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Chapter 7 - Recommendations

Introduction

The Kosovo conflict placed an additional burden on the already over-stretched resources of FYR of Macedonia. However, with the possible exception of Rasce Spring, where international research and monitoring efforts continue, the direct environmental impacts of the influx of some 261,000 refugees - the most tangible manifestation of the crisis in FYR of Macedonia - were found to be minimal.

In contrast, the wider political and economic destabilization of the Balkans region, have made environmental degradation in FYR of Macedonia more difficult to tackle, with corresponding implications for human health and the natural functioning of ecosystems. While the economic context of the last decade has led to decreased industrial output and some consequential reductions in pollution, there has also been a chronic lack of investment in environmental protection, so that much of the neglect of the post World War 11 era has not been remedied.

With regard to UNEP's 'hot spot' conclusions, two key areas of improvement emerged:

• The implementation of environmentally acceptable industrial processes, including measures for adequately controlling the use of chemicals; and
• Adequate handling, storage, treatment and disposal of waste, whether solid , or liquid, hazardous or non-hazardous, municipal or industrial.

It is apparent that FYR of Macedonia is seeking to make progress in the field of environmental protection and that some key steps have been taken in recent years with the ad Option of new environmental legislation and the creation of new institutional structures. However, many challenges remain, particularly in terms of investment, implementation and enforcement. The international community can provide crucial technical and financial assistance for FYR of Macedonia's priority environmental initiatives. Demonstration of concerted action and commitment to the provision of resources at the national level will be a major stimulus to external donors. The following series of recommendations is based on the findings detailed in previous chapters, though not all can be directly cross -referenced to the text.

Industrial 'hot spots'

1. Ferro-alloy plant at Jegunovce ('HEK Jugochrom')

a) To prevent further contamination, the chromium processing, facilities should be cleaned immediately, and the chromium waste should be stored and disposed of pursuant to appropriate waste handling methods.

b) The chromium remediation program requires urgent revision and acceleration. Additional mapping of the chromium plume in the groundwater should be considered. Additional investigation wells may also be necessary. Chromium should be removed and properly disposed of, not simply converted from Cr(VI) to Cr (III). The program should encompass the area between the factory and the Vardar River and not be limited to implementation of a hydrological barrier. The potential impact of groundwater pollution on Rasce Spring should be thoroughly investigated.

c) Existing proposals to reduce dust emissions from the three largest furnaces should be implemented. The six smaller furnaces require similar attention.

2. Organic chemicals plant, Skopje (OHIS A.D.)

a) A comprehensive strategy is needed to halt any contamination of soil and groundwater by the stored 10,000 tons of technical mixture of HCH isomers. While a long-term solution is needed, interim measures should be implemented at once. These include:

• investigating the precise storage method used;
• developing an overview of contamination inside and outside of the storage basins;
• Covering the storage area with a durable material to prevent leaching to groundwater and emissions to the atmosphere; and
• establishing monitoring wells screened at different levels in the aquifer around the storage area.

b) Longer-term measures should include a thorough investigation of the extent and nature of existing contamination; control and reduction of contamination that may pose a threat to human health; preventing contaminated groundwater from reaching the Vardar River; and remediation of contaminated soil.

c) As part of an overall strategy for the safe treatment and disposal of all hazardous waste generated by the plant, the wastewater treatment facility should be renovated and upgraded to receive and treat all effluent. Untreated wastewater must not continue to enter the Vardar River.

d) Steps are also required for the reduction of sulfur dioxide emissions.

e) The landfill and other waste dumpsites located inside the complex should be closed and the non-hazardous waste taken to Drisla landfill. Hazardous waste should be collected separately and stored for proper treatment.

3. Lead and zinc smelter, Veles ('MHK Zletovo')

a) If commitments for the financing of urgently needed filters and other clean technologies cannot be obtained within the next year, then management, together with appropriate Government officials, should review the costs and benefits of the plant's continued operation, taking into account the costs to public health and other relevant factors.

b) In the short term, existing air monitoring stations should be moved to sites closer to the plant that will indicate more quickly when elevated pollution levels are increasing health risks. In the longer term, additional stations that provide continuous data should be installed to provide citizens and relevant authorities, including regional public health and environmental officials, with early warning of acute health risks.

c) Urgent measures should be taken to reduce emissions of sulfur dioxide and dust containing heavy metals.

d) The proposed reconstruction of the wastewater treatment plant should be accelerated. The volume of process water used should be reduced through recirculation in a closed system. Untreated wastewater must not continue to enter the Vardar River.

e) A soil and groundwater monitoring program is required and should encompass the vicinity of the plant itself, the adjacent flood plain, and areas immediately downstream.

