ADVISORY SERVICES AGREEMENT ON TECHNICAL SUPPORT TO ROMANIA IN ANALYZING AND ADDRESSING THE CHALLENGES IN MEETING THE UWWTD REQUIREMENTS Output No. 1 Concept paper on support provided to update the UWWTD implementation plan including approach, workplan and roadmap of the associated activities July 2019 Disclaimer This report is a product of the International Bank for Reconstruction and Development / the World Bank. The findings, interpretation, and conclusions expressed in this paper do not necessarily reflect the views of the Executive Directors of the World Bank or the governments they represent. The World Bank does not guarantee the accuracy of the data included in this work. This report does not necessarily represent the position of the European Union or the Romanian Government. Copyright Statement The material in this publication is copyrighted. Copying and/or transmitting portions of this work without permission may be a violation of applicable laws. For permission to photocopy or reprint any part of this work, please send a request with the complete information to either: (i) Ministry of Waters and Forests (Calea Plevnei 46, Bucharest, Romania) or (ii) the World Bank Group Romania (Vasile Lascăr Street, No 31, Et 6, Sector 2, Bucharest, Romania) Purpose This report has been delivered under the Advisory Services Agreement on Technical Support to Romania in Analyzing and Addressing the Challenges in Meeting the UWWTD requirements signed between the Ministry of Waters and Forests and the International Bank for Reconstruction and Development on January 28, 2019. It corresponds to Output 1 under the above-mentioned agreement. Acknowledgements This report is the result of the work performed by a team of World Bank staff and experts led by Ivaylo Hristov Kolev (Task Team Leader) and including Adina Fagarasan, Alexandru Cosmin Buteica, Anca Bors, Bruno Rakedjian, Clara Ivanescu, Diogo Faria de Oliveira, Gabriel Ionita, Gabriel Simion, Galina Dimova, Dessislava Kovatcheva, Irina Ribarova, Horia Barnaure, Florian Gaman, Teodor Popa, Todor Lambev, Toma Alexandrov Yanakiev, Orlin Dikov, Silviu Lacatusu. The team also benefited from the solid logistic support provided by Anastasia Gadja and Carolina Delgadillo of the World Bank offices in Bucharest and Washington DC. The authors would like to give special thanks to David Michaud (Practice Manager, Water Global Practice in Europe and Central Asia, World Bank) and Tatiana Proskuryakova (Country Manager for Romania, World Bank), for the overall coordination, as well as for the guidance and valuable advice. The team also thanks Raimund Mair, Carmen Rosa Yee-Batista and Adriana Pienaru for the insightful peer review and recommendations that contributed to enhancing the report quality. Table of Contents Chapter 1. Project scope and purpose ..................................................................................... 9 Chapter 2. Stocktaking of UWWTD implementation .............................................................. 14 2.1 Institutions – roles and responsibilities ................................................................................ 14 2.2 WSS Sector Situation............................................................................................................. 17 2.3 UWWTD compliance situation as at the end of 2017 ........................................................... 24 2.4 Review of the accomplishment of the existing UWWTD Implementation Plan ................... 29 Chapter 3. Component A: Support for the update of the UWWTD Implementation Plan ......... 33 3.1 Methodology for defining agglomeration boundaries for agglomerations with more than 2,000 p.e. .......................................................................................................................................... 34 3.2 Methodology for calculation of agglomeration load for agglomerations with more than 2,000 p.e. .......................................................................................................................................... 41 3.3 Application of Individual Appropriate Systems .................................................................... 49 3.4 Strategic Financing Plan ........................................................................................................ 51 3.5 Establishing a baseline and a new timetable on UWWTD implementation ......................... 57 3.6 Additional measures to optimize compliance costs and accelerate implementation of UWWTD in Romania ......................................................................................................................... 58 Chapter 4. Component B: Assistance for the update of the national mechanism for monitoring, evaluation and reporting on UWWTD implementation................................................................ 61 4.1. Assessment of the existing process of data collection, processing and validation of information regarding UWWTD compliance reporting .................................................................... 61 4.2. Review of the existing information systems for monitoring, evaluation and reporting on UWWTD implementation ................................................................................................................. 63 4.3. Approach and workplan to enhance the information systems and make them SIIF compliant .......................................................................................................................................... 66 Chapter 5. Component C: Recommendations towards development of a National Strategy for the Water Supply and Sanitation Sector ..................................................................................... 67 5.1 Stocktaking from all ongoing strategic efforts in the WSS sector, institutions, roles and responsibilities .................................................................................................................................. 67 5.2 Addressing the WSS sector challenges through preparation of WSS sector vision, strategic objectives, targets and measures ..................................................................................................... 71 5.3 Approach and workplan to develop the outline of the Water Supply and Sanitation Strategy ............................................................................................................................................. 72 Chapter 6. Capacity building for MoWF and ANAR for the UWWTD implementation .............. 76 4 6.1 MoWF and ANAR capacity needs assessment ...................................................................... 76 6.2 Development of capacity improvement plan and delivery of trainings on specific issues related to UWWTD implementation................................................................................................. 77 6.3 Lessons learned from other EU member states on UWWTD implementation .................... 79 6.4 Approach and workplan to increase MoWF and ANAR capacity regarding UWWTD obligations......................................................................................................................................... 79 Chapter 7. Workplan and roadmap of the associated activities of WSS RAS “Technical support to Romania in analyzing and addressing the challenges in meeting the UWWTD requirements”... 86 Annex 1: Examples of UWWTD compliance reporting discrepancies ............................................ 90 List of Tables Table 1: Population connected to WSS services ................................................................................... 19 Table 2: Number of agglomerations, population and p.e. as at the end of 2017 ................................ 24 Table 3: Article 3 compliance. ............................................................................................................... 25 Table 4: Article 3 distance to compliance. ............................................................................................ 26 Table 5: Article 4 compliance. ............................................................................................................... 27 Table 6: Article 5 compliance. ............................................................................................................... 28 Table 7: Determination of population density...................................................................................... 39 Table 8: Different types of wastewater management in the agglomeration of Romania as per December 2017 ..................................................................................................................................... 45 Table 9: Data base needed at agglomeration level and potential sources........................................... 48 Table 10: Comparison between data available in SIIF and ROC data ................................................... 65 Table 11: The Matrix of Capacity Improvement Project Activities ....................................................... 81 Table 12: Workplan and resources to increase MoWF and ANAR capacity with regard to UWWTD Obligations ............................................................................................................................................ 85 List of Figures Figure 1: Share of population connected to wastewater treatment plants in selected EU member states ..................................................................................................................................................... 20 Figure 2: Sludge production and disposal (2012-2017) ........................................................................ 21 Figure 3: Sewage sludge disposal by type of use .................................................................................. 22 Figure 4: Territorial distribution of multiannual average rainfall quantities from 1961 to 2014 (left) and Changes in multiannual average rainfall (mm) in Romania (2011–40 vs. 1961–90) (right). ......... 23 Figure 5: Connection rates to centralized collection systems at a county level ................................... 25 Figure 6: Methodologies to be developed for improvement of the UWWTD implementation process .............................................................................................................................................................. 34 Figure 7: Cost comparison of sanitation options for Bulgaria .............................................................. 38 Figure 8: Types of WWM within an agglomeration .............................................................................. 44 Figure 9: Romania GDP growth ............................................................................................................. 53 Figure 10: UWWTD current reporting representation ......................................................................... 62 Figure 11: Evolution of number of WSS operators ............................................................................... 69 Abbreviations ANAR National Administration "Romanian Waters" ANCPI National Agency for Cadaster and Land Registration ANRSC National Regulatory Authority on Communal Services of Public Utilities ARA Romanian Water Association BOD5 5-day Biochemical Oxygen Demand CAPEX Capital Expenditure CIP Capacity Improvement Plan CLC CORINE Land Cover CNA Capacity Needs Assessment DG Regio Directorate-General for Regional and Urban Policy EBRD European Bank for Reconstruction and Development EC European Commission EEA European Environmental Agency ESIF European Structural and Investment Funds EU European Union FADIDA Federation of IDAs FM Financial Model GD Government Decision GIS Geographic Information Systems GoR Government of Romania IAS Individual Appropriate Systems IDAs Intercommunity Development Associations IFIs International Financial Institutions INHHGA National Institute of Hydrology and Water Management IP Implementation Plan ISPA Structural Pre-Accession Instrument LAU Local Administrative Units LIOP Large Infrastructure Operational Programme LOC Local Operating Company LPAs Local Public Administration MARD Ministry of Agriculture and Rural Development MEF Ministry of European Funds MoE Ministry of Environment MoH Ministry of Health MoWF Ministry of Waters and Forests MPF Ministry of Public Finances MPW Ministry of Public Works MRDPA Ministry of Regional Development, Public Administration MS Member States MUDPs Danish Eco-Innovation Programs NPLD National Program for Local Development NRDP National Rural Development Program OP Operational Programme OPE Operational Programme – Environment OPEX Operational Expenditure P.E. Population Equivalent PV Present Value RAS Reimbursable Advisory Services RBD River Basin Directorate ROC Regional Operating Company SAPARD Special Accession Programme for Agricultural and Rural Development SDGs Sustainable Development Goals SFP Strategic Financing Plan SIIF Structured Implementation and Information Framework SOP Sectoral Operational Program TA Technical Assistance UN United Nations UWWTD Urban Waste Water Treatment Directive WB World Bank WBAs River Basin Administrations WFD Water Framework Directive WICS Water Industry Commission of Scotland WSS Water Supply and Sanitation WW Wastewater WWM Wastewater Management WWTP Wastewater Treatment Plant Chapter 1. Project scope and purpose PURPOSE 1. This Concept Paper represents the first output specified in the Reimbursable Advisory Services Agreement (RAS) signed between the Ministry of Waters and Forests (MoWF) and the World Bank (WB) on January 28, 2019 to provide “Technical support to Romania in analyzing and addressing the challenges in meeting the UWWTD requirements”. The Concept Paper describes the scope of the advisory services, its objectives, including the approach, workplan and roadmap of the associated activities, as described in the ‘Schedule – Description of Reimbursable Advisory Services’ that is part of the Advisory Services Agreement. It also aims to provide a common understanding about the implementation framework for this project. PROJECT CONTEXT 2. During the negotiation process leading to the European Union (EU) Accession Treaty, Romania committed to harmonization with the EU “Environmental acquis”—which includes the complex body of EU water legislation. Compliance with these directives and the associated calendar became de facto mandatory once Romania became a full EU member on January 1, 2007, although for some of these directives (e.g., the Urban Waste Water Treatment Directive), Romania was able, like all other EU-13 countries, to negotiate interim deadlines for compliance in recognition of the challenges involved. It is worth noting that Romania is one of the few countries that negotiated not only compliance deadlines related to the size of agglomerations, but also target rates related to the total load generated at national level. 3. The initial Urban Waste Water Treatment Directive (UWWTD) Implementation Plan (IP) was adopted in October 2004 and became effective in 2007, targeting wastewater collection and load treatment in agglomerations above 10,000 people equivalent (p.e.) at the end of 2013 and 2015, respectively, and at the end of 2018 for agglomerations between 2,000 and 10,000 p.e. The IP identified a total number of 2,609 agglomerations above 2,000 p.e. – including 263 above 10,000 p.e. and 2,346 between 2,000 and 10,000 p.e. All national territory was classified as Sensitive Area under Articles 5 (8) and 5 (2, 3) of the Directive, thereby requiring more stringent treatment of nitrogen and phosphorus in all wastewater treatment plants (WWTP) for agglomerations with more than 10,000 p.e. 4. The communist regime in Romania was rather unique among Eastern-bloc countries for not having ensured access to water supply and sanitation (WSS) services for all. As a consequence, in the early 1990s Romania had a considerable investment backlog, including both a large portion of urban areas not connected to piped WSS systems, and most of its rural settlements without any WSS network infrastructure. Thus, Romania, in comparison to other EU Member States (MS), started from a very low level in terms of water supply and wastewater collection and treatment infrastructure and services. Consequently, Romania’s UWWTD Implementation Plan revealed a difficult context: at the end of 2003 only 11.5 million inhabitants out of the total population of 21.7 million in Romania had access to wastewater collecting and treatment services. The breakdown of population benefiting from public sewerage services was 10.3 million inhabitants in urban 9 area and only 1.15 million inhabitants in rural areas. The IP had also pointed out that only 644 localities (265 cities and towns and 379 rural localities) out of around 3,000 localities have had public collecting systems. It also highlighted that in the existing WWTPs only 77 percent of the total discharged wastewater flow was treated, while in the same time in 47 urban localities, with more than 150,000 inhabitants, the wastewater was discharged without a preliminary treatment. 5. Compliance with EU water legislation has been the over-arching priority for the Romanian water sector for almost two decades. Compliance with the UWWTD has been by far the most difficult task. Since the 1989 revolution, almost 90 percent of all financing for water infrastructure investment has come from European Commission (EC) funding (mostly Cohesion Funds since 2007), and water reforms have been driven by EC requirements to access funding (the rest of the funding was mostly co-financing along with the EU grants). 6. Despite having carried out massive investments coupled with support for reforms implementation, compliance with the UWWTD remains extremely challenging. Implementation of the UWWTD has always been closely linked to the need to reform the Romanian Water Supply and Sanitation (WSS) sector, which encountered various challenges including resistance by local authorities against joining regional public utilities, resistance of households to connect to newly installed sewerage networks, slow utilization of EU grant funds, and the absence of a strategy for expanding WSS services to small rural areas. As the 2015 deadline was missed, the EC launched an infringement case for non-compliance with the UWWTD for agglomerations above 10,000 p.e., which requires urgent actions from the Romanian Government. Besides, the 2018 deadline for compliance with UWWTD for agglomerations over 2,000 p.e. was also missed and Romania is at risk that a second infringement case would be triggered by the EC. OBJECTIVE 7. Given this context, the Ministry of Waters and Forests approached the World Bank to seek technical support to analyze and address the challenges in meeting the UWWTD requirements under the overarching environmental objective to improve the quality of water bodies under Water Framework Directive (WFD). The advisory services to be delivered by the Bank under the current project will support the Government of Romania, through the MoWF, to prepare an updated comprehensive implementation plan aiming to address the requirements of EU UWWTD. With compliance deadlines not being met it is crucial to have an action plan tackling all outstanding wastewater issues, including responsibilities, required resources and sources of funding as well as proposing new deadlines to work towards to. To ensure a proper monitoring of the new Implementation Plan the MoWF is committed to work towards a Structured Implementation and Information Framework (SIIF) compliant national reporting system. Credibility and transparency of the delivery of the UWWTD implementation plan is essential to ensure that progress is measured accurately, and information is received and reported in a timely manner internally and externally, so that any deviation from the plan or challenges during implementation can be identified early on and duly addressed by the relevant stakeholders. 8. The Bank will also provide technical support to the MoWF to enhance the information processes and systems for monitoring, evaluation and reporting on UWWTD implementation, and propose measures to make the data reporting compatible with SIIF, 10 as well as track Romania’s compliance progress status. Since the existing WSS sector issues are going beyond the requirements of the UWWTD the project will provide initial inputs to the Romanian authorities to initiate the development of a National Strategy for the Water Supply and Sanitation Sector. The Strategy will put the wastewater related issues in a broader perspective, which should lead to improved water supply and sanitation services, increased efficiency of WSS operators in the country and overall technical and financial sustainability of the WSS sector. SCOPE 9. The present WSS reimbursable advisory services (RAS) agreement is entitled “Technical support to Romania in analyzing and addressing the challenges in meeting the UWWTD requirements” and include the following components: COMPONENT A: SUPPORT FOR THE UPDATE OF THE UWWTD IMPLEMENTATION PLAN The Bank will assist the MoWF in the preparation of an updated implementation plan for the Directive 91/271/EEC, including the following technical assistance activities to support MoWF in: (i) Carrying out a stocktaking assessment of the current implementation plan based on the available most up-to-date data, and identifying bottlenecks and options to accelerate implementation in line with the UWWTD including the review of alignment of existing national policies, institutional arrangements, incentives towards improved compliance efforts, and relevant lessons learned from other EU member states; (ii) Assessing options for optimization of compliance costs including: − review and update of the methodology for defining agglomeration with more than 2,000 p.e.; − organize and participate in meetings in 40 counties to present and discuss the new methodology and potential implications for the county; − update of the list of agglomerations above 2,000 p.e. based on the revised methodology and available information, which will include details and maps; − conduct analytical field work to validate the maps in boundary cases (up to 90 visits in agglomerations around 2,000 p.e. and/or in cases where there is difference compared to the last country report), which will also cover agglomerations where industrial pollutants discharging in urban systems are crucial for agglomeration formation. Final list of agglomerations above 2,000 p.e. will be prepared following the field work for inclusion in the updated UWWTD Implementation Plan; − review of legal requirements towards Individual Appropriate Systems (IAS) in Romania, and preparation of a detailed proposal for the process of registration and inspection of existing IAS; and planning, design, construction, operation and maintenance, monitoring and control of new IASs, in order to facilitate adequate environmental protection, while optimizing compliance costs. (iii) Establishing a baseline in terms of status of implementation of various UWWTD articles based on available information including: − mapping and analyzing information gaps with regard to data on UWWTD implementation in all agglomerations above 2,000 p.e.; 11 − analyzing available information and assisting the Recipient in identifying compliant/non-compliant agglomerations above 2,000 p.e.; (iv) Developing a draft Strategic Financing Plan for the remaining investments in the country to address the challenges of UWWTD requirements and existing funding gap, based on the available most up-to-date information and analytical work carried out by the Bank under (ii) above; (v) Developing an indicative timetable for the implementation of Directive 91/271/EEC, taking into account the available financial resources and including suggestions for better linkages and alignment with WFD’s environmental objectives by prioritizing Waste Water Treatment Plant investments based on the expected impact on the ecological status of recipient water bodies; (vi) Strengthening capacity of the personnel of MoWF and “Romanian Waters” National Administration (ANAR) in data collection, information validation and reporting to European Commission on UWWTD implementation. COMPONENT B: ASSISTANCE FOR THE UPDATE OF THE NATIONAL MECHANISM FOR MONITORING, EVALUATION AND REPORTING ON UWWTD IMPLEMENTATION The technical assistance will include support to the MoWF in: (i) Evaluating the existing national UWWTD reporting systems under the Recipient and ANAR, and their compatibility with the SIIF requirements; (ii) Developing a proposal to improve the process of data collection, processing and validation of information regarding UWWTD compliance reporting to the EC, including responsibilities and timeframe; (iii) Based on (i) and (ii) above, developing technical specifications to update the existing systems (or systems under development) in order to be SIIF compatible. The updated national database should enable visualization of the UWWTD reporting file, and support the validation of available information; (iv) Increasing the capacity of the personnel of MoWF and ANAR to work with the updated national UWWTD data collection and reporting system and SIIF, with special emphasis on drawing lessons learned from other EU countries, which are more advanced in the implementation of UWWTD. In this regard the Bank will carry out up to 5 trainings on specific issues related to the implementation of Directive 91/271/EEC, including SIIF reporting requirements, and carry out evaluations of the trainees to assess the transfer of knowledge. COMPONENT C: RECOMMENDATIONS TOWARDS DEVELOPMENT OF A NATIONAL STRATEGY FOR THE WATER SUPPLY AND SANITATION SECTOR Based on the technical assistance delivered under Components A and B above, the Bank will assist the MoWF in initiating the development of a National Strategy for the Water Supply and Sanitation (WSS) Sector (Strategy) by supporting the MoWF in: (i) Preparing a recommended vision statement and an executive outline of the proposed Strategy, focusing on specific areas and issues that need to be addressed in line with the 12 applicable EU environmental directives pertaining to the WSS sector, and improve sector performance and sustainability; (ii) Taking stock and analyzing all available information from national authorities and other International Financial Institutions (IFIs) that provide support to the WSS sector; and (iii) Proposing a mechanism to coordinate efforts and inputs during the preparation of the Strategy to engage all key stakeholders and IFIs involved in the sector. REPORT OVERVIEW 10. This Concept Paper has the following structure: Chapter 1 of the report describes the project scope and purpose; it also highlights the objectives of the technical assistance. Chapter 2 provides stocktaking of UWWTD implementation. It presents the situation in the WSS sector, ongoing challenges and describes the compliance situation as at the end of 2017. Chapter 3 looks in detail at the activities under the project to support the update of the UWWTD Implementation Plan. The approach for the development of methodologies for defining the agglomeration boundaries and calculation of agglomeration load is also presented. Application of Individual Appropriate Systems and development of Strategic Financing Plan are also described. Chapter 4 describes the assistance for the update of the national mechanism for monitoring, evaluation and reporting on UWWTD implementation. It presets information on the existing process for data collection, makes review of the employed information systems and describes the approach for improving the existing situation. Chapter 5 of the report covers the recommendations towards development of a National Strategy for Water Supply and Sanitation Sector. It presents information from ongoing strategic efforts in the sector, describes the steps towards preparation of WSS sector vision, strategic objectives, targets and measures. Chapter 6 provides information on the plan to increase the capacity of MoWF and ANAR administration dealing with UWWTD implementation. The approach to capacity needs assessment and development of capacity improvement plan is also described in detail. Chapter 7 presents the overall workplan and roadmap of activities for the delivery the advisory services including key next steps and decisions to be made. Annexes 1 include example of existing UWWTD compliance reporting discrepancies. 