Maastricht, The Netherlands, in 2003 - IMPEL

IMPEL at Work | Report 1 

Contents 

PAGE CONTENTS 

3 1. Introduction and acknowledgements 

5 2. Programme of the conference 

7 3. Speeches Opening Session 

• Mr. Gerard Wolters (Chairman) 

• Mr. Henk Evers (Province of Limburg) 

• Mr. Pieter van Geel 

(Ministry of Housing, Spatial Planning and the Environment; The Netherlands) 

• Mrs. Ruth Frommer (European Commission) 

4. Developments since Villach 2000 

5. IMPEL at Work 

6. Forum discussion (Mr. Neil Emmott) 

7. Results of the working sessions 

• Session 1: New instruments and the improvement of the current instruments. 

(Mrs. Katerina Iakovidou) 

• Session 2: The role of inspections and different approaches. (Mr. Peter Schryvers) 

• Session 3: Identifying and spreading good practice – getting the best out of networks 

like IMPEL. (Mr. Frank Clinton) 

• Session 4: Capacity building – How can we manage our job ? (Mr. Costas 

Hadjipanayiotou) 

8. Overall results of the different sessions – New project ideas and suggestions for the 

promotion of IMPEL’s work (Mr. Terence Shears) 

9. Closing address by Mrs. Dr. Caroline Jackson (European Parliament) 

10. Final remarks (Mr. Gerard Wolters) 

11. Annexes 

1. Abstracts of all presentations 

2. Short overview of the organisation of inspections in the EU Member States, 

Norway and acceding and candidate countries 

3. Letter to Mrs. Margot Wallström (EU Commissioner) 

4. List of participants 

5. List of participants to the exhibition 

6. CD-ROM with all speeches and power point presentations.

2 6 – 8 October 2003 | IMPEL at Work 

Page with pictures.


Page with pictures.


Page with pictures


1Introduction and acknowledgements 

The 2nd. European Conference of the European Union Network for the Implementation and Enforcement 

of Environmental Law (IMPEL) was held in Maastricht (The Netherlands) from 6th. – 8th. October 

2003. In total 218 (out of 231 registered) participants from 31 countries and the European Commission 

attended the plenary meetings and parallel workshops that were held during these 3 days. The aim of 

the conference was to exchange information between the participants as well as sharing ideas and experiences 

to improve the quality of the daily work. Practitioners from both national and regional level in 

the fields of inspections, permitting and policy-making, thus representing the “three pillars” of IMPEL, 

took the opportunities that the conference offered them by discussing developments in their fields of 

work with colleagues and explored ideas for new IMPEL-projects. 

The core of the conference was formed by the parallel sessions around the themes: 

• New instruments and improvement of the current instruments 

• The role of inspections and different approaches 

• Identifying and spreading good practice – getting the best out of networks like IMPEL 

• Capacity building – How can we manage our job ? 

Various participants, representing 12 organisations, displayed the results of their work at the exhibition 

that took place at the same time. 

This conference marked the 10th. anniversary of IMPEL. This was not only recognized by the birthday 

cake that was offered to all participants, but also by the speakers in the plenary sessions who, from 

their differing perspectives, referred to the importance of the IMPEL network in the implementation of 

European environmental policies and legislation. Representatives from the European Commission and 

the European Parliament as from national and regional governments challenged and encouraged the 

IMPEL network to continue and extend its work and make the results more visible, both on the national- 

as well as on the European level. 

This conference was prepared with great enthusiasm by a preparatory committee, led by the projectleaders 

Annelie Kohl (Inspectorate of the Ministry of Housing, Spatial Planning and the Environment 

of The Netherlands) and Ed Eggink (Province of Limburg; The Netherlands). The other members of the 

preparatory committee were (in alphabetical order): Chiqui Barrecheguren (Spain); Annick Bonneville 

(France); Steen Fogde (Denmark); Erik Forberg (Norway); Camilla Frisch (Sweden); Vita Jokumsen 

(Denmark); Helmut Kruber (Germany); Karin Miklautsch (Austria); Lenka Nemková (Czech Republic); 

Krystyna Panek-Gondek (Poland); Gernot Schnabl (European Commission); Terence Shears (United 

Kingdom); Sabine Sommer (IMPEL-secretariat/European Commission); Ellen Topman (The Netherlands); 

Pieter-Jan van Zanten (The Netherlands); Svetlana Zhekova (Bulgaria) and Frederique van Zomeren (The 

Netherlands) 

Of course we are also very grateful for the work that has been done by the many speakers and the 

chairs and rapporteurs of the different sessions. 

Finally we like to thank the sponsors of this conference: the European Commission; the Ministry for 

Housing, Spatial Planning and the Environment of the Netherlands; the Association of Dutch Provinces 

(IPO); the Province of Limburg and the Ministry of Traffic and Waterworks.


In this report we have tried to present as much of the original speeches and presentations as possible, 

to make it useful not only for the participants of the conference but also for their colleagues who 

could not attend. For that purpose this report itself will serve as a source of information, as will the CD- 

ROM which is attached to the inside of the back-cover of this report. 

We express the hope that the conference and the content of this report may inspire you to give new 

impetus to the work of the IMPEL network. 

Annelie Kohl and Ed Eggink 

November 2003


2Programme of the Conference 

Sunday, 5th. October 2003 

17.00 hr. Registration for the conference followed by a reception in the NH Maastricht Hotel, Forum 

110 in Maastricht, next to the Maastricht Exhibition and Congress Centre (MECC) where the 

conference will take place. 

Monday, 6th. October 2003 Location: Auditorium 2 

09.00 hr. Opening session. 

Chair: Mr. Gerard Wolters (The Netherlands). 

• Mr. Henk Evers; Provincial Executive for Environment and Water policy of the Province of 

Limburg (The Netherlands) 

• Mr. Pieter van Geel; State Secretary for Environment of the Ministry for Housing, Spatial 

Planning and the Environment of The Netherlands 

• Mrs. Ruth Frommer; Director at DG Environment of the European Commission 

10.30 hr. Break 

11.00 hr. Developments since Villach 2000. 

Chair: Mr. Gerard Wolters (The Netherlands) 

11.00 hr. IMPEL from Villach to Maastricht; its developments and achievements; 

Mrs. Giuliana Gasparrini (Italy) 

11.20 hr. The new enlarged IMPEL; how can we support each other and what are the necessary conditions; 

Mrs. Anna Bobo Remijn (European Commission) 

11.40 hr. Recent developments in the Accession Countries; Mrs. Krystyna Panek-Gondek (Poland) 

12.00 hr. Discussion with and between the speakers. 

12.30 hr. Lunchbreak 

14.00 hr. IMPEL at Work 

Chair: Mr. Jim Gray (United Kingdom) 

14.00 hr. Minimum criteria for environmental inspections - what we can learn from the first round of 

reporting; Mr. Georges Kremlis (European Commission) 

14.20 hr. Minimum criteria for inspections - A Member State’s perspective from Austria; 

Mr. Günther Düssing (Austria) 

14.40 hr. IMPEL’s Review Initiative - Benchmarking and comparing inspection- and enforcement units 

across Europe; Mr. Martin Murray (United Kingdom) 


15.30 hr. The future of environmental inspections and enforcement – 

A necessity or a waste of energy? 

A forum discussion with key- actors from different backgrounds, looking forward to future 

developments in inspections, enforcement, self-regulation, voluntary instruments, the European 

and the national approach and other relevant items.


Chair: Mr. Georges Kremlis (European Commission) 

Rapporteur: Mr. Neil Emmott (United Kingdom) 

15.30 hr. Introduction to the theme; Mr. Jan Pronk (Former Minister for Housing, Spatial Planning and 

the Environment of The Netherlands) 

15.50 hr. Views from different perspectives. Short statements from: 

• Mr. Michel Bruder of UNICE (European Industry) 

• Mr. John Hontelez of the European Environment Bureau (Non Governmental Organisations) 

• Mrs. Marie-Claude Dupuis (France; representing the IMPEL network) 

Followed by discussion 

17.15 hr. End of the programme 

18.15 hr. Departure by bus to the “Gouvernement”. Buses leave in front of the hotel/MECC. 

18.30 hr. Reception and dinner hosted by the Governor of the Province of Limburg, Mr. B.J. baron van 

Voorst tot Voorst, in the “Gouvernement”, Limburglaan 10, Maastricht. 

This is the seat of the Provincial Government. Visit to the rooms where the Maastricht Treaty 

was signed. 

Tuesday, 7th October 2003 

On this day there will be 4 parallel-sessions/workshops. 

Each of these sessions/workshops will last the whole day. 

Session 1: New instruments and improvement of the current instruments. 

Location: Room “Brussels” (0.4) 

Chair: Mr. Jan Teekens (The Netherlands) 

Rapporteur: Mrs. Katerina Iakovidou (Greece) 

09.00 hr. Welcome and introduction; Mr. Jan Teekens (The Netherlands) 

The floor is yours. 

09.15 hr. Permitting and inspection as instruments to achieve environmental objectives; 

Mrs. Annelie Johansson and Mrs. Jessika Mähler (Sweden) 

09.45 hr. Working with EU-law; discussion and suggestions on how to improve EU-laws 

• Mrs. Valérie Drezet-Humez (European Commission) 

• Mrs. Anna Barbora Stykova (Slovak Republic) 

10.05 hr. Reflection and discussion, including experiences of the IMPEL Better Legislation project. 

Discussion leader: Neil Emmott (United Kingdom) 


11.15 hr. How to feed back experiences to policy, law and permitting. 

Introduction by the discussion leader Mr. Gustaaf Biezeveld (The Netherlands) 

Contributions by: 

• Mrs. Karin Uhlenbrock (Germany) 

• Mr. Marek Mroczkowski (Poland) 

• Mr. Christian Bathelier (France) 


New instruments and what do they mean for inspection? 

13.40 hr. Environmental management systems. 

• Environmental management systems and permitting in Germany; 

Mr. Bruno Reddehase (Germany)


• Environmental management systems and permitting in Ireland; Mrs. Valerie Doyle (Ireland) 

• Discussion 

14.25 hr. Flexible instruments like emission trading. 

• Mr. Chris Howes (United Kingdom) – Flexible instruments and the changing role of inspectors 

• Mrs. Ivona Grozeva (Bulgaria) – The use of flexible instruments in Bulgaria 

• Discussion 


15.40 hr. Voluntary agreements – The changing role of inspectors; Mr. Franz Grassmann (Germany) 

16.25 hr. Merging economy and environmental protection; Mr. Mikael Skou Andersen (Denmark) 

16.50 hr. Summary and conclusions. 

Relevant questions for the report to the plenary meeting on 8th. October are: 

• How to improve the role of permits and inspections in the regulatory cycle? 

• How to improve the extent to which community law meets the needs of 

permit-makers and inspectors? 

• Do the new instruments change the roles of permit-makers and inspectors? 

• Are the new (voluntary) instruments enforceable? 

• Suggestions for further work of IMPEL? 

17.30 hr. End of the programme 

18.30 hr. Departure by bus from the hotel/MECC to the dinner location. 

19.00 hr. IMPEL dinner in “Het Koetshuis”, Kasteelstraat 15, Rijckholt/Gronsveld. 

Session 2: The role of inspections and different approaches. 

Location: Room “Paris” (0.5) 

Chair: Mrs. Chiqui Barrecheguren (Spain) 

Rapporteur: Mr. Peter Schryvers (Belgium) 

09.00 hr. Welcome and introduction; Mrs. Chiqui Barrecheguren (Spain) 

09.15 hr. Different perspectives and approaches to inspections 

• Strategy, tactics and operational enforcement in Limburg; Mr. Evert Steijnebrugh 

(The Netherlands) 

• Different perspectives and approaches to inspections in Norway; Mr. Erik Forberg 

(Norway) 

• Application of minimum criteria for environmental inspections in Bulgaria; 

Mr. Nikolai Kenanov (Bulgaria) 

10.10 hr. Discussion 


11.15 hr. Different ways of prioritising inspections. 

• Compliance assessment plans; Mr. David Pugh (United Kingdom) 

• Mr. Pascal Barthe (France) 

• Environmental inspections in Herning Municipality; Mr. Gert Thorhauge Andersen 

(Denmark) 



13.45 hr. Brainstorming session in two groups. 

• Group 1: To what extent can self-monitoring replace inspections? 

Short introduction to the theme by Mr. Erkki Kantola (Finland) and Mr. Miguel 

Costoya (Spain). Facilitators: Mrs. Chiqui Barrecheguren (Spain) and Mr. Terence 

Shears (United Kingdom)


• Group 2: How do enforcement actions contribute to environmental improvement Short introduction 

to the theme by Mr. Aare Sirendi (Estonia) and Mr. Fernando Figueira 

(Portugal). Facilitators: Mr. Peter Schryvers (Belgium) and Mr. Erik Forberg 

(Norway) 


15.30 hr. Feedback from brainstorming sessions. 

15.50 hr. Indicators for measuring the efficiency and effectiveness of inspections – how to assess the 

results of inspections and the impact they have? 

• Effectiveness and efficiency of environmental inspections; Mr. Paul Bernaert (Belgium) 

• Assessment of indicators for efficiency of inspections at Czech Environmental Inspectorate; 

Mr. Pavel Sremer (Czech Republic) 

• Environmental inspection plans and a method to assess the results; Mr. Bert Dam (The 

Netherlands) 




• Are there general criteria for prioritising inspections? Who or what 

determines priorities? 

• Can indications be given for situations where self-regulation should be 

used instead of command-and-control approaches? 

• How can enforcement actions improve the quality of the environment? 


17.30 hr. End of the programme. 



Session 3: Identifying and spreading good practice – getting the best out of networks like IMPEL 

Location: Room “Rome” (0.8) 

Chair: Mr. Christof Sangenstedt (Germany) 

Rapporteur: Mr. Frank Clinton (Ireland) 

09.00 hr. Welcome and introduction; Mr. Christof Sangenstedt (Germany) 

09.15 hr. IMPEL products - A short overview; Mrs. Sabine Sommer (IMPEL secretariat/European 

Commission) 

09.30 hr. Spreading the message - examples and experiences 

• Project “The four instruments (EMAS; Seveso; IPPC; EIA)”/; Mrs. Alessandra Burali (Italy) 

• Obstacles to implementing IMPEL products in Lithuania; Mr. Vaclovas Berzinskas 

(Lithuania) 

10.00 hr. Four small discussion groups: “What do you expect from IMPEL?” 


11.30 hr. Reporting back from the discussion groups 

12.00 hr. Discussion and conclusion 


“Networking - Challenges and obstacles” 

13.30 hr. National networks. 

• A national network between inspectors in Denmark; Mr. Steen Fogde (Denmark) 

• Inspection and enforcement network in Slovenia; Mr. Ivan Stefelj (Slovenia) 

• IMPEL national network in Austria; Mr. Armin Heidler (Austria)


14.10 hr. Networking between networks 

• INECE; a network of networks; Mr. Durwood Zaelke (USA; INECE secretariat) 

• BERCEN network; Mihail Dimovski (Hungary; Regional Environmental Center for CEE; 

BERCEN Secretariat) 

• Solving the puzzle of good environmental governance in Eastern Europe, Caucasus and 

Central Asia; the contributions of networking; Mrs. Angela Bularga (NIS Co-ordinator) 

14.50 hr. Cross border co-operation 

• Transfrontier shipment of waste; Mr. Walter Pirstinger (Austria) 

• Co-operation between the Czech Republic and Slovakia; Mr. Daniel Geisbacher 

(Slovak Republic) 


16.00 hr. Forum discussion with all the speakers: “Can we still afford networking in face of resource 

constraints?” 

Discussion leader: Mrs. Helga Stülgies (Germany) 



• Are IMPEL-products a proper and effective tool for environmental 

administrative bodies? 

• Is networking an appropriate instrument for better practice and how can it be facilitated 

within your countries? 

• How can IMPEL improve its performance? 





Session 4: Capacity building – How can we manage our job? 

Location: Room “Athens” (0.9) 

Chair: Mrs. Kia Regner (Sweden) 

Rapporteur: Mr. Costas Hadjipanayiotou (Cyprus) 

09.00 hr. Welcome and introduction; Mrs. Kia Regner (Sweden) 

Quality or Quantity? 

09.15 hr. Capacity building in practice - The IMPEL Review Initiative; Mr. Martin Murray 

(United Kingdom) 

09.45 hr. Developing an outcomes approach in the Scottish Environmental Protection Agency; 

Mrs. Nerina Holden (Scotland) 


Training and qualification. 

10.30 hr. Training and qualifications for inspectors and permit-makers - Results of an IMPEL project; 

Mrs. Annick Bonneville (France) 

10.45 hr. Training and qualifications of inspectors in Germany; Mr. Hans-Werner Breuer (Germany) 

11.00 hr. Training and qualification of inspectors in Hungary; Mr. Pál Varga (Hungary) 


Skills for permit-makers and inspectors 

11.30 hr. Improving professionalism in enforcement; Permit preparation and enforcement should not 

be combined in one person; Mr. Wout Klein (The Netherlands) 

11.45 hr. The individual making permits and doing inspections should be the same;


Mrs. Charlotte B. Larsen (Denmark) 



The best ways to organise and manage our job? 

13.30 hr. Small working groups discussing: 

• Best practices in organising duties in an inspectorate 

• Do we need to document the knowledge, experience and skills? 

• How to share knowledge, skills and experience with colleagues in other 

countries? 

• How to make information necessary for inspectors and permit-makers 

available and accessible? 


15.30 hr. Reporting back from the working groups 

16.00 hr. Information Technology tools for inspectors; Mr. Markku Hietamäki (Finland) 

16.20 hr. How do we make our documentation?; Mr. Jean-Pierre Janssen (Belgium) 



• Do you have suggestions to improve the quality of staff and of the work? 

• How to improve co-operation between permit-makers and inspectors? 

• Are there suggestions making relevant informationmore readily accessible to permitmakers 

and inspectors? 





Wednesday, 8th. October 2003 Location: Auditorium 2 

Chair: Mr. Gerard Wolters (The Netherlands) 

Rapporteur: Mr. Steen Fogde (Denmark) 

09.00 hr. Reports from the parallel sessions/workshops on Tuesday 7th. October. 

• Session 1: New Instruments; Mrs. Katerina Iakovidou (Greece) 

• Session 2: The role of inspections; Mr. Peter Schryvers (Belgium) 

• Session 3: Identifying and spreading good practice; Mr. Frank Clinton (Ireland) 

• Session 4: Capacity building; Mr. Costas Hadjipanayiotou (Cyprus) 

10.00 hr. Discussion about the reports. 


Rounding-up…the future is ours !! 

11.00 hr. Summing-up new project ideas and suggestions for the promotion of IMPEL’s work; 

Mr. Terence Shears (United Kingdom) 

11.30 hr. IMPEL as an instrument to stimulate better inspections and enforcement in Europe; 

Mrs. Dr. Caroline F. Jackson (Chairman of the Environment Committee of the European 

Parliament). 

12.00 hr. Closing remarks; Mr. Gerard Wolters (The Netherlands) 

12.30 hr. Lunch


3Speeches Opening Session 

Opening speech by the Chairman of the Conference, Mr. Gerard Wolters 

Inspector-General for Housing, Spatial Planning and the Environment 

of The Netherlands 

Good morning ladies and gentlemen, esteemed colleagues, 

On behalf of the organising committee, it is my pleasure to welcome 

you here to Maastricht for the second IMPEL conference. This is truly 

a special and unique event. And, yes, I feel confident in saying so at 

this early stage. Why, you ask? 

Foto van Gerard 

Wolters invoegen 

To start, the interest to participate in the conference has been overwhelming. In the days to come, 

two hundred and twenty participants will exchange ideas with one another regarding nearly every 

aspect of our work in our capacity as inspectors, policymakers, politicians, managers, etc. 

Secondly, this conference is special because it is IMPEL’s tenth anniversary. Something of which I am 

proud. Not just because we have been around for ten years, but also because we have achieved so much 

in the last decade. This includes the fact that we have brought together not only representatives from 

EU Member States, but also individuals from EU accession countries and related organisations, such as 

the INECE. This morning, we will continue to exchange ideas about the developments within IMPEL and 

Europe. 

We hope to achieve this through a very diverse programme. I would like to congratulate the organising 

committee on succeeding to address the many aspects of our work and, in particular, finding so 

many individuals prepared to play an active role in the programme. 

During the past year, the organising committee met twice to lay down the conference’s programme. 

Together with project managers, civil servants of the province of Limburg and the Inspectorate of the 

Ministry of Housing, Spatial Planning and the Environment, the organising committee worked tirelessly 

to make this possible. This is another reason why this conference is so unique. The conference is organised 

by and intended for inspectors, while keeping an open eye on the world outside. 

The conference programme looks to the past and future. It stimulates learning from one another, 

exchanging stories from the field, brainstorming new approaches to our work and ways to work more 

effectively and reviewing the developments taking place around us, including those originating in the 

political arena. 

The programme offers the opportunity to reflect seriously on what we do, both in a formal context, 

such as during official meetings, and in an informal setting, such as when we meet eachotherher in the 

hall or over dinner. 

I won’t run through the entire programme since you are probably already aware of what has been 

planned. I can, however, summarise it as follows: three days of hard work (The conference’s title ‘IMPEL 

AT WORK’ might have tipped you off), but also with enough room for the social aspect!.


At this moment I will limit myself to identify a few aspects of the programme. 

First is the political context in which we work. I trust this issue will also be addressed by the speakers 

following me; Mr Evers, Provincial Executive for Environment of the province of Limburg, Mr Van Geel, 

State Secretary of the Ministry of Housing, Spatial Planning and the Environment, and Ms Ruth 

Frommer, Director of the Life Programme, Legal Implementation and Civil Protection Directorate of the 

Environment DG, who, at very short notice, was prepared to speak in place of Ms Catharine Day, EC 

Environment Director-General. 

The current economic situation has placed pressure on the subject of environment. I’m certain this 

phenomenon is not limited to the Netherlands. Budget cuts will impact us as well. This compels us to 

take a critical look at our approach to work. Identifying ways to achieve the best results with the financial 

resources on hand. In short, working ‘smart’ and ‘enfocing ‘smart’. We must achieve a certain level 

of efficiency in our work and spark discussion within the political arena. Where do our priorities lie? How 

do you ensure that political choices are well-founded and transparent? What can inspectorates do to 

help improve legislation? These improvements must focus specially on enforceability, feasibility and ability 

to prevent fraud and be implemented in such a way that the available resources can be used as efficiently 

and effectively as possible. 

Inspectors and enforcement staff, in other words you, represent a wealth of practical experience. We 

must benefit from that. 

As an inspector, you want to make the world a safer and more healthy place. In my opinion, safety 

involves much more than protecting the public from criminal activity. It also encompasses the environment, 

risks associated with the transport of hazardous substances and the risks faced by those who live 

near a chemicals plant. Our job is to raise the awareness of politicians and substantiate this knowledge 

with facts and our collective knowledge. 

If, at the end of this three-day conference, we have identified possible paths to pursue for an answer, 

then I will have to say that this conference was a success. 

Another aspect involves the professionalisation of our work. Several programme items will address 

this. If we want to contribute to preserving the quality of life of our respective societies, we must also 

look at ourselves. It is not only a question of whether we are doing the right things, but also whether 

we are doing them well. This has to do with standards, qualifications, training and specialist know-how, 

as well as organisational structures, networks and information exchange. Rounding off the list are attitude 

and behaviour. How do we act in our role as legislative enforcer? What skills are required? What is 

needed at the individual and organisational level? What role can and do we want to assume in the area 

of policy and implementation? Several initiatives are already underway in this regard, consequently, it is 

a good idea to exchange ideas and look for ways to improve what we are already doing. 

This brings me to the third aspect: co-operation. Both literally and figuratively, our work is boundless. 

Co-operative partnerships in all manner of fields are already running full steam, on both an ad hoc 

and a more structural basis. These involve not only the various inspectorates within a single country, but 

also the inspectorates of neighbouring countries and beyond. A good example, I think, is the TFS seaport 

co-operative partnership project, which unites several EU and EU-accession countries, such as Latvia 

and Poland. Of course, such examples abound. 

You will also be presented with several examples of best practice in the coming days. Though I do 

hope that some less successful examples are highlighted as well. After all, we can learn from both.


Finally, I would like to briefly address the fact that the Netherlands will soon assume the presidency 

of the EU. This second edition of the IMPEL conference is being held in a historic European city. The 

Maastricht Treaty was signed here. This evening, we will have the opportunity to visit the Gouvernement 

building, which is where this historic event took place. Perhaps the atmosphere and history of the building 

will inspire us. 

Ladies and gentlemen, I’d like to close my speech with an appeal. The organising committee has 

worked diligently to create a diverse conference programme that addresses both the past and future. 

Many of you are actively involved in this. I hope, however, that we will not only hear from the official 

speakers. The conference is the product of an interactive planning process. One of its primary aims is to 

stimulate interaction between the participants. I invite you to rise to the challenge and let your voice be 

heard. 

I wish you, also on behalf of our host, the Province of Limburg, a beneficial, educational and, above 

all, pleasant conference. 

Thank you for your attention.


Speech by Mr. Henk Evers 

Provincial Executive for Environment and Water policy of the Province 

of Limburg (The Netherlands) 

Dear Mr. Van Geel, Mrs. Frommer, Mr. Wolters, 

Ladies and Gentlemen, 

Foto van Henk Evers 

invoegen 

1. Introduction 

On behalf of the executive of the Province of Limburg I bid all of you, 

from 31 countries and from the European Commission, a warm welcome 

to Maastricht, the capital of our beautiful province. 

Maastricht is worth the effort but that is certainly among the topics you will be discussing over the 

next few days. First of all, I would like to convey to you greetings from our Provincial Governor, Mr Van 

Voorst tot Voorst, who is unable to be here just now as he is on his way back from Italy. He will however 

be your host at dinner in the Provincial Government Building this evening and will say a few words 

to you then. 

2. The Province of Limburg 

As a speaker on behalf of the provincial executive I would like to tell you something about this province 

and our policy, having particular regard to the issuing of permits and enforcement. I would also like to 

consider the significance of international cooperation to Limburg. I will of course also be talking about 

the significance of IMPEL. 

The province is the tier of government between the national government and the municipalities. The 

province of Limburg is the most southerly of the Netherlands’ 12 provinces. The province’s tasks are in 

the fields of regional economic development and tourism; spatial planning; health and welfare; traffic, 

transport and infrastructure, water and the environment. The provincial government is elected by the 

people every four years and has an executive in which I have held the Environmental and Water Policy 

portfolio since the last elections this spring. 

3. The policy pursued by the province of Limburg 

What is remarkable about Limburg is that 75% of the province’s border is with other countries, namely 

Belgium in the west and south and Germany in the east. 

After the west of the country, South Limburg is the most densely populated part of the Netherlands 

with some 500 inhabitants per km2. The proximity of industrial zones in Belgium and Germany, combined 

with the accumulation of agricultural activities and industry in our own province means that we 

have to devote a great deal of care to the quality of our environment. 

This is not just about traditional environmental issues such as efforts to reduce and manage waste 

flows, noise levels and water, soil and air quality. It is also about adopting an integrated approach to 

these problems. We have to strike a balance when considering both environmental and ecological 

aspects and the economic aspects and socio-cultural aspects. We believe it is very important to be coherent 

in this regard in order to achieve sustainable development. 

For this reason, the province established the Provincial Environment Plan for Limburg in 2001. This 

plan fleshes out this integrated approach between the environment, water, the economy, spatial planning 

and transport. We are the first province in the Netherlands to produce an integrated policy over 

this spread of policy sectors. We realise that this first-generation plan has not yet been perfected. We 

are therefore setting to work in 2004 evaluating and investigating new developments so that we can 

focus on the second version of this Provincial Environment Plan, which will have to be completed in 

2007 for decision-making purposes.


Some hard work is currently being done on five themes within which the integrated approach is to 

take shape. One of the results of our work is a reconstruction plan for the agricultural sector and the 

rural area in the north and centre of our province. This plan includes drastic changes to the traditional 

approach to the agricultural sector, but has of course been drawn up in consultation with all the 

parties involved. 

This was also necessary after periods involving serious outbreaks of animal diseases and the resulting 

social and economic problems. In the reconstruction plan the emphasis is still on our environmental 

objectives. We hope that the national government appreciates the value of and endorses this 

approach and will make a substantial financial contribution to its implementation. 

4. Issuing of permits and enforcement by the province of Limburg 

Of course, besides this integrated approach, sectoral policy is important to us, particularly as regards the 

environment and water. The Dutch Environmental Protection Act (Wet milieubeheer) states that the 

province is responsible for policymaking and planning. In addition, we are responsible for issuing permits 

to a multiplicity of mainly industrial concerns. We must also oversee compliance with these permits. 

We issue permits to about 600 of the largest companies in Limburg. These include companies required to 

comply with the Integrated Pollution Prevention Control (IPPC) Directive and the Seveso II Directive issued 

by the European Union. The municipalities are responsible for issuing permits to smaller businesses. 

Our approach to inspections and enforcement concerns these businesses as well as surface mining 

activities, groundwater extraction, water quality in swimming pools, illegal tree-felling in wooded areas, 

nature conservation and illegal advertising in the countryside. 

In the late 1990s and the early days of this century the provincial executive was confronted with 

some large-scale illegal activities, particularly in relation to waste, but also with regard to accidents in 

the chemical industry. As a result of this, we have decided to improve the quality of both the system for 

issuing permits and the system of enforcement and to deploy the instrument of sanctions in our enforcement 

system very deliberately and very strictly. 

The result of this is that both our permit-issuing process and our inspection and enforcement process 

have now been certified in accordance with international standard ISO nine thousand and one, version 

2000. Audits are carried out each year and improvements are constantly being made. 

As part of our quality control system, we are actively working on encouraging cooperation between 

permit-makers and inspectors in order to create enforceable permits. As a result of the accidents we have 

experienced in the chemical industry, we are convinced that regulations must be specific. The development 

of new instruments such as general permits, voluntary agreements and targets, however good and 

necessary they may be for achieving more general environmental objectives, carries the risk of being 

unverifiable and can therefore cause difficulties in enforcement. It would be a good thing if you members 

of the IMPEL network could give this issue some attention. 

Experience has also taught us that it is an illusion to think that ISO certified businesses require fewer 

inspections. 

The provincial executive does not want to base its policy exclusively on ways of dealing with accidents 

but wants to put our permit system and our enforcement process into effect in a systematic and 

programmatic way. Permit and enforcement systems are not ends in themselves but instruments for 

achieving environmental objectives. It is therefore essential to have efficient interaction between policy 

on the one hand and issuing permits/enforcement on the other. 

We want to be a predictable and reliable authority. This means that we communicate openly with 

members of the provincial parliament, the groups our policy is targeting and our citizens on both our 

plans and the results of our efforts. 

Our primary goal is to achieve the environmental objective as set out in our policy plans. In addition, 

we want to produce compliant behaviour in all those who have to comply with environmental 

requirements and work with partners such as the water boards, the municipalities, the national govern-


ment and in particular the Inspectorate of the Ministry of Housing, Spatial Planning and the 

Environment, and the public prosecutor’s office to achieve that objective. 

This means that we have to make choices and set priorities in inspections and enforcement. We have 

designed a system for this which takes many aspects into account. Some time ago, our programmatic 

approach was appreciated so much by the Ministry of Justice that we won a cash prize of € 45,000 as 

the best example at the time of a programmatic approach to the enforcement of environmental regulations. 

We are really proud of this achievement. Mr. Steijnebrugh will be telling you more about this 

and about our method of systematic prioritisation in the session on “Inspections” tomorrow. 

As I said earlier, we are working in close cooperation with our enforcement partners in the province 

whom I just mentioned. This led to the creation of a Service Point (SEPH) in early 2000 which coordinates 

the activities of the various bodies and in which the government agencies work closely together. 

I believe this is unique in Europe. The funding of the staff employed there and the accommodation is 

provided jointly by the national government, the province, the municipalities and the water boards. 

I sincerely hope that this service point will continue to develop and that financial cutbacks by the 

national government will not make it impossible for its work to continue. 

5. Significance of international cooperation to Limburg 

It is not only environmental policy, the issuing of permits and inspections and enforcement that are high 

on our list of government priorities, as international cooperation is very important to us as well. After 

all, we are almost surrounded by foreign countries. It is necessary for us to become familiar with the systems 

used by our neighbours, to find out how their environmental policy instruments are used and to 

harmonise policy aims, permit systems, enforcement, etc. So that’s what we are doing. 

Together with the Dutch provinces of Overijssel and Gelderland we have a cooperation agreement 

with the German state of North Rhine-Westphalia. We are also working closely with our Belgian colleagues 

in Flanders and Wallonia. One of the results of this cooperation is that we have made voluntary 

agreements with both our German and our Belgian neighbours on mutual involvement in the EU’s 

Environmental Impact Statement schemes. We also take part in an EU-funded network on “sustainable 

development” which is run by Wales. 

I would now like to say a few brief words on the internationalisation of our policy. In our opinion, 

the enlargement of the European Union and the resulting extension of our external borders does not 

mean that the specific problems in relation to our internal borders have therefore been solved. From our 

day-to-day experience, we know that as a regional government we need some latitude to solve problems 

in direct contact and through direct negotiations with the countries around us. We would be delighted 

to be a pilot province for trying out new methods of cooperation to solve problems. In this connection, 

it is also desirable to keep a European instrument such as Interreg in place in order to continue to boost 

cross-border cooperation along Europe’s internal borders. 

The IMPEL network is very special to us and we are therefore delighted to lend our assistance, not 

only during this conference but also by deploying our manpower in a more permanent way. 

We are particularly pleased that so many different countries are willing to allow their national and 

regional experts, and I mean real experts in the field of policymaking, permits and enforcement, to 

exchange ideas with each other informally and carry out projects on issues that concern us all and from 

which we also all stand to benefit. I congratulate you on keeping the network going for 10 years in our 

bureaucratic world. I call on you to keep up the good work and regard the arrival of the new EU members 

as a challenge to deepen and spread knowledge better and further. 

As the emphasis in the IMPEL network was on enforcement for the first few years, after which greater 

attention was focused on the issuing of permits, I call on you to close the regulatory cycle further and 

also give further form and content to policymaking and the development of instruments in this 

European context. I think it is of the greatest importance that the formal status accorded to IMPEL by 

the European Parliament and the European Commission should also be exploited to give further and


stronger form and content to its advisory role as regards new policy initiatives and new regulations from 

the European Union. Your own multi-annual working programme provides an excellent point of departure 

in this regard. I hope that it will also work in this way. 

I am coming to the end of my talk. You have a really inspiring programme ahead of you for the next few 

days. It will mean hard work for you but will hopefully also allow time for the necessary relaxation. 

I hope that you will play an active part and find the necessary inspiration for your own work in your own 

country in your own situation. But most of all I hope that you will discover this international network 

with all the opportunities it offers. 

If all this hard work means that you have little time in which to discover Maastricht and Limburg, 

I warmly invite you to come back another time. 

I wish you much success.


Speech by Mr. Pieter van Geel 

State Secretary for Environment of the Ministry for Housing, Spatial 

Planning and the Environment of 

The Netherlands 

Mr. Chairman, ladies and gentlemen, 

Foto Pieter van Geel 


[Introduction] 

This is the second time IMPEL has held a conference, and I am 

pleased that the Netherlands is able to host such an important meeting. 

As you probably know, the Netherlands and the United Kingdom 

have been involved in IMPEL from the start – over ten years ago – when the idea of establishing a 

European environmental inspectors’ network first came up. 

Those who proposed this initiative can look back with pride. The original ‘Chester Network’ has 

grown into a widely recognised platform. Despite the network’s informal character, the European 

Commission’s Sixth Environmental Action Programme makes frequent reference to IMPEL. Its projects 

are highly valued by the organisations and experts involved. This conference will further enhance 

IMPEL’s reputation among a large and varied public. 

The first IMPEL conference was held in Villach, Austria, in 2000. It was a great success, and I hope 

this conference will continue that tradition. 

Much has happened in the three years since Villach. In terms of European unification, IMPEL has 

actually progressed further than the EU, which still faces years of negotiations over who will be allowed 

to join. IMPEL has now built up a network linking member states, acceding countries and countries that 

hope to join the EU in the longer term. This is what IMPEL is all about: achieving results quickly by sorting 

matters out informally, among people in the field. 

I hope we will manage to do this again over the next three days. At any rate, I find the sight of a 

room full of IMPEL members very encouraging. Of course you all work under different conditions – one 

country has more manpower and resources than another. But the main conclusion of the first conference 

was that our problems and interests are so similar that we can gain a lot from working together 

on a practical level. And of course pollution is no respecter of national boundaries. Only if we act jointly 

and effectively, both within and outside Europe, will we be able to protect the environment properly. 

[The Netherlands] 

The global recession has put many inspection authorities under great pressure. The Dutch government 

is making record cutbacks in public spending this year. Nevertheless, I am asking for more money to be 

put into inspection. And with good reason. The Netherlands is a small country with a population of sixteen 

million and a lot of livestock. This concentration of people and animals places great pressure on 

the environment, and entails considerable safety risks. 

Two disasters that happened a few years ago made us all too aware of that fact. In Enschede an 

explosion in a fireworks factory wiped an entire residential area off the map. And in Volendam many 

young people were killed and injured when fire broke out in a bar. 

These disasters had a major impact on our attitude to public safety and the role of the government 

in the Netherlands. They reminded us in no uncertain terms of the government’s responsibility to provide 

a safe environment for people to live in. People need to know that the rules and regulations are 

being enforced. 

[Enforcement Strategy] 

The Dutch inspectorate is therefore taking action on two fronts. First, it is introducing a new enforce-


ment strategy, with clear priorities. Cases that involve a major risk to the public – like a firework factory 

that stores its products in an unsafe manner – are now given absolute priority. Cases that cause public 

concern, or undermine the credibility of the authorities, also get priority. 

