Being aware of need of preservation of the ecosystem of the Black Sea, the Supreme Audit Institutions of Georgia, Republic of Bulgaria, , Russian Federation, Romania and Republic of Turkey present Joint Report on the Results of the Coordinated Parallel Audit on Protection of the Black Sea against Pollution. The audit was conducted in line with the mandate of the participating SAIs.

Chairman of the Chamber of Control of President of the Bulgarian National Georgia Audit Office Mr. Levan Bezhashvili Prof. Valeriy Dimitrov

Chairman of the Accounting Chamber of Chairman of the Accounts Chamber Ukraine of the Russian Federation Dr. Valentyn Symonenko Dr. Sergey Stepashin

Vice‐President of the Romanian Court of President of the Turkish Court of Accounts Accounts Mr. Mircea Popescu Dr. Recai Akyel

Image 1. Black Sea coast Source: The Black Sea Commission

Contents

Introduction ...... 5 Preamble ...... 9 Section I. Joint conclusions and recommendations ...... 12 Section II. National audits on protection of the Black Sea against pollution ...... 14 Turkish Court of Accounts ...... 14 National Audit Office of Bulgaria ...... 20 Romanian Court of Accounts ...... 24 Accounting Chamber of Ukraine ...... 28 Accounts Chamber of the Russian Federation ...... 33 Chamber of Control of Georgia ...... 38 Section III. Comparative analysis and assessment of auditing data of audit participant SAIs ...... 41 3.1. National strategies ...... 41 3.2. The Black Sea current pollution state and evolution ...... 45 3.3. Monitoring and supervision ...... 49 3.4. Data access ...... 54 Section IV. Improving International and Regional Collaboration to Deal with Pollution ...... 57 4.1. Importance of International and Regional Collaboration for the Black Sea environmental protection ...... 57 4.2. Enhancing the Efficiency of the Black Sea Commission and Its Activities ...... 58 4.3. The Need for the International and Regional Initiatives Development for Saving the Black Sea Environment ...... 60

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Image 2. Dr. Valentyn Symonenko – Chairman of the Accounting Chamber of Ukraine Source: The Accounting Chamber of Ukraine archive

Image 3. Participants of the I Expert Team Meeting for Coordinated Parallel Audit of Protection of the Black Sea against Pollution, June 23, 2010 – Kyiv, Ukraine Source: The Accounting Chamber of Ukraine archive

4 Introduction

The Black Sea (Karadeniz – Turkish, Черно The area of the Black Sea is 432 000 sq. km. море – Bulgarian, Marea Neagră – Its greatest extent from north to the south – Romanian, Чорне море – Ukrainian, Черное 580 km. The maximum depth is 2212 m, the море – Russian, შავი ზღვა – Georgian) – is average – 1240 m. The Black Sea catchment a sea between Europe and Western Asia (the area is about 2 M sq. km., of which about 1 M border between Europe and Asia Minor goes sq. km in the Black Sea coastal countries, through it). The Black Sea is the most isolated including: from the World Ocean – connected to the Oceans via the Mediterranean Sea through Republic of Turkey – 255 ths sq. km, Istanbul, Canakkale (Turk Strait) and Republic of Bulgaria – 16.6 ths sq. km, Gibraltar straits and with the Sea of Azov Romania – 238.4 ths sq. km, in the northeast through the Kerch Strait. The Black Sea Catchment Area is almost Ukraine – 422.7 ths sq. km, fivefold bigger than the area of the sea. For Russian Federation – 8.9 ths sq. km, this reason, the Black Sea is very vulnerable to pressure from land based human activity Georgia – 28 ths sq. km. and its health is equally dependent from the coastal and non-coastal states of its basin.

Image 4. The Black Sea Catchment Area Source: ESRI, HydroSHEDS, GeoNames

5 The Black Sea coast is not cut much but its Chorokh, Kızılırmak, Yesilirmak, Sakarya (to northern part, mainly. The only large the south) and Southern Bug (to the north). peninsular is the Crimean. The biggest bays are: Yagorlytsky, Tendrovsky, The seabed is divided into the shelf, the Dzharylgachsky, Karkinitsky, Calamita and continental slope and the deep-sea depression. Feodosiya in Ukraine, Varna and Bourgas in The shelf occupies a large area in the north- Republic of Bulgaria, Sinop and Samsun – by western part of the Black Sea, where it is over the southern coast of the Black Sea, in 200 km wide and has a depth ranging from 0 Republic of Turkey. The delta and estuaries to 160 meters. In other parts of the sea it has a overflow in the northern and north-western depth of less than 100 m and a width of 2.2 to part of the sea. The total length of the 15 km. Near the Caucasian and Anatolian coastline is over 5000 km, including: coasts the shelf is only a narrow intermittent strip. Republic of Turkey – 1778 km, Republic of Bulgaria – 378 km, The thin upper layer of marine water (up to 150 m) supports the unique biological life in Romania – 245 km, the Black Sea ecosystem. The deeper and more dense water layers are saturated with Ukraine – 1829.1 km, hydrogen sulfide, that over thousands years, Russian Federation – 470 km, accumulated from decaying organic matter in Georgia – 315 km. the Black Sea. Due to the unique geomorphological structure and specific The large European rivers, Danube, Dnieper, hydrochemical conditions, specific organisms, Dniester, and Don via the Sea of Azov, flow baasically on the level of protozoa, bacteria, into the Black Sea. The smaller rivers, which and some multi-cellular invertebrates inhabit flow into the sea include: Mzymta, Psou, the deep-sea waters. Knowledge about Bzyb, Rioni, Kodori, Inguri (to the east), biiological forms of life in the deep waters of the Black Sea is very limited.

Figure 1. Length of the Black Sea coastline

Ukraine 37%

Romania Russian 5% Federation 9% Republic of Bulgaria 8% Georgia 6%

Republic of Turkey 35%

6 The Black Sea flora includes more than 1600 The largest port cities of the Black Sea: types of fungi, algae and higher plants. At the same time, fauna includes: about 2000 species Samsun, Trabzon (Republic of Turkey); of invertebrates, 4 marine mammals and 168 Burgas, Varna (Republic of Bulgaria); fish species, from which the following species have marketable value: grey mullet, anchovy, Constanţa, Mangalia (Romania); mackerel, jack mackerel, pikeperch, bream, Odessa, Evpatoria, Ilyichevsk, Yuzhny, sturgeon and herrings. During recent years of Kerch, Sevastopol, Yalta (Ukraine); XX century – the beginning of the XXI Novorossiysk, Sochi, Tuapse (Russian century Black Sea fishing has been significantly cut due to overfishing and Federation); worsening of the ecological state of the sea. Batumi, Poti (Georgia).

The international transport corridor The voyages of tankers, ensuring oil and oil TRACECA (Transport Corridor Europe — products export from Russian (mainly Caucasus — Asia) goes through the Black Novorossiysk and Tuapse) and Georgian Sea. The Black Sea ports are terminals for (Batumi) ports form significant volume of Pan-European transport corridors. shipping.

Favourable climatic conditions of the Black Sea area stipulate its development as an important resort region. The largest Black Sea resort regions include: the Crimea Southern Coast (Yalta, Alushta, Sudak, Koktebel, Feodosiya) in Ukraine, the Caucasian Black Sea coast (Anapa, Gelendzhik, Sochi) in Russian Federation, Batumi in Georgia, the Bulgarian Black Sea coast (Golden Sands and Sunny Beach), the Romanian Black Sea coast (Mamaia, Eforie, Mangalia).

Image 5. Main tanker movements via the In addition, the Black Sea is a region of Bosphorus­inbound strategic and military significance. Source: http://enrim.grida.no

Image 6. Main tanker movements via the Image 7. Fishing in the Black Sea Bosphorus­outbound Source: The Black Sea Commission Source: http://enrim.grida.no

7 On April 21, 1992 in Bucharest, bearing in situations, provoked by dumping or mind the adverse effect of pollution within continental shelf activity, from atmosphere or internal waters on the marine environment of through it, by hazardous waste during their the Black Sea, authorized representatives of transboundary movement, as well as Republic of Turkey, Republic of Bulgaria, protection of marine living resources, Romania, Ukraine, Russian Federation and scientific cooperation and monitoring. Georgia had signed the Convention on the Protection of the Black Sea Against Pollution It is obvious, that the Black Sea is on the (hereinafter referred to as Bucharest thresholds of intensification of anthropogenic Convention) and agreed to take individually impact on its ecosystem, which creates the or jointly, as appropriate, all necessary background of labelling it as extremely measures to prevent, reduce and control ecologically “vulnerable”. This means that pollution thereof in order to protect and ecological loses are accompanied by preserve the marine environment of the Black economical ones, in particular due to sharp Sea. decrease of the sea natural resource potential. That’s the reason of arising of an idea to The area of cooperation, identified by conduct an audit of how countries carry out Bucharest Convention, is pollution by their commitments of compliance with the hazardous substances and materials from signed convention. land-based sources, ships, in emergency

Image 8. Participants of the I Expert Team Meeting for Coordinated Parallel Audit of Protection of the Black Sea against Pollution, June 23, 2010 – Kyiv, Ukraine Source: The Accounting Chamber of Ukraine archive

8 Preamble

The initiative of conducting the Coordinated monitor and assess the efficiency while Parallel Audit on Protection of the Black Sea utilizing the public funds allocated to this end. against Pollution was introduced by the Accounting Chamber of Ukraine during the The scope of the audit: XII INTOSAI Working Group on - implementation of international Environmental Auditing (hereinafter agreements regulating pollution of the Black INTOSAI WGEA) meeting, that was held on Sea marine environment; January 25-29, 2009 in Doha, State of Qatar. - organization efficiency of the national system for control, prevention and In July 2009 the Accounting Chamber of consequences elimination of marine Ukraine has send invitation letters to the environment pollution; potential participants of the parallel audit, in - utilization efficiency of the public funds particular to SAIs of Black Sea region allocated to protection of the Black Sea basin countries: Republic of Turkey, Republic of waters against pollution; Bulgaria, Romania, Russian Federation and - implementation of international Georgia, as well as to SAIs of Danube river collaborative projects on protection, basin: Federal Republic of Germany, monitoring and assessment of the waters Republic of Austria, Republic of Hungary and quality in the Black Sea catchment area. Slovak Republic. Common Audit Questions were to: The initiative of conducting audit was - establish main pollution sources of the supported by 10 SAIs (Republic of Austria, waters in the Black Sea catchment area; Republic of Bulgaria, Republic of Hungary, - identify the common legal framework for Federal Republic of Germany, Georgia, the cooperating countries that falls within this Russian Federation, Romania, Slovak audit and assess the compliance level; Republic, Republic of Turkey and Ukraine), 6 - assess and compare the systems for of which agreed to participate in it. In terms control, prevention and consequences of this, the draft of the Common Position on elimination of the marine environment Cooperation for the Coordinated Parallel pollution; Audit of Protection of the Black Sea against - assess the activities of the authorities Pollution was introduced during the VII regarding the protection of waters in the EUROSAI Working Group on Environmental Black Sea basin; Auditing (hereinafter EUROSAI WGEA) - determine and assess the implementation meeting, that was held on October 5-8, 2009 efficiency of international, national and in Sofia, Republic of Bulgaria. regional programs as within the frames of this audit; The official approval of the Common Position - determine the dynamics of the qualitative on Cooperation for the Coordinated Parallel composition of the Black Sea waters. Audit of Protection of the Black Sea against Pollution was conducted via electronic The cooperation was based on the rules correspondence in May 2010. contained in the official publication by the INTOSAI WGEA titled “Cooperation The audit objective was to assess the between SAIs, Tips & Examples for implementation of commitments resulting Cooperative Audits”, approved in 2007 at the from international agreements and INTOSAI WGEA Meeting. collaborative projects on prevention of disasters and catastrophes and pollution of the Black Sea marine environment as well as to

9 The participants of audit included SAIs of: results, agreed to break collaboration on the Republic of Turkey, Republic of Bulgaria, Coordinated Parallel Audit of Protection of Romania, Ukraine, Russian Federation and the Black Sea against Pollution into three Georgia (hereinafter audit participants). The phases, endorsed the following preliminary audit coordinator: SAI of Ukraine. structure of a Joint Report and also approved in whole the list of data for comparative The audit covered the following period: analysis and main addressees of the Joint - referring the issues of policy performance Report. – from the date of coming into effect of the Convention on the Protection of the Black Sea The Second Expert Team Meeting for the Against Pollution signed on April 21, 1992 in Coordinated Parallel Audit of Protection of Bucharest; the Black Sea against Pollution was held on - referring the funds utilization efficiency – October 20-21, 2010 in Istanbul, Republic of years 2007-2009, depending on each SAI’s Turkey. national approach. During the meeting participants heard the In addition, the Accounts Chamber of the presentation by the Executive Director of the Russian Federation and the Accounting Commission of the Protection of the Black Chamber of Ukraine, from September 2009 to Sea against Pollution, Prof. Ahmet Kideys, on July 2010, within the scope of the the subject: “The regional environmental Coordinated Parallel Audit of Protection of governance in the Black Sea – The Bucharest the Black Sea against Pollution, have Convention”. Also, the participants finally conducted the Parallel inspection of state approved the list of data for comparative funds and funds from other funding sources analysis, the Joint Reporrt structure and the list utilization, allocated for regulation, of its main addressees. protection, research and reproduction of water biological resources and for provision of The Third Expert Team Meeting was held on environmental safety in the Sea of Azov and April 12, 2011 in Bucharest, Romania. The the Black Sea fishing basin. The Resolution meeting was organized in order to discuss on conducting parallel inspection was the SAIs suggestions and amendments to the approved by chairmen of SAIs on December draft Joint Report, to prepare the final 28, 2009 in Moscow, Russian Federation, and steps for the approval of the Joint Report and the Memorandum on its results was signed on to decide the procedure and the way it is to be December 2, 2010 in Kyiv, Ukraine. signed, as well as to prepare for its presentation at the VIII EUROSAI Congress, Three expert team meetings were held before that is to be held on May 30 – July 2, 2011 in signing the Joint Report. Lisbon, Portuguese Republic.

The First Expert Team Meeting was held on In addition the SAI off Republic of Bulgaria June 23, 2010 in Kyiv, Ukraine. has conducted national audit regarding this matter in 2008-2009 and has updated the audit During the meeting, participants reported on data in accordance to the time period the national audits’ status and preliminary stipulated in the Common Position.

Table 1. The number of auditors participating in the audit

3 3 2 7 5 3

10 While compiling the Joint Report, participant implement the regulations of the countries were guided by the following Bucharest Convention in a specific approaches. country and its main executors, volumes of the funds allocated for the Introduction contains information about the purpose of pollution prevention from significance of the Black Sea to each country. land-based sources on the Black Sea coast. This chapter allows us to The Preamble contains information evaluate intentions. concerning the history of conducting this 1.2. The current Black Sea pollution state audit, its general provisions and the and dynamics: information regarding information on resources used. the volumes of water discharges, including polluted water, evolution of The first section contains joint conclusions main water quality indicators of the and recommendations made audit Black Sea and the outflow of its basin participants, worked out in accordance with main rivers. This chapter shows how national audits and main topics of the third loaded the ecosystem is and the results section. of the state policy in this sphere. 1.3. Monitoring and supervision – this The second section contains summaries of chapter testifies the possibilities to national audits, conducted by audit receive current and reliable participants, as the basis for carrying out joint information for effective management. conclusions or recommendations. 1.4. Data access – shows state policy transparence, as a feedback indicator The third section contains the comparative with its main consumer – population. analysis of auditing data, and is divided into 4 chapters: The fourth section is devoted to improving 1.1. National strategies – information international and regional collaboration to about the documents, which deal with pollution.

