Ministry of Environment

STRATEGY FOR USING ISPA FUND AS A SUBSIDIARY INSTRUMENT FOR IMPLEMENTATION OF THE NATIONAL ENVIRONMENTAL POLICY

December 1999

TABLE OF CONTENTS

1. INTRODUCTION

1. INTRODUCTION

The Republic of Poland, like nine other Central and Eastern European countries, is a candidate to a membership in the European Union (EU). In preparation for its planned accession date of 1st January 2003, Poland is currently undertaking various measures to comply with the acquis communautaire. In addition to the existing Phare programme, support will be provided by the EU through ISPA (Instrument for Structural Policies for Pre-Accession) managed by the EU Commission (DGXVI and DGIA). ISPA funds will be devoted to implementation of investments in environment and transport sectors, only and will operate most probably during the period of seven years (2000-2006).

This document deals with the environmental protection sector. It establishes the strategy in Poland for identification and selection of projects which will be proposed to be supported within the ISPA instrument in the following areas: wastewater treatment and water supply, air quality, and waste management. The main focus for ISPA in the environment sector is on measures which enable beneficiary countries, including Poland, to comply with the objectives of the Accession Partnerships as well as with the priorities indicated in the National Programmes for the Adoption of the Acquis. It is assumed that in the field of environmental protection ISPA resources will be used for implementation in Poland of the requirements of the following directives:

• Directive 80/778/EEC (with amendments) on drinking water, to be replaced in November 2003 with Directive 98/83/EC;

• Directive 91/271/EEC on urban wastewater treatment;

• Council Directive 96/62/EC on air quality assessment and management, together with the directives related to specific pollutants;

• Directive 88/609/EC on Large Combustion Plants;

• Directive 89/429/EEC on air pollution caused by the existing municipal waste incineration;

• Directive 94/67/EC on hazardous waste incineration;

• Directive 75/442/EEC on waste, so-called framework directive;

• Directive 91/689/EEC on hazardous waste;

• `Landfill Directive' (99/31/EC)

• Directive 96/61/EC on Integrated Pollution Prevention and Control.

Community assistance within the framework of ISPA may be granted in various forms (e.g. direct non-repayable grants, repayable aid, and others). ISPA beneficiaries will be public sector units, such as state enterprises acting in public interest, local communities (gminas) and municipal enterprises registered under commercial law but totally owned by local communities. The rate of Community assistance granted under ISPA will in most cases amount to up to 75% of the total expenditure from public resources. ISPA funds cannot be combined with any other Pre-Accession instruments, except for LIFE programme. All investments supported from ISPA must be economically efficient. Social cost and benefit analysis must prove the net benefit for the society resulting from the investment. The total cost of each project will in principle be not less than Euro 5 million, although, in exceptional cases, projects with a total cost of less than Euro 5 million will also be considered.

ISPA may finance preliminary studies and technical support measures at 100% of the investment's total cost (up to 2% of the total ISPA allocation), including:

1. Economic/financial feasibility studies,

2. Environmental Impact Assessments, according to EU rules,

3. Technical reviews, designs and cost analyses,

4. Assistance in the preparation of tender documentation,

5. Assistance in project management.

This document relates only to environmental protection problems, and in particular to water and sewer management, waste management and assuring appropriate quality of air. It consists of six parts:

1. Information on changes in the state of environment;

2. Information on provisions and goals of environmental protection policy;

3. Overview of environmental infrastructure;

4. Information on financing environmental projects;

5. Information on selection criteria for projects to be financed from ISPA;

6. List of priority areas in the field of investment needs that is helpful in project selection.

2. CHANGES IN THE STATE OF ENVIRONMENT

2.1 Introduction

Poland is one of the larger countries in Europe with a territory measuring some 312,685 km². The country is subdivided into 16 voivodships (regions).

Poland has a population of around 38,600,000, with 65% living in urban areas. There are 42 cities with population of over 100,000. Warszawa, the capital, is by far the largest city with a population of over 1,626,000, followed by Lodz (815,000), Krakow (740,000), Wroclaw (641,000), Poznan (580,000), Gdansk (462,000), Szczecin (419,000), Bydogoszcz (387,000), Lublin (356,000) and Katowice (350,000).

The most urbanised region is the Upper Silesian Industrial District, which contains eleven cities including Katowice with over 100,000 inhabitants. There are also large clusters of towns and industrial settlements in Warsaw industrial district, Lodz industrial district, Gdansk-Gdynia district, and in Lower Silesia.

Rivers draining most of the country's surface area (99.7%) flow into the Baltic Sea. The two largest rivers have their outlets in the Baltic Sea. They are:

1. Vistula, which drains around 50% of Poland's surface area, is 1,047 km long and has a total catchment area of 194,400 km², 85% of which is within the Polish territory;

2. Odra, which is 854 km long and has a total catchment area of 118,900 km², 90% of which is situated within the Polish territory.

Warszawa, Krakow, Bydgoszcz and Gdansk lie in the catchment area of the Vistula river. Lodz, Wroclaw, Poznan and Katowice lie in the catchment area of the Odra river.

During the period 1988-98, Poland has undertaken and implemented many environmental protection programmes, which have resulted in a significant improvement of the state of environment in the country. Emissions of pollutants into the air and water have decreased, the area covered with legal nature protection has increased, and decisions on the adoption of several international environmental conventions have been taken. The improvement of the state of environment is the consequence not only of the decline in heavy industry's activity, but also of the numerous capital-intensive investments undertaken by private and public institutions as well as of other measures implemented in accordance with the National Environmental Policy.

2.2 Water Supply

Currently, groundwater constitutes the main source of water for municipal supply, providing about 60% of the total volume of water abstracted (1282.7 hm³), with the rest (1009.3 hm³) abstracted from surface water intakes (mostly from the rivers, and to a lesser degree - from artificial water reservoirs and lakes). In the nineties water consumption decreased; in addition, a significant change of municipal water provision sources took place - share of water abstracted from surface waters has significantly decreased (in 1990 1527.9 hm³, i.e. 54% of water abstracted originated from surface waters). Abstraction from groundwater sources has decreased much less (in 1990 it amounted to 1476.7 hm3). This phenomenon is related to poor quality of surface waters in Poland - in 1997 none of the rivers monitored was classified as first class quality water, 0.5% was assigned the second class, 13.8% - third class, and 85.7% was considered to be beyond any standards. Quality of groundwater is generally higher than the quality of surface waters, although a certain percentage of these waters (some 17%) is significantly polluted.

