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Politiche di gestione delle acque reflue

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The considerations explained herein about the legal aspects of water utilization must be regarded as a concerned citizen's manifesto on water policies.

The following pages will be useful to water policy advisors and decision-makers, particularly in many parts of Europe and North America, as well as in those regions of the world that may be tempted to reproduce unsustainable supply and sanitation techniques. Arid and semi-arid regions of the world are traditionally and naturally more sensitive to the significance of rainwater harvesting, and it is to be hoped that official policies in these regions will be more in line with this concern: therefore, the considerations herein may (or may not) apply to those regions.

Managing one’s water as per the EAUTARCIE concept is more than a simple technical option: it is a social choice expressing a highly political standpoint. As such, the system’s prime quality is to conduce to a school of responsible management.

The text within this page was first published in French on www.eautarcie.com:
in 2003

The original text has since been adapted and was first published in English on this page at www.eautarcie.org:
2010-04-20

Last update: 2010-04-20

Politiche di gestione delle acque reflue

Analysis of Official European Policy on «Integrated Wastewater Management»

As a case in point, let’s look at the different measures most often recommended and/or required in Belgium, to «better prevent pollution», as expressed in a booklet published in 2003 by the Walloon chapter of the World Wildlife Fund (WWF). They are representative of what is being propounded elsewhere in Europe and North America.

«Prioritizing individual wastewater treatment set-ups»

While official set-speeches encourage the implementation of individual wastewater treatment set-ups, official regulations in sewered areas under authority of the Walloon Region’s GMDPs [1] do not.

[1]
GMDP = General Municipal Drainage Plans» (or PCGE = «Plans communaux généraux d’égouttage»)

The GMDPs demand that at least 90% of housing be connected to the sewerage network, an absurdity when you consider the catastrophic environmental performance of conventional sanitation [2]. For the environment’s and taxpayers’ sakes, centralized sanitation should be limited to traditional urban centres where, short of a complete overhaul of water policies, cities remain tributary to this major environmental nuisance. In Wallonia (as is now called the Walloon Region of Belgium), urban centres with high density (high-rise) housing only represent about 25 to 30 % of all housing.

Areas reserved for individual wastewater treatment systems only represent 5 to 10% of Walloon housing. If the purpose were to be environmental protection, you would seriously need to downgrade the scale of sewered areas.

«Requiring separate sanitary and storm sewerage networks in both public and private realms»

The implementation of separate sewerage systems (storm vs. sanitary) aims to prevent dilution of sewage by stormwater. True, wastewater purification efficiency is affected by such dilution, but preventing dilution doesn’t necessarily improve the quality of treated wastewater effluent [3]. Separate sewer systems are deemed to be the consummate technique by sanitation plant technicians. Even if the efficiency of this approach remains quite dubious, sewerage corporate revenues can practically double by this means.

[3]
I’ve had the opportunity of observing analyses of water entering and issuing from a certain number of sanitation plants in the Walloon region. In many instances, the wastewater entering the plants already complied with discharge standards, due to dilution by stormwater. The water issuing from the plant is necessarily better than what went in. It nevertheless stands that the standards regulating the quality of wastewater discharged in a watercourse are rather lax and do not provide an efficacious protection for the aquatic milieu. They were established according to the collective purification techniques available at the time. The possibility of not discharging wastewater into rivers has not even been envisaged. And yet, in more than half the instances, discharge into a watercourse could have been avoided, which would have provided a much greater environmental protection.

Consequently, the creation of separate sewerage networks cannot be warranted by pleas about environmental protection, but can only be based on judicial reasonings. Indeed, sanitation corporations are obliged by law to comply with a relatively high purification efficiency, concurrently with lax discharge standards. To attain the required purification efficiency, sanitation plants operators can only benefit from highly polluted wastewater at the plant’s inlet. Nevertheless, a more heavily laden wastewater entering the system means a lesser quality water discharged from the plant, whatever the technique used.