We are now more alert to signals from society. The public, companies and civil-society organisations 

often have important information, and can help us tackle problem situations. 

One important element in our new enforcement strategy is thorough analysis of cases where the 

rules have been broken. It might well be our fault, if the rules are not clear enough, or we have not been 

effective in our communications. We have at any rate established that there are too many rules. My ministry 

is therefore streamlining environmental rules and procedures. Once they have been pruned back, 

rules are easier – and cheaper – to enforce. Streamlining and synchronisation should ensure that unnecessary 

rules do not stifle individual and corporate initiative. By concentrating on really important issues, 

we can create scope for self-regulation by companies and individuals. But those who do break the rules 

will soon find the authorities knocking at their door. 

Another thing we must consider is whether we have the right resources to enforce the rules effectively. 

So we have conducted a study. We asked more than 500 enforcement authorities – provincial and 

local authorities, the police – to complete a questionnaire. The results show how well equipped they 

think they are to do their work. This baseline measurement will help us devise improvement plans, which 

will be put into effect by 2005. 

My ministry’s inspectorate also completed the questionnaire. One of our conclusions was that we 

must work in a more transparent way. We must explain more clearly how and why we tackle certain 

cases. We also plan to lay down clear procedures for visiting companies. Of course inspection will always 

remain a ‘people thing’. It is certainly not our intention to turn inspectors into machines, leaving no 

room for the instinct that comes with experience. But a professional organisation has to have transparent, 

uniform procedures. This is important for the public, and for our accountability to parliament. 

Accountability includes showing that we work efficiently. Our new enforcement strategy and protocols 

are in fact designed to make us more efficient. The Ministry of Housing, Spatial Planning and the 

Environment – to which the Inspectorate belongs – has restated its core tasks. We have decided to concentrate 

on purely central government tasks – setting clear standards and frameworks for our enforcement 

partners. They have maximum freedom within those frameworks, which is more efficient and 

generates more support for our work. 

We also want to ensure our ministry becomes more active internationally. Around 80% of all legislation 

comes from Brussels. Reason enough to make sure we are aware of and involved in the European policymaking 

process. IMPEL can help with this. You can screen new projects and legislation in advance, which 

could help raise standards considerably. That is one reason why I am such a fervent supporter of IMPEL. 

[Conclusion] 

Ladies and gentlemen, over the next three days you will be looking at many IMPEL projects and their 

results. You will also discuss various Dutch initiatives, such as a project designed to make enforcement 

more professional. I think this could be important for you, too. And I hope we will also learn from your 

experiences, both in the workshops and during the coffee breaks. In fact it would be hard not to, given 

the huge amount of knowledge gathered here in the form of inspectors and policymakers, experts and 

generalists. 

I would advise you to make maximum use of this knowledge and experience during the next three 

days, continuing the ten-year tradition of IMPEL. I should like to congratulate you on your anniversary 

and express the hope that IMPEL will organise many more conferences such as this. 

Thank you.


Speech by Mrs. Ruth Frommer 

Director at the Directorate-General for the Environment of the 

European Commission 

Mr. Chairman, ladies and gentlemen, 

I was happy to accept the invitation to speak to you today. It gives 

me the opportunity of sharing my ideas with you about implementation 

and enforcement of EC environmental law and the important 

role IMPEL is playing in this regard. 

FOTO RUTH FROMMER 

INVOEGEN 

Implementation and enforcement 

Implementation of environmental law is a main priority for the Commission. This is clearly stated in the 

6th Environmental Action Programme. Proper implementation is a pre-requisite to a high level of environmental 

protection. It is encouraging for me to see so many experts and practitioners in the field of 

implementation and enforcement from all over Europe here at this second IMPEL Conference. All of you 

dedicated to ensure that the environment in that we live and work will continue to be protected. 

Implementation of EC environmental legislation covers transposition of directives and practical 

application in the Member States. Implementation goes hand in hand with enforcement. It is not 

enough to have the laws on your statute books - you need to apply them. This is challenging and maybe 

sometimes difficult - you as the people working “on the ground” on permitting and inspection tasks, may 

know this better than me. 

Over the last few years the Commission has identified a growing difficulty in correct implementation 

and good application of EC environmental legislation. This is reflected in the number of complaints 

alleging breaches of Community environmental law the Commission receives. To give you an idea, in 

2002, 555 new complaints on environmental issues were lodged with the Commission. This is four times 

more than in 1996. Reasons might be: 

• Certain provisions of our legislation are complex; they raise interpretation difficulties that in turn 

lead to transposition gaps. 

• There are high costs of implementation and/or insufficient resources in the Member States. 

• There are different competencies between different levels of authorities in the Member States. 

• Awareness is different in Member States. 

The Commission has already initiated various activities to ensure a better implementation of Community 

legislation. 

In June 2002, the Commission issued four Communications – the so-called Better Regulation Package – 

examining the way that EU legislation (across all areas, not just environment) development could be 

improved. The ultimate goals are to ensure that Community legislation is more attuned to the problems 

posed, to the challenge of enlargement and to technical and local conditions, and to achieve a common 

legislative culture in the EU. 

A central element of the “Better Regulation Package” is the Communication “Action Plan - Simplifying 

and improving the regulatory environment”. It proposes amongst others, to set up a legislative network 

between the Community, represented by the Commission, and the Member States. In this network 

the Commission and the Member States shall work together with a view to pooling current rules and 

practices and developing a joint approach to monitoring and applying legislation. 

Further, in view of putting the “Better Regulation Package” into action, a Communication on “Better 

Monitoring the Application of Community Law” has been adopted. It aims at tackling the existing deficit


in the Member States with regard to their implementation of EC legislation. This Communication calls 

for a differentiated approach to the handling of complaints lodged concerning breaches of EC legislation, 

implying that the Commission will primarily use legal action for certain 'priority' infringements. 

‘Priority’ infringements include e.g. failure to transpose or incorrect transposition of Directives, infringements 

threatening human health and damaging the environment with implications for human health 

and infringements relating to projects receiving EC funding. With regard to ‘low-priority’ infringements, 

the Commission will first give mechanisms that complement the infringement proceedings a chance to 

solve the problem. Such mechanisms include contacts with member States authorities, using the IMPEL 

network whenever appropriate. 

Current activities of the Commission to assist Member States in the implementation of Community 

environmental include, inter alia, issuing guidance documents where implementation problems arise. 

Further, the Commission has started to apply pro-active measures through bilateral contacts and 

meetings between the Commission and the Member States. Last year, several seminars – either ad-hoc 

or back to back to “package meetings” - were held in some Member States where the Commission's view 

on the correct implementation of particularly complex environmental directives was explained to the 

competent authorities. This helps to prevent, rather than correct, instances of bad application. 

Networking 

Benefit can also be gained by developing stronger co-operation between national, regional and local 

authorities that have responsibility for transposition and implementation. Exchange of information and 

experiences and networking are keys to improving and promoting implementation. This is explicitly highlighted 

in the 6th Environmental Action Programme. Networking leads to a better quality of work and 

products. Networking helps to ensure a greater consistency of approach in the implementation and 

enforcement of environmental legislation. 

Networking promotes the exchange of relevant information, the accumulation of experience among 

the network members, and the development of good and whenever possible best practices as regards 

inspection, permitting, monitoring, reporting and enforcement of Community environmental legislation. 

This is why IMPEL has a strong added value 

IMPEL 

May I say that IMPEL is the implementation network par excellence. Creating the IMPEL network has 

been a major achievement. As a result a unique pan-European forum now exists that allows people “on 

the ground” from the different Member States, Norway, acceding and candidate countries to work 

together and with the Commission in an informal context. 

I particularly appreciate this informal nature of the IMPEL network. I am convinced that this enables 

it to achieve objectives that would otherwise be much more difficult to realise in a formal context where 

only official positions are expressed. 

IMPEL provides us a great opportunity to promote mutual understanding of the common characteristics 

and differences of national regulatory systems. It is no secret that national regulators share many 

common problems - from drawing up inspection plans to controlling transports of hazardous waste or 

ensuring the application of best available techniques - and thus can benefit tremendously from learning 

how other countries tried to solve these problems. 

This is particularly true for the acceding and candidate countries in the context of the accession 

process. I am proud to say that in the framework of the sister network for the candidate countries, AC- 

IMPEL, valuable work has been done in helping these countries to bring their environmental legislation 

in line with that in the Member States. Especially, support has focused on capacity building to improve 

implementation and enforcement in these countries. 

Members of the AC-IMPEL network have been fortunate to participate in IMPEL activities and have 

thus benefited from the greater experience of their IMPEL counterparts. These efforts resulted in the


merger of the two networks, IMPEL and AC-IMPEL, which took effect on 1 January this year in a very 

successful way. 

IMPEL products 

IMPEL's key success factor is its projects. I think it is appropriate to say that the essence of IMPEL and 

how it functions is contained in the projects and their reports. The quality of IMPEL project reports is 

generally very good; a fact that is recognised by the way the IMPEL report on Minimum Criteria for 

Environmental Inspections has served as the basis for a Council/EP Recommendation adopted under 

the co-decision procedure by the EP and the Council. Further, Commission experts drew from IMPEL 

reports on best practice on compliance monitoring and on the implementation of Directive 96/61/EC 

Integrated Pollution Prevention and Control (IPPC) in the food production/processing industries to issue 

EU reference documents on Best Available Techniques (BREFs). 

In the context of AC-IMPEL, the Commission received independent assessments from EU-experts on 

implementation and enforcement capacity in the acceding and candidate countries. 

There are many more examples of excellent IMPEL reports and I would like to stress that these 

reports deserve a broad dissemination. National, regional and local authorities and practitioners in the 

field should be able to draw from the best practices laid down in these reports. I am convinced that this 

IMPEL Conference will encourage you to make use of the IMPEL reports and pass the message on to 

your colleagues. But, this Conference is also a great opportunity for you to let us know what could be 

done better or in addition to support you in your inspection, permitting and enforcement work. 

The future 

I know that IMPEL has done much to streamline its structure and to ensure that it concentrates on 

priority work. In her letter of 2000 to IMPEL members Commissioner Wallström challenged the network 

to carrying out further tasks within EC priority areas also beyond its core areas – inspection and permitting 

–, for example in coherence between different legal acts, co-operation with and between 

Member States and exchange of information and best practice. 

IMPEL has taken up this challenge and in this regard the development of IMPEL's multi-annual work 

programme is a very good starting point. It illustrates in my view the “evolution” of IMPEL. While 

the initial scope of IMPEL activities was on the implementation and enforcement of industrial-related 

environmental legislation, it now also covers other sectors (e.g. waste, air) and other parts of the 

regulatory chain. The programme gives a clear focus to the work of the network and with its emphasis 

on the 6th Environmental Action Programme it will help us to reach our common environmental objectives. 

But the multi-annual work programme must be a dynamic instrument. It should be kept under regular 

review to ensure its continuing relevance. 

Further, we all know that the adoption of the Recommendation on Minimum Criteria for Environmental 

Inspections has had a substantial impact on the work of the IMPEL network. The Recommendation 

includes several tasks which the network is specifically invited to undertake and IMPEL has 

already devoted a great deal of its activities to it. For example, a voluntary scheme for offering advice 

on inspectorates and inspection procedures - the IMPEL Review Initiative - and best practice for the training 

and qualifications of environmental inspectors have been developed. IMPEL should continue its work 

on inspections and Member States and future Member States are encouraged to make use of the results, 

because environmental inspections are a key activity in the implementation and enforcement of environmental 

law and therefore essential if we are to secure a high level of environmental protection. 

Let me also highlight the fact that IMPEL has inspired the formation of two other networks in Europe, 

the Compliance and Enforcement Network of the Newly Independent States (NISECEN) and the Balkan 

Environmental Regulatory Compliance and Enforcement Network (BERCEN). They follow IMPEL’s path 

as the pioneer network and benefit from its products. By this co-operation and transfer of knowledge 

IMPEL helps to promote environmental quality in the wider European region.


10 years of IMPEL 

I am sure you have heard or read that the Commission considered IMPEL since its inception in 1992 as 

a key forum to discuss issues related to the stage of practical application of existing legislation. Would 

you not think that today IMPEL has much more to offer? As a result of its practical experience in the 

implementation of EU environmental legislation, is IMPEL not in a good position to identify and comment 

on aspects of the current legislation that hinder its practicality and enforceability? Could IMPEL 

not also be an important source of advice for the development of new, better and enforcement-friendly 

legislation? 

I feel that it is time to celebrate IMPEL's achievements of the past ten years. And, what could be a 

more appropriate occasion than this IMPEL Conference where you, people making up the IMPEL network, 

have come together? Even the meeting venue seems to be perfectly chosen since the Netherlands 

is one of the “founding fathers” of IMPEL. 

In that respect - congratulations and let us look forward to the next successful decade. This second 

IMPEL Conference is a perfect start. It will provide us with inspiration for our future work and ideas for 

new IMPEL projects. I am convinced that in the years ahead IMPEL will continue to play its important 

role as regards implementation and enforcement. 

Pictures cutting the birthday cake

26 6 – 8 October 2003 | IMPEL at Work


4Developments since Villach 2000 

In this session three presentations focussed on developments in the IMPEL-network during the last years. 

Mrs. Giuliana Gasparrinni from Italy described the developments within the IMPEL-network itself. Mrs. 

Anna Bobo Remijn (European Commission) described the enlargement of the European Union and its 

consequences for the enlarged IMPEL network. Mrs. Krystyna Panek-Gondek gave an illustration of the 

developments within the acceding and candidate countries. 

These three contributions are presented hereafter in the form of the presented power-point presentations. 

IMPEL from Villach to Maastricht, its developments and achievements 

Mrs. Giuliana Gasparrinni (Italy) 

Picture Mrs. 

Gasparrinni



The new enlarged IMPEL 

how can we support each other and what are the necessary conditions 

Mrs. Anna Bobo Remijn (European Commission) 

Picture Mrs. Bobo 

Remijn +


Recent developments in the Accession Countries 

Mrs. Krystyna Panek-Gondek (Poland) 

Picture Mrs. Panek

IMPEL at Work | Report 31


Foto sprekers achter forumtafel invoegen 

Picture of Wolters; Gasparrinni; Bobo Remijn; 

Panek behind forum-table


5IMPEL at Work 

In this session attention was given to two major projects of IMPEL. Two speakers gave their impressions 

about the Recommendation about Minimum Criteria for Environmental Inspections. Mr. Georges Kremlis 

from the perspective of the European Commission and Mr. Günther Düssing from the perspective of a 

Member State, in this case Austria. 

The second project which was presented was IMPEL’s Review Initiative, a benchmark project explained 

by Mr. Martin Murray (United Kingdom). 

Minimum Criteria for Environmental Inspections 

What can we learn from the first round of reporting 

Mr. Georges Kremlis (European Commission) 

Foto Kremlis invoegen



Minimum Criteria for Inspections – A Member State’s perspective from Austria 

Mr. Günther Düssing (Austria) 

Foto Düssing invoegen




IMPEL’s Review Initiative – 

Benchmarking and comparing inspection- and enforcement units across Europe 

Mr. Martin Murray (United Kingdom) 

In 2000 the IMPEL Network developed a voluntary scheme for reporting 

and offering advice on inspectorates and inspection procedures – Foto Murray invoegen 

the IMPEL Review Initiative “IRI”. The scheme was proposed against 

a background of preparation of a European Parliament and Council 

Recommendation providing for Minimum Criteria for Environmental 

Inspections (MCEI) and implementation of the IPPC Directive. Terms 

of reference were agreed by IMPEL in May 2000. The review process 

including a questionnaire and guidance developed and approved by 

June 2001 and to date inspection authorities in seven Member States 

have been reviewed. The last review taking place in March 2003. 

This paper describes the background to the review process and act as an introduction to discussions in 

Session 4 “Capacity Building”. The presentation will outline the review methodology and practical experience 

gained by the presenter and participants in taking part in the review process. 

1. Introduction 

The IMPEL Review Initiative was developed in three-phases 

• Phase 1: development of the project, 

• Phase 2: the drafting of a questionnaire as a basis for reviews. First drafts of the questionnaire and 

associated guidance were discussed and revised at a seminar in London in October 2000. These were 

assessed again and tested for practicality in a limited trial of the review process, in Nykobing, 

Denmark on 22/24 February 2001. The report of that assessment and test proposed another version 

of the questionnaire and associated guidance, revised on the basis of experience of that trial. The 

report, (“IMPEL Review Initiative (IRI) Phase 2: Assessment and Test of Questionnaire and Guidance), 

was adopted during the IMPEL Meeting of 18-20 June 2001 in Falun, Sweden. 

• Phase 3: the testing of the revised IRI process by way of six reviews, over a period of two years, using 

the Questionnaire and Guidance developed in Phase 2. 

2. Purpose 

The purpose of this voluntary scheme is to examine the arrangements within which the Candidate 

Inspectorate operates with the objective of delivering the following benefits, which were foreseen in the 

agreed Terms of Reference for the project with particular relevance to the Recommendation 

(2001/331/EC) and IPPC. 

• Encouragement of capacity–building in EU Member State inspectorates. 

• Encouragement of further collaboration between EU Member State inspectorates on common issues 

or problems, on exchange of experience and on development and dissemination of good practice in 

environmental regulation. 

• Provision of advice to inspectorates (“candidate inspectorates”) who may be seeking an external view 

of their structure, operation or performance by trusted, knowledgeable and independent counterparts 

for the purpose of benchmarking and continuous improvement of their organisation. 

• Spread of good practice leading to improved quality of inspectorates and inspections, and contributing 

to continuous improvement of quality and consistency of application of environmental law across 

the EU (“the level playing-field”). 

The IRI Review process was intended to enable the Candidate Inspectorate and Review Team to explore 

the idealised regulatory system. This is not an audit process but is intended to meet recital 17 European 

Parliament and Council Recommendation (2001/331/EC)


(17) Member States should assist each other administratively in operating this recommendation. The establishment 

by Member States in co-operation with IMPEL of reporting and advice schemes relating to inspectorates and inspection 

procedures would help to promote best practice across the Community 

3. The IRI Process 

The IRI Review process enables the Candidate Inspectorate and Review Team to explore the idealised 

regulatory system, to identify areas of good practice for dissemination together with opportunities for 

improvement to existing practice within the Candidate Inspectorate and Member State. 

The IRI process follows a questionnaire is structured in sections with open questions. The guidance 

assists by expanding on the goals the sections are intended to achieve. 

The process is in ten parts: 

1. Constitutional Basis for Inspectorate 

2. Legal basis for the inspectorate 

3. Organisational structure and management of the Inspectorate Workload 

4. Workload 

5. Qualifications, Skills and Experience 

6. Training 

7. Procedures 

8. Standards and Guidance 

9. Performance Assessment 

10. Reporting 

The Review process enables the Candidate Inspectorate and Review Team to explore their regulatory systems 

by comparing practice in the candidate inspectorate with the arrangements in the review teams 

inspectorates. 

Areas of good practice and opportunities for development are then noted and reported through a published 

IMPEL report for dissemination across the IMPEL Network. 

4. Practical and personal experience 

There have been 7 IRI Reviews, Denmark, Germany, Ireland, Belgium, France, the Netherlands and Spain. 

These have involved inspectors from 9 Member States, Austria, Belgium, Denmark, France, Germany, 

Netherlands, Spain, Sweden and the United Kingdom. 

• The Review Process benefits both the review team members and the Candidate Inspectorate. 

• IRI process works for large and small inspectorates 

• IRI process works in Northern, Southern Europe, for Federal or Centralised Administrative Systems 

• Every Member States constitution and regulatory arrangements are different to reflect their history 

and their society 

• Under subsidiarity Member States have their own way of implementing European Environmental Law 

• Different Member States have different priorities 

• National, centralised, and large inspectorates concentrate on national issues to the detriment of local 

environmental issues 

• Local and small inspectorates concentrate on local concerns to the detriment of larger national issues 

• All inspectorates and inspectors need to understand the wider regulatory system their role and the 

role of other participants to ensure that overall their regulatory systems implement European 

Environmental Law. 

• All inspectorates have too much work, not enough resource and are developing systems to target 

resources to deliver effective regulation, to plan inspections, to measure their impact and to challenge 

and be able to answer five key questions Why do we regulate?, What are we doing? , How should we 

do it ?, What does it deliver ? How is it done elsewhere?


Conclusion 

The IRI process has helped to promote best practice by: 

• Identifying areas of Good Practice and Areas for Development in the candidate inspectorate. 

• Removing misconceptions concerning regulation and regulatory practice between Member States 

• Resulting in the candidate inspectorates and review team members implementing changes to improve 

current practice as a result of the review process. 

This topic will be taken further in the session on Capacity Building on 7 October where some key observations 

from the IRI review process will be explored



foto’s


6Forum discussion 

“The future of environmental inspections and enforcement - 

A necessity or a waste of energy ?” 

Report by Neil Emmott (United Kingdom). 

The session involved a series of presentations and then a forum discussion among key actors from 

different backgrounds. Based around the overall question of whether environmental inspections and 

enforcement are a necessity or a waste of energy, the participants looked forward to future developments 

not just in inspections and enforcement, but also concerning self-regulation, voluntary instruments, 

EU versus national approaches and related issues. 

The session was chaired by Georges Kremlis, Head of Legal Implementation and Enforcement in the 

Directorate General for Environment of the European Commission. Mr Jan Pronk, former Minister for 

Housing, Spatial Planning and the Environment of the Netherlands (but speaking as a private citizen), 

introduced the theme with an expansive speech. More detailed views were then given from three different 

perspectives. Mr Michel Bruder of UNICE gave the industry point of view, Mr John Hontelez of the 

European Environment Bureau reflected the position of environmental NGOs, and Mrs Marie-Claude 

Dupuis spoke on behalf of the French Ministry of the Environment while also representing the IMPEL 

network. Neil Emmott of the Environment Agency of England and Wales acted as the rapporteur. 

Are inspections and enforcement a necessity or a waste of energy? 

On this basic question, there was no disagreement that inspections and enforcement are absolutely 

essential to ensure proper application of the law and protection of the environment. Most speakers 

viewed this as so self-evident that they saw no need to discuss it at length. Michel Bruder of UNICE commented 

that, while self-monitoring is an important principle for industry, nevertheless UNICE equally 

accepts that compliance testing and enforcement by regulators are essential. He drew an analogy 

between industrial operators and drivers: not all operators are perfect, and inspections and enforcement 

are therefore needed for industry just as action is required to make some drivers respect speed limits. 

Beyond this basic question, six key topics emerged. 

The conditions needed for good implementation and enforcement 

The panelists discussed conditions that support the implementation of EU environmental law, including 

through inspections and enforcement. Jan Pronk suggested that these include: good choice of policy 

measures that are transparently related to objectives; coherence between laws; adoption of ambitious 

yet achievable standards that become progressively more demanding; good prioritisation, focusing first 

on things with irreversible consequences; and non-discrimination in enforcement regardless of shortterm 

economic interests. He also commented that governments must fully back their regulators, and be 

willing to change laws on the basis of practical feedback from them. 

John Hontelez agreed with Mr Pronk's point about standards, noting that unless ambitious and robust


laws are adopted, implementation and enforcement will achieve little anyway. Michel Bruder did not disagree 

with this but stressed the need for dialogue between governments, industry and NGOs to establish 

the optimum approaches. He also identified the issue of training as key, observing that industry as 

well regulators must have enough well-trained staff to apply the law properly. Marie-Claude Dupuis 

agreed that adequate training and resources in industry are essential, as she saw industrial operators 

as having the primary responsibility for risk management and pollution prevention. She additionally 

highlighted transparency - for example in the application of law and the performance of industry - as a 

key driver for improvement. 

The participation of the public in implementation and enforcement 

Another important theme was public involvement in the development and application of law. Jan Pronk 

suggested that environmental policy-making and enforcement have become increasingly technocratic 

and bureaucratic exercises in recent years, which has created a confidence gap between the people and 

their governments. He thought this could only be addressed by making ecosystems, health and enforcement 

issues political matters, so that the public could increasingly engage. Public participation was also 

a key strand of John Hontelez's remarks. He suggested that the Aarhus Convention should enable more 

effective enforcement by strengthening public involvement in and support for regulatory processes. 

Marie-Claude Dupuis explained how, following recent high profile environmental cases in France, French 

laws are being amended to allow increased consultation of local people in proposals for new industrial 

developments. The changes also promote greater response to public complaints, and provision of information 

on inspections to the public. 

The role of self-monitoring 

There was some discussion of the role of self-monitoring or even self-regulation. Jan Pronk noted that a 

recent “hands-off” political philosophy is increasingly encouraging moves in this direction, although he 

believed that it would be wise for inspectors to remain sceptical of monitoring information from industry. 

Michel Bruder said that self-monitoring was a basic principle for industry, recognising that industry 

itself had a responsibility to monitor its emissions and impacts. He reiterated that this was as a complement, 

rather than an alternative, to compliance monitoring by regulators. Marie-Claude Dupuis 

thought that self-monitoring was essential to allow operators to follow the performance of their plants 

from day-to-day, enabling them to detect and solve problems in real-time. 

The use of alternative measures to traditional “command and control” instruments 

Jan Pronk introduced this topic by noting that a pre-requisite for good implementation and enforcement 

is choice of the right policy instruments in the first place. This might entail alternatives to command and 

control such as taxes, voluntary instruments or other measures. However, none of the speakers advocated 

a major shift away from laws allowing for inspections and enforcement. 

John Hontelez confirmed that NGOs are generally sceptical of efforts to promote alternatives to 

approaches that allow for legal enforcement, although he felt it was important to make the market work 

more for the environment as well. Michel Bruder commented that is perhaps the type of law that is more 

important rather than the fact that there is a law at all. He cited the IPPC Directive as an example of 

an effective and innovative approach. UNICE supports IPPC, he explained, because it creates a legally 

enforceable regime underpinned by inspections and enforcement, while nevertheless allowing appropriate 

flexibility in determining the standards to be enforced. He saw this flexibility as important, and 

better than more traditional command and control measures based on uniform standards, because no 

two plants are the same. Marie-Claude Dupuis added that new French legislation is aiming to improve


not just the traditional regulatory aspects, but also important supporting provisions such as protection 

for those who “blow the whistle” on companies who fail to meet their environmental obligations. 

Does EU environmental legislation put an excessive burden on industry? 

Discussion on this topic turned around the industry perspective put by Michel Bruder. He suggested that 

it is important to take account of the local situation, and what is reasonable from an economic point of 

view, in determining environmental standards. He also suggested that some EU companies are relocating 

to other parts of the world where production costs are lower. Jan Pronk was concerned that industry 

might use the threat of such relocation to head off important environmental improvements in a way 

that amounted to economic blackmail. He doubted whether environmental measures, on top of more 

significant provisions such as tax levels, were really a significant contributor to industrial relocation. In 

response, Michel Bruder confirmed that UNICE is not arguing that it is the environmental costs, on top 

of others, that cause relocation. Rather, it is the total costs which are decisive. Mr Bruder acknowledged 

that environmental issues were only part of a wider picture in this respect, and were not one of the more 

significant factors. Nevertheless he stressed it was always important to have dialogue to establish what 

was reasonable and how best use could be made of the money available. He was not saying UNICE did 

not want industry to spend money for the environment, but it was important that costs were sustainable 

and money spent on the right things. 

Marie-Claude Dupuis noted the potential to phase industrial improvements over time, so that they could 

be ambitious yet achievable. John Hontelez was concerned that industrial costs are often exaggerated, 

and the ability of industry to innovate is usually underestimated. He also thought it was important that 

readily quantifiable costs to industry do not outweigh what will inevitably be more subjective assessments 

of the importance of environmental improvements, for example in cost-benefit analyses. 

The role of IMPEL 

A final issue discussed was how IMPEL might support the more effective implementation and enforcement 

of EU environmental law. Opening the session, the Chairman Georges Kremlis had posed the question 

of whether some form of EU-level inspection system was required. John Hontelez picked up on this 

issue, stating that from the NGOs' perspective a more structured EU inspection system would be desirable. 

However, in the absence of this he viewed IMPEL as having an important role in promoting greater 

consistency in implementation. Michel Bruder and Marie-Claude Dupuis echoed their support for promoting 

consistency both within and between Member States, and also saw IMPEL as an important contributor 

in this area. 

Conclusion 

All of the participants saw inspections and enforcement as a necessity rather than a waste of energy. A 

number of pre-requisites to allow inspections and enforcement to be effective were identified, including 

adequate levels of well-trained staff in regulators and industry. Industry must take responsibility for 

managing environmental risks and preventing pollution, but regulation is needed to impose enforceable 

controls. Achieving greater consistency of implementation of EU legislation, both within and between 

Member States, is important, and IMPEL can play a significant role in this area.


Pictures of the forum


7Results of the working sessions 

The results of the four parallel working sessions were reported by the rapporteurs in the plenary meeting 

on the last day of the conference. The power-point presentations of the rapporteurs show as follows. 

Session 1. New instruments and improvement of the current instruments 

Rapporteur: Mrs. Katerina Iakovidou (Greece)



Session 2. The role of inspections and different approaches. 

Rapporteur: Mr. Peter Schryvers (Belgium)


Session 3. Identifying and spreading good practice – 

getting the best out of networks like IMPEL 

Rapporteur: Mr. Frank Clinton (Ireland)



Session 4. Capacity building – How can we manage our job ? 

Rapporteur: Mr. Costas Hadjipanayiotou (Cyprus)



Pictures werkgroepen


8Overall results of the different sessions 

New project ideas and suggestions for the promotion of IMPEL’s work 

The overall results of the four parallel sessions were presented by 

Mr. Terence Shears (United Kingdom), using the following powerpoint 

presentation. 

Foto Shears invoegen



9Closing address 

At the end of the conference, the participants were addressed by Mrs. Dr. Caroline Jackson, Chairman of 

the Environment Committee of the European Parliament. 

Ladies and gentlemen, 

Members of the European Parliament (MEPs) play a major part in 

shaping new EU environmental laws. The environment committee is 

one of the busiest in the Parliament. 20% of amendments adopted 

to new laws come from us, and we are responsible for 40% of the codecision 

negotiations. Through the co-decision process we not only 

propose amendments to new laws, but have the power to follow these 

through to final adoption. This means that we press our amendments 

during the final conciliation stage, face to face with ministers and 

their representatives. We have had some very long and late night 

meetings in this way, notably on the WEEE directive. 

Foto Jackson 


Because we take such an important part in drawing up new law, we have a particular interest in seeing 

what happens to it after adoption. Not only that – we know from our contacts with constituents that there 

is general suspicion in the EU that “the others” do not follow EU laws “as we do”. Where is the dividing 

line here? Broadly between rich and poor, north and south, but also between the willing and the wilful. 

The picture we get is not a happy one. It is true that we now have legislation in place covering the most 

significant areas - water and air pollution, waste management, habitat protection, and environmental 

impact of major planning decisions. The style of most of these laws has been that they set very tight 

standards, sometimes with highly specific targets and limits. They generally include a reporting requirement 

that is often ignored. We are not able to discern, except in very vague terms through the conciliation 

process, when Member States have expressed doubts about their ability to comply with what 

they agree to. And because these are environmental laws, environment ministers do not like to stand in 

their way. Rather the reverse, each country that takes over the Presidency wants to be able to claim that 

this or that directive is adopted during its term. This means that we often legislate in a great hurry, and 

then have to sort out the problems afterwards. We have also legislated, until now, in ignorance of the 

likely cost of what we adopt. 

The result is that laws are adopted but are then not transposed at all into national law, or poorly transposed. 

Once transposed the level of implementation may vary widely. In 2002 the environment sector 

covered over one third of al infringement cases investigated by the Commission. 

MEPs have tried to focus greater attention on this neglect of environment laws. We have carried out a 

series of follow up reports on directives where things have gone wrong, notably the nitrate directive. We 

have a special question time in the committee where we have regular reports form the Commission on 

what is happening to improve things.


Things are changing beyond the Parliament: the imminence of enlargement means that the existing 

Member States and their MEPs are getting nervous about the derogations granted to new states, and 

the threat they may pose to the competitiveness of the existing 15. This means that MEPs enthusiasm 

for new EU laws is somewhat tempered, as we have seen in our debates on environmental liability and 

on the new packaging directive. We are very glad that the Commission is grappling with the issue of 

how much new directives are going to cost, and brining forward cost benefit statements in the new 

extended impact assessments. We are intrigued that the Council will now legislate in public because 

that will mean that ministers are making a public commitment to laws they cannot wriggle out of. 

We do have some further areas on which we want action: 

• The Commission should take action more quickly on infringements. Giving them time has not worked 

• Extended impact assessments have to be robust given that member states are now doing their own 

sums 

• The Commission should make more use of the EEA as an intelligence service on areas of neglect. 

It is not enough to rely on complaint from the public. 75% of cases at the moment derive from 

such complaints. 

• We should not be afraid to take our time over new legislation: if the thematic strategies herald a new 

stream of directives it will be a mistake. 

Where does IMPEL come in? 

Your work underpins outs. We are concerned that there may not be enough of you to do the work that 

is needed to make our decisions a reality. We believe that this shortage of resources is probably going 

to prove a lot worse in the candidate countries. 

We need your in-put earlier on. This especially true on questions concerning the practicality of what is 

proposed, on issues related to the strengths and weaknesses of national monitoring systems and their 

equivalence (or lack of it). We look to IMPEL to forecast where the problems are going to arise. 

We also need your views at an earlier stage, during the development of policies. What does IMPEL think 

about moving more towards progress through voluntary agreements? What are your views on the advantages 

and pitfalls of framework directives? 

We believe that you could work more closely with the EEA to deepen their perspectives on what is 

actually happening in the EU, and, as MEPs, we would welcome our views on new proposals. 

Above all, MEPs would welcome the chance to help IMPEL get a higher profile in the public eye. 

You perform a vital task, and more people should hear about it.


10Final remarks 

The conference was closed by the Chairman, Mr. Gerard Wolters by thanking the Preparatory Committee, 

the speakers and rapporteurs, the sponsors, Conference Agency Limburg and the project-leaders. 

He mentioned some main conclusions and announced that he will send a letter about the Conference 

to the European Commissioner for the Environment, Mrs. Margot Wallström (see the annexes). 

The main conclusions can be summarised as follows: 

• It was stressed that the role of IMPEL should be developed further. The existing emphasis on inspections 

and enforcement and permit-making must be continued as well as the relationship between 

permit-making and enforcement. Besides that more attention should be given to broadening the 

scope of IMPEL to the advisory role for the European Commission in the field of giving feed-back to 

the regulators by bringing in practical experiences. This may improve the quality of the regulatory 

process. Also attention should be given to the applicability and enforceability of new legislation on 

the European level. Inspectors should play an active role in closing the regulatory cycle. 

• Ideas for new projects should be developed along these lines. All participants were invited to bring 

up new ideas. 

• The IMPEL reports are in many countries recognized as useful and are important in the process of 

developing and fine-tuning procedures and implementation plans. It is however necessary to improve 

the “visibility” of IMPEL by improving the dissemination of its products and its multi-annual working 

programme. The national IMPEL-co-ordinators play a key-role in this. 

• It is necessary to give continuously attention to the resources that are necessary for this work to 

reduce the threats for safety, health and environment. 

Foto invoegen van Wolters en Fogde


• It is important for permit-making- and enforcement organisations to have an open dialogue with 

Industry and Non-Governmental Organisations. 

• The extension of the IMPEL-network with the acceding and candidate countries is a big challenge for 

new and old member states of the European Union. Implementation and enforcement are key priorities 

for the enlarged EU. 

• This requires additional and longer term financial- and human resources on the levels of as well the 

European Commission and the member States as the authorities on the regional and local level. 

• Improving the quality of inspections and giving them a common basis are important in the enlarged 

IMPEL network and in the EU. Fine-tuning of training programmes and qualifications for inspectors 

and others are important as well as exchange programmes in which practical experiences can be 

discussed. In this respect the benchmarking of inspection organisations in the different countries 

should be continued.


11Annexes 

Annex 1. Abstracts of all presentations 

Developments since Villach 2000 

Monday, 6th. October 2003 

SESSION: Developments since Villach 2000 

DATE: 6th. October 2003 

TITLE OF PRESENTATION: IMPEL from Villach to Maastricht 

NAME OF SPEAKER: Giuliana Gasparrini 

ORGANISATION: Italian Ministry of the Environment 

ADDRESS: Via Christoforo Colombo, 44, I-00147 Rome 

TEL. NUMBER: +39 06 5722 8150 

FAX NUMBER: +39 06 5722 8172 

E-MAIL ADDRESS: Gasparrini.giuliana@minambiente.it 

Summary 

The IMPEL 2000 Conference on Environmental Compliance and Enforcement (Villach, 11-13 October) 

offered for the first time the possibility of presenting IMPEL to a large audience, to raise awareness as 

well as to discuss and evaluate the role of IMPEL. The participants of the conference encouraged the 

IMPEL Network to continue and develop its activities in line with its particular strengths. They gave 

many ideas for future areas of co-operation and projects, and called for further IMPEL Conferences to 

be held regularly to provide a forum to share experience and to strengthen networking. 

What has IMPEL done out of it and what has IMPEL achieved since then? - A lot! 

Development of a multi-annual work programme. This programme outlines the framework for all IMPEL 

projects and activities. It provides a structure for IMPEL's work for the years 2002 - 2006. It is largely 

drawn from the 6th Environmental Action Programme and has a particular focus on the Recommendation 

on Minimum Criteria for Environmental Inspections (2001/331/EC). 

