The EU water framework Directive, agreed in 2000, requires all waters to meet good ecological status by 2015. It will also consolidate much of the community's existing water legislation including the 1976 Directive on dangerous substances, which sets limits on discharges of pollutants like pesticides, metals and persistent organic compounds.
Article 16 of the 2000 Directive recognises "priority substances" and "priority hazardous substances" (PHSs). It requires a progressive reduction of discharges, emissions and losses of priority substances and, for PHSs, a "cessation or phasing out of discharges, emissions and losses" by 2020.
Some 33 candidate substances have been identified. In 2001, 11 were regarded as PHSs and another 8 as priority substances. The remaining 11 are still under review (ENDS Reports 312, pp 46-47 and 317, pp 37-38 ).
At a July meeting on the water framework Directive hosted by New Civil Engineer magazine, Yorkshire Water said it feared the priority substances regime would prove to be "the largest investment driver the industry has ever seen".
The company's head of environment, health and safety, Tony Harrington said the company believed the requirements could cost £880 million over 25 years. The figures were produced by a study commissioned from consultants AEA Technology.1Reductions or elimination of discharges of hazardous substances will be achieved by controls on products, treatment at the point of use and end-of-pipe treatment. The study examined the economic and environmental costs of applying additional treatment at sewage works - such as sand or granular activated carbon filtration, ozone and ultra-violet irradiation.
AEAT worked out the costs of extra treatment at 48 Yorkshire Water sewage works to reduce levels of priority substances and PHSs. Although these comprise only a small fraction of the company's 624 works, they represent all those with dangerous substances limits in their discharge consents.
The capital costs of building new treatment plant was estimated at £625 million, with annual operating costs of £39 million - amounting to £880 million when discounted over 25 years.
Extrapolating this cost to the whole of England and Wales on the basis of population, the report puts the total bill in the region of £10 billion. A study being conducted by UK Water Industry Research has independently come up with a similar figure - £12 billion - the study says.
Additional treatment technologies could remove 73 tonnes of dangerous substances present in discharges from the 48 sites, the report concludes. This would amount to 71% removal - well short of total cessation that the Directive requires for PHSs.
Additional annual environmental costs would include the use of 335,000 megawatt-hours of electricity, 420,000 kilometres of lorry journeys to transport sludge and an additional 4,700 tonnes per annum of sludge.
Mr Harrington told the conference: "If the Directive is applied badly it could do seriously more harm than good - and cost our economy into the bargain. It is not possible for us to invest in two years or build everything that is needed - not even in five years."
The report echoes concerns raised by the Environment Department (DEFRA) in 2002. A regulatory impact assessment concluded that the cost to industry would be £4 billion and threaten several industrial sectors (ENDS Report 324, p 43 ). DEFRA noted that "without a practical and workable approach...the costs could be much higher."
Industry association Water UK has also raised concerns about the Directive's hazardous substances provisions with consultants working for the European Commission.
Steve Ntifo, policy advisor at Water UK, said that the best way to control these substances was upstream of sewers, including removal from products or processes or by treatment at source. "But if that doesn't happen we are looking at a bill of £6 billion for England and Wales, based on research by UK Water Industry Research," he reflected.
A further issue is that to achieve good ecological status under the Directive, waters must not exceed environmental quality standards (EQSs) for priority substances. EQS levels will be set by a new methodology and are likely to be stricter than those currently in use in the UK.
Some substances are likely to be particularly problematic. A study for DEFRA last year concluded that the cost implications of an EQS for polyaromatic hydrocarbons (PAHs) alone could cost "billions of pounds".2 For the key pollutant benzo-a-pyrene, some sites would fail a more stringent EQS by a factor of ten.