondents from countries in regular situation of water stress or more generally from Southern EU (over 80% of respondents within each of these categories). A large number of respondents (more than 70% of all respondents) also identify the following benefits:   

increased resource efficiency, enhanced innovation potential in the water industry, and reduced pollution discharge from urban waste water treatment plants into rivers. In this respect, a utility provider recognised that capture of effluents currently discharged in coastal areas would benefit the environment. An academic representative noted that the increased stringency on water treatment plants to produce high quality reused water would indirectly benefit the environment by enhancing the global quality of water discharged.

The benefits of water reuse as a mean to contribute to soil fertilisation, increase revenues and create jobs are much less consensual across categories of respondents. When identified, these benefits are also considered more moderate. Soil fertilisation for instance was perceived as high by only 27% of the respondents (some of whom highlighted its benefits to reduce the use of mineral fertilisers and contribute to nutrient recycling), compared to 40% for the aforementioned objectives. Several respondents - in particular from the health, environment and agriculture sectors - expressed their concern about the difficulty for water users (in particular farmers) to accurately estimate the amounts of nutrients present in the reused water, and therefore the difficulty to apply fertilisers in the right amount, in order to avoid contamination of the local environment with nutrients and meet the needs of the crops. During the workshop on 8th March, a representative from Copa-Cogeca insisted on the need for nutrient-free or better specifications of the nutrient content of reused water, in order to mitigate the risks for contamination of the local environment. Respondents are also much less inclined overall to perceive cost savings for authorities or energy and carbon savings as benefits of water reuse. They were rated as “low” or “no benefit” by 60% and 50% of respondents respectively. Interesting patterns can be observed across categories of respondents. Respondents from Southern EU countries and countries in situation of regular water stress recognise most of the benefits listed in the consultation in a much larger proportion than other respondents. Similarly, respondents

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

from agriculture, drinking water and sanitation sectors11 as well as environment sector tend to recognise more benefits than respondents from other sectors, across all categories of benefits. Comments from respondents generally highlighted their support for one or the other of the listed benefits or their indirect benefits, rather than allowed to identify new benefits. The results related to the perception of benefits of water reuse in irrigation are in line with the results of the consultation carried out in 2014, for water reuse in general. Similar conclusions can be observed both for most and least perceived benefits, with even stronger recognition of the benefit of adaptation to climate change (nearly 40% of respondents in 2014 perceived this benefit as high and nearly 60% in 2016). In contrast, perception about the benefits of energy and carbon savings is lower in the present consultation (53% of respondents in 2014 vs. 40% in 2016). Views on job creation remain similar in both consultations.

1.1.2 Detailed analysis 

Analysis of overall responses

Figure 9 represents overall views on potential benefits of water reuse for irrigation. There is a wide perception across respondents of environmental benefits of reusing water related to:

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reduced pressure on resources that are over-abstracted (85% perceive this benefit as at least medium and 68% perceive this benefit as high),

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reduction of water scarcity (83% perceive this benefit as at least medium and 63% perceive this benefit as high), and



adaptation to climate change (76% perceive this benefit as at least medium and 55% perceive this benefit as high).

A relatively high share of respondents also perceives water reuse as an opportunity to:   

reduce pollution discharge from urban waste water treatment plants into rivers (69% perceive this benefit as at least medium and 45% perceive this benefit as high), increase resource efficiency (77% perceive this benefit as at least medium and 44% perceive this benefit as high), foster innovation in the water industry (77% perceive this benefit as at least medium and 42% perceive this benefit as high).

Between 40 and 50% (depending on the benefits considered) of the respondents perceive at least one of these benefits as high. Although the benefit in terms of soil fertilisation is perceived as high by only 27% of the respondents, nearly 40% perceive it as a medium benefit. On the other hand, respondents do not perceive cost savings for authorities, increased revenues for sectors, or energy and carbon savings as clear benefits. They were rated as “low” or “no benefit” by 60%, >45% and 50% of respondents respectively.

Respondents representing drinking water and sanitation sectors show very similar views regarding every proposed option (the responses do not differ by more than 5%) which is not surprising as around 64% of respondents involved in either sector also declared to be involved in the other. 11

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

Reduced pressure on over-abstracted water resources Reducing of water scarcity Adaptation to climate change Reduced pollution discharge from urban waste water treatment… Increased resource efficiency (nutrients recycling

Innovation potential in the water industry Increased revenues and/or reduced costs for the agricultural sector Increased revenues for other sectors (due to higher water availability) Contribution to soil fertilisation Job creation Energy and carbon savings (in waste water treatment and irrigation) Cost savings for public authorities 0%

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Figure 9: Overview on potential benefits of water reuse in agriculture irrigation, for all respondents



Highlights from the analysis of responses per type of respondents

The 6 most supported benefits are relatively shared within and across types of respondents, as more than 60% of respondents from each category (except industry and trade associations) perceive them as having at least medium benefit. In particular, responses from authorities, citizens and NGOs show similar patterns regarding many benefits, especially the most supported ones. It is interesting to note, however, that: 



public authority representatives were generally less inclined than most types of respondents to highlight water reuse potential for increasing revenue (~45% of respondents vs. at least 60% across all types of respondents except associations), job creation (~45% of respondents vs. at least 60% across all types of respondents except associations and providers) and costs saving for public authorities (15% of respondents vs. at least 23% across all types of respondents). Comparison between responses from authorities and the average of other categories is presented in Figure 10, respondents from industry or trade associations supported the presented benefits much less than other types of respondents, even those who answered as private companies 12: the difference is about 20 points between associations and companies for the top 6 benefits, but it is even higher regarding other benefits, e.g. soil fertilisation (nearly 80% of private companies recognising it as benefit vs. 40% of associations).

As a reminder, some water providers/utilities registered as private companies and among this category; 68% of responding as private companies declared representing sanitation and/or drinking water sectors. 12

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

Job creation Cost savings for public authorities Reducing of water scarcity Contribution to soil fertilisation Reduced pressure on over-abstracted water resources Innovation potential in the water industry Increased resource efficiency (nutrients recycling Reduced pollution discharge from urban waste water treatment plants into rivers Adaptation to climate change Energy and carbon savings (in waste water treatment and irrigation) Increased revenues and/or reduced costs for the agricultural sector Increased revenues for other sectors (due to higher water availability) 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Average of other categories

Authorities

Figure 10: Overview on potential benefits of water reuse in agriculture irrigation, comparison between authorities and the average of other categories

Figure in section Benefits of water reuse in agriculture irrigation in the Annex to this report shows benefits perceived and difference in perception between respondents representing different categories. 

Highlights from the analysis of responses per economic sector

Respondents from agriculture, drinking water and sanitation sectors13 as well as environment sector tend to recognise more benefits than respondents from other sectors, across all categories of benefits. In comparison, respondents from the food industry, health sector and industrial sectors other than sanitation and drinking water generally perceived fewer benefits from water reuse compared to the other sectors (despite their good perception of water reuse (over 60% of respondents from these sectors perceive benefits in reducing pressure on resources, increased resource efficiency, reducing water scarcity, fostering innovation, adaptation to climate change and reduced pollution). Interestingly though, respondents which mostly perceive as a high benefit the fostering of innovation come from the agriculture and industrial sectors (besides food industry), while drinking water and sanitation sectors are less inclined to see it as a high benefit. The figure in the section on Benefits of water reuse in agriculture irrigation in the Annex to this report shows the benefits perceived and differences in perception between respondents representing different sectors.

Respondents representing drinking water and sanitation sectors show very similar views regarding every proposed option (the responses do not differ by more than 5%) which is not surprising as around 64% of respondents involved in either sector also declared to be involved in the other. 13

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

Increased Increased Reduced revenues revenues pollution Reduced for other and/or discharge pressure sectors reducedon Increased from urban overfor Innovation resource waste water (due to costs Reducing higher of abstracted the potential in efficiency treatment Adaptation water water water agricultural the water (nutrients plants into to climate scarcity resources availability) sector industry recycling rivers change



East North South East North South

East Highlights from the analysis of responses per geographical location North

Increased Increased Reduced Energy and revenues revenues Energy and pollution carbon for other and/or discharge carbon savings (in sectors reduced Increased (in from urban savings Cost waste water (due to costs for Innovation resource water waste water Cost waste in treatment savings for treatment Contributio higher the potentialfor efficiency treatment Contributio Adaptation savings water (nutrients climate public and n to soil water agricultural the plants into to soil public and n to authorities irrigation) Job creation fertilisation availability) sector industry recycling rivers change authorities irrigation) Job creation fertilisation

Figure 11 highlights the significant difference in perception of benefits between Southern EU countries South 14 (full comparison is on the one hand East and Eastern and Northern EU countries on the other hand North presented in section Benefits of water reuse in agriculture irrigation in the Annex to this report). South East East North North South South East East North North South South East East North North South South East East North North South South East East North North South South East East North North South South East

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Figure 11: Benefits perceived by the respondents (top 6): comparison between geographic locations of South countries East North

Overall, respondents from Eastern and Northern EU countries have a typically lower rate of South appreciation ofEastall benefits compared to those from Southern EU (between 20 to 10 points less of total appreciation North in all benefits proposed), who perceived most presented benefits as high. A very large majority of respondents from Southern countries highlighted benefits related to pressure on South East water scarcity and adaptation to climate change, with 95%, 97% and 90% of water resources, North respondents considering these benefits as “high” or “medium”, compared to 70%, 60% and 60% in South 15 other EU regions . Nearly 90% percent of respondents from Southern countries also perceive East increased resource efficiency as a benefit of water reuse, whereas they are slightly over 60% in North Northern and Eastern EU. Furthermore, they are more than 70% to highlight potential for job creation South

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I don't consider this as a potential benefit

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Respondents having specifically notified representing EU organisations have not been taken into account in this particular analysis. It should be noted that the share of responses from Southern EU was almost twice higher than from Northern EU and Eastern EU countries contributed only in a very small part (9% of responses). Due to this difference in number of respondents, the results should be considered with caution. 15 Participants to the consultation highlighted that water reuse also exists and may be needed beyond the Southern EU. To illustrate the benefits of water reuse in Northern EU, a representative from Flanders Knowledge Center Water that participated in the stakeholder meeting on 8th March provided a concrete example of a project in Belgium (Flanders) that involves treated wastewater use in food processing company: “Ardo uses annually 600 000 m³ of water for processing vegetables. A total amount of 300 000 m³ is annually being discharged into the Veldbeek. Farmers currently use mostly surface water for the irrigation of vegetable crops. Farmers with fields adjacent to water courses place a reel in the surface water and pump the water directly on the fields. Farmers who do not have access to a water course, get surface water with a dung cart. Farmers sometimes ride in a radius of more than 10 km to pump water from a canal or a reservoir. This movement of water on the road is time consuming for the farmers who have to queue during dry periods to pump water and causes nuisance to the environment in terms of noise and roadside damage. Around Ardo an underground pipeline network of high pressure will be constructed over an agricultural area of 670 hectares. The effluent of Ardo will be stored in a buffer basin of 110 000 m³ until the crops are in need for water. The pipeline network currently covers 32 km but will be further optimized in terms of the participating farmers. This network will be divided into several blocks so that there could be irrigated simultaneously in the different blocks”. 14

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

from the development of water reuse, while this benefit remains little highlighted when considering all responses to the consultation. On the other hand, respondents from Eastern EU were the most numerous to highlight the reduction of pollution discharge into rivers as a benefit (over 80% perceived it as benefit, compared to 77% and 51% of respondents from Southern and Northern EU). As pointed out by a representative from the French water utility company SUEZ that participated in the meeting on 8th March, the future EU regulatory framework should take into account national differences, as different regions have varied needs in terms of water supply and can benefit differently from development of water reuse. In particular, this participant stated that in water scarce regions such as Southern and Central Europe, water reuse can be “an efficient and cost effective drought-proof water supply alternative which could enable economic growth in such areas as agriculture, industry and tourism, as well as enhancing quality of life (green environment, leisure activities)”. In highly stressed regions, “water reuse for agricultural irrigation is absolutely critical for a sustainable economic growth”. On the other hand, in Northern countries, where there is significant pressure on sensitive water bodies, water reuse could “facilitate restoration, biodiversity protection and reduction of the high investment costs and energy consumption for wastewater collection and treatment (e.g. advanced nutrient removal)”. 

