RENA WG 4 Dec 2011 final assessment needs ... - Renanetwork.org

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MACEDONIA (Attachment 2 questionnaire)Background information from the commission (PROGRESS REPORTS 2009 - 2011 and recentreport in the framework of RENA WG4 of 2011)Progress has been made towards further transposing the EU acquis in the field of the environment, inparticular for horizontal legislation and waste management. Some sectors, like water quality or IPPC, arestill lagging behind. The pace of institutional strengthening has dropped off somewhat, usually blamed onthe current global economic crisis and a lack of available resources. The weakness of cooperationmechanisms between authorities responsible for related policy areas (and the tradition of verticalintegration in administrations) creates problems of inconsistency, overlap and confusion betweenmanagement procedures. This remains true for the central-local cooperation, as well as cooperationbetween MoEPP and other ministries such as the Ministry of Health. Implementation of the legislationremains a considerable challenge. Administrative capacity is weak at both national and local levels.Significant further efforts are still needed to further align with the EU acquis in this sector and, moreover,to ensure the required investments. Overall, preparations in the field of environment lacks clear progress.Some progress was made in the area of air quality. Transposition in this area is moderately advanced. Thelist of ambient air quality zones and agglomerations was adopted. The inventory of air pollutant emissionsis being compiled, in accordance with the CORINAIR methodology. The administrative capacity is stillweak particularly at local level. Cooperation between the ministries and institutions involved in air qualityis still not sufficient, in particular on collection and analysis of data. Amendments to the WasteManagement Law were enacted, including provisions on sanctions and the level of fines formisdemeanours. The national waste management plan was adopted. Administrative capacity at central andlocal levels is still largely insufficient. Municipal waste management systems have not been set up yet.Investment in this area needs to be increased. A system to deal with data collection, registration andreporting is still not in place. Little progress can be reported in the case of water quality. Thetransposition process needs to be stepped up.The Administration of Environment is the responsible body for permitting, while SEI is the responsiblebody for supervision/inspection. It is important to remember that inspection information is a valuabletool in permit writing and condition setting; appropriate information exchange and participationprocedures will need to be implemented.Little progress was made on industrial pollution control and risk management. Transposition of theSeveso II Directive on control of major accident hazards involving dangerous substances has progressed.The lack of administrative capacity in this area is a major issue, especially at local level. It results insubstantial delays in issuing IPPC (integrated pollution prevention and control) permits. Training for IPPCinspectors is still not provided. The stakeholders are not sufficiently involved in this process. Theoperators of industrial sites have not yet prepared contingency plans. Significant efforts need to be madein this area. Little progress was made in the area of chemicals (REACH). The EU acquis in this sectorhas still not been transposed. The staff of the national information centre was increased. Some trainingand awareness-raising activities for the institutions and companies concerned have started. Preparations inthis area are at an early stage. Some progress was made in the area of noise. Implementing legislation wasadopted. The administrative capacity is still not sufficient. The units responsible for dealing with noiseissues at central and local levels have not been established yet. Preparations in this area are at an earlystage. The administrative capacity for implementing and enforcing environmental legislation is still farfrom sufficient at both central and local levels. This is particularly true of the inspectorates. The inspectionsystem is understaffed and individual inspectors are required to inspect with respect to all matters and allmedia.Inspectors should be trained to become specialized in areas including IPPC, air, nature, waste, water,SEVESO and chemicals, and hydro-installations, water use and supply. The use of RMCEI is notgenerally introduced and must be speeded together with the new IED. The last one will also have7
considerable impact on inspection and enforcement planning. The country has to implement the new IEDat the same time.Improvement in the quality of the inspection can only be achieved when the quality of the permit and itsconditions are improved at the same time. The latter can only efficiently be improvement when the permitapplication is improved. The latter is the solely responsibility of the enterprises.Reforms to permit procedures will allow more effective inspection, reducing the risks of inconsistentapproaches, conflict of responsibilities and duplication of effort.It will be necessary to ensure that a high level of cooperation is achieved between inspectorates to ensurethis.It should also improve the willingness of operators to collaborate with inspections as their number andthe time spent on them reduces.Combined inspections will also facilitate the introduction of IPPC permit verification; extensive training islikely to be needed to ensure procedures are effective. Existing environmental legislation does notestablish principles for negotiation to complement command and control processes.The coordination between administrative bodies responsible for environment-related issues is not yeteffective. Enforcement of legislation has improved in terms of fines and sanctions, but the system is notyet efficient and no credible record has been established. A command and control approach is used toenforce compliance, with administrative fines specified by law and inspectorates empowered to issue stoporders.More flexibility in tools available to the SEI including compliance orders and the use of economicincentives should be instituted.The environmental monitoring and information system is still not adequate. No funds are foreseen in the2009 budget for new environmental projects., The amount provided is still far from sufficient to meet theneeds. The national environmental investment strategy was adopted. Environmental protectionrequirements are still not well integrated into policy making and implementation in other areas. Theprecautionary principle, the principle of preventive action and the polluter-pays principle are only partiallyapplied.Inception missionAbout 113 applications of IPPC permits are in more or less advanced state of permitting. In total 130installations are in A (bigger installations), and 150 installations are classified in category B for smallerinstallations.Pilot training in IPPC permitting is in demand. Step by step training is very much needed and all the stepsof the regulatory cycle must be trained. (from Application to permit drafting, compliance monitoringenforcement and feedback).It was agreed that in the IPPC permits not enough attention is paid in the quality of monitoringrequirements. It was mentioned that according to Macedonian IPPC legislation, industry needs to fullycomply with the BREFs as from 2016, and at that time the limit values will have to be upgradedResults QuestionnaireThe results are divided according the sub headings of the questionnaires:8
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