13 Chapter 2. Stocktaking of UWWTD implementation 2.1 Institutions – roles and responsibilities 11. The institutional setup related to the governance, management, and funding of the WSS sector includes many actors acting at central and local level, as described below: Central level authorities – in charge with policy development setting the objectives at national and local levels and include the following: • The Ministry of Regional Development, Public Administration (MRDPA) has the responsibility to elaborate and monitor the implementation of the strategies for all public services. It also governs the implementation of the National Program for Local Development (NPLD) covering public investment in infrastructure projects of local interest, including water supply and wastewater collection and treatment for localities not included in the EU-funded programs. NPLD has allocated RON 8.61 billion (€1.89 billion) for water supply, sewerage and wastewater treatment facilities in 2015 –2019 (29 percent of total program funds), most of them (94 percent) targeted at rural areas. MRDPA also hosts the Inter-ministerial Working Group for Water in charge with facilitating the inter-institutional coordination towards compliance with EU water directives. • National Regulatory Authority on Communal Services of Public Utilities (ANRSC), is the national water and sanitation services regulator. It is a public institution under the authority of MRDPA, established first based on the Government Decision (#404/2004) and then on the Law of Communal Services of Public Utility (#51/2006). It operates through a central office in Bucharest and seven regional offices. ANRSC has national regulatory, monitoring and control authority for all suppliers of public utility services at community level and all economic operators and public institutions with monopolistic activity of public utility in the following fields: water supply, collection and treatment and disposal of waste water, solid waste collection, public lightening, and local public transportation. ANRSC is in charge with licensing public utilities operators, sets the rules for tariff policies and rules on tariff adjustment requests by operators. Moreover, it elaborates the performance and benchmarking indicators for public utility companies and maintains and updates the database established under the monitoring information system regarding the public utility infrastructure and operators’ activity. • Ministry of Water and Forests (MoWF) has also a central role as the policy maker in charge with the strategic planning on water resources management, including qualitative and quantitative monitoring of water resources, and implementation of EU policy defined under the Water Framework Directive. MoWF is also in charge with monitoring and reporting to EC on compliance with all EU water directives and represents Romania in relation with the European Union institutions on all water management related matters. • National Administration “Romanian Waters” (ANAR1) is a public institution which is coordinated by the MoWF and which manages the water resources infrastructure nationwide (except for dams dedicated to hydropower production). ANAR operates as a public institution of national interest, having a legal personality and its own specific economic and financial mechanisms (self-financed), organized into a Central Office located 1 In Romanian language: Regia Autonoma “Administraţia Naţională Apele Române” 14 in Bucharest, 11 River Basin Administrations with their main offices located in a key city in the respective river basin, the Stânca-Costești Complex Exploitation, organized around Stânca-Costeşti Reservoir and the National Institute of Hydrology and Water Management (INHGA). ANAR is also in charge, nationwide, with quantitative and qualitative monitoring of all bulk water abstraction and restitution of waste water in natural water bodies, issuing permits to all water operators, as well as controlling their observance of the permits’ provisions. • Ministry of Health (MoH) is responsible for permanent monitoring programs implemented through the county-based directorates of public health based on the periodic testing of samples of drinking and bathing water taken in both urban and rural areas. The monitoring of drinking water is conducted for centralized water supply systems jointly by the water supply companies and the local directorates of public health and has two components: audit monitoring and control monitoring. The local public health authorities also monitor the quality of public wells in rural areas to determine whether their water matches the minimum drinking quality requirements, particularly in localities without centralized water supply systems where most of the drinking water is abstracted from shallow underground resources. • Ministry of European Funds (MEF) has a central role in financing the water and wastewater projects under the Large Infrastructure Operational Program (LIOP), through its Management Authority. LIOP is considered the leading program to support Romania not only meeting the requirements of the EU directives on drinking water and urban wastewater treatment, but a change driver for regionalization and institutional setup, exceeding its financing role. • Ministry of Public Finance (MPF) as the main Government financing entity is in charge with channeling the EU funds and national counterpart funding for the water sector, as well as with budgeting and funding the national WSS programs (e.g. NPLD). • Ministry of Agriculture and Rural Development (MARD) is the policy maker for agriculture and rural development. It oversees managing all public funds allocated for sector development from the national and EU budgets, and of the implementation of the corresponding programs. This includes the implementation of the National Program for Rural Development (NRDP) which has a strong component for development of water and wastewater rural infrastructure, through the Managing Authority for NRDP. • Ministry of Environment (MoE) was in charge with development and implementation of SOP Environment during previous financing period as it also incorporated the Department of Water Management (turned into the current Ministry of Water and Forests), until 2016. The National Environmental Guard (and County Environmental Guards) is a specialized inspection and control body under the authority of the MoE (which includes relevant inspection and control activities for the implementation of the UWWTD, such as the operation of WWTPs and compliance of the quality of waste water discharged into emissaries, connection of population to WSS infrastructure etc.). Local level authorities – responsible with implementation of national policies and include the following: • Local Public Administration (LPAs) have exclusive competence and responsibility, granted by Law 51/2006, with regard to setting up, organization, monitoring and control 15 of the functioning of the public services, including the water supply and wastewater services. They are also responsible for management of public assets and general planning in relation with the water supply and wastewater systems, in accordance with the Law of Local Public Administration, #215/2001)2. The local authorities are the only shareholders of the ROCs and owners of all water and wastewater infrastructure, transferred for management, operation and maintenance to the operators through delegation contracts. • Intercommunity Development Associations (IDAs) regroup the local authorities which have delegated their WSS services to a regional public operator (ROC). There are 43 of them and they were established a decade ago, as one of the pillars of the regionalization reform. Their role is to supervise the performance of the ROCs under the delegated services contracts, as well as to endorse the tariff strategy and tariff adjustments based on the tariff strategy, before their approval by the LPAs. IDAs are established as cooperation structures set-up by LPAs at county, municipal and rural level organized according to Government Ordinance 26/2000 (on associations and foundations), with the statute of public utility (in line with Law 215/2001) and Government Decision 855/2008. Their main role is to either provide certain public services or jointly achieve development projects of areal or regional interest, representing the interests of all their members. However, the decision process within IDAs remains complex and difficult, with more effectiveness remaining to be achieved. • Regional Operating Company (ROC) is a commercial entity established solely to provide the water supply and wastewater services for the members of an IDA. It is owned by all or a part of IDA members. The management, operation and maintenance of water infrastructure owned by IDA is entrusted to ROCs through Delegation of Management Contracts, with specific rights and obligations of parties on development of investment programs and certain performance levels. The ROCs serve, by far, the largest portion of the population connected to piped WSS services – 9 million out of 13.2 million people (6.9 million out of 9.5 million for sewerage collection networks). • Other WSS Operators. WSS services are provided also by a mix of two large private operators under mixed-ownership and over 950 small local operators. The small operators are mostly municipal departments that are not ring-fenced from the other municipal services (and are referred to as “Communal operators”) but they also include a number of corporatized enterprises under limited liability structure, the so-called “SRL-operators”. Private operators serve about 2.1 million people – with 2 million people in Bucharest and Ploiesti served by an international operator, and about 0.1 million served by small local private operators elsewhere. Small municipal public operators serve about 1.5 million people. • Romanian Water Association (ARA), a professional association representing the various Romanian WSS actors (operators, entrepreneurs, suppliers), has played a key role in the development of the sector over the past 20 year. ARA has 48 members (mostly utilities) that finance its activities. It has been involved in major investment programs implemented in the WSS sector in the past two decades and played an active role in the design of the institutional set-up for regionalization. It also plays a leading role in the national WSS benchmarking process through the Romanian WSS center of excellence set- 2 EBRD-RAMBOL-BDO: Water Sector Development in Romania, Strategic Paper (Draft), 2019 16 up in 2015. • Federation of IDAs (FADIDA) is an association of IDAs with the role to strengthen the institutional framework for regionalization of water services and disseminate best practice in structuring the relations IDA-ROC. • Other organizations of local administration, with national coverage are the following: National Union of County Councils, Romanian Municipalities Association, and Association of Romanian Communes, established as non-profit associations representing the respective institutions of local administration. The wide range of institutions described briefly above, representing an apparent diversity of interests not always congruent with each other, create the family of the water and wastewater sector stakeholders that could and should contribute to the development of a comprehensive sectoral strategy for further development and strengthening the water and wastewater services. Their respective roles and, possibly, enhanced responsibilities, would ensure the success of the envisaged reforms. 2.2 WSS Sector Situation BACKGROUND 12. At the end of the socialist era, Romania showed a highly fragmented WSS sector, significantly developed in the large cities but quasi-absent in small urban and rural localities. Self-supply of water from private or public wells and household latrines was the norm in most small urban and rural settlements, while most city dwellers benefitted of piped potable water and sewerage infrastructure. Water self-supply wells and pit latrines were still present even in the large cities’ suburbs (including Bucharest). Most urban WSS services were provided by local public husbandry or water and sewerage enterprises (Bucharest). In rural settlements, such services, if any, were performed by small units of the local administration. 13. After 1990, with less than 50 percent of population connected to piped water and about 35 percent connected to sewerage networks (with about 80 percent of wastewater discharged untreated into surface waters), Romania was lagging significantly behind most former socialist countries in Europe, which led to a slow and cumbersome head start. Recognizing this backlog, from 1995, new principles of local autonomy were introduced, with clearer responsibilities gradually transferred to local authorities together with new financial regulations, under the general obligation to provide adequate public services through efficient organization of their operations. 14. Romania embarked on a series of investment programs to rehabilitate and modernize the water and wastewater infrastructure in large municipalities (over 100,000 inhabitants), financed from EU (pre-accession ISPA program), EBRD (MUDPs) and the World Bank. Attention was paid also to the development of water and wastewater infrastructure in small towns and rural areas through various small projects financed from the state budget, EU and World Bank funds, but they could not trigger substantive changes in people’s mindset and improved awareness regarding the benefit of water services and the associated costs. Besides, three other programs provided financing to development of rural water infrastructure, mainly to water supply: Government Program for Rural Water Supply, EU SAPARD and Rural Development Project (WB). 17 15. Private management of water services was also sought in a few large cities, but only in Bucharest and Ploiesti concession contracts were concluded and are operational since 2000. After EU accession, in 2007, compliance with the European water directives (mainly the Drinking Water Directive 98/83/EC and Urban Wastewater Directive 91/271/EC) became the principal sectoral objective. Larger investment programs with EU funding on water supply and wastewater collection and treatment were implemented under the Sectoral Operational Program (SOP) Environment 2007-2013 (€3.4 billion) and National Rural Development Program (€0.9 billion), within the framework of the new policy of regionalization of water services developed to enable the implementation of applicable EU directives, also reflected in the first round of regional WSS County Master Plans (2007- 2009). The regionalization policy aimed at substantial institutional reforms towards consolidation of the myriad of water and wastewater service suppliers to secure sustainable water services through long-term planning, coordinated financing and implementation of suitable technical solutions tailored to local specificity. 16. The investment programs continue during the current programming and financing period (2014-2020), with slightly lower resources, under the Large Infrastructure OP (LIOP - €3 billion) and the Rural Development Program 2 (RDP – 0.75 billion), supported by a set of revised WSS County Master Plans prepared in 2011-2014. LIOP included 29 projects phased from the previous programming period and 43 new projects. Almost 30 years since its turning to democracy and market economy and more than a decade after EU accession, Romania has made significant efforts to cope with the legacy of socialist time and close the gap with the other EU member states on providing quality water services for urban and rural population. However, given the head start gap, several challenges remain to be addressed by Romania in the water services, as described below. ONGOING CHALLENGES 17. It should be mentioned that a lot has been achieved in improving WSS services compared to the situation as at the end of 2003 (see paragraph 4) in Romania. Some of the main achievements are related to improved access to water supply and sanitation, regionalization of services, delivery of significant investment program, improved regulation, and etc. However, there seems to be a few remaining challenges that need addressing during the preparation of the WSS Strategy. 18. Unfinished reform agenda. The regionalization policy is the main structural reform undertaken in the water services sector, actively promoted under the SOP Environment. Its two main objectives consist of (i) promoting more integrated water resources management and application of solidarity principle between urban and rural settlements in each region; and (ii) achieving economies of scale in water services through concentration of operation of multiple WSS operators within a geographical area into a large public utility (Regional Operating Company – ROC), thus overcoming the high fragmentation of services. Joining the Intercommunity Development Associations (IDA) at county level was not compulsory but the local authorities were strongly encouraged by the pre-condition to access the EU-grants for investment. However, a significant proportion of local authorities did not join the IDAs and continued with their local utilities. Currently, about two-thirds of local authorities are part of IDAs but only about 60 percent of them have delegated their WSS services to ROCs. Nevertheless, the push to establish creditworthy public utilities resulted in diminishing the incentives for them to expand to 18 poor and rural areas, which would affect their operational and financial performances. There is still resistance from small rural authorities to embark on the regionalization process reinforced by the decisions of several rural administrations to leave IDAs. Therefore, much remains to be done to complete the regionalization and provide professionalized services and access to investment to smaller, particularly rural, localities. 19. Fragmentation of service delivery. Two decades after the regionalization policy was enacted, the water supply and wastewater services continue to be delivered by a large number of operators (1,001), including 43 regional and two private operators (ANRSC, Annual Report 2018). The 956 small, local operators (some of them private), mostly serving localities between 2,000 and 8,000 people, have been largely established after the demise of the socialist regime; some of them, however, have been operational in medium- sized towns for more than 40 years, in absence of any coverage from the county capital city. The number of these small operators decreased slightly over time but their incorporation in larger utilities, either regional or not, is still not addressed strategically, with detrimental results for small localities not part of IDAs. 20. Closing the urban-rural gap on living standards. While reliable water services are delivered to a large percentage of urban population (97 percent for water supply and 88 percent for wastewater), the disparity with the rural population is huge, as seen in Table 1 below. Table 1: Population connected to WSS services Population (% of total) Access to public WSS services Total (%) Urban (%) Rural (%) Connected to Water Supply 67.74 97.03 33.66 Connected to Sewerage 51.09 87.92 8.25 Connected to WW Treatment 49.72 85.96 6.88 Source: NSI Data3 on access to WSS services (2017) processed by the WB team The above figures placed Romania at the tail of EU member states, distant by 35 percent behind Bulgaria and 20 percent behind Albania and Serbia on water supply access, and 25 percent behind Hungary and Lithuania and 35 percent behind Bulgaria in terms of wastewater treatment4, as shown in Figure 1. About 4.5 million people do not have access to piped water in their houses, while about 2.5 million (12 percent of total population) are self-supplied from unsafe, non-potable water sources (own or public shallow wells, subject to potential fecal contamination). A higher gap exists in the access to flush toilets, with more than 6 million people without flush toilets in their homes (according to the 2016 household survey). 3 INS Data on access to WSS services (2017) processed by the WB team. These numbers refer to statistical population and differ from other data in the report that refer to loads and population equivalent. 4 EBRD-RAMBOL-BDO: Water Sector Development in Romania, Strategic Paper (Draft), 2019 19 Figure 1: Share of population connected to wastewater treatment plants in selected EU member states Source: Eurostat Water Statistics, 2017 Since the access of rural population is such an issue, substantial efforts are needed not only to provide the required infrastructure, but also to raise the awareness of rural population of the benefits brought by that to their own health and comfort, and community environment. Safe piped water and sanitation would be an important element to encourage economic development of rural space which has so much to offer for successful businesses. 21. Closing the inclusion gap for the poor. The lack of access to basic water and wastewater services is higher not only in rural areas, but for the rural poor in particular. While the incidence of extreme poverty cases is higher in urban areas, more poor people live in the rural space which shelters about 46 percent of total population, the highest proportion of rural population amongst EU countries. The affordability of costs, including capital investment for indoor bathroom and connection to water and sewerage, as well as the monthly services, are the main restricting factors for all disadvantaged people (mainly elderly, disabled and Roma) living both in urban and rural. The periodic increases in tariffs, that reached 2.9 percent of average household’s income and exceeded 5 percent of household income for poor households5, contribute to their reluctance to add more costs to their household. Although the specific water services legislation has been amended few years ago to allow for development of mechanisms to provide financial support to poor households to enable their connection and subsidize their monthly water charges, no progress was made on development of such mechanisms. 22. Compliance with the European living standards defined by the EU directives. The remaining low level of access of the Romanian population to public water supply and sanitation services outside big cities and the slow pace in implementation of investment programs in water infrastructure undermines not only Romania’s compliance with the commitments made through the EU Accession Treaty and conformation with the EU water 5 World Bank, Romania Water Sector Diagnostic, 2018 20 directives but also keeps Romanian people at significant lower living standards than all other member-states. Besides, infringement penalties could be very high and undermine the country’s financial capacity to accelerate the pace of investment in water infrastructure. A better prioritization of investment projects, yet to be launched to maximize their impact on compliance, as well as enhance harmonization and alignment of all sources of financing available for water and wastewater infrastructure, would significantly help to convince the European partners of Romania’s commitment to close the gap with the other member-states. 23. Management of increasing volume of sludge. The expected increase in the level of wastewater treatment would also result in an upward trend in sludge accumulated at the wastewater treatment plants managed by regional and local operators, following and possibly, increasing the pace shown in Figure 2. Evolution of sludge quantities from WWTP (tone/year) 140,000 116,255 120,000 112,121 106,859 100,000 87,457 87,846 89,691 89,402 86,372 80,000 74,185 74,232 62,367 60,000 57,191 40,000 20,000 - 2012 2013 2014 2015 2016 2017 Total quantity of sludge Sludge sent to landfill Linear (Total quantity of sludge) Figure 2: Sludge production and disposal (2012-2017) Source: EBRD report, 20196 A National Sludge Management Strategy was drafted and underwent a SEA procedure in 2011, but it has not yet been approved based on a legal instrument. With the expected sharp trend in sludge accumulation in the coming years (expected to reach 520 million tons/year), Romania needs to update and develop the strategy for sludge disposal, including diversification of methods and legislation for their application, with due respect to environment and health protection. The strategy will pose, indeed, a series of technical and financial challenges to the central and local authorities, as well as for the operators. While in Romania most of the sludge is stored at the WWTPs or transported to landfills, and only a small fraction is used in agriculture (about 16 percent7), many other countries have developed more diversified methods for sludge disposal, as illustrated in Figure 3. 6 EBRD-RAMBOL-BDO: Water Sector Development in Romania, Strategic Paper (Draft), 2019 7 Ibidem 21 The experience of other countries blended with local lessons learned so far in Romania should be used in developing sustainable mechanisms for sludge management. Sewage sludge disposal from urban wastewater treatment, by type of treatment, 2015 100 75 50 25 0 Poland Finland Lithuania Slovenia Ireland Bulgaria Luxembourg Sweden Hungary Cyprus Romania Croatia Malta Netherlands Slovakia Spain France Portugal Czech Republic Greece Latvia United Kingdom Germany Italy Estonia Austria Agricultural use Compost and other applications Landfill Incineration Others Figure 3: Sewage sludge disposal by type of use Source: Eurostat Water Statistics, 2017 24. Need for a fresh look at WSS sector vision. Since the sector is required to find solutions to many challenges, the absence of a comprehensive vision and strategy to implement it deepens the fragmentation of investment approaches. Romania needs to close several critical gaps at the same time, such as compliance with EU water directives (particularly on water supply and wastewater collection and treatment), ensure universal access to piped water and sanitation, improve inclusion of vulnerable population to water services distribution, secure a balanced development and access to water services across the country, similar in urban and rural settlements. Closing the financial gap for both capital investment and operational expenses would require synergy in using European and national funds and their management along similar rules and principles. Romania is the most unequal EU country – with the sharpest discrepancies between urban and rural areas, and between rich and poor households – and it is not on track for complying with Target Six of the UN Sustainable Development Goals (SDGs), which requires that access for all to safe and affordable drinking water and adequate sanitation to be achieved by 20308. Thus, these shortfalls need to be addressed by developing the sector strategic vision, with a particular attention to the rural areas. The current WSS service delivery model and tariff structure and levels need to be updated to secure inclusive development of all counties while preserving the valuable achievements in commercialization of public utilities9. The lack of incentives for regional operators to expand their activity in poor area needs to be addressed, possibly by implementing new financial mechanisms for blending commercial financing with budget transfers, having programmatic and portfolio approach instead of single project investments etc. 8 World Bank, Romania Water Sector Diagnostic, 2018 9 Ibidem 22 25. Requirement for a strong leadership in the WSS sector. Even though an inter-ministerial group was created to deal with WSS sector issues related to investment preparation and prioritization, compliance issues and the infringement process, utilization of EU funds and coordination of institutional efforts, including assistance from IFI’s, it is still hard to see a single Romanian institution being in charge of the overall WSS sector policies and efforts. There is a significant number of institutions working within their mandate and although some coordination is ongoing due to the inter-ministerial group there is a clear lack of leadership in the Romanian WSS sector. 