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Agw stellungnahme prioritäre stoffe_engl_endg_280312

Aggerverband Bergisch-Rheinischer Wasserverband Erftverband Emschergenossenschaft Linksniederrheinische Entwässerungs-Genossenschaft Lippeverband Niersverband Wasserverband Eifel-Rur Ruhrverband Wupperverband agw-Position paper
on the proposal for a Directive of the European
Parliament and of the Council amending
Directives 2000/60/EC and 2008/105 as regards
priority substances in the field of water policy
COM(2011) 876 final, 31.01.2012
The Water Board Association (agw) in the German State of Northrhine
Westfalia (NRW) comprises the regional water boards: Aggerverband,
Bergisch-Rheinischer-Wasserverband, Emschergenossenschaft, Erft-
verband, LINEG, Lippeverband, Niersverband, Ruhrverband, Wasser-
verband Eifel-Rur and Wupperverband. We operate on the principle of
‘open responsibility for public water management’. As members of the
agw, we are responsible for water management in an area covering
almost two thirds of the NRW region, in which we operate 310 water
treatment plants to serve approximately 19 million inhabitants. We also
manage 29 dams and a river network of 17,700 kilometres.
Preliminary Note:
The agw generally welcomes the EU-Commission’s initiative to extend
the list of priority substances and the Environmental Quality Standards
(hereinafter EQS) specified therein in light of new technical and scien-
tific findings. This includes a proposed increase in quantity for 6 sub-
stances in the current list and the inclusion of a further 15 additional
The agw questions the reasoning behind the inclusion of naturally oc-
curring substances in the list. We are particularly concerned about the
partially inadequate data and standard of data quality and the selection
of assessment factors on which the EQS are based. We, therefore, pro-
pose that certain substances be placed on the ‘Watch list’ until such
time that adequate data is available to create a solid and reliable envi-
ronmental quality standard.
The agw requests that the EU-Commission, the European Parliament
and the European Council eliminate the substantial deficiency of techni-
cal data in the draft proposal and requests that the aforementioned
European institutions consider the comments and suggestions of the
agw in the course of the consultation.
agw comments as follows in response to the proposed Directive:
1. agw- questions the practicality and purpose of including
naturally occurring or produced substances in the list

agw Statement:
The list of proposed substances includes 17-beta-estradiol (no. 47).
This substance is the natural female hormone, which is also an ingredi-
ent in certain medicinal drugs. According to the literature references,
90% of the measurement values recorded in waters concerns the natu-
rally produced hormone.

The second example relates to polyaromatic hydrocarbons (no. 28),
for which the quality targets have been made considerably more strin-
gent. One can assume that these substances result from combustion
processes, such as forest fires, which can also be naturally occurring in
origin, and enter into the natural environment through diffuse sources.
The industrial use of products containing polyaromatic hydrocarbons
(PAH), such as coal tar, has been widely prohibited for years.
It is questionable as to whether such substances should be included in
the list at all. In the view of agw, there is no technical, scientific basis on
which to justify the inclusion of naturally occurring substances. The
same applies to a lesser extent for the heavy metals Lead (no. 20) and
Nickel (no. 23). Waterways can be polluted by geogenically determined
levels of lead and nickel. Based on the considerably more stringent
quality levels stipulated in the draft proposal, it makes sense to estab-
lish provisional targets for both substances based on preexisting con-
centrations to account for background presence and geogenically de-
termined levels. Otherwise many of the European water bodies will find
themselves unavoidably exceeding quality levels.
2. The derivation of EQS for lead, nickel, PFOS, 17 alpha-
ethinylestradiol, 17 beta-estradiol and diclofenac is inade-
quate and fundamentally called into question

agw Statement:
The proposal to introduce a considerably more stringent limit for Lead
comes only 4 years after the first Directive on priority sub-
stances entered into force. The SCHER Report (May 2011), offers no
justification for reducing the EQS for lead from 7.2 µg/l to 1.2 µg/l. The
report only refers to a need to consider bioavailability and at the same
time, criticises the lack of sound data basis. The derivation of new EQS
is manifestly deficient, as the previous value of 7.2 µg/l for lead (2008
Directive) already accounts for bioavailability.
A comparable error is also apparent for the tightening of EQS for Nickel
(no. 23)
from 20 µg/l to 4 µg/l. For this reason, the agw requests that
the EU-Commission checks the proposed values for lead and nickel. As
agw reinforces in point 3 of this position paper, it is crucial to be able to
draw upon a scientifically sound data basis to establish proposed con-
centration values.

