To the kind attention of Members of ENVI Committee
RE: Recommendations on ENVI Committee vote on ‘Quality of water intended for human consumption. Recast’
I am writing to you on behalf of the European Alliance to Save Energy (EU-ASE). We are a multi-sectoral business organisation whose members have operations across the 28 Member States of the European Union, directly employ 340.000 people in Europe and have an aggregated annual turnover of €115 bn.
We welcome the collaborative and fast-paced work of the rapporteur and shadow rapporteurs on the recast of the Drinking Water Directive. The recast is a historic first step to fix the missing dimension of the water regulatory framework, which is the energy-water nexus. There is a huge energy savings potential in the water sector that must be untapped to secure that we meet the Paris Agreement. As technology and solutions providers in energy efficiency and water, we would like to highlight our support for the following provisions ahead of the forthcoming vote in the ENVI Committee.
Energy performance transparency requirements
The energy consumption of the EU water sector represents the equivalent of 3.5% of the EU electricity consumption. In municipalities, water and waste water facilities account for the largest consumption of electricity, representing 30-40% of local authorities’ total electricity bill. It is realistic to cut the energy use of the water and waste water sector by 50%, yet investments are below their cost-optimal levels. To untap this huge potential, a first step is to secure transparency on their energy performance. However, the state of the energy performance of the drinking water sector is not taken into consideration in the compromise amendments. This represents a missed opportunity for the drinking water sector to transition towards a more energy efficient and carbon-neutral operation and to attract investments.
An effective way to raise awareness about the energy performance and leakage reduction of the water supplier would be to make the information on the energy performance of water suppliers available online for the local governments and decision makers. Specifying the scope of the information requirement from raw water extraction to tap delivery, i.e. across the whole water supply chain, would enhance transparency on the energy use of the drinking water sector, build baseline of energy use for the detection of opportunities and be a driver towards a more energy efficient model.
Water leakage reduction target based on a common metric
A significant amount of energy and investment could be saved by monitoring and reducing water leakage, not to talk about precious water resource in times of water scarcity. Indeed, in the EU, energy to pump and distribute billions of cubic meters of water, that are lost through leaking pipes, is used in vain every day. We therefore support the introduction of provisions for Member States to introduce water leakage reduction targets, as outlined in Compromise Amendment 4 on the General Obligations of the Directive.
The European Commission estimates that, in average in the EU 23% of all treated water in public water supplies is lost within the distribution network as a result of leakage. In some municipalities, this figure can increase to 60%..
Mandated Member State targets to combat these water losses within the distribution system would provide the EU with improved economic returns for water operators, as well as a safer drinking water supply from an environmental perspective.
However, it is important that the establishment of Member State targets is based on a common metric – cubic metres of water/km of pipe per day. This would ensure that improvements in addressing the leakage are both measurable and comparable. Without such metric, there is a risk that Member States would create arbitrary targets that would have no meaningful impact on improving leakage rates.
Water leakage comprehensive assessment
We regret that in the compromise amendments Member State competent authorities may not be obliged to carry out a comprehensive assessment of the water leakage levels on their territory which includes all relevant public health, environmental, technical, economic factors.
Including all environmental, technical, health and economic factors in a comprehensive assessment will ensure that Member State competent authorities can maintain a holistic overview over all the factors that impact on the drinking water infrastructure.
We wish you a fruitful vote and remain at your disposition for further discuss the provisions above to your best convenience.
President of the European Alliance to Save Energy (EU-ASE)
 IEA (2016), WEO-2016 Special Report : Water-Energy Nexus
 IMPACT ASSESSMENT Accompanying the document Proposal for a Directive of the European Parliament and of the Council on the quality of water intended for human consumption (recast)