for a better environment - IMPEL

IMPEL in progress 

for for a better etter environment environment 

27-29 September 2006, RIGA, Latvia

1 


Contents 

1. Conference Programme 3 

2. Introduction and Welcome 8 

Session 1 ”Opening Session” 9 

Session 2 ”IMPEL and New Developments” 14 

Session 3 ”Workshop on Enforcement Strategies and Approaches” 22 

Session 4 „Workshop: Contribution of the IMPEL Network to Better Legislation” 28 

Session 5 ”Workshop on Permitting” 34 

Session 6 ”Workshop on Recently Finished IMPEL Reports and New Fields of Work” 39 

Session 7 ”Workshop on Networking” 46 

Session 8 ”Workshop on Inspection and Enforcement for the Future” 56 

Session 9 ”Reports from Workshops” 61 

Session 10 ”Keynote Speech and Conclusions” 72 

3. Conclusions and Recommendations 74 

Annex 1. Conference participants’ list 80 

Annex 2. Short overview of the organization of inspection in IMPEL Member States, 

Norway, acceding and candidate countries 2006 91 

Annex 3. Questionnaire “The 3rd IMPEL Conference in Riga (Latvia), 

27-29 September 2006 100 

for a better environment

IMPEL Conference 2006 

27-29 September 2006 

Riga (Latvia) 

2 

Agenda

27 September 2006 

Day 1 

Session 1 ”Opening Session” 

Chairman: Mr. Raimonds Vējonis (Latvia) 

Rapporteur: Mr. Terry Shears (United Kingdom) 

Welcome and Introduction 

Mr. Raimonds Vējonis (Latvia) 

The Benefi ts of IMPEL Network for Latvia 


The Role of the IMPEL Network for the Implementation of the EU Environmental Regulations 

Message of Commissioner for Environment Mr. S.Dimas by Ms. Pia Bucella (European Commission) 

New Trends in Permitting and Compliance Monitoring 

Mr. Antero Honkasalo (Finland) 

The Role of the Industry in the Reaching of the Environmental Goals 

Mr. Lars Aagaard (UNICE) 

The Role of the Citizen in the Implementation of European Environmental Policy 

Mr. Stefan Scheuer (European Environment Bureau) 

Discussion 

Chairman: Mr. Terry Shears (United Kingdom) 

Session 2 “IMPEL and New Developments” 

Chairman: Mr. Jim Gray (United Kingdom) 

Rapporteur: Mr. Erik Forberg (Norway) 

EC Environment Law: Development and Implementation 

Mr. Julio Garcia Burgues (European Commission) 

Evaluation of the Recommendation for “Minimum Criteria for Environmental Inspections” and Introduction of 

the Three Parallel Workshops 

Ms. Anna Karamat (European Commission) 

Workshop 1 

“Better Regulations, Competitiveness and Effective and Effi ciency Protection of the Environment” 

Chairman: Mr. Roy Ramsay (United Kingdom) 

Referent: Mr. Martin Whitworth/Mr. Michel Catinat (DG-Enterprise) 

Co-referent: Mr. Marek Mroczkowski (Poland) 

Workshop 2 

“Better Permitting and Sustainable Development” 

Chairman: Ms. Waltraud Petek (Austria) 

Referent: Ms. Marianne Wenning (DG-Environment; European Commission) 

Co-referent: Ms. Patricia Blanc (France) 

Workshop 3 

“Better Inspections and Enforcement and Sustainable Development” 

Chairman: Mr. Ed Eggink (The Netherlands) 

Referent: Ms. Martina Froben (Germany) 

Co-referent: Mr. Flemming Joergensen (Brenntag Nordic, Denmark) 

Reporting Back from Workshops 

Mr. Roy Ramsay (United Kingdom) 

Ms. Waltraud Petek (Austria) 

Mr. Ed Eggink (The Netherlands) 

Discussion 

Chairman: Mr. Jim Gray (United Kingdom) 

Introduction of the Workshops of the Next Day 

Mr. Jim Gray (United Kingdom) 

3 




Day 2 -Morning (parallel sessions) 

Session 3 “Workshop on Enforcement Strategies and Approaches” 

Chairman: Ms. Tatjana Bernik (Slovenia) 

Rapporteur: Ms. Ana Isabel Garcia (Portugal) 


Ms. Tatjana Bernik (Slovenia) 

Enforcement and Sanction Strategy in Belgium 

Mr. Jean Pierre Janssens (Belgium) 

Intervention Strategies in the Netherlands 

Mr. Arthur Faber (The Netherlands) 

Sanction Strategy in Germany 

Mr. Franz Grassmann (Germany) 

Enforcement and Sanction Strategy in the United Kingdom 

Mr. Martin Quinn (United Kingdom) 

Experiences with a Sanction Strategy in Sweden 

Ms. Anna Tiberg (Sweden) 

Discussions 


Conclusions 

Ms. Tatjana Bernik (Slovenia) 

Session 4 “Workshop Contribution of the IMPEL-NETWORK to Better Legislation” 

Chairman: Mr. Andreas Wasielewski (Germany) 

Rapporteur: Ms. Karen Riddick (United Kingdom) 


Mr. Andreas Wasielewski (Germany) 

IPPC Review and Interrelationship of Directives 

Mr. Terence Shears (United Kingdom) 

Inspector’s View on Better Legislation 

Mr. Paul Bernaert (Belgium) 

Legal Aspects 

Ms. Eva Kruzikova (Czech Republic) 

Practicability and Enforceability of Legislation 

Mr. Jan Teekens (The Netherlands) 

Commission’s Point of View on Role of IMPEL for Better Legislation 

Mr. Charles Pirotte (European Commission) 

Reaction of Politicians 

Mr. Indulis Emsis (Latvia) 

Discussion 


Conclusions 



for a better environment 

4

Session 5 “Workshop on Permitting” 

Chairman: Mr. Frank Clinton (Ireland) 

Rapporteur: Ms. Barbara Pucker (Austria) 


Mr. Frank Clinton (Ireland) 

Overall View of the European Developments on Licensing and Permitting for the Next Coming Years 

Mr. Alexandre Paquot (European Commission) 

Introduction of Best Practice on Quality Approach 

Mr. Sami Koivula (Finland) 

Introduction of Best Practice on Standardization Approach 

Mr. Didier Pitrat (France) 

Demands from the Public to the Permitting Process 

Mr. Per Christensen (Denmark) 

Discussion with and between workshop attendants and forum 


Conclusions 

Mr. Frank Clinton (Ireland) 

Session 6 “Workshop on Recently Finished IMPEL Reports and New Fields of Work” 

Chairman: Mr Gernot Schnabl (European Commission) 

Rapporteur: Mr. Steen Fogde (Denmark) 

IMPEL Review Initiative in Sweden 

Ms. Inga Birgitta Larsson (Sweden) 

INSPECTAN Project 

Mr. Riccardo Quaggiato (Italy) 

Solving Environmental Problems through Neighbourhood Dialogue 

Mr. Lars Bobzien (Germany) 

Doing the Right Things 

Mr. Wike Niessen (The Netherlands) 

EU Emission Trading Scheme 

Ms. Lesley Ormerod (United Kingdom) 

IPPC Related Water Issues in the Netherlands and in Hungary 

Mr. Jan Leentvaar (The Netherlands), Mr. Pal Varga (Hungary) 

Discussion 

Chairman: Mr. Gernot Schnabl (European Commission) 

Session 7 “Workshop on Networking” 

Chairman: Mr. Markku Hietamäki (Finland) 

Rapporteur: Ms. Alessandra Burali (Italy) 

Welcome Speech 

Mr. Markku Hietamäki (Finland) 

Czech National Network 

Ms. Lenka Nemcova (Czech Republic) 

German National Network 

Ms. Gisela Holzgraefe (Germany) 

Irish National Network 

Ms. Valerie Doyle (Ireland) 

Introduction on TFS Cluster 

Mr. Peter Wessman (European Commission) 

TFS Seeports Project 

Ms. Malgorzata Kotodziej-Nowakowska (Poland) 

Continuty of the TFS Network and Goals for the Future 

Ms. Magda Gosk (Poland) 

ECENA Network 

Mr. Mihail Dimovski (ECENA secretariat) and Mr. Zoran Dimovski (Former Yugoslav Republic of Macedonia) 

Green Enforcement Network 

Mr. Ladislav Miko (European Commission) 

Modernising Environmental Regulation and Enforcement in the EU’s Eastern Neighbours: The Role of the 

Regulatory Environmental Programme Implementation Network 

Ms. Angela Bularga (OECD) 

5 



Session 8 “Workshop on Inspection and Enforcement for the Future” 

Chairman: Mr. Pieter-Jan van Zanten (The Netherlands) 

Rapporteur: Mr. Jesus Angel Ocio (Spain) 


Mr. Pieter-Jan van Zanten (The Netherlands) 

Overall View of the European Developments on Inspection and Enforcement for the Next Coming Years 

Ms. Lena Callermo (Sweden) 

Introduction of Best Practice on Quality Approach 

Mr. Boguslaw Dabrowski (Poland) 

Delegation of Inspection 

Mr. Pierre Bois (France) 

Doing the Same with Less Recourses 

Mr. Mick Henry (Ireland) 

Compliance Assistance 

Ms. Lena Thystrup (Denmark) 

Discussion 


Conclusions 



Day 3 

Session 9 “Reports from the workshops” 

Chairman: Mr. Julio Garcia Burgues (European Commission) 

Rapporteur: Ms. Judīte Dipāne (Latvia) 


Mr. Julio Garcia Burgues (European Commission) 

Report from Workshop on Networking 

Ms. Alessandra Burali (Italy) 

Report from Workshop on Better Legislation 

Mr. Karen Riddick (United Kingdom) 

Report from Workshop on Permitting 

Ms. Barbara Pucker (Austria) 

Report from Workshop on Inspection 

Mr. Jesus Angel Ocia (Spain) 

Report from Workshop on IMPEL Products 

Mr. Steen Fogde (Denmark) 

Report from Workshop on Enforcement Strategies and Approaches 

Ms. Ana Isabel Garcia (Portugal) 

Questions and Discussions 


Session 10 “Keynote Speech and Conclusions” 


Rapporteur: Ms. Judīte Dipāne (Latvia) 

Challenges for the IMPEL Network 

Mr. Ladislav Miko (European Commission) 

Conclusions and Closure of the Conference 




6

Photo: Ivars Druvietis (Latvia)

Session 1 | Opening Session | 27 September 2006 



Opening Speech by Mr. Raimonds Vējonis, 

Minister of the Ministry of Environment of the Republic of Latvia 

Excellencies, ladies and gentlemen, dear participants, 

On behalf of the Preparatory Committee, it is my 

pleasure to welcome you in Riga, the capital city 

of Latvia and for this week also the capital of 

environmental experts. 

Every three years IMPEL organises a large-scale 

conference on the implementation and enforcement 

of the European environmental law in practice. These 

conferences are of particular interest for experts, state 

offi cials and practitioners in the fi eld of transposition, 

implementation and enforcement of European 

environmental legislation on national, regional and 

local level. 

“IMPEL in Progress for a Better Environment” is a 

common title for 200 participants representing more 

than 30 countries. I would like to draw your attention 

that today IMPEL network crosses the borders of 

Europe and has become a focus of interest for more 

and more countries. You will fi nd colleagues from 

the Russian Federation, Belarus, Armenia, Georgia, 

as well as representatives from other networks and 

organizations. 

8 

One of the main aims of this Conference is to 

evaluate more than 10 years’ experience of IMPEL 

network in the framework of EU environmental 

legislation development and enforcement. We are 

eager to provide you a forum to exchange your 

experiences and ideas, your knowledge and to learn 

about implementation and enforcement of European 

environmental legislation. 

You have been invited here, as you are the experts in 

the fi eld or representatives from national governments 

or stakeholders from local governments dealing with 

environmental inspection and permitting. We would 

like to offer you several plenary presentations and 

workshops with the most challenging discussion 

topics, for instance, inspection, permitting, 

enforcement strategies and approaches, aspects of 

environmental legislation. We would like to invite you 

to discuss the recent situation of IMPEL, the role of 

this network today and in the future. I would like to 

encourage everyone to take an active part in making 

this event a great success.

Excellencies, ladies and gentlemen, dear participants, 

As the former Latvian national coordinator of IMPEL 

and now from the position of the Minister of the 

Environment of the Republic of Latvia, I see IMPEL as 

a good tool for experience exchange on enforcement 

of European Law. Therefore I took an active role in 

the preparation of the Conference and initiated a 

Europe-wide assessment of the IMPEL network by my 

colleagues, the Ministers of Environment in Europe. 

For this purpose, during Conference preparation, 

we developed a questionnaire, which was sent to 

the European Environmental Ministers. The aim 

was to evaluate the IMPEL network, compare our 

expectations and refl ect on the main benefi ts IMPEL 

gives to our everyday work. The feedback on the 

questionnaire was very positive and herewith I would 

like also to express my big thanks to those countries 

which responded to my initiative. 

In the following I would like to give you a summary of 

the fi ndings from the answers assessed. 

The fi rst block of questions dealt with the role of 

IMPEL as information provider - we wanted to know 

if countries consider the information forwarded via 

IMPEL as suffi cient, regularly enough and reaching 

the right points in the countries. 

Latvia, same as most of European countries (more 

than 90% of respondents), receives information 

about IMPEL activities on regular basis. We know 

each other in the network and we can build upon 

common practice of implementation and enforcement 

of environmental legislation. The IMPEL Network, 

I would say, is well advanced in use of modern 

communications tools. The assessment shows that 

nowadays e-mail functions as the main information 

tool for our purpose. Additionally, the work of national 

coordinators, who actively bring the information from 

the European level to the national, regional and local 

level, was positively evaluated as one of the main 

tools for information. We were also pleased to hear 

that the state institutions recognized reports at the 

IMPEL web-site as a valuable source of information. 

My personal evaluation is, that the IMPEL Network 

has achieved a high level of information exchange, 

which is worth to be kept and even increased. 

Almost all countries have stated this as well in the 

assessment. I think we can be satisfi ed with this 

achievement. 

The Benefi ts of IMPEL Network for Latvia 


9 


Another important question assessed was “Which 

activities of IMPEL in Latvia and other European 

countries are recognized at the national/local level?” 

The answers illustrate that participation in various 

projects is one of the most important activities. 

Latvia, for example, has also participated in several 

projects: we took an active role in implementation of 

the “Sea Port Project” where we analyzed the waste 

shipment through harbours of Europe. During the 

implementation of the projects we worked together 

with partners from many countries and felt a stronger 

cooperation spirit and, of course, we learned a lot 

from each other. 

Another aspects of the IMPEL work highlighted in 

the assessment as very important are the efforts 

to support a harmonised approach for supervision 

and control of transboundary movement of waste. 

The IMPEL Recommendations on Minimum Criteria 

for Environmental Inspections strengthen the 

enforcement of national environmental legislation 

as well as ensure the compliance with Community 

environmental law. They are a valuable tool for 

inspection. 

Last, the meetings and technical trainings provided 

by IMPEL are among the best evaluated tools for 

sharing experience and best practices. We jointly 

train our staff to increase their capacities for better 

enforcement of the environmental legislation in our 

countries as well as all over the Europe. Our people 

return from these European events with new skills, 

competences and I see their progress in handling the 

complexity of environmental protection. 

Finally, Latvia and all our partners in the IMPEL 

Network are practicing active membership - we are 

not only “consuming” the benefi cial programmes 

and projects organized by the secretariat, but we 

also are contributing with our experiences and 

take over responsibilities – last for hosting the 

Conference in Riga. In the recent years, since we 

are members of the European Union, Latvia has 

considerably increased its activity and the same 

stands for the other new EU member states. I 

consider our experience to be especially valuable for 

those countries which are currently acceding to the 

European Union or building partnerships with EU 

countries, like our Eastern neighbours. Therefore I can 

foresee an even higher activity of the new Member 

states in the frame of IMPEL for the success of 

enforcement of European Environmental policy. 




The Role of the IMPEL Network for the Implementation of the EU Environmental Regulations 

Message of Commissioner for Environment Mr. S.Dimas by 

Ms. Pia Bucella (European Commission) 

Dear Colleagues, 

As Commissioner for the Environment, I see 

implementation of Community environment 

legislation as one of my core objectives. Even the 

best environmental legislation is of little value 

without effective implementation. And since 

implementation is primarily the responsibility 

of Member States, it is indispensable to have a 

mechanism to promote dialogue, co-operation 

and exchange of experience between national 

enforcement authorities. 

The idea of establishing a network of European 

environmental enforcement authorities was fi rst 

put forward over fourteen years ago. From the start 

IMPEL has done much to improve implementation 

of Community environmental law. It has helped to 

develop channels for exchanging information and 

experience on permits and inspections. It has also 

promoted greater consistency in the implementation 

and enforcement of environmental legislation. 

One of IMPEL’s main strengths is clearly its broad 

membership – EU Member States, Candidate and 

Accession countries, plus Norway. Moreover, the 

informal character of the network enables IMPEL 

to achieve objectives that would otherwise be 

much more diffi cult to achieve through more formal 

channels. The light structure and the voluntary 

approach mean that IMPEL can focus on practical 

and topical issues. 

IMPEL’s key priorities in recent years have been 

capacity building (including reviewing inspectorates) 

improving methodologies and developing good 

practices for issuing permits and conducting 

inspections. At the same time, IMPEL has been 

exploring new approaches and providing feedback for 



10 

policy-makers on the practicalities and enforceability 

of environmental legislation. A new “Cluster” was 

set up to take this work forward, and this allowed 

IMPEL, among other things, to contribute to the 

review of the IPPC Directive. 

There are of course many other examples of 

IMPEL’s excellent work, but I would specifi cally 

like to mention the development of Minimum 

Criteria and the Reference Book for Environmental 

Inspections, which contributed substantially to the 

Recommendation on environmental inspections. 

The two Seaport Projects are also an important 

achievement. They highlighted the extent of illegal 

waste shipments in the EU and the need for a 

European enforcement strategy. The problems 

identifi ed by IMPEL during the common inspection 

weeks put the Network on the front pages of national 

newspapers. 

IMPEL will have to deal with many challenges in 

the future, but I am confi dent that you will continue 

to work on the priorities of European environmental 

policy as defi ned in the 6 th Environment Action 

Programme. In the coming years your role will be 

more important than ever, notably as regards our 

Better Regulation agenda, which will require your 

input and feedback. 

In particular, the Commission would welcome 

IMPEL’s contribution to the review of the 

Recommendation on Minimum Criteria for 

Environmental Inspections. You should also continue 

your work on waste, particularly in view of the 

adoption of the new Waste Shipments Regulation, 

and the need to ensure the implementation of other 

legal instruments on waste.

Climate change could also emerge as an important 

priority for IMPEL. The basic legislative framework 

is now in place so IMPEL could certainly play 

a signifi cant role with the key task of effective 

implementation. 

Your work and deliberations at this Conference are 

very important, as they will help determine IMPEL’s 

future activities and priorities. I look forward to 

working closely with the network in the future to help 

achieve our common goal of a better environment. 

Finally let me thank the Latvian Government for 

hosting this Conference, and all the people who 

helped to organise it. I hope your discussions over 

the next few days will be interesting and fruitful. 

Yours sincerely, Stavros Dimas 

Stavros Dimas 

B-\1049 Brussels 

Member of the European Comission 

Telephone: +32 2 298 20 00 

11 


Attention to: 

Mr. Vilis Avotins, 

Head of Conference Preparatory Committee 

Director-General 

State Environmental Service of LATVIA 

Conference Secretariat 

State Environmental Service 

Rupniecības iela 23, Riga 

LV-1045, Latvia 

e-mail: vilis.avotins@vvd.gov.lv 

Telephone: +371 7084 818/201 

Fax: +371 7048 212 




Mr. Lars Aagaard (UNICE), Mr. Stefan Scheuer (EEB), Mr. Will Fawcett (United Kingdom), Mr. Terry Shears (United Kingdom), 

Ms. Pia Bucella (European Commission), Mr. Raimonds Vējonis (Latvia), Mr. Antero Honkasalo (Finland) 

The experiences with the environmental permit 

system created by IPPC-directive have been mainly 

positive. The IPPC-directive has harmonized 

permit writing, permit procedures and authority 

organizations in Member States as well as the level of 

environmental protection required, but it also leaves 

enough room so that specifi c national conditions can 

be taken into account. However, there exists a need 

for further development in the permit system. The 

needs are partly internal and partly external. 

Internal factors exist due to the diffi culties in the 

interpretation of some articles and defi nitions of 

the directive. The external stress is caused by 

developments in environmental policy and economic 

problems in Member States. Emission trading, 

environmental management systems and other new 

policy instruments force us to look at their interface 

and possible overlapping with the permit system. 

Adaptation to the changes in global economy forces 



New Trends in Permitting and Compliance Monitoring 

12 

governments to seek new possibilities to increase 

productivity in the public sector. At the same time 

information technology gives us new ways to develop 

compliance monitoring. 

In Finland, the Ministry of the Environment has 

started a productivity development project to make 

permitting more effective. The aim is to have only one 

state’s permit authority with few regional sub-bodies. 

Binding rules will be developed and permits will be 

handled with a new advanced IT-data system 

However, in spite of all these activities to increase 

productivity of the permit system, we must remember 

that permitting is not only a means of environmental 

policy, but it also guarantees rights for operators 

and citizens and increases their possibilities in 

participation. It forms a legal base for the use of 

other relevant policy instruments. New trends and 

developments must be adapted into this framework in 

order for it to function properly. 

Mr. Antero Honkasalo 

Director, Environmental Protection in Industry and Trade 

the Ministry of the Environment, Finland 

Kasarmink 25, Po Box 35, FIN- 00023, Government, Finland 

+358 9160 39345 

+358 9160 39453 

antero.honkasalo@ymparisto.fi


Session 2 | IMPEL and New Developments | 27 September 2006 

Mr. Julio Garcia Burgues (European Commission), Mr. Erik Forberg (Norway), Mr. Jim Gray (United Kingdom) 



EC Environment Law: Development and Implementation 

EC environment law has experienced a rapid 

expansion over the past 30 years, and now it has 

reached maturity. However, legislative production 

has not stopped. On the contrary, major legislation 

proposals have just been adopted or are in the 

pipeline. At the same time, legislation is being 

refi ned, rationalised and codifi ed under the 

Better Regulation agenda (which does not mean 

deregulation). 

14 

At present, ensuring the effective implementation of 

EC environment law is probably the key challenge. 

There are signifi cant implementation gaps which 

need to be addressed through an appropriate mix of 

legal and non-legal instruments. It is also essential 

to promote a more effective role for all relevant 

authorities in Member States and to strengthen cooperation 

with stakeholders. IMPEL’s contribution, 

as an informal platform to bring together 

implementation and enforcement offi cials, is certainly 

of major importance. 

Mr. Julio García Burgués 

European Commission 

BU-9 1/185, B-1049, Brussels, Belgium 

Telephone:+322 296 876 3 

Fax:+322 299 107 0 

julio.garcia-burgues@ec.europa.eu

Under the Recommendation 2001/221/EC 

establishing minimum criteria for environmental 

inspections Member States were asked to report on 

the implementation of the RMCEI and its application 

in practice. 

On the basis of these reports the Commission should 

assess how well the RMCEI has been implemented 

and how it could be further developed. 

The Commission received reports from all Member 

States and Acceding Countries. 

The fi rst conclusions that can be drawn are those that 

the information received is in many cases incomplete 

and not comparable. Therefore, it is diffi cult to draw 

conclusions on the implementation of the RMCEI. 


Evaluation of the Recommendation Establishing Minimum Criteria for Environmental 

Inspections 

15 

It appears from the available information that the 

most important elements of the RCMEI to be further 

discussed are the following: 

- How to improve the planning of inspections; 

- Criteria for the evaluation of the success of 

inspection plans; 

- Clarifi cation of important defi nitions, such as 

inspection plans versus inspection programmes 

- How to make reporting on the RMCEI more effi cient 

and clear; 

- How to measure whether an inspection system 

is achieving its objective, i.e. to ensure better 

compliance with environmental legislation. 

The Commission services are working on a report 

summarising the information received from Member 

States and on a communication outlining the areas of 

the RMCEI that need to be further discussed. 

Ms. Anna Karamat 

European Commission, DG Environment 

BE-1049 Brussels, Belgium 

Telephone: +32 2 2953583 

Fax: +32 2 2991068 

anna.karamat@ec.europa.eu 




Mr. Marek Mroczkowski (Poland), Mr. Martin Whitworth (United Kingdom), Mr. Roy Ramsay (United Kingdom) 

Workshop 1 



Reducing Burdens on Industry - Examples from Environmental Regulation 

As part of the practical implementation of the 

Lisbon Strategy and its better regulation agenda 

Member States have been developing their national 

simplifi cation programmes. These aim at reducing 

administrative burdens on industry by simplifying 

legislation and the framework for its implementation. 

This project started in 2004 to identify practical 

examples of actions that authorities had successfully 

taken to reduce burdens. A group of national experts 

and a consultant carried out the work under the 

auspices of the European Commission’s ‘BEST 

Procedure’. 

The study found 75 concrete actions taken by 

contributing countries as part of their simplifi cation 

initiatives. They were grouped into the following 

seven categories developed by the Expert Group for 

further analysis: organisation/institutional framework; 

simplifi cation of permit schemes; simplifi cation of 

monitoring/reporting; simplifi cation of inspection; use 

of IT tools/electronic systems; risk-based/incentivedriven 

approach; and compliance assistance/support. 

Of the 75 concrete actions, 26 were further 

evaluated as being clearly innovative approaches to 


16 

simplifi cation, and thus represented best practice. 

Overall, the Expert Group recommended that 

concrete actions be taken in all of the categories 

identifi ed during the study. The selected best 

practice examples form the basis for a series of 

recommendations for policy makers and relevant 

stakeholders to help improve the development and 

implementation of simplifi cation initiatives. The 

Expert Group made 33 recommendations to Member 

States and the Commission on taking forward the 

simplifi cation actions. They are addressed primarily 

at Member States who should use them in their 

national simplifi cation programmes. Some are 

addressed jointly to them and the Commission, or 

the Commission alone. The European Commission 

published all of the best and good practice examples 

and the recommendations in a report on 22 June 

2006. 

The work undertaken by the Expert Group shows 

that burdens can be reduced without lowering 

environmental protection standards by putting in 

place concrete simplifi cation actions, which promote 

growth and jobs across the EU. 

Mr. Martin Whitworth 

Environment Agency (formerly of DG Enterprise and Industry) 

Industry Regulation, Block 1 Govt Buildings, Burghill Road 

Westbury-on-Trym, Bristol, BS10 6BF, United Kingdom 

Telephone: +44 1179 142948 

Fax: +44 1179 142827 

martin.whitworth@environment-agency.gov.uk 

Mr. Michel Catinat 

DG Enterprise and Industry, European Commission 

Unit B4, Competitiveness Aspects of Sustainable Development 

Breydel 7/335, Avenue d’Auderghem 45, B-1040 Brussels, Belgium 

Telephone: +32 2 29 92403 

Fax: +32 2 29 91925 

michel.catinat@ec.europa.eu

1. The infl uence of “good environmental regulations” 

on the industry and business costs. (Issue of 

costs reduction, saving energy and benefi ts 

connected with them.) 

2. Environmental regulations and environmental 

goods and services. (Infl uence of high 

environmental standards that stipulate the 

company’s strong position on the market.) 

3. Relations between “good environmental 

regulations” and innovative activity. (Positive 

infl uence of environmental regulation on 

innovative activity of companies that brings them 

to successive activity in a competitive world.) 

4. Confi dence of the market and insurers. (Issue 

of positive image of the companies complying 

with environmental regulations that helps them 


Workshop 1 


Good Environmental Regulation and Competitiveness 

17 

in their relations with fi nancial and insurance 

institutions.) 

5. The myth of a competitive disadvantage. (Good 

infl uence of environmental regulation on 

innovation and better practices in business.) 

6. The infl uence of “good environmental regulations” 

on the jobs’ creation. (Development of 

environmental goods and service branch.) 

7. The issue of the society health and the conditions 

of natural resources taking into consideration 

“good environmental regulations”. (Links between 

the environment and people’s health; positive 

infl uence of “good environmental regulations” 

on natural resources used by industry in the 

production process.) 

Mr. Marek Mroczkowski 

Chief Inspectorate for Environmental Protection 

Wawelska 52/54 str., 00-922 Warsaw, Poland 

Telephone: +48 22 825 98 15 

Fax: +48 22 825 98 15 

m.mroczkowski@gios.gov.pl 




Ms. Marianne Wenning (European Commission), Ms. Waltraud Petek (Austria), 

Ms. Patricia Blanc (France) 

The IPPC Directive is a key legislative framework to 

achieve the objectives of sustainable development. 

The IPPC Directive addresses all major industrial 

sectors and sets ambitious goals to ensure high 

environmental protection through an integrated 

permitting regime based on Best Available 

Techniques. 

In this context, the Directive leaves some fl exibility to 

Member States in their application of the Directive. 

Since its adoption in 1996, emissions and impacts 

have been reduced through the application of more 

advanced techniques. New and more effi cient 

permitting regimes were also introduced in a number 

of Member States. 

However, the Commission notes that stronger efforts 

are still needed by the majority of Member States to 

fully comply with the Directive by its fi nal deadline 

of 30 October 2007. In its report in November 

2005, the Commission highlighted that there are still 

diffi culties and shortcomings in implementation. The 

Commission launched an Implementation Action Plan 

with a view to support Member States and assess the 

potential rooms for improvement. 