26. Cope with climate change effects. The effects of climate change, in terms of upwards trend in average temperatures, downwards trend in average annual precipitations with an upwards trend in rainfalls intensity have been noted in Romania in the past three decades, placing it among the affected EU countries. These effects have had uneven territorial distribution as shown in Figure 410. Figure 4: Territorial distribution of multiannual average rainfall quantities from 1961 to 2014 (left) and Changes in multiannual average rainfall (mm) in Romania (2011–40 vs. 1961–90) (right). Source: National Meteorological Administration, 2015 While the total average water availability from internal rivers (together with ground water the main source for water supply) over the past 50 years seems to be at reasonable value (40 billion m3), the annual variability of water resources is significant, in the range of 25- 62 billion m3 during the current decade. The change in the pattern of rainfalls, with heavy rain storms turning into strong runoff to even catastrophic floods, raises questions about the future availability of water for the population. It is also important to note that the climate change effects would differ from one river basin to another, so the actions have to be tailored to the local specificity. Nevertheless, with the gradual reduction of availability of natural water in the internal rivers by 2050 (expected to range between 8-10 percent for the main rivers Siret, Olt, Mures, Jiu Arges, and 25 percent in smaller rivers in the South), the problem of reducing/eliminating discharges of untreated wastewaters into rivers becomes more urgent. It is also expected that water demand for population supply will increase, together with more discharges of wastewater. Hence, the need to accelerate the efforts towards collection and treatment of all wastewaters (if possible) to preserve the vital natural 10 Ibidem 23 resource – water. This brings to the attention the need to integrate the WSS sector strategy into the larger scale program to improve the quality of surface and ground water bodies, in compliance with the requirements of the Water Framework Directive. 2.3 UWWTD compliance situation as at the end of 2017 COMPLIANCE AS REPORTED BY ANAR 27. As agreed between Romania and EC, the responsibility for data collection and reporting to EC on compliance with all water directives was assigned to the ministry and agency in charge with water management, currently the MoWF and the National Administration “Romanian Waters” (ANAR). According to the UWWTD, reporting on compliance is submitted to EC-DGENV every two years; however, ANAR gathered information from the stakeholders involved bi-annually (until December 2017) and annually (since then). 28. The number of agglomerations changed almost permanently since the development of the initial Implementation Plan (2004) following a general downward trend for a number of reasons: (i) reorganization of agglomerations following the preparation of County WSS Master Plans (2007-2010) and their revision (2012-2017); (ii) changed lay-out of sewerage networks and location of WWTP during preparation of feasibility studies and engineering designs; and (iii) population drop – some agglomerations at the fringe of 10,000 and/or 2,000 p.e., respectively, lost a significant number of inhabitants and/or economic activities; such agglomerations moved to a smaller one (e.g. from above 10,000 p.e. to below 10,000 p.e., from above 2,000 p.e. to below 2,000) or dropped from compliance requirements. 29. The last report on UWWTD compliance11 provides data for 1,870 agglomerations (207 agglomeration above 10,000 p. e. and 1,663 agglomerations between 2,000 and 10,000 p.e.). Table 2 presents the estimated population and p.e. in these two groups of agglomerations. Table 2: Number of agglomerations, population and p.e. as at the end of 2017 Agglomerations* Population** p.e.* non- domestic contribution number number number % Above 10,000 p.e. 207 8 321 501 13 624 623 39% 2,000 -10,000 p.e. 1 663 2 513 710 6 611 943 62% Total 1 870 20 236 566 *Provided by ANAR (Raport ape uzate sem II 2017_final) **Own calculations based on 2011 census and NSI data for 2017 population by counties These estimations, although being rough, show much higher p.e. than the population number, i.e. considerable non-domestic (industrial) contribution to the biodegradable load, generated in the agglomerations. While 39 percent non-domestic contribution of the total agglomeration load for the larger agglomerations (above 10,000 p.e.) could be accepted as reasonable, the value of 62 percent for the smaller agglomerations appears highly overestimated. This is an indication that agglomeration loads should be carefully 11 Source: Raport ape uzate sem II 2017_final 24 reviewed or recalculated based on a sound methodology. It is anticipated that a proper calculation of the pollution load will results in reduction of the non-compliance rate. The UWWTD compliance situation as at the end of 2017, based on the data provided by ANAR in its report of 2017 is presented below. People connected to centralized collection system (Article 3 compliance) The ANAR report provides visualization of compliance situation with regard to the collection of wastewater, shown below: Figure 5: Connection rates to centralized collection systems at a county level Source: ANAR Report, 2017 In numbers, the compliance with regards to the connection looks as follows: Table 3: Article 3 compliance. Agglomerations Population equivalent (p.e.) Total Compliant* Total Compliant number number % number Number % Above 10000 p.e. 207 18 8% 13 624 623 2 489 544 18% Between 2000 -10000 1663 11 0.7% 6 611 943 69 952 1% p.e. Total 1870 29 1.5% 20 236 566 2 559 496 13% Source: ANAR data received by the WB team (Raport ape uzate sem II 2017_final) * It should be noted that for agglomerations above 10,000 p.e. the connection rate assumes p.e. connected both to centralized sewer network and IAS. For agglomerations between 2,000 and 10,000 25 p.e. the connection rate assumes only the p.e. connected to centralized sewer network; no information is provided concerning the IAS. These numbers indicate an extremely worrying low compliance rate. Only 29 agglomerations are reported as compliant, which is less than 2 percent of the total number of the agglomerations. In terms of connected p.e., the situation is not much better – only for 13 percent of the total p.e. there is compliance. However, population connected to the centralized sewerage networks is reported to be much higher – above 66 percent. The reason for this significant discrepancy is that, in cases, where the connection rate is lower than 98 percent, the agglomeration is reported as non-compliant, even if the connection rate is closer, but below 98 percent. This is in line with UWWTD requirements (legal compliance) even of it’s not reflecting the progress (distance to compliance). As per the directive compliance rate is assessed based on the simultaneous satisfaction of three criteria: • compliance with Art. 3, the rate of connection to collection systems in agglomerations larger than 2,000 p.e. must be of at least 98% and the remaining 2% should cover less than 2,000 p.e.; • compliance with Art. 4 and 5, the agglomerations should have a level of wastewater treatment (secondary or tertiary) of at least 99% of the overall collected wastewater and the remaining 1% should account for less than 2,000 p.e.; • the quality of the treated wastewater should match the requirements in Annex 1 of the UWWTD (the parameters established in Tables 1 and 2). The preliminary analysis, carried out during the inception phase of this assignment, showed that although not compliant, a considerable number of agglomerations have partial centralized collection systems in place. The data are shown in Table 4 below. Table 4: Article 3 distance to compliance. Agglomerations Population equivalent (p.e.) Total With partial or Total Connected completed collection system number number % number number % Above 10000 p.e. 207 202 97% 13 624 623 11 855 665 87% Between 2000 -10000 1 663 689 41% 6 611 943 2 060 105 31% p.e. Total 1 870 891 47% 20 236 566 13 915 770 69% Source: ANAR data received by the WB team (Raport ape uzate sem II 2017_final) The data indicates that in terms of distance to compliance the situation is much better (considering the fact that the country failed to meet the compliance deadline of December 31, 2018). While the efforts should focus on reaching UWWTD compliance in places where the distance to compliance is smaller, a special attention should be put on avoiding excessive costs. 26 Secondary treatment ensured (Article 4 compliance) Table 5 below summarizes the data about compliance with the provisions of Article 4 of the UWWTD. Table 5: Article 4 compliance. Agglomerations Population equivalent (p.e.) Total Compliant Total Compliant number number % number number % Above 10000 p.e. 207 14 7% 13 624 623 2 240 179 16% Between 2000 -10000 1663 6 0.3% 6 611 943 41 847 0.6% p.e. Total 1870 20 1% 20 236 566 2 282 026 11% Source: ANAR data received by the WB team (Raport ape uzate sem II 2017_final) The situation here is similar to the compliance in regard to Article 3 of the UWWTD, which is logical, because of the link “sewerage system-WWTP”. In comparison to Bulgaria, for example, it is obvious that there are limited cases where a sewerage system is not connected to WWTP causing point source pollution. The slightly lower values indicate that although not all sewerage pipes are connected to WWTP, the issue of discharge of untreated wastewater is not widespread. The UWWTD allows using of either the effluent concentration or the removal rate for assessment of the UWWTP performance. Romania has reported on the UWWTP implementation following the reporting requirements and using not only the removal rate criterion, but also the pollutant concentration in effluents. However, during the evaluation, EC consultants took into account only the removal rate criterion for the assessment of the UWWTP performance. In this regard, there are a lot of agglomerations with high dilution of influent wastewater, so the removal rate becomes very difficult and costly to be met. Using the requirement for effluent concentration would have been therefore more appropriate for Romania. In 2016 database, several WWTPs were reported failing compliance, although they had correct results of effluent concentration. Correcting this approach in the reporting methodology would help Romanian authorities to properly reflect the existing compliance reality in the country. Examples are shown in Annex 1. 27 Ensuring N and P removal (Article 5 compliance) Table 6 below summarizes the data for compliance with the provisions of Article 5 of the UWWTD. Table 6: Article 5 compliance. Agglomerations Population equivalent (p.e.) Total Compliant Total Compliant Number number % number number % Above 10, 000 p.e. 207 14 7 13 624 623 2 228 631 16 Source: ANAR data received by the WB team (Raport ape uzate sem II 2017_final) Status of the IAS Collection and temporary storage of wastewaters from households and small industrial units is also done through Individual and other Appropriate Systems (IAS), particularly in remotely located settlements, far from or uneconomical to connect to any existing central collection system. As of December 2017, the following status of IAS has been reported: • Septic tanks, all models, all dimensions – 5,837 units, for 458,386 p.e. • Small WWTP – 2,436 units, for 488,706 p.e. These values for IAS are cumulative, including both industrial and household units. There is no further level of details in the most recent UWWTD implementation reporting. IAS registration and monitoring process does not exist, which does not allow appropriate estimation of their load to complement and facilitate compliance reporting. Only the load collected from IAS and discharged at WWTPs located in agglomerations larger than 10,000 p.e. is reported by Romanian authorities. Industrial waste water Under monitoring (units above 4,000 p.e.) are 47 units, 20 of which are certified as compliant and 27 with reduced production or closed. Discharging load to the rivers per types of food industries is as follows: • 34.95% – dairy factories • 4.13% – products from vegetables and fruits • 2.53% – non-alcoholic drinks • 42.16% – meat and meat products • 16.22% – alcoholic drinks 28 2.4 Review of the accomplishment of the existing UWWTD Implementation Plan BACKGROUND 30. As mentioned above, the applicable UWWTD IP was adopted in October 2004 and became effective in 2007. The IP identified a total number of 2,609 agglomerations above 2,000 p.e. – including 263 above 10,000 p.e. and 2,346 between 2,000 and 10,000 p.e. All national territory was classified as Sensitive Area under Articles 5 (8) and 5 (2, 3) of the Directive, thereby requiring all wastewater treatment plants for agglomerations with more than 10,000 p.e. to comply with more stringent treatment for nitrogen and phosphorus removal. ACCOMPLISHMENT OF THE MAIN REQUIREMENTS OF THE IMPLEMENTATION PLAN 31. The Implementation plan established two types of requirements, which should be accomplished: Horizontal requirements and Main requirements. The Horizontal requirements concern mostly determination of the responsibilities of the relevant authorities, which appear to be accomplished. Thus, only the ten Main requirements of this document will be presented and discussed here, which had to be completed by December 31, 2018. Requirement 1 To designate the whole territory of Romania as sensitive area Status Accomplished in December 2004; whole territory of Romania designated as sensitive area Requirement 2 To ensure that all agglomerations of more than 2,000 p.e. are provided with collecting systems of urban waste water (Article 3) Progress 2004: 2609 agglomerations identified, 320 have sewage systems between 2004 201712: 1870 agglomeration; 29 agglomerations reported as compliant, but and 2017 891 have at least partially constructed collection systems, which collect about 69% of the total p.e.; This shows that the number of the agglomerations above 2,000 p.e. has dropped considerably in the period 2004-2017. The reasons for this are: (i) reorganization of agglomerations following the development of the WSS County Master Plans (2007-2010) and their partial update (2011-2015); (ii) changed layout of sewerage collection networks and WWTPs in the subsequent feasibility studies; (iii) population decrease – some agglomerations at the fringe of 2,000 p.e. lost a significant number of inhabitants and/or economic activates closed and they dropped from compliance requirements. While a relatively good percent of p.e. was reported to be connected to the centralized sewerage system in 2017 (nearly 70 percent), the compliance rate is extremely low – only 29 agglomerations out of 1,870. The reason for this discrepancy (percent connection population versus percent compliant agglomeration) was explained in the previous chapter. 12 Data for 2004 are taken from the Implementation plan. Data for 2017 are taken from ANR report, Conformitate agl.umane mai mari de 2000 l.e. decembrie 2017_ANAR 29 Requirement 3 To ensure that urban waste water entering the collecting systems of agglomerations of more than 2,000 p.e. are before discharge subject to secondary treatment or an equivalent treatment (Article 4) Progress 2004: N.A. between 2004 2017: 14 agglomerations above 10,000 p.e. and 6 agglomerations between and 2017 2,000 p.e. and 10,000 p.e. compliant with Art. 4. Requirement 4 To ensure that urban waste water entering in collecting systems from agglomerations of more than 10,000 p.e. and situated in sensitive areas are before discharge subject to more stringent treatment and the discharges satisfy the relevant emission standards for nitrogen and phosphorus (Annex I, Table 2, Article 5 para 2,3,4) Progress 2004: N.A. between 2004 2017: 14 agglomerations (out of 1,870) compliant, 16% of p.e. compliant and 2017 Requirement 5 To ensure that urban waste water entering in the collecting systems of agglomerations of less than 2,000 p.e. for discharges into fresh waters and of less than 10,000 p.e. for discharges to coastal water are before discharge subject to appropriate treatment (Article 7). Steps Identification and collection of the necessary data – accomplished in 2003; undertaken Implementation of the action programme for waste water treatment in the agglomerations of less than 2,000 p.e. – initiated. Requirement 6 To ensure that, where waters within the area of jurisdiction of a Member State are affected by discharges of urban waste water from another Member State, the affected Member State notifies to the other Member State and the Commission the relevant facts (Article 9) Steps Establishing a co-operation framework for notification in case of pollution undertaken with transboundary effect – accomplished; Identification of the discharges with transboundary adverse effect – accomplished. Requirement 7 To ensure that urban waste water treatment plants are designed, constructed, operated and maintained to ensure sufficient performance under all normal local climatic conditions (Article 10) Steps Analysis of existing water management technical regulations and standards undertaken according to the requirements of the Directive – accomplished; Drawing up a programme for updating the technical regulations and standards concerning the construction and operation of collecting systems and urban waste water treatment plants - The Law 10/1995 on Quality in Constructions sets the Government responsibility to issue / revise technical regulations. Through Government Decision 399/1995, the Ministry of Public Works (or its’ successors) is empowered to fulfill these obligations, while through its’ Order 542/2003, the Ministry of Public Works (MPW) approved the methodology for programming, contracting, elaboration and approval of the technical regulations on constructions. The general conclusion of this primary and secondary legislation was that the Regulations are to be revised when the monitoring structures in MPW consider that they need modifications. A more recent order, no. 2901 / 04.09.2013 for the approval 30 of the technical regulation “normative regarding the design, execution and exploitation of the water supply and sewerage systems of the localities (Indicative NP 133-2013)”, was developed by the Ministry of Regional Development and Public Administration. Updating the technical regulations and standards concerning construction and operation of collecting systems and urban waste water treatment plants – as above. Requirement 8 To ensure that the discharges of industrial waste water into collecting systems and urban waste water treatment plants (Article 11), the discharges from urban waste water treatment plants (Article 12) and the disposal of sludge from urban waste water treatment plants are subject to prior regulations and/or specific authorizations by the competent authority Steps Analysis of the existing legislation in the field of water management and undertaken waste management according to the requirements of the UWWTD – accomplished; Update of the existing legislation in the field of water and waste management – as needed; Issuing the relevant water management permits and licenses for construction and operation of urban waste water treatment plants – continuous. Requirement 9 To ensure that biodegradable industrial waste water from plant, which does not enter urban waste water treatment plants, complies with conditions established in prior regulations and/or specific authorization by the competent authority (Article 13) Steps Data collection and analysis of existing situation concerning biodegradable undertaken industrial waste water from plants belonging to the industrial sectors listed in Annex III which discharge in water resources – accomplished; Issuing of the relevant water management permits and licenses according with the requirements of the legislation in force – continuous. Requirement 10 To ensure the monitoring of discharged waste water, the monitoring of relevant receiving waters and the monitoring of sludge disposal procedures concerning sludge arising from urban waste water treatment (Articles 14 and 15) Steps Identification of the implementation steps – accomplished; undertaken Updating of the national monitoring system for water quality – accomplished; review during preparation of each phase of River Basin Management Plan for every river basin; Drawing and adoption of a methodology for collection and evaluation of monitored data – accomplished; methodology reviewed as above; Evaluation and periodical monitoring according to the requirements of the Directive – continuous. The tables above show that some of the requirements of the Implementation plan have been well accomplished. Those related to legislative action have been taken, but WSS investments are still lagging behind. After a period of 15 years and significant amounts of investments (see the paragraph below) the progress towards achievement of the requirements of the UWWTD (articles 3, 4 and 5) is still relatively modest. 31 PLANNED VERSUS MONEY SPENT ON WSS INVESTMENTS 32. The national Implementation plan concluded that: “At present, the estimated costs for the implementation of UWWT Directive are about EUR 9.5 billion for investments, EUR 5.7 billion for waste water treatment plants and EUR 3.8 billion for urban sewage collecting systems.” In the period from 2004 till 2019 the invested amount for achieving compliance with the UWWTD is approximately EUR 6.6 billion13, i.e. nearly 70 percent of the initially estimated investments were completed. However, distance to compliance is still considerable (about 30 percent of the load to be collected and 40 percent of the load to be properly treated as shown in the previous chapter of this report). This information indicates that the necessary costs for reaching compliance have been significantly underestimated, which would be taken into account during the update of the Implementation plan. These UWWTD implementation challenges are not unique for Romania, other new member states as Bulgaria and Croatia are also lagging behind but Romania’s remaining investment needs to achieve compliance are estimated to be the biggest. In addition to the “optimistic” projections for the required investments, the tight timeframe for compliance achievement to which the Romanian authorities had agreed (despite the extremely low starting point towards achieving compliance with UWWTD, which put the country in a rather unique position compared to the other member states) further complicates the ongoing challenges. 13 Raport ape uzate Sem.II_2017_final_ANAR plus ISPA funds 32 Chapter 3. Component A: Support for the update of the UWWTD Implementation Plan STEPS TO ACCELERATE UWWTD IMPLEMENTATION 33. The stocktaking assessment of the current UWWTD Implementation plan will be further strengthened in the next phase, while the team is working on Output 4: Report with a proposed updated Implementation Plan of UWWTD, including prioritization of measures and new timeline for compliance of the agglomerations above 2,000 p.e. to identify bottlenecks and options to accelerate compliance. Alignment of existing national policies, institutional arrangements, incentives towards improved compliance efforts as well as relevant lessons learned from other EU member states will also be reviewed and analyzed. Methodologies for better determination of agglomeration boundaries and estimation of their size (as p.e.) at national level will be developed in the framework of the current assignment to avoid excessive costs for reaching compliance. All agglomerations with incomplete collection systems will be analyzed on case by case basis to assess whether: • Increase of the compliance rate with no further investment could be achieved – this will be possible if IAS are well handled or when proper methodology is applied, and non-compliant areas appear outside agglomeration boundaries; • Excessive costs could be avoided – this will be possible if low densely populated areas are considered to be connected to IAS instead to centralized collection system. All agglomerations at the fringe of 2,000 p.e. and 10,000 p.e. will also be analyzed to: • Verify that the agglomeration boundaries are correctly established; • Verify that p.e. has been correctly estimated; These analyses should help Romanian authorities to optimize compliance costs by excluding some of agglomerations that are currently presented as being above 10,000 p.e. and requiring N and P removal as well as update the list of agglomeration above 2,000 p.e. by removing those that should no longer be there based on the revised methodologies for definition of agglomeration boundaries and calculation of pollution load. Thus, while ensuring the necessary environmental protection and compliance with UWWTD, the focus will be on putting in place an ambitious but achievable Implementation plan, which prioritizes interventions and investments, responsibilities and performance incentives, and proposes the necessary financing plan, which was the biggest missing piece from the 2004 program document. IMPROVING THE PROCESS 34. The analysis, presented in Section 1 of this report, leads to a conclusion that for reaching compliance in an effective way (in terms of time and money) the UWWTD implementation process should be streamlined by applying together: A. More precise definition of agglomeration boundaries and loads; B. Improvement of the reporting process; C. Development of a National Strategy for the Water Supply and Sanitation Sector. 33 This section presents the concept for Component A. Three methodologies will be developed as shown in the figure below: Development of methodology for definition of agglomeration boundaries ✓ Determination of sufficiently concentrated areas, suitable for centralised sewer system; ✓ Determination of areas suitable for IAS; Development of methodology for calculation of Development of methodology for the agglomeration loads implementation of IAS ✓ Sound procedures for registration and ✓ Precise defining of the organic load inspection of existing IAS; emitters within the agglomeration ✓ Sound procedures for establishment of new boundaries; IAS (planning, design, construction, O&M, ✓ Precise calculation of the agglomeration monitoring and control); load; Figure 6: Methodologies to be developed for improvement of the UWWTD implementation process The conceptual approach for each of these building blocks is presented below. 3.1 Methodology for defining agglomeration boundaries for agglomerations with more than 2,000 p.e. BACKGROUND 35. The concept of the “agglomeration” is central to the implementation of the UWWTD. The UWWTD specifies (article 2-4) “agglomeration” means an area where the population and/or economic activities are sufficiently concentrated for urban waste water to be collected and conducted to an urban wastewater treatment plant or to a final discharge point;” and (article 3-1): “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.” As the key concept of “sufficiently concentrated” is not narrowly defined it provides the authorities with some flexibility in defining agglomeration boundaries. To help with the interpretation and implementation of the UWWTD, in 2007 the UWWTD-REP working group published its “Terms and Definitions of the Urban Wastewater Treatment Directive”14. 14 http://ec.europa.eu/environment/water/water-urbanwaste/info/pdf/terms.pdf (last accessed on April 15, 2019). 