Image 9. Participants of the II Expert Team Meeting for Coordinated Parallel Audit of Protection of the Black Sea against Pollution, October 20­21, 2010 – Istanbul, Turkey Source: The Turkish Court of Accounts

11 Section I. Joint conclusions and recommendations

Joint Conclusions

1. In terms of significance of the Black marine ecosystem quality changes. However, Sea and its basin for sustainable development the issues of financing the development and of the Black Sea region countries, their functioning of the existing monitoring governments have taken main necessary systems activities on the national level, as measures for implementing provisions of the well as financing issues of scientific Bucharest Convention on Protection of the laboratory researches conduction, create Black Sea Against Pollution in their national certain risks in well-timed receiving of high- legislature. Every country of the Black Sea quality data concerning marine environment. region has identified the government executive authority, responsible for 5. The Black Sea countries contribute to implementation of provisions of the Bucharest pollution struggling in the Black Sea marine Convention on its territory. In addition, the environment via reporting relevant data and authorities, responsible for supervision and information to the BSC. However there are protection of environment against pollution gaps in data availability and data reporting have been identified, as well. As a result, state due the insufficient correlation among policy of these countries was oriented on national standards. This leads to gaps also in decrease and prevention of the Black Sea Black Sea Information System (BSIS), and as pollution from land-based sources, as well as a result of the lack of a comprehensive on intensification of supervision and common database, data production and responsibility for the caused damage. reporting activities become less effective in However, “polluter pays” principle has not achieving the anticipated targets. been fully implemented and the issue of oil pollution from ships remains unsolved. 6. Insufficient financial support of monitoring is one of the common challenges 2. Despite the efforts at national and of the Contracting Parties in carrying out their regional level, the eutrophication national monitoring programs. They affect phenomenon of the sea by compounds of adversely both the quantity and quality of the nitrogen and phosphorus (nutrients), largely data as well as sustainability and efficiency of as a result of pollution from agricultural, monitoring programs of the coastal countries. domestic and industrial sources, is still the main challenge for the Black Sea 7. Lack of harmonization and Environment. standardization between the national monitoring programs makes it more difficult 3. Although there is a growing trend in to develop common strategies for the investments on the sewage systems and waste collaborative struggle against pollution. water treatment plants in both the river basins and coastal cities, there is yet much more to 8. The appropriate conditions for do since the current situation is still population and interested parties to access inappropriate. Inputs of untreated sewage and environmental information regarding the industrial waste water are not adequately Black Sea ecosystem conditions and issues controlled, and therefore significant funds are were provided in each and every country of necessary for the implementation of river the Black Sea region. This fact testifies the basin management. existence of premises for understanding and support of the measures necessary to improve 4. The Black Sea region countries qualitative and quantitative indicators of managed to establish sufficiently wide Black government activities in the area of protection Sea water monitoring system, which allows of the Black Sea against pollution by the receiving reliable and rather complete data on population of the Black Sea region states.

12 Joint Recommendations

1. In order to protect the Black Sea included in their national reports so that BSIS Environement against untreated waste water could be an effective mechanism able to dumping, concrete and continuous measures achieve the anticipated targets through the should be taken by all coastal countries. The common efforts of countries and the BSC. number of waste water treatment plants should be increased and the level of treatment 5. Harmonization of monitoring at the available treatment plants should be programs and standardization of sampling and improved. For this purpose, sufficient and sample analysis techniques among the adequate funds should be allocated for countries should be achieved in order to treatment systems. ensure the sustainability and efficiency of the monitoring programs in the countries. 2. Supervision systems need to be improved especially to deal with illegal 6. With the purpose of comprehensive dumping into the rivers and the Black Sea. It and practical risk assessment due to gradual is neceesary to strenghten the capacity increase of oil shipping in the Black Sea, it is building of the national supervisory essential to ensure better cooperation, authorities in order to properly control all scientific data exchange and implementation polluters and all sources of pollution that of “polluter pays” principle. affect the Black Sea Environment. 7. To improve scientific regional 3. It is imperative that strategies for the cooperation. controlling of pollution carried by rivers be adopted by all Black Sea coastal countries. In 8. Good environmental protection for the this regard, river basin management programs Black Sea not only depends on the strong should be prepared and implemented regional collaboration but also requires effectively by the above mentioned countries, international initiatives. Regional and especially the ones which do not have yet. It international initiatives to protect the Black is essential that “the best agricultural Sea should be enhanced especially via practice” be adopted and implemented by all developing the operational capacity of the the Black Sea coastal countries, for the BSC. Within the scope of the BSC activities, purpose of reducing nutrient inputs from efficient strategies are needed to be agriculture sources. emphasized in order to obtain the necessary funds from the UN and other international 4. Data quality assurance and quality donors. control procedures should be developed by the BSC (AG IDE) for all the data and 9. To improve the collaboration between information regarding its activities. The the BSC member countries in order to Contracting Parties should follow these practically provide sustainable development procedures to ensure the reliability, relevance of the Black Sea. and completeness of the data and information

13 Section II. National audits on protection of the Black Sea against pollution

Turkish Court of Accounts

I. GENERAL OVERVIEW II. LEGAL FRAMEWORK, INSTITUTIONAL CAPACITY AND With its rich ecosystem the Black Sea INTERNATIONAL COOPERATION TO provides diverse opportunities for economic DEAL WITH POLLUTION IN THE BLACK and social life and has a vital importance for SEA Turkey. But, because of over exploitation of its resources and increasing level of marine The principal national authorities responsible pollution, this invaluable asset is under great for implementation of the laws and threats. regulations on the protection of the Black Sea can be stated as Ministry of Environment and The narrow coastal area of the Black Sea is Forestry, Ministry of Agriculture and Rural densely populated and due to weaknesses in Affairs and Undersecretariat of Marine the regional management systems, human Affairs with their provincial directorates and activities and natural disasters have great also the municipalities. stresses on the Black Sea. Both degradation of the ecosystem due to unsustainable use of the Since Ministry of Environment and Forestry marine resources and land based sources of is the coordinator body in implementation of pollution composed of domestic, industrial the Bucharest Convention and its Protocols, and agricultural wastes as well as ship based its success in establishing and managing the pollution sources increase the vulnerability of coordination among all responsible bodies in the Sea. order to both assess and respond to existing challenges in the region is vital. Turkey has launched many international, national and regional initiatives in order to Turkey has been actively participating in the protect the Black Sea against pollution and joint projects that are carried out to improve had considerable progress in many areas. But the international cooperation in the frame of Turkey still needs to develop its institutional Bucharest Convention and has been trying to and financial capacity to restore and protect do its part in order to add value to information the invaluable environmental, economic and exchange network. However, international cultural resources of the basin for both current activities cannot be attributed to public and future generations. opinion as expected so that a sufficient level

of public participation cannot be obtained to dealing with the basic challenges in the region.

Instead of considering “international information exchange” as the main objective, it should be better considered as a tool to achieve specific goals. That’s why it should be ensured that reported and shared information is functional in developing common policies and strategies and also putting of concrete cooperation tools into

practice on the basis of action plans and Image 10. Presentations during Expert projects. Team Meetings Source: The Turkish Court of Accounts

14 III. DEALING WITH LAND BASED 2. Waste Water Management in the Black Sea POLLUTION Region

The Black Sea is under the threat of many Discharge of inadequately treated waste water land based sources of pollution. Solid waste, is another main pollutant for the Black Sea municipal and industrial discharges, rivers marine environment. Admittedly, the basic loads and agricultural activities can be stated components of sound waste water as the main sources of pollution in the Black management are the collection of waste water Sea region. into sewage system and proper treatment. Central areas of all provinces in the region 1. Waste Management in The Black Sea have sewage infrastructure. But some rural Region. areas are not still connected to sewage system. In these areas, sewage is being In Turkey, the necessary legal framework for discharged directly or via brooks into the the implementation of a sound waste Black Sea. management is in place. Especially the environmental legislation that ensures the The number of waste water treatment plants control of the wastes and the disposal of them or the level of current treatment systems in in an environment-friendly manner offers the the Black Sea region are still not adequate to necessary legal framework for the protection deal with improper sewage discharges. of the marine environment. However, there However, almost all municipalities have are some problems emerging in the ongoing projects on waste water treatment implementation process in the region. plants. Therefore, it is expected that significant progress will be made in that area The processes of collection and transportation in the nearest future. of waste to the landfills are functioning well in general, but there aren’t sufficient Since financing problem is the main treatment facilities in the region. First of all, hindrance for municipalities, their financial despite the law, solid waste isn’t controlled means to use for environmental investments and minimized properly at source. A huge should be increased and the amount of central amount of waste is one of the main threats for funds allocated to municipalities should be environment of the region and the Black Sea. improved. Effective supervision and control Because the number and capacity of sanitary by the Ministry could force municipalities to landfills are very limited and the most serious take serious measures for promoting their challenge confronted in waste management in waste water management. the region is the storage of the waste into unsanitary landfills. 3. Dealing with Pollution Through Rivers

There is a progress in construction of new As one of the main sources of land based landfills and other environmental pollution, many brooks and rivers in the infrastructure investments in the region during region play an important role in carrying the last few years with guidance and financial pollution from agricultural and husbandry contribution of Ministry of Environment and activities into the Black Sea. Especially, Forestry. To promote a sound waste Kızılırmak, Yeşilırmak and Sakarya River management system, main requirement is to basins are the areas where the adverse effects enhance institutional, technical and financial of pollution from agriculture and husbandry capacity of municipalities and increase the activities are observed the most seriously. support of central government for environmental investments. The contributions In order to protect the Black Sea against of private sector and waste producers are pollution from agricultural sources, essential as well. significant projects have been conducted by government agencies. For example, Anatolia

15 Watershed Rehabilitation Project has been IV. DEALING WITH POLLUTION FROM conducted by the Ministry of Environment SHIPS and Forestry with the Ministry of Agriculture and Rural Affairs. The Project that aimed at 1. Marine Transportation and Environmental rehabilitating Kızılırmak and Yeşilrmak River Safety Basins and fighting against agricultural pollutant sources in these basins is supported There is an intensive ship traffic in the Black by World Bank and Global Enviroment Fund Sea and its potential threats on the marine (GEF). Within the scope of this project, environment are increasing continuously. The activities have been carried out to combat most intensive and risky area in the region is with agricultural pollutant sources and the connection point of the Black Sea to the rehabilitate natural resources in micro- Istanbul Strait. More than 50 000 ships of catchments in six provinces that are in the which 1/5 carry oil and other hazardous drainage area of the Yeşilırmak and chemicals pass through the Istanbul Strait Kızılırmak Rivers. lead great threats for the Bosphorus and the coastal zone of Istanbul. Since the ship traffic Another project related to agricultural is one the most important source of oil pollution is “The Project on Capacity pollution in the sea, necessary measures Strengthening and Support to Implementation should be taken in case of any incident that of the Nitrates Directive in Turkey”. It is may affect sea environment and coastal zones. aimed with this project supported by European Union to reduce water pollution It is obvious that a sound environmental caused or induced by nitrates from protection depends on thorough coordination agricultural sources, to develop and apply of preventive, contingency and combating "good agricultural practices code” and to measures, and requires fast and effective develop implementation capacity. action of the responsible national authorities and international cooperation. Unfortunately It is crucial that such projects should be it is difficult to state that all these conditions regarded as good practices and be set as an are valid and effectively implemented in the example for new projects covering all Black Sea region. But there is a considerable catchments in the Black Sea basin in order to progress to ensure effectiveness of protect the sea environment effectively administrative measures for preventing against agricultural pollution through rivers. pollution from ships and strengthen mechanisms in the region for detecting marine pollution incidents and eliminating their consequences.

Still, there is an urgent need for comprehensive and realistic risk assessments because of the dramatic increase in oil shipping in the Black Sea. In general, there is a need for more cooperation, exchange of information on research and sharing of good practice.

Image 11. Oil pollution Source: The Black Sea Commission

16 2. Waste Reception Facilities in the Ports Experiences in the world show that any tanker accident in the Black Sea will affect marine For preventing waste disposal from ships into environment more dramatically because of its the sea, the most important thing is providing close situation. So, oil pollution prevention, adequate facilities in ports for ships to dispose preparedness and response represent a of their waste in an environmentally sound growing challenge for Turkey in view of manner. The ports in the Black Sea shore increasing oil transportation and exploitation have adequate waste reception facilities. But in the region. they cannot use their capacity because of the lack of demand from ships. Ship traffic is not Dealing effectively with the ship based intensive and only a small amount of waste is pollution depends on the availability of being received by ports. adequate equipment with this purpose and employment of the qualified personnel who In contrast to seashore ports, Istanbul can get use of them in case of a need. Apart Bosphorus has very intensive ship traffic that from the barriers with a limited number in has effects on the oil pollution in the Black some ports and shore facilities at the Black Sea. For that reason, it is important to take Sea coast, neither governmental nor private relevant measures to improve waste reception facilities have the adequate equipment and facilities of Istanbul Port and increase ship capacity. That’s why only penalties are inspections for preventing illegal waste imposed in the detected pollution incidents disposal to the sea. and no activity for the removal of the pollution is carried out. Therefore, the polluters face only with the payment of those penalties not being obliged to bear the cost of pollution removal as required by “polluter pays” principle.

There are also severe sanctions and high penalties in the case of detection of ship based pollution incidents. Correspondingly, there has been a fall recently in the pollution incidents caused by ships. In dealing with ship based pollution, ship surveys and port state control activities have important roles and there is a need to improve especially port Image 12. Friendly meeting of audit state controls in the Black Sea ports. participants, April 12, 2011 – Bucharest, Romania Source: The Romanian Court of Accounts

3. Prevention and Removal of Pollution

The intensive traffic in the Black Sea and its composition (oil and other hazardous chemicals) pose great risks for the region, especially for Istanbul. According to official data, 154 million tons of oil was transported via the strait zone in 2009. In the past, many ship accidents have occurred in the region and most of them were devastating for marine Image 13. Turkish Expert Team environment. Source: The Accounting Chamber of Ukraine archive

17 V. MONITORING FACILITIES AND the scope of Anatolia Watershed CONTROL ACTIVITIES Rehabilitation Project and implementation projects of the Nitrate Directive. 1. Monitoring and Assessment of the Black Sea Pollution Inadequate level of specialized human resource and technical capacity as well as Monitoring systems have the key role in non-integrity and discontinuity of monitoring observing the damaging effects of the main activities are the major challenges in Turkey pollutants and in developing the appropriate in the area of water quality monitoring. So, policies and strategies to deal with the national agencies responsible for monitoring pollution threat on the basis of the need to be adequately staffed and assessments of those observations. As strengthened with technical expertise. stipulated in the Bucharest Convention with Moreover, necessary resources should be its Protocols and Black Sea Strategic Action allocated in order to develop their institutional Plans, both international and national and technical capacity. monitoring systems should be put into practice to better analyze the pressures for the 2. The Need for Developing a Common Black Sea. Database and Its Importance in the Phase of Strategy Development As a part of the Black Sea Monitoring System, Turkey has been carrying out its The fact that numerous monitoring activities national monitoring programme under the in the Black Sea coast cannot be carried out in responsibility of the Ministry of Environment a standardized manner and the incapability of and Forestry and with the technical assistance carrying out long-life monitoring projects are of the Institute of Marine Sciences and the main causes of the lack of a Management of Istanbul University since comprehensive database in the Black Sea 2004. region. This situation weakens the functionality of the monitoring activities in Turkey adopted BSIMAP (Black Sea addressing the main challenges and taking the Integrated Monitoring and Assessments appropriate steps to deal with the pollution Programme) and integrated it into its national sources. monitoring and assessment program and support observations of all mandatory For the Black Sea region, the sources of parameters in the frames of the BSIMAP. pollution or risks are put forth somehow as Samplings have been made at 69 stations results of monitoring activities but strategy along the Black Sea Coast of Turkey in which development facilities should be improved. there are 10 hot-spots identified as high There is a need for comprehensive and priority point sources. realistic risk assessments for the dramatic increase of pollution in the Black Sea. So, Beside this programme, there are some other national information derived from monitoring monitoring activities along the Black Sea activities should be evaluated together with coast that are carried out by different regional information and national strategies institutions such as the Ministry of should be promoted for national issues; but Agriculture (monitoring of agricultural most importantly regional strategies should be pollution in the river basins), the Ministry of developed collaborated with other parties Health of Turkey (monitoring of the sea water based on monitoring results submitted by quality in the seasides) and municipalities each country to the Black Sea Information (monitoring activities related to their System (BSIS). missions). There are also ongoing water quality monitoring activities in the river basins to explore the effects of agricultural and nitrate pollution that are carried within

