E1711
Ministry of Tourism and Environment, Montenegro
Public Disclosure Authorized
Ministry of Environment, Forest and Water Administration,
Albania
Public Disclosure Authorized
ENVIRONMENTAL IMPACT ASSESSMENT
OF
LAKE SKADAR/SHKODRA INTEGRATED ECOSYSTEM
MANAGEMENT PROJECT
Public Disclosure Authorized
Final Report
Public Disclosure Authorized
May 2007
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
LIST OF ABBREVIATIONS
Albania Al
APAWA
Association for Protection of the Aquatic Wildlife of Albania
BESAP Biodiversity
Strategy
and
Action
Plan
COOPI Cooperazione
Internazionale
COSPE
Cooperation for the Development of Emergent Countries
CSDC
Civil Society Development Centre
CTR
Council of Territorial Regulation
EA Environmental
Assessment
ECENA
The Environmental Compliance and Enforcement Network for Accession
EMP Environmental
Management
Plan
EU
European Union
FMO
Fishing Management Organization
GEF
Global Environment Facility
GoA
Government of Albania
GoMN
Government of Montenegro
GTZ
German Technical Cooperation
IMPEL
Implementation and Enforcement of Environmental Law
IPPC
Integrated Prevention and Pollution Control
LEAP
Local Environmental Action Plan
LG
Local Government
LSIEMP
Lake Skadar/Shkodra Integrated Ecosystem Management Project
MAFPC
Ministry of Agriculture, Food and Protection of Consumer
MEFWA
Ministry of Environment, Forests and Water Administration
MN
Montenegro
MoU
Memorandum of Understanding
MoTE
Ministry of Tourism and Environment (Montenegro)
NCW
National Council of Water
NEAP
National Environment Action Plan
NES
National Environmental Strategy
NGO Non-Governmental
Organization
NPO
Non-profit organization
NSSD
National Strategy for Sustainable Development (Montenegro)
OG
Operational goal
REA
Regional Environment Agency
REC
Regional Environmental Center
RM
Republic of Montenegro
SA
Social assessment
SAP
Strategic Action Plan
SDC
Swiss Agency for Development and Cooperation
SEA Strategic
Environmental
Assessment
SME
Small and Medium size Enterprises
TDA
Transboundary Diagnostic Analysis
TOR
Terms of Reference
UNDP
United Nations Development Program
WB
World Bank
WFD
Water Framework Directive
ii
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
iii
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
TABLES OF CONTENT
LIST OF ABBREVIATIONS..........................................................................................................................................II
EXECUTIVE SUMMARY..............................................................................................................................................V
1. INTRODUCTION.........................................................................................................................................................1
1.1 BACKGROUND...........................................................................................................................................................1
1.2 APPROACH OF THE ENVIRONMENTAL ASSESSMENT (EA) .........................................................................................2
2. POLICY, LEGAL, AND ADMINISTRATIVE FRAMEWORK (ALBANIA AND MONTENEGRO) ...............3
2.1 POLICY, LEGAL, AND ADMINISTRATIVE FRAMEWORK IN THE ENVIRONMENTAL SECTOR IN ALBANIA .......................3
2.1.1 Environmental legislation in Albania ...............................................................................................................4
2.2 POLICY, LEGAL, AND ADMINISTRATIVE FRAMEWORK IN THE ENVIRONMENTAL SECTOR IN MONTENEGRO ...............6
2.2.1 Environmental legislation in Montenegro ........................................................................................................8
2.3 COMPARISON OF WB GUIDELINES ON EA WITH EIA GUIDELINES IN ALBANIA AND MONTENEGRO .......................10
3. PROJECT DESCRIPTION .......................................................................................................................................11
3.1 SHORT PROJECT DESCRIPTION ................................................................................................................................11
4. ENVIRONMENTAL IMPACTS AND MITIGATIVE ACTIONS ........................................................................13
4.1 COMPONENT A........................................................................................................................................................13
4.2 COMPONENT B ........................................................................................................................................................13
4.3 COMPONENT C ........................................................................................................................................................14
4.3.1 Creation of well marked bicycle and hiking trails..........................................................................................14
4.3.2 Construction of bird observation platforms....................................................................................................15
4.3.3 Construction of visitor centers........................................................................................................................17
4.3.4 Establishment of an effective protected area management and zoning system...............................................19
4.4 COMPONENT D........................................................................................................................................................19
4.4.1 Removal or containment of hazardous waste at the KAP aluminum plant site ..............................................20
4.4.2 Treatment of wastewater from small lakeside villages and isolated restaurants............................................22
5.
ANALYSIS OF ALTERNATIVES ......................................................................................................................23
5.1 ALTERNATIVES TO COMPONENT A..........................................................................................................................23
5.2 ALTERNATIVES TO COMPONENT B..........................................................................................................................24
5.3 ALTERNATIVES TO COMPONENT C..........................................................................................................................24
5.4 ALTERNATIVES TO COMPONENT D..........................................................................................................................25
6.
PROCEDURES FOR ENVIRONMENTAL SCREENING OF COMPONENT INTERVENTIONS ..........25
6.1 PROCEDURES FOR ENVIRONMENTAL ASSESSMENTS ...............................................................................................26
6.2 ENVIRONMENTAL SCREENING.................................................................................................................................26
LAW ON ENVIRONMENTAL IMPACT ASSESSMENT, NO.8990, DATED 23.1.2003 ............................................27
7.
ENVIRONMENTAL MANAGEMENT PLAN AND MONITORING ............................................................28
7.1 INSTITUTIONAL STRENGTHENING............................................................................................................................29
7.1.1 Institutions in Albania ....................................................................................................................................30
7.1.2 Institutions in Montenegro..............................................................................................................................31
7.2 MANAGEMENT ARRANGEMENTS .............................................................................................................................33
7.2.1 Project Secretariat..........................................................................................................................................33
7.2.2 Project Steering Committee ............................................................................................................................34
8. REFERENCES............................................................................................................................................................35
Annex 1: Terms of Reference
Annex 2: Programme and people met
Annex 3: Environmental Management Plan
iv
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
EXECUTIVE SUMMARY
This is the Environmental Impact Assessment of the Lake Skadar/Skhodra Integrated Ecosystem
Management Project. The EA has been prepared in compliance with the World Bank EA requirements on
projects proposed for Bank financing to help ensure that they are environmentally sound and sustainable, and
thus improve decision making (OP 4.01, January 1999).
