The European Irrigation Association (EIA) , which represents all professionals involved with the irrigation industry from the Agriculture, Golf and Turf sectors, fully supports the original multiple objectives of the European Commission for developing a harmonised regulatory framework for water reuse for irrigation at EU level. The EIA also supports that such regulatory framework is set in the legal format of Regulation which stipulates standardized approach to planning, implementation and validation of water reuse projects on equal terms in all Member States.
As contribution to the public consultation launched by the European Commission, the EIA wishes to point out a few observations on provisions set in the Regulation, where minimum requirements for reference values in reclaimed water as presented in Annex 1 to the Regulation present the major concern.
1. The supporting documents to the Regulation proposal, including a Science for Policy report (JRC 2017: Minimum quality requirements for water reuse in agricultural irrigation and aquifer recharge) and earlier Public Consultation Reports, identify public acceptance to be the key barrier for increase in waste water reuse for irrigation. Consequently, it can be observed that the Regulation proposal primarily aims at alleviating public health concerns by imposing stringent quality requirements for irrigation of food crops and mandatory provisions on risk management procedures.
While such focus is partly understandable, it should be noted that the same research shows highest rate of acceptance for the use of reclaimed water for irrigation of urban green spaces. Yet the Regulation proposal leaves this sector, as well as water reuse for irrigation of non-food crops, golf courses and sports turf areas, without any appropriate regulatory framework. Subordinating this type of projects to stern provisions of the Regulation in effect will leave this type of projects to arbitrary level of local requirements in terms of approval and compliance check procedures. Instead of its original intention to facilitate uptake in waste water reuse practice, the Regulation proposal itself - if adopted as such - will thus become a sort of a barrier, even for projects with inherently higher public acceptance.
2. We share the concerns of many stakeholders in countries with existing regulations that the Regulation proposal, based on such stringent water quality demands, will be difficult to enforce and will inevitably impose significant additional costs on existing and future systems.
Definition of only four water reuse categories and explicit prescription of high disinfection standards in this context is in effect more a “one-size-fits-all” approach than the intended “fit-for-purpose” approach.
