Survey on the Situation with the Waste Dis- Posal in the Republic of Macedonia

Republika Makedonija NARODEN PRAVOBRANITEL Republika e Maqedonisë AVOKATI I POPULLIT Republic of Macedonia OMBUDSMAN

SURVEY ON THE SITUATION WITH THE WASTE DIS- POSAL IN THE REPUBLIC OF MACEDONIA

July-October, 2016 Title: Survey on the situation with the waste disposal in the Re- public of Macedonia

Publisher: Ombudsman of the Republic of Macedonia

Editing board: Ombudsman of the Republic of Macedonia

Translation: Slavica Dimitrievska

Graphic design: Keti Stefkova, Vladimir Sidorovski

Circulation: 150 TABLE OF CONTENTS:

Introduction - Ixhet Memeti, Ombudsman of the Republic of Macedonia

1. LEGAL FRAMEWORK 104

2. THE SITUATION IN THE MUNICIPALITIES ACCORDING TO OBTAINED DATA 106 3. CONCLUDING REMARKS ON THE SITUATION WITH WASTE DISPOSAL IN THE MUNICIPALI- TIES 118

4. REGIONAL WASTE MANAGEMENT 121 5. CONCLUDING REMARKS ON REGIONAL WASTE MANAGEMENT 125 6. FIELD INSPECTION 128 - Regional landfill “Drisla”, Skopje 128 - Landfill besides the local road at the outskirts of Gostivar 129 - Regional landfill “Rusino”, Gostivar 130 - Transfer station Tetovo 132 - Landfill Kichevo 133 - Landfill Ohrid 134 - Landfill Gevgelija 135 - Landfill Kumanovo 138 - Landfill Kochani 139 - Landfill Shtip 140 - Landfill Strumica 141

INTRODUCTION

Living in a healthy environment is a fundamental human right. This right should be guaranteed by the state in a manner of securing conditions for its implementation. On the other hand, the citizens are those who should also contribute in promotion and protection of the healthy environment. Hence, despite the constitutionally guaranteed right to live in a healthy environment, of concern is the fact that already for years the state institutions do not pay sufficient attention and do not take concrete measures to preserve and improve the environment. Furthermore, there is a lack of quality implementation of systematic solutions to the problems relating to the environment, being left on the sidelines of the obligations undertaken by the institutions. Considering the importance of the right to a clean and healthy environment, in 2016 the Ombudsman conducted a research on the situation with the waste disposal and waste management in the Republic of Macedonia. For this purpose, we obtained information and data on the current situation with the landfills in each municipality, and we conducted a field visit to a number of landfills. In terms of the findings and recommendations, I expect the authorities to seriously take into consideration the quality implementation of the regula- tions governing this matter. At the same time, the authorities should start with preparation and implementation of specific projects for regional waste management or construction of landfills according to all standards for the purpose of proper exercise of the right to a healthy environment.

OMBUDSMAN Ixhet Memeti Survey on the situation with the waste disposal in the Republic of Macedonia

In accordance with its responsibilities arising from the Law on the Om- budsman (Official Gazette no. 60/03, 114/09, 181/16 and 189/16), the - Om budsman is a body that protects the constitutional and legal rights of citizens when they are violated with acts, actions and omissions by state administration bodies, by other bodies and organizations with public authority, units of local self government and public institutions and services. In this context the Om- budsman acts upon complaints relating to environmental protection. The right of the citizens to live in a healthy environment is an integral part of the corpus of constitutionally guaranteed rights, according to Article 43, “Everyone has the right to a healthy environment. Everyone is obliged to protect and improve the environment and the nature. The Republic provides conditions for exercising the right to a healthy environment.” The waste disposal is a process that directly affects the environment and human health. The improper waste disposal pollutes the air and the soil- groundwater which affects the whole biodiversity. Having in mind the information that currently the waste is disposed in official municipal landfills or wild dumps that do not meet the prescribed norms and standards, according to its Work Program for 2016, the Ombudsman conducted a survey for assessing the situation in the country with the waste disposal. The Ombudsman submitted a questionnaire to all 71 local self government units in Macedonia and Skopje. The aim of the survey was to determine whether and in which cities the landfills are built in accordance with the legal standards, so as to assess the manner they are managed. The Ombudsman has asked the municipalities and the City of Skopje to give answer to the following issues: • do they have a local landfill or do they use a regional one; • in case the municipality does not have its own landfill, nor it uses a regional one, in which manner the issue of waste disposal is resolved; in case the municipality uses its own / regional landfill, whether the landfill is constructed according to prescribed legislative provisions, do they possess a work permit and integrative environment permit; • what are the available human, material and technical resources for performing this activity; the possibilities for sorting the waste; • whether the municipality has a proper place for transfer station built in accordance with the legislative provisions; • whether the municipality has a plan / program for waste management; whether the municipality has created or used specific study on the im-

102 pact upon the human health, the environment and the nature; • whether the municipality has created a department or has designated a person for waste management; • if the municipality does not have a landfill that meets the prescribed minimum technical conditions due to lack of financial means, which actions have been taken for overcoming the situation in terms of applying for loans, utilization of foreign funds and similar concrete measures to be taken in the upcoming period for improving the conditions in this field.

