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 MONTENEGRO Dr Dominic Hogg Marijana Krivokapic Thomas Vergunst Olivera Miljanic Tim Elliott Jasminka Mikalacki Wim Van Breusegem Ivana Madžarević 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 Marijana Krivokapic, Olivera Miljanic, Jasminka Mikalacki, and Ivana Madžarević 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 Montenegro. 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. E.1.2 The National Waste Assessment The National Waste Assessment for Montenegro indicates that although some progress is being made in introducing waste legislation and improving planning for waste management. In reality, however, progress towards meeting the objectives set out in the EU waste acquis is slow. There remain some significant omissions in respect of various key Directives where transposition is concerned, though our understanding is that legislation transposing the EU waste acquis is expected to be complete by the end of 2016 and to have come into force by 2018. Implementation of the legislation remains an issue. The Law on Waste Management seeks to establish certain principles of the Waste Framework Directive, but the hierarchy is 1 The other consortium partners are EMS, LDK, and IVL. i not accurately transposed, and nor is it given adequate meaning through implementing measures. The recently approved National Plan for Waste Management for the period 2015-2020 takes some significant strides towards the development of a coherent approach to waste management in Montenegro, but it also raises questions regarding the appropriate locus for decision making in respect of waste management. Montenegro is a small country in terms of the quantity of wastes which are generated, but there are large parts of the country which are relatively sparsely populated, and which would merit a quite different approach to logistics and choice of vehicles than other parts of the country. The diversity of situations, and the effect this would logically have on logistics, suggest local adaptation of systems is required rather than a single scheme for the country. Similarly, the collection methods chosen in different locations would be expected to influence the nature of treatment infrastructure required. The details of the National Waste Assessment are presented in Sections 4 to 15 of the Main Report – each Section explores a different theme of the waste management system (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). Key observations include the following: 1) The Ministry of Sustainable Development and Tourism (MSDT) has struggled to ensure that municipalities change their approach to waste management in a manner that laws envisage. If MSDT is to develop a strategy and a Plan that delivers change on the ground, it needs to work closely with municipalities and other stakeholders, and to develop policies that are conducive to bringing about change, not least through using financial incentives to drive the change. It is disappointing that such limited progress has been made since the elaboration of the Republic-Level Waste Strategic Master Plan, which was developed with support from the European Agency for Reconstruction back in 2004. This is not for lack of commitment on the part of MSDT’s small, but committed, team, but reflects the prevailing political realities as well as the absence of appropriate incentives, and enforcement of the legislation being developed. 2) In terms of landfill infrastructure, there are two sanitary landfills in the country designed to, or close to, EU standards. A further four are in various stages of design / seeking financing support.2 According to the Report on the Implementation of the National Waste Management Plan in 2013, of the total amount of waste generated, about 30% of waste ends up in unregulated landfills, and about 30% in uncontrolled landfills. This unsatisfactory situation reflects inadequate infrastructure, especially in the North and the northern part of the Central regions, as well as a lack of proper enforcement in those areas where sanitary landfills already exist. 2 These proposed landfills will be developed in Niksic (located in Budos), Herceg Novi (located in Duboki Do), Bijelo Polje (located in Celinska Kosa), and Berane (located in Vasov Do). ii 3) Formal collection services for waste are yet to reach some households (11% or so of the total population), thereby exacerbating the problem of improper disposal. 4) The National Plan steps heavily into the appropriate domain of Local Plans for municipal waste management (for example, in - seemingly - seeking to completely specify, at a national level, systems for recycling). As noted above, the geographical diversity suggests that systems will be different across the country and this will affect treatment options and patterns. 5) Apart from the fact that there is not a complete set of waste management plans that are aligned with the national one (the latest National Plan indicated that of the 21 municipalities, 13 developed Municipal Waste Management Plans in accordance with legislation), the latest National Waste Management Plan (NWMP) suffers from a number of shortcomings, including some inconsistencies between the Plan’s recommendations and the evidence it presents. Although, for example, incineration is the option deemed least affordable, it is retained as an option whose feasibility is to be explored further. It should also be noted that in the collection system being envisaged, the high level of organic – mainly food waste – content of the residual waste would likely render it unsuitable for combustion. Further work is required to understand the options, and potential of, different collection schemes. 6) The regionalisation process – envisaged in the 2004 plan, but never actually formalised – has been slower than many would like: regional planning is now gaining momentum, but the expectation that these should identify significant projects gives rise to concerns that this will lead – as in other countries – to over-investment in residual waste treatment technologies. This is made more likely by virtue of the fact that the approach envisages only limited separate collection, a fact that may make the meeting of longer term targets (now being discussed at the European level) more problematic. 7) Capacity at the state and local level suffers from some shortcomings, with capacity gaps in terms of both resourcing, and technical competence, suggesting a need for capacity building and training. The gap between the current levels of skill and competence, and the levels required, is considerable at the local level. 8)