The project as such has been defined and described, and an input to the final design has been given in the
joint Strategic Action Plan for Skadar/Shkodra Lake, Albania & Montenegro, where jointly agreed activities
of each component have been described. However, the assessment of the subcomponents has not been
completed, and for this reason the EA/EMP will be a framework EA/EMP, providing procedures to follow,
when the project is ready for implementation.
The policy, legal, and administrative framework in Albania and Montenegro has been described, and proper
EIA legislation is in place in both countries. When comparing the WB guidelines with the EIA legislation of
the respective countries, only two specific differences have been identified. Projects in category "A"
according to the Bank guidelines will need two public hearings/consultations, while they only need one
according to the legislation of Albania and Montenegro. This specific requirement should be taken care of by
the respective ministries, or whom they have delegated it to, by arranging an extra hearing/consultation, if
any of the activities of the project will be categorized as Category "A". Furthermore, projects categorized as
Category "B" according to the WB guidelines do not require any public hearings according to the national
legislation in Albania and Montenegro, as they do according to the WB guidelines, where they also require
preparation of an Environmental Management Plan. Also this will have to be taken care of by the respective
ministries, or whom they have delegated it to, by preparing an EMP and arranging a hearing/consultation for
subprojects categorized as Category "B".
The overall objective of the Lake Skadar/Shkodra Integrated Ecosystem Management Project is to assist the
Governments of Albania and Montenegro in achieving more sustainable use of the natural resources of Lake
Shkodra and its watershed. The global environmental objective of the project is to reduce pollution and
conserve the lake and its biodiversity as an internationally important natural habitat, especially for water
birds. The project will achieve its objectives through three pillars: (i) establishing and strengthening national
and transboundary institutions, systems and capacity for effective ecological management; (ii) creating an
enabling environment for local and national authorities to improve environmental regulation by building
public awareness and support, and by helping local residents and businesses comply with the requirements;
and (iii) helping to eliminate or reduce some of the most urgent existing threats to the Lake's ecosystem.
The Project consists of four components, A, B, C, and D: Component A: Coordinating Lake Management.
This component will help to put in place an institutional structure for coordinating protection and
management of Lake Skadar-Shkoder and its natural resources. Component B: Monitoring and Research:
This component will support Technical Assistance, training, the purchase of equipment and incremental
operating costs (on a declining basis) needed to put in place a permanent joint monitoring system, guided by
management requirements and by the parameters outlined in the EU Water Framework Directive and the
Ramsar Convention. Component C: Protected Area and Natural Resources Management. Ensuring that
natural resources are used sustainably and limiting their ecological impact is an essential and challenging
part of PA management and is an important long term strategic goal for Lake Skader-Shkoder in both
countries. Component D: Urgent Environmental Investments . The project will provide financing to help
remediate some hotspots which are identified as high priority in the joint SAP.
Environmental impacts and mitigative actions
Component A:
Taking into account that there are no physical activities in Component A, just strengthening of legal and
institutional framework, establishment of working groups, etc. no negative environmental impacts have been
identified.
v
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Component B:
Component B will deal with monitoring and research, and no negative impacts have been identified.
As the monitoring and research activities will be designed by environmental scientists, it must be a
prerequisite that these activities will not be harmful to the environment. Monitoring stations are supposed to
be chosen with proper concern for the environment and disturbing as little as possible any nesting or
spawning sites for birds and fish. The positive environmental impact of the more systematic monitoring of
the lake is that detection of sudden higher levels of certain chemicals or detrimental effects will be
discovered, and be brought to the attention of decision-makers in the two countries at an early stage. Another
positive impact is that the scientist can report on the environmental health of the lake on a regular basis,
creating awareness of the importance of protecting its fragile ecosystem.
Component C:
Component C entails activities that could potentially be harmful to the environment. Some of the proposed
activities are classified as Category B according to the World Bank Classification system. These are the
following: 1) Creation of well-marked bicycle and hiking trails, 2) Construction of bird observation
platforms, and 3) creation of two visitor centers.
The potential Environmental impacts of making bicycle and hiking trails and their mitigating measures in
national parks and nature parks are the following:
Creation of well marked bicycle and hiking trails
Potential environmental impact
Mitigation measures
Vegetation clearance, including possible removal of trees and
Construction phase:
shrubs
Clearing the vegetative cover will be necessary in some locations. This
construction will alter some vegetation cover, but the impact is considered
minimal, if the areas have been properly investigated before forming the
trails.
Destruction of habitats for endemic plants and animals.
Construction phase:
The risk of destroying habitats is very small, but the area to be used for trails
should be properly investigated in order to avoid destroying habitats for
endemic plants and animals. The trails should be placed, where any impact is
minimized, without destroying the purpose of the trail.
Elevated noise level and disturbance of nesting birds
Construction phase:
A minor and temporary increase in noise level will occur as a result of normal
construction activities associated with trail development. Construction should
occur during non-peak visitor use or on weekdays when visitation is less, and
also take into account the nesting seasons.
Operation phase:
Once the initial trail development is over, the level of noise should be barely
noticeable as hikers disperse and use the system.
Potential problems with litter from tourists using the bicycle and
Operation phase:
hiking trails
Litter bins can be placed at regular intervals along the trails and a system
should be set up to secure emptying on a regular basis. Furthermore, park
regulations should emphasize that littering is not allowed and will be fined.
Providing easier access to prohibition zones of the lake
Operation phase:
In some cases it might be necessary to fence the prohibition zones on land, as
well as putting warning signs and mark the prohibition zones with signs.
Furthermore, the rangers should control the trails with regular intervals and
maps in the park regulations should indicate placements of prohibition zones.
Soil instability or changes in geologic substructure, disruption,
Operation phase:
displacement, erosion, compaction, moisture loss, or over-
A minor amount of soil displacement will occur due to the trail construction.
covering of soil, which would reduce productivity or fertility
Soil disturbance should be minimal and mitigated by erosion control devices
and the inclusion of switchbacks and meanders on steep slopes. The trail
could result in some compacted, less-productive soil where it is being used.