Growing recognition for IMPEL and its work. The 6th Environmental Action Programme gives explicit 

recognition to IMPEL's work - Article 3.2 is about encouraging more effective implementation and 

enforcement of Community legislation on the environment, which requires, amongst other things: 

improved exchange of information on best practice on implementation including by the IMPEL network 

within the framework of its competencies. The IMPEL series of reports on Minimum Criteria for 

Environmental Inspections (1997 - 1999) has formed the basis for the Recommendation 2001/331/EC 

of the European Parliament and of the Council of 4 April 2001 providing for minimum criteria for environmental 

inspections. The adoption of the Recommendation has had a substantial impact on the work 

of IMPEL; it includes several tasks which IMPEL is specifically invited to undertake. 

An impressive number of projects has been carried out and finalised in the past three years. More than


20 project reports have been adopted and published on the IMPEL website. These projects were mostly 

concerned with integrated permitting and inspections. They provided an opportunity for a lot of inspectors 

and permitters from national and regional authorities to take part in IMPEL activities. To name some 

of the projects, there is the IMPEL Review Initiative - a voluntary scheme for reporting and offering 

advice on inspectorates and inspection procedures - six reviews have been carried out so far. Two more 

projects on environmental enforcement practices have been carried out. IMPEL has looked at best practices 

for training and qualifications for inspectors, a first IMPEL project on web-based distance learning 

was organised. Projects on the IPPC Directive were concerned with the food production/processing 

industries, best practice on compliance monitoring (both projects have contributed to the development 

of EU reference documents on Best Available Techniques) and energy efficiency in environmental permits. 

IMPEL has also broadened its scope of activities, projects are now also carried out in the field of 

waste. Further, IMPEL with its over 10 years practical experience is in a good position to develop common 

views on the coherence and enforceability of EU legislation in appropriate areas of focus. A first 

IMPEL project the “Better Legislation Initiative” has started this year. Other activities are to follow, 

Doubling of its members - merger of the two networks IMPEL and AC-IMPEL. Participants from the accession 

and candidate countries participated in several IMPEL activities over the past three years. The two 

networks have worked ever more closely together and they merged as from 1 January 2003. IMPEL is 

now a network of 29 countries - all Member States, the 10 acceding countries and the candidate countries 

Bulgaria, Romania and Turkey as well as Norway. The Commission is also a member. 

Strengthening co-operation with other environmental networks. IMPEL has played an important role in the 

development of the Compliance and Enforcement Network of the Newly Independent States (NISECEN) 

and the Balkan Environmental Regulatory Compliance and Enforcement Network (BERCEN) and maintains 

close co-operation with them. The co-ordinators of the NISECEN and the BERCEN network are invited to 

participate in IMPEL Plenary Meetings and representatives from NISECEN and BERCEN take part in IMPEL 

projects on a case-by-case basis. And of course, IMPEL organised this second IMPEL Conference. 

SESSION: Developments since Villach 2000 


TITLE OF PRESENTATION: The enlargement of the IMPEL network: mutual support and necessary conditions 

NAME OF SPEAKER: Anna Bobo Remijn 

ORGANISATION: European Commission 

ADDRESS: Avenue de Beaulieu 9, office 5/159, B-1160 Brussels 

TEL. NUMBER: 00-32-2-2990334 

FAX NUMBER: 00-32-2-2994123 

E-MAIL ADDRESS: anna.bobo-remijn@cec.eu.int 

Summary 

The Associated Countries Implementation and Enforcement of Environmental Law Network (AC-IMPEL) 

was founded in 1997 as a sister network of IMPEL. The network provides support to the acceding and 

candidate countries to meet their obligations in the field of environmental legislation, specifically in 

terms of implementation and enforcement. Furthermore, it promotes co-operation in capacity building 

in the administrative/implementation/enforcement agencies of all acceding and candidate countries. 

In recent years AC-IMPEL has been drawing closer to the IMPEL network, by organising parallel activities 

and participating in the IMPEL meetings and events. 

The AC-IMPEL network merged with IMPEL on 1 January 2003. The two budgets will be merged in 

2005. In this interim period, the acceding and candidate countries will be able to carry out projects and


activities tailored to their needs within the enlarged network. These include training programmes for 

environmental inspectors, study tours and in country assessments, as well as specific studies on implementation 

of key environmental legislation. After 1-1-2005 AC-IMPEL, as a Cluster of the IMPEL 

network, will continue specific activities for the acceding and candidate countries, within the overall 

multi-annual work programme. 

The IMPEL work programme includes a number of priority activities that can help prepare the ground for 

implementation in the future member states. AC-IMPEL members are encouraged to participate in the 

different IMPEL events, such as the IMPEL Plenary meetings, training programmes and selected comparison 

and exchange programmes. AC-IMPEL members have successfully participated in the “four instruments”-project 

(IPPC, EIA, EMAS, SEVESO), the “IPPC-Food Industry” project, the project on “energy efficiency 

in IPPC permits” and the activities of the Cluster on Transfrontier Shipments, just to name a few. 

A wider participation in IMPEL events and discussions in the IMPEL forum, from both acceding/ 

candidate countries and the Member States, will lead to improved cross-border co-operation, better 

understanding of EU environmental law and more effective implementation and enforcement in the 

enlarged Europe. It has been clear that the acceding and candidate countries should benefit as much 

as possible from EU experience in the subsequent phases of implementation and enforcement of EU 

environmental legislation. In this respect, the IMPEL members have committed to provide technical support 

and expertise to their AC-IMPEL counterparts. The European Commission also benefits from AC- 

IMPEL activities, where it receives verified opinions of independent experts in the framework of the in 

country assessments. 

Different funding opportunities exist in the Community budget to support the participation of AC-IMPEL 

members in the IMPEL activities. For example, within the PHARE pre-accession instrument, we have supported 

so far AC-IMPEL activities with EUR 175,000. Under the TAC (“Travel Accommodation and 

Conference”) facility of PHARE, we have supported the participation of AC-IMPEL members to different 

events; inter-alia, to this Conference in Maastricht. However, it is important to keep in mind that the preaccession 

instrument PHARE only covers 10 out of the 13 candidates countries (CZ, EE, HU, LT, LV, PL, SI, SK, 

BG and RO) and therefore, the participation of MT, CY and TK needs to be secured from other financial 

sources, such as for example their respective EU Pre-accession Financial Assistance Programmes. Another 

PHARE facility called TOC (“Travel Observers in Committees”) can cover travel costs for participation of representatives 

from the PHARE countries (excluding BG and RO) in certain IMPEL meetings in Brussels. 

It is foreseen that the AC IMPEL activities (including projects and meetings) will be considered in the 

proposal for the IMPEL budget under the 2005 exercise. 

The merged network provides the acceding and candidate countries the opportunity of learning about 

new initiatives from the European Community, the work of IMPEL, and the priorities and approach to 

environmental policy, as well as to take part in the IMPEL projects initiated by the Member States. The 

acceding and candidate countries will also provide valuable input to the discussions in the IMPEL forum, 

in terms of new ideas and approaches. IMPEL has been at the forefront of taking on board the future 

Member States, and will continue this role in the development of other networks, such as the network 

for the newly independent states (NISECEN) and the network for the BALKAN countries (BERCEN).


SESSION: Developments since Villach 


TITLE OF PRESENTATION: Recent developments in the Accession Countries 

NAME OF SPEAKER: Krystyna Panek 

ORGANISATION: Chief Inspectorate for Environmental Protection, Poland 

ADDRESS: ul. Wawelska 52/52, 00 922 Warsaw, Poland 

TEL. NUMBER: +48 22 825 97 75 

FAX NUMBER: +48 22 825 97 75 

E-MAIL ADDRESS: kpanek@pios.gov.pl 

Summary 

The Associated Countries who decided to access the European Union have undertaken a very difficult 

challenge, that is to harmonise their laws with and establish their structures providing for implementation 

of the Community legal provisions. Nowadays, one can say that almost the entire task consisting in 

the integration of EU law into legal frameworks of the Candidate Countries has been completed. Not 

less important, but often rather yet more complicated and expensive is to implement and enforce new 

law into practice. The background for such activities is to build respective administrative structures which 

will provide the opportunities for new regulations and which will control their application. Bureaucracy 

is a weakness we have for years grumbled about in our countries. However, it appeared that the institutions 

established with the aim to supervise implementation of the Community law can cause yet multiplied 

expansion of that bureaucracy. That will become unavoidable unless the appropriate mechanisms 

are not applied timely which will rationalise the use of human resources and decentralise the powers of 

governmental administration towards local self-governments who can collaborate directly with their 

local inhabitants. 

All the Candidate Countries developed their implementation programmes for such Directives for which 

the adaptation periods were established in negotiations. These programmes set out the tasks, executors, 

measures and resources required for their implementation. They are thought as a control instrument 

which will enable for the Commission to verify progress in the compliance with the key requirements 

included in Directives. But, application of such an instrument will produce measurable benefits also for 

the Candidate Countries. It is noteworthy, that completion of the implementation programmes, once 

enforced by the integration process, will lead to significant improvement in the state of the environment 

in sectors requiring de facto the most urgent investment activities. 

One of the most important problems was, as it will for the next years be, the allocation of respective 

financial resources for implementation of strategic goals included in the implementation programmes. 

Al the Candidate Countries have unanimously pointed out the difficult and complicated procedures for 

acquisition of the EU funding for implementation of pro-ecological projects. However, none made reservation 

against spending the public resources, including also the Community pre-accession assistance in 

the framework of the ISPA and SAPARD Programmes, in a rational way and under special supervision. 

However, it was hard to accept the fact, that the principles and procedures were changed by the 

Commission day after day in the course of tendering or contracting processes, thus annihilating the 

efforts done and wasting the outlays spent for preparation of relevant documentation. 

Large investments and strengthening administrative capacity - these are the challenges which can be 

calculated and estimated. But, there is a difficulty not easy to quantify: the matter concerns the change 

in mentality and attitudes on the part of institutions, industries and the public towards environmental


protection issues. Thanks to integration process with EU, a huge redevelopment of ecological awareness 

of the public is under way in the accession countries. One should remember that these changes run in 

the Candidate Countries during thorough economic transformation and with accompanying social perturbations. 

Thus, it will be not easy and long-lasting process. 

Process of integration would for sure lasting longer be more difficult, and more frustrating without AC 

IMPEL and IMPEL co-operation. Exchange of experience and information, open discussions and presentation 

of various approaches towards the problems to be solved as well as exchange of practical experience 

have fulfilled an extremely important role. 

IMPEL at Work 


SESSION: IMPEL at Work 


TITLE OF PRESENTATION: Minimum Criteria for inspections – what can we learn from the first round of reporting 

NAME OF SPEAKER: Georges Kremlis 

ORGANISATION: European Commission, DG Environment, Head of Unit D.2 Legal Implementation 

ADDRESS: Beaulieu 9 1/185, B-1049 Brussels, Belgium 

TEL. NUMBER: 0032 2 296 65 26 

FAX NUMBER: 0032 2 299 10 70 

E-MAIL ADDRESS: georges.kremlis@cec.eu.int 

Summary 

The Recommendation of the European Parliament and of the Council of 4 April 2001 providing for 

minimum criteria for environmental inspections in the Member States (RMCEI) came into effect on 27 

April 2001. It seeks to improve the enforcement of environmental law in the Member States (MS) by 

establishing plans for environmental inspections, performing site-visits, reporting on these site-visits and 

by investigating serious accidents, incidents and occurrences of non-compliance. 

MS were asked to inform the Commission of the implementation of the RMCEI (point X) and to report 

on their experiences of the operation of the RMCEI (point VIII). Acceding and candidate countries 

(AC/CC) in the context of the former AC-IMPEL network (presently enlarged IMPEL network) volunteered 

to submit reports as well. 

IMPEL Guidance Document on point VIII RMCEI: supporting tool for MS and AC/CC to provide the information 

specified under point VIII.2 and to respond in a consistent manner. 

Assessment of reports: some findings as regards structures and resources for meeting RMCEI requirements, 

the extent of practical implementation and the extent to which national practice conforms to the 

requirements of the RMCEI. 

Important role for IMPEL to help MS and AC/CC to further improve their inspection systems (exchange 

of experiences, development of “best practice”, co-financing projects promoting compliance with RMCEI). 

Further development of the RMCEI – first evaluation of the Commission.


SESSION: IMPEL at work 

DATE: 6th. October 2003. 

TITLE OF PRESENTATION: The Implementation of the Recommendation for Minimum 

criteria for environmental inspections in Austria 

NAME OF SPEAKER: Guenter Dussing 

ORGANISATION: Dep. of Environmental Protection at the office of the government 

of the province of Salzburg 

ADDRESS: A-5010 Salzburg, Postfach 527 

TEL. NUMBER: 0043/662/8042-4548 

FAX NUMBER: 0043/662/8042-4167 

E-MAIL ADDRESS: guenter.dussing@salzburg.gv.at 

Summary 

Austria is a federal state. Government responsibilities, which are determined by the Federal Constitution, 

are shared by three levels of territorial authority: the federation, nine provinces (Länder) and the communities. 

In A there is no general competence for environmental matters, therefore they are spread out 

in numerous laws and regulations on the federal and provincial level. 

Execution is in Austria either performed by courts or by administrative bodies. Courts mainly deal with 

civil and criminal law whereas the execution of environmental law is in most cases performed by administrative 

bodies. One important principle in the Constitution concerning administration is the principle 

of legality which means that administration is strictly bound by law. 

Inspections and enforcement are also governed by the respective administrative laws, but the practice 

varies in the different provinces. There are no separate inspection bodies. 

Inspections are performed by the competent authority, by external experts and/or by self monitoring. 

The methods and frequencies of inspections and monitoring depend on the respective legal provisions 

or regulations, complaints by neighbours, experiencies of the authority and resources available. 

The respective legal provisions also provide for enforcement actions (e.g. to order certain measures or 

the shut down of an installation or parts of it) and sanctions (fines). The administrative penal precedures 

are usually performed by the county authority. 

For the implementation a working group, which consisted of representatives of the 9 provinces and the 

respective ministeries, was established. There was an agreement, that Austria should implement the RMCEI. 

An important step was the collection of informations, how environmental inspections are organized in 

each province and their capitols (because of the competences). Only some provinces are used to have 

an inspection planning and reporting system, but not for all environmental matters (mainly in the field 

of sewage plants). 

Some provinces started working out a concept or established a project group for implementing the 

RCMEI. In the province of Salzburg eg the concept shows: 

• how environmental inspections can be organized (administrative structure, resources etc.) 

• which installations are concerned (IPPC, VOC, sewage plants, waste disosal, etc.) 

• the competent authorities 

• a timetable (frequencies of invironmental inspections etc.) 

• provisions for planning and reporting 

At the end of 2002 an environmental inspection plan was created and discussed with all concerned 

authorities and experts. During this time also checklists were developed, for the preperatory work as well 

as for the inspection on site (using IMPEL reports). 

Since the beginning of 2003 environmental inspection corresponding to the RCMEI are carried out on


site. Most inspections are made by experts (air, waste and water) ordered by the competent authority. 

Reports are written after each inspection and are forwarded to the competent authority. 

At the end of 2003 a summary report and an evaluation of the inspection plan including the 

performance of the inspections on site will be made. 

SESSION: IMPEL at Work 


TITLE OF PRESENTATION: IMPEL’s Review Initiative 

NAME OF SPEAKER: Martin Murray 

ORGANISATION: Environment Agency 

ADDRESS: Rio House, Waterside Drive, Aztec West, Almondsbury, Bristol, BS32 4UD 

TEL. NUMBER: 00 44 1454 205561 

FAX NUMBER: 00 44 1454 624032 

E-MAIL ADDRESS: martin.murray@environmen-agency .gov.uk 

Summary 

In 2000 the IMPEL Network developed a voluntary scheme for reporting and offering advice on inspectorates 

and inspection procedures – the IMPEL Review Initiative “IRI”. The scheme was proposed against 

a background of preparation of a European Parliament and Council Reccomendation providing for 

Minimum Criteria for Environmental Inpections and implementation of the IPPC Directive. Terms of reference 

were agreed by IMPEL in May 2000. The review process including a questionaire and guidance 

developed and approved by June 2001 and to date inspection authorities in seven Member States have 

been reviewed. The last review taking place in March 2003. 

This presentation will describe the background to the review process and act as an introduction to 

discusions in Session 4 “Capacity Building”. The presentation will outline the review methodology and 

practical experience gained by the presenter and participants in taking part in the review process. 

The Future of environmental inspections and enforcement-A necessity or a waste of energy? 

forum discussion 


SESSION: The future of environmental inspections and enforcement 



TITLE OF PRESENTATION: The point of view of the Eropean industry 

NAME OF SPEAKE: Michel BRUDER 

ORGANISATION: UNICE 

ADDRESS: 4 rue des Menus, F 92100 Boulogne 

TEL. NUMBER: +33146990460 

FAX NUMBER: +33146055133 

E-MAIL ADDRESS: Michel.Bruder@wanadoo.fr 

Summary 

1 It is essential to mention that UNICE, on behalf of the European industry, is much in favour of the 

IPPC approach and collaborate actively to the development of the applications of the IPPC Directive,


which is mainly the development of the BREFs. The reason for that is the new, innovative approach of 

the Directive differing considerably from the classical “command and control” approach. This 

approach gives more flexibility and opens the possibility for optimal tailor made solutions. 

2 The process for conducting the writing of the 'permits' is co-operative between industry and local 

authorities in order to provide the best environmental results, taking into account the local situation, 

the existing techniques, their costs and a reasonable economical approach. This is also the reason why 

a national and local approach should be preferred to an centralized European approach, provided that 

it does not introduce distortions between Member States. 

3 Self monitoring is included in the basic principles of the IPPC directive. It is clear for the industry that 

self monitoring is indissociable from compliance testing. Compliance should be checked locally for 

each individual industrial installation, but also on a national and European level. Local authorities 

should of course have enough well trained staff for allowing that. 

SESSION: The future of environmental inspections and enforcement 



TITLE OF PRESENTATION: EEB statements-forumdiscussion 

NAME OF SPEAKER: John Hontelez 

ORGANISATION: European Environment Bureau 

Summary 

1. THE ROLE OF IMPEL IS IMPORTANT 

• Implementation and enforcement of EU environmental legislation is an essential element of an 

effective EU environmental policy. The EEB believes IMPEL mission “to protect the environment by the 

effective implementation of European Environmental law” sets a very ambitious goal. That is, to 

enable public authorities to fully serve the common goods rather than turning their eyes to specific 

interests. 

• IMPEL is an informal network, and the EEB duly appreciates its role in trying to tackle the challenge 

to practically implement legislation, which may have ambiguities due to political compromises laid 

down in the final versions of EU law. 

• Areas of established and successful IMPEL work include minimum criteria for environmental inspections 

and training of inspectors, comparison schemes and exchanges of information on the application 

of existing EU legislation relating to major industrial sources (IPPC), transfrontier waste shipments, 

and waste management operations. This is all very important. 

• IMPEL’s work is explicitly recognised in the 6th Environmental Action Programme. Article 3.2 is about 

encouraging more effective implementation and enforcement of Community legislation on the environment 

which requires, among other things: promotion of improved standards of permitting, inspection, 

monitoring and enforcement by Member States; and improved exchange of information on best practice 

on implementation including by the IMPEL network within in the framework of its competencies. 

2. PUBLIC PARTICIPATION, BOTH AT EU AND LOCAL LEVEL, IS AN ESSENTIAL PRE-REQUISITE TO 

ENSURE GOOD APPLICATION OF ENVIRONMENTAL LAW BY MEMBER STATES. 

• In its Third Annual Survey on the implementation and enforcement of Community environmental law 

January 2000 to December 2001, the Commission concludes that a strong increase in the number of 

new complaints per year has been identified since 1996. The sector of environment represented over 

a third of the complaints and infringement cases concerning instances of non compliance with 

Community law investigated by the Commission in 2001. In 2001, about 600 new complaints on 

environmental issues were lodged with the Commission.


• Increasing public concern on environmental issues, its greater awareness of Community environmental 

law and of the possibility to bring instances of non compliance to the attention of the Commission, 

in particular in the framework of Commission’s complaints handling, is mentioned among the main 

factors leading to the increasing number of environmental cases. 

• However, Implementation is a term, which covers a wider area than enforcement, as it also includes the 

process of converting general requirements into specific actions. This is no longer a process that exclusively 

takes place at national level. In Brussels, a number of advisory and technical committees hold 

meetings with representatives from member states, stakeholders, and also private bodies such as the 

European Committee on Standardisation (CEN). Many of these meetings are hold behind closed doors, 

and are based on diplomacy and lobbywork rather than effective participatory democracy. 

• The EEB believes that the establishment of mechanisms ensuring access to information, adequate 

public participation mechanisms and access to justice will contribute to fill the existing gaps in the 

implementation of environmental law. 

• In this context, the EEB supports a more structured dialogue between IMPEL and citizens’ organizations. 

3. VOLUNTARY AGREEMENTS ARE NO ALTERNATIVE TO LEGISLATION 

• Last May, the European Parliament adopted a resolution on the Commission's initiative to present the 

terms on which environmental agreements at Community level should be drawn up. It stated that it 

is necessary to define a series of essential prerequisites for the conclusion of an environmental agreement 

which would be valid irrespective of the specific sector to which the agreement is applied. 

Parliament suggested the following criteria: 

- the decision to make use of a voluntary instrument rather than a legislative act should be based on 

a comparative analysis of the potential impact of the two instruments in environmental, economic 

and social terms and in terms of administrative costs; 

- every voluntary instrument should indicate clear, quantified and measurable objectives, as well as 

the deadline for achieving them. 

- the risk of 'free riding' must be tackled 

- all the parties involved, and the civil society at large, should be informed of the intention to make use 

of a voluntary instrument and should be able to formulate observations at any stage in the procedure; 

- monitoring and assessment mechanisms and possible penalties in the event of the agreement being 

a failure should be clearly defined. Achievement of the objectives set and, where relevant, intermediate 

objectives, must be verified at regular intervals. Finally, The European Parliament and the 

Council should be kept informed by the Commission about the application of the agreement. If the 

results achieved do not meet the agreed objectives the legislator may ask the Commission to submit 

a legislative proposal to replace or supplement the environmental agreement. 

The European Parliament did not say it outright, but one can only conclude that it seriously distrusts 

the voluntary agreements approach. 

• Last June the OECD released a report concluding that voluntary agreements between governments 

and industry sectors aimed at achieving environmental objectives are neutral at best and potentially 

harmful. Indeed, environmental improvements appear no different from what would have happened 

with business-as-usual. Most voluntary agreements only play a small role in fulfilling environmental 

targets. In addition, administrative costs “tend to vary significantly”, and the fewer the resources allocated 

to the voluntary agreement, the more modest its environmental impact. Competitiveness 

concerns in certain industrial sectors, the report concludes, tend to be the main motivation for making 

voluntary agreements. Both in terms of environmental effectiveness and economic efficiency, however, 

“economy-wide economic instruments” would in most cases be “a better policy option than voluntary 

approaches”.


SESSION: The future of environmental inspections and enforcement- 



TITLE OF PRESENTATION: Prevention of pollution and of the risks: the owner is the first person being responsible 

NAME OF SPEAKER: Mrs Marie-Claude Dupuis 

Head of the Industrial Environment service 

Chief of the French environmental Inspectorate Impel national coordinator 

ORGANISATION: Ministry for Ecology and sustainable development 

ADDRESS: 20 Avenue of Segur 75302 PARIS 07 SP FRANCE 

TEL. NUMBER: + 33.1.42.19.14.40 

FAXNUMBER: + 33.1.42.19.14.67 

E-MAIL ADDRESS: Marie-Claude.DUPUIS@environnement.gouv.fr 

Summary 

Prevention of pollution and of the risks: the owner is the first person being responsible 

It is clear that the first person being responsible is the person who conceives, carries out and exploits the 

industrial installation. He has to produce the background information, to proceed to the necessary 

preliminary studies, to manage the divergences that use inevitably involves. His civil and penal liability 

will be engaged directly in the event of problems. This is a difficult situation that deserves our attention. 

But at the same time, this is one of the driving forces of environmental protection. The official authorities 

have to act carefully and shall not confuse their own role, not only for political reasons, but also for 

not losing the benefit of this motivation. 

In this regard self-monitoring by the owner is an essential tool for the protection of people and of the 

environment because it makes it possible for the company owner to follow the performances of its 

facilities from day to day, to detect the problems and to bring solutions in real time. 

Inspections by the public authorities are essential to ensure compliance with the rules by all and to 

maintain progress dynamics 

If the first responsibility belongs to the owner it is clear that not all industrial facilities do comply with 

the rules at the same level. In addition, pollution and accidents that continue to occur show that as 

regards risks full prevention cannot be acquired and that progress still remains to be done. For example, 

in France there was the tragic explosion in Toulouse in 2001 with 30 deaths and thousands of casualties, 

and due to the serious impacts on health in Northern France caused by the pollution of the soils, 

Métaleurop Nord was closed. 

This led to the adoption a new French law on 30 July, which aims at improving the prevention of 

accidental risks and providing better measures to close down certain activities. It is accompanied by a 

modernisation programme of the environmental inspection and by the creation of 400 additional posts 

for inspectors within the next 4 years. 

In the event of noticed non-compliance the availability of a range of adapted sanctions (penal, administrative, 

financial, media) appears to be essential in order to assure that inspections contribute to 

significant improvements. 

Harmonisation of the rules and of the practices at European level is the key of real progress 

European regulations on the environment are a very important factor to achieve a harmonisation of the 

existing rules between the various countries of the Union. 

Co-operation at European level by sectors of activities with the industries concerned, as it is done under 

the IPPC Directive, makes it possible to identify the prevention measures proportioned to the risks, based 

on the best techniques available and on the publication of guides of good European practices. 

But the harmonisation of inspections is also essential - in the interest of the citizens who we protect and


in the interest of the companies, which are entitled to equal treatments. In fact this is not easy within 

the same country, from one region to another, but far more challenging when it concerns 15 countries 

respectively 28 countries. In this regard the role of IMPEL is important because it makes it possible to 

exchange at a practical level among inspectorates/inspectors good practices. The European 

Recommendation of the Council and of the Parliament on Minimum Criteria for Environmental 

Inspection also helps us by providing a common framework common for our activities. 

In conclusion I would like to stress the necessary transparency which has to accompany the action of 

both, the owners and of the public authorities, as regards respect for the environment. In this regard, 

the European inventory EPER should have a positive impact by allowing a comparison of the performances 

among the industrial installations from different European countries. It is clear that the companies 

which make efforts to respect their environment and to reduce their harmful effects benefit from 

improving their image, with an inciting effect for those that do less. 

Résumé 

Prévention des pollutions et des risques : l’exploitant premier responsable 

Il est clair que le premier responsable est celui qui conçoit, réalise et exploite l'installation industrielle. 

C'est lui qui est en première ligne, c'est lui qui doit produire les éléments d'appréciation, procéder aux 

études préalables nécessaires, gérer les écarts que l'exploitation entraîne inévitablement. Sa responsabilité 

civile et pénale sera aussi directement engagée en cas de problème. Dure situation qui mérite 

notre estime. Mais en même temps, il y a là un des moteurs essentiels de la protection. Les autorités 

publiques doivent veiller avec soin à ne pas introduire de confusion de rôle, pas seulement pour des 

raisons politiques, mais aussi pour ne pas perdre le bénéfice de cette motivation. 

En ce sens l’auto surveillance par l’exploitant est un outil essentiel de protection des personnes et de 

l’environnement car il permet à l’industriel de suivre au jour le jour les performances de ses installations, 

de détecter les problèmes et d’y apporter des solutions en temps réel. 

Les contrôles par les pouvoirs publics sont indispensables pour s’assurer du respect des règles par tous et 

pour maintenir une dynamique de progrès 

Si la première responsabilité appartient à l’exploitant il est clair que toutes les installations ne 

respectent pas les règles au même niveau. Par ailleurs, les pollutions et accidents qui continuent à se 

produire ici où là prouvent qu’en matière de risque rien n’est jamais acquis et que des progrès restent 

encore à faire. En France on peut citer la tragique explosion survenue à Toulouse en 2001 qui a coûté 

la vie à 30 personnes et fait des milliers de blessés, ou encore les graves problèmes de gestion sanitaire 

liés à la pollution des sols rencontrés dans le Nord avec la fermeture de Métaleurop Nord. 

Ceci a conduit la France à adopter une nouvelle loi le 30 juillet dernier, visant à mieux prévenir les 

risques accidentels et à mieux encadrer les cessations d’activité. Celle-ci s’accompagne d’un programme 

de modernisation de l’inspection environnementale et de la création de 400 postes d’inspecteurs supplémentaires 

pour les 4 ans à venir. 

En cas de constations d’écarts importants l’existence d’un éventail de sanctions adaptées paraît indispensable 

pour que ces contrôles s’accompagne d’améliorations significatives (pénales, administratives, 

financières, médiatiques). 

Une harmonisation des règles et des pratiques au niveau européen est la clé de réels progrès 

Les réglementations européennes en matière d’environnement sont un facteur très important pour 

atteindre une harmonisation des règles existantes entre les différents pays de l’Union. 

La concertation au niveau européen par secteur d’activité avec les industriels concernés, à l’instar de ce 

qui se fait dans le cadre de la directive IPPC, permet d’identifier les mesures de prévention proportionnées 

aux risques, basées sur les meilleures techniques disponibles et sur la publication de guides de 

bonnes pratiques européens.


Mais l’harmonisation des contrôles est également indispensable, dans l’intérêt des citoyens que nous 

protégeons et dans celui des entreprises qui ont droit à des traitements équitables. Celle-ci n’est déjà 

pas facile au sein d’un même pays, d’une région à l’autre, que dire quand elle concerne 15 pays et maintenant 

28. En ce sens le rôle d’IMPEL est déterminant car il permet d’agir au niveau concret entre les 

inspections pour échanger les bonnes pratiques. La recommandation européenne du Conseil et du 

Parlement sur les critères minimum de l’inspection nous aide également en fixant un cadre commun à 

notre action. 

En conclusion je voudrais insister sur la nécessaire transparence qui doit accompagner l’action tant des 

exploitants que des pouvoirs publics en matière de respect de l’environnement. En ce sens l’inventaire 

européen EPER devrait avoir un impact positif en permettant une comparaison des performances d’un 

industriel à l’autre, d’un pays à l’autre. Il est normal que les compagnies qui font des efforts pour 

respecter leur environnement et réduire leur nuisances en tirent également un bénéfice au niveau de 

leur image de marque, avec un effet incitatif pour ceux qui restent à la traîne. 

New Instruments and Improvement of the current instruments, Session 1 

Tuesday, 7th. October 2003 

Session: New instruments and improvement of the current instruments 

Date: 7th. October 2003. 

Title of presentation: Welcome and introduction 

Name of speaker: Jan Teekens 

Organisation: Netherlands Ministry of Housing, Spatial Planning and the Environment 

Address: IPC 660, Postbus 30945, 2500 GX Den Haag 

Tel. number: +31703393777 

Fax number: +31703391302 

e-mail address: jan.teekens@minvrom.nl 

Session: New instruments and improvement of the current instruments 

Date: 7th. October 2003 

Title of presentation: Inspections and permitting as instrument to achieve 

environmental objectives. (Presentation of a new model to 

reach the superior goal – sustainable development.) 

Name of speaker: Jessica Mähler 

Organisation: The local authoritys in Eskilstuna municipality 

Address: Eskilstuna kommun, 631 86 Eskilstuna 

Tel number: +46 (0)16 – 10 20 38 

Fax number: +46 (0)16 - 13 18 35 

e-mail address: jessika.mahler@eskilstuna.se 

Name of speaker: Annelie Johansson 

Organisation: County Administrive Board in Jönköping 

Address: Länsstyrelsen I Jönköpings län, 551 86 Jönköping 

Tel number: +46 (0)36 – 39 50 72 

Fax number: +46 (0)36 – 12 78 45 

e-mail address: annelie.johansson@f.lst.se


Summary 

Swedish Environmental Protection Agency has, during the last year, together with two County 

Administrive Board (Jönköping and Sörmland) and two local authoritys (Tranås and Eskilstuna municipality) 

been in charge of a project to present a new model to use at inspections and permitting. The 

intention with the project is to develop an effective supervision based on the environmental objectives 

on purpose to reach sustainable development for the next generation. 

SESSION: New instruments and improvement of the current instruments 


TITLE OF PRESENTATION: Making Law: need or temptation? 

NAME OF SPEAKER: Valérie Drezet-Humez 

ORGANISATION: European Commission-DG Environment 

ADDRESS: Rue de la Loi 200 B-1049 Bruxelles 

TEL. NUMBER: +32.2.296.00.38 

FAX NUMBER: +32.2. 299.66.17 

E-MAIL ADDRESS: valerie.drezet-humez@cec.eu.int 

Summary 

Has recourse to Law-making become such a traditional and known field that it is an immediate and 

reassuring option for policy-makers? 

Law is not an untouchable set of principles built in stone but is now fully open to question and scrutiny from 

those who have to implement, enforce and report on it, and as such is not vested of any sacred status. 

As a means to achieve defined objectives, Law has to be assessed against its relevance and effectiveness; 

the ability to implement it and achieve policy objectives; the likelihood to induce long-lasting 

changes in its target groups. This means that use of Law has to be questioned a priori and not be taken 

as granted because of the nature of policing bodies. 

Questioning the past and building for future are the two work streams opened by the Commission in 

that respect under the reflection on European Governance. 

Actions foreseen to deal with the past will include consolidation, codification and recasting of the acquis. 

In parallel, improving the grounds of future legislation will require thorough rethinking of the whole 

policy-making cycle for all actors involved in its different stages from Commission initiatives to implementation 

and enforcement. 



TITLE OF PRESENTATION: Working with EU-law, accession country experiences and obstacles 

NAME OF SPEAKER: Stykova Anna-Barbora 

ORGANISATION: Slovak Inspectorate of the Environment 

ADDRESS: Karloveska 2, 842 22 Bratislava, Slovak Republic 

TEL. NUMBER: +421 2 6542 6950 

FAX NUMBER: +421 2 6542 33181 

E-MAIL ADDRESS: stykova@sizp.sk


Summary 

As an accession country the Slovak Republic has had a recent experience with the transposition of the 

acquis communautaire. Many pieces of legislation were enacted during the last two years when the work 

aimed at harmonization of Slovak environmental laws with those of the EC intensified. In the process of 

adaptation of rules of various directives into consistent up-to date Slovak legislation some difficulties 

were identified. 

Slovak Inspectorate of the Environment is a key environmental enforcement authority in the field of the 

environment. However, it as obvious that Inspectorate has not a lot of experiences with impacts of new 

environmental legislation in real life. 

It is important to keep a high level of environmental protection by consolidating environmental legislation. 



TITLE OF PRESENTATION: Introduction on feedback to policy, law and permitting 

NAME OF SPEAKER: Gustaaf Biezeveld 

ORGANISATION: Public Prosecutor’s office at The Hague 

ADDRESS: P.O. Box 19518, 2500 CM The Hague 

TEL. NUMBER: 0031703023254; 0031618302750 

FAX NUMBER: 0031703023222 

E-MAIL ADDRESS: ga.biezeveld@sgrarr.drp.minjus.nl 

Summary 

1. There is a difference between the world seen from the centre of Government and social and ecological 

reality. Therefore the focus of the policy maker and legislator must be on the reality of companies 

and the executive branch of the government. In other words: a execution-oriented attitude is required. 

The same applies to permitting officials. 

2. Companies and the executive branch of the government must help policy makers, legislators and 

permitting officials to catch sight of practical solutions and limitations. In two ways: by giving feedback 

and by giving advise. Both require specific organisational provisions. 

3. In a joint project of the Dutch Ministry of Environment and the Board of the Public Prosecutors 

activities have been undertaken to improve the implementability and enforceability of environmental 

legislation by bridging the gap between the legislative process and the enforcement branch of the 

government. Some results will be mentioned. 

4. It may be expected that by exchanging experiences in various member-states best practices can be 

learned and implemented at national and European level. 



TITLE OF PRESENTATION: Feedback to policy, law and permitting 

NAME OF SPEAKER: Karin Uhlenbrock 

ORGANISATION: Staatliches Umweltamt Lippstadt, 

ADDRESS: Lipperoder Str. 8 

TEL. NUMBER: 02941 / 986 - 315 

FAX NUMBER: 02941 / 986 - 350 

E-MAIL ADDRESS: karin.uhlenbrock@stua-lp.nrw.de


Summary 

Feedback from the point of view of immission-control in Germany 

Feedback to permitting 

Permitting installations allows to set standards and emission control measures before the installation is 

built. As a consequence, it is easier to convince the operators and to get the new standards. It allows to 

prescribe in detail the legal obligations and conditions under which the installation is to be used in 

order to prevent illegal immissions, especially for the direct neighbours. The permission is the basis for 

the inspections and for monitoring the plants. 

Feedback of experiences to permitting is important because the obligations and conditions of the permits 

are “tested” by the monitors on the possibility to enforce them. The feedback to permitting has the 

following instruments: 

- Direct feedback between the colleges permitting and the ones monitoring, 

- Regular quality circles to enrich the point of view, 

- Job rotation between the collegues permitting and controlling to get more experiences. 

feedback to law 

The Federal Immission Control Act of Germany contains clear and useful means and regulations, which 

are quite efficient to use and enforce. 

First there are clear legal obligations for the operators of industrial installations to get a 

permission(license) and fulfil it. The obligations are prescribed in detail in the permission. 

1. Then the monitoring authorities have legal tools to enforce these obligations:operators of illegal 

(altered) installations are to be given close down orders (§ 20 II) 

2. The operators of old installations can be ordered to follow the best available technique (usable, mild 

enough, proportional measures), especially to prevent harmful effects on the neighbours (§ 17), 

3. If an operator of an installation does not comply with a permit condition or an enforceable order the 

operation can be shut down until the plant complies with the permit. (§ 20 I) 

These regulations help our technical collegues to force the operators of industrial plants to comply with 

legal requirements and permission. Additionally the inspectors can use means of enforcement or fine 

the operators and win a court-hearing against them. 