In this context, the Commission is carrying out a 

study to assess the implementation by Member States 



Workshop 2 

“Better Permitting and Sustainable Development” 

18 

of the Directive through the analysis of particular 

installations. Preliminary assessments in the context 

of the Action Plan illustrate that unsatisfactory and/ 

or delayed implementation is often due to the late 

preparation towards the deadline of October 2007, 

the lack of administrative resources, of expertise and 

the poor commitment from industry to achieve BAT. 

The Commission is also preparing guidance 

documents to facilitate the implementation of the 

Directive by setting common interpretation of different 

terms and defi nitions. 

Furthermore, the Commission has launched a review 

of the IPPC Directive and related industrial emissions 

to assess ways to improve the current legal framework 

in the context of Better Regulation. An important 

pillar is the assessment of ways to streamline current 

legislation. The results of the review and possible 

draft legislation are expected by the end of 2007 and 

should contribute to better permitting of industrial 

installations in the EU. We invite the permitting 

authorities to express their views and contribute to 

the review process either through the national IMPEL 

coordinators or within the Advisory Group set up to 

ensure close collaboration of Member States and 

other stakeholders. 

Ms. Marianne Wenning 


Av. de Beaulieu, 5. 02/166, Brussels, Belgium 

Telephone: +32 2 295 59 43 

Fax: +32 2 298 88 68 

marianne.wenning@ec.europa.eu

The basis for sustainability is a balance between 

economic development, social cohesion and the 

preservation of our natural foundations of life. 

Therefore, a sustainable economic policy should 

always keep environmental policy in view, and 

vice versa. In addition to the economical use of 

resources, one of the ecological criteria for sustainable 

development should be the avoidance of risks 

unacceptable to human health and natural cycles. 

In the past, classic instruments of regulatory law such 

as permission were the main measures used in both 

Germany and other European countries in order to 

advance sustainability and integrate environmental 

objectives into economic activity. However, laying 

down environmental standards and issuing permits is 

not enough to guarantee sustainable activity. It must 

be ensured that these requirements are also complied 

with. 

Different approaches within a legal system can be 

taken to achieve this. A traditional method, and the 

one most frequently used in Germany, is control by 

the state, for instance, in the form of inspections or 

other types of monitoring. However, comprehensive 

and regular control by the state is not always 

possible, e.g., due to the lack of human or fi nancial 

resources. 

Steering instruments are a conceivable alternative 

to state control. These emphasise the responsibility 

of trade and industry itself. The current debate 

on deregulisation and reduction of bureaucracy 

stresses the advantages of trade and industry taking 

on responsibility, also, e.g., to compensate for the 

defi ciencies in state control. 


Mr. Ed Eggink (The Netherlands), Ms. Martina Froben (Germany), Mr. Flemming Joergensen (Denmark) 

Workshop 3 

“Better Inspection and Enforcement and Sustainable Development” 

Improving Inspection and Enforcement – Sustainable Development 

19 

However, these instruments are not fully suitable for 

ensuring that environmental provisions are met, and 

thus cannot be considered as a general alternative 

to state control. The success of these instruments 

always entails a degree of uncertainty. Therefore, they 

cannot be used in the fi eld of hazard aversion. Nor 

must their use mean that the state unconditionally 

hands over its responsibility to trade and industry or 

other players. If industry’s voluntary measures prove 

inadequate the state is required to intervene. In such 

a case it can and should have recourse to traditional 

instruments. Moreover, voluntary instruments 

always contain the risk that self-interest will lead 

stakeholders to lower their sights with regard to 

environmental requirements. 

Finally, a voluntary self-inspection by trade and 

industry always requires clearly specifi ed and binding 

objectives. However, this in turn also needs an 

effective control mechanism, e.g., regular reporting to 

the relevant authorities. 

A good example of a combination of the various 

methods is the European Environmental Management 

System EMAS. The voluntary application of EMAS 

not only has clear advantages for companies and 

organisations, using external reviews it can also 

guarantee that legal provisions are complied with. 

This enables the reduction of inspections and 

measurements by authorities. 

Mr. Peter Hart 

Federal Ministry for the Environment, 

Nature Conservation and Nuclear Safety 

Alexanderplatz 6, 10178 Berlin, Germany 

Telephone: +49 1888 305 2234 

Fax: +49 1888 305 3331 

peter.hart@bmu.bund.de 






Workshop 3 

“Better Inspection and Enforcement and Sustainable development” 

Being an international chemical distributor, Brenntag 

experiences a great difference in assessments of 

safety levels in different countries. There seems to be 

a need for more uniform guidelines for the inspectors 

as the differences in the required documentation 

makes a European approach very diffi cult for 

companies present in more than one country. 

A way to make the inspections better (that is, lead 

to a signifi cantly higher safety level) is to enter into 

a constructive dialogue with the companies instead 

20 

of making a lot of orders – bearing in mind that the 

inspectors of course can do this if the dialogue fails. 

In order to make this work, the inspectors must 

recognise that the companies should be seen as coworkers 

with the same interest – to avoid serious 

accidents. No company can afford – image-wise 

or fi nancially – the cost of a serious accident and 

this will encourage most companies to work openly 

with the inspectors. However, this demands that the 

inspectors have a high degree of knowledge to act as 

sparring partners to the companies. 

Mr. Flemming Jørgensen 

Brenntag Nordic 

Strandvejen 104 A, DK-2900 Hellerup, Denmark 

Telephone: + 45 4329 2762 

Fax: + 45 4329 2700 

fl emming.jorgensen@brenntag-nordic.dk


Session 3 | Workshop on Enforcement Strategies and Approaches | 28 September 2006 

Mr. Martin Quinn (United Kingdom), Mr. Franz Grassmann (Germany), 

Ms. Ana Isabel Garcia (Portugal), Ms. Tatjana Bernik (Slovenia), 

Mr. Jean Pierre Janssens (Belgium), Mr. Arthur Faber (The Netherlands) 

The Brussels Capital Region has to face typical 

urban environmental problems: we have many 

small and medium sized enterprises, which are 

integrated in the city life, and this causes many 

consequences for the management of environment. 

One of these consequences is the importance of clear 

communication to explain to these small enterprises 

the existing legislation, because they do not have 

specialists to care about environmental problems and 

they are not aware in case amendments are made in 

the environmental legislation. 

Therefore we base our Inspection philosophy on “a 

dialogue” with the enterprises, to help them going 

back into compliance and changing their habits. 

The inspection division provides technical assistance 

to encourage voluntary compliance and develops 

mutually agreeable schedules and approaches for 

achieving compliance. 



Enforcement and Sanction Strategy in Belgium 

22 

Nevertheless, a dialogue is not always strong enough 

in face of some operators acting in bad faith. That 

is the reason why a legal framework has been 

established: the ordinance of 25 March 1999 on the 

investigation, reporting, prosecuting and sanctioning 

of environmental infringements, amended by the 

ordinance of 28 June 2001. This ordinance allows 

inspectors to make Prosecution reports that will be 

submitted to the prosecutor. If the prosecutor does 

not accept the case within six months, the BIME 

may levy an administrative fi ne. However, the aim of 

the system of administrative fi nes is not to impose 

as many fi nes as possible, but rather to change 

the hearts and minds of the operators over time. 

Moreover, in light of the prosecutor’s practice of 

shelving legal proceedings involving environmental 

infringements, the operators often believe they are 

somehow safeguarded from the law. 

Mr. Jean-Pierre Janssens 

Brussels Institute for the Management of Environment 

Gulledelle 100, 1200 Woluwe-Saint-Lambert, Belgium 

Telephone: +32 2 775 7501 

Fax: +32 2 775 7505 

jpj@ibgebim.be

The work of the Dutch Inspectorate is organized 

along two lines. First of all, our Compliance 

strategy provides the criteria for choosing our 

priorities in our work. The main criteria are the 

level of compliance and the risks for safety, health, 

sustainability and social factors. The higher the 

risks and the lower the level of compliance, the 

higher the priority and vice versa. 

Secondly, the Inspectorate has recently developed 

a model for choosing the most effective approach 

in improving compliance levels. This is called 

our intervention strategy. One of the underlying 

axiom’s is that enforcement is not a goal in itself, 

but one of the means (a very important one!) 

in improving compliance. The main target is to 


Intervention Strategies in the Netherlands 

23 

infl uence behaviour of the target groups, either by 

stimulating spontaneous compliant behaviour or by 

deterring non-compliant behaviour. 

In determining the most effective approach, a 

key factor is formed by the analyses of the target 

group. By understanding the motives for compliant 

or non-compliant behaviour of the target group, 

we can better choose an intervention strategy in 

a particular case. For analysing these motives an 

instrument called “The Table of Eleven” is used. 

This presentation presents the various steps 

in determining the most effective intervention 

strategies. Furthermore, the instrument of “The 

Table of Eleven” will be demonstrated in a nutshell. 

Mr. Arthur Faber 

The Inspectorate of the Ministry of Housing, 

Spatial Planning and the Environment 

P.O. Box 16191, the Netherlands 

Telephone: +31 7033 93894 

Fax: +31 7033 91299 

arthur.faber@minvrom.nl 




Comparison of the tasks of the environmental 

administration (bring to an end of an environmental 

non-compliance situation) on one hand and the public 

prosecutor’s offi ce (punishment of an environmental 

crime) on the other hand. 

Different strategies of the environmental 

administration in Germany are outlined to reach this 

goal. Non-formal strategies such as negotiations, 



Sanction Strategy in Germany 

24 

agreements under public law, reduction concepts, 

neighbourhood dialogues, and the use of formal 

orders and means of execution. 

In general, it is a combination of some of those 

instruments of the environmental administration 

to get back to a compliance situation. This will be 

demonstrated by an example. 

Mr. Franz Grassmann 

State Offi ce for the Environment Brandenburg 

Am Baruther Tor 12, D-15806 Zossen, OT Wuensdorf, Germany 

Telephone: +49 33702 73101 

Fax: +49 33702 73107 

franz.graszmann@lua.brandenburg.de


Enforcement and Sanction Strategy in the United Kingdom 

Once an offence has been detected, the Environment 

Agency has a transparent, published policy on how 

it will decide upon the appropriate enforcement and 

prosecution action. The key elements of this will be 

described. 

The policy applies to the wide range of activities 

regulated by the Environment Agency, however 

the way in which it has been applied in practice 

25 

appears to be different in different business sectors. 

The presentation will look at this record and the 

reasons for it. We will also look at the success of the 

Environment Agency’s prosecutions in the courts and 

the effectiveness of sanctions in the UK. 

The UK government is reviewing sanctions for 

environmental offences and we will look at the 

options currently being considered. 

Mr. Martin Quinn 

Environment Agency for England and Wales 

Rio House, Waterside Drive, BS 32 4 UD, Bristol, United Kingdom 

Telephone: +44 7785 765759 

Fax: +44 1454 284301 

martin.quinn@environment-agency.gov.uk 




Ms. Anna Tiberg (Sweden) 

In 1999 a new unifi ed Environmental Code 

was adopted in Sweden. It is a compilation and 

modifi cation of 16 previous statutes. The Code 

contains a partly new system of sanctions with 

environmental penalty charges and a list of offences. 



Eexperience with a Sanction Strategy in Sweden 

26 

Shortly after its coming into force it was clear that the 

system of sanctions of the Code needed to be revised. 

The presentation will focus on the experiences from 

this revision and the ideas behind the Code and the 

revised version. 

Ms. Anna Tiberg 

Federation of Swedish Farmers 

Federation of Swedish Farmers, 105 33 Stockholm, Sweden 

Telephone: + 46 8 787 50 24 

anna.tiberg@lrf.se


Session 4 | Workshop on Contribution of the IMPEL Network to Better Legislation | 28 September 2006 

Mr. Andreas Wasielewski (Germany), Mr. Terry Shears (United Kingdom) 

The EU Commission is undertaking a review of the 

IPPC Directive of the IPPC Directive which is due to 

be completed in 2007 with the tabling of a possible 

legislative proposal. 

As part of the review the Commission let contracts to 

review certain aspects of the Directive. The contracts 

included “An assessment of options to streamline 

legislation on industrial emissions and analysis of the 

interaction between the IPPC Directive and possible 

emission trading schemes for NO x and SO 2 ” (often 

referred to as the “Regulatory Streamlining” study) 

and “Beyond regulatory compliance: Incentives to 

improve the environmental performance of IPPC 

installations” (often referred to as the “Beyond 

Regulatory Compliance” initiative). 

The Better Legislation Cluster has previously identifi ed 

a role for IMPEL to work with the Commission to 

identify, consider and prioritise those areas of the EU 

legislative work programme where IMPEL can make a 

useful contribution. 

As part of fulfi lling this role, the Better Legislation 

Cluster developed the project on the “Interrelationship 

of the IPPC Directive with other 

Directives.” It aimed to gather information from 

IMPEL members to feed into the Commission’s 



IPPC Review and Interrelationship of Directives 

28 

review of the IPPC Directive. The information is 

on areas of concern relating to the implementation 

and enforcement of the IPPC Directive arising from 

its interface with other horizontal and sectoral EU 

legislative instruments. 

The report identifi ed a number of areas of 

inconsistency and overlap between the IPPC Directive 

and other directives, in particular sectoral directives. 

Overlaps and inconsistencies between the IPPC 

Directive and other directives should be harmonised: 

where defi nitions vary between directives, there 

should be clarity as to why they are different. 

Consistency in the use of environmental standards 

would aid the interface between the IPPC Directive 

and other directives. The regulatory effort to grant 

permits for some small installations may not be 

proportional to the potential regulatory impact of 

those installations. 

The information in the report is based on the practical 

implementation of the IPPC Directive in installations. 

It provides feedback on areas where the wording 

of the IPPC Directive has an impact on the day-today 

administration of the permitting regime. The 

feedback also refers to structural changes that 

continuously take place within industry and impact on 

the permitting regime. 

Mr. Terry Shears 

Environment Agency 

Rio House, Waterside Drive, Aztec West, Almondsbury, 

Bristol BS32 4UD, United Kingdom 

Telephone: +44 1454 205743 

Fax:+44 1454 205533 

terence.shears@environment-agency.gov.uk


In the Flemish region of Belgium, the compilation of 

a RIA (regulation impact analysis) is obligatory (since 

1 January 2005) for all new legislation with an effect 

on citizens, companies and non-profi t organisations. 

The starting point for this RIA is the defi nition of 

good legislation: good legislation is (1) necessary and 

effective, (2) effi cient and balanced, (3) practicable 

and enforceable, (4) lawfully, (5) coherent, (6) 

simple, clear and accessible, (7) grounded and 

negotiated, and (8) remaining relevant and actual. 

The most important aspect for the environmental 

inspector is practicability and enforceability. They are 

enhanced by the following aspects: 

a) good rules: 

• clear and simple structure and terminology (good 

defi nitions); 

• technically practicable (for example, detection/ 

analyses equipment is available); 

• good technical standards (for example, emission 

limit values); 

• economically achievable (BATNEEC); 

• coherent (no overlap/no contradictions throughout 

legislation); 

• proportional (rules in proportion with the risks and 

the impact on people and environment); 

• realistic and workable; good balance between costs 

and benefi ts. 

29 

Mr. Paul Bernaert (Belgium), 

Ms. Eva Kruzikova (Czech Republic) 

Inspector’s View on Better Legislation 

b) good enforcement instruments, provided in the 

legislation: 

• to prevent or to stop non-compliances; 

• to undo the consequences of non-compliances; 

• to promote the compliance after a situation of noncompliance; 

• to punish non-compliances. 

These instruments have to be clear, simple to use and 

coherent. The inspector has to have the possibility 

to apply them proportional to the detected noncompliance. 

c) external circumstances: 

• acceptance of the legislation by the stakeholders 

(operators, owners etc.); 

• grounded and negotiated legislation; 

• regular evaluation and revision (by simple 

procedures): the environmental inspectors have to 

give feedback from their experiences in the fi eld. 

From the environmental inspector’s point of view 

good legislation means maximum compliance with 

minimum enforcement effort. 

Mr. Paul Bernaert 

Environmental Inspectorate Division 

Koning Albert II-laan 20 bus 8, 1000 Brussels, Belgium 

Telephone: +32 2 553 81 97 

Fax:+32 2 553 80 85 

paul.bernaert@lin.vlaanderen.be 




The presentation will give an overview of the issues 

addressed in the IMPEL Project “Developing a 

checklist for assessing legislation on practicability 

and enforceability”, that is currently run by the 

Inspectorate of the Netherlands Ministry of Housing, 

Spatial Planning and the Environment (VROM). This 

project aims at producing a checklist to help identify 

aspects of legislation that hinder practicability and 

enforceability. 

The checklist aspects of practicability will be 

addressed both from the perspective of the competent 

authorities and from that of the regulated target 

group. Practicability relates to the suitability of the 

legislation for the purpose of its practical application 

by competent authorities in Member States, taking 

into account such questions as the need for individual 

administrative decisions and the infrastructure and 

resources that are necessary in order to enable 

competent authorities to perform all their duties under 

EC law. 



Practicability and Enforceability of Legislation 

30 

Practicability also concerns the ability of the 

addressees of the obligations to clearly identify and 

understand their obligations and to comply with 

them. 

Enforceability is an issue that is of primary concern 

to public authorities, as it refers to the suitability of 

the legislation in terms of their ability to use the legal 

and administrative means at their disposal to check 

compliance and encourage or, in the event of wilful 

non-compliance, compel individual addressees to 

comply with their obligations. 

The checklist will be applied by IMPEL when it 

comments on EU Environmental legislation. The 

checklist or parts of it may also be used by the EU 

(the Commission, the Parliament and the Council) 

and national law making institutions when drafting 

legislation. 

The presentation will both address the content of the 

checklist and the question who and when should use 

the checklist. 

Mr. Jan Teekens 

The Inspectorate of the Netherlands Ministry of Housing, 

Spatial Planning and the Environment 

IPC 530, P.O. Box 16191 Den Haag, the Netherlands 

Telephone: +31 703393777 

Fax: +31 703391299 

jan.teekens@minvrom.nl


IMPEL has set up a Cluster to ensure that existing 

and proposed European Legislation is consistent with 

the principles of Better Legislation derived from the 

IMPEL report on Better Legislation project and is 

practicable and enforceable by contributing to the EU 

Law making process. 

From the Commission’s point of view, the potential 

role of the Cluster should be seen in the context of the 

life cycle approach to regulation, of which obtaining 

an appropriate feedback on the implementation of 

rules forms an integral part. 

31 

Mr. Charles Pirotte (European Commission), 

Mr. Jan Teekens (The Netherlands), 

Ms. Karen Riddick (United Kingdom) 

Commission’s Point of View on the Role of IMPEL for Better Legislation 

In that context, issues such as the types and content 

of the feedback that the IMPEL Cluster could provide 

are considered, taking into account the specifi c 

characteristics of IMPEL membership. The particular 

expertise of IMPEL members and the possibility of 

obtaining feedback from a wide range of jurisdictions 

constitute relevant factors to be borne in mind in that 

respect. 

It is also suggested that a distinction should be made 

between expert advice and a more policy-oriented 

approach, the latter of which properly belongs to the 

competent institutions of Member States and the 

Community. 

Mr. Charles Pirotte 


BU-5 6/153, B-1049, Brussels, Belgium 

Telephone: +32 2 299 23 47 

Fax: +32 2 299 20 68 

charles.pirotte@ec.europa.eu 




Mr. Indulis Emsis (Latvia) 

Latvia started to develop its environmental legislation 

in the early 90s after the restoration of Latvia’s 

independence. Considerable revision of Latvia’s 

environmental legislation was performed between 

1999 and 2003 while the country was preparing for 

joining the EU. It was a very diffi cult task because we 

had to transpose the requirements of EU directives 

adopted in different time periods and at the same 

time we had to take into account the specifi c needs 

and developments in Latvia. For example, economic 

instruments based on the Law on Natural Resources 

Tax were in place in Latvia even before similar 

instruments were adopted in many other European 

countries. 

In Latvia we attempted to consolidate different EU 

and national requirements in a few legal acts. One 

of the basic political tasks was to achieve gradual 

consolidation of separate environmental permits 

(air, water, waste) into one integrated permit as 

required by the IPPC Directive. All requirements on 

environmental permits were included in 2 legal acts 

– the Law on Pollution (adopted in 2001) and the 

Regulations regarding Permit (License) Requirements 

issued by the Cabinet of Ministers. 

The best available techniques reference documents 

(BREFs) are important guideline documents, and I 

think it is very important that these documents be 

fully translated into all Community languages. 



Reaction of Politicians 

32 

One of the problems was that sometimes too much red 

tape was involved in issuing permits (licenses). So we 

consulted industrial associations and NGOs and received 

many helpful proposals for simplifying the legislation. 

The legislation was revised but there is still need for 

more simplifi cations that in no way will compromise the 

basic aim of the legislation. One of our future tasks is 

to consolidate the results of public hearings regarding 

environmental and building legislation. 

Some EU legislation also needs to be streamlined. 

Maybe there are ways to better coordinate EIPPCB 

and EIA procedures. Both from environmental 

protection and environmental administration point 

of view it could be a positive step if it were possible 

to have a single permit for polluting activities and 

greenhouse gas emissions. With regard to the new 

EU environmental legislation I think there are some 

problems related to cost effectiveness. Too much 

emphasis in put on monitoring issues, and there 

are too many requirements for action plans. If there 

are too many action plans it might be diffi cult to 

supervise their implementation. I fi nd very interesting 

the suggestion regarding emission allowance trading 

schemes on SO2 and NOx; however, administrative 

costs especially for smaller countries with not so many 

installations should be considered. 

Better legislation and better enforcement are 

principles that should be taken into account both on 

the EU and the national level. 

Mr. Indulis Emsis (Member of Parliament) 

Saeima of the Republic of Latvia 

Jēkaba iela 11, Riga, LV-1811, Latvia 

Telephone: +371 7087251 

Fax: +371 7087251 

indulis.emsis@saeima.lv


Session 5 | Workshop on Permitting | 28 September 2006 

Mr. Sami Koivula (Finland), Mr.Frank Clinton (Ireland), Ms. Barbara Pucker (Austria), 

Mr. Didier Pitrat (France), Mr. Per Christensen (Denmark) 

Overall View of the European Developments on Permitting for the Next Coming Years 

In November 2005 the European Commission 

launched a process to review the IPPC Directive and 

other related industrial emissions legislation. The 

main objective is to improve the current framework 

with the view to Better Regulation while ensuring the 

same level of environmental protection. The main 

developments being assessed as regards permitting 

are the following: 

1. Streamlining of the existing legislation: a number 

of legislation related to the permitting of industrial 

installations (in particular the IPPC, Large 

Combustion Plants (LCP), Waste Incineration 

(WI) and Solvents Emissions Directives) have 

been prepared, adopted and implemented at 

different time. The Commission has launched 

a study to assess in particular the possible 

practical permitting diffi culties, which might 

arise from the interaction between these parts of 

legislation. This assessment relates for instance 

to the differences in the scope of these Directives 

(e.g., different scope in IPPC and WI Directives 

as regards incineration installations), in some 

defi nitions (e.g., “combustion installation” in 

IPPC and “combustion plant” in LCP) and in 

the permit conditions (sectoral Directives setting 

minimum standards, IPPC permit conditions 

based on BAT). The key question is whether these 

differences lead to practical permitting diffi culties 

and whether these parts of legislation need to be 

streamlined in order to ensure better permitting 

by competent authorities. This on-going study is 

based on a literature survey, the analysis of the 

legal interactions, the assessment of specifi c case 

studies as well as the impact assessment of several 

scenarios to address the issues identifi ed. 



34 

2. Improving the IPPC Directive as regards 

permitting: a lot of experiences with different 

permitting systems have been gained during the 

implementation of the Directive and can help 

to identify possible improvements in the legal 

framework. In this context, the Commission is 

carrying out a study to gather information and data 

on possible amendments. As regards permitting, 

options are being evaluated, for instance, as 

regards the review of permit conditions (how to 

clarify the obligation to regularly review IPPC 

permits), the use of the BREFs (how to improve 

the Sevilla process, as well as the way the BREFs 

are taken into account in setting permit conditions) 

and the inspection of installations (whether the 

IPPC Directive should be more precise as regards 

inspection requirements). 

3. The results of the review and possible legislative 

proposals are expected by the end of 2007. 

It is therefore a key and strategic moment for 

permitting authorities to express their views, 

provide information and data in order to inform this 

process. Do not miss the opportunity to contribute 

to the preparation of an improved permitting 

framework of industrial installations in the EU. 

For more information and contribution as regards 

the various studies being carried out, see http:// 

forum.europa.eu.int/Public/irc/env/ippc_rev/library. 

Mr. Alexandre Paquot 


Av. de Beaulieu, 5. 02/112, Brussels, Belgium 

Telephone: +32 2 299 61 30 

Fax: +32 2 298 88 68 

alexandre.paquot@ec.europa.eu

According to Finnish legislation environmental permit 

consideration and the setting of permit conditions is 

done case by case by permit authorities. Stakeholders 

has broad right to participate to process, that includes 

opportunity to give their opinions of the permit 

application and a right to appeal. These elements 

are commonly seen as a strength in permitting 

process. In order to preserve these elements in 

the future it means that the Finnish environmental 

permit administration and permit procedures must be 

enhanced. 

35 


Introduction of the Best Practice on Quality Approach 

Necessary improvements are expected to be done by 

streamlining permitting procedures and by utilizing 

new IT-solutions. One of the key features of planned 

solutions is common working space for permit writers, 

applicants, supervisory authorities etc., where permit 

application is written and processed as structured 

text fi le. This working space contains, e.g., guidance 

material, common “good” permit conditions and it is 

a place for interaction between different parties. By 

using this tool it is possible to achieve better quality 

of permits, shorter permit writing times and proper 

use of the resources. 

Mr. Sami Koivula 

Northern Finland Environment Permit Authority 

Isokatu 14, 90101 Oulu, Finland 

Telephone: +358 40 525 6778 

Fax: +358 20 490 6499 

sami.koivula@environment.fi 




Rigorous environmental enforcement is based 

on the principle of equity, a principle essential 

to ensure the effi ciency and credibility of any 

environmental enforcement entities. Indeed, exotic 

or lax environmental enforcement actions on a local 

level may lead to the concentration of many sensitive 

environmental activities on a specifi c territory, 

whilst neighbouring territories may suffer signifi cant 

economic disadvantages deriving from this situation. 

Besides, in France environmental enforcement 

actions are more than ever challenged by industrial 

operators in front of courts. Such challenges are 

often a legal, convenient and effi cient way of freezing 

- for undefi ned periods - the enforcement of offi cial 

regulation acts confl icting the interest of some 

“environmentally dishonest” operators. 

Therefore, standardizing forms and contents of offi cial 

regulation acts have become a necessity and a priority 



Introduction of the Best Practice on Standardization Approach 

36 

to guarantee consistent, effective and coordinated 

enforcement actions everywhere on the national 

territory. To reach this goal, the French Ministry of 

Environment has initiated several programs within the 

framework of the “Inspection Modernization Plan”. 

In addition to these national programs, independent 

regional and local initiatives have been undertaken to 

amplify the results of such programmes. 

This presentation, based on a local fi eld inspector’s 

experience, will give an overview of the methods 

and tools currently used by French local enforcement 

entities to ensure a better standardization of its 

acts. After introducing national programs such as 

the “inspector certifi cation program” or the “generic 

specifi cations software” (DDAE), this presentation 

will especially focus on some initiatives aimed at 

increasing the sharing of regulation knowledge and 

good practices between the French local enforcement 

entities. 

Mr. Didier Pitrat 

DRIRE Ile de France 

Ministère de l’Ecologie et du Développement Durable 

GS 95 – 203, Les Chênes Bruns, 95 000 Cergy, France 

Telephone: +33 1 34 41 58 71 

Fax: +33 1 34 41 58 60 

didier.pitrat@industrie.gouv.fr

Demands from the Public to the Permitting Process 

IPPC has been a tremendous success seen from the 

view of the public. Contrary to many older permitting 

systems it has delivered good results, mainly: 

1) because it provided better access to information 

(also on the application); 

2) because it demands the permitting authority to 

describe its “reason and considerations” on which 

the decision is based; 

3) because of the integrative approach; 

4) because of the underlining of BAT. 

Today there is reason to believe that this permit 

in many respects does not deliver enough and 

relevant information. The reason behind this is 

mainly that the traditional permit vis-à-vis many new 

environmental policies and new issues on the top of 

the agenda stands out as delivering only half of the 

information relevant to decide on the appropriateness 

37 


of the activities of a company. These challenges 

encompass the “competing” EIA system, new trends 

in environmental policies where – besides climate 

change – biodiversity and the water framework 

directive also stands out as pivotal. Furthermore 

the developments within “self-regulatory” measures 

like reporting, environmental management system 

and green labels also underlines that much the 

information disclosed in the permitting process is not 

the most relevant for the public at large 

These tendencies question not only the way 

permits are made and functions but also the role 

of inspection. Does inspection – besides checking 

the compliance of the fi rm – lead to better results 

that eventually would improve performance of the 

company? And does it deliver information valuable for 

the public? 