34 One year later, in 2008, the Ministry of Environment and Sustainable Development of Romania published the document “Guidance on how to define agglomerations under the Urban wastewater treatment Directive 91/271”15. This document is consistent with the above-mentioned EU guidelines and supported the initial definition of the agglomeration boundaries in the country. However, it did not go further to suggest quantitative criteria for unified application by the local authorities involved in the process of definition of agglomeration boundaries. With the preparation of the WSS County Master Plans these authorities were empowered to define and approve agglomeration boundaries, which, in view of the lack of clear criteria, have led to oversizing or under-sizing and the corresponding financial and environmental implications. WAYS TO IMPROVE THE EXITING SITUATION 36. The document “Terms and Definitions of the Urban Wastewater Treatment Directive” provides in-depth discussion on how the terminology of the UWWTD should be understood. However, it does not transpose the two most substantial narrative terms “sufficiently concentrated” and “equal level of treatment” into quantitative guidance criteria. To assist Romanian authorities in taking decisions – which areas should be included or excluded from the agglomeration, there are three crucial issues, which would be clearly addressed in the Methodology for defining agglomerations boundaries to be developed under this assignment: A. How to consider lower densely populated peripheries of the settlements? B. Which are the cut-off values determining that a centralized collection system involves more excessive costs than IAS? C. How to apply the requirement for “equal level of environmental protection” for the collection system and the IAS as required by article 3-1 of the UWWTD? These three challenges are briefly discussed below. A. Considerations about the lower densely populated peripheries Historically, urban developments have been formed in most cases as high densely populated central areas and less densely populated peripheries. While central areas in most cases are more suitable for centralized collection systems, for the peripheries it is not always easy to decide whether they are “sufficiently concentrated”. The figures below illustrate a settlement (google map image used) with a few buildings in the periphery (red area A). 15 http://posmediu.ro/wps/contenthandler/dav/fs- type1/public/files/documente/Definirea%20aglomerarilor%20(Romania).doc (last accessed on April 15, 2019). 35 Inside agglomeration Inside agglomeration A A Option 1: Agglomeration Option 2: Agglomeration boundary boundary (in yellow) is equal (in yellow) excludes low densely to settlement boundary populated areas (red area A) Two options for defining of the agglomeration boundaries could be considered, respectively excluding or including low densely populated areas as shown in the figure above. Currently, agglomeration boundaries in Romania in most cases are the same as the settlement boundaries16, i.e. they include low densely populated areas (Option 1 above). Each of these options has some advantages and disadvantages as follows: Option 1 Option 2 (includes low densely populated (excludes low densely populated areas) areas) Advantages Existing agglomeration boundaries Possibly applies more strictly the (equal to settlement boundaries) definition of the UWWTD for are maintained. “sufficiently concentrated”. May result in a higher level of Results in a reduction of the size of environmental protection in the Agglomeration and associated cost of sparsely populated part of the infrastructure, hence avoids excessive agglomeration due to the costs for infrastructure. application of advanced IAS solutions. The option may fulfil the expectations of citizens about not being “left out” Disadvantages Higher level of environmental The level of environmental protection protection may result in higher may be reduced in the sparsely investment and operating cost if populated areas outside the new demands for centralized systems agglomeration boundaries due to are misunderstood, e.g. if there is application of traditional IAS solutions an expectation for piped collection rather than advanced IAS solutions that 16 Based on a review of WSS County Master Plans of Alba, Brasov, Calarasi and Iasi counties, prepared in 2013 36 covering the whole agglomeration provide better level of environmental area. protection. If the settlement grows in this direction, in a certain time it will become “sufficiently concentrated”, but will be left outside agglomeration boundaries. The disadvantages of Option 1 could be overcome if there are clearly defined areas, more suitable for IAS. The disadvantage of Option 2 associated with lower environmental protection could not be so easily overcome, because implementation, registration and control of the IAS outside agglomeration boundaries may result in even higher costs than if they had been kept inside agglomeration boundaries. The disadvantage of Option 2 associated with the growth or shrinking of an agglomeration could be overcome by regular update of the agglomeration boundaries (for example on every 5 years). Having in mind the existing situation in Romania, the WB team anticipates that the national Methodology for definition of agglomerations boundaries, which will be developed under this assignment, will enable Romanian authorities to have a more precise list of agglomerations, enabling proper assessment of compliance situation and optimization of compliance costs. Such an approach will be fully consistent with article 3- 1 of the UWWTD since the excessive cost of construction of centralized collection system will be avoided through construction of IAS, which achieve the same level of environmental protection. B. Cut-off values determining that centralized collection system involves excessive costs than IAS As mentioned, currently there are no clear cut-off values in Romania for the definition of agglomeration boundaries. The national document “Guidance on how to define agglomerations under the Urban wastewater treatment Directive 91/271” introduces a criterion “critical distance” as follows: “On the outskirts of an agglomeration, pay special attention to find the right border; set the borders of an agglomeration after a critical distance from currently built-up area and an area to be built up fulfilling the cost-effectiveness criterion. Beyond this critical distance, cost-effectiveness to connect the premises/settlements to a central sewer system is not assured and other technical solutions such as individual systems (i.e. septic tanks) should be considered” We have not seen in the reviewed WSS County Master Plans an analysis that refers to “sufficiently concentrated areas” or of the cost-effectiveness of the waste water collection system17. The Methodology for defining agglomerations boundaries to be developed under this assignment will follow the approach used by the World Bank while providing similar technical assistance to the Bulgarian Government, which has already been considered as 17 Ibidem 37 reasonable and acceptable by key WSS sector stakeholder players both at national and international level like DG Environment and DG Regio from the EC and JASPERS. In the case of the Bulgarian methodology development, in order to determine cut-off criteria for what constitutes “sufficiently concentrated” areas, a cost comparison between centralized systems and IAS was undertaken based on Present Value (PV). Costs of the piped sewerage system were taken from executed or on-going projects in the Operational Programme – Environment (OPE). Figure 7 below summarizes the cost comparison depending on whether only an extension of the sewerage system should be constructed (assuming an existing WWTP is available and has sufficient capacity), or both sewerage network and WWTP should be constructed. This example is taken from WB a similar work that the Bank delivered for the Government of Bulgaria and is presented for illustrative purposes. Figure 7: Cost comparison of sanitation options for Bulgaria Only the cheapest and the most expensive IAS are considered in this figure to outline the two boundary cases. IAS1 is the cheapest solution, “Septic tank plus soil infiltration system”. IAS3 is the most expensive solution, “Package WWTP plus tertiary treatment”. This approach enables determination of cut-off values. As shown in the figure, below 10- 12 people/100m sewerage pipe, all individual solutions are cheaper than piped sewerage system. For large agglomerations (more than 150,000 p.e.) piped sewerage system is cheaper than the cheapest individual solution at densities higher than 21 people/100m. For small agglomerations (less than 10,000 p.e.) piped sewerage system is cheaper than the cheapest individual solution at densities higher than 30 people/100m. Between the high values (30/21 people/100m) and the low value (12 people/100m) the relative costs depends on the local conditions (which type of IAS will be possible). In the case of Romania, the team will propose, discuss and use different cut-off values, which 38 need to reflect local conditions and especially population density and average historical and most recent costs to collect and treat pollution load from p.e. Alternative criterion (population density) was also applied in Bulgaria to determine the boundary of the sufficiently concentrated areas. This criterion correlates with the number of people connected per 100 m of pipework. Table 7 summarizes the decision-making scenarios for identifying sufficiently concentrated areas; the data presented is from Bulgaria and the criteria was consistent with JASPERS data and work in the country: Table 7: Determination of population density Item High density Medium density Low density >2,000 people/km2 Between 750 and <750 people/km2 2,000 people/km2 Agglomeration people/100m pipe 12< people/100m people/100m pipe ≤12 below 10 000 PE ≥30 pipe <30 without existing WWTP All other cases people/100m pipe 12< people/100m people/100m pipe ≤12 ≥21 pipe <21 Decision Collection system case by case IAS decision As mentioned above, the Methodology for defining agglomerations boundaries to be developed for Romania under this assignment will apply the same approach, but local reference data will be used. Costs for construction of centralized system will be taken from ongoing or executed investment projects. Costs for construction of IAS will be estimated based on the local market prices. C. Equal level of environmental protection for the collection system and the IAS With respect to IAS which discharge into surface water bodies “the same level of environmental protection” appears to have a clear interpretation, considering that UWWTD focuses on discharge of urban wastewater collection systems into surface water bodies. There are well-defined treatment levels in the UWWTD. Regarding IAS which discharge to the soil “the same level of environmental protection” is not defined in the UWWTD. To help with the interpretation and implementation of the UWWTD, the following recommendation is made in the document “Terms and Definitions of the Urban Wastewater Treatment Directive” (2.3.7): The decision as to whether a system can be regarded as in conformity with the final subparagraph of Article 3(1) has to be made individually on a case-by-case basis, taking into consideration the specific circumstances. A justification is always required (given the precise wording of the last sub-paragraph of Article 3(1)). The necessity for justification should be embodied in the transposing legislation. This is crucial from the point of view of the individual rights of citizens. The Commission should also receive summary information on the exceptions applied under the final sub-paragraph of Article 3(1). The challenge here is because the Soil Framework Directive is not in force. On 30 April 2014, the Commission took the decision to withdraw the proposal for a Soil Framework 39 Directive. In taking its decision, the Commission stated that it remains committed to the objective of the protection of soil and will examine options on how to best achieve this (European Commission 2014a, 2014b). The Methodology for defining agglomerations boundaries will propose modification to the Romanian legislation regarding IAS application to include a requirement for the same effluent quality of the soil discharge as of surface water discharge, considering that wastewater discharged to the soil may eventually reach a water body (ground or surface). This requirement will ensure prevention of pollutants to ground and surface water in accordance with the Water Framework Directive 2000/60/EC (European Commission, 2000). COVERAGE OF THE METHODOLOGY 37. The methodology will cover the following, but will not be limited to: Concept This chapter will provide the basis for development of the methodology, such as legislative background and experience in other countries. It will further give the overall framework including the suggested way to overcome the challenges, discussed in the previous section. In particular, it will suggest the approach for how the peripheries as well as the treatment level of the IAS, available in the Romanian market should be considered. Determination of cut off values for decision on centralized collection system or IAS Based on the approach, developed in Bulgaria and discussed in the previous section, cut off criteria for centralized collection system or IAS will be determined for Romania using local data. Two types of criteria will be provided: “number of people/connected to 100 m pipe” and “population density, people/km2”. These quantitative criteria will assist the process of delineation of the agglomeration boundaries and zones, suitable for IAS. Algorithm for defining agglomeration boundaries and IAS zones The document “Terms and Definitions of the Urban Wastewater Treatment Directive” provides extensive discussion on several specific cases, like: • A settlement, situated on both sides of a river, motorway, etc.; • A settlement with a quarter, located remotely from the central part; • A number of settlements connected to the same WWTP and with already existing collection system; • Other specific local situations. These specific cases will be organized in an algorithm, enabling methodologically sound step by step delineation of the agglomeration boundaries. Procedure for map delineation of the agglomeration boundaries and IAS zones A procedure for delineation of the agglomeration boundary will be developed considering the availability of GIS layers and statistical data. During the inception phase of this assignment, it has been clarified that the following are available: 40 • Orthophoto maps (provided by WMS through the National Agency for Cadaster and Land Registration – ANCPI), Google satellite images or their analogue – these maps will be used as a background layer. • GIS layers with the Local administrative units (LAU2) borders downloaded from the ANCPI through INSPIRE Geoportal18, footprint of buildings for 27 counties and transport network, by agreement with ANCPI. • GIS layers with the boundaries of the built-up areas of all Romania’s settlements, which have been provided to the World Bank in the framework of another project and GIS layer for the urbanized areas, which is available at CORINE Land Cover 2018 (CLC 2018), as well as County Master Plans– these layers will be considered together as indicative in excluding the area that are not suitable for centralized collection system. • Population grid, based on 2011 Census, available at National Institute of Statistics with resolution 1x1 km as well as in GHS POPULATION GRID with a resolution 250x250 m – these maps will be used as a third layer. To sum up, the process will be as follows: since the procedure is spatially based, the issue is how to capture disparate data at differing spatial scales to facilitate the delineation of the agglomeration boundaries and IAS zones. The LAU2 boundaries (SHP files) will be transposed in GIS environment (QGIS) with orthophoto maps, and settlements built-up borders. Data for the population density will be geo-referenced19 by joined with the LAU2 borders to obtain a GIS layer at this administrative level. Population data from 2011 Census will be classified and analyzed so that to exclude all settlements with less than 2000 inhabitants. Probably there will be cases where several settlements under 2000 people are close together and form an agglomeration with a sufficient number of inhabitants. After determining all agglomerations above 2,000 inhabitants based on 2012 Census data, all GIS layers will be overlaid (Orthophotos, CLC 2018 with delineation of urban areas, Google satellite images, LAU2 boundaries and County Master Plan data), and then we will proceed with the manual delineation of the agglomerations boundaries, considering the established methodology on what should be kept inside the agglomeration boundaries and what should be considered as IAS zone. 3.2 Methodology for calculation of agglomeration load for agglomerations with more than 2,000 p.e. BACKGROUND 38. The size of the agglomeration, in the sense of the UWWTD, is equivalent to the generated organic load within the agglomeration, expressed in “population equivalent” ( p.e., as 1 p.e. = 60gBOD5/day)). The UWWTD uses the size of the agglomeration, as the key criterion for determining the requirements for the wastewater management and the deadlines for reaching compliance. 18 http://geoportal.ancpi.ro/geoportal/catalog/main/aboutGeoportal.page 19 Georeferencing is the process of assigning real-world coordinates to each pixel of the raster. 41 Pursuant to item 1.3 of the UWWTD-REP,200720: “Member States should ensure that the method applied21 does not lead to any underestimation of the applicable treatment level and the overall volume to be treated.” The Guidance also provides a general calculation scheme for determining the agglomeration loads. At national level, the document “Guidance on how to define agglomerations under the Urban Wastewater Treatment Directive 91/271” developed by the Romanian Ministry of Environment and Sustainable Development in 2008, recommends the calculation of the generated load to follow the established general principles in UWWTD-REP, 2007. TYPES OF EMITTERS 39. Within an agglomeration, there are many emitters of organic load. Depending on their specific features however, they are divided into 4 major groups (UWWTD-REP,2007): • Permanent resident population The permanent resident population load, commonly known as “domestic load”, originates from the daily life needs of people (e.g. toilets, washing, food preparing, household maintenance, etc.). It can vary in quantity depending on the personal characteristics of an individual, as well as the social, cultural and religious habits of the population. It is relatively constant, at an annual base, in a given region. • Non-resident population (e.g. seasonal workers, tourists) The load is similar in type to the load of the resident population, although it may significantly vary throughout the year, depending on the period when the number of non- residents is highest (e.g. in case of seasonal tourist activities). • Industrial emitters All the industrial emitters that discharge into the centralized sewer system are subject to regulation pursuant to Art. 11 of the UWWTD. The industrial load originates from the production process and it is closely related to the input raw materials and the technological process. For determining of the size of the agglomerations, only the organic (BOD5) industrial load, prior to discharge into the sewer collectors is considered. Thus, the food processing industries, without on-site local pretreatment, can be a significant contributor to the load, respectively the size of the agglomerations. Pursuant to UWWTD-REP, 2007, the load of the agglomerations “…does not include the load of unmixed industrial waste water which is treated separately and directly discharged into waters". • Other emitters The other possible emitters not encompassed within the above-mentioned groups shall be decided case by case for each specific agglomeration. This shall include all the remaining wastewater generated within the agglomeration. This could be big trading 20 UWWTD-REP 2007 para 1.3, see: http://ec.europa.eu/environment/water/water- urbanwaste/info/pdf/terms.pdf 21 i.e. the method applied for the calculation of the agglomeration load; 42 centers where other than domestic type load could appear or livestock in village households where the load can enter the sewer network. CALCULATION OF THE AGGLOMERATION POLLUTION LOADS IN ROMANIA 40. The pollution loads of the different emitters are calculated either: a) separately for each of the above-mentioned groups or b) as conglomerate load, e.g. in case there is WWTP treating the collected load within the agglomeration. It should be noted that the load of the IAS is also a kind of “conglomerate load” of the emitters connected to them. The existence of the IAS shall be taken into account, since they can turn to be the decisive factor for reaching compliance of a given agglomeration. Based on the information, at local level (collected at the time of writing of the report) the following conclusions can be made: Case a) separate calculation of the emitters loads • Permanent resident population The population load, calculated in the reviewed WSS County Master Plans, assumes that the specific BOD5 load of one person is equal to 60 gBOD5/d, i.e. 1 p.e. • Non-permanent resident population No specific information was found. • Industrial emitters In the reviewed WSS County Master Plans, the industrial wastewater volume is taken as a percentage of the domestic volume and the Industrial water is assumed to be 100% percent pre-treated, which means that it was brought to the chemical content of the domestic waste water (Romanian, NTPA 002 discharge regulation). When specific information could not be collected, the industrial load was determined as percentage of the population load, e.g. 10 percent in small agglomerations and 15 percent in bigger agglomerations. • Other emitters No specific information was found. Case b) calculation of the emitters loads as a conglomerate load Currently in Romania there are 711 WWTPs treating the wastewater from the whole agglomeration or from parts of it (the predominant case). The conglomerate load of all the emitters, entering the WWTP, is assumed to be determined as the “maximum average weekly” load based on the monitoring data about the flow and BOD5 concentration at the inlet. Concerning the IAS loads reported for the agglomerations above 10,000 p.e. no information was found on how they have been determined. The information in the ANAR database is insufficient to clarify on whether the wastewater of the IAS is treated at the municipal WWTP or there is local treatment, although the sum of the collection rates to sewer network and IAS is equal to the collection rate of the WWTP. It was communicated that in case of lack of specific information, the load of the IAS is calculated through the wastewater volume and BOD5 concentration acc. to the provision 43 of HG no. 188/2002 amended (i.e. 300 mg/l BOD5 for IAS pumping and transported by truck to the UWWTPs/sewage network and for the influent of small UWWTPs). There is no evidence however that this approach has been applied in the reporting of the agglomerations above 10,000 p.e. The predominant situation in the Romanian agglomerations is a combination of case a) and case b). Then the agglomeration load is a sum of the loads calculated according to case a) and case b). In this context it is important to be determined the proportion of loads calculated as conglomerate or separately within a given agglomeration. Therefore, it is necessary to be determined the connection rates to sewer system and to WWTP. The connection rates to sewer network and to WWTP are the key conditions for determining compliance/or non-compliance of the given agglomeration according to Art. 3 and Art. 4 of the UWWTD. Based on the information received, it seems that the connection rates in the WSS County Master Plans and/or application forms for EU funding have been determined according to specific assumptions (e.g. based on the number of connections to sewer system). The information needs to be verified case by case, since sometimes the way of determination of the connection rates seems not to be very clear. Concerning the connection rate to WWTP, if there is no direct discharge of sewage water into the river body, it is assumed that the connection rate is the same as the connection rate to the sewer network plus (eventually) the connection rate to IAS. CONCEPTUAL APPROACH FOR CALCULATION OF THE AGGLOMERATION LOAD 41. As above-mentioned, the type of wastewater management (WWM) predetermine the way of calculation the agglomeration load. There can be three types of WWM. depending on the level of social and economic development and on the site-specific characteristics. Figure 8: Types of WWM within an agglomeration • Type 1 WWM - all generated load is collected through centralized sewer network, conveyed to the municipal WWTP and after treatment discharged into a receiving water body (Figure 8, T1); • Type 2 WWM - all generated load is collected through centralized sewer network and discharged into a receiving water body without treatment (Figure 8, T2); 44 • Type 3 WWM – there is no centralized sewer network. Each emitter is solving the problem “on its own” (Figure 8, T3). In the common case the domestic load is collected through different types of individual systems (i.e. water tight tanks, cesspits, individual WWTPs, etc.); The review of the current level of compliance according to Art. 3 and Art. 4 of the UWWTD has led to the conclusion that all the above-mentioned types of management exist. The agglomerations can be conditionally divided into seven groups of cases (Table 8). Table 8: Different types of wastewater management in the agglomeration of Romania as per December 2017 Agglomerations Agglomerations above 10,000, between 2,000 - Cases Short description of the case (Type of WWM) p.e. 10,000 p.e. Compliant with art. 3 and art. 4 Case A 18 6 (Type 1, Type 3 WWM) Compliant with art. 3; NO WWTP Case B1 0 4 (Type 2 WWM, Type 3 WWM) Compliant with art. 3, there is WWTP but NOT ALL the Case B2 load connected 1 1 (Type 1, Type 2, Type 3 of WWM) Incomplete sewer system, NO WWTP Case C1 5 241 (Type 2 , Type 3 WWM) Incomplete sewer system; all the collected load treated Case C2 in existing WWTP 171 429 (Type 1 and Type 3 of WWM) Incomplete sewer system; NOT ALL collected load is Case C3 treated in existing WWTP 7 8 (Type 1, Type 2, Type 3 of WWM) Case D NO SEWER SYSTEM, (Type 3 WWM) 5 974 Total 207 1 663 Source: Own calculations based on ANAR data base, 2017 42. Depending on: 1) the existence/non-existence of a municipal WWTP; 2) the availability of representative monitoring database on the wastewater quality at the inlet and 3) the types of WWM applied within an agglomeration, two general options for calculation the agglomeration load are suggested for Romania. 45 Option 1: Existing WWTP with sufficient and reliable database at the inlet of the plant ▪ The load is calculated acc. to Art. 4(4) of the WWTD (i.e. maximum average weekly load); Type 1 ▪ In case one WWTP is serving several agglomerations, the contribution of each WWM will be determined proportionally to the population, if there is no any other more specific information. ▪ In case of NON-evenly distributed social and economic activities, the load is calculated as sum of the separately calculated loads of the different groups of Type 2 emitters. WWM ▪ The load is calculated as sum of the loads of the permanent and non- Type 3 permanent residents and other emitters (e.g. household livestock). Separately WWM treated and directly discharged industrial waste water into the receiving water bodies, is not considered. The types of WWM are as per Figure 8. Option 2: No WWTP or the existing one has no sufficient and reliable database at the inlet Type 1 • The load is calculated as per Type 2 of WWM WWM Type 2 ▪ The load is calculated as sum of the separately calculated loads of the different WWM groups of emitters. ▪ The load is calculated as sum of the loads of the permanent and non- Type 3 WWM permanent residents and other emitters (e.g. household livestock). Separately treated and directly discharged industrial wastewater into the receiving water bodies, is not considered. 