The feedback of experiences to law is pursued 

- in regular circles with the Ministery of NRW 

- in reports to the Ministry, when asked to comment government drafts 

Feedback to policy 

There are not too many posibilities to feed back to policy, so I use this means today: 

- Feedback to federal law: go on 

- My feedback to european policy and law is the following pledge: not to alter the basis of our federal 

system of law too much/completely since it is very effective: 

- Clear legal obligations for the operators, (especially to get a permision and to fulfil it) 

- These obligations are prescribed in detail in the permissions 

- Clear effective legal/tools for the monitoring authorities to enforce the legal obligations.




TITLE OF PRESENTATION: The impact of inspection activities on policy, legislation and permitting 

NAME OF SPEAKER: Marek Mroczkowski 

ORGANISATION: Chief Inspectorate for Environmental Protection, Poland 

ADDRESS: ul. Wawelska 52/52, 00 922 Warsaw, Polan0d 

TEL. NUMBER: +48 22 825 98 15 

FAX NUMBER: +48 22 825 98 15 

E-MAIL ADDRESS: mamrocz@pios.gov.pl 

Summary 

In Poland the control and enforcement of environmental law compliance is, apart from the Inspection 

for Environmental Protection, also handled by other environmental agencies in accordance with their 

competence outlined in the appropriate acts and regulations. Bodies of the Inspection for Environmental 

Protection have been established under the Act on the Environmental Inspection Law and perform their 

tasks under the Environmental Protection Law and other environmental acts. 

In the Polish system bodies of the Inspection for Environmental Protection deal with the monitoring of 

the condition of the environment as well as the monitoring of environmental law compliance. They do 

this by way of scheduled inspections, control inspections and intervention inspections when they 

respond to complaints and requests of citizens. 

In 2002 bodies of the Inspection for Environmental Protection conducted 16,933 inspections in 13,929 

plants using the environment. At the end of 2002 48,844 plants were registered with voivodship inspectorates 

for environmental protection. 

The Inspection for Environmental Protection is not authorised to issue administrative decisions with 

respect to the rationing of the use of the environment. This right is held by heads of districts and voivods. 

At the same time, the Inspection can exert an impact on the development process of ecological permits. 

It does this by participating in the investment process as well as in the negotiations of the Adjustment 

Programme for those applying for integrated permits. 

The impact of the Inspection on the shape of ecological permits is also shown by its involvement in the 

preparation as well as the updating of relevant legislation. 

In 2002 the Inspection expressed its comments on 1407 draft documents, including acts, regulations, 

ordinances and position statements of the government. Among others, it presented its suggestions of 

amendments to the Act of 27 April on the Environmental Protection Law. Following the entry into force 

of the package of environmental legislation, the Inspection for Environmental Protection has prepared 

a great number of executive regulations to individual acts. 

Moreover, it has developed a number of topical reports and information on key and frequently discussed 

problems concerning the environmental protection. In 2002, for the third time, the Inspection prepared 

a report on the condition of the environment in Poland. The report was developed at the time of the 

remarkable overall reconstruction of Polish environmental legislation stemming from its adjustment to 

EU requirements. Therefore, the report closes the period of environmental assessments based on the 

principles and methods used in Poland.


The Chief Inspector for Environmental Protection and voivodship inspectors draft and publish numerous 

materials in the form of reports, bulletins and communications. In 2002 the series “Environmental 

Monitoring Library” was continued with a number of new titles being published. 

In 2002, within the EU integration process, the bodies of the Inspection for Environmental Protection 

also continued to cooperate with foreign agencies. Moreover, they performed tasks resulting from the 

implementation of various conventions and multilateral as well as bilateral international agreements. 

As regards the activities of the Inspections related to the EU integration process, particular attention 

should be drawn to its cooperation with the European Environmental Agency, the European Union 

Network for the Implementation and Enforcement of Environmental Law, and the execution of projects 

aimed at the institutional building financed through Phare funds. 

The implementation of the community environmental legislation provides for specific obligations of all 

environmental protection bodies, including the Inspection. The Inspection is currently facing new challenges 

covering all areas of its operations i.e. controlling compliance with environmental law, monitoring 

the condition of the environment and preventing Major industrial accidents. Streamlining the 

control system in the area of environmental protection is a continuous process, taking into account 

the experienced gathered to date as well as the needs stemming from various changes in the Polish 

economy and EU requirements. 

SESSION: New instruments and the improvement of current instruments 


TITLE OF PRESENTATION: How to make a permit with controlable regulations? 

NAME OF SPEAKER: Bathelier Christian 

ORGANISATION: 

ADDRESS: DRIRE Alsace 

TEL. NUMBER: 03 88 25 92 45 

FAX NUMBER: 03 88 36 98 13 

E-MAIL ADDRESS: christian.bathelier@industrie.gouv.fr 

Summary 

To dispose of a clear exploitation permitting of an industrial installation; precise, complete, if possible 

short, easy to inspect in the field, is, to my mind, a common wish to all the European inspectors. But is 

this concept really realistic as a whole? 

Indeed, a quick comparison of some different European countries permittings shows that these are 

always long documents in which regulations are often expressed with objectives to reach before to 

impose results to respect (standards of rejection for example), functions to be ensured and sometimes 

means. The reference to national texts that conform to the legislation is frequent. A preoccupation with 

the comprehension of the text and the exhaustiveness in the imposed regulations, quite naturally 

explains this manner of proceeding. 

Apart from its own drafting, the possibility to control a permitting rests, in my opinion, first of all on the 

request file’s quality, which is integral part of the control supports at the disposal of the inspection. That 

request file’s quality would necessitate indisputably to be improved in the sense that the increasing complexity 

in the requirements isn’t always well understood by the seekers, and because they do not always


imply as they should in the development of their own files. 

In front of the multiple interactions between the various components of the environment (water, ground, 

water table, waste, air, health…) including the risks, the permitting should be as possible a single document 

resting on a single file, thus privileging the integrated approach of pollutions and risks. 

The good control of an installation also depends on the explicit fixing of pertinent demands in matters 

of monitoring : values or functions to be respected (standards of emissions for the aqueous or atmospheric 

effluents, production of waste, noise, quality of the grounds, underground waters, documents 

on safety...). 

But, this control can’t be effective only if it goes with a transmission from the licensee, documents of 

quality accompanied with notes and not a multitude of values left to the inspection appreciation, these 

comments having to lead the owner to come to a conclusion on the anomalies met but also about the 

validity of the parameters selected, according to the evolutions being able to occur in his company. 

If the control of a permitting regulations about an industrial installation is an important question in the 

management of pollutions and risks, I find necessary in conclusion to indicate that the effectiveness of 

a control doesn’t rest only on the written formulation of a regulation but firstly on the competence and 

the perspicacity of the inspector charged to carry out this control and also on the active participation 

of the inspected licensee. 

Résumé 

Disposer d’un arrêté d’exploitation d’une installation industrielle clair, précis, complet, si possible court, 

facilement contrôlable sur le terrain, sanctionnable est, me semble t-il, un souhait commun à tous les 

inspecteurs européens. Mais ce concept est-il vraiment réaliste dans sa globalité ? 

En effet, une comparaison rapide de quelques permis de différents pays européens montrent que ce 

sont toujours des documents longs dont les prescriptions sont souvent exprimées en termes d’objectifs 

à atteindre avant d’imposer des résultats à respecter (normes de rejet par exemple), des fonctions 

à assurer et parfois des moyens. La référence à des textes réglementaires nationaux y est fréquente. 

Un souci de compréhension du texte et d’exhaustivité dans les prescriptions imposées, explique tout 

naturellement cette manière de faire. 

En dehors de sa rédaction propre, le caractère contrôlable d’un arrêté repose tout d’abord à mon sens, 

fortement sur la qualité du dossier de demande, qui fait partie intégrante des supports de contrôle à la 

disposition de l’inspection. 

Cette qualité des dossiers de demande nécessiterait sans conteste, d’être améliorée dans le sens où la 

complexité croissante dans les exigences réglementaires n’est pas toujours bien comprise par les demandeurs 

et dans le sens où ces derniers ne s’impliquent pas toujours comme ils le devraient dans l’élaboration 

de leurs propres dossiers. 

Devant les interactions multiples existantes entre les différentes composantes de l’environnement 

(eau, sol, nappe, déchets, air, santé..) y compris les risques, l’arrêté d’exploiter devrait être dans la 

mesure du possible un document unique reposant sur un dossier unique, privilégiant ainsi l’approche 

intégrée des pollutions et des risques. 

Le bon contrôle d’une installation dépend également de la fixation explicite d’exigences pertinentes en 

matière de suivi: valeurs ou fonctions à respecter (normes de rejets pour les effluents aqueux ou atmosphériques, 

production de déchets, bruit, qualité des sols ou des eaux souterraines, documents sur la 

sécurité…). Mais, ce contrôle ne peut être efficace que s’il s’accompagne d’une transmission de la part


de l’exploitant, de documents de qualité commentés et non pas d’une multitude de valeurs laissées à 

l’appréciation de l’inspection, ces commentaires devant conduire l’exploitant à se prononcer sur les 

anomalies rencontrées mais également sur la validité des paramètres retenus, en fonction des évolutions 

pouvant survenir dans son entreprise. 

Si le caractère contrôlable ou vérifiable des prescriptions d’un arrêté d’exploitation d’une installation 

industrielle, est une problématique importante dans la gestion des pollutions et des risques, il m’apparaît 

important en conclusion de signaler que l’efficacité d’un contrôle ne repose pas uniquement sur la 

formulation écrite d’une prescription mais prioritairement sur la compétence et la perspicacité de l’inspecteur 

chargé de mener ce contrôle et également sur la participation active de l’exploitant contrôlé. 



TITLE OF PRESENTATION: The enlargement of the IMPEL network: mutual support and necessary conditionsenvironmental 

management systems and permitting in Germany 

NAME OF SPEAKER: Bruno Reddehase 

ORGANISATION: Staatliches Gewerbeaufsichtsamt Hannover, 

ADDRESS: Germany 

Summary 

1. Situation in Deutschland/Niedersachsen 

In Deutschland wurden mit Stand Juli 2003 bisher 2364 Standorte ins EMAS-Register einge-tragen. 

Etwa die Hälfte der niedersächsischen Standorte führt das EMAS inzwischen nicht mehr weiter, so 

dass aktuell 46 EMAS-Standorte im Re-gister geführt werden. 

In Niedersachsen werden an ca. 2200 Standorten Anlagen betrieben, die nach dem Bundes-Immissionsschutzgesetz 

einer Genehmigung für Errichtung und Betrieb. 18 dieser Standorte genehmigungsbedürftiger 

Anlagen sind als EMAS-Standorte eingetragen. Das entspricht einem Anteil von ~ 0,8 %. 

Vergleichbare Zahlen für weitere Umweltmanagementsysteme liegen nicht vor. Erkennbar ist ein deutlicher 

Rückgang der EMAS-Registrierungen und ein verstärkter Trend zu Umwelt-managementsystemen 

nach DIN EN ISO 14001 (Stand Dezember 2002: in Deutschland 3700 Zertifikationen). 

2. Umweltmanagementsysteme und Genehmigungsverfahren 

Bei der Beantragung immissionsschutzrechtlicher Genehmigungen sind die zur Prüfung der Genehmigungsvoraussetzungen 

erforderlichen Unterlagen dem Antrag beizufügen. Angaben, die bereits in 

einer für gültig erklärten Umwelterklärung oder einem Umweltbetriebsprüfungsbericht enthalten sind, 

sind zu berücksichtigen (gilt nur für EMAS I und EMAS II). 

Im wesentlichen handelt es sich bei diesen Angaben um allgemeine Beschreibungen des Standortes, der 

Produkte und der Produktionsverfahren sowie der Umweltschutzorganisation. Umwelterklärung und 

Umweltbetriebsprüfungsbericht beschreiben beide den IST-Zustand eines vorhandenen Standortes mit 

seinen Einrichtungen und Anlagen. Genehmigungsverfah-ren dagegen prüfen zukunftsgerichtet im 

Detail geplante Änderungen und ihre zu erwarten-den Auswirkungen auf die Umwelt. 

Entscheidungsrelevante Angaben können somit naturge-mäß weder in der Umwelterklärung noch im 

Umweltbetriebsprüfungs-bericht enthalten sein.


Für das Zusammenspiel zwischen Antragssteller und Genehmigungsbehörde im Genehmigungsverfahren 

ergibt sich durch die unterschiedliche zeitliche Ausrichtung und Detailtiefe der Angaben kein 

praxisrelevantes Vereinfachungs- oder Erleichterungspotential. Niedersachsen unterstützt jedoch das 

Antragsverfahren neuerdings durch einen elektronisch gestützten Handlungsleitfaden, der gemeinsam 

von Verwaltung und Wirtschaftsverbänden entwickelt wurde. 

Umweltmanagementsysteme entwickeln allerdings betriebsintern ihren Nutzen vor Antragsstellung. 

Aufgrund der vorhandenen Organisationsstruktur ist ein schneller und umfassender Zugriff auf alle 

wichtigen und umweltrelevanten Daten der bestehenden Anlagen am Standort möglich. Der Aufwand 

für die Zusammenstellung der Antragsunterlagen reduziert sich damit auf die erweiterungs- oder 

änderungsspezifischen Ergänzungen des vorhandenen Daten-bestandes. 

Ein weiterer spezieller Nutzen von EMAS liegt für Standorte in Niedersachsen und einigen anderen 

Bundesländern in der Gewährung eines 30%-tigen Rabattes auf anfallende Verwaltungsgebühren in 

Genehmigungsverfahren. Nordrhein-Westfalen hat dies auch auf Umweltmanagementsysteme nach 

DIN EN ISO 14001 erweitert. 

3. Umweltmanagementsysteme und Überwachung 

Bundeseinheitlich bestehen für EMAS-Standorte Regelungen zur Überwachungserleichterung (EMAS- 

Privilegie-rungs-Verordnung). Diese zielen hauptsächlich auf Berichts- und Messpflichten sowie die 

Bestellung von Betriebsbeauftragten ab. Substanzielle Erleichterungen sind nur begrenzt vorhanden, da 

gesetzliche Anforderungen nicht aufgehoben oder eingeschränkt werden, sondern nur eine andere Form 

der Ausführung zugelassen wird. Nichtgenehmigungsbedürftige Anlagen sind von Überwachungserleichterungen 

nicht betroffen. 

Überwachungsintervalle werden entweder direkt in Genehmigungen (Messungen und sicherheitstechnische 

Prüfungen) oder als verwaltungsinterne Vorgaben festgelegt. Niedersachsen hat in 

Verwaltungsvorschriften die zyklische Überwachung bestimmter genehmigungsbedürftiger Anlagen 

geregelt. Störfallanlagen (Seveso-Richtlinie) sind jährlich, alle anderen genehmigungsbedürftigen 

Anlagen alle 3 Jahre zu überprüfen. Dabei soll sich die Überwachungstätigkeit vorrangig auf die Prüfung 

vorhandener Manage-mentsysteme beschränken und nur stichprobenartig Kontrollen von Anlagen 

enthalten. EMAS zertifizierte Betriebe sollen lediglich aus besonderem Anlass einer Betriebsprüfung 

unterzogen werden. 

Weitere Verwaltungsanweisungen betreffen formale Nachweisverfahren und wiederholen die bereits in 

der Privilegierungsverordnung genannten Erleichterungen zu Berichts- und Messpflichten. 

4. Schlussbemerkungen 

Nennenswerte substanzielle Erleichterungen bei der Durchführung von Genehmigungsverfahren oder 

bei der Überwachung von Betrieben mit Umweltmanagementsystemen haben sich in Deutschland bisher 

in der Praxis weder für Unternehmen noch für Aufsichtsbehörden ergeben. 

Umweltmanagementsysteme leisten zwar als innerbetriebliche Instrumente einen erheblichen Beitrag zur 

Verbesserung des jeweiligen Umweltschutzstandards, haben aber bisher nicht ihren Platz als 

wirkungsvolle Instrumente im Zusammenwirken betrieblicher und staatlicher Umweltschutzbemühungen 

finden können.


SESSION: New instruments and improvement of current instruments 

DATE: 7th October 2003 

TITLE OF PRESENTATION: Environmental Management Systems and permitting in Ireland 

NAME OF SPEAKER: Valerie Doyle 

ORGANISATION: Environmental Protection Agency 

ADDRESS: P.O. Box 3000, Johnstown Castle Estate, Wexford, Ireland 

TEL. NUMBER: + 353 53 60600 

FAX NUMBER: + 353 53 60699 

E-MAIL ADDRESS: v.doyle@epa.ie 

Summary 

Environmental Management Systems and permitting (Ireland) 

A presentation on the experience in Ireland to dates on the incorporation of environmental mangement 

system (EMS) into the IPC Permits. 

Ireland includes a mandatory EMS as part of the IPC permit. In regulation of permits the Environmental 

Protection Agency has focused its efforts in four main areas, checking information reported from the 

licencees, monitoring of emmissions, site inspections/audits and enforcement. This presentation will 

focus on the benefits and constraints of having an EMS in the permit with respect to regulation of permits. 

The presentation will focus on the prospective of the regulator/inspector. 



TITLE OF PRESENTATION: Flexible instruments and the changing role of inspectors 

NAME OF SPEAKER: Chris Howes 


ADDRESS: Rio House, Aztec West, Almondsbury, Bristol 

TEL. NUMBER: 01454 624029 

FAX NUMBER: 

E-MAIL ADDRESS: chris.howes@environment-agency.gov.uk 

Summary 

When environmental regulation was based upon direct styles of command and control legislation, the 

role of the inspector was, in theory at least, straightforward. 

However, now that a new breed of environmental instruments have been developed, and the potential 

benefits from command and control styles of regulation have largely been gained, the potential roles of 

the inspector in Europe have also changed. 

This presentation will discuss those changing roles with regard to: 

Negotiated agreements; 

Voluntary agreement 

Framework permits; 

Market based instruments, such as emissions trading schemes; 

Environmental management systems (such as ISO 14001 and EMAS); 

Environmental standards based legislation; 

IPPC.


It will not only outline how the roles have changed but also look at the potential consequences for competencies 

and recruitment, the expectations of industry and the public, as well for the inspector. 

SESSION: New instruments and improvement of the current instruments. 


TITLE OF PRESENTATION: The use of flexible instruments in Bulgaria 

NAME OF SPEAKER: Ivona Grozeva 

ORGANISATION: Ministry of Environment and Water 

ADDRESS: 67 “W. Gladstone” Str., 1000-Sofia, Bulgaria 

TEL. NUMBER: + (359 2) 940 6001 

FAX NUMBER: + (359 2) 981 66 10 

E-MAIL: ji_grozeva@moew.government.bg 

Summary: 

The use of Flexible instruments in Bulgaria 

Bulgaria joined the international efforts in addressing Climate Change issue and demonstrated its commitment 

to it by ratifying the UNFCCC in 1995 and the Kyoto Protocol in 2002. According to the 

Protocol, the Bulgarian target during the first commitment period is to achieve greenhouse gases (GHG) 

emission reduction of 8 % compared to the levels of base year 1988. Currently the GHG emissions level 

in the country is about 45 % of the level in the base year. 

In spite of the large amount AAUs currently available the forecasts show that the country may achieve 

the target set in Kyoto only in case an active policy for GHG emissions reduction is implemented. 

The measures already taken, however, guarantee not only achievement of the target, but also the availability 

of residual that can be traded in the period 2008 – 2012. 

The GHG mitigation policies and measures in the country are set in the National Climate Change Action 

Plan (NCCAP) adopted in 2000. The Plan states as a strategic priority the use of Flexible mechanisms, 

in particular Joint Implementation. 

Bulgaria already has certain experience with the Joint Implementation mechanism. In 2000 a 

Memorandum of understanding in this relation was signed with the Kingdom of the Netherlands. A JI 

Unit was established for coordination of activities, information dissemination, assessment of projects, 

etc. Currently the Unit exists as a JI sector within the Ministry of Environment and Water. 

In 2002 similar Memorandum and an Agreement were signed and ratified with the Government of 

Austria and the Prototype Carbon Fund (PCF) of the World Bank. In June 2003 an Agreement with 

Switzerland was officially finalised and its ratification by the National Assembly is expected to take 

place until the end of the year. Undergoing are negotiations on with Denmark. Germany, Japan, Canada 

and other countries have also expressed interest in the area of Joint Implementation projects. 

The JI projects proposed so far are in the following areas: 

Eru-PT 3 

• Gasification 

• Collection and utilisation of landfill gas 

Austria 

• Hydro power plant


• Energy Efficiency and co-generation 

Prototype Carbon Fund 

• Utilisation of biomas 

• Energy efficiency 

Switzerland 

• Energy efficiency 

• Denitrification of waste water 

The assessment of the proposed projects is performed by a Steering Committee, which consists of 11 

members – representatives of all relevant ministries and institutions in the country. In this way the projects 

are assessed in a transparent way. 

Based on the assessment of the SC the Minister of Environment and Water approves the projects as JI. 

Bulgaria is currently under negotiations with the EU about accession, which will result in possible EU 

membership in 2007. How will the JI potential in Bulgaria develop depends also on the timing of entry 

into the EU and the transitional arrangements that will be negotiated. It is probable that the adoption 

of the European environmental Acquis will reduce the scope for JI. In this case Bulgaria may consider 

using JI early action, in which respect the relationship between the EU emission trading scheme and JI 

projects would be of interest. 

Regarding the possible integration between the JI and ET scheme, it will be important how implementation 

of the Directive on Emissions trading will account for JI credits. When the new EC 

Directive on Emissions trading comes into force, it will directly have an impact on the potential of 

Joint Implementation. The discussion will probably focus on the extent to which JI will be used in the 

trading scheme. The EU may decide to limit the number of JI credits that firms can acquire, or decree 

that credits from certain projects, such as sinks, are not eligible for meeting the cap. However, this 

probably means that JI will become embedded in the overall EU ETS, and that future EU member 

states therefore should focus their policy efforts on building the necessary legal and trading infrastructure 

for emissions trading. It also means that companies now investing in industrial facilities in 

the candidate countries should be aware of the impact that the allocation of CO2 allowances has 

on their performance. If the industrial facilities in the candidate countries are governed by the EU 

Emissions Trading Directive, Joint Implementation is only applicable for the non-participants. This in 

turn means smaller transactions and relatively higher costs. 

In conclusion, the use of “flexible mechanisms” in Bulgaria could be a determining element for the selection 

of a development strategy of the country, as well as a valuable source of economic and environmental 

benefits. For this purpose it is necessary that a strategy for the participation in the Kyoto mechanisms 

is developed, as the economic and environmental potential for Bulgaria is preliminary investigated. 



TITLE OF PRESENTATION: Voluntary Agreements – The Changing Role of Inspectors 

NAME OF SPEAKER: Grassmann, Franz 

ORGANISATION: Environment Office Wuensdorf 

ADDRESS: Amt f. Immissionsschutz Wuensdorf, Am Baruther Tor 12, 

D-15838 Wuensdorf, Germany 

TEL. NUMBER: +49 33702 73101 

FAX NUMBER: +49 33702 73107 

E-MAIL ADDRESS: Franz.Graszmann@afi-wdf-brandenburg.de


Keywords: self-commitment, agreement under public law, discretionary power, confidence-building 

measures 

Summary 

Voluntary agreements and self-control mechanisms will also lead to comparable results for the environment 

than traditional administrative actions can do. This is especially important with the increasing 

deficit of the enforcement due to the growing lack of states´ personnal and financial resources. 

In continuing the presentation Dr. Weigand gave at Villach in 2000 the changing role of inspectors will 

be illustrated with help of two categories of voluntary agreements: 

1. Self-commitments as agreements between the industry in general or an industrial branch and a federal 

state or a ministry of the federal state 

2. Agreements between the authority or the administrate body and the operator of an individual installation 

to avoid administrative actions 

The changing role of the inspectors from command and control to more contracting and consulting 

will be shown on concrete examples. The different forms and the legal character of the agreements 

influence the profession of the inspectors in special ways. 

The benefits and disadvantages of voluntary agreements on the side of the administrate body will be 

discussed. 

SESSION: New instruments and improvement of current instruments 


TITLE OF PRESENTATION: New influences: Merging economy and environmental protection 

NAME OF SPEAKER: Prof. Mikael Skou Andersen, 

ORGANISATION: Dept. of Policy Analysis, National Environmental Research Institute, 

ADDRESS: Grenaavej 12, DK-8410 Roende 

TEL. NUMBER: +45 89201555 

FAX NUMBER: +45 89201515 

E-MAIL ADDRESS: msa@dmu.dk 

Summary 

After more than a decade of “good will” in favour of the environment, citizens and policy makers are 

becoming more hesitant and are raising questions about the effectiveness and efficiency of environmental 

policies. To protect the environment is a long-term exerise, and the absence of short-term visible 

improvements in environmental conditions may lend support to some of the doubts being expressed. 

These doubts run contrary to the philosophy of ecological modernisation, which underpinned environmental 

policy in the 1990's in the European Union and many member states. According to the philosophy 

of ecological modernisation it makes sense to protect the environment, not only from an environmental 

viewpoint, but also from an economic one. There is, it has often been claimed, a “double dividend” 

from environmental regulations, one of both environmental improvements and of increased employment 

and prosperity. Measures to protect the environment will cause new technologies to be developed, and 

new markets to become available. It will increase the overall welfare of society, it was claimed.


Yet, ecological modernisation now adays stands a cross-road: can the economic benefits be substantiated? 

If the first environmental dividend is long-term, where is the second economic dividend? Can we 

account for the economic advantages of environmental regulations ? 

In this presentation there will be focus on the new influences emerging from this debate on the economic 

benefits of environmental regulations, a debate which has been intense in both Denmark and 

several other member states in rcent years. 

Issues covered in the presentation will include; 

- what do we know about the costs of environmental regulations, and how significant are they in comparison 

with other expenditure areas ? 

- which areas of environmental protection are the most burdensome and why ? 

- how can we account for the benefits ? 

- can we trust environmental valuation, asking willingness-to-pay questions ? 

- should we prefer cost-effectiveness or cost-benefit analysis ? 

Mikael Skou Andersen, previously of Aarhus University, is now employed at the National Environmental 

Research Institute, part of the Danish Ministry of the Environment. He is author of several books incl. 

“Market-based instruments for environmental management” (2001). 

The role of inspections and different approaches , Session 2 


SESSION: The role of inspections and different appoaches 


TITLE OF PRESENTATION: Strategy, tactics and operational enforcement in Limburg 

NAME OF SPEAKER: E. Steijnebrugh, Manager Department for Enforcement and Monitoring of the Province 

of Limburg 

ORGANISATION: Province of Limburg 

ADDRESS: P.O. Box 5700, NL-6202 MA Maastricht 

TEL. NUMBER: +31(0)433898868 

FAX NUMBER: +31(0)433897659 

E-MAIL ADDRESS: ew.steijnebrugh@prvlimburg.nl 

Summary 

In this contribution the enforcement strategy of the Province of Limburg will be presented. 

The strategic target is the compliance of companies and citizens towards environmental law and legal 

standards. The instruments wich are used to achieve this target will be discussed (tactical level). 

Not only the traditional instruments like preventive surveillance and the use of criminal legislation for 

enforcement purposes but also new instruments like mediation, communication and the use of environment 

magement systems, including self-auditing seem useful instruments. On operational level the 

strategic target and tactical intstruments for enforcement are translated into programs. 

Due to the restircted amount of finances and manpower, a system of priority-ranking is inevitable. The 

funnel-model of the Province of Limburg for the enforcement of the major rules and requirements of a 

permit will be presented.


In order to demonstrate the system in daily practice two enforcement cases will be explained. 

The first one discribes the enforcementprocess for a quite complex plant in the chemical process-industry, 

the other one discribes the process for a simple car-demolition yard. 

Finally the results of the enforcement strategy as well reporting to the responseble political board will 

be an issue of this contibution. 

SESSION: The role of inspections and different approaches 

DATE: 7th.October 2003. 

TITLE OF PRESENTATION: Different perspectives on approaches to inspections 

NAME OF SPEAKER: Erik Forberg 

ORGANISATION: Norwegian Pollution Control Authority 

ADDRESS: P.O. box 8100 dep, N-0032 Oslo Norway 

TEL. NUMBER: +47 22 57 34 46 

FAX NUMBER: +47 22 67 67 06 

E-MAIL ADDRESS: erik.forberg@sft.no 

Summary 

During this short presentation I will try to present some of the effects an Environmental Management 

System can have on inspections and inspectors. 

In Norway all industrial installations are obliged to implement such a system due to a regulation from 

the early nineties. This has affected the inspections in many ways, of which I will focus on the following: 

1 Our focus has moved a little from checking compliance on the installation in retrospect, to more looking 

at the installations capability to comply in the future, even though we still do checks on compliance. 

2 Our focus on management systems makes us use more time on the installations management, their 

goal-setting, follow-up and other activities. This is important, because if the management is not sufficiently 

involved and committed, the system will soon be just documents and not a living system. 

3 Those two first points has changed our inspectors role more to the role of an auditor, and the need 

for good communication skills are more pronounced. 

4 As a result of this mandatory requirement for a management system it is possible to simplify the permitting. 

More responsibility is clearly laid on the installations. Most permits are now therefore framework 

permits. The majority of industrial activities will during the next two years probably be regulated 

by general binding rules/regulations, and not by individual permits.



DATE: 7th.October 2003 

TITLE OF PRESENTATION: Application of minimum criteria for environmental inspections in Bulgaria 

NAME OF SPEAKER: Nikolay Kenanov 

ORGANISATION: Ministry of Environment and Water of Bulgaria 

ADDRESS: Bulgaria, Sofia, 67 W. Gladston street 

TEL. NUMBER: +3592 9406387 

FAX NUMBER: +3592 9813384 

E-MAIL ADDRESS: Kraps@moew.government.bg ; Djeleva@moew.government.bg 

Summary: 

Application of minimum criteria for environmental inspections in Bulgaria 

The purpose of the minimum criteria application for environmental inspections in Bulgaria is: checking 

and promoting the compliance of controlled installations with the requirements set for them in the 

national legislation or with the issued permits. 

The inspections are carried out: 

1 By all the competent authorities according to our national legislation; 

2 Operators of the controlled installations. 

The main steps in an environmental inspection are: 

1 Detailed inspection plan; 

2 Site visits - routine, non- routine and follow up; 

3 Reports and conclusions. 

The structure of the MOEW is: the Ministry as a governing body, 15 RIEWs (Regional Inspections of 

Environmental and Water), 3 National Park Directorates and 4 BD (Basin Directorates). The control 

activities of the 15 RIEWs are co-ordinated by the Department for co-ordination of the RIEW within the 

MOEW. The EEA (Environmental Executive Agency) is an administrative body to the MOEW for managing 

the national automatic system for environmental monitoring. 

As for our environmental legislation - Bulgaria is coming to the end of the process of harmonization of 

its environmental legislation. 

The planning of the environmental inspections is done at regional level by the RIEWs through their 

annual plans, which are drawn up by them and approved by the Director for coordination of the RIEWs 

and the respective Deputy Minister. The annual plan of each RIEW contains data for the number of controlled 

installations on its territory and these installations are divided in three groups: 

- Permitted installations - 1594; 

- Installations requiring permits - 1626; 

Installations for which permits are not required, but included in the planning list of the 

respective RIEW and are subject of control - 2153. 

Each RIEW composes a monthly, semiannual and an annual report on the environmental activities in the 

region which is submitted to the Coordination of RIEWs Directorate. This report contains data about the 

number of controlled installations, the number of inspections carried out, the number of reports drawn 

up against polluters, the number of issued penalty statements and the number of sanctions imposed. 

Also every year the Ministry composes a report on the state of environment in the country, which report 

is endorsed by the Parliament.




TITLE OF PRESENTATION: Compliance Assessment Plans 

NAME OF SPEAKER: David Pugh 


ADDRESS: Head Office, Rio House, Waterside Drive, Aztec West, 

Almondsbury, Bristol, BS32 4UD, United Kingdom 

TEL. NUMBER: 44 1454 205549 

FAX NUMBER: 44 1454 624032 

E-MAIL ADDRESS: david.pugh@environment-agency.gov.uk 

Summary 

The Environment Agency (England and Wales) is developing and implementing a risk based approach 

to compliance assessment, particularly with respect to permits issued for IPPC Directive installations. 

This will look to prioritise resources and inspections on nationally and locally identified outcomes. The 

presentation will outline one of the tools the Environment Agency is developing to support this 

approach; namely Compliance Assessment Plans. 

SESSION: The role of inspection and different approaches 


TITLE OF PRESENTATION: The French way of prioritising inspection 

NAME OF SPEAKER: Pascal Barthe 

Senior French environmental inspector 

ORGANISATION: Direction régionale de l’industrie, de la recherche et de l’environnement 

DRIRE Midi-Pyrénées 

ADDRESS: 12, rue Labrousse BP 1345 TOULOUSE Cedex FRANCE 

TEL. NUMBER: +33.5.62.14.90.49 

FAX NUMBER: +33. 5.62.14.90.01 

E-MAIL ADDRESS: pascal.barthe@industrie.gouv.fr 

Summary 

In France, the Ministry of Ecology and Sustainable Development (MEDD) has overall responsibility for 

inspection and enforcement, which is exercised at National level through its Directorate for the Prevention 

of Pollution and Risks (DPPR). At Regional level, the main executive responsibility for inspection rests with 

the 24 Regional Directorate for Research and Environment (DRIRE), although the Directorate for 

Veterinary Services (DDSV) is responsible for inspection of farming and agro-food activities. 

Environmental inspectors are both in charge of permitting and enforcement through an integrated 

approach for pollution and risk prevention where all the existing aspects are taken into account ( water, 

air, waste, noise, risk..) 

The 24 DRIRE have the responsibility of 33 000 establishments, including 5000 IPPC and 1200 Seveso, 

with a staff of 1000 people including 700 inspectors in. That requires a high level of prioritisation. 

Every year, priorities are defined at a national level and implemented at the regional and local level. 

Regional priorities are also defined to complete the national ones, because of local differences.


In the region MIDI- PYRENEES there is a special way to calculate the time available and to plan the 

activities following the defined frame of priorities. The implementation is followed and assessed through 

special tools. Thanks to this assessment, new priorities are prepared for the next year. 



TITLE OF PRESENTATION: Environmental inspections in Herning Municipality, Denmark 

NAME OF SPEAKER: Gert Thorhauge Andersen 

ORGANISATION: Herning Municipality, Environmental Division 

ADDRESS: Rådhuset, Torvet, DK7400 Herning, Denmark 

TEL. NUMBER: 45 96 28 26 63 

FAX NUMBER: 45 95 28 29 80 

E-MAIL ADDRESS: mjoga@herning.dk 

Summary 

In Denmark local authorities are responsible for environmental inspections. A part of the inspections are 

done by the counties, mainly on bigger and more complicated industries, the rest are left to the municipalities. 

According to the environmental protection Act the municipalities monitors overall compliance 

with the Act and the rules laid down under the Act. 

Because of the small size of municipalities in Denmark, most environmental inspectors also have other 

jobs in the municipalities, for example approvals or permits, waste handling, handling sewers and wastewater 

treatment plants, soil pollution, water supply or different planning tasks. As a consequence of this 

is environmental inspections actually are an integrated part of all the activities taking place in the technical 

departments. 

In Denmark industry is dominated by small and medium sized companies. In Herning Municipality 

(58000 inhabitants) this is illustrated by the following figures on types of industry: 

IPC Approval Other 

Metal 4 24 53 

Wood - 13 39 

Textile - 5 35 

Animal 15 - 382 

Autorepair - - 111 

Other - 33 94 

All of these companies will have inspections with frequencies varying from once a year to once 

every 4 years. 

Since the adoption of the environmental protection act in 1974 the focus of environmental administration 

has changed. In the seventies the focus was on approvals of industries. More than 140 approvals 

of industries were given in Herning from 1974 to 1985. Inspections were mainly carried out when neighbours 

complained about noise, dust or smell. 

From the mid-eighties the local authorities had to do inspections actively, not waiting for complaints. It 

was expected that municipalities used approximately 1 year per 10000 inhabitants on inspection. 

Illegal conditions should be legalized.


From the mid-nineties environmental problems were moving into focus. In 2001 the City Council accepted 

an actionplan for the Environmental Division. The plan describes the prioritized environmental problems, 

as we see them in Herning, and what we will try to do about these problems. Several projects have 

been carried out in the last 7 years and inspections are now in many cases related to one or more projects. 

SESSION: The role of inspections and different approaches, Brainstorming Session 2 Group 1 


TITLE OF PRESENTATION: To what extent can self-monitoring replace inspections? 

NAME OF SPEAKER: Erkki Kantola 

ORGANISATION: Northern Finland Environmental Permitting Authority 

ADDRESS: P.O.Box 113, FIN-90101 Oulu, FINLAND 

TEL. NUMBER: +358-400-892001 

FAX NUMBER: +358-8-5348550 

E-MAIL ADDRES: erkki.kantola@ymparisto.fi 

Summary 

The Finnish Self Monitoring system in a nutshell 

According to IPPC Directive and the corresponding national legislation an operator is responciple to 

carry out monitoring of emission. In addition to that the environmental permit contains requirements to 

monitore processes but also impacts to environment. 

Plant-specific self-monitoring, particularly in industries involving complex processes, comprises monitoring 

of emissions and the state of the process. This approach ensures a comprehensive view of the emissions 

and the factors impacting them. As this procedure produces a great deal of data, it is essential 

that the authorities and operator agree beforehand on the extent of reporting. 