18 Regular updating of the hot spots defined Ministry of Environment and Forestry that highly vulnerable to the pollution is also an new “non-coastal” hot spots are to be important indicator of the success of the included in the monitoring programme in line monitoring activities. A recently finalized with the revised “Protocol on the Protection project put some recommendations forward to of the Marine Environment of the Black Sea update/review the hot spots and sensitive from Land Based Sources and Activities areas of all the coasts of Turkey. In addition (2009)” on the issue of basin based approach to existing hot spots in the coastal region of in dealing with the land based pollution. the Black Sea, it is now on the agenda of the

Image 14. Participants of the III Expert Team Meeting for Coordinated Parallel Audit of Protection of the Black Sea against Pollution, April 12, 2011 – Bucharest, Romania Source: The Romanian Court of Accounts

19 National Audit Office of Bulgaria

The Black Sea is a unique body of water MAIN AUDIT FINDINGS AND resembling a lake. Its only contact with the ASSESSMENTS World Ocean is the Bosphorus Strait which is 35 km long and 700 m wide. Therefore it has 1. Legal framework. taken several centuries for the Black Sea to The adopted regulations in the field of water exchange its seawater with that of the management provide a high degree of Mediterranean. It is therefore extremely harmonization of the Bulgarian legislation vulnerable to pollution. The pollution of the with the European one. Legal terms have been Black Sea ecological system is caused not elaborated for effective implementation of the only by marine activity but also by activities activities aimed at achieving the Bucharest on the land and in the coastal regions or the Convention objectives. upper streams of rivers which carry polluted water into the sea. This fact is of great 2. Provision of resources for carrying importance for the Black Sea into which flow out the activities in MOEW for more than 300 rivers. The largest rivers that implementation of the Bucharest Convention. run into the Black sea are the Danube, Dnepr and Don. 2.1. Administrative capacity Structural units have been set up in MOEW, The Bulgarian Black Sea coast consists of the Executive Environment Agency and the well organized and developed resorts with Regional Inspectorates of Environment and nearby settlements that produce not well Water in line with the tasks assigned to them purified wastewater, discharging directly into by the regulations. The fluctuation of the sea or into the rivers that flow into the sea. manpower and the vacant expert positions Furthermore, there are also big industrial, create a risk for non-effective implementation chemical and oil processing plants. of the tasks assigned to them. The MOEW management has endevoured to enhance the Being aware of the great significance of the qualification and develop the professional Black Sea marine environment as regards skills of the employees in the field of water economy, social issues and health care, the management which has added value to the countries from the Black Sea region have effectiveness of their work. joined forces to protect their common interest. The Convention on the Protection of the 2.2. Provision of funds Black Sea Against Pollution was signed in In order to fund the water protection activities Bucharest in 1992. Its provisions are focused and projects incl. Black sea water, the on undertaking all necessary measures to following sources were used: prevent, reduce and control pollution in view ƒ State budget; of preservation and conservation of the Black ƒ MEW budget; Sea marine environment. The Bucharest ƒ Enterprises in charge of management of Convention was ratified by the Bulgarian environment protection activities; National Assembly through a law, adopted on ƒ Pre-accession funds ISPA and PHARE 26.11.1992 which was enforced for Bulgaria for EU candidate countries. as of 15.01.1994. Financial prerequisites have been established In order to achieve the audit objectives, the in MOEW for implementing the Bucharest activity of the Ministry of the Environment Convention objectives. Funding is provided and Water (MOEW) was examined, with by different external and internal sources and respect to the prevention, decrease or control the funds from internal sources amount to of the marine environment pollution by all 94%, thus providing for the implementation land based sources. of the projects.

20 3. Analysis and assessment of the more than 10 000 p.e. and of the Programme activities for implementation of the Bucharest for application of 91/271/EU Directive for Convention. waste water treatment are in compliance with the requirements and obligations of our Issuing licenses for discharge into water country under the Convention on the objects (for the Black Sea region). Protection of Black Sea Against Pollution.

The issuing of licenses for wastewater A serious delay has occurred in the discharge in water object (Black Sea) implementation of the National programme corresponds to the legal requirements. for objects of priority which is poses a risk for the achievement of its objectives as well as No regulation was adopted by the Minister of for the observance of the provisional terms environment until completion of the audit on agreed. the form and contents of the discharge license registers, maintained by the Water Participation in the Working Groups of the Directorate. Bucharest Convention. During the audited period 16 experts from MEW have taken part Development and implementation of plans, in the work of all advisory groups. Their programmes and projects. participation was most active and regular in the activity of the Advisory Group on Two strategic documents have been in Pollution Monitoring and Assessment, function during the audited period: Advisory Group on Integrated Coastal Zone ƒ The National Strategy for the Management and Advisory Group on Control environment and action plan 2000 -2006; of Pollution from Land Based Sources. ƒ The National Strategy for management and development of the water sector until No specific rules have been elaborated for the 2015. experts’ activity which poses a risk for the implementation of all commitments The objectives included in these strategic undertaken, due to the fact that many documents do not contradict and are in structural units and administrations were conformity with the objectives set in the included in the groups. Bucharest Convention. 4. Analysis and assessment of control The following documents have been activity. implemented during the audited period: ƒ National programme of a special The aim of the control carried out is to priority for the establishment of urban observe the environmental normative acts as wastewater treatment plants for settlements well as to prevent water pollution above having a population of above 10 000 in the admissible limits. Republic of Bulgaria; ƒ Strategic Action plan on the Following an order issued by the Minister of rehabilitation and protection of the Black Sea; Environment and Water the Regional ƒ The Project “Rehabilitation of the Black Inspectorate of Environment and Waters was Sea Ecosystem”: is implemented by the assigned with the task to control the objects United Nations Development Programme for that produce wastewater and also the assisting the countries from the Black Sea provisions and requirements set forth in the Region in the application and implementation licenses for waste water discharge. The Basin of Bucharest Convention Strategic plan and Directorate Director was entrusted with the policies. task to control the implementation of the ƒ The development of a National issued licenses, including the discharge programme for priority in the construction of licenses and this caused overlapping of urban waste water plants for settlements of control activities.

21 The number and location of stations and the The Regional Inspectorate of Environment indicators monitored conform to the and Waters and the Black Sea Basin requirements of international conventions. Directorate control the objects that discharge into surface water objects including the Black The planned sample collections were not Sea by means of conducting checks according carried out in full due to the lack of an own to annual plans, approved by the Minister of sea vessel, with a year-round capability for Environment and Water. As a result of the sample collection for physical, chemical and control carried out infringement statements biological monitoring in areas away from the were issued and sanctions imposed for cases shore. envisaged in the legal framework. The seawater monitoring system provides The overlapping of control activities, assigned information, necessary for making analyses, to both regional structures, the Regional assessments and forecasts as well as for Inspectorate of Environment and Waters and taking appropriate measures by the MOEW in the Basin Directorate, poses a risk of order to achieve the Bucharest Convention’s ineffective control. objectives.

5. Analysis and evaluation of the Black 6. Reporting to international Sea Monitoring System. organizations and informing the public on the Black Sea state. The Black Sea monitoring network consists of stations and points for monitoring the The Executive Environment Agency issues condition of coastal and territorial sea water. annual reports to the European They are situated along the whole coastline Environmental Agency, the Advisory Group and reflect to a great extent the chemical on Pollution, Monitoring and Assessment with condition of sea water in the area close to the the Commission on the Protection of the Black coastline. Sea Against Pollution, on the quality of coastal sea waters. The monitoring of surface waters on the territory of the Black Sea Basin Management The Executive Environmental Agency reports is conducted in accordance with the Program to the European Environmental Agency at 16 for river, lake, dam and seawater monitoring different locations, reflecting the condition of and the Group of indicators for analysis for sea waters. Bulgaria reports the condition of 2005 and 2006. Both of them have been sea waters to the Commission on the approved by the Minister of environment and Protection of the Black Sea Against Pollution water. The certified points for sample on 5 locations and 15 sources of pollution – collection in sea waters are 23 in total, 17 of 10 wastewater treatment plants and 5 which are located in coastal waters, and the industrial pollutants. Data from the physical other 6 – in territorial waters. The samples and chemical monitoring of sea waters and from territorial waters are taken not only from analysis of the sea water quality trends have the surface, but from a deeper water layer as been submitted by the observation points in well. Shabla, Varna, Obzor, Bourgas and Ahtopol. A report was submitted, detailing the The control of water quality and the change of condition of waste waters in the wastewater its characteristics over time is done in treatment plants in Balchik, Asparouhovo, accordance with the norms establishing Tsarevo, Pomorie, Ravda, Obzor-Byala, maximum allowed concentrations of indicator Meden Rudnik, Kiten, the sewerage of substances in coastal sea waters. Those norms Sozopol, as well as the industrial pollutants were introduced with specialized ordinances. “Solvei sodi” JSC, the main site of Lukoil Neftohim Bourgas and its bases in Rosenetz, Varna Harbour and Bourgas Harbour.

22 The deadlines for submitting reports to the Regional Inspectorate of Environment and relevant institutions have been observed and Water and the Basin Directorate. so were the respective criteria, established by 3. Actions should be taken to publish the those institutions. Ordinance for issue of licenses for wastewater discharge in water objects and determining The Executive Environmental Agency the individual emission limitations of effectively carries out Bulgaria’s pollution sources. commitments to share information with the countries, which have ratified the Bucharest 4. The rights and obligations of Convention as well as with other international participants in the advisory groups of the bodies. Commission should be specified.

7. Coastal sea waters assessment for the 5. Actions should be taken to overcome period 2005-2007. the delay in implementing the National Program in order to meet the negotiated The analyses made during the audited period, postponed deadlines. even though based on incomplete amount of sample collections, show that the general 6. Actions should be taken to ensure that trend of improving the quality of Black Sea sample collection for physical, chemical and waters from North to South has been biological monitoring is carried out maintained. throughout the year.

The Ministry of Environment and Water has initiated prerequisites for implementing the activities needed to achieve the aims of the Bucharest Convention. Actions have been taken to reduce, control, and prevent pollution of the Black Sea. The delay in implementing the National Program poses risk to the achievement of the following objectives: reduction of substances, discharged into the sea; achieving the standards of quality for Black Sea waters before the expiration of the negotiated postponed deadlines.

RECOMMENDATIONS

The following was recommended to the Minister of Environment and Water:

1. Actions should be taken to fully staff Directorate “Water management” in the MEW.

2. Actions should be taken to amend the Image 15. The Black Sea Sunrise Water Act in order to stop the overlapping of Source: The Black Sea Commission control functions, delegated to both the

23 Romanian Court of Accounts

Audit Objective. The audit objective was to The state of the Romanian coastal water assess the implementation of commitments quality has improved slightly but resulting from the Convention on the continuously, after 1990, due to the decrease Protection of the Black Sea Against Pollution, of the economic activities in the Central and signed on April 21, 1992 in Bucharest. Eastern European countries within the Danube basin and to the modernization of the Audited entities: wastewater treatment plants of human ƒ Ministry of the Environment and of settlements and industrial units in the EU Forests Member States. o Water Basin Administration - Dobrogea Littoral Regarding the water management major o National Institute for Marine issues, the following four main categories Research and Development “Grigore have been identified: water quality Antipa” degradation, eutrophication, reduction of the o Constanta Environmental Protection aquatic flora and fauna biodiversity and the Agency coastal erosion of the Romanian Black Sea o Regional Commissariat Galati / shoreline. Constanta County Commissariat ƒ Ministry of Health / Constanţa County 1. Water quality degradation is Public Health Department determined by the pollutants discharge ƒ Ministry of Transport and Infrastructure / generated by the anthropogenic activities. Romanian Naval Authority Pollutant load of the Danube led, through the ƒ Ministry of Administration and Interior / process of sedimentation in the coastal areas, Inspectorate for Emergency Situations – at increased levels of nutrients, heavy metals “Dobrogea” of Constanţa County. and organic pollutants in the marine sediments. Furthermore, the predominantly STATE OF THE ROMANIAN COASTAL N-S direction of marine currents favours AND SEA WATERS QUALITY dispersion in the Romanian coastal waters of pollutants originating from the North-East of The state of the Romanian coastal and sea the Romanian littoral. water quality depends mainly on the following: 2. In the instance of coastal and sea ƒ The Danube river, which transports waters, eutrophication has been the main significant quantities of pollutants originating cause of the Black Sea ecological unbalance, from the entire Danube basin; especially in the North-Western and Western ƒ Other rivers (Dnieper, Dniester, South sector. The change of the trophic status of the Bug, Don, Kuban); Romanian coastal waters was due to the ƒ Atmospheric deposition; nutrient intake of the Danube River, as the ƒ Off-shore activities (oil/gas main source and as the favouring source, exploitation platforms, navigation); climate change. ƒ Pollution sources located in the North- East of the Romanian littoral; 3. The process involving reduction of ƒ Local pollution sources on the biodiversity especially displayed in the Romanian Black Sea coast (the contribution Danube River – Danube Delta – Black Sea of the local pollution sources is insignificant, system, was caused by different types of they have a limited impact as compared to the pressure which often act synergistically, their Danube River intake and the sources located effects being cumulated. These include on the North-East of the Romanian littoral). pollution of marine water, over-fishing and emergence of invasive species. The

24 assessment of biodiversity reduction in the SYSTEM instance of the Danube River – Danube Delta – Black Sea system was conducted in a Romania, as Contracting Party of the causality relation with the pressures in the Bucharest Convention, has established and upper and middle sectors of the Danube, carries on a program of water pollution given that upon entry in the country the monitoring and assessment of the national Danube has modified physical – chemical and transitional, coastal and marine water quality biological characteristics, to which are added (Article XV 4); the chemical and hydro-morphological pressures (embankment works) within the Romania, as member state of the European Romanian sector of the Danube. Union, has the obligation to harmonize and implement EU legislation in the field, namely: 4. Coastal erosion – in recent decades, Water Framework Directive, Directive on the Romanian Black Sea shore has suffered bathing waters, Shellfish Directive, Birds and due to coastal erosion, as a result of new Habitats Directives and NATURA 2000 conditions arising in the pre-existing Network, Integrated Maritime Policy, Marine landscape, including climate change and sea Strategy Framework Directive (2008/56/CE), level rise. including the obligation of monitoring;

Coastal erosion has resulted in reduction of Romania is also Contracting Party to other the Romanian seaside beach areas, affecting European and international conventions, about 127 km (57% of the Romanian namely: INSPIRE Directive (Infrastructure shoreline length) and is mainly determined by for Spatial Information in Europe), containing the reduction of the sediment discharge the water component of WISE (European carried by the Danube (consequence of the Water Information System), Initiative on hydro-technical works from the entire Danube Global Monitoring for Environment and river basin) and by the reduction of the Security (GMES), common policies on amount of biogenic sand, following reduction fisheries, European maritime policies, in the shellfish population, consequence of the including maritime spatial planning, coastal water pollution increase. ACCOBAMS Convention.