4. Zinc and lead mine, Probistip ('Rudnici Zletovo')

a) High priority should be given to constructing a wastewater treatment plant for the concentration plant.

b) There is an urgent need for investigation wells downstream of the hydrotailings sedimentation basins.

c) An investigation program should be established for private water wells downstream from the discharge points of the Koritnico and Kiselia Rivers into the Zletovska River. The Kiselia River should be diverted from its channel under the old hydro-tailing area to a position less vulnerable to the influence of leached pollutants.

d) Measures should be implemented to reduce dust levels from ore crushing.

5. Thermal power plant, Bitola ('REK Bitola')

a) Several steps are required for tackling the problem of contamination from the dumpsite:

• divide the area into compartments;
• separate the compartments, using layers of fly ash and slag covered with coarse material to prevent ash and slag from spreading to the surrounding area;
• use only one compartment at a time; vegetate inactive compartments to increase rainfall evaporation and reduce leaching of contaminants into the groundwater; and
• establish a drainage system in the bottom of the dumpsite to handle leachate and percolate.

b) Technical solutions should be implemented to reduce fly-ash dust and sulfur dioxide emissions from the plant.

c) Soil and groundwater at the power plant site and in adjacent areas is likely to be contaminated, and polluted groundwater may be entering the river. This requires establishment of an investigation program that includes the wastewater canal, river water and private wells downstream of the power plant.

d) The flow of untreated wastewater from the plant should be halted by replacing the neutralization basins with proper wastewater treatment facilities and by reconstructing the oil separator to match wastewater volumes.

e) The feasibility of using excess heat to supply the city of Bitola should be investigated.

Other industrial sites visited

6. Landfill site, Drisla, near Skopje

a) Creating an environmentally safe, long-term operation of Drisla is a national priority. Failure to implement appropriate environmental safety measures, including those outlined below, could result in Drisla evolving into a 'hot spot .

b) Hazardous wastes should be collected separately, stored and exported for treatment until the on-site facilities for their proper treatment are constructed.

c) The landfill's monitoring program should be expanded to cover hazardous, water-soluble organic and inorganic components.

d) Improved management of medical waste is needed. Steps should be taken to ensure that medical waste producers use Drisla's medical waste incinerator.

e) Parts of the site not yet receiving waste should be remodeled to incorporate environmental safety features, notably a groundwater protection lining.

7. Fertilizer factory, Veles ('MHK Zletovo')

a) More efficient dust collectors and insulation should be installed to reduce dust emissions. Workers need training and incentives to implement resourceretention and pollution-prevention practices.

b) Reconstruction of the wastewater treatment plant should be accelerated to prevent untreated wastewater discharges from entering the Vardar River.

c) The volume of process water should be reduced by recirculation in a closed system.

d) To prevent gypsum sludge from eventually floating into the Vardar River, the dumpsite should be redesigned to include a dam and artificial lake, similar to the hydro-tailings facilities used by the mining industry. Water from the artificial lake could be recycled as process water.

8. Copper mine, Radovis ('Buchim S.C.')

a) Construction of a wastewater treatment that includes removal of heavy metals should be accelerated.

b) In view of the high risk of groundwater contamination, the plant's monitoring program should be expanded to cover heavy metals such as lead, cadmium and chromium.

c) The hydro-tailing dam poses a high risk of infiltration by heavy-metal contaminated water into the upper groundwater aquifer downstream, especially during high water periods. Additional monitoring is require to establish the presence and extent of contamination.

d) Efforts to stabilize tailing dust at the hydro-tailing dam should ensure that emissions affecting the village downwind are eliminated.

9. Metal resurfacing factory, Kicevo ('Tane Caleski')

a) There is an urgent need for appropriate management of by-products and wastes.

b) The sedimentation and neutralization basin should be cleaned out, and an entirely new wastewater facility, including an oil separator, constructed.

c) There is an urgent need for wells and an investigation of soil and water conditions around the factory facilities and in relevant downstream areas.

d) To avoid further contamination of soil and groundwater by oil, the quantity of oil lost in the process should be reduced, and an oil storage facility (complete with bottom lining) constructed. Soil contaminated with oil should be collected and stored until proper treatment can be arranged.

10. Lojane Mine

a) The site should be immediately subject to a comprehensive environmental investigation. Recommendations for short-term risk reduction should e implemented without delay, and longer-term remediation and environmental protection measures fully supported.

Managing environmental consequences of the refugee crisis

11. At the outset of any humanitarian emergency, GIS-based inventory and other state-of-the-art data should be used to identify environmentally sensitive areas in the country. This would make possible the selection of sites with low environmental impacts and high redevelopment potential. It would also enable the use of technologies to minimize environmental impacts on sensitive areas selected. UNEP's Environmental Information. Services, UNHCR and other international organizations could assist in this process. In addition, the refugee camp site selection process should solicit input from competent national environmental agencies, as well as from non-governmental and inter-governmental organizations, and municipalities.

