Input on the environmental challenges and participation in environmental decision making processes in Macedonia
Provided by Eko-svest Macedonia
Challenges in the environmental sector
Air Pollution– Although the EU legislation has been almost fully transposed, implementation and enforcement are still not satisfactory, resulting in high pollution levels in the country. Funding remains an issue, and even though a special clean air fund was created in 2019, there is no integrated and synchronized way of tackling this problem. More capacities are needed to implement practical projects, monitor and evaluate and perform research in the area of air pollution and health impact.
Another challenge in the sector remains the IPPC permit for the Bitola Thermo power plant as the process has finally begun but it is questionable whether significant investments will be actually made if the Energy Strategy plans the closure of this installation by 2025 (depending on scenario). In either case (investment or not) the economy and human health are at stake.
Just transition as a way forward is a challenging new opportunity for the country both for Oslomej and Bitola regions. Economic feasibility study for the Kichevo region show far better economic development of the region without the thermos power plant. Even though initial discussions have started about the transformation of the region, no practical implementation (except the PV plant in Oslomej) and no long term strategies and plans are in place (in the case of Bitola, the discussion is not even started).
Climate action– Main challenge remains the finalization of the Climate Law and Strategy, and mainstreaming climate in all other strategies and plans on national and local level. Some efforts have been made in preparation of local action plans but little has been done in practical terms. Upcoming revisions of strategies and preparation of new legislation within other ministries do not take into consideration climate change mitigation and adaptation (with the exception of the new transport and energy strategies).
Nature protection– The conflict between infrastructure development and nature protection remains a challenge. In 2019, a tender procedure was launched for 22 hydropower project concessions and 11 of them were located in a protected area such as national park, Emerald site, future Natura2000 site). A major challenge is the proclamation of the NP Shar Planina due to an issued hydropower concession in the territory of the future national park.
The upcoming revisions and changes to legislation such as the hunting law and forest law needs to involve conservationists and nature protection authorities. The hunting law is being prepared without the consultation of wider stakeholders.
Other major challenges in the sector are the waste management (implementation seems to lag behind for decades), water management (improvements in the waste water treatment but not in the protection of drinking water and river basin protection), and the implementation of EIA/SEA Directive which needs to improve. In some cases, projects are being “salami-sliced: to avoid the full EIA procedure (Skopje- Blace highway). In other cases, such as the hydropower development, none of the projects were subject to EIA procedure, even the ones in protected areas. Funding for environment is again not delat with in a systemic way as environmental taxes end up in the central budget instead of a special Fund or Agency which would administer the funding, implement the projects and deal with operational matters in the sector.
Participation in environmental decision making
The preparation of the Energy Strategy involved a consultative panel of CSOs which were self-selected and self-organised in the process. They were able to review documents and provide inputs in key periods of the process. The collaboration was seen as beneficial by the Government. The public consultation process for the draft strategy was extended after the request by CSOs and two public hearings were held.
Note: Even though the process was constructive and included CSOs, informing the public should have been done better and fully following the principles of the Aarhus Convention.
Involvement of CSOs in governmental bodies
The Council for the cooperation with CSOs was established and the work was quite intensive in the first year with sessions almost every month. Although this is a governmental body which enables the authorities and CSOs to discuss jointly about the improvements in the cooperation and strengthening of the capacities of CSOs, it is still work in progress. Regretfully, as CSOs take this work seriously by attending regularly and preparing for the sessions, the Governmental institutions- members of the council do not seem to share the same motivation.
The intersectorial working group for air pollution is also a governmental body that involves the participation of CSOs. It allows the institutions and CSOs to interact on the plans around tackling air pollution levels in the country by exchange of views, presentation of data and drafting plans and programmes. In the past, the participation of CSOs was either not allowed or limited to participation but no interation. The new set up of this working group started in 2018.
Involvement of CSOs in working groups for drafting new legislation
Since 2012 the environmental CSOs have signed a memorandum of understanding with the Ministry of environment on the cooperation and communication practices and principles. According to this memorandum, the Ministry needs to contact the CSO structure and request the appointment of a CSO representative to a certain working group. This practice was sometimes functional and at other times less so. In the case of the Industrial Emissions Law and the Climate Law and Strategy, the CSOs were able to appoint their own representatives in the working groups.
Changes in legislation without stakeholder involvement and public consultation
This practice was evident in the case of the new changes to the Ambien air quality Law, which happened without the involvement and consultation of CSOs.
The package of Waste related legislation was prepared without the participation of CSOs in the working groups. A public hearing was organized but only after the reactions from CSOs.
Law on hunting is being prepared without environmental CSOs or the Ministry of environment involved in the working groups.
In the case of several EIA processes for coal mining projects (Oslomej, Bitola), national environmental CSOs were not invited, in some cases only the minutes of public hearings were published but not the invitation and announcements.
In the case of the Bitola IPPC permit, the period for comments was extended from 14 to 30 days, after reactions from CSOs, which is still too short for the massive documentation for the permit (500 pages).
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