In peri-urban zones, to be truly efficient, discharge of residential wastewater into sewers should be prohibited. Sewers should be reserved exclusively for roadway stormwater runoff. The indications in the present website highlight the fact that in these zones, wastewater can be treated in homes’ gardens (or «yards»). When using a proper dry toilet, no pollution is produced. And even if you were to maintain flush toilets while selectively treating the black water in situ, the negative environmental impacts would be much less than for sanitation plants. As to rainwater falling on roofs, its place is in a cistern [4]. Thus, it no longer becomes necessary to double reticulated sewerage networks, and roadway stormwater would only require a really inexpensive primary treatment (screening and deoiling). After going through a retention basin (like a stormwater basin), this water would be no more harmful than mains water discharge.

[4]
This elementary truth is far from integrated in official water policy, as can be witnessed on the data sheet that was published in March 2003 at the «Journée Mondiale de l’Eau» (an annual symposium on water management, in Poitiers, France)

«Implementing separate sanitary and storm collectors, and individual (or collective) wastewater treatment stations for all government buildings»

As established above, extending separate sewerage networks is unwarranted. It can only hamper efforts to get us out of the «all to the sewer» mentality. For buildings, it is the most inefficacious solution. Water falling on the roof must go into a cistern, not a sewer, be it separate or combined. Otherwise, we are wasting an available resource, disrupting the hydric regimen of rivers and circumventing the indispensable replenishment of ground waters.

Government buildings (in zones of individual wastewater treatment as is intended in this case) should be equipped with rainwater cisterns. If there are to be separate drainage systems for the buildings, it should be restricted to grey water and black water. Grey water produced within these buildings could be infiltrated directly into the ground, without treatment, with an appropriate dispersal system or absorption pit. As to black water, it becomes necessary to implement ultra-low flush toilets and convey their effluent to septic tanks. This sludge could be used to impregnate carbonaceous litter obtained from the shredding of branch cuttings from public park and tree maintenance in and around cities, in order to produce high-quality compost for city residents. Moreover, this type of collective composting system could absorb the organic portion of domestic waste (representing 45% of all domestic garbage) including soiled paper, other plant wastes (autumn leaves) and even shredded cardboard packaging. This is the integrated approach to water and biomass management. Of course, none of this is addressed in official policy-making.

«Providing all new housing with separate sanitary and storm sewers, even when situated in areas serviced by combined sewers»

Obviously, the idea of separate storm and sanitary sewers is a recurrent «idée fixe». All this would make no sense with more widespread rainwater harvesting. With a properly sized cistern, the experience of tens of thousands of families using rainwater for all household uses has shown that the rainwater cistern’s overflow practically never serves.

«Promoting the use of compost bins to help generate compost as an alternative to synthetic fertilizers»

One can only rejoice that there is a will to encourage garden composting. However, the problem lies in the recommended (and incorrect) technique of composting in an enclosed plastic bin. The aerobic transformation of organic waste is best done in symbiosis with soil organisms. Composting apart from the soil is just as environmentally unadvisable as are food production and livestock raising done apart from the soil: nitrogen is transformed into nitrates to varying degrees, and humus is not created (or very little).

Composting is an art that is easy to learn, but you need to know the basics, which quite obviously, many qualified agricultural engineers don’t yet master. Read more on the elementary rules of composting at the chapter on composting human dejecta.

«Installing collective compost bins at central city locations»

This is a first step in the right direction, but it would be infinitely more efficient to organize the selective pick-up of organic domestic waste, especially in urbanized sectors, like what is done in the province of Nova-Scotia, in Canada (where this is called «curbside collection for centralized composting»). Once this type of program is put in place, there is only one short step needed to include the composting of dry toilet effluent, as is already done in some Norwegian cities.

One can only be revolted by the piles of garbage bags filled with grass clippings and fallen leaves that are often witnessed on curbsides. This biomass is part of the ecosystem that sustains us! Note that bringing your organic waste to a central «compost bin» [5] supposes a certain motivation that the vast majority or the public does not yet have.

