WATER GLOBAL PRACTICE Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? A wastewater management assessment based on the World Bank’s engagement DECEMBER 2018 About the Water Global Practice Launched in 2014, the World Bank Group’s Water Global Practice brings together financing, knowledge, and implementation in one platform. By combining the Bank’s global knowledge with country investments, this model generates more firepower for transformational solutions to help countries grow sustainably. Please visit us at www.worldbank.org/water or follow us on Twitter at @WorldBankWater. Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? A wastewater management assessment based on the World Bank’s engagement DECEMBER 2018 © 2018 International Bank for Reconstruction and Development / The World Bank 1818 H Street NW, Washington, DC 20433 Telephone: 202-473-1000; Internet: www.worldbank.org This work is a product of the staff of The World Bank with external contributions. The findings, interpretations, and conclusions expressed in this work do not necessarily reflect the views of The World Bank, its Board of Executive Directors, or the governments they represent. The World Bank does not guarantee the accuracy of the data included in this work. The boundaries, colors, denominations, and other information shown on any map in this work do not imply any judgment on the part of The World Bank concerning the legal status of any territory or the endorsement or acceptance of such boundaries. Rights and Permissions The material in this work is subject to copyright. Because The World Bank encourages dissemination of its knowledge, this work may be reproduced, in whole or in part, for noncommercial purposes as long as full attribution to this work is given. Please cite the work as follows: World Bank. 2018. “Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region?: A wastewater management assessment based on the World Bank’s engagement.” World Bank, Washington, DC. Any queries on rights and licenses, including subsidiary rights, should be addressed to World Bank Publications, The World Bank Group, 1818 H Street NW, Washington, DC 20433, USA; fax: 202-522-2625; e-mail: pubrights​@­worldbank.org. Cover photo: Hrvoje Dobrović Cover design: Jean Franz, Franz and Company, Inc. Contents Acknowledgments vii Executive Summary ix Abbreviations xv Chapter 1  Introduction 1 Notes 2 Chapter 2 Status Overview of EU Wastewater Policies Compliance in the Danube Region 3 Chapter 3 Key Questions Regarding Implementation of EU Wastewater Policies 9 3.1. Is the Region Achieving European Union (EU) Wastewater Policy Objectives? 9 3.2. Do Countries have the Financial Capacity to Achieve and Maintain EU-Compliant Wastewater Management? 16 3.3. Do Countries have the Technical and Institutional Capacity to Achieve and Maintain EU Compliant Wastewater Management? 22 3.4. Is EU Compliant Wastewater Management Affordable for the Utility Companies and the People of the Region? 25 3.5. Is EU Compliant Wastewater Management Implemented in an Economically Efficient Manner? 32 Notes 35 Chapter 4  Recommendations 37 4.1. Implementation of the Directive 37 4.2. Candidate Countries 39 4.3. Potential Review of Directive 40 Chapter 5  Conclusions 43 References 45 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? iii Boxes 1.1. EU Wastewater Management Policies 1 2.1. Black Sea Eutrophication Status 3 2.2. World Bank Support to Bulgaria in Planning to Achieve UWWTD Compliance 7 3.1. Romania Has Exceeded the EU-Wide Goal Concerning Water Bodies, but Has Very Low UWWTD Compliance 14 3.2. Investment Levels in the Water Supply and Sewerage Sector in Albania 21 3.3. Sustainability of O&M Costs of WWTPs in Bosnia and Herzegovina 29 Figures 2.1. Share of Collected Load between Treatment Levels for EU-28 Member States and Danube River Basin Member States, 2014 5 2.2. Average Compliance Rates with Articles 3, 4, and 5 of the Urban Waste Water treatment Directive in Relation to Total Subjected Wastewater Load for EU-28 and Danube River Basin Member States, 2014 6 3.1. BOD5, COD, Ntot, and Ptot Emissions from Agglomerations Greater or Equal to 2,000 Population Equivalent in Danube Region, 2005–06 and 2011–12 10 3.2. BOD5 and COD Emission Rates of Danube River Basin Member States, 2005–14 10 3.3. Nitrogen and Phosphorus Emissions of Danube River Basin Member States, 2005–14 11 3.4. Contribution of Discharged Loads from Agglomerations ≥ 2,000 Population Equivalent to Water Quality in Danube River, 2005–06 and 2011–12 12 3.5. Mean Annual BOD5 and COD Concentrations for Danube River Basin Member States, 1987–2013 13 3.6. Mean Annual Concentrations of Ntot and Ptot for Danube River Basin Member States, 1992–2013 13 B3.1.1. EU Legal Noncompliance under UWWTD Articles 3, 4, and 5 14 B3.1.2. Ecological Status and Proportion of Rivers Affected by Hydromorphological Alterations and Diffuse Pollution in EU Member States 16 3.7. Share of Pressures and Impacts to Surface Water Bodies in Danube River Basin Member States 17 3.8. Future Demand for Capital and Per Capita Investments to 2040 in Danube River Basin Member States, 2015 19 3.9. Financing Sources for Water Supply and Sanitation in Danube River Basin Countries 26 3.10. Tariffs of Wastewater Collection and Treatment in Danube River Basin Member States 26 3.11. O&M Costs of Wastewater Collection and Treatment in Danube River Basin Member States 27 3.12. Estimated Long-Term Evolution of TCR Ratios in Danube River Basin Member States, SOP Scenario, 2015–40 28 iv Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 3.13. Wastewater Treatment Coverage in Danube Region, 2012 31 3.14. Affordability of Water and Wastewater Tariffs for Income Groups in Selected Countries of Danube Region 32 3.15. UWWTD Related Costs and Benefits Discounted (2015) in Danube River Basin Member States, 2000–40 34 Map 2.1. Level of Wastewater Treatment of Agglomerations ≥ 2,000 Population Equivalent in the Danube River Basin for 2011–12 5 Tables 2.1. Implementation of the Urban Waste Water Treatment Directive (UWWWTD) in Danube River Basin Member States 7 3.1. Point and Diffuse Nutrient Emissions in the Danube Basin Based on Pathways, 2009–12 17 3.2. Calculated Total Investment Costs Needed for Initial Full UWWTD Compliance among Danube River Basin Member States 18 3.3. Estimated Reinvestment Needs for Sustained Compliance with UWWTD among Danube River Basin Member States, 2015–40 19 3.4. Past UWWTD Compliance Investment among Danube River Basin Member States, before 2015 20 3.5. EU Funds Used to Co-Finance Investments in Wastewater Infrastructure in Danube River Basin Member States, 2000–20 20 B3.2.1. Wastewater Investment Needs in Albania, 2012–40 21 3.6. EU Fund Disbursement in Danube River Basin Member States, 2007–15 23 3.7. Estimated Changes in Affordability Ratio of Wastewater Tariffs for the B40 in Danube River Basin Member States, SOP scenario, 2015–40 30 3.8. UWWTD Related Discounted Costs and Benefits (2015) per Danube River Basin Member States, 2000–40 34 3.9. Economic Indicators among Danube River Basin Member States toward Implementation of UWWTD, 2000–40 35 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? v Acknowledgments This report was prepared by a team of World Bank staff and consultants led by Stjepan Gabric and comprising Elvira Cusiqoyllor Broeks Motta, Maria Salvetti, and Patricia Lopez. Supporting data and analysis were prepared by the Umweltbundesamt consultant team, led by Alexander Zinke and Katharina Lenz, and results presented in the study and annex titled “Wastewater Management in the Danube Region: Opportunities of EU Accession” (Umweltbundesamt et al. 2017). The report was edited by Alexandra Soininen. The authors welcome comments and can be contacted through Stjepan Gabric.1 The team would like to thank, in particular, team assistants Carolina A. Delgadillo and Ntombie Z. Siwale; study peer reviewers Ivaylo Hristov Kolev, Thierry Davy, Mike Webster, and Andreas Rhode; and Philippe Marin, Philip Weller, Katherine Schilling, Richard Damania, Genevieve Connors, Adam Kovacs, Klara Toth, Benoît Fribourg-Blanc, Philippe Bergeron, Nele Frederike Rosenstock, Michael Sponar, and many other individuals and institutions for their helpful support, comments, and feedback throughout the conception and realization of this study. This report is a product of the World Bank under the Danube Water Program2 financed by the Austrian government, whose contribution is gratefully acknowledged. Notes 1. Stjepan Gabric can be contacted at sgabric@worldbank.org. 2. See the Danube Water Program’s website: www.danube-water-program.org. Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? vii Executive Summary This note takes stock of the World Bank experience with wastewater management changes under the European Union (EU) water policies in the Danube River Basin (DRB) since the early 1990s, considering environmental, economic, sustainability, and affordability aspects. This review highlights the significant challenges that the EU member and candidate coun- tries face during their alignment with the Urban Wastewater Treatment Directive (UWWTD) and underlines the opportunities that lie ahead to optimize the implementation of the Directive. The review focuses on seven new member states: Bulgaria, Croatia, the Czech Republic, Hungary, Romania, the Slovak Republic, and Slovenia, and includes Austria as an older ­member state mostly for comparative purposes. It is complemented by a more detailed underlying study conducted by Umweltbundesamt et al. (2017).1 While this review is limited in scope and resources, one of its intention is to spur a debate and further research and discussion—building on the World Bank’s regional experience—and to identify issues worthy of further attention and more in-depth analysis. To do so, the fol- lowing key questions are explored: • What are the main issues related to wastewater management in the Danube region? The region faces a different reality than many old EU member states. After the collapse of socialist regimes in Eastern Europe, market forces had a dramatic impact on socioeco- nomic trends in the Danube region. Overall population is decreasing in most countries, in particular in rural areas. Industrial activities have been significantly reduced, and the intensively cultivated agriculture area drastically cut, all of which have contributed to sig- nificantly lower pollution load and reduced pressure on water quality. Further, the overall level of economic development is far behind that of older EU member states, leaving a more limited disposable income at household and national levels. Those conditions mean that the Danube region faces a wastewater management and environmental situation that is significantly different from that of some of the older EU member states that initially drove the design of the UWWTD. At the fall of communism, countries of the Danube region faced unequal levels of wastewater collection and treatment, and wastewater management took second stage given the economic and political transformation of the early 1990s. The wastewater agenda became ­ a priority again during the EU accession and membership phase given its significance in the EU environmental acquis, leading to mobilization of very large financial resources (primarily from EU funds) in the largest ever investment cycle in wastewater infrastruc- ture that the Danube region has ever seen. The main environmental problem in the DRB consists of a serious eutrophication of the Black Sea that largely derives from the severe industrial, urban, and intensive agriculture pollu- tion in the Danube watershed during the socialist era. The poor state of water in the Black Sea led the countries, under the auspices of the International Commission for the Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? ix Protection of the Danube River (ICPDR), to classify most of the DRB as a sensitive area in 2007, triggering requirements for more stringent wastewater treatment under the UWWTD Article 5. • Is the region achieving EU wastewater policies’ objectives? As a result of wastewater management efforts over the past 15 years, all countries of the DRB have witnessed major improvements in levels of wastewater treatment but falls behind implementation schedule. Since EU expansion in Eastern Europe in 2004, the share of wastewater treated according to the UWWTD requirements among the DRB’s new EU member states continues to rise, and is now reaching 79 percent, with significant varia- tions between countries. Although this evolution shows that a major improvement has been achieved, the new EU member states from the DRB are still lagging behind the EU-28 average when it comes to UWWTD requirement fulfillment, and almost all new EU mem- ber states of the region are facing major delays in meeting UWWTD requirements. The time allocated to new EU member states for transitioning toward UWWTD compliance was almost universally underestimated by national governments during negotiations, leading to noncompliance within the negotiated time frame, and triggering potential infringement procedures. The continuous improvement of surface water quality in the Danube region can be only partly attributed to the implementation of EU wastewater policies. The surface water quality of the Danube river has noticeably improved over the last 20 years for both organic pollutants and nutrients. However, this improvement is only partially derived from UWWTD imple- mentation. UWWTD is not the only policy instrument that helps improvement of surface water quality; others, such as the Nitrates Directive and the recent Industrial Emission Directive, have also contributed. The application of source apportionment revealed that, as expected, UWWTD agglomerations are responsible for only part of the total nitrogen and phosphorus emissions into the DRB. Major decreases in industrial activity, reductions in the use of mineral fertilizers, closures of large livestock farms (significant point sources of agricultural pollution) in the early 1990s—and the general depopulation in the region since the 1990s—have significantly contributed to improved surface water quality. • Do the countries have the financial capacity to achieve and maintain EU compliant wastewa- ter management? A total of €42.5 billion has been invested by the seven new EU member states of the Danube region, plus Austria, to implement the UWWTD. An additional €57 billion will be needed to reach and maintain full compliance until 2040, out of which €17 billion would fund new investment in noncompliant agglomerations above the 2,000 population equivalent (PE), and €40 billion would fund reinvestment needs for older infrastructure renewal from 2015 to 2040. This means that even after UWWTD compliance is achieved, new ­ infrastructure renewal and reinvestment are expected, requiring a very significant invest- ment for full, longer term UWWTD compliance. Given the size of the needed investments, x Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? even if a significant portion of wastewater infrastructure investment were continued to be financed through EU funds, all new EU member states would have to mobilize significant additional funds, either from taxes or tariffs, in the next few decades to bridge the invest- ment gap and remain compliant with the UWWTD. • Do the countries have the technical and institutional capacity to achieve and maintain EU compliant wastewater management? Technical and institutional capacity enhancement is crucial for successful wastewater project implementation. One of the main bottlenecks for UWWTD implementation has been the lack of institutional capacity of the implementing utilities, given the size and complexity of investment projects. The tendering process has also proved difficult and challenging and has generated important delays. A lack of established mechanisms to fund equity contributions for the project beneficiaries presents a serious barrier in some countries. Slow responsiveness, lack of knowledge and of information exchange, and transfer between different levels of governance and responsibility have had negative impacts on project identification and have significantly slowed investment preparation and imple- mentation. Local construction markets have not been able to quickly respond to the sud- den, significant increases of investment levels, leading to limited competition and higher costs. The challenges faced have shown that most new EU members have not managed to conduct the necessary institutional reforms or adjustments to prepare for an exception- ally large infrastructure investment cycle, resulting in low absorption of available funds and delays in UWWTD compliance. • Is EU compliant wastewater management affordable for the utility companies and the people of the region? Total cost recovery (TCR) achievement is a challenge in most countries of the region. Operation and maintenance (O&M) costs in the Danube region are essentially financed through tariff revenues with either no or minimal subsidies provided by national or local governments. In general, with the exception of Austria, current tariffs in the studied