43. The suggested calculation approach for the above presented single elements and/or emitters is explained below: • Load of the WWTP In case of existing WWTP, with sufficient and reliable database, the generated load of all the emitters connected to the WWTP shall be assessed as the maximum average weekly load during a year, excluding unusual situations such as those due to heavy rain (refer Art. 4(4) of UWWTD). There is no specific determination for the “sufficient” and “reliable” database. The calculation approach however, assumes that there shall be credible measurement of the flow and BOD5 concentration at the inlet of the WWTP at least twice per week (i.e. 104 samples per annum). In case of smaller number of samples, the requirement of Art. 4(4) can be applied conditionally. 46 • Load of the emitters connected to sewer network but not to WWTP In case that the social and economic activities are evenly distributed throughout the agglomeration, the summary load of the emitters not connected to the WWTP can be assessed as percentage of the pollution load at the WWTP based on a) the share of the connected/not connected population or b) the share of the respective area. In case that the social and economic activities are not evenly distributed throughout the agglomeration the load of the emitters connected to sewer network but not to WWTP will be calculated separately, i.e. o Resident population The load will be calculated as per the current practice in Romania, i.e. the specific load of one person is equal to 1 p.e. (60 g BOD5/cap/d). After collection of sufficient and reliable database from different WWTPs with predominantly domestic load, a study can be developed on determining of a representative value for Romania for the specific BOD5 load per person per day. o Non-resident population Since it is a domestic load, it will be calculated in the same way as the load from the resident population. For the resort type agglomerations, additional increasing of the non- resident load may be considered due to the servicing staff and/or increased food offering public premises. This shall be considered case by case. The maximum daily load of the non-resident population shall be considered when determining the size of the agglomeration. • Calculation of the industrial load Determining the load of the industrial emitters is usually a challenging task. Separate calculation of the industrial load will be necessary for the agglomerations where a sewer network exists but there is no WWTP or not all sewer collectors are connected to the WWTP. There are 13 agglomerations above 10,000 p.e. and 254 agglomerations between 2,000 and 10,000 p.e. that fall in one of cases B1, B2, C1 and C3 in Table 8 With 509,000 p.e. connected to sewer network but not to WWTP, the agglomeration of Bucharest leads this group22. In one agglomeration there can be hundreds of industrial units, not all however produce organic load with industrial origin or the individual share of most of them is negligible. Therefore, it is suggested: 1) the industries to be divided into “significant” and “non- significant” based on their percentage contribution to the waste water flow of the agglomeration; 2) special considerations to be given to the significant industries in the food processing sector and 3) the additional pollution load of the non-significant industrial emitters to be considered as percentage of the population load. The load of the major industries, subject to wastewater quality regulation according to BOD5 will be determined based on monitoring data, provided by the WSS Operators. The load of non-significant industries will be determined as a percent of the load of permanent residents. The percentage factor will be initially set (based on practice in other countries) in the range of 1 to 5 %, based on the agglomeration size. 22 According to the ANAR database, at December 2017 47 If there is no information on the major and non-major industrial emitters, their total load will be determined as percent of the load of permanent residents. The percentage factor will be initially set (based on practice in other countries) in the range of 5 to 20% based on the agglomeration size. The values of the factors can be further refined during the data processing, e.g. after processing the data from all the UWWTPs, a survey can be performed on the likely contribution of the industrial sector depending on the size of the agglomeration. Tailor made percentage factor can also be applied for certain agglomerations based on specific information (e.g. Master Plans or Regional Feasibility Studies). • Load of the Individual Appropriate Systems Based on the information collected so far, it appears that the existence of the IAS within the agglomerations is not well documented. Therefore, the general approach will be the load of the IAS to be calculated based on the number of people connected to IAS and their specific loads. In some specific cases, where the municipal WWTP treats predominantly domestic type load, the conglomerate load of the IAS may be calculated as percentage of the WWTP load based on the percent share of the population connected to IAS. • Calculation of the connection rates It was communicated that the ROCs do not maintain database of the individual accounts of households but only database of the accounts of the residential buildings. The determination of the population connection rate is a bit more complicated, since in the predominant case, the residents are irregularly spread all over the agglomeration area, as well as the sewer service. The WB team is planning to use the information by the ROCs and local operators concerning the connection rates to sewer network and WWTP. The method of determination of the rates will be clarified. Upon receiving sufficient information, the team will develop a methodology of more precise determination of the connection rates. NECESSARY DATABASE AND SOURCES OF INFORMATION 44. The necessary database for the calculation of the agglomeration loads is presented in the table below: Table 9: Data base needed at agglomeration level and potential sources Data/Emitter Data needed Data source Resident • Current/projected number of people; National Statistical Population Institute Industrial Emitters • Information about the significant industrial users WSS Operators, Industrial concerning the wastewater flow and quality, management bodies. discharged into the sewer network: specific data on Public information the type and technology of production, monitoring data, discharge permits. Non-resident • Current/projected number of non-residents (e.g. National Statistical population tourists, seasonal workers, barracks); Institute; County, Municipal administrations Other wastewater • Information about the type of wastewater source; Municipal sources • Information about the specific pollution load or administrations monitoring flow and quality data, if available. 48 Connection rate • Information on the current values of connection WSS operator data rates to sewer network and to WWTP WWTP data • Regular (daily) monitoring data on the wastewater WSS Operators flow and quality at the inlet of the existing WWTP (for year 2018, if available). Draft template of the data base has already been shared with three ROCs and partial data was received. After reviewing and analyzing the data the WB will finalize the request for information and send it to MoWF for distribution to all entities providing WSS services to existing agglomerations. Timely submission of requested data will be extremely important for proper delivery of the current advisory services (all components). The leading role of MoWF is crucial for obtaining information from Romanian institutions and operators. While the Agreement’s clause 9 (b) provides legally for the case that there would be delays or lack of data (“It is expressly agreed and understood that the Bank shall bear no responsibility for delay in performance occasioned by the Recipient’s failure to provide its contribution as set forth in Section D of the Schedule to this Agreement or otherwise cooperate as set forth in paragraph (a) above”) we encourage MoWF and ANAR to continue being proactive and keep the team informed on any issues related to obtaining data from other institutions. 3.3 Application of Individual Appropriate Systems INTRODUCTION 45. The term „Individual Systems or other Appropriate Systems“ (IAS) is introduced in Article 3(1) of Council Directive 91/271/EEC concerning urban wastewater treatment (UWWTD). The application of IAS is stipulated as an alternative to centralized collection systems 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”. Considering the above, the application of IAS is discussed in light of achieving: • Accelerating the UWWTD compliance rate and, • possibility for achieving optimization/reduction of compliance costs. Two aspects need to be clarified before taking a decision to apply IAS, as follows: • cut-off criteria for “excessive costs” in the country context, and • the requirement of the UWWTD for “the same level of environmental protection” between the IAS and the centralized system. To determine the cut-off criteria for “excessive cost” in Romania, a cost comparison between centralized systems and IAS will be undertaken, based on the Present Value (PV) of initial investment costs and the annual expenses for maintenance and operation as explained in section 3.1 of this report. To determine “the same level of environmental protection” between the IAS and “centralized system” discharge values for respectively soil or water bodies will be set a s explained in section 3.1 of this report. 49 ROMANIAN IAS RELEVANT LEGAL FRAMEWORK 46. There is no specific piece of legislation regulating the application, design and construction of IAS. Several laws, bylaws, design norms and standards include requirements for design and construction of IAS, while the requirements for operation and maintenance are succinct. For example, Art 3(e) of the Law 241/2006 concerning the water supply and sewerage services, which specifies typical components of sewerage systems does not include IAS. However, Art 2(4) of the same Law stipulates that in rural localities only water supply services can be organized, as appropriate, provided that collection of wastewaters is ensured by other individual systems. The following European IAS standards are adopted by the Romanian Institute for Standardization: • EN 12566-1:2017 Part 1 – prefabricated septic tanks; • EN 12566-1:2017 Part 3 – packaged and/or site assembled domestic waste water treatment plants; • EN 12566-1:2017 Part 4 – septic tanks assembled in situ from prefabricated kits; • EN 12566-1:2017 Part 6 – prefabricated secondary treatment units; • EN 12566-1:2017 Part 7 – prefabricated tertiary treatment units; The EN 12 566:2017 Part 2 – soil infiltration systems and Part 5 – pre-treated effluent filtration systems have not been adopted in Romania, though soil infiltration (through septic tanks) is in use. In conclusion, the Romanian water supply and sanitation legislation does not provide a systematic regulation of the IAS and in particular excludes the stricter requirements of EN standard for soil infiltration and pre-treated effluent filtration systems. Apparently different individual systems are in use, based on technical agreements specific for each product/system. PROPOSED APPROACH TO PROPER APPLICATION AND REPORTING OF IAS 47. Currently, in Romanian reports to the EU the load from IAS in p.e. is only provided for agglomerations above 10,000 p. e., because the load produced by all existing individual systems is not known. Since a significant percentage (around 34 percent23) of the population does not rely on centralized wastewater collection one can conclude that a similar percentage uses some type of individual system. The question is whether the existing individual systems comply with the adopted technical standards and achieve the level of environmental protection as required by the UWWTD. To answer this question and be able to include the IAS as component in reporting on compliance with WWTD requirements, the Government of Romania will need to introduce a system of registration and monitoring of IAS. While the registration of the newly built systems seems straightforward, i.e. with the issuance of the permit for use of the respective house/building by the competent authority, the challenge comes from the existing IAS. In order to establish a system for registration and monitoring of IAS we will propose to the Government to assign competent authorities and allocate respective 23 The difference between 100% and existing coverage as reported by ANAR 50 budget. The latter will be used to inform the affected people, planning of IAS zones, preparation of inspection plans, inspectors’ salaries etc. Part of the budget allocations can be secured through introduction of IAS registration fee. In general, the responsibilities of the different stakeholders should be as follows: Stakeholder Responsibilities National Initiates the process, assigns competent authorities and Government responsibilities (local authorities, water and environmental authorities) Competent Prepare a register, register the IAS within a designated area, plan Authorities inspections, hire inspectors, monitor IAS performance, impose sanctions IAS Carry out field inspections, prepare inspection reports, issue inspectors instructions to IAS owners IAS owners Register their IAS, operate (empty) and maintain IAS by themselves or through a contract Consolidated proposal for competent IAS authorities and responsibilities of all stakeholders will be made after consultations with the relevant central institutions, local authorities, water operators, NGOs, IAS providers etc. The proposal will cover all stages of planning, design and construction/reconstruction, putting into operation, registration and inspection, monitoring and control of both existing and new IAS. If there is a consensus on the proposed process, an action plan will be elaborated including, activities, cost and implementation time of each activity and responsible entity/institution. In general, the action would may include the following activities: (i) setting up of inter-agency working group to elaborate and agree on the details; (ii) preparation of regulatory changes to enable the process; (iii) development of technical guidelines; (iv) development of IAS register; (v) identification of IAS areas; (vi) preparation and rolling out of public awareness campaign; (vii) registration of existing IAS; (viii) drafting of a 3 year IAS inspection plan; (ix) inspections; (x) reconstruction/replacement or performance improvement of existing IAS. 3.4 Strategic Financing Plan DEVELOPING A STRATEGIC FINANCING PLAN FOR THE REMAINING COMPLIANCE INVESTMENTS 48. UWWTD is and will remain one of the key environmental legislations, however, one of the objectives of this assignment is to assist the Government of Romania on implementing it in the most cost-effective and economically efficient manner. The prevailing driver for UWWTD compliance remains the need for uniformity of regulatory compliance under the EU directives, and environmental protection beyond strict economic justification. This, however, does not mean that economic efficiency could not be improved by a closer alignment of Directive 91/271/EEC with the WFD principles and objectives, for example, through better prioritization of wastewater infrastructure investment. In addition, the use of economic appraisals, such as cost-effectiveness analysis or cost-benefit analysis, to assess the impact of wastewater projects could help improve investment efficiency while maintaining environmental and health benefits and achievement of WFD objectives. 51 The positive environmental and health impact created by massive UWWTD-driven investments can be preserved and further enhanced only if service quality levels are sustained or improved. If system operation and reinvestment are not financially sustainable, there is a risk of decline in service quality and deterioration of quality of discharges into receiving waters. Hence the issue of UWWTD investment sustainability needs to be addressed through a clear prioritization of investments, persistence for sustainable solutions, proper costing of sewerage network and wastewater treatment plant (WWTP) projects, including lifecycle and long-term costs and funding planning. Because the financing gaps between tariff revenues and total costs of wastewater services already exist in several new member state countries (Bulgaria, Croatia), there should be an effort to strengthen the financial viability of utilities to ensure financial sustainability. Most recent fairly rough calculations made by EBRD and Water Industry Commission of Scotland (WICS) present figures amounting to EUR 40 billion for Romania to achieve compliance. The WB team will make more detailed calculation reflecting the work on the above-mentioned methodologies. Management of the new assets, their financing, operation, maintenance and future replacement should be tackled also in the case of Romania, where so many small operators exist, which are not sustainable and can hardly be expected to achieve UWWTD compliance in the agglomeration served by them. According to the EC forecast for Romania the economic boom that began in Romania in 2017 eased in 2018. Real GDP growth eased from 7 percent in 2017 to 4.3 percent annualized in the first three quarters of 2018. For the year as a whole it is estimated at 4 percent. The slower pace of growth was due to private consumption, as the effects of tax cuts implemented in 2017 faded away and inflation weighed more heavily on real disposable income. Real GDP growth is forecast to further decrease to 3.8 percent in 2019 and 3.6 percent in 2020. Headline inflation is forecast to decelerate further to 3.3 percent in 2019 and 3.1 percent in 2020, driven by base effects and falling oil prices. However, a further depreciation of RON against EUR poses an upward risk to price levels. This macroeconomic context will be taken into account by the team, while rethinking the approach to wastewater management and availability of fiscal space and opportunities for additional funding to the WSS sector. 52 Figure 9: Romania GDP growth Source: European commission, Economic forecast for Romania, 2019 Finally, affordability issues deriving from UWWTD implementation need to be tackled. UWWTD implementation requires substantial investments, which result in operating expense (OPEX) increase. This leads to tariff increases, which trigger affordability issues requiring proper policies and support at national and local levels to ensure access to services for vulnerable households. APPROACH TO THE STRATEGIC FINANCING PLAN 49. The preparation of a draft Strategic Financing Plan is intended to address the financing needs in Romania, notably the challenges towards achieving compliance with UWWTD. It will analyze the three sources of funds for WSS expenditure, namely tariffs, taxes and transfers in annual time steps for the next 20 years in the country. It will compare a baseline trajectory for these sources with the funding needs for the investment required for compliance24. Based on the updated list of agglomerations over 2000 p.e., the remaining investments will be calculated considering the most up to date information and investment needs calculations, where information is not available or reliable. The gap between expenditure needs and availability of funding will be calculated and policy options for bridging the WSS sector funding gap will be presented, discussed and agreed with the Government of Romania. 24 Investments remaining through SOP Environment, the feasibility studies under LIOP, implementation financed from other sources (PNDL, PNDR, State Budget, Environmental Fund, etc.), remaining investments from the County Master Plans for reaching compliance with the Water Directive and Wastewater Directive, as well as estimations and calculations by the WB team during the implementation of this assignment. 53 In this regard, a master financial model (FM) will be developed and populated for each WSS Operator at county level (to display the financing needs and the possibilities for their financing), options for WSS service provision for agglomerations above 2,000 p.e. not currently covered by ROCs will be presented, discussed, agreed and FM will be created, and finally an aggregated FM at national level will be produced – to aggregate and present the big picture for Romania at national level, to demonstrate when the compliance with UWWTD can be achieved at a country level. This master model would serve as the backbone of the different Scenarios to be developed to demonstrate how the investment needs for each WSS Operator can be financed, and would provide answers to the following questions; • Is there a capital expenditures (CAPEX) financing gap and what are the options for filling it - ESIF, or Private and public capital investments, or IFI loans and other debt financing, or a combination of some or all of the above? • Is there an OPEX financing gap and what are the options for filling it - tariffs vs. taxes? • What is the estimated ability of the existing WSS Operators to operate, maintain and finance from available funding sources the existing and new infrastructure (in particular water treatment and wastewater treatment infrastructure)? • What are the affordable tariffs levels for the population relative to household incomes - not just the averages but also at distribution of incomes to capture social equity? • What’s the minimum size of an operator to be able to invest, operate and maintain the required WSS infrastructure? • What is the likely impact of potential consolidation of WSS Operators on delivery of significant WSS investments, efficiency gains and thus optimization of costs and revenues? • What is the impact of the calculated expenditure needs on water WSS tariffs assuming full cost recovery; Different scenarios, displaying the remaining funding gap and options for bridging it towards, will be developed and presented, including: • Business as usual scenario. • The previous Scenario + EU grant at max (for CAPEX) and maximum tariff increases (for CAPEX and OPEX), where the eligibility of the WSS infrastructure by EU Fund and the affordability issues will be reflected. • The previous Scenario + commercial/IFIs debt financing (where the bankability of the WSS Operators will be considered). • The previous Scenario + Governmental grant to close the remaining funding gap. • The previous Scenario with reduced OPEX resulting from efficiency gains from consolidation and enhanced technical efficiency. As needed, a set of policy options including options for reduced/delayed capital expenditure and for enhanced financing will be developed. These policy options will be discussed with the Government of Romania and the selected option will later become part of the National WSS strategy vision. The developed draft SFP would become part of Output 4: Report with a proposed updated Implementation Plan of UWWTD, including prioritization of measures and new timeline for compliance of the agglomerations above 2,000 p.e. Later on, the national FM would be updated during the drafting the WSS 54 strategy recommendations proposals to reflect the proposed additional measures at national level. It is expected that Government investment support will be more demanded from counties with larger investment needs and less ability to self-finance25, however, redistribution of EU funding and budget resources will be discussed and agreed with the Government of Romania during the preparation of the SFP. The results will be visualized through graphs and tables. KEY ASSUMPTIONS 50. The expenditure needs are the starting point for the Strategic Financing Plan. CAPEX may influence financing needs directly and indirectly; usually compliance-driven investments increase CAPEX (for example the construction of a new treatment plant), while efficiency- driven investments decrease OPEX (for example, rehabilitation of old pipes, refurbishment of pumping stations, etc.). Therefore, the CAPEX and OPEX will be considered jointly. The short-term investment programs and County Master Plans will be used where available. Similarly, for financing: where EU grants have been committed already, this funding will be allocated to those counties and projects. The master model will be developed first for one of the Water Operators, e.g. for an Operator with existing approved County Master Plan, an Operator that is also a pilot for other purposes etc. When finalized, it will be then pilot tested with another 3 Water Operators with different characteristics, to allow for early adjustments to different specifics. The aggregation at national level will be made by Scenarios. The proposal is to develop the first master model for Brasov Water Operator which has an excellent financial situation, and to pilot test it on selected Water Operators from the followings: • Iasi and/or Timis Water Operator both operating at county level, with different population connection rates resulting in different investment needs; • Alba and/or Vrancea Water Operator with similar county sizes and projects approved under POIM; • Bihor and/or Bacau Water Operator from rather large counties and operating only in some localities. • Bistrita and/or Satu Mare Water Operator from rather small counties and operating at county level; • Calarasi and/or Olt Water Operator operating only in some localities at county level • Caras Severin and/or Vaslui Water Operator with limited extension in the county and rather challenging financial situation. 25 A very good example reflecting the inactivity of the sector is the fact that the total cash available at the level of regional operators is around 250 million Euro, while the investments from own sources stay at around 40 million/year, despite huge needs to reach compliance (Water Sector Development in Romania, Strategic paper, 2019-2035). 55 GOING FORWARD: MANAGEMENT MODELS OF WSS SERVICE DELIVERY 51. The UWWTD requires the member states to build and operate sewage collection systems and treatment plants for all urban wastewater emerging from agglomerations with more than 2,000 p.e.26. Unfortunately, Romania could not comply with the targets set under the UWWTD, within the timeframe negotiated before EU accession. To better plan for compliance, it is imperative for the country to develop a comprehensive plan to address the delayed compliance, including the new investments needed. 52. Currently the water and sanitation services are performed27 by: 43 regional operators, 2 large operators with mixed capital (public and private), and 956 small operators. The market share of the 43 ROCs covers about 72 percent of the population connected to WSS services (9 million out of 13.2 million people that benefit of water supply, and 6.9 million out of 9.5 million connected to sewerage collection networks28). The water operators in Bucharest and Ploiesti, altogether, serve another 2 million people benefiting from water infrastructure and 1.7 million people connected to sewerage collection. Hence, only 15 to 17 percent of the population is served by the small operators. 53. Having in mind the recent analysis and recommendations made by EBRD29, lack of decision on ROC expansion to cover all agglomerations above 2,000 p.e. and clear lack of investment and delivery capacity by smaller operators30, only two options seem viable for development of the strategic financing plan for the WSS sector: 1) to develop Scenarios based on the master model for all 43 regional operators, Bucharest and Ploiesti, where the financing needs of the remaining 900 small operators serving agglomerations above 2,000 p.e. are estimated based on a sample analysis; or 2) to develop Scenarios based on the master model only for all 43 regional operators, Bucharest and Ploiesti with the assumption that they will expand to cover all agglomerations above 2,000 p.e. The second option would involve significant assumption as well as an administrative decision forcing ROCs to expand. The WB team recommends using the first option as а more balanced one. REQUIRED DATA AND INFORMATION 54. To estimate the investment needs for compliance and before data collection, the World Bank team will assess the existing data. It will refer to the EBRD ’s technical assistance which already collected and analyzed data regarding the current situation in the sector and of the new investments needed for compliance. Information was requested from MRDPA, MEF, ANAR, ANRSC and benchmarking platform. Also, detailed customized questionnaires in Excel were used to collect information on various categories including 26 Compliance with the Directive No 91/271/EC on urban wastewater treatment: (i) by 2015 for all agglomerations with more than 10,000 p.e.; (ii) by 2018 in all agglomerations between 2,000 and 10,000 p.e. (thus, investments needed for urban wastewater collection, treatment and discharge infrastructure); 27 EBRD-RAMBOL-BDO: Water Sector Development in Romania, Strategic Paper (Draft), 2019, page 38, based on information provided by ANRSC 28 Population connected to water supply services, INS, 2019 29 EBRD-RAMBOL-BDO: Water Sector Development in Romania, Strategic Paper (Draft), 2019 30 WB will use its global experience to propose different management models for small systems during the preparation of WSS Strategy outline. 