Comparison between countries in situation of water stress and others

Respondents from countries regularly exposed to water stress perceive significantly more and higher benefits than others, except for energy and carbon savings, which perception remains similar across categories of respondents. A much higher share of respondents in those countries perceived potential benefits of irrigation with reused water such as reducing water scarcity (over 95% vs. 70% of respondents from other countries), reduced pressure on water resource (over 95% vs. nearly 80%), adaptation to climate change (nearly 80% vs. 65%), increased resource efficiency (over 90% vs. nearly 70%) as well as innovation potential in the water industry (nearly 90% vs. 70%). Job creation is perceived as having at least a medium benefit by more than 75% of respondents from countries exposed to water stress, compared to about 40% of respondents from other countries. The figure in the section on Benefits of water reuse in agriculture irrigation in the Annex to this report shows the similarities and differences in perception between respondents representing countries in situation of water scarcity and other countries.

1.2 Aquifer recharge 1.2.1 Overview A large share of respondents (more than 70% of all respondents) perceive the environmental benefits of reusing water in aquifer recharge for: 

 

reducing pressure on resources that are over-abstracted: an industry association representing French water companies highlighted in particular the benefits of the limited evaporation allowed by water storage in the aquifer, reducing water scarcity, and protecting coastal aquifers against salt intrusion.

In addition, water reuse is perceived by a significant number of respondents across all sectors (over 70%) to contribute to fostering the innovation potential in the water industry. A large proportion of respondents also considers adaptation to climate change and reduced pollution discharge into rivers as benefits of reusing water for aquifer recharge, although they are considered slightly more moderate to the first ones and appear less consensual across sectors and categories of stakeholders. Several respondents commented on the benefits of aquifer recharge to reduce pollution

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

discharge, e.g. by reducing water exposure to various contaminations and eutrophication occurring at the surface of the earth and through filtering services from the soils. While it was not explicitly listed as a potential benefit in the questionnaire for the EU public consultation, respondents from Spain and France also highlighted as a benefit the natural storage and distribution system offered by the aquifers, which may greatly limit the need for costly infrastructures. On the other hand, respondents are much less inclined to perceive cost savings for authorities, or energy and carbon savings as benefits of water reuse. They were rated as “low” or “no benefit” by 60% and 57% of respondents respectively. Interesting patterns can be observed across categories of respondents. Respondents from the sanitation and drinking water sectors, environment and industrial sectors other than food industry perceive more benefits from water reuse than other sectors, especially in the environmental field. Furthermore, significant differences can be observed according to the location of respondents. Respondents from Southern EU countries recognise in a much larger proportion than other EU regions most of the benefits listed in the consultation. The results related to benefits are in line with the results of the consultation carried out in 2014, which was about water reuse in general. Similar conclusions can be observed both for most and least perceived benefits, with even stronger recognition of the benefit of adaptation to climate change (nearly 40% of respondents in 2014 perceived this benefit as high and over 53% in 2016). On the contrary, perception about the benefits of energy and carbon savings is lower in the present consultation (53% of respondents in 2014 vs. about 35% in 2016).

1.2.2 Detailed analysis 

Analysis of overall responses

Figure 12 represents overall views on potential benefits of water reuse in aquifer recharge. Similarly to agriculture irrigation, there is a wide perception by respondents of the following environmental benefits of water reuse:   

reduced pressure on resources that are over-abstracted (80% perceive this benefit as at least medium and 60% perceive this benefit as high), reduction of water scarcity (83% perceive this benefit as at least medium and 63% perceive this benefit as high), and protection of coastal aquifers against salt intrusions (73% perceive this benefit as at least medium and 56% perceive this benefit as high).

Each of these benefits is perceived as high by more than 50% of the respondents. A relatively high share of respondents also considers water reuse as an opportunity to:   

improve resilience/adaptation to climate change (71% perceive this benefit as at least medium and 50% perceive this benefit as high), reduce pollution discharge (60% perceive this benefit as at least medium and 37% perceive this benefit as high), and foster innovation in the water industry (73% perceive this benefit as at least medium and 37% perceive this benefit as high).

Between 35 and 50% (depending on the benefits considered) of the respondents perceive at least one of these benefits as high. On the other hand, respondents do not perceive as clear benefits of water reuse: cost savings for authorities (60% of respondents rated it as “low” or “no benefit”), increased revenues for sectors (39%), job creation (40%) or energy and carbon savings (57%). An overall consensus can be found within sectors and organisation types on this question.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

Reduced pressure on over-abstracted water resources

Reduced water scarcity Protection of (coastal) aquifers against salt intrusion

Improved resilience/adaptation to climate change Reduced pollution discharge from urban waste water…

Innovation potential in the water industry Increased revenues and/or reduced costs for…

Job creation Energy and carbon savings

Cost savings for public authorities 0%

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Figure 12: Views on potential benefits of water reuse in aquifer recharge



Highlights from the analysis of responses across economic sectors

Respondents from the sanitation and drinking water sectors, environment and industrial sectors other than food industry perceive more benefits from water reuse than other sectors (in general, perception higher about 15 points) such as agriculture, health and food industry, especially in the environmental field. Economic benefits such as carbon or cost savings, or job creation, are perceived as of low interest for all sectors in general. The figure in the section on Benefits of water reuse in aquifer recharge in the Annex to this report shows benefits perceived and the difference in perception between respondents representing different sectors. 

Highlights from the analysis of responses across the types of respondents

All types of respondents strongly perceive environmental benefits (adaptation to climate change, reduction of pressure on over abstracted water resources, reduction of water scarcity), which are perceived as “medium” or “high” by at least 60% within each type of respondents. Industry and trade associations are, however, less optimistic than other types of respondents regarding the most perceived benefits (difference is from 5 to 25 points between responses from associations compared to other categories). More respondents from private companies perceive more benefits than any other group (except regarding potential benefits of reduced pollution and energy and carbon savings of which citizens and NGOs are more supportive). While most economic benefits are little identified by the respondents, respondents from private companies still perceive job creation as a benefit of water reuse for aquifer recharge (+20% share of respondents in average compared to what citizens, public authorities and NGOs expressed). The figure in the section on Benefits of water reuse in aquifer recharge in the Annex to this report shows benefits perceived and the difference in perception between respondents representing different categories. 

Analysis of responses across geographical regions

Similarly to the responses for irrigation, respondents from Southern EU countries perceive significantly more and higher benefits than respondents from other EU regions (the difference in their perception of all benefits is of about 10 to 30 points compared to Northern and Eastern countries, except for reduced pollution and energy and carbon savings). They perceive most presented benefits as high, and in particular those related to reduced pressure on water resources and water scarcity and protection of aquifers, with over 90% of respondents perceiving them as “high” or medium”

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

benefits. They are also significantly more likely to consider job creation as a benefit from water reuse compared to respondents from Eastern and Northern EU (60% of respondents compared to 20% and less than 40% respectively). In comparison, far fewer respondents from Eastern EU countries identified benefits from water reuse, either in a similar or lower proportion than respondents from Northern EU countries (the difference in their perception is no more than 10 points more or less compared to Northern EU countries for many benefits except reduced pollution, job creation and energy and carbon savings). In particular, respondents from Eastern EU countries were more inclined than respondents from Northern EU to identify as a benefit the reduction of pollution discharge into rivers (63% of respondents compared to 42%). The figure in the section on Benefits of water reuse in aquifer recharge in the Annex to this report shows benefits perceived and the difference in perception between respondents representing different categories. 

Comparison between countries in situation of water stress and others

Similarly to the previous section, respondents from countries regularly exposed to water stress perceive significantly more and higher benefits than other categories of respondents, except for energy and carbon savings. In particular, reduced pressure on resources, reduced water scarcity, protection of coastal aquifers against salt intrusions and improved resilience to climate change (all environmental benefits) are massively identified as benefits by respondents from countries in water stress situation compared to other respondents. The difference is of about 25 points in average compared to countries that are not exposed to water stress. They also identify significantly more economic benefits such as job creation and increased revenues for water using sectors (nearly 30 points in average compared to countries that are not exposed to water stress). The figure in the section on Benefits of water reuse in aquifer recharge in the Annex to this report shows benefits perceived and the difference in perception between respondents representing countries in situation of water scarcity and other countries.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

2.

Perception of the potential barriers of water reuse

2.1 Irrigation 2.1.1 Overview Overall, according to the respondents, the negative perception on the quality of reused water and land planning issues (distance between waste water treatment plants and irrigation fields) are the main factors preventing a wider uptake (over 80% and nearly 90% of respondents perceiving these factors as barriers, respectively). Barriers related to policy and governance such as insufficient clarity in the regulatory framework to manage risks associated with water reuse and consideration in integrated water management (about 80% of respondents) are generally more perceived as a barrier than the absence of national water reuse standards (nearly 70%). In countries where water reuse schemes are already in place and which experience water reuse in practice, however, respondents particularly highlight administrative and legal barriers due to the high stringency of national standards and associated administrative burden. Other barriers mentioned by a majority of respondents from different groups (categories, location) include economic barriers (low price of freshwater compared to reused water in particular and high cost of treatment for production of reused water to a lesser extent) and fear of potential trade barriers. In this respect, a respondent highlighted the need to consider both potential trade barriers between Member States and barriers between the EU and other countries, which will not have similar minimum requirements. There is a large consensus regarding the perception of all these barriers, although they are more or less stressed by different categories of respondents. Most of these barriers though are perceived by respondents from Southern EU countries and countries facing regular water stress. On the other hand, awareness and availability of technical solutions to produce safe water are not considered as barriers or seen as low barriers by a majority of respondents, except in Eastern EU countries. In addition to recognising different barriers listed in the consultation, some participants expressed their concerns about other potential barriers of water reuse. Several respondents representing different categories (several authorities, academics, a water provider, an industry association and several individuals) share their concern regarding environmental risks of reusing water for irrigation, through the perturbation of environmental flows (e.g. limitation of river flows in regions affected by water scarcity), the contamination of soils and groundwater by nutrients, pathogens, heavy metals or emerging contaminants and their potential salinisation (one individual stakeholder from Spain highlighted increased salinity of reused water). Besides the issue of water and soil contamination, a representative from Copa-Cogega also highlighted that particulates are increasingly becoming a problem as water with particulates is not suitable for using with current technology (sprinkle systems are not adapted to spread solids). The results related to barriers are in line with the results of the consultation carried out in 2014, about water reuse in general. Similar conclusions can be observed concerning the overall ranking of barriers. In 2016, there is higher perception as barriers (~10%) of the price of water (low price of freshwater and high costs of treated water) and scientific uncertainties regarding potential risks. Interestingly, in 2014, the low perception of economic benefits of water reuse was already explained by the general lack of awareness and the lack of economic analyses covering the whole range of costs and benefits of reuse schemes. On the other hand, perception of barriers is lower (~10%) regarding the insufficient awareness of benefits, insufficient control on freshwater abstraction, ‘negative perception’ of water reuse.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

2.1.2 Detailed analysis 

Analysis of overall responses

Figure 13 represents overall views on potential barriers of water reuse in irrigation. Negative public perception on the quality of reused water Distance between waste water treatment plants and irrigation fields – need for conveyance infrastructure Low price of freshwater compared to price of reused water Insufficient consideration for water reuse in integrated water management (e.g. in scarce areas no incentives to develop water reuse… Insufficient clarity in the regulatory framework to manage risks associated with water reuse High cost of treatment for production of reused water Fear of potential trade barriers (e.g. import bans) for food products irrigated with reused water Stringent national water reuse standards Administrative burden for water operators and users and for public authorities (e.g. specific permits for water reuse) Absence of national water reuse standards Insufficient awareness on benefits of water reuse Scientific uncertainties as regards potential risks Low awareness of technical solutions to produce safe reused water Insufficient control on (freshwater) water abstractions Low availability of technical solutions to produce safe reused water 0%

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Figure 13: Views on main barriers to wider uptake of water reuse solutions in agriculture irrigation

Overall, according to more than 80% of respondents, the main barriers include:

29

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the negative perception of issues around water reuse (85% perceive this barrier as at least medium and 63% perceive this barrier as high),



a land planning barrier (distance between waste water treatment plants and irrigation fields): 91% perceive this barrier as at least medium and 61% perceive this barrier as high,

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policy barriers: o insufficient clarity in the regulatory framework to manage risks associated with water reuse (87% perceive this barrier as at least medium and 55% perceive this barrier as high), o insufficient consideration for water reuse in integrated water management (87% perceive this barrier as at least medium and 62% perceive this barrier as high),



economics: o low price of freshwater compared to price of reused water, but slightly more in countries not affected by regular water stress (82% perceive this barrier as at least medium and 62% perceive this barrier as high), o high cost of treatment for production of reused water (85% perceive this barrier as at least medium and 49% perceive this barrier as high),



administrative/legal barriers: o fear of potential trade barriers (e.g. import bans) for food products irrigated with reused water (80% perceive this barrier as at least medium and 49% perceive this barrier as high), o administrative burden for water operators and users and for public authorities (e.g. specific permits for water reuse): 80% perceive this barrier as at least medium and 44% perceive this barrier as high.

Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

A relatively high share of respondents also see the following barriers (35 to 49% depending on the barrier considered perceive them as “high”):   

absence of water reuse standards, or on the contrary – stringent national water reuse standards, insufficient awareness on benefits of water reuse, as well as scientific uncertainties as regards potential risks.

As stated in a position paper from Copa-Cogeca, the awareness of water reuse potential is still very low. According to the association, the term reuse “is perceived as more complicated, more costly and more risky”. In order to change the perception of reuse as a safe and efficient process, they suggest for example using the term water recycling rather than urban waste water reuse, as the water returns to the natural cycle. On the other hand, awareness and availability of technical solutions to produce safe water as well as insufficient control of water abstractions are little seen as barriers. 

Highlights from the analysis of responses across economic sectors

A larger share of respondents from the sanitation and drinking water sectors report the following barriers to water reuse compared to other respondents (as shown in Figure 14): low price of freshwater compared to reused water (about 10 to 15 points more than food and agriculture), distance between plants and irrigation fields (about 12 points more than food industry sector) as well as insufficient consideration for water reuse in integrated water management (about 10 points more than all other sectors). 100% 90% 80%

70% 60% 50% 40% 30% 20% 10% 0% Distance between Insufficient Low price of consideration for freshwater compared waste water treatment plants and water reuse in to price of reused irrigation fields – integrated water water need for conveyance management (e.g. in infrastructure scarce areas no incentives to develop water reuse projects) Sanitation

Drinking water

Average of other sectors

Figure 14: Views on main barriers in agriculture irrigation by sanitation and drinking water sectors in comparison with other sectors

The negative public perception on the quality of reused water appears as the most highlighted barrier by food and agriculture and health sectors (72% and 65% identified as high), as shown in Figure 15.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

Other Economics Environment / Climate Health

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Figure 15: Views on the share of respondents highlighting negative perception of water quality in the case of agriculture irrigation by food, agriculture and health sectors in comparison with other sectors

In this respect, a representative from a farmer association highlighted during the 8 th March stakeholder meeting the natural tendency from both these categories of stakeholders to follow public opinion on this matter, which reflects consumer demands. For both of these sectors, the question of the ultimate liability for water reuse was extensively raised during the meeting. The figure in the section on Barriers against a wider uptake of reused water in agriculture irrigation in the Annex to this report shows barriers perceived and the difference in perception between respondents representing different sectors. 

Highlights from the analysis of responses across types of respondents

Respondents from civil society or public authorities perceive more and stronger barriers to water reuse compared to other types of respondents. In particular, citizens are particularly concerned about the low availability and awareness of technical solutions to safely reuse water as well as about the absence of water reuse standards. Public authorities stress the negative perception of water reuse by the public and lack of awareness on reused water quality as well as economic barriers (high costs of treatment, fear of potential trade barriers, low price of freshwater compared to the price of reused water). The private sector as well as water utilities or providers (which can be from the public or private sector) rather highlight as barriers legal constraints and administrative burden related to the development of water reuse (approximately 85% of respondents in these categories identified these barriers as of high importance). They also mention the low price of freshwater compared to reused water. While respondents from industry and trade associations are seeing the least benefits to water reuse in general, few also report barriers compared to other types of respondents (between 10 or 15% fewer respondents ranked barriers as medium or high, depending on the type of barrier considered). This pattern is difficult to explain based on available information. The figure in the section on Barriers against a wider uptake of reused water in agriculture irrigation in the Annex to this report shows barriers perceived and the difference in perception between respondents representing different categories. 

Highlights from the analysis of responses across geographical regions

A larger proportion of respondents in Southern EU are inclined to perceive potential barriers to water reuse compared to respondents from Northern and Eastern EU. Particularly significant differences exist regarding the following barriers: 

31

stringent national water reuse standards (almost 90% of Southern EU perceive this barrier as at least medium vs. 62% and 50% for Eastern and Northern EU countries),

Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results



administrative burden (almost 90% of Southern EU perceive this barrier as at least medium vs. around 70% for Eastern and Northern EU countries).

As pointed out by a representative from Copa-Cogeca during the workshop on 8th March, respondents from Southern EU countries are those that perceive both most barriers and benefits to water reuse because of their practical experience of water reuse in the field. He suggested that lessons could be learnt from this implementation, in particular to alleviate administrative barriers to water reuse in the Member States. Interestingly, respondents from Eastern EU countries reported in a large proportion the awareness and availability of technical solutions to produce safe water as a barrier (80% of respondents vs. 58% in Northern and Southern EU) while they are not considered as such by most respondents from other EU regions. The figure in the section on Barriers against a wider uptake of reused water in agriculture irrigation in the Annex to this report shows barriers perceived and the difference in perception between respondents from different EU regions. 

Comparison between countries in situation of water stress and others

Respondents from countries facing regular water stress generally perceive a larger number of barriers compared to respondents from other countries, although they usually rank the different barriers similarly. The key barriers identified are similar to those previously highlighted for Southern EU countries: stringent water reuse standards (85% of respondents in countries facing regular water stress perceive this barrier as at least medium vs. around 70% in other countries) and administrative barriers (88% vs. 74%). Regarding the price of water, respondents in countries experiencing water stress are slightly more concerned than others about the possibility that the price of freshwater is low compared to the price of reused water. Among them, 83% consider it as a potential barrier to water reuse (including 69% considering is as high barrier) and 73% of respondents in countries not in situation of water stress consider it as barrier (including 52% considering is as high barrier). The figure in the section on Barriers against a wider uptake of reused water in agriculture irrigation in the Annex to this report shows barriers perceived and the difference in perception between respondents representing countries in situation of water scarcity and other countries.

2.2 Aquifer recharge 2.2.1 Overview Overall, a large share of respondents consider the following barriers to a wider uptake of water reuse (over 70% of overall perception): the negative perception on the quality of reused water, barriers related to policy and governance such as insufficient clarity in the regulatory framework to manage risks associated with water reuse and insufficient consideration in integrated water management as well as economic barriers, through low price of freshwater compared to price of reused water and high cost of treatment for production of reused water. The policy barriers mentioned are generally more perceived as a barrier than absence of national water reuse standards (less than 60%). In countries where water reuse schemes are already in place and which experience water reuse in practice, however, respondents particularly highlight administrative and legal barriers due to the high stringency of national standards (over 70% considering as barriers in Southern EU vs. less than 50% in Northern EU countries). There is a large consensus between regarding the perception of all these barriers, although they are more or less stressed by different categories of respondents. Most of these barriers though are perceived by respondents from Southern EU countries and countries facing regular water stress. Few respondents consider awareness and availability of technical solutions to produce safe water as barriers, except respondents from Eastern EU countries.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

In addition to recognising different barriers listed in the consultation, some participants expressed their concerns about other potential barriers of water reuse in aquifer recharge, and in particular the risks for the environment. Concern was expressed regarding risks of contamination of the aquifers and its irreversibility, due to the difficulty to remove pollutants from this water body. During the workshop on 8th March, some stakeholders highlighted the need for more transparency and public involvement among key elements to successfully develop water reuse, confirming the fact that negative perception and lack of awareness on benefits are seen as barriers today. The results related to barriers are in line with the results of the consultation carried out in 2014 about water reuse in general. Similar conclusions can be observed concerning the overall ranking of barriers. In 2016, there is higher perception as barriers (~10%) of the price of water (low price of freshwater and high costs of treated water) and of scientific uncertainties regarding potential risks. On the other hand, perception of barriers is lower (~10%) regarding insufficient awareness of benefits and ‘negative perception’ of water reuse. These conclusions are similar to conclusions for water reuse in irrigation.

2.2.2 Detailed analysis 

Analysis of overall responses

Figure 16 represents overall views on potential barriers of water reuse in aquifer recharge. Overall, according to at least 80% of respondents, the main barriers include: 

the negative perception of issues around water reuse (80% perceive this barrier as at least medium and 60% perceive this barrier as high),



policy barriers: o insufficient clarity in the regulatory framework to manage risks associated with water reuse (84% perceive this barrier as at least medium and 56% perceive this barrier as high), o insufficient consideration for water reuse in integrated water management (85% perceive this barrier as at least medium and 58% perceive this barrier as high),



economics: o high cost of treatment for production of reused water (81% perceive this barrier as at least medium and 54% perceive this barrier as high), o administrative burden for water operators and users and for public authorities (e.g. specific permits for water reuse): 80% perceive this barrier as at least medium and 43% perceive this barrier as high.

A relatively high share of respondents also sees the following barriers (40 to 57% consider them as “high”): low price of freshwater compared to price of reused water, absence of water reuse standards, or on the contrary – stringent national water reuse standards. On the other hand, awareness and availability of technical solutions to produce safe water as well as insufficient awareness on benefits are less seen as barriers.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

Negative public perception on the quality of reused water Insufficient consideration for water reuse integrated water management (e.g. in scarce areas no incentives to develop water reuse projects) Low price of freshwater compared to price of reused water Insufficient clarity in the regulatory framework to manage risks associated with water reuse High cost of treatment for production of reused water Stringent national water reuse standards Administrative burden for water operators and users and for public authorities (e.g. specific permits for water reuse) Absence of national water reuse standards Scientific uncertainties as regards potential risks Insufficient awareness on benefits of water reuse Low awareness of technical solutions to produce safe reused water Low availability of technical solutions to produce safe reused water 0%

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Figure 16: Views on main barriers to a wider uptake of water reuse solutions in aquifer recharge



Highlights from the analysis of responses across economic sectors

Respondents from the sanitation and drinking water sectors are those who identify most barriers to water reuse compared to other sectors. In particular, a large share of these respondents report the following barriers to water reuse: low price of freshwater compared to reused water, insufficient consideration for water reuse in integrated water management as well as insufficient clarity in the legislation to manage water reuse risks. Respondents from food, agriculture and health sectors particularly highlight the negative public perception on the quality of reused water (over 90% in health sector and nearly 80% in food and agriculture). The figure in the section on Barriers against a wider uptake of reused water in aquifer recharge in the Annex to this report shows barriers perceived and the difference in perception between respondents representing different sectors. 

Highlights from the analysis of responses across types of respondents

Similarly to reuse in agriculture irrigation, more responding citizens are concerned about low availability and awareness of technical solution to safely reuse water (57% and 69% citizens considering them as high or medium compared to no more than 46% and 54% for others respondents). Public authorities rather stress the economic barriers (high costs of treatment (85% of respondents considering it a barrier), low price of freshwater compared to the price of reused water (nearly 80%)), in addition, they are about 80% to highlight policy barriers (insufficient clarity in the regulatory framework to manage risks associated with water reuse and insufficient consideration for water reuse in integrated water management) as well as negative perception of water reuse by the public as barriers. A large share of respondents as water utilities/providers also perceives as barriers the administrative burden and insufficient consideration for water reuse integrated water management (over 80% considering each of the factors as potential barriers). Respondents from private companies tend to highlight more as a barrier the insufficient clarity in legislation to manage risks associated with water reuse and insufficient consideration for water reuse in integrated water management (over 80% of respondents) as well as inadequacy of national

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

standards (absence or too stringent). Indeed, about 75% of private companies consider stringent national standards as barrier compared to slightly more than 60% in average and 45% of authorities, and nearly 70% believe that absence of standards would be a barrier compared to 56% in average and less than 40% of associations). While respondents from industry and trade associations are seeing the least benefits to water reuse in general, few also report barriers compared to other types of respondents (between 10 or 20% fewer respondents ranked barriers as medium or high, depending on the type of barrier considered). This pattern is difficult to explain based on available information. The figure in the section on Barriers against a wider uptake of reused water in aquifer recharge in the Annex to this report shows barriers perceived and the difference in perception between respondents representing different categories. 