The main sources of surface water pollution are untreated or inadequately treated wastewater discharges from urban areas, industrial discharges, and agricultural runoff. Deposition of pollution suspended in the air constitutes less significant source of surface water pollution. The main cause of groundwater pollution is infiltration of pollutants (industrial, agricultural and municipal) from soil surface.

2.3 Wastewater

The amount of municipal and industrial wastewater discharged into surface waters has decreased over the past 10 years, as shown in Table 2.3.1. Decrease of the amount of wastewater requiring treatment results from more rational use of water in households and industry, and decrease of the amount of untreated wastewater discharged occurred thanks to construction of approximately 7 000 new wastewater treatment plants during the period of 1988 - 98.

Since municipalities discharge five times more untreated wastewater than industrial sources, it is clear that urban wastewater has the potential to exert an enormous impact on water quality. Therefore, construction of municipal wastewater treatment plants has been attached a priority in the National Environmental Policy.

Table 2.1 Wastewater discharges in the period 1988-97

[GUS 1990, GUS 1998]

Type of wastewater	1988	1990	1991	1992	1993	1994	1995	1996	1997
Industrial hm^3	9581	9055	8418	7973	7757	7798	8129	8324	8269^1
Municipal hm^3	2478	2314	2166	2075	1981	1999	1852	1752	1692
Untreated hm^3	1664^2	1343	1134	995	844	809	700	611	520^3

¹ including 7111.9 hm³ of refrigeration waters (according to the regulations not requiring treatment),

² including 37.3% of wastewater requiring treatment,

³ including 18.3% of wastewater requiring treatment.

2.4 Air Quality

During the past 10 years a general decrease in emissions of all basic atmospheric pollutants including sulphur dioxide (SO₂), oxides of nitrogen (NO_x), carbon dioxide (CO₂) and particulates has been observed in Poland (table 2.4.1.). The change in pollution levels is partly related to reduction in industrial activity, but it is mainly due to the elimination of industrial technologies resulting in emission of significant amounts of pollution to the air, modernisation and restructuring of production technologies, installation of equipment for treatment of exhaust gases etc.

Increase of NO_x emissions over the last three years is a reason of concern. This increase in NO_x emissions is related to a rapid increase of the number of motor vehicles in Poland and to the increasing share of road transport in shipment of passengers and goods. Stopping the increase of NO_x emissions and further reduction of emissions of other pollutants constitutes one of the basic goals of the National Environmental Policy.

Table 2.4.1 Emission levels for selected air pollutants (1988-97)

GUS 1990, GUS 1998

Pollutants	1988	1990	1991	1992	1993	1994	1995	1996	1997*
SO2(10^3 t)	4180	3210	2995	2820	2725	2605	2376	2368	2320
NOx (10^3 t)	1550	1280	1205	1130	1120	1105	1120	1154	1180
CO2 (10^3 t)	509	384	388	359	372	348	330	373	370
Particulates (10^3 t)	3400	1950	1680	1580	1495	1395	1308	1250	1200

* approximate data

2.5. Solid Waste

Table 2.5.1 indicates changes in the volume of generated and utilised municipal and industrial waste over the past 10 years. Still a large volume of industrial and municipal waste is deposited in landfills; also the tendency of growth of the volume of municipal waste generated in recent years is observed. This is partly due to mass introduction of disposable products and packages into the Polish market. The amount of waste utilised in the economy is considered to be too low, and recycling systems or environmentally safe waste utilisation systems operate for an insufficient scale. Therefore, development of environmentally safe methods of waste disposal constitutes one of the most important goals of the National Environmental Policy.

Table 2.5.1 Production and utilisation of waste (1988-97)

[GUS 1990, GUS 1998]

	1988	1990	1991	1992	1993	1994	1995	1996	1997
Municipal waste deposited in landfills, 10^3 m^3	46478	42686	40915^*	47000	40941^*	42364^*	42248	44697	46859
Industrial waste generated during the year, 10^6 t	185.9	143.9	128.3	121.9	120.5	121.5	122.7	124.5	124.5
Industrial waste utilised in the economy, 10^6 t	105.7	77.0	65.5	64.3	64.6	65.6	66.9	69.5	80.2
Industrial waste deposited in landfills, 10^6 t	79.7	66.5	62.3	57.1	55.5	54.7	55.5	54.8	44.0

* excluding waste removed by small private firms

3. KEY FEATURES OF ENVIRONMENTAL PROTECTION POLICY

3.1 Introduction

The institution responsible for environmental protection, including transposition and implementation of the acquis communautaire in this field, is the Ministry of Environment. The Ministry is responsible for drawing up national environmental policy provisions and for preparation of legislation within its field of competence (related to, among others, air protection, soil and water protection, forests and nature as well as natural resources). The Inspectorate of Environmental Protection is responsible for control over the performance and execution of environmental law and its obligations both nationally and within the voivodships. The Inspectorate is independent of the Ministry but still under the control of the Minister. The Ministry oversees also five independent research institutes: Institute of Meteorology and Water Management, Institute of Environmental Protection, Institute for Industrial Environmental Problems, Institute for Forestry Research, and Geological Institute.

The Minister of Health and Social Care is responsible for chemicals control and quality of water for human needs. He shares responsibilities with the President of the State Atomic Agency in relation to radiation protection. The Minister of Internal Affairs and Administration is responsible for spatial planning.

Activities such as discharge of wastewater, emission of pollutants into the air, waste generation require holding a permit in a form of administrative decision. Such decisions - in relation to enterprises that are particularly harmful for the environment - are issued by the voivods, and in case of other economic units - by wójt (head of gmina), mayor or president of the city.

3.2 Environmental Policy

The National Environmental Policy adopted in 1991 is a document setting directions of environmental policy in Poland. It indicates the main environmental protection priorities and areas where state's intervention is necessary for preservation of natural resources. Since the situation of Poland changes (accession to OECD and NATO, launching membership negotiations with the EU), as well as because of new emerging environmental challenges a necessity of verification of the NEP is emerging. Currently the new National Environmental Policy is being prepared. It is assumed that this document will be based expressis verbis on the rules of sustainable development and will be fully consistent with the EU policy in this field.

Environmental programmes implemented between 1988-98 have been successful in reducing the levels of pollution in Poland. Nevertheless, many environmental problems still exist and they are awaiting solutions. Currently the following problems are considered to be the most important challenges of the country's environmental policy:

1. transposition of the EU environmental requirements to the Polish legislation and implementation of their practical requirements;

2. decreasing the energy- and material-intensiveness of the economy, e.g. through introducing water- and energy-saving technologies and solutions, reducing packaging needs and closing the circulation of materials within groups of enterprises;

3. ensuring effective protection of natural resources and biodiversity;

4. limiting negative impact of transport on the environment.