56 information related to performance, impact of investments from different sources as well as information related to the value of remaining investments from the County Master Plan for reaching compliance with the Wastewater Directive. The World Bank team will review the methodology and assumptions used for this data collection and processing, as well as the results of these assessments. A template questionnaire for data collection of financial and operational data as well as the investment needs is being prepared. It will be adjusted depending on the data readily available from other sources to enhance reliability of the analysis and avoid overlapping. We estimate at about two months the time needed to collect and input the data in the questionnaires, considering that access is granted to the respective sources. The estimated period might extend in case the information needs to be collected from each water operator and other sources. 3.5 Establishing a baseline and a new timetable on UWWTD implementation BACKGROUND 55. The analysis, done during the conceptual phase of the assignment shows that there is scope to accelerate the process of reaching compliance with the requirements of the UWWTD at reasonable costs, provided that a structured comprehensive approach for determination of agglomeration boundaries and load is applied. The room for improvement lies in: 1. Developing a sound methodology for redefining agglomeration boundaries; 2. Developing a methodology for correct calculation of pollution load; 3. Updating the list of agglomerations above 2,000 p.e. based on the revised methodologies; 4. Suggesting phasing approach, in which boundary cases could drop due to population decline. ESTABLISHING A BASELINE AND NEW TIMETABLE 56. The current reported UWWTD compliance results are based on the existing agglomeration boundaries and method for calculation of the load demonstrating significant margin of errors. A new baseline in terms of status of implementation of various UWWTD articles will be established once the new methodologies for establishing agglomeration boundaries and calculation of pollution load are developed and applied. The will result in a new list of agglomerations and new compliance level. An indicative timetable for the implementation of Directive 91/271/EEC will be developed during the next phase, while the team is working on Output 4: Report with a proposed updated Implementation Plan of UWWTD including prioritization of measures and new timeline for compliance of the agglomerations above 2,000 p.e. During the preparation of the report the results from Strategic Financing Plan will be reflected to account for the remaining compliance WSS investments, availability of funding and overall ability and capacity of the WSS sector to absorb and accommodate such significant investment efforts. 57 3.6 Additional measures to optimize compliance costs and accelerate implementation of UWWTD in Romania 57. Definition of sensitive areas: The UWWTD requires additional, more stringent, treatment of wastewater in the so-called “sensitive areas” (Article 5) for agglomerations above 10,000 p.e. More stringent treatment means removal of nutrients (Nitrogen and Phosphorus), where the recipient water bodies are fragilized inter alia due to eutrophication. Since all territory of Romania was classified as Sensitive Area under Articles 5(8) and 5(2, 3) of the Directive this requires that all wastewater treatment plants for agglomerations with more than 10,000 PE need to comply with more stringent treatment for nitrogen and phosphorus removal. The team was asked to review the initial designation and assess its relevance and implications on compliance costs. As mentioned the UWWTD requires Member States to identify sensitive areas. These are: • Freshwater bodies, estuaries and coastal waters which are eutrophic or which may become eutrophic if protective action is not taken; • Surface freshwaters intended for the abstraction of drinking water which contain or are likely to contain more than 50 mg/l of nitrates; • Areas where further treatment is necessary to comply with other Council Directives such as the Bathing Water Directive. The appropriate designation of sensitive areas is a crucial first task in implementing the UWWTD as it determines the type of waste water treatment that should be put in place, i.e., more stringent than the treatment that would be applied otherwise (secondary or biological). Sixteen Member States (Austria, Belgium, Czech Republic, Denmark, Estonia, Finland, Germany, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Romania Slovakia and Sweden) either apply a treatment more stringent than secondary in their whole territory, which is considered de facto as a sensitive area, either identify all their water bodies as sensitive areas. The remaining twelve Member States (Bulgaria, Croatia, Cyprus, France, Greece, Hungary, Ireland, Italy, Portugal, Slovenia, Spain, and the United Kingdom) have identified certain water bodies and/or their catchments as sensitive areas. If Romania wants to change the definition of sensitive areas there should be scientific results showing that the discharges of secondary treatment plants do not contribute to the eutrophication downside or that there is no more problem of eutrophication in the Danube river and the Black sea. This would require receiving the agreement of all the countries and stakeholders in the river basins, specifically the Danube Commission. • If there is no possibility to change the Danube river and Black sea sensitive area situation, it means that Romanian authorities should provide for each of the treatment plants justifications taking into account the receiving river quality and their ecological status. • If there is a possibility to reconsider the Danube river and the Black sea situation as not sensitive area it does not mean that the Romanian tributaries will not have to be 58 considered as sensitive areas. Romanian authorities have to provide information on each river to demonstrate that they have no problem of eutrophication. Having in mind that most of the investments in agglomerations above 10,000 p.e. have been completed or are ongoing there seems to be limited possibility for optimization of compliance costs related to more stringent wastewater treatment. However, the team will try to identify wastewater systems that need to do nutrient removal to meet the UWWTD requirements and explore whether by applying secondary treatment there will be the same environmental benefits for the receiving water body and water qualitive objectives. Then, it will assess the cost of tertiary treatment solution vs. secondary treatment (both capex and opex) and provide feedback to the Romanian authorities on the most cost-effective solutions, which is ensuring the same environmental impact with less resources. 58. Implementation of WSS investments: According to data from EBRD’s report31 the implementation of the SOP Environment program (2007 – 2015) was a significant challenge for the ROCs. The report points out that the tender processes were very difficult and took a significant amount of time to operators: • The average period between signing the EU financing contract and signing all works contracts: 1,259 days; • The average period of tendering a works contract: 295 days; • Average savings after tender for works contract: 18.6%. EBRD highlights that the construction phase of WSS projects was also challenging with the local construction market being overwhelmed by the high number of the contracts to be implemented in parallel, leading to delays in implementation and to tension between the regional operators and construction companies: • The average period from signing the financing contract until the completion of all works contracts: 2,325 days; • The average period from signing a works contract until the completion: 1,133 days; • On average, it took 292 days to spend EUR 1 million in investment implementation. The report is also referring to the fact that the maximum annual investments implemented by the ROCs (amounts paid) under the SOP Environment was achieved in 2015 – EUR 1.2 billion, which was rather extraordinary effort and included some administrative measures to improve absorption. Although it might not be strictly within the ToR of the current RAS that the WB team should try to identify and address issues hampering the implementation of WSS investments, the team believes that in order to accelerate implementation of UWWTD in Romania, this should be reflected. The team will analyze why implementation has been slow, despite widespread availability of EU funding; review incentives for application for EU funding of WSS projects; options to shorten the tender (possibilities for different contracting approaches) and construction processes; changes to implementation arrangements and financing modalities of the next SOP. Having in mind that the team is supporting the MoWF on updating the UWWTD Implementation plan we would also 31 EBRD-RAMBOL-BDO: Water Sector Development in Romania, Strategic Paper (Draft), 2019 59 recommend measures to improve implementation of WSS investments to ensure delivery on the newly updated compliance plan. A proposal for prioritization of WSS investments based on closing the gap to compliance, while taking into account the available financial resources and better linkages and alignment with WFD’s environmental objectives and expected impact on the ecological status of recipient water bodies will be made. 59. Innovative WSS technical solutions: During the delivery of this assignment, the WB team will bring the Bank’s global knowledge and good practices from various investment projects around the world and analytical studies on inclusive sanitation and wastewater management. Specifically, the team will apply, as applicable to this assignment, tools and guidance developed under the Bank’s City-Wide Inclusive Sanitation (SWIS) Initiative, including strategies to connect households to sewers systems, small town wastewater treatment solutions, and strategic sanitation planning. Planning tools, such as the CWIS Costing and Planning Tools and the planning tool developed for Bulgarian Government to address UWWTD implementation challenges would be applied to evaluate a diversity of technical solutions that combine centralized wastewater systems and AIS and innovative solutions to improve operational efficiency and utilize water reuse and biosolids for beneficial use. The WB advisory services will also utilize the recent global knowledge from the 2019 “Integrating Green and Gray – Creating Next Generation Infrastructure” Study to evaluate the use of nature-based solutions as polishing treatment options and to mitigate the impacts of urban stormwater flows into the wastewater system. In addition, the team will explore energy management options by tapping into the 2017 Energy Management for Water Utilities in Latin America and the Caribbean (LAC) study, which provides good practices from water utilities in the United States and Latin America and guidance note to integrate energy efficiency and recovery into the operations and capital investment of utilities. 60 Chapter 4. Component B: Assistance for the update of the national mechanism for monitoring, evaluation and reporting on UWWTD implementation 4.1. Assessment of the existing process of data collection, processing and validation of information regarding UWWTD compliance reporting CURRENT REPORTING PROCESS SITUATION 60. Since 2007 the reporting under Article 15 of the UWWTD follows a new standardized approach, which was jointly developed by the European Commission, the European Environment Agency (EEA) and EU Member States, and which was set-up in line with reporting principles under the Water Information System for Europe (WISE). For the 9th Reporting, a new standardized reporting template for the reporting under Article 17 was prepared, and the reporting template for the reporting under Article 15 was updated. • Under article 15 of the UWWTD, Member States are asked to provide the information inventory on the core elements of the Directive, in particular: o Information and geo-referenced information on designated sensitive areas and their catchments (and also less sensitive areas in the case they have been designated) o Information on agglomerations, including: ▪ Master data (agglomerations/treatment plants/discharging points/receiving areas/receiving water bodies) and ▪ complete information per each agglomeration: part (a) plus information on waste water collection, conduction, treatment performance etc. o Aggregated information at Member State level on sewage sludge and waste water reuse • Under article 17 of the UWWTD, Member States are asked to provide the information on the status and on the forecasts for implementation of the Directive, in particular: o information on individual agglomerations and urban waste water treatment plants which have to become compliant, and o aggregated socio-economic information at national level. 61. Figure 10 below illustrates the current reporting process and types of documents (Word or Excel) submitted for national and EU reporting. 61 European EEA commission SIIF website Excel documents Others ANAR MoWF Excel documents WBA 1 WBA 2 … WBA 11 Word documents LOC 1 LOC 2 … ROC 1 ROC 2 … LOC 400 … LOC 972 … ROC 43 Figure 10: UWWTD current reporting representation ANAR: National Administration "Romanian Waters" EEA: European Environmental Agency LOC: Local Operating Company MoWF: Ministry of Waters and Forest WBA: River Basin Administration ROC: Regional Operating Company The current reporting process data flow is a hierarchical setup based on human work starting with data points each, reporting to higher level data nodes. The nodes collect data from different data points and forward them again to the next tier of the system until the data finally reaches the highest level of the reporting system (EEA / SIIF). The UWWTD reporting process is organized in the following way: (i) The local and the regional water operators fill in a predefined Word template for each agglomeration and submit the completed files to the river basin administrations. This Word template contains data requested by the EU reporting, concerning articles 15 and 17 of the UWWTD, as well as additional data requested at national level to produce specific national statistics. (ii) The river basin administrations transpose the Word files into Excel files, following a predetermined format established by ANAR. (iii) At national level, an Excel file with multiple worksheets is consolidated, following the format requested by the European Commission. Reporting under the UWWTD is carried out by uploading data into WISE via ReportNet (the European Environment Agency's 62 electronic infrastructure for data collection). The Excel file is transformed into an XML file using conversion tools, as Member States are asked to upload their UWWTD Art. 15 and Art. 17 data in XML files following the reporting templates into a Central Data Repository (CDR). Additional documents and reports can be uploaded next to data files as well. Automatic quality control scripts have been incorporated into the CDR, which means that data will be accepted only after passing basic Quality Assurance/Quality Control (QA/QC) procedures (Article 1532 and Article 1733). (iv) The tool provides feedback to the Romanian authorities concerning potential problems with the database (format related). After cleaning of these types of errors and validation of the file in the right format, it is further processed in the Structured Information and Implementation Framework (SIIF)34 that allows to visualize all the information reported in a user-friendly way. A SIIF European platform35 is connected to 28 national platforms using the same visualization tool, allowing all countries to become partially compliant to what is requested by the INSPIRE directive36 (namely the requirements of Article 11 of the INSPIRE directive: view, discover, download, invoke, transformation services). This website provides an easy access to the public, as well as operators, to all the information reported and problems of locations of agglomerations, UWWTPs or other discrepancies can be easily spotted. (v) A more in-depth analysis is carried out by a Commission contractor to identify other problems in the database, which leads to another update of the reporting database, corrected at national level. The procedure for data collecting at national level appears ineffective since it requires a sequence of human interventions, which, in addition to the considerable staff load, creates preconditions for delays or errors of various types. Process optimization will help streamlining the reporting, avoiding double filling (at operator and river basin administration levels) and avoiding mistakes. 4.2. Review of the existing information systems for monitoring, evaluation and reporting on UWWTD implementation 62. There is no unitary information system that is used at local (ROC and LOC), regional (WBA) and central level (ANAR and MoWF). The data is collected both in electronic format and on paper. However, during the process of monitoring, evaluation and reporting on UWWTD implementation some proprietary or open source software is used by different actors to fulfil their specific roles and responsibilities. At local level there are two different patterns for data gathering and reporting: one for ROCs and one for LOCs. At ROCs level, the utilities’ staff use a dedicated software for monitoring, evaluation and reporting, which also helps them having a relatively good management of the progress and results, such as EffiValidation37. Most of the ROCs have 32 http://cdr.eionet.europa.eu/help/UWWTD/UWWTD_613/AutomaticQC_UWWTDART15_2017_v05122017.xlsx (last accessed on April 15, 2019) 33 http://cdr.eionet.europa.eu/help/UWWTD/UWWTD_524/AutomaticQC_UWWTDART17_2017_v24112017.xlsx (last accessed on April 15, 2019) 34 https://uwwtd.eu/Romania/ 35 https://uwwtd.eu 36 https://inspire.ec.europa.eu (last accessed on April 15, 2019) 37 www.Effivalidation.com 63 the water test (wastewater inlet and/or outlet) done at their own accredited laboratories (accredited by RENAR – the national accreditation association), which assures the quality of results. The data is stored in electronic format by using specialized software programs or on paper (in case the analyses are outsourced to other laboratories). At LOCs level, the water tests are almost entirely outsourced or conducted in-house, but using unaccredited laboratories; hence, the results have limited accuracy, also due the limitation of the equipment and personnel. As explained earlier (section 3.1) for reporting from local level to regional level, all responsible entities (ROC & LOC) use MS Word documents (template provided by ANAR). All data are collected in MS Word documents from local level, processed and transferred further to central level in MS Excel documents, through a manual conversion (copy/paste) from Word to Excel files. This can hardly be seen as an integrated information system for monitoring, evaluation and reporting on UWWTD implementation. It should be clarified that a methodology for quality assurance is in place at regional level – Qualitative evaluation of data regarding the reporting of art. 15 of UWWTD (2016). The main objective of the qualitative assessment is to verify the plausibility of the reported data, especially with regard to calculation of pollution loads at the inlet and outlet of the treatment plant. The methodology contains explanations on the verification keys and the applied evaluation criteria. The key issues included in the methodology are related to: • avoiding the occurrence of errors when comparing the historical data; • filling in some data without which error will occur; • calculating the size of the agglomeration; • the code of the wastewater treatment plant/sewer system without connection to the wastewater treatment plant (uwwCode) is unique; • the code of the discharge point of the wastewater treatment plant / sewer system without connection to the wastewater treatment plant (dcpCode) is unique; • ensuring the connection chain agglomeration / collection system / wastewater treatment plant / evacuation / water body; • correlation between the design capacity of the wastewater treatment plant and the pollutant load at the inlet of the plant; • correlation between the pollutant loading data at the inlet and outlet of the wastewater treatment plant; • verification of the correlation between the theoretical load at the inlet of the wastewater treatment plant and the reported value; • data verification of loads at the outlet of wastewater treatment plant. Most part of the above-mentioned criteria are automatically checked within MS Excel rules or macros. However, because there is no unified reporting system, and the data is manually processed at regional and national levels there are many options for human mistakes and the team has already identified some discrepancies in UWWTD implementation reporting data. One example might be that there are some differences between the data available at ROC level and the data available in SIIF, such as: 64 Table 10: Comparison between data available in SIIF and ROC data Incoming Discharged BOD 7445.6 t/year 478.37 t/year 194.44 mg/l 12.49 mg/l 195.01 mg/l 12.32 mg/l COD 13479.53 t/year 1319.1 t/year 352.01 mg/l 34.45 mg/l 338,90 mg/l 32.05 mg/l Nitrogen 1606.55 t/ year 455.91 t/year 41.94 mg/l 11.91 mg/l 38.10 mg/l 11.0 mg/l Phosphorus 241.67 t/year 37.59 t/year 6,31 mg/l 0.98 mg/l 4.31 mg/l 0.93 mg/l Data available in SIIF Data available at ROC level When reporting processed data from one level to a superior one, national/regional authorities should provide feedback to ROCs and LOCs in order to have the same information at all levels. As mentioned earlier, from the regional level to the national level, reporting is done through Excel files, which are consolidated for the reporting to EU. Afterwards, the reporting file is transformed in XML format through a conversion tool. After uploading it in the EEA central depositary, the Romanian authorities receive a feedback with format and basic mistakes that are in the file and are required to correct them. For the monitoring, evaluation and reporting requirements it would be much easier to have a unified information system to be commonly used in by all stakeholders, which are responsible for compliance monitoring like LOC, ROC, RBA, ANAR, MoWF and that could be also used by other authorities which use the same data (e.g. Environmental Agency). The current project will provide such a support to the Romanian authorities under Output 65 6: “Report with technical specifications on how to update and make the existing UWWTD reporting systems SIIF compatible”. 4.3. Approach and workplan to enhance the information systems and make them SIIF compliant 63. An in-depth assessment of the current reporting process (including data collection, processing and validation of information) will be carried out over the next six months highlighting: • the number of people and full-time equivalents in charge of the reporting process at each level (process diagram); • the procedures / methodology used to fill-in and validate the information; • the use of reporting information at each level (reports, statistics etc.) and the time needed to do that (start and end dates of reporting process at each level); • the existence of data needed to manage the service that are not reporting at an upper level; • current storage level procedures and possible alternative software solutions; • other documents available at each level related to the waste water collecting and treatment systems; • a stakeholder satisfaction assessment (of operators) on the current reporting process; • examples of relevant international practices for monitoring, reporting and evaluation mechanisms will be outlined. Based on the evaluation of the existing national UWWTD reporting systems and their compatibilities with the SIIF requirements, a proposal to improve the process of data collection, processing and validation and reporting to the EC on UWWTD compliance, will be developed in the beginning of next year, including responsibilities and timeframes. The goal is to promote a more efficient (and less burdensome) reporting system which, at the same time, is to deliver accurate and reliable information. Further on, technical specifications will be developed to update the existing systems to be SIIF compatible. The proposed update will enable visualization of the UWWTD reporting file and support validation of available information. Finally, the capacity of the personnel of MoWF and ANAR to work with an updated national UWWTD data collection, reporting system and SIIF, will be enhanced by carrying out up to five trainings on specific issues related to the implementation of Directive 91/271/EEC, including SIIF reporting requirements. Further details on this are presented in Chapter 6. 66 Chapter 5. Component C: Recommendations towards development of a National Strategy for the Water Supply and Sanitation Sector 5.1 Stocktaking from all ongoing strategic efforts in the WSS sector, institutions, roles and responsibilities BACKGROUND 64. Chapter 1.2 highlighted the importance to address sectoral issues beyond the compliance agenda to ensure sustainable and affordable WSS services to all. Romania strongly embarked in the process of development and modernization of its water supply and wastewater collection and treatment infrastructure before finalization of negotiations for EU accession. Consequently, regionalization and commercialization and of WSS services have been the backbone of the reforms of the past decade. The regionalization aimed to promote a more integrated water resources management and the application of the solidarity principle between urban and rural areas in each region. Second, it sought to overcome excessive sector fragmentation and lack of local capacity, and to achieve economies of scale. 