Highlights from the analysis of responses across geographical regions

A larger proportion of respondents in Southern EU perceive most of potential barriers to water reuse listed in the consultation. They highlight in particular: 





insufficient consideration for water reuse integrated water management (nearly 90% of respondents from Southern EU perceive this barrier as at least medium compared to about 77% for Eastern and 63% for Northern EU countries), which was less stressed in the case of irrigation, stringent national water reuse standards (over 70% of respondents from Southern EU perceive this barrier as at least medium compared to 43% and 48% for Eastern and Northern EU countries), and absence of national water reuse standards (64% of respondents from Southern EU perceive this barrier as at least medium compared to 47% for Eastern and Northern EU countries).

A larger share of respondents from Eastern EU countries considers low price of freshwater compared to reused water as a high potential barrier than from other EU regions (over 80% compared to 75% for Southern and 70% for Northern EU countries). The figure in the section on Barriers against a wider uptake of reused water in aquifer recharge in the Annex to this report shows barriers perceived and the difference in perception between respondents from different EU regions. 

Comparison between countries in situation of water stress and others

Respondents from countries facing regular water stress tend to perceive more barriers to water reuse, although they rank different barriers similarly. Similarly to barriers identified in Southern EU countries, most notable differences concern insufficient consideration for water reuse in integrated water management (93% of respondents in countries facing regular water stress perceive this barrier as at least medium vs. around 80% in other countries), stringent water reuse standards (77% vs. 65%) and administrative barriers (88% vs. 74%). Regarding the price of water, respondents in countries in situation of water stress are slightly more concerned than others about the possibility that the price of freshwater is low compared to price of reused water. Among them, nearly 77% consider it as a potential barrier to water reuse (including 60% considering is as high barrier) and 71% of respondents in countries not in situation of water stress consider it as barrier (including 48% considering is as high barrier). The figure in the section on Barriers against a wider uptake of reused water in aquifer recharge in the Annex to this report shows barriers perceived and the difference in perception between respondents representing countries in situation of water scarcity and other countries.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

3.

Safety of reusing treated waste water

Respondents were asked their views on the safety of reusing treated waste water for irrigation and aquifer recharge compared to the use of freshwater from rivers and groundwater.

3.1 Irrigation 3.1.1 Overview The results of the consultation show a relative consensus among respondents about reused water in irrigation as being at least as safe as compared to water abstracted from rivers. This perception is more controversial regarding groundwater. There is a large consensus among respondents representing different economic sectors about the safety of reused water compared to water from rivers, as nearly 70% of them (in each sector but agriculture, where this figure is closer to 60%) consider reused water as at least as safe. There is also a consensus between different types of stakeholders, as more than 60% of respondents from each group indicate that they perceive reused water as at least as safe as using water from rivers, with private companies having a particularly favourable opinion. The large majority of respondents from Southern EU countries and countries in high water stress also report a positive perception of the safety of reused water in agriculture compared to freshwater. On the other hand, the results of the consultation show a more negative perception from respondents of the safety of reused water compared to groundwater, as nearly 50% of respondents perceive it as not as safe. This is particularly true for respondents from Northern EU countries and for respondents from the health sector, for which this figure raises to nearly 70%.

3.1.2 Detailed analysis 

Analysis of overall responses

Figure 17 sets out the overall views on safety of water reuse in irrigation. There is a relatively large consensus amongst respondents about the safety of reused water compared to water from rivers. In comparison, the issue of safety of reused water compared to groundwater is more controversial amongst respondents. Nearly 50% of respondents perceive reused water as less safe than groundwater. These overall figures hide high discrepancies in the perception of reused water safety depending on the EU region, situation of water stress, sector and type of organisation as detailed below. Figure 17: Share of respondents considering that reusing treated waste water for agriculture irrigation nowadays in the EU is… Using water from groundwater Using water from rivers 0%

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results



Analysis of responses across economic sectors

Figure 18 shows difference in perception of safety between respondents representing different sectors.

Using water from rivers

Figure 18: Share of respondents considering that reusing treated waste water for agriculture irrigation nowadays in the EU is… Economics Environment

Health Agriculture Food Drinking water Sanitation

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Positive perception about the safety of reused water compared to water from rivers or groundwater is most largely seen amongst respondents from the sanitation and drinking water sectors: for instance, over 45% of respondents from these sectors consider reused water as safer as water from rivers and nearly 70% as being at least as safe, compared to ~30% safer for the other sectors. Most reservations are seen in both cases from respondents from the health and agriculture sectors. In particular, respondents from the health sector show high consensus on their perception of reused water as being less safe than groundwater (70% of respondents). 

Highlights from the analysis of responses across types of stakeholders

Notably, respondents from private companies are by far the most positive across types of stakeholders about the safety of water reused compared to other sources of freshwater (groundwater or water from rivers):  

70% consider reused water as at least as safe compared to groundwater and 44% to consider it even safer (support from other groups does not exceed 50%), 75% consider it at least as safe as using water from rivers and 49% even safer (support from other groups of respondents does not exceed 65%).

It could be explained by the fact that the majority of responding private companies (68%) declared representing sanitation and/or drinking water sectors and these sectors have general better perception of the water reuse safety. In comparison, respondents from industry and trade associations as well as NGOs and academics have the most negative perception of the safety of reused water, in particular when compared to groundwater. Figure 19 shows difference in perception of safety between respondents representing different categories.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

Figure 19: Share of respondents considering that reusing treated waste water for agriculture irrigation nowadays in the EU is… Using water from groundwater

Citizens NGO and others

Industry or trade associations Private companies Providers Authorities

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Analysis of responses across geographical regions



The question of safety of reused water for irrigation compared to other sources of freshwater is controversial when considering responses from the different EU regions. A significantly larger share of respondents from Southern EU countries consider reused water as at least as safe, independently from the source of water it is compared with. 

In comparison to groundwater: 65% of respondents from Southern EU countries also consider reused water as at least as safe, while 70% of respondents from Northern and Eastern EU countries consider reused water as less safe than groundwater, In comparison to rivers: 80% of respondents from Southern EU countries perceive reused water as at least as safe (with half of them considering it even safer), compared to 55% of respondents from Northern EU and only a third of respondents from Eastern EU countries.



There is larger consensus between respondents from Northern and Eastern EU countries about the opinion that reused water was less safe than groundwater, in comparison to water sourced from rivers, which remains more controversial within each of these EU regions.

Using water from rivers

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Figure 20 shows difference in perception of safety between respondents from different EU regions. South East North South East North 0%

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Figure 20: Safety perception – comparison between Southern EU, Northern EU and Eastern EU countries in the reuse of water for agriculture irrigation

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results



Comparison between countries in situation of water stress and others

A majority of respondents from countries facing regular water stress perceive reused water as at least as safe as using water from rivers or from groundwater. They account for a much larger share than respondents from other countries: 



When compared to rivers, 80% of respondents from countries facing regular water stress perceive reused water as at least as safe, compared to 50% of respondents from other countries. When compared to groundwater, 70% of respondents from countries facing regular water stress consider reused water as at least as safe, compared to 30% of respondents from other countries.

The figure in the section on Perceived safety of water reuse in agriculture irrigation in the Annex to this report shows the difference in perception of safety between respondents representing countries in situation of water scarcity and other countries.

3.2 Aquifer recharge 3.2.1 Overview The results of the consultation show similar trends regarding agriculture irrigation. The results of the consultation show a relative consensus among respondents about reused water in irrigation as being at least as safe as compared to water abstracted from rivers. This perception is more controversial regarding groundwater, except for respondents from Southern EU and countries in situation of water stress, which report a positive perception of the safety of reused water compared to both water sources. There is a large consensus among respondents representing different economic sectors about the safety of reused water compared to water from rivers, as more than 60% of them consider reused water as at least as safe, with over 70% of them in each sanitation, drinking water, economics and environment sectors. There is also a consensus between different types of stakeholders, with private companies having a particularly favourable opinion. More concerns are found about the safety of reused water compared to groundwater, as 44% of respondents perceive it as not as safe. The concerns are particularly strong for respondents from Eastern and Northern EU countries (for which this figure raises to 80% and 60%) and for respondents from the health and agriculture sectors, for which this figure raises to over 50%.

3.2.2 Detailed analysis 

Analysis of overall responses

Figure 21 represents overall views on safety of water reuse in aquifer recharge. Trends with regards to safety of reused water are very similar for irrigation and aquifer recharge. The perception of the safety of water reuse in aquifer recharge significantly depends on the alternative source considered (water from rivers or groundwater) and categories of respondents. As for irrigation in agriculture, the issue of safety of reused water compared to groundwater is more controversial amongst respondents than when it is compared with water from rivers. Forty four percent of respondents perceive reused water as less safe than groundwater. These overall trends hide high discrepancies in the perception of reused water safety depending on the EU region, situation of water stress, sector and type of organisation as detailed below.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

Figure 21: Share of respondents considering that reusing treated waste water for aquifer recharge nowadays in the EU is… Using water from groundwater Using water from rivers 0%

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Analysis of responses across economic sectors

Figure 22 shows difference in perception of safety between respondents representing different sectors. Figure 22: Share of respondents considering that reusing treated waste water for aquifer recharge nowadays in the EU is…

There is a relatively large consensus amongst respondents from different economic sectors about the safety of reused water compared to water from rivers, as nearly 60% of respondents from all sectors except agriculture and health consider reused water as at least “as safe”. Amongst these sectors, respondents from industrial sectors other than food and sanitation/drinking sectors are those that reported the most positive perception of reused water safety. This may be explained by less stringent levels of water quality required for some industrial uses. Similarly to water reuse for irrigation, respondents from the health and agriculture sectors have the most reservations about the safety of reused water, in particular as compared to groundwater (over 50% of respondents, compared to ~40% for other sectors). 

Highlights from the analysis of responses across types of stakeholders

Figure 23 shows difference in perception of safety between respondents representing different categories of stakeholders.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

Figure 23: Share of respondents considering that reusing treated waste water for aquifer recharge nowadays in the EU is…

A significant share of respondents shared their opinion on the safety of reused water across different groups, except industry or trade associations which were around 40% to claim not having an opinion. While there is a relative consensus regarding the safety of reused water compared to rivers amongst those that shared an opinion (more than 60% of respondents from each group indicated that they perceive reused water as at least as safe as using water from rivers), perception of safety of reused water compared to groundwater is more controversial within and across stakeholders categories. Respondents from private companies are once again by far the most positive about the safety of water reused compared to other types of stakeholders. They are 75% to consider reused water as at least as safe compared to both groundwater and water abstracted from rivers, compared to 50% in average for all respondents. 

Highlights from the analysis of responses across geographical regions

Figure 24 shows difference in perception of safety between respondents representing different EU regions. Figure 24: Share of respondents considering that reusing treated waste water for aquifer recharge nowadays in the EU is…

Similarly to the section on irrigation, the question of safety of reused water for irrigation compared to other sources of freshwater is controversial when considering responses from the different EU regions.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

A significantly larger share of respondents from Southern EU countries consider reused water as at least as safe, independently from the source of water it is compared with: 



in comparison to rivers: over 70% of respondents from Southern EU countries perceive reused water as at least as safe (with over 40% of them considering it even safer), compared to less than half of respondents from Northern and Eastern EU, in comparison to groundwater: over 60% of respondents from Southern EU countries also consider reused water as at least as safe, while nearly 70% of respondents from Eastern EU countries and nearly 60% of respondents from Northern EU countries consider reused water as less safe than groundwater.