These priorities will be taken into account in the new National Environmental Policy. They must be supplemented with the detailed goals, implementation of which will ensure execution of the requirements of the EU law in Poland, will lead to improvement of the state of natural environment, and will ensure effective mechanisms for protecting the environment against degradation. Such goals, covered with the scope of this document, are the following:

1. In the field of water and wastewater management

1. implementation of programmes aimed at reduction of water consumption, both for water used for industrial purposes and for municipal purposes (among others through introduction of closed water circulation, educational actions etc.);

2. improvement of quality of surface waters, especially in places where they constitute a source of drinking water or assuring provision of drinking water consistent with the EU quality requirements (e.g. through construction of wastewater treatment plants in agglomerations and enterprises which affect the quality of water used for provision of drinking water, through modernisation of water-sewer systems and development of water reservoirs, as well as through the reform of water management system);

3. modernisation, extention and construction of wastewater collection and treatment facilities for municipalities with a population equivalent (p.e.) of over 2,000;

4. protection of groundwater resources (among others through limiting use of groundwater for industrial purposes);

5. reconstruction of small retention systems, elimination of water deficits in urban agglomerations and rural settlements, provision of good quality water for drinking purposes and for farming purposes in rural areas, including construction of reservoirs;

6. reduction of discharge of salt waters from hard coal mines to surface waters.

1. In the field of air quality

1. implementation of programmes aimed at increasing energy efficiency and at its saving (among others through thermoinsulation of apartment buildings and public utility buildings, modernisation of power networks etc.);

2. Improvement of air quality in agglomerations where the permissible levels of concentration of pollutants are exceeded, first of all through decreasing emissions of particulate matter and gases into the atmosphere (both reduction of emissions from large enterprises and from small, dispersed, local sources), and through reduction of burden created by transport;

3. Implementation of programmes for counteracting global climate changes;

4. Reduction of SO₂ emissions up to the level resulting from the Second Sulphur Protocol;

5. Reduction of NO_x emissions to the atmosphere;

6. Reduction of volatile organic compound emissions and heavy metals.

1. In the field of solid waste

1. implementation of programmes aimed at reduction of the amount of generated industrial and municipal waste, implementation of modern technologies of reuse of waste;

2. decreasing the total amount of industrial waste deposited in landfills through successive implementation of modern technologies with little or no waste generated;

3. decontamination or safe deposition of all generated hazardous waste;

4. creation of pre-selection systems and recycling of waste as well as environmentally safe disposal.

Significant from the point of view of integration with the European Union is also achieving the following goals:

• Adjustment of the environmental monitoring system to the requirements resulting from the European Union directives;

• Increase of the areas of protected nature and creation of the coherent system of protected areas within the framework of the NATURA 2000 programme;

• Rehabilitation of contaminated land polluting groundwater sources.

It is assumed that the investments necessary for achievement of these goals will be eligible to receive support from the European Union funds.

4. BRIEF OVERVIEW OF ENVIRONMENTAL INFRASTRUCTURE

4.1 Introduction

One of the principal challenges to local authorities in the 1990s was improvement of the municipal infrastructure management. It was viewed as a precondition for development of the local economy. As indicated in Section 2, much progress has already been achieved in this field. However the process of integration with the European Union imposed on Poland new obligations in this field. Meeting these obligations will be difficult and costly, and therefore it will need much time. Selected issues related to environmental protection infrastructure and to the problems covered with the scope of this document will be described below.

4.2 Water Supply

There are considerable differences between the existing Polish regulations and Directives 80/778/EEC and 98/83/EC related to the quality of water intended for human consumption. Adjustment of Poland to the requirements of EU regulations will need expansion of the existing system in the selected agglomerations as well as construction and modernisation of water purification stations. Estimates based on evaluation of the current demand for water in municipalities indicate the necessity of extension of the network by some 9,000 km. In many rural areas provision of water supply network is impractical, due to highly dispersed nature of settlements.

4.3 Wastewater

Current Polish legislation does not impose the obligation to build wastewater collection systems and treatment plants, as imposed by the Directive 91/271/EEC concerning urban wastewater treatment. Therefore, the needs in this field are considerable (see Table 4.3.1). Two cities with population equivalent (p.e.) of over 100,000 - Kalisz and Grudziądz - do not have any wastewater treatment facilities. In Tarnów (p.e. 152,900) 92% wastewater is not treated, Szczecin (p.e. 418,800) - 87%, and in Bydgoszcz (p.e. 386,600) - 79%. Warsaw (p.e. 1,626,000), is currently the single largest point source of untreated wastewater in Poland, discharging into the environment 93.2 hm³/year of untreated municipal wastewater. Construction and operation of wastewater treatment plants in just six cities - Warsaw, Lodz, Krakow, Szczecin, Bydogoszcz and Torun - would reduce the total discharge of untreated municipal wastewater in Poland by about 50%.

In order to comply with the requirements of EU legislation extension of the sewer network will be necessary. At the rural areas with dispersed settlements it is planned to preserve the existing methods of wastewater management, i.e. its storage in contained reservoirs without drain and periodical removal to wastewater treatment plants using special cars.

4.3.1 Vistula and Odra river basins

In 1992, a report prepared within the framework of the High Level Task Force of the Helsinki Convention was prepared, which identified sites and areas which were the most harmful to the Baltic Sea. In Poland 33 such areas were identified, 19 in the Vistula basin and 12 in the Odra basin. During the period of 1992-99, Poland implemented a number of actions which resulted in a significant reduction of the pollution load discharged to the Baltic Sea.

Table 4.3.1 Municipal wastewater treatment facilities (1997 data)

[GUS 1998]

Specification	Municipalities with the population number
	2,000-4,999	5,000-9,999	10,000-19,999	20,000-49,999	50,000-99,999	Over 100,000
Number of municipalities	235	181	182	137	50	42
Municipalities which are equipped with wastewater treatment plants: mechanical biological with enhanced removal of nutrients	169 9 148 11	154 13 124 16	160 21 103 36	129 17 78 31	46 7 23 16	39 7 27 4
Municipalities without wastewater treatment plants	66	27	22	8	4	3
Population served by wastewater treatment plants: In thousands As % share of municipal population	354.4 45.1	751.4 58.5	1,809.2 68.4	3,355.5 79.4	2,585.7 77.0	8,293.7 71.8

In 1997, of the 1,536 hm³ of wastewater discharged into surface waters in the Vistula basin, approximately 292 hm³ (i.e. 19%) was released untreated (of which 248 hm³ was untreated municipal wastewater). Wastewater discharged from 18 municipalities in the Vistula basin constituted over 80% of the total amount of untreated wastewater discharged to surface water within this river basin (Warsaw is the source of 40% of the total load of untreated municipal wastewater discharged into the Vistula river each year). Construction of wastewater treatment plants in these municipalities, including Krakow and Warsaw agglomerations, should be considered to be priority investments.