countries are not sufficient to ensure TCR of actual wastewater services (including depreciation for future investment and reinvestment). Bringing wastewater management in compliance with EU wastewater policy brings a range of benefits, but also significantly increase O&M costs of utilities, triggering wastewater tariff increases that will continue in the future. These nec- essary long-term tariff increases to improve operational cost recovery ratio will almost certainly trigger affordability issues for the bottom 40 percent (B40) of the population. The situation will be much more challenging for EU candidate countries, who will have to increase tariffs (or taxes) much more significantly to meet EU acquis 2 despite lower levels of economic development. • Is EU compliant wastewater management implemented in an economically efficient manner? The challenges highlighted previously raise the question of economic justification of the UWWTD implementation in the Danube region. While further work is needed to reach a Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? xi more robust conclusion, assessment conducted under this study, on the basis of limited literature review and available evidence, shows no compelling self-standing economic case to support full compliance with the Directive in the Danube region. However, the UWWTD is an important environmental legislation that provides an equal level of aquatic environmental protection among EU member states, and levels the field to access the European single market. Therefore, it should not be primarily seen as a measure that yields a positive economic cost-benefit ratio by itself. This makes it all the more important to ensure that the Directive is implemented in the most economically efficient manner to maximize its cost-benefit ratio. • Recommendations For Directive implementation: Optimizing the economic efficiency of UWWTD implementa- tion could be achieved by using cost-effective analysis to prioritize investments for the most impactful projects with regard to fulfilling the objectives of the Water Framework Directive (WFD). Efforts should then gradually move toward projects with lower environmental impact using cost-benefit analysis. Using solid economic appraisals could help improve investment efficiency while maintaining environmental benefits and WFD objectives achievement. In addition, more efforts are needed to increase wastewater service provision efficiency. Adopting a regional approach—following the WFD River Basin Management Plan—to better plan and manage wastewater infrastructure could lead to economies of scale, better efficiency, and minimized costs of service provision. In addition, member states should explore possibilities to increase benefits from UWWTD implementation through the promotion of reuse and circular economy. The positive impact created by massive UWWTD-driven investments can be preserved and further enhanced only if service quality levels are sustained or improved. If system operation and reinvestment are not financially sustainable, there is a risk of decline in service quality and deterioration of quality of discharges into receiving waters. Hence the issue of UWWTD investment sustainability needs to be addressed through a clear costing of wastewater treatment plant (WWTP) projects, including lifecycle and long-term costs and funding planning. Because the financing gaps between tariff revenues and total costs of wastewater services already exist in several new member state countries, there should be an effort to strengthen the financial viability of utilities to ensure financial sustainabil- ity. Finally, affordability issues deriving from UWWTD implementation need to be tack- led. UWWTD implementation requires substantial investments, which result in an operating expense (opex) increase. This leads to tariff increases, which trigger affordabil- ity issues to be addressed through targeted subsidies for the poorest part of the population as well as provision of basic sanitation services for vulnerable and marginalized groups. For candidate countries: Most of the current and potential candidate countries are far from compliant with the UWWTD. They face significantly lower economic development levels than EU member states, further constraining their ability to fund the needed investments. xii Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? Facing such challenges and learning from the experience of the new EU member states of the Danube region, candidate countries should prepare a strategic financing plan for wastewater infrastructure compliance well in advance of accession negotiations. During the ­ accession process, they should negotiate an appropriate deadline to implement the UWWTD, taking into account the economic affordability and sustainability of this costly piece of EU environmental legislation. For the evaluation of the Directive: Achieving WFD environmental objectives in the most cost-efficient way should be the key priority of the EU’s water and wastewater policies, and this should guide the UWWTD review process. The UWWTD is a relatively simple directive, requiring only limited data and modeling and planning capacity for its implementation, in contrast, for example, to the Water Framework Directive. Therefore, member states know exactly what is excepted from them, and the progress can be easily tracked, ensuring a good level of enforcement. At the same time, this simplicity does not provide much space for policy makers and planners to adjust requirements according to the specificity of each situation, which might be significantly different from the one for which the Directive was initially designed. Giving more flexibility to member states to optimize their urban wastewater policies could offer ways to improve the economic efficiency of the UWWTD ­ implementation. For instance, alternative measures to the ones mandated in the UWWTD could be allowed if they are proven to be more cost effective in terms of reaching WFD environmental objectives while safeguarding public health. In rural areas or small settlements, just above 2,000 PE, some flexibility could be given to local utilities to adopt ­ measures such as green infrastructure or nature-based solutions3 that could be well ­ adapted to their issues, be less costly, and prove financially sustainable. Exceptions to the Directive requirements could be considered when no clear environmental or health benefit derives from the UWWTD implementation. For instance, if the economic costs of ­ a project are higher than its benefits, lower levels of wastewater treatment could be con- sidered as long as the proposed investment option is cost-effective and WFD goals are achieved. Notes 1. See Umweltbundesamt’s website: http://www.danubis.org/eng/sector-resources/technical-topics/wastewater-management​ -and-treatment/. 2. The acquis is the body of common rights and obligations that is binding on all the EU member states. 3. The International Union for Conservation of Nature defines nature-based solutions as “actions to protect, sustainably ­ manage, and restore natural or modified ecosystems [and] that address societal challenges effectively and adaptively, simul- taneously providing human well-being and biodiversity benefits.” Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? xiii Abbreviations B40 bottom 40 percent BOT build–operate–transfer BOD5 five-day biochemical oxygen demand Capex capital expense COD chemical oxygen demand DRB Danube River Basin DRBMP Danube River Basin Management Plan DWP Danube Water Program EC European Commission EEA European Environment Agency EIRR economic internal rate of return ENPV economic net present value E-PRTR European Pollutant Release and Transfer Register ERC environmental and resource costs EU European Union GoB government of Bulgaria ICPDR International Commission for the Protection of the Danube River ICR Implementation Completion and Results report IED Industrial Emission Directive (2010/75/EU) IWRM Integrated Water Resource Management MS member state Ntot total nitrogen NH4-N nitrogen content of the ammonium ion NO3-N nitrate nitrogen OCR operation cost recovery OECD Organisation for Economic Co-operation and Development O&M operations and maintenance Opex operating expense Ptot total phosphorous PE population equivalent PIU project implementation unit PO4-P phosphate phosphorous PPP purchasing power parity PWU public water utility Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? xv RBMP River Basin Management Plan SOP sustainability orientated pathway TCR total cost recovery UWWTD Urban Waste Water Treatment Directive (91/271/EC) WFD Water Framework Directive (2000/60/EC) WSS water supply and sanitation WWTP wastewater treatment plant xvi Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? Chapter 1 Introduction Wastewater management is key to ensure environmental preservation of water bodies, improve health and hygienic living conditions of populations, and support economic ­ development. As such, it generates important positive environmental and socioeconomic externalities. This note takes stock of 25 years of wastewater management under the European Union (EU) water policies (box 1.1) in the Danube River Basin (DRB), considering environmental, economic, sustainability, and affordability aspects. It builds extensively on the World Bank’s experience in wastewater management in the region,1 as well as a series of recent Bank-led analytical pieces (Umweltbundesamt 2017; World Bank 2018; World Bank and Danube Water Program 2015), and several World Bank implementation completion reports capturing the Bank’s experience on wastewater management in the EU member and candidate countries in the region. This note is also informed by a regional stakeholder work- shop on wastewater management with the International Commission for the Protection of the Danube River (ICPDR) held in Bucharest in December 2017. This note focuses on Austria, which joined the EU in 1995, and on the seven new EU mem- ber states of the DRB located in Central, Eastern, and Southeastern Europe (Bulgaria, Croatia, the Czech Republic, Hungary, Romania, the Slovak Republic, and Slovenia) that have joined the EU between 2004 and 2013 and are still implementing the Urban Wastewater Treatment Directive2 (UWWTD) in line with harmonization schedules agreed upon during the accession process. The present note incorporates lessons learned from the Bank’s experience in work- ing on this agenda with other countries in the region, in particular Albania, Bosnia and Herzegovina, the former Yugoslav Republic of Macedonia, and Montenegro. This work seeks to contribute to the ongoing European Commission (EC) UWWTD evaluation and help EU member and candidate countries that are facing or will face challenges to harmonizing their legislation with the UWWTD and implementing it in the coming years. BOX 1.1. EU Wastewater Management Policies The common drive behind EU wastewater legislation has been environmental protection, with the nature of the directives’ requirements gradually evolving from pollutant emission limits (under the Urban Waste Water Treatment Directive [UWWTD]) to overall water bodies’ quality achievement (under the Water Framework Directive [WFD]). The EU legal framework on water management is governed by the WFD, adopted in 2000, which is the main instrument for integrated water resource management (IWRM) in Europe. This Directive introduces an environmentally driven, outcome-based approach requiring member states to reach good status on all their water bodies through the implementation of River Basin Management Plans (RBMPs), box continues next page Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 1 BOX 1.1. continued thus focusing on water quality standards. To design RBMPs, the WFD introduces the use of economic appraisals, giving member states leeway to select cost-effective and cost-beneficial measures, either curative or preventive, to achieve WFD compliance. With regard to wastewater management, the WFD is complemented by the UWWTD, which seeks “to protect the environment from the adverse effects of urban waste water discharges and discharges from certain industrial sectors” by mandating wastewater collection and treatment in urban agglomerations with a population equivalent (PE) over 2,000, and more advanced treatment in places with a PE above 10,000 and in water bodies deemed sensitive. Such more advanced treatment is required to reduce nitrates and phosphorus pollution loads and hence decrease eutrophication. For the past 25 years, the UWWTD has been seen as key to achieving the objectives of the WFD, although the situation might be different in some of the DRB member states. The UWWTD requirements are considered basic measures under the WFD, and their fulfillment is obligatory but not always sufficient to comply with the WFD. Most older EU member states had to go beyond the mere UWWTD implementation to achieve the required WFD water quality improvement objectives. The Danube region faces a different starting point because of the collapse of agricultural and industrial activities and its lower economic and demographic development, which on their own have led to significant reductions in pollution. In fact, some DRB member states (box 3.1) have exceeded the EU-wide goal of 60 percent of water bodies at good or very good status despite noncompliance with the UWWTD. The UWWTD is not the only instrument that helps improvement of surface water quality, because a set of other EU environmental protection directives deals with reduction of nutrient and industrial pollution of water (e.g., the Nitrate Directive and Industrial Emission Directive). Notes 1. The full list of countries includes Albania, Austria, Bosnia and Herzegovina, Bulgaria, Croatia, the Czech Republic, Hungary, Kosovo, FYR Macedonia, Moldova, Montenegro, Romania, Serbia, the Slovak Republic, Slovenia, and Ukraine. 2. The full title is Council Directive 91/271/EEC concerning urban wastewater treatment (May 21, 1991). 2 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? Chapter 2 Status Overview of EU Wastewater Policies Compliance in the Danube Region The main environmental problem in the region is considered to be a major eutrophication of the Black Sea (box 2.1). This situation largely derives from the severe industrial and intensive agri- culture pollution during the socialist era. This period was characterized by a strong urbaniza- tion, a lack of environmental sensitivity, and the rapid development of the water supply infrastructure. Because these changes were not followed by adequate wastewater treatment provision, the receiving waters suffered major water quality deterioration. The poor state of water in the Black Sea led the countries, under the auspices of the International Commission for the Protection of the Danube River (ICPDR), to classify most of the Danube River Basin (DRB) as a sensitive area in 2007, triggering requirements for more stringent wastewater treat- ment under Urban Wastewater Treatment Directive (UWWTD) Article 5. Since then, nitrogen inputs into the Black Sea have been reduced but are still higher than what was observed during the 1960s, while current phosphate inputs appear to be roughly the same as in the 1960s. According to the Black Sea Commission, efforts to reduce discharges from 49 high priority pollution sources, pollution from insufficiently treated wastewater and airborne emissions in all the Black Sea coastal states are beginning to bear fruit, since fewer and less intense algal blooms are being recorded, and total fish catches have increased. BOX 2.1. Black Sea Eutrophication Status Serious eutrophication of the Black Sea, and in particular of its coastal waters, was the main driver for introducing a more stringent level of urban wastewater treatment in the DRB. The Black Sea is the world’s most isolated sea: it is connected to the oceans via the Mediterranean Sea through the Bosporus, Dardanelle, and Gibraltar straits. The unique ecosystem of the northwestern shelf of the Black Sea is burdened by excessive loads of nutrients and hazardous substances from coastal countries and rivers that enter it—the most important of which is the Danube, followed by the Dniester and the Dnepr. Pollution inputs and other factors have radically changed Black Sea ecosystems since 1960, and seriously threaten biodiversity and the use of the sea for fishing and recreation. In addition to nutrient pollution, other pressures on the Black Sea ecosystems include organic pesticides, heavy metals, incidental and operational spills from oil vessels and ports, overfishing, and invasions of exotic species. The ecological status of the coastal waters of the Black Sea has improved significantly since the beginning of the 1990s because of reduced nutrient inputs, which has led to reduced eutrophication and fewer algal blooms (phosphorus inputs into the Black Sea were halved compared to the levels of 1990), and recovery of aquatic life forms. However, the most significant improvements were registered in box continues next page Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 3 BOX 2.1. continued the first