Larger consensus was reached between respondents from Northern and Eastern EU countries about the opinion that reused water was less safe than water sourced from rivers, in comparison to groundwater, which remains more controversial within each of these EU regions. 

Comparison between countries in situation of water stress and others

Figure 25 shows difference in perception of safety between respondents representing countries with different situations of water stress. Figure 25: Share of respondents considering that reusing treated waste water for aquifer recharge nowadays in the EU is…

A comparison between responses from countries in situation of water stress and others also shows significant differences in the perception of water reuse safety when using water for aquifer recharge. A majority of respondents from countries facing regular water stress perceive reused water for aquifer recharge as at least as safe as using water from rivers or from groundwater (no significant difference in the perception of safety is seen from the comparison with one or the other of these freshwater sources). Respondents from these countries account for a much larger share than from other countries: 



42

In comparison to rivers, nearly 75% of respondents from countries facing regular water stress perceive reused water as at least as safe with more than 40% of them considering it even safer, compared to 43% of respondents from other countries. In comparison to groundwater, nearly 75% of respondents from countries facing regular water stress consider reused water as at least as safe, compared to 40% of respondents from other countries.

Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

4.

EU minimum requirements for water reuse

Respondents were asked their view on the best instrument to use in order to set minimum requirements for water reuse at EU level. Both for irrigation and aquifer recharge, proposed options were: EU regulation (binding), Commission recommendation (not binding), CEN standards (not binding) or other.

4.1 Irrigation 4.1.1 Overview A majority of respondents (60%) are in favour of an EU regulation to set minimum requirements for water reuse. The level of support from each category of respondents across economic sectors for such an instrument is not lower than 50%, although this trend hides some specificities across categories of respondents. High support for an EU binding instrument can be seen in particular from respondents from:  

the sanitation, drinking water, food and environmental sectors, in particular from the private sector, Southern EU countries and countries facing water stress.

About 25% of respondents prefer a non-binding instrument, such as Commission recommendation (2/3 of these respondents) or CEN standards (1/3 of these respondents). Among respondents these respondents: 

CEN standards are generally preferred within: o agriculture, food and health sectors, o industry or trade associations,

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Commission recommendation is generally preferred within: o sanitation, drinking water, environment and economics sectors, o providers and public authorities, o Eastern and Southern EU countries (respondents from Northern EU countries being slightly more open to other policy options or undecided).

Several comments from respondents pointed out the preference for an EU Directive, either explicitly or implicitly, for its binding character associated to its flexibility to be best adapted to local contexts and needs. However this instrument was not specifically listed amongst policy options in the consultation questionnaire. For this reason, the results should be considered with caution. It should be noted that there was no significant difference in the results when comparing agriculture irrigation and aquifer recharge. The two proposed uses of water received about the same distribution of answers from the respondents. During the stakeholder meeting on 8th March, participants confirmed their overall support for an EU action to promote safe water reuse. Attendees agreed that any EU instrument should be flexible and adapted to local situations as well as to the European context. It should also take into account differences between countries as well as the level of risk and quality control of reused water. Specifically regarding the instrument for irrigation, respondents to the consultation and participants of the workshop highlighted the importance of ensuring the economic feasibility of the implementation of a future instrument and of preventing potential overlap with other instruments (through conducting an impact assessment). The question was also raised of carefully assessing the impact of such EU instrument on agricultural products traded within and outside the EU. The results related to EU minimum requirements for water reuse are in line with the results of the consultation carried out in 2014, about water reuse in general. Already in 2014, nearly 80% of respondents called for legally binding EU minimum standards to promote water reuse. In

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

addition, more than 80% of respondents considered legally binding EU minimum standards effective to ensure the environmental and health safety of water reuse practices.

4.1.2 Detailed analysis 

Analysis of overall responses

Figure 26 represents overall views on the instruments to set minimum requirements for water reuse at EU level in irrigation. Over 60% of respondents are in favour of an EU regulation (binding) to set minimum requirements for water reuse. About 25% of respondents would prefer a non-binding instrument, such as Commission recommendation (2/3 of these respondents) or CEN standards (1/3 of these respondents). Preference for one or the other of these non-binding instruments depends on the economic sectors EU region and organisation types considered. The rest of respondents does not have any opinion or would rather consider other policy options. Amongst these respondents, most advocate for a legislation adapted to local contexts such as an EU Directive.

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Figure 26: Views of the respondents on the instrument to be used to set EU minimum quality requirements for water reuse in agricultural irrigation



Highlights from the analysis of responses across economic sectors

Figure 27 shows difference in views between respondents representing different sectors on the instruments to set EU minimum quality requirements for water reuse in irrigation. The analysis across economic sectors shows that respondents of each category rank EU binding regulation as the preferred policy option, with a particularly high level of support from respondents from sanitation, drinking water, food and environmental sectors (at least 60%) compared to agriculture and other economic sectors (50% or less). CEN standards are the second preferred policy option by other respondents representing agriculture, food and health sectors, with 20% or more respondents in favour of this instrument. In particular, respondents from the food sector showed high level support with nearly 30% of respondents in favour of this option compared to Commission recommendations (~5%). Commission recommendations are the second preferred policy option by other respondents from the sanitation, drinking water, environment and economics sectors (~25% of support in average across these sectors).

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

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Figure 27: Views of the respondents by sector on the instrument to be used to set EU minimum quality requirements for water reuse in agriculture irrigation



Highlights from the analysis of responses across types of stakeholders

The analysis of responses by type of stakeholder shows similar trends with regards to the primary support to EU regulation. At least 50% of respondents from private companies (over 80%), citizens (65%) and NGOs, academics and other associations (over 50%) supported this option. The high rate of responding private companies in favour of an EU regulation could be explained by the fact that the great majority comes from sanitation and/or drinking water sector which are in majority supporting such legally binding instrument. Public authorities, utility providers and industry or trade associations are slightly less favourable for the legally binding option (slightly less than 50% of these respondents in favour of EU regulation) compared to other stakeholders. Commission recommendation was the second preferred option and CEN standards were least preferred across sectors. Figure 28 shows views of different types of stakeholders on the instruments to set EU minimum quality requirements for water reuse in irrigation. Private companies Citizens NGO and others Authorities

Industry or trade associations Providers 0%

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EU regulation (binding)

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80%

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Figure 28: Views of the respondents by categories on the instrument to be used to set EU minimum quality requirements for water reuse in agricultural irrigation



Highlights from the analysis of responses across geographical regions

Figure 29 shows difference in views from respondents from different EU regions on the instruments to set EU minimum quality requirements for water reuse in irrigation.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

Instrument needed for agricultural irrigation

Respondents from Southern EU countries are slightly more in favour (65%) of an EU regulation than Northern and Eastern EU countries (respectively 53% and 42%). When considering non-binding options, respondents from Eastern EU countries are more in favour of a Commission recommendation compared to respondents from other countries (over 35% vs. about 10 to 15% for other countries). Respondents from Northern countries are equally supportive of both non-binding options and slightly more respondents are open to other policy options or undecided).

South

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Figure 29: Views of the respondents on the instrument to be used to set EU minimum quality requirements for water reuse in agricultural irrigation



Comparison between countries in situation of water stress and others

Respondents from countries with water stress are more in favour of an EU regulation than respondents from other countries (87% compared to 70%). When considering a non-binding instrument, they also tend to prefer a Commission recommendation (about 20% vs. about 15% for other countries) more than other countries. Figure 30 shows difference in views between respondents representing countries in situation of water stress and other countries on the instruments to set EU minimum quality requirements for water reuse in groundwater recharge.

Countries not in situation of water stress

Countries in situation of water stress

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Figure 30: Views of the respondents on the instrument to be used to set EU minimum quality requirements for water reuse in agriculture irrigation by water stress

4.2 Aquifer recharge 4.2.1 Overview Similarly to the opinions on the most suitable EU policy instrument for water reuse in irrigation, a majority of respondents (60%) are in favour of an EU regulation to set minimum requirements for water reuse for aquifer recharge. The level of support from each category of respondents across economic sectors for such an instrument is not lower than 50% for all but agriculture and industrial sectors other than food industry, drinking water and sanitation. Over

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

80% of respondents from private companies are in favour of this option. The highest supporters of this option include:   

representatives of private companies and civil society, sanitation, drinking water, food industry and environment sectors, Southern EU countries and countries facing water stress.

About 25% of respondents prefer a non-binding instrument: Commission recommendation (2/3 of these respondents) or CEN standards (1/3 of these respondents). Amongst these respondents, Commission recommendations are the preferred policy option within and across most categories of respondents (except economics sector). The highest level of support is from water providers/utilities, public authorities and Eastern EU countries. CEN standards are the least preferred policy option. They are in particular supported by respondents from agriculture sector. Similarly to irrigation, many comments from respondents pointed out the preference for an EU Directive, for its binding character providing sufficient level of protection associated to its flexibility to be best adapted to local contexts. However this instrument was not specifically listed amongst policy options in the consultation questionnaire. For this reason, the results should be considered with caution. During the workshop on 8th March, participants confirmed their overall support for an EU action while highlighting that it should be adapted to local situations. As the Groundwater Directive already addresses a number of aquifer recharge challenges in terms of water quality, some participants highlighted that a future EU instrument should not lead to an overlap between existing legislation and that it should bring more clarity to the conditions of water reuse as an added-value. In addition, some stakeholders expect exchange of best practices and guidance to complement any new EU legislation. The results related to EU minimum requirements for water reuse are in line with the results of the consultation carried out in 2014, about water reuse in general. Already in 2014, nearly 80% of respondents called for legally binding EU minimum standards to promote water reuse. In addition, more than 80% of respondents considered legally binding EU minimum standards effective to ensure the environmental and health safety of water reuse practices.

4.2.2 Detailed analysis 

Analysis of overall responses

Figure 31 represents overall views the instruments to set minimum requirements for water reuse at EU level in aquifer recharge. Similarly to irrigation, there is no clear consensus across all types of respondents on the most suitable type of EU instrument to promote water reuse in aquifer recharge as listed in the questionnaire. Nearly 60% of respondents are in favour of an EU regulation (binding) to set minimum requirements for water reuse. About 25% of respondents prefer a non-binding instrument, such as Commission recommendation (2/3 of these respondents) or CEN standards (1/3 of these respondents). Preference for one or the other of these non-binding instruments depends on the economic sectors EU region and organisation types considered. The rest of respondents does not have any opinion or would rather consider other policy options. Amongst these respondents, most advocated for legislation adapted to local contexts such as an EU Directive. Similarly to responses about irrigation, most comments from respondents which selected the responses “EU Regulation”, “Commission recommendation”, or “others” tend to show that a Directive would be the preferred option.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

Instrument needed for aquifer recharge

0%

20%

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60%

80%

EU regulation (binding)

Commission recommendation (not binding)

CEN standards (not binding)

Other

100%

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Figure 31: Views of the respondents on the instrument to be used to set EU minimum quality requirements for water reuse in aquifer recharge



Highlights from the analysis of responses across economic sectors

The analysis across economic sectors shows that respondents from most sectors rank the EU binding regulation as the preferred policy option (Figure 32), with a particularly high level of support from respondents from sanitation, drinking water, food and environmental sectors (at least 60% of respondents from each of these sectors) compared to health, agriculture and other economic sectors (52%, 47% and 40% respectively). Commission recommendations are the preferred option by industrial sectors other than food, drinking water and sanitation. They are, however, the second preferred policy option by other respondents from all other sectors (~20-25% of support across these sectors). Support for CEN standards is low (less than 10%, except agriculture where 15% are in favour of this option). Sanitation Drinking water Environment Food industry Health

Agriculture Economics 0%

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Figure 32: Views of the respondents by sector on the instrument to be used to set EU minimum quality requirements for water reuse in aquifer recharge



Highlights from the analysis of responses across types of stakeholders

Nearly 70% of citizens and over 80% of private companies support EU regulation option while only about half of the respondents from other types of organisations indicated to be in favour of an EU regulation. Commission recommendation was the second preferred option for all stakeholders and CEN standards was least preferred. Figure 33 shows difference in views between respondents representing different categories of stakeholders on the instruments to set EU minimum quality requirements for water reuse in groundwater recharge.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

Private companies Citizens NGO and others

Providers Authorities Industry or trade associations 0%

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Figure 33: Views of the respondents by categories on the instrument to be used to set EU minimum quality requirements for water reuse in aquifer recharge



Highlights from the analysis of responses across geographical regions

Respondents from Southern EU countries are slightly more in favour of an EU regulation than Northern and Eastern EU countries (67% of respondents in Southern countries compared to about 50% for other regions). When considering a non-binding instrument, respondents from Eastern EU countries are the most inclined to support the idea of an EC recommendation compared to other EU regions (about 30% vs. about 10 to 15% for other regions).

