While Ukraine is just starting to implement the Pollutant Release and Transfer Register (hereinafter – the Register), the international community is actively working to improve it.
Among other things, the following ideas for improvement of functioning of the European Pollutant Release and Transfer Register (hereinafter – E-PRTR) were proposed at the ninth meeting of the Working Group of the Parties to the Pollutant Release and Transfer Register (hereinafter – Protocol) to the Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters:
I. Simplification of requirements for access to information from the EU Industrial Emissions Directive (IED).
E-PRTR reporting and other tools of access to information on emissions and pollutants should be co-operated in one centralized and user-friendly resource. Such centralization will contribute to establishing the compliance of indicators and will significantly simplify data benchmarking.
II.The content of emission permit conditions must be directly included in the E-PRTR.
III.It is necessary to implement an electronic form of entering the annual compliance report into the system, that is, operators must enter data directly, but with verification/validation control, which remains in the competence of the authorized bodies.
IV.Implementing the principle of “Track and Compare” through the prism of the best available technologies.
V.Determination of the most significant, key performance indicators at the activity level (activity-based pollution reduction indicators, intensity indicators).
At the Working Group meeting, the following thesis was voiced: “We need a new approach to reporting in order to facilitate compliance and benchmarking, to enable the digital era to work to achieve a high level of protection for the environment and human health.”
Key expectations expressed by experts in the area of E-PRTR development:
1. Development of accurate indicators of the input/output ratio to assess “productivity”.
2. More data in the context of one or another type of activity (production/services provided).
3. Integration of data on consumption of water, natural materials, chemicals, energy.
4. Expansion of groups of substances and removal of threshold values.
5. Reference to environmental quality standards and performance comparison and tracking.
Experts also emphasized the importance of integration of reporting streams into the “Global Harmonized Annual Report on Compliance of Activities with PRTR” and verification of compliance with the best available technologies. Overcoming language barriers still remains an important issue.
Improvement of the existing E-PRTR system opens new opportunities. For example, environmental management systems include the concept of “continuous improvement” and “benchmark of excellence”, mentioned performance indicators for pollution prevention/reduction, but without detailed ambitions/expectations. The concepts remain vague and cannot be measured and compared at the level of a facility or specific activity. Improvement of E-PRTR functioning will allow to identify opportunities to prevent pollution, improve the distribution of efforts, identify common control points, better use information aimed at preventing the problem.
For pollutant emissions, the E-PRTR reporting thresholds remain, and so far there is no input data in this register, such as data on water, energy, material use, etc. It looks like such data should be added. This will correspond, in particular, to the provisions of the Kyiv Protocol, which establishes the triple goal of expanding public access to information through: coordinated, integrated PRTRs and promoting public participation in environmental decision-making, as well as promoting the prevention and reduction of environmental pollution.
The E-PRTR lacks contextual information, in particular, on the production results and data of effectiveness of an annual compliance report. It should be emphasized that E-PRTR is a tool for benchmarking similar types of activities (environment, human health), comparison of productivity/efforts of operators, as well as achievement of goals. At the same time, it is better to use already provided data to achieve the proper results of comparisons or analyses.
Studying the experience of foreign colleagues, Ukraine can not only implement the Pollutant Release and Transfer Register on its territory, but also make it high-quality and such that meets modern European standards.