12. Life-cycle assessment should be used as the basic planning tool at the outset of a refugee crisis. This approach mandates that the future use of a refugee accommodation site be considered during the site-selection process and during each successive management phase. The goal of life-cycle assessment is to ensure the use of appropriate on-site technologies that will facilitate rehabilitation and development at minimum cost. Developing after-uses that have significant long-term benefit to local communities should be the main priority.

13. Although UNHCR made best efforts to facilitate the process of camp rehabilitation, a lack of donor funding and interest prevented the complete rehabilitation of some camps. The environmental benefits of future rehabilitation efforts need to be assessed against other national environmental priorities, such as the rehabilitation of industrial 'hot spots' or the establishment of a solid waste management infrastructure.

14. In order to minimize the production of solid waste, the procurement policies adopted by aid and donor agencies should require purchasing of food products and durable goods that are produced with minimal and/or fully biodegradable packaging. Preference should be given to goods that are produced in a sustainable way and which can be used by local communities following the repatriation of the refugees.

15. In order to minimize the potential for contamination, metal tanks should be used as the default method for wastewater management. Soak-away pits may be considered if local geophysical and hydrological conditions are certain to prevent contact with groundwater. An improved refugee wastewater collection and treatment system needs to be developed to ensure that the amount of waste collected from campsites corresponds to the amount of waste received by the selected treatment facilities. High financial penalties should be imposed to deter illegal dumping by contractors.

16. UNHCR has developed environmental guidelines and policies to minimize the environmental impacts of refugees. These documents, however, were not distributed in a timely or comprehensive manner to some relevant agencies and camp managers. Improved efforts should therefore be taken by UNHCR to distribute these materials at the outset of refugee operations.

17. In order to assess the site-specific environmental impacts of refugee camps, standardized photographs should be taken from permanently marked camera locations before, during and after refugee occupation. This technique, known as Photopoint Monitoring, would help to document site conditions throughout refugee operations and minimize the potential for false damage claims.

18. Site-specific recommendations concerning refugee management:

a) Blace Camp

A proposal exists to develop the site into additional border facilities and services. Decisions on this proposal should be made in cooperation with the landowners, and appropriate compensation should be provided for loss of land use. If additional border-crossing facilities are developed, care should be taken to minimize environmental impacts on the alluvial terrace and water quality of the Lepenca River.

b) Bojane Camp

In the short term, illegal dumping activities by local residents must be immediately stopped to prevent potential contamination to Rasce Spring. Signs should be erected to mark the boundary of the protected area, and fines should be enforced to deter illegal dumping. In the long term, the local municipality should develop a strategy for solid waste management, reduction and recycling, as well as environmental education and awareness programs for the community.

c) Cegrane Camp

The permaculture training center is being developed and managed by CARE International for 12 months, and then by a local NGO, the Permaculture and Peacebuilding Center (PPC), for the remainder of the project. Currently, the project is entering the fourth stage of implementation, known as the 'sustainability' phase. This phase will require donor support to help the center develop revenue- generating operations, which are to eventually become selfsustaining.

d) Neprosteno Camp

Rehabilitation has not been conducted due to a political dispute over the future use of the site. While the current development plan is for a cemetery for the neighboring municipality of Tetovo, local residents favor the development of a sports facility. A community-based process is needed for reaching agreement on the future use of the site.

e) Radusa Camp

UNHCR has recently provided resources to the land owners for rehabilitation. During the rehabilitation process, consideration must be given to its sensitive location in relation to groundwater, and the use of fertilizers or pesticides of any kind should be avoided.

f) Senokos Camp

Site rehabilitation was conducted by Mercy Corps International for UNHCR. This included stabilization of a creek that flowed through the campsite and rehabilitation of the community football field. The municipality is in charge of further development on behalf of the community.

g) Stenkovec I Camp

Appropriate compensation or assistance should be provided for the re-establishment of the site's original function as an airfield.

h) Pretor Collective Centers

Given the environmental importance of the Lake Prespa region, donor support is required to develop a strategy for the management of wastewaters and solid wastes. Existing wastewater treatment facilities, which are currently nonfunctional, should be repaired or upgraded as required by the strategy.

i) Radusa Collective Center

At the time of the mission, this collective center housed refugees and was being used as a long-term facility. While there are no significant environmental issues associated with this site, the sewage treatment plant servicing the local community is currently non-operational due to an inadequate electrical supply. As a result, the plant is idle and sewage is being disc harged into local rivers. Donor support is therefore required to help investigate local sources of power generation including renewable options.

j) Suto Orizari Collective Center

This site has been recently developed for the current caseload of Roma refugees. The center is located on land that was formerly used as an illegal dumpsite. As a result, it lacks vegetation cover and suffers from serious erosion and wind-blown dust. The establishment of a permaculture project on site would contribute to its greening and enhance the quality of life for the refugees. This could also improve food self-sufficiency for camp residents.