65. While the water supply and sanitation reforms allowed for significant progress, it should now be revisited and updated as 2nd generation issues emerge, such as: addressing O&M sustainability of newly installed wastewater infrastructure (both sewerage networks and treatment plans); moving towards financial sustainability of WSS services in poor depopulating rural areas; growing concerns of affordability levels for the poor. Thus, a new water supply and sanitation strategy involving all actors and addressing the various challenges and blockages of the reform is needed. The first attempt to prepare a strategy for development of the water supply and sewerage sector was encompassed in the “Government Strategy for development of public services of communal husbandry” prepared and approved in 2001, which covered the period 2001-2004. It included directions for the decentralization of public services, increased responsibility of local authorities on the quality of services provided to population, priority development of services with direct impact on population’s health and living standards (water, sewerage, heating) and their accessibility, social protection mechanisms for vulnerable population etc. The Strategy also stated the need to promote sustainable development of local services through harmonization of national legislation with EU directives applicable, steady co-financing of EU programs of the time (ISPA, SAPARD, MUDP 2), as well as development of new programs for small municipalities. Once negotiations for EU accession were completed, compliance with the provisions of the EU directives on drinking water and wastewater collection and treatment, and fulfilling the targets set in the Accession Treaty became mandatory. The first step was the establishment of the “regionalization policy” developed under the SOP Environment, as “a precondition for the accession to EU funds for water and wastewater infrastructure”38. Albeit initiated in 2005, the “regionalization policy” received the legal support in 2006 through the legislation on communal services of public utility (Law 51/2006) and on water supply and sewerage services (Law 241/2006) which also set the new institutional, 38 EBRD-RAMBOL-BDO: Water Sector Development in Romania, Strategic Paper (Draft), 2019 67 organizational and financial framework for implementation of the new policy. The process led to fast consolidation of many small operators (mainly around the largest operator in the county capital city) into the 43 regional operating companies (ROCs) existing today and also opened the way for emergence of the first private water operators (Apa Nova Bucharest and Apa Nova Ploiesti, both established in 2000). Implementation of the regionalization policy benefitted, after 2007, of substantial financing from EU funds through the SOP Environment as “the main feature of the policy of water supply and sewerage services development, (…) with the main purpose to improve the sector performances through better management and professionalism, benefitting of economies of scale”39. In parallel, development of WSS rural infrastructure was funded under the National Rural Development Program (NRDP), without much connection with the regionalization policy, as the projects were not exclusively focused to localities included in the operational area of the ROCs. In total, about €4.3 billion have been invested during first programming period (2007-2013), of which € 3.4 billion under SOPE and €0.9 billion under NRDP. ON-GOING STRATEGIC EFFORTS IN THE WSS SECTOR 66. The main investment programs supporting WSS development (LIOP, NRDP2, NPLD40) during the current financing period (2014-2020) have been prepared based on a number of strategic decisions: (i) all programs will support reaching compliance with UWWTD; (ii) LIOP will give priority to agglomerations over 10,000 p.e. through financing the finalization of the 29 phased projects (that started during 2007-2013) and preparation of new projects; (iii) in the rural space, financing will be targeted exclusively to agglomerations over 2,000 p.e.; (iv) NPLD will complement the EU financing through investments outside the operating area of ROCs. The preparation of NRDP2 was based on the new Strategy for Medium and Long-Term Development of the Agri-food Sector (2015), leaning on the Medium and Long-Term Vision Document (2020/2030) prepared by the World Bank (2014). The Strategy has set two targets for rural water supply and sanitation: “All communes in Romania should have access to safe drinking water and sewerage through centralized systems by 2030 to comply, thus, with the requirement of the acquis communautaire on environment. In addition, at least 70% of rural households should have house connection to water and sewerage.”41 However, in the recent years, the regional consolidation process seems to have reached some limitations and a balance between the area of operation and financial stability; also, only few new localities are joining the existing ROCs, while other decided to leave. Besides, as mentioned earlier, fragmentation of WSS service delivery continued and even expanded after implementation of the regionalization policy started and Romania joined EU; a large number of smaller operators are active in almost all counties, although their number is slightly decreasing, as shown in Figure 11. 39 Royal Haskoning-BDO-IL, Guidelines on Regionalization of Water and Sewerage Services (Version 4), 2009 40 National Local Development Program implemented by the Ministry of Regional Development and Public Administration 41 Strategy for Medium and Long-Term Development of the Agri-food Sector, Ministry of Agriculture and Rural Development, 2015 68 Evolution of total number of WSS operators 1200 1077 1068 1066 1061 1021 1041 1017 983 985 986 978 1000 912 800 800 742 600 400 200 0 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 Figure 11: Evolution of number of WSS operators42 While development of wastewater management infrastructure (for agglomerations with more than 10,000 p.e.) is more advanced, development of new WSS infrastructure in many new localities, most of them smaller (below 10,000 p.e.) will continue for a longer period, until full compliance with the EU directives. It is important to highlight that Romania is also not on track for complying with Target Six of the Sustainable Development Goals (SDGs), which requires that access for all to safe and affordable drinking water and adequate sanitation be achieved by 2030. As EBRD mentioned recently, “Although significant EU and other public funds are available for water sector investment, Romania faces issues of funding gap and unsustainable financing strategies”43. Hence, the Government recognized the need for a comprehensive water sector strategy to clarify the way forward for preserving a sustainable development of water and wastewater services both in urban and rural space and a number of reasonable questions are being asked: “Has the regional policy reached its limits?”, “Is the regional policy the only option?”, “Where to go?”, “What to do next?”. Besides the current work undertaken by the Ministry of Water and Forests, two separate strategic activities have been initiated by the Ministry of Regional Development and Public Administration (MRDPA) and National Regulatory Authority for Communal Services of Public Utilities (ANRSC) and are conducted, in parallel, by a team led by the EBRD and the Water Industry Commission of Scotland (WICS), respectively. Both are briefly presented below. The “Technical Assistance to consolidate the water and wastewater sector in Romania” implemented by a team led by EBRD and comprising a consortium of consulting firms (RAMBOLL - Denmark and BDO – Romania), included support for “formulation of a strategic proposal with options for water sector development centered on the further regionalization and water sector consolidation.”44 The Strategic Paper prepared in February 2019 responded to this task with a good review of the WSS sector based on in- depth knowledge of regionalization policy and ROCs role in its implementation (including 42 WB based on ANRSC data included in the annual reports (2002-2017) 43 EBRD-RAMBOL-BDO: Water Sector Development in Romania, Strategic Paper (Draft), 2019 44 Ibidem 69 investment process). A strong analysis is devoted to the remaining challenges towards achieving sustainability of the WSS sector as well as compliance with EU water services directives. Much useful information is also included in the annexes. The comprehensive baseline assessment, candid and realistic SWOT analysis and the financial analysis of the sector (however, centered on ROCs) are the main pillars of the current sector status, while the options analysis for further regionalization and consolidation in the sector tried to imagine the possible way forward. Besides the structured presentation of ROCs, the Strategic Paper contains brief technical and financial information on the area outside their operation, served by other public/private operators. However, the options presented remain to be linked with the investment capacity to generate stronger strategic options for discussion. Some important aspects need, however, to be further clarified in a revised version of the report, such as: (i) an in-depth analysis of the patterns of ROC options for further development, including investment needs and operational costs associated; (ii) clarification of the level to which ROCs service area should increase (including coverage) and the optimal delivery arrangement for WSS services; (iii) analysis of the ways to increase ROCs service area (voluntary vs. administratively); (iv) means to facilitate further merger of the existing operators to reduce the fragmentation of WSS service delivery. The “Strengthening of the economic and environmental regulation in the water and wastewater sector in Romania” commissioned by ANRSC to WICS aimed at preparation and implementation of a strong information framework as the basis for effective long- term sector regulation through (i) awareness of the benefits of economic regulation and strong information framework, (ii) understanding of the systematic and steady information framework, and (iii) analysis of the approach to river basin planning and its potential strengthening. Three ROCs have been involved in this work, Water Company Somes (Cluj), ApaVital Iasi and ACET Suceava. From the presentations delivered so far on the interim results it appears that much work was undertaken on the factors that contribute to enhancing the economic, financial efficiency of ROCs activity towards improving the level of services delivered to their customers including the impact of future investment in infrastructure. A significant share of work consisted in estimating the volume of investment required to reach compliance with EU water directives, confirming the parallel estimates made by ANAR and EBRD teams. It appears that some work remains to be done towards the development of the expected comprehensive information framework to support the regulatory work of ANRSC. ASSESSING ONGOING STRATEGIC EFFORTS IN THE WSS SECTOR 67. As described earlier, the water sector governance in Romania is complex, given the fact that its “command chain” isn´t vertical. Instead, it forms a matrix of several ministries, local authorities, agencies, institutions and other public stakeholders. This characteristic reveals the importance of having a comprehensive analysis of each stakeholder with its roles and responsibilities. This task will start by assessing the existent organic laws of the government to understand the responsibilities of each ministry and their agencies. Additionally, an analysis of the statutes of the several institutes should be performed. Interviews will be held to understand the actual (and sometimes unavoidable) differences between the written mandates and the reality, and also the relationships (political, 70 managerial and technical) between each player. This first task will end by crossing each player’s competences, in order to identify gaps and overlaps in their roles towards the water sector. The output of this task will be a comprehensive structure of the water sector governance in Romania, as well as the identification of the main strengths and weaknesses and improvement recommendations. The next task would consist in assessing the ongoing work of each player, namely, what dossiers they have in hands, which are their priorities, how they are organized to manage their day-to-day businesses, etc. This will allow the understanding of ongoing policies regarding the water sector as well as how they are being handled by each ministry, agency, department, etc. Additionally, it would permit to identify the matching (and, eventually, mismatching) of the work carried out by different ministries, agencies, institutions, etc. In the end, the output of this task will be a report of the ongoing work of each player and the overall effort towards the approved water sector policy. 5.2 Addressing the WSS sector challenges through preparation of WSS sector vision, strategic objectives, targets and measures THE CONTEXT OF A NATIONAL STRATEGY FOR WSS IN ROMANIA 68. A sectoral National Strategy for the WSS sector aims to define the overall efforts of a Government to achieve certain middle-long term objectives. It addresses the means to achieve the ends – the objectives. Therefore, it addresses the targeted activities (water resources, demand, supply, network coverage, quality of service, environmental protection etc.), the required capital asset investment, the forecasted operational costs and the financial resources needed (from tariffs, taxes, transfers and other sources of finance). The National WSS Strategy should provide answers to the challenges identified in Chapter 2 like unfinished reform agenda, fragmentation of service delivery, closing the urban-rural gap on living standards, closing the inclusion gap for the poor, compliance with the European living standards defined by the EU directives, management of increasing volume of sludge, coping with climate change effects, assign responsibilities and develop a timeframe. Additionally, the Strategy defines the institutional framework in which it will unfold: who is responsible for what; the resources needed; the legal amendments needed; the management models of the utilities; the roles of the regulators etc. In short, it is a valuable management tool, with clear responsibilities and targets, that allows decision makers to define and identify the efforts and resources needed to improve the WSS sector. In the particular case of Romania, such a Strategy is also an instrument to attract financial funds and loans, once it clearly and factually highlights the financial needs to attain the sectoral goals. The Strategy holistically deals with the sector issues and aligns institutional and financial efforts to ensure the success in achieving the defined objectives. 71 PREPARING THE WSS SECTOR VISION, STRATEGIC OBJECTIVES, TARGETS AND MEASURES 69. The WB team proposal is that the timeline of the Strategy is up to ten years. In accordance with the Bank’s most recent experience in supporting and reviewing WSS Sector Strategies in EU member-states, the sectoral Strategy for Romania should either match the period of the next EU Budget (2021-2027) – to align it with the available resources - or go a bit further, to outline the path towards sustainability beyond EU funds for the sector. The timespan of the strategic document is to be decided at one of the above-mentioned workshops. This will help the dialogue with the EU (by maximizing EU support, once the needs of the country are well documented and targets clearly identified) and the monitoring of the effectiveness of the implemented measures and the allocation of funds, both by Romanian Government and by the EU. The Bank’s assistance will be focused on specific areas and issues that need to be addressed by the Strategy in line with the applicable EU directives pertaining to the WSS sector and options to improve sector performance and sustainability. The Bank will support an Advisory Committee to establish priorities – for instance, should the focus be on urban areas or rural areas; should the tariffs increase to near the cost recovery policy or should subsidization be part of the policy. Other priorities could also be established (e.g. social policy may overlap economic sustainability through subsidies.). Only after having agreed on the major objectives with all key stakeholders, the next task– setting up the WSS sector vision, strategic objectives, targets and measures – could begin. This task requires the alignment of the sectoral policies with the national and EU policies. In other words, the vision and strategic objectives should be ambitious but feasible, firm but tangible, definitive but flexible. Nevertheless, both the objectives and the defined targets must be measurable. This will allow implementation monitoring and promotion of necessary mitigation measures during the course of the Strategy. Hence, the WSS sector vision, strategic objectives, targets and measures to be developed by the Bank in consultation with an Advisory Committee will be aligned with: • The baseline – the existing situation; • The interest of both public authorities and consumers of WSS services; • The country’s specificities, historical and economic development; • The required improvement of the WSS sector; • The resources needed to implement it. 5.3 Approach and workplan to develop the outline of the Water Supply and Sanitation Strategy PRELIMINARY CONSIDERATIONS 70. In the process of supporting the MoWF with recommendations towards the development of a National Strategy for the Water Supply and Sanitation Sector the Bank will start with analyzing the legislation governing the WSS sector. 72 After having a clear notion of the rights, duties and obligations of both the public authorities and consumers of WSS services, the first task will be to assess the current strategic objectives, targets and measures or lack of them in the WSS sector. This will consist in verifying not only the adherence of the strategic objectives with the current policies, but also – and mainly – the effectiveness of those objectives in the field. Then, the second task will be to conduct a series of meetings and brainstorming activities with all key WSS stakeholders in Romania to agree on the major objectives to be achieved. This task will require that the Government nominates an Advisory Committee with representatives of just a few main stakeholders to discuss such objectives. To develop a good WSS Strategy the WB team recommends to Romanian authorities to focus at least on: WSS Asset Planning and Delivery; Governance: Improvements/Reforms; Control: Monitoring and Evaluation. Considering the above-mentioned components, the drafting of the Strategy should include (but not limited to) the following stages (*): ASSET PLANNING AND GOVERNANCE CONTROL DELIVERY Improvements & Reforms Monitoring & Evaluation (1) Establish the (1) Establish the Baseline (1) Establish the Baseline Baseline (2) Review of (2) Establish the ambition (2) Set objectives and Management Models in terms of targets management and (3) Environmental control of the Strategic (3) Quantify Capital Protection Plan Investment (4) Private Sector (3) Define which entities (4) Improving Participation should administrate the Delivery Capacity Strategic Plan (5) Legal Framework (5) Financing Models Reforms (4) Governance Framework and Tariff reforms Structure (6) Regulatory Framework Reforms (5) Set the resources needed for the (7) Contribution of the implementation of the Strategic Plan to Strategic Plan other governmental policies/plans To undertake such project (of conceiving and drafting the Strategic Plan), the Government should consider appointing a three stage Task Force: 73 Sponsor (Rapporteur of Strategic Plan) • Ministry of Water and Forests Steering Committee (Drafting the Strategic Plan) • Sponsor plus: • Ministry of Public Funds • IDA’s representative • ROC’s representative Strategy Advisory Board (all relevant stakeholders) • Steering Committee plus: • Ministry of Public Finance • Ministry of Health • Ministry of Regional Development and Public Administration • Local authorities’ representative • ANRSC’s representative • MA LIOP’s representative • ANAR’s representative • Association’s (UNCIR, AMR, AOR, ACR, ARA, FADIDA) representatives • Competition Council’s representative • Consumer’s representative The Task Force should be established and fully operational at the kick-off of the drafting of the Strategy. Until then, (that is, during the preparation of the outline of the Strategy) the Advisory Committee will be sufficient. This Task Force will provide the Government with a Strategy that, on one hand, has the broad view of all stakeholders and, on the other hand reflects the WSS sector capacity to implement and execute it on the field. DEVELOPING THE OUTLINE OF THE WATER SUPPLY AND SANITATION STRATEGY 71. Before embarking on the actual activities towards development of the outline of the Strategy, the Advisory Committee would need to be appointed and empowered to discuss and make decisions along the process of preparation of the Strategic document. Then, the Bank will start performing the tasks described earlier, including organizing meetings and brainstorming activities with the Advisory Committee. The next step will include preparation of the first draft of a “Table of Contents”, which requires the thorough understanding of the existing data and information on the state of play in the sector, main strategic objectives and cross-institutional relations. In absence of the required information and confirmation of their reliability, a plan to collect the missing data would be required prior to defining the baseline and starting the development of the Plan. The first draft of the Table of Contents will be submitted to the Advisory Committee for analysis and validation. At this point, drafting of the outline of the Strategic Plan (the Plan) can start. The WB team will also prepare a step-list of all the contents of the document and create the templates 74 to tables, data and information that should appear in it. The Plan should be well structured, already containing text and guidelines to fill the tables and missing text. So, a meeting with the Advisory Committee would be required to validate the details of the Plan and understand the possible constraints in the drafting of the Strategic Plan. That meeting would also allow to review (if necessary) the “Table of Contents” and the details that should be addressed in each of its points. After a final review, the draft Plan would be submitted for approval to the Advisory Committee. 75 Chapter 6. Capacity building for MoWF and ANAR for the UWWTD implementation INTRODUCTION 72. This Chapter presents a snapshot of the current situation, as well as methodology, approach and instruments that will be applied for the capacity improvement at the MoWF and ANAR level, with regard to UWWTD obligations. In line with the Legal Agreement, the WB will provide support to MoWF and ANAR for adapting existing structures, optimizing processes, developing the skills and competences of human resources and enhancing the inter-institutional cooperation necessary to fulfill the obligations assumed for compliance with Directive 91/271 / EEC concerning urban waste water treatment. The capacity building activities will be carried out during the entire project duration, along the following phases: a) Taking stock of current situation; b) Capacity needs assessment and development of Capacity Improvement Plan in relation to UWWTD reporting obligations, and c) Delivery of five trainings on specific issues related to the implementation of Directive 91/271/EEC, including SIIF reporting requirements. This will also include carrying out evaluations of the trainees to assess the transfer of knowledge. 6.1 MoWF and ANAR capacity needs assessment STOCKTAKING 73. Handling reporting requirements under UWWTD as well as the EC initiated infringement case related to compliance obligations failures for agglomerations above 10,000 p.e. requires for MoWF to take a series of capacity building actions. Romania will need to demonstrate credibility and pro-activeness in solving the various institutional challenges and bottlenecks to meet Directive 91/271/EEC obligations. There are valuable lessons and good practices from other EU countries also to be considered. An updated Implementation Plan will need to be developed and submitted to EC, outlining in a realistic manner the various measures and actions to be carried out over the next decade. While the responsibility of monitoring and reporting, at national and European levels, on the status of UWWTD compliance lies with MoWF, the involvement of many other players makes it difficult to align efforts and resources as well as follow the progress 45. ANAR holds a central technical role in gathering the information required for periodic reporting on Romania’s compliance with all water-related EC directives including UWWTD. However, other public institutions, namely the National Regulatory Agency on Communal Services (ANRSC), MRDPA, MEF/LIOP, county councils, and local or municipal councils also have specific and important roles, responsibilities and information regarding the current planning, financing and implementation of investments in WSS sector. Consequently, developing inter-institutional mechanisms for coordination, consultation and reporting on UWWTD implementation represents a top priority for achieving 45 Romania Water Sector Diagnostic Report, WB, June 2018 76 compliance and handling the EC infringement case. The issue of strengthening the inter- institutional cooperation and enforcing the coordination role of MoWF in the area of UWWTD implementation remains a real challenge which implies a longer and dynamic process. Moreover, the lack of a unitary database at national level generates overlaps between many institutional actors including MEF, ANRSC, the local authorities and the WSS operators. Currently, the responsibilities of various WSS key stakeholder players related to collection and treatment of urban wastewater, basically achievement of compliance with UWWTD, are not very clear and consistent. Another issue requiring attention is the constant need to enhance the personnel knowledge and skills of MoWF, ANAR and other key players, as concerns the UWWTD implementation. While MoWF personnel would need to enhance their skills for inter- institutional coordination and process efficiency, ANAR’s staff require support to improve the skills for data collection and management, validation and reporting and enhance the communication with regional and local actors, as well as mainstream the coordination with the regional and local players. Furthermore, the motivation and dedication of the staff seems adequate and these form a solid basis for continued improvement of their skills for operating in the near future the updated UWWTD reporting procedures and systems. ANAR itself plays a role in training of the personnel at regional and local level, by ANAR Professional Development and Training Center, that operates according to the provisions of G.D. 1176/2005. The capacity building actions to be developed and implemented over the project duration will be closely coordinated with other IFIs’ current interventions in the WSS sector. The TA project currently implemented by EBRD to consolidate the water and wastewater sectors in Romania focused on ROCs, provides a detailed institutional analysis of these key players of WSS sector, as well as specific capacity building actions dedicated mainly to their staff. A constant dialogue will be maintained between the WB and EBRD teams, to ensure the efficient exchange of information and complementarity of capacity building actions developed within the two projects. 6.2 Development of capacity improvement plan and delivery of trainings on specific issues related to UWWTD implementation. CAPACITY NEEDS ASSESSMENT (CNA) 74. During the CNA the WB team will focus on the following: • analysis of the current situation; • mitigation/elimination of bottlenecks in the current system; • efficiency of coordination measures and analysis of skills required for implementation of the new system for data collection, validation, reporting and monitoring to be developed under the project; • inter-institutional cooperation; and • usefulness of/expediency in the provision, processing and validation of information. The institutional CNA will need to respond to the following: 1) Stakeholders: the assessment will consider the current situation, including the actual institutional responsibilities and bottlenecks at the level of MoWF, ANAR and other 77 stakeholders related to data collection, validation and reporting for the implementation of the UWWTD provisions. 2) Process: the assessment will examine changes in how the MoWF, ANAR and other relevant institutions carry out the activities related to the implementation of UWWTD (in particular data collection, validation and reporting), how risks are identified, the list of parameters to ensure high quality outputs, and the required personnel skills. 