Romania has one of the most comprehensive monitoring systems, with a network of stations located along the Romanian shoreline, covering transitional, coastal and marine waters; it has the capacity to report to the Black Sea Commission Secretariat complete data sets on the physical and chemical parameters, hazardous substances (in the water, sediments and biota), as well as the biological ones. The results obtained through the marine integrated environmental quality monitoring allow knowledge of the current state of the marine ecosystem, as well as of the dynamics of the physico-chemical and biological components at the spatial and temporal scale. Image 16. Romanian Expert Team Source: The Accounting Chamber of Ukraine archive

ROMANIAN MARINE MONITORING

25 PRESENT STATE AND EVOLUTION REGIONAL COOPERATION TRENDS OF THE ROMANIAN BLACK The NIMRD Constanţa has five national focal SEA COASTAL ENVIRONMENT, IN THE points operating within the Black Sea PERIOD 2007-2009 Commission Advisory Groups in the ƒ The state and evolution trends of following areas: Marine Pollution Monitoring Romanian marine and coastal environment and Assessment; Land-based sources of continued to be physically, chemically and pollution; Biodiversity Conservation; biologically monitored in the period 2007- Fisheries and other living marine resources 2009, and the results were compared with the management; ICZM. historical data (reference periods from the early '60s or more recent years). ANTHROPOGENIC PRESSURES ƒ The state of the marine and coastal Accentuated development of the various environment in 2009 confirms a general trend socio-economic activities within the natural of improvement of the monitored parameters. space of the coastal zone: Tourism and recreation; Agriculture and food industry; THE BLACK SEA AND ITS Shipyards; Petrochemical Industry/Oil- SUSTAINABLE DEVELOPMENT refineries; Mining/Extractive Industry; Constructions/holiday houses; Aerial The strategic documents for sustainable transport/Airports; Ports/Navigation; Tourist development implementation are: the Ports; Manufacture Industry; Nuclear National Strategy for Sustainable Industry; Military and Defence Activities. Development of Romania and the 2009 - 2012 Governance Program. FINANCING THE BLACK SEA ENVIRONMENTAL PROGRAMS. INTEGRATED COASTAL ZONE ENVIRONMENTAL PROGRAMMES MANAGEMENT – THE KEY TOOL OF FINANCED BY THE EUROPEAN UNION SUSTAINABLE DEVELOPMENT During the period of 2000 - 2006, Romania The European strategic documents for the was the beneficiary of ISPA financial Integrated Management of Coastal Zones assistance - Instrument for Structural Policies (ICZM) implementation are: the ICZM for pre-Accession. Strategy Directive; the Water Framework Directive; the Shellfish Directive; the Birds Since January 2007, the date of its accession and Habitats Directives and NATURA 2000 to the EU, Romania is the beneficiary of the Network; the Integrated Maritime Policy; Cohesion Fund for Environment Marine Strategy Framework Directive; the Infrastructure. INSPIRE Directive containing the water component of WISE; the Initiative Global ƒ EX-ISPA IN CONSTANŢA, one of the Monitoring for Environment and Security main international ports and a city with a (GMES); the common policies on fisheries; flourishing tourist activity. the European maritime policies, including maritime spatial planning. The implementation stage. The non- reimbursable financial assistance granted INSTITUTIONAL FRAMEWORK through the ex-ISPA Program in order to finance the measure „Constanţa sewerage and It has been established the National Wastewater Treatment Plant Rehabilitation, Committee of the Coastal Zone, within which Romania” is of 96 556 653 Euros, out of there is a Permanent Technical Secretariat and which the EU contribution is of 72 417 490 Working Groups have been set up Euros. (responsible entity: NIMRD Constanţa).

26 The general objective of the measure consists Protection of the Black Sea Against Pollution in the improvement of the Environment (BSC) is performed according to the Work infrastructure in Constanţa. More specifically, Program of the BSC. through this measure, the Black Sea and the coastal line will be protected against the RECOMMENDATIONS pollution caused by the uncontrolled disposal of untreated industrial wastewater and At regional level sewerage, through the building and extension ƒ Improving the collaboration between of Wastewater Treatment Plants that will treat the BSC member countries in order to carry the wastewaters according to the accepted out a sustainable development of the Black standards of the effluent quality. Sea; ƒ Improving the coordination within the The objectives of this project have been BSC; achieved to a great extent, the project being in ƒ Improving the scientific regional its final implementation stage. cooperation; ƒ Enhancing efforts to reduce pollution of ƒ SECTOR OPERATIONAL the Danube basin waters. PROGRAM FOR THE ENVIRONMENT (SOP ENVIRONMENT). At national level ƒ Improving the coordination between Projects in the area shall be further financed national authorities in order to carry out a through the SOP ENVIRONMENT, the sustainable development of the Black Sea document which sets the strategy for the coastal zone; allocation of European funds for the ƒ Improving the capacity of the health environment sector in Romania, having a total authorities to control the implementation of budget of about 5.6 billion Euros and the the legislation in the field of bathing water; enforcement period – 2007-2013. ƒ Continuing entreaties for the adhesion of the European Union, represented by the European Commission, to the Convention on CONCLUSIONS the Black Sea Protection Against Pollution, in order to facilitate the European funds Following the examinations conducted, an accession process; assessment was made of the progress in the ƒ Strengthening the administrative implementation of commitments resulting capacity regarding the European funds from the Convention on the Black Sea management and implementation at central, Protection Against Pollution, as well as the regional and local level; monitoring and analysis of the efficiency of ƒ Continuing the works for wastewater the use of public funds allocated for this collection and treatment in the human purpose (year 2009) and a reasonable settlements, consisting in the rehabilitation, assurance was obtained relating to the modernization and extension of wastewaters following aspects: sewerage networks, as well as of the ƒ Romania has made entreaties and has wastewaters treatment plants and installations, taken measures relating to the compliance of so as to comply with Directive 91/271/EEC, the engagements undertaken by means of the respectively modernization of all treatment Bucharest Convention. plants on the coastal zone; ƒ An institutional structure is in place in ƒ Continuing the actions to integrally this respect as well as systems for control, protect and rehabilitate the coastal zone, from prevention and consequences elimination of the North to the South, and the environmental the marine environment pollution. factors. ƒ Financial programs have been provided. ƒ The reporting activity to the Permanent Secretariat of the Commission on the

27 Accounting Chamber of Ukraine

PREAMBLE Audit aim – to ascertain real state of effectiveness of utilization of the state budget Within the scope of the Coordinated Parallel resources allocated for providing ecological Audit of Protection of the Black Sea against safety in the Azov-Black Sea Basin and for Pollution the Accounting Chamber of Ukraine regulation, protection, researches and has conducted two audits on national level: reproduction of the biological water resources. First. Audit of Utilization of the State Budget Resources by Scientific and Research Audit objects: Institutions of the National Academy of ƒ The Ministry of Environmental Sciences of Ukraine in Sevastopol City Protection, State Ecological Inspection, state (Report approved on February 9, 2010, no. 2- authorities of environment protection in 4). Odessa and Donetsk regions, State Ecological Inspection in Odessa region, State Audit aim – to ascertain the real state of Ecological Inspection in North-Western Black utilization of the state budget resources Sea region; allocated to research institutions of the ƒ The State Committee of Fisheries and National Academy of Sciences of Ukraine in Fishing Industry, East Black Sea and Sea of Sevastopol City in 2007-2009, including Azov Basin Administrations for protection, those allocated for researches of the utilization and reproduction of water living ecosystems of the Black Sea and the Azov resources and fishing industry regulation; Sea Basins. ƒ Business entities – state budget funds recipients. Audit objects: The National Academy of Sciences of Ukraine, The Institute of the One of this audit questions was the South Seas Biology Named after A. assessment of implementation of the Kovalevsky, The Sea Hidrophysical Institute Accounting Chamber of Ukraine of the National Academy of Sciences of recommendations on the results of the Audit Ukraine. of implementation of Provisions of Convention on the Protection of the Black Sea Among common general activities of the Against Pollution, conducted jointly with institutions mentioned above, are the Bulgarian National Audit Office in 2009 researches on development of effective (Report approved on January 21, 2009, no. 2- measures for biological diversity conservation 1). in the Black Sea and the Sea of Azov, establishment of scientific basis for efficient Audit aim – was ascertaining and assessment utilization of their resources and prevention of of the real state of implementing of the the negative impact of anthropogenic activity provisions of the Bucharest Convention by on marin environment. The effectiveness of Ukraine. According to this aim, three main implementation of these challenges was the issues were covered by audit: audit subject. ƒ legal and normative regulation of implementation of provisions of the Bucharest Second. Audit of effectiveness of utilization Convention on the Protection of the Black Sea of the state budget resources, allocated for Against Pollution; providing ecological safety in the Azov-Black ƒ organization and results of ecological Sea Basin, its protection, regulation and monitoring conduction; reproduction of the water biological resources ƒ implementation of the State Program on (Report approved on March 9, 2010, no. 5-2). Protection and Reproduction of the Black Sea and the Sea of Azov Environment.

28 Audit objects: The Programs stipulated: ƒ The Ministry of Environmental Protection of Ukraine; 1) necessity of improving water ƒ State authorities of environment resources management by implementing the protection on regional level; basin management approach; ƒ State Ecological Inspection of Ukraine; ƒ State Ecological Inspection on regional 2) development and implementation of level; programs and action plans for improving ƒ Scientific Institution «Ukrainian environmental state of basins of Dnieper, Scientific Center of Ecology of the Sea». Danube, Dniester, South Bug, Siver Donets and small rivers by the Black Sea and the Sea AUDITS RESULTS of Azov;

In order to ensure the implementation of 3) coordination of activities using the requirements of the Convention on the basin approach, which is illustrated on the Protection of the Black Sea Against Pollution, scheme of regulatory and organizational in Ukraine, its main provisions have been provision of ecological safety in the Black consolidated in national legislation as Sea and the Sea of Azov Basin, Figure 2. obligatory for all entities. Audit objects have developed and approved main aims and State authorities of Ukraine have established directions of state policy realization in this auxiliary structures, stipulated by Bucharest sphere. The responsible executive authorities Convention and assigned legal principles of have been assigned. sea waters and territorial sea protection.

Main regulatory document, which ensures the In Ukraine, the Ministry of Environmental implementations of regulations of the Protection is a central executive authority Convention on the Protection of the Black Sea responsible for carrying out commitments, Against Pollution on the territory of Ukraine which result from the membership of Ukraine is the State Program on Protection and in the Commission of Protection of the Black Reproduction of the Black Sea and the Sea of Sea Against Pollution. Azov Environment, adopted by the Law of Ukraine in 2001. Organizational support and In 2002, the Ministry of Environmental coordination of Program realization activities Protection has assigned active center for are entrusted to the Ministry of monitoring and assessment of pollution from Environmental Protection. land-based sources – Ukrainian Scientific Center of Marine Ecology, which is located in The Program object is the Black Sea and the Odessa. Sea of Azov environment within inner sea waters, territorial sea, exclusive (marine) economic zone of Ukraine and coastal line.

Besides, in order to implement state policy, aimed at prevention of increase of anthropogenic impact on environment in Ukrainian rivers basins, the Supreme Soviet of Ukraine have approved the State Program for Water Industry Development by adopting a Law of Ukraine in 2002. Image 17. Working process at the III Expert Team Meeting for Coordinated Parallel Audit, April 12, 2011 –Bucharest, Romania Source: The Romanian Court of Accounts

29 30 Information from monitoring subjects is The dynamics of the Black Sea pollutants forwarded to the Center of Sea Ecology intake from main rivers of Ukraine testifies annually. The received data is included in the the downward tendency from 1995 to 2003. Black Sea and the Sea of Azov pollution state However starting from 2003 this tendency indicators data base – “SeaBase” – as the became upward, as result of economic activity components of the integrated geographic resumption in the Black Sea region. information system, established within TACIS Black Sea environmental projects. At the same time main amount of the Black The Black Sea waters monitoring system is Sea pollutants come from the Danube river illustrated on Figure 3. flow. The Danube river flow volume makes up approximately 80 per cent of total flow of The requirements regarding prevention of other rivers, which fall into the North- pollution and obstruction of inner sea waters Western part of the Black Sea. Second place and territorial sea of Ukraine by enterprises, after the Danube river by the amount of establishments, organizations of all patterns pollutants, which flow to the Black Sea, of ownership, citizens of Ukraine, as well as belongs to Dnieper. by foreign legal, physical bodies and persons without citizenship, and also by Ukrainian It has been determined, that Ukraine is not and foreign vessels, which are situated in using all possibilities of Bucharest these waters, are stipulated by Regulation on Convention, regarding more effective Protection of Inner Sea Waters and Territorial mobilization of funds for maintenance of Sea of Ukraine against Pollution and institutions stipulated in it. Obstruction, dated February 29, 1996. Audits testified, that impact of anthropogenic The ensuring of ecological supervision factors on natural complexes has reached an realization is carried out by State Ecological enormous extent and may be compared to a Inspection on Environment Protection in number of natural processes, and besides North-Western Black Sea Region, State Black pollution issues, one of priority areas of Sea and Sea of Azov Ecological Inspection solving main issues regarding the Black Sea and State Azov Sea Ecological Inspection. ecological condition is preservation and reproduction of its biological diversity.

According to their provisions, the inspections Anthropogenic changes of the Black Sea mentioned above are special sub-sections of ecosystem led to the decrease of biological the Ministry of Environmental Protection of productivity of the major part of fish species. Ukraine and are under its management. Pollution level of the Black Sea exceeds capability of water bodies to self clean and The inspections activities extend to inner sea poses a threat to human health. In connection waters, territorial sea, exclusive (marine) to this, measures aimed at regulation, economic zone and continental shelf of protection, research and reproduction of water Ukraine, and estuaries. biological resources and provision of environmental safety in the Black Sea basin The mechanisms of implementing the gain special significance. Bucharest Convention provisions regarding responsibility and supervision over damaging the Black Sea marine environment in regions under the sovereignty of Ukraine, were not adequately adopted, and one of the main environmental principles “polluter pays” is ensured inadequately.

31 RECOMMENDATIONS

With regard to the results of conducted audits, the Accounting Chamber of Ukraine carried out recommendations to The Cabinet of Ministers of Ukraine and The Ministry of Environmental Protection: ƒ to hasten the implementation of the basin approach to water resources management, which is declared by the Water Code of Ukraine, and, in particular, to set standards for maximum allowed pollutant dumping; ƒ to take measures to increase coordination of activities among state ecological inspections; Image 18. Working process at the II Expert ƒ to improve financial support of Team Meeting for Coordinated Parallel implementation of the State Black Sea and Audit of Protection of the Black Sea against Sea of Azov Ecological Monitoring Program Pollution, October 20­21, 2010 – Istanbul, using the funds of entities, which implement Turkey it, in particular, to conduct annual field Source: The Turkish Court of Accounts researches of the state of marine environment; ƒ to liven international cooperation in order to mobilize additional funds for conducting activities in the sphere of protection of the Black Sea against pollution.