If further damage occurred during construction, that area could be reseeded
with e.g. a native grass mix.
Introduction and spread of noxious weeds
Operation phase:
The potential for the spread of noxious weeds may increase with enhanced
visitor use of the park on both sides. If not existing, there might be a need for
putting a Weed Control Plan in place. If noxious weeds exist in the proposed
trail areas, trail completion could actually assist park employees in their
control by allowing easier access into the affected areas.
Fecal contamination of surrounding areas
Operation phase:
Latrines should be constructed at suitable places along the trails and a system
for cleaning at regular intervals should be set up.
Concerning construction of well-marked bicycle and hiking trails, the following can be recommended, taking
into account the mentioned potential environmental impacts:
vi
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
The respective laws "on protected areas" in Albania and "National Parks" in Montenegro should be
followed when the bicycle and hiking trails are planned and designed. This means that prior to any
implementation, permits or licenses should be obtained from the respective authorities in the two
countries, being the Regional Environment Agency and approved by the Council for Territorial
Readjustment in Albania, and State Enterprise National Parks in Montenegro. In addition, the subproject
might be categorized as Category "B" according to the WB system, involving the preparation of an
Environmental Management Plan, and a public consultation (see Section 6). Hiking and bicycle trails are
not mentioned specifically in the Albanian and Montenegrin laws on national parks, but have to be
treated as "construction". The proposed construction of bicycle and hiking trails also has to be consistent
with PA management plans and spatial plans in Montenegro.
The potential Environmental impacts of constructing bird observation platforms in national parks and nature
parks are the following:
Construction of bird observation platforms
Potential environmental impact
Mitigation measures
Potential destruction of habitats for endemic plants and animals.
Construction phase:
The risk of destroying habitats is very small, but the area to be used for bird
observation platforms should be properly investigated in order to avoid
destroying habitats for endemic plants and animals. The placement of the
platforms should be chosen with care, minimizing the potential negative
impacts, without destroying the purpose of the observation platforms.
Elevated noise level and disturbance of nesting birds
Construction phase:
A minor and temporary increase in noise level will occur as a result of normal
construction activities associated with platform construction. Construction
should occur during non-peak visitor use or on weekdays when visitation is
less, and also take into account the nesting seasons.
Operation phase:
There will be an elevated noise level in the operation phase as well, which
makes the choice of location of the observation even more important. When
maintained, colours matching the background, without light reflecting
surfaces should be used for the construction.
Vegetation clearance, including possible removal of trees and
Construction phase:
shrubs
Clearing the vegetative cover will be necessary at the chosen locations for the
platforms. This construction will alter some vegetation cover, but the impact
is considered minimal, if the areas have been properly investigated before
constructing the platforms.
Potential problems with litter from tourists using the bird
Operation phase:
observation platforms
Litter bins should be placed at the bird observation platforms, and a system
should be set up to secure emptying on a regular basis. Furthermore, park
regulations should emphasize that littering is not allowed and will be fined.
Providing easier access to prohibition zones at the banks of the
Operation phase:
lake
In some cases it might be necessary to fence the prohibition zones on land, as
well as marking the prohibition zones with signs. Furthermore, the rangers
should control the bird observation platforms with regular intervals and maps
in the park regulations should indicate placements of prohibition zones.
Risk of contamination of soil during maintenance of platform
Operation phase:
(cleaning and painting) and leakage of impregnation substances
During maintenance of the platform, spills of the impregnating substances
from wooden building materials
should collected by plastic covers on the ground or foundation of the
platform. If made of wood, not freshly impregnated wood should be used, but
reused or reutilized wood where leakage of impregnation substances is
minimal, as some substances in impregnation are toxic to the environment.
Establishment or spread of noxious weeds
Operation phase:
The potential for the spread of noxious weeds may increase with enhanced
visitor use of the park on both sides. If not existing, there might be a need for
putting a Weed Control Plan in place. If noxious weeds exist in the proposed
placement of the platform, platform completion could actually assist park
employees in their control by allowing easier access into the affected areas.
Fecal contamination of surrounding areas
Operation phase:
Latrines could be constructed at each bird observation platform and a system
for cleaning at regular intervals should be set up.
Concerning construction of bird observation platforms, the following can be recommended, taking into
account the mentioned potential environmental impacts:
The respective laws "on protected areas" in Albania and "National Parks" in Montenegro should be
followed when the construction of bird observation platforms is planned. This means that prior to any
vii
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
implementation, permits or licenses should be obtained from the respective authorities in the two
countries, being the Regional Environmental Agency and approved by the Council for Territorial
Readjustment in Albania, and State Enterprise National Parks in Montenegro. In addition, the subproject
might be categorized as Category "B" according to the WB system, involving the preparation of an
Environmental Management Plan, and a public consultation (see Section 6). The proposed construction
of bird observation platforms also has to be consistent with PA management plans.
As mentioned, the Skadar Lake National Park in Montenegro has already four bird observation towers
and one platform constructed with assistance from GTZ, and experiences gained might be useful in
Montenegro in this context.
The potential Environmental impacts of constructing visitor centers in national parks and nature parks and
their corresponding mitigation measures are among others the following:
Construction of visitor centers
Potential environmental impact
Mitigation measures
Contamination of surroundings during construction with
Construction phase:
all types of construction waste (building materials,
A waste management plan should be prepared, covering the whole
packaging, solvents, paints, plastic, etc.)
construction phase. Waste containers with locks could be placed at
the building site for different kind of waste, and frequent inspections
should be done by the monitoring authority. A special container
should be made for hazardous waste, incl. solvents, paints, and other
toxic chemicals.
Destruction of habitats for endemic plants and animals
Construction phase:
The risk of destroying habitats is very small, but the area to be used
for visitor centers should be properly investigated in order to avoid
destroying habitats for endemic plants and animals. The placement
of the centers should be chosen with care, minimizing the potential
negative impacts. The visitor centers do not have to be placed close
to prohibition areas but should be placed near access roads, as
parking should be available for visitors.
Elevated noise levels and general disturbance, depending
Construction phase:
on site
A minor and temporary increase in noise level will occur as a result of
normal construction activities associated with center construction.
Construction should occur during non-peak visitor use or on weekdays
when visitors are fewer. Other mitigation measures are not necessary.