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LEGAL FRAMEWORK

The Republic of Macedonia has completed the legal framework that regu- lates this area, while as the national legislation complies with the legislation of the European Union. The harmonization process began in 2003 when series of laws were adopted - Environmental Law, the Law on Waste Management, the Spatial Plan of Macedonia, Strategy for Waste Management of the Republic of Macedonia (2008-2020), the National Waste Management Plan (2009-2015) of the Republic of Macedonia, the Law on management of packaging and waste packaging. For more detailed regulation of the landfill operation, there are a number of bylaws as: • Rulebook on the conditions that should be met by the landfills, • Rulebook on the criteria for acceptance of the waste of each class in the landfills, preparatory procedures for the acceptance of the waste, general testing procedures, sampling and acceptance of the waste, • Rulebook on the form and content of the request for establishment of a landfill for hazardous and inert waste and Rules on the method of operation, monitoring and control of the landfill during the phase of closure and further maintenance of the landfill after the closure and the manner and conditions of care about the landfill once they stop operating, • Rulebook on the manner of functioning of the integrated system for removing waste, • Rulebook on minimum technical requirements in terms of environmental protection to be met by waste transfer stations, the conditions to be met by the sites where the waste transfer stations should be built, as well as deadlines for storage of waste in the waste transfer stations according to its type,

104 • Rulebook on the manner and conditions of waste storage and the conditions to be met by the locations where the waste storage is done, • Rulebook on the measures that must be undertaken by the manufac- turers, the owners and the entities that deal with used vehicles for protection of the environment, their components and materials, targets and deadlines and the manner and conditions of storage, the form and content of the confirmation document for undertaking the vehicle that should be destroyed, • Rulebook on the manner of handling the waste tires, and the conditions to be met by the legal entities and the individuals who import used tires, • Rulebook on the amount of biodegradable components in the waste that can be disposed, • Rulebook on the form and content of the application for a permit, and the form and content of the landfill operator, • Rulebook on requirements in terms of facilities and equipment for waste disposal, and the conditions and manner of training program for employees, • Rulebook on limit values of emissions from burning and incineration of waste and the conditions and manner of operation of incineration and co-incineration, • Rulebook on the form and content of the application for a permit, and the form and content of the license for conducting business - operator of the incineration or co-incineration, • Rulebook on procedures and manner of collection, transportation, processing, storage, treatment and disposal of waste oils, the method of keeping records and submitting data, • Rulebook on the manner of handling medical waste, etc.

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THE SITUATION IN THE MUNICIPALITIES ACCORDING TO OBTAINED DATA

From a total of 71 municipalities, 67 answered the questionnaire while as the municipalities of Arachinovo, Valandovo, Dolneni and Kichevo did not act upon the Ombudsman’s request. The answers vary in quality and scope of received data, but what can be drawn as a general conclusion, the obtained data vis-à-vis the legislation, is that the situation with the management of solid waste (deposit waste) in the Republic of Macedonia is substandard and almost never observes any legal norm in that respect. • Berovo Municipality uses its own local landfill which is not standardized and does not have integrated environmental permit, it uses over 90% of its capacities. The municipality has produced a local environmental action plan in 2004, and in 2015 has adopted a five-year plan for waste management. The municipality actively participates in the Council of the Eastern Plan Region for construction of a regional landfill. • The Municipality of Bitola has its local landfill located near the village of Meglenci and the mine REK Suvodol. The landfill is managed by the local public enterprise for communal hygiene that has adopted a three-year plan and a work program. The landfill does not select the waste. In 2014 the municipality adopted a five-year plan for waste management. Currently they are preparing a local environmental action plan, but have not conducted a study on the impact of the waste on the human health, the environment and the nature. • The Municipality of Bogdanci uses a local landfill with no integrated environmental permit, managed by the local public enterprise for communal hygiene. There is no sorting of the waste. The municipality has not adopted a plan for waste management nor has produced a study

106 on the impact of the landfill on the environment. In 2016 a partnership agreement was signed for implementation of a project for integrated waste management in the Southeast Plan Region. • Bogovinje Municipality has no local landfill because it uses are- gional one. The municipality has its own public enterprise for communal hygiene. The waste sorting is not carried out. The municipality has adopted an annual plan for waste management but has not prepared a study on the impact of the landfill upon the environment. • The Municipality of Bosilovo has no local landfill nor they use a regional one but in every town there is a non-standardized temporary location for municipal waste. The municipality has its own public enterprise for communal hygiene. There is no sorting of the waste. The municipality has adopted an annual plan for waste management but has not prepared a study on the impact of the landfill upon the environment. • Brvenica Municipality has no local landfill since it uses a regional one, Rusino landfill. The Municipality of Brvenica does not have its own public enterprise for communal hygiene but the collection and transportation of the waste is carried out by the concessionaire company. There is no sorting of the waste. • Municipality of Vasilevo has no local landfill but they use the regional one in the village of Dobroshinci. The municipality has its own public enterprise for communal hygiene. There is no sorting of the waste. The municipality has adopted an annual plan for waste management. • The Municipality of Vevchani has no local landfill nor they use the regional one. The municipality has its own public enterprise for communal hygiene that disposes the waste in a location determined by the neighboring municipality of Struga. There is no sorting of the waste. The municipality has adopted an annual plan for waste management but has no conducted study on the impact of the landfill upon the environment. • The Municipality of Veles uses the local landfill with no obtained integrated environmental permit, the landfill is managed by the local public enterprise for communal hygiene. The process of selecting the waste is in its initial phase, the households have been given special bins for sorting the waste, while as the construction of a landfill for selection and storage of the collected waste is ongoing. The municipality regularly adopts an annual plan for waste management. The procedure