Mr. Per Christensen 

Aalborg University 

Fibigerstraede 13, 9220 Aalborg OE, Denmark 

Telephone: +45 96 35 83 26 

Fax: +45 98 15 37 88 

pc@plan.aau.dk 




Session 6 | Workshop on Recently Finished IMPEL Reports and New Field of Work | 28 September 2006 

The presentation starts with a background to the 

IMPEL Review Initiative (“A voluntary scheme for 

reporting and offering advice on inspectorates and 

inspection procedures”) mentioning the basis given 

by RMCEI as well as IRI reviews in other countries. 

The methodology of IRI reviews is presented shortly 

being illustrated by the Swedish IRI study. The 

review took place at the County Administrative 

Board of Stockholm and the Environment and Public 

Health Committee of the Municipal of Södertälje, 

Sweden, on 7-11 March 2005. The outcome of the 

Swedish IRI review is presented by some “Examples 

of Good Practices” and “Examples of Opportunities 

for Development” highlighted by the review team. 

Dissemination of information concerning the IRI 

review has been made by press releases, articles 

and presentations at conferences etc. in Sweden. 

The IRI review has been and is followed up at the 

39 

Mr. Gernot Schnabl (European Commission), 

Ms. Inga Birgitta Larsson (Sweden) 

IMPEL Review Initiative (IRI) in Sweden 

studied authorities. Also, other authorities take use 

of the experiences gained by the IRI review. The 

outcome has been used for OECD follow up, for the 

review of the Environmental Code and as information 

to government and central authorities. A workshop 

focusing on the exchange of experiences from the IRI 

review was arranged for inspecting, enforcement and 

permitting authorities in Sweden. A pilot project is 

now being planned to develop a model based on the 

IRI concept to be used by sister authorities on local 

level. The presentation is fi nalised by encouraging 

more countries to take on IRI reviews and by 

mentioning some further follow up that might be of 

interest within IMPEL. 

The report “IMPEL Review Initiative (IRI) Sweden” 

(Dec. 2005) is available at the IMPEL website http: 

//ec.europa.eu/environment/impel/reports. 

Ms. Inga Birgitta Larsson 

Swedish Environmental Protection Agency 

SE-10648 Stockholm, Sweden 

Telephone: +46 8 698 11 42 

ingabirgitta.larsson@naturvardsverket.se 




Mr. Riccardo Quaggiato (Italy) 

INSPECTAN is a project approved and fi nanced 

by the European net IMPEL (Implementation and 

Enforcement of Environmental Law), an informal 

network created by the European Union to 

stimulate the exchange of experiences between the 

Environmental Authorities of the countries. Italy, who 

is represented in IMPEL by the national Agency APAT, 

has been designated as a lead country of the project, 

and other 7 countries participating are: France, 

Germany, Latvia, Spain, Poland, Sweden and Austria; 

APAT has asked ARPAV and HARP Tuscany to 

participate in the project and, particularly, our Agency 

to undertake the technical role of a leader. 

The project INSPECTAN is placed in the vein of 

initiatives where Italian Environmental Agencies 

are carrying out the turn from the “commandcontrol” 

system to the integrated approach of the 

environmental controls aiming at the caution on the 

areas and results, which are especially relevant for 

the environment. 



INSPECTAN Project 

40 

The objective of the project is to create a common 

base of knowledge, at the European level, on the 

present situation of the tanning sector both as regards 

productive and technological aspects and permits 

release and control activities. Such base will be 

necessary to defi ne the start and the formal procedure 

for the execution of the environmental inspections 

integrated in the tanning plants, shared between all of 

the countries participating in the net IMPEL. 

Projects have been developed by a questionnaire 

on technological aspects, environmental impacts 

and permits and control activities; each participant 

country has answered the questions, the result is a 

report that describes the tanning production sector 

from the economic, environmental and legislative 

point of view in 7 countries with an important 

presence of tanning industries. 

The second part of the project has developed a 

guideline that provides some brief suggestions on how 

to perform an environmental inspection in tanneries, 

based on the IMPEL guidelines and the integrated 

pollution prevention and control methods. 

Mr. Riccardo Quaggiato 

Regional Environmental Agency of Veneto 

Piazzale Stazione 1, 35131 Padova, Italy 

Telephone: +390 4987 67604 

Fax: +390 4987 67670 

rquaggiato@arpa.veneto.it


Informal Resolution of Environmental Confl icts by Neighbourhood Dialogue 

30 representatives of 17 IMPEL Member States 

participated in the project “Informal resolution of 

environmental confl icts by neighbourhood dialogue”. 

Two conferences were held in November 2004 

and May/June 2005 in Hannover, Germany. The 

focus of the project was on the existing sites with 

neighbourhood complaints where a dialogue process 

was used as a voluntary instrument to try and resolve 

the confl ict. 

Neighbourhood complaints and confl icts often occur 

near sites such as industrial production facilities, 

waste management sites and quarries because of 

their emissions or potential dangers including health 

risks. Sites built near inhabited areas or that have 

become surrounded by residential areas are especially 

affected. Confl icts can focus on concerns about 

odours, noise, air pollution, accidents, operation 

disorders or new permit conditions and procedures. 

41 

The participants of the project discussed several case 

studies and exchanged their experiences of using 

various dialogue approaches. The discussions covered 

application fi elds, essential framework conditions, 

chances, best-practice proceedings, advantages, 

risks, limits and involvement of authorities. 

The participants of the project recommend support for 

further application of dialogue processes as voluntary 

instruments in the implementation and enforcement 

of environmental law. 

A qualifi ed strategy of neighbourhood communication 

is a useful method towards an agreed identifi cation 

of problems and priorities and the development of 

realistic solutions. 

Mr. Lars Bobzien 

Department of Labour and Environmental Inspection 

(Staatliches Gewerbeaufsichtsamt) 

Listholze 74, 30177 Hannover, Germany 

Telephone: +390 4987 67604 

Fax: +390 4987 67670 

lars.bobzien@gaa-h.niedersachsen.de 




Representatives of 23 European countries, the 

European Commission and the IMPEL Secretariat 

participated in a workshop, which was held on 26 

– 28 April 2006 in the Netherlands. This IMPEL 

Comparison Programme workshop addressed 

the ways in which inspecting authorities set their 

priorities. The draft report will be discussed in 

the IMPEL cluster I meeting in September and 

after approval by the IMPEL Plenary in Helsinki in 

December brought to the attention of all interested 

parties, including the European Commission. 

Inspecting authorities constantly have to choose 

between options and have to make choices in 

planning and execution of their inspection tasks. This 

happens both on the strategic and organisational 

level, as well as on the operational and individual 

level. In fact they try to do the right things. Over the 

years it became clear that there is a lot of interest to 

discuss the different ways of priority setting and to 

exchange experiences in this fi eld. Moreover, countries 

have to implement the Recommendation, providing 

for minimum criteria for environmental inspections 

in Member States (2001/331/EC) (RMCEI). Priority 

setting by making inspection plans and inspection 

programmes is a key element of the RMCEI. 

In preparation for the workshop, a questionnaire was 

completed by representatives of inspecting authorities 

on national, regional or local levels of 24 European 

countries. The questionnaire covered the key elements 

on prioritising environmental inspections as described 

in the RMCEI. 

Three elements were found to be of special interest: 

- parameters/indicators that infl uence priority setting, 

including their weights; 



Doing the Right Things 

42 

- specifi cation of “environmental impact” and “-risks”; 

- process, organisation, monitoring and evaluation of 

inspection plans and programmes. 

At the workshop three examples of national practices 

(Poland, the Bask country and the Netherlands) 

were presented with regard to priority setting 

and participants discussed personal ideas and 

experiences. The key fi ndings of the workshop were: 

- comparison of differences gave insight into national 

circumstances and settings; 

- priority setting has to take place within a specifi c 

national context and it depends on many factors, 

such as administrative structures, legal and cultural 

aspects, the organisation of tasks and competences 

of organisations involved, as well as human 

capacity, budget and qualifi ed personnel; 

- the difference between inspection plans and 

inspection programmes, as described in the 

RMCEI, is not that easy to make in practice; 

many conclusions and recommendations given are 

applicable for both; 

- future activities are needed to improve the further 

practical implementation of the RMCEI, and to 

advance the quality of existing inspection plans and 

programmes. 

The RMCEI is being reviewed during the execution 

of this project. The Commission intends to adopt its 

communication on the review of the Recommendation 

in Autumn 2006. Therefore the output of this project 

could serve as an important contribution to the review 

of the RMCEI in relation to inspection plans and 

programmes. 

Mr. Wike Niessen 

Inspectorate of the Ministry of Housing, Spatial Planning and 

the Environment, the Netherlands Kennedy Business Center 

P.O. Box 850, 5600 AW Eindhoven, the Netherlands 

Telephone: +31 40 2652911 

Fax: +31 40 2653030 

wike.niessen@minvrom.nl


The EU Emissions Trading Scheme (EU ETS) was 

established in 2003 by Directive 2003/87/EC and 

is the largest emissions trading scheme in the world. 

Harmonisation of its implementation across the EU 

25 is a key element in order to strengthen both its 

credibility and its role in the market. 

Competent authorities have now had over 12 months 

experience of regulating operators and installations 

that are required to participate in the scheme. An 

IMPEL project in 2004/05 reviewed regulatory 

practice in relation to the EU ETS and made a 

number of recommendations for short-term action, 

which have been taken forward by an informal 

“IMPEL EU ETS Support Group” which was formed 

as a result of this project. In addition, the report 

concluded that for some regulatory tasks there had 

not been enough experience (at that time) to identify 

examples of good regulatory practice. 

The objective of this current project was therefore 

to build on the previous work by reviewing in more 

detail those regulatory tasks, which were not covered 

in detail in the fi rst project, but with which there has 

also been a signifi cant amount of new experience 

over the fi rst year of operation of the scheme. These 

included monitoring and reporting, verifi cation, 

compliance and enforcement and small installations. 

The project aims to produce the following outputs: 

43 

Ms. Lesley Ormerod (United Kingdom), 

Mr. Wike Niessen (The Netherlands), Mr. Steen Fogde 

(Denmark), Mr. Gernot Schnabl (European Commission) 

Options and Proposals for Consistency in the Implementation of the 

EU Emissions Trading Scheme 

i) summary report of the fi rst year of operation of 

the scheme; 

ii) good practice guides for the regulatory aspects 

reviewed; 

iii) tools/templates which can be used by Member 

States where possible. 

The results of the project will be useful not 

only to Competent Authorities responsible for 

implementation of the EU ETS, but also to newer 

Member States joining the scheme, and to the 

European Commission in its evaluation of the fi rst 

year of operation of the scheme. 

The fi rst project workshop took place is 

Budapest, Hungary in April 2006, with 23 

representatives from 14 Member States 

attending. The bulk of the workshop involved 

developing a questionnaire, which the project 

participants are in the process of completing, 

to gather information needed to compile the 

summary report and good practice guides, and 

also examples of tools and templates which are 

in use by the project participants. 

A second workshop is planned for September 

2006 to review the responses to the 

questionnaires and agree the output reports and 

guidance. 

Ms. Lesley Ormerod 

Environment Agency 

Richard Fairclough House, Knutsford Raod 

Warrington, WA4 1HG, United Kingdom 

Telephone: +44 1925 542046 

Fax: +44 1925 542771 

lesley.ormerod@environment-agency.gov.uk 




Waters in each Member State are under increasing 

pressure from the continuous growth in demand 

for suffi cient quantities of good quality water for all 

purposes. The response for this pressure is to prevent 

further deterioration, protect and enhance the status 

of aquatic ecosystems. Many pieces of legislation 

are dealing with water issues, besides others, two 

directives – Council Directive 96/61/EC “concerning 

integrated prevention and control” (IPPC) and 

Directive 2000/60/EC on “establishing a framework 

for Community action in the fi eld of water policy” 

(WFD) - are the most important sources for the 

competent authorities. 

The relation of the two main directives is clear: 

sustainable use and protection of waters are legally 

controlled by the WFD and emissions to these waters 

are regulated by the IPPC. 

With regard to pollution prevention and control, 

Community level and national water policy should be 

based on a combined approach: 

- emission controls using best available techniques 

(BAT); 

- relevant emission limit values (ELV); 

- best environmental practices in the case of diffuse 

impacts (BEP). 

It is important to prioritize among the pollutants - 

pollutants in general, priority pollutants and priority 

dangerous pollutants - and also to distinguish between 

“direct” or “indirect” discharges to the aquatic 

environment. 

With regard to indirect releases into water, the effect 

of a water treatment plant may be taken into account; 

on a case by case basis, treatment of wastewaters 

on site as part of the IPPC installation – as a directly 

associated activity – may provide the best level of 

environment protection. The emission limit values for 

substances shall normally apply at the point where 

the emission leaves the installation, any dilution being 

disregarded when determining them. In the practice 

you should take into consideration of the impact of 

other sewage, or the sewerage system and the sewage 



IPPC Related Water Issues in the Netherlands and Hungary 

Mr. Jan Leentvaar 

Water Management Inspectorate 

Noorderwagenplein 6, Lelystad, the Netherlands 

Telephone: +31 320299507 

Fax: +31 320299501 

jan.leentvaar@ivw.nl 

44 

treatment facilities before discharge them to the fi nal 

aquatic environment. It is also important to defi ne the 

point where ELV should be checked for compliance. 

The programme of measures to be taken shall 

include “basic measures” and where necessary 

“supplementary measures”. 

“Basic measures” covering emission control are as 

follows: 

- the prohibition and/or reduction of entry of pollutants 

into waters; 

- applying combined approach; 

- the control of pollution at the source; 

- using prior authorization or registration based on 

general binding rules; 

- the prevention of accidents and limit their 

consequences. 

These are the main principles and the basis how the 

competent authorities in both countries issue the 

IPPC permits, perform the compliance monitoring and 

enforce the permit holders for better compliance. 

Investigations of the Netherlands Water Management 

Inspectorate in 2005 showed a substantial backlog 

by authorities concerned in updating and amending 

permits for IPPC installations. The Inspectorate 

therefore published a practical guideline and 

an inspection framework, specifying minimum 

requirements for permitting authorities and for 

individual permits. After summer a new investigation 

will take place on the current situation. Results will be 

used for increasing the pace of activities of relevant 

authorities. 

In Hungary the Inspectorates for Environment, Nature 

and Water issue the IPPC permits and all type of 

water permits for discharge emissions to waters. By 

this time the competent authority issued 590 IPPC 

permits and altogether 20 guidances were also issued 

to help in their work (9 national BAT-guidances and 

11 BREF summaries). The present number of IPPC 

installations in Hungary is 1093. 

Mr. Pal Varga 

National Inspectorate for Environment, Nature and Water 

Meszaros 58, Budapest, Hungary 

Telephone: +36 1 2249210 

Fax: +36 1 2249274 

vargap@mail.kvvm.hu


Session 7 | Workshop on Networking | 28 September 2006 

Mr. Peter Wessman (European Commission), Ms. Valerie Doyle (Ireland), 

Ms. Alessandra Burali (Italy), Mr. Markku Hietamaki (Finland), 


The Czech Republic has been a member of IMPEL 

since 2003, before we had participated in AC-IMPEL 

network. 

The Czech national IMPEL network was established 

in May 2005 under the umbrella of twinning project 

CZ 34.04.01 “Integrated and planned enforcement of 

environmental law”. 

The reason why we established this kind of network 

was mainly due to problems with the dissemination 

of IMPEL information from the Inspectorate to 

other bodies. We had also problems fi nding good 

people to participate in the IMPEL projects from 

other institutions. We had to solve this problem as 

soon as possible because the Czech Environmental 

Inspectorate is only responsible for control and 

enforcement, not for implementation of EU law 

or permitting. The Ministry of the Environment, 

the Ministry of Agriculture, regional authorities, 

municipalities, the Police, the Fire Brigade, the 

Czech Trade Inspectorate, the Occupational Safety 

Inspectorate and many other authorities are involved 

in the network. 

Head of the network is the Czech Environmental 

Inspectorate – IMPEL national coordinator who is 



Czech National IMPEL Network 

46 

responsible for the dissemination of IMPEL products 

and information. The national IMPEL coordinator 

is also responsible for maintaining the website. We 

translate annotations of all IMPEL projects, some 

IMPEL reports and all conclusions from IMPEL 

plenary meetings into the Czech language and inform 

all participants when we add new information on the 

website. We hold meetings twice a year before IMPEL 

plenary meeting and the nominated contact persons 

from all regional inspectorates are responsible for 

communication with people from the authorities in 

their region. These representatives work closely with 

the national co-ordinator and participate in the IMPEL 

meetings. 

One big advantage of the network is that this network 

is informal, so people can participate voluntarily. 

Other benefi ts of the network activity include better 

communication and especially better dissemination 

of information between institutions and ministries at 

national and regional level. 

The Czech Republic has a national “IMPEL Directory 

of Contacts”, where the national co-ordinator, but also 

other Czech representatives and all contact people in 

the ministries and other authorities are listed. 

Ms. Lenka Němcová 

Czech Environmental Inspectorate 

Břehu 267, 190 00 Prague 9, the Czech Republic 

Telephone: +420 222 860 283 

Fax: +420 283 892 662 

nemcova@cizp.cz

Networking has a long tradition in Germany. 

Germany is a federal republic consisting of 16 states 

(Bundesländer). The federal and the state parliaments 

have different competencies in environmental 

legislation. The federal parliament transfers European 

regulations into German law and depending on the 

individual matter, additional laws on state level are 

needed. The enforcement (permitting, supervision 

etc.) of national environmental law is the task of the 

states. 

Due to the fact that Germany is a federal republic, 

there has always been the need for close cooperation 

and intense coordination in the work on and between 

federal and state level. This cooperation between 

the federal Ministries and the administration on 

state level is organised in networks. The organisation 

of the cooperation of the Federal Ministry for the 

Environment, Nature Conservation and Nuclear Safety 

with the state administrations will be explained. 

Elements: German Conference of Environment 

Ministers, 8 advisory boards (working groups), 

subcommittees. 

Objectives: prepare good and enforceable laws, make 

decisions that take into account all concerns, discuss 

problems, work out common guidelines for the 

practitioners, guarantee equal treatment throughout 

Germany, technology is always changing/developing 

� determine the best available technology. 

German National Network 

47 


Ms. Gisela Holzgraefe (Germany) 

2. Networking on state level and networking of the 

practitioners: 

The states have organised their own networks. A 

variety of different forms have been developed, e.g., 

cooperation of inspectors in one state; several states 

organise their exchange of experiences together; 

further training offered to all who are concerned. 

Expert groups with members from all states, e.g., 

in the fi eld of plant safety have been established. 

Examples will explain this. 

Objectives: fi nd out the best way to enforce 

environmental legislation, produce a common 

understanding of things guarantee equal treatment 

throughout Germany, support persons working in the 

environmental administration (e.g., permit writers 

and inspectors) to do the right things, make good and 

not vulnerable decisions, to avoid mistakes, to share 

experiences, to bring things ahead within an appropriate 

time, to have short licensing procedures of good quality, 

to disseminate important results, to develop best practice. 

3. Networking via internet 

Ministries, authorities and environmental institutions 

have access to the Internet. 

The German Environmental Information Network 

was established on the basis of close cooperation 

between federal and state experts. It provides recent 

environmental news, new monitoring results, general 

information on environmental problems, information 

on workshops, events and activities. In addition there 

is, e.g., the UDK, a database of all institutions, which 

work in the fi eld of environmental protection. 

Objectives: dissemination of information. 

Ms. Gisela Holzgraefe 

Staatliches Umweltamt Itzehoe 

Breitenburger Straße 25, 25524 Itzehoe, Germany 

Telephone: +49 4821 662100 

Fax: +49 4821 662877 

gisela.holzgraefe@stua-iz.landsh.de 




The Environmental Protection Agency (EPA) coordinates 

a national Environmental Enforcement 

Network (EEN) which harnesses the collective 

resources, expertise and investigative capacity 

of all public sector agencies and government 

departments to bring about real change in the way 

that environmental crime is tackled in Ireland. The 

network is well established with over 950 staff 

from over fi fty agencies. The network is managed 

via a steering committee with representatives from 

the EPA, the local authorities, the Department of 

Environment, Heritage and Local Government, the 

Health Services Executive and the Central Fisheries 

Board. The work of the EEN is continuing to raise 

the awareness of environmental issues, reduce the 

level of illegal activity and implement a consistent 

approach to enforcement where illegal activities 

are detected. There are currently 12 main work 

areas in the Network, which are grouped under the 

themes Waste, Water, Management and Producer 

Responsibility. 

During 2006 the EEN held two major National 

Conferences on waste, and water respectively. Over 

60 enforcement network events will be hosted this 

year. 

Achievements in 2006 include: 

- further reductions in the illegal traffi cking of waste 

from the Republic of Ireland to Northern Ireland and 

to Europe through enhanced co-ordination with An 

Garda Siochana 

- consolidation of the regional approach to tackling 

unauthorised wastes activities and implementation 



Irish National Environmental Enforcement Network 

48 

of a co-coordinated action plan; 

- improved inspections through the development and 

delivery of a specialised environmental inspection 

skills training course; 

- increased co-ordination of water enforcement 

activities through exchange of information at the 

National Water Conference and the implementation 

of catchment specifi c actions plans; 

- the establishment of Enforcement Management 

Group to developed and implement management 

systems for dealing with inspections and 

environmental complaints in a consistent manner. 

This includes the implementation and reporting 

on the Recommendation on Minimum Criteria for 

Environmental Inspections. 

The key priorities for the future include: 

- reductions in Flytipping and back yard burning 

- improved water quality and maintenance of good 

water quality status sites; 

- improved quality of inspections; 

- implementation of the national environmental 

complaints procedure to improve closure of 

environmental complaints. 

This will be achieved through: 

- the use of better management systems; 

- the implementation of regional and local 

inspection plans; 

- the continual delivery of specialised training; 

- the further development and implementation of 

guidance; 

- the exchange of information through networks and 

working groups. 

Ms. Valerie Doyle 

Environmental Protection Agency 

P.O. Box 3000, Johnstown Castle Estate, Wexford, Ireland 

Telephone: +353 53 9160600 

Fax: +353 53 9160699 

v.doyle@epa.ie

A new waste shipment regulation was adopted on 14 

June 2006 by the Council and the Parliament. It will 

become applicable in one year’s time. 

The new regulation includes important developments 

in terms of improved enforcement and strengthened 

environmental protection. Currently, the national 

authorities for handling procedures concerning 

shipments of waste have to examine and assess 

planned and notifi ed shipments in order to verify their 

legality. A provision has been inserted in the new 

regulation requiring Member States to co-operate, 

bilaterally or multilaterally, with one another in order 

to facilitate the prevention and detection of illegal 

shipments. 

Illegal waste shipments are a major problem. During 

recent inspections the IMPEL-TFS cluster identifi ed 

over 50 per cent of illegal waste shipments from 

EU Member States. One of the main priorities of the 

Commission’s waste management policy is to prevent 

and reduce these illegal waste shipments as much as 

possible. 

49 


Co-operation under the New Waste Shipment Regulation 

Member States have designated, in addition to 

their competent authorities, waste shipment 

correspondents. The Commission regularly organises 

meetings for these correspondents. In this context 

issues relating to the implementation of the new 

waste shipment regulation, including illegal waste 

shipments, are discussed. 

Guidelines are planned for the co-operation envisaged 

between Member States relating to illegal waste 

shipments. In addition, a number of events in certain 

Member States are planned in order to increase 

awareness and improve co-operation between 

authorities on this matter. 

The good functioning of co-operation, both within 

and between Member States, is essential in order 

to prevent and reduce the number of illegal waste 

shipments, which is very high currently. 

Mr. Peter Wessman 

European Commission Directorate - General Environment, Unit G.4 

(Sustainable Production and Consumption) 

BU-5 5/178, B-1049 Brussels, Belgium 

Telephone: +32 2 2991227 




Ms. Malgorzata Kotodziej-Nowakowska 

(Poland) 

Experience of Regional Inspectorates for Environmental Protection in Poland in Undertaking 

Inspections on Transboundary Waste Shipment in Seaports. Establishing a Network between 

Appropriate Institutions in Poland and Other EU countries 

From 2004 till 2006 two Regional (Voievodship) 

Inspectorates for Environmental Protection in Szczecin 

and Gdańsk (Poland) participated in the IMPEL TFS 

(transfrontier waste shipment) Seaport Project II. 

The main aim of the IMPEL TFS Seaport Project II 

was to improve enforcement and align enforcement 

activities of TFS Regulations in and between the 

participating seaports around Europe. Experiences 

and practical knowledge about the execution and 

enforcement of TFS Regulations were expanded 

and shared with all countries involved. The project 

also stimulated co-operation between national 

and international authorities. Raised awareness of 

the general public about the need for this kind of 

regulation and higher profi le of enforcement activities 

were also achieved. 



50 

During this project many inspections in Polish 

seaports of Szczecin, Świnoujście, Gdańsk i Gdynia 

were undertaken. The inspections showed violations 

of transboundary waste shipment. Inspectors have 

identifi ed two different directions of shipment of 

waste: to Poland and from Poland. Illegal shipments 

to Poland still appear to be a big problem in Poland. 

Inspectors from Regional Inspectorates for 

Environmental Protection in Szczecin and Gdańsk 

co-operated with inspectors, mainly from the 

Netherlands and Germany. Although the IMPEL TFS 

project has fi nished the network of co-operation still 

exists. 

Ms. Małgorzata Kołodziej-Nowakowska 

Regional (Voievodship) Inspectorate for Environmental 

Protection in Szczecin 

Wały Chrobrego 4, 70 – 502 Szczecin, Poland 

Telephone: + 48 91 43 03 725, mobile: + 48 508 02 02 20 

Fax: + 48 91 43 40 554 

mkn@wios.szczecin.pl

51 


Continuity of the TFS Network and Goals for the Future 

The IMPEL TFS Network is a forum for competent 

authorities in the EU Member States and other 

countries (Norway, Switzerland and Hong Kong) that 

enforce the European Waste Shipment Regulation 

No. 259/93/EEC – EWSR - to share information 

and experience in implementing and enforcing this 

regulation. 

Despite the fact that the IMPEL TFS Network has 

completed a lot of valuable work and products during 

the past years, the need was felt to better ground the 

effective international cooperation by a more targeted 

focus on enforcement and priorities and to switch 

from an informal approach to a well structured, 

consensus-based approach, with the associated 

development of knowledge and capacity. Therefore, 

at the annual TFS conference in 2004 in Malta, the 

work of IMPEL TFS has undergone a critical review. 

It was concluded that important improvements were 

needed and that it was necessary to involve high 

management levels in Member States to make these 

improvements work. 

Following conference in Malta continuous process has 

been launched to establish a structured framework to 

activities of IMPEL TFS. 

The purpose of the presentation will be to present 

milestones of the transformation of IMPEL TFS 

(within the IMPEL frames) to more effi cient and 

better structured organization as well as a goal for the 

future. 

Ms. Magda Gosk 

Chief Inspectorate for Environmental Protection 

Wawelska st. 52/54, PL-00922 Warszawa, Poland 

Telephone: +48 22 5928092 

Fax: +48 22 5928093 




Mr. Mihail Dimovski (ECENA), 

Ms. Magda Gosk (Poland) 

Environmental Compliance and Enforcement Network - Paving the Road to Accession 

One of the main prerequisites for accession is to 

bring national legislation into harmony and to achieve 

compliance with the laws of the European Union. 

Environment is considered to be a sector that will 

pose particular problems for pre-candidate and 

candidate countries because of the extent of the EU 

environmental requirements. Effective system for 

capacity building and exchange of experience on 

transposition and implementation of the EU legislation 

is important, because of the cost implications of 

approximation in the environmental sector, in order 

to achieve timely and cost-effective progress. Some 

of the main challenges faced by pre-candidate and 

candidate countries regarding the implementation of 

the EU environmental legislation are: 

- need to increase the understanding of environmental 

inspectors on the steps needed to implement the EU 

law; 

- requirements to improve the capacity for enforcing 

and implementing the EU law; 

- need to increase ability of environmental 

inspectors to deal with specifi c problems related 

to implementation and enforcement of the 

environmental acquis; 

- need for technical assistance and exchange of 

experiences. 

Informal networking among environmental 

practitioners and inspectors has proved to be one 

of the most powerful mechanisms enabling more 

effective implementation of the EU environmental 

legislation. There is an enormous need for knowledge/ 

information and exchange of experiences at the level 

of inspection and implementation of the EU legislation 

in pre-candidate and candidate countries. 

Environmental Compliance and Enforcement Network 

for Accession – ECENA is an informal network 

of environmental authorities from pre-candidate, 

candidate and acceding countries. Members of 

ECENA are the following countries: Albania, Bosnia 

and Herzegovina, Bulgaria, Croatia, the former 



52 

Yugoslav Republic of Macedonia, Montenegro, 

Romania, Serbia, including Kosovo as defi ned by the 

United Nations Security Council Resolution 1244, 

and Turkey. The European Commission is also a 

member of ECENA. 

The structure of ECENA is similar to the structure of 

IMPEL, while the scope of application is based on 

lessons learned from the former AC IMPEL. 

ECENA played a pivotal role in identifying needs of its 

member countries in the implementation of the EU 

legislation, as well as providing substantial support in 

improving enforcement capacity in the pre-candidate 

and candidate countries. 

In line with the needs of the ECENA member 

countries, the core of ECENA activities concerns 

the training of inspectors, assessing needs, peer 

reviews focused on IPPC and minimum criteria for 

environmental inspections, exchange programmes 

and study tours on the implementation of major EU 

environmental directives. 