half of the 1990s because of reduced nutrient emissions due to economic changes and decreased agricultural and industrial activities in the region. Since then, there has been only minor improvements, indicating the predominance of diffuse pollution over point source pollution. While the environmental trends have been favorable, the Danube delta, where the river flows into the Black Sea, is still a eutrophic zone, and the challenge will be to prevent a possible reversal of the existing trend. If industrial and agricultural activities were to increase in countries from the middle and lower regions of the DRB, this could negatively affect the coastal waters of the Black Sea. All DRB countries have witnessed major improvements in wastewater treatment over the past 15 years. The DRB covers more than 800,000 square kilometers (approximately 10 percent of continental Europe) and extends through the territories of 19 countries, featuring an import- ant socioeconomic heterogeneity. From an unequal but generally low starting point in the 1990s, after political and economic changes in the region, these countries have come a long way to improve their wastewater services and quality of surface waters. Over the past 15  years, wastewater treatment levels have had great improvement (map 2.1) due to the region benefiting from very large investments, mostly financed by European Union (EU) grant funds, but also with substantive co-financing provided by individual countries. However, despite their progress and efforts, almost all new EU member states of the region face major challenges in meeting UWWTD requirements. The share of wastewater treated according to the UWWTD requirements—in terms of population equivalent (PE) treated at secondary and tertiary levels, and through individual and other appropriate systems— among observed DRB member states since membership in 2004 continues to rise. It is now reaching 79 percent, although with significant variations between countries. While this evo- lution shows a major improvement, the DRB member states still lag behind the EU-28 aver- figure 2.1, panels a and b). Compared to older EU member states, the level of UWWTD age (­ compliance is significantly lower in the Danube EU member states, indicating a significant gap for collection (Article 3), secondary treatment (Article 4), and more stringent treatment (Article 5) of wastewater (figure 2.2). However, in comparison, EU candidate countries or perspective candidate countries from the Danube region (Albania, Bosnia and Herzegovina, Kosovo, the former Yugoslav Republic of Macedonia, Montenegro, and Serbia) are even far- ther behind because urban wastewater is still mainly collected without treatment. In these countries, the overall percentage of the population connected to urban wastewater systems ranges from 35 percent to 59 percent, but most of this collected urban wastewater is not ­adequately treated. 4 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? MAP 2.1. Level of Wastewater Treatment of Agglomerations ≥ 2,000 Population Equivalent in the Danube River Basin for 2011–12 LEGEND Treatment type Collection rate ≥ 80% of the wastewater Not collected and not treated Collected but without treatment Size classes Collected in individual systems* 2,000 - 10,000 PE 10,001 - 15,000 PE Mechanical treatment 15,001 - 100,000 PE Biological treatment > 100,000 PE More stringent treatment: N-removal Danube River Basin District More stringent treatment: P-removal Danube River More stringent treatment: N and P-removal Tributaries (with catchment area > 4,000 km2) Lake water bodies (with surface area > 100 km2) Collection rate < 80% of the wastewater Transitional water bodies Collected but without treatment Coastal water bodies Collected in individual systems* Canals Mechanical treatment National borders Biological treatment 0 50 100 200 km Cities: N More stringent treatment: N-removal 100,000 - 250,000 inhabitants W E More stringent treatment: P-removal 250,000 - 1,000,000 inhabitants Scale: 1 : 4,500,000 S More stringent treatment: N and P-removal > 1,000,000 inhabitants (Scale 1: 6,000,000 * Individual or other Appropriate Systems in A4 landscape paper format) FIGURE 2.1. Share of Collected Load between Treatment Levels for EU-28 Member States and Danube River Basin Member States, 2014 a. EU-28 member states b. DRB member states 100 100 90 90 80 80 70 70 60 60 Percent Percent 50 50 40 40 30 30 20 20 10 10 0 0 h yp a l ia lg m ia De ub s nm lic Es ark Fi onia F nd rm ce Gr any un e Ire ary Ita d La ly xe ua a bo a th Ma g er lta Po nds ov R rtug d ak om al p ia ov ic ia d we in ng en m lg a ec Cr ria pu a un c ak m y pu a ov c ia p u H bli Sl bli Lu Lith tvi m ni Bu tri Re ti Re ani ov Ro gar ec C atia H eec n ur Po lan Sl ubl Be str Cr ar Re an en en ite S Spa Bu giu do Ge ran Re r Ki d a h oa a la g s la nl t Au Au o Ne Cz Cz Un Sl Sl Less than secondary Secondary treatment More stringent treatment Source: European Commission 2017. Note: DRB = Danube River Basin; EU = European Union. a. Since Croatia joined the EU in July 2013 data was not yet available. Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 5 FIGURE 2.2. Average Compliance Rates with Articles 3, 4, and 5 of the Urban Waste Water treatment Directive in Relation to Total Subjected Wastewater Load for EU-28 and Danube River Basin Member States, 2014 a. EU-28 member states b. DRB member states EU-28 EU-15 EU-13 EU-8 100 100 80 80 491 Mpe (98.6%) 558 Mpe (94.7%) 439 Mpe (90.8%) 277 Mpe (90.4%) 497 Mpe (88.7%) 309 Mpe (84.5%) 60 60 58 Mpe (75.3%) Percent 67 Mpe (73.5%) Percent 40 Mpe (73%) 45 Mpe (69%) 25 Mpe (60%) 32 Mpe (54.4%) 40 40 20 20 0 0 3 4 5 3 4 5 3 4 5 3 4 5 le le le le le le le le le le le le tic tic tic tic tic tic tic tic tic tic tic tic Ar Ar Ar Ar Ar Ar Ar Ar Ar Ar Ar Ar Source: European Commission 2017. Note: “Article 3: Member States shall ensure that all agglomerations larger than 2,000 PE are provided with collecting systems for urban wastewater. Where the establishment of a collecting system is not justified either because it would produce no environmental benefit or because it would involve excessive cost, individual systems or other appropriate systems which achieve the same level of environmental protection shall be used. Article 4: Member States shall ensure that urban waste water entering collecting systems shall before discharge be subject to secondary treatment or an equivalent treatment. Discharges from urban waste water treatment plants shall satisfy the relevant requirements provided in Annex of the directive. Article 5: Member States shall ensure that urban waste water entering collecting systems shall before discharge into sensitive areas be subject to more stringent treatment than that described in Article 4, for all discharges from agglomerations of more than 10 000 PE.” DRB = Danube River Basin; EU = European Union; MPE = Million person equivalent. The time allocated to new EU member states for transitioning toward UWWTD compliance was almost universally underestimated during negotiations, indicating unrealistic assessment of the magnitude of efforts required to achieve compliance. Deadlines for compliance with the UWWTD vary across countries: for EU-15 it was set to December 31, 2005, whereas for new member states from Central and Eastern Europe, staged transitional periods have been agreed upon within individual accession treaties. In principle, however, these transitional periods did not exceed 2015 (except for Romania, in which agglomerations with less than 10,000 PE must comply with the Directive by the end of 2018; and Croatia, which has dead- lines between 2018 and 2023). Deadlines have already expired and implementation delays toward full compliance have occurred in all five observed older regional member states (the Czech Republic, the Slovak Republic, Hungary, Slovenia, and Bulgaria) of the Danube region (Table 2.1). It should be also recognized that the original EU-15 had 14 years for compliance (the Directive was adopted in 1991 with a 2005 deadline for EU-15), while this period was 11 years for EU-13, except Romania, with 14 years maximum for less than 10,000 PE. Although pending deadlines still exist for Romania (2018) and Croatia (2023), it is doubtful that they will achieve compliance in due time because of the current annual investment and rate of UWWTD compliance. 6 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? TABLE 2.1. Implementation of the Urban Waste Water Treatment Directive (UWWWTD) in Danube River Basin Member States Final deadline Compliance status Country for UWWTD Art. 3: collecting Art. 4: secondary Art. 5: more implementation system (%) treatment (%) stringent treatment Austria 2005 0 0 0 Bulgaria 2014 15.8 36.9 87 Croatia 2023 — — — Czech Republic 2010 0 1.4 23.4 Hungary 2015 0 4.6 7.8 Romaniaa 2018 11.2 41.1 75.1 Slovak Republic 2015 0.4 1.7 39.5 Slovenia 2015 4.5 12.3 42.3 Source: 9th UWWTD Synthesis report, 2014. a. Romania has a transition period with specific rules, and the official agreed compliance presented here is not calculated as for other countries. BOX 2.2. World Bank Support to Bulgaria in Planning to Achieve UWWTD Compliance With its accession to the EU in 2007, Bulgaria made commitments to improve the quality of water supply and sanitation (WSS) services to comply with the requirements of the EU’s environmental legislation. During the last decade, however, the quality of WSS services in the country increased rather slowly, mainly because of unsustainable political commitment, overreliance on EU funding for the sector, weak enforcement of national environmental regulations, and a chronic shortage of funding due to low WSS tariffs and lack of support from the national budget. This has resulted in a highly undermaintained WSS infrastructure, with high water losses at 57.9 percent, and a low percentage of population with access to wastewater collection (75.5 percent) and wastewater treatment services (62.3 percent),a as compared to the DRB average. Consequently, despite a negotiated transition period, Bulgaria failed to meet its accession commitments: compliance with UWWTD for agglomerations over 10,000 PE expired on December 31, 2010, and on December 31, 2014, for agglomerations between 2,000 and 10,000 PE. In 2012 the government of Bulgaria (GoB) and the World Bank signed a Reimbursable Advisory Services Agreement requesting the Bank’s support for the preparation of a Strategy for Development and Management of the Water Supply and Sanitation Sector in the Republic of Bulgaria 2014–2023 (approved by Ministers Council Decision No. 269 of May 7, 2014). The strategy and the action plan for its implementation outlined the necessary reform measures, which can lead the Bulgarian WSS sector box continues next page Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 7 BOX 2.2. continued to compliance. The vision of the Bulgarian government is to develop a financially, technically, and environmentally sustainable WSS sector, which would provide quality services at affordable prices to customers, and in accordance with EU environmental legislation. This requires sustainable institutional reform and considerable infrastructure investments over the next decade and beyond. The GoB and the World Bank cooperation in the WSS sector includes support for strengthening the capacity of the Energy and Water Regulatory Commission and optimizing the cost of compliance with the UWWTD. The Bank has further assisted compliance efforts by helping Bulgaria to optimize compliance costs through the reassessment of agglomeration boundaries to improve the implementation of Directive 91/271/EEC and focus on concentration of population and pollution load rather than using administrative boundaries, as well as introducing cost-effective individual and other appropriate systems. Delays in the implementation of the sector strategy have led to a new Reimbursable Advisory Services Agreement, in which the World Bank has committed to further supporting of the GoB in the development of a financing strategy, regulatory capacity building, and the increase of service efficiency in the WSS sector. Through this Agreement, the World Bank has also helped the GoB to address the ex-ante conditionality of EU grant funding for the sector through Operational Program Environment 2014–20. Overall, the World Bank assistance to Bulgaria has resulted in the following: (a) preparation of a systematic plan to achieve compliance with UWWTD requirements within a 10-year period; (b) reassessment of agglomerations’ boundaries following the Bank guidelines in the current 15 regional feasibility studies, which will reduce the cost of UWWTD compliance; and (c) a proposal to introduce specific funding instruments to support UWWTD implementation, which will allow the GoB to bridge the identified financing gap. a. NSI data for 2015 for all presented percentage figures. 8 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? Chapter 3 Key Questions Regarding Implementation of EU Wastewater Policies Is the Region Achieving European Union (EU) Wastewater 3.1.  Policy Objectives? Short answer: The Urban Wastewater Treatment Directive (UWWTD) aims “to protect the environment from adverse effects of waste water discharges from cities and certain indus- trial sectors” while the Water Framework Directive (WFD) aims for “good status” for all ground and surface waters in the EU. The surface water quality has noticeably improved over the last 20 years for both organic pollutants and nutrients. However, this continuous improvement of water quality and pollution reduction is only partially derived from UWWTD implementation. The application of source apportionment revealed that, as expected, UWWTD agglomerations are responsible for only part of the total nitrogen and phosphorus emissions into the Danube River Basin (DRB), and that other sources of pollution are domi- nant in different countries of the Danube region. Emission control from agglomerations has led to a continuous reduction of overall emissions into water bodies. Total emission loads for BOD5, COD, Ntot, and Ptot from urban settlements in DRB countries decreased significantly between 2006 and 2012 (figure 3.1). In 2012 the total percent, emissions were 596  kilotons per year for BOD5 (a decrease of 142 kilotons, or 20  ­ kilotons per year, or if compared to 2006); 1,182 kilotons per year for COD (a decrease of 329 ­ 22 percent); 138 kilotons per year for Ntot (a decrease of 30 kilotons per year, or 18 percent); and 22 kilotons per year for Ptot (a decrease of 6.6 kilotons per year, or 24 percent). Since 2006, all DRB countries have managed to decrease their pollutant emissions, corre- sponding to improved compliance with secondary and tertiary treatment requirements, except for Austria, whose emission levels have remained constant due to reaching UWWTD full compliance by 2005. In 2014, the lowest pollution emissions indicators, such as BOD5 (below 2  kilograms per population equivalent per year [kg/PE/year]), were achieved by countries which had already achieved more than 90 percent compliance with secondary treatment (Austria, the Czech Republic, the Slovak Republic, and Hungary). Slovenia and Bulgaria, both of which show compliance rates of less than 25 percent (Article 4), reached BOD5 emission values of 5 kg/PE/year to 7 kg/PE/year, while for Romania (4 percent compli- ance rate with Article 4), BOD5 emissions were still over 10 kg/PE/year (figure 3.2, panel a). percent in all countries except the Slovak Mean annual Ntot emissions decreased by 45  ­ Republic, whereas mean annual emissions of Ptot decreased by 15 percent, to 72 percent, in figure 3.3, panels a and b). six out of seven countries investigated (­ In countries where more than 85 percent of the load in the DRB is treated by secondary treatment (Austria, the Czech Republic, the Slovak Republic, and Hungary), discharges from UWWTD agglomerations contribute only between 0.01 to 0.03 milligrams per liter (mg/l) BOD5 to BOD5 concentrations in the Danube (based on measurements taken in 2012). Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 9 FIGURE 3.1. BOD5, COD, Ntot, and P tot Emissions from Agglomerations Greater or Equal to 2,000 Population Equivalent in Danube Region, 2005–06 and 2011–12 1,511,423 1,500,000 1,182,024 1,000,000 Tons per year 737,348 595,718 500,000 167,988 138,430 28,627 22,027 0 BOD5 COD Ntot Ptot 2005–06 2011–12 Sources: DRBMP 2009; DRBMP 2015. Note: BOD5 = five-day biochemical oxygen demand; COD = chemical oxygen demand; Ntot = total nitrogen; Ptot = total phosphorous. FIGURE 3.2. BOD5 and COD Emission Rates of Danube River Basin Member States, 2005–14 a. BOD5 emissions b. COD emissions 16 30 14 25 BOD emissions (kg/PE/year) COD emissions (kg/PE/year) 12 20 10 8 15 6 10 4 5 2 0 0 2004 2006 2008 2010 2012 2014 2004 2006 2008 2010 2012 2014 Austria Bulgaria Czech Republic Hungary Romania Slovenia Slovak Republic Source: Umweltbundesamt et al. 2017. Note: BOD5 = five-day biochemical oxygen demand; COD = chemical oxygen demand; PE = population equivalent. 