Twinning Project SK03/IB/EN/01

Institutional and Capacity Building in the Environmental Sector

Activity A: “Standardization of Reporting Processes”

Final Conference, 13.06.2006Svetlana Zhekova

Background

Review of the EC reporting obligations -carried out during the first quarter of project implementation A gap analysis focusing on discrepancies between the data required for reporting under the EU legislation and that available in SlovakiaIdentification of possible solutions to overcome the gapsAssessment of the progress achieved, following the gap analysis and the identified possible solutions

Main findings of the GAAIR Sector

No institutional gaps in the Air sectoral reporting were identified in the gap analysis exercise

Data flows are well defined and clear

Where data availability gaps were found, measures have been taken to overcome them (for instance, among other measures, the installation of 6 new analysers measuring benzene)

Main findings of the GANATURE protection sector

No institutional gaps in the Nature protection sectoral reporting were identified

As for the data availability, some gaps were relating to the Habitats Directive and steps to overcome them were already taken

All required data for the designated Natura 2000 sites in Slovakia have been provided to the Commission

Main findings of the GAWATER sector

The GA has identified certain data related gaps in the water sector

The GA brought up some issues, mainly of institutional character, that needed to be explored further

Monitoring budget restrictions planned in the middle of 2005, raised uncertainties about the ability to fulfil the reporting obligations

Main findings of the GAWater Framework directive

With respect to the WFD, many of the identified gaps were related to measuring certain indicators and the solution for these issues was to extend the monitoring activities with a view to cover the missing measurementsThis is already taken into account by the ME in future programming of the water monitoring activities; it is important the pace of regular securing of sufficient and regular research and monitoring resources to be kept The issue of identification and including in the Summary Water Database small and medium polluters of groundwater is still to be considered!

Main findings of the GAUrban Waste Water Treatment

Directive

With respect to the UWWTD, the GA has identified overlaps in the waste water discharges data collection and storing

Enterprises were required to report discharged waste water to 3 institutions

As a result 3 databases with similar data on waste water discharges co-exist and could mutually complement (instead of duplicating) each other

Main findings of the GAUrban Waste Water Treatment

Directive Ordinance No 605/2005 to a large extent resolves this issue by providing for data to be sent to the Ministry of Environment

There is an informal agreement between the 3 institutions for mutual exchange of data for their purposes

Ordinance No 605/2005 also resolves the issue of missing data from small municipal and industrial WWTP, by requiring the respective operators to report these data to the ME

Main findings of the GAUrban Waste Water Treatment

Directive

At present, the 3 data bases with similar data on waste water discharges still co-exist, but with the legal provisions already in place, avoiding duplication should be considered at a later stage

Main findings of the GANitrates Directive

The GA concluded that the institutional responsibilities related to assessment of surface water pollution by nitrates from agricultural sources were not clearly defined and needed to be further clarified

Considering this gap, the Implementing Regulation to the Water Management Act was amended accordingly by Regulation 221/2005, where the respective institutional responsibilities were assigned to the Slovak Hydrometeorological Institute

Main findings of the GABathing Water Directive

The GA concluded that stronger cooperation between the MoE and the MoH is needed for the implementation of the Bathing Water Directive related reporting obligations, with respect to the development of programme of measures for the river basin management plans

Formal agreement between the MoE and the MoH has not been considered yet

Main findings of the GABathing Water Directive

With respect to the bathing water quality the responsibilities are divided as follows:

- MoE issues waste water discharge permits;

- MoH holds the competencies related to the BW quality management

A formal agreement between the two institutions is still needed to ensure proper information flow for reporting purposes

Main findings of the GA Directive on the quality of water intended for human consumption

Co-operation between the MoH and the MoE needs to be clearly defined also with respect to the Directive on the quality of water intended for human consumption, in order to develop compatible databases containing information needed for reporting purposes (data on drinking water sources, on suppliers and on drinking water quality)

Main findings of the GADangerous Substances Directive

and its Daughter Directives Uncertainties in data keeping and provision were identified during the reporting GA of the DSD and its Daughter Directives.

According to the Slovak Water Act, the permit registers are kept by:

- the district environmental authorities – for a particular district;

- the river basin authorities – for water bodies on river basin level;

- the administrative bodies dealing with small water courses – for smaller water entities

Main findings of the GADangerous Substances Directive

and its Daughter Directives

There was a lack of legal basis for keeping a water related permits register on central level in Slovakia. The newly adopted Ordinance No 221/2005 provides for the establishment of a Permits Register as part of the Summary Water Register (SWR)

Data on discharged volumes of dangerous substances is often missing in the permits authorized by the District Environmental Offices

Main findings of the GAWater sector

General issue

A general institutional issue identified by the GA: SHMI, SWME and SWRI report data to the SEA directly upon request (for SoE reporting) or via the MoE (for other purposes)

There is a room for further simplifying the process of information exchange between the four institutions within the Ministry of Environment

Recommendations Water sector

On institutional level:

Stronger cooperation is needed between the Ministry of Environment and the Ministry of Health

Further simplifying the process of information exchange between the four institutions within the Ministry of Environment

Recommendations Water sector

With respect to data handling:

Inclusion into the Summary Water Register of data on indirect discharges of dangerous substances and on discharged volumes of dangerous substances should be considered

Identification and including in the database small and medium polluters of groundwater

Avoiding duplication of data on waste water discharges kept in 3 separate database, should be considered