Operation phase:
There will be an elevated noise level in the operational phase as well,
which makes the choice of location of the visitor center important.
No mitigation measures are necessary, but it could be mentioned in
the park regulations that noisy behaviour is generally not accepted
inside the park and destroys the chances for observing wildlife at
close range.
Potential problems with litter from tourists using the
Operation phase:
visitor centers
Litter bins should be placed at the visitor center, and a system should
be set up to secure emptying on a regular basis. Furthermore, park
regulations should emphasize that littering is not allowed and will be
fined
Problems with domestic waste water from toilets at the
Operation phase:
centers, if no proper sanitation solutions have been
The visitor centers should be equipped with proper sanitation
installed, providing bad examples for local inhabitants
facilities, taking care of domestic waste water. It can either be in the
and restaurants.
form of a mini waste water treatment plant, as installed in the
existing visitor center in Skadar Lake National Park in Montenegro,
or a modern septic tank. If a septic tank solution is chosen, a system
for emptying the tank should be set up, transporting the sludge to a
proper disposal site outside the park.
Concerning construction/extension of two visitor centers, the following can be recommended, taking into
account the mentioned potential environmental impacts:
viii
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
The respective laws "on protected areas" in Albania and "National Parks" in Montenegro should be
followed when the construction of bird observation platforms is planned. This means that prior to any
implementation, permits or licenses should be obtained from the respective authorities in the two
countries, being the Regional Environment Agency and approved by the Council for Territorial
Readjustment in Albania, and State Enterprise National Parks in Montenegro. In addition, the subproject
might be categorized as Category "B" according to the WB system, involving the preparation of an
Environmental Management Plan, and a public consultation (see Section 6). Construction is mentioned
in both Albanian and Montenegrin laws on national parks. The proposed construction of visitor centers
also has to be consistent with PA management plans. The details are mentioned under the respective
descriptions of the environmental legislation in Albania and Montenegro.
As mentioned, the Skadar Lake National Park in Montenegro has already four bird observation towers
and one platform constructed with assistance from GTZ, and experiences gained might be useful in
Montenegro in this context.
Component D:
Component D entails activities that could potentially be harmful to the environment. One of the proposed
activities is classified as Category "A" according to the World Bank Classification system, namely the one
regarding clean-up at KAP. The other is classified as Category "B". The activities are the following: 1)
Removal or containment of hazardous waste at the KAP aluminium plant site, and 2) Support to wastewater
treatment facilities for small lakeside villages and isolated restaurants. Each of these activities will be
addressed below.
The potential Environmental impacts and environmental issues of removing or contain hazardous waste at
the KAP aluminum plant site are among others the following:
Remediation of hazardous waste at KAP
Potential environmental issue and impact
Mitigation measures
Determination of content and amounts of waste
Preparation phase:
Pre-investigation or technical feasibility study, determining
content and amount of waste, including options for removal and
design of hazardous waste landfill. Any placement of the landfill
will have to be consistent with the Spatial Plan for Podgorica
Municipality
Movement of hazardous waste will create dust and spread the
During the movement of the contaminated soil, modest spraying
contaminated soil to adjacent land.
with water can be done, if dust is a problem. The waste is not
considered a serious health hazard, but the proposed pre-
investigation will determine the type of mitigation necessary.
In case of movement in a season with increased precipitation,
Construction/preparation phase:
increased leakage of contaminants to groundwater and
It is proposed to do the movement in the months with lesser
subsequently to the river and from there to the lake
precipitation, e.g. during the spring and summer. If water is still a
problem, water leaking to the bottom of the excavation can be
pumped to a tanker, which should be emptied at a place, where
the water will not go to the lake
In case of capping with impermeable membrane, risk for
According to information from Montenegro, the risk for flooding
spreading to adjacent land and the river in case of flooding or
is very modest. It should be possible to avoid landslides by
landslide
proper placement of the landfill.
Contamination of groundwater resulting from leachate that can
Operation phase:
leak through the liner system.
A leachate control system should be put in place, with regular
monitoring of leachate
Consistency with the overall land-use planning in the area.
The Municipality of Podgorica should be part of the preparations
for the pre-investigation, and they should ensure that the
placement of the landfill will be consistent with the spatial plan
for Podgorica.
Landfill not large enough to accommodate the hazardous waste
Allocation of sufficient land for landfill. Depends on reliable
from KAP for a reasonable time (10 to 30 years).
production figures from KAP and whether others than KAP will
be allowed to use the landfill for hazardous waste disposal.
Based on the above mentioned potential environmental impacts, the following is recommended:
Terms of Reference for a pre-investigation should be prepared by the involved authorities in Montenegro
or the Project Secretariat, or a consultant hired by it. The outcome of the pre-investigation should be a
project document or technical feasibility study living up the requirements for project description under
ix
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
the EIA Law of Montenegro, which will be in force from January 2008, concerning documentation. Any
existing documentation concerning the hazardous waste should be collected and analyzed and if
necessary translated to English, before or during the pre-investigation, constituting a so called zero state
study. Furthermore, this technical feasibility study should live up to the requirement of the World Bank,
as their approval is equally important.
The developed project description should be used for an application of approval to the Ministry of
Tourism and Environment and follow the normal EIA procedures, and likewise be submitted to the
World Bank. Movement of hazardous waste and construction of a landfill for hazardous waste is on the
list for preparation of a mandatory EIA study according to the Law on EIA in Montenegro. An extra
hearing/consultation apart from the obligatory one according to the Montenegrin EIA Law should be
initiated by the implementing ministry or somebody whom it has been delegated to, as soon the project
description is ready in order to live up the WB requirements for Category "A" projects.
Most likely, expertise for this kind of remediation and construction of landfills for hazardous waste is not
present in the Ministry, as no landfills for hazardous waste to date has been constructed in Montenegro
or Serbia. It is therefore recommended that international expertise should be used for that part of the pre-
investigation.
If the EIA study is approved, implementation should be initiated according to the conditions given by the
Ministry of Tourism and Environment, including monitoring requirements. Furthermore, the EIA study
should be approved by the World Bank, and an Environmental Management Plan should be prepared.
The Ministry will be responsible for monitoring the implementation.