10 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? FIGURE 3.3. Nitrogen and Phosphorus Emissions of Danube River Basin Member States, 2005–14 a. Nitrogen emissions b. Phosphorus emissions 3,500 450 400 3,000 Phophorus emissions (g/p.e./year) Nitrogen emissions (g/p.e./year) 350 2,500 300 2,000 250 1,500 200 150 1,000 100 500 50 0 0 2004 2006 2008 2010 2012 2014 2004 2006 2008 2010 2012 2014 Austria Bulgaria Czech Republic Hungary Romania Slovenia Slovak Republic Source: Umweltbundesamt et al. 2017. Note: DRB = Danube River Basin; PE = population equivalent. For Slovenia and Bulgaria, where 60 percent to 70 percent of the Danube River Basin’s load is treated by secondary treatment, the contribution amounts to 0.04  mg/l (Slovenia) to 0.2 mg/l BOD5 (Bulgaria). In Croatia and Romania, where around 45 percent of the load in the Danube River Basin is treated by secondary treatment, the BOD5 contribution amounts to 0.2 mg/l (Croatia) and 1.2 mg/l (Romania).1 The surface water quality of the Danube region has noticeably improved over the last 20 years for both organic pollutants (BOD5, COD) and nutrients (Ntot, NH4-N, NO3-N, Ptot, PO4-P). In most countries investigated, mean annual concentrations in surface waters (calculated as the aver- age of the annual concentration) have decreased over time. As an example, mean annual BOD5 concentrations dropped by 22 percent to 70 percent in five out of seven countries investigated. NH4-N concentrations in 26 monitoring stations along the Danube also decreased over time. The highest decreases are observable in the new EU member states that joined in 2004, 2008, and 2013. Germany and Austria fully implemented the UWWTD by 2005 and have therefore recorded only slight decreases since then. An increase for non-EU member states is also observable and is probably due to the construction of sewer sys- tems without fully operational wastewater treatment plants, resulting in an increased transfer of wastewater discharge from soil to surface water. In Bulgaria, the increase could be due to improved data quality for the reference year 2012 (figure 3.4, ­panels a and b). The continuous improvement of water quality and pollution reduction is only partially derived from UWWTD implementation. Indeed, the significant pollutant decrease has actually happened before the decrease in pollution load discharge following EU Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 11 FIGURE 3.4. Contribution of Discharged Loads from Agglomerations ≥ 2,000 Population Equivalent to Water Quality in Danube River, 2005–06 and 2011–12 a. BOD5 discharged loads 1.71 Contribution to the concentration 1.80 1.60 in the Danube river (mg/I) 1.40 1.16 1.20 1.00 0.72 0.80 0.45 0.60 0.32 0.20 0.22 0.21 0.19 0.18 0.16 0.40 0.15 0.08 0.12 0.06 0.04 0.05 0.03 0.03 0.03 0.03 0.02 0.02 0.02 0.02 0.01 0.01 0.20 0 ia ia er sn ia vi d ia ro ia va e ria y ic ic ry in go an ar an en t rb an bl bl eg ga do st oa na ra lg Se rm pu pu m ov ze ia Au n un ol Cr Uk Bu te Ro Re Re Ge Sl M H on H Bo h ak M ec ov Cz Sl b. Ntot discharged loads Contribution to the concentration 0.32 0.35 in the Danube river (mg/I) 0.30 0.22 0.25 0.20 0.15 0.11 0.07 0.07 0.06 0.06 0.10 0.05 0.05 0.04 0.04 0.04 0.04 0.03 0.03 0.03 0.03 0.03 0.02 0.02 0.001 0.01 0.01 0.01 0.01 0.01 0.01 0.05 0 ria ic ia o ia va e y ic ry tia ia ia vi d gr in an bl en an bl rb ar go an ga do st oa ra ne pu na rm pu lg m ov Se Au un ol Uk ze ia Cr te Bu Ro Re Re Sl Ge er sn M H on H Bo h ak M ec ov Cz Sl 2005–06 2011–12 Source: Umweltbundesamt et al. 2017. Note: BOD5 = biochemical oxygen demand; Ntot = total nitrogen. membership, because of economic decline in the 1990s (figure 3.5, panels a and b, and figure 3.6, panels a and b). Thus, the quantification of the influence of improved waste- water treatment on enhanced water quality is, indeed, difficult to assess, because waste- water from agglomerations is only partly responsible for the pollution of the aquatic environment. Major decrease in industrial activity, reductions in the use of mineral fer- tilizers, closures of large livestock farms (significant point sources of agricultural pollu- tion), and general depopulation in the region since the 1990s have all significantly contributed to improved surface water quality. The application of source apportionment reveals that UWWTD agglomerations are responsible for only one part of the total nitrogen and total phosphorus emissions into the DRB, and that other sources of pollution are dominant throughout the Danube region. As defined under the UWWTD, 12 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? FIGURE 3.5. Mean Annual BOD5 and COD Concentrations for Danube River Basin Member States, 1987–2013 a. Mean annual BOD5 concentration b. Mean annual COD concentration 12 40 35 10 30 8 25 mg/I BOD5 mg/I COD 6 20 15 4 10 2 5 0 0 87 89 91 93 95 97 99 01 03 05 07 09 11 87 89 91 93 95 97 99 01 03 05 07 09 11 20 20 19 19 20 20 19 19 19 19 19 19 19 19 20 20 20 20 20 20 19 19 19 19 20 20 Austria (18 stations) Romania (85 stations) Austria (25 stations) Romania (74 stations) Czech Republic (61 stations) SIovenia (6 stations) Czech Republic (73 stations) SIovenia (24 stations) Croatia (4 stations) Slovak Republic (9 stations) Croatia (16 stations) Slovak Republic Hungary (31 stations) Hungary (150 stations) (75 stations) Source: Umweltbundesamt et al. 2017. Note: BOD5 = biochemical oxygen demand; COD = chemical oxygen demand; stations = measuring stations where water samples are taken and analyzed. FIGURE 3.6. Mean Annual Concentrations of Ntot and P tot for Danube River Basin Member States, 1992–2013 a. Ntot concentrations b. Ptot concentrations 7 0.8 6 0.7 5 0.6 0.5 mg/I Ntot mg/I Ptot 4 0.4 3 0.3 2 0.2 1 0.1 0 0 2 4 96 98 00 02 04 06 08 10 12 87 89 91 93 95 97 99 01 03 05 07 09 11 9 9 20 20 19 20 20 19 19 19 19 19 20 20 20 20 19 19 19 19 19 20 20 20 20 20 Czech Republic (24 stations) Romania (56 stations) Austria (20 stations) Romania (99 stations) Croatia (4 stations) Slovak Republic Czech Republic (45 stations) Slovenia (5 stations) (6 stations) Croatia (35 stations) Slovak Republic Hungary (19 stations) (6 stations) Source: Umweltbundesamt et al. 2017. Note: Ntot = total nitrogen; Ptot = total phosphorous. emissions from agglomerations cover the emissions from combined sewer overflows, uncon- nected population, urban wastewater treatment plants (WWTPs), and the population con- nected to sewer systems without treatment plants. For Ntot, the pathways’ “urban runoff”’ and “point sources” amount to only 26 percent of the total nitrogen emissions into the DRB, which means that urban wastewater from agglomerations under the  UWWTD is only partly Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 13 responsible for nitrogen loads in the surface waters of the DRB. For Ptot the pathways ‘“urban runoff”’ and “point sources” amount to 51 percent of the total phosphorus emissions into the DRB, which suggests that measures addressing urban waste management have a potential for reducing those emissions (e.g., by reducing Ptot concentrations in detergents and removal of Ptot in wastewater treatment plants) (table 3.1). The ecological status of surface water bodies in the eight EU member states of the Danube region show that 27 percent of surface water bodies are affected by pollution pressure, with diffuse sources being the most important (20 percent). Nutrient enrichment causing eutro- phication is the most important impact, affecting around 20 percent of the surface water bodies in the countries investigated (figure 3.7). BOX 3.1. Romania Has Exceeded the EU-Wide Goal Concerning Water Bodies, but Has Very Low UWWTD Compliance Romania is the worst UWWTD performer among all EU countries. Its rate of legal compliance at agglomerations level was of only 2.6 percent for Article 3; 3.8 percent for Article 4; and 0.9 percent for Article 5 (figure B3.1.1, panels a–c), and its compliance gap remains quite large: 11 percent for Article 3; 41 percent for Article 4; and 75 percent for Article 5 (i.e., the percentage expresses the percentage of load that has still to be addressed adequately). However, despite this noncompliance situation with regard to UWWTD, Romania has already exceeded the WFD EU-wide goal of 60 percent of good and very good ecological status of water bodies. With two thirds of surface water bodies already achieving good or very good ecological status as of 2016, Romania compares very well within the EU-15. Moreover, it stands out for being the only EU country in which FIGURE B3.1.1. EU Legal Noncompliance under UWWTD Articles 3, 4, and 5 a. Article 3 100 90 80 70 60 Percent 50 40 30 20 10 0 ria st rm ce un e xe ua a bo a ak erl lta d we ic ng en rt m Sp m Es ain a ov s lg ia m a ia nm ic Fi ark Gr ny Ire ary Sl Net M rg p ds Po taly EU 8 lg l EU 15 3 F nd La nd Cy nd Sl pru Be ga Lu Lith tvi m ni ni Ro ari H eec -2 ite S ubl -1 Bu en an De ubl Au Po do iu Ge ran u Re an Ki d a - ov h a to g a la la u EU I nl p Re h ec Cz Un figure and box continues next page 14 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? BOX 3.1. continued FIGURE B3.1.1. continued b. Article 4 100 90 80 70 60 Percent 50 40 30 20 10 0 en o ia L ria Ne th ia er ia xe rm k ak ng e p m F ium Po nia rt in m ia M ia ta ed lg ic Cy nce Ire aly nm s bo y g pu y Es blic S s EU 8 3 ec u nd Fr nd It l l d EU 15 Lu e ar ov Ki ec De and u a m an Re ar -1 Sl gar ur Li atv th uan Ro ven an -2 Be ubl Po pa Re do Bu lan al ug st pr - Sw to Cz H inla la h ng Sl d re a EU Au l ite G G Un c. Article 5 100 90 80 70 60 Percent 50 40 30 20 10 0 er ria th ce L ia nm ia e Cy nia rt in ta rm ds Gr ny Fr ark d ng n Be dom Fi ium Po rus ak ep ly p ic ov ic xe ela a bo d Bu urg m ia M ia ng ry EU 28 3 Es and nd al EU 15 Sw nc Lu Ir eni ite Hu ede m n -1 n De atv Po Spa Re bl Sl ubl Ro gar an al ov R Ita Li ee Ki a ug Ge lan th st a - - ua to la p a u EU lg nl Ne Au l Sl ch e Cz Un Source: World Bank 2018. Note: EU = European Union; UWWTD = Urban Wastewater Treatment Directive. the entire territory is reported above 50 percent good ecological status compliance, and less than 30 percent is affected by hydromorphological alterations (figure B3.1.2). While this is largely due to the significant rural population and scarcely populated characteristics of its territory, with little anthropogenic pressures, it still indicates a disconnection between WFD and UWWTD objectives in Romania, and somehow a lack of adaptability of the UWWTD implementation to the specifics of local situations. Romania’s case requires additional analysis to fully understand the links between pollution reduction and water status. box continues next page Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 15 BOX 3.1. continued FIGURE B3.1.2. Ecological Status and Proportion of Rivers Affected by Hydromorphological Alterations and Diffuse Pollution in EU Member States a. Ecological status b. Hydromorphological alterations and di use pollution Estonia Estonia Slovak Republic Slovak Republic Romania Romania Spain Spain Latvia Latvia Portugal Portugal Slovenia Slovenia Finland Finland Sweden Sweden Ireland Ireland Italy Italy Denmark Denmark Greece Greece Bulgaria Bulgaria EU EU France France Cyprus Cyprus Austria Austria Lithuania Lithuania United Kingdom United Kingdom Czech Republic Czech Republic Hungary Hungary Poland Poland Germany Germany Luxembourg Luxembourg Netherlands Netherlands Belgium Belgium 0 20 40 60 80 100 0 20 40 60 80 100 Percentage of water bodies Percentage of water bodies Bad Poor Moderate Hydromorphology Good High Di use sources Source: EEA 2012. Note: EU = European Union. Do Countries have the Financial Capacity to Achieve and Maintain 3.2.  EU-Compliant Wastewater Management? Short answer: A total of €42.5 billion has already been invested to implement the UWWTD. However, despite this important investment effort, an additional €57 billion is still needed to reach and maintain full UWWTD compliance until 2040. To fund new investment in non- equipped agglomerations above 2,000 PE, €17 billion is needed, and a further €40 billion to fund reinvestment for older infrastructure renewal from 2015 to 2040. This means that even after UWWTD compliance is achieved, new infrastructure renewal and reinvestment are expected to require a very significant funding to maintain full UWWTD compliance in the Danube region in the longer term, but in a period when EU funding could be expected to decrease. The necessary 16 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? TABLE 3.1. Point and Diffuse Nutrient Emissions in the Danube Basin Based on Pathways, 2009–12 Ntot Ptot Pathway Total tons per year % Total tons per year % Direct atmospheric deposition 12,309 2 301 0.8 Overland flow 49,678 8 602 1.6 Soil erosion 16,665 3 12,169 32 Tile drainage flow 43,694 7 253 0.7 Groundwater flowa 325,091 54 5,472 14 Urban runoffb 62,226 10 7,129 18 Point sourcesc 95,404 16 12,627 33 Total 605,067 100 38,553 100 Source: ICPDR 2015. Note: Ntot = total nitrogen; Ptot = total phosphorous. a. Summed emissions via all subsurface flow components (base flow and interflow). b. Summed emissions via urban runoff, combined sewer overflows and not connected population. c. Summed emissions from urban wastewater treatment plants, population connected to sewer systems without treatment plant and emissions from industrial direct dischargers. FIGURE 3.7. Share of Pressures and Impacts to Surface Water Bodies in Danube River Basin Member States a. Pressures b. Impacts No pressure No impacts Point sources Organic enrichment Di use sources Nutrient enrichment Contamination Water abstraction Acidi cation Hydromorphology Altered habitats Other pressures Other impacts 0 10 20 30 40 50 60 0 10 20 30 40 50 60 Percentage of surface water bodies Percentage of surface water bodies Source: Umweltbundesamt et al. 2017. Note: The eight countries investigated are Austria, Bulgaria, the Czech Republic, Croatia, Hungary, Romania, Slovenia, and Slovak Republic. The total reflects rivers, lakes, transitional waters, and coastal waters. level of investment—an estimated €2.6 billion per year—would represent a 30 percent increase compared to the past level of investment, and a total of 0.2 percent of gross domestic product (GDP), is still below the level recommended by the Organization for Economic Co-operation and Development (OECD). This change would entail significant increases in either taxes, which might be delicate given the region’s fiscal situation, or tariffs, which might be politically or socially delicate. The reality might be even more difficult in regional EU candidate countries that are starting from an even lower base and have lower GDP per capita. Given the wastewater management starting point in most of the EU member states of the region, a total of €42.5 billion has already been invested to implement the UWWTD. Three- quarters of this amount was spent on sewer networks and the rest on wastewater treat- ment plants in the eight countries (table 3.2). Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 17 However, despite this important investment effort, an additional €57 billion is still needed to reach and maintain full UWWTD compliance (Umweltbundesamt et al. 2017). An addi- tional €17 billion is still needed to fund new investment in non-equipped agglomerations above 2,000 PE (two-thirds for sewers and the rest for wastewater treatment plants). Moreover, to maintain full UWWTD compliance, €40 billion of reinvestment needs for older infrastructure renewal are required from 2015 to 2040 (table 3.3). This means that even after UWWTD compliance is achieved, new infrastructure renewal and reinvestment is expected to require twice as much funding as the initial investment needed for full compliance in the Danube region (figure 3.8, panels a and b). As a whole, the total future capital expense (capex) demand is roughly estimated at €57 billion for continu- ous UWWTD compliance up to 2040, which is 30 percent higher than what the DRB member states have spent so far on UWWTD implementation (table 3.4). The overall investment gap could possibly be increased by €8 billion to €10 billion to cover waste- water management needs in small rural settlements with populations below 2,000 inhabitants. This would amount to €64 billion to €66 billion of a total investment gap to sustain UWWTD imple- mentation up to 2040, which represents €38 per capita per year for the next 25 years, or 0.2 per- cent of all eight EU member states’ GDP (in purchasing power parity [PPP], current US$). This level of spending remains below the OECD recommendation ranging from 0.3 percent to 1.2 per- ­ easible. As a comparison, from 1993 to 2013, cent of GDP (OECD 2011), and as such appears to be f Austria invested an average of €78 per capita per year in the wastewater sector, which repre- sented 0.13 percent of its GDP (in PPP, current US$). This very high amount equals the funding necessary for the initial achievement of UWWTD objectives. This underlines the heavy financial significance of future renewal and upgrading as a neglected aspect of wastewater management. TABLE 3.2. Calculated Total Investment Costs Needed for Initial Full UWWTD Compliance among Danube River Basin Member States Historical investment Future investment costs Total Total costs €, millions €, millions investment Target Countries Pollution cost for fuII Sewer Sewer load, PE WWTP WWTP compliance network network €, millions Austria 20,270,894 10,150 4,238 — — 14,388 Bulgaria 8,080,245 3,370 810 804 865 5,849 Czech Republic 7,179,593 4,675 1,590 — 21 6,286 Croatia 5,026,227 0 0 3,074 999 4,073 Hungary 10,210,998 5,592 1,221 — 12 6,825 Romania 20,786,160 5,852 990 7,037 3,373 17,252 Slovenia 1,371,002 883 87 112 222 1,304 Slovak Republic 3,890,209 2,360 578 17 281 3,236 Danube Region 76,815,328 32,882 9,514 11,044 5,773 59,213 Source: Umweltbundesamt et al. 2017. Note: Umweltbundesamt et al. (2017) mentions a total investment need for initial full UWWTD compliance of €17 billion for Romania. However, it should be noted that other sources provide figures varying from €8 billion to €20 billion. PE = population equivalent; UWWTD = Urban Wastewater Treatment Directive; WWTP = wastewater treatment plant; — = not available. 