In the view of agw, the method of deriving EQS for PFOS (no. 35) in
the SCHER Report (May, 2011) is not plausible. A recalculation of EQS
for waterways with effects on biota, with additional assessment factors
lacking adequate data (for e.g., the influence of water parameters such
as pH-value, salinity and total organic carbon content), results in a pure-
ly mathematical, very low EQS of 0.000,00065 milligrams per litre. This
concentration is so low that it cannot be reliably detected or measured
using currently available analysis methods. As PFOS are ubiquitous,
this would lead to unavoidable exceedances of limits set for priority
substances in many waters. Apart from a so-called ‘phasing-out’, there
are no other measures which can achieve such a low concentration in
the long term. Please refer to our statements in points 3 and 4 of this
position paper.
As regards the parameters for 17 alpha-ethinylestradiol and 17 beta-
please refer to our comments under points 1 and 6 of this
position paper. Additionally, the derivation of EQS for 17 alpha-
(SCHER-Report, March 2011) includes an assess-
ment factor of 2 for the parameter ‘Fish’, despite a basis of apparently
good quality data. The SCHER also confirms that, as a principle, a good
quality data basis should be sufficient for avoiding the need for an as-
sessment factor.
The SCHER-Report (May 2011), regarding a derivation of EQS for di-
clofenac (no. 48),
makes surprising and significant contradictory
statements regarding the solubility of this substance. The details for
solubility vary by a factor of 1800 in the scientific publications. The
SCHER-Report makes no sufficient statements regarding the MAC val-
ues in waterways or regarding bioaccumulation. For deriving the annual
average quality standard, there is, despite claims of good quality data
from the authors of the SCHER-Report, a more stringent assessment
factor of 10, which actually serves to compensate for a bad quality data.
The derivation of factors is apparently very subjective and therefore
basically makes the proposed values vulnerable. We therefore suggest
that diclofenac also be included in the ‘Watch list’, until such time that
the issue of contradictory data can be clarified.
3. Substances with a assessment factor greater than, or equal
to 5 should remain on the ‘Watch list’ until sufficient
ecotoxicological information is available for deriving a reli-
able environmental quality standard

agw Statement:
As compliance with the EQS may indeed require the measures ad-
dressed in point 7 of this position paper, and given that according to
agw’s initial calculations, such measures will potentially require Billions
in financial investments, it is crucial, that the data, on which the deriva-
tion of EQS is based, proves to be scientifically accurate and statisti-
cally reliable. This means that an assessment factor no greater than 5
should be used – ideally the target should be an assessment factor of 1.
In cases where the base data is inadequate, the substances in question
should be placed on the ‘Watch list’.

It is generally questionable whether, and in what way, an improved data
basis for assessment factors will ultimately impact the EQS. It can be
assumed that these will become less stringent. Experience shows that it
will become challenging for the politically accountable to make estab-
lished environmental quality standards less stringent based on an im-
proved data situation in the face of a more aware and better-informed