The potential environmental impacts of discharging untreated wastewater from small lakeside villages and
isolated restaurants and their respective mitigation measures are among others the following:
Treatment of wastewater from small lakeside villages and isolated restaurants
Potential environmental issue and impact
Mitigation measures
Contamination of surroundings during construction with all types
A waste management plan should be prepared, covering the whole
of construction waste (packaging, solvents, paints, plastic, etc.)
construction phase. Waste containers with locks could be placed at the
building site for different kind of waste, and frequent inspections should be
done by the monitoring authority. A special container should be made for
hazardous waste, incl. solvents, paints, and other toxic chemicals.
Contamination of the lake with domestic waste water, containing
Different solutions for treating wastewater should be considered, including
fecalia, pathogens and contaminants (e.g. detergents,
sand filters, mini wastewater treatment plants, and modern septic tanks. If
disinfectants, chlorine, etc.)
septic tank solutions are used, a system for emptying the tanks should be put
in place.
Destruction of recreational values because of odours, tainting of
First of all, and environmental awareness campaign is necessary in order to
the water at outlets, etc.
stop new construction projects on primarily the Albanian side of the lake.
Secondly, the local environmental authorities on both sides of the lake
prepare a prioritization list of possible projects, pinpointing hotspots
Health risks near outlets
The local environmental authorities on both sides of the lake should see to it
that the future monitoring programmes analyse water samples for E. coli and
coliforme bacteria in order to be able to give the public information on health
risks in the lake
Oxygen depletion because of high organic content in waste water
Oxygen content should as part of the future monitoring programmes be
measured on a regular basis
Eutrophication because of high phosphorus content of waste
As mentioned above, different solutions for treating the wastewater should be
water
considered, including sand filters, mini wastewater treatment plants, and
modern septic tanks.
Concerning construction of treatment facilities for wastewater from small lakeside villages and isolated
restaurants, the following can be recommended, taking into account the mentioned potential environmental
impacts and proposed mitigation measures:
The respective laws "on protected areas" in Albania and "National Parks" in Montenegro should be
followed when the feasibility studies for small lakeside villages and isolated restaurants are prepared and
prioritized. This means that prior to any implementation, permits or licenses should be obtained from the
respective authorities in the two countries, being the Regional Environment Agency and approved by the
Council for Territorial Readjustment in Albania, and State Enterprise National Parks in Montenegro. In
addition, the subproject might be categorized as Category "B" according to the WB system, involving
the preparation of an Environmental Management Plan, and a public consultation (see Section 6).
x
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Wastewater treatment is not mentioned specifically in the Albanian and Montenegrin laws on national
parks, but has to be treated as "construction". The proposed construction of smaller wastewater treatment
facilities also has to be consistent with PA management plans and spatial plans in Montenegro.
Terms of Reference for feasibility studies are prepared by the project secretariat, which goes through the
different options for wastewater treatment for small lakeside villages and isolated restaurants, living up
to both national legislation and EU legislation (The EU Directive concerning Urban Wastewater
(91/271/EC) and EU Water Framework Directive). Based on that, a number of subprojects with proper
documentation should be designed by the Project Secretariat or consultants recruited by it taking into
account the economic frames set, using the recommended options. Criteria for selection, including e.g.
possibilities for owners to co-finance, should be prepared.
For the selected projects, the EIA procedures for the respective countries should be followed, taking into
account the proposed mitigation measures. As the projects might have a potential for Transboundary
pollution, a common procedure based on the MoU between the two countries and following Espoo
principles should be established. As usual, the selected projects should also be assessed according to the
WB classification system, and apart from the EIA study, an EMP should be prepared, if they are
classified as belonging to category "B".
Analysis of alternatives
No alternatives were identified for Component A. The `without project' scenario would not improve
transboundary cooperation concerning protection and exploitation of natural resources of the lake, and it is
not considered a good alternative.
No alternatives were identified for Component B. The `without project' scenario will not bring any benefits,
as an overall monitoring programme will not be brought in place and it will not be possible to describe the
ecological and environmental situation of the lake properly and take actions accordingly.
There are several alternatives for Component C regarding placements of bicycle and hiking trails, bird
observation platforms and visitor centers.
It can always be discussed how massive the interventions should be, and how close to nesting sites of the
birds, the observation platforms and bicycle and hiking trails should be placed. It will probably not bring a
lot of visitors, if all observation platforms and towers are far away from the nesting sites, and only
professional ornithologist with strong binoculars will be able to see the birds. Furthermore, it can be
considered to camouflage some of the platforms colourwise, and even coat their interior with noise
dampening material and put roofs on. It is therefore suggested that some of the platforms should be relatively
near to some of the nesting sites of some of the birds, and that restrictions should be made at certain times of
the year, if negative effects are discovered. The placement of the visitor centers on the other hand, does not
have to be close to nesting birds. Rather they should be placed at the edge of the park, close to access roads,
and with parking possibilities. Here it is considered more important that the pollution resulting from the
center is minimal (that wastewater is treated, and waste collected), and that options for refreshments and
parking are available.
The `without project' alternative will not meet the objective of developing tourism, as it probably will stay at
the same level, as it is now or even lower, if the public gets the impression that the parks on either side have
nothing to offer. It will not create awareness of the value of protecting the lake and might in the long term be
negative for the development of activities around the lake.
There are several alternatives for Component D, and a few will be mentioned here. The component aims at
providing financing to help remediate some hotspots which are identified as high priority in the joint SAP.
Concerning the concrete activities proposed under Component D, they are still rudimentarily described, but it
is mentioned that the hazardous waste at KAP aluminium plant could either be contained or removed. What
will be the best solution depends on the result of the proposed pre-investigation. It is possible that by far the
cheapest solution might be to contain the waste at its location, but it might not take into consideration that
xi
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
the factory continuously needs a storage place for its hazardous waste, and a new landfill will have to be
constructed anyway.
Concerning alternatives to the proposed activities, there might e.g. be other environmental problems at KAP,
besides the hazardous waste. One of the obvious aspects to consider is the huge energy consumption, and
subsequent consumption of fossil fuels. An energy audit of the factory might possible reveal that it is
possible to reduce the energy consumption substantially. Another option is to investigate if any cleaner
technology solutions might be available, as well as looking at the content of the emissions to air through the
chimneys and the discharges to the river from the wastewater treatment plant. Another hotspot to consider is
the discharge of untreated wastewater from Shkodra directly to the lake, whenever the pumping station
pumping the the wastewater to the Boyana/Buna River due to power failure does not work. That is a serious
and very visible environmental problem for the lake that could be addessed under this component as well.