Image 19. Working process at the III Expert Team Meeting for Coordinated Parallel Audit of Protection of the Black Sea against Pollution, April 12, 2011 – Bucharest, Romania Source: The Romanian Court of Accounts

32 Accounts Chamber of the Russian Federation

The legal basis for the international cooperation in the area of Black Sea basin According to the requirements under the marine environment protection is the Bucharest Convention Russian Federation has international agreement – The Convention on the obligations to develop and adopt national the Protection of the Black Sea Against action plans and potential response options in Pollution, adopted in Bucharest in April 1992 case of Black Sea pollution, as well as and ratified by Russian Federation in August commitments to timely inform other Parties 1993. about the cases of pollution and measures taken for their elimination. The integral parts of Bucharest Convention are Protocol on Cooperation in Combating It has been established, that Russian Pollution of the Black Sea Marine Federation is currently completing its Environment by Oil and other Harmful domestic procedures, necessary for making a Substances in Emergency Situations, Protocol decision to sign the Contingency plan on on Protection of the Black Sea Marine cooperation in fighting the Black Sea marine Environment Against Pollution from Land environment pollution by oil and other Based Sources, Protocol on the Protection of harmful substances. the Black Sea Against Pollution by Dumping. According to the Russian Federation The Bucharest Convention regulations are government direction, dated February 11, harmonized with the separate norms of other 2002, no. 166-p, the organization of international agreements, including the commitments fulfilment by Russian International convention on prevention of Federation, which are resulting from the pollution from ships, International Bucharest Convention on Protection of the conventions on providing preparedness in Black Sea Against Pollution, is assigned to case of oil pollution, control and cooperation, the Ministry of environment and natural Convention on international guidance for resources of Russian Federation. prevention of accidents at sea, International conventions on civil responsibility for the The inspection has shown, that the regulations damage caused by oil pollution. of the ratified in 1993 Bucharest Convention meet the international foundations and norms The Parties of Bucharest Convention as for of the Russian Federation legislature. There now are: Russian Federation, Bulgaria, are no issues in the area of protection of the Romania, Georgia, Ukraine and Turkey. Black Sea against pollution, that aren’t settled During the 22nd session of Black Sea in the Russian Federation legislature. Commission, in January 2010, it has been noted that the current environmental state of According to the articles XVII and XVIII of the Black Sea is not satisfactory, first of all the Bucharest Convention, in order to achieve due to the continuing pollution of the water the declared targets the Commission on area by oil and oil products, as the results of Protection of the Black Sea Against Pollution high density of tanker shipping of (hereinafter referred to as – the Black Sea hydrocarbons and general increase cargo Commission) has been established. traffic through Black Sea ports. At the same time, during the discussion on the national Seven consulting groups have been reports of Bucharest Convention established within the Black Sea Commission implementation, member countries have on: environmental aspects of navigation; acknowledged positive progress, caused by pollution loads monitoring and assessment; the Parties’ effort on protection of the Black land based pollution control; information Sea against pollution. sharing; coastal area comprehensive

33 management; biological diversity preservation discharges from land-based sources on their and environmental aspects of fisheries. territories such as rivers, canals, coastal establishments, outfalls, as well as pollution In order to implement the regulations of emanating from any other land-based source, Bucharest Convention the Global including through the atmosphere. Environment Fund has established the Black Sea Environmental Program in 1993. The In order to provide protection of water objects Program’s coordination center was against pollution by discharging waste and established in 1994 in Istanbul. Six drain waters, the environmental and water coordination centers for implementing the legislature of Russian Federation stipulates Program regulations with the following the establishment of the permissible norms for distribution of responsibilities have been set pollutant discharges into water objects up: for Bulgaria – center of response to the according to the norms of the permissible emergencies situations relating to navigation; impact on water objects. Georgia – coordination center on biodiversity; Russian Federation – coordination center of The legal protection of the water objects is activity on development of the methodology expressed by establishing measures and for comprehensive coastal area management; control of the water protection zones and Romania – coordination center on fisheries; coastal strips, water objects under special Turkey – coordination center on land based protection, and by conducting compulsory pollution control and for Ukraine – state environmental inspection, which justifies coordination center on monitoring programs planned economic and other activity within development. inland sea waters, territorial sea, adjacent zone, continental shelf and exclusive The Black Sea Environmental Program was economic zone of Russian Federation, as well completed in 2008 by carrying out the GEF as within the natural territories under special project “On the Black Sea ecosystem protection. rehabilitation”. The main purpose of the project was to support the Black Sea basin All rivers, flowing to the Black Sea (except countries (Bulgaria, Georgia, Russian the Psou River), flow through the territory of Federation, Romania, Turkey and Ukraine) in one constituent of Russian Federation – implementation of practical measures on Krasnodar region. rehabilitation and protection of the Black Sea, declared under the Strategic Action Plan on The intensive economic and anthropogenic Black Sea rehabilitation and protection in activity causes negative influence on the 1996. natural bioproductivity and functionality of The Black Sea Commission session was held the Black Sea ecosystem, which is one of the in April 2009, during which the Declaration, most important regions of international that establishes general policy for countries significance for fishing and recreation and regarding Black Sea, and an updated Black tourist industry. Sea Strategic Action Plan, that reflects main working directions within the Black Sea The geographical reticence of the Black Sea Commission, were adopted. stipulates its vulnerability regarding the environmental balance. The sea accumulates In accordance with the Protocol on Protection pollution, brought by waters flowing from the of the Black Sea Marine Environment Against territory of coastal states. The Black Sea Pollution from Land Based Sources, which is pollution level exceeds the self-cleaning an inevitable part of the Convention on the ability of the water body and endangers water Protection of the Black Sea Against Pollution, bioresources and human health. the Parties shall take all necessary measures Intensification of shipping has gradually to prevent and reduce pollution of the marine increased the risk of pollution of water environment of the Black Sea caused by bodies, including pollution by transferring

34 pollutants together with fouling and ballast water and river discharges of water treatment waters. plants at the enterprises of housing and communal services. The stirring up of dredging in recent years presents a special danger. The movement of High level of economic activity in the Black major volumes bottom sediments in water Sea, which has half-closed ecosystem, is the bodies leads to degradation of bottom reason for high level of environment biocoenoses and marine environment vulnerability of this region. One of the most pollution by suspended and toxic matters. serious hazards to the Black Sea ecosystem is In the course of inspection, it has been pollution by oil and other harmful substances, established, that discharge overregulation and first of all considering high density of reallocation, which disturbed natural shipping and coastal fishing in the Black Sea, hydrological conditions of rivers of the Black which requires the coordination of efforts on Sea basin, caused the reduction of biological possible emergency situations elimination at productivity of the majority fish species, and the regional level. the natural productivity of sturgeons has been practically lost. As a result of Black Sea In Russian Federation the functions of state environment state deterioration the population policymaking on legal regulation in the area of living organisms is steadily reducing, the of research, utilization, reproduction and number of separate fish species has reduced protection of natural resources, including and is kept only at the level of existence. water objects, their pollution, as well as environmental monitoring are implemented In 2009 the total amount of water users by the Ministry of natural resources and (including water intakes from underground environment. The provision of environmental water objects) is 294, which is less than in safety and protection of the Black Sea against 2008 by 3 and less than in 2007 by 7. The pollution is implemented by regional volume of intakes from surface water sources authorities and establishments of federal of the Black Sea basin in 2009 has reached 1 services and agencies, which are part of the 080 thousand cu. m, or by 12.2 % less than in Ministry of natural resources and environment 2008, and the volume of water discharges – network. 138 800 thousand cu. m, or by 1.2 % less than in 2008. Still the wastewater discharge into The state monitoring of water objects and surface water sources in the Black Sea basin organisation of its conduction; development in 2009 has increased by 47.8% comparing to of the scheme of comprehensive utilization 2008 and reached 18 860 thousand cu. m. and protection of water objects of The Black Sea Basin rivers; development of permissible For the last three years the total number of norms of impact on rivers of the Black Sea water users drafting water from the Black Sea basin is implemented by the basin or discharging it into the Black Sea reached administration of the Federal agency of water 105. The volume of water drafted from the resources. Black Sea in 2009 was 408 thousand cu. m, and the number of water users drafting water Great role in protecting natural environmental from the Black Sea – 27. In 2009, 104 water systems and biological diversity belongs to users discharged water into the Black Sea, the specially protected natural territories: volume of water discharged by the mentioned Caucasian state nature reserve; Sochi national water users reached 218 400 thousand cu. m, park and Sochi state natural wildlife preserve including 18 240 thousand cu. m of waste of federal importance. water, as the result the 2008 level has been exceed by 50%. According to the Regulation on state The main source of Black Sea pollution on monitoring of water objects conduction, the territory of Russian Federation is waste adopted by the Russian Federation water, flowing into the sea through deep- governmental regulation on April 10, 2007,

35 no. 219, the organisation and conduction of absence of proper craft the observation of state monitoring of water objects is background state of waters distant from shore implemented by the Federal Agency of Water has not been conducted. The control over Resources, Federal Agency of Subsoil pollutants is conducted using minimum Utilization, Federal Service of quantity of indices. Hydrometeorology and Environmental Monitoring together with the Federal Service In order to prevent exhaustion of water of Nature Management Supervision, Federal resources and irreversible environment Service of Environmental, Technological and deterioration, and protect human activity and Atomic Supervision, Federal Service of business entities against floods and other Supervision over Protection of Consumers harmful impacts of natural and anthropogenic and Human Prosperity, Federal Agency of waters, the Federal Water Agency implements Fishing, Federal Service of Supervision over the provision of rational and safe water Transportation, empowered authorities of the utilization, establishes the norms of Russian Federation constituents, owners of acceptable impact on water objects of the water objects and water users. Black Sea basin.

Conduction of monitoring of the Black Sea The developed norms of acceptable impact environment is provided by regional and are intended to set safe levels of pollutants federal structural subdivisions of the Federal and microorganisms content, volumes of Service of Hydrometeorology and water resources catch and water pumps, Environmental Monitoring and its research considering the climatic and natural institutes. peculiarities and established natural and anthropogenic conditions in the The monitoring of the Black Sea marine corresponding region. environment in the area of Adler-Sochi-Adler is also conducted by: NGO “Typhoon”; According to point 226.7 of the sub-program Center of Oceanographic Data at the All- “Objects Construction and Reconstruction for Russian Research Institute of Hydro- Development of the City of Sochi as a Meteorological Data; Federal State Authority Mountain Climatic Resort” of the Program for “State oceanographic institute” and Institute Olympic Objects Construction and of Global Climate and Environment at Hydro- Development of the City of Sochi, by the Meteorological Committee of Russian Order of the Federal Water Resources Agency Federation and Russian Academy of Sciences. dated April 1, 2010, no. 69, the Program for Water Objects Monitoring, situated in the The permissible norms of impact on water Olympic Objects Construction Area in the objects of the Black Sea basin of Russian City of Sochi has been approved. This Federation have been developed by the Kuban program stipulates the order of conduction of Basin Administration and adopted by the water resources, bottom, coast and water Federal Water Resources Agency for all 26 protection areas monitoring, as well as water objects. Frequency of sample drawing, monitoring of hydroeconomic systems and the set of objects under supervision and facilities in the Olympic objects construction supervision parameters and geographical scale area. of the water body under supervision are not quite sufficient.

In addition the monitoring of bottom sediments, suspension, aerosols, biota and structural biological indices pollution, as well as monitoring of microbiological characteristic of beaches and floating trash assessment is not being conducted. Due to the

36 CONCLUSIONS

In Russian Federation the normative legal The monitoring of bottom sediments, base in the sphere of protection of the Black suspended matters, particulate pollutants, Sea against pollution corresponds to biota pollution and structural biological international principles and norms of the indicators, as well as beach microbiological Russian Federation legal acts. characteristics and floating waste assessment is not being conducted. Due to the absence of At the same time, the absence of coordinated corresponding vessels the observation over interstate policy of coastal countries on background state of remote waters is not several normative acts regarding the Black being conducted. Supervision over pollutants Sea protection still exists. Clear distribution is being conducted on minimal quantity of of powers of federal executive authorities in indicators. the sphere of fish industry and subjects of Russian Federation in the process of The instrumental stock and developed distributing coastal water resources quota, is methods allow conducting content analysis of in lack. the main groups of pollutants (oil hydrocarbons, surfactants, heavy metals, As result of control and supervisory activities pesticides) in water environment in adequate of Russian Natural Supervising Authority, volume, however, a part of instruments conducted on the Black Sea in 2009, 224 requires modernization and replacement with infringements have been detected, while the more modern ones. share of removed violations made up 77,7%. 8.8 M rubles have been exacted from 11.4 M In 2008, comparing to 2007, the quality of sea rubles, presented for reimbursement, or 77%. water hasn’t changed significantly and is labeled as “moderately polluted” – 328 water users have been prosecuted, 7.5 M “conditionally clear”. rubles of penalties charged, 6.4 M rubles – exacted, or 85%.

Image 20. Russian Expert Team Image 21. Russian Expert Team Source: The Accounting Chamber of Ukraine Source: The Romanian Court of Accounts archive

37 Chamber of Control of Georgia

INTRODUCTION CORRESPONDENCE OF THE LEGAL FRAMEWORK AND REGULATIONS The Black Sea is one of the most remarkable WITH THE OBLIGATIONS ASSUMED BY regional seas in the world. It is almost totally THE BUCHAREST CONVENTION isolated from the world Oceans, is more than 2200 m deep and has water inflow from basin In order to ensure compliance with the over 2 million km2 including 1/3 of the measures foreseen by the Bucharest continental Europe. The only channel Convention Georgia has enacted appropriate connecting it to the rest of the world is the laws and regulations , such as laws ,,About Bosphorus Straight, which is 35 km long and Water”, ,,About Environmental Impact is as shallow as 40 m at some places. Permits”, order of the Minister of Health ,,About the Approval of the Sanitary norms” Isolation from the neutralizing features of the and others. world oceans and its huge catchment area made the Black Sea especially susceptible to These norms regulate issues related to the the eutrophication (a phenomenon of over water use, determine the terms and fertilization by nutrients and subsequent conditions for issuing the environment impact bloom of phytoplankton). Eutrophication has permits, set level of maximum allowed caused radical changes in the Black Sea discharges and concentrations into the water ecosystem during the last three decades, objects etc. However, the existing negatively affecting sea biodiversity as well legislations needs further improvement for as recreational quality of the waters. harmonization with the EU norms. Currently the new framework for the water law is The Black Sea Coast has a huge social and being drafted which will incorporate River economic importance for Georgia, for Basin and Integrated Coastal Zone recreation and tourism development. Lately Management Principles and will be in the state policy aimed at the realization of the compliance with EU legislation. According to country’s tourist potential and sharp increase the Second National Environmental Programe in the number of the holidaymakers on the the new water law is set to be approved by Georgian Coast has increased the importance 2011-2012. Furthermore, the economic of achieving and maintaining high quality of instruments for stimulating the pollution Black Sea waters a great deal. reduction should be used more widely.

In order to combat the deterioration of the ecological state of the Black Sea, the Black Sea basin countries have signed a convention against the Black Sea pollution in 1992 in Bucharest.

