REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Seventh Report on the Implementation of the Urban Waste Water Treatment Directive (91/271/EEC)
Date: 2013-08-07
Institutions: European Commission
Subjects: application of EU law, urban area, wastewater, water pollution, water protection, water treatment













EUR-Lex - 52013DC0574 - EN











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52013DC0574

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Seventh Report on the Implementation of the Urban Waste Water Treatment Directive (91/271/EEC) /* COM/2013/0574 final */









TABLE OF CONTENTS
1........... Introduction.................................................................................................................... 3
2........... Overall compliance assessment....................................................................................... 4
2.1........ Collecting systems.......................................................................................................... 4
2.2........ Secondary treatment....................................................................................................... 5
2.3........ More stringent treatment................................................................................................. 5
2.4........ Big cities/big dischargers................................................................................................. 8
2.5........ Sensitive areas................................................................................................................ 8
3........... Trends in compliance...................................................................................................... 8
4........... Past and future pollution
reduction................................................................................... 9
5........... Improvement through co-financing................................................................................. 10
6........... Past compliance action.................................................................................................. 11
7........... The “new approach” for compliance promotion............................................................. 11
8........... Conclusions and outlook............................................................................................... 12
1.           Introduction
The Urban Waste Water Treatment Directive[1] (hereinafter referred to as “the
Directive”) is one of the major water policy tools in Europe. Its objective is
to protect the environment from the adverse effects of discharges of urban
waste water from settlement areas (cities/towns) and of biodegradable
industrial waste water from the agro-food sector (e.g. milk processing industry,
meat industry, breweries etc.). The Directive requires the appropriate
collection of sewage and regulates discharges of waste water by specifying the
minimum type of treatment to be provided and setting maximum emission limit
values or the major pollutants (organic load and nutrients)[2]. Full implementation of the Directive is a pre-requisite for
meeting the environmental objectives set out in the EU Water Framework
Directive (WFD)[3] and the Marine Strategy Framework Directive[4]. 
Implementation of this Directive has been challenging
mainly because of the financial and planning aspects related to major
infrastructure investment such as sewerage systems and treatment facilities.
Low levels of implementation can lead to organic pollution in rivers and lakes
and also to the accumulation of excessive nutrient loads (eutrophication)[5] especially affecting lakes, coastal
and marine waters which are particularly sensitive. According to the recently
published WFD implementation report[6], point
source pollution was still a significant pressure in 22% of EU water bodies.
Eutrophication remained a major threat in about 30% of water bodies in 17
Member States. Untreated or insufficiently treated waste water discharges
significantly contribute to these problems. 
Wastewater pollution can also accelerate biodiversity
loss and deteriorate drinking water supplies or bathing waters, causing public
health concerns. These include outbreaks of water-borne diseases, especially
linked to small water supplies, diseases due to exposure to contaminated
bathing water (organic pollution, pollution by algal bloom due to excess of
nutrients) or the consumption of contaminated seafood, etc. These impacts may
also entail negative consequences for economic sectors such as the tourism or the
shellfish farming industry[7].

The implementation efforts of the Member States have
already led to significant improvements in waste water treatment. As a
consequence, water quality in Europe has improved significantly in recent
decades and effects of pollutants have decreased[8].
However, implementation is far from being completed and pollution problems
persist. 
The Commission proposal for a 7th
Environmental Action Programme (7th EAP)[9] and the new “Blueprint to
Safeguard Europe’s Water Resources”[10]
recognise the importance of this Directive and underline that re-enforced
action is necessary to secure its successful implementation. 
This 7th Report on the implementation of the Directive
describes the progress made up to the end of 2009/2010. The Report also
includes trends in compliance and presents the new approach for
"compliance promotion" and its steps towards public information and
reporting. In addition to this Report, an Annex with Tables[11] and a more detailed technical
"Report"[12] is available. The gaps between data reported and the publication of
this report are intrinsic to the way in which data management between the Commission
and the Member States was organised in the past. The Commission services are
therefore proposing a “new approach” also in relation compliance information
and encourage Member States to provide more up to date information online at
national level (see point 7).