The `without project' alternative is not environmentally sound, as it will deteriorate the environmental
situation of the lake, because 1) Contaminants from KAP will continue to leak to the river and ultimately to
the lake, and 2) The small lakeside villages and already established restaurants will continue to contaminate
the lake.
Procedures for environmental screening of component interventions
The procedures to be followed during project implementation by the respective ministries, who will have the
overall responsibility for implementation of the project, have been described. The underlying principle of the
development of these procedures would be that environmental issues are best addressed when they are made
an integral part of the project cycle - in this particular case, it would be early in the project cycle for all
activities to be funded under the project.
Environmental plan and monitoring
An Environmental Management Plan (EMP) must be kept as simple as possible, clearly describing adverse
impacts and mitigation actions that are straight forward to implement. It is suggested that the following
information be included:
(a) Responsible Party: The authors who prepared the EMP along with the date of preparation.
(b) Project Description: Present a brief description of the subproject. Include the nature of the investment,
the location, and any characteristics of the area that are of particular interest (e.g. near a protected area, area
of cultural or historical interest, sensitivity of the area).
(c) Mitigation Plan: This should include a description of the steps to be taken to identify all anticipated
significant effects, to mitigate the major potential impacts on land, water, air and other media during the
planning, design, construction and operation phases.
(d) Monitoring Plan: This should include a description of the key parameters to be monitored (including
monitoring locations, schedules and responsible entities) and reporting procedures to ensure that the
construction and operation of the project is in conformance with either Albanian or Montenegrin law and
other relevant norms and standards, and conditions set by the WB. If such details are covered by permits or
construction or monitoring contracts these can be referenced as attachments.
(e) Institutional Arrangements: There should be a narrative discussion that provide a brief presentation on
how the monitoring data is going to be used for sound environmental performance - who collects the data,
who analyzes it, who prepares reports, who are the reports sent to and how often, what is done by the
responsible authorities after they receive the information; and how is non-compliance with the EMP treated.
This should also include (a) technical assistance programs, (b) procurement of equipment and supplies, and
(c) organizational changes.
(f) Implementation Schedule and Cost Estimates: For all three aspects (mitigation, monitoring, and
capacity development), the EMP provides (a) an implementation schedule for measures that must be carried
xii
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
out as part of the project, showing phasing and coordination with overall project implementation plans; and
(b) the capital and recurrent cost estimates and sources of funds for implementing the EMP. These figures
are also integrated into the total project cost tables.
(g) Consultations with affected groups and non-governmental organizations. The following should be
included: Date(s) of consultation(s); Location of consultation(s); Details on attendees (as appropriate);
Meeting Program/Schedule: What is to be presented and by whom; Summary Meeting Minutes (Comments,
Questions and Response by Presenters) Agreed actions.
The EMP for the activities under the four components potentially affecting the environment in a negative
way can be found as Annex 3. The EMP should be part of the Project Implementation Manual. If further
activities are designed, they should be addressed and added to the EMP as appropriate.
Institutional strengthening
Nature Park Administration, Shkodra.
At present, the nature park administration consists of 10 rangers. None of them have managerial experience,
and according to information obtained in Shkodra the inspection level is low, and job descriptions for their
tasks probably do not exist. A director for the park has not been appointed yet. The park administration is
supposed to be in charge of the daily operation of the park, and enforcement of the regulations for the park,
when prepared. Furthermore, it is foreseen that part of the inspection of on-going activities in the park will
be done by the park administration.
It is recommended that:
A manager is appointed as soon as possible and that regulations for the park are prepared accordingly.
The employed rangers will get training courses matching their tasks, including training in enforcement of
regulations in force in the nature park, such as actions against illegal fishery, illegal construction, illegal
disposal of waste etc. The training should be conducted in cooperation with the Regional Environment
Agency Shkodra.
Regional Environmental Agency Shkodra
The agency has an important role in issuing and monitoring permits for construction within the nature park
and screening EIA projects in the region, before submitting them to the Ministry in Tirana. Other approved
EIA projects in the region are also inspected by the REA. It is the perception that the agency is not very
visible in Shkodra, and the project could enhance this, by providing training in environmental auditing and
inspection.
It is recommended that:
The project should support training for staff of the agency in environmental auditing and inspection.
University of Shkodra
The university has got the specialists necessary for doing most of the monitoring of flora and fauna in the
lake. Concerning measurements of physico-chemical parameters, which might have to be measured quite
often, it is not considered a good idea to involve the University of Shkodra, as they because of their lectures
generally have difficulties in finding much time for such activities Anyhow, they should be part of the
working group designing the overall monitoring programme, which should be in accordance with the
preparation of surface water status for lakes in the EU Water Framework Directive (2000/60/EC, Annex V).
It is recommended that:
The University of Shkodra should be involved in the monitoring of the flora and fauna of the lake and
the design of the overall monitoring programme for the lake, in accordance with the EU Water
Framework Directive (2000/60/EC, Annex V).
University of Tirana, Faculty of Natural Sciences
xiii
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
The university should assist the University of Shkodra in some of the disciplines required for monitoring of
the freshwater invertebrate fauna of the lake, as they have a broader range of expertise and has more staff
than the corresponding faculty in Shkodra. Furthermore, the university could be involved in the
measurements of heavy metals and organic chemicals, if the monitoring programme is ready, before the
Hydrometeorological Institute has the necessary expertise.
It is recommended that:
The University of Tirana assists the University of Shkodra in monitoring the fauna of the lake, e.g. on
monitoring of freshwater invertebrates and fish
The University of Tirana assists in monitoring organic chemicals and heavy metals, if the
Hydrometeorological Institute is not having the necessary expertise in place, when the monitoring starts.
Hydrometeorological Institute of Academy of Sciences, Tirana
The Hydrometeorological Institute has been assessed to be the institution best positioned to do the
monitoring of heavy metals and organic compounds on the Albanian side of the lake. The institute is at the
time receiving support by an EU project (Strengthening of the Environmental Monitoring System
in Albania, StEMA), providing them with all necessary equipment as well as training, and they have
environmental monitoring as a core task for the institution.
