De-Mystifying the EU Water Framework Directive

By Mike Woolgar

At the core of Europe’s approach to water policy, the WFD and River Basin Management Plans are meant to better manage resources stretched by growing population and stress put on systems due to climate change but their implementation isn’t without challenges, according to Atkins Ltd.

Water quality monitoring site at Dee Catchment Area on the Dee River near Aberdeen, England
[Photo credit: Brian Cox]Click here to enlarge image

The purpose of the EU Water Framework Directive (WFD) is to stimulate a more systematic approach to sustainably improving integrated water management at a catchment or river basin level, with the outcome of better chemical and ecological water quality as the goal. The need for “good water quality” extends into the marine environment to ensure pollution is managed at the source and the sea isn’t used a dump. As a systematic approach, to be based on as good science as can be managed, it has taken some time to define baseline conditions and outcomes in a way that’s suitable to allow progress toward such outcomes to be planned and measured. But a great deal of uncertainty over key issues remains at a time when important decisions have to be made, ones which will be with us for many years to come.

Decision Time 2008

This is a critical year for implementation of the Water Framework Directive in England and Wales, particularly for the regulated water industry, as companies prepare for the next periodic review. It’s close to the point where money has to be committed and consumers, who’ll bear the costs, will need to be engaged in the process.Several forces are working together to put pressure on the water industry. These include increasing demands to improve water quality, whether by reducing point source pollution such as wastewater treatment works effluent or by better managing more diffuse sources of pollution. Simultaneously, continuing market and regulatory incentives minimize water service cost and price increases. On top of that, the industry must deal with society’s need to reduce greenhouse gas (GHG) emissions, either through carbon reduction commitments or emissions trading schemes. And this is all taking place in an economic environment where there’s the strong possibility of a downturn and a squeeze on industry margins. In this challenging context, yesterday’s solutions or even today’s are unlikely to suffice in a more complex and demanding future. The key question for the industry now is, can we aim for a cost-effective implementation of WFD objectives by 2015, or is an adaptive/phased scenario the only answer?

Uncertainty

In seeking to answer that question, one of the biggest issues facing the water industry is the high degree of uncertainty that surrounds so many key issues, but especially cost. Indeed, the UK Environment Agency’s own analysis last year concluded: “Uncertainties in planning to meet WFD objectives are greater than normally experienced in water management. There are very significant uncertainties which may lead to a high risk of abortive expenditure and missed objectives [see www.environment-agency.gov.uk/subjects/waterquality/955573/1458449/].

Identifying Key Questions

Given this backdrop, what are the main questions where water companies need to focus? The WFD seeks to drive improved water quality and better integrated management of water to reduce effects of flooding and droughts, where necessary through appropriate use of economic instruments; it also makes specific reference to the need to reduce and ultimately phase out discharges and emissions of priority hazardous substances. These are substances deemed “toxic, persistent and liable to bio-accumulate”; in other words, substances inherently likely to be difficult to remove from the environment once released. Of course, preventing further release of such pollutants, i.e., source control, is the right course of action to avoid further contamination; but the “persistent” nature of these substances means there may be an implied duty on the water companies to take action to reduce existing pollution by treatment as well as reducing future pollution by controlling emissions.

To date, removal of newly proscribed pollutants or contaminants has been achieved by improving existing water or wastewater treatment processes or by adding or substituting new ones. Technically this may continue to be possible but at what cost?

Furthermore, in accordance with the “polluter pays” principle required in the WFD, who should meet the cost of such additional capital cost, operating cost and indeed additional carbon output? If so-called “end of pipe” solutions to be installed by the water industry are preferred, water consumers will be carrying the costs through increased charges, irrespective of their individual or collective responsibility for the original contamination. Of course, if industry has to cease polluting with particular chemicals, then either the cost of additional treatment or the costs associated with not using such chemicals in the first place will be passed onto the consumer of the product.

And what of diffuse pollution from farmland, from roadway run-off or from underground storage tanks, for example? Whilst such pollution may not contribute much to chemical contamination of water, what’s the overall contribution to impaired water quality?