ConclusionsWater sector

All institutions in Slovakia, responsible for reporting, came to the common vision that the reporting related gaps in the water sector might be deepened if streamlining measures are not taken in a timely and reasonable way, and financial resources are not secured for proper and comprehensive monitoringThere is a clearly stated political will now, for the reporting related needs to be taken into account in future programming of the monitoring activities It could be expected that respective resources would be foreseen in the monitoring budgetNumber of steps have been taken to rationalize reporting in the water sector, and to overcome institutional gaps related to data provision or streamlining of the information flow

Main findings of the GAWaste sectorGeneral issue

The main overlap identified by the GA in the waste sector concerns the information collection from municipalities as waste information providersAccording to the existing legislation they were required to provide more or less the same information to both the Statistical Office and their respective District Offices for Environment in two different formatsAn agreement between the Ministry of Environment and the Statistical Office has been signed. According to this agreement the municipalities are required to report municipal waste data to the SO only, while information on hazardous and construction waste is reported by the operators to the DEO

Main findings of the GA Waste sector

Data related issue

The problem which remains to be solved in relation to the Regional Waste Information System is related to validation of the data providedThe Ministry of Environment has commissioned the Environmental Agency to manage the system, but the validation of the RWIS data is still not provided for in the existing legislation. Even though the validation is within the competency of the District Environmental Offices and they are providing it in practice, it is important from the point of view of information reliability the validation of the RWIS data to be provided for in the existing legislation

Main findings of the GA Waste Oils Directive

With respect to the Waste Oils Directive, the existing statistics in Slovakia did not dispose of data related to the various undertakings which dispose of waste oils, because the waste oils related data is not collected separately from information on other hazardous waste streamsWaste oils sub-database within the hazardous waste one is not established yet, but should be considered at a later stage

Main findings of the GA Landfills Directive

Data on biodegradable municipal waste produced and going to landfills was missing in the Slovak statisticsOvercoming of this data availability gap has been duly considered, and a requirement for collection of the respective data was included in the national State Statistics Regulation, which is published annually and provides for the yearly State Statistical Surveys Programs

Main findings of the GA End-of-life Vehicles

Information from ELV treatment facilities is collected in the respective district environmental offices, where the permits are issued, and there is not a single database established to collect and keep the data provided by permitted installationsFurthermore, the term “required data” is still not defined in the Slovak legislation and it is not clear what information on substances, materials and components accepted for treatment, the permitted facilities are supposed to provideOne single authority to collect and evaluate the data provided by the ELV treatment installations needs to be designated by law.The need for a special Regulation on ELVs has been recognized by the Slovak authorities and should be further considered

Main findings of the GA Sewerage Sludge Directive

A new law on the soil application of sewage sludge was enforced in 2004, but it did not designate the authority to establish a register of the sewage sludge generated and applied on soilsThere is an informal agreement between the MoE and the MoA on the division of responsibilities relating to the reporting: MoE to provide data on sewerage sludge generation; MoA to provide data on sludge applicationIt is proposed a body to establish and keep a sewage sludge register to be designated through a Ministerial Order, but no final decision has been taken yet

Main findings of the GAPackaging Waste Directive

A packaging waste database has been developed at SEAPilot report was prepared under the Packaging Waste Database Decision (97/138/EC) and sent to the EC on 30th June 2005The pilot reporting exercise has found that it was necessary to legally define both the operation and administration of the packaging waste information system An amendment to the Packaging Act was drafted in September 2005, but neither requirements on the system itself, nor on its administration have been provided for in the amended legislationThe SEA should be given a legal mandate both for administration of the information system, and for reporting on packaging wasteA requirement for obliged persons and authorized organizations to provide data directly to the SEA should also be embodied in the law

Recommendations Waste sector

Clear provisions on validation of the RWIS data should be introduced in the existing legislationSEA should be given a legal mandate for reporting on packaging waste and operating the packaging waste information systemThe authority to establish a register of the sewage sludge generated and applied on soils should be designatedA special Regulation on ELVs needs to be adoptedWaste oils sub-database within the hazardous waste one is not established yet, and should be considered at a later stage

General Conclusions and Recommendations

A clear picture of the reporting readiness in Slovakia is the main result of the GA exercise.

On this basis possible solutions have been identified and can be implemented to overcome the identified gaps

General Conclusions and Recommendations

The main institutional issue of general character identified by the gap analysis is that with the ME delegating the responsibility for fulfilling environmental reporting obligations to the SEA, this process has become quite complicated and would still need some streamlining…For the institutions that are part of the Ministry of Environment’s system (SEA, SWME, SHMI WRI) it would be logical and time saving the data flow to be organized as a direct information exchange between them. Instead of requesting data from an institution via official letter to the Ministry of Environment, data requests from SEA should go directly to the institution in question (copy to the MoE), who, in turn, should supply data to SEA only after they have been verified/validated by the Ministry.

General Conclusions and Recommendations

With the delegation of many reporting related tasks, the institutional position of SEA should be strengthened:The role of SEA in environmental reporting should be laid down in the law to facilitate getting the required data from data providersWhenever possible, agreements between institutions should be put in writing to guarantee continuity and to allow SEA to best fulfil its reporting tasks Knowledge of new legislation is key for SEA to update their databases on environmental reporting obligations. A regular exchange of information between experts of the ME and SEA, who participate in different EU working groups, should be instigated and institutionalised

Conclusion

All Standardization of Reporting Process activities, carried out within the Project, have been quite a good basis for:

- inter-institutional discussions - further increasing awareness about

reporting related issues - encouraging commitments to provide

the necessary resources needed to fulfil the Slovak environmental reporting obligations