Dear Sir or Madam,
We would like to ask for an interpretation of Article 27 of the Regulation on urban waste water discharge and treatment (Official Gazette of the RS, No 98/15, 76/17 and 81/19) and Article 7 of the Regulation on the use of sewage sludge in agriculture (Official Journal of the RS, No 62/08), namely: the public service operator must keep records, which include annual reports on the use of treated sewage sludge in agriculture, in accordance with the Regulation governing the use of sewage sludge in agriculture.
Question: As a public service operator, do we have to obtain an annual report on the use of treated sludge in agriculture from users or does this only apply to plants with a capacity of more than 500 PE?
We also ask for clarification on Article 17 of the Regulation on urban waste water collection and treatment (Official Journal of the European Union 98/15, 76/17 and 81/19): we have a user who has an agricultural holding but no animals, so we assume that the holding does not produce manure or slurry. The content of the application for exemption from the collection of septic sludge/ sludge from a septic tank is not prescribed.
Question 1: In a specific case, does the user have a legitimate claim to be exempted from the collection of the sludge from the septic tank?
Question 2: Do public service operators have to ask the user in writing - in person or on the back of the bill - to renew the application for exemption from the collection of faecal sludge/ sludge from a MSWF?
Question 3: When renewing an application for exemption from the collection of septic sludge/ sludge from MSWM, do we have to require the user to provide us with data on the management of septic sludge/ sludge from MSWM for the previous 3 years, or where is the way to oblige the user to provide us with the data?
Question 4: Do we, as public service operators, also need to request information on the number of animals on agricultural land when receiving an application? Where are the criteria for the application of the exemption in relation to the number of animals defined, as we wonder whether we are competent to make such a judgement?