Polish part of Odra basin contains some 1,700 point sources of pollution, including 700 sources having a significant impact on water quality. In 1997, of the 1,076 hm³ of wastewater discharged into surface waters in the Odra basin, 19% was released untreated, and 45% received only mechanical treatment. 97 of the 375 municipalities in the Odra basin do not have wastewater treatment facilities. Construction of wastewater treatment plants in municipalities such as Lodz, Wroclaw and Poznan is a priority.

4.4 Air Quality

The quality of atmospheric air in Poland is generally good, although in some agglomerations periodical exceedances of the permissible concentrations of pollutants occur. This relates primarily to suspended particulates, ozone, carbon oxide and nitrogen oxides. The main sources of air pollution are power and heating plants as well as large enterprises - especially steal mills, refineries and other chemical plants. In the recent years most of these economic units has installed equipment for exhaust gases treatment. It is assessed that equipment of industrial enterprises related to particulates' emission control is satisfactory; a significant improvement has been achieved in the field of construction of desulphurisation equipment. Significant investment outlays in the area of limiting emissions of nitrogen oxides, volatile organic compounds and selected other industrial pollutants are necessary.

The main sources of pollution in municipalities are local boiler houses, individual boilers, and car transport. Gradual decrease of these types of burden is assumed through covering a higher number of inhabitants with central heating networks, switching medium of energy in municipal and individual boilers from coal into gas, and, where it is impossible, introduction of higher quality coal into the market. Improvement of air quality will also be achieved through support for technologies increasing energy efficiency and its saving. Also the activities aimed at decreasing burden related to transport will be undertaken; it is assumed that emission of pollution from motor vehicles will drop as a result of adjustment of liquid fuels' quality to EU requirements.

4.5 Solid Waste

The primary method of waste disposal in Poland is its deposition at landfills. Selective waste collection, its recycling and economic use are not well developed. Only a few municipalities are equipped with facilities for composting of organic waste, other technically advanced methods of waste utilisation are applied only at a small scale. It is estimated that for improvement of the situation in the field of waste management a significant number of modern installations for waste disposal (sorting stations, composting stations, incinerators etc.) has to be built as well as approximately 1 500 new landfills. Also activities aimed at improvement of sanitary conditions of municipal landfills are necessary because many of the landfills - both these under exploitation and these which are already closed - are in a bad state and require taking actions aimed at protection of the environment against their negative impact.

The most serious problems with restitution of the existing landfills, lack of suitable locations for new ones, and lack of facilities for the decontamination and recycling of waste occur in the largest cities. For example:

1. Krakow (740,000 inhabitants) currently produces approximately 200,000 t of waste per year. It is estimated that over 90% of the population in Krakow is served with systematic waste removal services. Selective collection of waste is implemented for around 100,000 inhabitants. Waste is deposited in Barycz landfill which is projected to be filled up to capacity in the year 2009.

2. Szczecin (419,000 inhabitants) currently generates 200,000 t of waste (including 100,000 t of municipal waste) per year, which is landfilled.

3. Poznan (580,000 inhabitants) generates around 166,000 t of waste per year. Around 90% of the city is served by waste collection services.

4. Wroclaw (640,000 inhabitants) generates around 260,000 t of waste per year. The waste is taken to Maslice landfill, which is almost full and is planned to be closed up until the end of 1999.

5. Lodz (815,000 inhabitants) generates approximately 347,000 t of waste per year. Selective collection of waste is undertaken on a small scale.

6. 8 former voivodships of mid-eastern Poland generate 14.4 Mt of waste per year, of which only 20% is reused. Around 90% of waste comes from the energy and mining sectors, where the indicator of reuse equals 18%.

Taking into account the necessity of organising waste management systems in large agglomerations, investments in the agglomerations of over 400 000 inhabitants will be considered to be priorities within ISPA.

5. FINANCING ENVIRONMENTAL PROTECTION INVESTMENTS

5.1 Introduction

Over the years financial means for the maintenance, modernisation and development of environmental protection infrastructure in Poland have been insufficient. However recently achievements in this field have been made through creation of an effective system of environmental protection financing from environmental funds. The system of financial support for environmental investment created at the beginning of the nineties is functioning based on the National Fund for Environmental Protection and Water Management, voivodship, poviat and gmina funds as well as on banks, foundations and aid programmes, leasing institutions investment funds and others. During the past three years the value of environmental investment accounted for approximately 2 billion euro per year, which in 1997 constituted 8.1% of all investment outlays in the economy. Table 5.1 contains informationon share of different sources in financing environmental protection investment in Poland during the period 1991 - 1997.

Table 5.1.1 Financial resources devoted to environmental investment during the period 1991-97

[GUS 1994, Ministry of Environment 1999]

Source of financing	% share in total financial resources devoted to environmental investment
	1991	1992	1993	1994	1995	1996	1997	1998
Environmental funds*	40	58	47	41	40	34	30	28
Investors' own resources & commercial loans	30	20	25	31	32	38	40	43
State budget	5	5	7	5	5	5	3	3
Municipal budgets	20	13	16	19	18	19	23	19
Foundations and foreign aid	5	4	5	4	5	4	4	7

Note: * National Fund for Environmental Protection and Water Management, regional (voivodship) and local (gmina) funds

In the nineties foreign financial resources played a significant role in supporting environmental investment (see table 5.1.2). These were in particular bilateral aid funds, Phare funds, funds from debt-for-environment swap, and World Bank resources. The role of foreign funds was important in spite of the fact that they constituted only 4-5% of total investment outlays for environmental protection, because they had a function of financial leverage in mobilisation of domestic resources.