Instrument needed for aquifer recharge

Figure 34 shows difference in views between respondents from different EU regions on the instruments to set EU minimum quality requirements for water reuse in groundwater recharge. South East North 0%

10%

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EU regulation (binding)

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Figure 34: Views of the respondents by geographical locations on the instrument to be used to set EU minimum quality requirements for water reuse in aquifer recharge



Comparison between countries in situation of water stress and others

Respondents from countries with water stress are more in favour of an EU regulation than others (nearly 70% vs. over 55%). They also tend to prefer more than other countries the Commission recommendation (about 20% vs. about 15% for other countries) as a non-binding instrument. Figure 35 shows differences in views on the instruments to set EU minimum quality requirements for water reuse in groundwater recharge, between respondents representing countries in situation of water stress and other countries.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

Countries not in situation of water stress

Countries in situation of water stress

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Figure 35: Views of the respondents on the instrument to be used to set EU minimum quality requirements for water reuse in aquifer recharge by water stress

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

5.

Specific objectives of EU minimum requirements

Participants were asked to share their opinions on specific objectives to be addressed by EU minimum quality requirements for water reuse in agriculture irrigation and groundwater recharge.

5.1 Irrigation 5.1.1 Overview Key objectives for the EU minimum quality requirements for water reuse identified by respondents in the consultation include:    

protection of human health of consumers through the safety of agricultural products placed on the EU market, protection of human health of public directly exposed to reused water, protection of water resources and dependent ecosystems, and protection of the wider environment.

There is large overall consensus from respondents on these objectives, within and across categories of stakeholders (in particular within public authorities and civil society) and economic sectors (in particular within agriculture, health and environment). Consensus on these objectives is also seen amongst most respondents of Southern and Northern EU regions, except for respondents from Eastern EU countries which identify less the protection of human health of public directly exposed to water reuse as an objective. No difference is seen between respondents from countries facing water stress and respondents from other countries. In comparison, the protection of agricultural productivity is not given as much importance by respondents. Yet, respondents from the agricultural sector are more than 75% to think that protection of agricultural productivity should be an objective of the EU policy instrument on water reuse, well above the number of similar responses provided by the other sectors. Respondents from Eastern EU countries also show higher level of support for this objective compared to other EU regions (nearly 60% vs. less than 40% for other regions). Some respondents (11%) chose the option “other objectives”, and provide additional objectives that seemed important to them, most of them focusing on the environment. Many of the additional objectives proposed by respondents can be regrouped within the objective “protection of the wider environment”, such as mitigation of climate change impact, protection against soil erosion or maintaining a good water balance in rivers. Other comments were complements to the objective “protection of human health of consumers through the safety of agricultural products placed on the EU market”, with suggestions of possible aspects to be addressed to meet this objective. They are in the section 6 (Specific aspects of EU minimum requirements).

5.1.2 Detailed analysis 

Analysis of overall responses

Figure 36 shows the proportion of respondents in favour of specific objectives that should be addressed by EU minimum quality requirements for water reuse in agriculture. When looking at overall responses, there is a large consensus from respondents about the need for the EU minimum quality requirements to address the protection of human health, of water resources and environment: 

51

protection of human health of consumers (safety of agricultural products placed on the EU market) is ranked as the primary objective (87% of respondents consider it should be addressed),

Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results



protection of water resources and dependent ecosystems is the second higher objective (80% of respondents consider it should be addressed).

These objectives are followed equally (75% of respondents) by:  

protection of human health of public directly exposed to reused water, protection of wider environment.

In comparison, only nearly 40% of respondents think that protection of agricultural productivity should be covered by the EU requirements. 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Protection of Protection of water Protection of Protection of the Protection of human health of resources and human health of wider environment agricultural consumers (safety dependant public directly (e.g. soil) productivity (crop of agricultural ecosystems exposed to reused yield) products placed on water (e.g. the EU common workers) market)

Other

I don't know

Figure 36: Proportion of respondents recognising specific objectives that should be addressed by EU minimum quality requirements for water reuse in agriculture

Highlights from the analysis of responses across economic sectors



A majority of respondents in all sectors recognise specific objectives of health, water and environmental protection. The only major difference in sectors comparison can be observed in the objective of protecting agricultural productivity, where 75% of agriculture representatives would like to see this objective addressed by minimum requirements for water reuse in agriculture. Figure 37 shows difference in views on specific objectives that should be addressed by EU minimum quality requirements for water reuse in agriculture between respondents representing different sectors. 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Protection of human Protection of human Protection of water health of consumers resources and health of public (safety of agricultural directly exposed to dependant products placed on ecosystems reused water (e.g. the EU common workers…) market) Sanitation Drinking water Food

Protection of the wider environment (e.g. soil)

Agriculture

Health

Protection of agricultural productivity (crop yield) Environment

Other

Economics

Figure 37: Views of the respondents by sector on the specific objectives to address in EU minimum quality requirements in agriculture irrigation



Highlights from the analysis of responses across types of stakeholders

At least 70% of respondents in all categories consider as objectives of EU minimum requirements the protection of human health of consumers, the protection of human health of public directly exposed to reused water and the protection of water resources and dependent ecosystems. While respondents from civil society and public authorities show a very large support for all of these objectives (generally more than 80% of respondents), respondents from industry and trade associations show a lower level of support (50% of respondents), which cannot be explained based

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

I don't know

on the comments received. The protection of agricultural productivity is the objective finding the least support within and across categories of stakeholders, with a maximum of 50% of respondent considering it important. Figure 38 shows the views across types of stakeholders on specific objectives to be addressed by EU minimum quality requirements for water reuse for agriculture irrigation. 100% 90% 80% 70% 60%

50% 40% 30% 20% 10% 0% Protection of human health of consumers (in case the recharged aquifer is abstracted for drinking water purposes) Authorities

Providers

Protection of water resources and dependant ecosystems

Private companies

Other

Industry or trade associations

I don't know

NGO and others

Citizens

Figure 38: Views of the respondents by categories on the specific objectives to address in EU minimum quality requirements in agriculture irrigation

Highlights from the analysis of responses across geographical regions



The analysis within EU regions shows a large consensus on the protection of the human health of consumers and in the protection of resources and ecosystems (over 85% and about 80% in all regions). While respondents from Southern and Northern EU countries consider the protection of human health of workers as a key objective (75% of respondents from each of these categories at least), only 50% of respondents in Eastern EU countries share this view. On the contrary, the protection of agricultural productivity is considered important much more in Eastern EU countries (55%) compared to in Northern and Southern countries. Figure 39 shows difference in views on specific objectives that should be addressed by EU minimum quality requirements for water reuse in agriculture between respondents from different EU regions. 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0%

Protection of Protection of Protection of human health human health water of consumers resources and of public (safety of dependant directly exposed to agricultural ecosystems products reused water placed on the (e.g. EU common workers…) market) South

Protection of the wider environment (e.g. soil)

East

Protection of agricultural productivity (crop yield)

Other

I don't know

North

Figure 39: Views of the respondents by geographical location on the specific objectives to address in EU minimum quality requirements in agriculture irrigation

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

Comparison between countries in situation of water stress and others



Analysis of responses from countries in situation of water scarcity and others did not reveal any major differences between these two categories.

5.2 Aquifer recharge 5.2.1 Overview There is large overall consensus from respondents (over 80% of respondents) regarding the two listed objectives for the EU minimum quality requirements for water reuse in aquifer recharge:  

protection of water resources and dependent ecosystems, and protection of human health of public directly exposed to reused water.

Consensus on these objectives is very large in particular amongst respondents from public authorities and civil society as well as water utilities/water providers. Further analysis of responses confirms this consensus - within and between sectors, EU regions and countries groups impacted or not by water stress - around the objectives related to the protection of human health and water resources and dependent ecosystems: more than 70% of respondents of each economic sector and 80% of respondents in each EU region and countries groups are in favour of including these objectives in the EU policy instrument about water reuse for aquifer recharge. While a number of respondents (11%) chose the option “other objectives”, they did not specify any additional objectives to those listed in the questionnaire.

5.2.2 Detailed analysis Analysis of overall responses



Figure 40 shows the proportion of respondents in favour of specific objectives that should be addressed by EU minimum quality requirements for water reuse in aquifer recharge. The need for the EU minimum quality requirements to contribute to the protection of water resources and dependent ecosystems was supported by 87% of respondents while the protection of human health of consumers was supported by 84% of respondents. 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0%

Protection of water resources and dependant ecosystems

Protection of human health of consumers (in case the recharged aquifer is abstracted for drinking water purposes)

Other

I don't know

Figure 40: Proportion of respondents recognising specific objectives that should be addressed by EU minimum quality requirements for water reuse in aquifer recharge

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results



Highlights from the analysis of responses across economic sectors

The comparison between sectors also reflects the overall level of consensus for both the objectives:  

the share of respondents in favour of the protection of water resources and dependent ecosystems ranges from 82% to 90% depending on the economic sector considered, the share of respondents in favour of the protection of human health range from 70% for the food and economics sectors to 100% for the health sector.

The figure in the section on Specific objectives to address in EU minimum quality requirements in aquifer recharge in the Annex to this report shows the difference in views on specific objectives that should be addressed by EU minimum quality requirements for water reuse in aquifer recharge between respondents representing different sectors. 

Highlights from the analysis of responses across types of stakeholders

The level of consensus within categories of stakeholders is lower than within a same sector. Although both objectives of protection of human health and protection of water resources and dependent ecosystems remain important for all categories of respondents (at least 60% of respondents from each category), private companies and industry associations tend to perceive them as less important than other categories of respondents. This trend cannot be explained based on the qualitative responses to the consultation. The figure in the section on Specific objectives to address in EU minimum quality requirements in aquifer recharge in the Annex to this report shows the difference in views on specific objectives that should be addressed by EU minimum quality requirements for water reuse in aquifer recharge between respondents representing different categories. 

Highlights from the analysis of responses across geographical regions

The analysis within EU regions shows a consensus on the protection of the human health of consumer (between 80% and 90%) and in the protection of resources and ecosystems (over 85% in all regions). The figure in the section on Specific objectives to address in EU minimum quality requirements in aquifer recharge in the Annex to this report shows the difference in views on specific objectives that should be addressed by EU minimum quality requirements for water reuse in aquifer recharge between respondents from different EU regions. 

Comparison between countries in situation of water stress and others

Analysis of responses from countries in situation of water scarcity and others did not reveal any major differences between these two categories.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

6.

Specific aspects of EU minimum requirements

Participants were asked to indicate what specific aspects should be covered by EU minimum quality requirements for water reuse in agriculture irrigation and groundwater recharge.

6.1 Irrigation 6.1.1 Overview A majority of respondents from all categories identify the following key aspects to be covered by minimum EU requirements:  



microbiological contaminants: this aspect has a large consensus across all categories, monitoring: this aspect has a large consensus across all categories of respondents, except from respondents from the agriculture sector (where answers are more heterogeneous) and from respondents from industrial sectors other than food, drinking water and sanitation, which expressed a lower level of interest in this aspect. Several participants to the consultation highlighted that quality requirements for agricultural irrigation should be measured at the output of wastewater treatment plants where it is produced, and not after delivery in agricultural fields, other chemicals addressed by EU legislation: this aspect is largely supported by respondents from the agriculture, health and environment sectors, respondents from NGOs and academics, and respondents from Northern and Eastern EU.

