Scholarly record
INTEGRATED ENVIRONMENTAL PERMITTING IN RUSSIA: FIRST RESULTS AND LESSONS
Abstract
In Russia, Best Available Techniques (BAT) are considered to be Environmental Industrial Policy instruments, used both by environmental and industrial authorities. The Ministry for Natural Resources and Environment (Minprirody) and the Federal Supervisory Natural Resources Management Service (Rosprirodnadzor) are responsible for the development of environmental legislation and its enforcement. The Ministry for Industry and Trade (Minpromtorg) works out industry-related acts, sectoral and regional programmes, and uses financial instruments stimulating implementation of BATs. In 2019, first Integrated Environmental Permits (IEP) based on BATs and BAT-Associated Emission Levels (BAT-AELs) were granted to Russian Category I installations (similar to the European Integrated Pollution Prevention and Control, IPPC) installations. Procedure used in 2019 was worked out as the result of the five-year collaboration of environmental, industrial authorities, business, and civil society. In Russia, Environmental Performance Enhancement Programmes (EPEPs) have to be worked out by installations not fully meeting BAT-AEL requirements. Of 17 Category I installations granted IEPs in 2019, seven prepared EPEPs to be implemented for 7 years. Draft EPEPs were assessed by the Inter-Departmental Commission (IDC). BAT experts (leading professionals who participated in the development of BAT Reference Documents, BREFs and national BAT standards) supported the assessment processes, reviewed draft EPEPs and provided conclusions used by IDC. Though most Category I installations, which obtained IEPs are existing industrial installations, they had to run Environmental Impact Assessment Procedures (EIA), public hearings and undergo State Environmental Reviews (SER). This resulted in long ?preparatory? periods (more than 5 months), and the actual assessment of IEP applications appeared to be extremely short (less than 2 weeks). Industrial managers focused on EIA procedures paid less attention to the preparation of IEP applications and hoped that consulting companies experienced in EIA procedures would manage preparing applications for them. BAT experts supported Rosprirodnadzor both at the stage of the State Environmental Review and during the assessment of IEP applications. In 2020, the IEP granting procedure will be changed to exclude the SER and to add IEP assessment by public health, water resources, fishery management, and other authorities.
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References2
Best Available Techniques (BAT) for Preventing and Controlling Industrial Pollution, Activity 3: Measuring the Effectiveness of BAT Policies, Environment, Health and Safety, Environment Directorate, OECD. 2019. URL: https://www.oecd.org/chemicalsafety/risk-management/measuring-the-effectiveness-of-best-available-techniques-policies.pdf
Guseva T., Potapova E., Molchanova Y., Lomakina I., Begak M. Public Dialogue in the Field of Best Available Techniques and Integrated Permits: Lessons from Russian Construction Materials Industry. In: Proc. International Multidisciplinary Scientific GeoConference SGEM. 2017. Vol. 17. Is. 5.2. Pp. 733-740.
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