2.A.4.1 Reduction and regulation of operational discharges (point sources)
Problems Stakeholders Proposals Milestones
Lack of licensing procedures for regulating the reduction of operational discharges Ministries of the Environment

Regulatory committees for the environment

Private sector/ state enterprises

Municipalities

 Governments are advised to adopt and implement, by December 1999, the laws and mechanisms necessary for regulating operational discharges with a view to the gradual reduction of inputs of harmful substances in general and the eventual elimination of discharges of persistent organic pollutants of global significance (POPs). The basis for regulating discharges should be a licensing system consisting of the following components:
  • marine environmental quality objectives based on the different uses to which water is put (e.g. drinking water, bathing water, ports) and with which licensees shall comply,
  • procedures for the application and issuing of licenses,
  • procedures for integrating scientific advice into the licensing procedure,
  • effluent charges, based on the polluter pays principle,
  • procedures for purposes of monitoring compliance, including the role of the licensee,
  • enforcement procedures, and
  • fines.

Such a licensing system would constitute an essential step towards the implementation of article VII and the Protocol on Land Based Sources of the Bucharest Convention.

 By December 2000 all operational discharges of harmful substances will be regulated through national licensing systems.

By 2025 all operational discharges of POPs will be eliminated.
Lack of harmonized marine environmental quality objectives Ministries of the Environment

Istanbul Commission

 Governments are advised to harmonize marine environmental quality objectives based on the different uses to which the water is put (e.g. drinking water, bathing water, ports) in order to implement the Protocol on Land Based Sources to the Bucharest Convention. It is advised that the Panel on Pollution Control of the Istanbul Commission commence work on the harmonization of marine environmental quality objectives and where appropriate, standards, in 1996 and prepare recommendations for adoption by the Istanbul Commission in mid 1998.

It is advised that the marine environmental quality objectives and standards adopted be reviewed every five years within the Istanbul Commission with the object of the gradual reduction of inputs of harmful substances in general and the eventual elimination of discharges of POPs. The reviews conducted by the Istanbul Commission should include a broad cost benefit analyses, taking into the account the benefits which further reductions of inputs will realize for public health and the environment and the overall costs involved in attaining such reductions.

The marine environmental quality objectives adopted by the Istanbul Commission should provide the basis for the marine environmental quality objectives which governments incorporate into their national licensing systems.

The initial costs of establishing common objectives will be $300.000 with reoccurring review costs at $100.000 every 5 years.

 Harmonized marine environmental quality objectives will be applied to all discharges of harmful substances by the December 2000.
Lack of harmonized compliance monitoring procedures Ministries of the Environment

Istanbul Commission

Inspectorates

 Governments are advised to harmonize the procedures used for monitoring compliance in order to implement the Protocol on Land Based Sources to the Bucharest Convention. It is advised that the Panel on Pollution Control of the Istanbul Commission commence work on the harmonization of the procedures for monitoring in 1996 and prepare recommendations for adoption by the Istanbul Commission in mid 1998. The procedures adopted should be compatible so as to enable comparison of data. The costs of realizing these procedures should be absorbed by governments with ODA support where appropriate. The international costs for attaining harmonization will be $200.000 per annum (for the start-up period of 3 years). Harmonized procedures will be applied to measure compliance with licenses emitting harmful substances by December 2000.

Full and compatible data from all Black Sea states will be available by 2001 which will enable more accurate assessments of inputs of harmful substances into the Black Sea.
Lack of enforcement mechanisms Ministries of the Environment

Other Ministries in each of the states

Inspectorates

 Governments are advised to adopt and implement, by December 1999, efficient enforcement mechanisms consisting, where possible, of both administrative and judicial sanctions which can be imposed on those licensees which do not abide by the terms of their license. Such sanctions shall include fines. Effective deterrents to avoid non-compliance with environmental measures aimed at reducing operational discharges will be applied by December 1999.
    In the interim, Governments are advised to consider negotiating reduction programs for emissions of harmful substances with the individual entities responsible for generating operational discharges, especially with those identified as hot spots in 3.A.3) On the short term reduction of operational discharges from hot spots.
Weak staffing of relevant agencies both in terms of quantity and quality Ministries of Environment

Inspectorates

 In order to secure the implementation of the above proposals, Governments are advised to ensure that the licensing, monitoring and enforcement agencies have the appropriate qualified staff and the necessary supporting resources (e.g. laboratories, equipment and operating costs) to undertake the tasks expected of them.

Where necessary, the organization of training courses for regulators and inspectors on location is advised.

 By December 2000 efficiently functioning licensing, monitoring and enforcement agencies in all Black Sea states.
Inadequate incentive structure facing polluters Ministries of Environment

Private sector/state enterprises

Municipalities

Households

 Governments are advised to consider adopting and implementing by December 2000, the following economic instruments, possibly initially on a pilot basis:
  • polluters payment of compliance costs;
  • effluent charges based on the polluter pays principle;
  • eco-incentives for environmentally friendly production process or other innovations which reduce inputs of harmful substances, financing for which should be generated from fees, charges and penalties.

Instruments should be set at levels which reflect the benefits of improvement or the costs of removal.

 Implementation of the polluter pays principle with the generators of pollution paying for a large part of the compliance costs.

Overall end product: By December 2000 efficiently functioning and compatible licensing systems in operation in all Black Sea States.

See also
2.A.4.2 Reduction and regulation of operational discharges (dumping)
2.A.4.3 Reduction and regulation of operational discharges (vessels)
3.A.3 Hot Spots in the Black Sea Region