Bosnia and Herzegovina NWA and Roadmap
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A COMPREHENSIVE ASSESSMENT OF THE CURRENT WASTE MANAGEMENT SITUATION IN SOUTH EAST EUROPE AND FUTURE PERSPECTIVES FOR THE SECTOR INCLUDING OPTIONS FOR REGIONAL CO- OPERATION IN RECYCLING OF ELECTRIC AND ELECTRONIC WASTE TASK 1: NATIONAL WASTE ASSESSMENT AND ROADMAP FOR IMPROVING WASTE MANAGEMENT IN BOSNIA AND HERZEGOVINA Dr Dominic Hogg Fethi Silajdzic Thomas Vergunst Maja Maretić Tiro Tim Elliott Ines Fejzić Wim Van Breusegem Costis Nicolopoulos Chara Kotsani 12th January 2017 Report for: Maja Mikosinska DG Environment of the European Commission Prepared by prepared by: Dr Dominic Hogg (Eunomia), Thomas Vergunst (Eunomia), Tim Elliott (Eunomia), Wim Van Breusegem (EMS), Costis Nicolopoulos (LDK), Chara Kotsani (LDK) and the following country experts Fethi Silajdzic, Maja Maretić Tiro, and Ines Fejzic Approved by …………………………………………………. Dr Dominic Hogg (Project Director) Eunomia Research & Consulting Ltd Tel: +44 (0)117 9172250 37 Queen Square Fax: +44 (0)8717 142942 Bristol Web: www.eunomia.co.uk BS1 4QS United Kingdom Disclaimer The information and views set out in this study are those of the author(s) and do not necessarily reflect the official opinion of the Commission. The Commission does not guarantee the accuracy of the data included in this study. Neither the Commission nor any person acting on the Commission’s behalf may be held responsible for the use which may be made of the information contained therein. Eunomia Research & Consulting has taken due care in the preparation of this report to ensure that all facts and analysis presented are as accurate as possible within the scope of the project. However, no guarantee is provided in respect of the information presented, and Eunomia Research & Consulting is not responsible for decisions or actions taken on the basis of the content of this report. EXECUTIVE SUMMARY E.1.1 Introduction A key task of the Project A Comprehensive Assessment of the Current Waste Management Situation in South East Europe and Future Perspectives for the Sector Including Options for Regional Co-Operation in Recycling of Electric and Electronic Waste, funded by DG Environment, and undertaken by a Consortium led by Eunomia Research & Consulting Ltd.,1 is the development of a National Waste Assessment and Roadmap for improving waste management in Bosnian and Herzegovina (B&H). The National Waste Assessment and Roadmap is being developed by means of a 13- stage approach. The stages are as follows: Stage 1 – Develop assessment criteria; Stage 2 – Gather baseline information and data; Stage 3 – Develop overview of waste management situation; Stage 4 – Assess country performance; Stage 5 – Identification of issues; Stage 6 – Consultation on key issues; Stage 7 – Development of the Roadmap; Stage 8 – Define sequencing of selected measures; Stage 9 – Review of financing sources; Stage 10 – Submission of draft Roadmap to the European Commission; Stage 11 – Consultation with Ministry officials; Stage 12 – Discussion at national workshop; and Stage 13 – Produce final version of country Roadmaps. Further details about the approach taken to developing the Roadmap are provided in Section 3 of the Main Report. Given the small size of Brčko District (BD), it was agreed at the project inception meeting that the National Waste Assessments and Roadmaps would focus on the Federation of Bosnia and Herzegovina (FB&H) and the Republika Srpska (RS). The current waste management situation in both entities was assessed separately and their differences were taken into account when developing the Roadmap which also considers the role that the national government could play in helping to facilitate collaboration on certain aspects of waste management (e.g. with respect to producer responsibility), recognising that competences rest with the entities themselves in accordance with the Constitution. 1 The other consortium partners are EMS, LDK, and IVL. xi E.1.2 The National Waste Assessment The National Waste Assessment was conducted at the state level and for both FB&H and RS. The details of the Assessment are presented in Sections 4 to 14 of the Main Report – each Section explores a different theme of the waste management systems across each entity (e.g. key organisations involved in waste management, performance of the regulatory system, status of planning and strategy documents, waste data and infrastructure, and approach to extended producer responsibility). In the development of the National Waste Assessment, a number of key issues were highlighted for the national and entity levels and key observations are presented below. The full range of issues raised by stakeholders can be found in Section 14 of the Main Report. E.1.2.1 Bosnia and Herzegovina The main observation from stakeholders in respect of the national government level, apart from the fact that the 2000 B&H Strategy for Solid Waste Management prepared by the Ministry of Foreign Trade and Economic Relations (MoFTER) was never formally adopted at the national level (although it established the basis for planning in the entities), was that national government may have stepped back too far from some aspects of waste management. This is in keeping with B&H’s Constitution, but can create challenges in certain areas, for example, those which have implications for markets (such as producer responsibility), and some of the more strategic areas of waste management (such as planning for the treatment of hazardous waste). In respect of producer responsibility, most obligated producers would likely prefer one single mechanism that covers the entire country rather than two separate systems. MoFTER already deals with state level treaties, but the matter of compliance with the EU acquis is a matter for the two entities (i.e. FB&H and RS) to demonstrate. This arrangement has been set up under the country’s Constitution and there appears to be little scope for addressing this segregation of responsibilities at present. However, in the medium- to longer-term consideration should be given to seeking stronger alignment of policies between the two entities in areas such as producer responsibility and hazardous waste. E.1.2.2 Issues Common to Both FB&H and RS A number of issues are common across the two entities, reflecting the distance still to be travelled by both entities: 1) Administrative capacity at the state and local level is weak, with capacity gaps in terms of both resourcing and skills being evident. Few municipalities have dedicated waste management staff. 2) The quality of waste data is poor. This makes it difficult to develop accurate projections, or for understanding how, for example, recycling performance is changing. In RS, there are very few weighbridges in operation. In both RS and FB&H, all plants and facilities requiring a permit are required to report data, but the majority of public utility companies still have no permits (and are not covered by the relevant Regulation). xi 3) In general, implementation of the priority ordering of the waste hierarchy is not evident. Recycling rates remain at a low level (and many of the key targets remain to be established, especially in RS), with much of the activity accounted for by the informal sector. In the absence of other measures, the low level of disposal costs is insufficient to drive activity further up the hierarchy. 4) For municipalities cost recovery is a key issue. In FB&H, depending on the municipality, unpaid fees can amount to between 50% and 70% of the total costs. In RS, the unpaid fees of municipalities have been estimated to range from 30% to 90%. Both FB&H and RS have environmental funds in place, and whilst these can be used to support the development of waste management services in future, the revenues destined for waste management seem unlikely to make a major dent in what is required in future. 5) Management of hazardous wastes is problematic. Neither FB&H nor RS have suitable plans in place for managing hazardous materials. E.1.2.3 Federation of Bosnia and Herzegovina Some key issues identified in FB&H are as follows: 1) There is a division in responsibilities for permitting and inspecting waste facilities between entity and cantonal inspectors which has the potential to create conflicts of interest, and which is unlikely to foster the required expertise in the permitting and inspection services. Overall, the inspection services are under- resourced. 2) Only four landfills (three regional and one municipal) meet EU standards and, although another three are planned, it is estimated that at that stage, only 40% of the population will be served by such landfills. Around 45 landfills are used by municipalities or disposal and several municipalities have prepared Adaptation Plans for their landfills, which is a positive step.2 There remain, however, a large number of illegal sites, and so disposal is generally problematic. 3) We estimate that around 60% of the population is covered by a waste collection service, with coverage more or less complete in larger cities, but dropping to low levels in rural areas. 4) Very large parts of the EU waste acquis remain to be transposed. Waste management planning is not complete (cantonal level plans were not complete), or aligned with the requirements of Article 28 of the Waste Framework Directive. 2 In 2010, according to data from the Federal Institute for Statistics, there were 49 registered municipal waste disposal sites (landfills and official municipal non-sanitary waste disposal sites – see: Federal Institute for Statistics (2011) First Release: Collected and Disposed Municipal Solid Waste in 2010, No. 20.5.1, July 20th 2011). The Federal Institute for Statistics has not updated this information since the publication of this document. Given that there are four sanitary landfills (three regional and one municipal) it is assumed that 45 municipal landfills that are potentially still in operation do not meet sanitary landfill standards as set out in the Landfill Directive.