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for approving the study on the impact of the landfill upon the environment is in procedure. • The Municipality of Vinica uses the local landfill operated by the local public enterprise for communal hygiene. There is a primary selection of PET packaging, paper and hazardous batteries. The municipality adopts a three-year plan for waste management. • The Municipality of Vrapchishte through concessionary uses the regional landfill Rusino. There is a selection of paper, plastics and metal products. The Municipality adopted a three-year plan for waste management. • The Municipality of Gevgelija uses the local landfill run by the local public enterprise for communal hygiene. There is an ongoing procedure for preparation of the municipal plan for waste management. Of particular interest for this municipality is that during 2016 the amount of municipal waste increased in several occasions due to the refugee crisis. • The Municipality of Gostivar uses the regional landfill Rusino. There is a selection of paper, plastics and metal products, and there is a facility on the landfill where the baling of the sorted waste is performed. There is a three-year plan for waste management in place but so far no study on the impact of the waste upon human health has been conducted. There is a plan for construction of pits and ducts so as plants for recycling selected waste on the regional landfill. • The municipalities in Skopje use the regional landfill “Drisla” which is the only one in the country with integrated environmental permit. In 2013 the City of Skopje chose a private partner / founder from the Republic of Italy for investing in the landfill for a period of 35 years. In its final stage is the construction of a special station of large scale for selection and processing of waste with a capacity of over 250,000 tons per year. The Public Enterprise for the disposal of municipal waste “Drisla” Skopje and PE “Communal Hygiene” Skopje that performs collection and disposal of waste, have on their disposal sufficient human, material and technical resources necessary for quality performance of that activity. The project for sorting the waste by placing containers for selection of glass, plastics and paper has been successfully implemented. The transfer stations in the regions of Karposh and Vardarishte serve as recycling collection centers where besides the usual selection of waste, there is a collection and selection of electronic, electrical and waste batteries. The selected, processed and packed waste would be

108 sold as fuel or as side product. Each year Skopje adopts and imple- ments a program for waste management. • The Municipality of Gradsko has its local landfill run by the local public enterprise for communal hygiene. There are no opportunities for sorting of the waste. The municipality has adopted a multi-year plan for waste management, but has not prepared a study on the impact of the landfill upon the environment. • The Municipality of Debar has its local landfill run by the local public enterprise for communal hygiene. There are no opportunities for sorting of the waste. The municipality has adopted an annual plan for waste management, but made no study on the impact of the landfill upon the environment. • The Municipality of Debarca has no local landfill but when needed it uses the one of the neighboring municipality of Ohrid. The municipality has its local public enterprise for communal hygiene. There is no sorting of the waste. The municipality had its five-year plan for waste management valid until 2014. There is no study on the impact of the landfill upon the environment. • The Municipality of Delchevo has its own local landfill run by the local public enterprise for communal hygiene. There are no opportunities for sorting of the waste. The municipality has adopted annual plan for waste management, but made no study of the impact of the landfill upon the environment. • The Municipality of Demir Kapija has its own local landfill run by the local public enterprise for communal hygiene. There are no opportunities for sorting of the waste. The municipality has adopted annual plan for waste management, but made no study of the impact of the landfill upon the environment. • The Municipality of Demir Hisar has its own local landfill run by the local public enterprise for communal hygiene. There are no opportunities for sorting of the waste. The municipality has adopted annual plan for waste management, but made no study of the impact of the landfill upon the environment. • The Municipality of Dojran has its own local landfill run by the local public enterprise for communal hygiene that has adequate machinery and sufficient human potential. As of 2016 there is a sorting of the waste in place. The municipality has adopted a four-year plan for waste management, but made no study about the impact of the landfill upon the environment. www.ombudsman.mk 109 Survey on the situation with the waste disposal in the Republic of Macedonia

• The Municipality of Zhelino has no local landfill nor they use the regional one. The waste disposal is performed by the concessionaire company which has the obligation to select the waste. The municipality has adopted a plan for waste management but has not prepared a study on the impact of the landfill upon the environment. • The Municipality of Zelenikovo has no local landfill, but they use the regional one. There is no sorting of the waste. The municipality has not adopted an annual plan for waste management nor has produced a study on the impact of the waste upon the environment. • The Municipality of Zrnovci has its own local landfill run by the local public enterprise for communal hygiene. There is constructed facility for recycling in place. The Municipality generates an annual plan and program for waste management, but has not prepared a study about the impact of the landfill upon the environment. • Ilinden Municipality has no local landfill, but it uses the regional “Drisla”. There is no sorting of the waste. The municipality has adopted a four-year plan for waste management and developed a feasibility study for the treatment of biological waste. • Jegunovce Municipality does not have a local landfill due to its vicinity to the first protection zone of the spring “Rashche”. The waste disposal is carried out by the concessionaire company that has adequate staff personnel and technical equipment. This company has an obligation to select the waste. The Spatial Plan of the region for the protective zones Rashche is in use. • Kavadarci Municipality has a local landfill run by the local public enterprise for communal hygiene. The landfill has no possibility for sorting of the waste. The municipality has adopted annual plan for waste management. • Karbinci Municipality has no local landfill, for this purpose they use several standardized landfills located near the major populated sites. There is no sorting of the waste. The municipality has not prepared an annual plan for waste management nor they have produced a study on the impact of the waste upon the environment. • Municipality of Konche has its own local landfill run by the local public enterprise for communal hygiene. There is no sorting of the waste. The Municipality adopts an annual plan and program for waste management, but has not conducted a study about the impact of the landfill upon the environment.

