Submission to European Commission Call for Evidence to evaluate Water Framework Directive

AMI Clean Water Advisory Group member, BM Popoola, submitted her thoughts on the consultation revising the EU Water Framework Directive (WFD).

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The WFD aims to achieve “good ecological and chemical status” for EU waters. While it includes biological elements such as aquatic flora, phytoplankton, invertebrates and fish, microbiology is not clearly reflected in how ecological status is defined or assessed. In contrast, microbiology is addressed more explicitly in directives focused on human health(e.g. Drinking Water and Bathing Water), meaning it is often treated primarily as a safety issue rather than as part of ecosystem functioning.

Given the central role of microbiology in water quality, ecosystem processes, and emerging risks such as antimicrobial resistance (AMR), this consultation presented a timely opportunity to raise these gaps.

In her submission, BM Popoola highlighted how the current EU WFD overlooks the critical role of microorganisms in ecosystem health, focusing primarily on larger biological indicators while neglecting bacteria, archaea, and other microbial communities. Expanding the directive to include microbial indicators — such as faecal coliforms, antimicrobial resistance monitoring, and prokaryotic communities — would provide a more scientifically comprehensive approach to assessing and protecting water quality. Read the complete response below.