Compliance with the WFD

The water industry is concerned about being driven to adopt measures which aren’t cost-effective for either the business or customers. As objectives of the WFD are essentially to develop better integrated management of the aquatic environment, mechanisms to achieve compliance need to follow suit. As such, water companies need to make serious progress in the following crucial areas:

Understanding environmental issues

Similarly to the systematic approach applied to searching for and dealing with leakage in water networks or infiltration/exfiltration in sewer networks, we need to continue to improve understanding of physical, chemical and hydrodynamic processes at a catchment scale. Many tools are already available such as nutrient modeling, resource and flood modeling, fate of chemicals modeling, abstraction and discharge consenting, pollution plume monitoring, bioassay techniques, gene chemistry or radioactive marking for source and fate assessment, etc. for evidence gathering, baseline condition assessment and progress monitoring.
The question that needs to be asked is whether or not the suite of tools available is being used in a sufficiently joined up way.

Catchment management

Many of these tools for improving water quality are also available or becoming available. There have been successes already in reducing nutrient inputs from agriculture by altering management practices, and there are surely more management practice approaches that can be taken at relatively low cost provided we have sufficient information to assess benefits as well as capture costs.
Reducing the input of potential pollutants must of course be addressed, but this assumes that the source of such pollutants is known, reduction can be made permanent and reliable, and it’s cost effective. For example, border strips on farmland may well be part of the answer if theland uphill is managed appropriately and consistently but only if the strips reliably control the source;
Dilution may have its place, given that many of the proscribed pollutants are to be reduced to specified concentrations; but many water bodies are already under stress in certain months (during droughts) and it may be impossible to securely allocate sufficient water to ensure the necessary dilution.
In summary, the development of an integrated catchment management approach will be key to achieving the WFD goals. The good news is that UK Water Industry Research (www.ukwir.org) is proactively evaluating how catchment-based management can be delivered to meet requirements of the WFD from the water industry standpoint.

Technology development

Effective, well-known treatment technologies exist which water companies can add to their process streams. In some cases, this approach may be the only solution.
Numerous new technologies are being developed all the time, which seek to achieve improved outputs with lower energy input, or lower land footprint or both. It may be possible to deploy these, but their reliability is currently uncertain. Where new technologies are developed, but which need to be “proven” for the industry to accept them, there needs to be an understanding between the water companies and environmental regulator on achieving full compliance with the WFD’s target of achieving “good ecological and good chemical status” by 2015. Without this, water companies are unlikely to take the risk on “process critical”, unproven technologies.
Technology also needs to be brought to bear on the enormous issue of making UK water more “sustainable”. All technological solutions whether ‘end of pipe’ or process improvements should aim to keep the carbon footprint of improvements to a minimum.

Beckingham Marshes environmental management along the River Trent near Gainsborough, EnglandClick here to enlarge image

As we said before, the WFD seeks to stimulate an integrated approach, and it is likely that combinations of all of the above options, and others not listed, may be necessary to provide the most appropriate and sustainable programme of measures. Clearly in the absence of a sound understanding of the “water contaminant sources fate of contaminant” cycle, there is a risk that, for the sake of expediency, planned improvements could be less than optimal in terms of cost, carbon impact, operability and sustainability. As indicated by the water industry’s representative organization, Water UK “High water customer bills are not acceptable unless the costs and benefits and improvement needed can be clearly justified. We are keen to see the polluter pays principle implemented as a given and any deviation by policy makers explained and justified.”

Costs & Benefits

The UK Department for Environment, Food and Rural Affairs (DEFRA)’s last updated “Overall Impact Assessment” makes a brave attempt to calculate the cost to the water industry in England and Wales of both total compliance by 2015 and second option of a phased implementation, see www.defra.gov.uk/environment/water/. The former could be as high as £2 billion or as low as low as £1.1 billion, the report, with the latter in a much narrower range of £646-£686 million.

The authors of the report concede this analysis is once again “subject to considerable uncertainty”. Assessing benefits is even more complex and open to interpretation. DEFRA has helped to develop some useful definitions of what the WFD means by “good” water status (for example, varied fish population, supporting diverse and native plants and animals). But assessing the “benefit” to the public of bringing the UK’s water bodies to “good” status is a more tricky exercise. And “benefits” to the water industry, in terms of improved long-term business performance, profitability, and reputation seem even less clear. Once we move into the area of tackling climate change (which has been identified by the Environment Agency as part of the planning cycle for the WFD), any meaningful cost-benefit analysis becomes almost impossible, with no “price” (so far) for carbon in an ever-changing legislative framework.

Conclusion

While we may never satisfactorily assess the benefits of compliance with the WFD, we do know for certain that at some point there will be a large bill heading toward the water industry. The current river basin planning process will be focusing top minds in the industry on making compliance as costeffective as possible and searching for the best solutions on the market.