Table 5.1.2 Bilateral aid during the period 1990 - 30.06.1998

[Karaczun 1999]

	Sector	No. of projects	Donations in US$ million	% share of donations
1	Air protection	51	54.82	41
2	Water protection and management	136	53.99	40.3
3	Soil protection	29	7.55	5.6
4	Nature protection	6	0.76	0.6
5	Environmental monitoring	13	4.67	3.5
6	Other problems	50	12.04	9
	Total	285	133.81	100

Experience gained in managing foreign resources in the nineties will be utilised for appropriate handling with ISPA resources.

Because of differences in Polish and EU environmental protection laws, and because of weak financing of environmental protection infrastructure during the years 1945 - 1989 it is predicted that implementation of the acquis in the field of Environment will be very costly. The existing estimates in this field indicate that indispensable investment outlays will amount to 30-40 billion euro. Poland has prepared a strategy for financing programme of implementation of the acquis. Table 5.3 shows a preliminary forecast of financial flows in environmental protection sector during the period 1999-2006.

Table 5.1.3 Preliminary financial flow forecast for implementation of approximation programmes in environmental protection sector during the period 1999-2006 (million Euro)

Capital needs - adopted assumptions
	2000	2001	2002	2003	2004	2005	2006	Total
Water quality	950	950	1000	900	900	900	800	6 400
Air quality	1370	1470	1655	1200	1200	1200	1200	9 295
Waste management	252	302	347	350	350	350	300	2 251
TOTAL	2 572	2 722	3 002	2 450	2 450	2 450	2 300	17 946

Balance of available resources - in constant prices (1999)
	2000	2001	2002	2003	2004	2005	2006
EU support	177	177	177	177	177	177	177
Polish public resources	606,0	608,5	610,9	613,4	615,8	618,3	620,7
Polish private resources including loans	1427,4	1427,4	1427,4	1427,4	1427,4	1427,4	1427,4
IFIs	0,0	0,0	0,0	0,0	0,0	0,0	0,0
Total	2 089,5	2 226,5	2 383,8	2 645,1	2 771,1	2 799,4	3 086,9
Needs	2 572	2 722	3 002	2 450	2 450	2 450	2 300
Deficit	361,6	509,1	786,7	232,2	229,8	227,3	74,9

Poland can receive 30-37% of the total ISPA fund devoted to environmental protection and transport. Therefore, the annual portion of ISPA fund for environmental protection may account for 156 to 192.4 million euro.

However it is predicted that a financial gap for implementation of approximation programmes during the years 1999-2006 (in different periods) may amount to 25-660 million euro (depending on scenario), and it will be the highest during the period 2001-2003. During the described period Poland will also be able to use the resources of international financial institutions (which was not taken into account in the balance).

The following activities are predicted in order to eliminate financial gap:

1. implementation of product fees and deposits;

2. transferring part of investment outlays to consumers (through gradual increase of charges for energy, drinking water, wastewater discharged to sewers);

3. soliciting funds from international financing institutions;

4. mobilisation of additional funds from the central budget, environmental funds and commercial sources.

Currently work is being conducted on possibilities of utilisation of new financing sources for environmental investment, among others a draft act on product fees and deposits has been directed to inter-ministerial consultations.

5.2 An outline of financing strategy for the investment programme in environmental protection sector

5.2.1 Public financing sources

In such a fields like the municipal water-sewer and solid waste infrastructure or municipal heating systems a dominating role in financing of the investments will be played by the public sources, both domestic and foreign ones. Main domestic sources are self-government own budgets, public debt created by self-governmental authorities, earmarked donations from the state budget, and extra-budgetary funds for environmental protection and water management (see Table 5.1.1).

Specific feature of the environmental investment financing system in Poland, created in the early 90-ties, is that a burden imposed on the state budget, i.e. eventually on tax payers, has been minimal for many years. Extra-budgetary funds for environmental protection play an important role in the environmental protection financing system. Part of their incomes comes from the fees for using the environment and fines imposed for violation of legal environmental protection standards (although recently the share of returned loans granted before has been systematically increasing). Share of the environmental funds in financing investments is decreasing year by year, mainly because of increase in the share of investors' own resources and commercial loans (see Table 5.1.1). This is a positive trend, consistent with the “Polluter Pays Principle”.

The role of environmental funds in financing pre-accession investment programme will focus not so much on lowering financial costs of the investments, but rather on concentrating the resources on supporting investments which constitute priorities from the point of view of the investment programme. The funds should place the goals related to European integration on their priority lists, and they should implement the requirement of consistency with the European Union standards.

A significant burden of financing investments in water-sewer infrastructure will rest on shoulders of gminas (local communities). Within the limits set by law and credit ability, self-governmental financing of these investments should be based either on loans, or on gmina guarantees for external debt coming from the banking sector or international financing institutions. In situations justified by gmina authorities, investments can be financed out of current incomes of self-government authorities, or, where possible, out of earmarked donations of the state budget.

5.2.2 Private sources of financing

To date Poland used private sources of financing of investment in public infrastructure only to a limited extent. An effective system of incentives and preferential conditions for attracting private sector capital was non-existent. Granting concessions to private firms for construction and operation of gmina infrastructure is still exceptional, and at the moment it is quite complicated from the legal point of view.

Full balancing of the programme aimed at implementation of the acquis will require increasing the role of the private sector versus the expected further decrease of incomes of environmental protection funds and exhausting capabilities of self-government authorities, in order to meet the increasing needs in the area of gmina infrastructure financing. As a result of administrative reform of the state it is expected that over the next several years competition (in getting access to public funds) among environmental protection infrastructure and other sectors' infrastructure (health protection, education, social assistance, culture) will increase.

Commercial banks are systematically increasing interest in financing gmina infrastructure. Water-sewer investments unfortunately have low financial rates of return and long repayment periods, but they are also characterised with a relatively low risk. This risk should be further decreased through rational and stable approach of self-government authorities guaranteeing sound financial base of public infrastructure.

As for municipal bonds, primarily larger cities have decided to finance infrastructure investments through emission of such bonds to date. Until the end of 1996, 70% of total municipal debt in the form of bonds was issued by 44 largest cities, although there are also good examples of small cities that issue bonds in order to finance water-sewer infrastructure. Approximately 95% of bonds was purchased by banks, which confirms inclination of the commercial banks to financing municipal debt, but at the same time it indicates that attractiveness of municipal bonds for institutional and individual investors is still low.

It is predicted that within the framework of the National Strategy for Environmental Protection (being a part of the National Development Programme), the investments co-financed by the private sector, in compliance with EU requirements on free competition, will be given a priority.

