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New developments are increasingly focusing on rainwater storage. Climate change is causing more intense rainfall, which means that water storage needs to be given greater consideration in projects. Sustainable and climate-adaptive construction is becoming increasingly important.
The Water Framework Directive (WFD) has been in force since 1 January 2000. The WFD is a European directive aimed at achieving and maintaining chemically clean and ecologically healthy surface water and groundwater. From 2027 onwards, water in the Netherlands must be sufficiently clean and healthy, both in terms of chemical and ecological quality. Chemical quality is determined on the basis of the concentrations of “Priority Substances”, such as benzene. The ecological status encompasses the complex quality of aquatic life. If one criterion is not met in a water body, the entire water body fails to meet the criteria. Currently (2024), 9% of waters in the Netherlands meet the chemical quality criteria and less than 1% meet the ecological quality criteria. For example, Dutch waters contain too much nitrate and phosphate (from fertilisers), PFAS and microplastics, as well as residues from medicines and cosmetics, among other things. One difficulty is that Dutch waters are located at the end of European river basins. In addition, the Netherlands has many small ditches that fall outside the scope of the WFD, but from which water ends up in rivers and can ultimately pollute surface water in several provinces. Farmers, industry and citizens will all have to contribute to preventing further pollution and improving chemical and ecological water quality. Industrial discharge activities are a necessary part of business operations, but they can negatively affect chemical and/or ecological water quality and cause or lead to bottlenecks.
In recent decades, water quality in the Netherlands has already improved significantly thanks to the Surface Water Pollution Act (Wvo) and the Water Act. As a result, companies often already had to deal with permits and/or notifications for wastewater discharges. Since the introduction of the Environment Act (1 January 2024), the Living Environment Quality Decree (Bkl) has included national environmental quality standards (OGW) based on the WFD and the Priority Substances Directive. The environmental values enable the municipality, the water board, the province or the national government to objectively determine water quality and make it quantitatively measurable. It is important to note that water quality must not deteriorate, even temporarily.
When a new permit must be applied for because a company wants to start new discharges, modify existing discharges or because the permit has been wholly or partially revoked by the competent authority, the wastewater discharges must be assessed against the criteria set out in the WFD. The location of the discharge point largely determines what and how much may be discharged. If a discharge point is located near a downstream protected area (such as a water extraction area, bathing water location or Natura 2000 area), the requirements for discharge are stricter. The assessment is carried out using a General Assessment Methodology (ABM) and an Immission Test. The ABM classifies substances and mixtures on the basis of water pollution classes and the associated remediation effort. The starting point here is that the aim is to achieve zero discharge or at least minimise discharge by means of Best Available Techniques (BAT). The Immission Test is then used to assess the impact of residual discharges on local water quality and/or protected areas downstream.
We conduct a risk assessment for existing and new permits. We can perform both the ABM assessment and the Immission assessment based on information provided by you regarding substances and/or mixtures and effluent concentrations, among other things. We can also determine the residual risk of unforeseen discharges and their effect on the environment with an Environmental Risk Analysis (ERA). Based on the results of the risk assessment and any ERA, we advise you on possible follow-up actions. We can take care of the permit application for your discharge activities. In addition, we are happy to advise you on sustainable construction and climate-adaptive construction. Please contact one of our advisors.