The main factors that contributed to ECENA becoming 

a successful assistance mechanism are as follows: 

- activities planed according to the accession needs of 

its member countries; 

- regular progress monitoring of key achievements and 

dissemination of outcomes of all activities; 

- countries’ ownership of the results; 

- strong and effi cient secretariat; 

- excellent cooperation with the EC, IMPEL and other 

similar networks. 

Mr. Mihail Dimovski 

ECENA Secretariat, the Regional Environmental Centre for 

Central and Eastern Europe 

9-11 Ady Endre, 2000 Szentendre, Hungary 

Telephone: +36 2650 4052 

Fax: +36 2631 1294 

mdimovski@rec.org

Policy Dialogue and Peer Learning within the 

Framework of REPIN 

The Regulatory Environmental Programme 

Implementation Network (REPIN), which is part of 

the OECD/EAP Task Force, was formally established in 

1999 and has operated in Eastern Europe, Caucasus 

and Central Asia (EECCA) since late 2000. REPIN 

work has helped to revise policies and legislation, 

to reform environmental institutions and to upgrade 

the knowledge and skills of environmental offi cials 

and experts in EECCA countries. The Network has 

substantially enlarged its scope of work after the Kiev 

“Environment for Europe” Ministerial meeting in 2003 

and has been concentrated efforts in three main areas: 

(i) environmental policy instruments; (ii) environmental 

compliance assurance strategies and instruments; 

and (iii) performance of environmental enforcement 

authorities in EECCA. The working methods of the 

REPIN and the Task Force emphasise policy dialogue 

and peer learning, and rigorous analysis and good 

practice guides to support reform efforts. 

As a result, a suite of practical tools to assist EECCA 

governments to implement reforms have been 

developed. Since 1998 the Task Force added noninvestment 

demonstration projects to its working 

methods in order to help promote environmental 

reform by achieving concrete results “on the ground”. 

These demonstration projects have been used both 

to develop and to apply the tools referred to above. 

The results of these projects are used also to drive the 

regional process of peer learning. 

Reforms Spurred by Networking 

Regional networking and capacity building stimulated 

important changes in EECCA, including: 

• Armenia has re-designed its system of economic 

instruments; 

• Moldova is working to align its water quality 

standards with the EU requirements; 

53 


Mr. Ladislav Miko (European Commission), 

Ms. Angela Bularga (OECD) 

Modernising Environmental Regulation and Enforcement in the EU Eastern Neighbours: 

the Role of the Regulatory Environmental Programme Implementation Network (REPIN) 

• Strategies for reforming environmental permitting 

systems have been prepared in Georgia, Ukraine 

and Kyrgyzstan; 

• Representatives of environ men tal authorities are 

also being trained on how the guidelines could be 

applied in their countries; 

• Analysis of environmental permitting in these 

countries facilitated the implementation of bilateral 

projects supported by Finland, Sweden, and the 

World Bank; 

• The legal frameworks for self-monitoring by 

enterprises in Kazakhstan and Kyrgyzstan have been 

revised in light of Task Force guidance; 

• Armenia, Georgia and Kazakhstan have drafted new 

legislation on environmental enforcement based on 

the Guiding Principles on Reform of Environmental 

Enforcement Agencies; 

• EECCA countries are working to implement good 

practices for performance managements and 

fi nancing environmental inspectorates; 

• Armenia, Georgia, Kyrgyzstan and Kazakhstan 

are implementing reform of their environmental 

enforcement institutions in light of recommendations 

provided within the REPIN framework; 

• A Performance Rating and Information Disclosure 

Scheme is being implemented in Lviv, Ukraine. 

Similar projects are launched in Kazakhstan and the 

Russian Federation with the expectation that greater 

transparency will create incentives for enterprises to 

reduce pollution; 

• In 2003-2006, training was conducted for about 

400 managers and experts from environmental 

authorities in EECCA. 

All these activities and thus achievements were made 

possible due to expert input from OECD countries, 

including IMPEL, and fi nancing provided by the EU 

member countries, including the Czech Republic, 

Poland, the Netherlands, Sweden, the UK, and also 

from Norway. 




Remaining Challenges 

Unfortunately, environmental protection is 

often perceived as an impediment to economic 

development and investment. In some instances, 

deregulation of economies lead to a temporary 

abolishment of environmental permitting (e.g., in 

Kyrgyzstan) and severe restrictions to conduct onsite 

inspection instead of eliminating regulations 

that stifl e growth by inducing excessive compliance 

costs. Weak analytical capacities, non-transparent 

or lengthy decision-making and cases of corruption 

in the environmental fi eld do not help to change the 

situation. 

The environmental legislation has been developed 

extensively but regulatory impact analysis (beyond 

government costs) is almost never conducted. 

Many legislative provisions are not supported 

by implementing regulations, and there are still 

many discrepancies between new and older laws, 

especially those developed by different government 

agencies. Some countries are reviewing their current 

legal frameworks to make them more coherent. 

Convergence with the EU environmental legislation 

has been declared as a goal but its implementation 

remains sporadic and incoherent. The incentive 

basis for industries to comply with environmental 

regulations is weak. The economic instruments 

for environmental protection and natural resource 

management remain largely unreformed and do not 

promote environmentally sound behaviour. 

Many environmental ministries/agencies undergo 

structural changes to increase their effi ciency 



54 

and effectiveness. Modern management tools, 

as performance-based budgeting or performance 

assessment have been introduced as part of 

strengthening government agencies. However, the 

institutional changes are often very frequent and 

result in long transition periods of institutional 

uncertainty and inaction. Excessive fragmentation of 

internal units and lack of mechanisms for cross-sector 

co-ordination of policies runs contrary to the need 

for integrated approaches to policy implementation. 

In some cases, restructuring has been used to 

downgrade the status of environmental agencies 

and limit their infl uence over government policies. 

The implementation of subsidiarity principle in 

environmental management remains a challenge. 

Often the distribution of functions between central 

and sub-national levels is unclear, and capacities 

(human and fi nancial) at sub-national level very low. 

Emerging Opportunities 

Several opportunities are emerging in EECCA to 

pursue modernisation of environmental regulation 

and enforcement. Renewed economic growth 

provides room for additional national investment 

efforts on environmental protection. EU enlargement 

could become a benefi cial infl uence, for the new 

neighbours, including through knowledge transfer 

from the EU member countries, in particular from 

those ones that share historical traits with the EECCA 

region. The new international development agenda 

(including the Millennium Development Goals, MDGs) 

potentially offers an important lever for promoting 

policy integration. 

Ms. Angela Bularga 

Environment and Globalisation Division, Environment Directorate, 

Organisation for Economic Co-operation and Development 

2, rue André-Pascal, 75775 Paris Cedex 16, France 

Telephone: +33 1 4524 9863 

Fax: +33 1 4430 6183 

angela.bularga@oecd.org


Session 8 | Workshop on Inspection and Enforcement for the Future | 28 September 2006 

Ms. Lena Callermo (Sweden) 

The presentation starts with a recollection of why 

inspection and enforcement are important. Together 

with a few observations from the Swedish IRI this 

serves as a background to a general view of European 

developments on inspection and enforcement for the 

next coming years. 

Environmental issues and priorities vary for different 

authorities and Member States. Therefore, there is 

a need for fl exibility in a system for inspection and 

enforcement, whether it is the current RMCEI or a 

future directive. The ambition should be to benefi t 

from working at the EU-level at the same time as the 

advantages of different national systems could be 

preserved and further developed by each Member State. 

It should be an ambition to promote continual 

improvement at all levels of the system, in the 

The procedure for environmental inspection of liable 

undertakings of signifi cant environmental impact will 

be presented as follows: 

1. The legal basis of the classifi cation of undertakings. 

2. The procedure for environmental inspection of 

liable undertakings of signifi cant environmental 

impact before starting up operation - environmental 

compliance of undertakings. 

3. The formula of the offi cial record from the inspection 

4. The after inspection procedure. 



Where will we be Five Years from Now? 

56 

authorities as well as in the enterprises. From different 

starting points, enterprises and authorities could 

benefi t a lot from the methodology of Quality and 

Environmental Management Systems: Plan-Do-Check- 

Act, the four-step model for carrying out changes. 

Just as a circle has no end, the PDCA cycle should be 

repeated again and again for continuous improvement. 

To enable this, it is important that recommendations 

or rules are kept at a system level and that reporting 

requirements are kept from extensive detailed 

quantitative data, but instead designed to evaluate the 

actual quality of the environmental inspection. Instead 

of detailed regulation the development of inspection 

and enforcement should rely on improving the skills of 

the national inspecting personnel. 

Ms. Lena Callermo 

Swedish Environmental Protection Agency 

S-106 48 Stockholm, Sweden 

Telephone: +46 8 698 12 42 

Fax: +46 8 698 12 22 

lena.callermo@naturvardsverket.se 

Introduction of the Best Practice on Quality Approach – Inspection and Enforcement in 

Starting up Operation of Liable Undertakings of Signifi cant Environmental Impact 

The procedure for environmental inspection of liable 

undertakings of signifi cant environmental impact before 

starting up operation in accordance of environmental 

law (environmental compliance) will be presented. 

The undertakings mentioned above cover EIA Directive 

(Council Directive 85/337/EEC of 27 June 1985 on 

the assessment of the effects of certain public and 

private projects on the environment). 

Mr. Boguslaw Dabrowski 

Opole Voivodeship Inspectorate for Environmental Protection 

Nysy Luzyckiej 42, 40-035 Opole, Poland 

Telephone: +48 77 4530069 

Fax: +48 77 4530069 

b.dabrowski@opole.pios.gov.pl

In the last years, more and more EU Member 

States have engaged in a process of delegation of 

environmental inspection from the public state sector 

to some semi-public or private structures, and it is 

likely that this process will continue steadily in the 

future. However, this signifi cant evolution raises many 

questions and challenges. 

The two main questions are “why” and “what” to 

delegate? 

In fact, there are many different approaches to the 

notion of delegation. The technical approach would 

discuss whether the mission of inspection could be 

better done if delegated. The economical approach 

would evaluate the cost of inspection – cost to the 

state or cost to the companies, and would take 

in account the creation of a market of inspection, 

possibly open to competition. The organizational 

approach will introduce the necessary coordination 

between administrative authorities, judicial authorities 

and the various public or private structures in charge 

of inspection. 

All those approaches give different directions for 

analysis, each of which opening an optimization 

issue, able to justify the decision of delegating some 

missions of inspection. 


Ms. Lena Thystrup (Sweden), Mr. Mick Henry (Ireland), Mr. Pierre Bois (France), 

Mr. Pieter-Jan van Zanten (The Netherlands), Mr. Jesus Angel Ocio (Spain), 

Mr. Boguslaw Dabrowski (Poland) 

Delegation of Inspection 

57 

Although it is almost sure that neither full delegation 

nor zero delegation is the best solution, the 

combination of the different approaches tends to be 

an insoluble problem, with several possible ways 

to improve the global performance of inspection, 

depending on the fi eld of the missions and domains of 

competence that one chooses to delegate. 

In any case, delegation leads to a situation where a 

border is created between what is delegated and what 

is not. One could argue that inspection as a whole 

is a core mission of the state, since it is one of the 

roots of enforcement. Yet, a proper system of offi cial 

accreditation of inspecting or controlling structures 

virtually allows to limit the core mission of state 

to the 2 nd level of control, namely, controlling the 

structures in charge of inspection themselves. 

This observation leads to a much more critical issue, 

which is the administration of this border between 

what is delegated and what is not. It is most likely 

that the global improvement expected from delegation 

of inspection rather depends on this connection 

between the state level and the delegated level, than 

on the extent of their respective scopes. 

The fundamental questions to answer are as follows: 

what responsibility does the inspection structures 

carry, when is it necessary to involve intervention of 

state offi cers, what kind of reporting and monitoring 

do state authorities expect. 

Mr. Pierre Bois 

DRIRE Alsace / Ministère de l’Ecologie et du Développement Durable 

1 rue Pierre Montet, 67000 Strasbourg, France 

Telephone: +33 388 25 92 40 

Fax: +33 388 36 98 13 

pierre.bois@industrie.gouv.f 




The Environmental Protection Agency (EPA) 

has developed a methodology for assessing the 

environmental risk arising from operations carried 

out at licensed facilities. This is being undertaken on 

the basis of stakeholder consultations and relevant 

international comparisons. The environmental risk of 

facilities will be assessed on the basis of fi ve criteria: 

- Complexity of the activities on site; 

- The level and type of emissions; 

- Location of the activities; 

- Operator management standards (e.g., 

environmental management systems); and 

- Enforcement record of the facility. 

Complexity and location are fi xed attributes, and 

beyond the control of the operator, but the remaining 

three criteria can be controlled. Minimising emissions, 

good operational practices and a high level of 



Developing Risk Based Regulation 

58 

compliance with licence conditions will ensure the 

risk from licensed sites can be reduced. Within each 

of the fi ve criteria, a list of factors that contribute to 

the risk has been developed. For each criterion, risk 

is assessed, and the scores are aggregated to arrive at 

an overall risk category for that facility, as follows: 

- High Risk – A1, A2, A3; 

- Medium Risk – B1, B2, B3; 

- Low Risk – C1, C2;(A1 is extremely high risk, while 

C2 is very low risk). 

The system will provide a consistent, transparent and 

tangible rationale for the level of enforcement and will 

bring EPA’s enforcement into line with international 

best practice and EU recommendations (e.g., 

2001/331/EC). It will also result in improved use of 

resources within the EPA and provide a rationale for 

charging licensees for its enforcement. 

Mr. Mick Henry 

Environmental Protection Agency 

John Moore Road, Castlebar, Co. Mayo, Ireland 

Telephone: +353 94 9048441 

Fax: +353 94 9048499 

m.henry@epa.ie

As inspectors we often focus on techniques and law. When we add communication skills and look for potential 

improvements in stead of “errors”, then it is possible to create a “win-win” situation. 

Competence / 

Instruments / 

Systems 

Key factors in compliance assistance: 


Command and Control 

Reactive 

Laissez-faire 

Business as usual 

Compliance Assistance 

C o m m u n i c a t i o n 

- Invite to a cooperation process instead of a confl ict; 

- Focus on the whole material (value)-fl ow through the site, and not just end of pipe; 

- Defi ne the environmental issues/potential improvements, and fi nd mutual goals/priorities; 

- Visualise goals and project process; 

- Stay in charge of the project process. 

59 

Negotiation 

Proactive 

Convince 

Active 

Authority 

Company 

Ms. Lene Thystrup Knudsen 

Copenhagen County 

Stationsparken 27, 2600 Glostrup, Denmark 

Telephone: +45 43 22 28 33 

Fax: +45 43 22 28 66 

lethkn@hotmail.com 




There were nine presentations in the session, which 

unfortunately did not give time for an in-depth 

discussion. It is possible to divide the presentations of 

the workshop in three main parts: 

1. National Networks 

2. Topical Networks 

3. Geographically Limited Networks 

National Networks 

The speakers of the Czech Republic, Germany and 

Ireland described the organisation of their national 

networks. In the three countries, the networks 

on environmental issues, implementation and 

enforcement of environmental laws are organised 

on national, regional and local scale, with the 

involvement of other authorities. 

The Czech Republic created a specifi c network for 

IMPEL, coordinated by the Czech Environmental 

Inspectorate, which meets before the Plenary 

meetings. This network consists of different 

authorities involved in the implementation and 

enforcement process. The network is a channel 

for dissemination of IMPEL reports, exchange of 

information and a way to fi nd people to attend IMPEL 

projects. They also have a national web site for 

IMPEL. They translate the summaries of the project 

reports and the conclusions of the Plenary meetings. 

Germany has several networks due to its federal 

structure. In the Federal (State) network. you can 

fi nd other networks related to different environmental 

issues. There is networking between the different 

states and between different authorities, networking 

with interest groups on an international level and 

networking via the internet. IMPEL products are also 

disseminated through these networks. The network 

Report from Workshop on Networking 

Chairman: Mr. Markku Hietamäki (Finland) 

Rapporteur: Ms. Alessandra Burali (Italy) 

61 

Session 9 | Reports from Workshops | 29 September 2006 

meets twice a year and also deals with exchange of 

information and discussions on projects. 

As in other countries, the Czech Republic and 

Germany can fi nd it diffi cult working in English. It is 

diffi cult to fi nd people to participate in the projects, 

prepare and present new projects and to understand 

project reports written in English. 

Ireland has a specifi c network on environmental 

enforcement focused mainly on inspections and 

enforcement. This harnesses the collective resources, 

expertise and investigative capacity of all public 

sector agencies and government departments to 

change the way that environmental crime is tackled. 

They implemented the RMCEI and produced guidance 

documents on inspections and training for inspectors 

based on the IMPEL products. 

Topical Networks 

Ms. Alessandra Burali (Italy) 

During the workshop there were three presentations 

on Transfrontier Shipment of Waste. One from the 

Commission’s representative who illustrated the new 

Waste Shipment Regulation which came into force 

recently. He pointed out the importance of the IMPEL 

TFS Cluster work and the need for collaboration. 

The other two presentations were from representatives 

of the IMPEL TFS Cluster, one on the outcome of the 

Seaport II project in Poland, and the other on the 

future of TFS. 

The TFS Cluster coordinates action in seaports 

between Member States to enforce the Waste 

Shipment Regulation in order to prevent illegal 

shipments of waste and to work towards a level 

playing fi eld. The new Waste Shipment Regulation 

(WSR) introduces obligatory international enforcement 

collaboration, which underlines the importance of the 

TFS Cluster. 




The main challenge emerged during coordinated 

actions. These showed that the compliance factor 

was around 50%, indicating that urgent and more 

effective cooperation is needed. During the discussion 

another interesting point arose, that for a more 

effective handling of waste shipment, the problems 

should be tackled at the source! 

The GreenEnforce network deals with the 

implementation and enforcement of nature 

conservation and forestry issues. It is a new network 

and looks at approaches on how to measure 

enforcement. Methods are diverse in the different 

countries, sometimes there is no approach strategy 

at all. This can give rise to some diffi culties in 

defi nitions. It was suggested that the work of the 

network should be widened to include RMCEI and 

nature issues (this will be discussed during their next 

Plenary meeting in December). 

At the moment the Czech Republic coordinates a 

comparison programme on Inspection Methodology 

for Natura 2000 sites. IMPEL, ECENA and REPIN 

networks are invited to attend the Plenary meeting. 

There might be a possibility to make a joint project 

with IMPEL. 

Geographically Limited Networks 

ECENA, the Environmental Compliance and 

Enforcement Network for Accession (see 

www.rec.org/REC/Programs/REReP/BERCEN) is an 

informal network of environmental authorities from 



62 

pre-candidate, candidate and acceding countries. The 

European Commission is also a member of ECENA. 

The core activities concern assessing needs, capacity 

building, provide technical assistance, exchange of 

experience on implementation and enforcement of 

environmental laws also through study tours. Several 

times the Commission stressed that IMPEL members 

should participate in ECENA projects. 

A representative from the Republic of Macedonia 

illustrated their experience with ECENA and other 

networks on exchange of experience with EU 

countries and candidate countries. Specifi cally on 

training of inspectors and on specifi c environmental 

issues such as IPPC, RMCEI and Seveso II. 

REPIN, the Regulatory Environmental Programme 

Implementation Network, which is part of OECD/EAP 

Task Force (see www.oecd.org/env/eap), has been 

active in Eastern Europe, Caucasus and Central 

Asia (EECCA) since 2000. Its efforts focus on the 

modernisation of policies and legislation in the region, 

reform of environmental institutions, and upgrade of 

the knowledge and skills of environmental offi cials 

and experts. IMPEL members can play an important 

role in this process, mainly through know-how 

transfer, but also by putting a certain peer pressure 

on counterparts from ECENA countries in relation to 

environmental enforcement, either in the context of 

multilateral cooperation or within bilateral relations. 

Both networks invite IMPEL to support their activities 

and take part in their projects.

Report from Workshop on Contribution of the IMPEL Network to 

Better Regulation 


Rapporteur: Ms. Karen Riddick (United Kingdom) 

This session looked at the concept of Better Regulation 

and the means by which the IMPEL network can 

contribute to this. Around 60 people attended the 

session which was chaired by Mr. Andreas Wasielewski 

from Germany. 

The chairman welcomed attendees and opened 

the session by suggesting that better regulation 

is concerned with more effi cient application and 

achievement of regulatory standards, and that this 

should not be confused with de-regulation. 

Six presentations followed. These mostly looked at 

practical issues which must be taken into consideration 

when working towards better regulation but there 

were also some examples given of specifi c projects 

which have been carried out by IMPEL. The role 

of IMPEL within the fi eld of better regulation was 

further examined in a presentation from the European 

Commission. 

The fi rst speaker was Mr. Terry Shears from the 

United Kingdom who reminded attendees that the 

potential contribution of IMPEL has been enhanced 

by the creation of a Better Legislation cluster. This 

cluster is used as a central group through which 

comments can be made on both new and existing 

legislation and on the implications of decisions from 

the European Court of Justice. He went on to outline 

the fi rst project that had been carried out by this 

cluster, “The inter-relationship of the IPPC Directive 

with other Directives”. This project identifi ed a number 

of areas of concern including the need for better 

harmonisation for example in defi nition and scope, the 

possible disproportionate application to some smaller 

installations, the overlaps with the Emissions Trading 

Scheme and the need to improve fl exibility in response 

to industrial changes. The outcome of this project has 

been of use to the Commission as part of their ongoing 

review of the IPPC Directive and Terry believes IMPEL 

should be carrying out other similar projects. 

The second speaker was Mr. Paul Bernaert from 

Belgium who provided a useful summary of the 

principles of good regulation in terms of application 

and outcomes. He pointed out that the matter 

of practicability and enforceability of legislation 

is of particular importance and that enforcement 

authorities should always seek to achieve maximum 

compliance with minimum enforcement effort. Mr. 

Paul Bernaert acknowledged that there is “nothing 

more complex than making legislation simple” but he 

offered a number of practical suggestions that should 

63 


Ms. Karen Riddick (United Kingdom) 

be considered within the context of environmental 

legislation. These included a limit to the amount of 

new legislation, a move towards single permitting 

systems (beyond that which has come from the IPPC 

Directive) and a move towards single codifi cation of 

legislation. He also suggested that more work should 

be carried out on removing contradictory terms from 

legislation and ensuring that suffi cient resources were 

available to implement and enforce legislation. 

The third speaker was Ms. Eva Kruzikova from the 

Czech Republic. She recognised some of the issues 

that had already been raised and was able to give 

examples of both problems and solutions. Ms. Eva 

Kruzikova described how the need to complete 

various legislative chapters as part of the entry into 

the EU had resulted in rapid transposition of laws in 

the Czech Republic. Within the environmental fi eld, 

this resulted in too much administration with little 

environmental benefi t. There was limited transparency 

in the transposition and implementation procedures 

and the resulting laws were considered by industry 

to be strict, rigid, burdensome and anti-competitive. 

As a result, there was also a limited ability to carry 

out enforcement with a subsequent low respect for 

legislation and its objectives. 

In order to address some of these problems, the Czech 

government established a working group, which is now 

looking at improving the perception, application and 

outcome of environmental legislation. This may include 

development of a codifi ed or framework approach and 

a move towards co-ordinated permitting. There is also 

a strong desire to improve consultation and to ensure 

that people and industry are able to give their views at 

the right stage in the process. This work is ongoing and 

the outcome should be an interesting practical example 

of how to work towards better regulation. 

The fourth speaker was Mr. Jan Teekens from the 

Netherlands who identifi ed problems that exist in the 

regulatory cycle in terms of development and review 

of legislation. He then introduced the checklist that 

is currently being developed as part of an IMPEL 

project and which is intended to help users identify 




and reduce problems associated with practicability and 

enforceability of European environmental legislation. 

The checklist includes questions such as the choice of 

legal instrument and the suitability of the measure for 

transposition, implementation and compliance. A key 

point was that the checklist can be used by a variety 

of stakeholders for example the European Commission, 

Member State governments, enforcement authorities. 

It can be used at a variety of stages in the legislative 

process, to review new draft legislation or legislation 

that is already in place. In terms of IMPEL’s own use of 

the checklist, thought that IMPEL should involve itself 

at those stages where its competence is most relevant. 

The fi fth speaker was Mr. Charles Pirotte from the 

European Commission who recognised the value of 

IMPEL in that it can use practical experience to inform 

the development and amendment of legislation. He 

repeated the view already given by his Commission 

colleague that the continued input of IMPEL is 

something that the Commission wants and needs. 

This input should be focused on relevant stages of the 

process where IMPEL can identify specifi c practical 

issues, in particular at the ex ante stage where new 

legislation is being drafted and the post ante stage 

where existing legislation is reviewed. Mr. Charles 

Pirotte also suggested that the Commission would be 

interested in the ongoing development and application 

of the checklist described by Mr. Jan Teekens in his 

earlier presentation. 

The sixth and fi nal speaker was Mr. Indulis Emsis from 

Latvia who started his presentation with an interesting 

history to the development of environmental legislation 

in his country. He identifi ed similar problems to those 

raised by Ms. Eva Kurzikova from the Czech Republic 

in terms of the problems that can arise when entering 

the European Union. Legislation may be transposed 

too quickly and then prove diffi cult to implement and 

enforce. 

Mr. Indulis Emsis considered that successful 

transposition and implementation of environmental 

legislation in Latvia had been partly due to the 

enthusiasm demonstrated by the parliament. This is an 

aspect of better regulation that is not always mentioned 

but which is critical. He also supported the IMPEL 

focus on practicability and enforceability of legislation 

and made similar suggestions to Mr. Paul Berneart 

with respect to possible solutions, for example, limits 

to the introduction of new legislation and a move 

towards single permitting. In addition, Mr. Indulis 

Emsis recognised the need to deal with problems of 

translation (using the example of BREFs associated 

with IPPC permitting) and to keep in mind the costs 

and benefi ts associated with better regulation. 

Following the six presentations, a lively discussion took 



64 

place during which many interesting questions and 

comments were raised. Some of the main comments 

are summarised below. 

• IMPEL should focus on practicability and 

enforceability when looking at better regulation 

although IMPEL is also entitled to contribute at any 

stage when public consultation is invited. 

• Contribution from inspectors should be increased 

and processes developed to enable this to happen at 

the most effective time and level. 

• There is a need to recognise the balance between 

prescriptive legislation and the principle of 

subsidiarity. 

• The increased number of Member States increases 

the need for fl exibility and this may have both 

positive and negative impacts on better regulation. 

• Recognition must be given to the fact that new 

member states may have more diffi culty and need 

more help in pursuing better regulation if they 

need to transpose laws quickly in order to enter the 

European Union. 

• Different actors are responsible for reaching the goal 

of better regulation and IMPEL must be clear about 

what it’s role is. 

• Obstacles to better regulation have been identifi ed 

when an interface exists between the ‘command and 

control’ approach and the ‘economic instrument’ 

approach, for example IPPC and ETS. 

• Hasty transposition, amendment and 

implementation can lead to too much administration 

and not enough environmental benefi t. 

• Costs and benefi ts should always be considered. 

• IMPEL projects should be timed to correspond 

with wider projects and reviews where possible, for 

example the IPPC project mentioned earlier, tied into 

the Commission review of the Directive. 

• Much support shown for both single permitting and 

codifi ed laws. 

• Above all, when focusing on procedures and 

approaches towards ‘better regulation’ IMPEL must 

not lose sight of the environmental outcome. 

In conclusion, Session 4 examined the contribution 

that IMPEL can make towards better regulation 

and it proved to be most interesting, with six highly 

informative presentations and an active discussion 

thereafter. The competence, professionalism and 

practical experience of IMPEL is needed to achieve the 

aim of better regulation and IMPEL should be involved 

both when new legislation is drafted and when existing 

legislation is being reviewed. The establishment 

of the Better Legislation Cluster should provide an 

opportunity for IMPEL to make appropriate input but 

it should also be recognised that these principles must 

be applied and considered on a more general basis 

too. In all cases, IMPEL is able and willing to help the 

Commission in achieving better regulation.

During this workshop four speeches were given. 

The speakers were Mr. Alexandre Paquot from 

the European Commission, Mr. Sami Koivula - an 

inspector from Finland, Mr. Didier Pitrat - an inspector 

from France and Mr. Per Christensen from Aalborg 

University in Denmark. 

The fi rst speech came from Mr Alexandre Paquot 

(European Commission). 

Mr Paquot pointed out, that the main objective of 

the review of the IPPC directive is to ensure better 

permitting by competent authorities. Therefore 

the European Commission outlined its IPPC- 

Implementation Action plan. 

Objectives of the Action plan are: 

1 st : Full transposition 

2 nd : Monitoring progress 2007 

3 rd : Implementation assessment 

4 th : Finalisation of the BREFs 

5 th : Working out guidance 

The commission has launched the study to assess the 

possible practical permitting diffi culties, which might 

arise from the interaction between the IPPC Directive 

and other Directives such as the Large Combustion 

Plants Directive (LCP) Waste Incineration Directive 

(WID) and the Solvents Emissions Directive. The key 

question is whether these differences lead to practical 

permitting diffi culties and where whether these pieces 

of legislation need to be streamlined. 

Amendment studies were also launched to specify 

the frequency of monitoring, the periodic review of 

permits, the defi nition of inspections like RMCEI and 

the extension of the scope of the Directive. 

The Commission offers to contribute to the review 

via http://forum.europa.eu.int/Public/irc/env/ippc_rev/ 

library. 