Monitoring of processes provides important data and information that the operator can directly use to 

control the processes in order to minimize the emissions and to prevent malfunction and breakdown that 

usually create bigger emissions than the normal operation. Operators are also allowed to carry out emission 

monitoring themselves if they fulfill certain requirements. These requirements are consistent with 

those listed in the paper “Operator Self Monitoring” presented by the IMPEL Network in February 1999. 

When operators are not able to carry out emission monitoring themselves (typically SMEs, but also many 

bigger enterprises), it has to be undertaken by independent consulting companies. Statutory impact 

monitoring must always be conducted by independent companies, research institutes or the like - operators 

are not allowed to do it. Operators must bear the costs of all forms of monitoring. 

Consulting companies and research institutes undertaking emission and impact monitoring have to 

prove their competence via accreditation, certification or an approval by the competent authorities. 

The permitting and supervising authorities review and approve self monitoring programmes proposed 

by operators. The supervising authorities must also ensure that self-monitoring carried out properly and 

that the measurement data obtained are reliable.



DATE: 7th. October 

TITLE OF PRESENTATION: Simultaneous measurements by portable equipment with electrochemical analysis 

of emissions of air pollution using Certified reference materials 

AUTHORS: J.F. Rilo; A.Saez; M.F.Couto; E.Fariñas; M.Costoya. 

ORGANISATION: Environmental Laboratory of Galicia (LMAG) 

Consellería de Medio Ambiente 

ADDRESS: Xunta de Galicia, Spain 

Summary 

The measurement of air pollution at emission points poses problems regarding: 

1 Who does the measuring? 

2 The measuring procedure. 

3 The comparison of the results between different external laboratories and the LMAG (Environmental 

Laboratory of Galicia). 

The simultaneous measurement of emissions by different organizations entails the following difficulties: 

1 The points for measuring are always fixed, but the sample concentrations vary with the gas flow. 

2 The number of people involved, access to equipment and the security norms for working at heights 

make it physically impossible for more than one measuring team to be present. 

3 The comparison of the measurement of emission requires portable, calibrated emission equipment. 

4 The variability of the flow of the emission produces differences in the results. 

To tackle this problem, the LMAG made an experimental comparison by simulating a fixed point with a 

controlled volume of emission and easy access to the multiple apparatus. 

The experiment consisted in the simultaneous measurement of air pollution with a guaranteed flow and 

concentration at each point where the measurement was made. 

The objective was to carry out simultaneous measurements of gases at different concentrations 

(obtained by dilution), using portable equipment and electrochemical analysis. 

A dilution system to obtain different concentrations was used with sufficient volume (approximately ten 

litres) for simultaneous measurement by six apparatus as shown in Table 1. The gases are diluted with 

air in an artefact and then connected to the measuring equipment. 

The gases used are SO2, NO and CO, because they are the most commonly occurring in the measurements 

undertaken in emissions with portable equipment. They are supplied with the corresponding certificate 

(SCS) with an uncertainty of 0,6 % for SO2 and NO and 0,5% for CO. 

The concentration values where the measurements were made are as follows: 

Canal Range Conc 1 Conc 2 Conc 3 Conc 4 

SO2 15 ppm-5.000 100 500 1000 2000 

(4492 ppm) ppm 

NO 25 ppm-3.000 100 250 500 2400 

(2299,8 ppm) ppm 

CO 40 ppm-3.000 100 500 1000 2400 

(3000 ppm) ppm 

Table 1. Initial gas concentrations and values generated by dilution.


The methodology is based on a proposal in the document CTM-34 (ICAC Test Meted for Periodic 

Monitoring) of the EPA. Eight values are taken over a period of two minutes for each batch of measurements, 

repeating four batches at every point obtaining 32 data facts for each one of the concentrations 

indicated in Table 1. When the process of obtaining information is completed, air is passed through 

the conduit for eight minutes, followed by a gas concentration for two minutes. 

From these values, we can determine an associated uncertainty as well as the maximum deviation. 

Information about the line can also be obtained from the illustrated graphics with the four points used. 



TITLE OF PRESENTATION: How do enforcement actions contribute to environmental improvement? 

NAME OF SPEAKER: Aare Sirendi 

ORGANISATION: Environmental Inspectorate 

ADDRESS: Kopli 76, 10416 Tallinn, Estonia 

TEL. NUMBER: +37251 01590 

FAX NUMBER: +372 696 2237 

E-MAIL ADDRESS: Aare.Sirendi@kki.ee 

Summary 

Under enforcement actions we understand the use of sanctions (fines) against violators of environmental 

legislation and also using the other administrative or court actions including issuing of orders requiring the 

operator to take actions or to stop the activity. The aim of these actions is to warn the violators and also 

potential violators to avoid the infringements of environmental legislation. While in many advanced 

European countries fulfilling the environmental law is the question of good image of the company in 

Estonia few years ago it was still the question of getting the smaller profit from the business and environmental 

investments were often avoided. Inspectorate started to use its enforcement power more actively 

5-6 years ago. During that time there was still quite a lot of industries who operated without environmental 

permits. Now it is hard to find any industry who does not know what is environmental permit. But still there 

is a need to use administrative sanctions against those who violate the requirements of permit. 

We have had a case when one oil transit company was quite ignorant to environmental permit requirements 

and used to load often those oil products that were not allowed by the permit. Also they refused 

to set up any monitoring station to measure its influence to ambient air. When Inspectorate stopped 

their activity due to the violation of environmental permit requirements they were quite in trouble (the 

mobile containers full of oil where coming by rail from one side and an empty ocean tanker was arriving 

to the port from the other side). After that they agreed to all environmental conditions only to get 

the permission to continue their operations. 

There has been cases in Estonia when the operators refuse to let the inspector to the site. According to 

the legislation the environmental inspector can start the administrative or criminal case against those 

who resist to the inspectors right to check the site when needed. We have the examples when this 

enforcement power has been used by the inspectors. 

The usage of administrative and criminal sanctions is also giving the feedback to the legislators as all 

the weak points in the law will be revealed during the Court procedure.This will avoid the possibility that 

the real big violators of environmental law will get no punishment because of the weaknesses and 

“holes” in legislation.


In general it is obvious that the activities of Environmental Inspectorate have forced the industry to 

invest more than they would have wished to do. Certainly there are a lot of other measures to guarantee 

the environmental improvement. 



TITLE OF PRESENTATION: How do enforcement actions contribute to environmental improvement? 

NAME OF SPEAKER: Fernando Figueira 

ORGANISATION: Inspectorate-General for the Environment (Portugal) 

ADDRESS: Rua de “O Século”, nº 63 – 1249-033 Lisboa 

TEL. NUMBER: +351 21 3215500 

FAX NUMBER: +351 21 3432777 

E-MAIL ADDRESS: ffigueira@ig-amb.pt 

Summary: 

Short perspective on the portuguese Inspectorate, followed by na essay on the role of enforcement 

policy and compliance policy in Portugal; finally, a policy assessment will be presented, through the use 

of different indicators for that purpose, supported with examples & new proposals for 2003, future 

perspectives and summary conclusions from the presentation. 



TITLE OF PRESENTATION: Effectiveness and efficiency of environmental inspections 

NAME OF SPEAKER: Paul Bernaert 

ORGANISATION: The Flemish Environment Inspection Section (Belgium) 

ADDRESS: Koning Albert II-laan 20 1000 Brussels 

TEL. NUMBER: 0032 (0)2 553 81 97 

FAX NUMBER: 0032 (0)2 553 80 85 

E-MAIL ADDRESS: paul.bernaert@lin.vlaanderen.be 

Summary 

The “raison d’être” of the Environment Inspection Section is to prevent nuisance, damage and serious 

accidents; and to preserve the environmental quality and to improve it where possible. 

To realise this aim, the Environment Inspection Section has drawn up strategic objectives and is implementing 

several processes. The key process is ‘inspecting and taking measures’, or, in brief, enforcement. 

In order to determine how well the objectives have been met, measurement indicators are of great 

importance. The statement ‘measuring is knowing’ certainly holds true in this case. It’s rather straightforward 

to generate data on the output of the enforcement activities. However, measuring the outcome 

of the environmental inspections is a whole lot more complex and time-consuming. There is a great need 

for outcome-indicators, which are transparent, relevant, easy to handle, feasible and measurable. 

Furthermore, there is a tension between effectiveness and efficiency. And last but not least: before 

measurements are possible, there has to be performance! 

The effectiveness of the enforcement can be partly determined by measuring the output of the process, 

but mainly by measuring the outcome (effects obtained). It is fairly easy to determine the output of the


enforcement process correctly and completely, on the basis of quantitative data, such as the number of 

inspections, samples taken, inspection reports, reports of infringements, administrative measures, project 

reports, …. Carefully compiling these data, e.g. in an electronic dossier management system, allows 

to generate them afterwards without too much effort. 

These quantitative data, although being very informative, do not allow a qualitative appreciation of the 

output itself, nor of the gravity of the infringements or their impact on the environment, of the emission 

reductions, of improvements of the plant management, of changes of the attitude of the companies, of 

the effect on the environmental quality, … As such, these output figures are of limited value. In order to 

determine the quality of the performance, one not only has to measure the output, but also the outcome, 

i.e. the effects obtained. However, this is a complex and time-consuming work, which is strongly 

dependent upon the type of inspection. 

The effectiveness of inspections is also directly proportional to the measures of criminal and administrative 

law, which follow them. Both the quality of these measures, as well as the effectiveness of their 

application are important. It is typical for enforcement dossiers that at a certain stage, the enforcement 

authority is no longer dealing them with, as they are handed over to other actors. In case of criminal 

prosecution, this will be the public prosecutors; for changes of or additions to the licence or for suspending 

or cancelling the licence, this will be the licensing authorities and in case of appeals against 

coercive measures, this will be the responsible minister. The way these authorities handle the dossiers is 

beyond the influence of the Environment Inspection Section, but this will strongly determine the effectiveness 

of the environmental inspections. Insufficient or, even worse no action at all by these authorities 

may lower or even neutralise the effect of the inspections. The same holds true for the feedback of 

the results of enforcement actions and of recommendations towards the policy makers: the enforcing 

authority has no, or limited impact, on the way this information is afterwards being dealt with. 

Concerning the efficiency of the enforcement, it can be stated that it will increase as the organisation 

disposes of: 

• sufficient, strongly motivated and highly qualified personnel 

• clear objectives 

• workable indicators 

• good legal instruments 

• well suited inspection instruments (checklists, codes of good practice, …) 

• permanent training facilities 

Effectiveness and efficiency do not always go together. Sometimes, raising the efficiency may even cause 

a lower effectiveness and vice versa. Due to the limited amount of resources, Pareto’s 80/20-rule is well 

applicable. In many actions, 80% of the wanted effects can be obtained within 20% of the time. Time 

is money, also for public authorities. 

To illustrate the effectiveness and efficiency of environmental inspections, the way the Environment 

Inspection Section has obtained its objectives for the cleanup of the municipal waste incinerators and 

the handling of complaints will be presented.


SESSION: The role of inspections and different approaches, Group 2 


TITLE OF PRESENTATION: Assessment of indicators for efficiency of inspections at Czech environmental Inspectorate 

NAME OF SPEAKER: Pavel _remer 

ORGANISATION: Czech Environmental Inspectorate 

ADDRESS: _I_P, Na B_ehu 267, 190 00 Prague 9, Czech Republic 

TEL. NUMBER: ++420 283891564; ++420 283893574 

FAX NUMBER: ++420 283892662 

E-MAIL ADDRESS: sremer@cizp.cz 

Summary 

Many quantitative indicators are collected at Czech Environmental Inspectorate (CEI), mostly for annual 

assessment of work. New qualitative indicators for measuring of efficiency and effectiveness are in 

development (e.g. number of valid complaints per inspector, number of remedial actions per inspector, 

number of penalties per inspector, number of decisions approved by appeal authority per inspector etc.). 

These qualitative indicators will be used for comparison between regional inspectorates and different 

sectorial departments at CEI. 

SESSION: The role of inspections and different approaches, Group 2 


TITLE OF PRESENTATION: Environmental Inspection Plans and Methods to assess the results 

NAME OF SPEAKER: Albert Dam 

ORGANISATION: Provincie Overijssel, team Enforcement Environmental management act 

ADDRESS: Postbus 10078, 8000 GB Zwolle 

TEL. NUMBER: 038-4252103 

FAX NUMBER: 038-4252610 

E-MAIL ADDRESS: A.Dam@prv-overijssel.nl 

Summary: 

Monitoring the execution of policy by means of achievement-indicators by the authorities is less usual 

as in circles of business and industry. Authorities have more quantitative as qualitative policy-aims. For 

example the aim of 800 visits instead of an increase of observance and good housekeeping of …%. 

Since the end of 2002 in Overijssel the team started working with Environmental Inspection Plans. 

These E.I.P.’s are set up from the principle “from business/industrial-activities via risk/hazard-analysis to 

maintenance-substances”. 

In the first half of 2003 an inquiry was done into the possibility to get insight in the observance/compliance 

of the environmental management act permit by means of a measuring method. 

A method is developed with which the effects of inspections can be followed. 

From the inquiry it goes to show that a causal connection between maintenance efforts on the one side 

and compliance on the other hand is very hard to prove. However it is possible to point out trends. 

Two methods are developed which will be executed and tested on workability in the second half of 2003. 

These methods can serve as management-tools during the process of fixing the priorities of inspectionactivities. 

Both methods will be explained during the presentation.


Identifying and spreading good practice-getting the best out of networks like IMPEL , Session 3 


SESSION: Identifying and spreading good practice-getting the best out of networks like IMPEL 


TITLE OF PRESENTATION: IMPEL products – a short overview 

NAME OF SPEAKER: Sabine Sommer 

ORGANISATION: European Commission, DG Environment, IMPEL Secretariat 

ADDRES: Beaulieu 9 1/94, B-1049 Brussels, Belgium 

TEL. NUMBER: 0032 2 299 43 83 

FAX NUMBER: 0032 2 299 10 70 

E-MAIL ADDRESS: sabine.sommer@cec.eu.int 

Summary: 

• The essence of the IMPEL network is its projects. For the most part these are concerned with the 

implementation and enforcement of industry-related environmental legislation, mainly IPPC, but also 

small and medium sized enterprises (SMEs). 

• IMPEL develops projects and activities in the framework of its multi-annual work programme, which 

draws on the Recommendation on minimum criteria for environmental inspections and the 6th 

Environmental Action Programme. 

• As a general rule, IMPEL projects look at how legislation is currently implemented and enforced and 

then good/best practice for the inspection and/or permitting process is defined. 

• The projects enable those who take part to become aware of different approaches to implementation 

and enforcement. 

• Reports on the IMPEL projects are published on the IMPEL website. 

• Examples: IMPEL Reference Book for Environmental Inspections, Best Practices concerning Training 

and Qualification for Environmental Inspectors, IMPEL Workshop on Integrated Permitting, Energy 

Efficiency in Environmental Permits, Fact Sheet for Printers, Seminars on Lessons learnt from Accidents. 



TITLE OF PRESENTATION: The Four Instruments 

NAME OF SPEAKER: Pietro Milella 

ORGANISATION: Italian Ministry of the Environment 

ADDRESS: Via Christoforo Colombo, 44 , I-00147 Rome 

TEL. NUMBER: +39 06 5722 8150 

FAX NUMBER: +39 06 5722 8172 

E-MAIL ADDRESS: 

Summary 

In 1997 and 1998, IMPEL held a series of workshops to discuss issues arising from the parallel imple-


mentation of three important environmental management instruments adopted between September 

1996 (IPPC) and March 1997 (EIA amendments), including the new Seveso Directive in December 1996. 

Some Member States were also relating the 1993 EMAS Regulation to the implementation of IPC and 

his application. 

IMPEL found the exercise of value not just for the sake of the exchange of experience but also because 

it allowed network members to raise and discuss issues of legal drafting and implementation, enforcement 

process and to debate how to arrive at more effective environmental management systems. This 

is of special importance in the context of AC-IMPEL, whose members are the executors of legal obligations 

whose preparation or modification they cannot always influence. 

Thus the European Commission decided that it would be useful to fund a project involving AC-IMPEL in 

a similar discussion, based on similar information at a time when the candidate countries were transposing 

and implementing the same instruments. The following “abstract” is taken from the final report 

discussed at the joint IMPEL and AC-IMPEL seminar held in Rome, March 2001. As the candidate countries 

are still in the process of transposing some of the legislation considered in this report and the 

Community legislative framework is constantly changing, a follow up is thus necessary. 

Presentation of the four Instruments 

• IPPC and Seveso govern environmental management practice of industrial or related activities (storage, 

for example). They are concerned with authorising activities ahead of their start-up and during 

their performance. The aim of Seveso is the prevention of major accidents and not, as in IPPC, the control 

of pollution. Its project lists and procedures are therefore significantly different and the extent of 

possible common actions consequently reduced. There are nevertheless common areas, where activities 

subject to IPPC may also be covered by Seveso; 

• EIA concerns the assessment of the likely environmental effects of projects including but by no means 

limited to industry. It is concerned with projects before their implementation. EIA is concerned with a 

much wider range of activities than the other instruments, such as infrastructure or agriculture, and 

it is undertaken in order to provide information for planning or building rather than for operation. It 

may therefore be managed by authorities other than those responsible for permitting or inspecting 

polluting activities. As a result, although there may be a desire to combine their procedures, it may 

be difficult to do so in practice. The purpose of EIA and of IPPC procedures is not the same, consequently 

the lists of project types falling under each are different, although there is a lot of overlap. 

One result of the difference in purpose is a difference in thresholds aiming to determine which installations 

fall within the scope of each instrument. This introduces a further element of complexity in the 

common administration of the two procedures; 

• EMAS provides rules for environmental self-regulation of industrial enterprise during operation. (In 

the future, it may also become applicable to other sectors.) It is only concerned with the performance 

of activities. It does not impose obligations on public authorities since it is addressed to industrial 

operators, and it only imposes obligations on those operators who want to participate, since it is voluntary. 

EMAS is a voluntary scheme designed to promote continuous improvements of the environmental 

performance and compliance with all relevant regulatory requirements. It is targeted at industrial 

sector operators but not specifically at either IPPC or Seveso sites or operations. One of its outputs 

is information, which could be used in assessing performance under either Seveso or IPPC. 

The possibility of using the synergies between the four instruments does therefore exist, but it is circumscribed 

first by the differences in scope of each and second by the differences in response countries 

make as a result. 

Objectives of the project 

• promote debate within AC-IMPEL on the interrelationships and synergies between a series of key environmental 

management instruments, to see what benefits each could bring to the others;


• to help AC-IMPEL (and the candidate countries) break down the barriers between law-making and 

implementation, so that practice can inform the drafting process and so improve their effectiveness; 

• to achieve the integration of the procedures required by the instruments as being the solution which 

goes furthest towards rationalising implementation and enforcement (the “one-stop shop”). No solutions 

to this are valid unless they also meet the objective of supporting a gradual and continuous 

improvement in environmental conditions as part of the process. 

The great variety of projects and activities controlled by the four instruments and the diversity of environmental 

conditions across countries means that the optimum solution combining the objectives of a 

high level of protection with a streamlined permitting and enforcement system could be quite different 

from situation to situation. A final and generally applicable objective would thus be to ensure flexibility 

in response to different challenges, and in the application of procedures once established. 

Action and national actions 

The term “conclusion” suggests finality, an end to a process. But the report should be seen only as the 

end of one step in a process that must continue if the identified objectives are to be met. 

In addition to the practical steps which might be taken to cover the issues raised, several forms of broader 

enabling action that may also be envisaged: 

• Creating the conditions for change; 

• Ensuring the support of other groups in society; 

• Improving cooperation; 

• Building on experience; 

• Ensuring feedback. 

Follow-up 

The value of the information in the report and the recommendations based on it are therefore likely to be 

short-lived. In order to ensure that the impetus given to its preparation by Italy, the European Commission 

and IMPEL secretariat is not lost, follow-up activities are essential. 

The following recommendations are made: 

• Review of the extent of transposition, practical application and progress in developing interrelationships 

(to allow for experience to begin to build up) at candidate country meeting; this should include 

firm recommendations for policy makers on steps to be taken to improve cooperation or integration; 

• A policy makers’ meeting to test progress (initiated by the European Commission in the framework of 

its obligations to ensure practical application?); 

• Early establishment of a focal point and secretariat for information on integration and cooperation 

practice in a country/institution with an existing interest in the issue; 

• Early establishment of a network or group within AC-/IMPEL to promote information exchange relating 

to the instruments and methods of application, not just on country experience but also on good 

practice. This should include both member states and candidate countries. 



TITLE OF PRESENTATION: Obstacles to implementing IMPEL products in Lithuania 

NAME OF SPEAKER: Vaclovas Berzinskas 

ORGANISATION: Lithuanian Environmental Inspectorate 

ADDRESS: Juozapaviciaus Str. 9, LT-2005, Vilnius, Lithuania 

TEL. NUMBER: +370-5-2723756: 

FAX NUMBER: +370-5-2722766 

E-MAIL ADDRESS: v.berzinskas@nt.gamta.lt


Summary 

The presentation describes about the main obstacles to implement IMPEL recommendations in 

Lithuanian environmental inspection practice. 

The first obstacle is to make recommendationseasily available and to train the environmental inspectors 

to understand and to use them creatively. 

Inspectors have to plan inspections in advance and inspection frequencies for controlled installations 

have to be established. In this area inspectors face with numerous uncertantities, because the field of 

theirs activity is very wide: quarries, wildlife and protected territories. IMPEL recommendations show 

which installations have to be included to the lists primarily and why. 

Transitional period creates new obstacles: splitting major enterprises into number of small ones, establishment 

of new ones and these processes require closer co-operation with other controlling institutions. 

Several other obstacles does exist and the ways in which Lithuanian Environmental Inspection deals 

with them is shown in this presentation. 

SESSION: Identifying and spreading good practice-getting the best out of networks like IMPEL. 


TITLE OF PRESENTATION: A National network between inspectors in Denmark 

NAME OF SPEAKER: Steen Fogde 

ORGANISATION: FMK 

ADDRESS: City of Elsinore 

TEL. NUMBER: +45 49 28 25 06 

FAX NUMBER: +45 49 28 24 16 

E-MAIL ADDRESS: sfo55@helsingor.dk 

Summary 

As many as more than 900 inspectors in Denmark are actually “networking” in order to improve the outcome 

of licensing, inspecting and enforcing. 

A brief introduction to the Danish network, and a bit of the history behind it. 


DATE: 7th. October 2003 : 

TITLE OF PRESENTATION: Inspection and enforcement network - Slovenia 

NAME OF SPEAKER: Ivan _tefelj 

ORGANISATION: Inspectorate of the RS for Environment and Spatial Planning 

ADDRESS: Dunajska c. 47, Ljubljana, Slovenia 

TEL. NUMBER: +386 1 478 7124 

FAX NUMBER: + 386 1 478 7102 

E-MAIL ADDRESS: ivan.stefelj@gov.si 

Summary 

In Slovenia was setting up the inspection and enforcement network. The fact is that many institutions 

are responsible for implementation and enforcement of legislation, not only Inspectorate of the RS for 

environment and spatial planning. That is why we established the network. The priority tasks are how 

we should inspect and enforce successfully the entire environment legislation. Goals of the network are 

providing better and more efficiency work, better communication between internal institutions and min-


istries. Members are all institutions which are responsible to inspect and enforce entire environmental 

legislation. 

Head of the network is sector – Environment in Inspectorate of the RS for Environment and Spatial 

Planning. We established 26 expert groups. Members of expert groups are representatives of 

Inspectorate, Environment Agency and other institutions. 

The main tasks of the expert groups are the preparation of the inspection and enforcement handbook 

and exercise of direct inspection. The benefits of activity of the network are better communication and 

dissemination of information between internal institutions and ministries. 

The main goal has been reached: more efficient and uniform inspection and enforcement. The basement 

is handbook for inspection and enforcement. 


DATE: 7th.October 2003. 

TITLE OF PRESENTATION: IMPEL National Network in Austria 

NAME OF SPEAKER: Heidler Armin Dipl. Ing. 

ORGANISATION: Federal Ministry of Agriculture Forestry Environment and Watermanagement 

ADDRESS: A-1010 Vienna Stubenbastei 5 

TEL. NUMBER: + 43 1 51522 2109 

FAX NUMBER: + 43 1 51522 7122 

E-MAIL ADDRESS: armin.heidler@bmlfuw.gv.at 

Summary 

IMPEL National Network Austria 

Austria is a federal republic, composed of nine federal provinces. Due to the Federal Constitution the 

competencies in environmental issues are shared between federal and provincial legis--la-tion. The 

enforcement of Austrian environmental law is mainly carried out by the pro-vinces. 

Austria is a member of IMPEL since its accession to the EU in 1995. Since the very beginning of Austria’s 

work within IMPEL there was a tendency to create a national IMPEL network within Austria. The co-ordination 

is carried out by the Austrian Ministry of Agriculture, Forestry, Environment and Water 

Management. The networking process started with the involvement of other federal ministries like the 

Federal Ministry for Economic Affairs and the Federal Environmental Agency. Representatives of the 

provinces had the possibility to join the IMPEL exchange programmes. 

The involvement of the provinces in the actual work of IMPEL started in 1996. An official representative 

of all nine provinces was nominated to co-ordinate the actions of the provinces. This official representative 

works close together with all provinces, the national IMPEL co-ordinator and participates in the 

IMPEL Plenaries and other IMPEL meetings. Within the federal ministries and the provinces a network 

of contact persons was installed. Representatives of federal ministries and of the provinces were regularly 

invited to national co-ordination meetings under the chairmanship of the Federal Ministry of 

Agriculture,Forestry, Environment and Water Management. 

National IMPEL co-ordination meetings with all other involved federal ministries and the provinces and 

the official Austrian IMPEL representatives take place up to two times a yearbefore the plenary meeting.


Austria has a national „IMPEL Directory of Contacts„, where the national co-ordinator, but also the 

Austrian representatives in the several working groups and all contact persons in the ministries and 

provinces are listed. 

The information about the work done in IMPEL is disseminated by the national co-ordinator to all 

national representatives, but also to all IMPEL contact persons in the different federal ministries and the 

provinces. The reports concerning IMPEL meetings are distributed by the participants of this meeting to 

all the different contact persons and to Austrian IMPEL representatives. A clear system for the distribution 

of this information was elaborated. 

Not only the dissemination of information about IMPEL activities is the main task of the Austrian IMPEL 

network, but also to have a national network of environmental experts, who are interested in participating 

in the work of IMPEL in the several Working Groups. For this reason the national Austrian IMPEL 

network tries to establish a link to other existing national expert networks, like the expert network for 

waste management, for water, for environmental impact assessment, for industrial plants etc. 



TITLE OF PRESENTATION: INECE: A Network of Networks 

NAME OF SPEAKER: Durwood Zaelke 

ORGANISATION: International Network for Environmental Compliance and Enforcement 

ADDRESS: 1367 Connecticut Avenue NW #300, 

Washington, DC 20036, USA 

TEL. NUMBER: 1-202-249-9607 

FAX NUMBER: 1-202-249-9608 

E-MAIL ADDRESS: inece@inece.org 

Summary 

This presentation will discuss the role of The International Network for Environmental Compliance and 

Enforcement (INECE), as a network of networks, in improving compliance and enforcement practices. 

Key to INECE's strategy is working through INECE regional and topic-specific networks, and expanding 

collaboration with existing networks including IMPEL, BERCEN and NISECEN, to strengthen enforcement 

cooperation and build necessary capacity to achieve better compliance with environmental 

requirements. INECE is uniquely positioned to respond to global concerns and foster enforcement cooperation 

beyond national and regional borders to achieve measurable results for human health, the environment 

and sustainable development. 

INECE activities include a tri-annual international conference for 200 participants, on-line newsletter, 

a dynamic Web site, the Principles of Environmental Enforcement course, as well as creative efforts to 

“brand” INECE through projects done in cooperation with other networks such as its efforts to develop 

“INECE Enforcement Indicators” and an INECE “Best of Compliance and Enforcement” book. These activities 

are designed to build capacity for the development of effective compliance and enforcement programs 

and activities, and are helping many nations take crucial steps needed to begin to improve their 

enforcement programs. Illustrative of project areas are the INECE special topic Web forums, which are 

designed to build capacity and foster enforcement cooperation on issues including hazardous waste, 

ozone, wildlife, pesticides/chemicals, inspectors, indicators, and public participation and water. Further 

information on INECE activities and resources is available at http://www.inece.org




TITLE OF PRESENTATION: Improving the Implementation of Environmental Law in south Eastern Europe 

Through Networking and Exchange of Experience 

NAME OF SPEAKER: Mihail Dimovski 

ORGANISATION: The Regional Environmental Center for CEE. 

ADDRESS: Ady Endre, 9-11, 2000 Szentendre, Hungary 

TEL. NUMBER: + 36 26 504 052 

FAX NUMBER: + 36 26 311 294 

E-MAIL ADDRESS: mdimovski@rec.org 

Summary 

BERCEN is an informal country-driven network operating under the framework of the Stabilisation and 

Association Process for countries of South Eastern Europe. BERCEN communicates and cooperates with 

IMPEL, INECE and NISECEN. 

The members of BERCEN are: Albania, Bosnia and Herzegovina, Croatia, FYR Macedonia and Serbia and 

Montenegro. Bulgaria and Romania have observer status, contributing and exchanging experience with 

the network and forming the bridge between IMPEL and BERCEN. 

Reasons for BERCEN Establishment 

Environmental law implementation has not received sufficient attention in the SAP countries in the period 

of their transition to market economies. The instability in the SEE region has retarded the development 

of strong environmental enforcement and compliance. The weak institutional and legal framework 

coupled with the limited financial and human resources of the environmental enforcement agencies in 

the SAP countries is a major cause of ineffectiveness of environmental compliance and enforcement. 

Thanks to substantive national assistance, the SEE countries have initiated the process of preparing new 

laws in line with the EU integration process. However, weak enforcement of environmental laws has 

been identified as one of the main obstacles, undermining the effectiveness of legislation. 

The environmental enforcement systems in the BERCEN member countries were identified as very weak, 

not integrated and characterised by slow process of adjustment from single-media approach to 

multi–media approach in fields of permitting and inspection. 

The BERCEN intends to improve the implementatin of environmetnal law and strengthen the environmental 

enforcement and compliance by exchange of expereince, networking, and co-operation. 

Driving Force 

Albania, Bosnia-Herzegovina, Croatia, the FYR Macedonia and the FR Yugoslavia are now part of the 

Stabilisation and Association Process (SAP) that constitutes the European Union’s key policy to draw the 

countries of the region closer to the prospect of European Integration. A cornerstone of this new 

approach will be a new kind of contractual agreement, tailor made for each country and known as a 

Stabilisation and Association Agreement (SAA). This offers the countries the prospect of integration into 

the EU's structures whilst setting political and economic conditions to be met. Environment is included 

as a key area for co-operation. Measures should be taken to put in place the necessary enforcement 

mechanisms to enable SEE institutions to improve the implementatio of environmenal law. 

BERCEN Structure 

BERCEN network has a similar stucture as AC IMPEL network and it is based on AC IMPEL postive experience.


Plenary meetings 

The Plenary Meeting is the forum for strategic discussions and decision-making subject to the objectives 

and activities of the network and endorses the work plan. 

The BERCEN Network Coordinators will determine the number of the plenary meetings, dependent on 

the progress of the work plan, the available budget and subjects to be discussed. They should take place 

at least once a year. 

In the initial two-year phase for which finance has been secured, for each plenary meeting the 

Secretariat will invite the network co-ordinators for whom travel and lodging allowance expenses will be 

provided. Should a country wish to participate with further representatives it must bare the additional 

costs The Secretariat will also invite the donor countries and SEE AC IMPEL national co-ordinators to 

participate the plenary meetings. 

The plenary meetings will be co-chaired by the European Commission and a SEE country hosting 

the plenary. 

The meetings will be held in English. 

c. Secretariat 

The Secretariat shall maintain contact with the national co-ordinators and other members of the 

Network. It shall support the Chairmen of the Plenary Meeting in the function of their duties and prepares 

the draft work plan. It will provide the Network with relevant information. For the initial two year 

phase the Secretariat will be managed and hosted by The Regional Environmental Centre and must 

remain in close cooperation with the European Commission. 

The secretariat will actively disseminate information from other similar compliance and enforcement 

networks such as AC/EU IMPEL, INECE, and NISECEN etc. 

The secretariat will review every 6 months the progress of the activities of the BERCEN members. 

Activities: 

The first two years of BERCEN operations were focused on establishing the network and assessing the 

level of enforcement. Training programmes, exchange of experience, study tours and provisions of equipment 

have been focussed on building capacity at the environmental inspectorate level. Capacity building 

basically started from a scratch, due to extremely law knowledge and understanding of the major 

enforcement issues as integrated inspection, regulatory cycle, permitting system, monitoring, planning 

of inspection and on site inspection. 

Following the implementation of these activities during the period 2001-2003, the capacities of the 

inspectors significantly improved. The core group of trained inspectors was established in order to further 

disseminate the knowledge on the national level. 

The BERCEN work plan for 2003 – 2006 consists of further capacity building for implementation of 

environmental law. Furthermore, the network will perform Peer Reviews of the enforcement systems in 

each of the member countries. The network member countries, will report on IPPC and MCEI implementation 

in their national permitting systems. 

Exchange of experience with IMPE is seen as one of the most important tools for achieving the 

network objectives. 

Acheivements 

BERCEN facilitates, assists and promotes the enforcement of regulations in South Eastern Europe by dis-


seminating information, finding common denominators for cooperation and developing projects of common 

interest. The members work together to enhance the implementation of environmental legislation 

and to increase the effectiveness of enforcement 

agencies and inspectorates. 

The results of current activities of BERCEN are: 

• National and regional needs assessment reports published, 

• National project proposals on the most urgent needs in environmental enforcement and compliance 

developed, 

• Two training programs ‘Train the Trainer’ organized and a training manual published for environmental 

inspectors, 

• Small IT and monitoring equipment and vehicles delivered to enforcement agencies and inspectorates, 

• Two exchange programs on IPPC and MCEI organized in Croatia and Bulgaria, 

• Two study tours on IPPC and MCEI organized in Germany and Finland, 

• 1st BERCEN plenary meeting held for the BERCEN National Network Coordinators: 

-Adopted network recommendation for preparatory activities for introduction of IPPC Directive 

(96/61/EC) in the BERCEN member countries, 

-Adopted network recommendation for implementation in the BERCEN member countries of the 

Recommendation of the European Parliament and of the Council of 4 April 2001 providing for 

minimum criteria for environmental inspections in the Member States (2001/331/EC). 

Links with IMPEL 

The BERCEN cooperation with IMPEL network was strengthened; strategic guidance and know how was 

received, particularly from the EU candidate countries and Member States. Moreover, BERCEN member 

countries are strongly committed to further cooperate and improve the national enforcement systems. 

In order to draw closer to IMPEL, the BERCEN 1st Plenary Meeting concluded that the countries will 

report measurable results on the implementation of IPPC directive using the same reporting format as 

EU Member States, although they are not legally obliged to do so. Also the countries agreed to use 

IMPEL guidance for reporting on the implementation of Parliament and Council recommendation on 

Minimum Criteria for Environmental Inspections (MCEI). 

Cooperation with IMPEL in terms of exchange of experience, transfer of knowledge and lessons learned 

is of outmost importance for BERCEN. 

At present, the network inspectors are experiencing difficulties in terms of capacity to further expand 

the activities on more pragmatic and innovative issues, and draw closer to the IMPEL . 



TITLE OF PRESENTATION: Solving the Puzzle of Good Environmental Governance in Eastern Europe, 

Caucasus and Central Asia: The Contribution of Networking 

NAME OF SPEAKER: Angela BULARGA 

ORGANISATION: OECD, Environment Directorate, Non-Member Countries Division 

ADDRESS: 2, rue Andre Pascal, 75775 Paris Cedex 16, France 

TEL. NUMBER: + 33 (0) 1 45 24 98 63 

FAX NUMBER: + 33 (0) 1 45 24 96 71 

E-MAIL ADDRESS: angela.bularga@oecd.org


Summary 

SOLVING THE PUZZLE OF GOOD ENVIRONMENTAL GOVERNANCE 

IN EASTERN EUROPE, CAUCASUS AND CENTRAL ASIA: 

The Contribution of Networking 

The network of environmental inspectorates of Eastern Europe, Caucasus and Central Asia (EECCA) was 

estab-lished under the name of NISECEN in 1999 within the framework of the EAP Task Force – an intergovernmental 

body that facilitates international co-operation and transfer of experience to transition 

economies in the field of environmental protection and management. The Network includes twelve 

countries of the former Soviet Union. Despite their common origin, these countries have diverse economic 

and environmental characteristics, and do not necessarily share a common set of priorities. 

Nevertheless, their environmental compliance assurance systems do share a common design that still 

originated from a single system. This provides a different platform for networking in comparison with 

IMPEL: the NISECEN members are prima-rily interested to learn from international experience in order 

to strengthen their systems as part of transition to a market-based democratic society. With the enlargement 

of the European Union (EU), several EECCA countries aspire to a wider European integration and 

convergence with EU environmental legislation. 

The NISECEN was established in response to the crisis of compliance assurance systems and institutions 

that touched all EECCA countries in the 1990s. That crisis resulted in a lack of effec-tiveness, a loss of 

integrity and credibility. Despite ma-jor changes in social and economic conditions, environmental inspectorates 

continued to rep-li-cate the “centrally planned” model that included maintaining the authoritarian 

culture, inconsistent and discretionary enforcement, and unchanged arsenal of enfor-ce-ment instruments. 

Creating deterrence and changing the behaviour of the regulated community were neglected. 