110 • Municipality of Kochani has its own local landfill run by the local public enterprise for communal hygiene. The landfill has no possibility for sorting of the waste. The municipality has adopted an annual plan for waste management. • Municipality of Kratovo has its own local landfill run by the local public enterprise for communal hygiene. The landfill has no possibility for sorting of the waste, but there is an individual waste selection. The municipality has adopted an annual plan for waste management. • Municipality of Kriva Palanka has its own local landfill run by the local public enterprise for communal hygiene company which pos- sesses old machinery with sufficient human resources. During 2015 the Municipality placed numerous containers for plastics and paper in order to sort the waste. As of 2016 there has been sorting of electrical and electronic waste. The Municipality has adopted a five-year plan for waste management, but conducted no study about the impact of the landfill upon the environment. • Municipality of Krivogashtani uses its local landfill run by the local public enterprise for communal hygiene company. There is no waste sorting. The Municipality prepares an annual plan and program for waste management, but has not conducted a study about the impact of the landfill upon the environment. • Municipality of Krushevo uses its local landfill run by the local public enterprise for communal hygiene company. The selection of plastic waste is carried out through 40 specialized for that purpose containers. The Municipality prepares an annual plan and program for waste management, but has not conducted a study about the impact of the landfill upon the environment. • Kumanovo municipality uses its own local landfill run by the local public enterprise for communal hygiene company. The selection of the waste is carried out in collaboration with a private company. The municipality regularly prepares an annual plan and program for waste management. • Lipkovo Municipality uses its own local landfill run by the local public enterprise for communal hygiene company. There is no sorting of the waste. The municipality has adopted a six years plan and program for waste management, and has conducted a study about the impact of the landfill upon the environment.

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• Lozovo Municipality does not have a local landfill nor they use a regional one. The waste is disposed in the local landfill of the neighboring municipality of Veles. • Municipality of Mavrovo and Rostushe does not have a local landfill nor they use a regional one. The waste is disposed in the local landfill of the neighboring Municipality of Debar. There is no sorting of the waste. The municipality has not adopted a plan and program for waste management, neither has produced a study about the impact of the landfill upon the environment. • Municipality of Makedonska Kamenica uses its local landfill run by the local public enterprise for communal hygiene company. The selection of the plastic waste and paper is carried through specialized for that purpose, containers. The Municipality adopts an annual plan and program for waste management, but has not conducted a study about the impact of the landfill upon the environment. • Municipality Makedonski Brod uses its own local landfill run by the local public enterprise for communal hygiene company. There is no sorting of the waste. The municipality has adopted a five-year plan and program for waste management, but made no study about the impact of the landfill upon the environment. • Municipality of Mogila does not have a local landfill neither they use the regional one. The waste is disposed in the local landfill of the neighboring Municipality of Bitola. There is no sorting of the waste. The municipality has not adopted a plan and program for waste management, neither has produced a study about the impact of the landfill upon the environment • Negotino Municipality uses its own local landfill run by the local public enterprise for communal hygiene company. There is no sorting of the waste. The municipality has adopted a five-year plan and program for waste management, but made no study about the impact of the landfill upon the environment • Municipality of Novaci does not have a local landfill nor they use a regional one. The waste is disposed in the local landfill of the neighboring Municipality of Bitola. There is no sorting of the waste. The municipality has adopted a plan and program for waste management, and has conducted a study about the impact of the landfill upon the environment

112 • Municipality of Novo Selo uses its local landfill run by the local public enterprise for communal hygiene company. There is no sorting of the waste. The municipality has adopted a five-year plan and program for waste management, but made no study about the impact of the landfill upon the environment. • Ohrid Municipality uses its own local landfill run by the local public enterprise for communal hygiene company which has the appropriate machinery and personnel for that purpose. There is a selection of the waste from paper and plastics which is compressed and baled, while as the electrical and electronic waste is selected and collected by an authorized company. The municipality regularly adopts an annual plan and program for waste management, and has developed and study/ report on the impact of the landfill upon the environment. • Petrovac Municipality has no local landfill and its uses the regional Drisla landfill. There is no sorting of the waste. The municipality has no annual plan for waste management nor has produced a study on the impact of the waste upon the environment. • Municipality of Pehchevo uses its local landfill run by the local public enterprise for communal hygiene company. There is no sorting of the waste. The municipality has adopted a multi-year plan and program for waste management, but made no study on the impact of the landfill upon the environment. • Municipality of Plasnica uses its local landfill run by the local public enterprise for communal hygiene company. There is no sorting of the waste. The municipality has adopted a five-year plan and program for waste management, but made no study on the impact of the landfill upon the environment. • Municipality of Prilep uses its local landfill run by the local public enterprise for communal hygiene company which has the appropriate machinery and personnel for that purpose. The process of sorting the waste has been launched in 2008. On 400 locations there are so called ecological islands with three containers for selection of biodegradable waste paper and PET bottles and plastics. There is also a selection of household waste. Currently 30% of the total waste in the municipality is recycled. The procedure for land acquisition and construction of composting plants is in its final stage where the biodegradable waste would be processed. The Municipality has adopted a three-year plan and program for waste management, and has developed and study/ report on the impact of the landfill upon the environment as well as other numerous activities in this area. www.ombudsman.mk 113 Survey on the situation with the waste disposal in the Republic of Macedonia