6. BASIC CRITERIA FOR SELECTION OF INVESTMENT TO BE CO-FINANCED FROM ISPA FUND

6.1 Introduction

All the investments supported by ISPA must be economically efficient. It is not equivalent to financial profitability. Social cost and benefit analysis (CBA) must prove the net benefit for the society resulting from implementation of the investment.

The projects which are to be supported from ISPA resources do not have to be financially profitable without subsidies from public sources. However, after receiving the subsidies (especially from ISPA), economic indicators (ERR and ENPV) for the investor should overcome the threshold of profitability, which is a necessary condition for implementation of the investment. Financial liquidity of the investment during operation should also be documented; alternatively, it should be proved that the investor will be capable to finance deficits in financial flows, should they occur. Too high financial profitability of the project for the investor will cause rejection or decrease of the ISPA subsidy, because it will mean that the investment can be financed out of commercial sources.

In each case capability of the investment to generate incomes will be analysed. In environmental infrastructure of gminas user fees (paid by households, economic entities) constitute a source of income. The level of fees covering costs of operation, maintenance and amortisation (depreciation) must be scrupulously calculated. Calculations of the full annualised costs, which corresponds to total demand of the investment for annual income in order to be self-sufficient, will also be required. It will be possible to gradually increase the user fees related to public infrastructure, provided that it can be proved that too rapid increase in fees will impose too high burden on households' budgets. Incomes generated from fees which the users will be able to pay, will decrease the share of ISPA in financing the investment, because after capitalisation they will be subtracted from eligible costs constituting the basis for calculating the share of public resources.

The criteria for selecting priority areas of investments which will be eligible for receiving support from ISPA resources are as follows:

1. projects which are consistent with the EU environmental policy objectives (Art. 130 R of the Maastricht Treaty)

a) preserving, protecting and improving the quality of the environment,

b) protecting human health,

c) prudent and rational utilisation of natural resources.

2. projects which are consistent with the EU environmental principles (Art. 130 R of the Treaty), and in particular with:

a) precautionary principle,

b) preventive action principle,

3. elimination of pollution at its source,

4. Polluter Pays Principle.

3. Activities which are listed as priorities in the National Programme for the Adoption of the Acquis (NPAA);

4. projects which can demonstrate quantitative reductions in pollution for a maximum number of people (thus generating an effect of scale);

5. projects which will support implementation of the new National Environmental Policy in those areas where it is fully compatible with NPAA and the provisions of the Council regulation on ISPA;

6. pilot projects which have the potential to stimulate strong partnership between regional and local authorities, aimed at fast development of regions through utilisation of regional characteristics of human and environmental resources. These are area of such a rank as: Białowieża Forest, Drawieński National Park, Podhale region where 4 national parks are situated, the green belt region around Warsaw and the area of “Zielona Płuca Polski”;

7. projects contributing to protection of ecosystems of extraordinary value from the point of view of nature protection and biodiversity;

8. projects which have the best potential to contribute to gradual achievement of economic and social cohesion of Poland with the EU (showing the highest economic and social benefits).

The projects co-financed from ISPA and realised on regional level will be placed in broader legal and institutional frameworks enabling implementation of sustainable development, and will be consistent with the environmental protection programmes in these regions.

Of particular interest will be the projects proposed by gmina associations or by the units connected with the coherent environmental systems. This should allow to create larger, more comprehensive projects with a higher budget - easier for handling and supervising; also supporting cooperation of self-government units.

6.2 Environmental goals for the years 2000-2002

Investments serving environmental goals for 2000-2002 will be given priority in access to ISPA grants that will reach up to 75% of the share of public resources. Supplementary investment from public sources will be available in the form of grants and soft loans from national and regional funds for environmental protection. The investors will have to prove impossibility of receiving co-financing from commercial sources and from international financing institutions. At least 20% of investment outlays will have to be provided from gmina (local community) resources, e.g. from gmina budget, profits or amortisation funds of gmina companies. The most important goals to be achieved during this period will be:

1) In water supply and wastewater sectors:

a. preparation of the new water law and executive orders to this act, fully compatible with the EU requirements;

b. preparation of detailed water quality improvement programmes;

c. completion of institutional changes related to EU law implementation in the water supply and wastewater sectors;

d. modernisation of the national water quality monitoring network;

e. launch of investments in the water provision and wastewater sector in the largest Polish agglomerations.

2) In the air quality sector:

a. adoption of the new act on environmental protection and executive orders to this act, regulating air protection issues;

b. modernisation of the country's air quality monitoring network;

c. completion of institutional changes related to the necessity of EU law implementation in the field or air protection;

d. preparation of air quality improvement plans in the areas where the permissible concentrations of pollutants are exceeded;

e. implementation of investments in new large combustion plants related to desulphurisation of exhaust gases;

f. initiation of implementation of investments related to production of fuel of the quality consistent with the EU requirements;

3) In the solid waste sector:

a. adoption of the new act on waste and executive orders to this act;

b. strengthening of institutions dealing with waste management;

c. initiation of the process of verification of existing waste management programmes and creation of new programmes, consistent with the EU requirements;

d. implementation of waste management investments in major agglomerations, in accordance with the existing programmes. Programmes in smaller settlement units will be implemented according to availability of funds;

6.3 Environmental protection goals for the years 2002-2006

Investments serving implementation of environmental goals for 2002-2006 will also be given a priority in access to ISPA grants which will reach up to 75% of the share of public resources. Supplementary investment from public sources will be available in the form of grants and soft loans from National and regional funds for environmental protection. The investors will have to prove impossibility of receiving co-financing from commercial sources and from international financing institutions. At least 20% of investment outlays will have to be provided from gmina resources. The most important goals to be achieved during this period are:

1) In the water supply and wastewater sectors:

a. investments leading to regulating water provision and wastewater management (in accordance with the requirements of Directive 91/271 EEC) in all agglomerations with a population equivalent of over 100,000;

b. investments leading to regulating water provision and wastewater management (in accordance with the requirements of Directive 91/271 EEC) in 50% of all agglomerations with a population equivalent between 10,000 and 100,000;

c. investments leading to achieving compliance of water quality with the requirements of the EU for 75% of Polish citizens;

d. investments leading to compliance with the EU water quality standards related to water quality in all large water reservoirs serving as sources of drinking water;

e. protection of the most important reservoirs of standing water against eutrophication.

2) In the air quality sector:

1. implementation of investments resulting from air quality improvement plans in the areas where permissible levels of concentration of pollutants are exceeded;

2. launch of investments aimed at improvement of air quality in agglomerations.