4. There is no standardised analysis procedure for compliance
with specific environmental quality standards

agw Statement:
Some of the new specifications for quality standards are extremely low.
By way of example, the proposed annual average permissible concen-
tration for brominated diphenylethers (no. 5) is 0.000,000,000,049
milligrams per litre. There is currently no standardised or suitable analy-
sis procedure for measuring such a low concentration for the purpose of
implementing the Directive. Similarly, for 17 alpha-ethinylestradiol und
17 beta-estradiol
, the currently available analysis procedures are only
able to detect limits 20-times higher than the EQS proposed for these
5. Permissible annual average values and maximum allowance
concentration are not coherent for some parameters

agw Statement:
The annual permissible average value for some selected parameters is
not coherent with the associated maximum allowable concentrations
(MAC value). In which case, a single sample of brominated di-
phenylethers (no. 5)
could easily comply with the concentration levels
stipulated for the maximum allowable concentration, and yet greatly
exceed the permitted average annual concentration.
Conversely, for Anthracene (no. 2) and Mercury (no. 21) the values
are identical, or almost identical. The agw requests that the Commis-
sion checks the accuracy of the values for these categories.
6. The proposed new substances are not coherent with the ex-
isting EU-Guidelines for accompanying measures

agw Statement:
In its position paper on the Fitness Check for European Water Policy,
the agw recently criticised the lack of coherence between Directives.
This criticism also applies to the proposal to extend the list of priority
substances. Although there are accompanying guidelines for measures
regarding some substances, for example, authorisation processes for
pesticides, or restrictions on the usage of PFOS (no. 35), there are also
substances included in the list, for which absolutely no guidelines for the
protection of waterways exist, for example, the medicinal drug ingredi-
ents 17 alpha-ethinylestradiol (no. 46) und diclofenac (no. 48). In our
opinion, it is vital, that there is EU-wide regulation governing such sub-
stances, which the EU defines as priority substances, to best-manage
and stop emissions of polluting substances at their source. It is also
proposed, as mentioned, that a compulsory ‘phasing out’ is introduced
for the priority hazardous substance, PFOS (no. 35). It is the responsi-
bility of the EU in its legislative capacity to ensure that European water-
ways remain free of PFOS emissions and to ensure it is no longer pos-
sible to pollute waters with PFOS products.
7. There is no guideline or proposal for implementing and en-
forcing the Directive in the Member States

agw Statement:
In the view of agw, there is a further deficiency in the Directive proposal
regarding the necessary measures for implementation throughout the
European Member States. Aside from the known difficulties of minimis-
ing potential substance emissions from diffuse sources, there is a seri-
ous problem when priority listed substances are primarily emitted from
household or communal water into urban waste water systems. This is
particularly problematic where insufficient, or no guidelines for usage or
disposal of these substances are provided. Under such conditions, the
responsibility for ensuring provisions to enforce the content of the Direc-
tive result in the upgrading of the communal wastewater treatment
and potential further empowering of locally responsible authorities
to this end
via the so-called fourth treatment (purification) stage, as a
possible solution. We request that the European Commission clearly
communicates its strategy for the role water treatment plants within the
context of this proposed Directive. It was made clear in the last report
regarding the implementation of the European Urban Waste Water Di-
rective (January 2012) that even in the course of implementing existing
measures there are considerable deficits and imbalances between
Member States. In the view of the agw, it must be ensured, that the
Directive can be equally implemented throughout all European Member
States and not just the few, which assume they are able to comply.
It is also important to respect the polluter-pays-principle and to ensure
that measures are implemented as close as possible to the source. In
order to enforce the Directive, we expect the EU-Commission to pro-
pose a defined, Europe-wide concerted and consistent solution which is
consumer-viable and affordable throughout all EU Member States. The
agw requests that the EU-Commission undertakes to present an esti-
mation of the costs associated with implementing the Directive in the
Member States.
It is also unclear whether the processes referred to under the fourth
wastewater treatment stage, such as ozone oxidation, the use of acti-
vated carbon powder or granules, or nano-filtration for purpose of
achieving environmental quality standards, are even sufficient for, or in
the wider interests of water management. In this context, there are also
the secondary effects to consider, such as the accumulation of toxic
byproducts through Ozone, the disposal of concentrates in the nano-
filtration process and the significantly increased energy consumption, to
name a few. All of which are not in the interests of a coherent Commu-
nity policy.


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