• Probishtip Municipality uses its own local landfill run by the local public enterprise for communal hygiene company. Only a selection of the plastic waste is conducted. The municipality has adopted a multi- year plan and program for waste management, but made no special study on the impact of the landfill upon the environment. There are ongoing preparation and development of several project studies within the projected establishment of an integrated and sustainable financial system for regional waste management. • Radovish Municipality uses its local landfill run by the local public enterprise for communal hygiene company. There is no sorting of the waste. The municipality has adopted a multi-year plan and program for waste management and has produced a study on biodiversity. • Rankovce Municipality uses its own local landfill run by the local public enterprise for communal hygiene company which owns the appropriate machinery and personnel for that purpose. There is a sorting of the paper waste and plastics in special containers, while as the electrical and electronic waste is selected and lifted from an authorized company. The municipality regularly adopts an annual plan and program for waste management, and has developed a local action plan for the environment. • Resen Municipality uses its local landfill run by the local enterprise for communal hygiene company. There is a sorting of the paper waste and plastics in terms of biodegradable waste. The municipality has adopted a five-year plan and program for waste management, but made no special study/report on the impact of the landfill upon the environment. • Municipality of Rosoman uses its local landfill run by the local enterprise for communal hygiene company with outdated equipment. There is no sorting of the waste. The municipality has adopted annual plan and program for waste management, but made no special study / report on the impact of the landfill upon the environment. • Saray Municipality has no local landfill but it uses the regional Drisla landfill. There is no sorting of the waste in place. The municipality has not made an annual plan for waste management nor has produced a study on the impact of waste upon the environment • Municipality of Sveti Nikole uses its local landfill run by the local enterprise for communal hygiene company. There is a sorting of the paper waste and plastics, and there is a location for collection of electrical and electronic waste and containers for batteries. The mu-

114 nicipality has adopted a plan and program for waste management, but made no special study / report on the impact of the landfill upon the environment. • Sopishte Municipality has no local landfill, but it uses regional landfill Drisla. There is no sorting of the waste. The municipality has not made an annual plan for waste management nor has produced a study on the impact of the waste upon the environment. • Municipality of Staro Nagorichane has no local landfill nor it uses a regional landfill. The collection and transport of the waste is carried out by a legal entity which has signed a multiyear contract. There is no sorting of the waste. The municipality has not made an annual plan for waste management nor has produced a study on the impact of the waste upon the environment. • Struga Municipality uses its local landfill run by the local enterprise for communal hygiene company. There is no sorting of the waste. The municipality has adopted a plan and program for waste management, but made no special study / report on the impact of the landfill upon the environment. • Municipality of Strumica uses its local landfill run by the local enterprise for communal hygiene company. There is no sorting of the waste. The municipality has adopted a plan and program for waste management, but made no special study / report on the impact of the landfill upon the environment. There is ongoing preparation and development of several project studies within the projected establishment of an integrated and sustainable financial system for regional waste management. • Municipality of Studenichani has no local landfill but it uses the regional Drisla landfill. There is no sorting of the waste. The municipality has not prepared an annual plan for waste management nor has produced a study on the impact of the waste upon the environment. • Municipality of Tearce has no local landfill. The waste management is given to a private company-concessionaire that collects and transports the waste to the regional landfill Rusino. There is no sorting of the waste. The municipality has not made an annual plan for waste management nor has produced a study on the impact of waste upon the environment. • Tetovo Municipality has no local landfill but only a transfer station where the primary selection of paper and plastics and other wastes is taking place, the remaining waste is occasionally disposed in the www.ombudsman.mk 115 Survey on the situation with the waste disposal in the Republic of Macedonia

Rusino landfill or in the regional Drisla landfill. The municipality has adopted a multi-year plan for waste management and made certain studies on the impact of the waste upon the environment. • Municipality of Centar Zhupa has its own local landfill. There is no sorting of the waste. The municipality has adopted annual plan for waste management, but made no study on the impact of waste upon the environment. • Municipality of Chashka uses its local landfill run by the local enterprise for communal hygiene company. There is no sorting of the waste. The municipality has adopted a five-year plan and program for waste management, but made no special study/report on the impact of the landfill upon the environment. • Municipality of Cheshinovo-Obleshevo uses its own local landfill run by the local enterprise for communal hygiene company. There is no sorting of the waste. The municipality has adopted a plan and program for waste management, but made no special study/report on the impact of the landfill upon the environment. • Municipality of Chucher Sandevo has no local landfill but uses its regional Drisla landfill. There is no sorting of the waste. The municipality has adopted a five-year plan for waste management, but made no study on the impact of the waste upon the environment. • Municipality of Shtip uses its own local landfill run by the local enterprise for communal hygiene company. There is a sorting of plastic waste. There is an ongoing preparation and development of several project studies within the projected establishment of an integrated and sustainable financial system for regional waste management.

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CONCLUDING REMARKS ON THE SITUATION WITH WASTE DISPOSAL IN THE MUNICIPALITIES