3) The operational capacity of the MoWF, ANAR and other relevant institutions as concerns the data collection, validation and reporting on the UWWTD Implementation, given the mix of managerial and technical competences required. A series of interviews will be organized with relevant staff of MoWF, ANAR and, if needed, of other institutions involved, analyzing, where applicable or available, additional organization documents, structures and working arrangements. Questionnaire(s) – tailored to suit the current situation - will be developed by the WB team and circulated to MoWF, ANAR and other relevant institutions to assess the institutional capacity of for the implementation of the UWWTD (with focus on data collection, validation and reporting) based upon several criteria, such as: - Personnel; - IT Systems for Data Collection and Reporting; - Procedures and processes. Personnel The questionnaire will contain elements to assess the personnel needs to improve their managerial and technical skills, in particular related to data collection, validation and reporting on UWWTD obligations. Based on the results of the interviews and the processed questionnaires applied to the personnel of MoWF, ANAR and other institutions and the detailed review of all documents provided, the resulting findings will be presented as capacity needs assessment (the correlation of capacity improvement activities with the RAS components, activities and outputs are shown in Chapter 5.4, Table 11 below). IT Systems for Data Collection and Reporting The questionnaire will contain general elements for a preliminary review and assessment of the existing approach and IT Systems for Data Collection and Reporting. An in-depth analysis will be conducted further on for the preparation of project Output 6 “Report with technical specifications on how to update and make the existing UWWTD reporting systems SIIF compatible”. Procedures and Processes Considering the major current shortcomings in data collection for UWWTD monitoring and compliance (e.g. each entity involved in UWWTD implementation has its own database, and updates occur at different pace and is using different reference elements) a preliminary assessment of the current procedures and processes for data collection, validation and reporting will be conducted as part of CNA. This analysis will be expanded in Activities B (i) and B (ii) of the project. 78 6.3 Lessons learned from other EU member states on UWWTD implementation CAPACITY IMPROVEMENT PLAN 75. The capacity improvement plan (CIP) aims at enhancing the MoWF and ANAR’s capacity for data collection, validation and reporting on the UWWTD implementation and will be based on realistic resources and time-frame. The capacity improvement plan (CIP) will be elaborated and implemented over the entire project duration, with the WB team support. CIP will reflect key institutional building priorities and will be developed in close partnership with MoWF and ANAR. CIP will analyze the current situation and areas for improvement in the capacity of reporting on the implementation of UWWTD (in particular data collection, validation and reporting) and provide concrete institutional capacity building actions. The information to be included in CIP will be built on the CNA results, as well as further extensive discussions with MoWF, ANAR and other involved counterparts. The WB team will capture a wide array of perspectives, in order to ensure that the proposals would be amenable to Romanian authorities. CIP will propose a gradual approach to build on current capacity, while engaging with more of the relevant stakeholders. It will also outline the content and logistics in organizing and delivering five trainings on specific issues related to the implementation of Directive 91/271/EEC, including SIIF reporting requirements. These training will finish with evaluations of the trainees to assess the transfer of knowledge and received competencies. EXPERIENCE OF OTHER MEMBER-STATES ON UWWTD IMPLEMENTATION 76. The WB team get in touch with national experts from other member states (MS) to share experience in achieving compliance with UWWTD. Although the experience of each EU MS is unique and reflecting the specificities of the country WSS sector history, infrastructure ownership, management models, regulation and etc. efforts to reform the sector to deal with required significant WSS investments, accelerating investments and private sector participation, increase capacity of operators, changes to tariff setting and financing of WSS infrastructure and etc. are worth sharing and lessons learned can be applied in Romania. The UWWTD experience from Bulgaria, Cyprus, Hungary, France and Portugal will be shared and if the MoWF finds specific approach or activities of particular interest further presentations are to be organized in addition to the specific notes on other member-states UWWTD experience. Lessons learned will be incorporated into Outputs 2 and 3. 6.4 Approach and workplan to increase MoWF and ANAR capacity regarding UWWTD obligations 77. Beyond enhancing the inter-institutional cooperation, the capacity building effort will focus on improving the knowledge and skills of the personnel involved in UWWTD implementation. On-the job training related to each of the project Outputs, including examples of good practices will be provided by the WB team to MoWF, ANAR and other regional and local players, along with explanations of how capacity building aspects need to be integrated into long-term planning or how these apply to the needs of various involved institutions. 79 The capacity building measures will be approached by the WB team in each project component, in the context of a larger national effort to improve administrative capacity for implementation of UWWTD. To create effective and sustainable capacity building measures, these will need to be treated with priority in each project component and comprehensively integrated into all levels of planning and financing related to UWWTD implementation. The main types of capacity building activities, links with all the project components, activities and outputs are presented in Table 11. The Matrix of Capacity Improvement Project Activities below: 80 Table 11: The Matrix of Capacity Improvement Project Activities Proposed Capacity Building Activities46 Contribution to the RAS Project Component and Related Activity (as per Legal project outputs/Expected Agreement) time of delivery COMPONENT A: Support for the update of the UWWTD Output 2: Report on options Implementation Plan for optimization of compliance costs and (i) Carrying out a stocktaking assessment of the implementation status of - Conduct MOWF and ANAR capacity needs current implementation plan based on the UWWTD, including assessment; available most up-to-date data, and identifying methodology for defining - Propose a capacity improvement plan bottlenecks and options to accelerate agglomeration with more (CIP), with focus on improving processes, implementation in line with the UWWTD than 2,000 p.e. personnel skills and enhancing the inter- including the review of alignment of existing institutional cooperation for (28th September 2019) national policies, institutional arrangements, implementation of UWWTD incentives towards improved compliance efforts, and relevant lessons learned from other EU member states; (ii) Assessing options for optimization of compliance costs including: - Organize and participate in meetings in 40 − organize and participate in meetings in 40 counties to present and discuss the new counties to present and discuss the new methodology and potential implications methodology and potential implications for the for the county; county; 46 The final list as well as details on capacity improvement activities (activity type, topics target groups, duration, locations, etc.) will be provided in the capacity improvement plan. 81 COMPONENT A: Support for the update of the UWWTD Output 4: Report with a Implementation Plan proposed updated - Organize and participate in consultation Implementation Plan of (v) Developing an indicative timetable for the sessions and workshops with the relevant UWWTD, including implementation of Directive 91/271/EEC, taking institutions on updated Implementation prioritization of measures into account the available financial resources and Plan of UWWTD. and new timeline for including suggestions for better linkages and compliance of the alignment with WFD’s environmental objectives agglomerations above 2,000 by prioritizing Waste Water Treatment Plant p.e. investments based on the expected impact on the ecological status of recipient water bodies; (28th February 2020) (vi) Strengthening capacity of the personnel of MoWF and “Romanian Waters” National Administration - Design and deliver on-the-job training on (ANAR) in data collection, information validation data collection, information validation and reporting to European Commission on and reporting to European Commission on UWWTD implementation. UWWTD implementation; provide examples of good practices in other EU Member States. COMPONENT B: Assistance for the update of the national Output 5: Report with mechanism for monitoring, evaluation and reporting on proposals to improve data UWWTD implementation collection, validation of information regarding - Participate in meetings with MoWF and (i) Evaluating the existing national UWWTD reporting UWWTD reporting to the EC, ANAR on existing national UWWTD systems under the Recipient and ANAR, and their including proposal for reporting systems and their compatibility compatibility with the SIIF requirements; responsibilities and with the SIIF requirements; timeframe (ii) Developing a proposal to improve the process of - Meetings on improving the process of data data collection, processing and validation of collection, processing and validation of (28th May 2020) information regarding UWWTD compliance information regarding UWWTD compliance reporting to the EC, including responsibilities and reporting to the EC; timeframe; 82 COMPONENT B: Assistance for the update of the national Output 6: Report with mechanism for monitoring, evaluation and reporting on technical specifications on UWWTD implementation how to update and make the existing UWWTD reporting - Provide guidance, coaching/on-the-job (iii) Based on (i) and (ii) above, developing technical systems SIIF compatible training to MoWF, ANAR and River Basin specifications to update the existing systems (or Administrations for updating the existing (28th July 2020) systems under development) in order to be SIIF reporting systems (or systems under compatible. The updated national database development). should enable visualization of the UWWTD reporting file, and support the validation of available information; (iv) Increasing the capacity of the personnel of - Design and deliver 5 training sessions on MoWF and ANAR to work with the updated specific issues related to the Exact date to be decided national UWWTD data collection and reporting implementation of Directive 91/271/EEC, jointly with MWF and ANAR system and SIIF, with special emphasis on including SIIF reporting requirements. at a later stage drawing lessons learned from other EU countries, which are more advanced in the implementation of UWWTD. In this regard the Bank will carry out up to 5 trainings on specific issues related to the implementation of Directive 91/271/EEC, including SIIF reporting requirements, and carry out evaluations of the trainees to assess the transfer of knowledge. COMPONENT C: Recommendations towards development - Participate in consultations, prepare and Output 7: Report with a of a National Strategy for the Water Supply and deliver workshops with the relevant WSS recommended vision Sanitation Sector sector stakeholders, for discussing on WSS statement and an executive sector reform and strategic planning; 83 (iii) Proposing a mechanism to coordinate efforts and - Conduct other capacity building activities, outline of the draft National inputs during the preparation of the Strategy to as per CIP. Strategy for the WSS Sector engage all key stakeholders and IFIs involved in the sector. (28th September 2020) 84 Details on the workplan to increase MoWF and ANAR capacity with regard to UWWTD obligations are presented in Table 12 below: Table 12: Workplan and resources to increase MoWF and ANAR capacity with regard to UWWTD Obligations No. Key aspect/Action Responsible Method/ Timeframe Link with institution Instruments RAS Component / Activity 1. Definition of the WB, MoWF, Discussions, March 2019 – A/ (i), (ii), dimensions/areas of the ANAR meetings mid June 2019 (v), (vi) capacity needs assessment B/ (i), (ii), (iii) (specific issues related to the (iv) implementation of the UWWTD) C (iii) 2. Conduct the capacity needs WB Discussions, end April assessment (with Questionnaires 2019-mid July participation 2019 of MoWF and ANAR) 3. Selection of the priority types of WB, MoWF, Discussions, end July 2019 capacity building actions ANAR Questionnaires 4. Elaboration of the capacity WB Discussions, mid- improvement plan meetings September 2019 5. Submission to MoWF of the WB N/A 28th A/ (i), (ii), capacity improvement plan September (v), (vi) 2019 B/(i), (ii), (iii), (iv) C (iii) 6. Implementation of the capacity WB, MoWF, Training, October 2019- A/ (i), (ii), improvement plan ANAR coaching, up to the end (v), (vi) on-the-job of the legal B/(i), (ii), training, agreement (iii), (iv) consultations, C (iii) etc. 85 Chapter 7. Workplan and roadmap of the associated activities of WSS RAS “Technical support to Romania in analyzing and addressing the challenges in meeting the UWWTD requirements” 2019 2020 Date Jan Feb Mrch April May June July August Sept October November December January Feb Mrch April May June July August Sept October November 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Deadline in Deliverables start 1 2 3 4 5 6 7 end County meetings and field visits Workshops Output 1: Concept paper on support provided to update the UWWTD implementation plan including 3 Months approach, workplan and roadmap of the associated activities April 28, 2019 COMPONENT A: Support for the update of the UWWTD Implementation Plan Output 2: Report on options for optimization of compliance costs and implementation status of UWWTD, 8 Months including methodology for defining agglomeration with more than 2,000 p.e. September 28, 2019 - review and update of the methodology for defining agglomeration with more than 2,000 p.e.; - organize and participate in meetings in 40 counties to present the new methodology Output 3: Report with updated list of agglomerations above 2,000 p.e. details and maps based on the 11 Months methodology for optimizing cost of compliance with UWWTD December 28, 2019 - update of the list of agglomerations above 2,000 p.e. based on the revised methodology, incuding details and maps - conduct analytical field work to validate the maps in boundary cases - review of legal requirements towards Individual Appropriate Systems (IAS) in Romania, and preparation of a detailed proposal for the process of registration and inspection of existing IAS; and planning, design, construction, operation and maintenance, monitoring and control of new IASs, in order to facilitate adequate environmental protection, while optimizing compliance costs. Output 4: Report with a proposed updated Implementation Plan of UWWTD, including prioritization of 13 Months measures and new timeline for compliance of the agglomerations above 2,000 p.e. February 28, 2020 Establishing a baseline in terms of status of implementation of various UWWTD articles based on available information including: - mapping and analyzing information gaps with regard to data on UWWTD implementation in all agglomerations above 2,000 p.e.; - analyzing available information and assisting the MoWF in identifying compliant/non- compliant agglomerations above 2,000 p.e.; Developing a draft Strategic Financing Plan for the remaining investments in the country to address the challenges of UWWTD requirements and existing funding gap Developing an indicative timetable for the implementation of Directive 91/271/EEC Strengthening capacity of the personnel of MoWF and “Romanian Waters” National Administration (ANAR) in data collection, information validation and reporting to European Commission on UWWTD implementation. COMPONENT B: Assistance for the update of the national mechanism for monitoring, evaluation and reporting on UWWTD implementation Output 5: Report with proposals to improve data collection, validation of information regarding UWWTD 16 Months reporting to the EC, including proposal for responsibilities and timeframe May 28, 2020 - Evaluating the existing national UWWTD reporting systems under the MoWF and ANAR, and their compatibility with the SIIF requirements; - Developing a proposal to improve the process of data collection, processing and validation of information regarding UWWTD compliance reporting to the EC, including responsibilities and timeframe; - Increasing the capacity of the personnel of MoWF and ANAR to work with the updated national UWWTD data collection and reporting system and SIIF; - The Bank will carry out up to 5 trainings on specific issues related to the implementation of Directive 91/271/EEC, including SIIF reporting requirements. Output 6: Report with technical specifications on how to update and make the existing UWWTD reporting 18 Months systems SIIF compatible July 28, 2020 - Developing technical specifications to update the existing systems in order to be SIIF compatible. The updated national database should enable visualization of the UWWTD reporting file, and support the validation of available information. COMPONENT C: Recommendations towards development of a National Strategy for the Water Supply and Sanitation Sector Output 7: Report with a recommended vision statement and an executive outline of the draft National 20 Months Strategy for the WSS Sector September 28, 2020 - Preparing a recommended vision statement and an executive outline of the proposed Strategy, focusing on specific areas and issues that need to be addressed in line with the applicable EU environmental directives pertaining to the WSS sector, and improve sector performance and sustainability; - Taking stock and analyzing all available information from national authorities and other International Financial Institutions (IFIs) that provide support to the WSS sector; and - Proposing a mechanism to coordinate efforts and inputs during the preparation of the Strategy to engage all key stakeholders and IFIs involved in the sector. 86 KEY NEXT STEPS 78. Component A • Methodology for defining agglomeration boundaries for agglomerations with more than 2,000 p.e. o Preparation and issuing questionnaire: data for completed WSS infrastructure projects. As explained in section 3.1 of the report, there is a need of information for determination of the cut-off values for selection of the least-costly option (collection system or IAS). During the inception phase, the Ministry of the EU Funds ensured the WB team that the necessary data is available as well as expressed willingness to provide it. A questionnaire with the necessary data has been prepared by the team (March 2019) and submitted to the MoWF. Timely access to this data is crucial for the next activities for the preparation of the methodology. o Establishment of delineation procedure: the procedure will be established on the basis of: i) the developed algorithm for delineation; ii) availability of maps/GIS layers. The procedure will consist of approaches for combining of the available GIS layers as well as producing of maps. Timely access to orthophoto maps and other necessary GIS layers is extremely important for the preparation of the delineation maps for agglomerations following the new methodology. o Visiting two pilot counties: two counties will be visited to validate the piloted delineated boundaries. Participation of a representative(s) of the MoWF is strongly recommended. o Meetings at county level to present and discuss the new methodology: although the WB team will be responsible for the organization and participation it is expected that the MoWF will lead the discussions, while the WB team will ensure technical preparation and provide detailed explanations. Participation of a representative(s) of the MoWF at an appropriate level is mandatory. o Field verification of the boundaries: During the delineation process, some agglomeration boundaries will not be easy to be determined, while performing a desk exercise and looking at maps and statistical data about population. These agglomerations will be included in a list, which will be used for planning of up to 90 visits. Participation of a representative(s) of ANAR at least in the first 5-10 visits is strongly recommended. • Methodology for determination of agglomeration loads with more than 2,000 p.e. o Preparation and issuing questionnaire: based on the experience with load calculation in other countries, a draft version of a questionnaire for gathering the necessary data from WSS operators was prepared in March 2019. The questionnaire was sent to three operators with aim to inquire about data availability, adjust it for the 87 specificities of Romania and finalize the request for information. Data was received, and finalization of questionnaire will be done shortly. MoWF involvement for timely access to data from WSS operators is crucial for the preparation of the methodology. o Algorithm for calculation of the agglomeration loads: As explained in section 3.2 a comprehensive step-by-step algorithm will be developed describing how to calculate the agglomeration load, based on the available data base. o Visit of two pilot WSS operators: to i) present the algorithm and results; ii) discuss the current way of load calculation and iii) explore possibilities for further precision of load calculation. Participation of a representative(s) of MoWF is strongly recommended. 79. Component B o Visit of two river basin directorates: two RBD will be visited to i) continue with the evaluation of the existing national UWWTD reporting system at a regional level; ii) discuss opportunities for improving the existing processes. o Visit of two ROCs and two LoCs: four pilot operators will be visited to i) understand whether specific approach for reporting is used and existence of reporting databases; ii) assess reporting capacity and opportunities for improvement of the process by using IT systems. Participation of a representative(s) of ANAR is strongly recommended. 80. Component C o Establishing baseline: the WB team will work with Romanian institutions to establish a baseline of the existing situation in the WSS sector. Participation of all key WSS stakeholders and IFIs providing assistance to the sector is strongly recommended. o Establishing Advisory Committee: an advisory committee to support the preparation of the WSS Strategy needs to be established. Timely establishment and leading role of the MoWF is crucial for the preparation of the Strategy. o Setting up objectives, target and measures: series of meetings and brainstorm activities will be organized in order for all key WSS stakeholders to agree on the objectives, targets and measures for their achievement for the WSS Strategy. MoWF leadership is extremely important for moving the Strategy preparation forwards. KEY DECISIONS TO BE TAKEN BY MoWF 81. Component A • Determination of the cut-off values: MoWF needs to decide on the proposals for cut-off values for finalization of the methodology for defining agglomeration boundaries for agglomerations with more than 2,000 p.e. 88 • Calculation of the agglomeration loads: MoWF needs to decide on the proposals for algorithm for calculation of agglomeration loads for the finalization of the methodology for determination of agglomeration loads with more than 2,000 p.e. 82. Component B • UWWTD reporting system: once presented with options MoWF needs to decide on what kind of UWWTD reporting system they could implement, taking into account capacity of data originators and availability of funding. 83. Component C • Advisory Committee: MoWF should establish an Advisory Committee to support the preparation of the WSS Strategy • WSS Strategy: High level MoWF involvement would be required for setting up objectives, target and measures to be achieved by the WSS Strategy. 89 Annex 1: Examples of UWWTD compliance reporting discrepancies The UWWTD (table 1 of annex 1) allows using of either the effluent concentration or the removal rate for assessment of the WWTP performance. Romania uses the removal rate criterion. However, there are a lot of agglomerations with high dilution of influent waste water, so the removal rate target is impossible to be met. Using the requirement for effluent concentration is therefore more appropriate for Romania. This is evident from the examples, shown below. In 2016 database, several WWTPs were reported failing, although they had correct results of effluent concentration. Correcting this approach in the reporting methodology will increase the compliance of by hundreds of thousands p.e. In the table below several agglomerations (in total 164,761 p.e.) seems to have correct concentration performance concerning Nitrogen and Phosphorus with both parameters declared Fail in the reporting database. More details for the first agglomeration (ROWP SC Aquacaras SA Resita - Identifier: ROWP_50807_01) are visualized below the table and apparently N and P concentration meet the UWWTD requirement. Load entering Name and ID code BOD COD N P Hyperlink ROWP SC Aquacaras SA Resita - Identifier : https://dev.oieau.fr/uwwtd_ro/treatment- 85559 ROWP_50807_01 Pass Pass Fail ? Fail ? plant/rowp_50807_01/2016 https://dev.oieau.fr/uwwtd_ro/treatment- 31896 ROWP HARLAU - Identifier : ROWP_95364_01 Pass Pass Fail ? Fail ? plant/rowp_95364_01/2016 https://dev.oieau.fr/uwwtd_ro/treatment- 24933 ROWP TG.FRUMOS - Identifier : ROWP_95471_01 Pass Pass Fail ? Fail ? plant/rowp_95471_01/2016 https://dev.oieau.fr/uwwtd_ro/treatment- 17592 ROWP RAJA Cernavoda - Identifier : ROWP_60785_01 Pass Pass Fail ? Fail ? plant/rowp_60785_01/2016 ROWP SC Aquaserv SA Tulcea - Centrul Operational https://dev.oieau.fr/uwwtd_ro/treatment- 4781 Babadag - Identifier : ROWP_159669_01 Pass Pass Fail ? Fail ? plant/rowp_159669_01/2016 164761 Total load entering 90 In the table below several agglomerations (with total 515,099 p.e.) meet the concentration performance concerning Phosphorus, but the parameter was declared “Fail” in the reporting database due to failure of the removal rate. More details for the first agglomeration (ROWP SC APA CANAL SA Sibiu - Identifier: RO7SB_51) are visualized below the table and apparently P concentration meets the UWWTD requirement. Load entering Name and ID code BOD COD N P Hyperlink ROWP SC APA CANAL SA Sibiu - Identifier https://dev.oieau.fr/uwwtd_ro/treatment- 181261 : RO7SB_51 Pass Pass Pass Fail ? plant/ro7sb_51/2016 ROWP Baia Mare - Identifier : https://dev.oieau.fr/uwwtd_ro/treatment- 148234 RO6MM_57 Pass Pass Pass Fail ? plant/ro6mm_57/2016 ROWP RAJA Eforie Sud - Identifier : https://dev.oieau.fr/uwwtd_ro/treatment- 61374 ROWP_60464_01 Pass Pass Pass Fail ? plant/rowp_60464_01/2016 ROWPI SC Rompetrol Rafinare SA - https://dev.oieau.fr/uwwtd_ro/treatment- 45506 Identifier : ROWPI_105.08_01 Pass Pass Pass Fail ? plant/rowpi_10508_01/2016 ROWP TECUCI - Identifier : https://dev.oieau.fr/uwwtd_ro/treatment- 35259 ROWP_75212_01 Pass Pass Pass Fail ? plant/rowp_75212_01/2016 ROWP HUSI - Identifier : https://dev.oieau.fr/uwwtd_ro/treatment- 23710 ROWP_161838_01 Pass Pass Pass Fail ? plant/rowp_161838_01/2016 ROWP RAJA Poarta Alba - Identifier : https://dev.oieau.fr/uwwtd_ro/treatment- 10739 ROWP_62770_01 Pass Pass Pass Fail ? plant/rowp_62770_01/2016 ROWP RAJA Harsova - Identifier : https://dev.oieau.fr/uwwtd_ro/treatment- 9016 ROWP_60810_01 Pass Pass Pass Fail ? plant/rowp_60810_01/2016 515099 Total load entering 91 Competența face diferența! Proiect selectat în cadrul Programului Operațional Capacitate Administrativă cofinanțat de Uniunea Europeană, din Fondul Social Europ ean Competence makes a difference! Project selected under the Administrative Capacity Operational Program, co-financed by European Union from the European Social Fund 92