Experts and practitioners from OECD countries and international institutions joined enforcement and policy-making officials at the meeting held in Kiev, Ukraine, from 16-18 October 2003. Representatives of non-governmental organizations, business, and industry were observers. The Ministry of Environmental Protection and the State Environmental Inspectorate of Ukraine hosted the meeting, which was organized within the framework of the Environmental Action Programme Task Force located at the OECD.

The Work Programme takes account of the decisions made at the 2003 "Environment for Europe" Ministerial Conference and includes the following projects:

	streamlining and integrating environmental permitting.
	making environmental standards more realistic.
	strengthening economic instruments for environmental protection.
	analysis of economics of environmental compliance programs and financing of enforcement efforts.
	promoting information-based instruments and public involvement in compliance assurance.
	improving industrial self-monitoring.
	reviewing performance of environmental enforcement agencies.
	developing enforcement and compliance indicators.
	establishing sustainable mechanisms for building capacities of enforcement managers and officers.

The delegates also endorsed the new Terms of Reference of the Network. The Terms of Reference present the origins of the Network, its mission and goals as well as the means of operations, the decision-making, and management structure. The Terms of Reference will be the principal document governing the Network's activities over the coming years.

Regulatory Environmental Programme Implementation Network Seeks To Optimize Self-Monitoring System in Kazakhstan
As part of the Regulatory Environmental Programme Implementation Network's (REPIN) efforts to facilitate access to best practices and efficient environmental management tools, the network is working to optimize the self-monitoring system in Kazakhstan.

The ultimate goal of the Kazakhstan project is to help set up a reliable self-monitoring system to manage environmental and financial risks related to production processes.

To launch the project, REPIN held a meeting on the 18 November 2003 in Astana, the Kazakhstan capital. Ms. Aitkul Samakova, the Kazakh Environment Minister, opened the meeting, which was attended by the representatives of the Ministry and its territorial offices, other ministries and departments, representatives of the industry and NGOs.

The workshop will be followed by the development of the Environmental Self-Monitoring Guide which will assist in reforming the legal and regulatory framework for self-monitoring in Kazakhstan. The findings of the project will be presented at the annual meeting of the Regulatory Environmental Programme Implementation Network (formerly known as the Newly Independent States' Network of Environmental Compliance and Enforcement or NISECEN) which will be held in September 2004 in Armenia.

'IMPEL at Work' Focuses on Practical Enforcement Aspects
At the second conference of the European Union Network for the Implementation and Enforcement of Environmental Law (IMPEL), participants emphasized the importance of practical experiences in its feedback to regulators in Maastricht, The Netherlands, 6-8 October 2003.

Participants discussed different aspects of practical work in the fields of permit-making, inspections and enforcement. They also sought to develop new ways to improve work quality and create new policy instruments to improve inspections, strengthen networks, and build capacity for relevant organizations.

The conference reached several important conclusions and committed themselves to:

	broaden the scope of its advisory role to the European Commission by including its practical experiences in its feedback to regulators. This may improve the quality of the regulatory process.
	pay more attention to the applicability and enforceability of new legislation at the European level. In particular, they should stress that inspectors should play an active role in closing the regulatory cycle.
	continue to emphasize inspections, enforcement, and permit-making as well as the relationship between permit-making and enforcement.
	develop ideas and proposals for new projects along these lines.
	encourage National IMPEL coordinators to play a key role in improving the distribution of IMPEL products and multi-annual working programs.
	encourage permit-making and enforcement organizations to have an open dialogue with industry and non-governmental organizations.
	recognize the challenge of extending the IMPEL network to include acceding and candidate countries of the European Union (EU) and that implementation and enforcement strategies must be key priorities for an enlarged EU.

Participants at the conference also concluded the benchmarking of inspection organizations in different countries should be continued because improving the quality of inspections and providing them with a common basis will be critically important in an enlarged IMPEL network. This includes fine-tuning of training programs, qualifications for inspectors, and exchange programs where practical experiences can be discussed and shared.

For more information, please email Ed Eggink (e.eggink@prvlimburg.nl) or Annelie Kohl (annalie.kohl@minvrom.nl)

Effective Enforcement Needs a Good Legal Base - The IMPEL Better Legislation Initiative and IMPEL Management Reference Book for Environmental Inspectorates
The European Union Network for the Implementation and Enforcement of Environmental Law (IMPEL) Plenary Meeting in Rome in November 2003 adopted the final report on the "IMPEL Better Legislation Initiative" and the "IMPEL Management Reference Book for Environmental Inspectorates." The IMPEL Better Legislation Initiative was established to examine the challenges that IMPEL members have faced in the practical implementation of European Union (EU) legislation and to suggest recommendations for legislative improvement. The project covered a range of issues relating to the practical implementation of legislation, such as clarity, coherence, and proportionality.

