Hello!
We are writing to draw attention to the difficulties in providing adequate drainage and treatment of urban waste water in areas where public sewerage is not provided, i.e. for individual households.   In the field of wastewater management, the Regulation on the emission of substances from small municipal wastewater treatment plants (Official Journal of the Republic of Slovenia No 98/07 and 30/10) lays down two deadlines by which the owners of residential buildings in areas where no public sewerage system is planned must ensure the discharge and treatment of municipal wastewater in a non-flowing septic tank or a small municipal wastewater treatment plant, namely:
- 31 December 2015 for a settlement area located in a sensitive water catchment area or in a bathing water influence area or in a water protection area, if the urban waste water generation density in that settlement area is greater than 10 PE/ha, and for a settlement area not located in the abovementioned areas, if the urban waste water generation density in that settlement area is greater than 20 PE/ha; and
- 31 December 2017 for a settlement area not included in the areas referred to in the first and second indent, if the urban waste water generation density in that settlement area is less than 20 PE/ha and the area is included in an operational programme for urban waste water collection and treatment.
In the Regulation on the classification of objects according to the complexity of construction (Official Journal of the RS, No 18/13 and amendments), the small municipal wastewater treatment plant is classified as a non-complex object (capacity of the wastewater treatment plant from 50 PE up to and including 200 PE) and a simple object (capacity of the wastewater treatment plant up to and including 50 PE). In the Regulation on the criteria for the designation of a water protection zone (Official Journal of the RS, No 64/04 and amendments), it is classified as a simple object, for which the installation in the WPA is not allowed.   As the old (1985, 2002) municipal ordinances are still in force for the protection of water resources, the construction of a WWTP in an IWP is not allowed. It should be noted that the water protection zones cover a large part of the area of the municipalities of Krško and Kostanjevica na Krki.   As far as we know, the situation is similar in most Slovenian municipalities. According to the available information, the State has adopted 10 regulations on the protection of water resources, and four are in the process of being drafted and adopted.  The State regulations conditionally allow the installation of a small municipal wastewater treatment plant with a capacity of 50 to 200 population units inclusive and a small municipal wastewater treatment plant with a capacity of up to 50 population units in VVO II and VVO III, subject to the issuance of a water consent.   As the State is responsible for the preparation and issuance of Water Protection Zone Regulations for the aquifer water body(s), in accordance with the provisions of Article 74 of the Water Act, it is necessary to adopt regulations to protect water resources and to specify in more detail in which areas and under what conditions the installation of MSWW is permissible. However, as things stand at present, implementation by the envisaged date is not possible.  Due to the untimely adoption of the regulations, the citizens of the different municipalities in Slovenia have different/non-uniform requirements as to how to deal with the problem of urban waste water discharge and treatment, which is unacceptable.    The deadline for the provision of equipment in water protection areas is 31.12.2015!?? It follows from the above that, despite the interest in installing a WWTP in a WFD, it will not be allowed to be built by the deadline (31.12.2015) due to bureaucratic complications.  In addition to the above, municipalities are not or cannot ensure that all agglomerations are equipped with public sewerage systems, where this is required by the Operational Programme for Urban Wastewater Disposal and Treatment, which raises the question: what to do in these cases?