In comparison, other aspects are more controversial within and across categories of respondents, such as risk-based management in particular. Risk-based management approaches were extensively discussed during the Stakeholder meeting on March 8 th. They appeared as a key instrument to ensure adequate protection of health and the environment, but their modalities were subject to extensive discussions. While risk assessment can consist in a simple decision tree to identify sources the most vulnerable to contamination according to some stakeholders, other perceive this exercise as being costly, time-consuming and requiring specific expertise. In consequence, it was asked in particular to clarify the type of risk-assessment to be used, as it may be qualitative (simplified approach based on expert judgment) or quantitative / semi-quantitative (comprising estimation of likelihood/frequency and severity/consequence). Participants recommended that the approach remains flexible to ensure deeper investigation is carried out with increasing level of risks. Several respondents raised the question of the relevance of setting quality parameters with associated thresholds when EU minimum requirements could rather promote key principles such as risk-based approach. About 50% or less of respondents expressed their interest in the following aspects:

56



nutrients: interestingly, respondents from Southern EU are only 40% to support this option (vs. 60% from Eastern and 70% from Northern EU countries). The question of nutrients remains highly controversial, as it can be seen both as a benefits from water reuse and a key barriers for ends-users like farmers. Several respondents to the consultation and a participant to the Stakeholder meeting on 8th March, highlighted the difficulty for farmers to reuse water which may be charged with nutrients. In practice, farmers need accurate and timely information on the quality of water they use, to mitigate potential contamination of the environment (groundwater contamination or eutrophication if water is directly released in the environment) or risks for their crops.



handling of treated water at farm level: the highest level of support is achieved within the health (63%) and agriculture sectors (58%) - which are naturally the most concerned by this issue – but the percentage of responses show less consensus on this question than for the other aspects,

Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results



other chemicals not addressed by EU existing legislation: the sanitation, drinking water, food and economics sectors are the least inclined to include this aspects in minimum requirements (less of 40% of respondents in each of these categories). The message is less clear when looking at the responses from the agriculture (~60% interest), health (52%) and environment sector (55%), which are more heterogeneous. Furthermore, respondents from Southern EU are only about 60% to support this option (vs. >80% of respondents from Eastern and Northern EU countries),



waste water treatment techniques: the sanitation and drinking water sectors – which are both directly concerned by this aspect, reach a large consensus about not covering this aspect in EU minimum quality requirements (less than 25% in favour of such an option). Similarly to previous options, respondents from Southern countries are the least inclined to include this aspect in future EU requirements. Concerns from several respondents about including this aspect in minimum requirements lie in possible consequences on impeding innovation. Best practices are continuously improving, as illustrated by a respondent through the work of the WIRE Action Group under the EIP-WATER.

Other aspects to be covered were raised by respondents to the consultation and/or during the Stakeholder meeting on 8th March, beyond those listed in the public consultation questionnaire: 

some respondents highlighted the need to ensure the safety of workers involved in water reuse and include relevant criteria,



a key issue raised during the stakeholder meeting on 8 th March relates to the need to clarify ultimate liability with regards to water reuse in the Member States, independently of the selected EU instrument. According to some participants, this question could directly impact on the types of aspects to be included in the EU minimum requirements. In this respect, some stakeholders recommended to apply minimum requirements that are stringent enough for farmers to be confident in the water they use on their crops, especially if they are to be held liable about the quality of food products irrigated with treated waste water. According to a comment provided by a representative from Global GAP, “it is important to specify if the [requirements] will cover the use of treated wastewater in irrigation or in any pre-harvest activity the farmer may do, e.g. de-frosting, application of plant protection products, pre-washing of products, washing of machinery in contact with the fruits and vegetables, hand washing, etc.” In addition, applying different water quality thresholds for different activities may be challenging as same water source is often used for several different activities.



elaborating on the consumer health objectives for the EU minimum requirements, some respondents also proposed to consider as an aspect to be included the protection of the intra-EU market from foreign agricultural products produced using regulated waste water with lower and the need to clearly report the origin of the water used to grow products.

6.1.2 Detailed analysis 

Analysis of overall responses

As shown in Figure 41, aspects to be covered in priority by EU minimum quality requirements for irrigation, based on the overall responses to the public consultation, include:    

microbiological contaminants (90% of responses) monitoring (71% of respondents), other chemicals addressed by EU legislation (~70%), and risk-based management (~65%).

The question of nutrient is another important aspect to be covered for 52% of respondents. Less than 50% of respondents expressed their interest in the following aspects:

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

  

handling of treated water at farm level (45%), other chemicals not addressed by EU existing legislation (44%), and waste water treatment techniques (39%).

100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0%

Microbiological contaminants

Monitoring

Other Risk-based chemicals management already (e.g. water addressed by safety plan) EU legislation on water quality in the environment or on discharges to water

Nutrients

Handling of Other Waste water treated water chemicals not treatment at farm level addressed by techniques (e.g. irrigation existing EU practices) legislation

I don't know

Figure 41: Proportion of respondents recognising specific aspects to be covered by EU minimum quality requirements for water reuse in agriculture irrigation and aquifer recharge



Highlights from the analysis of responses across economic sectors

Figure 41 shows the different views between respondents from different economic sectors with regards to specific aspects that should be covered by EU minimum quality requirements. Beyond the large consensus within and across the different sectors for the aspect of microbiological contaminants and monitoring, differences can be observed between sectors for other aspects: Risk-based management: Respondents in majority recognise risk-based management aspect, however respondents from agriculture, environment and economics sectors express less interest in seeing this aspect covered than other sectors (of about 10 to 15 points). Other chemicals: There is a clear difference between chemicals already covered in EU legislation and other chemicals, with a higher interest for the formers found in each category of respondents: 





A large majority of respondents from the agriculture (80%), health (90%), environment (80%) and economics (70%) sectors show interest for the coverage of chemicals already addressed by EU legislation. About 60% of respondents from the sanitation sector and 65% from the drinking water sector also show interest in this aspect. Respondents from the food sector are less interested in this aspect (55%). Respondents are much less in favour of covering chemicals not addressed by EU legislation. The sanitation, drinking water, food and economics sectors are the least inclined to include this aspects in minimum requirements (less of 40% of respondents in each of these categories). Trade and industry associations show less interest to include these aspects in EU minimum quality requirements.

Nutrients: The health sector is more in favour of including nutrients in the minimum requirements (73%) than other sectors (e.g. about 20 points more than agriculture sector). Handling of treated water at farm level: The highest level of support for handling of treated water at farm level is from the health (63%) and agriculture sectors (58%) - which are naturally the

58

Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

most concerned by this issue – but the percentage of responses show less consensus on this question than for the other aspects. Waste water treatment techniques: Least interest for waste water treatment techniques is shown by the sanitation and drinking water sectors – which are both directly concerned by this aspect, they reach a large consensus (less than 25% in favour of this option).

100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0%

Microbiological contaminants

Nutrients

Sanitation

Monitoring

Other chemicals Risk-based Other chemicals Artificial Waste water already management not addressed recharge treatment addressed by (e.g. water by existing EU techniques techniques EU legislation safety plan) legislation on water quality in the environment or on discharges to water Drinking water Food Agriculture Health Environment Economics

Figure 42: Proportion of respondents per sector recognising specific aspects that should be covered by EU minimum quality requirements for water reuse in irrigation



Highlights from the analysis of responses across types of stakeholders

Respondents from the industry and trade associations are generally less favourable than other stakeholders for the EU minimum requirements to cover the different aspects listed in the consultation, and in particular monitoring (50%) and risk-based management (40%). This trend cannot be explained based on qualitative results from the consultation. The figure in the section on Specific aspects to be covered by EU minimum quality requirements in agriculture irrigation in the Annex to this report shows the difference in views on specific aspects that should be covered by EU minimum quality requirements for water reuse in agriculture irrigation between respondents representing different categories. 

Highlights from the analysis of responses across geographical regions

Respondents from Southern EU countries are less in favour than other EU regions of including in EU minimum requirements other chemicals (whether they are already covered or not by EU legislation), nutrients or technical aspects such as waste water management and handling of treated water at farm level. The difference is of about 10 to 20 points depending on the aspect and region considered. Figure 43 shows difference in views on specific aspects that should be covered by EU minimum quality requirements for water reuse in agriculture irrigation between respondents from different EU regions.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

I don't know

100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Microbiological contaminants

Monitoring aspects

Risk-based Other Handling of Nutrients management chemicals treated water (e.g. water already at farm level safety plan) addressed by (e.g. irrigation EU legislation practices) on water quality in the environment or on discharges to water South East North

Other Waste water chemicals not treatment addressed by techniques existing EU legislation

I don't know

Figure 43: Proportion of respondents per location recognising specific aspects that should be covered by EU minimum quality requirements for water reuse in irrigation



Comparison between countries in situation of water stress and others

Other chemicals already addressed by EU legislation are largely supported by respondents from countries not in situation of water stress (80% vs. around 50% for other countries). Also, the majority of respondents from countries not in situation of water stress favours including other chemicals not addressed by EU existing legislation (nearly 60%) which is much more than those subject to water stress (about 30%). In addition, respondents from countries in situation of water stress are more in favour of including risk-based management and less supportive of including the technical aspects such as waste water management and handling of treated water at farm level in the requirements than others. The figure in the section on Specific aspects to be covered by EU minimum quality requirements in agriculture irrigation in the Annex to this report shows the difference in views on specific aspects that should be covered by EU minimum quality requirements for water reuse in agriculture irrigation between respondents representing countries in situation of water stress and other countries.

6.2 Aquifer recharge 6.2.1 Overview According to the responses, priority aspects to be covered by minimum quality requirements for water reuse include: microbiological contaminants, monitoring, other chemicals addressed by EU legislation and risk-based management (for over 60% of respondents). The question of nutrients is considered as a priority aspect to be covered when reusing water for aquifer recharge (78% of respondents). Differences can be seen depending on the economic sector and the region considered.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

In particular: 



microbiological contaminants, nutrients and monitoring are aspects that are subject to a large consensus across most categories of respondents, and in particular within the sanitation and drinking water sectors and health and environment (over 80% of respondents). Responses from the agriculture sector are more mixed, other chemicals already addressed by EU legislation is an aspect subject to a very large consensus within and across respondents from the health, economics and environment sectors and large consensus amongst respondents from the agriculture sector (75%). It is also largely supported by respondents from the Eastern and Northern EU countries and generally by respondents from countries not experiencing water stress. Less consensus within and across categories of respondents is seen for including other chemicals that are not yet addressed by EU legislation, except from respondents from Northern and Eastern EU countries.

Respondents express less interest in general for technical aspects such as waste water management and artificial recharge techniques. Some respondents explain this by the diversity of techniques in the reuse of water and the need to allow new techniques to be developed to meet specific challenges in given situations and geographies. Another aspect to be covered, as mentioned by some respondents beyond those listed in the public consultation questionnaire, is to ensure the safety of workers involved in water reuse.

6.2.2 Detailed analysis 

Analysis of overall responses

As shown in Figure 44, aspects to be covered in priority by EU minimum quality requirements for aquifer recharge, based on the overall responses to the public consultation, include:     

microbiological contaminants (82% of responses), nutrients (78% of responses), monitoring (72% of respondents), other chemicals already addressed by EU legislation (71%), risk-based management (~65%).

100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0%

Microbiological contaminants

Nutrients

Monitoring

Other Risk-based Other chemicals management chemicals not already (e.g. water addressed by addressed by safety plan) existing EU EU legislation legislation on water quality in the environment or on discharges to water

Artificial recharge techniques

Waste water treatment techniques

I don't know

Figure 44: Proportion of respondents recognising specific aspects to be covered by EU minimum quality requirements for water reuse in aquifer recharge

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

About 50% of respondents or less express their interest in each of the following categories:   

other chemicals not addressed by EU existing legislation (52% of respondents), artificial recharge techniques (43%), and/or waste water treatment techniques (38%).