The inspectorates were deprived of considerable authorities as well as of adequate human and financial 

resources. Their situation has been even more aggravated by very frequent organisational reforms that 

occurred without having improved the methods of operation. All these factors led to institutional instability 

and a distortion in priorities. Hence, the status and impacts of envi-ronmental inspectorates declined. 

The NISECEN is the only regional mechanism that helps to overcome the current crisis of envi-ronmental 

compliance assurance in EECCA countries. The Network provides its Members with the opportunity 

to learn good international practices, develop new reference models and tools, and apply them. Most 

recently, the “Guiding Principles for Reform of Environmental Enforcement Authorities in Transition 

Economies of Eastern Europe, Caucasus and Central Asia” were developed as a basis for true institutional 

restructuring. This non-binding policy document was recommended for the implementation by the 

Envi-ronmental Ministers of the UNECE region in their Declaration adopted at the Kiev Conference in 

May 2003. Furthermore, specific tools have been developed to support the implementation of the 

Guiding Principles: 

- A review of compliance and enforcement practices in EECCA countries to serve as a baseline to monitor 

implementation; 

- A toolkit that will help environmental inspectorates to adopt strategic enforcement and improve management 

style, as well as to help in conducting inspections more effectively and in communicating with 

the regulated community and the general public; 

- Recommendations to improve permitting approaches and procedures; 

- Analysis of how to design and apply compliance promotion tools; 

- Glossary of key terms used in environmental enforcement and compliance promotion. 

Regional training and study visits to Central European countries have been conducted and country-specific 

programmes supporting environmental inspectorates and permitting systems have been implemented


through donor programmes in Armenia, Belarus, Georgia, Moldova, Kyrgyz Republic, Russian Federation 

and Ukraine. The later reflects the work in individual countries to put into practice policy recommendations 

and new compliance assurance tools, which is done under the umbrella of the EAP Task Force. 

The Network, for which the OECD provides the Secretariat, will continue realizing its goals and supporting 

environmental inspectorates of the EECCA region. A new work programme will be discussed at 

the Fifth Annual Network Meeting in Kiev, on 16-18 October 2003. 

SESSION: Identifying and spreading good practice getting the best out of networks like IMPEL 


TITLE OF PRESENTATION: TFS - Transfrontier Shipment of Waste 

NAME OF SPEAKER: Walter Pirstinger 

ORGANISATION: Federal ministry of agriculture, Forestry, Environment and Water management 

ADDRESS: Stubenbastei 5.,1010 Vienna 

TEL. NUMBER: + 43-1 51522,3519 

FAX NUMBER: + 43-1 513.1679.1265 

ES-MAIL ADDRESS: walter.pirstinger@bmlfuw.gv.at 

Summary 

TFS - Transfrontier Shipment of Waste 

What is TFS? 

The TFS network is a cluster of projects within IMPEL. It was set up upon a Dutch initiative already with 

the establishment of IMPEL in 1992. The aim of the network is to: 

• Harmonise the enforcement of the EU Regulation 259/93. 

• Promote exchange of knowledge and experience with the enforcement of the EU Regulation 259/93. 

• Promote the development of cross-border networks of the authorities competent for the transfrontier 

shipmentof waste. 

• Support the acceding and candidate countries in the field of EU Regulation 259/93. 

• Carry out joint (cross-border) enforcement projects. 

The TFS network is a network of representatives from enforcement authorities of the EU Member States 

(national, local and regional level), Hong-Kong, Norway as well as the acceding and candidate 

countries dealing with matters on transfrontier shipments of waste. Besides representatives of public security 

(Interpol, police), the customs and other organisations (Basel convention, EPA) participate on a 

regular basis. 

Structure 

The TFS network has its own secretariat (the Netherlands), that liaises with the IMPEL-Secretariat and 

provides it with the results of completed projects, the ToRs (term of Reference) of new TFS projects and 

the reports on the annual TFS conference. Together with the host country, the TFS secretariat is also 

responsible for the co-ordination of the TFS conference. 

Selection of current TFS-project 

• Joint transport controls (road, water, railway) 

• TFS network in the accession states 

• Manual for the return of illegal traffic 

• Electronic processing of data (EUDIN)


• Electronic waste data base 

• Threat assessment - transfrontier shipment of waste 

• Co-operation with Interpol in the field of environmental crime “Green Interpol” 

• Co-operation with secretariat of the Basel convention (TFS-Asia) 

• IMPEL TFS website 

Was ist TFS? 

Die TFS-Arbeitsgruppe, bereits 1992 bei Gründung von IMPEL auf Initiative der Niederlande mit dem 

Projekt “TFS-1” ins Leben gerufen, ist ein fixer Bestandteil des IMPEL-Netzwerkes und versteht sich als 

technische Arbeitsgruppe, deren Ziele in folgenden Bereichen liegen: 

• Einheitliche EU-weite Anwendung der EG-Abfallverbringungsverordnung 259/93 (AbfVVO) 

• Aufzeigen/Verbessern/Lösen der mit der AbfVVO verbundenen Vollzugsprobleme 

• Auf- und Ausbau grenzüberschreitender Netzwerke (Informations- und Erfahrungsaustausch) der für 

die grenzüberschreitende Verbringung von Abfällen zuständigen Behörden 

• Unterstützung der EU-Beitrittsländer im Bereich AbfVVO 

• Durchführung gemeinsamer länderübergreifender Abfallkontrollen 

Die TFS-Gruppe setzt sich vor allem aus Vertretern aus den mit dem Vollzug der AbfVVO betrauten 

Behörden (Länder, Regionen, Provinzen) der EU-Mitgliedsstaaten, Hong-Konk, Norwegen sowie den EU- 

Beitrittsländern zusammen. Daneben nehmen regelmäßig Vertreter der öffentlichen Sicherheit (Interpol, 

Polizei, Gendarmerie), des Zolls und anderer Organisationen (Basler Konvention, EPA) teil. 

Struktur 

Die TFS-Gruppe verfügt über ein eigenes Sekretariat (Holland), das als Verbindungsglied zum IMPEL- 

Sekretariat die Resultate der abgeschlossenen bzw. die TORs (Terms of Reference) der geplanten TFS- 

Projekte zur Evaluierung vorlegt, über die Ergebnisse der TFS-Konferenzen berichtet und die 

Durchführung der einmal jährlich stattfindenden TFS-Konferenz zusammen mit dem jeweiligen 

Gastgeberland koordiniert. 

Auswahl an aktuellen TFS-Projekten 

• Gemeinsame Abfalltransportkontrollen (Straße, Wasser, Bahn) 

• Unterstützung der EU-Beitrittsländern (TFS-AC) im Bereich AbfVVO 

• Handbuch für die Rückführung illegal verbrachter Abfälle 

• Elektronischer Datenaustausch (EUDIN) 

• Elektronische Abfalldatenbank 

• Abschätzung des Ausmaßes illegal verbrachter Abfälle 

• Zusammenarbeit mit Interpol im Bereich Umweltkriminalität “Green Interpol” 

• Zusammenarbeit mit Sekretariat der Basler Konvention (TFS-Asien) 

• Öffentlichkeitsarbeit (TFS-Webseite)


Session: Identifying and spreading good practice-getting the best out of networks like IMPEL 

Date: 7th. October 2003 

Title of presentation: Co-operation between the Czech Republic and Slovakia 

Name of speaker: Daniel Geisbacher 

Organisation: Slovak Inspectorate of the Environment 

Address: Karloveska 2, 842 22 Bratislava, Slovak Republic 

Tel. number: +421 2 65426950 

Fax number: +421 2 65423181 

e-mail address: geisbacher@sizp.sk 

Summary 

Common history of establisment of the Czech Environmental Inspectorate and Slovak Environmental 

Inspectorate from the former State Water Management Inspectorate and State Technical Air Protection 

Inspectorate, common interest in implementation and enforcement of EU legislation and direct communication 

are preconditions for good bilateral cooperation. 

The cooperation is carried out on national and regional levels. The cooperation on national level realized 

via Headquarters of Environmental Inspectorates is based on exchange of information on progress 

in implementation and enforcement of EU legislation, inspection procedures and international cooperation. 

Cooperation of Regional Environmental Inspectorates is focused on inspection practice and specific 

problems in regions with potential trans-boundary impacts. There are organized also common 

inspections on both sides. 

Capacity building-How can we manage our job?, Session 4 


SESSION: Capacity Building-How can we manage our job ? 


TITLE OF PRESENTATION: Capacity building in practice – The IMPEL Review Initiative 

NAME OF SPEAKER: Martin Murray 


ADDRESS: Rio House, Waterside Drive, Aztec West, Almondsbury, Bristol, BS32 4UD 

TEL. NUMBER: 00 44 1454 205561 

FAX NUMBER: 00 44 1454 624032 

E-MAIL ADDRESS: martin.murray@environmen-agency.gov.uk 

Summary 

In Session 1 “IMPEL at Work” the background to the review process was described. 

This presentation will outline some key observations from the IRI: 

• the variety of organsational approaches, 

• different skills and competencies required to deliver effective environmental regulation 

• effect of different cultural background and legal frameworks on permitting and inspection.


SESSION: Capacity Building-How can we manage our job? 


TITLE OF PRESENTATION: Developing an outcomes approach in the Scottish Environment Protection Agency 

NAME OF SPEAKER: Nerina Holden 

ORGANISATION: Scottish Environment Protection Agency 

ADDRESS: Corporate Office, Erskine Court, Castle Business Park, Stirling, Scotland, UK, FK9 4TR 

TEL. NUMBER: 01786 457 700 

FAX NUMBER: 01786 446 885 

E-MAIL ADDRESS: nerina.holden@sepa.org.uk 

Summary 

The Scottish Environment Protection Agency has changed the way it plans its work. 

We now place a much greater emphasis on the final results – the outcomes – of our activity when we 

plan. Previously the emphasis was on the activities we undertook – such as how many permits we would 

handle or how many inspections we would do - without always showing how that activity affected the 

environment. For example, SEPA has historically tended to report the number of samples taken, permits 

issued and inspections undertaken rather than the tonnes of pollutants no longer emitted. 

We used a logical approach when we changed our planning:- 

What outcome do we have to achieve? 

How will we measure that? 

What targets should be set? 

What activities do we have to do? 

For one area of our work we already had this approach well-established, but for many others it was a 

new way to plan. 

The new approach allows scrutiny of activities to ensure they are helping us achieve outcomes. For 

example inspections are undertaken to, ultimately, improve or protect the environment. Setting a target 

of “10km of rivers will be improved by 2005” (rather than a target of “10,000 inspections will be completed 

this year”) can allow flexibility in the approach you take to achieving that improvement. This 

ensures that the focus of planning is on the final outcome (river improvement) rather than the activities 

undertaken. 

SESSION: Capacity building – How can we manage our job ? 


TITLE OF PRESENTATION: IMPEL project “Best practices concerning training and qualification for 

environmental inspectors 

NAME OF SPEAKER: Annick Bonneville 

French environmental inspection coordinator 

ORGANISATION: Ministry for Ecology and sustainable development 

ADDRESS: 20 Avenue de Segur 75302 PARIS 07 SP FRANCE 

TEL. NUMBER: +33.1.42.19.14.44 

FAX NUMBER: +33.1.42.19.14.67 

E-MAIL ADDRESS: annick.bonneville@environnement.gouv.fr


Summary 

This project arose from Recommendation 2001/331/EC published in JOC on April 4, 2001 providing 

for minimum criteria for environmental inspectors (Article IX 2), which itself was based on IMPEL reports 

on minimum Criteria for Inspection. 

This Recommendation calls on the Commission in co-operation with IMPEL, to ‘draw up minimum criteria 

concerning the qualifications of environmental inspectors’. Beyond to minimum criteria, France was 

asked during the plenary meeting in Falun in June 2001, to lead the IMPEL project « Good practices concerning 

training and qualification for inspectors in E.U.». 

13 Member States and the IMPEL secretariat actively participated in this project: Austria, Belgium, 

Denmark, Finland, France, Germany, Ireland, Italy, The Netherlands, Portugal, Spain, Sweden, and 

United-Kingdom. 

The IMPEL report, adopted on March 2003, examines the systems in place in Member States for the 

Training and Qualification of Inspectors and aims to identify best practices from them. These best practices 

are more than “minimum criteria”. 

It begins with a summary of the position in the Member States: more complete information can be found 

in the annexed report. It then describes a framework for identifying qualification and training needs for 

staff undertaking inspections, or preparing permits for those Member States where these inspection and 

permit activities are undertaken by the same people or within the same body. These include entry level 

requirements such as academic qualifications, personal attributes and general suitability. Initial training 

will often be needed before the new recruit can work alone, which will include practical experience 

on the job gained under supervision from a senior member of staff. His or her competency will need to 

be assessed and an evaluation should be undertaken. Continuing professional development will be 

needed in order to keep abreast of changes and to maintain the required level of competence. Some 

specialist training may also be appropriate, in order to have specialist knowledge within a particular 

team or organisation. The effectiveness of training given should also be checked. 

Skills and competencies need to be assessed according to the inspector’s role within a particular team. 

Inspectors need to plan their inspections, carry out site visits and draw conclusions on appropriate 

action to take as a result. It is important to define how well these tasks should be performed, which in 

turn assists in defining core competencies. Broadly similar steps are often followed in order for a permit 

to be issued. The permit writer has to be able to assess the operator’s application against the requirements 

of the relevant legislation. He/she will decide whether to issue a permit with conditions or to 

refuse an application for a permit, with reasons. If more than one authority is responsible for issuing a 

permit, it is important to ensure that conflicting permits are not issued for a particular activity. 

In any group of individuals in a profession, qualifications, skills and attributes will vary widely. A distinction 

can be made between “core competencies” at individual level (of which an inspector should 

have at least a basic understanding) and at the team level (which are necessary within a team but need 

not be found in each inspector). These competencies cover administrative framework and legal skills, 

inspection, permitting, technical skills and communication and management tools. 

Entry qualifications will depend on the specific role (inspector or permit writer) and the sector or level 

in which they work. Generally studies for 2 or 3 years leading to a diploma after secondary education 

completed at the age of 18 or 19 or relevant experience in science, technical or legal matters or the environment. 

According to the needs of the organisation, specific skills and competencies that may be 

required are technical skills, knowledge of national environmental legislation and organisations’ roles, 

technical report writing and communication and negotiation techniques.


Each new entrant has to have some core competencies before he or she can work on their own. If necessary 

their knowledge must be developed and further assessed while an inspector will need refreshment 

training and possibly training in a speciality. Competencies can be divided into three levels – 

awareness, knowledge and full understanding. Training can be at the levels of entry qualifications, initial 

training and further training for generalists and specialists. 

The inspecting body responsible for training should plan and report about it as an integrated part of 

the quality management system and annual planning procedures. Assessment means a comparison of 

the desired qualifications and skills necessary to perform a particular role. It is recommended that 

inspectors should be assessed during the selection procedure, after the beginners’ training and periodically 

throughout the career, this latter in order to assess whether there are further training requirements. 

SESSION: Capacity building-How can we manage our job ? 


TITLE OF PRESENTATION: Fortbildung von Umweltinspektoren (Training for environmental inspectors) 

NAME OF SPEAKER: Hans-Werner Breuer 

ORGANISATION: Umweltministerium NRW 

ADDRESS: Schwannst. 3, 40476 Düsseldorf 

TEL. NUMBER: 0211/4566586 

FAX NUMBER: 0211/4566-417 

E-MAIL ADDRESS: hans-werner.breuer@munlv.nrw.de 

Summary 

Current regulations, technical changes and greater public awareness make great demands on the qualifications 

of the people who are working in the environmental area. Wide-ranging training is necessary 

to make the inspectors fit for their job. That is why the training has played an important role for many 

years. Due to the many different tasks of the environmental inspections and the adaptation to the 

requirements, the inspectors have four possibilities to choose from: seminar programme of the ministry of 

environment, in-house-training within the authorities, external events an d distance learning supported 

by the internet (e-learning). The experiences hitherto have shown that the high efficiency and motivation 

of the environmental inspectors could be maintained with these different training possibilities. 

Summary 

Aktuelle gesetzliche Regelungen, technologischer Wandel und eine ständig sinkende Halbwertzeit des 

Wissens stellen hohe Anforderungen an die Qualifikationen der im Umweltbereich tätigen Menschen. 

Um die Mitarbeiterinnen und Mitarbeiter der Staatlichen Umweltverwaltung des Landes Nordrhein- 

Westfalen in die Lage zu versetzen, die an sie gerichteten Anforderungen zu erfüllen, ist eine vielseitige 

Fortbildung notwendig. Daher hat die Fortbildung seit Jahren einen unverändert hohen Stellenwert. 

Wegen des vielfältigen Aufgabenspektrums der Staatlichen Umweltverwaltung und um eine Anpassung 

der Fortbildung an den Bedarf zu erreichen, haben die Mitarbeiterinnen und Mitarbeiter die Möglichkeit, 

Fortbildung in vier verschiedenen Formen in Anspruch zu nehmen: durch Teilnahme an dem 

Seminarprogramm des Umweltministeriums, an einer Inhouse-Fortbildung, an externen Veranstaltungen 

und an internetunterstützten Fernkursen (e-leraning). Die bisherigen Erfahrungen haben gezeigt, dass 

mit diesem Fortbildungsangebot die hohe Leistungsfähigkeit und –bereitschaft der Mitarbeiterinnen 

und Mitarbeiter der Staatlichen Umweltverwaltung erhalten werden kann.


SESSION: Capacity Building- How can we manage our job ? 


TITLE OF PRESENTATION: Training and qualification of inspectors in Hungary 

NAME OF SPEAKER: Pál VARGA 

ORGANISATION: National Inspectorate for Environment and Nature Protection 

ADDRESS: Budapest, 1384 POBox 256 

TEL. NUMBER: 36-1-346 8310 

FAX NUMBER: 36-1-315 0812 

E-MAIL ADDRESS: vargap@mail5.ktm.hu 

Summary 

In Hungary the principal policy-making and administrative body in he field of environmental protection 

is the Ministry for Environment and Water. The task of the implementation of environmental legislation 

are under the responsibility of National Inspectorate for Environment and Nature Protection at the 

national level and of the twelve Regional Inspectorates at the regional level. The scope of the activities 

authorized and monitored by the Inspectorates extends to air quality, water quality, waste management, 

noise and vibration, etc.. They have the power for permission, inspection and enforcement as well. The 

main environmental monitoring network together with the laboratory is also operated by them. The 

total staff of the Inspectorates is 1250 employees. 

The entry level qualification for the inspectors is a five year degree in science/ environmental/ legal as the 

basic education. In the next half of the entry year it is necessary to qualify themselves as a civil servant getting 

a successful „ civil servant administrative” qualification according to the Act on the Civil Servant. 

For the reason of “better understanding of the regulations” or to exchange the experiments on the field 

of implementation of the legislation , it is a tradition to arrange one-two-three days “expert meetings” 

for group of inspectors. We have monthly “unitary legal-construction meetings”( understanding the actual 

legislation on the some way), seasonal “expert- meetings” (dealing with the issues of underground 

water, waste management, EIA, remediation etc). 

The up-to date training itself is a relatively new educational system for the inspectors. In the years of 

the approximation of the European environmental legislation the requirement for training-type of education 

became more and more important. The inspectors are needed not only lectures, presentations, 

explanations, etc. by the top ministerial man but to be practiced 

on the implementation of the special legislation as well. Writing enforceable emission limit values, 

measurable emission components in the permit paper, having regard to the submissions received from 

the interested parties, having competences for checking of compliance of controlled installations, or for 

monitoring their impact on the environment these are all equally important elements of their training. 

For this reason many trainings were arranged on the issues of EIA, IPPC, BAT, hazardous waste management, 

remediation of the contaminated sites by different type of Training Centers (Environmental 

Management Institute, VITUKI, Water Research Centre, Technical University Budapest). 

There were special trainings initiated and partly sponsored by DG Environment through Phare projects: 

• 6/19 August 1999. “In-country training of Inspectors in the Framework of AC-IMPEL”, attendees: 35 

inspectors 

• 22/26 April 2003, “Training of trainers” attendees: 30 inspectors,


The feedback of these training were: 

• inspectors eager to know more 

• continuous information exchange 

• professional guideline needed 

• training is a basic element of the capacity building in efficient implementation of the legislation 

Taking into account these feedbacks we put “more training task” into the ongoing implementation projects. 

In the framework of the Phare Twinning project “Institutional Strengthening of Environmental 

Inspectorates” ( HU/IB/2202/EN/02, German - Finnish twinning project) next January – March we 

are going to train 300 inspectors and 18 core group of trainers. The training focus to the most important 

EU directives , the essential procedures of integrated permitting and inspection, and the minimum 

criteria of inspection. The trainers will be experts from Germany and Finland. 

To ensure continuous training on environmental administration and to keep the staff of high level of 

knowledge, inside this project the basis of special Environmental Training Academia (ETA) is going to 

be planed. The task includes identifying the training materials, number of trainers, room requirements, 

determination of running cost and necessary investment, etc. The results of this system to have most of 

the inspector in Hungary as a qualification of “Verified State Environmental Inspector” . 

We hope ETA will be set up from 2005. 

SESSION: Capacity building- How can we manage our job ? 


TITLE OF PRESENTATION: Permit preparation and enforcement should not be combined in one person 

NAME OF SPEAKER: Wout Klein 

ORGANISATION: VROM Inspectorate 

ADDRESS: PO box 16191, 2500 BD Den Haag ipc 500, The Netherlands 

TEL. NUMBER: 0573 401756 

FAX NUMBER: 0573 401675 

E-MAIL ADDRESS: wout.klein@minvrom.nl 

Summary 

All 550 or so organisations in The Netherlands that are responable for the enforcement of environmental 

regulations have adopted quality standards for their operations. 

One of these standards is that no one person should be responsible for both the preparation of permits 

and for enforcement, even when not related to the same installation. (separation at employee level) 

It is fair to say that the adoption of this quality standard did not get unanimous support from all organisations. 

Small organisations generally would be satisfied to ban this combination only for the same 

installation. (separation at case level). At the other hand larger organisations like my own do favour 

separate agencies for enforcement (separation at agency level). 

Although feedback from enforcement is needed for preparation of better permits and vice versa, these 

two types of work should at least not be combined in one person for the following reasons: 

1. Enforcement is a different kind of work and does demand different skills and attitudes compared to 

preparation of permits. While the preparation of a permit demands technical and negotiating skills 

and a facilitating and cooperative attitude to the applicant, enforcement asks for straitforwardness 

and stubbornness and a fair, but unnegotiable judgement. 

2. For the inspector the rule is the untouchable and unbendable starting point of his job; for the permit 

maker the rule is the final outcome of study and negotiation. It is hard to look at the rule as some-


thing one shouldn’t bend or negotiate, if – be it in another case - it’s the same employee’s job to do 

exactly that. 

3. There is always an applicant urging that the permit be ready and the law or the organisation has 

always established a maximum timespan for the preparation. At the other hand: no offender will ever 

urge to speed the enforcement and as long no offences are noticed the organisation will not have 

demands. An employee with both tasks will therefore allways give priority to permitting. And so 

inevitably does the organisation as a whole. 

Recently all organisations have evaluated their score with respect to all quality standards. Roughly 50 % 

have already implemented the separation at employee level. The others will implement this before 2005. 



TITLE OF PRESENTATION: The individual making permits and inspections should be the same 

NAME OF SPEAKER: Charlotte B. Larsen 

ORGANISATION: County of Sønderjylland, Denmark 

ADDRESS: Jomfrustien 2, 6270 Tønder, Denmark 

TEL. NUMBER: 74 33 50 48 

FAX NUMBER: 74 33 50 01 

E-MAIL ADDRESS: cj@sja.dk 

Summary: 

Background: 

Since 1974 a number of special types of business in Denmark have been subject to regulation of their 

pollution through an environmental approval. 

During the first few years, the jobs of preparing the environmental approval and of supervising the businesses 

were divided between two authorities – counties and municipalities. (Denmark now consists of 

275 municipalities of varying size and 14 counties of more or less the same size). 

The counties would prepare the environmental approvals, and the municipalities would be in charge of 

the supervision. 

Later, the legislation was changed so that the same authority would prepare environmental approvals 

and be in charge of the supervision of the same business. 

The counties were responsible for the ”heavy”, particularly polluting businesses, and the municipalities 

were in charge of the ”light”, particularly polluting businesses divided into various lines of business 

During the first couple of years, the jobs were done in two groups – a supervising group with responsibility 

for supervising the businesses, and an environmental approval group with the responsibility for 

issuing the environmental approvals. 

After about two years, this structure was reviewed in the light of the recognition that there was room 

for an improvement of the co-operation with the businesses and efficient use of the resources. 

At present: 

”The key tasks” are: 

• preparation of environmental approvals 

• supervising a number of businesses. 

Organisation: 

each business has one first case worker and one second case worker. 

• The first case worker was and is the main contact to the business 

• The first case worker prepares the environmental approval and is responsible for the supervision of 

the business.


• The second case worker is a ”sparring partner” for the first case worker as far as both the preparation 

of the environmental approval and the supervision are concerned. 

The advantages of this organisation – which we have now used for more than ten years – is that: 

• the case worker acquires a thorough knowledge of the environmental problems of the business and 

is able to co-ordinate ”environmental approval visits” with actual so-called periodic supervision visits; 

• there is a better chance of establishing a relation of mutual confidence between the business and 

the authorities, since the business refers to only one person who is in charge of both approval 

and supervision; 

• the risk of having many different case workers and the consequent disadvantages is smaller; 

• in connection with the future role as an environmental guide for the business, the case worker is able 

to cover questions related to both approval and supervision. 

Disadvantages: 

• there is a risk that routine visits are postponed during periods where many approvals have to be issued. 

In practice, this is not a problem, as the environmental case worker is often able to combine visits to the 

business for the preparation of an approval with an actual supervision visit. 

In other cases, the routine supervision visits can be made during periods when the environmental 

approval work is ”awaiting information”. 

Education and experience: 

To be able to carry out the environmental work, i.e. both the preparation of environmental approvals 

and the implementation of environmental supervision, it is important that the employees are professionally 

”up to date”. 

The following elements are considered important: 

• relevant basic education (a department with several people with different theoretical background) 

• experience from employment in industry 

• courses in the preparation of environmental approvals 

• courses in the implementation of environmental visits 

• for new employees – a trainee period with an experienced colleague 

• creation of networks with colleagues in other counties 

• trade literature (print + the Internet) 



TITLE OF PRESENTATION: Information Technology (IT) tools for inspectors 

NAME OF SPEAKER: Markku Hietamäki 

ORGANISATION: Ministry of the Environment, Finland 

ADDRESS: PO Box 35, FIN-00023 GOVERNMENT, Finland 

TEL. NUMBER: +358 9 160 39707 

FAX NUMBER: +358 9 160 39453 

E-MAIL ADDRESS: markku.hietamaki@ymparisto.fi 

Summary: 

Environmental legislation puts increasing demands for the monitoring of the environmental permits and 

also the society requires the active and transparent monitoring of the environmental permits. 

Unfortunately governments are not always eager to increase resources accordingly. To do the work with 

present recourses or sometimes with less recourses it is necessary to rationalize the work of inspectors 

through training and planning but also through providing them effective IT tools.


Because inspectors' main task is to inspect their working hours should not be used to test not so well 

made IT applications. Applications change the way inspectors work, so it is important that inspectors 

are continuously consulted during the development of IT tools and inspectors' opinions should be 

reflected in the new versions of the application. In Finland inspectors in Regional Environmental Centres 

(REC) carry out the compliance monitoring of large installations. There are 13 Regional Environmental 

Centres in Finland. In all centres there is a contact persons who should present developing ideas to 

inspectors and collect their comments. It was however noticed that the developers of the IT application 

should every now and then go to RECs to train inspectors and to encourage them to give their views. 

This put extra burdens to developers but makes it possible to get better IT tools. 

VAHTI – compliance monitoring system encompass environmental permits (as a Word documents), 

environmental requirements (database), information about the operator or customer (database), periodical 

data of raw materials, fuels, emissions into air, discharges to water, wastes according to EWC 

(database) and production, inspection reports (both Word documents and database) and the interface 

to add new data, to change data and to retrieve reports. At the beginning customers database and also 

the documents management were parts of VAHTI-system, but now these are independent systems in 

state environmental data management system and VAHTI-system only utilises them. 

Most part of the data from operators come via electronic reporting system (forms or a schema = xml-file), 

which is run by a private contractor. Operators reported year 2002 data using forms, because a schema 

become available only in summer 2003. It is projected that larger facilities move from filling forms to use 

the schema in the near future. When reporting to authorities the operator can see also data, which she 

or he has reported previously. Only after an inspector proves the data it is removed to VAHTI – system. 

Although reports of emissions, discharges and waste are important, there are also reports “for administrative 

purposes”. When preparing for site inspection an inspector can get out of the VAHTI-system 

reports which includes facility's general information, environmental requirements and last years reported 

periodical data. It is also useful to look inspection reports or why in other facilities of the same industrial 

sector there has been inspections. 

VAHTI – system is still under development. Now we have users from the state environmental 

administration, but at the beginning of the next year we open the system also for authorities from municipalities. 

In Finland municipal authorities give permits to small facilities and also monitor compliance. 

For the state administration an interesting addition shall be an application which includes the monitoring 

objectives of regional centre, the collection of data from monitoring activities (like how quickly 

inspectors collect and check periodical reports, response time to exceeding of the limit values or complains, 

how much and why inspections are made and how inspectors react to non-compliance situations) 

and the comparison between the objectives and monitoring activities. This application is under development 

and should be in use in 2004.




TITLE OF PRESENTATION: How do we make our documentation ? 

NAME OF SPEAKER: Jean-Pierre Janssens 

ORGANISATION: BIME 

ADDRESS: Gulledelle 100, 1200 Bruxelles 

TEL. NUMBER: 02/775 75 11 

FAX NUMBER: 02/775 75 05 

E-MAIL ADDRESS: jpj@ibgebim.be 

Summary 

The dissertation explains how documentation is implemented for inspection at the BIME. 

All available information is easy accessible thanks to user friendly computer designed programs (for ex. 

Database of permits). 

This documentation system does not only allow to create an annual inspection program, but together 

with the manual ‘professionalization of inspection’, is consulted in all stages of inspection. This way 

technical and administrative information gets easily obtained and procedures are handled in a homogenous 

way. 

The extern handling of documentation concerns the importance of input of civilians, the output towards 

enterprises(for ex. for information about permits) and the obligations existing towards the political body. 

Wednesday, 8th. October 2003 

SESSION: Wednesday, 8 th. October 2003 


TITLE OF PRESENTATION: IMPEL as an instrument to stimulate better inspections and enforcement in Europe 

NAME OF SPEAKER: Caroline Jackson 

ORGANISATION: MEP, European Parliament, Environment Committee 

ADDRESS: Bruxelles 

TEL. NUMBER: 

FAX NUMBER: 

E-MAIL ADDRESS: cj@caroline jackson.demon.co.uk 

Summary: 

“As Chairman of the European Parliament's Environment Committee Dr Jackson has given particular priority 

to ensuring that there is adequate parliamentary follow-up to legislation already in place. She has 

instituted a series of follow up reports by MEPs on a number of directives now in force. She has given 

follow-up work this priority because she believes very strongly that, if EU environmental policy is to be 

meaningful it must be properly put into force, everywhere. If Member States neglect their obligations, 

then they are being dishonest with their own people, and simply perpetuating the conditions of uneven 

concern for the environment which was the origin of EU enviornmental policy in the 1970s.


However,she is concerned that the trend may continue for MEPs to be much more interested in putting 

new laws on the statute book than in following up what has happened to them. Time constraints, an 

understandable tendency for elected members to want to deal with something new, and the fact that 

MEPs depend on the Commission to shape their agenda all tend to take MEPs away from the essential 

work of parliamentary scrutiny. 

She believes that enforcement agencies, nationally and locally, need to be prepared to work much more 

closely with MEPs and to inform them about the work that they are doing. Whether or not a European 

directive actually works on the ground often depends on the work of enforcement officials a long way 

distant from the centres of national power, and this trend will continue as new Member States develop 

regional structures. 

She also believes that the European Commission should give a much higher priority to ensuring that it 

has good information from national governments in order to ensure that there really is equivalence of 

observance of EU laws. Where the evidence is lacking, or not delivered, the Commission needs to move 

much faster to take action through the Court of Justice. On all major directives it should publish short 

annual reports on the state of observance. 

The difficulties of ensuring uniform observance of highly complex environmental laws also mean that 

we need to examine what kind of legislation makes sense in a much more diverse EU than provided the 

original model for the kind of legislation we still have. Dr Jackson examines the case for less legislation 

form Brussels, based on rigorous impact assessments, and asks, if this means “shrinking the statute 

book”, what will there then be for the Commission to do...”


Annex 2. Short overview of the organisation of inspections 

in the EU Member States, Norway and acceding and candidate countries 

Austria 

Austria has no central inspection system. The licensing authorities in the Länder are also responsible for 

inspection activities. At a national level ultimate responsibility for co-ordinating inspection and 

enforcement rests with the Federal Ministry of Agriculture, Forestry, Environment and Water (BMLFUW), 

while responsibility for implementation rests primarily with the Provinces (except in the case of waste). 

In relation to the implementation of inspection, different agencies are involved at National, Regional, 

Sub-regional and Local levels and responsibilities are different for different sectors and laws. 

Responsibilities differ between regions. There are changes planned, which will result in more responsibilities 

being devolved to local authorities. 

Belgium 

Belgium is a federal state based on three regions defined by economic considerations: the Flemish 

Region, the Brussels Capital Region and the Walloon Region. The Regional Governments are each 

responsible for passing and implementing their own environmental legislation with the exception of legislation 

for transit of waste through Belgium, for setting of product norms and for matters concerning 

ionising radiation and nuclear waste management. 

The role of the regions, provinces and municipalities in compliance checking and enforcement varies 

between the regions. 

Brussels Capital Region 

The Brussels Inspectorate for Management of the Environment (BIME) plays a key role for inspections in 

the Brussels Capital Region. It is responsible for the control of air-, water- and soil-pollution, noise nuisance 

and elimination of all types of waste (except nuclear waste and transfer of waste). The BIME and 

the 19 Local Authorities of the Brussels region each have responsibility for inspection of all classes of 

installation; the BIME throughout the Region and Local authorities within their own jurisdiction. The 

BIME is responsible for issuing permits for class Ia and Ib installations (IPPC Annex 1 installations). Local 

authorities are separately responsible for permitting installations in the Class II. These are installations 

that require neither Environmental Impact Assessment nor Environmental Report. They are also responsible 

issuing “Declarations” for Class III installations, which are the smaller installations. 

Flanders 

In Flanders the Environment Inspection Section (EIS) is the enforcement agency for environmental 

hygiene legislation in the Flemish Region and is part of the Environment, Nature, Land and Water 

Management Administration. The Environment Inspection Section has a conventional vertical structure 

with the Chief Inspectorate in Brussels and 5 local services based in the main towns of the Flemish 

provinces. Each service is managed by a head of service who is appointed as hierarchical superior in 

accordance with civil service status. The Head of Section is responsible for overall organisation of each 

service. The Chief Inspectorate initiates and supervises the management of the inspections and investigation 

activities. Furthermore, it is responsible for the preparation, formulation and evaluation of policy 

and for ensuring logistical support for the service. The local services are responsible for carrying out specific 

inspection tasks, implementing measures, keeping company files up to date and providing policymakers 

with feedback on experience gathered in the field. 

In addition to the vertical structure, a horizontal structure has also been set up in the form of working 

groups for each environmental compartment. Each working group is composed of five members (one 

representative from each local service) and a representative from the Chief Inspectorate who acts as the 

working group moderator (project leader).


Walloon Region 

In the Walloon Region, environmental inspection is carried out by the Division of the Environmental 

Police (DPE) of the la General Directorate for Natural Resources and Environment of the Ministry of the 

Walloon Region). The DPE is organised as a central service providing logistic, administrative and legal 

support and co-ordinating 4 external directorates. 

Other organisations involved in inspections are the Judicial Police (Local Police – Federal Police)) as well 

as by the Water Division (Pollution of Surface Water)) and Division of Nature and Forests. 

Bulgaria 

The Ministry of Environment and Water (MoEW) is the main ministry responsible for inspection, 

although the Ministry of Health supervises bathing and drinking water inspection. 

MoEW has a number of regional bodies, including 

• The 15 regional inspectorates of environment (RIE) with a considerable degree of operational autonomy, 

• Four recently-established river basin directorates which will be gradually taking over some of the 

water pollution control responsibilities from the 15 regions; 

• A new Department within the Executive Environment Agency, which is to have permit responsibilities 

for IPPC installations; 

• Three national park directorates with nature protection responsibilities. 

The RIE must give their consent to any permit drafted for an operation in their region, whether by the 

Ministry, a basin directorate or the new Department in the Executive Environment Agency. 

RIE have laboratories all of which are equipped for air and water analyses and some of which can also 

undertake soil or radiological analyses. 

Cyprus 

Inspection responsibilities are shared by the Ministry of Agriculture, Natural resources and Environment 

(MANRE) and the Ministry of Labour and Social Insurance (MLSI) as follows: 

• Environment Service of MANRE with responsibilities in water and waste, 

• Department of Labour Inspectorate (previously factories inspectorate) of MLSI with responsibilities for air 

Both ministries are also responsible for permitting and monitoring; MANRE additionally evaluates EIA 

reports. For permitting, a technical advisory committee holds hearings where all stakeholders participate. 

They advise the relevant issuing ministry on operating conditions and emission limits. 

Other bodies also play an important environmental management role: 

• The Ministry of Health deals with all aspects of ground, drinking and bathing water quality, 

• The Ministry of Interior (in its role as town planning ministry) has responsibilities for landfill management, 

and 

• The Ministry of Commerce, Tourism and Industry has industry and energy efficiency as well as some 

waste responsibilities (batteries, packaging). 