The ratification of the Bucharest Convention by the Parliament of Georgia emphasized the importance of the Black Sea for the country and the Parliament’s commitment towards implementation of the obligations assumed by the Bucharest Convention itself

Image 22. Georgian Expert Team Source: The Turkish Court of Accounts

38 ORGANIZATIONAL STRUCTURE OF has to be registered, is defined by the THE REGULATING BODIES, THEIR Ministry. Potential water user is obliged to ROLES AND DESCRIPTION OF present Ministry a document “Project of the ACTIVITIES Normatives of the Polluting Substances Flowing into the Surface Waters with the Entities charged with the protection of the Discharged Waters”, where technological Black Sea and its river basin belong to the process has to be described: what polluting various levels of Government: substances may flow into the water and calculations of MAC (Marginally Allowed THE MINISTRY Concentrations). Ministry is reviewing the The main responsible body for the document and in case of no objection the implementation of the Bucharest Convention water user gets Environmental Impact Permit is the Ministry of Environment Protection and within the “Marginal Allowed Normatives for Natural Resources. The ministry contains: the Polluting Substances Flowing into the regional territorial units (Samegrelo-Zemo Water with Discharged Waters”, which is Svaneti and Central West directorates), mandatory to comply with. Directorate of the Water Resource Management ,National Environment Agency, Registration of discharged water and Inspection of The Environment Protection. pollutants from the water users in the Black The responsibility of the regional directorates Sea basin Rivers is carried out by the entity of the Ministry of Environment among others within the Ministry-Directorate of is to control the accuracy of the water Management of Water Resources. In this unit registration by the water users: information about the used/discharged water - The Directorate of the Water Resource by the water users alongside with the Management pollutant substances for a whole year is - National Environment Agency gathered annually. Data provided by every - Inspection of Environment Protection water user has to be in accordance with the - Directorate of Environment Protection and marginal allowed concentrations that are Natural Resources of Adjara defined in the Technical Reglament for environmental protection approved by the The entities involved in the Black Sea Ministry. protection and monitoring belong to the different levels of management. Without the The Directorate is making sure that the integral structure with clearly defined provided data is correct (makes adjustments responsibilities some instances of duplication of technical nature) and consolidates it in one of functions has been observed. As the database, groups according to the sectors of entities charged with the protection of the economy, river basins, territorial units and Black Sea belong to the different levels of produces annual reports. government (local, regional and central), the lack of clearly formed structure impairs MANAGEMENT OF THE DISCHARGED coordination, exchange of Information and WASTEWATER FROM THE generally reduces efficiency and effectiveness MUNICIPALITIES of their actions. One of the sources of the pollution of the CONTROL MEASURES Black Sea is the inadequately treated municipal waste water. The numerous In Georgia waters used by industrial, infrastructure development projects that are construction, agricultural and other under the way in the littoral regions of organizations, firms and institutions (water Georgia, especially the ones related to the users) are subject to state registration in spite rehabilitation of the sewage and water supply of the supplying and receiving water bodies. systems will significantly improve the List of water users for which the water usage ecological state of the Georgian coast, but

39 further investments in the wastewater Resources the monitoring of the physical and treatment facilities and other infrastructure chemical qualities of marine water had taken projects are necessary. place. The samples have been taken at the 8 points of the water use. The sample taking CONSERVATION ACTIVITIES and monitoring took place from the 1st of July to 10 of October. In Poti the monitoring In 1998, the World Bank approved a USD 4.4 has been done by the LTD “Laboratory million loan to Georgia Integrated Coastal Research Center”. In the audited period every Management Project (GICMP), which was year in June-September the Center was also funded by a USD 1.3 million grant from conducting monitoring on the Black Sea the Global Environment Fund, a USD 1 water quality. Samples have been taken from million grant from the Dutch Government, 3-4 points and few physical and chemical, as and USD 0.9 million contributed by the well as microbiological parameters been Government of Georgia for a total project cost measured. of USD 7.6 million. According to the World Bank Project Appraisal Document, GICMP Rivers have been monitored by the National was designed to “strengthen institutions in Environment Agency. The monitoring has a Georgia to manage the coastal resources of regular character and its data is put into the the Black Sea by developing, testing and databank. On the grounds of this information evaluating methods to effectively integrate further reports and newsletters are prepared. environmental planning and management into By the main parameters the pollution economic development activities along the standards are within the allowed limits set by Black Sea coast,” and “to assist Georgia in the Order N297/N. meeting its international commitments… including conservation of biodiversity at sites Georgia is a party to the Aarhus Convention of international significance on Georgia’s and the monitoring data is available at the Black Sea coast, such as the Kolkheti and web page www.aarhus.ge. The Ministry of Kobuleti wetland Ramsar sites.” The two Environment cooperates with the Black Sea main components of the GICMP project are Comission and presents it with the annual the establishment of the Kolkheti National reports about the ecological state of the Black Park and the development of the State Sea. Consultative Commission on Integrated Coastal Zone Management which is intended RECOMMENDATIONS to integrate development with environmental management. - The legislative framework has to be optimized in order to ensure the meeting the BLACK SEA MONITORING obligations assumed by the Bucharest Convention. Monitoring is one of the prerequisites for the - The optimization of the structure of the protection of the Black Sea and elimination of bodies responsible for the Black Sea the polluting hotspots. Monitoring in itself protection has to be carried out; more implies constant supervision of the quality of centralized, integral and efficient structure has surface (and marine) waters, gathering data to be created with clearly set duties and for compiling databases and in order to take responsibilities. Such structure has to be prompt action if needed. conducive to the collection and exchange of The Black Sea monitoring system is unevenly information. developed. In the Adjara Autonomous Region - The Ministry has to develop monitoring the monitoring is carried out irregularly. In network for the Black Sea and its river basin. years 2007 and 2008 within the framework of - Cooperation in Black Sea protection the coordinative plan of Directorate of the measures and scientific research should be Environmental Protection and Natural intensified on a regional level.

40 Section III. Comparative analysis and assessment of auditing data of SAIs – participants of the audit

3.1. National strategies

The Bucharest Convention stipulates that each EcoQO 2c: Reduce and manage human Contracting Party shall ensure the application mediated species introductions of the Convention in those areas of the Black EcoQO 3: Reduce eutrophication Sea where it exercises its sovereignty, as well EcoQO 4: Ensure Good Water Quality for as its sovereign rights and jurisdiction. Human Health, Recreational Use and Aquatic Biota The Contracting Parties take all necessary EcoQO 4a: Reduce pollutants measures to prevent, reduce and control originating from land based sources, pollution thereof in order to protect and including atmosphere emmissions preserve the marine environment of the Black EcoQO 4b: Reduce pollutants Sea. originating from shipping activities and offshore installations With the purpose of carrying out and adopting specific measures on implementation of National audits, which had been conducted by Bucharest Convention, the Ministers of SAIs within the scope of the parallel audit, environment of participant countries of have generally testified that all countries of convention on October 31, 1996 in Istanbul, the Black Sea coast had implemented main Republic of Turkey, have agreed and signed regulations of the Bucharest Convention in the Strategic Action Plan for the their national legislation. environmental protection and rehabilitation of the Black Sea, that has been updated on April The main legislative acts of the Black Sea 7, 2009 in Sofia, Republic of Bulgaria. countries on implementing the Bucharest Convention in their national legal framework According to the Strategic Action Plan, it has are: been determined that main issues of the Black Sea environment pollution, and their causes, Republic of Turkey – The Law on could be most effectively and appropriately Ratification of Bucharest Convention, dated addressed through the aims of four Ecosystem March 29, 1994; The Environment Law Quality Objectives (EcoQOs): (Official Gazette (O.G.): dated August 11, 1983, no. 18132) with modifications and EcoQO 1: To preserve commercial marine amendments (Law no. 5491 dated 2006); The living resources Law About the Emergency Interference and EcoQO 1a: Sustainable use of Indemnification In Case Of The Pollution Of commercial fisheries and other marine Sea Environment By Petroleum and Other living resources Harmful Substances (O.G.: dated March 11, EcoQO 1b: Restore/rehabilitate stocks 2005, no. 25752); Organic Agriculture Law of commercial marine living resources (O.G: dated December 1, 2004, no. 25659). EcoQO 2: Conservation of Black Sea Biodiversity and Habitats Republic of Bulgaria – The Law on EcoQO 2a: Reduce the risk of extinction Ratification of Bucharest Convention, dated to threatened species February 23, 1993; The Environmental Law. EcoQO 2b: Conserve coastal and marine habitats and landscapes

41 Romania – Law no. 98/1992 for the 2003, no. 964-IV; Law of Ukraine “On ratification of the Convention regarding the Environmental Protection”, dated June 25, Black Sea protection against pollution; Water 1991. Law no. 107/1996 with modifications and amendments; Law on environmental Russian Federation – The Supreme protection no. 137/1995, repealed and Council of Russian Federation Regulation replaced by Government Emergency “On Ratification of the Convention on Ordinance no. 195/2005, with further Protection of the Black Sea Against Pollution, modifications and amendments; Government dated August 12, 1993, no. 5614-1; over 20 Decision no. 546/2008 on the management of legislative acts, including the Water Code of the bathing water quality – that transposes the Russian Federation dated June 3, 2006, no. Directive 2006/7/CE concerning the 74-ФЗ, Federal Law “On Environmental management of bathing water quality. Protection”, dated January 10, 2002, no. 7-ФЗ and other, as well as over 10 Parliament of Ukraine – Resolution of Verkhovna Russian Federation standard and legal acts. Rada of Ukraine (Parliament) “On ratification of the Convention on the Protection of the Georgia – The Law on Ratification of Black Sea Against Pollution” dated February Bucharest Convention, dated September 1, 4, 1994, no. 3939-XII; Law of Ukraine “On 1993; Georgian law on environmental the basis of national security” dated June 19, protection.

Figure 4. Anatolia Watershed Rehabilitation Project

Republic of Turkey is implementing the Anatolia Watershed Rehabilitation Project The aim of the Project supported by the Word Bank and GEF is: 9 providing a stabilized natural resources management; 9 increasing the income of the people living in the Anatolia and Black Sea Regions; 9 decreasing the pollution originated by agricultural activities and transported by means of Kızılırmak and Yeşilırmak rivers. Duration of the Project which has gone into action in 2005 is 7 years. The components of the Project are: 1. Animal waste management system; 2. Pollution coming from agricultural industries; 3. Monitoring of the water and soil quality; 4. Public awareness; 5. Identification of the legal framework of organic agriculture; 6. Preparation of the good agricultural practices guideline; 7. Improvement of the institutional and political structures necessary for adaptation of the European Union. Objectives of the Project are: 1. Identification of the effects of the agricultural pollutants on water and soil resources with using N and P analysis; 2. Getting under control the nutrients transported to Black Sea through Kızılırmak and Yeşilırmak Rivers and getting the nutrient concentration level to comply with the standards determined in the legislations; 3. Ensuring international quality standards in parameters and measurement methods; 4. Making inventory works to identify agricultural industries and pollutants originated from these in the Project site; 5. Making an action plan to prevent the pollutants coming from agricultural practices; 6. Implementation of the Regulations of “Protection of the Water Resources Against Nitrate Pollution Coming From Agricultural Activities” (18.02.2004/The Official Gazette No:25377).

42 In addition, national plans (strategies) of dated August 10, 1998, no. 191, Program for realization of measures on protection of the Olympic Objects Construction and Black Sea against pollution were developed Development of the City of Sochi as a and implemented in several states, e.g.: Mountain Climatic Resort, adopted by the Parliament of Russian Federation Regulation, Republic of Turkey – The fulfilment dated December 29, 2007, no. 991. of the regulations of the Law About the Emergency Interference and Indemnification National audits have testified that the main In Case Of The Pollution Of Sea Environment institution responsible for national strategies By Petroleum and Other Harmful Substances. implementation by government is the supreme government executive authority in the area of Republic of Turkey has put into effect several environmental protection: important documents on the issue of Republic of Turkey – Ministry of environmental protection such as EU Environment and Forestry; Integrated Environmental Approximation Republic of Bulgaria – Ministry of Strategy (2007-2023), National Action Plan Environment and Water; on Land Based Pollution in Black Sea Romania – Ministry of Environment Region, The National Action Plan on and Forests; Wastewater Treatment Management (2008- Ukraine – Ministry for Ecology and 2012), National Action Plan on Waste Natural Resources; Management (2008-2012). Russian Federation – Ministry of Natural Resources and ecology; Georgia – Ministry of Environmental Republic of Bulgaria – National Protection and Natural Resources. strategy of environmental protection and action plan on 2000 – 2006. National strategy of water In addition, with the purpose of state policy sector management and development till 2015, implementation the ministries of the following adopted by the Councils of ministers, Water fields were drawn in: agriculture and rural resources management plan (Black Sea region). affairs (Republic of Turkey, Russian Federation, Ukraine); maritime affairs Romania – Government Emergency (Republic of Turkey); public health, Ordinance no. 71/2010 on establishing the transportation and infrastructure, home affairs strategy on marine environment, Government (Romania, Ukraine, Russian Federation); Emergency Ordinance approved by Law no. foreign affairs (Russian Federation). 280/2003 concerning Integrated Coastal Zone Management. In addition, the issues of the Black Sea protection are dealt with by specially Ukraine – State program of water established public scientific institutions: industry development, adopted by the Law of National Institute for Marine Research and Ukraine, dated January 17, 2002, no. 2988-III, Development “Grigore Antipa” Constan a State program of the Black Sea and the Sea of (National Research and Development Institute Azov environment protection and for Environmental Protection – INCDPM) reproduction, adopted by the Law of Ukraine, (Romania); Institute of oceanography named dated March 22, 2001, no. 2333-III. after P.P. Shirshov, All-Russian scientific institute of hydro-meteorological information, Russian Federation – State Strategy of State oceanographic institute named after environmental protection and sustainable N.N. Zbruyev, Institue of global climate and development provision, adopted by the ecology, All-Russian scientific institute of President of Russian Federation Decree, dated fish industry and oceonography (Russian February 4, 1994, no. 236, Federal Target Federation); Institute of Biology of Southern Program “The Great Ocean”, adopted by the Seas named after O.O. Kovalevsky, Marine Parliament of Russian Federation Regulation Hydro-physics Institute, Southern Scientific

43 Institute of Marine Fish Industry and In Romania and Republic of Bulgaria a Oceanography, scientific institution of the significant financing source of the mentioned Ministry for Ecology and Natural Resources activities consisted of pre-accession funds (Ukraine). (ISPA, PHARE, SAPARD) and EU funds after these countries have obtained EU As the national audits have testified, the funds membership. As a result during 2007 – 2009 for implementation of activities on protection investments in Romanian coastal area from of the Black Sea against pollution during EU funds, such as pre-accession funds (ISPA, 2007 – 2009 were allocated basically from SAPARD) and poost-accession funds two sources: state and local budgets. (Structural Funds, Cohesion Fund), as well as loans from international financial institutions It is worth mentioning that there is no fund for instance EBRD, WB topped 738.5 M specifically allocated for the purpose of USD, which is 15.7 times more than the pollution prevention from land-based sources volume of funds, allocated from all other on the Black Sea coast in Republic of Turkey. sources. The volume of EU funds, invested Relevant agencies use funds to perform their during 2007 in Republic of Bulgaria, was missions on protection of the Black Sea close to 3% of the whole volume of funds, against pollution but it is not possible to allocated for implementing the activities on calculate an exact volume of funds. protection of the Black Sea against pollution in this country. In Georgia, funds for pollution prevention from land-based sources on the Black Sea coast were not allocated.

Figure 5. Volumes of funds allocated for the purpose of pollution prevention from land­ based sources on the Black Sea coast in 2007 (M USD)

14

12

10 8.6 8

6 8.8 8.0 3.1 4 4.6 2 2.7

0 Republic of Romania Ukraine Russian Federation Bulgaria

State budget, M USD Local budget, M USD

44 Figure 6. Volumes of funds allocated for Figure 7. Volumes of funds allocated for the purpose of pollution prevention the purpose of pollution prevention from land­based sources on the Black from land­based sources on the Black Sea coast in 2008 (M USD) Sea coast in 2009 (M USD)

20 20

15 6.1 15 5.8 10 10 2.8 11.6 3.0 5 10.2 9.1 5 8.4 1.0 0.3 0 0 Romania Ukraine Russian Romania Ukraine Russian Federation Federation

State budget, M USD Local budget, M USD State budget, M USD Local budget, M USD

3.2. The Black Sea current pollution state and evolution

The analysis of the data, acquired while volumes of waste water discharges into the conducting the audit, regarding the issues of Black Sea almost in all Black Sea coast the Black Sea pollution from land-based countries. sources has shown gradual decrease in

Figure 8. Total volume of waste water discharges into the Black Sea (M cu. m)

489.4

500 450 400 240.1 241.0 350 294.8 142.9 251.5 300 169.3 250 128.4 285.4 291.4 200 15.3 130.1 150 151.9 17.2 100 96.0 2009 50 136.7 17.7 0 M cu. m 95.8 2008 Republic of Republic of Turkey Romania 2007 Bulgaria Ukraine Russian Federation Georgia 2007 2008 2009

45 In addition the volumes of discharges of polluted/inadequately treated waters into the Black Sea are decreasing.

Figure 9. Volumes of discharges of polluted/inadequately treated waste waters into the Black Sea (M cu. m)

160 108.3 140 93.2 58.0 120 40.0 69.2 151.7 100 47.4 80 18.2 60 74.2 40 42.5 2009 20 12.2 0 2008 10.6 M cu. m Republic of 2007 Turkey Romania (Inadeq. treated Ukraine Russian WW) Federation 2007 2008 2009

However, the percentage (%) of polluted/inadequately treated waste water discharges in total discharges into the Black Sea stays significant, that testifies the necessity of implementation of additional measures for discharged water treatment in all Black Sea region countries.