18 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? TABLE 3.3. Estimated Reinvestment Needs for Sustained Compliance with UWWTD among Danube River Basin Member States, 2015–40 (€, millions) Target Reinvestment need on historical installations Reinvestment need on future installations Annual Total reinvestment countries Sewer network WWTP Sewer network WWTP reinvestment need need until 2040 Austria 203 212 0 0 415 10,375 Bulgaria 67 41 16 43 167 4,175 Czech Republic 94 80 0 1 174 4,350 Croatia 0 0 61 19 81 2,025 Hungary 112 61 0 1 173 4,325 Romania 117 50 141 169 476 11,900 Slovenia 18 4 2 11 35 875 Slovak Republic 47 29 0 14 90 2,250 Danube region 658 476 221 258 1,613 40,275 Source: Umweltbundesamt et al. 2017. Note: The reference year is 2015 and progresses for 25 years based on the calculated investment cost. For this assessment, the annual reinvestment requirements for a sewer network have been defined as 2 percent of the initial investment value (life expectancy of 50 years) and 5 percent for the WWTP (life expectancy of 20 years). UWWTD = Urban Wastewater Treatment Directive; WWTP = wastewater treatment plant. FIGURE 3.8. Future Demand for Capital and Per Capita Investments to 2040 in Danube River Basin Member States, 2015 a. Future investment demand b. Per capita investments Slovak Republic Slovak Republic SIovenia SIovenia Romania Romania Hungary Hungary Croatia Croatia Czech Republic Czech Republic Bulgaria Bulgaria Austria Austria 0 5,000 10,000 15,000 20,000 25,000 0 200 400 600 800 1,000 1,200 1,400 1,600 €, millions €, millions New investment for full compliance with UWWTD Per capita new investment need up to 2040 Reinvestment need until 2040 Per capita re-investment need up to 2040 Source: Umweltbundesamt et al. 2017. Note: UWWTD = Urban Wastewater Treatment Directive. The situation might be more challenging in non-EU countries of the DRB, which face signifi- cantly larger investment needs and a lower level of economic development. The cost of UWWTD implementation for today’s candidate and potential candidate countries (all countries of DRB with the exception of Ukraine) is estimated to amount to €19 billion, without asset renewal and small agglomerations (the case of Albania is presented in box 3.2). This rep- resents about €35 per capita per year, and 0.34 percent of candidate and potential candidate countries’ GDP (in PPP, current US$). While those are hypothetical at the moment, they may add up to the costs of UWWTD implementation in the DRB. Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 19 TABLE 3.4. Past UWWTD Compliance Investment among Danube River Basin Member States, before 2015 Countries €, billions Austria 14,338 Bulgaria 4,80 Croatia 0 Czech Republic 6,265 Hungary 6,813 Romania 6,842 Slovak Republic 2,938 Slovenia 970 Total 42,346 Source: Umweltbundesamt et al. 2017. Note: UWWTD = Urban Wastewater Treatment Directive. TABLE 3.5. EU Funds Used to Co-Finance Investments in Wastewater Infrastructure in Danube River Basin Member States, 2000–20 €, millions 2000–06 2007–15 2014–20 Total EU Target countries ISPA, ERDF CF, ERDF Budgets CF, ERDF contribution Bulgaria 246 1,122 1,000 2,368 Czech Republic 397 229 0 626 Croatia a 21 200 1,100 a 1,321 Hungary 493 410 900 1,803 Romania 1,044 2,382 3,810 a 7,236 Slovak Republic 259 546 200 1,005 Slovenia 117 351 250 718 Total Danube region 2,577 5,240 7,260 15,077 Sources: World Bank staff calculations based on data from the European Commission’s Director General for Regional and Urban Policy; ICPDR 2009; World Bank 2015; Umweltbundesamt et al. 2017. Note: CF = Cohesion Fund; ERDF = European Regional Development Plan; EU = European Union; ISPA = Instrument for Structural Policy for Pre-Accession. a. Partially disbursed after 2020. More than one-third of wastewater infrastructure investment is financed through EU funds. However, because the situation is changing, significant increases of taxes and tariffs will be needed to fund future investments. An important proportion of the investment costs has so far been covered by transfers from EU cohesion funds for new EU member states, which account for more than 40 percent of investment funding in some countries. Up until 2020, €15 billion has been allocated and transferred. In the current programming period (2014–20) Romania, Croatia, and Bulgaria continue to receive substantial EU funding, as their wastewater infrastructure is still below UWWTD compliance requirements (table 3.5). But the reduction of EU allocations for the next EU budget period (2021–27) might jeopardize the overall funding of wastewater capex in the region just when investment will need to increase to ensure asset renewal. As a result, countries will have no option but to turn to a combination of taxes and tariff increases to fund those investments, presenting fiscal, political, and social challenges. ­ 20 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? BOX 3.2. Investment Levels in the Water Supply and Sewerage Sector in Albania The water supply and sewerage infrastructure in Albania is old, damaged, and inefficient. Demographic changes related to the rapid rural-to-urban population migration after the regime change in 1991, and the subsequent sharp increase in the demand for drinking water and sewage disposal services, have exacerbated the already precarious situation of the water supply and sewerage infrastructure, which is often operating at peak capacity. Although in recent years investments have been increasing, and recently more targeted toward wastewater, they were never sufficient to meet capital investment needs. According to the most recent information provided by the Ministry of Transport and Infrastructure, around €24 per inhabitant are invested yearly, financed from a combination of national and international sources. This amount remains well below the estimated €63 per capita per year needed to fund the investments (MPWT 2012) as stated in the National Water Supply and Sewerage Master Plan recently developed and approved by the Government of Albania as a fundamental tool for national investment planning. The Master Plan is based on a sector analysis and considers national strategies and policies. It presents the total investments identified for both the water and wastewater sectors for 2012–40 (table B3.2.1). Through this tool, the elaboration of a priority ranking for the defined projects supports the sustainable use of investment funds in line with sector considerations and development policies. Based on priorities, a ranking according to short-, medium-, long-term investment is defined by considering national and foreign investments for water and sanitation. Eighty percent of the identified investment needs is planned to go toward wastewater management (sewer extension and wastewater treatment plant construction), which is consistent with the country’s ambitions regarding EU integration. TABLE B3.2.1. Wastewater Investment Needs in Albania, 2012–40 €, thousands Sector Item Rehab. Extension New Total % Water Utility based 530.5 352.7 3.4 886.6 17.45% Supply OJ based 0 0 154.7 154.7 3.04% Total 530.5 352.7 158.1 1,041.3 20.50% Sewerage Utility based 285.2 1,899.8 522 2,707 53.28 OJ based 1.3 16.2 1,325.7 1,343.20 26.22 Total 286.5 1,916 1,847.7 4,050.2 79.50% Total 817 2,268.7 2,005.8 5,091.5 100% Source: MPWT 2012. Note: Prior to the Territorial Administrative Reform (2015-16), the 58 water supply and sewerage utilities that officially provided data to the Benchmarking and Monitoring Unit in Albania covered 80 percent of the population. The remaining 20 percent, called Out of Jurisdiction (OJ), were served by communal/village systems. Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 21 Do Countries have the Technical and Institutional Capacity to 3.3.  Achieve and Maintain EU Compliant Wastewater Management? Short answer: Technical and institutional capacity enhancement is crucial for successful wastewater management project implementation. One of the main bottlenecks for UWWTD implementation has been the lack of institutional capacity of the implementing utilities, given the size and complexity of investment projects. The tendering process has been chal- lenging and has generated important delays. A lack of established mechanisms to fund equity contributions for the project beneficiaries is a serious barrier in some countries. Lack of political willingness; and slow responsiveness, knowledge, and information exchange and transfer between different levels of governance have had a negative impact on project identification, and have significantly slowed investment preparation and implementation. Local construction markets have not responded quickly enough to the significant increases of investment levels, leading to limited competition and higher costs. The challenges have shown that most new EU members have not manage to conduct the necessary institutional reforms or adjustments to prepare for a large investment cycle, resulting in low absorption of available funds and significant delays in UWWTD implementation. Technical and institutional capacity enhancement is crucial for successful wastewater management project implementation. As mentioned in the previous section, achieving EU wastewater policies compliance requires the delivery of massive infrastructure investment programs, and the associated management, operations and maintenance (O&M) of assets. For various reasons, many countries in the region did not have the adequate capacity to set up these investment programs and ensure proper wastewater asset management. For instance, in some countries, provision of wastewater services was low during the pre-1990 era, and, hence, no capacity in this field existed. In other countries in which provision of wastewater services was high, the facilities and assets were managed according to standards that were not consistent with those of the EU. Moreover, as stated in previous sections, delays in EU wastewater policies’ implementation and issues related to EU funds absorption are also showing limits in capacity to deliver the required massive investment programs. Based on the findings from World Bank capacity building and investment support activi- ties in the region, the following lessons have been drawn on the capacity to both deliver investment and maintain assets. These lessons could be valuable for the potential future member states from the Danube region that will almost certainly face similar issues. One of the main bottlenecks for UWWTD implementation has been the lack of institutional capacity of the implementing utilities, given the size and complexity of investment projects. The water supply and sanitation (WSS) sector in the Danube region has not had to imple- ment a national investment program of such magnitude ever before. While utilities often create special project implementation units (PIUs) to implement investments, these new units have to be trained and nurtured, and have faced multiple practical challenges during the projects’ preparation and implementation. In addition, the pressure of investments to abide by compliance deadlines has not always allowed designers and local communities to 22 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? look for the best technical and financial solutions. Instead, they typically have sought for implementation easiness, which has proved appropriate in the short term but not optimal in the longer term. Project preparation and implementation mechanism established by the World Bank under Croatia Coastal Cities Pollution Control Project (2004–16) is a good exam- ple of a regional multi-entity project management scheme that has significantly benefited Croatia in developing critical infrastructure, therefore building its project preparation capac- ity during the preparation for the EU membership phase. In an effort to benefit from econo- mies of scale and facilitate EU funds absorption, Romania, Hungary, and Croatia have turned to regionalization of WWS utilities. Although aggregation brings along its own issues (World Bank 2017), it has proven quite effective in improving capacity for project preparation and implementation by creating larger regional utilities, such as in Romania. While trying to bridge investment gaps, all new EU member states have over-contracted their available EU budget, triggering absorption issues. New EU member states have rushed into investment programs that were not always optimized, as shown by the gap between the grants contracted and the payments effectively made on the basis of those grant contracts (table 3.6). Although the dataset displayed in the table does not reflect the EU grants strictly allocated and disbursed for UWWTD implementation, it gives an overview of issues experi- enced by the seven countries in using EU grant funding. The biggest variances between pay- ment ratio and contracting ratio are observed for the Slovak Republic (25 percentage point difference) and Romania (43 percentage point difference) showing strong difficulties to absorb EU allocated funds. On the contrary, Slovenia displays only a 2 percentage point dif- ference between payment ratio and contracting ratio. Hungary also achieved good results with a 6 percentage point deviation between payment ratio and contracting ratio, thus show- ing a good absorption capacity of EU grants. Croatia, which joined the EU in 2013, is an excep- tion because it had a significantly shorter period to allocate, contract, and disburse funds. TABLE 3.6. EU Fund Disbursement in Danube River Basin Member States, 2007–15 Available Available Contracted Paid Target Contracting Payment budget budget per grants grants countries ratio (%) ratio (%) (€, billions) capita (€) (€, billions) (€, billions) Bulgaria 6.7 926.9 7.0 6.4 105 95 Czech Republic 26.3 2,495.9 27.0 23.3 103 89 Croatia 1.3 305.5 1.5 0.7 117 57 Hungary 24.9 2,528.6 29.2 27.7 117 111 Romania 19.1 959.5 22.1 13.9 116 73 Slovenia 4.1 1,987.8 4.4 4.3 107 105 Slovak 11.7 2,144.4 14.2 11.3 122 97 Republic Total 94.1 1,621.2 105.4 87.6 112 90 Source: KPMG 2016. Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 23 The tendering process has proved difficult and challenging, generating significant delays. Overcomplicated grant schemes and public procurement procedures requiring large volumes of documentation, combined with fundamental weaknesses in public procurement practices (lack of transparency and frequent irregularities in Bulgaria, the Slovak Republic, and Romania), have very significantly slowed down implementation. The average period between the signature of the financing contract and the signature of all works contracts for a water utility in Romania has been about three-and-a-half years. The average time for tendering a civil works contract has been about 10 months, but in some cases, it has exceeded two years even for small contracts. In addition, the lowest price has been the main criteria used to award contracts, which has created quality problems later during the implementation phase. A further challenge has been posed by the limited capacity of the local construction market. Local companies have not been able to respond quickly enough to the significant increases of investment levels, leading to limited com- petition and significantly higher costs than initially estimated. Anecdotal evidence shows that current project costs are up to 40 percent higher today in Croatia than they were shortly before accession, when sector wide investments in wastewater infrastructure were a few times lower. A lack of established mechanisms to fund equity contributions for the project beneficiaries is a serious barrier in some countries (e.g., Romania) that should be addressed through the establishment of national financial support mechanisms (without actually using national funds) before countries launch into large investment programs. The Croatia Coastal Cities Pollution Control Project has been innovative, because it has introduced a concept of desig- nated project-specific surcharge included in increased water tariff and collected at a desig- nated account used specifically for project financing and loan repayment. Experience shows that this concept of direct beneficiary contribution not only works but also has a positive impact on project ownership and overall rationality. Slow responsiveness, knowledge, and information exchange and transfer between different levels of governance and responsibility have had a negative impact on project identification, and have significantly slowed investment preparation and implementation. Experience from some countries (e.g., Croatia) confirms that implementation efficiency depends on the degree of integration of EU procedures into existing administrative and management mech- anisms. In other countries (e.g., Bulgaria) the experience of suboptimal project preparation by municipalities that have received EU grants has led to “no-regret” financing approach and lack of optimized regional wastewater treatment solutions. Countries should take advantage of the EU accession process to ascertain their institutional ability to deliver the investments and associated services. Countries must analyze the actual capacity of their local and national institutions to implement the necessary investment programs and sub- sequently manage the assets and deliver the services, before launching into the accession process. A positive example can be seen in the approach taken by the Croatian water authority (Croatian Waters) that has established a dedicated EU project unit for supporting the prepara- tion and implementation of EU co-financed projects, in addition to a unit that works on approval and monitoring of water projects co-financed from EU funds (as Intermediate Body 2). 