Additionally, local authorities have broad management and implementation powers in law. 

Czech Republic 

The Ministry of Environment is responsible for the implementation of EC environmental law. It directs 

the tasks of the inspectorates, responsible for control and enforcement. A headquarters inspectorate provides 

methodological direction and supervision of regional inspectorates 

Several other institutions also play a role, including an IPPC Agency, the inspections of other ministries 

(Agriculture), local government etc. Co-operation among the institutions exists, some of it required by 

law, other on an ad hoc basis.


Denmark 

Environmental regulation in Denmark is decentralised. At the policy level, the Ministry of Environment 

and Energy is responsible for environmental policy and for establishing the legal framework in Acts. The 

Danish Environmental Protection Agency issues Orders and provides Guidelines on how to implement 

the Acts at an operational level, the counties (14) and the municipalities (274) are the main players and 

are responsible for issuing licenses, and undertaking inspections and environmental enforcement. 

Enforcement in Denmark is undertaken by the provinces (counties) and municipalities. In the legislation 

it is clearly defined which installations fall under whose responsibility. Principally installations which 

may have an environmental impact on water systems situated in more than one municipality fall under 

the responsibility of a county. The same principle holds for air emissions. Also, installations that are 

owned by municipalities are under the responsibility of a county. 

Total compliance checking and enforcement of about one sixth of the installations is done by the counties. 

The other installations are taken care of by the municipalities. Municipalities and counties are not 

subordinate to each other, but are the same level of authority. 

The state (the Danish Environment Protection Agency) does not have an inspectorate. 

Estonia 

In Estonia a single Environment Inspectorate is concerned with inspection and enforcement. It employs 

approximately 210 staff at national level and in seven regional units, who are involved in controlled 

installation work and in forest and nature protection. 

Laboratories are independent businesses. Permitting is the responsibility of the county (15) authorities. 

The inspectorates provide positions and opinions on permits. 

Finland 

The Ministry of Environment is responsible for preparing laws and regulations on environmental protection, 

the development of environmental policy, and supervising actions taken by authorities at the 

regional and local levels. Environmental permitting and the compliance monitoring of permits is decentralized: 

environmental permits are issued by the Environmental Permitting Authorities (3), the Regional 

Environmental Centres (13) and the Municipal Environment Authorities (414); compliance monitoring 

takes place through the Regional Environmental Centres (13) and the Municipal Environment 

Authorities (414). 

As part of the environmental permits, the authorities stipulate how an operator is to monitor emissions 

and report the results. In large installations, compliance monitoring focuses heavily on the quality and 

operation of self-monitoring and reporting systems as well as on the assessment report produced by the 

operator. In the case of medium-sized and small installation sites, inspections concentrate more on 

assessing the overall compliance of the operation. The compliance monitoring authorities may take coercive 

measures such as imposing a fine or even suspending an installation's operations. If such actions 

do not result in rectification of an unlawful situation, the authorities report the offence to the police for 

preliminary investigation. The public prosecutor may take the case to court. The Finnish Environment 

Institute supervises transboundary transportation of waste. 

France 

The Ministry of Ecology and Sustainable Development (MEDD) has overall responsibility for inspection 

and enforcement, which is exercised at National level through its Directorate for Risk and Pollution 

Prevention (DPPR). At Regional level, the main executive responsibility for inspection rests with the 

Regional Department of Industry, Research and Environment (DRIRE), although the Department of 

Veterinary Services (DDSV) is responsible for inspection of agro-food establishments and the Technical 

Department of the Police Prefecture of Paris (STIIIC) for inspection in Paris. At Department (Sub-region-


al) level, some inspection responsibilities (primarily relating to landfill sites) are discharged by three 

Département Directorates, while the Département Service for the Water Police covers the Urban Waste 

Water Directive. 

Responsibility for permitting rests with the Departmental Prefects supported by the services of the 

inspection of classified installations (DRIRE, DDSV, STIIIC). 

Germany 

In Germany responsibilities for inspections are devolved to the 16 states known as “Länder“. The administrative 

structures and responsibilities for compliance checking and enforcement varies among the Länder. 

Most commonly within the Länder there is a Ministry of Environment at the top level, a Bezirksregierung 

at the middle level and Kreise and Staatliche Umweltämter at the lower level. The Bezirksregierung is 

responsible for the quality control of lower governments. The Staatlichen Umweltämter are responsible for 

compliance checking and enforcement of big, medium and small size installations whereas the Kreise are 

often only responsible for the small size installations in the fields of waste and waste water. 

Greece 

Overall inspection responsibility rests with the Ministry for the Environment, Physical Planning and Public 

Works (YPEHODE), but many other ministries are also involved as Central Authorities at national level. 

Bodies involved at a regional level include Special Body of Environmental Protection Controllers (SBEPC), 

Bodies for the Control of Environmental Quality (BCQE), YPEHODE Regional Environmental & Physical 

Planning Unit, regional services of YPEHODE and other ministries, regional prefecture authorities, and 

prefectural units for environment and for health. 

A new legislation has been introduced to set up the Special Environmental Inspection Service (SENVIS). 

This will take over the responsibilities of a number of the existing agencies (e.g. SBEPC) and work with 

others. 

Hungary 

The national inspectorate is described as a ministerial office working under the authority of the Minister. 

Its main functions include appeals on decisions of Regional Environment Inspectorates, REI, data and 

reports on activities, evaluation of the effectiveness of implementation procedures and co-operation 

with other relevant organisations. 

The bodies responsible for most activities in the environment field are the 12 REI (covering groups of 

counties), whose responsibilities will include all major environment sectors once the merger of environmental 

pollution and water management is complete (except Seveso). REI each have a laboratory 

responsible for all sample testing in their region which also provide expert opinions on the evolution of 

environmental conditions. 

Both national and regional levels are in turn supervised and co-ordinated by the MoEW. 

The annual work programmes of the 12 REI are more than inspection and enforcement plans, since their 

responsibilities are much wider but include EIA (taken as a permitting process in Hungary), CI permitting, 

participation in monitoring, work on pollution sites, support of local authorities, co-operation with 

other relevant authorities. However, inspection plans set the number of visits to be undertaken and CI 

to be checked. Each REI knows the figure of controlled installations inside their region. But the meaning 

of “controlled installations” may differ from inspectorate to inspectorate. 

Procedures and responsibilities are extensively described in regulation, for example setting intervals for 

routine inspections by authority or purpose or leaving them free to determine their own. (The extent and 

strictness of regulation was identified as a bottleneck in both assessments.)


Ireland 

The key Inspecting Authority is the Environmental Protection Agency (EPA). As well as having specific 

responsibilities in relation to IPPC, waste management, VOCs (petroleum) and groundwater protection, 

the EPA oversees the activities of local authorities at a sub-regional level (counties and cities) in other 

areas (covering most non-IPPC installations). Responsibilities of the EPA include licensing and permitting 

as well as inspection and enforcement. 

The local authorities issue single media licenses to smaller industries involving emissions to air, wastewater 

discharges and waste disposal. The local authorities are also largely responsible for compliance 

checking and enforcement. 

The Occupational Health and Safety Authority checks installations that constitute a potential risk for 

major accidents. 

Italy 

Several Administrations cover an inspection role in Italy. Depending on the Regional laws of each environmental 

sector (air, water, waste, soil, Seveso and IPPC), either the regional or provincial administrations 

issue permits and are, in most of the cases, responsible for the planning of ordinary inspections 

together with the Regional Agencies for the Protection of the Environment (ARPA). 

Generally the routing site visits are fulfilled by the ARPAs, while the non-routing site visits due to either 

serious environmental complaints, environmental accidents, incidents and occurrences of non-compliance 

are carried out by the Carabinieri Corps for Environmental Protection, the Provincial Police (on 

request of the provincial authorities), the Financial Guards and the State Forestry Corps, together with 

the ARPAs who provide technical support. 

But in most of the cases the Police Authorities (Provincial Police, Carabinieri Corps, Forestry Corps and 

Financial Guards) are in charge to investigate and/or identify environmental crimes such as for example 

illegal waste business, illegal water discharges, etc. 

APAT, the Agency for Environmental Protection and Technical Services (former ANPA) executes inspections, 

controls and monitoring for Seveso (together with the Ministry of Environment, the National Body 

of Firemen, ISPESL, ARPAs, for nuclear matters and for the competencies assigned to the Agency. 

In some Regions, due to institutional competencies, the State Forestry Corps realises routing site visits 

while the ARPA provides technical support on sampling and analysis. 

Latvia 

A national Environment State Inspectorate and 8 Regional Environment Boards are responsible for 

inspection and enforcement under the supervision of the Ministry of Environment and Regional 

Development. 

The Environment State Inspectorate and Regional Environment Boards are separate entities; they are 

nevertheless jointly responsible for environmental inspection. The national body may also undertake 

inspections and participate in decisions in non-compliance cases. Finally, the State Inspectorate is taking 

particular responsibility for Seveso-related inspection. 

Regional Boards are generally responsible for permitting. Appeals on permit conditions are heard by the 

State EIA Bureau, which also has BAT responsibilities under IPPC. 

Other bodies involved in environmental management include the Occupational Health Inspection, State 

Label Inspection, Fire Service and Municipalities. 

Lithuania 

There are 8 Regional Departments for Environmental protection, which in turn operate through 56 more 

local Environmental Protection city/district agencies under Ministry of environment. The State 

Environmental Protection Inspectorate conducts methodological support. Appeal against punishment 

procedures have only courts. Both national and regional organizations report to the Ministry of the


Environment whilst the local agencies report to their regional department. 

They cover most but not all environmental sectors. Nature protection is inside their remit, but certain 

water issues (drinking and bathing waters) are outside their remit. Some aspects of waste management 

are the responsibility of 10 county or 60 municipal authorities. 

Regional departments have permitting, monitoring and laboratory services. Local Agencies are responsible 

for inspection and enforcement. Monitoring is conducted both by Regional Departments and 

National Agency for Environmental Protection and coordinated by National Agency for Environmental 

Protection. 

Luxembourg 

Inspection responsibilities in Luxembourg are focused at national level, with the Administration for the 

Environment (AfE) having primary responsibility and reporting to the Ministry of the Environment. 

Routine monitoring and inspection is carried out by accredited contractors on behalf of AfE, and 

Customs and Excise is also involved in some aspects (particularly transboundary movements of waste). 

Officials from the Administration of Environment will only perform on site visits occasionally and in 

order to respond to complaints, sometimes in order to verify the work of the external accredited experts. 

Malta 

In Malta, three authorities respond to the major number of inspections and enforcement requirements 

of the environment and nature related directives or national legislation. MEPA is the competent authority 

responsible for the implementation of the majority of environmental laws. Coordination between the 

other two competent authorities - Occupational Health and Safety Authority (responsible for Seveso) 

and the Malta Resources Authority (responsible for water pollution and resource management) - is 

achieved through bilateral or multilateral ministerial committees, and formal memoranda of understanding 

(being finalized). 

In addition, several other bodies are described as playing a technical role, with the Malta Police Force 

playing a very important role in offering support on access and enforcement. Local Councils are also 

involved through their Warden service. 

There are currently 22 staff members within the Environment Protection Directorate –MEPA, dealing 

with the policymaking, permitting, implementation and enforcement of environmental related legislation 

in regards to pollution control, waste and mineral issues. Regular monitoring is being carried out in 

the following fields: marine, air, mineral extraction and land filling. 

Inspections are carried out according to a work plan devised on a yearly basis. Both announced and 

unannounced inspections are performed. The inspectorate possesses prosecutorial powers but the system 

is still not in place. A database of inspections and permits has been established. This enables the 

inspector to fill in a report after every inspection and provide this information to the other inspectors 

instantly. 

Other branches within MEPA are responsible for other areas, e.g. nature protection. 

The Netherlands 

In the Netherlands more than 500 organisations have roles and responsibilities for inspections. Co-ordination 

of inspection activities is ensured by the National Conference on Environmental Enforcement 

(ALOM/BLOM) and the National Information Service for Environmental Enforcement (LIM) at national 

level and 35 service points of the Regional Service for Environmental Law Enforcement (SEPH) at subregional 

level. 

Provinces, municipalities and water boards are largely responsible for permitting and inspection. 

However, for certain sectors, e.g. Nuclear installations and transfrontier shipment of waste, these activities 

are performed by central organisations like the Inspectorate for the Environment (part of the 

Ministry of Housing, Spatial Planning and Environment and the Directorate General of Public Works and


Water Management (Rijkswaterstaat). 

The Inspectorate General carries out a supervisory role over provinces, municipalities and water boards, 

including first-and second line compliance checking and enforcement actions. 

Norway 

The Ministry of the Environment is responsible for all subordinate agencies with responsibility for environmental 

protection. The Norwegian Pollution Control Authority (SFT) is one of the subordinate agencies 

to the Ministry of the Environment. SFT’s Department of Control and Emergency Response carries 

out enforcement and monitoring of compliance in industry at the national level. 

The 18 County Departments of Environmental Affairs are also subordinate to the Ministry of the 

Environment and administers parts of the Pollution Control Act. They are responsible for enforcement 

and monitoring of compliance of municipal functions and some types of industries at the regional level. 

SFT is authorised to issue instructions to the County Departments of Environmental Affairs concerning 

e.g. pollution, and waste. Local authorities are also involved in inspections. 

Poland 

The environmental inspection authority is a single structure with the Chief Inspectorate for Environmental 

Protection setting out the direction of work for 16 voivodship inspectorates for environmental protection 

included in so called joint voivod administration. 

Its responsibilities focus on inspection, with permitting limited to transfrontier movement of waste 

(exclusive competence of the Chief Inspector for Environmental Protection). Field of action of the 

Inspection encompasses the whole environment chapter including the rational use f natural resources, 

GMOs, packaging, Seveso. The Inspection is also responsible for state of environment monitoring and 

for reporting. The Chief Inspector hears appeals from the voivodship inspectorates’ decisions and also 

can undertake all activities belonging to the competencies of the voivodship inspectorates when considered 

it as justified with regard to the importance and complexity of those activities. 

There are also other authorities responsible for undertaking inspections, such as: self-government bodies 

(on the level of voivod, poviat and gmina) which are competent to control of the compliance to the 

administrative decisions issued by them in the scope of environmental protection, State Sanitary 

Inspection (as regard of drinking water and bathing water), Veterinary Inspection, State Labour 

Inspection, Trade Inspection, Construction Supervision. 

Portugal 

The Ministry of Towns, Territorial Planning and Environment (MCOTA) plays a key role for inspections at 

National Level (through the Inspectorate General for the Environment (IGA)) as well as for co-ordinating 

inspection and enforcement. 

The IGA is the competent authority for implementation and enforcement of environmental law with an 

integrated approach for inspections dealing with different types of pollution - air , noise , water, solid 

wastes, and also other aspects related to environmental legislation e. g. industrial safety, critical areas 

for risk. 

IGA deals also with checking compliance with environmental contract and water supply systems, discharges 

from municipal wastewater plants and collective industrial wastewater plants and accidents. For 

all the cases inspections are often carried out by unannounced on-site visits. 

Permitting for waste water discharges is up the five regional departments of the Ministry for 

Environment as well as to check the compliance for this license by low educated trained personnel in 

drive by visits.


Romania 

The Ministry of Waters and Environmental Protection includes a General Commissioner’s Office with 8 

commissioners leading an environmental guard in the 44 Regional Inspectorates Inspectorates (42 

judets, Bucharest and the Danube Delta biosphere reserve). Since 1998, a water inspectorate with a 

Ministry supervising team plus inspectors in 11 river basin areas exists in parallel. 

The inspectors function as advisers in the permitting procedure undertaken by a separate unit of the 

environment body within each Judet. At present, a single permit is issued with annexes relating to each 

medium according to a standard format. The system is in the process of transformation, with the creation 

of a national Environment Agency and eight regional Inspectorates taking over some responsibilities 

currently divided between the Ministry and Judet inspectorates. 

Slovakia 

In Slovakia the inspection authority structure combines national, regional, sectoral and local responsibilities. 

The national headquarters includes the five sectoral departments, each providing methodological support 

and appeal functions for groups of three to five regional sectoral inspectorates. 

76 district offices under the aegis of the Minister of the Interior are responsible for all permits at present 

and also have powers of inspection and enforcement to ensure permit conditions are met. 

Permitting responsibilities are to be transferred to 36 new districts under the responsibility of the 

Minister of Environment. Further, a new national IPPC department is being created, with three regional 

groups combining permitting and inspection. 

Slovenia 

In Slovenia the national inspection authority combines a number of functions including mining, energy 

and spatial planning as well as environment. At the regional level, eight inspectorates cover environment 

and spatial planning. In addition, there are local environmental inspections with limited competence 

based on local ordinances. 

Other authorities with related responsibilities include health, agriculture, forests, hunting and fishing, 

and trade. 

An Environment Agency is responsible for permitting activities that are independent and isolated from 

inspections. 

Spain 

The organisation of the inspection system in Spain is largely comparable to the situation in Germany. 

The inspection system is organised in the individual states at a regional level. There is no national 

inspecting body. 

The main focus of inspection and enforcement in Spain is at “regional” level,(Autonomous Communities 

are different than regions). The 17 Autonomous Communities and the two autonomous cities of Ceuta 

and Melilla) have prime responsibility for inspection through their Environment Ministries. At national 

level the Ministry of Home Affairs is responsible for the implementation of Seveso II, while the nature 

protection services of the Civil Guard (SEPRONA) provide technical support to Autonomous 

Communities. At waterbasin level, the 9 Water Management Boards are responsible for inspection and 

enforcement relating to discharges to inland waters. At Local levels some officials are also involved. 

Sweden 

In Sweden environmental inspection takes place at three levels (National, Regional and Local). The 

Swedish Environmental Protection Agency (SEPA) is the central authority on supervision concerning all 

the directives listed by Commission as connected to the Recommendation except for the SevesoII 

Directive. The Swedish Rescue Services Agency is the central authority on supervision concerning


SevesoII Directive. Both these authorities have a role concerning guidance, evaluation, co-ordination as 

well as giving advise and support to the regional and local authorities carrying out inspection and 

enforcement. 

Swedish environmental inspection and enforcement concerning installations and other activities, among 

which the Controlled Installations according to the Recommendation 2001/331/EC only are a minor 

part, is mostly planned and carried out at regional and local level. There are 21 regional authorities 

responsible for inspection and enforcement concerning all the listed directives. For all the listed directives 

except the SevesoII Directive, such inspection responsibility may be delegated after a special procedure 

to the local environmental authorities of which there are 290, also having other environment 

and health protection inspection responsibilities. 

The Surgeon General (National) is responsible for inspecting military installations. 

Operators are required to self-monitor (there is a separate Operator Self Monitoring Ordinance) and 

demonstrate compliance with their permits. 

Permitting is carried out by four Environmental Courts and the above mentioned 21 regional environmental 

authorities. At the regional authorities the permitting and inspection is taking place at the same 

authority. Special governmental instructions keep the licensing task separated from the inspection task. 

The Enforcement and Regulations Council has been established for exchange of experiences between 

the central, regional and local authorities under the Swedish Environmental Code. 

United Kingdom 

In the UK, there are three separate but similar systems for the regulation of the environment in (1) 

England and Wales, (2) Scotland and (3) Northern Ireland. Environmental laws and policies are generally 

made at the sub-UK level e.g. Northern Ireland, and these are then fully implemented (including 

permits, inspection and enforcement) by the Environment Agency (England and Wales), the Scottish 

Environmental Protection Agency or the Northern Ireland Environment and Heritage service for each 

area. Local authorities also have a role in inspections, although in Scotland it is fairly limited. 

Environmental negotiations in Europe are however dealt with at the UK level, which means that all three 

areas work together on this. The Department of Trade & Industry covers offshore installations at a 

national level.


Annex 3. Letter from the Ministry of Housing, 

Social Planning and the Environment


Annex 4. List of participants. 

AUSTRIA 

Guenter Düssing 

Chemist 

Office of the Provincial Government 

Dep. of Environmental Protection 

Postfach 527 

5010 SALZBURG 

AUSTRIA 

Tel: 0043662-8042 4548 

Fax: 0043662-8042 4167 

guenter.dussing@salzburg.gv.at 

Armin Heidler 

Impel Coordinator Austria 

Ministry of Environment 

Stubenbastei 5 

1000 VIENNA 

AUSTRIA 

Tel: 0043151522 2109 

Fax: 0043151522 7122 

armin.heidler@bmlfuw.gv.at 

Karl Hiesberger 

UVP-Jurist 

Ambt der NÖ Landesregierung 

Landhausplazt 1 

3109 ST.PÖLTEN 

AUSTRIA 

Tel: 00432742 9005 15206 

Fax: 00432742 9005 15280 

karl.hiesberger@noel.gv.at 

Andrea Jungwirth 

Legal Expert for the Industrial Code-Env. Matters 

Federal Ministery for Economics 

Stubenring 1 

1010 VIENNA 

AUSTRIA 

Tel: 00431-71100 5811 

Fax: 00431-7142718 

andrea.jungwirth@bmwa.gv.at 

Mag. Markus Mac Kitzberger 

Anlagenjurist 

Bezirkshauptmannschaft Grieskirchen 

Manglburg 14 

4710 GRIESKIRCHEN 

AUSTRIA 

Tel: 00437248 603-407 

Fax: 00437248 603-399 

markus.kitzberger@ooe.gv.at 

Waltraud Petek 

Head of Department 

Fed. Ministry of Agriculture, Forestry 


1010 VIENNA 

AUSTRIA 

Tel: 00431-51522-2123 

Fax: 00431-51522-7122 

waltraud.petek@bmlfuw.gv.at 

Walter Pirstinger 

IFS Koordinator Austria - Technical Expert 

Bundesministerium fur Umwelt 


1010 WIEN 

AUSTRIA 

Tel: 00431-515223519 

Fax: 00431-51316791265 

walter.pirstinger@bmlfuw.gv.at 

Otto di Simoner 

Amtssachverständiger 

Amt d. stmk. LReg. 

Albertstrasse 1 

8010 GRAZ 

AUSTRIA 

Tel: 0043316-8775977 

Fax: 0043316-8772930 

otto.simoner@stmk.gv.at


Gisela Wolschner 

Responsible for EU-Projects 

Provincial Government of Carinthia 

15 Environment and Technology 

Flatschacherstrasse 70 

9020 KLAGENFURT 

AUSTRIA 

Tel: 0043463-536-31535 

Fax: 0043463-536-31500 

Gisela.Wolschner@ktn.gv.at 

BELARUS 

Marina Yanush 

Deputy head of legal and personnel department 

Ministry of Natural Resources and 

Environment Protection 

10, Kollectornaya str. 

220048 MINSK 

BELARUS 

Tel: 00375 17 2202767 

Fax: 00375 17 2205583 

yanush-marina@tut.by 

BELGIUM 

Robert Baert 

Inspector-General 

Environment Inspection Section 

Koning Albert II-Laan 20 bus 8 

1000 BRUSSELS 

BELGIUM 

Tel: 00322-5538183 

Fax: 00322-5538085 

milieu-inspectie@lin.vlaanderen.be 

Paul Bernaert 

Head of the Chief Inspectorate 

The Flemish Env. Inspection Section 

Graaf de Ferraris, 

Koning Albert II-laan 20 

1000 BRUSSELS 

BELGIUM 

Tel: 00322-5538197 

Fax: 00322-5538085 

paul.bernaert@lin.vlaanderen.be 

Ann van Damme 

Hoofd onderafdeling Inspectie 

Afdeling Inspectie en Patrimonium 

Gulledelle 98-100 

1200 BRUSSELS 

BELGIUM 

Tel: 00322-7757523 

Fax: 00322-7757505 

ava@Ibgebim.be 

Olivier Dekyvere 

Inspector 

Environment Police Department 

15, Avenue Prince de liège 

5100 NAMUR 

BELGIUM 

Tel: 003281-336003 

Fax: 003281-336020 

O.Dekyvere@mrw.wallonie.be 

Linda van Geystelen 

Director 

Milieu-Inspectie 

A Van Roeyenstraat 12 

2070 ZWYNDRECHT 

BELGIUM 

Tel: 00323-2246423 

Fax: 00323-2246428 

linda.vangeystelen@lin.vlaanderen.be 

Serge Godfroid 

Inspecteur Général 

Environmental Police Department 

Avenue Prince de Liège, 15 

5000 NAMUR 

BELGIUM 

Tel: 003281-33607 

Fax: 003281-336022 

se.godfroid@mrw.wallonie.be 

Bernard Gratia 

Inspector 

Department of the Walloon Region 

Rue de l' Ecluse 22 

6000 CHARLEROI 

BELGIUM 

Tel: 003271-654737 

Fax: 003271-654711 

BGratia@mrw.wallonie.be


Didier Hanquart 

Inspector 


Chaussie de Biuche, 101 

7000 MONS 

BELGIUM 

Tel: 003265-320440 

Fax: 003265-320480 

d.hanquart@mrw.wallonie.be 

Jean Pierre Janssens 

Directeur-Head of Division Inspection 

Institute for the Management of Env. 

Gillledelle 100 

1200 BRUSSELS 

BELGIUM 

Tel: 00322-7757501 

Fax: 00322-7757505 

jpj@ibgebim.be 

Roland Loontiens 

Ingenieur-Diensthoofd 

Milieu-Inspectie 

K.astridlaan 29/4 

B 8200 BRUGGE 

BELGIUM 

Tel: 003250-404211 

Fax: 003250-311512 

roland.loontiens@lin.vlaanderen.be 

Claude Loterman 

Inspector 

Environnement Police Department 

Avenue Prince de Liège, 15, 

Chemin du Canon,112 

5100 NAMUR 

BELGIUM 

Tel: 003281-336013 

Fax: 003281-336022 

c.loterman@mrw.wallonie.be 

Frans van de Maele 

Directeur-Ingenieur 

Milieu-Inspectie Vlaanderen 

Waaistraat 1 

B 3000 LEUVEN 

BELGIUM 

Tel: 003216-211165 

Fax: 003216-211151 

frans.vandemaele@lin.vlaanderen.be 

Dominique Martin 

Inspector 


Rue Nanon 98 

5000 NAMUR 

BELGIUM 

Tel: 003281-243449 

Fax: 003281-243450 

d.martin@mrw.wallonie.be 

Regine Merz 

Inspector 


Rue Nanon 98 

5000 NAMUR 

BELGIUM 

Tel: 003281-243441 

Fax: 003281-243450 

r.merz@mrw.wallonie.be 

Laurent Mont 

Inspector 


22, Rue de l' Ecluse 


BELGIUM 

Tel: 003271-654738 

Fax: 003271-654711 

l.mont@mrw.wallonie.be 

Patrick Nelis 

Chef DV Departement Prevention des Risque 

Inst. pour la Gestion de L'Environnement 

Gulledelle 100 

1200 BRUSSELS 

BELGIUM 

Tel: 003227757522 

Fax: 003227757505 

pne@ibgebim.be 

Serge Pierlot 

Inspector 




BELGIUM 

Tel: 003271-654719 

Fax: 003271-654711 

s.pierlot@mrw.wallonie.be


Lydia Ranwez 

Inspector 




BELGIUM 

Tel: 003271-654738 

Fax: 003271-654711 

l.ranwez@mrw.wallonie.be 

Peter Schryvers 

Chemical Engineer - Environmental Inspector 

Environment Inspection Section 

Koning Albert II-Laan 20 bus 8 

B-1000 BRUSSELS 

BELGIUM 

Tel: 00322-5538196 

Fax: 00322-5538085 

Peter.Schryvers@lin.vlaanderen.be 

Gaetan Wilmart 

Inspector 


Rue Nanon 98 

5000 NAMUR 

BELGIUM 

Tel: 003281-243445 

Fax: 003281-243450 

g.wilmart@mrw.wallonie.be 

BULGARIA 

Ivona Grozeva 

Senior Expert 

Ministry of Environment and Water 

67 W. Gladstone Street 

1000 SOFIA 

BULGARIA 

Tel: 003592-9406001 

Fax: 003592-9816610 

ji_grozeva@moew.government.bg 

Nikolay Kenanov 

Coordinator of the Regional Inspectorates 


67, W. Gladstone Street 

1000 SOFIA 

BULGARIA 

Tel: 003592-9406387 

Fax: 003592-9813384 

Kraps@moew.government.bg 

Svetlana Zhekova 

AC-Impel National Coordinator 


67, W. Gladstone Strreet 

1000 SOFIA 

BULGARIA 

Tel: 003592-9406266 

Fax: 003592-9885316 

szhekova@moew.government.bg 

CROATIA 

Iva Milic-Strkalj 

Head of sector env. and nature protection 

Min. of Env. Protection and Physical Pl. 

Gajeva 30a 

10000 ZAGREB 

CROATIA 

Tel: 003851-4898070 

Fax: 003851-4898066 

iva.milic@mzopu.hr 

Sladana Miocic 

Assistant minister-Inspection Division 

Min. of Environmental Protection 

Gajeva 30a 

10000 ZAGREB 

CROATIA 

Tel: 003851-4898022 

Fax: 003851-4898049 

s.miocic@mzopu.hr 

Anita Pokrovac Patekar 

Head Inspector for Environmental Protection 

Min. of Env. Protection and Physical Pl. 

Gajeva 30a 

10000 ZAGREB 

CROATIA 

Tel: 003851-4898024 + 14898022 

Fax: 003851-4898066 + 148980 

anita.pokrovac.patekar@mzopu.hr


CYPRUS 

Aristodemos Economides 

Labour Inspection Officer 

Department of Labour Inspection 

Apellis 12 

1480 NICOSIA 

CYPRUS 

Tel: 0035722300334 

Fax: 0035722663788 

roc.dli@cytanet.com.cy 

Costas Hadjipanayiotou 

Environmental Officer 

Environment Service 

Ministry of Agriculture, 

Natural Resources & Environment 

1411 NICOSIA 

CYPRUS 

Tel: 0035722-303854 

Fax: 0035722-774945 

rocperiv@cytanet.com.cy 

CZECH REPUBLIC 

Lenka Nemcová 

Czech Environmental Inspectorate 

Dep. for International Co-operation 

Na Brehu 267 

190 00 PRAHA 


Tel: 0042602-644068 

Fax: 0042283-892662 

nemcova@cizp.cz 

Jan Slanec 

Director 


Na Brehu 267 

190 00 PRAGUE 


Tel: 0042283-891564 

Fax: 0042283-892662 

slanec@cizp.cz 

Pavel Sremer 

Deputy Director for International Co-operation 


Cizp, Na Brehu 267 

190 00 PRAGUE 


Tel: 0042283891564 

Fax: 0042283892662 

stremer@cizp.cz 

Ivo Trojan 

Head of the International Dep. 


