Regulation of Waste Water Discharges. Differentiation of the Rates Charged for Water Usage

5. REGULATION OF WASTE WATER DISCHARGES. DIFFERENTIATION  OF THE RATES CHARGED FOR WATER USAGE

The analysis of the current system regulating the wastewater discharges into water sources in Belarus reveals that in many cases the allowable concentrations of certain ingredients (subject to degree of water pollution upstream of the point of discharge) either significantly exceed MAC or cannot be calculated because of the lack of assimilating capacity of the river. Thus, if a natural concentration is lower than maximum allowable, the norms of wastewater discharge into water bodies of certain categories and sufficient assimilating capacity may several times exceed the established MAC for water bodies used by fish industry. On the other hand, cases are much more frequent when there is no diluting capacity of a water course and standards of wastewater discharges have to be established very high in terms of water quality criteria for specific water uses. These two opposite outcomes frequently apply to one discharge and are different for specific types pollutants.

Thus, in many cases estimates based on the existing standard setting system do not yield the results, which may be adopted as allowable pollutant discharges. 

It is necessary to adopt a theoretically grounded approach to environmental assessment of a region and a river basin, to the assessment of the actual efficiency of treatment facilities and to the estimation of total pollutants coming from all the sources. In practice this approach can be applied only on “the polluter pays” basis.

At present the total of environmental tax  is determined chiefly by the volume of a discharge and the tax rate, which depends on the category of wastewater and its ability to meet the established quality criteria. In practice, the environmental tax rate is fixed on the bases of the data provided by the laboratories of environmental control, which take one-time sampling at the point of discharge and analyze the wastewater.

It is more objective, however, to charge payment based not only on a discharge volume but chiefly on the weight of pollutants containing in the discharge. To calculate the latter, a well known method of calculating the pollutant weight depending on its hazard category in “conventional tons” can be applied.

Another criterion of regulation of wastewater discharges is the feasible at a present level of technological development operation capacity of treatment plants. In this case it is necessary to establish the specific standards for the treatment facilities providing a complete biological treatment and standards for specific cases of deep treatment (after treatment). This standards must be consistent with the factual state of wastewater treatment. It is possible to draw an analogy with the international practice of standardization, where the facilities for removal of biological elements, nitrogen and phosphorus are singled out into a separate group.

The total payments for the use of water resources in the Republic of Belarus account for 0.1% of GDP. Thus, the rate of payment charged for water use is relatively low and is designated to perform mostly fiscal functions. Nevertheless, a mere increase of environmental tax rates on water use is not expedient. The increase of this specific tax without the appropriate revision and adjustment of the whole taxation system will lead to the increase of the prime costs of production. Sharp increase in the environmental tax rates (with consideration of cross subsidies) may worsen the state of the national producers due to the increased price competition.

The system of environmental taxation must be improved by means of differentiation of the rates depending on the conditions of water use.

The environmental tax must promote the efficient use of water resources, reduction of pollutant discharges, and the use of the so-called ‘secondary’ water resources – treated storm water, domestic and industrial wastewater.

The rates of environmental tax on collection of water from natural sources mast be fixed depending on the quality of the collected water. The accessibility of the resource and environmental restrictions of the amounts of collection also must be considered.

The current system of payments for the discharge of pollutants containing in wastewater into natural water bodies is not working efficiently because the tax rates are fixed depending on the category of wastewater (untreated, insufficiently treated, treated up to the standards) and do not depend on the amount of pollutants containing in it and their toxicological hazards. Moreover, the tax rates do not encourage water users to take measures to reduce the pollutant concentration in wastewater. 

Therefore, tax calculated must be based on the following principles:

-  Rates charged for pollution of the environment must encourage water users to take environmental measures, to reduce anthropogenic load on natural water bodies, and to use water resources efficiently;

-  Rates charged for pollutant discharges must be calculated as the total of payments for each specific ingredient or a group of similar ingredients containing in a discharge as specified in the established list. The number of criteria must be limited.

-  Rates must be fixed with regard of local/regional specifics and basin principle of territorial division.

-  Rate calculation procedures must be absolutely simple, logical, well grounded and posing no difficulties for the specialist of manufacturing enterprises and environmental and fiscal institutions.

As an option, it is possible to use the method of calculation based on the assessment of pollutant load with regard of the natural water quality parameters. In certain cases, instead of the natural parameters it is appropriate to use the target quality criteria, which must be achieved as a result of implementation of the program of restoration and rehabilitation of hydro-ecological conditions of water bodies.

The best way to improve the system of licensing of water collection and wastewater disposal is to introduce a basin water management system. The procedure of licensing of ground water collection must include the obtaining of the approval from geological institutions. Licenses for surface water collection and wastewater disposal may be issued by basin agencies reporting to basin committees.

Such basin management bodies may be established in the basins of the major rivers (the Neman, the Bug, the Western Dvina, the Dnipro, the Pripiat). They must develop the water management policy.

Since the existing administrative division of Belarus does not coincide with its geographical division on a basin principle, a mere basin approach may create certain management problems. That is why the most acceptable scenario of the reform of water management system is the combination of the basin approach with the existing administrative division.

In this case, the Environmental Ministry will coordinate the activities of its regional departments and the envisaged basin agencies and ensure their cooperation. At the same time the authority of the basin agencies and the regional departments of the Environmental Ministry in the following fields must be clearly delimited: 

-  control and supervision of the activities of water users, monitoring of water quality;

-  establishing of quotas and issuing of licenses for water use;

-  development of methods of calculation of environmental tax on water use with consideration of basin specifics;

-  establishment of the target criteria of water quality of natural water bodies and development of the related elements of environmental taxation policy in terms of fixing of the environmental tax rates;

-  management of the costs received as environmental tax on water use.

Basin principle of water resources management shall be introduced stage-wise (in order to work out ways of interaction of the basin agencies, the existing departments of the Environmental Ministry and other governmental bodies, manufacturing enterprises and organizations).

Basin committees shall take up the development of general conception of imposing quotas on water collection aiming to minimize the adverse impacts [of water collection] on hydrological regimes of water bodies and general conception of imposing quotas on wastewater discharges aiming to meet the criteria of water quality of natural sources. In addition, to control the wastewater discharges from the municipal sewage systems, basin agencies shall oversee the systems of storm water collection.

Payment rates fixed with consideration of the factor of geographical specifics of catch water bodies, recommended by the basin management agencies, shall become an effective instrument ensuring that the target water quality criteria are met.

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