24 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? Is EU Compliant Wastewater Management Affordable for the Utility 3.4.  Companies and the People of the Region? Short answer: Total cost recovery (TCR) is a challenge in most countries from the region. O&M costs are essentially financed through tariff revenues with either no or minimal subsi- dies provided by national or local governments. In general, with the exception of Austria, current tariffs in the studied countries are not sufficient to ensure TCR of actual wastewater services (including depreciation for future investment and reinvestment). Bringing waste- water management in compliance with EU wastewater policy brings a range of benefits, but also significantly increases O&M costs of utilities, triggering wastewater tariff increases that will continue in the future. These necessary tariff increases, needed to improve operational cost recovery ratio, will trigger affordability issues for the bottom 40 (B40) percent of popu- lation. The situation will be much more challenging for EU candidate countries, which will have to increase tariffs (or taxes) much more significantly to meet EU acquis despite lower levels of economic development. Total cost recovery is a challenge in most countries from the region. Article 9 of the WFD requests member states to ensure adequate contribution of water uses to the cost recov- ery of water services. Furthermore, the “polluter pays” principle implies that polluters are responsible for the pollution they generate and, therefore, must bear the associated costs. For the 2014–20 EU program, the cost recovery principle was made mandatory through the necessity to fulfill an ex ante conditionality (European Commission 2014). This means that the approval of 2014–20 operational program was subject to the “existence of an ade- quate contribution of the different water uses to the recovery of the costs of water ser- vices,” as stated in Article 9. The definition of what is an “adequate contribution” remains, however, at the member states’ discretion. O&M costs in the Danube region are essentially financed through tariff revenues with either no or minimal subsidies provided by national or local governments (figure 3.9). In general, with the exception of Austria, current tariffs in the studied countries are not sufficient to ensure TCR of actual wastewater services (including depreciation for future investment and reinvestment). The national average TCR from tariffs for wastewater for the eight countries studied in the region ranges from 0.24 to 0.86, well below the desired TCR value of 1 (Umweltbundesamt et  al. 2017). The wastewater tariffs display substantial differences. Average wastewater tariffs in Austria (€2.0 per cubic meter) are more than three times higher than in Bulgaria ­ (€0.6 per cubic meter) (figure 3.10). The average O&M costs per cubic meter for wastewater services of the EU member states of the region amounts to 1.1/m3. It fluctuates in a ratio of 1 to 5 with a maximum of €1.5/m3 (for Austria) and a minimum of €0.3/m3 (for Bulgaria) (figure 3.11). Wastewater management alignment with EU wastewater policy compliance significantly increases O&M costs of utilities, triggering wastewater tariff increases that will continue. Necessary investments for the improvement of wastewater collection and treatment have Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 25 FIGURE 3.9. Financing Sources for Water Supply and Sanitation in Danube River Basin Countries 100 Share of overall financing (percent) 80 60 40 20 0 o ia ia ic ic tia ry ia ria va a ia vo ia er sn e vi nd gr ni in bl bl ar an rb ga en on do st oa na so go a ba ne ra pu pu lg Se m Au un ov ed ze ia ol Cr Ko Uk Bu Al te Ro Re Re M H Sl ac on H Bo ak h M M ec ov R Cz FY Sl Tari s (local) Tari s (national) Taxes (local) Taxes (national) Transfers Source: World Bank 2015 FIGURE 3.10. Tariffs of Wastewater Collection and Treatment in Danube River Basin Member States 2.5 2.0 2.0 1.7 Euro per cubic meter 1.5 1.5 1.4 1.3 1.1 1.0 1.0 0.6 0.5 0 Austria Czech Hungary Slovak Slovenia Croatia Romania Bulgaria Republic Republic Sources: Umweltbundesamt et al. 2017; World Bank 2015. been matched by significant increases in overall operating expenses, leading to parallel tariff increases (World Bank 2015). As a result, a significant shift in the water and wastewater tariff structure has happened. Whereas wastewater represented about 50 percent of the total average water and wastewater invoice in the 1990s, this share presently represents percent, and is anticipated to reach 70 percent after UWWTD full implementation due to 60 ­ expensive tertiary treatment (Umweltbundesamt et al. 2017). 26 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? FIGURE 3.11. O&M Costs of Wastewater Collection and Treatment in Danube River Basin Member States 1.6 1.5 1.4 1.4 1.3 1.3 1.2 Euro per cubic meter 1.0 1.0 0.9 0.9 0.8 0.6 0.4 0.3 0.2 0 Austria Hungary Czech Slovak Slovenia Croatia Romania Bulgaria Republic Republic Sources: Umweltbundesamt et al. 2017; World Bank, 2015. Note: O&M = operations and maintenance. The supporting study conducted national analyses of long-term financial sustainability of tariffs until 2040 and used two key indicators: the operation cost recovery (OCR) ratio (includes only O&M costs), and the total cost recovery (TCR) (includes O&M costs but also investment and reinvestment including financial costs). The analysis was conducted for two scenarios that integrate investment and reinvestment, including the cost of financing, O&M costs, and tariff revenues of the utilities. Costs and revenues are expressed in real terms (with no inflation impact taken into consideration) on the basis of 2015. A first “business as usual” scenario considers only two off-sector elements as factors of change, such as popula- tion change and labor cost increases affecting O&M costs. A second scenario, called a “sus- orientated pathway (SOP),” attempts to simulate the outcome of financial tainability ­ operation when tariff increases compatible with EU affordability rules are applied. In this scenario the aim of the revenue increase is to achieve OCR ratios comparable to the current Austrian level (1.44–1.6) and TCR ratios not lower than 1. TCR was defined as embracing not only O&M costs but also investment and reinvestment including financial costs to be achieved as soon as possible within the affordability threshold encouraged by EU guidelines. Without a tariff increase, the OCR ratio for the wastewater sector is expected to decrease in all analyzed countries below O&M cost covering requirements, except in Austria. Because coun- tries will not be able to cover their O&M costs, wastewater service provision can be expected to deteriorate and eventually become unsustainable. By 2040, the typical TCR would range between critical and poor (0.5–0.7 for six countries and for Bulgaria even lower, 0.3), while only Austria is expected to have a better ratio of 0.9. Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 27 In the sustainability orientated pathway scenario that considers robust annual tariff increases within the boundary of EU recommended affordability threshold,2 and with produc- tivity and efficiency gains by operators, countries can expect their TCR ratio through tariffs to reach 1 within a variable timeframe: Austria within five years and Romania after 25 years, and with annual tariff increases from 1 percent to 5 percent over the entire period (figure 3.12). The necessary tariff increases to achieve full cost recovery will trigger affordability issues for the B40 of population in some countries. The SOP for 2015–40 is using 3 percent as the afford- ability threshold for wastewater tariffs for the poorest segment of the population. The anal- ysis of affordability3 of wastewater prices for the poorest 40 percent of the population clearly reveals alarming affordability problems over the years, especially in Hungary, Bulgaria, and Romania (table 3.7). For the B40, paying the prices corresponding to the full implementation costs of UWWTD is expected to be affordable in Austria, Slovenia, Czech Republic, and the Slovak Republic. In Croatia affordability issues should be transitory and disappear by 2035. Following the analysis, these caveats should be highlighted: • Should one or more of the assumptions of the modeled scenario (GDP growth, social tol- erance, efficiency gains) not be met, financing gaps, especially for capital investment and reinvestment, would appear, which could still be bridged by EU grants for a limited period, until perhaps 2021–27. FIGURE 3.12. Estimated Long-Term Evolution of TCR Ratios in Danube River Basin Member States, SOP Scenario, 2015–40 1.20 1.00 0.80 Cost recovery rate 0.60 0.40 0.20 0 2015 2020 2025 2030 2035 2040 Austria Czech Republic Hungary Slovak Republic TCR-level Bulgaria Croatia Romania SIovenia Sources: Umweltbundesamt et al. 2017; World Bank, 2015. Note: Cost recovery rate here refers to total revenue per total expenditure (operational plus capital expenditures). DRB = Danube River Basin; SOP = sustainability orientated pathway; TCR = total cost recovery. 28 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? BOX 3.3. Sustainability of O&M Costs of WWTPs in Bosnia and Herzegovina Access to public services in Bosnia and Herzegovina is around 60 percent for water supply and 32 percent for wastewater collection. During recent years, with significant financial support from the EU, several WWTPs (in Sarajevo, Bihać, Mostar, Bileća, Konjic, and Zivinice) have been constructed or reconstructed, increasing percentage of wastewater treatment from 3 percent to currently 20 percent. However, authorities face challenges in the postcompletion phase of the project to maintain the achievements, for example: (i) low financial capacity because of low tariffs and substantial overall inefficiencies in the public water utility (PWU) operations; and (ii) low technical capacity, lack of qualified staff, and lack of interest from the authorities in improvement of the PWUs’ accountability through reforms. O&M of newly constructed WWTPs is under the responsibility of municipal PWUs, which have neither the adequate financial nor human resources to manage it. Although operation of the facilities has started, the tariff structure for services has not changed, directly endangering both wastewater treatment and water supply systems. Often, support to PWU to manage WWTPs is given on an ad hoc basis, mainly through financial subsidies from municipal or higher levels of government (Sarajevo WWTP). This situation is directly endangering investments, and PWUs are struggling to secure stable funding for WWTP operation. If practices do not change soon, some may stop working. Typical is the city of Mostar, in which the World Bank, an EU delegation, and the Swedish government have invested more than US$13 million in construction of the WWTP. Although all works were finished in June 2017, the facility is still not in operation (as of May 2018) due to lack of local financial and operational capacities to run the WWTP. This clearly shows that local communities and higher governmental intervention have failed to perform necessary assessment of affordability and operating costs of the WWTP and other capital investments before its implementation. Although Bosnia and Herzegovina is not an EU member state, its legal framework is being harmonized with the EU acquis (Drinking Water Directive and UWWTD). However, the implementation is very weak, and the new legal and operational framework should be established to enable sustainable development and operation of WWTP investment. Findings of the World Bank Implementation Completion and Results (ICR) report, prepared for recently completed projects (Sarajevo Wastewater Project and Water Quality Protection Project), have identified issues characteristic for water utility operations and projects in Bosnia and Herzegovina and regionwide, including the following: • The financial sustainability of the water utilities is often precarious and efforts are needed to ensure that utility can fully cover their operating costs. box continues next page Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 29 BOX 3.3. continued • Project objectives should be closely tailored to the capacity of the government and utility and the conditions of the enabling environment existing at the time of project preparation. • Operation costs need to be properly calculated. • Affordability of tariffs needs to be carefully assessed before the project. • Authorities at various levels in government must secure upfront sustainability of investments and commitment to guarantee sustainable and efficient operations. • Active measures for wastewater collection and users’ connection to sewers must exist as construction of wastewater treatment facilities are constructed. • Implementing sectoral or tariff reforms needs to be joined with improvement of water and wastewater services for consumers to find tariff increases acceptable. TABLE 3.7. Estimated Changes in Affordability Ratio of Wastewater Tariffs for the B40 in Danube River Basin Member States, SOP scenario, 2015–40 Countries 2015 2025 2035 2040 Austria 1.06 1.10 0.98 0.93 Bulgaria 3.31 4.37 4.76 4.71 Czech Republic 2.00 2.24 2.17 2.15 Croatia 2.59 3.14 2.55 2.24 Hungary 3.20 3.90 3.27 3.00 Romania 5.15 4.41 4.41 3.86 Slovenia 0.79 0.95 0.86 0.79 Slovak Republic 2.57 2.97 2.57 2.37 Sources: Umweltbundesamt et al. 2017; World Bank 2015. Note: B40 = bottom 40 percent; SOP = sustainability orientated pathway. • Tariff increases required for the SOP scenario will not be easy to implement for political reasons because the population may not be willing to accept continuous price increases. Consequently, UWWTD asset depreciation costs may not be fully covered. In the absence of sufficient national and European grants, the asset management situation might become critical. Market-based loans or bonds could be an option to temporarily bridge financing gaps but will, however, have to be reimbursed using tariff revenues. • Because commercial loans or bonds are provided only to creditworthy organizations, water and wastewater utilities—and related municipalities—must start early to build up their credit ratings and creditworthiness to gain access to money markets for their UWWTD-related capital investments and reinvestments. 30 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? Finally, while the affordability analysis focused on the B40, for the poor and extreme poor, those constraints will appear much earlier, and the governments should address them through timely developing properly designed, targeted subsidy schemes. Here again, constraints will be much more significant for EU candidate countries . Many of the  candidate countries currently have low and relatively affordable WSS services, given the limited levels of wastewater treatment provided (figure 3.13 and figure 3.14, panels a and b). Potential candidate and candidate countries such as Albania, Bosnia and Herzegovina, and Kosovo have much lower levels of access and service levels in terms of sanitation, specifically in rural areas. While willingness to pay for reliable and good quality drinking water among nonconnected households is substantial, waste- water services improvements will require a steep increase in tariffs that will require even more targeted support ­ m echanisms, and intensive communications to timely increase the willingness to pay (World Bank 2018). Higher investment needs, poten- tially lower EU contributions, and lower levels of economic development in most of the candidate or potential candidate countries mean that tariffs will have to rise sig- nificantly, and affordability issues will be much more pronounced than in EU member countries. FIGURE 3.13. Wastewater Treatment Coverage in Danube Region, 2012 100 90 Wastewater treatment connection (%) 80 70 60 50 40 30 20 10 0 ria ic Re ry ic ia Ro ia ia e tia va o a YR ia na vo ni in gr bl bl ar en an rb a do vi so st oa ,F ba ra ng ne pu pu lg Se m go ov Au Ko ol Cr Uk ia Al Bu u te Re Sl ze M on H on er h ak ed M ec H ov ac Cz d Sl M an ia sn Bo EU member countries EU candidate countries Non-EU countries Source: World Bank, IAWD, and GIZ 2015. Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 31 FIGURE 3.14. Affordability of Water and Wastewater Tariffs for Income Groups in Selected Countries of Danube Region a. Average b. B40 35 Ukraine 60 Ukraine Romania 30 50 25 40 Romania 20 30 15 Macedonia Macedonia 20 10 Moldova Serbia Kosovo Moldova Montenegro Serbia Kosovo 10 Montenegro 5 4,4 4,2 5,8 2,0 2,4 2,3 2,2 2,9 3,3 4,6 2,8 1,9 2,2 2,7 0 0 0 2 4 6 8 0 2 4 6 8 Share of expenditure in total income Percent of hhs with expenditure above 5 percent Source: World Bank, 2015. Note: B40 = bottom 40 percent; hhs = head of household. Is EU Compliant Wastewater Management Implemented in an 3.5.  Economically Efficient Manner? Short answer: The challenges highlighted previously raise the question of economic effi- ciency of the implementation of the UWWTD in the Danube region. While further work is needed to reach a more robust conclusion, assessment conducted under this study, on the basis of limited literature review and available evidence, shows no compelling self-­ standing economic case to support full compliance with the Directive in the Danube region. This makes it all the more important to ensure that the Directive is implemented in the most economically efficient manner, to maximize economic cost-benefit ratio of the Directive implementation. The challenges highlighted previously raise the question of whether the full implementation of the UWWTD is economically efficient in the Danube region. The UWWTD is an important environmental legislation that levels the field for environmental and public health protection—and overall access the European single market—and, therefore, does not neces- ­ sarily need to yield a positive economic cost-benefit ratio by itself. Nonetheless, an attempt was made to quantify costs and benefits of the Directive’s implementation in the Danube region to further inform the discussion on ensuring its success. The analysis was limited by available information and resources, and mainly relies on available literature review and expert estimates. As such, it should therefore be seen only as a way to spur the dialogue, highlighting a need for a deeper and more detailed analysis. The economic assessment of UWWTD implementation here considers the economic costs of the Directive implementa- tion and the economic benefits deriving from good water quality, including health and envi- ronmental impacts. In a supporting report (Umweltbundesamt et al. 2017), the unit benefit 32 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? transfer methodology, combined with estimates of the willingness to pay for good water quality extracted from past studies, are used to derive countrywide estimates of the economic value of UWWTD compliance in the Danube region. The estimated values are not ­ very robust, but they provide an indicative range of what the economic benefits of UWWTD compliance are for the DRB member states. Though they may represent the most significant source of economic value to justify UWWTD implementation, the costs and benefits of ecosystem services are not being adequately addressed in the Danube region due to the ­ absence of a feasible method for estimating and monetizing the environmental benefits of improving the Black Sea’s water quality. Results of the cost-benefit assessment of the UWWTD do not allow confirmation that full implementation of the Directive is economically efficient for the Danube region. The following costs are taken into account: investment, reinvestment, and O&M costs for wastewater col- lection and treatment system required under UWWTD Articles 3, 4, and 5. Administrative costs—along with environmental and resources costs—have been ignored in this first approx- imation due to a lack of data. On the benefit side, health, environmental, and social benefits have been taken into account based on the willingness to pay for good drinking water quality (health benefits) and for good water resource quality for environmental and social purposes (environmental and social benefits) (Umweltbundesamt et al. 2017). According to the litera- ture reviewed, the environmental benefits for good water quality are 10 to 30 times higher than health benefits, as is generally the case in upper income countries. For all the countries analyzed for the period 2000–40, the cost of implementing the UWWTD stands above the higher range of the estimated benefits (figure 3.15). Hence, regard- less of how economic benefits are valued (lower or higher estimates), the implementation of the UWWTD shows no apparent economic surplus, even when considering the higher range of estimated economic benefits (figure 3.15, table 3.8, and table 3.9). When considering the period 2000–40, the expected net present value (ENPV)4 remains slightly negative and the economic internal rate of return (EIRR) is only marginally positive (2 percent to 3 percent) for most countries. These estimates are rough, however, and need further in-depth analysis. The ENPV corresponds to the discounted aggregated value of the economic costs and bene- fits of the investment made over the assessment period. The EIRR is the discount rate that yields an ENPV of zero. If positive, it is an indicator that the investment has generated an eco- nomic surplus for the beneficiary populations of the Danube region. The cost-benefit ratio of UWWTD investment costs compares discounted costs and benefits over the assessment period. If above one, the investments generate an economic surplus to the concerned societies. A more positive cost-benefit ratio for UWWTD implementation may appear when more bene- fits are qualified, quantified, and monetized and when policy makers can assess and account for the full economic value of water-related ecosystem services. Regardless, EU member states should explore possibilities to increase benefits from UWWTD implementation, including promotion of water-related recreation activities, and wastewater reuse for irrigation in Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 33 FIGURE 3.15. UWWTD Related Costs and Benefits Discounted (2015) in Danube River Basin Member States, 2000–40 €, millions 50,000 45,000 40,000 35,000 30,000 25,000 20,000 15,000 10,000 5,000 0 Austria Bulgaria Czech Croatia Hungary Romania Slovenia Slovak Republic Republic Total costs Total bene its—lower range Total bene its—higher range Source: Umweltbundesamt et al. 2017. Note: UWWTD = Urban Wastewater Treatment Directive. TABLE 3.8. UWWTD Related Discounted Costs and Benefits (2015) per Danube River Basin Member States, 2000–40 €, millions Present value of costs and benefits Elements Czech Slovak Austria Bulgaria Croatia Hungary Romania Slovenia Republic Republic New investment 14,388 5,560 6,266 3,145 6,824 15,447 1,266 3,202 Reinvestment 12,603 2,492 3,367 1,602 3,453 5,717 552 1,668 O&M 19,455 1,979 13,241 4,370 14,623 18,501 2,921 6,512 Funding 371 72 117 37 94 204 19 49 Subtotal 46,817 10,103 23,171 9,154 24,994 39,869 4,758 11,431 Health benefits (lower range) 309 21 102 27 94 121 19 44 Health benefits (higher range) 1,823 128 609 165 563 727 117 263 ERC benefits (lower range) 7,475 2,166 4,237 894 3,877 5,956 778 2,049 ERC benefits (higher range) 33,637 6,498 12,710 2,683 11,630 17,869 2,335 6,146 Sub-total benefits (lower range) 7,784 2,187 4,339 921 3,971 6,077 797 2,093 Subtotal benefits (higher range) 35,460 6,626 13,319 2,848 12,193 18,596 2,452 6,409 Source: Umweltbundesamt et al. 2017. Note: ERC = environmental and resource costs; O&M = operations and maintenance; UWWTD = Urban Wastewater Treatment Directive. 34 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? TABLE 3.9. Economic Indicators among Danube River Basin Member States toward Implementation of UWWTD, 2000–40 Slovak Indicators Austria Bulgaria Czech Republic Croatia Hungary Romania Slovenia Republic ENPV (lower range) −39,033 −7,915 −18,653 −8,232 −21,024 −33,793 −3,961 −9,339 (€, millions) ENPV (higher range) −11,357 −3,476 −9,672 −6,306 −12,801 −21,274 −2,307 −5,023 (€, millions) EIRR (higher range) (%) 3 10 6 .. 2 3 3 5 Cost/Benefit ratio 0.76 0.66 0.58 0.31 0.49 0.47 0.52 0.56 (higher range) Source: Umweltbundesamt et al. 2017. Note: DRB = Danube River Basin; EIRR = economic internal rate of return; ENPV = economic net present value; UWWTD = Urban Wastewater Treatment Directive. specific areas sensitive to climate change. To build a more robust economic assessment of the benefits of UWWTD implementation, more relevant datasets need to be developed and monitored at country and river basin levels. While further work is needed to reach a final conclusion, the UWWTD is and will remain one of the key environmental legislations, and future focus should be put on implementing it in the most cost-effective and economically efficient manner. The prevailing driver for UWWTD com- pliance remains the need for uniformity of regulatory compliance under the EU directives, and environmental protection beyond strict economic justification. This, however, does not mean that economic efficiency could not be improved by a closer alignment with the WFD principles and objectives, for example, through better prioritization of wastewater infra- structure investment (focusing on wastewater systems having a large negative impact on environment, and upgrading levels of treatment primarily based on environmental monitor- ing of water bodies’ status), and adoption of more phased development (avoiding financing expensive, oversized infrastructure designed for long-term needs). In addition, the use of economic appraisals, such as cost-effectiveness analysis or cost-benefit analysis, to assess the impact of wastewater projects could help improve investment efficiency while maintain- ing environmental and health benefits and achievement of WFD objectives. Notes 1. Information regarding emissions from UWWTD agglomerations is available from the ICPDR Urban Waste Water Inventory for the reference years 2005–06 and 2011–12 and was additionally calculated for all years between 2005 and 2014 by means of information provided by the member states for the TA-UWWTD. 2. The EU recommended affordability threshold corresponds to 4 percent of household disposable income of the lowest income group for water and wastewater expenditure. 3. Affordability is calculated as the share of wastewater expenditure in household disposable income. 4. The discount rates used in the analysis derive from the Annex III to the European Commission (EC) guidelines regarding the implementation regulations on the application form and cost-benefit analysis methodology for the programming period 2014–20. The discount rate for older EU member states is set at 3 percent while it reaches 5 percent for new EU member states. Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 35 Chapter 4 Recommendations Building upon the outcomes of the analysis performed, some recommendations have been sections. These are formulated to respond to the challenges identified in the previous ­ divided between recommendations to member states implementing the current Directive; recommendations to candidate or potential candidates preparing for European Union (EU) membership; and recommendations to the European Commission (EC) as it considers whether to review Urban Wastewater Treatment Directive (UWWTD) ­ requirements. ­ 4.1. Implementation of the Directive ­ WWTD. Several of the new member states in the region are struggling to comply with the U In fact, an infringement procedure has been opened against Bulgaria in July 2017 when the notice. Romania is currently significantly lagging behind Commission sent a letter of formal ­ the schedule, with full compliance forecasted to be reached by 2027–30, far beyond the final ­ 018. As countries move forward and address those shortcomings deadlines of 2015 and 2 while maintaining the cost of services at affordable levels, the following recommendations might be ­ useful. management. To achieve a better efficiency Use a regional approach to optimize wastewater ­ and to minimize costs of service provision, wastewater infrastructure would be best planned and potentially implemented and managed at regional level, following the philosophy of the Water Framework Directive’s (WFD’s) River Basin Management ­ Plans. Using a regional approach to optimize the Directive’s implementation could be explored rather than having each utility or municipality set up its own investment ­ program. Such an approach would externalities. It would allow policy makers to, for instance, prioritize generate many positive ­ wastewater management investments at a regional level, generate infrastructure economies of scale, and explore potential for reuse and circular economy at a regional l ­ evel. Foster the adoption of cost-effective innovations in the wastewater s ­ ector. More efforts are needed to foster the adoption of new technological innovations in the wastewater s ­ ector. Recently, new technologies spreading from the digital revolution have allowed for more effi- (e.g., remote monitoring of water quality and wastewater cient wastewater management ­ ­ e.g., for wastewater: individual and other appropri- reuse) and optimized investment costs ( beds). Nature-based treatment ­ ate systems and extensive treatment with reeds ­ solutions ­opex). could also be favored to lower capital expenses (capex) and operating expenses ( Implementation should follow circular economy focus of EU institutions: using the waste- water treatment plant (WWTP) as a resource unit, and making it more energy efficient through various options ( ­ ncineration). Promoting innovations should be part of ­ e.g., biogas, i ­genda. Moreover, the legal constraints put in place against the government’s reform a public-private partnerships in water supply and sanitation (WSS) services in some countries ­ is reducing opportunities to benefit from private sector innovations, such as with Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 37 build–operate–transfer (BOT) schemes promoting technical innovations in WWTPs through approach. a results-based turnkey ­ Revisit the institutional setup for wastewater management, where relevant, to address lim- ­ apacity. Strong implementation capacity is crucial for optimal devel- ited national and local c ­unds. Good practices opment of wastewater infrastructure and better absorption of EU f indicate that the establishment of a proper institutional framework and the timely imple- mentation of water utility sectoral transformation and reform process significantly increase success. Various arrangements can be explored to address limited local capacity chances for ­ management. For instance, in Austria, multiple small municipalities group in wastewater ­ into Zweckverband, which is a special-purpose vehicle set up to develop WWTP investment projects. In Portugal, regional wastewater treatment utilities have been set up to address ­ efficiency. Support for further capacity technical capacity issues and generate economic ­ building policies in wastewater management is needed to ensure and strengthen the exis- ­ ector. Strengthening utilities in their efforts to tence of a professional workforce in the WSS s provide efficient and sustainable services is a key focus of the Danube Water Program (DWP), ­ opics. Moreover, investing in which supports capacity development in complex managerial t training can create appropriate capacity in the utilities and universities for the next genera- tion of water ­ challenges. upfront. Positive impact created by Address the question of opex financing and affordability ­ massive investments in wastewater infrastructure can be preserved and further enhanced ­ ustained. This requires the O&M and renewal costs to be only if service quality levels are s term. This leads to necessary covered by the revenues of the service providers in the long ­ tariff increases, which trigger affordability issues to be addressed through targeted subsidies population. If system operation and reinvestment are not finan- for the poorest part of the ­ cially sustainable, there is a high risk of decline in service quality and deterioration of the quality of discharges into receiving w ­ aters. Hence, opex sustainable financing should be ­ rocess. WWTP projects should come addressed upfront in the UWWTD implementation p with a clear costing, including life cycle and long-term costs and a funding ­plan. They should commitment. be supported with the necessary political ­ basis. Better Prioritize investments according to their impact rather than on a readiness ­ ­ prioritization of investments is needed to maximize the impact