Environmental, economic and social impacts of the use of sewage sludge on land Final Report Part II: Report on Options and Impacts RPA This report has been prepared by RPA, Milieu Ltd and WRc for the European Commission, DG Environment under Study Contract DG ENV.G.4/ETU/2008/0076r. The primary author was Ms Rocio Salado. Additional expertise was provided by Daniel Vencovsky, Elizabeth Daly, Tony Zamparutti and Rod Palfrey. The views expressed herein are those of the consultants alone and do not necessarily represent the official views of the European Commission. Milieu Ltd. (Belgium), Rue Blanche 15, B-1050 Brussels, tel: +32 2 506 1000; fax: +32 2 514 3603; e- mail: [email protected]; [email protected]; web address: www.milieu.be Executive Summary Introduction Milieu Ltd, together with partners WRc and Risk & Policy Analysts Ltd (RPA), has carried out a contract for the European Commission’s DG Environment, entitled Study on the environmental, economic and social impacts of the use of sewage sludge on land (DG ENV.G.4/ETU/2008/0076r). The Sewage Sludge Directive (86/278/EEC) could be said to have stood the test of time in that sludge recycling has expanded since its adoption without environmental problems. Since its adoption, however, several Member States have put in place stricter national requirements. Moreover, EC legislation has evolved in many related fields, such as chemicals regulation. Any revision should aim to retain the flexibility of the original Directive which has permitted sludge recycling to operate effectively across the wide range of agricultural and other environmental conditions found within the expanded EU. The aim of the study is to provide the Commission with the necessary elements for assessing the environmental, economic and social impacts, including health impacts, of present practices of sewage sludge use on land, provide an overview of prospective risks and opportunities and identify policy options related to the use of sewage sludge on land. This could lay the basis for the possible revision of Community legislation in this field. This is the final deliverable of the study: the first was a review of literature on the topic, Assessment of existing knowledge. The second was the development of a baseline scenario to 2020 concerning the spreading of sewage sludge on land and an analysis of the relevant risks and opportunities. The project Interim Report reviewed the results of the first consultation. This report provides the list of Options for the revision of Directive 86/278/EEC as well as an assessment of the impacts of these Options, including a cost-benefit analysis (CBA). The Options An initial set of five options for the revision of the Sewage Sludge Directive (Directive 86/278/EEC) was developed based on the review of literature and of regulations in Member States as well as comments received from Member States and stakeholders in the first consultation for this study and the first workshop. The options are as follows: Option 1: do-nothing: keeping the Directive as it is; Option 2: introduce certain more stringent standards, especially for heavy metals, standards for some organics and pathogens, and more stringent requirements on the application, sampling and monitoring of sludge; Option 3: introduce more stringent standards across all substances and bans on application of sludge to some crops; Option 4: total ban on the use of sludge on land; and Option 5: repeal of the Directive. The Options were formulated in discussion with the Commission, based on the interim project results. The specific components of the Options are detailed in section 1.2 of this report. Service contract No 070307/2008/517358/ETU/G4 i Environmental, economic and social impacts of the use of sewage sludge on land Approach to Data Gathering The information used for the analysis was gathered in several stages. Report III provides the results of the information-gathering phase of the project, together with an overview of the results of the first consultation, held in July and August 2009. On this basis, a preliminary impact assessment was prepared: this was the subject of the second project consultation, held in December 2009 and January 2010. Results from this consultation, including additional information on costs, were used in revising the assessment. In total, 39 responses were received in the second consultation, providing valuable information on the costs and benefits from the different options and the magnitude of impacts on sludge recycling. A summary of the responses is provided in Annex 1. The following table summarises the numbers and types of stakeholders that replied in the consultation. Some further information was gathered at a workshop held in Brussels in late January 2010. Table 1: Project consultation 2: Number of responses by type of stakeholder National authority (MS) 8 Regional authority (MS- R) 4 Statutory advisor, agency, public institution (MS-A) 3 International Professional association/federation (EF) 6 National Professional association/federation (NF) 7 Company/industry (IS) 8 Consultancy 1 Research/academic institute 0 NGO 1 Other 1 Comparison of the Options An impact screening of the different options was one of the first steps of the assessment. This was carried out following the EC Impact Assessment Guidelines. The most important impacts identified in this screening were carried forward for detailed assessment. Table 2 sets out the results of this first assessment of the Options in qualitative terms (this assessment uses the information gathered throughout the project, including the responses provided in the second consultation). It should be noted that the original list was longer: only those impacts considered as significant are presented in the table below (other impacts, e.g. impacts on agricultural production, are considered to be limited; the consultation responses agreed with these judgements). Table 2: Initial qualitative assessment Option Economic Impacts Environmental Impacts Social Impacts Option 1 - 0 0 0 Baseline Scenario Option 2 – Costs of alternative disposal (-) Environmental benefits from Human health benefits from “moderate Obligation of treatment (-) reduced application (?/+) reduced application (?/+) Service contract No 070307/2008/517358/ETU/G4 ii Environmental, economic and social impacts of the use of sewage sludge on land Option Economic Impacts Environmental Impacts Social Impacts changes” Changes to regulation: including costs of consultation (-) Environmental benefits/costs Human health costs from Policy implementation and from alternative routes of alternative routes of control (-) disposal including climate disposal, e.g. air pollution Benefits/costs if meeting other change impacts from from incineration (-) related legislation requirements incineration, landfilling (-) (i.e. WFD, Waste Directive) (?) Odour/amenity impacts (-/?) Loss of use of sludge as a fertiliser and fertiliser replacement costs (-/?) Option 3 – more As above but greater in magnitude significant changes Option 4 - Total Fertiliser replacement costs (--) Environmental benefits from Human health benefits from Ban Alternative routes of disposal reduced application (?/+) reduced application (?/+) for all sludge arisings (--) Environmental benefits/costs Human health from from alternative routes of alternative routes of disposal disposal including climate including climate change change impacts (--) impacts (--) Odour/amenity impacts from increased landfilling and incineration (-/?) Option 5 - Repeal Benefits from reduced policy Environmental benefits/costs Human health from of the Directive monitoring and compliance (+) from alternative routes of alternative routes of disposal disposal including climate including climate change (?) change (?) Potential risks to human Potential environmental risks health if a MS abandons all if a MS abandons all sludge sludge regulation (?/--) regulation (?/--) Odour/amenity impacts from increased landfilling and incineration (-/?) 0: impact expected to be negligible; - : low/moderate negative impacts expected --: significant negative impacts expected +: low/moderate positive impacts ++: significant impacts expected This report presents a cost-benefit analysis (CBA) for a number of impacts. It should be emphasised, however, that not all impacts could be valued. The following table summarises which impacts are valued in the assessment. Table 3: Overview of impacts considered and approach Economic Stakeholder Description Quantified? Qualitative assessment when impacts no quantification/other comments Costs of Water and As sludge recycling will be Yes - alternative sludge ended, there will be internal disposal management costs from its disposal operators Obligation of Water and Sludge will need further Yes - treatment sludge treatment to deal with new management standards Service contract No 070307/2008/517358/ETU/G4 iii Environmental, economic and social impacts of the use of sewage sludge on land Economic Stakeholder Description Quantified? Qualitative assessment when impacts no quantification/other comments operators Changes to Regulators There will be costs from No These are expected to be regulation changing legislation and moderate in comparison with consultation (not monetised) total costs Policy Regulators Costs from monitoring in No These are expected to be implementation order to check that legislation moderate in comparison with and control is being met total costs Benefits/costs if Regulators Option 2 and 3 likely to No Depends on the