2.           Overall
compliance assessment
The compliance assessment has the objective to analyse
the degree of compliance with the Directive, on the basis of information which Member
States provide. It is based on the application of guidelines and methodology available
in EEA's Reportnet[13].
The reported data on wastewater infrastructure is available from water info
Waterbase of the Water Information System for Europe (WISE) for the reported
settlements and their treatment plants.[14]
This reporting exercise on the implementation of the
Directive has been a success. For the first time, 27 Member States have
provided information for the report and all largely on time. The report covers
almost 24000 towns and cities of more than 2000 inhabitants (generating
pollution corresponding to a population of 615 million, so called
population-equivalents[15]). Almost 18000 towns and cities (or 81% of the pollution load) are
in the 15 Member States which joined the EU before 2004 (EU-15). The remaining
are in the 12 Member States which joined the EU in 2004 and 2007 (EU-12). The
compliance assessment was carried out for 26 Member States given that for Romania, none of the compliance deadlines agreed in their Accession Treaty had expired by
2010. Croatia joined the EU on 1st July 2013 and therefore was not
included in this reporting exercise.
For several other Member States that joined in 2004 or
2007, additional compliance deadlines expired during the reporting period for
this report. However, many of their towns/cities will have to comply with
deadlines of 2010 and later and therefore have not been assessed in this
report. 
The main results of the implementation analysis are
summarised below (for details per Member States, see table 1 in the Annex,
which also includes detailed information on expired deadlines in the 12 Member
States joining the EU in 2004/2007).
2.1.        Collecting
systems 
Most of the EU Member States collect their waste waters
at very high levels with an average rate of compliance equal to 94% (up from
92%). Some 15 Member States even reach compliance of 100%. All Member States
have either maintained or improved on previous results. However, there are
still countries where there is either no or only partial collection of sewage. Five
Member States still had compliance rates below 30% in 2009/2010 (BG, CY, EE, LV, SI).
2.2.        Secondary
treatment
In 2009/2010, a total of 82% of the waste waters in the
EU received secondary treatment complying with the provisions of the Directive,
four percentage points up from the previous Report. Four Member States reached
100% compliance and another six Member States had levels of compliance of 97%
and higher. However, the compliance rates in EU-12 Member States are trailing
behind significantly with only 39% of their waste waters receiving appropriate
secondary treatment. Only CZ, HU, LT and SK achieved compliance results between
80-100%.
2.3.        More
stringent treatment
This type of treatment of waste waters, also known as
tertiary treatment, complements the secondary treatment when needed and is
mostly targeted at the elimination of nutrients to combat eutrophication or
reduce bacteriological pollution that might affect human health (such as for
drinking water zones or bathing waters)[16].
There was an overall compliance rate of 77%. However there were particular
delays in implementation of more stringent treatment in EU-12 Member States
where only 14% of waste waters are treated appropriately. On the positive side,
four countries reached 100% compliance. 
Figure 1: Compliance results
at EU-27, EU-15 and EU-12 level regarding article 3 of the Directive
(collection), in green, article 4 (secondary treatment), in pink and article 5
(more stringent treatment), in blue. Average values are reflected, weighted by
size of MS.
Results at EU-27, EU-15 and EU-12 level are reflected in
Figure 1[17].

Values at EU-15 level are, in general, high, and even
very high in countries such as Germany, Netherlands and Austria. EU-12 results are rather low, especially as regards more stringent treatment. 
Values at EU-27 level are also high and quite similar to
EU-15 values (even though slightly lower), due to: 
a) The relatively higher relevance of figures on
collection and treatment by EU-15 countries. At EU-15 level, all the deadlines
for compliance are expired and therefore the amount of waste waters subjected
to compliance is large, also being the related compliance results high.
b) The lower relevance of figures on collection and
treatment by EU-12 countries, where compliance results only regard to part of
their towns/cities, i.e, those subjected to compliance by 2009/10.
Figure 2:Compliance results
per Member State regarding article 3 of the Directive (collection), in green,
Article 4 (secondary treatment), in pink and article 5 (more stringent treatment),
in blue. Countries are classified showing first those having lowest compliance
levels for article 5, and then in increasing order of compliance. In Slovakia (art 5) and   Romania (arts 3, 4 and 5), the concept "installations in place" is
represented instead of compliance, as the deadlines for those articles had not
expired yet by the reported year (figures on compliance were not requested, but
MS reported the waste water collected and treated). In Cyprus and Latvia compliance results were equal to 0% because the collecting systems and treatment
plants were not fully operational yet in the reported year(2009).; however, significant
progress has been made since then and recent compliance rates are much higher.