of available resources on UWWTD compliance and WFD objective ­fulfillment. Despite the approximately ­€42.5 ­billion invested in the sector since 2000, the improvement of sewerage and treatment coverage has expected. One cause is bad prioritization of investment because resources not progress as ­ infrastructure. Because most countries will have not been directed to the most impactful ­ not achieve timely compliance, they should focus efforts on the most impactful projects initially, and gradually move toward projects with lower environmental impact using analysis. Hence, investments should be prioritized on only on the basis of cost-benefit ­ agglomeration size as per UWWTD requirement but also with the goal of reaching WFD way. Moreover, EU funds could be environmental objectives in the most cost-effective ­ 38 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? prioritized toward investments in which the disconnection between externalities and direct ­ evere. In addition, a solid benefits is the largest, or in which affordability issues will be most s regime of time-sensitive fines should be approved to incentivize local governments to ­ pportunity. implement wastewater management master plans rather than wait for a grant o Strengthen utilities’ financial viability to ensure sustainability and access to financial m ­ arkets. Financing gaps between tariff revenues and total costs of wastewater services exist in sev- eral new member states of the region, which can be expected to widen further with increas- ­ ompliance. This can be a very serious problem in the ing advancement toward full UWWTD c term. Should EU grants for UWWTD investment cease around 2027, the medium to long ­ financing gap for remaining investment and reinvestment will be bridgeable only with com- loans. This will require governments to facilitate the establishment of financially mercial ­ utilities. Reforms need to be launched as soon as possible in each new member viable water ­ creditworthy. The financial posi- state to enable water utilities and municipalities to become ­ tion of operators and owners ought to be characterized by transparency, accountability, and autonomy. It is only after these qualities become prevalent that the national or international ­ utilities. financial market could expect to be invest in wastewater ­ 4.2. Candidate Countries Most of the current and potential candidate countries are far from complying with the UWWTD. They also face significantly lower economic development levels than EU member ­ states, which further constrains their ability to mobilize either taxes or tariffs to fund the investments. This represents a challenge, but also an opportunity to learn from the needed ­ ­hemselves. Below are a few lessons of the most recent member states in preparing t ­recommendations. Invest into a better process to plan wastewater management compliance and avoid underesti- compliance. Building upon the experience of the new EU mating the time needed for directive ­ member states of the Danube region, candidate countries should prepare a strategic plan for negotiations. To do so, wastewater infrastructure compliance well in advance of accession ­ they should invest into the development of regional master plans and roll them out ahead of time. Moreover, during the accession process, candidate countries need to negotiate appro- ­ priate deadlines to implement UWWTD, accounting for the economic affordability of this legislation. costly piece of EU environmental ­ ­nfrastructure. Assess institutional and technical capacity to deliver and maintain wastewater i Ahead of accession negotiations, candidate countries should thoroughly understand and compliance. They should also determine what investments are required to reach UWWTD ­ procedures. realistically assess the time required to avoid delays and possible infringement ­ This review should include an analysis of the institutional and technical capacity needed to timely deliver and maintain wastewater ­ infrastructure. Necessary reforms should then be proposed to develop and strengthen institutional and technical capacity and address ­shortcomings. Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 39 ­ anagement. Develop a financing strategy for affordable, sustainable wastewater m Implementing the UWWTD implies substantial investment that needs to be planned well in advance and staged to facilitate and secure the mobilization of the required financial ­ osts. WWTPs with secondary and tertiary treatment tend to have resources at the lowest c significant O&M costs that need to be covered by wastewater system users through t ­ ariffs. As a result, developing a financing strategy using the “3Ts” (tariffs, taxes and transfers), for the wastewater sector can soundly determine the financial feasibility of investments ­ bjectives. Moreover, the and sequence implementation toward achieving UWWTD o financing strategy should address existing and future affordability constraints with tar- geted subsidies for the poorest individuals and households, who will not be able to cope increases. with projected tariff ­ Conduct the reforms and policy changes necessary to implement the recommendations ahead of ­time. Considering the preceding recommendations, candidate countries should develop and implement the critical package of reforms needed to address the challenges and issues levels. on technical and financial ­ 4.3. Potential Review of Directive reviewed. While The Commission is currently considering whether the Directive should be ­ many considerations will go into any revision of the current requirements, the following are recommendations that could significantly ease the implementation of the Directive in the Danube region without compromising the overall environmental objectives provided by the WFD. ­ bjectives. The UWWTD is a relatively simple Align the UWWTD more closely with WFD o directive, requiring only limited data and model and planning capacity for its implementa- ­ FD). Due to its simplicity member states know exactly tion (in contrast, for example, to the W what is expected, and the progress can be easily tracked and good level of enforcement ensured, which make it an important asset in EU environmental ­policy. This simplicity, how- ever, does not provide much space for policy makers and planners to adjust requirements to situations that might differ from those for which the directive was initially d ­ esigned. In most of the older EU member states, basic measures deriving from the UWWTD were not suffi- cient to reach a good status of water bodies, making a discussion of the relevance of the UWWTD measures—which are part of the WFD basic Programmes of Measures—somewhat ­ ­ egion. UWWTD review unnecessary. This is, however, not the case in much of the Danube r discussions could restate that achieving WFD environmental objectives in the most cost-­ ­ olicy. Giving more flex- effective way remains the key priority of EU water and wastewater p ibility to member states to optimize their urban wastewater policies could offer ways to improve the economic efficiency of the UWWTD implementation while focusing on WFD fulfillment. For instance, if the economic costs of a project are environmental objectives’ ­ higher than its economic benefits, lower levels of wastewater treatment could be allowed as long as the proposed investment option is cost-effective, WFD goals are achieved, and public 40 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? ­ afeguarded. Still, the UWWTD is not the only EU directive dealing with water qual- health is s partial. ity, and its contribution to reach WFD good status is ­ ­ ssessment. The lack of comprehen- Strengthen the economic basis for UWWTD impact and a sive and transparent central database with wastewater discharges—emissions, investments, and water quality information—in the Danube River Basin (DRB) at national and local levels has made assessing the impact of UWWTD implementation on health, social, and environ- mental improvements ­difficult. No systematic effort to link waterborne diseases information to wastewater management and surface water quality could be identified for the Danube region. Data models to assess the different pollutant pathways into the aquatic environment ­ (which exist for biggest polluters through the European Pollutant Release and Transfer Register [E-PRTR] and the UWWTD) should be expanded and integrated to apply in all the ­ e.g., diffuse sources, such as countries’ river basins to better quantify individual pressures ( agriculture, versus point sources such as WWTPs) and benefits associated with UWWTD implementation. Focusing on implementing an integrated, detailed information system ­ would allow better assessment and prioritization, for a small fraction of investment costs, cost. Because achieving WFD environmental objectives is a key making it high value for its ­ priority, UWWTD review discussion could consider exceptions to the Directive requirements ­ mplementation. when no clear environmental and health benefit derives from the UWWTD i In the meantime, policy makers should evaluate and document the economic values of UWWTD. Member states should explore possibilities to increase benefits implementing the ­ (e.g., promoting activities that benefit from good water sta- from UWWTD implementation ­ irrigation). tus such as tourism, water sports, fishing, and ­ Introduce a solid economic and environmental analysis of individual projects to allow lower ­ eneficial. Revision of the UWWTD could introduce a solid level of treatment when it is cost b economic appraisal and environmental impact assessment to assess individual investment ­ projects. If a project is not assessed as cost beneficial, alternative wastewater treatment could be allowed as long as overall environmental impact is acceptable and WFD goals are achieved. For example, longer marine and submarine outfalls could eliminate the need for ­ more advanced level of wastewater treatments, and allow the achievement of good water ­ avings. The use of economic appraisal could help status with substantial opex and capex s reduce capex and opex, and improve investment economic efficiency while maintaining achievement. environmental and health benefits and WFD objectives’ ­ Provide more flexibility on the choice of technology especially in rural areas and small ­towns. UWWTD implementation, through constructing dedicated wastewater collection and treatment systems with secondary and more stringent treatment, has improved water quality of DRB surface waters primarily by reducing organic load and, to a lesser extent, discharge. In rural areas or small settlements, just above 2,000 population nutrient load ­ equivalent (PE), some flexibility should be given to local utilities to adopt measures such as green infrastructure or nature-based solutions that could be well adapted to their issues, sustainable. The concept less costly, sufficient to achieve WFD objectives, and financially ­ Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 41 and definition of “individual and other appropriate systems” could be revisited and con- solution. Wastewater treatment facilities with second- sidered as an alternative sanitation ­ ary treatment tend to have significant O&M costs that need to be covered by wastewater users. In some situations, extensive “nature near” e system ­ ­ cological WWTP solutions (such as constructed wetlands or lagoons) may be favored because they have significantly lower O&M costs and can achieve required level of pollution reduction with smaller per PE costs. Development of a modular conception of WWTPs may also help in reducing O&M ­ ­ e.g., costs, through allowing use of part of the treatment plant depending on received load ( situations of major load variations, as in seasonal tourist a in ­ ­ reas). ­ conomy. Member states should explore possibilities to increase Promote reuse and circular e ­ mplementation. For instance, the wastewater sector can contribute benefits from UWWTD i ­ ntapped. First, improve to promoting a greener circular economy, which remains largely u the management of sludge from WWTPs, gradually increasing the amount recycled in biogas production or in agriculture, provided that heavy metal concentration is below ­ EU Sludge Directive thresholds (86/278/EEC of June 12, 1986) and that a clear traceability is implemented. Second, develop the potential benefits of water-related tourism in protected ­ opportunities. Finally, promote rural areas, which often lack economic development ­ wastewater reuse in areas expected to be most affected by climate change, and where high ­ ­pumping costs currently make irrigation not economically viable (the European Commission reuse). has recently adopted a proposal for water ­ 42 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? Chapter 5 Conclusions This limited review of wastewater management in Danube region under European Union (EU) water policies shows that, despite several challenges, the UWWTD has indeed delivered ­ egion. The share of wastewater treated results for the people and environment in Danube r according to the Urban Wastewater Treatment Directive (UWWTD) requirements has shown major improvement since 2004, demonstrating the impact of massive investment efforts. As a result, in the past 20 years, there has been a noticeable emission reduction of ­ ­ utrients. Continued improvement can be expected proportional organic pollutants and n to an increase in compliance with UWWTD and other relevant water directives in newer states. Danube River Basin (DRB) member ­ The review points out several challenges associated with implementing the ­ UWWTD. Implementation capacity, key for optimal development of wastewater infrastructure and better absorption of EU funds, is often neglected and insufficiently p ­ repared. Necessary tariff increases, which are a consequence of investment in new infrastructure and related ­ O&M cost increases, trigger affordability issues for the bottom 40 (B40) percent of popula- tion in some countries, prompting a need to develop adequate subsidy and transfer mechanisms. The lack of necessary sectoral institutional reforms or sectoral adjustments to ­ prepare for a large investment cycle has resulted in lower than planned absorption of avail- ­ rocedures. able funds and delays in UWWTD compliance, triggering potential infringement p These challenges represent opportunities in implementing the current Directive within and ­ eview. The current implementation could be made beyond member states and its potential r more efficient using sound economic appraisal to prioritize investments according to their cost-effectiveness while maintaining public health and environmental benefits and ­ bjectives. Candidate countries can achievement of Water Framework Directive (WFD) o accession. Finally, learn from recent EU members and address relevant challenges before ­ an evaluation of the Directive could consider providing more flexibility to member states to optimize their urban wastewater policies by making use of cost-effective measures, efficiency. thus offering ways to improve the UWWTD’s economic ­ This note is meant to spur discussion—not provide all answers—because substantive work is still ­needed. Given the limits of available data regarding wastewater discharges, e ­ missions, investments, and water quality in the DRB, further work is needed to improve the assessment of the impact of the UWWTD implementation on surface water quality, public ­ benefits. Attempts to provide more flexibility health, and other social and environmental ­ implementing the Directive requires stronger institutional capacity, given the need for in ­ ­ ositive. reliable data and sound modeling, to ensure the impact remains p Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? 43 As the Danube region continues to converge with the rest of Europe, considering its particularities will benefit all ­ ­ parties. The Danube region—new member states and candidate countries—have demonstrated a strong commitment to meet the European acquis commu- ­ nautaire, ensure the health of their citizens, and protect and improve the quality of their bodies. The ongoing implementation of the UWWTD, the accession negotiations with water ­ candidate countries, and the review of the Directive offer opportunities for governments and the Commission to learn from past challenges and consider the region’s socioeconomic and environmental reality as they develop the policies, plans, and investment programs standards. necessary to meet the European wastewater management ­ 44 Is the UWWTD Implementation Delivering Results for the People, the Economy, and the Environment of the Danube Region? References European Commission. 2003. Economics and the Environment: The Implementation Challenge of the Water Framework Directive. Brussels, Belgium: European Commission. ———. 2007. Terms and Definitions of the Urban Waste Water Treatment Directive 91/271/EEC. Brussels, Belgium: EC. ———. 2010. DG Environment Compliance Costs of the Urban Wastewater Treatment Directive. Brussels, Belgium: EC. ———. 2014a. 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