Our association, AQUA!, wished to contribute to the European Commission’s call for evidence regarding a possible review of the Water Framework Directive, which closed on 14 April 2026. Whilst this initiative primarily concerns the simplification of administrative authorisation procedures for the exploration and extraction of ‘critical raw materials’, AQUA is taking this opportunity to highlight the risk of a significant imbalance in treatment between projects with a major impact on water resources (both qualitative and quantitative), such as these industrial projects, and other much smaller projects with reduced negative impacts, or even positive ones, such as projects to reactivate historic mills for hydroelectric power generation.
The document we have posted on the European Commission’s portal sets out this reasoning in detail and leads to several recommendations at European level:
- Recognise that small hydropower plants are in the ‘overriding public interest’, explicitly highlighting their contribution to renewable energy targets, energy security and rural development;
- Establish a proportionate authorisation system with fast-track procedures for micro- and small hydropower plants (<1 MW), particularly for existing structures, and reduce the administrative burden in relation to environmental risk;
- Apply a ‘net ecological benefit’ criterion that authorises projects incorporating fish passages, sediment continuity and improvements to wildlife habitats, and which enable an overall improvement in ecological status despite a minor structural presence;
- Ensure equal treatment with critical raw materials (CRM) projects, by ensuring that any simplification or exemption framework applied to these projects also applies to low–impact renewable energy projects.