From the information obtained, we can conclude that 42 municipalities in the Republic of Macedonia use local landfills for municipal and other type of non-hazardous waste, none of them possess integrated environmental permit i.e. meets the legal standards. 14 municipalities use regional landfills (all municipalities of the City of Skopje), and 11 mainly smaller rural municipalities, use local or regional landfills. For collection and transportation of the waste, the municipalities that use its local landfills have established public enterprises for communal hygiene that have the necessary staff personnel with appropriate vehicles, machinery and equipment. They claim the vehicles and machinery are mostly out of date. Only a small percentage of the waste collectors are private companies, mainly those dealing with waste in rural areas. General practice is to collect non-sorted municipal and non-hazardous industrial waste, so as non-sorted, non-hazardous and hazardous waste fractions. The practice of waste disposal does not meet any technical or environmental standards. Most public enterprises for communal hygiene are faced with shortage of funds due to low rate of collection of receivables and / or low price for services related to waste. Only 19 municipalities carry out sorting of waste, while as the other municipalities still do not have such an opportunity. The recovery and recycling of municipal waste are very limited. The utilization of material that can be recycled, such as metal, paper, plastics, car batteries and accumulators is performed by the informal sector. Scrap metals represent the biggest part of the materials collected for recycling, so as the fraction of paper and cardboard. The solid waste generated in the Republic of Macedonia is mainly disposed in the landfills. Drisla landfill serving the region of Skopje is the only landfill in the country with integrated environmental permit, covering an area of approximately 76 hectares. Solid municipal and other type of non-hazardous 118 waste is deposited in this landfill. Only 18 percent of the waste is recycled which is far below the standards. The other landfills for municipal and other types of non-hazardous waste are usually full, improperly constructed, maintained and operated, and do not meet the requirements and standards in respect to the environmental protection and human health. The current situation of solid waste management in Macedonia can be characterized as sub-standard, insuf- ficient and inefficient and hampered by serious deficiencies (such as lackof public awareness, non-implementation of the legislation), resulting in various dysfunctional systems and many other similar negative impact upon the environment and human health. Similar is the situation especially in smaller towns, the collected waste is simply thrown in open space on the outskirts of the town, on the slopes of the mountain ridge or along roadsides or river banks near the city. All the waste hereby including the industrial garbage, the medical waste and hazardous household waste, is mixed and disposed in one place. Once the empty location is full, the landfill is left as such (without proper closing) and another one, new location is selected for that purpose. From the field visits we conducted on several landfills, we got the impres- sion that many of the municipalities do not pay any attention to the environment, but they only deposit the waste in the most suitable location for that purpose. Most of the landfills are not fenced or marked. Only in approximately 10 municipalities there are special departments and entities designated for waste management. In the other this issue is covered by the municipal departments of Urban Planning and Communal Affairs or through the municipal utilities. Transfer stations in the Republic of Macedonia have only Tetovo and Skopje. All the municipalities share the opinion that for overcoming the existing problems and improving the poor conditions of the landfills, there is a need of finances for which the municipalities are unable to secure. That is why they turn towards a regional approach to waste management, a process that has been initiated, but so far is far from implementation. Until then, through their annual plans for municipal waste, the municipalities should: • continue operating with the existing landfills up until the regional landfills are constructed; • conduct remediation and re-cultivation of the existing landfills; • introduce a system for organized collection and disposal of municipal waste in the suburbs and villages; • introduce the principle of primary separation of waste; • cleaning of illegal landfills by engaging wider community;

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• establish and develop projects for the collection of recyclable materials; • establish and develop projects for the use of bio-waste for energy purposes; • establish and develop projects for separation of the hazardous waste from the communal one and organization of its collection, and • intensify the activities of the municipalities and relevant institutions for drafting and adoption of the necessary documents for implementation of the measures and activities in the field of waste management. • The National Plan for Waste Management envisages closure of all existing landfills and their replacement with regional landfills constructed and operational according to the standards listed in the Landfill Direc- tive. The existing municipal landfills and the illegal dumpsites (so called “wild” landfills), continue to cause pollution, while as the final costs for their cleaning and closure continue to increase on a daily basis. There are measures envisaged for gradual closure of the existing landfills and gradual cleaning of the “wild” dumpsites based on the calculated environmental risk.

120 REGIONAL WASTE MANAGEMENT

The National Plan for Waste Management envisages closure of all existing local landfills and their replacement with regional ones or setting up a so-called regional waste management. For this purpose the Republic of Macedonia has been divided in eight regional plans and each region is planned to have a regional landfill. - Skopje Plan Region - Vardar Plan Region - Northeast Plan Region - East Plan Region - Southeast Plan Region - Pelagonija Plan Region - Southwest Plan Region and - Polog Plan Region

The construction of the envisaged regional landfills in the Republic of Macedonia should provide: • safe services for municipal waste collection and its disposal in accordance with the EU practices for management of municipal solid waste; • significantly improved general environmental conditions in the municipalities; • reduction/removal of all risks to human health due to existing landfills

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in the region that do not comply with the required standards for construction thereof; • new regional landfills would enable safer use of disposed municipal waste from all municipalities that would be incorporated in the region, upon which all existing local landfills would be closed down.

Regions in the Republic of Macedonia

Skopje Plan Region – The Skopje Plan Region integrates Gazi Baba, Gjorche Petrov, Zelenikovo, Ilinden, Karposh, Kisela Voda, Petrovec, Saraj, Sop- ishte, Studenichani, Centar, Chair, Chucher Sandevo and Shuto Orizari. The municipalities in the City of Skopje and the other municipalities in the Skopje region use the regional Drisla landfill which is unique one in the country with an integrated environmental permit. In 2013 the City of Skopje chose a private partner / co-founder from the Republic of Italy to invest in Drisla landfill for a period of