Report from Workshop on Permitting 


Rapporteur: Ms. Barbara Pucker (Austria) 

65 


Ms. Barbara Pucker (Austria) 

After this introductory speech, three further speeches 

where held, two from inspectors and one from the 

NGO´s perspective. 

Mr. Sami Koivula from Finland pointed out that in 

Finland, it was obvious that greater effi ciency in 

permitting was required. The permitting procedures 

had to be enhanced. Four objectives were described: 

1 st : To streamline the permit procedure 

2 nd : To reduce the workload on the permit writer 

3 rd : To improve the quality of the permit 

4 th : To use IT more effectively 

An IT system will be set up to create a “common 

working space”. The applicant, the permit authority, 

the stakeholders and the appeal/enforcement 

authorities should be given access and support to 

this system electronically. Within this system, which 

will become live in 2009, a centralised permitting 

authority should be given resources. This means 

templates of permit conditions, BAT or BREF 

resources and guidance on permit writing should be 

available. 

The next speaker Mr. Didier Pitrat from France 

described the situation in France. There have been 

inconsistencies in environmental enforcement, 

especially at a local level. These inconsistencies 

have led to unjustifi ed economic disadvantages 

for enterprises. To address this the Ministry 

for Environment worked out the “Inspection 

Modernisation plan” to standardize offi cial regulation. 

Consistency between the national, regional and local 

levels should be the goal. The permit writer should 

be provided with specifi c resources: vade mecum 

set of guidance – similar to BREFs, template permit 

conditions, coaching for new inspectors, an intranet 

legal register, a database of past decisions, an 

incidents database, a network for informal exchange, 

national and regional interlinks and review by legal 

experts. 




The next speaker Mr. Per Christensen from Aalborg 

University in Denmark stated that the IPPC Directive 

has been a tremendous success from the view 

of the public. Especially in terms of information, 

reasons, BAT and the integrated approach. But the 

question was raised whether the IPPC-directive is 

comprehensive enough, broad enough, dynamic 

enough and informative enough. But today there’s 

reason to believe that an IPPC-permit does not deliver 

enough relevant information to the public. The IPPC 

Directive has to compete with other Directives above 

all the EIA-system, the Water Framework Directive 

and Biodiversity. The question arises whether the 

scope of the IPPC Directive should be extended to 

cover these systems and policies. Per Christensen 

brought forward a so-called “NGO wish-list”. This 



66 

wish list concerns the process of greening industries 

with life cycle analysis or green procurement, 

biodiversity, climate change and EMAS. 

After these four speeches a very lively discussion took 

place. One of the most discussed questions was if the 

scope of IPPC should be extended in any way. Further 

more the relationship or the connection between the 

EIA-system and the IPPC Directive was discussed and 

above all, public participation within these different 

systems. This is an important area of work for IMPEL. 

It was proposed that IMPEL should undertake new 

projects to improve permitting.

When looking at the future of inspection and 

enforcement, we have to bear in mind their fi nal 

purpose. This is very well summarised in the IPPC 

Directive when it says “...to achieve a high level of 

protection of the environment taken as a whole...”. 

The best approach to do so is to promote continuous 

improvement at different levels i.e. European, 

Member State, regional, local and operator levels. 

The basis of continuous improvement is “plan-docheck-act”. 

Inspection and enforcement have already 

been running for several years at the European 

level, with IMPEL being one of the main promoters. 

Therefore it is time to check and review the work 

done to continue with the improvement for the 

future. The regulatory cycle has proved to be valid 

in planning inspections and will remain valid for the 

future with some adjustments. Therefore we will use 

this cycle as the starting point for this review. 

The regulatory cycle 

The cycle can be divided in several parts, the fi rst 

one being policy planning, legislation and permitting. 

It was perceived that there is a need for higher 

harmonisation and consistency of the inspection 

at the European level. The main tools needed 

to reach these objectives are; the review of the 

Recommendation by the European Council and the 

Parliament, the support to European networks such 

as IMPEL and the implementation of the activities 

which have already started in the area of better 

legislation/permits. 

The second part of the regulatory cycle is compliance 

assessment and promotion. This was the core of the 

session and the efforts were concentrated on the 

improvement of when and why should the inspections 

be done “doing the right things”, who should perform 

them and how. These points will be discussed in 

more detail below. 

67 


Mr. Jesus Angel Ocio (Spain) 

Report from Workshop on Inspection and Enforcement for the Future 


Rapporteur: Mr. Jesus Angel Ocio (Spain) 

Enforcement is the third part of the cycle. One 

point to be considered in the future is the for a legal 

network, parallel or within. Another issue to look 

at is better coordination on the interface between 

assessment and enforcement. Finally, a common 

future objective for all the parts of the cycle was 

addressed. This was a better communication and 

dissemination of the information related with the 

inspection and enforcement. 

In any case, it is very clear that the future of the 

inspection has to rely on the competence of the staff 

conducting them, its effi ciency, its effi cacy and its 

transparency. To ensure this, we have to be certain 

that “the right things are done right”. Instruments 

such as logic models can be helpful since they 

consider the quality parameters or indicators of the 

resources (staff, money, etc.) that are put into the 

system to perform the activities (inspections, analysis, 

etc.) in order to get intermediate results (better degree 

of compliance) and environmental outcomes (better 

quality of the environment). 

In this sense, several Member States have already 

started to use risk based management approaches 

to plan/program inspections. The most extended 

approach is based on the screening and classifi cation 

of the operators taken into account the following 

attributes related to the risk: 

- complexity of the installation, 

- location of the site: proximity to population, 

environmentally sensitive areas, etc., 

- emissions to air, water and soil, 

- environmental management, and 

- compliance with environmental law. 

Regarding who should conduct the inspections, a 

detailed technical, economical and legal assessment 

was presented. The options considered went from the 

inspection performed only by public administration 

to its delegation to private entities. An intermediate 

point that is applied in several Member States is 




the delegation of some technical controls (e.g. air 

emissions analyses), under certain limitations and 

supervision by the public administration. Neither full 

nor zero delegation seems to be the best solution. The 

optimal combination of the different options depends 

on the Member State or inspecting organisation 

with a trend to recognise the role and responsibility 

of the operator, by promoting self-monitoring/selfcontrol. 

This can encourage continuous compliance 

assessment. 

When it comes to how the inspections should be done 

in the future, new approaches taking the advantages 

of technical competence and communication skills 

can be foreseen. Traditional approaches will remain 

valid in the future and some developments will be 

needed in the detailed inspection procedures to 


IMPEL Review Initiative (IRI) (Sweden) 

• The aim is to promote best practice and offer advice 

on inspectorates and inspection procedures and 

fi ndings are “Good Practices” and “Opportunities for 

Development”. 

• The Review Team was impressed and concluded 

that the Swedish system works well. 

• Dissemination widely by press-releases, articles, 

website, IRI-workshop and conferences. 

• There have been a number of follow up activities in 

Sweden. 

• IRI methodology may be used for reviews between 

Swedish sister authorities. 



68 

ensure their Quality Assurance and Quality Control. 

The IMPEL Review Initiative has proven to be a very 

helpful tool in this area, increasing the harmonisation 

and consistency of the inspection in Europe. 

However, illustrative examples of how communication 

skills can infl uence the response by the operator 

were shown. If the inspection authority “takes it 

easy”, the operator will continue doing business as 

usual. If it uses methods based on sanctions without 

communication, the operator will only react to the 

actions of the inspector. However, if communication 

skills are used, inspectors can convince and get 

an active answer when acting with low level 

of competence and a proactive response when 

negotiating with high level of it. 

Report Workshop on Recently Completed IMPEL Projects 

Chairman: Mr. Gernot Schnabl (European Commission) 

Rapporteur: Mr. Steen Fogde (Denmark) 

• Follow up ideas for new projects were discussed in 

IMPEL Cluster 1. 

• In summary it was a very useful process, it takes 

time, but it’s worth the effort. 

Inspectan report – environmental inspection 

guidelines for the tanning industry (Italy) 

• There are four main parts in the report: economy 

and production, environmental aspects, legislation, 

guidelines and recommendations. 

• Two different approaches, indirect and site specifi c, 

depending on how many, how big and how remote 

the production sites are.

• Planning inspections - identify critical aspects of the 

product and process of the tanning cycle. 

Solving environmental problems through 

neighbourhood dialogue (Germany) 

• 17 countries participated. 

• Based on experience from chemical industry having 

dialogue with neighbours. 

• Informal and voluntary method, can create winwin 

situations, but cannot replace usual task of 

authorities. 

• Equal partners, all relevant groups must be 

involved, enable direct communication, building 

trust, this leads to increased environmental 

performance, anyone can ask questions and will get 

answers. 

• Key factors are the willingness to cooperate, to 

negotiate and to act. 

69 


Doing the right things (The Netherlands) 

• Prioritising inspections - RMCEI does not include 

recommendations on how to prioritise. 

• 23 countries + Commission + IMPEL secretariat 

participated. 

• Questionnaire results showed very inconsistent 

prioritising methods from day-to-day at one end and 

scientifi c based prioritising at the other. 

• The project was an important fi rst step to fi nd tools 

for prioritising inspection strategies. 

EU emission trading scheme (United Kingdom) 

• Harmonization of its implementation across the EU 

25 is a key element in order to strengthen both its 

credibility and its role in the market. 

• It included monitoring & reporting, verifi cation, 

compliance & enforcement and small installations. 

• The results of the project will be useful not 

only to Competent Authorities responsible for 

implementation of the EU ETS, but also to newer 

Member States joining the scheme, and to the 

European Commission in its evaluation of the fi rst 

year of operation of the scheme. 




Ms. Ana Garcia (Portugal) 

There were about 50 participants in this workshop. 

The presentations and discussions showed that 

Environmental Administration is in permanent 

evolution and establishing new strategies to promote 

effi cient ways to achieve goals. 

1. Highlights from presentations 

Belgium, Mr. Jean Pierre Janssens 

The enforcement and compliance strategy in Brussels 

Capital Region is based on pollution prevention and 

thus change mentality and promote compliance. 

For example, to fi ght pollution at source instead of 

at “the end of pipe”. It is important to check and 

assure compliance and also to promote compliance, 

for example, to have dialogue, to motivate and to 

convince. This strategy is particularly important 

because in this region there are many small and 

medium enterprises that are usually characterised 

by lack of fi nancial and human resources and lack of 

knowledge of legislation. 

Dialogue is not always strong enough in face of 

some operators, so there is a legal framework for the 

investigation; reporting, prosecuting and sanctioning 

of environmental infringements. This legal framework 

establishes that Public Prosecutors (PP) have six 

months to act upon a prosecution report, if after that 

time period the PP has not a decision or has decided 

not to prosecute the Environmental Administration 

can start an Administrative fi ne procedure. 

Netherlands, Mr. Arthur Faber 

The Netherlands have a new intervention strategy. 

The main objective is to defi ne the problem, defi ne 

the goals, defi ne the Target Group, defi ne the strategy 

and to defi ne an effective intervention. 

Previously there was a target group analysis, based 

on the Table of Eleven factors; factors that infl uence 

behaviour. That includes understanding of the rule, 

cost and benefi ts, non offi cial control, risk of being 

reported/inspected/detected/sanctioned and severity 



Report from Workshop on Enforcement Strategies and Approaches 


Rapporteur: Ms. Ana Garcia (Portugal) 

70 

of sanction. There are fi ve target group defi nitions, 

which can go from “spontaneously complying” to 

“consciously violating”. 

For the Netherlands, enforcement is not a goal in 

itself but an important instrument to achieve goals 

like improving compliance, improving behaviour and 

changing the culture in an organisation at all levels. 

Germany, Mr. Franz Grassmann 

Mr. Grassmann stated that there is a “confl ict of 

interest” between operators and administration, 

meaning that operators want to make profi ts and 

administrators want to protect the public interest, 

protect the environment and to create and keep jobs. 

Both Public Prosecutors (PP) and Environmental 

Administrations (EA) have tasks in the defence of 

public interest. PP have to prosecute environmental 

crimes, bring them to court and punish the offender. 

EA has to close a non-compliance situation and to 

bring it to a compliance status. 

Different sanctions can be applied by EA for instance 

orders, fi nes, sending information to the prosecutor. 

Different measures of coercion can be applied by EA, 

for instance penalty payment, substitute performance, 

coercive detention, and direct coercion as, for 

example, the sealing of an installation. 

England and Wales, Mr. Martin Quinn 

When an infringement to the law has been detected 

the Environmental Administration (EA) has to take 

some action that has to be based on principles 

of proportionality, consistency, transparency and 

targeting. 

The measures to assure compliance, can include 

discussion/persuasion to permit revocation, depending 

on factors like environment effect of offence, intent of 

offender, attitude of offender, history of offender. 

Measures of enforcement and application of sanctions 

can go from persuasion, the emission of a warning, 

application of a fi ne, community service or even the 

application of criminal law that can result in prison.

There are now some new proposals in EA, that 

include the review of existing criminal and 

enforcement notice powers, the review level of fi nes, 

special courts for environmental infringements, and 

due diligence versus strict liability. 

Sweden, Ms. Anna Tiberg 

In 1999 a new unifi ed Environmental Code was 

adopted in Sweden. Shortly after coming into force it 

was clear that the system of sanctions in this Code 

needed to be revised. This presentation showed the 

main principles that became important during this 

revision process, for instance; the choice between 

environmental sanction charges or criminal charges; 

penalties for the serious crimes and protecting the 

criminal system from infl ation. It also looked at 

tougher punishments for serious crimes through 

negligent behaviour and environmental sanction 

charges where infringements can be verifi ed without 

too much assessment of prerequisites. 

2. Key elements in the discussion 

The main subjects that were present in presentations 

and in the discussion included: 

- The need to set priorities in choosing installations to 

assure compliance of legislation, based on criteria 

like environmental risk, environmental reputation, 

compliance rates and pollution capability. 

- Prevention – use of dialogue to encourage 

compliance and change behaviour in organisations, 

as a long term tool that is effective especially in 

small installations that are usually characterised by 

lack of fi nancial and human resources and lack of 

knowledge of legislation. The use of these tools can 

be very important and effective but there are some 

risks that have to be avoided, for instance; giving 

technical advice when operators are responsible 

to choose technical solutions to comply with 

legislation. To defi ne a reasonable time period for 

the application of dialogue, if at the end if the period 

the operator doesn’t comply with legislation other 

sanctions must be taken to ensure the correction of 

the situation. 

71 


- Better regulation: enforceable legislation 

(and permits), that cannot lead to different 

interpretations. 

- Public Prosecutors and Judges play an important 

role. It is necessary to ensure good coordination and 

that they are aware of environmental legislation. 

- Criminal Law: need to ensure there are effective 

tools to combat organised crime, for example in 

transboundary shipment of waste. 

3. Proposals - further IMPEL work 

A common project to be prepared by TFS Cluster 

and Cluster 1 on “Review of the sanction system and 

guidance to make sure that there is consistency”. It 

is important to ensure that in all countries there is a 

similar approach concerning the same infringement 

and that Environmental Administrations have the 

tools to guarantee that offences to environmental 

legislation are sanctioned in an effective way. This 

should be according to pre-established criteria and 

guarantee that the non-compliances are corrected. 

Benchmarking on “enforcement strategies and 

approaches”: it was clear during this session that 

there are many different approaches and that it would 

be very useful if we could learn with each other. 

Notes: The revision of the Recommendation on the 

minimum Criteria (RMCEI) should incorporate all 

relevant guidance on enforcement strategies and 

approaches The project “Review of sanction system 

and guidance to make sure that there is consistency” 

could give the necessary information for this. 

It is also important to take in account the new 

EU legislation on criminal law and environmental 

liability and also previous studies from the European 

Commission, IMPEL, OECD and other entities over 

this subjects. 



Session 10 | Keynote Speech and Conclusions | 29 September 2006 


Dear participants of the IMPEL Conference, 

We have experienced three busy working days of this 

European Environment Conference with the motto 

“IMPEL for Higher Environment Quality”. 

As I pointed out at the opening of the Conference, 

IMPEL represents the result of successful activities of 

many years, demonstrating its essence: the exchange 

of practical work experience and information among 

environmental specialists of European countries. 

IMPEL that originated as a cooperation mechanism 

for environment inspectors, has developed into 

a widespread network among parties involved in 

the fi eld of environment protection. The European 

network has created national IMPEL networks. 

In addition, I clearly see that the exchange of 

information and sharing of experience is useful for 

everyone, as environment protection involves many 

people and various spheres of life. Therefore, in 

the future IMPEL should serve as a mechanism 

that fosters the implementation and enforcement 

of European legislation. Certainly, it has to provide 

effective and modern solutions that bring us towards 

the achievement of common goals. 

Our network has expanded both in terms of contents 

and new countries; it also cooperates with similar 

cooperation networks from various European regions, 

such as ECENA, REPIN from various European 

regions. It is important that we continue the 

promotion of such cooperation in the future. 

During the Conference special interest was devoted to 

issues related to the preparation and issue of permits, 

as well as further application of practical inspection 

methods. 



Closing speech 


72 

The focus is a simplifi ed, more precise procedure 

in order to reduce time required for the preparation 

of permits, on the one hand, and to improve the 

quality of permits, on the other hand. To fulfi l 

this aim, cooperation among all interested parties 

– applicants, permit issuance institutions, the society 

and environment protection control institutions - is 

essential. One needs to employ all available resources 

and modern technologies, information from the best 

available technical facilities (BAT and BREF), as well 

as the environmental impact assessment. 

Inspection methods are an important issue and the 

Conference agenda and the vast interest about this 

theme clearly demonstrates this. Implementation 

monitoring, with an aim to defi ne how the provided 

permit conditions are complied with, can be 

carried out in various manners; however, it has to 

be systematic, complex and economically effi cient 

by balancing the available resources. The IMPEL 

network’s implemented projects and the projects 

planned for the future can contribute to that goal. 

Sanctions are used as a method in cases when 

environment law is ignored or violated. Each of 

European countries brings in different experience in 

respect of which methods are effective (penalties, 

annulment of permits etc.), and during the 

Conference we had a wonderful opportunity to share 

this experience. I agree to a speaker of a task group 

who pointed out that the IMPEL network could 

facilitate the use of a more unifi ed approach in this 

sphere. 

Mr. Ladislav Miko presented the vision of the 

European Commission about the IMPEL network’s

further development. As IMPEL is a wide 

representation of environmental specialists from all 

over Europe, it can contribute to the very topical 

work of the European Commission on drafting 

of better legislation. Environment inspectors and 

other practitioners, who work on a daily basis at 

the implementation of environmental law have the 

possibility to offer suggestions and recommendations 

how to improve the existing legislation in Europe in 

order to foster the improvement of environment’s 

quality and so that environment protection is not 

regarded as an obstacle for economic development. 

The Riga Conference also included a special 

work session that focused on proposals for the 

improvement of legislation by looking at various 

legislative acts and how to link them together. I do 

hope that the European Commission will take into 

account these proposals in its further work of the 

advancement of legislation. The cooperation between 

IMPEL and the European Commission will continue. 

Environmental law ensures the execution of strategic 

goals and tasks of the European Union. We carry out 

the Sixth Environment Action Programme and actively 

invest our capacity and resources in the development 

and implementation of thematic strategies. We 

discussed very topical themes, such as climate 

changes, transboundery movement of waste, water 

reservoirs management etc. I would like to point out 

that in the future we also need to pay attention to 

aspects of the preservation of biological diversity and 

search for effective control mechanisms for solutions 

of nature protection in this area. 

At the end of the Conference I would like to thank all 

people, who worked with great enthusiasm and high 

Session 10 | Keynote Speech and Conclusions | 29 September 2006 

73 

sense of responsibility for almost a year to work out 

this Conference programme, namely, the Conference’s 

“Preparation Committee”, which consists of 

representatives of various countries and experienced 

environmental specialists. 

My profound gratitude is addressed to Hilda Farka 

from the European Commission, Ed Eggink from the 

Netherlands, Andreas Wasielewski from Germany and 

Trerence Shears from the United Kingdom. 

The participants and guests of this Conference had 

a wonderful opportunity to hear a large variety of 

excellent examples from our colleagues, and they will 

serve us as inspiration for further work. 

I would like to render my thanks to all chairs of 

plenary meetings and sessions and their reporters; 

and I dare not forget our speakers who prepared their 

presentations in order to share their information and 

experience with us. 

One cannot imagine an international conference 

without a professional team of interpreters, which 

is ready to react to spontaneous deviations from our 

carefully drafted speeches. Therefore I would like to 

say special thanks to all interpreters who worked at 

the conference. 

I would like to express thanks to everyone once 

again, who actively participated and fostered that this 

event could run successfully and effi ciently, and I will 

follow up further development of IMPEL with a great 

interest. 



Conclusions and Recommendationsa 



Introduction to the Conclusions and Recommendations 

High priority is given to the implementation and enforcement of environmental law by the 

Commission and European Parliament. IMPEL is one of the principal mechanisms that can assist 

in this process. 

Throughout the conference, both during the workshops and in the plenary sessions, it was clear 

that IMPEL fulfi ls an important role. The European Commission, acknowledging the good work 

that IMPEL had already done, invited the network to build on its current activities on improving 

permitting, inspections and enforcement and in the fi eld of transfrontier shipments of waste. It 

also encouraged IMPEL to continue feeding back to policy makers the practical experiences of 

its members on the practicability and enforceability of EU Environmental law. In particular the 

European Commission invited IMPEL to contribute to the review of the Recommendation on 

Minimum Criteria for Environmental Inspections (RMCEI) and to continue its work on the review 

of the Integrated Pollution Prevention and Control (IPPC) directive. 

Climate change is recognized as a major environmental challenge. IMPEL is already carrying 

out projects which will have an impact on climate change, for example, assisting in the 

implementation of the EU ETS trading scheme. It will examine the potential for carrying out 

further projects to help tackle this problem. 

Strategic planning, by means of the adoption of the Multi annual work (MAWP) programme 

2007-2010, should also help IMPEL to meet LIFE+ requirements. The reviewed MAWP should 

be fi nalised by the end of 2006. 

74

Better Regulation 

The matter of practicability and enforceability of legislation is of particular importance. 

Enforcement authorities have limited resources and are keen to achieve maximum compliance 

with minimum enforcement efforts. Issuing single, integrated permits that even go beyond what 

the IPPC directive requires and simplifying and codifying legislation can be instrumental to this 

result, and IMPEL can support a further exchange of good practices in these fi elds. 

IMPEL believes it can have a role in the regulatory cycle by providing practical knowledge and 

insights in the process of developing new legislation or reviewing existing legislation. IMPEL can 

use its members’ experiences to assess EU Environmental legislation with the aim of identifying 

practicability and enforceability problems. The checklist on practicability and enforceability that 

has been developed by IMPEL can serve as a useful tool in this respect. 

IMPEL can highlight the need for harmonisation of legislation, for example where defi nitions are 

concerned. IMPEL can also draw attention to the interaction between legislative acts and the 

need for competent national authorities responsible for implementation to apply the different 

legal acts in an integrated, effi cient way. 

Some new members of the European Community are concerned that stakeholders experience 

problems resulting from the rapid transposition of EU legislation in their countries. They 

argued that in some cases industry was concerned about the lack of transparency in the 

transposition and implementation procedures, and found the resulting laws rigid, burdensome 

and anti-competitive. It was suggested that IMPEL could help to improve the perception of the 

environmental legislation concerned. 

75 







Permitting 

The IMPEL network identifi ed that there is scope for greater effi ciency in permitting and 

permitting procedures. The main priorities for working in this fi eld should be streamlining the 

permit procedure, reducing the workload on permit writers, improving the quality of permits and 

using IT tools more effectively. 

The IMPEL network should work with the European Commission to assess the possible practical 

permitting diffi culties which might arise from the interaction between the IPPC-directive and 

other directives (large combustion plants, waste incineration and solvents emissions directives). 

The key questions are: whether these differences lead to practical permitting diffi culties; and 

whether these pieces of legislation need to be streamlined and, if so, how. 

The permitting procedures should be consistent at all administrative levels, national, regional 

and local. Inconsistencies in these procedures could result in an uneven playing fi eld for industry. 

Permitting authorities should be provided with specifi ed resources (guidance – similar to BREF’s; 

template permit conditions; training for new inspectors; databases of legislation, past decisions 

and incidents; networking within and between authorities; appropriate technical/legal support). 

The importance of public consultation, including with NGO’s, during permitting procedures was 

recognized. Reference was also made to complementary tools for greening industries, such as life 

cycle analysis and green procurement. 

76

Inspection 

IMPEL is one of the main promoters of continuously improving inspection and enforcement in 

order to achieve a high level of protection of the environment. Future work in this fi eld needs to 

take place at all different levels, that is, European, Member State, regional, local and operator 

level. 

At the time when the Recommendation on minimum criteria for environmental inspections is 

being reviewed, it is appropriate to look at the work that has already been done in order to achieve 

continuous improvement in the future: 

• There is a need for a greater consistency of data collection in order to help compare 

environmental inspections at the European level. This objective can be achieved by sharing 

experience through European networks, such as IMPEL, which would also help in identifying 

current good practice. 

• There is potential for further improving inspection planning as described in the IMPEL project 

“Doing the right things”. Computer software can assist in this process. 

The quality of future inspections relies on the competence of the staff conducting them, their 

effi ciency and the extent to which they work in a transparent way. 

The use of risk-based management approaches to plan inspections was suggested as a method 

for achieving good practice in inspections. A good example of this approach is based on the 

classifi cation of operators taking into account defi ned criteria related to the risk. 

The operator has a role in achieving compliance through carrying out self-monitoring. 

Quality Assurance and Control mechanisms should be promoted. The IMPEL Review Initiative 

has proved to be a very helpful tool in increasing the consistency of approaches to inspections in 

Europe. 

77 







Networking 

Networking plays an important role in the exchange of information between different regulatory 

authorities and in identifying good practice. 

National IMPEL Networks are organized at national, regional and local levels, involving different 

authorities. From the IMPEL viewpoint one of the main tasks of these National networks is to 

act as a channel for disseminating IMPEL projects and reports, to exchange information on 

IMPEL activities, to fi nd people to attend IMPEL projects and to propose new projects. Almost 

all IMPEL products are available only in English, which causes problems in some countries in 

fi nding people to participate in the projects, in preparing and presenting new projects and even 

in understanding the project reports. 

Topical Networks focus their work on particular issues. IMPEL TFS coordinates actions in 

seaports between Member States to enforce the Waste Shipment Regulation in order to prevent 

illegal shipments of waste and to work towards a level playing fi eld. The new Waste Shipment 

Regulation (WSR) introduces obligatory international enforcement collaboration, which 

underlines the importance of TFS. 

GreenEnforce network deals with the implementation and enforcement of nature conservation 

and forestry legislation. There is a need for IMPEL to co-operate effectively with Topical 

networks. 

IMPEL should cooperate with other environmental networks such as the Environmental 

Compliance and Enforcement Network for Accession (ECENA), the Regulatory Environmental 

Programme Implementation Network (REPIN) and the International Network for Environmental 

Compliance and Enforcement (INECE). Further cooperation could be based on carrying out joint 

projects. 

78

Enforcement Strategies and Approaches 

Enforcement is an important instrument in achieving goals like improving compliance and 

behaviour and in changing the culture in an organization at all levels. It is important to develop 

enforcement strategies and approaches to help achieve continuous improvement and they should 

be based on principles of proportionality, consistency, transparency and targeting. 

In that context, priority setting can refl ect a risk-based approach based on different criteria, such 

as environmental risk, environmental reputation and compliance history. 

The potential use of dialogue as a tool to encourage compliance and change behaviour in 

organizations should be considered as it could be an effective tool over the longer term. This is 

especially true for small installations, which are usually characterized by a lack of fi nancial and 

human resources and a lack of knowledge of legislation. 

The success of enforcement was recognized as depending notably on the quality of legislative 

and permitting systems. 

The identifi cation of different enforcement strategies and approaches in Member States 

showed the potential value of creating a common approach concerning the same infringement. 

The common approach should guarantee that offences against environmental legislation are 

sanctioned in an effective way, and should guarantee that the non-compliances are corrected. 

IMPEL should promote communication with Public Prosecutors and Judges in order to make 

them aware of their important role in the enforcement chain. 

The outcome of the project “Comparison Programme on Sanction Systems and Guidance to 

Make Sure that There is a Consistent Approach”, could be taken into account in developing 

enforcement strategies and approaches. 

The new waste shipment regulation contains a new obligation requiring Member States to 

cooperate in order to facilitate the prevention and detection of illegal waste shipments. There is a 

clear potential role for IMPEL here. 

