BALTIC SEAENVIRONMENT PROCEEDINGS No. 59 - Helcom

- norms may cause technical stagnation
- norms set as concentration limits do not promote efforts to dec-
rease water cunsumption
- norms cannot be set as kg/day neither does it take into account
the nature of polluter or the receiving watercourse
- to be effective norms often create a rigid system difficult to
understand by individual polluters.
A chart for the comparison of the policy instruments i.e. norms,
permits and emission charges is annexed (Annex 2). All systems have
their benefits and applications, and a rational combination of the
three together with other instruments would obviously give an optimum
solution.
4. Supervision of point source polluters in Finland
The supervision of polluters in Finland is based on a notification
and permit system and on the supervision of polluters' selfcontroll.
The permits are given by an independent Water Court. There are about
200 factories, 500 municipalities and 370 fish farms in Finland that
have a permit. The date for a new application is determined .in the
permit, but changes in the production or pollution load or other cir-
cumstances may also initiate a new application process. Normally a
permit is valid 3...7 years.
New international recommendations may influence the application
and above all the permit conditions. Most important is, however, the
technical developement and the results of the monitoring program,
which have a great influence not only on single permit conditions but
also on national goals. The interaction between goals, permits,
research and developement on one hand and different supervision
activities on the other is shown in an annexed figure (Annex 3). The
figure also points out items for negotiations (Annex 4).
As may be understood the supervision of the implementation of Helcom
Recommendations is totally integrated in the national supervision
system.. Also the reporting to the Pollution Load Compilation is an
integrated part of the normal reporting system serving the supervisi-
on. As an example the human recources and tasks of the industrial
office at the National Board of Waters and the Environment is presen-
ted in an annex (Annex 5).
225