Figure 10. Percentage (%) of polluted/inadequately treated waste water discharges in total discharges into the Black Sea

50% 44.60% 45% 40% 35% 30% 28.00% 24.54% 25% 20% 15% 10.44% 10% 5% 0% Republic of Romania Ukraine Russian Turkey (Inadeq. treated Federation WW)

46 As a result, change of the main indicators of the Black Sea waters chemical composition is insignificant.

Table 2.1 Main indicators of the Black Sea waters chemical composition

Indicators Suspended Dissolved BOD 5 (5­day biochemical Sulphates Chlorides matters oxygen oxygen demand) States Positive Positive Positive Positive Positive change: ↓ change: ↓ change: ↑ change: ↓ change: ↓ Republic of Turkey ↓ → No data No data ↓ Republic of Bulgaria ↑ No data No data No data ↑ Romania → ↑ ↓ ↓ → Ukraine ↓ ↓ ↑ → ↓ Russian Federation ↓ ↓ → → →

Georgia ↓ No data → ↓ ↓

Table 2.2 Main indicators of the Black Sea waters chemical composition

Indicators Ammonium Nitrites Nitrates Phosphates States Positive change: Positive change: Positive change: Positive change: ↓ ↓ ↓ ↓ Republic of Turkey ↓ ↑ ↓ ↑ Republic of No data No data Bulgaria ↓ ↑ Romania ↑ ↓ ↓ ↓ Ukraine ↓ ↑ → ↓ Russian Federation ↓ ↓ ↓ → Georgia No data No data No data No data

Thereby, the Black Sea countries have In addition, the significant changes of the generally implemented the regulations of the marine ecosystem quality and the level of Bucharest Convention in their national pollution were not reached, that may testify legislation, assigned authorities, responsible the necessity of complex international for implementation of corresponding measures development and implementation. measurements, and also the sources of their financing.

47 Figure 11. Agricultural Pollution Control Project

Romania has implemented the Agricultural Pollution Control Project in the period April 2002 - June 2007 in a pilot area of Călăra i county.

The 10.8 million dollars project was co-financed by the World Bank, with funds from the Global Environment Facility (GEF - $ 5 150 000) and from the Government of Romania ($ 5 650 000). The overall objective of the project was to reduce the long term nutrient discharge (especially nitrogen and phosphorus) and other agricultural pollutants into the Danube River and the Black Sea, through integrated soil and water management and promoting the ecologically sustainable use of natural resources in two agricultural polders. The global environmental objective is to reduce over long-term nutrient enrichment in the waters flowing into the Danube River and Black Sea, through integrated soil and water monitoring. The project, to be implemented over five years, includes the following four components: Component 1: Investments at the commune level focusing on about 86 Nitrate Vulnerable Zones (NVZ); Component 2: Support for institutional strengthening and capacity building ; Component 3: Public Awareness and investment replication Strategy; Component 4: Project Management. As a result of the interventions done, nutrient discharge (nitrogen and phosphorus) into the Danube, from the implementation area of the Project, has decreased by about 10 %, since 2006, when the livestock manure collecting and management systems became operational in the 7 communes included in the project. The situation continues in the present. Given the success of the project, acknowledged and given example by the GEF and the World Bank, starting with 2008, it has been replicated at the national level, in 86 localities vulnerable or potentially vulnerable to nitrate pollution through the Integrated Nutrient Pollution Control project financed through a 50 million Euro World Bank loan and a $ 5.5 million non- reimbursable financial assistance from GEF funds. Current situation Until 31 December 2009, project disbursements have been made in the amount of U.S. $ 902 933.20 from the GEF grant and EUR 908 112.39 from the World Bank loan. Also, at the reporting date (June 2010), two applications were in process, from the GEF grant, totaling about 640 000 USD. On June 30, 2010, withdrawals from the GEF grant were of 1 194 788 Euro and 1 624 992 Euro from the World Bank loan. The investments for the livestock manure collecting and management systems in 11 communes, which have been designated as Demonstration and Training Centre, will be completed in 2010, and will become operational in 2011. The effect of these investments, combined with behavioral changes induced by demonstrations and information campaigns organized within the project is estimated to an annual reduction of the amount of nutrients discharged into surface and ground waters, and finally into the Danube River and Black Sea, of about 130 tons nitrogen and about 110 tons phosphorous. Gradually, as the project interventions will be completed in the remaining 75 localities - Nitrate Vulnerable Zones, the nutrients discharges will be reduced. Quantitative estimates will be possible starting with 2012, based on the monitoring measurements to be carried out.

48 3.3. Monitoring and supervision

The Bucharest Convention stipulates, that the National audits have testified, that all Black Contracting Parties shall, inter alia, establish Sea region countries carry out the Black sea complementary or joint monitoring programs water quality monitoring in their territorial covering all sources of pollution and shall waters. establish a pollution monitoring system for the Black Sea including, as appropriate, As the parallel audit has shown, the funds programs as bilateral or multilateral level for allocated for the functioning of the Black Sea observing, measuring, evaluating and water monitoring systems in coast countries analyzing the risks or effects of pollution of during 2007 – 2009 (without data for the marine environment of the Black Sea. Republic of Bulgaria and Georgia) totaled 3.6 M USD, about 1.3 M USD annually, except Each Contracting Party shall designate the 2009, due to the global economic crisis and competent national authority responsible for public funds saving during this period. scientific activities and monitoring.

Figure 12. Volumes of the funds actually utilized for the development of the national monitoring system for the Black Sea waters (USD ths)

492.5 500 438.2 450 431.8 402.8 396.1 379.3 400 349.0 337.1 350

300

250

200

132.2 150 106.4 113.5 100

50 25.2

0 Republic of Turkey Romania Ukraine Russian Federation

2007 2008 2009

49 In Republic of Turkey the water The implementation of the objectives quality monitoring activities have been of the Bucharest Convention in Republic of carried out both at hot spots and in the sea as Bulgaria is regulated by the Environmental well as in the river basins. Protection Act (EPA), Water Act (WA) and the secondary legislation issued on the Hot spot and deep sea monitoring activities in grounds of these acts. the Black Sea are mainly performed by the Ministry of Environment and Forestry The Environmental Protection Act is a basic through close collaboration with the Institutes law that regulates the ecological control over of Marine Sciences of various universities. the economic activity. It introduces the main The Black Sea Pollution Monitoring Project objectives of the legislation, regulating the which is conducted by Istanbul University protection and utilization of the Institute of Marine Sciences and Management environmental components – water and water is one of the most comprehensive monitoring objects, soil, air, depths of the earth and activities carried out in Turkey. biological diversity.

Water quality monitoring activities in the The Water Act regulates the rights and river basins carried out within the scope of obligations of the state, municipalities, private several projects such as Anatolia Watershed and legal entities in the protection and use of Rehabilitation Project and implementation waters. The Act regulates the water projects of the Nitrate Directive are important management using the basin principle, the by means of exploring the effects of terms of water and water basins utilization, agricultural and nitrate pollution. It is aimed the requirements for water protection against with these projects that monitoring activities pollution, licenses, monitoring, penalties and will be put in a standardized manner through compulsory administrative measures upon providing technical and fiscal assistance in violations. the short-term period and institutional capacity of the relevant agencies will be The secondary legislation regulates mainly developed in order to achieve an advanced the indicators and norms to which the quality monitoring network system in the mid-term of the coastal sea waters should correspond, period. the emission norms for admissible degree of some harmful and dangerous substances in There are also monitoring activities executed wastewaters discharged into water objects. It by the provincial directorates of the Ministry also regulates the procedure for issuing of Environment and Forestry in order to licenses for discharging waste water from control the provision of the anticipated quality pollution sources into surface water objects, standards of discharged waste water to the the procedure for setting up water monitoring rivers or directly to the Sea. The legal basis network and the activity of the National for this kind of monitoring activity stems Water Monitoring System on the territory of from “Regulation for Water Pollution Republic of Bulgaria. Control” and “Regulation on the Urban Waste Water Treatment”. Main entities are: - Executive Environmental Agency inistry of Health is the other complementary - Basin Directorate for water management in authority that is responsible of the quality of Black Sea Region. the bathing water and therefore public health. The Ministry along with the municipalities performs this mission depending on the “Regulation of Bathing Water Quality”.

50 In Romania, the following documents of the Water Framework Directive regulate the development and management of 2000/60/EC; the Black Sea waters national monitoring - Constanţa Environmental Protection system: Agency – participation in the activities - Water law no. 107/1996, with further concerning the water state assessment on the modifications and amendments – that level of Constanţa county, through monitoring transposes the EU Water Framework of the environmental factors quality, Directive 2000/60/EC; including marine environment; - Law on environmental protection no. - Constanţa County Public Health 137/1995, repealed and replaced by Department – responsibility for monitoring of Government Emergency Ordinance no. the bathing water quality from micro- 195/2005, with further modifications and biological point of view, within the coastal amendments; zone. - Government Decision no. 686/1999 on the establishment of National Institute for Marine The main regulatory legal act that Research and Development "Grigore Antipa" determines the necessity for conducting state Constanţa, with further modifications and water quality monitoring in Ukraine is the amendments; Water Code, adopted by the Law of Ukraine - Government Decision no. 546/2008 on the dated June 6, 1995, no. 213/95-BP. According management of the bathing water quality – to the Water Code the state water quality that transposes the Directive 2006/7/CE monitoring is conducted with the purpose of concerning the management of bathing water collecting, processing, saving and analyzing quality; of data regarding water condition, prediction - Government Emergency Ordinance no. of its change and development science-based 71/2010 on establishing the strategy on recommendations for management in the marine environment. sphere of water utilization and protection and rehabilitation of water resources. State water The ecological status of the Romanian Black monitoring is a part of the state environmental Sea transitional, coastal and marine waters is monitoring system in Ukraine and is being assessed on the basis of the physical, conducted according to the procedure, chemical, biological and hydromorphological assigned by the . indicators recommended by the Water Framework Directive and Marine Strategy The state water monitoring conducting Framework Directive. procedure has been adopted by the resolution of the Government of Ukraine dated July 20, Organizational system of the Black Sea water 1996, no. 815, and it determines the monitoring in Romania includes: cooperation between the state water - National Institute for Marine Research and monitoring entities, development of the Development "Grigore Antipa" Constanţa – monitoring system, as well as methodological, responsible for monitoring of physico- metrological, material, technical and financial chemical parameters, contaminants and provisions of its conduction. biological indicators in transitional, coastal and marine waters (44 monitoring stations / In addition, the state task environmental water, sediments and biota), according to program for environmental monitoring Water Framework Directive (2000/60/EC), conduction has been adopted by the resolution Marine Strategy Framework of the Government of Ukraine dated Directive (2008/56/EC) and Shellfish Waters December 5, 2007, no. 1376. Directive requirements; - River Basin Administration – Dobrogea According to this document the main littoral – responsibilities for monitoring of the authority in the water monitoring system is water quality for coastal and transitional the Ministry for Ecology and Natural waters in order to comply with the provisions Resources of Ukraine, which implements its

51 duties through the specially established indicators (5 stations – State ecological institutions (State ecological inspections) and inspection for the Northwestern part of the via state authorities under its subordination Black Sea environmental protection, 3 (Water industry committee, Centre of marine stations – State Black Sea and the Sea of ecology). Azov ecological inspection, 8 stations – Centre of marine ecology). This situation has In addition, the institutions, subordinated to been changed in 2009 by putting into the Ministry of Public Health and the State operation the research vessel “Academician Meteorological Service are included in the Parshyn”, which conducts monitoring water monitoring system. researches.

The Ministry for Ecology and Natural The data from the monitoring stations is Resources of Ukraine has identified the active directed to the Centre of marine ecology centre for monitoring and pollution from yearly. The received information is included land-based sources assessment in 2002 – the in the Black Sea and the Sea of Azov Ukrainian scientific center of marine ecology, pollution state indicators data base – which is situated in Odessa. “SeaBase” – as the components of the integrated geographic information system, The Ukrainian scientific center of marine established within TACIS Black Sea ecology has developed the Black Sea and the environmental projects. Sea of Azov state environmental monitoring program. This program has been developed as Russian Federation performs the a section of the State environmental functions of state policy making regarding monitoring program of Ukraine. legal regulation in the area of research, utilization, reproduction and protection of The objective of the program is to secure natural resources, including water bodies, legal, organizational, methodological and their pollution, and also environmental procedural principles of the state marine monitoring. environment monitoring system functioning, the purpose of which is to establish the Provision of environmental safety and information base for environmental state protection of the Black Sea against pollution management and efficient use of the Black are performed by local authorities of the Sea and the Sea of Azov natural resources Krasnodar Territory and the establishments of within the territorial waters and the exclusive federal services and agencies, which are a part marine economic zone of Ukraine. of the Ministry of Environment of Russian Federation system. The establishment of the monitoring stations network was stipulated under the mentioned In Russian Federation the Black Sea program from 2005 till 2009 with the total environment monitoring is conducted by state budget funding of 2 M USD. The organization departments of the Federal monitoring program had an aim of Hydrometeorology and Environmental establishing the observation system on 287 Monitoring Service and its scientific existing and newly created monitoring institutions with participation of other federal stations, out which: 206 in the Black Sea and and constituent territory executive authorities, 81 in the Sea of Azov. as well as owners of water objects and water users, in accordance with the Regulation on However, due to the absence of necessary conducting state monitoring of water objects, funding the monitoring stations network is adopted by the Government of Russian represented only by 16 stations, which stay Federation Regulation, dated April 10, 2007, under direct influence from the coast sources no. 219. of pollution, as well as in port water areas and do not cover the whole range of necessary

52 The Black Sea marine coastal monitoring With regard to holding the XXII Winter network under Federal Hydrometeorology Olympics and the XI Winter Paralympics in and Environmental Monitoring Service the City of Sochi in 2014, the Program for includes 6 monitoring spots. The Black Sea Monitoring of Water Objects, located in the marine environment state monitoring is Olympic Objects Construction Area in Sochi conducted by contact (from vessels) and non- has been approved, and it will ensure contact methods (satellite monitoring, remote comprehensive approach and coordination of methods of water surface condition control, activities of state authorities in the sphere of etc.). Monitoring over hydro-chemical provision of ecological safety in the Black characteristics and the Black Sea coastal Sea. waters pollution is conducted by complex environmental pollution monitoring The monitoring in Georgia is laboratories. Scientific and technological supported by the law, "About Environment support for monitoring allows conducting Protection", granting the Ministry of adequate content analysis of pollutants in Environment Protection with the overall water environment (oil carbohydrate, supervision and maintenance of the surfactants, heavy metals, pesticides). monitoring system. Other important acts are law ,,About water” , ,,About Environment With the purpose of optimizing the Black Sea Impact Permits” , ,,About Biodiversity “ and water environment monitoring program and other legal acts such as order of the Minister widening the number of processes and of Health and Social security No 297/N parameters under control, Federal setting the qualitative norms for the surface Hydrometeorology and Environmental waters. Monitoring Service has worked out the Draft Complex Black Sea Monitoring Program, The monitoring function is further delegated which includes description of parameters, to provincialities and local governments. frequency and location of the monitoring Monitoring on rivers is carried out by the spots. Directorate of Environment Protection and samples are taken bimonthly on BS basin The usage of monitoring data after processing rivers at 21 points, analyzed and published includes four levels of information directing: monthly on a web site. The Black Sea - informational support of federal (including Monitoring Centre in Batumi studies the state Federal Nature Management Supervision of sea biodiversity. The quality of Black Sea Service and Federal Water Resources waters is monitored by the Adjarian Agency) and regional government authorities Directorate of Environment and other local (prompt data on emergency and extremely governments . high water environment pollution); - informational support of population Within the Black Sea Integrated Monitoring (submitting analytical materials in internet, Programme the samples are taken at 5 materials for mass media, etc.); locations in 1 mile from the shoreline. - informational support of business entities; Monitoring results are provided to the BSC informational support of international annually. commitments if Russian Federation.