79 




IMPEL Conference 2006 in Riga (Latvia) 

27-29 September 2006, Riga (Latvia) 

Last Name/ 

First Name 

Austria 

Jungwirth 

Andrea 



Organisation Position Address Telephone / Fax / E-mail 

Federal Ministry of 

Economics and Labour 

Ministry of Forestry, 

Petek Waltraud Agriculture, Environment 

and Water Management 

Pucker Barbara Government of the Province 

of Carinthia 

Belarus 

Yanush Marina Ministry of Natural 

Resources and 

Environmental Protection 

Belgium 

Bernaert Paul Environment Inspection 

Division Flemish Region 

Janssens Jean- 

Pierre 

Brussels institute for 

the Management of the 

Environment 

Merz Régine Walloon Region 

- Environment Police 

Department 

Walgrave Pascal Walloon Region 

- Environment Police 

Department 

Bulgaria 

Malinov Boyko Ministry of Environment and 

Water 

Milova Eolina Ministry of Environment and 

Water 

Savov Nikolay Ministry of Environment and 

Water 

Croatia 

Blažević-Perušic 

Josip 

Ministry of Environment 

Protection, Physical 

Planning and Construction 

Damir Rumenjak Ministry of Environment 



Nećak Jasenk Ministry of Environment 



Paladin-Popović 

Jana 

Ministry of Environmental 



Pašalić Vlast Ministry of Environment 



Pokrovac 

Patekar Anita 




Legal Expert Stubenring 1, 1010, Vienna, 

Austria 

Head of Department Stubenbastei 5, A 1010, 

Vienna, Austria 

Head, Water Act Authority Miestaler Strasse 1, A-9020, 

Klagenfurt, Austria 

Deputy Head, Legal and 

Personnel Department 

80 

10, Kollektornaya St., 

220048, Minsk, Belarus 

Inspector Koning Albert II-Laan 20, 

Brussels, 1000, Belgium 

Director-Head of Division 

Inspection 

Gulledelle 100, 1200, 

Brussels, Belgium 

Inspector Avenue Reine Astrid 39, 5000, 

Namur, Belgium 

Inspector Chaussee de Binche 101, 

7000, Mons, Belgium 

Head, Industrial Pollution 

Prevention Department 

Executive Head, European 

Integration Unit 

67 W. Gladstone Str., 1000, 

Sofia, Bulgaria 

22 Maria Louisa Blvd., 1000, 


Chief Expert 67Q Gladstone Str., 1000, 


State Secretary Vinogradska 25, 10 000, 

Zagreb, Croatia 

Head of Division, 

Department for EIA 

Head, Air Protection 

Department 

Ul.Republike Austrije br.14, 

10 000, Zagreb, Croatia 

Ul.Republike Austrije br.14, 

10 000, Zagreb, Croatia 

Head Inspector Vinogradska 25, 10 000, 


Senior Environmental 

Inspector 

Vinogradska 25, 10 000, 


Head of Section Vinogradska 25, 10 000, 


List of participants 

+43 1 71100 5811 

+43 1 714 2718 

andrea.jungwirth@bmwa.gv.at 

+43 1515222123 

+43 1 51522 7122 

waltraud.petek@lebensministerium.at 

+43 0505 36 30811 

+43 0505 36 30800 

barbara.pucker@ktn.gv.at 

+375 172 002 767 

+375 172 005 583 

yanush-maryna@tut.by 

+32 0 2 553 81 97 

+32 0 2 553 81 95 

paul.bernaert@lin.vlaanderen.be 

+322 775 7501 

+322 775 7505 

jpj@ibgebim.be 

+32 81 71 5330 

+32 81 71 5333 

r.merz@mrw.wallonie.be 

+32 6532 0474 

+32 6532 0480 

p.walgrave@mrw.wallonie.be 

+359 2 940 6035 

+359 2 981 3398 

malinov@moew.government.bg 

+359 2 9406153 

+359 2 980 3547 

e_milova@moew.government.bg 

+359 2 940 6019 

+359 2 981 3384 

nsavov@moew.government.bg 

+385 1 3712 714 

+385 1 3712 713 

josipa.blazevic-perusic@mzopu.hr 

+385 1 3782 197 

+385 1 3782 157 

damir.rumenjak@mzopu.hr 

+385 1 3782 137 

+385 1 3782 157 

jasenka.necak@mzopu.hr 

+385 137 127 85 

+385 137 127 13 

jasna.paladin.popovic@mzopu.hr 

+385 1 3712 786 

+385 1 3712 713 

vlasta.pasalic@mzopu.hr 

+385 1 3712 797 

+385 1 3712 713 

anita.pokrovac.patekar@mzopu.hr

Cyprus 

Adonis Pais Department of Labour 

Inspection 

Georghiades 

Stelios 

Hadjipanayiotou 

Costas 

Czech Republic 

Kroutilová 

Marcela 

Department of Labour 

Inspection 

Cyprus Environmental 

Service 


EU Department 

Labour Inspection Officer 12 Apellis, 1493, Nicosia, 

Cyprus 

Labour Inspection Officer 12 Apellis, 1493, Nicosia, 

Cyprus 

Environment Officer, 

Chief Inspector 

Kružíková Eva Ministry of Environment Director, Legal 

Department 

Kyjovský Štěpán Municipality of Prague Head of IPPC and SEA 

Section, Environmental 

Department 

Němcová Lenka Czech Environmental 

Inspectorate 

Pelc Lubomir Czech Environmental 

Inspectorate 

Valta Jiri CENIA, Czech Environmental 

Information Centre 

81 

Ministry of Agriculture, 

Natural Resources & 

Environment 

1411, Nicosia, Cyprus 

Referent Vršovicka 65, 100 10, 

Prague, Czech Republic 

Directore Office- 

International 

Co-operation 

Vršovicka 65, 100 10, 

Prague, Czech Republic 

Marianske Namesti 2, 

110 01, Prague, Czech 

Repulic 

Na Brěhu 267, 190 00, 

Prague 9, Czech Republic 

inspector Lieberzeitova 14, 614 00, 

Brno, Czech Republic 

Head of Centrum, BAT 

Department 

Kodanska 10, 110 00, 

Prague 10, Czech Republiuc 

Denmark 

Andersen Keld Vejle County Head of Division Damhaven 12, 7100, Vejle, 

Denmark 

Christensen Ole 

Winther 

Country of West Zealand Environmental 

Administrative concerning 

Industrial Issues 

Christensen Per Aalborg University Professor Fibigerstrade 13, 9220, 

Aalborg OE, Denmark 

Fogde Steen City of Ellsinore Head, Environmental 

Protection Department 

+357 22 405 699 

+357 22 663 788 

apais@dli.mlsi.gov.cy 

+357 22 40 56 33 

+357 22 663 788 

sgeorghiades@dli.mlsi.gov.cy 

+357 22 303 854 

+357 22 77 49 45 

chadjipanayiotou@ 

environment.moa.gov.cy 

+420 267 122 045 

+420 271 734 221 

marcela_kroutilova@env.cz 

+420 267 122 889 

+420 267 311 596 

eva_kruzikova@env.cz 

+420 236 004 214 

stepan.kyjovsky@cityofprague.cz 

+42 0 222 860 283 

+42 0 283 892 662 

nemcova@cizp.cz 

+420 545 545 119 

+420 545 545 160 

pelc@bn.cizp.cz 

+420 724 503 838 

+420 267 225 299 

+420 271 742 306 

jiri.valta@cenia.cz 

+457 583 5333 

+457 583 5571 

kan@vejleamt.dk 

Alleen, 4180, Soroe, Denmark +455 787 2939 

+455 787 2800 

Moerdrupvej 15, 3060, 

Espergaerde, Denmark 

Jokumsen Vita Vejle Municipality Engineer Kirketorvet 22, 7100, 

Vejle, Denmark 

Jorgensen Brenntag Nordic Environmental Manager Strandvejen 104 A, 2900, 

Flemming 

Hellerup, Denmark 

Larsen Karin Frederikssund Kommune Environmental Inspector Industrildeddet 3B 1. sal, 

4000, Roskilde, Denmark 

Mortensen Jens Solrod Kommune, Teknisk Environmental Inspector Solrod Center 1, 2680 Solrod 

Peter 

Administration 

Strand, Solrod, Denmark 

Thystrup 

Copenhagen County Environmentalist Stationsparken 27, 

Knudsen Lene 

DK - 2600, Glostrup, 

Copenhagen, Denmark 

Zornow Asger Municipality of Gentofte Environmental Officer Bernstorffsvej 161, 

DK - 2920, Charlottenlund, 


owc@vestamt.dk 

+459 635 832 6 

+459 815 378 8 

pc@plan.aau.dk 

+454 928 250 6 

+454 928 241 6 

sfo55@helsingor.dk 

+457 644 510 9 

vitjo@vejle@dk 

+454 329 2762 

+454 329 2700 

flemming.jorgensen@ 

brenntag-nordic.com 

+454 736 658 6 

kla@frederikssund-kom.dk 

+45 561 822 41 

jpm@solrod.dk 

+454 322 2833 

+454 322 2866 

lethkn@tf.kbhamt.dk 

+453 998 0714 

+453 998 0722 

az@gentofte.dk 

asger@zornow.dk 



ECENA 

Dimovski Mihail The Regional Environmental 

Center for Central and 

Eastern Europe 

Glaser Rob RPS/EPTISA ECENA IMPEL 

project 

Zhechkov 

Ruslan 


The Regional Environmental 

Center for Central and 

Eastern Europe 


Senior Project Manager/ 

ECENA Secretariat 

CEO MAB Consultancy, 

the Netherlands 

Project Manageer/ECENA 

Secretariat 

Estonia 

Maran Himot Environmental Inspectorate Head, Development 

Department 

82 

9-11 Ady Endre, 2000, 

Szentendre, Hungary 

Asserlaan 7, 4334 EP, 

Middelburg, the Netherlands 

9-11 Ady Endre, 2000, 

Szentendre, Hungary 

Kopli 76, 10416, Tallin, 

Estonia 

Naruskberg Ave Environmental Inspectorate Senior Inspector Puuri tee 1, 63308, Polva, 

Estonia 

Roose Tarvo Environmental Inspectorate Deputy Director -General Kopli 76, 10416, Tallinn, 

Estonia 

Sepp Teet Environmental Inspectorate Head, Parnumaa Regional 

Department 


Bossenmeyer 

Grete 

European Commission, 

DG Environment 

Bucella Pia European Commission, 


DG Environment, 

Organizer 

Director, Communication, 

Legal Affairs&Civil 

Protection 

Kalda 1A, 80011, Parnu, 

Estonia 

BU-5 6/155, B- 1049, 


BU-9 2/202, B- 1049, 


Catinat Michel European Commission Head of Unit Av. d’Auderghem 45, 1040, 


Farkas Hilda European Commission IMPEL Secretariat BU-5 6/127, B- 1049, 


Garcia Burgues 

Julio 

Karamat Anna European Commission, 


Miko Ladislav European Commission, 


Paquot 

Alexandre 

Pirotte Charles European Commission, 


Schnabl Gernot European Commission, 


Wenning 

Marianne 

European Commission Head of Unit BU-9 1/185, B- 1049, 


Administrator BU-5 6/120, B-1049, 


Director BU-5 03/140, B- 1049, 


European Commission Avenue de Beaulieu 5 21/112, 

B-1160, 

European Commission, 



Administrator BU-5 6/153, B-1049, 


Principal Administrator Rue de la Loi 200, B-1049, 


Head of Unit DG Environment, B-1049 


Wessman Peter European Commission BU-5 5/178, B-1049, 


+36 26 506 052 

+36 26 311 294 

mdimovski@rec.org 

+311 186 258 10 

+311 186 175 91 

tops@zeelandnet.nl 

+36 26 506 052 

+36 26 311 294 

ruslan@rec.org 

+372 696 2238 

+372 518 5612 

+372 696 2237 

himot.maran@kki.ee 

+372 799 494 6 

+372 512 489 1 

+372 799 4946 

ave.naruskberg@kki.ee 

+372 696 2233 

+372 696 2237 

tarvo.roose@kki.ee 

+372 442 7522 

+372 442 7519 

teet.sepp@kki.ee 

+322 299 030 2 

+322 299 106 8 

grete.bossenmeyer@ec.europa.eu 

+322 295 709 9 

+322 296 787 0 

pia.bucella@ec.europa.eu 

+322 296 952 9 

+322 299 192 5 

michel.catinat@ec.europa.eu 

+322 295 137 6 

+322 299 106 8 

hilda.farkas@ec.europa.eu 

+322 296 876 3 

+322 299 107 0 

julio.garcia-burgues@ec.europa.eu 

+322 295 358 3 

+322 299 106 8 

anna.karamat@ec.europa.eu 

+322 298 723 7 

+322 295 389 2 

ladislav.miko@ec.europa.eu 

+322 299 613 0 

+322 298 886 8 

alexandre.paquot@ec.europa.eu 

+322 299 234 7 

+322 299 106 8 

charles.pirotte@ec.europa.eu 

+322 299 272 5 

+322 299 031 3 

gernot.schnabl@ec.europa.eu 

+322 295 594 3 

+322 298 886 8 

marianne.wenning@ec.europa.eu

European Environmental Bureau 

Scheuer Stefan European Environmental 

Bureau 

EUROPOL 

Ijsselstijn 

Raymond 

Finland 

Antero 

Honkasalo 

Hietamaki 

Markku 

Kantola Erkki Northern Finland 

Environmental Permit 

Authority 

EU Policy Director Boulevard de Waterloo 34, 

B-1000, Brussels, Belgium 

EUROPOL Analyst PO Box 90850, 2509 LW, The 

Hague, the Netherlands 

Ministry of the Environment Director, Environmental 

Protection in Industry and 

Trade 

83 

Kasarmink 25, Po Box 35, 

FIN- 00023, Government 

Finland, Helsinki, Finland 

Ministry of the Environment Environmental Counsellor Kasarminkatu 25, 00101, 

Helsinki, Finland 

Environmental Counsellor P.O.Box 113, FIN-90101, Oulu, 

Finland 

Kekki Maria Ministry of the Environment Attache EU Affairs P.O.Box 35, 00023 

Government, Finland 

Koivula Sami Northern Finland 

Environmental Permit 

Authority 

France 

Blanc Patricia Ministry of Ecology and 

Sustainable Development 

Presenting Official Isokatu 14, 90101, Oulu, 

Finland 

Chief of the Industrial 

Environmental Service 

Bois Pierre DRIRE Alsace Head of Regional Service 

of Environmental 

Inspection 

Bonneville 

Annick 

Huart 

Christophe 

Marsille 

Christine 

Ministry of Ecology and 

Sustainable Development 

Chief of the 

Environmental Inspection 

Bureau 

DRIRE Haute Normandie Senior Environmental 

Inspector 

DDSV del’Ain Chef de Serve 

Environment 

Senior Environmental 

Inspector 

Pitrat Didier DRIRE Ile de France Senior Environmental 

Inspector 

Servant Ludovic DDSV du Nord Inspecteur des 

Installations Classees 

Georgia 

Jinoria Irakli Ministry of Environmental 

Protection and Natural 

Resources 

Mumladze 

Ketevan 

Ministry of Environmental 

Protection and Natural 

Resources 

Germany 

Bobzien Lars Department of Labour and 

Environmental Inspection 

20 av de Segur, 75302, Paris 

07SP, France 

1 Rue Pierre Montet, 67082, 

Strasbourg, France 

20 av de Segur, 75302, Paris 

07SP, France 

48 Av Denfert Rochereau BP 

59, 76 084, Le Havre 

Cedax, France 

+322 289 130 4 

+322 289 109 9 

stefan.scheuer@eeb.org 

+317 035 310 10 

+317 030 254 50 

ijsselstijnr@europol.eu.int 

+358 0 9160 39 345 

+358 0 9160 39453 

antero.honkasalo@ymparisto.fi 

+358 916 039 703 

+258 916 039 453 

markku.hietamaki@ymparisto.fi 

+358 400 892 001 

+358 204 906 499 

erkki.kantola@ymparisto.fi 

+358 9 160 39687 

+358 9 160 39453 

maria.kekki@ymparisto.fi 

+358 40 525 6778 

+358 20 490 6499 

sami.koivula@environment.fi 

+33 1 42 19 14 40 

+33 1 42 19 14 67 

patricia.blanc@ecologie.gouv.fr 

+33 3 88 25 92 40 

+33 3 88 36 98 13 

pierre.bois@industrie.gouv.fr 

+33 1 42 19 14 44 

+33 1 42 19 14 67 

annick.bonneville@ecologie.gouv.fr 

+33 2 35 19 32 75 

+33 2 35 19 32 39 

christophe.huart@industrie.gouv.fr 

Chemie de la Miche, France +33 4 74 45 61 90 

+33 4 74 45 00 75 

christine.marsille@agriculture.gouv.fr 

6495 203 Las Sheman Bro, 

9500 Gergy, France 

105 Rue Philippe de Comines, 

59 000, Lille, France 

Head of Legal Division 6, Gulua St. 0114, Tbilisi, 

Georgia 

Chief Specialist 6, Gulua St. 0114, Tbilisi, 

Georgia 

Inspector Am Listholze 74, 30177, 

Hannover, Germany 

+33 1 34 41 58 71 

+33 1 34 41 58 60 

didier.pitrat@industrie.gouv.fr 

+33 3 20 29 98 71 

+33 3 20 29 98 75 

ludovic.servant@agriculture.gouv.fr 

+995 322 757 64 

+995 329 883 08 

kmumladze@yahoo.co.uk 

+995 322 757 64 

+995 329 883 08 

kmumladze@yahoo.co.uk 

+49 511 9096 116 

+49 511 9096 199 

lars.bobzien@ 

gaa-h.niedersachsen.de 



Bolwerk Richard Regional Council Muenster Chief Environmental 

Officer 

Buether Horst Environmental State Office 

Cologne 

Feldmann 

Wolfgang 


Staatliches Umweltamt 

Herten 

Froben Martina Federal Ministry for the 

Environment, Nature 

Conservation and Nuclear 

Safety 

Grassmann 

Franz 

Holzgraefe 

Gisela 

State Office for the 

Environment 

Brandenburg 

Staatliches Umweltamt 

Itzehoe 


84 

Domplatz 1-3, 48128, 

Muenster, Germany 

Head of Office Blumenthalstr. 33, 50670, 

Koeln, Germany 

Chief Officer Gartenstr. 27, 45699, Herten, 

Germany 

Government Employee, 

responsible for IMPEL 

Head of the Section 

for Supervision of 

Installations 

Alexanderplatz 6, 10178, 

Berlin, Germany 

Am Baruther Tor 12, 15806, 

Zossen, OT Wuensdorf, 

Germany 

Head of Authority Breitenburger Strasse 25, 

25524, Itzehoem, Germany 

Kruber Helmut Ministry of the Environment Referent Schwannstrasse 3, D-40190, 

Dusseldorf, Germany 

Maurer Ulrich Ministry for the Environment 

Baden-Wurttemberg 

Wasielewski 

Andreas 

Greece 

Dermitzakis 

Ioannis 

Ministry of Agriculture, 

Environment and Rural 

Areas 

Officer, IPPC directive Kernerplatz 9, 70182, 

Stuttgart, Germany 

Head, Environmental Law 

Division 

Mercatorstrasse 3, 24106, 

Kiel, Germany 

Environmental Inspectorate General Inspector 1-3 Kifisias Ave., 11523, 

Athens, Greece 

Psaila Angeliki Ministry of Environment 


Planning and Public Works, 

Special Environmental 

Service 

Titopoulou 

Athina 

Toleris 

Epaminondas 

Tryfona- 

Panagopoulou 

Vasiliki 

EIA/SEA Expert 11 Alexandras Av., Gr-11473, 


Environmental Inspectorate Inspector Andrianoupoleos 24, 55 133, 

Thessaloniki, Greece 



Planning and Public Works, 

Special Environmental 

Service 



Planning and Public Works 

Hungary 

Babcsany Ildiko National Inspectorate for 

Environment, Nature and 

Water 

Varga Pal National Inspectorate for 

Environment, Nature and 

Water 

Ireland 

Clinton Frank Environmental Protection 

Agency 

Director, Special 

Environmental issues 

Chemical Engineer, 

Head of Department of 

Industries 

11 Alexandras Av., Gr-11473, 


147 Patission Str., 11251, 


Head, IPPC Department Meszaros Str. 58/A, H-1016, 

Budapest, Hungary 

Head of Department Meszaros utca 58, H-1016, 

Budapest, Hungary 

Senior Scientist P.O.Box 3000, Johnstown 

Castle Estate, Wexford, 

Ireland 

+49 251 411 1550 

+49 251 411 81550 

richard.bolwerk@ 

bezreg-muenster.nrw.de 

+49 221 7740 402 

+49 221 7740 288 

horst.buether@stua-k.nrw.de 

+49 2366 807 200 

+49 2366 807 440 

wolfgang.feldmann@stua-he.nrw.de 

+49 3018 305 2267 

+49 3018 305 3331 

martina.froben@bmu.bund.de 

+49 33702 73101 

+49 33702 73107 

franz.graszmann@ 

lua.brandenburg.de 

+494 821 662 100 

+494 821 662 877 

gisela.holzgraefe@stua-iz.landsh.de 

+492 114 566 577 

+492 114 566 949 

helmut.kruber@munlv.nrw.de 

+49 0 711 1262 633 

+49 0 711 1262 822 

ulrich.maurer@um.bwl.de 

+49 431 988 7261 

+49 431 988 7179 

andreas.wasielewski@mlur.landsh.de 

+30 210 870 1800 

+30 210 870 1883 

dermitza@minenv.gr 

+30 210 641 2370 

+30 210 645 1914 

eype-ypehode@ath.forthnet.gr 

+30 231 048 3227 

+30 231 048 3247 

epbe@otenet.gr 

+30 210 641 2370 

+30 210 645 1914 

eype-ypehode@ath.forthnet.gr 

+30 210 865 2493 

+30 210 865 2493 

v.tryfona@deart.minenv.gr 

+361 224 914 0 

+361 224 927 4 

babcsany@mail.kvvm.hu 

+361 224 921 0 

+361 224 927 4 

vargap@mail.kvvm.hu 

+353 53 916 0600 

+353 53 916 0699 

f.clinton@epa.ie

Doyle Valerie Environmental Protection 

Agency 

Fanning Andy Environmental Protection 

Agency 

Henry Mick Environmental Protection 

Agency 

Marnane Ian Environmental Protection 

Agency 

McHugh Maeve Environmental Protection 

Agency 

Sweeney Leo Environmental Protection 

Agency 

Italy 

Burali 

Alessandra 

APAT (National Agency of 

Environmental Protection) 

Senior Inspector P.O.Box 3000, Johnstown 


Ireland 

Scientific Officer P.O.Box 3000, Johnstown 


Ireland 

Senior Inspector John Moore Road, Castlebar, 

Co.Mayo, Ireland 

Licensing Inspector P.O.Box 3000 Johnstown 

Castle Estate, County 

Wexford, Wexford, Ireland 

Inspector Regional Inspectorate, 

Inniscarra, Co.Cork., Ireland 

Senior inspector EPA region inspectorate 

Richview Clonskeagh, 

14, Dublin, Ireland 

Carella Fabio ARPA Lombardia Director, Technical 

Support and Sustainable 

Development 

85 

Via Curtatone, 3, 00185, 

Roma, Italy 

V. Le Restelli, 3/1, 20124, 

Milano, Italy 

Palminteri Daria Ministry of Environment Via Cristoforo Colombo 44, 

00148, Rome, Italy 

Pastore Maria 

Luisa 

Quaggiato 

Riccardo 

ARPA Lombardia Technical Manager V. Le Restelli, 3/1, 20124, 

Milano, Italy 

Environmental Agency of 

Veneto 

Technical Director Via Matteotti, 35131, Padova, 

Italy 

Latvia 

Avotiņš Vilis State Environmental Service Director-General Rūpniecības iela 23, Riga, 


Bebris Rolands Ministry of the Environment Director, Environmental 

Protection Department 

Peldu iela 25, Riga, 


Dipāne Judīte State Environmental Service Head of Division Rūpniecības iela 23, Riga, 


Emsis Indulis Saeima of the Republic of 

Latvia 

Hahele Inta State Environmental Service 

Lielrīgas Regional 

Environmental Board 

Jaunbirze 

Sabīne 

Member of Parliament Jēkaba iela 11, Riga, 


Director Rūpniecības iela 23, Riga, 


State Environmental Service Senior Expert Rūpniecības iela 23, Riga, 


Kalniņa Kristīne State Environmental Service Senior Referent Rūpniecības iela 23, Riga, 


Kasparinskis 

Raimonds 

Kazerovska 

Kristīne 

University of Latvia Dzelzavas iela 89-15, Riga, 


Baltic Environmental Forum Project Manager Peldu iela 26-28, Riga, 


+353 53 916 0600 

+353 53 916 0699 

v.doyle@epa.ie 

+353 53 916 0600 

+353 53 916 0699 

a.fanning@epa.ie 

+353 94 904 8400 

+353 94 904 8499 

m.henry@epa.ie 

+353 539 170 753 

+353 539 160 699 

i.marnane@epa.ie 

+353 21 487 5540 

+353 21 487 5545 

maeve.mchugh@epa.ie 

+353 12 680 100 

+353 12 680 199 

l.sweeney@epa.ie 

+390 650 074 156 

+390 650 074 832 

burali@apat.it 

+390 269 666 204 

+390 269 666 255 

f.carella@arpalombardia.it 

+390 657 228 219 

+390 657 728 172 

daria.palminteri@tfambiente.it 

+390 269 666 335 

+390 269 666 255 

m.pastore@arpalombardia.it 

+390 498 767 604 

+390 498 767 670 

rquaggiato@arpa.veneto.it 

+371 7084 201 

+371 7084 212 

vilis.avotins@vvd.gov.lv 

+371 7026 501 

+371 7820 442 

rolands.bebris@vidm.gov.lv 

+371 7084 218 

+371 7084 212 

judite.dipane@vvd.gov.lv 

+371 7087 251 

+371 7087 251 

indulis.emsis@saeima .lv 

+371 7084 246 

+371 7084 244 

inta.hahele@lielrigasrvp.gov.l 

+371 7084 238 

+371 7084 212 

sabine.jaunbirze@vvd.gov.lv 

+371 7084 200 

+371 7084 212 

kristine.kalnina@vvd.gov.lv 

+371 265 976 15 

kasparinskis@gmail.com 

+ 371 7357 555 

+ 371 7507 071 

bef@bef.lv 



Kramzaka Indra Environmental State Bureau Head of Division Rūpniecības iela 23, Riga, 


Krūmiņš Imants State Environmental Service Director of Department Rūpniecības iela 23, Riga, 


Kurmahere Inese State Environmental Service Head of Division Rūpniecības iela 23, Riga, 


Kurtiša Inguna State Environmental Service Assistant Rūpniecības iela 23, Riga, 


Lāce Zinta State Environmental Service Senior Expert Rūpniecības iela 23, Riga, 


Lobanoka Ineta State Environmental 

Service, Daugavpils Regional 




Head of Division Raiņa iela 28, Daugavpils, 


Lutere Līga Baltic Environmental Forum Project Assistant Peldu iela 26-28, Riga, 


Pļaviņa Ingūna State Environmental 

Service, Ventspils Regional 


Director Dārzu iela 2, Ventspils, 


Poikāne Ruta State Environmental Service Senior Inspector Rūpniecības iela 23, Riga, 


Reimanis 

Madars 

State Environmental Service Senior Inspector Rūpniecības iela 23, Riga, 


Rone Māra Ministry of Environment Head of Division Peldu iela 25, Riga, 


Roska Andris State Environmental Service Director of Department Rūpniecības iela 23, Riga, 


Rozenberga 

Laura 

State Environmental Service Director of Department Rūpniecības iela 23, Riga, 

LV-1045 

Stašāne Aina Ministry of Environment Director of Department Peldu iela 25, Riga, 


Sīle Māra State Environmental Service 

Lielrīga Regional 


Sīle Silvija SIA “COWI LATVIA” Environmental Expert in 

IPPC Permitting 

Šmite Evija State Environmental Service 

Marine and Inland Waters 

Administration 

Senior Expert Rūpniecības iela 23, Riga, 


86 

Skolas iela, 21-501A, Riga, 


Director Voleru iela 2, Riga, 

LV-1007 

Švinskis Jānis State Environmental Service Senior Expert Rūpniecības iela 23, Riga, 


Vaivods 

Raimonds 

Veidemane 

Kristīna 

State Environmental Service Senior Inspector Rūpniecības iela 23, Riga, 


Baltic Environmental Forum Project Manager Peldu iela 26-28, Riga, 


+371 7770 811 

+371 7321 049 

indra.kramzaka@vpvb.gov.lv 

+371 7084 202 

+371 7084 212 

imants.krumins@vvd.gov.lv 

+371 7084 209 

+371 7084 212 

inese.kurmahere@vvd.gov.lv 

+371 7084 208 

+371 7084 212 

inguna.kurtisa@vvd.gov.lv 

+371 7084 223 

+371 7084 212 

zinta.lace@vvd.gov.lv 

+371 542 443 0 

iveta.lobanoka@drvp.gov.lv 

+371 7357 555 

+371 7507 071 

liga.lutere@bef.lv 

+371 362 690 3 

+371 362 337 5 

inguna.plavina@vrvp.gov.lv 

+371 7084 228 

+371 7084 212 

ruta.poikane@vvd.gov.lv 

+371 7084 216 

+371 7084 212 

madars.reimanis@vvd.gov.lv 

+371 7026 532 

+371 7820 442 

mara.rone@vidm.gov.lv 

+371 7084 217 

+371 7084 212 

andris.roska@vvd.gov.lv 

+371 7084 204 

+371 7084 212 

laura.rozenberga@vvd.gov.lv 

+371 7026 537 

+371 7820 442 

aina.stasane@vidm.gov.lv 

+371 7084 266 

+371 7084 244 

mara.sile@lielrigasrvp.gov.lv 

+ 371 7369804 

+ 371 7369803 

sis@cowi.lv 

+371 7408169 

+371 7465888 

evija.smite@jiup.gov.lv 

+371 7084230 

+371 7084212 

janis.svinskis@vvd.gov.lv 

+371 7084 231 

+371 7084212 

raimonds.vaivods@vvd.gov.lv 

+ 371 7357 555 

+ 371 7507 071 

kristina.veidemane@bef.lv

Vējonis 

Raimonds 

Ministry of Environment Minister Peldu iela 25, Riga, 


Vībāns Kaspars 

Lithuania 

State Environmental Service Senior Expert Rūpniecības iela 23, Riga, 


Beržinskas Environmental Protection Head, Pollution 

Juozapavičiaus Str. 9, Vilnius, 

Vaclovas 

Agency 

Prevention Unit 

Lithuania 

Plančiūnaite 

Angele 

Stankevičiute 

Ausra 

Norway 

Aanonsen 

Ingegerd 

Panevežys Regional 


Department 

Alytus Regional 


Department, Prienai Agency 

Norwegian Pollution Control 

Authority (SFT) 