It is recommended that:
The Hydrometeorological Institute should be involved in the design of the overall monitoring
programme for the lake, and they should in the future be the main institution responsible for monitoring
of heavy metals and organic compounds. Until they are ready to take up the task, technical assistance
should be given to the institute by the University of Tirana, Faculty of Natural Sciences.
It is recommended that the institute participates in intercalibration with other laboratories in the region,
as soon as they master their new equipment. Furthermore, it is recommended that they get accreditations
for analysis of heavy metals and a number of relevant organic pollutants.
Public Enterprise National Parks of Montenegro
This institution under the Ministry of Tourism an Environmental Protection is in charge of the four national
parks in Montenegro, and also the competent authority regarding environmental protection in the parks. The
management of the Skadar Lake National seems to be performing very well, and is the only national park in
Montenegro that has been able to create a financial surplus on their activities. The park administration has
the role of inspecting all on-going activities in the park, including construction activities.
Nature Protection Institute
This institute has relevant expertise regarding monitoring of flora and fauna in the Montenegrin part of the
lake. It is not under the Ministry of Tourism and Environment, but under the Ministry of Culture. It has a
very low budget for monitoring of flora and fauna in the whole of Montenegro, only around EUR 12,000 per
year. It has relevant experience from the lake and has been cooperating with University of Shkodra on the
monitoring of biota.
It is recommended that:
The Nature Protection should be participating in the process of designing the overall monitoring
programme of flora and fauna for the lake, and also be an active partner in the future monitoring, along
with staff of the Skadar Lake National Park staff.
It is recommended that the project finances the participation of the institute in the monitoring of the lake,
at least for the first two years.
Public Institution "Center for ecotoxicological research"
The center has high expertise in analysing pollutants in different media and is considered an asset for
Montenegro in environmental monitoring. The center has accreditations for several analyses and participates
xiv
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
on a regular basis in intercalibrations with other European laboratories. It has been doing analyses on
samples from the lake and has also been training other institutions in the region. Furthermore, the center is
working for KAP Aluminium Plant on a commercial basis, and has a good knowledge of the environmental
problems in the country.
It is recommended that:
The center should be involved in the design and implementation of the overall monitoring programme
for the lake of physico-chemical parameters, heavy metals, and organic chemicals.
The center is probably the only one in the region that will be able to do the pre-investigation of the
hazardous waste land fill at KAP and should be used for that purpose.
The analyses of samples to be done at KAP should be done by the center.
The staff of the center may be used as trainers for the other monitoring institutions in Montenegro
Hydrometeorological Institute
The institute has relevant expertise in environmental monitoring, but still needs more equipment for heavy
metals and organic chemicals and training in using it. The economy of the institute is very modest, and they
have only funding for monitoring the lake in the summer months of the year. The institute should be
involved in the preparation of the design of the overall monitoring programme, and should be responsible for
measurements of physico-chemical parameters. In the future they could be seen as the responsible institution
for measurements of all physico-chemical parameters.
It is recommended that:
The institute should be involved in designing the overall monitoring programme for physico-chemical
parameters for the lake, and at this point be involved in the measurements of basic physico-chemical
parameters in the Montenegrin part of the lake. In the longer term, when capacity building has been
made and proper equipment purchased, the institute might also be responsible for measurements of
heavy metals and organic chemicals.
Management arrangements
A possible management arrangement for the project is suggested, including staffing of the project secretariat,
the establishment of a project steering committee, composition and basic tasks.
xv
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
1. INTRODUCTION
1.1 Background
Lake Shkodra/Skadar is a karstic lake of Neolithic origin. It is the largest lake in Balkans with a
surface area that varies from about 370 to 540 km2. Its watershed area is estimated to about 5,490
km2, with about 80 % of this area in Montenegro and 20% in Albania. The lake is shallow, with
an average depth of about 3 meters. The Moraca River in Montenegro is the largest tributary to
the lake. Its average discharge is about 200 m3/s. Significant additional flows come from
groundwater flows and springs that discharge in the northern part of the lake. The lake drains to
the Adriatic Sea through the Boyana/Buna River. The estimated outflow is about 330 m3/s.
In an 1846 storm, the River Drini diverted its primary channel into the Boyana/Buna River a few
kilometres South to its origin in Skadar/Shkodra Lake. The massive amounts of sediment this
catastrophic change brought to the Boyana/Buna River raised the channel bed substantially and
increased the water residence time in Skadar/Shkodra Lake. The resulting increase in water level
in the lake flooded the surrounding lowlands and has maintained a higher lake level since that
time. Currently water residence time is about 120 days.
The lake is a wetland site of international importance. It has a unique and rich flora and diverse
fauna that includes numerous endemic species. It is one of the most significant wintering sites for
water birds in Europe, including many species that are globally threatened. Ninety percent of the
bird species are migratory. The lake has a diverse fish community with high productivity.
Fishing is an important source of income for the local population in both countries. The Albanian
side of Lake Shkoder/Skadar is proclaimed "Managed Natural Reserve" and is classified within
the fourth category of protection, according to the IUCN classification system. In Montenegro the
lake is proclaimed "National Park" and belongs to the second category of protection, according to
the IUCN classification system. The lake has been declared as a Ramsar site by both countries
(Ramsar Convention).
The proposed project area consists of the lake itself and immediately surrounding areas. The total
population of the project area in Albania is about 170,000, living in seven municipalities and rural
communes, within three Regions of the Shkodra District. In Montenegro, the lake and immediate
surroundings fall entirely within the Lake Skadar National Park, which includes parts of the
territories of three municipalities, with a population of about 250,000 in the watershed area. The
population living within the park itself is about 12,500 people, distributed in 17 small settlements.
The recent economic history in the project area reflects that of the two countries as a whole, with
severe economic decline during the 1990s accompanied by the collapse of many industries and
large agricultural enterprises within the watershed. While creating hardships for the population,
this has had a positive impact on the lake ecology through decreased industrial pollution. Both
governments are now seeking to revive the economic base in the area, with tourism proposed as a
major economic driver.