3) In the solid waste sector:

a. completion of verification of the existing waste management programmes and creation of new programmes, consistent with the EU requirements;

b. implementation of waste management programmes in 50% of agglomerations;

c. enforcement of the existing waste management programmes in smaller settlement units.

7. PRIORITY PROJECTS TO BE CO-FINANCED FROM ISPA FUND

7.1 Water Supply/Wastewater

Priority investments in the water/wastewater sectors are projects related to:

1. wastewater collection, treatment and disposal projects:

a) implemented in agglomerations with a population equivalent of over 100,000;

b) serving protection of surface water and groundwaters serving as sources of drinking water; in this respect projects aiming at rehabilitation of contaminated land polluting groundwater resources, elimination of danger related to contamination of drinking water intakes;

c) serving protection of waters especially sensitive to eutrophication (e.g. rivers, lakes and reservoirs, Baltic Sea);

d) limiting discharge of wastewater directly to lakes;

e) serving protection of transboundary waters.

2) expansion of water pipeline system, construction and modernisation of water purification stations.

Table 7.1.1 identifies priority areas for investment on the basis of the size of the agglomerations and the adequacy of the wastewater collection, treatment and disposal systems relative to the Urban Wastewater Directive.

Table 7.1.1 Priority areas for wastewater sector investments

City	Population equivalent	% population connected to sewer system	% population served by wastewater treatment plant	Wastewater treatment investment planned?	Sewer modernisation investment planned?
Warszawa	1,626,000	91%	46%	Yes	Yes
Lodz	860,000	94%	91%	Yes	Yes
Krakow	854,000	92%	68%	Yes	Yes
Poznań	806 000	96%	80%	Yes	Yes
Wroclaw	792,000	94%	89%	Yes	Yes
Gdansk	555,000	94%	100%	-	Yes
Szczecin	419,000	95%	13%	Yes	Yes
Rzeszów	406,000	97%	95%	Yes	Yes
Bydgoszcz	387,000	87%	21%	Yes	Yes
Katowice	366 600	82%	66%	Yes	Yes
Gliwice	283,000	92%	44%	Yes	Yes
Sosnowiec	246,000	91%	68%	Yes	Yes
Torun	209,000	90%	65%	Yes	Yes
Olsztyn	190,000	90%	90%	Yes	Yes
Opole	189,000	84%	97%	Yes	Yes
Ruda Slaska	165,000	96%	66%	Yes
Kalisz	163,000	86%	n.a.	Yes	Yes
Tarnow	153,000	90%	n.a.	Yes	Yes
Jastrzebie Zdroj	149,000	85%	93%	Yes	Yes
Zielona Gora	147,000	94%	n.a.	Yes	Yes
Walbrzych	139,000	98%	96%	Yes
Grudziadz	129,000	95%	0%	Yes	Yes
Rybnik	107,000	63%	51%	Yes	Yes

Source: Ministry of Environmental Protection, Natural Resources and Forestry, August 1999

In order to improve the quality of drinking water the following investment projects from the priority group aimed at protection of major water reservoirs should be considered:

1) Sewerage and wastewater treatment system in Czechowice Dziedzice and neighbouring communities - to protect Goczałkowice reservoir which is the source of drinking water for Katowice agglomeration,

2) Sewerage and wastewater treatment system in Górna Raba basin - to protect Dobczyce reservoir: the source of drinking water for Kraków agglomeration,

3) Sewerage and wastewater treatment system in Górny Dunajec basin - to protect Czorsztyn reservoir: the source of drinking water for Podhale region and Rożnów Reservoir,

4) Sewerage and wastewater treatment system in Żywiec and neighbouring communities - to protect Żywiec Lake: the source of drinking water for Beskidy and Podbeskidzie regions,

5. Sewerage and wastewater treatment system in Piotrków Trybunalski and neighbouring communities - to protect Sulejów reservoir: the source of drinking water for Łódź,

6. Sewerage and wastewater treatment system- in order to limit the direct pollution discharge into the Baltic Sea e.g. Wolin Island and Vistula Sandbar (Mierzeja Wiślana);

7. Sewerage and wastewater treatment system in Szczecin and neighbouring gminas - to protect Miedwie lake: the source of drinking water for Szczecin;

8. Protection of underground drinking water reservoirs.

Moreover, the projects which comprehensively cover issues of water protection in river basins, including the rule of water protection at its source will be considered. The examples of such type of projects include e.g. water protection of Wisłoka river basin, protection of Jeziorka river basin, protection of Drwęca river basin and wastewater and drinking water management programme for Bug River.

For limiting danger of eutrophication, the projects of construction sewerage systems and wastewater treatment plants in the region of Great Mazurian Lakes will be considered priority projects.

7.2 Air Quality

Table 7.2.1 identifies agglomerations and municipalities where the need of implementation of investments aimed at decreasing air pollution exists.

Table 7.2.1 List of agglomerations and municipalities where surpassing of permissible concentrations of at least one pollutant occur

	Excessive air pollution	Number of inhabitants
1	Warszawa	1 624 743
2	Katowice	348 974
3	Kraków	740 537
4	Łódź	812 317
5	Poznań	580 046
6	Szczecin	418 895
7	Bielsko-Biała	179 835
8	Bytom	225 799
9	Chorzów	123 045
10	Dąbrowa Górnicza	131 394
11	Gliwice	212 781
12	Jaworzno	100 000
13	Opole	130 119
14	Ruda Śląska	165 182
15	Rybnik	144 878
16	Sosnowiec	246 313
17	Toruń	205 840
18	Tychy	133 646
19	Zabrze	201 122

Activities aimed at reduction of air pollution in Poland should focus primarily on increasing effectiveness of energy use and on its saving, as well as on investments aimed at: modernisation of municipal boiler houses, switching from coal fuel into gas fuel in local and individual boilers, connecting municipal objects with local, industrial heat sources. Decreasing danger for air quality caused by emissions from individual coal burners can be achieved through extension of local heating systems, conversion of fuel in municipal boiler houses from coal into gas, construction of small heating nods, or through implementation of electric heating. In cases where such solutions cannot be used, alternative solution will be provision of smoke-free fuels or replacing old burners with the new ones, of high energy efficiency. Important activities aimed at limiting air pollution at urbanised areas will be those focusing on decreasing transport-related emissions.

The priority for air pollution control investment financed partly from ISPA funding should be modernisation of municipal stoves in accordance with the Directive 96/62/EC in the 20 largest cities in Poland, with top priority given to Katowice agglomeration, Krakow and Łódź.