Forberg Erik Norwegian Pollution Control 

Authority (SFT) 

Samstad 

Norwegian Pollution Control 

Geir-Rune Authority (SFT) 

Poland 

Dabrowski 

Boguslaw 

Opole Voivodeship 

Inspectorate for 


Gosk Magda Chief Inspectorate for 


Huczko Joanna Chief Inspectorate for 


Jastrzebska 

Hanna 

Kolodziej- 

Nowakowska 

Malgorzata 

Kosinska 

Monika 

Mroczkowski 

Marek 

Pirowska 

Katarzyna 

Portugal 

Filomena Das 

Neves Carreira 

Paula 

Isabel Tete 

Garcia Ana 

Chief Inspectorate for 


Voivodship Inspectorate for 

Environmental Protection in 

Szczecin 

Deputy Director Žvaigždžiu Str.7, LT-37109, 

Panevežys, Lithuania 

Senior Environemntal 

Protection Inspector 

87 

Kestučio G. 32, LT-59129, 

Prienai, Lithuania 

Senior Executive Officer Staten Hus, N-3708, Skien, 

Norway 

Senior Advisor Postbox 8100 Dep, N-0032, 

Oslo, Norway 

Senior Executive Officer P.O.Box 8100 DEP, N-0032, 

Oslo, Norway 

Head, Inspection 

Department 

Senior Specialist, 

Transboundary Movement 

of Waste Division, 

Department of Market 

Control 

Senior Specialist, 

Inspection and 

Administrative Ruling 

Department 

Deputy Director, 

Department of Inspection 

and Administrative Ruling 

Voivodship Inspector for 


Nysy Luzyckiej 42, 45-035, 

Opole, Poland 

Wawelska 52/54, 00 922, 

Warsaw, Poland 

Wawelska 52/54, 00-922, 


Wawelska 52/54, 00-922, 


Waly Chrobrego 4, 70-502, 

Szczecin, Poland 

Ministry of Environment Specialist Waewelska 52/54, 00-922, 

Warshaw, Poland 





Inspectorate General for the 

Environment 


Environment 

+371 702 6400 

+371 7820 442 

raimonds.vejonis@vidm.gov.lv 

+371 7084 212 

kaspars.vibans@vvd.gov.lv 

+370 526 628 24 

+370 526 628 00 

v.berzinskas@aaa.am.lt 

+370 455 814 11 

+370 455 814 41 

a.planciunaite@prd.am.lt 

+370 686 760 08 

+370 319 603 90 

a.stankeviciute@ard.am.lt 

+473 558 612 0 

+472 267 670 6 

ingegerd.aanonsen@sft.no 

erik.forberg@sft.no 

+472 257 368 8 

+472 267 670 6 

geir-rune.samstad@sft.no 

+487 745 300 69 

+487 745 300 69 

b.dabrowski@opole.pios.gov.pl 

+482 2559 280 92 

+482 259 280 93 

m.gosk@gios.gov.pl 

+482 257 926 53 

+482 282 515 09 

j.huczko@gios.gov.pl 

+482 282 515 09 

+482 282 515 09 

h.jastrzebska@gios.gov.pl 

+480 914 859 501 

+480 914 340 554 

mkn@wios.szczecin.pl 

+482 257 927 09 

+482 257 927 55 

monika.kosinska@mos.gov.pl 

General Director Inspector +482 282 598 15 

+482 282 598 15 

m.mroczkowski@gios.gov.pl 

Senior specialist Waewelska 52/54, 00-922, 

Warshaw, Poland 

Inspector, Portuguese 

IMPEL Coordinator 

Rua de “O Seculo”, 63, 

1249-033, Lisbon, Portugal 

Inspector Rua de “O Seculo”, 63, 

1249-033, Lisbon, Portugal 

+482 257 924 16 

+482 282 597 75 

k.pirowska@gios.gov.lv 

+351 213 215 525 

+351 213 432 777 

pcarreira@igaot.pt 

+351 213 215 513 

+351 213 432 777 

agarcia@ig-amb.pt 



Pinto Santana 

Isabel 



Environment 

REPIN 

Bularga Angela REPIN Secretariat, 

Environment and 

Globalisation Division, 

Environment Directorate 

Mazur Eugene REPIN Secretariat, 

Environment and 

Globalisation Division, 

Environment Directorate 

Former Yugoslav Republic of Macedonia 

Dimovski Zoran Ministry of Environment and 

Physical Planning 

Romania 

Berbece Tiberiu National Environmental 

Guard 

Beu Mihaela National Environmental 

Guard - Regional 

Commissariat Cluj 

Gheorghe 

Magdalena 

National Environmental 

Protection Agency 

Ionescu Silvian National Environmental 

Guard 

Pascal Claudia 

Mirela 

National Environmental 

Guard, General 

Commissariat 

Popescu Ileana National Environmental 


Russian Federation 

Greshnikov 

Andrey 

Embassy of Russian 

Federation 

Terentyev Andrei Russian Regional 

Environmental Centre 

Serbia 

Stanojević 

Ljiljan 

Slovak Republic 

Durdovicova 

Jarmila 

Geisbacher 

Daniel 

Ministry for Science and 


of Serbia 

Inspectorate of the 

Environment 

Inspectorate of the 

Environment 

Slovenia 

Bernik Tatjana Inspectorate for 

Environmental and Spatial 

Planning 

Viler Kovačič 

Adrijana 


Portuguese IMPEL 

Coordinator 

88 

Rua de “O Seculo”, 63, 1249- 

033, Lisbon, Portugal 

Programme Manager 2, Rue Andre Pascal 75775, 

Paris Cedex 16, France 

Project Manager 2, Rue Andre Pascal 75775, 

Paris Cedex 16, France 

State Environmental 

Inspector and Inspector 

for Nature Protection 

Drezdenska 52, 1000, Skopje, 

Republic of Macedonie 

Head of section Str.Remus Bellu Nr.6, 

Ramnicu Valcea, 1000, 

Romania 

Regional Commissar Dorobantilor, 99, 400 609, 

Cluj-Napoca, Romania 

Director Aleea Lacul Morii, Nr.151, 

Sector 6, 060841, 

Bucharest, Romania 

General Commissar B-dul Unirii, Nr. 78, Sect. 3, 

BL. J2, Bucharest, 

Romania 

Inspector 78 Unirii blvd., 3-RD District, 

Bucharest, 030837, Romania 

Director Aleea Lacul Morii, Nr.151, 

Sector 6, 060841, 

Bucharest, Romania 

Antonijas iela 2, Riga, 


Principal Administrator 127473, 1 Volkonsky lane, 13, 

bld.2, Moscow, 

Russian Federation 

Head of Environmental 

Inspection 

Head Inspector, Waste 

Inspection Department 

Head Inspector, Water 

Protection Inspection 

Department 

Environmental Agency Environmental Legislation 

Adviser 

Nemanjina 22-26, Belgrade, 

11 000, Serbia 

Karloveska 2, 842 22, 

Bratislava, Slovak Republic 

Karloveska 2, 842 22, 

Bratislava, Slovak Republic 

Director Dunajska 47, Ljubljana, 1000, 

Slovenia 

Vojkova cesta 1 B, Ljubljana, 

1000, Slovenia 

+351 213 215 512 

+351 213 432 777 

isantana@ig-amb.pt 

+331 452 498 63 

+331 443 061 83 

angela.bularga@oecd.org 

+331 452 476 92 

+331 443 061 83 

eugene.mazur@oecd.org 

+389 230 669 30 (ext 133) 

+389 230 669 31 

zdimovski61@mt.net.mk 

+250 733 194 

+250 733 492 

tiberiu.berbece@gnm.ro 

+402 644 107 18 

+402 644 107 18 

gmcj@cluj.astral.ro 

+400 212 071 101 

+400 210 207 1102 

+400 212 071 103 

gheorghe.magdalena@anpm.ro 

+402 132 689 70 

+402 132 689 71 

silvian.ionescu@gnm.ro 

+402 132 622 54 

+402 132 622 59 

claudiapascal@gnm.ro 

+400 214 934 236 

+400 214 934 250 

+400 214 934 237 

ileana.popescu@anpm.ro 

+371 733 21 51 

+371 783 02 09 

rusembas@delfi.lv 

+7 495 737 64 48 

+7 495 737 64 48 

terentiev@rusrec.ru 

+381 648 166 302 

+381 153 469 12 

ekosabac@ptt.yu 

+421 265 420 752 

+421 260 292 352 

durdovicova@sizp.sk 

+421 265 426 950 

+421 265 423 181 

geisbacher@sizp.sk 

+386 142 044 73 

+386 142 044 91 

tatjana.bernik@gov.si 

+386 147 845 10 

+386 147 840 51 

adrijana.viler-kovacic@gov.si

Spain 

Ballarin Ignacio Ministry for Environment Legal Advisor PZA. San Jua de la Cruz S/N, 

28071, Madrid, Spain 

Canales-Canales 

Carmen 

Colmenares 

Maria 

Cuadrado- 

Iglesias Sergio 

Ministry of Environment IMPEL National 

Coordinator 

89 

C/Agustin de Betancourt, 

25.Despacho AB-106.1, 


Ministry of Environment Section Head Agustin de Bethancourt 25, 


Ministry of Environment Technician C/Agustin de Betancourt, 

25.Despacho.Planta 1a (AB- 

106), 28003, Madrid, Spain 

Ocio Jesus Angel Basque Government, 

Environment and Soil 

Planning Department 

Sweden 

Callermo Lena Environmental Protection 

Agency 

Larsson Inga 

Birgitta 


Agency 

Regner Kia Local Authority of 

Osteraker, Department of 

Environmental Health 

Sigvardsson County Administrative Board 

Karin 

of Ostergotland 

Tiberg Anna Federation of Swedish 

Farmers 

The Netherlands 

Borgers Harm VROM, Ministry of Housing, 

Spatial Planning and the 

Environment 

Head, Environmental 

Inspection 

Dols Niekol VROM Inspectorate Acting Head, Waste 

Department/Coordinator 

Eggink Ed Province of Limburg Head, Department for 

Environment and Water 

Policy 

Faber Arthur The Inspectorate of the 

Ministry of Housing, 

Spatial Planning and the 

Environment 

Leentvaar Jan Water Management 

Inspectorate 

Niessen Willem Inspectorate of Ministry of 

Housing, Spatial Planning 

and the Environment 

Donostia-San Sebatian 1, 

Vitoria-Gasteiz, Basque 

Country, Spain 

SE-10648, Stockholm, 

Sweden 

SE-10648, Stockholm, 

Sweden 

SE 184 86, Akersberga, 

Sweden 

Ostgotagatan 3, Linkoping, 

SE-58186, Sweden 

SE-105 33, Stockholm, 

Sweden 

Policy Co-ordinator P.O.Box 30945, 2500 GX, Den 

Haag, the Netherlands 

Enforcement Policy 

Coordinator 

Director, Chief Inspector 

Water 

P.O.Box 850, 5600 AW, 

Eindhoven, the Netherlands 

P.O.Box 5700, 6202 MA, 

Maastricht, the Netherlands 

P.O.Box 16191, 2500 BD, The 

Hague, the Netherlands 

PO BOX 61, 8200 AB, 

Lelystad, the Netherlands 

Coordinator KBC Kennedyplein 5 -12, 

5600 AW, Eindhoven, the 

Netherlands 

Oden Niels Erik Provincie Noord-Holland Unit Manager P.O.Box 3007, 2001 DA, 

Haarlem, the Netherlands 

Roeters Peter Water Management 

Inspectorate 

Coordinator International 

Affairs 

PO BOX 61, 8200 AB, 


Ruessink Henk VROM Inspectorate Management Consultant Ereprijsweg 21, 9753 AP, 

Haren, the Netherlands 

Teekens Jan Inspectorate of Ministry of 

Housing, Spatial Planning 

and the Environment 

Manager International 

Affairs 

IPC 530, Rijnstraat 8, P.O.Box 

16191, 2500 BD, Den Haag, 


+349 159 764 03 

+349 159 763 82 

eorteu@mma.es 

+349 145 354 04 

+349 153 486 09 

ccanales@mma.es 

+349 145 354 02 

+349 153 405 82 

mcolenares@mma.es 

+349 145 354 12 

+349 153 486 09 

at_scuadrado@mma.es 

+349 450 199 17 

+349 450 198 83 

jan-ocio@ej-gv.es 

+468 698 124 2 

lena.callermo@naturvardsverket.se 

+468 698 114 2 

ingabirgitta.larsson@ 

naturvardsverket.se 

+468 540 813 06 

kia.regner@osteraker.se 

+461 319 635 3 

karin.sigvardsson@e.lst.se 

+468 787 502 4 

anna.tiberg@lrf.se 

+317 033 926 76 

+317 033 913 02 

harm.borgers@minvrom.nl 

+314 026 529 58 

+314 026 530 30 

niekol.dols@minvrom.nl 

+314 338 974 87 

+314 338 970 18 

e.eggink@prvlimburg.nl 

+317 033 938 94 

+317 033 912 99 

arthur.faber@minvrom.nl 

+313 202 995 07 

+313 202 995 01 

jan.leentvaar@ivw.nl 

+314 026 529 11 

+314 026 303 0 

wike.niessen@minvrom.nl 

+312 351 433 63 

+312 351 430 30 

odenn@noord-holland.nl 

+313 202 995 66 

+313 202 995 01 

peter.roeters@ivw.nl 

+316 519 931 33 

+317 033 917 52 

+315 059 926 97 

henk.ruessink@minvrom.nl 

+317 033 937 77 

+317 033 912 99 

jan.teekens@minvrom.nl 



van der Pennen 

Wim 

Van Zanten 

Pieter-Jan 



Province Noord-Brabant Manager Environmental 

Permits 

Provincie Overijssel Deputy Head, Department 

for Economics and 

Environment 

Visbeen John Province of Flevoland Manager Environmental 

Enforcement 

Turkey 

Erkal Ibrahim 

Fatih 

Ministry of Environment and 

Forestry 

Eyup Yahsi Ministry of Environment and 

Forestry 

Gozu Hulya Ministry of Environment and 

Forestry 

UNICE 

Aagaard Lars Confederation of Danish 

Industry 

90 

Brabantlaan 1, 5200 MC, 

s’Hertogenbosch 


Luttenbergstraat 2 P.O.Box 

10078 Zwolle, 8000 GB, 


Postbuss 55, 8200 AB, 


Section Manager Sogutozu cad.No. 14/E 

Bestepe, 06560, Ankara, 

Turkey 

Section Manager Sogutozu cad.No. 14/E 


Turkey 

Environmental Expert/ 

Inspector 

Director for Environment 

& Energy 

United Kingdom 

Davis Gisela DEFRA Head of Environmental 

Law - A6 

Fawcett Will Environment Agency 

(England and Wales) 

Gray Jim Environment Agency 


Ledgerwood 

Kenneth 

Environment and Heritage 

Service 

Ormerod Lesley Environment Agency 


Quinn Martin Environment Agency 


Ramsay Roy Environment and Heritage 

Service 

Riddick Karen Scottish Environmental 


Shears Terence Environment Agency 


Whitworth 

Martin 

EU&International 

Relations Coordinator 

Head of Regulatory 

Department 

Chief Industrial Pollution 

Inspector 

T.C.Cevre ve Orman Bakanligi 

20.Kat B-Blok 

Ofis: 7, Sogutozu CD. 14/E 


Turkey 

18, HC Andersen Boulevard, 

DK - 1787 V, 


Area 3D Nobel House, 17 

Smith Square, SW 1P 3JR, 

London, UK 

Rio House, Waterside drive, 

Aztec West, Almondsbury, 

BS 32 4 UD, Bristol, UK 

Rio House, Waterside Drive, 

Aztec West, Almondsbury 


Calvert House, Castle Place, 

BT1 1FY, Belfast, 

Northern Ireland, UK 

Policy Advisor Room 1N12, Richard 

Fairclough House, Knutsford 

Road, 

WA4 1HG, Warrington, UK 

Future Regulatory 

Strategy Manager 

Director of Environmental 

Protection 



Commonwealth House 35 

Castle Street, BT1 1GU, 

Belfast, Northern Ireland, UK 

Principal Policy Officer Castle Business Park, FK 9 

4TR, Stirling, Scotland, UK 

EU & International 

Relations Adviser 


Aztec West, Almondsbury 


Environmental Agency Policy Manager Block 1, Govt Buildings, 

Burghill Road, Westbury-on 

Trym, BS10 6BF, Bristol, UK 

+317 368 124 89 

+317 368 125 34 

wvdpennen@brabant.nl 

+313 842 514 79 

+316 289 019 07 

pj.v.zanten@overijssel.nl 

+313 202 653 95 

+313 202 652 60 

john.visbeen@flevoland.nl 

+903 122 076 566 

+903 122 076 446 

ferkal@cevreorman.gov.tr 

+903 122 076 565 

+903 124 982 166 

yahsieyup@yahoo.com 

+903 122 076 569 

+905 363 492 768 

+903 122 076 446 

hgonultas@cevreorman.gov.tr 

hulyagonultas@yahoo.com 

+453 377 303 3 

+453 377 356 0 

lag@di.dk; mkc@di.dk 

+442 072 381 234 

+442 072 385 992 

gisela.davis@defra.gsi.gov.uk 

+441 545 205 756 

+441 545 205 533 

will.fawcett@environmentagency.gov.uk 

+441 454 284 306 

+441 454 284 301 

jim.gray@environment-agency.gov.uk 

+44 28 90 254 716 

+44 28 90 254 700 

ken.ledgerwood@doeni.gov.uk 

+441 925 542 046 

+441 925 542 771 

lesley.ormerod@environmentagency.gov.uk 

+441 454 284 312 

+441 454 284 301 

martin.quinn@environmentagency.gov.uk 

+442 890 546 614 

roy.ramsay@dolni.gov.uk 

+441 786 457 700 

+441 786 446 885 

karen.riddick@sepa.org.uk 

+441 454 205 743 

+441 454 205 533 

terence.shears@environmentagency.gov.uk 

+441 179 142 948 

+447 768 905 825 

+441 179 142 827 

martin.whitworth@environmentalagency.gov.uk

Short Overview of the Organisation of Inspection in IMPEL Member States, Norway, 

Acceding and Candidate Countries 2006 

Austria 

Austria has no central inspection system. The licensing authorities in the Länder are also responsible for inspection 

activities. At a national level ultimate responsibility for co-ordinating inspection and enforcement rests with the Federal 

Ministry of Agriculture, Forestry, Environment and Water (BMLFUW), while responsibility for implementation rests 

primarily with the Provinces (except in the case of waste). In relation to the implementation of inspection, different 

agencies are involved at National, Regional, Sub-regional and Local levels and responsibilities are different for different 

sectors and laws. Responsibilities differ between regions. There are changes planned, which will result in more 

responsibilities being devolved to local authorities. 

Belgium 

Belgium is a federal state based on three regions defi ned by economic considerations: the Flemish Region, the Brussels 

Capital Region and the Walloon Region. The Regional Governments are each responsible for passing and implementing 

their own environmental legislation with the exception of legislation for transit of waste through Belgium, for setting of 

product norms and for matters concerning ionising radiation and nuclear waste management. The role of the regions, 

provinces and municipalities in compliance checking and enforcement varies between the regions. 

Brussels Capital Region 

The Brussels Inspectorate for Management of the Environment (BIME) plays a key role for inspections in the Brussels 

Capital Region. It is responsible for the control of air-, water- and soil-pollution, noise nuisance and elimination of all 

types of waste (except nuclear waste and transfer of waste). The BIME and the 19 Local Authorities of the Brussels 

Region each have responsibility for inspection of all classes of installation; the BIME throughout the Region and Local 

authorities within their own jurisdiction. The BIME is responsible for issuing permits for class Ia and Ib installations 

(IPPC Annex 1 installations). Local authorities are separately responsible for permitting installations in the Class II. 

These are installations that require neither Environmental Impact Assessment nor Environmental Report. They are also 

responsible issuing “Declarations” for Class III installations, which are the smaller installations. 

Flanders 

In Flanders the Environment Inspection Section (EIS) is the enforcement agency for environmental hygiene legislation 

in the Flemish Region and is part of the Environment, Nature, Land and Water Management Administration. The 

Environment Inspection Section has a conventional vertical structure with the Chief Inspectorate in Brussels and 5 

local services based in the main towns of the Flemish provinces. Each service is managed by a head of service who 

is appointed as hierarchical superior in accordance with civil service status. The Head of Section is responsible for 

overall organisation of each service. The Chief Inspectorate initiates and supervises the management of the inspections 

and investigation activities. Furthermore, it is responsible for the preparation, formulation and evaluation of policy and 

for ensuring logistical support for the service. The local services are responsible for carrying out specifi c inspection 

tasks, implementing measures, keeping company fi les up to date and providing policy-makers with feedback on 

experience gathered in the fi eld. In addition to the vertical structure, a horizontal structure has also been set up in the 

form of working groups for each environmental compartment. Each working group is composed of fi ve members (one 

representative from each local service) and a representative from the Chief Inspectorate who acts as the working group 

moderator (project leader). 

Walloon Region 

In the Walloon Region, environmental inspection is carried out by the Division of the Environmental Police (DPE) of the la 

General Directorate for Natural Resources and Environment of the Ministry of the Walloon Region. The DPE is organised 

as a central service providing logistic, administrative and legal support and co-ordinating 4 external directorates. Other 

organisations involved in inspections are the Judicial Police (Local Police – Federal Police) as well as by the Water 

Division (Pollution of Surface Water) and Division of Nature and Forests. 

Bulgaria 

The control on the environmental components and factors in Bulgaria consists of three main components, according to 

the Environmental protection Act (EPA): 

- preventive control; 

- current (routine) control; 

- follow-up control. 

The preventive control is implemented through environmental assessment upon approval of plans and programmes 

(Strategic IA, SEA), through EIA as a condition for the issuance of a building permit, by means of issuance of IPPC 

permits, permits according Art. 104 of the Environmental Protection Act (Seveso II permits) and other administrative 

acts provided for in the environmental legislation. 

91 



Current control is related fi rst of all to overseeing the quality of the environmental media and of the factors impacting 

these media. It includes also overseeing compliance with the conditions specifi ed in the permits and environmental 

impact assessment decisions as issued by the Regional Inspectorates of Environment and Water and the Basin 

Directorates and of the measures provided for in the programmes. 

The current control is implemented by means of inspections, observations and measurements and includes access to: 

the data on the self-monitoring of the site, conducted by the operator; information relating to the production activity on 

the site; the real estate property and facilities constituting state, municipal and private property. 

In the course of exercise of current control, offi cials designated by the competent authorities draw up memorandums of 

ascertainment, which present the facts and circumstances as ascertained and give mandatory prescriptions, specifying 

deadlines and persons responsible for implementation of the prescriptions. 

Follow-up control is implemented by following: 

- the results of implementation of the measures provided for in the EIA decisions and the permits, as well as the results 

of execution of development projects; 

- implementation of the prescriptions given to the persons controlled during preventive and current control. 

Enforcement of administrative and economic measures such as sanctions including fi nes, penalties, cease-and-desist 

orders, or even penal prosecutions for violation of the environmental provisions are part of the current and follow-up 

control. 

The Ministry of Environment and Water (MoEW) is the main authority responsible for the environmental inspections 

through its regional branches, although the Ministry of Health (Regional inspectorates for protection of the public health) 

supervises bathing and drinking water inspection (according to the Water Act) and controls the dangerous chemical 

substances and preparations placed on the market (according to the Chemicals Act). MoEW has a number of regional 

bodies, including: 

� 15 regional inspectorates of environment and water (RIEW), which are the main controlling bodies in the system 

of environmental control. The RIEWs are responsible for inspections in the area of air quality, waste, waste water 

treatment, dangerous chemical substances and preparations, EIA, IPPC and are coordinating authority for the 

performance of the joint-team inspections under the major accident prevention legislation (Seveso II inspections); 

� The four river basin directorates are responsible for the control over the surface and groundwater quality and the 

management of the basin waters; 

� Three national park directorates are performing inspections which are aimed at achieving high level of nature 

protection and restoration. 

The Environmental Executive Agency (EEA) have laboratories, all of which are equipped for air and water analyses and 

some of which can also undertake soil or radiological analyses. 

For enterprises in the scope of Directive 96/82/EC and the amending Directive 2003/105/EC (control over major 

accidents hazards) joint-teams inspections are performed. They are coordinated by the RIEWs and also include members 

of the regional branches of the Ministry of Health, the Ministry of Emergency Management Policy, the fi re-fi ghting 

authority within the Ministry of Interior, the State Agency for Technical Surveillance, the regional and local authorities. 

All environmental inspections are performed on the basis of annual plan for environmental control, pre-endorsed by the 

minister of environment and water, with the exception of the inspections following complaints and signals. 

Croatia 

Ministry of Environmental Protection, Physical Planning and Construction (MEPPPC) has overall responsibility for 

environmental policy in Croatia, with the exception of water and nature protection as well as noise. 

The Ministry’s responsibility includes drafting of legislation regarding environment in general, air protection, waste 

management, emergency plans, protection of the maritime area, soil, quality of fuels, ozone depleting substances. It is 

also responsible for permitting, carrying out EIA and inspection. 

MEPPPC coordinates cooperation in the fi eld of environmental protection with other line state bodies such as the 

central state administration, state administration offi ces in the counties, units of local and regional self- government, the 

Croatian Environment Agency and the Environmental Protection and Energy Effi ciency Fund, as well as with industry 

and NGOs. 

The Directorate for Inspection within MEPPPC, which consists of the head offi ce and 20 branch units in the seats of 

counties, includes within its structure three inspections – environmental protection, urban planning and construction. 

The Environmental inspection is responsible for compliance checking and enforcement of laws; its activities are planned 

on the basis of annual and monthly working plans, with the exception of site visits on an ad hoc basis and in cases of 

emergency. 

The Environmental protection inspection within the head offi ce is organized in the Department for inspection control, 

whose structure includes three sections: Section for inspection control, Section for advancement of operation and 

Section for international co-operation. The advantage of such an organisation is in the possibility to link and coordinate 

the proceeding of all inspections in emergency interventions as well as in more effi cient sanctioning of violators by 

simultaneous enforcement of several laws. Inspectors have the obligation and duty, in case of non-compliance, to 



92

undertake sanctions against the operator for offences or to press administrative and criminal charges. 

Inspectors have still a role in informing/advising as well as carrying out inspection. 

The capacity of the inspection is going to be strengthened in order to provide a satisfactory degree of regulations 

implementation. MEPPPC has set as a priority capacity building and sector specialisation by certain branches and 

improving permanent coordination of the activities with inspections in other line bodies. 

The Environmental inspection is strongly involved in the process of proposing and adopting new legislation as well as in 

pertaining in its implementation. 

The Section for international co-operation within the Directorate coordinates all activities related to adjustment of 

inspection to EU standards and to Council Recommendation Providing Minimum Criteria for Environmental Inspections, 

which is directly linked with the process of EU approximation that Croatia is currently going through as a candidate 

country. 

Cyprus 

Inspection responsibilities are shared by the Ministry of Agriculture, Natural Resources and Environment (MANRE) and 

the Ministry of Labour and Social Insurance (MLSI) as follows: 

- Environment Service of MANRE is responsible for permitting and inspection activities for soil and water pollution 

control, and most of waste management issues, 

- Department of Labour Inspectorate of MLSI is responsibilities for air emissions control, for quality of ambient air and 

seveso issues. 

Both ministries are also responsible for permitting and monitoring in their fi elds of activities. 

MANRE additionally evaluates EIA reports. Before permitting, a technical advisory committee holds hearings where all 

stakeholders participate. They advise the relevant issuing ministry on operating conditions and emission limits. 

Other bodies also play an important environmental management role: 

- The Ministry of Health deals with all aspects of ground, drinking and bathing water quality, 

- The Ministry of Interior (in its role as town planning ministry) has responsibilities for landfi ll management, and 

- The Ministry of Commerce, Tourism and Industry has industry and energy effi ciency responsibilities. 

Czech Republic 

The Ministry of Environment is responsible for the implementation of EC environmental law. It directs the tasks of the 

inspectorates, responsible for control and enforcement. A headquarters inspectorate provides methodological direction 

and supervision of regional inspectorates. CENIA (Czech Environmental Information Agency) provides professional 

support to public administration in the area of integrated prevention and synthetic research in ecology and environment 

protection. Several other institutions also play a role, including the inspections of other ministries (Agriculture), regional 

offi ces, local government etc. Co-operation among the institutions exists, some of it required by law, other on an ad hoc 

basis. 