[5]
Here, the term «compost bin» is slightly incorrect. It is rather a collection bin for organic waste. There’s still a long process before the organic waste actually becomes compost.

«Educating the population on the correct use of chemical fertilizers»

If there is something to make people aware of, it’s to not use chemical fertilizers! A deterrent tax on the purchase of such products would even be better. Home gardening for food and flowers doesn’t represent a livelihood. One can understand – if not accept – the use of fertilizers by farmers or market gardeners whose livelihood depends on crop production. But there is no excuse for home gardeners.

«Implementing integrated programs aimed at reducing pesticide use»

Once you use properly prepared compost for your garden, experience has shown that the need for phytosanitary products is reduced. And anyway, these «integrated plans» serve no purpose if there is no fiscal penalty applied for polluting. If you don’t rigorously apply the polluter-pays principle, these «integrated plans» are of no better use than cheeseparing.

«Each citizen whose home is not connected to a sewerage network is expected to put in place an individual wastewater treatment set-up»

This statement contains all the incoherence of European water policy. The obligation to implement sanitation in cities and other inhabited regions is proclaimed in the European Community Directive 271/91. In fact, article 1 of the Directive asserts the aim of protecting the environment, while article 3 prioritizes the obligation of centralized sanitation [6]. After having read the pages on conventional sanitation, you come to understand why centralized wastewater treatment is contrary to the notion of environmental protection. Normally, environmental organizations like the WWF would be expected to vigorously denounce such contradictions. Yet only the Belgian chapter of Friends of the Earth has taken a position that is in line with the considerations of the present website. Unlike the WWF, Friends of the Earth [7] does not receive support from the European Council and other official bodies.

[6]
Article 1, 2nd paragraph states: «The objective of the Directive is to protect the environment from the adverse effects of the abovementioned waste water discharges.» Article 3, 1st paragraph states: «Member states shall ensure that all agglomerations are provided with collecting systems for urban waste water. » The expressed purpose of Article 1 is not to apply wastewater treatment at all cost, but rather to reduce negative environment impacts upstream and downstream from the actual treatment, which – as we rightly know – does not carry the same meaning as Article 3.

Add to this the truncated transposition of the Directive, whereby provisions included in part of Article 3 have unfortunately not been included into Walloon law. Article 3, 3rd paragraph, states: «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.»

By omitting this provision, authorities can continue applying scientifically outdated sanitation practices, which’s ultimate goal is not environmental protection, but sanitation. In so doing, Walloon authorities have legislated for lesser protection than provided in the original intent.

These omissions are defended by specialists (working mainly for business and industrial sectors) in order to impose conventional sanitation, against all environmental and economic logic. Their basic premise, which is totally false, is that efficacious wastewater treatment is automatically the best means to protect the environment. Scientifically, this assertion is only true in very exceptional circumstances. In the vast majority of cases, the opposite occurs: the more you treat wastewater, the more you harm the environment.

[7]
Amis de la Terre a.s.b.l.(Friends of the Earth – Belgium), 1, Place de la Vingeanne B-5100 Dave – Belgium. Tel.: 0032(0)81.40.14.78; fax: 0032(0)81.40.23.54; site web: www.amisdelaterre.be.

«Implementing an integrated plan for flood prevention by means of natural wetlands for stormwater retention and storage»

A truly integrated approach would exclude sewerage networks from rural and even peri-urban zones. Indeed, the quantity of wastewater produced by a community and discharged by way of the sanitation plant into a watercourse is equivalent to a small river, which’s flow-rate is added to that of the watercourse in spate.

The absurdity of taxing water and at the same time not seeking to encourage the practice of rainwater harvesting has another consequence: roof runoff is commonly sent back to rivers, and since it is conveyed through sewers, this water is of no use for the replenishment of the water table.