National results in Figure 2 refer to data and the
situation in 2009 or 2010 at the latest. The Commission services are aware that
in many Member States, in particular those with low compliance rates,
significant progress has been made since then and actual compliance rates are
often (much) higher (in particular in Cyprus and Latvia).
2.4.        Big
cities/big dischargers
There are 585 big cities identified in this Report, which each
produce waste water equivalent (or higher) to a population of 150000. The
pollution load that is produced by these big cities alone is 45% of the total
load collected. Out of these 585 big cities, approximately 91% of the pollution
load receives more stringent treatment (best available treatment). This is an
improvement in comparison to the previous report where only 77% of the relevant
pollution load received such treatment. However, the degree of compliance
varies significantly amongst big cities/big dischargers. 
To give an example, only eleven of the 27 capital cities[18] of the EU Member States can claim
"full compliance" in 2010 even with the most stringent treatment
requirements, when applicable (see Table 2 and comments in Annex for details on
EU capitals). 
2.5.        Sensitive
areas
The share of EU territory designated or considered as
sensitive area has increased since the previous report reaching almost 75% by 2010.
The most relevant increases took place in France and Greece. Details of
sensitive areas in EU- Member States are available in the WISE mapviewer.[19]
3.           Trends
in compliance
An assessment of progress towards full compliance of all
MS must distinguish between the EU-15 and those Member States having joined in
2004 and 2007. The compliance requirements have regularly changed mainly due to
enlargements and with the staged transitional periods in the Directive which
have expired. All deadlines for the EU-15 expired by 31 December 2005, but for
the EU-12 these will continue to expire with the last and final deadline expiring
in 2018. Only data from EU-15 Member States are available until 2004. As a
result, the measurement of progress for all 27 Member States level has only
been possible since the 5th Report (2005/2006). Bringing all the results
published by the previous Commission reports together, an indicative compliance
rate increase can be demonstrated. There is just one exception: the decrease
from the 5th to the 6th Report resulted from the fact that a number of Member
States with the poorer implementation results did not send the necessary
information for inclusion in the 5th Report (2005/2006). Despite this, it is
positive to note that there is an increase in the trend from the 6th Report
(2007/2008) to the 7th Report (2009/2010), as EU-12 Member States have had
compliance obligations/deadlines for the first time, but these have not lowered
the overall positive results. 
Figure 3 Compliance rate over
years: this Figure reflects the evolution of compliance on collection,
biological or secondary treatment and more stringent treatment, throughout the
several different Implementation Reports (the second Report onwards), in the
respectively reported years (1998 until 2009/2010). Not all the results were
available in all the Reports: when missing, values cannot be shown on the
Figure and a discontinuity in the "trend line" appears.
4.           Past
and future pollution reduction
The Commission has also assessed the pollution reduction that has
occurred as a result of the implementation of this Directive and the expected
reductions in the coming years in a situation of full compliance. This was done
as part of the FATE[20]
project (related to the assessment of fate and impacts of pollutants in
terrestrial and aquatic ecosystems). 
In 2011/2012, the Commission's Joint
Research Centre (JRC) published two reports[21]
which looked at the pollution loads and reductions as a result of several EU
policies (including the Water Framework Directive, the Nitrates Directive and
the Urban Wastewater Treatment Directive) in the past (1985-2005) and the expected
loads and reductions (until 2020 with reference year 2005). 
As regards the nutrient reduction in the past, the Urban
Wastewater Treatment Directive was successful in controlling point source
emission of nutrients and thereby reducing the inputs in Europe’s surface
water. This is described in one of the above-mentioned JRC reports: "Long
term nutrient loads entering the European Seas". According to this report,
comparing the estimates of nutrient loads for 2005 with
those of 1991 at European continental scale, the total nitrogen export had
decreased by 9%, while the total phosphorus load had decreased by around 15%,
mainly due to a decrease in point source emissions. It was also stated in the
Report that in the North Sea and in the Baltic Sea, the decrease was mainly
related to the reduction of point sources due to the implementation of advanced
waste water treatment. 