Na Brehu 297 

19000 PRAGUE 


Tel: 0042602-124285 

trojan@cizp.ez 

DENMARK 

Gert Thorhauge Andersen 

Environmental Inspector 

Herning Kommune 

Radhuset,Torvet 

DK 7400 HERNING 

DENMARK 

Tel: 004596-282663 

Fax: 004596-282980 

mjoga@herning.dk 

Mikael Skou Andersen 

Nat. Env. Research Institute 

Grenaavej 12 

8410 RONDE 

DENMARK 

Tel: 004589-201555 

Fax: 004589-201515 

msa@dmu.dk 

Steen Fogde 


City of Elsinore 

Moerdnipvej 15 

3060 ESPERGAERDE 

DENMARK 

Tel: 004549-282506 

Fax: 004549-282416 

sfo55@helsingor.dk


Vita Jokumsen 

Environmental Engineer 

Vejle Region 

Damhaven 12 

7100 VEJLE 

DENMARK 

Tel: 004575835333 

Fax: 004575727754 

vjo@vejieamt.dk 

Charlotte Larsen 

M. Sc. Chemical Engineering 

County of South Jutland/DK 

Jomfrustien 2 

6270 TOENDER 

DENMARK 

Tel: 004574-335052 

Fax: 004574-335001 

CBL@sja.dk 

Lars Arne Okkels 

Environmental Technician 

Vejle Region, Industrial Env. Division 

Damhaven 12 

7100 VEJLE 

DENMARK 

Tel: 004575835333 

Fax: 004575727754 

pw@vejleamt.dk 

Anne Marie Rasmussen 


Vejle Region 

Damhaven 12 

7100 VEJLE 

DENMARK 

Tel: 004575835333 

Fax: 004575727754 

amr@vejlcamt.dk 

ESTONIA 

Dora Kukk 

Leading Environmental Inspector 

Environmental Inspectorate 

Lahe 38 

90502 HAAPSALU 

ESTONIA 

Tel: 003724724120 

Fax: 003724724121 

dora.kukk@kkl.ee 

Aare Sirendi 

Head of Environmental Department 


Kopli 76 

10416 TALLINN 

ESTONIA 

Tel: 003725101590 

Fax: 003726962237 

aare.sirendi@kki.ee 

Marit Vihlver 



Kunderi 18 

44307 RAKVERE 

ESTONIA 

Tel: 003723258415 

Fax: 003723258418 

marit.vihlver@kki.ee 

EUROPEAN COMMISSION 

Anna Bobo Remijn 

Legal Coordinator 


Avenue de Beaulieu 9, B-1160 

1160 BRUSSELS 

BELGIUM 

Tel: 00322-7990334 

Fax: 00322-2994123 

anna.bobo-remijn@cec.eu.int 

Martina Doppelhammer 

Administrator 


Av. de Beaulieu 9 

1160 BRUSSELS 

BELGIUM 

Tel: 00322-2993660 

Fax: 00322-2991070 

martina.doppelhammer@cec.eu.int


Valérie Drezet-Humez 

Administrateur 


DG Environment 

200 Rue de la Loi 

1049 BRUSSELS 

BELGIUM 

Tel: 00322-2960038 

Fax: 00322-2996617 

valerie.drezet-humez@cec.eu.int 

Georges Kremlis 

Head of Unit: Legal Implementation 


Avenue de Beaulieu 9 

1049 BRUSSELS 

BELGIUM 

Tel: 00322-2966526 

Fax: 00322-2991070 

georges.kremlis@cec.eu.int 

Renata Novakova 

Stagiaire 

IMPEL Secretariat 

Avenue de Beaulieu 9 

1049 BRUSSEL 

BELGIUM 

Tel: 00322-2994383 

Fax: 00322-2991070 

renata.novakova@cec.eu.int 

Gernot Schnabl 

Principal Administrator 


BU-9 4/159 

B1049 BRUSSELS 

BELGIUM 

Tel: 003222992725 

Fax: 003222290313 

gernot.schnabl@ccc.cu.Int 

Sabine Sommer 

Impel Coordinator 


DG Environment 

Avenue de Beaulieu 9 1/94 

1049 BRUSSELS 

BELGIUM 

Tel: 003222994383 

Fax: 003222991070 

sabine.sommer@cec.eu.int 

EUROPEAN ENVIRONMENT BUREAU 

John Hontelez 

Secretary General 

European Environmental Bureau 

Boulevard de Waterloo, 34 

1000 BRUSSELS 

BELGIUM 

Tel: 00322-2891090 

Fax: 00322-2891099 

hontelez@eeb.org 

EUROPEAN PARLIAMENT 

Caroline Jackson 

Chairman 

European Parliament Environment 

ASP 14 E 205, Rue Weirtz 

1047 BRUSSELS 

BELGIUM 

Tel: 00322-2845255 

Fax: 00322-2849255 

CJackson@europarl.eu.int 

FINLAND 

Markku Hietamäki 

Environmental Counsellor 

Ministry of the Environment 

P.O. Box 35 

FIN-00032 Government Helsinki 

FINLAND 

Tel: 003589-16039703 

Fax: 003589-16039453 

markku.hietamaki@ymparisto.fi


Ari Kangas 

Chief Inspector 

Regional Environment Centre 

P.O. Box 36 

521 HELSINKI 

FINLAND 

Tel: 0035820-4903049 

Fax: 0035820-4903202 

ari.kangas@ymparisto.fi 

Erkki Kantola 

Environmental Counsellor 

Environment Permit Authority 

P.O. Box 113 

90101 OULU 

FINLAND 

Tel: 00358400-892001 

Fax: 003588-5348550 

erkki.kantola@ymparisto.fi 

Marianne Lindström 

Project Manager 

Finnish Environment Institute 

P.O. Box 140 

251 HELSINKI 

FINLAND 

Tel: 003589-40300458 

Fax: 003589-40300490 

marianne.lindstrom@ymparisto.fi 

FRANCE 

Pascal Barthe 

Ingenieur 

D.R.I.R.E Midi Pyrénées 

12, rue Michel Labrousse, BP 1345 

31107 TOULOUSE 

FRANCE 

Tel: 00335-62149049 

Fax: 00335-62149001 

pascal.barthe@industrie.gouv.fr 

Christian Bathelier 

Ingenieur 

D.R.I.R.E. Alsace 

1 Rue Pienet Montet 

67000 STRASBOURG 

FRANCE 

Tel: 003338-8259245 

Fax: 003338-88369813 

christian.bathelier@industrie.gouv.fr 

Annick Bonneville 

Environmental Inspection Coordinator 


20 Avenue de Segur 

75302 PARIS 

FRANCE 

Tel: 00331-42191444 

Fax: 00331-42191467 

annick.bonneville@environnement.gouv.fr 

Cecile Castel 

Environmental Inspection 

Ministry of Ecology 

20, Avenue de Segur 

75302 PARIS 

FRANCE 

Tel: 00331-42191473 

Fax: 00331-42191461 

cecile.castel@environnement.gouv.fr 

Francois Champeix 

Risk Engineer 

DRIRE Marseille 

67-69 Av. Du Prado 

13286 MARSEILLE 

FRANCE 

Tel: 00334-91836382 

Fax: 00334-91836440 

francois.champeix@industrie.gouv.fr 

Marie-Claude Dupuis 

Chief of the French Inspectorate 


20 Avenue de Segur 

75302 PARIS 

FRANCE 

Tel: 00331-42191440 

Fax: 00331-42191467 

marie-claude.dupuis@environnement.gouv.fr 

GERMANY 

Richard Bolwerk 

Referent/Reg. Gen. Direktor 

Bezirksregierung Münster 

Domplatz 1-3 

48128 MÜNSTER 

GERMANY 

Tel: 0049251-4111550 

Fax: 0049251-41181550 

richard.bolwerk@bezreg.muenster.nrw.de


Hans-Werner Breuer 

Referent 

Ministerium for Umwelt des Landes NRW 

Schwannstrasse 3 

40476 DÜSSELDORF 

GERMANY 

Tel: 0049211-4566586 

Fax: 0049211-4566417 

hans-werner.breuer@munlv.nrw.de 

Horst Büther 

Staatliches Umweltamt Siegen 

Unteres Schloß 

57072 SIEGEN 

GERMANY 

Tel: 0049271-585251 

Fax: 0049271-585201 

poststelle@stua-si.nrw.de 

Arnold Erle 

Referent 

Staatliches Umweltamt Lippenstadt 

Lipperoder Straße 8 

59555 LIPPSTADT 

GERMANY 

Tel: 00492941-986320 

Fax: 00492941-986350 

arnold.erle@stua-lp.nrw.de 

Wolfgang Feldmann 

Amtsleiter 

Staatliches Umweltamt Jarten 

Gartenstraße 27 

45699 JARTEN 

GERMANY 

Tel: 00492366-807201 

Fax: 00492366-807440 

wolfgang.feldmann@stua-he.nrw.de 

Franz Grassmann 

Director 

Environment Office Wünsdorf 

Amt F. immissionsschutz Wünsdorf 

Am Baruther Tor 12 

D-15838 WÜNSDORF 

GERMANY 

Tel: 004933702 73101 

Fax: 004933702 73107 

Franz.Grassmann@afi-wdf.brandenburg.de 

Andreas Jungmann 

District Government Arnsberg 

Bezirksregierung Arnsberg 

Referat 52 

59817 ARNSBERG 

GERMANY 

Tel: 00492931-822606 

Fax: 00492931-8240099 

andreas.jungmann@bezreg-arnsberg.nrw.de 

Helga Katzer 

Dezernentin im Dezernat Immissionsschutz 

Bezirksregierung Düsseldorf 

Cecilienallee 2 


GERMANY 

Tel: 0049211-4752296 

Fax: 0049211-4752790 

helga.katzer@brd.nrw.de 

Bernhard Klockow 

Behördenleiter 

Staatliches Gewerbeaufsichtsamt Hannover 

Am Listholze 74 

30177 HANNOVER 

GERMANY 

Tel: 0049511-9096300 

Fax: 0049511-909617300 

bernhard.klockow@gaa-h.niedersachsen.de 

Helmut Kruber 

Ministerium für Umwelt und Naturschutz 


GERMANY 

Tel: 0049211-4566577 

Fax: 0049211-4566949 

helmut.kruber@munlv.nrw.de 

Rolf Linnenkamp 

Abteilungsleiter 

Umweltministerium 


GERMANY 

Tel: 00492114566550/551 

Fax: 00492114566949 

rolf.linnenkamp@mun/v.nrw.de


Christof Mainz 

Ministerium für Umwelt und Naturschutz 

Schwannstraße 3 


GERMANY 

Tel: 0049211-4566-304 

Fax: 0049211-4566-388 

christof.mainz@munlv.nrw.de 

Paul-Jürgen Meier 


Staatliches Umweltamt Düsseldorf 

Schamzenstraße 90 


GERMANY 

Tel: 0049211-5778111 

Fax: 0049211-5778370 

paul-juergen.meier@stua-d.nrw.de 

Wulf Pompetzki 

Landesumweltamt NRW 

Wallneyer Straße 6 

45133 ESSEN 

GERMANY 

Tel: 0049201-79951306 

Fax: 0049201-79951574 

wulf.pompetzki@lua.nrw.de 

Bruno Reddehase 

Techn. Aufsichtsbeamter Arbeits- & Umweltschutz 

Staatliches Gewerbeaufsichtsamt Hannover 

Am Listholze 74 

30177 HANNOVER 

GERMANY 

Tel: 0049511-9096207 

Fax: 0049511-909617207 

bruno.reddehase@gaa-h.niedersachsen.de 

Christof Sangenstedt 

National IMPEL Coordinator 

Bundesministerium für Umwelt 

11055 BERLIN 

GERMANY 

Tel: 00491888-3054352 

Fax: 00491888-3053331 

christof.sangenstedt@bmu.bund.de 

Gabriele Schmidt 

Juristin 

Landesumweltamt Nordrhein-Westfalen 

Wallneyer Straße 6 

45133 ESSEN 

GERMANY 

Tel: 0049211-15902522 

Fax: 0049211-15902500 

gabriele.schmidt@lua.nrw.de 

Joachim Schmied 

Referent 

Staatliches Umweltamt Hagen 

Feithstr. 1506 

58097 HAGEN 

GERMANY 

Tel: 00492331-8005110 

Fax: 00492331-8005100 

joachim.schmied@stua-ha.nrw.de 

Rudolf Stork 

Referent 

Staatliches Umweltamt Minden 

Büntestraße 1 

32427 MINDEN 

GERMANY 

Tel: 0049571-8080 

Fax: 0049571-808239 

poststelle@stua-mi.nrw.de 

Helga Stülgies 

Amtsleiterin 

Staatl. Umweltamt Krefeld 

St. Töniser Straße 60 

47803 KREFELD 

GERMANY 

Tel: 00492151-844208 

Fax: 00492151-844207 

helga.stülgies@stua-kv.nrw.de 

Rolf Tippner 

Referent 

Bezirksregierung Köln 

Zeughausstraße 2-10 

50667 KÖLN 

GERMANY 

Tel: 0049221-1473419 

Fax: 0049221-1472469 

rolf.tippner@bezreg-koeln.nrw.de


Karin Uhlenbrock 

Rechts-Referentin (Juristin) 

Staatliches Umweltamt Lippstadt 

Lipperoder Sraße 8 

59555 LIPPSTADT 

GERMANY 

Tel: 00492941-986315 

Fax: 00492941-986350 

karin.uhlenbrock@stua-lp.nrw.de 

Matthias Weigand 

Head of Unit 

Bavarian Min. for Regional Development 

Rosenkavalierplatz 2 

D-81925 MUNICH 

GERMANY 

Tel: 004984-92142267 

Fax: 004989-92142249 

matthias.weigand@stmlu.bayern.de 

Wolfgang Wick 

Referent 

Staatl. Umweltamt Köln 

Blumenthalstraße 33 

50667 COLOGNE 

GERMANY 

Tel: 0049221-7740538 

Fax: 0049221-7740288 

wolfgang.wick@stua-k.krw.de 

Jürgen Wilbertz 


Staatliches Umweltamt Duisburg 

Am Freischütz 10-12 

47058 DUISBURG 

GERMANY 

Tel: 0049203-3052325 

Fax: 0049203-3052200 

juergen.wilbertz@stug-du.nrw.de 

Elfriede Winkler 

Referentin 

Staatliches Umweltamt Aachen 

Franzstraße 49 

52064 AACHEN 

GERMANY 

Tel: 0049241-457468 

Fax: 0049241-457291 

poststelle@stua-ac.nrw.de 

GREECE 

Katerina Iakovidou - Anastasiadou 

Chemist, Environmental Officer 

Ministry for the Environment, Physical Planning 

and Public Works 

Division of Industries 

147 Patission Street 

GR-11251 ATHENS 

GREECE 

Tel: 0030210-8652493 

Fax: 0030210-8652493 

kiakovidou.dearth@edpp.gr 

Angeliki Psaila 

Environmental Permitting Expert 

Ministry for the Environment 

11 Alexandras Avenue 

GR-11473 ATHENS 

GREECE 

Tel: 0030210-6412615 

Fax: 0030210-6451914 

eype-ypehode@ath.forthnet.gr 

HUNGARY 

Mihail Dimovski 

Programme Manager 

The Regional Environmental Center 

Ady Endre, 9-11 

2000 SZENTENDRE 

HUNGARY 

Tel: 003626-504052 

Fax: 003626-311294 

mdimovski@rec.org 

Jozsef Tiberenczl 

Director 

Regional Inspectorate 

Papnövelde u. 13 

H-7621 PECS 

HUNGARY 

Tel: 003672-520101 

Fax: 003672-520103 

tiber@mail.ddkvf.hu


Katalin Ughy 

Director General 

National Inspectorate for Environment 

Fö utca 44-50 

1011 BUDAPEST 

HUNGARY 

Tel: 00361-3468309 

Fax: 00361-3150812 

ughy@mail5.ktm.hu 

Pál Varga 


National Inspectorate for Environment 

Fö utca 44-50 

1011 BUDAPEST 

HUNGARY 

Tel: 00361-3468330 

Fax: 00361-3150812 

vargap@mail5.ktm.hu 

IRELAND 

Frank Clinton 

Senior Scientist 

Environmental Protection Agency 

P.O. Box 3000 

WEXFORD 

IRELAND 

Tel: 0035353-60600 

Fax: 0035353-60699 

f.clinton@epa.ie 

Valerie Doyle 

IPC Environment Inspector 


P.O. Box 3000, Johnstown Castle Estate, 

WEXFORD 

IRELAND 

Tel: 0035353-60600 

Fax: 0035353-60699 

v.doyle@epa.ie 

E. Nixon 

Inspector 

Aquaculture Licences Appeals Board 

Holbrook House, Holles Street 

DUBLIN 

IRELAND 

Tel: 0035316-620331 

Fax: 0035316-620340 

eugene.nixon@alab.ie 

Brendan Wall 

Inspector 


P.O. Box 3000, Johnstonn Castle Estate 

WEXFORD 

IRELAND 

Tel: 0035353-60600 

Fax: 0035353-60699 

b.wall@epa.ie 

ITALY 

Stefania Betti 

Expert 


Via C. Colombo 44 

00147 ROME 

ITALY 

Tel: 003906-57228209 

Fax: 003906-57228217 

betti.stefania@minembiente.it 

Alessandra Burali 

Apat Italian Environmental Agency 

Via Vitaliano Brancati 48 

144 ROME 

ITALY 

Tel: 003906-50072503 

Fax: 003906-50072531 

burali@apat.it 

Giuliana Gasparrini 

Director for Reginal Protocols 


Via C. Colombo, 44 

00174 ROME 

ITALY 

Tel: 003906-57228150 

Fax: 003906-57228172 

gasparinni.giuliana@minambiente.it


LATVIA 

Vilis Avotins 

Director 

Lielriga Regional Environment Board 

Rupniecibas Street 23 

LV 1045 RIGA 

LATVIA 

Tel: 0037173-23202 

Fax: 0037173-22359 

vilis.avotins@lielrigasrvp.gov.lv 

Sandra Krivmane 

Chair 

Environmental State Inspectorate 

Rupniecibas Str. 23 

LV-1045 RIGA 

LATVIA 

Tel: 0037194-78206 

Fax: 0037173-21577 

sandra.krivmane@vvi.gov.lv 

Iveta Lobanoka 

Head of Sub-department 

Environmental Protection Board 

Raina Street 28 

LV-5403 DAUGAVFILS 

LATVIA 

Tel: 0037154-24430 

Fax: 0037154-23219 

iveta.lobanoka@drvp.gov.lv 

LITHUANIA 

Vaclovas Berzinskas 

Env. Inspector 

Lithuanian Environmental Inspectorate 

Juozapavicious Street 9 

2005 VILNIUS 

LITHUANIA 

Tel: 003705-2723756 

Fax: 003705-2722766 

v.berzinskas@nt.lt 

Rolandas Masilevicius 

Director 

Vilnius Regional Dep. for Env.Protection 

Juozapavicious Street 9 

2005 VILNIUS 

LITHUANIA 

Tel: 003705-2728536 

Fax: 003705-2728389 

rmasilevicius@hotmail.com 

Angele Planciunaite 

Deputy Director 

Panevezys Regional Env. Protection 

Protection Department 

A. Jaksto str. 12 

5300 PANEVEZYS 

LITHUANIA 

Tel: 0037045581411 

Fax: 0037045581441 

praad@takas.lt 

MALTA 

Charmaine Vassallo 

Environment Protection Officer 

Malta Environment and Planning Authority 

C/o Quality Control Laboratory 

Industrial Estate Kordin 

PLA 19 PAOLO 

MALTA 

Tel: 0035621673085 

Fax: 0035621660108 

charmaine.vassallo@mepa.org.mt 

NORWAY 

Agnethe Dahl 

Advisor 

The Norwegian Ministry of the Env. 

P.O. Box 8013 

30 OSLO 

NORWAY 

Tel: 004722-245918 

Fax: 004722-249560 

ad@md.dep.no


Erik Forberg 

Special Adviser of Section 

Norwegian Pollution Control Authority 

P.O. Box 8100 

0032 OSLO 

NORWAY 

Tel: 004722-573400 

Fax: 004722-676706 

erik.forberg@sft.no 

Morten Taraldsvik 

Senior Executive Officer 

Norwegian Pollution Control Authority 

P.O. Box 8100 

0032 OSLO 

NORWAY 

Tel: 004722-573400 

Fax: 004722-676706 

morten.taraldsvik@sft.no 

OECD 

Angela Bularga 


Org. for Economic Co-operation and Development 

EAP Task Force Secretariat 

2, rue André Pascal 

75775 PARIS 

FRANCE 

Tel: 0033145249863 

Fax: 0033145249671 

angela.bularga@oecd.org 

POLAND 

Malgorzata Kolodziej-Nowakowska 

Inspector of Environmental Protection 

West Pomeranian Voivodship Inspectorate 

4 Waty Chrobrego Street 

70-502 SZCZECIN 

POLAND 

Tel: 004891-4303725 

Fax: 004891-4340554 

mkn@wios.szczecin.pl 

Marek Mroczkowski 

Director General 

Inspectorate for Env. Protection 

Wawelska 52/54 Street 

00-922 WARSAW 

POLAND 

Tel: 004822-8259815 

Fax: 004822-8259815 

mamrocz@pios.gov.pl 

Krystyna Panek-Gondek 

Director of International Cooperation Department 



00-922 WARSAW 

POLAND 

Tel: 004822-8259775 

Fax: 004822-8259775 

kpanek@pios.gov.pl 

Krzysztof Zareba 

Chief Inspector for Environmental Protection 



00-922 WARSAW 

POLAND 

Tel: 004822-8253325 

Fax: 004822-8250465 

remi@pios.gov.pl 

PORTUGAL 

Fernando Laranda Figueira 

Inspector of the Environment 

Portuguese Inspectorate for Environment 

Rua de O Século“ 63” 

1249-033 LISBOA 

PORTUGAL 

Tel: 00351213215505 

Fax: 00351213432777 

ffigueira@ig-amb.pt 

Magda Margarida Penedos 

Legal Consultant/Jurist 

General Inspection for the Environment 


1249-033 LISBOA 

PORTUGAL 

Tel: 0035121-3215538 

Fax: 0035121-3432777 

mpenedos@ig-amb.pt


António Sequeira Ribeiro 

Sub Inspector General for the Environment 

General Inspection for the Environment 


1249-033 LISBOA 

PORTUGAL 

Tel: 0035121-3215500 

Fax: 0035121-3432777 

aribeiro@ig-amb.pt 

RUSSIAN FEDERATION 

Vladimir Schwartz 

Head of Division of Ecological Control 

Ministry Of Nature Resources of Russian 

Federation 

Pyatnitskaya str. 59/19 

115095 MOSCOW 

RUSSIAN FEDERATION 

Tel: 0070952308753 

Fax: 0070952308705 

vi_schwartz@mtu-net.ru 

SLOVAC REPUBLIC 

Jarmila Durdovicova 

Head Inspector of Waste Management Inspection 

Slovak Inspectorate of te Environment 

Karloveska 2 

84222 BRATISLAVA 

SLOVAK REPUBLIC 

Tel: 004212-65420752 

Fax: 004212-60292352 

durdovicova@sizp.sk 

Daniel Geisbacher 

Head Inspector of Water protection Inspection 

Dpt. 

Slovak Inspectorate of the Environment 

Karloveska 2 



Tel: 004212-65426950 

Fax: 004212-65423181 

geisbacher@sizp.sk 

Anna Stykova 

Inspector-Lawyer 

Slovak Inspectorate of the Environment 

Karloveska 2 



Tel: 004212-65426950 

Fax: 004212-65423181 

stykova@sizp.sk 

SLOVENIA 

Bernarda Copar-Sotensek 

Inspector 

Inspectorate of the RS for Environment 

Vilharjeva 33 

1000 LJUBLJANA 

SLOVENIA 

Tel: 003861-4204400 

Fax: 003861-4204410 

bernardacopar-sotensek@gov.si 

Brigita Curk 



Vlica Herosa Tomsica 2 

2000 MAZIBOR 

SLOVENIA 

Tel: 003862-2201642 

Fax: 003862-2201654 

brigita.curk@gov.si 

Ivan Stefelj 

Deputy chief inspector 


Dunajska street 47 

1000 LJUBLJANA 

SLOVENIA 

Tel: 003861-4787124 

Fax: 003861-4787102 

ivan.stefelj@gov.si


SPAIN 

Chiqui Barrecheguren 

Head of Inspection Service 

Conselleria de Medio Ambiente 

San Lázaro, s/n 

15871 SANTIAGO DE COMPOSTELA 

SPAIN 

Tel: 0034981541052 

Fax: 00341541048 

chiqui.barrecheguren.beltran@xunta.es 

Miguel Costoya 

Head of Environmental Laboratory 


Torres Quevedo, 3-5 

15008 A CORUNA 

SPAIN 

Tel: 0034981259400 

Fax: 0034981259424 

miguel.costoya.rivera@xunta.es 

Jesus Angel Ocio 

Head of Environmental Inspection 

Gobierno Vasco 

Dep. de Ordenacion del Territorio 

C. Donostia-San Sebastian 1 

1010 VITORIA-GASTEIZ 

SPAIN 

Tel: 0034945-019917 

Fax: 0034945-019883 

jan-ocio@ej-gv.es 

Carlos Vila 

Head of Inspection in the Province of Lugo 


Ronda da Muralla 70 

27071 LUGO 

SPAIN 

Tel: 0034982294592 

Fax: 0034982294590 

carlos.vila.perez@xunta.es 

SWEDEN 

Olle Boström 

Senior Technical Officer 

Secretariat of the Enforcement 

Swedish Environmental Protection Agency 

SE-10648 STOCKHOLM 

SWEDEN 

Tel: 00468-6981612 

Fax: 00468-6981584 

olle.bostrom@naturvardsverket.se 

Camilla Frisch 

Legal Adviser 


SE-10648 STOCKHOLM 

SWEDEN 

Tel: 00468-698 1668 

Fax: 00468-698 1480 

camilla.frisch@naturvardsverket.se 

Annelie Johansson 

Director for the Environmental Control 

The County Administrive Board 

Septembergatan 4 

573 38 TRANÅS 

SWEDEN 

Tel: 004636-3950720 

annelie.johansson@f.lst.se 

Jessika Mähler 

Environmental Health Inspector 

Local Authority 

Alva Myrdals gata 5 

631 86 ESKILSTUNA 

SWEDEN 

Tel: 004616-108720 

Fax: 004616-131835 

jessika.mahler@eskilstuna.se 

Kia Regner 

Chief Environment, Health Officer 

Österåker Kommun 

Tallholmsv. 5 

18594 VAXHOLM 

SWEDEN 

Tel: 0046854137736 

Fax: 0046854061207 

kia@xpress.se


Kitty Victor 

Chief Legal Adviser 


10648 STOCKHOLM 

SWEDEN 

Tel: 00468-6981528 

kitty.victor@naturvardsverket.se 

THE NETHERLANDS 

Jos van den Berg 

Adj. inspector/coördinator 

VROM Inspectorate-South 

P.O. Box 850 

5600 AW EINDHOVEN 


Tel: 003140-2652911 

Fax: 003140-2653030 

jos.vandenberg@minvrom.nl 

Gustaaf Biezeveld 

Public Prosecutor's Office The Hague 

P.O.Box 19518 

2500 CM DEN HAAG 


Tel: 00316/18302750 

Fax: 0031703023222 

ga.biezeveld@sgrarr.drp.minjus.nl 

Eric Bolle 

Afdelingshoofd Handhaving 

Provincie Noord Brabant 

Brabantlaan 1 

5216 TV 'S-HERTOGENBOSCH 


Tel: 003173-6812608 

Fax: 003173-6812844 

ebolle@brabant.nl 

Jaap Bos 

Sectorhoofd 

Provincie Utrecht 

P.O. Box 80300 

3508 TH UTRECHT 


Tel: 003130-2583182 

Fax: 003130-2583981 

Jaap.Bos@Provincie-Utrecht.nl 

Chiel Bovenkerk 

Head Unit Enforcement Chemicals 

VROM Inspectorate-South 

P.O. Box 850 



Tel: 003140-2652911 

Fax: 003140-2460902 

chiel.bovenkerk@minvrom.nl 

Ruud Bruggeman 

Adviseur 

IPO 

P.O. Box 16107 

2500 BC DEN HAAG 


Tel: 003170-8881210 

Fax: 003170-8881280 

rbruggeman@ipo.nl 

Martin de Bruin 

Adjunct Director 

Provincie Zuid-Holland 

P.O. Box 90602 

2509 LP DEN HAAG 


Tel: 0031704416595 

Fax: 0031704417811 

bruin-m@pzh.nl 

Tineke Cnossen 

Unitmanager Kennis en Advies 

Inspectie Verkeer en Waterstaat 

P.O. Box 61 

8200 AB LELYSTAD 


Tel: 0031320-297444 

Fax: 0031320-287004 

Tineke.Cnossen@ivw.nl 

Albert Dam 

Inspector/coordinator 

Provincie Overijssel 

P.O. Box 10078 

8000 GB ZWOLLE 


Tel: 00316-28901908 

Fax: 003138-4252610 

A.Dam@prv-overijssel.nl


Guido Dekker 

Staff Member Enforcement and Levies 

Rijkswaterstaat, RIZA 

P.O. Box 17 

8200 AA LELYSTAD 


Tel: 0031320-297675 

g.dekker@riza.rws.minvenw.nl 

Kirsten van Dijk 


RIZA 

P.O. Box 17 

8200 AA LELYSTAD 


Tel: 0031320-298922 

k.a.vdijk@riza.rws.minvenw.nl 

Norbert Dolman 

Manager Enforcement Environmental Law 

Province Limburg 

Limburglaan 10 

6229 GA MAASTRICHT 


Tel: 003143-3897555 

ngm.dolman@prvlimburg.nl 

Ed Eggink 

Head Department for Environment and Water 

Policy 

Province of Limburg 

P.O. Box 5700 

6202 MA MAASTRICHT 


Tel: 003143-3897487 

Fax: 003143-3897018 

e.eggink@prvlimburg.nl 

Nicoline Elsink 

Redacteur 

Format Bladenmakers 

P.O. Box 270 

2700 AG ZOETERMEER 


Tel: 003179-3601236 

Fax: 003179-3601230 

format@bladenmakers.nl 

Kees van Essen 

Senior Advisor Int. Environmental Affaires 


P.O. Box 24 

3300 AA DORDRECHT 


Tel: 003178-6131399 

Fax: 003178-6316710 

essenk@pzh.nl 

Jo Gerardu 

Inspector 

VROM-Inspectorate 

VI/AL IPC 500 

P.O. Box 16191 

2500 BD DEN HAAG 


Tel: 003170-3392536 

Fax: 003170-3391985 

jo.gerardu@minvrom.nl 

Liesbeth Gerretsen 

Bestuurlijk-Juridisch Medewerkster 


Zuid-Hollandplein 1 

2509 LP DEN HAAG 


Tel: 003170-4417761 

Fax: 003170-4417820 

gerretsl@pzh.nl 

Rob Glaser 

Consultant EU - AC. Impel Project 

RPS BKH Consulting Engineers 

Asserlaan 7 

4334 EP MIDDELBURG 


Tel: 0031118-625810 

Fax: 0031118-617591 

tops@zeelandnet.nl 

Betske Goinga 

Specialist in Administr. environmental relations 

VROM- Inspectorate North West 

P.O. Box 1006 

2001 BA HAARLEM 


Tel: 003123-5150746 

Fax: 003123-5150777 

betske.goinga@minvrom.nl


Diederik van Grieken 

Legal Adviser 

Province Overijssel 

Koekoek 18 

8103 CE RAALTE 


Tel: 0031572-355511 

stenberg@zonnet.nl 

Cornelis de Haas 

Provincie Groningen 

P.O. Box 610 

9700 AP GRONINGEN 


Tel: 003150-3164153 

Fax: 003150-3164632 

c.de.haas@provinciegroningen.nl 

Ben Hendriks 

EU-Coordinator M&B 

Provincie Noord-Holland 

P.O. Box 205 

2050 AE OVERVEEN 


Tel: 003123-5143782 

Fax: 003123-5145050 

hendriksb@noord-holland.nl 

Rolf-Jan Hoeve 

Director Chief Inspector 

Water Management Inspectorate 

P.O. Box 61 



Tel: 0031320-299564 

Fax: 0031320-299501 

rolfjan.hoeve@ivw.nl 

Fred Huisman 

Acc. Manager External Safety 

VROM Inspectorate, IPC 530 

P.O. Box 16191 



Tel: 003170-3394126 

Fax: 003170-3391299 

fred.huisman@minvrom.nl 

Nancy Isarin 

Adjunct Inspecteur 

Vrom Inspectorate-South West 

Weena 723 

P.O. Box 29036 

3001 GA ROTTERDAM 


Tel: 003110-2244417 

Fax: 003110-2244485 

Nancy.Isarin@minvrom.nl 

Ineke de Jonge 

Policy Maker 

Provincie Groningen 

P.O. Box 610 



Tel: 003150-3164192 

Fax: 003150-3164632 

e.h.de.jonge@provinciegroningen.nl 

Raymond Kavsek 

Accountmanager Soil, Water, Rural Areas 

VROM-Inspectorate, IPC 530 

P.O. Box 16191 



Tel: 003170 3394212 

raymond.kavsek@minvrom.nl 

Kilicaslan, E. 

Senior-Adviseur 

Provincie-Utrecht 

P.O. Box 80300 

3508 TH UTRECHT 


Tel: 003130-2583588 

Fax: 003130-2583981 

ekremKilicaslan@provincie-Utrecht.nl 

Wout Klein 


VROM- Inspectorate 

P.O. Box 16191 Ipc 500 



Tel: 0031573 401756 

Fax: 0031573 401675 

wout.klein@minvrom.nl


Annelie Kohl 

Inspector International Environmental Affairs 

VROM- Inspectorate, IPC 530 

P.O. Box 16191 



Tel: 003170-3393969 

Fax: 003170-3391301 

annelie.kohl@minvrom.nl 

Sylvia Kuilboer 

Senior Communicatie Adviseur 

VROM-Inspectorate, IPC 530 

P.O. Box 16191 



Tel: 00316-11327515 

Fax: 003170-3391985 

sylvia.kuilboer@minvrom.nl 

Jan Kunst 

Sr. Advisor Int. Environment Affairs 

Province of Groningen 

P.O. Box 610 



Tel: 003150-3164135 

Fax: 003150-3164570 

j.kunst@provinciegroningen.nl 

Peter Kuppers 

Senior civil servant 

Provincie Limburg 

P.O. Box 5700 



Tel: 003143-3897644 

Fax: 003143-3897018 

pem.kuppers@prvlimburg.nl 

Michael Lunter 


P.O. Box 61 



Tel: 00313320-299506 

Fax: 0031320-299501 

michael.lunter@ivw.nl 

Willem Mulder 

Permitmaker 


Luttenbergstraat 2 



Tel: 00316-20549143 

Fax: 003138-4252610 

w.mulder@prv-overijssel.nl 

Alida Oppers 

Directeur Bestuurszaken 

VROM Inspectorate 

P.O. Box 16191/ IPC 530 



Tel: 003170-3392250 

Fax: 003170-3391299 

alida.oppers@minvrom.nl 

Jan Pronk 

1e Sweelinkstraat 4 

2517 GC DEN HAAG 


Tel: 003170-3460353 

janpronk@iss.nl 

Ike van der Putte 

Consultant EU - AC. Impel Project 

RPS BKH Consulting Engineers 

P.O. Box 5094 

2600 GB DELFT 


Tel: 0031157501515 

Fax: 0031157501520 

ike.van.der.putte@rpsgroep.nl 

Henk Ruessink 


VROM Inspectorate North 

Cascadeplein 10 

9700 RM GRONINGEN 


Tel: 0031505992700 

Fax: 0031505992699 

henk.ruessink@minvrom.nl


Jacob Rus 

Coordinator Enforcement 

Watermanagement Inspectorate 

P.O. Box 61 



Tel: 0031320-297458 

Fax: 0031320-297555 

jaap.rus@ivw.nl 

Gaby Schäfer 

Senior Adjunct Inspecteur 

VROM-Inspectorate East 

P.O. Box 136 

6800 AC ARNHEM 


Tel: 003126-3528400 

Fax: 003126-3528455 

gaby.schafer@minvrom.nl 

Marjanne Sint 

Secretary-General 

Mininstry of Housing, Spatial Planning and the 

Environment 

Rijnstraat 8 

2515 XP DEN HAAG 


Tel: 0031703393839 

Fax: 0031703391331 

marjanne.sint@minvrom.nl 

Evert Steynebrugh 

Afdelingshoofd 

Provincie Limburg 

Handhaving en monitoring 

P.O. Box 5700 



Tel: 003143-3898868 

Fax: 003143-3897659 

ew.steijnebrugh@prvlimburg.nl 

Frans Swinkels 

Adj. inspector/coördinator 

VROM Inspectorate South 

P.O Box 850 



Tel: 003140-2652911 

Fax: 003140-2653030 

frans.swinkels@minvrom.nl 

Jan Teekens 

Coördinator Regulatory Policies 

Netherlands Ministry of Housing, Spatial Planning 

and the Environment 

P.O. Box 30945 

2500 GX DEN HAAG 


Tel: 003170-3393777 

Fax: 003170-3391302 

jan.teekens@minvrom.nl 

Paula van Teylingen 

Senior Inspecteur/Coordinator 


P.O. Box 61 



Tel: 0031320297457 

Fax: 0031320297449 

paula.vteylingen@ivm.nl 

Ellen Topman 

Legal policy maker 

Ministry of Housing, Spatial Planning and the 

Environmnet 

P.O. Box 30945 



Tel: 003170-3394681 

Fax: 003170-3391302 

ellen.topman@minvrom.nl 

Ronald Visser 

Lid van het Directieteam 

DCMR Milieudienst Rijnmond 

's-Gravelandseweg 565 

3119 XT SCHIEDAM 


Tel: 003110-2468606 

Fax: 003110-2468560 

rvi@dcmr.nl


Patricia Weenink 

Inspector for environmental affairs 

Provincie Overijssel 

P.O. Box 10078 



Tel: 00316-18303836 

Fax: 003138-4252610 

PA.Weenink-Driessen@prv-overijssel.nl 

Nynke Westra 


Rijkswaterstaat, Riza 

Zuiderwagenplein 2 

8224 AD LELYSTAD 


Tel: 0031320-298923 

Fax: 0031320-298932 

n.westra@riza.rws.minvenw.nl 

Gerard Wolters 

Inspector General 

VROM Inspectorate 

P.O. Box 16191 



Tel: 003170-3394620 

Fax: 003170-3391985 

gerard.wolters@minvrom.nl 

Pieter- Jan van Zanten 

Head of Enforcement Division 


P.O. Box 10078 



Tel: 003138-425 1479 

Fax: 003138-425 2610 

pj.v.zanten@prv-overijssel.nl 

Frederique van Zomeren 

Legal Policy Advisor 

Ministry of Housing, Spatial Planning and the 

Envirronment 

Rijnstraat 8 



Tel: 003170-3394568 

Fax: 003170-3391306 

frederique.vanzomeren@minvrom.nl 

TURKEY 

Ayse Öse Karadeniz 

Asst. Environmental Expert 

Turkish Ministry of Env. and Forestry 

6530 ANKARA 

TURKEY 

Tel: 0090312-2879963 

Fax: 0090312-2855875 

ozgekaradeniz@hotmail.com 

UNICE 

Michel Bruder 

Chairman of IPPC.WG 

UNICE 

4 Rue des Menus 

92100 BOULOGNE 

FRANCE 

Tel: 003314-6990460 

Fax: 003314-6055133 

michel.bruder@wanadoo.fr 

UNITED KINGDOM 

Martyn Cheesbrough 

Environment Agency 

Government Building, Burghill Road 

BS 10 GBBF BRISTOL 


Tel: 004477-68276947 

Fax: 0044117-9142826 

mcheesbrough@remas.info 

Stephen Claughton 

Head of Env. Agency Sponsorship Division 

Department for Environment 

Room 5/D11, Ashdown House, 

123 Victoria Street 

SWIE 6DE LONDON 


Tel: 004420-79443350 

Fax: 004420-79446559 

stephen.claughton@defra.gsi.gov.uk


Jan Davie 

Environment Manager 

Environment Agency, England and Wales 

Phoenix House, Global Avenue 

LS11 8PG LEEDS 


Tel: 0044113-2134699 

Fax: 0044113-2134610 

jan.davie@environment-agency.gov.uk 

Neil Emmott 

Head of EV + International Relations 


Rio House, Aztec West 

B532 40D BRISTOL 


Tel: 00441454 878912 

Fax: 00441454 878726 

neil.emmott@environment-agency.gov.uk 

Jeremy Frost 

Process Management Waste 


Richard Fairclough House, Knutsford Road 

WA4 1HG WARRINGTON 


Tel: 00441925-653999 

Fax: 00441925-54217 

jeremy.frost@environment-agency.gov.uk 

Dave Gorman 

Operations Co-ordinator 

Scottish Environment Protection Agency 

Erskine Court, Castle Business Park 

FK9 4TR STIRLING 


Tel: 00441786 457700 

Fax: 00441786 446885 

dave.gorman@sepa.org.uk 

Jim Gray 

Head of Regulatory Development 


Rio House, Waterside Drive, Aztec West, 

Almondsbury 

B532 4VD BRISTOL 


Tel: 00441454 624400 

Fax: 00441454 624032 

jim.gray@environment-agency.gov.uk 

Nerina Holden 

Srategic Planning Manager 

Scottish Environment Protection Agency 

Erskine Court, Castle Business Park 

FK9 4TR STIRLING 


Tel: 00441786 457700 

Fax: 00441786 446885 

nerina.holden@sepa.org.uk 

Chris Howes 

Enforcement Policy Manager 


Rio House, Aztec West 

B5324VD BRISTOL 


Tel: 004414-54624029 

chris.howes@environment-agency.gov.uk 

Alun James 

Environment Agency Wales 

Ty Cambria, 29 Newport Road 

CF24 0TP CARDIFF 


Tel: 004429-20770088 

alun.james@environment-agency.gov.uk 

Martin Murray 

Regularry Development 


Rio House,Waterside Drive, Aztec West, 

Almondsbury 



Tel: 00441454E+11 

Fax: 00441455E+11 

martin.murry@environment-agency.gov.uk 

Sian Priest 

Policy Advice on the Implementation 


Zone F8, Ashdown House, 


LONDON SWIE 6DE 


Tel: 0044207-9446592 

Fax: 0044207-9446569 

sian.priest@defra.gsi.gov.uk


David Pugh 

Modernising Regulation 



Almondsbury 



Tel: 00441454 205549 

Fax: 00441454 624032 

david.pugh@environment-agency.gov.uk 

Terence Shears 

Env. + International Relations Adviser 

Environment Agency, England and Wales 


Almondsbury 

B532 4VD BRISTOL 


Tel: 00441454 878870 

Fax: 00441454 878726 

terence.shears@environment-agency.gov.uk 

Jeremy Stephens 

Remas Project 

Environment Agency, Block 1, 

Burghill Road 

B5106BF BRISTOL 


Tel: 004411-79156233 

Fax: 004411-79142826 

j.stephens@remas.info 

Richard Vincent 

Head of Industrial Pollution Control 


4/H11, Ashdown House 


SW1E 6DE LONDON 


Tel: 00442079446326 

Fax: 00442079446329 

richard.vincent@defra.gsi.gov.uk 

Steven Zdolyny 

Regional Solicitor 


Richard Fairclough House, Knutsford Road 

WA4 1HG WARRINGTON 


Tel: 00441925-653999 

Fax: 00441925-574736 

steven.zdolyny@environment-agency.gov.uk 

UNITED STATES OF AMERICA 

Durwood Zaelke 

Int. Network for Env. Compliance 

And Enforcement 

2141 Wisconsin Avenue N.W. 

Suite D2 

2007 WASHINGTON, DC 

UNITED STATES OF AMERICA 

Tel: 001202-2499607 

Fax: 001202-2499608 

inece@inece.org


Annex 5. List of participants to the exhibition. 

1. Ministry of Housing, Spatial Planning and the Environment; The Netherlands 

2. Province of Limburg (The Netherlands) 

3. BERCEN-Network; Mihail Dimovski; Regional Environmental Center; Hungary 

4. County of Vejle; Denmark 

5. INECE-Network; USA 

6. Environmental Protection Agency Sweden 

7. IMPEL-secretariat; European Commission 

8. Environment Agency United Kingdom 

9. Landesumweltamt Northrein-Westphalia (Germany) 

10. Staatliches Gewerbeaufsichtamt Hannover (Germany) 

11. Water Inspectorate Ministry for Traffic and Waterworks (The Netherlands) 

12. EAP Task Force Secretariat NIS-network (OECD; France)

Maastricht, The Netherlands, in 2003 - IMPEL

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