The «all to the sewer» approach aggravates present-day drops in water tables. In Wallonia, the groundwater take-up rate is about 85% - in an area where groundwater reserves are deemed plentiful [8]. This means that 85% of the water that infiltrates into ground reserves is taken up and distributed. The safety factor is thus relatively slim. Considering predictions on climate change, which suggest lower groundwater replenishment rates, one can surmise that we are looking at mid-term water shortages. Each litre of water discharged through the sewers will aggravate this. Even if collective centralized sanitation were not so environmentally harmful [9], the simple fact that the soil moisture regime is disrupted should be cause enough to consider conventional sanitation to be incompatible with the concept of sustainable development. This is the strong point that should be actively defended by environmentalist organizations like the WWF. That is unfortunately not the case…

[8]
État de l’environnement wallon 2001 (The State of the Walloon Environment 2001). Published by the DGRNE = Direction Générale des Ressources Naturelles et de l’Environnement (Environmental and Natural Resources Authority).
[9]
…notably due to pollution of rivers by treated wastewater discharge, and pollution of groundwaters by sewage sludge, and not forgetting the unbalance created on Nature’s great cycles by the massive destruction of our organic biomass. For further reading on this, go to chapters on dry toilets and composting of human dejecta.


The implementation of the recommended stormwater basins is like putting a plaster on a wooden leg! If there were one efficient measure that should be applied to prevent flood damage, it would be to revise zoning boundaries in order to forbid construction of houses in flood plains.

«Abiding by municipal regulations on compliance with domestic wastewater discharge standards»

It’s no use setting up municipal regulations when regional and state laws are so ill adapted that they cannot ensure the environment’s protection. About individual treatment systems, we can even conclude that letting us do anything (except discharging wastewater into a watercourse) is much more effective for environmental protection than the best individual electromechanical wastewater treatment systems.

If there is a rule to edict at the municipal level, it’s to formally prohibit domestic wastewater discharge in surface waters or even in sewers. This should only be authorized when it is technically impossible to do otherwise.

«Government procurement of land situated in protected watershed zones»

This is an extremely expensive measure, which is quite ineffectual. It would require government expropriation of homes situated in the watershed zones, which would come up against legal difficulties. Acquiring a few hectares of uninhabited land will not change the situation, unless it involves farmland. And acquiring farmland will come up against certain laws.

An effective measure would be to only authorize biological or organic farming in watershed zones, and to closely monitor farming activities. As for housing, homes will continue to pollute the water table, even and especially if they are forced to comply with laws on individual wastewater treatment. The type of home sewage treatment plant recommended by authorities, which infiltrates wastewater into the ground after it has gone through an activated sludge process, ends up polluting because it works so well. Elementary damage control for this specific type of set-up (which infiltrates nitrate-rich effluent into the ground) would be to disconnect the electrical components of the system. This would mean less groundwater pollution, and electrical energy savings [10].

[10]
Knowing this, you can rightly wonder what these set-ups are useful for, except to cost households 500 to 600 €. A simple trench in the ground laced with selected plants would be less polluting, at a negligible cost.


Ideally, the only treatment systems that should be authorized are those that present a satisfactory environmental life-cycle performance. In the assessment of this performance, the purification efficiency is altogether secondary and even insignificant, especially when infiltrating the effluent in the ground (which is preferable). The assessment of a system should concentrate on evaluating the annual quantity of nitrogen that is released within the liquid effluent and the sewage sludge. The application of these criteria would inevitably lead to the banning of all such electromechanical set-ups. The modus operandi of such mini-sewage treatment plants is incompatible with the notion of sustainable development.

«Propounding receptiveness to environmentally-friendly alternatives that prioritize prevention rather than correction»

Of course, the present website describes a few environmentally friendly alternatives. Yet the WWF booklet that so clearly expresses official policies remains totally silent on obvious solutions like rainwater harvesting and dry toilets, the latter being a fundamental factor in the prevention of water pollution. These two simple measures would do more to alleviate water problems than all the recommendations found in the booklet.

For further reading on these matters, go to chapters on Ecological sanitation.

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