As regards future trends under the "business as usual"
scenario (assumption: no nutrient mitigation measures have been applied), one
of the main conclusions of this report was that this scenario would result in
an increase of land based nutrient emissions by year 2020. If now the full
implementation of the Urban Wastewater Treatment Directive (UWWTD) is assumed,
significant reductions of point source emissions would be reached. In some
parts of Europe, however, full implementation of the UWWTD could also result
(as a first step) in an increase of point source emissions from non-collected
emission, in particular in the lower Danube basin. This is because small
agglomerations without drainage systems would receive a more organised
collection and discharge resulting in new point sources that do not exist at
the moment. Whilst this may reduce the effectiveness of the nutrient reduction
to the Black Sea, it still would lead to environmental improvements such as
reduced groundwater pollution which was not assessed as part of the study. 
In preparation of this implementation
report, a specific calculation was carried out in relation to the pollutant loads generated from the non-compliant fraction of
waste water from towns/cities (estimation of "distance to compliance").
It did not take into account the towns/cities still
without compliance obligations (i.e. where the deadlines in the Accession
Treaties had not expired yet in 2009 or 2010, the last year reported by Member States).
Based on these estimations, the total annual pollution loads originating from
urban waste water in breach with the Directive were approximately of 603 kt/y[22]
of nitrogen, 78 kt/y of phosphorus and 3900 kt/y of total organic pollution[23]. 
When comparing the above-mentioned figures
with the estimated annual total load of nutrients entering the European Seas
(nitrogen and phosphorus), in the JRC Report "Long term nutrient loads
entering the European Seas", the nitrogen generated by the non-compliant
fraction of waste water approximately reaches 15% of the total nitrogen
discharged into the seas. Regarding phosphorus, the ratio is even higher,
reaching 35% of total phosphorus. Such ratios prove the relevance to fully
implement the Directive all over the EU. 
Overall, the above-mentioned JRC report
concludes that "mitigation of point sources of nutrients is the most
effective option to reduce nutrients export to European Seas. However,
feasibility of this latter is relatively low and further reduction of nutrient
emitted as point sources will involve important costs".
5.           Improvement
through co-financing
EU funds can be used to assist in the
implementation of the Directive, in particular the Cohesion Fund and European
Regional Development Fund (ERDF) which help those regions lagging behind or
facing structural difficulties in achieving sustainable development. These
Funds have significantly supported Member States and the regions to invest in
the needed infrastructures for waste water treatment over several programming
periods. The financial support for investments in waste water related works and
infrastructures was planned to be about 14.3 billion € in 21 Member States in
the current programming period 2007-13. It is mainly, but not only, the
"new" Member States that have allocated the largest shares of their
funding into waste water treatment. During the reported years 2009/2010, the
total cumulative allocated funds in the category "waste water" was
3.5 billion € for 2009 and 9.7 billion € for 2010. The Member States with
highest cumulative allocated amounts were Poland (3.3 billion €), Romania (1.2 billion €) and Hungary (0.6 billion €). 
Despite the significant support from EU
funding, the "Fitness check of EU freshwater policy" underlined that
the majority of funds necessary to implement EU water policy needs to be
generated within the Member States. According to a study[24] of 22 Member States, there is
still a significant financing gap in relation to future compliance with the
Directive in those Member States.
The main reason for this financing gap is
that progress towards achieving cost recovery from water users and
implementation of the polluter pays principle, as required by the Water
Framework Directive (WFD), have been slow and insufficient in most Member
States. To encourage such water pricing policies, the Commission has proposed
some ex ante conditions, including the WFD requirements on water pricing which
Member States need to fulfil in the future EU Cohesion Policy (2014-2020) for
the financing of projects in the water sector.
6.           Past
compliance action
The Commission has tried to ensure compliance through
continued dialogue and, where necessary, also through the launching of
infringement procedures, some dating back to 1997. To date, approximately 20
horizontal grouped cases[25] against 10 of the EU-15 Member States are still open.
The recent policy evaluation in the "Fitness check
of EU freshwater policy"[26] concluded that the effectiveness in the implementation of the
Directive has been positively affected by the infringement procedures speeding
up implementation. Even though enforcement action at EU level is a relatively
slow and time-consuming process, the majority of cases have been resolved in
the pre-litigation phase.