122 35 years. In its final stage is the construction of a special utility with a capacity of over 250,000 tons per year for sorting and processing the waste of large scale. The Public Enterprise (PE) for disposal of municipal waste “Drisla” Skopje together with the PE “Communal Hygiene” Skopje carry out the collection and waste disposal in the Skopje region and have on their disposal human, material and technical resources necessary for quality performance of that activity. The project for selection of the waste by introducing containers for sorting glass, plastics and paper has been successfully implemented. Currently 18% of the waste has been recycled. The transfer stations in the regions of Karposh and Vardarishte serve as recycling collection centers where besides the usual selection of the waste, there is collection and selection of the electronic, electrical waste and the waste from batteries. The selected, processed and packed waste is sold as fuel or as by product. Vardar Plan Region consists of the municipalities of Veles, Kavadarci, Negotino, Sveti Nikole, Demir Kapija, Rosoman, Gradsko, Lozovo and Chashka. All these municipalities use their own local landfill. All the municipalities make part of the project funded by the European Union for preparation of the necessary documents for establishment of an integrated and sustainable financial system for regional waste management. No other concrete actions have been taken. Northeast Plan Region – covering Kumanovo, Kriva Palanka, Lip- kovo, Staro Nagorichane, Rankovce and Kratovo. All municipalities use their local landfill. For the purpose of implementing the regional plan for waste management in the Northeast region, they make use of the Instrument for Pre- Accession Assistance (IPA) of the European Union. There is funding approved for closure of all local landfills in the territory of this region; for purchase of new machinery and equipment and for setting up new regional location for final waste disposal. These procedures are currently under project development and preparation of tender documentation. A joint Public Enterprise for Waste Man- agement “Eco-region” Kumanovo has been set up. The Management Board, the Supervisory Board for control of the material and financial work was consti- tuted, and a director was elected. Hence the landfill has not started operating. East Plan Region – covers Shtip, Kochani, Probishtip, Vinica, Berovo, Pehchevo, Makedonska Kamenica, Zrnovci, Cheshinovo and Karbinci. In 2009 the municipal public enterprise “Landfill East” was established, and in 2012 the Inter-municipal / Regional Board on Waste Management in the East Region was founded. Both are not in function yet. All municipalities use the local landfill. Currently there are two projects in place. One is for the preparation of technical specification for procurement of equipment for the collection and transportation of the waste from the Eastern Region and the other is for the preparation

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of technical and tender documentation for closure of inappropriate and illegal landfills. Southeast Plan Region – covers the municipalities of Strumica, Ra- dovish, Gevgelija, Novo Selo, Valandovo, Dojran, Bogdanci, Konche, Vasilevo and Bosilovo. All the municipalities in this region are currently using the local landfill. In 2009 they prepared a feasibility study for integrated waste management, but although it was adopted by the councils of all municipalities that make part of this region, by the end of 2014 they did not manage to select the most suitable concessionaire. In 2015 the Council for Development of the Southeast Region made a decision to establish an Inter-municipal waste management board at regional level. Pelagonija Plan Region – covers the municipalities of Bitola, Prilep, Resen, Krushevo, Demir Hisar, Krivogashtani, Dolneni, Novaci and Mogila. All the municipalities use their local landfill. According to the National Plan for Waste Management, in the process of preparation is the regional plan for waste management that embraces all the municipalities from the region. Apart of this project financially supported by the European Union in cooperation with the Enviroplan from Greece, a strategic assessment of the planning document is envisaged to be designed, so as feasibility study for a regional landfill and documentation for necessary equipment for regional management of the municipal waste. So far no other concrete actions have been undertaken. Southwest Plan Region – Општините Охрид, Струга, Кичево, Вевчани, Дебар, Дебрца, Македонски Брод, Пласница и Центар Жупа кои спаѓаат во овој регион користат свои локални депонии. Сите општини се вклучени во проектот финансиран од Европската Унија, за подготовка на потребни документи за воспоставување на интегриран и финансиски самоодржлив систем за регионално управување на отпад. Реализацијата на овој проект се уште е во почетна фаза. Polog Plan Region – covers the territory of the municipalities of Tetovo, Gostivar, Bogovinje, Brvenica, Zhelino, Jegunovce, Mavrovo and Rostu- sha, Tearce. The municipalities from this region are currently using the regional landfill Rusino which does not have an integrated environmental permit because it does not meet the conditions provided with the national and European legislation on the standards for waste disposal. So far no concrete activities for regional waste management have been undertaken in this region.

124 CONCLUDING REMARKS ON REGIONAL WASTE MANAGEMENT

From the above stated we could conclude that apart of Skopje region where already with success operates the regional Drisla landfill, in the other regions the situation is far from satisfactory. Only the City of Skopje and the Municipality of Prilep work on the implementation of the complex where not only the waste would be disposed, but it would be processed too. We cannot be satisfied with the fact that only about 18% of the waste is recycled in the landfill Drisla, especially if you compare the situation with the one in the neighborhood where for example, in Sofia, Republic of Bulgaria 70% of the collected waste has been recycled. Some progress has been achieved in the Northeast region with the setting up of a joint regional public company based in Kumanovo, while as in the East and the Southeast region only the inter-municipal boards for waste management at regional level are being established, hence they are not operational yet. In the other regions there are hardly some concrete measures for implementation of the project for regional waste management. In order to assist the Republic of Macedonia in the preparation of regional plans for waste management, the project “Preparation of regional plans for waste management and strategic environmental assessment for the eastern and northeastern region” was implemented. The project was financed by the pre-accession funds of the European Union aiming at protecting the environment and improving the living standards of the local community through achieving an integrated and financially sustainable system for waste management in the Eastern and North- east regions of the country. The regional concept for waste management should be fully aligned with the recommendations, propositions and conditions defined with the adopted National Strategy for Waste Management. Namely, the development perspec- tives and needs of the Region are:

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• insuring institutional arrangements as prerequisite for setting up a regional system for waste management; • rehabilitation of the individual landfills that are environmentally ac- ceptable and gradual closure of the old ones; • securing organized collection of the waste throughout the whole territory of the region; • gradual establishment of a regional system for waste management; • construction of all elements of a future Regional Center, including regional sanitary landfill, section for recycling, system for processing the organic waste etc.; • awareness raising - spreading a culture of responsible waste treatment, and • systematic education of the public on the need for waste sorting and recycling.