53 3.4. Data access

The audit has testified that appropriate the provincial directorates of the Ministry of conditions for population, public Health in the summer seasons periodically. establishments and interested parties to access Also, “Law on Right of Information environmental information, as well as Acquirement” gives the individuals to exercise information regarding the Black Sea their right of information acquirement. ecosystem conditions, were provided in each and every country of the Black Sea region. In Republic of Bulgaria, the web page of the Ministry of Environment Water has the In Turkey Republic, the website of the option “public dialogue”, which makes it Ministry of Environment and Forestry possible for everyone interested to pose (www.cevreorman.gov.tr) provides questions and submit proposals on information about all the related environmental issues, to participate in public environmental issues, including the water discussions on draft legislation, etc. quality data for the Black Sea Environmental Status Reports prepared by each provincial The web page also contains the national directorate of the Ministry (81 reports Catalogue of the sources of information annually) and the General Environmental regarding the environment. The Catalogue Status Report of Turkey prepared by the provides data about the type, storage location Ministry are also accessible on this website. and means of access to environmental information. The Ministry of Agriculture and Rural Affairs contributes to environmental database by Information centers were created in the providing data for many topics, especially for Executive Environmental Agency, the agricultural pollution. The data derived from Regional Inspectorate of Environment and implementation of different projects such as Waters, and the Basin Directorates. “Anatolian Watershed Rehabilitation Project” and “Twinning Project on Capacity Basin Directorate – Varna has been preparing Strengthening and Support of Implementation weekly, quarterly and annual bulletins of Nitrate Directive in Turkey” is published regarding the condition of water resources on the website of the Ministry. under its jurisdiction. Those bulletins can be seen on the web page and the annual bulletin In addition to the contributions of the related is printed in a separate booklet. Many Ministries, Turkish Statistical Institute also initiatives were organized in order to enhance publish data of various environmental environmental awareness among young indicators for the Black Sea region on its people and involve the public in problems website annually. such as preservation and improvement of water quality. Among the initiatives there The Ministry of Environment and Forestry has were organized: round tables, open doors been developing a land monitoring system days, public inquiries on environmental called “Coordination of Information on the issues, lectures, exhibitions, best photo Environment (CORINE)” since 1998. This contests regarding the World Water Day system is composed of six topics “Land Use, (22nd March), World Environment Day (5th Spatial Planning, Biological Diversity, Water, June), International Black Sea Day (31st Soil and Forest” of whose data can be accessed October). on the website http://aris.cob.gov.tr. A comprehensive database about national biological diversity (www.nuhungemisi.gov.tr) has also been active since 2007. As an additional point, the results of bathing water quality analysis are published on the websites of

54 In Romania public information and With regard to ICZM database, it is posted on consultation process is an EU member state the websites of Ministry of Environment and obligation, according to Article 14 of the Forests (www.mmediu.ro) and NIMRD. Water Framework Directive, transposed into national legislation. Also, on the website of the Ministry of Environment and Forests, respectively the The main annual environmental Water Management Section, there is the documentation regarding the Black Sea Ocean Forecast Subsection, where the public marine environment is the „Report on the is informed about the dynamics of physico- state of marine and coastal environment” chemical parameters of the Black Sea (chapter of the National “Report on the state ecological system. of environmental factors in Romania”, prepared by and posted on the National In terms of pollution from ships, the Environmental Protection Agency website: Operative Command for Marine Antipollution http://www.anpm.ro), prepared by the (CODM), consisting of representatives of the National Institute for Marine Research and following institutions: MEF, MTI, MAI Development “Grigore Antipa” Constanţa (Ministry of Administration and Interior), (NIMRD). The document is made available to MND (Ministry of National Defense), central and local authorities and is posted on Constanţa County Council, has the the NIMRD website: www.rmri.ro. responsibility to inform the population about the present state in case of pollution event, One of the management goals of the causes and actions taken or to be taken and to Romanian National Plan for Integrated prepare the report for the media, in order to Coastal Zone Management, as stipulated in inform the public. the Bucharest Convention, is providing free public access along the coastline. In terms of bathing water quality, at the level of Constanţa County Public Health For the implementation of other important Department, the information is made management objectives stipulated in the available to the public by posting the Romanian National Plan for Integrated monitoring results on beach screens, on the Coastal Zone Management, namely on: institution website (www.dspct.ro) and ‐ ecological information and education through the media (conferences and press ‐ public participation in decision-making releases, radio - TV). ‐ ensuring information flow on the coastal environment, It also should be mentioned that Romania signed the Aarchus Convention, which was the following institutions are responsible: ratified by Law no. 86/2000 – Convention on Ministry of Environment and Forests (MEF): Access to Information, Public Participation in - National Institute for Marine Research and Decision Making and Access to Justice in Development “Grigore Antipa” Constanţa, Environmental Matters, with modifications - Constanţa Environmental Protection and amendments. Agency, - National Administration “Apele Române” In Ukraine the provision of free access - River Basin Administration - Dobrogea to the environmental information that is not a Littoral, state secret and is stated under lists, registers, Ministry of Education, Research, Youth and archives and other sources is granted by the Sports (MECTS), Law of Ukraine “On Environmental Ministry of Transport and Infrastructure Protection” dated June 25, 1991, no. 1264- (MTI), XII. Non-Governmental Organizations.

55 According to this standard and legal act the (http://www.mns.gov.ua), and the National ecological informational provision is carried Report on the Anthropogenic and Natural out by the state and local authorities within Security of Ukraine is published yearly. their privileges by: - preparing the National Report on In Russian Federation the right to Environmental Conditions in Ukraine for obtain reliable environmental information is consideration in of Ukraine ensured by the Federal Law “On (Parliament) by the specially privileged Environmental Protection” (Article 3), dated central executive authority dealing with the January 10, 2002, no. 7-ФЗ. ecology and natural resources issues annually, and after its consideration, publishing it as a On the web pages of federal executive separate edition and placing it on the web; authorities (including the Ministry of nature - annually informing the corresponding resources and ecology of Russian Federation soviets and population of the environmental (www.mnr.gov.ru), Federal state of corresponding territories by the Soviet Hydrometeorology and Environmental of Ministers of the Autonomous Republic of Monitoring Service (www.meteort.ru), Crimea, regional public administrations and Federal Water Resources Agency by Kyiv and Sevastopol municipal public (www.voda.mnr.gov.ru) , etc.) the administrations; information regarding the implementation - regularly informing the population via process of federal and target programs in the mass media of the environment conditions, sphere of ecological development of Russian their evolution, sources of pollution, waste Federation, activities on environmental location and other changes of the protection, announcements and scientific environmental conditions, as well as the type environmental reports is published. of ecological factors that have influence on human health. The results of water environment condition and pollution monitoring of the Russian part The main institution, responsible for of the Black Sea and the Sea of Azov basin, providing ecological information is the as well as monthly and final space monitoring Ministry for Ecology and Natural Resources bulletins of this area, and also decade of Ukraine. overviews and specialized space monitoring maps are published on the web page of The web-page of this state authority government establishment “Scientific center (http://www.menr.gov.ua) is where the of space hydrometeorology “Planet” ecological news summary is published and (http://planet.rssi.ru). the information regarding state task programs in the area of environmental protection, Information regarding the results of scientific ecological passports of regions, state researches in the Black Sea, conducted within environmental monitoring, state federal and target programs, including target environmental policy orientation, the biggest scientific program “Scientific Researches and environment pollutants, etc. is placed. Developments in the sphere of Hydrometeorology and Environmental In addition, information on emergency Monitoring”, is put on the web page of federal situations occurrence in Ukraine is placed government establishment “State daily, monthly and quarterly on the web-page of oceanographic institute named after N.N. the Ministry of Emergencies of Ukraine Zbruyev” (www.oceanography.ru).

56 Section IV. Improving International and Regional Collaboration in the Black Sea basin

4.1. Importance of International and Regional Collaboration for the Black Sea environmental protection

As the most isolated sea in the world, the and biological diversity. As it was so long ago Black Sea is so vulnerable to pressures from emphasized in the Bucharest Convention, the human activity such that if it is not properly Contracting Parties to the Convention should managed, the effect of pollutants from lots of commit themselves to take individually or sources on its environment could be jointly all necessary measures consistent with devastating. A comprehensive and realistic international law and in accordance with the risk assessment of the Black Sea pollution is provisions of this Convention to prevent, necessary. Due to its large catchment area reduce and control pollution, thereof in order including not only the pollution from coastal to protect and preserve the Black Sea marine countries but also from many European environment (Article 5, paragraph 3). countries, the regional collaboration for the Black Sea along with the international There are also multilateral and bilateral initiatives is unequivocally very important. In projects and scientific researches conducted general, there is a need for more co-operation, within the scope of the Black Sea exchange of information on research and Environment Programme by both the Black sharing of good practice. Sea countries and other involved countries. The Black Sea Commission, established Bucharest Convention with its Protocols and through the Bucharest Convention, has the Black Sea Strategic Action Plans impose key role in the assessment of the many tasks and responsibilities to the implementation of those tasks and Contracting Parties on different issues such as responsibilities stipulated in the relevant legal land based pollution sources, pollution documents and the environmental projects monitoring, environmental safety of shipping and researches mentioned above.

Image 23. The Premises of the Permanent Secretariat Source: www.blacksea‐commission.org

57 4.2. Enhancing the Efficiency of the Black Sea Commission and Its Activities

BSC, assisted in its activities by a Permanent Advisory Groups located in each Contracting Secretariat, is composed of Advisory Groups Party and national focal points, as it is (AG), Regional Activity Centres of those presented on the Figure 13.

Figure 13. Institutional Structure of the BSC

The Commission for the Protection of the Black Sea Against Pollution

Permanent Secretariat

Advisory Groups AC ESAS AGPMA AG LBS AGICZM AGCBD AG FOMLR AG IDE Environmental Pollution Control Development Conservation of Environmental Information and Safety Aspects of Monitoring and ofPoUution from ofthe Common Biological Aspects of Data Exchange Shipping (AG Assessment Land Based Méthodologies Diversity Fisheries and ESAS) Sources for Integrated Other Marine Coastal Zone Living Resources Management AC ESAS Management Regional Activity Centers Environmental Pollution Control of Development of Conservation of Environmental Information and Safely Aspects of Monitoring and Pollution from Common Biological Aspects of Data Exchange Shipping Assessment Land Based Methodologies Diversity Fisheries and (AC IDE), (AC ESAS), (AC PMA), Sources for Integrated (AC CBD). Other Marine Permanent Varna. Bulgaria Odessa, Ukraine (AC LBS). Coastal Zone Batumi, Georgia Living Resources Secretariat, Istanbul, Turkey Management Management Istanbul, Turkey (AG ICZM), (AG FOMLR), Krasnodar, Constanța, Russian Romania Federation

National Focal Points

Bg, Ge, Ro, Ru, Tr, Ua Ua, Bg, Ge, Ro, Ru, Tr Tr, Bg, Ge, Ro, Ru, Ua Ru, Bg, Ge, Ro, Tr, Ua Ge, Bg, Ro, Ru, Tr, Ua Ro, Bg, Ge, Ru, Tr, Ua Bg, Ge, Ro, Ru, Tr, Ua

Advisory Groups of the BSC are the main issues of each Advisory Group and BSC sources of expertise, information and support following the receipt of the national reports in the implementation of the Bucharest prepares the regional reports. These regional Convention and Strategic Action Plan. The reports are meant to facilitate the cooperation, data derived from the activities of the exchange of information and best practice, Advisory Groups, as well as all the other and common strategies among the countries relevant information are the basis of the Black in order to prevent, reduce and control the Sea Information System (BSIS). pollution of the Black Sea marine environment. However, as the regional reports BSIS data are comprised from: reveal, the data and information provided to - data obtained in framework of the Black the Permanent Secretariat is either not Sea Integrated Monitoring and Assessment sufficient or not provided at all for Programme (BSIMAP), comparative analysis. Such kind of gaps and - data provided in national reports to BSC weaknesses in data availability and in data organized according to the thematic division reporting lead to insufficient time-series data, of the Advisory Groups and necessary inclusively for trend analysis and - data obtained in framework of supportive represent the main reason which negatively activities/ projects. affects the functionality of BSIS. Contracting Parties prepare annual national reports via their national focal points on the

58 One of the relevant reports of the Advisory follow different approaches in the Groups is on the issue of pollution monitoring environmental status assessment. This leads and assessment. Pollution monitoring and to the lack of harmonization and assessment data has been loaded into BSIS standardization of the monitoring programs since 2001. However, due to insufficient among the countries, consequently to the lack financial support of monitoring, there are gaps of a common database. The reasons and the in the data flow and in the BSIS database. results of deficiencies in BSIS are exhibited in There are also differences in sampling and the Figure 14 below: sample analysis techniques and countries

Figure 14. Reasons and results of deficiencies in BSIS

- Insufficient financial support - Gaps in countries’ monitoring - Lack of harmonization and programs

standardization of the monitoring - Gaps in data flow and in the BSIS programs database - Lack of a common database

The lack of a reliable and comprehensive - The cooperation of the countries via the common database not only hinders to BSC should be enhanced by establishing determine the main environmental problems, appropriate rules, general standards and best their effects/impact and solutions but also practice and procedures for the prevention, renders the data production and reporting reduction and control of pollution of the activities less effective in achieving the Black Sea marine environment. anticipated targets. These reports with their - Harmonization of national monitoring anticipated valuable contents are deemed programs in order to achieve the Bucharest important to achieve the aims of the Convention’s requirements and Bucharest Convention. In consequence, the standardization of sampling and sample following actions should be considered as the analysis techniques should be achieved. major steps for ensuring the sustainability and - Data quality assurance and quality control efficiency of the national monitoring procedures should be developed by de AG programs: IDE.

Image 24. Satellite picture of the Black Sea Source: http://upload.wikimedia.org

59 4.3. The Need for the International and Regional Initiatives Development for Saving the Black Sea Environment

Good environmental protection depends on assistance for researches, publications, thorough coordination of preventive, trainings and communication activities about contingency and combating measures, and the Black Sea, a stronger cooperation between requires fast and effective action of the the BSC and the relevant countries is a must. responsible national authorities as well as international cooperation. As the main basis BSC should be more effective in the of the international and regional collaboration preparation and assessment of the database, in order to maintain the protection and reports, relevant documents and guidelines as sustainable development of the Black Sea well as in the contribution to current projects environment, the institutional, technical and and undertaking new initiatives. Advisory financial capacity of the BSC should be Group on Information and Data Exchange improved. (AG IDE) has not really started to fulfil its tasks up to now. The active involvement of Allocation of adequate experts, with expertise such an AG within the body of BSC will in different fields and financial resources for definitely add much value to data and the Permanent Secretariat are the prior issues information exchange. Also data access for all for the achievement of the environmental the involved parties – public or private, targets specific to the Black Sea. This international organizations, nongovernmental capacity development and achievement of the organizations, academicians and public could environmental targets is certainly under the be facilitated. The results of every responsibility of not only the Black Sea implemented action could be made more countries, but also of other related actors and efficient and applicable through the support the international community. and contributions of these relevant actors for the strategies, policies and decisions on the Especially the tools to enhance the Black Sea. collaboration with the European Union in the efforts to protect the marine environment against the pollution should be improved. Within the scope of the BSC activities, efficient strategies are needed to be emphasized in order to access the funds of the UN and other international donors.

There are finalized or ongoing projects carried out among some of the Black Sea countries, but it is a fact that the number and scope of the projects that are undertaken by all the coastal countries together remain insufficient. In order to ensure comprehensive and efficient solutions for the Black Sea pollution problems, there should be initiated more Image 25. Dolphin in the Black Sea collaborative actions among all the Source: UNDP Contracting Parties providing common efforts and strategies. In carrying out and obtaining

60