Another priority for ISPA funding should be modernisation or conversion to natural gas of approximately 1,000 local heat generating plants which are 30 or more years old.

7.3. Solid Waste

Priority agglomerations and regions for investment supported from the ISPA fund are those with populations of over 400,000, and first of all Gdansk-Gdynia, Krakow, Łódź, Poznań, Szczecin, Toruń together with Bydgoszcz, Warsaw agglomeration, Wroclaw, Katowice agglomeration and the region covered by the 8 former voivodships of mid-eastern Poland. Information on the selected priority undertakings is listed below:

The proposed waste management programme for Krakow includes:

• Stage I, pilot (1997-2000) - development of the concept of the composting system, sorting station, and further development of selective collection of secondary materials;

• Stage II, development (1999-2002) - further development of the sorting station, construction of the second installation for composting, further development of selective collection, extension of Barycz landfill (3^rd phase);

• Stage III, final (2003 onwards) - implementing a project of thermal utilisation of waste in 2004 and further development of the composting and sorting stations.

The proposed waste management development programme for Poznań consists of the following stages:

• Stage I (1998-99) - setting up new containers in Klucze and Sieraków landfills, development of selective collection of glass, etc., launching a composting station;

• Stage II (2000-2002) - constructing a plant in Świednica, composting station, sorting station for selective collection, landfill for waste which is not appropriate for further processing, pilot plant for selective collection of wet/dry fractions;

• Stage III (after 2002) - construction of a waste incineration plant.

Waste management system being created in Poznań covers: collection of segregated waste, construction of 8 recycling stations, construction of waste incineration plants and landfilling for waste not appropriate for further processing .

The short-term waste management programme for Wroclaw consists of the following stages:

• Stage I (1999) - changing the local plan to include a waste utilisation plant (wastewater treatment plant, waste sorting, processing and composting stations), assuring transportation means for transferring waste to another landfill; performing study on needs in the area of waste combustion, analysis of possible development of regional integrated waste management system;

• Stage II (2000) - closing Maslice landfill and launching its recultivation, establishing legislative and economic framework for regional integrated waste management, preparing waste management plan for Wroclaw, increasing selective collection of waste;

• Stage III (2001) - preparation of a detailed programme and institutional structures for regional integrated waste management, implementation of such a programme in the selected areas.

The City Council in Łódź has recommended construction of a 200,000 t/year waste incineration plant, a hospital waste incineration plant, a plant for processing and utilisation of hazardous waste, and a landfill for this type of waste. The waste management programme currently under preparation is based on selective collection of secondary materials, composting of organic waste, using waste as a fuel, and on depositing of the remaining waste in landfills.

7.4 List of priority investments according to agglomerations

Table 7.4.1 presents priority agglomerations and regions where environmental protection projects are proposed for co-financing from the ISPA fund.

Table 7.4.1 List of priority investments according to agglomerations

City		Water and sewer management		Air quality			Waste
	Population equivalent		Investment needs		Investment needs	Investment needs
Warsaw	Over 1 626 000		∨			∨
Łódź	860 000		∨		∨	∨
Kraków	854 000		∨		∨	∨
Poznań	806 000		∨		∨	∨
Wrocław	792 000		∨		∨	∨
Szczecin	419 000		∨			∨
Rzeszów	406 000		∨			∨
Bydgoszcz	387 000		∨			∨
Toruń	209 000		∨			∨
Olsztyn	190 000		∨
Opole	189 000		∨
Kalisz	163 000		∨
Tarnów	153 000		∨
Zielona Góra	147 000		∨
Wałbrzych	139 000		∨
Grudziądz	129 000		∨
Katowice (agglomeration) Including: Gliwice Sosnowiec Ruda Śląska Jastrzębie Zdrój Rybnik	Over 1 500 000 283 000 246 000 165 000 149 000 107 000		∨ ∨ ∨ ∨ ∨ ∨		∨	∨
Gdańsk-Gdynia agglomeration	Over 555 000		∨			∨

In addition to the priority investment in agglomerations with more than 100 000 inhabitants indicated above, a number of needs in medium-size municipalities (important for environmental protection) have been identified. They include urgent investment activities in the field of water protection and wastewater management. These are among others investments in the following municipalities: Brzeg, Krynica Morska, Podhale Region (Nowy Targ), Suwałki, Piła, Przemyśl, Wolin, Żywiec.

Prepared at the Department for Environmental Policy and European Integration

Commission may also consider the resources coming from international financial institutions granted in the form of loans for these public instutions to be equivalent with domestic public funds.

1998 data, Central Statistical Office, Annual Book, Warsaw

According to 1997 data, GUS 1998: Environmental Protection, GUS, Warsaw

This data change dynamically and need to be periodically updated

Former voivodships: Lubelskie, Radomskie, Tarnobrzeskie, Kieleckie, Zamojskie, Siedleckie, Bialskopodlaskie and Chelmskie.

The tables are made according to preliminary guidelines of the Ministry of Finance issued in September 1999. According to the assumptions the tranches of funds assigned to ISPA 2000, ISPA 2001 etc. were divided into 3 years of investment according to the following proportions: 30% spent during the first year of investment, 30% during the second year, and 40% during the third year.

Estimated annual average support level from ISPA Fund. The European Commission and Polish side as a result of working meetings have agreed this level.

Currently, the maximum debt of a gmina cannot exceed 60% of its annual income (Law on Public Finances)

World Bank and Municipal Development Agency, Workshop on financing gmina investments, July 1998, post-conference materials

Białowieża Forest region - unique natural resources on the world's scale, high unemployment rate; Drawieński National Park - unique natural resources, high unemployment rate; Podhale region - unique for the world's scale natural resources, high tourist value; Mazowiecki and Chojnowski Lanscape Parks together with protection of Jeziorna river basin - environmental zone in vicinity of the largest municipal agglomeration in the country (green belt around Warsaw); the valley of middle and lower Bug (so-called Bug Ecological Zone) - an important element of the “Natura 2000” programme, where an association of 10 counties situated at the Bug river was created with the goal of environmental protection.

It results from the Article 90 items 3 and 4 of the Act on Protection and Management of the Environment:

3. The Minister relevant for environmental protection aspects, voivodship parliaments and poviat councils as well as gmina councils will develop the programmes for sustainable development in the area of environmental protection resulting from the national environmental policy.

4. the national, voivodship, and self-governmental lists of priority undertakings constitute a part of the programmes mentioned in item 3.”

This list should be periodically verified, depending inter alia because of the continuous interest of municipalities listed in ISPA support.

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