The main recommendations of the project, which might also apply for non-EU legislation, are:

	More individuals with practical experience should be involved in the law making process.
	Before drafting a new law, it should be standard practice to review all other related EU legislation, international Conventions and European Court of Justice cases, including that from other policy fields.
	There is also a need for an overall, strategic approach to broad sectors of environmental policy, such as through the use of framework Directives.
	Definitions must be clear and unambiguous, especially in framework Directives, and particularly when they determine some key aspect of the scope of a measure or define the regulatory requirements. Technical definitions in different laws should be, as much as possible, identical in terms of units and scientific meaning.
	Time frames for the implementation of legal requirements should be clear and developed with care to avoid difficulties in subsequent implementation and compliance.
	The use of a single permit or control process which implements multiple pieces of legislation is a positive development and potentially avoids problems such as inconsistency and contradictions. Legislation that allows this is to be encouraged. There is also a need for a more harmonized reporting system for all environmental Directives, including more focused reports and greater commonality of reporting.

The report includes a bookmark with IMPEL's fourteen principles for better lawmaking and is available from the IMPEL Web site http://europa.eu.int/comm/environment/impel/reports.htm.

The IMPEL Management Reference Book for Environmental Inspectorates is concerned with management of environmental inspectorates. With examples on good practice compiled from many European countries, the Reference Book illustrates practical management solutions to challenges faced by environmental inspectorates.

The report stresses that the organizational elements are closely interrelated in a dynamic entity and seeks to illustrate the complexity of the management task but at the same time aims at easing this task by illuminating the most important organizational elements and by providing practical solutions to the managerial challenges. It does not attempt to prescribe "best management" of inspectorates, as each inspectorate decides its management approach considering the specific political, environmental, economic, social and cultural situation constituting the inspectorate context.

The report can be downloaded from the IMPEL Web site: http://europa.eu.int/comm/environment/impel/reports.htm.

By: Sabine Sommer, Network for the Implementation and Enforcement of Environmental Law, European Commission, Environment Directorate-General, Brussels, sabine.sommer@cec.eu.int.

Establishing Energy Efficiency in Environmental Permits in Europe
An European Union Network for the Implementation and Enforcement of Environmental Law (IMPEL) project studying energy efficiency in environmental permits concluded that European Union Member States have not included very many energy efficiency provisions in environmental permits under the European Directive on Integrated Pollution Prevention and Control.

The objective of the IMPEL project "Energy Efficiency in Environmental Permits" was to identify good practices in determining energy efficiency in IPPC permits.

Highlights of the final project report include:

	Practical guidelines are necessary to clarify and define energy efficiency. Where overall guidelines are not possible, sector-specific and case-by-case analyses may be more appropriate. Benchmarking, pinch technology, and energy balance checking can be useful.
	Prior information exchange between the operator and the authorities is integral to the permit application process. Application forms containing energy efficiency requirements should be available online.
	No good practices are available for establishing binding permit conditions. The final report gives some concrete examples of more or less binding permit conditions. The permit condition or the text in the descriptive part could also be linked to voluntary energy saving agreements.
	Environmental authorities should consult the Best Available Techniques Reference Documents, which contain information on energy consumption, energy saving, and energy recovery techniques.
	Permit authorities and inspectors should collaborate with the energy and environmental authorities.
	The energy audit report should be available on site for environmental inspectors and the summary of audit findings should be submitted as a part of any annual environmental report.
	Environmental permitting officers should strive to maintain transparency in their activities to ensure that the Aarhus Convention is implemented uniformly.
	The policy and targets set by a company should not be apparent in the permit as this can affect the companies' interests in setting targets. Regulators should offer clear and attractive incentives for companies to join the management systems.
	Voluntary energy saving agreements by national industries can lead to substantial energy savings and more efficient use of energy. Regulators should establish and follow up on concrete measures in these agreements.
	Regulators should provide general training for environmental authorities to increase their knowledge of energy efficiency principles. Environmental authorities should be provided with information from the voluntary energy audits made by energy experts.

·The full report is available at: http://www.environment.fi/publications/thefinishenvironment/2003/FE614

By: Marianne Lindström (Marianne.Lindstrom@ymparisto.fi), Mikko Attila, Jaana Pennanen from the Finnish Environment Institute and Elise Sahivirta from the Finnish Ministry of the Environment