Institutional capacities for environmental management

General recommendations

19. The process of updating the NEAP should be broadly supported. The process should once again include consultation with all interested governmental and nongovernmental institutions. The revised NEAP should include cost estimates for its elements, an identification of the planned sources of finance for each project, a timetable for project implementation, and clear, measurable targets. The development of a national Agenda 21 strategy should be coordinated with any updating of the NEAP to ensure consistency and coherence, as well as effective coordination of policy and legislation.

20. It will be important for the Government to articulate a strong strategic vision regarding environmental management issues. Among other things, this will require further streamlining of environmental legislation and responsibilities. Environmental strategies and priorities will need to be communicated to donors to increase their interest in environmental development assistance.

21. A national environmental monitoring program is needed in order to be able to provide accurate data to political decision-makers, environmental inspectorates, health authorities, and the public. The number of stations and parameters monitored should increase, as much as resources permit, until a comprehensive program is established. The Government and municipalities should participate in international monitoring networks.

22. Enforcement of environmental regulations must be greatly strengthened. It is especially important that a permit system be developed and implemented, and that draft legislation to require EIAs be swiftly adopted. In addition, better coordination among the relevant inspectorates is crucial. Consideration should also be given to training judges and law students in environmental law and policy.

Specific environmental management recommendations

23. Air

a) The anticipated revision of air quality legislation should provide for a comprehensive and effective permitting and inspection regime and ensure coordination of national and local monitoring and management programs.

b) A nationwide air quality monitoring network should be created to ensure sufficient knowledge of ambient air quality, especially in urban areas. It is especially important that additional air quality parameters, particularly heavy metals and persistent organic pollutants (P0Ps), be monitored strategically in areas where there are high risks that such pollutants exist. Ozone should be measured to enable assessment of risks to human health and crops.

c) Increased cooperation with EMEP and other international bodies should be an important element of FYR of Macedonia's strategy for improving air quality.

24. Water

a) State responsibilities for water policy should be consolidated to the extent practicable or, at a minimum, better coordinated among the relevant authorities.

b) Implementation of a national strategy for wastewater is one of the most urgent challenges facing the country. Relevant recommendations from the abovecited report, Wastewater, Water Quality and Solid Waste Management in the FYR of Macedonia, should be acted on as soon as possible. Wastewater management in the Tetovo-Gostivar area should be made a priority in order to reduce potential threats to Skopje's water supply.

c) A system of discharge permits and emissions standards should be developed, based on local hydrological and physical/chemical conditions and consistent with relevant EU directives.

d) An integrated river basin management plan should be developed and imple mented for the Vardar River. The approach should be consistent with the EU Water Framework Directive and take full account of transboundary considerations.

25. Solid waste

a) FYR of Macedonia urgently needs to implement a comprehensive, countrywide strategy and strengthen legislation for the management of solid waste. This should be based on further development of the 1999 national strategy for waste management, prepared with support from Phare. Special attention should be given to the handling of municipal waste and hazardous industrial waste.

b) Additional municipal landfills, designed, supervised and constructed in conformity with EU standards, should be established to meet the country's long-term needs. This would enable closure of many small and inadequately supervised landfills.

c) The practice of burning waste in landfills should be banned as soon as possible. Instead, landfill operators should continuously compact and cover waste with inert material.

26. Chemicals

a) Policy, legislation and management measures are urgently required for better control of chemicals such as PCBs, ozone-depleting substances, and agricultural pesticides and biocides. Clear responsibility for this issue should be assigned within the Government administration.

27. Biodiversity and landscape management issues

a) Effective nature and landscape conservation requires improved communication and cooperation between the MEPP and the Ministry of Agriculture, Forestry and Water Resource Management.

b) There is an urgent need for the development, implementation and adequate funding of management plans for all existing protected areas.

c) An expanded, fully-coherent network of protected areas should be established, taking into account the criteria of the 'Emerald Network' of the Council of Europe and the priorities of the Pan-European Biological and Landscape Diversity Strategy.

d) Special attention should be given to strengthening measures for the conservation and wise use of Lakes Ohrid, Prespa and Dojran.

e) Further development and implementation of the National Biodiversity Strategy should focus on integrating nature conservation as a key component of sustainable economic development, notably in the agriculture, forestry, tourism, water management and transport sectors.