Some successful examples are France (cases with 682
towns in breach launched in 1998 and 2000) and Belgium (175 towns/cities originally
in breach in a case launched in 1998). In both examples, practically all the
above-mentioned towns/cities are now compliant. Also in Italy 475 towns/cities were in breach when the procedure started in 1998; now only 110
remained in breach when the Court ruling was issued. In addition to these three
countries, Spain and Greece have made the most progress since the last
reporting exercise amongst those Member States for which infringement
procedures are pending, in particular as regards the treatment obligations. 
7.           The “new approach” for compliance promotion
Despite the encouraging signs of progress, there is
still a significant implementation gap, in particular in the Member States that
joined the EU in 2004 and after. It now is becoming clear that without
re-enforced efforts at EU, national, regional and local level, the
implementation delays in these “new” Member States will be as long as or even
longer than those in the EU-15 Member States. The prospects of achieving the
necessary progress, solely through infringement procedures, are not
encouraging. Taking into account the current crisis and the increasing
constraints of national budgets, the Commission has identified this Directive
as a candidate to launch a pilot initiative for a “new approach” in promoting
compliance and implementation. 
This “new approach” is set out in the proposed 7th
Environmental Action Programme (EAP) and the “Blueprint
to Safeguard Europe's Water Resources”. The priority objective 4 in the 7th
EAP “To maximise the benefits of EU environment legislation” proposed to carry
out specific actions[27],
in particular: 
·                        
Establishing systems at national level which
actively disseminate information about how EU environment legislation is being
implemented, coupled with an EU-level overview of individual Member States’
performance (a so called "Structured
Implementation and Information Framework" (SIIF)).
·                        
Drawing up partnership implementation agreements
between Member States and the Commission. 
The Water Blueprint has established the objective “to improve compliance rates on waste water treatment by 2018 through
long-term investment planning (including EU funds and EIB loans)”. In practical
terms, the Blueprint announced that the Commission will cooperate with Member
States to prepare implementation plans, which can take the form of partnership
implementation agreements, by 2014. 
The Commission services have started developing these
actions with a workshop[28]
in December 2012 and will report progress regularly. 
8.           Conclusions and outlook 
Nearly 20 years after the adoption of the Urban
Wastewater Treatment Directive, significant progress towards full
implementation was achieved by 2010. For the EU-15, average compliance rates
are 88% for secondary treatment and higher for collection systems and more
stringent treatment (97 and 90% respectively). The frontrunners Austria, Germany and the Netherlands have largely implemented the Directive with several others
being very close to it. For them, the priority will be to maintain and renew
the existing infrastructure. Moreover, since 2010, further investments took
place in those EU-15 Member States with delayed compliance, also as a result of
the Commission’s infringement actions. With continued efforts over the coming
years, it is possible to (largely) complete implementation successfully in
those 15 Member States by 2015 or 2016. This would be 10 years after the expiry
of the last deadline in the original Directive. 
The picture is different for those Member States which
have joined the EU in 2004 and later. Their distance to target is still
considerable with average compliance of 72% for collecting systems and 39% and
14% respectively for secondary and more advanced treatment. Without increasing
efforts at all levels, expected delays can be similar or longer than those for
EU-15 which would bring the laggards in implementation in line with the
Directive as late as 2028. 
Another area of concern is the lack of compliance in a
significant number of “big cities”. E.g. only eleven of the 27 EU capitals have
a collecting system and treatment in place which is complying with technical
standards of more than 20 years ago. Given the high pollution load of these big
discharges, this causes still considerable environmental pollution. 
This 7th Implementation Report includes, for
the first time, a detailed assessment of compliance for 27 Member States. The
reporting infrastructure established within the Water Information System for
Europe (WISE) is working well. The process has been improved and the timelines
for data processing and assessment significantly shortened. However, in some
Member States further improvements in the monitoring and reporting system are
still possible. These explain some of the low implementation levels or
inconsistency of data over the various reporting exercises.