Highlights from the analysis of responses across economic sectors

Respondents from the agriculture sector are those who support the least the consideration of: 

  

microbiological contaminants (60% of respondents only would include this aspect in future EU requirements compared to over 80% of respondents in other sectors such as sanitation and drinking water sectors, health and the environment), nutrients (65% of respondents compared to over 80% of respondents from sanitation, drinking water, health and environment sectors), monitoring (less than 60%), and risk-based management (around 40% of respondents compared to around 70% from the health, sanitation and drinking water sector).

Figure 45 shows difference in views on specific aspects that should be covered by EU minimum quality requirements for water reuse in aquifer recharge between respondents representing different sectors. Full figure presenting all aspects can be found the Annex of the report. 100% 90% 80%

70% 60% 50% 40% 30% 20% 10% 0% Microbiological contaminants Sanitation

Drinking water

Nutrients Food

Monitoring Agriculture

Health

Environment

Risk-based management (e.g. water safety plan) Economics

Figure 45: Proportion of respondents in agriculture and other sectors recognising 4 specific aspects to be covered by EU minimum quality requirements for water reuse in aquifer recharge



Highlights from the analysis of responses across types of stakeholders

Respondents from the industry and trade associations are generally less favourable than other stakeholders for the EU minimum requirements to cover the different aspects listed in the consultation, and in particular microbiological contaminants and risk-based management (less than 40% of respondents). This trend cannot be explained based on qualitative results from the consultation. Responses from authorities and providers are more or less in line between themselves for many aspects except regarding the technical aspects such as waste water treatment and artificial recharge techniques. For these aspects, responding authorities are much more in favour to cover them by

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

minimum requirements than providers (over 50% of authorities vs. 20% and 32% of providers in favour of waste water treatment and artificial recharge techniques respectively). The figure in the section on Specific aspects to be covered by EU minimum quality requirements in aquifer recharge in the Annex to this report shows the difference in views on specific aspects that should be covered by EU minimum quality requirements for water reuse in aquifer recharge between respondents representing different categories. 

Highlights from the analysis of responses across geographical regions

A majority of respondents from the Eastern and Northern EU countries support the consideration of “Other chemicals” in the EU minimum requirements, whether they are already addressed by existing EU legislation (85% of respondents compared to less than 65% of respondents from Southern EU countries) or not (over 70% of respondents compared to 40%). In addition, respondents from Southern EU countries are slightly less in favour of including the technical aspects such as waste water management and artificial recharge techniques in the requirements than others (about 10 points). Figure 46 shows difference in views on specific aspects that should be covered by EU minimum quality requirements for water reuse in aquifer recharge between respondents from different EU regions. 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Microbiological contaminants

Nutrients

Monitoring

Risk-based Other Other management chemicals chemicals not (e.g. water already addressed by safety plan) addressed by existing EU EU legislation legislation on water quality in the environment or on discharges to water South

East

Artificial recharge techniques

Waste water treatment techniques

I don't know

North

Figure 46: Proportion of respondents per location recognising specific aspects to be covered by EU minimum quality requirements for water reuse in aquifer recharge



Comparison between countries in situation of water stress and others

Respondents from countries that do not face water stress are more supportive of including the aspect “Other chemicals” in the EU minimum requirements, whether they are already addressed by EU legislation (82% of respondents compared to 57% from other countries) or not (65% of respondents compared to 35% from other countries). In addition, respondents from countries in situation of water stress are less in favour than other countries of including the technical aspects such as waste water management and artificial recharge techniques in the requirements. Figure 47 shows difference in views on specific aspects that should be covered by EU minimum quality requirements for water reuse in aquifer recharge between respondents representing countries in situation of water stress and other countries.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

90% 80% 70% 60% 50% 40% 30% 20% 10% 0%

Nutrients

Microbiological contaminants

Monitoring

Risk-based management (e.g. water safety plan)

Other chemicals already addressed by EU legislation on water quality in the environment or on discharges to water

Artificial recharge techniques

Other chemicals not addressed by existing EU legislation

Waste water treatment techniques

I don't know

Other Microbio chemicals contami already addressed by EU legislation on water quality in the environment or on discharges to water

Other Artificial chemicals rechargenot addressed techniquesby existing EU legislation

Waste water water Waste treatment treatment techniques techniques

don't know know II don't

Other Microbio chemicals contami already addressed by EU legislation on water quality in the environment or on discharges to water

Countries in situation of water scarcity

90% 80% 70% 60% 50% 40% 30% 20% 10% 0%

Waste water treatment techniques

I don't know

Nutrients Microbiological Other Microbiological contaminants chemicals contaminants already addressed by EU legislation on water quality in the environment or on discharges to water

Monitoring Monitoring

Risk-based Nutrients management (e.g. water safety plan)

Other Artificial Other Risk-based chemicals recharge chemicals not management alreadyby techniques addressed (e.g. water addressed existing EUby safety plan) EU legislation legislation on water quality in the environment or on discharges to water

Countries Countries notininsituation situationofofwater waterscarcity scarcity

Figure 47: Views of the respondents in countries affected by water stress on the aspects to be covered in EU minimum quality requirements in aquifer recharge

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

7.

Other uses to be covered by EU minimum requirements

Participants were asked to share their views on other uses of treated waste water that EU minimum quality requirements for water reuse should cover: irrigation of sport fields, irrigation of urban green spaces, industrial uses and other urban uses.

7.1 Overview Other types of uses than irrigation and aquifer recharge “could” be addressed according to a large majority of respondents (and “should” be addressed for 50% of them). In this respect, a representative from the water suppliers highlighted during the Stakeholder meeting on 8 th March the relevance of considering several types of uses beyond agriculture irrigation and aquifer recharge, in order to maximise water reuse and optimise investments returns. Among the overall responses, the largest consensus amongst respondents (over 85%) concerns the extension of irrigation to urban green spaces and sport fields. This overall consensus hides various levels of support between economic sectors. While irrigation of sport fields and urban green spaces receives relatively large support from respondents from the health and environment sectors, they are supported by fewer respondents from the industrial sectors other than food industry and water and sanitation. In comparison, other types of uses, and in particular industrial uses, are slightly more controversial overall (nearly 20% of respondents think industrial uses should not be addressed, compared to 10% for irrigation of sport fields & urban green spaces or 15% for other urban uses). Yet, these industrial uses “should” still be included according to 40% of respondents and “could” be included according to 35% of respondents. Some respondents from private companies in drinking water or sanitation and industrial sectors highlight that minimum standards already exist for industrial uses and that creating new ones would lead to regulatory duplications and additional administrative burden. It is important to highlight a possible confusion in the responses from the respondents on this issue. Based on the Stakeholder meeting on 8 th March and some comments from the consultation, it appears that the scope of EU minimum requirements was not necessarily clear for everyone, which may have impacted the responses to this question: the water to be reused would be the waste water as covered by the Urban Waste Water Treatment Directive, and not waste water directly treated by the industrial sector. Respondents from Southern and Eastern EU countries are more inclined than Northern regions to expand EU requirements to irrigation of sport fields, irrigation of urban green spaces or other urban uses. This trend is also found for the respondents from countries in situation of water stress compared to other countries.

7.2 Detailed analysis 

Analysis of overall responses

Figure 48 shows overall support of respondents for developing EU minimum quality requirements for other uses of treated waste water. The largest consensus amongst respondents (>85%) concerns:  

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irrigation of urban green spaces, which ‘should’ be addressed according to 50% of respondents and ‘could’ be addressed according to 35% of respondents; and irrigation of sport fields, which ‘should’ be addressed according to 48% of respondents and ‘could’ be addressed according to 38% of respondents.

Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

In comparison, slightly less consensus is achieved with regards to the other two types of uses:  

Other urban uses: 80% of respondents consider either the possibility (37%) or even the need (43%) to cover this type of use, Industrial uses: 75% of respondents consider either the possibility (35%) or even the need (40%) to cover this type of use. A higher number of respondents explicitly say not to be in favour of including industrial uses in EU minimum quality requirements (nearly 20% compared to 10% for irrigation of sport fields & urban green spaces or 15% for other urban uses). Some even highlighted the availability of guidance for water reuse in the industry. As mentioned in the overview, the scope of water reuse may not have been clear to some respondents and might have impacted on the relevance of answers.

Other urban uses (street cleaning, firefighting…)

Irrigation of urban green spaces

Irrigation of sport fields (incl. golf courses)

Industrial uses

0%

10%

20%

30%

40%

50%

60%

70%

80%

Should be covered by EU minimum quality requirements

Could be covered by EU minimum quality requirements

Should not be covered by EU minimum quality requirements

I don't know

90%

100%

Figure 48: Views of respondents on other uses of treated waste water to be covered by EU minimum quality requirements



Highlights from the analysis of responses across economic sectors

The level of support of a type of use or another is quite heterogeneous within and across categories of stakeholders. Respondents from the health sector show the highest level of support for including the irrigation of sport fields (“should” be included for 62% of respondents), urban green spaces (“should” be included for 62% of respondents) and to a lesser extent other urban uses (“should” be included for 59%) in EU minimum quality requirements for water reuse. Similarly, respondents from the environment sector were more keen than other sectors to include irrigation of sport fields and urban green spaces (each use “should” be included according to 54% of respondents) under EU minimum quality requirements. Drinking water and sanitation respondents are more or less in line regarding opinion on the EU minimum quality requirements for all listed uses except for other uses (street cleaning, firefighting, etc.), where respondents from sanitation are nearly 90% in favour of including these uses and drinking water representatives are less than 70% in favour. There is no clear difference across sectors with regards to the need or possibility to include industrial uses, except for the agriculture and environment sectors which appear to be the most in favour of these options. The figure in the section on Other uses to cover by EU minimum quality requirements in the Annex to this report shows the difference in views on other uses of treated waste water to be covered by EU minimum quality requirements between respondents representing different sectors. 

Highlights from the analysis of responses across types of stakeholders

The level of support of a type of use or another is quite heterogeneous within and between categories of stakeholders.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

The civil society and academics are the categories the most in favour of addressing other types uses than agriculture irrigation and aquifer recharge in the EU minimum requirements, including irrigation of urban green spaces (~60% of respondents), irrigation of sports fields (~55% of respondents) and other urban uses such as street cleaning, firefighting, etc. (~50% of respondents). Respondents from public authorities are in great majority in favour of including all listed uses in the scope of the EU minimum requirements (over 80% state that other uses could be covered by requirements). Their support is highest in favour of including the irrigation of urban spaces (nearly 90%). In comparison, the group of industries and trade associations is remarkably less in favour of including other uses than agriculture irrigation and aquifer recharge in the scope of EU minimum requirements, compared to other stakeholders: 25% only on average think the different other uses should be covered by EU minimum quality requirements. In particular, 50% of respondents from these categories consider that industrial uses should not be covered (please refer in this respect to the disclaimer from section “Analysis of overall responses” above). The figure in the section on Other uses to cover by EU minimum quality requirements in the Annex to this report shows the difference in views on other uses of treated waste water to be covered by EU minimum quality requirements between respondents representing different categories. 

Highlights from the analysis of responses across geographical regions

When looking at the responses from different EU regions, respondents from Southern and Eastern EU countries are much more inclined than Northern regions to expand EU requirements to irrigation of sport fields, irrigation of urban green spaces or other urban uses (over 80% of respondents from these EU regions “could” include these types of uses in EU requirements). Amongst 85% of respondents from Southern EU countries are also in favour of expanding EU requirements to industrial water reuse. The figure in the section on Other uses to cover by EU minimum quality requirements in the Annex to this report shows the difference in views on other uses of treated waste water to be covered by EU minimum quality requirements between respondents from different EU regions. 

Comparison between countries in situation of water stress and others

Similarly, respondents from countries in situation of water stress are also the most inclined to expand EU requirements to other types of water use compared to other countries. Almost all respondents from these countries are in favour of including other uses (over 90%) while in countries not in situation of water stress about 15% to 25% in average of respondents consider that other uses should not be covered by EU minimum quality requirements. The figure in the section on Other uses to cover by EU minimum quality requirements in the Annex to this report shows the difference in views on other uses of treated waste water to be covered by EU minimum quality requirements between respondents representing countries in situation of water scarcity and other countries.

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Policy options to set minimum quality requirements for reused water in the EU – analysis of open public consultation | Analysis of results

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