For many years in Macedonia there is an unsuccessful construction of regional landfills. In fact, with the amendments to the Law on -Waste Man agement, which entered into force in October 2012, the competencies in the management of municipal solid waste undertaken by the municipalities were covered. The substantial amendments to the Act are referring to the introduction of regional waste management i.e. the obligation of the municipalities to establish a regional center for waste management which has to implement the decisions and regional policies in the field of waste management delegated by the inter-municipal board for waste management (whose members are the municipalities’ mayors as founders of the regional center). This regional management should establish and organize a regional system for waste management with emphasis on setting up a regional landfill for waste and / or other facilities and installations for treating the waste. It is necessary to intensify the work for setting up regional centers for waste management and in a very short period of time to implement the project for construction of a regional landfill in each region. Only in this way there would be basic preconditions in place for effective protection of the fundamental factors of the environment and the health of the residents in the region. This would allow reduction of the amount of waste in the existing local landfill. In addition, the coverage of the territory by the system for municipal solid waste would increase significantly, which would remove the illegal landfills from the suburbs and villages. The regional system for waste management implies compulsory asso- ciation of the municipalities in regions, establishment of inter-municipal board 126 for waste management for each region and a regional center that prepares regional plan for waste management and construction of a regional landfill, while as each municipality should develop a system for collection, sorting and recycling of the waste, its treatment and transportation to the sanitary regional landfill. The transport of the waste to the regional landfill without its prior selection, recycling and transport would be unacceptable from an environmental perspective since in that case the area of the regional landfill could be used for a limited time only. That would also be unacceptable even from an economic point of view due to the fact that the transport costs would be larger. The sorting and recycling of the waste reduces the need for frequent transport, thereby it reduces the costs. In this framework there should be plants for mechanical- biological treatment of municipal waste in place, as well as plants for production of energy from the waste that should play a major role in the approach towards the sustainable management of the municipal waste. With this smart selection of the waste and the recycling of the solid waste, the lifespan of the landfills would be extended because it reduces the amount of disposed waste, but it also gives a possibility for development of a solid recycling industry and creation of new jobs. The benefits of sorting the waste and its further recycling is multiple, since in such way the natural resources are saved, such as the oil for production of new plastics and the wood pulp for paper production. There is a need for essential coordination of the multiple stakeholders - the local authority has a central role in planning and establishing a sustainable system for waste management, households, enterprises, private sector, NGOs and individuals. The key objective of this idea is to contribute to sustainable development of the region by establishing a system for waste management which would oversee the creation of the waste, would reduce the impact of the waste upon the environment, would improve resource efficiency, would allow proper flow of waste until its transfer to the regional landfills, would stimulate the investments and would maximize the economic opportunities arising from the waste through separation of waste fractions that could further use the energy significance of the waste (energy, heat, fuels) and produce compost. The Ombudsman calls upon all stakeholders in this society to continu- ously undertake measures for protection of the environment as a basic condi- tion for a healthy life.

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FIELD INSPECTION

Regional landfill “Drisla”, Skopje

The regional landfill “Drisla” is the only landfill in the country that has integrated environmental permit. At the entrance of the landfill which is fully fenced, the measurement of the trucks that carry garbage is done, so as their disinfection before leaving the site. The sorting of the waste is also performed here. The landfill has on its disposal filters for collection of the leakage generated from the disposed waste.

128 Landfill besides the local road at the outskirts of Gostivar

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Regional landfill “Rusino”, Gostivar

The regional landfill “Rusino” where the waste from Gostivar and Tetovo regions is disposed is located outside the city of Gostivar. There is no asphalt road to this landfill. It can be noted that in this regional landfill only the plastic waste is sorted, it is packed in bales, while as the remaining waste is set on the ground, covered with soil and leveled.

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Transfer station Tetovo

Given the fact that Tetovo does not have its own local landfill, the waste is disposed in the regional landfill Rusino or sometimes it is taken to the regional landfill Drisla. There is a so-called transfer station that operates in this city, located at the entrance of the city, which is not fenced and everyone has unhin- dered access there. Given the fact that in this place a large amount of waste has been collected which is impossible to be completely transported to the regional landfill, very often the waste is burnt causing enormous air pollution in the city.

132 Landfill Kichevo

The waste disposal in Kichevo is carried out outside the city near the TPP “Oslomej”. Huge amount of waste is piling up along the road leading to the landfill which is only partly paved. The waste here is not recycled, but it is covered with soil and leveled with excavators. One can see here the old sites where the waste was disposed in the past, which due to overfilling are now abandoned.

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Landfill Ohrid

The landfill in Ohrid is located outside the town in the locality called “Bu- kovo”. An asphalt road leads to the location, the site is fenced, the entrance has a ramp that does not work and the place looks more like a hill full of garbage than a location where waste is disposed.

134 Landfill Gevgelija

The waste disposal in Gevgelija is conducted in a place which is relatively close to the city, unmarked, the access to the landfill is difficult since it has no paved road. The place is open, not fenced, without a ramp or guards.

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Landfill Kumanovo

The landfill of Kumanovo is located outside the city. There is an asphalt road to the landfill, a fence and guards. Once the waste is disposed, it is covered with a layer of soil which is leveled and compacted.

138 Landfill Kochani

The situation with the deposited waste in Kochani is no different than the other sub-standard landfills in the country. The only thing indicating it is a landfill is the waste and the smoke of its burning. The site is located outside the city, but it is not fenced nor has guards.

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Landfill Shtip

The location where the waste is disposed in Shtip is outside the city. As it is the case with the other local landfills, here too the waste is disposed, covered with soil and leveled with excavators. An asphalt road goes directly to the landfill which is fenced, with clear designation that the location is a landfill.

140 Landfill Strumica

The waste in Strumica is disposed outside the city in the area called “Do- brushino”. From the conducted inspection, one can see an asphalt road leading directly to the landfill. The place has been marked with a ramp and a fence. The waste is not sorted here but it is covered with soil and leveled.