Denmark 

Environmental regulation in Denmark is decentralised. At the policy level, the Ministry of Environment is responsible 

for environmental policy and for establishing the legal framework in Acts. The Danish Environmental Protection 

Agency (DEPA) is part of the ministry. DPA issues Orders and provides Guidelines on how to implement the Acts at an 

operational level. The 14 counties, which are the regional authorities, and the 271 municipalities, which are the local 

authorities, are responsible for both issuing licenses (permits), and carrying environmental inspections and enforcement. 

In the legislation it is clearly defi ned which installations fall under whose responsibility. Principally installations which 

may have an environmental impact on water systems situated in more than one municipality fall under the responsibility 

of a county. The same principle holds for air emissions. Also, installations that are operated by municipalities - e.g. 

wastewater treatment plants and waste incinerators - are under the responsibility of a county. In total the counties 

are responsible for environmental permitting an controlling of about one sixth of the licensed industrial installations, 

while the municipalities are the environmental authorities for all other installations inclusive farms. Municipalities and 

counties are not subordinate to each other, but are at the same level of authority. The state (the Danish Environment 

Protection Agency) does not have an inspectorate. After 1 January 2007 the 271 municipalities will merge to 98 new 

and bigger municipalities while the counties will disappear. At the same time the State (DEPA) will establish 7 regional 

environmental centres of which 3 centres will be responsible for permitting, inspection and enforcement of 215 of the 

most environmental complicated installations. The rest of the installations, which the counties were responsible for, will 

go to the new municipalities. 

Estonia 

The Ministry of Environment is responsible for environmental policy and for preparing environmental laws and regulations. 

The Ministry is also the permitting authority, mainly through its substructures in the 15 counties. 

Enforcement and inspection at the state level is the responsibility of the Environmental Inspectorate, a governmental 

93 



ody operating in the area of government of the Ministry. The Inspectorate has its central coordinating offi ce and 7 

regional departments carrying out the inspection. The range of topics is wide, from water, air, waste and radiation control 

up to the “green” issues, including protected areas, fi sheries and forestry. 

At the local level the municipalities also have a responsibility for environmental regulation, permitting and inspection, 

mainly in the fi eld of planning, building and waste management. 

Finland 

The Ministry of Environment is responsible for preparing laws and regulations on environmental protection, the 

development of environmental policy, and supervising actions taken by authorities at the regional and local levels. 

Environmental permitting and the compliance monitoring of permits is decentralized: environmental permits are 

issued by the Environmental Permitting Authorities (3), the Regional Environmental Centres (13) and the Municipal 

Environment Authorities (414); compliance monitoring takes place through the Regional Environmental Centres (13) 

and the Municipal Environment Authorities (414). As part of the environmental permits, the authorities stipulate how an 

operator is to monitor emissions and report the results. In large installations, compliance monitoring focuses heavily on 

the quality and operation of self-monitoring and reporting systems as well as on the assessment report produced by the 

operator. In the case of medium-sized and small installation sites, inspections concentrate more on assessing the overall 

compliance of the operation. The compliance monitoring authorities may take coercive measures such as imposing a fi ne 

or even 5 suspending an installation’s operations. If such actions do not result in rectifi cation of an unlawful situation, 

the authorities report the offence to the police for preliminary investigation. The public prosecutor may take the case to 

court. The Finnish Environment Institute supervises transboundary transportation of waste. 

France 

The Ministry of Ecology and Sustainable Development (MEDD), through its Directorate for Risk and Pollution Prevention 

(DPPR), has the overall responsibility concerning all the directives listed by the Commission as related to the 

Recommendation, including IPPC and Seveso II Directives. Within the DPPR, the “Service de l’Environnement Industriel” 

is the central authority for inspection and enforcement, exercised locally by the services of the Inspection of classifi ed 

installations that include: 

– 24 Regional Directorates for Industry, Research and Environment (DRIRE), in charge of industrial activities; 

– 100 Departmental Directorates of Veterinary Services (DDSV), responsible for the inspection of agrofood establishments, 

animal-rearing establishments and slaughterhouses; 

– the Technical Department of the Police Prefecture of Paris (STIIIC), responsible for inspection in Paris and its surrounding 

area. These organisations deal with, among other things, issuing permits, carrying out inspections and enforcement. 

Even though the Inspection services prepare the permits, the authority for signing and issuing all the environmental 

permits, and administrative sanctions, lies with the Prefect of the relevant Department (100 geographical departments). 

The permits issued are “integrated”, they deal with all the concerned matters: air, water, soil-pollution, noise nuisance, 

waste, and risk prevention. 58 000 facilities run under such an integrated permit. 

Germany 

In Germany responsibilities for inspections are devolved to the 16 states known as “Länder“. The administrative 

structures and responsibilities for compliance checking and enforcement varies among the Länder. Most commonly 

within the Länder there is a Ministry of Environment at the top level, a Bezirksregierung at the middle level and Kreise 

and Staatliche Umweltämter at the lower level. The Bezirksregierung is responsible for the quality control of lower 

governments. The Staatlichen Umweltämter are responsible for compliance checking and enforcement of big, medium 

and small size installations whereas the Kreise are often only responsible for the small size installations in the fi elds of 

waste and waste water. 

Greece 

In Greece inspection responsibility rests mainly with the Ministry for the Environment, Physical Planning and Public 

Works (YPEHODE), in conjunction with other Ministries such as: Ministry of Development, Ministry of Agricultural 

Development and Foods (for forest protection issues), Ministry of Health and Social Welfare, Ministry of Labour (for 

occupational health issues), Ministry of Public Order (Fire Brigade). Since late 2003, the Hellenic Environmental 

Inspectorate acts as the central inspection authority covering the totality of the Greek territory. In parallel, ministerial 

environmental permitting authorities, as well as the 13 regional and 51 prefectural environmental permitting authorities, 

perform inspections to projects and activities within the limits of their responsibilities. 

Hungary 

The environment related inspection in Hungary is based on two organisational levels: on national and regional level. 

The National Inspectorate for Environment, Nature and Water, acting at the national level, is described as a ministerial 

offi ce working under the authority of the Minister. The National Inspectorate is a second instance (appeal) authority - 



94

eviewing decisions of the Regional Inspectorates for Environment, Nature and Water (REI). The primary responsibility 

for the enforcement of the environmental legislation is held by the twelve REIs. REIs are the fi rst instance authority 

for permitting inspection, enforcement, monitoring and reporting in fi eld of all major environmental sectors, including 

some nature conservation and water management issues too (The authority responsible for implementation of Seveso in 

Hungary is the Directorate General for Disaster Management.). Each REI has a laboratory responsible for all chemical 

and biological testing in their region providing support on the evaluation of environmental conditions. Both national and 

regional levels are supervised and co-ordinated by the Ministry for Environment and Water (MfEW.) Inspections are 

undertaken according to annual work plans drawn up by the REIs, which give — among other things — the number of 

routine inspections and the companies to be checked. The annual work programmes of the REIs are more than inspection 

and enforcement plans, since their responsibilities are much wider, including IPPC-, water-, waste-, EIA- (which results 

in a permit in Hungary) and other environmental type of permitting procedures, participation in monitoring, supervision 

and control of the polluted sites, preparation of pollution reduction measurement plants, support of local authorities, 

co-operation with other relevant authorities. 

Ireland 

The key Inspecting Authority is the Environmental Protection Agency (EPA). As well as having specifi c responsibilities 

in relation to IPPC, waste management, VOCs (petroleum) and groundwater protection, the EPA oversees the activities 

of local authorities at a sub-regional level (counties and cities) in other areas (covering most non-IPPC installations). 

Responsibilities of the EPA include licensing and permitting as well as inspection and enforcement. The local authorities 

issue single media licenses to smaller industries involving emissions to air, wastewater discharges and waste disposal. 

The local authorities are also largely responsible for compliance checking and enforcement. The Occupational Health 

and Safety Authority checks installations that constitute a potential risk for major accidents. 

Italy 

Several Administrations cover an inspection role in Italy. Depending on the Regional laws of each environmental sector 

(air, water, waste, soil, Seveso and IPPC), either the regional or provincial administrations issue permits and are, in most 

of the cases, responsible for the planning of ordinary inspections together with the Regional Agencies for the Protection 

of the Environment (ARPA). Generally the routing site visits are fulfi lled by the ARPAs, while the non-routing site visits 

due to either serious environmental complaints, environmental accidents, incidents and occurrences of non-compliance 

are carried out by the Carabinieri Corps for Environmental Protection, the Provincial Police (on request of the provincial 

authorities), the Financial Guards and the State Forestry Corps, together with the ARPAs who provide technical support. 

But in most of the cases the Police Authorities (Provincial Police, Carabinieri Corps, Forestry Corps and Financial 

Guards) are in charge to investigate and/or identify environmental crimes such as for example illegal waste business, 

illegal water discharges, etc. APAT, the Agency for Environmental Protection and Technical Services (former ANPA) 

executes inspections, controls and monitoring for Seveso (together with the Ministry of Environment, the National Body 

of Firemen, ISPESL, ARPAs, for nuclear matters and for the competencies assigned to the Agency. 7 In some Regions, 

due to institutional competencies, the State Forestry Corps realises routing site visits while the ARPA provides technical 

support on sampling and analysis. 

Latvia 

Inspection on implementation of environment law in Latvia is carried out by inspectors of State Environmental Service 

(SES) under the supervision of the Ministry of Environment. SES associated all institutions which manager supervisory 

and control 8 Regional Environmental Boards, Marine Environmental Board and central structure of SES. The main 

task of the inspectors of the SES is control and supervises the implementation of legislation framework in the area of 

environment protection and natural resources use in the territory of Latvia, continental shelf, economic zones of the 

Baltic Sea and the Riga Gulf, territorial waters and inland waters. It also supervises and guides environmental inspector 

activities of Regional Environmental Boards, Marine Environmental Board and other specially protected nature territories. 

The national body may also undertake inspections and participate in decisions in non-compliance cases. Finally, SES is 

taking particular responsibility for SEVESO-related inspection. Regional Boards are generally responsible for permitting. 

Appeals on permit conditions are heard by the Environmental State Bureau, which also has BAT responsibilities under 

IPPC. Other bodies involved in environmental management include the Occupational Health Inspection, State Labour 

Inspectorate, Fire Service and Municipalities. 

Lithuania 

There are 8 Regional Departments for Environmental Protection, which in turn operate through 56 more local 

Environmental Protection city/district agencies under the Ministry of Environment. The State Environmental Protection 

Inspectorate conducts methodological support. Appeals against punishment procedures are settled only in courts. Both 

national and regional organizations report to the Ministry of Environment whilst the local agencies report to their regional 

department. They cover most but not all environmental sectors. Nature protection is inside their remit, but certain water 

95 



issues (drinking and bathing waters) are outside their remit. Some aspects of waste management are the responsibility 

of 10 county or 60 municipal authorities. Regional departments have permitting, monitoring and laboratory services. 

Local Agencies are responsible for inspection and enforcement. Monitoring is conducted both by Regional Departments 

and National Agency for Environmental Protection and coordinated by National Agency for Environmental Protection. 

Luxembourg 

Inspection responsibilities in Luxembourg are focused at national level, with the Administration for the Environment 

(AfE) having primary responsibility and reporting to the Ministry of the Environment. Routine monitoring and inspection 

is carried out by accredited contractors on behalf of AfE, and Customs and Excise is also involved in some aspects 

(particularly transboundary movements of waste). Offi cials from the Administration of Environment will only perform 

on site visits occasionally and in order to respond to complaints, sometimes in order to verify the work of the external 

accredited experts. 

Former Yugoslav Republic of Macedonia 

In the framework of the efforts aimed at integration into the modern trends of environmental protection in Europe and 

wider, and also as an important segment of the process of reforms, the Government of the Republic of Macedonia 

established the Ministry of Environment (Law on Amendment and Supplementing the Law on Public Administration 

Bodies”, Offi cial Gazette of RM” No.63/98). 

The establishment of this Ministry has not only enabled the development of environmental management system, 

accompanied by adequate institutional capacity and appropriate legislative framework, that is implementation of one of 

the priority recommendations of the National Environmental Action Plan (NEAP), but at the same time the Republic of 

Macedonia joined the modern trends of developed European and world states, where such Ministries represent one of 

the key points in system of public administration, which is its long-term commitment. 

Article 122-а of the Law on Amendment and Supplementing the Law on Public Administration Bodies defi nes the 

competencies of the Ministry. 

The State Environmental and Nature Protection Inspectorate carries out inspection supervision over the implementation 

of technical and technological measures for air and water pollution, conservation of the special natural heritage, 

protection of soil against degradation and contamination, harmful noise and protection against waste matters and nonionizing 

radiation. 

The State Environmental and Nature Protection Inspectorate (SENPI) is a body within the Ministry of Environment 

and Physical Planning. 

The SENPI within MEPPPC, which consists of the head offi ce (Director, Technical Secretary) and 6 branch units in the 

seats of counties, includes within its structure two inspections – environmental protection (13 Inspectors) and nature 

protection (5 Inspectors, in same time are Environmental and Nature Protection Inspectors). 

The Environmental and Nature Inspection is responsible for compliance checking and enforcement of laws; its activities 

are planned on the basis of annual and monthly working plans, with the exception of site visits on an ad hoc basis and 

in cases of emergency. 

The advantage of such an organisation is in the possibility to link and coordinate the proceeding of all inspections in 

emergency interventions as well as in more effi cient sanctioning of violators by simultaneous enforcement of several 

laws. Inspectors have the obligation and duty, in case of non-compliance, to undertake sanctions against the operator 

for offences or to press administrative and criminal charges. 

Inspectors have still a role in informing/advising as well as carrying out inspection. 

The capacity of the inspection is going to be strengthened in order to provide a satisfactory degree of regulations 

implementation. MoEPP has set as a priority capacity building and sector specialisation by certain branches and 

improving permanent coordination of the activities with inspections in other line bodies. 

The Environmental and Nature Inspection is strongly involved in the process of proposing and adopting new legislation 

as well as in pertaining in its implementation. 

The Sector for EU and International co-operation within the SENPI coordinates all activities related to adjustment of 

inspection to EU standards and to Council Recommendation Providing Minimum Criteria for Environmental Inspections, 

which is directly linked with the process of EU approximation that Republic of Macedonia currently going through as a 

candidate country. More information on our offi cial web page: www.moepp.gov.mk. 

Malta 

In Malta, three authorities respond to the major number of inspections and enforcement requirements of the environment 

and nature related directives or national legislation. MEPA is the competent authority responsible for the implementation 

of the majority of environmental laws. Coordination between the other two competent authorities - Occupational Health 

and Safety Authority (responsible for Seveso) and the Malta Resources Authority (responsible for water pollution and 

resource management) - is achieved through bilateral or multilateral ministerial committees, and formal memoranda of 

understanding (being fi nalized). 



96

In addition, several other bodies are described as playing a technical role, with the Malta Police Force playing a very 

important role in offering support on access and enforcement. Local Councils are also involved through their Warden 

Service. 

There are currently 22 staff members within the Environment Protection Directorate – MEPA, dealing with the 

policymaking, permitting, implementation and enforcement of environmental related legislation in regards to pollution 

control, waste and mineral issues. Regular monitoring is being carried out in the following fi elds: marine, air, mineral 

extraction and land fi lling. 

Inspections are carried out according to a work plan devised on a yearly basis. Both announced and unannounced 

inspections are performed. The inspectorate possesses prosecutorial powers but the system is still not in place. A 

database of inspections and permits has been established. This enables the inspector to fi ll in a report after every 

inspection and provide this information to the other inspectors instantly. 

Other branches within MEPA are responsible for other areas, e.g., nature protection. 

The Netherlands 

In the Netherlands more than 500 organisations have roles and responsibilities for inspections. Coordination of 

inspection activities is ensured by the National Conference on Environmental Enforcement (ALOM/BLOM) and the 

National Information Service for Environmental 8 Enforcement (LIM) at national level and 35 service points of the 

Regional Service for Environmental Law Enforcement (SEPH) at sub-regional level. Provinces, municipalities and water 

boards are largely responsible for permitting and inspection. However, for certain sectors, e.g., Nuclear installations 

and transfrontier shipment of waste, these activities are performed by central organisations like the Inspectorate for the 

Environment (part of the Ministry of Housing, Spatial Planning and Environment and the Directorate General of Public 

Works and Water Management (Rijkswaterstaat). The Inspectorate General carries out a supervisory role over provinces, 

municipalities and water boards, including fi rst- and second line compliance checking and enforcement actions. 

Norway 

The Ministry of the Environment is responsible for all subordinate agencies with responsibility for environmental 

protection. The Norwegian Pollution Control Authority (SFT) is one of the subordinate agencies to the Ministry of 

the Environment. SFT’s Department of Control and Emergency Response carries out enforcement and monitoring of 

compliance in industry at the national level. The 18 County Departments of Environmental Affairs are also subordinate to 

the Ministry of the Environment and administers parts of the Pollution Control Act. They are responsible for enforcement 

and monitoring of compliance of municipal functions and some types of industries at the regional level. SFT is authorised 

to issue instructions to the County Departments of Environmental Affairs concerning, e.g., pollution, and waste. Local 

authorities are also involved in inspections. 

Poland 

In Poland the environmental inspection authority is a single structure with the Chief Inspectorate for Environmental 

Protection setting out the directions of work for 16 Voivodship Inspectorates for Environmental Protection and their 34 

Field Offi ces. Its responsibilities focus on inspection and enforcement, with permitting limited to transfrontier shipment 

of waste (exclusive competence of the Chief Inspector for Environmental Protection). Generally permitting is carried out 

by the Ministry of Environment and the regional authorities. 

The fi eld of action of the Inspection covers most environmental sectors, including GMOs, packaging, Seveso and emission 

trading. Outside the Inspection’s competences is nature protection, drinking water and bathing water. The Inspection is 

also responsible for state of environment monitoring and for reporting. 

The Chief Inspector hears appeals from the Voivodship Inspectorates’ decisions and also can undertake inspection 

activities belonging to the competencies of the Voivodship Inspectorates when considered it as justifi ed with regard to 

the importance and complexity of those activities. 

In case of non-compliance there is a wide range of sanctions available for the inspectors, from issuing post-control 

instructions, giving administrative or penal fi nes, to informing the prosecutor and suspending the operation of installation. 

Nevertheless, the inspectors have also an important role in informing and advising the society. 

Portugal 

Ministry of Environment, Territorial Planning and Regional Development (MAOTDR) plays a key role for inspections at 

National Level (through the Inspectorate General for Environment and Territorial Planning (IGAOT)) as well as for coordinating 

inspection and enforcement. The IGATO is the competent authority for implementation and enforcement of 

environmental law with an integrated approach for inspections dealing with different types of pollution - air, noise, water, 

solid wastes, and also other aspects related to environmental legislation, e. g., industrial safety, critical areas for risk. 

IGAOT also performs inspections related to the territorial planning issues and inspections to verify the compliance of 

the SEVESO Directive (SEVESO inspections). IGATO deals also with checking compliance with environmental contract 

and water supply systems, discharges from municipal wastewater plants and collective industrial wastewater plants 

97 



and accidents. For all the cases inspections are often carried out by unannounced on-site visits. Permitting for waste 

water discharges is up the fi ve regional departments of the Ministry of Environment, Territorial Planning and Regional 

Development as well as to check the compliance for this license by low educated trained personnel in drive by visits. 

The Environmental Permit (IPPC permit) is issued by the Environmental Institute. 

Romania 

The structure of the Ministry of Environment and Water Management includes separate institutions for environmental 

inspections - National Environmental Guard (NEG) and for permits issuing, monitoring, strategies and projects - 

Environmental Protection Agencies. NEG is a public institution for environmental inspection and control, with juridical 

status, fi nanced from the public budget, under the subordination of the Ministry of Environment and Water Management 

and has competences in governmental policy enforcement in the area of prevention, ascertainment and penalization 

of the infringements of the legal provisions concerning the protection of environment. NEG includes a General 

Commissioner’s Offi ce, which subordinates 8 Regional Commissariats. Each Regional Commissariat, subordinates 

4-7 county commissariats (in total 41 counties plus Bucharest and the Danube Delta biosphere reserve), having as 

main task to perform inspections for all environmental factors (air, noise, water, solid wastes, protected areas and 

also other aspects related to environmental legislation i.e. industrial safety, pollution prevention control etc). The NEG 

commissariats are also involved in the permit issuing process for both IPPC and non IPPC installations. Under the 

Water Administration (subordinated also to the Ministry), a water inspectorate exists in parallel with a supervising team 

at the Ministry level plus inspectors in 11 river basin areas. 

Environmental Protection Agencies are organized as follows: A National Environmental Protection Agency coordinates 8 

Regional Environmental Protection Agencies and 42 Local Environmental Protection Agencies. Regional Environmental 

Protection Agencies have mainly responsibilities on IPPC permits issuing, conceiving of regional strategies, actions plans 

and projects. Local Environmental Protection Agencies have mainly responsibilities regarding the “non IPPC” units 

permitting and monitoring. 

Slovakia 

In Slovakia the inspection authority structure combines national, regional and local responsibilities. The Slovak 

Inspectorate of Environment (SIE) is a specialized supervisory authority providing for the state supervision and 

imposing fi nes and introducing corrective measures on the matters concerning environment protection and carrying 

out the municipal administration in the fi eld of integrated pollution prevention and control. The administrative structure 

comprises headquarters located in Bratislava providing methodological and professional support to the fi rst-level 

decision-making 4 regional environmental inspectorates. The SIE headquarters coordinate SIE work nationwide and 

internationally and represent the appellate authority to the appealed fi rst-level decisions of regional inspectorates. There 

are 49 district environmental offi ces under the aegis of the Ministry of Environment responsible for all environmental 

sector permits and 8 regional environmental offi ces represent appellate authority to the appealed fi rst-level decisions of 

district environmental offi ces. District environmental offi ces also have powers of inspection and enforcement to ensure 

permit conditions are met. 

Slovenia 

Ministry for Environment and Spatial Planning (MESP) has overall responsibility for environmental policy. Inspectorate 

for Environment and Spatial Planning (IRSEP), as a body within MESP, with 8 branch units, is the national inspection 

authority which undertakes inspection and enforcement activities on the basis of state legislation. Inspection on the local 

level is exercised by local inspection services pursuant to local legislation; they have limited competences to undertake 

inspection. IRSEP is responsible for inspection of air and water emission, water management, waste management, 

nature protection and GMO and is not included in permitting procedure. Permitting authority is the Environmental 

Agency which is also a body within MESP. Between IRSEP and Agency is a close cooperation. In case of minor offence 

inspector impose a fi ne. For the implementation and enforcement of some part of the environmental legislation also 

other authorities are responsible: Health Inspectorate, Inspectorate for Agriculture, Forestry, Hunting and Fisheries, Trade 

Inspectorate, Inspectorate for Protection against Natural and other Disasters, Customs and Police. Therefore a close 

cooperation is established. 

Spain 

The organisation of the inspection system in Spain is largely comparable to the situation in Germany. There is no national 

inspecting body. The main focus of inspection and enforcement in Spain is at “regional” level, keeping in mind that 

Autonomous Communities in Spain are no regions as such and have their own government, parliament, legislation, 

etc. The 17 Autonomous Communities and the two autonomous cities of Ceuta and Melilla have prime responsibility 

for inspection through their Environment Departments or “Consejerías”. At national level the Ministry of Home Affairs 

is responsible for the implementation of Seveso II, while the nature protection services of the Civil Guard (SEPRONA) 

provide investigation and control support to Autonomous Communities. At water basin level, the 9 Water Management 



98

Boards are responsible for inspection and enforcement relating to discharges to inland waters. At local levels some 

offi cials are also involved. 

Sweden 

In Sweden environmental inspection takes place at three levels (National, Regional and Local). The Swedish 

Environmental Protection Agency (SEPA) is the central authority on supervision concerning all the directives listed by 

Commission as connected to the Recommendation except for the SevesoII Directive. The Swedish Rescue Services 

Agency is the central authority on supervision concerning SevesoII Directive. Both these authorities have a role concerning 

guidance, evaluation, co-ordination as well as giving advice and support to the regional and local authorities carrying 

out inspection and enforcement. Swedish environmental inspection and enforcement concerning installations and other 

activities, among which the Controlled Installations according to the Recommendation 2001/331/EC only are a minor 

part, is mostly planned and carried out at regional and local level. There are 21 regional authorities responsible for 

inspection and enforcement concerning all the listed directives. For all the listed directives such inspection responsibility 

may be delegated after a special procedure to the local environmental authorities of which there are 290, also having 

other environment and health protection inspection responsibilities. The Surgeon General (National) is responsible for 

inspecting military installations. Operators are required to self-monitor (there is a separate Operator Self Monitoring 

Ordinance) and demonstrate compliance with their permits. Permitting is carried out by four Environmental Courts and 

the above mentioned 21 regional environmental authorities. At the regional authorities the permitting and inspection 

is taking place at the same authority. Special governmental instructions keep the licensing task separated from the 

inspection task. The Enforcement and Regulations Council has been established for exchange of experiences between 

the central, regional and local authorities under the Swedish Environmental Code. 

Turkey 

The Ministry of Environment and Forestry (MoEF) has overall responsibility for control and monitoring of activities that 

have impact on the environment. If needed, this competence might be transferred to other institutions and organizations 

(Provincial Special Administrations, Municipalities which have established their own environmental inspection units, 

under secretariat of Maritime etc.) by the MoEF. The Ministry has three main service units related to environmental 

issues: the Directorate General for the Environmental Management, the Directorate General for EIA and Planning, the 

Directorate General for Nature Protection and Natural Parks. 

In Turkey, there is an integrated environmental inspection system since 2002; the Inspection Department has been 

established under the General Directorate of Environmental Management. Whereas the existing environmental 

permitting system is media based (water, air, waste etc.). The permitting departments are responsible for follow-up 

permit compliance checking related to their working areas (air, waste etc.). Also the inspectors working in permitting 

departments participate in the integrated inspections under the coordination and leading of the Inspection Department. 

The integrated inspection teams consist of chief inspector from the Inspection Department, inspectors from related 

permitting departments, and also an inspector from the host Provincial Directorate. Inspections are carried out in frame 

of an annual programme prepared by the Inspection Department and approved by the Minister. In total number of 

inspectors (already trained for integrated inspections) in permitting departments of the MoEF is 170, and the number of 

chief inspectors in the Inspection Department is 7. 

The Ministry has 81 Provincial Directorates all over the country. These Provincial Directorates carry out media based 

inspections (water, air etc.) as well as the unplanned inspections (complaints, incidents etc.) in their responsibility 

area. 

The effectiveness of environmental enforcement system has been increased with the Environmental Law dated 26 

April 2006. According to this new law, the enforcement authority of governors was completely transferred to Ministry 

of Environment of Forestry. According to law, the MoEF and its provincial offi ces are fully responsible for environmental 

inspection and enforcement. Furthermore, in the frame of this law, certain number of new personnel will be employed 

to strengthen the institutional capacity. 

United Kingdom 

In the UK, there are three principal separate organisations, which regulate the environment. These are the Environment 

Agency of England and Wales, the Scottish Environment Protection Agency and the Northern Ireland Environment and 

Heritage Service. These organisations deal with, amongst other things, issuing permits, carrying out inspections and 

enforcement. Local authorities also have a role in some types of inspections, although in Scotland their role is fairly 

limited. Environmental negotiations in Europe are dealt with at the UK level by the Department for the Environment, Food 

and Rural Affairs (Defra), which means that all three organisations work together with central or devolved government. 

The Department of Trade & Industry covers offshore installations at a national level. 

99 



The 3rd IMPEL Conference in Riga (Latvia) 

27-29 September 2006 

1. Your identity (please tick): 


a. State institution � 

b. Regional institution � 

c. Local authority � 

d. Other � 

2. Do you have information about IMPEL activities on regular basis? 

a. Regularly � 

b. Sometimes � 

c. Never � 

3. How is the information provided? 

a. By e-mail � 

b. In offi cial round letters � 

c. Other � 

i. Which_______________________ 

4. Would you like to have more information? 

a. Yes � 

b. No, it is Suffi cient � 

5. Which activities of IMPEL have you recognized in your country? 

a. (describe)__________________________ 

b. __________________________________ 

6. How do you asses your country’s participation in the IMPEL network? 

a. Active � 

b. Moderate � 

c. Passive � 

7. Is the IMPEL network a useful tool for international experience exchange? 

a. Very useful � 

b. Moderate � 

c. Useless � 

8. Does IMPEL network help to achieve a better environment? 

a. Yes, a lot � 

b. Partly � 

c. Not at all � 

9. Which IMPEL products you would like to implement and develop in your country? 

a. Describe_________________________ 

b. ________________________________ 

10. What do you expect from IMPEL in future? 

a. Describe_________________________ 

b. ________________________________ 


100 

Questionnaire

Ms. Hilda Farkas (IMPEL Secretariat) 

Ms. Jasna Paladin-Popovic (Croatia) 


Ms. Vita Jokumsen (Denmark) 


Mr. Markku Hietamaki (Finland) 

Ms. Annick Bonneville (France) 


Mr. Pal Varga (Hungary) 

Mr. Ed Eggink (The Netherlands) 


Ms. Lucja Staszkiewicz-Szwarocka (Poland) 

Mr. Terry Shears (United Kingdom) 

Mr. Ken Ledgerwood (United Kingdom) 

Ms. Judite Dipane (Latvia) 

Mr. Vilis Avotins (Latvia) 

Preparatory Committee

for a better environment - IMPEL

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