The proposed 7th Environment Action Programme
and the Blueprint to Safeguard Europe's Water Resources
underline the importance of collecting and treating urban wastewater. The
Commission announced in these recent policy initiatives that it will further
increase its support to Member States in their implementation efforts by
promoting a “new approach” for reaching compliance. In December 2012, the
Commission services started these “new approach” activities with the aim of
encouraging Member States to establish or revise implementation plans at the
latest by 2014. 
[1]               Directive 91/271/EEC, OJ L135
of 30.5.1991.
[2]               For more details on the
scope, objectives and provisions of the Directive, see: http://ec.europa.eu/environment/water/water-urbanwaste/index_en.html.
[3]               Directive 2000/60/EC, OJ L327
of 22.12.2000.
[4]               Directive 2008/56/EC, OJ L164
of 25.6.2008.
[5]               Eutrophication means the
“enrichment of water by nutrients, especially compounds of nitrogen and/or
phosphorus, causing an accelerated growth of algae and higher forms of plant
life to produce an undesirable disturbance to the balance of organisms present
in the water and to the quality of the water concerned”.
[6]               For more details, see http://ec.europa.eu/environment/water/water-framework/implrep2007/index_en.htm#third.
[7]               For more details: EEA (2010):
The European Environment – State and Outlook 2010 – Freshwater Quality.
[8]               For more details: EEA (2012):
European Waters-assessment of status and pressures.
[9]               COM
(2012) 710 final. For more details, see http://ec.europa.eu/environment/newprg/pdf/7EAP_Proposal/en.pdf.
[10]             COM
(2012) 673 final. For more
details, see
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2012:0673:FIN:EN:PDF.
[11]             SWD(2013)
298
[12]             7th Technical assessment of
information on the implementation of Council Directive 91/271/EEC of 21 May
1991 concerning Urban Waste Water Treatment as amended by Commission Directive
98/15/EC of 27 February 1998.(Situation as of 31 December 2009 or 31 December
2010).Drafted by Commission's consultant Umweltbundesamt GmbH (Austria).
[13]             For
more details, see http://rod.eionet.europa.eu/obligations/613.
[14]             http://www.eea.europa.eu/data-and-maps/data/waterbase-uwwtd-urban-waste-water-treatment-directive-3.
[15]             The term "population
equivalents" or p.e. can be found in the Directive and covers the organic
pollution generated mainly by the inhabitants of a village/town, and other
sources such as non-resident population (tourists) and agro-food industries.
[16]             In addition, tertiary treatment
technologies (e.g. ozonation, chlorination, UV, membrane technologies, sand
filters, are widely discussed as one of the most promising options for the
mitigation of micro-pollutants (emerging contaminants, including
pharmaceuticals and personal-care products, other industrial chemicals)
entering the aquatic environment.
[17]             Table 1
(see Annex) reflects results as per Member State and EU-27, EU-15, EU-12 level,
classified by ranges of compliance.
[18]             Amsterdam, Athens, Berlin,
 Bratislava, Copenhagen, Helsinki, Madrid, Paris, Stockholm, Vienna and Vilnius.
[19]             http://www.eea.europa.eu/themes/water/interactive/soe-wfd/urban-waste-water-treatment-directive-viewer.
[20]             http://fate.jrc.ec.europa.eu/rational/home.
[21]             http://bookshop.europa.eu/en/scenario-analysis-of-pollutants-loads-to-european-regional-seas-for-the-year-2020-pbLBNA25159/ and http://publications.jrc.ec.europa.eu/repository/bitstream/111111111/15938/1/lbna24726enc.pdf.
[22]             Kilotons/year.
[23]             Based
on chemical oxygen demand (COD).
[24]             COWI 2010: Compliance Costs of the Urban Wastewater
Treatment Directive. Final report http://ec.europa.eu/environment/water/water-urbanwaste/info/pdf/Cost%20of%20UWWTD-Final%20report_2010.pdf.
[25]             A list of
most relevant
infringement cases (to date) and judgements since the years
2009/2010 is provided in the Annex of the Report
(Tables 3 and 4 respectively).
[26]             SWD
(2012)
393
[27]             Annex VI (p.
102 pp) of the Impact Assessment (SWD(2012) 397 final) provide details on the
Urban Wastewater pilot action. 
[28]             https://circabc.europa.eu/w/browse/340cea09-390f-4c11-8e99-712c519c21e4.