There is at present an important window of opportunity to put in place a strategic, coordinated
planning for the Lake Skadar-Shkodra basin. Both governments are striving to harmonize their
policies, legislation and practices with European Union instruments, such as the Water
Framework Directive which sets standards for water quality and calls for integrated watershed
management and Transboundary cooperation. A Memorandum of Understanding (MoU)
between the two Ministries of Environment was signed in 20031. The MoU calls for joint
1 Memorandum of Understanding for Cooperation in the Field of Environment Protection and Sustainable
Development Principle Between the Ministry of Environment of the Republic of Albania and the Ministry
of Environment and Physical Planning of the Republic of Montenegro
1
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
monitoring of air, water and soil quality and pollution, cooperation in environmental impact
assessment, common strategies for clean industrial and energy development, cooperation for
protection of the natural environment, creation of joint regulation for controlling international
commerce of industrial and toxic wastes, other dangerous substances and endangered flora and
fauna, joint educational and training activities, and creation of working groups and an Action Plan
for implementation of the MoU. Apart from activities as part of the preparations of this project,
no concrete measures have yet been taken to implement this MoU aside from some collaboration
between scientific institutions. The fact that both sides of the lake fall within legally protected
areas, although not with the same status in both countries, is a positive factor in that it establishes
environmental protection, sustainable natural resource use and ecotourism development as central
management objectives for the entire area. However, capacity for protection and management of
both protected areas needs to be strengthened considerably if they are to achieve these objectives.
In Albania in particular, this must be done in close coordination with the local governments,
which have significant responsibilities for environmental and natural resource management.
With respect to tourism, the Montenegro Master Plan for Tourism Development designates Lake
Skadar/Shkodra as a tourism development zone, with cultural tourism and sailing, walking and
fishing as the main potential attractions. Spatial and development plans in Albania are setting
similar objectives for the area. Such tourism could be a positive force by forging an important
linkage between nature and cultural protection and local and national economic interests.
However, the current trend of uncontrolled construction of residences, restaurants and other
facilities along the lake shore will have to be replaced by careful planning and effective
regulation of tourism development.
1.2 Approach of the Environmental Assessment (EA)
The EA will be done according to the guidelines of the World Bank (WB's Operational Policy
4.01) and will cover the topics listed in the TOR, such as policy, legal and administrative
frameworks in the two countries, project description, environmental impacts, analysis of
alternatives, options to mitigate potential environmental impacts, procedures for environmental
screening of environmental investments, the environmental management plan and monitoring.
Under the environmental management plan, mitigation of potential negative impacts, institutional
strengthening, and monitoring of project interventions will be described.
The project as such has been defined and described, and an input to the final design has been
given in the joint Strategic Action Plan for Skadar/Shkodra Lake, Albania & Montenegro, where
jointly agreed activities of each component have been described. However, the assessment of the
subcomponents has not been completed, and for this reason the EA/EMP will be a framework
EA/EMP, providing procedures to follow, when the project is ready for implementation. It is
possible though that the final version of the project description will differ slightly, depending of
the outcome of the appraisal of the project and the final agreement between the two countries and
the WB.
As part of finalizing the preparations for the project, the EA of the project was initiated in the
middle of February, and an international consultant was recruited. As part of the EA a field trip
was made to Albania and Montenegro from the 15th of February to the 1st of March 2007. During
his stay in Albania and Montenegro, the consultant consulted a number of stakeholders, in order
to get a broad view of opinions on the proposed project, but not necessarily all. In Albania, the
consultant met representatives from the Ministry of Environment, Forestry, and Water
Administration, the Municipality of Shkodra, the LSIEMP Secretariat, the Regional
2
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Environmental Center, University of Shkodra, the Regional Environmental Agency, the Shkodra
Fishery Inspection, the Faculty of Science of the University of Tirana, the Institute of
Hydrometeorology, and the EU financed project StEMA. They were all positive towards the
project and offered their cooperation. No environmental NGOs were met in Albania. In
Montenegro, the consultant met representatives from the Ministry of Tourism and Environment,
the Municipality of Podgorica, the Center for Ecotoxicological Research, the
Hydrometeorological Institute of Montenegro, the Institute for Nature Protection, the Ministry of
Agriculture, Forestry and Water Management, the Kombinat Aluminijuma Podgorica (KAP), the
National Park Skadar Lake, and four NGOs (Green Home, Greens of Montenegro, Center for the
Protection and Research of Birds, and "Nvo Godinje"). All representatives met in Montenegro
were also positive towards the project, and the NGOs mentioned that it was important that the
project would follow the new EIA legislation in Montenegro. A list of the people met can be
found as Annex 2.
2. Policy, legal, and administrative framework (Albania and
Montenegro)
This section describes the respective policy, legal, and administrative framework in the two
countries. At the end of the section it is assessed whether the Albanian and Montenegrin
legislations has legal instruments relating to EA, and to what extent they are in harmony with the
WB's EA procedures, or if gaps exists. Furthermore, Transboundary agreements and conventions
to which the two countries are signatories will be looked at.
2.1 Policy, legal, and administrative framework in the environmental sector in
Albania
The Ministry of Environment (MoE), established in 2001, is the main environmental policy-
making public institution in the country. Until recently, the Ministry of Agriculture and Food,
Forests and Waters had some responsibilities for environmental protection and biodiversity
conservation. The General Directorates of Fishery, Forest and Pastures under this Ministry were
responsible for fishing (a.o. in Lake Shkodra), national parks and protected areas. The MoE has
been given the additional responsibilities of forest and water administration sectors and is now the
Ministry of Environment, Forests and Water Administration.
Albania began in 1992 to develop a framework for addressing the environmental problems that
have arisen during decades of industrialization and neglect. The country's Constitution provides
that the republic must maintain a 'healthy and ecologically suitable environment for the present
and future generations. Natural resources are to be 'rationally exploited' consistent with 'the
sustainable development principle.'
Several positive developments have resulted from this constitutional directive. In 1993, the
Government published its first National Environmental Action Plan (NEAP). The NEAP set
Albania's environmental goals and recommended an action plan. It also identified several short-
term priorities, including:
· monitoring industrial and urban pollution, including air and water pollution;
· establishing admissible pollution standards;
3
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
· halting illegal tree cutting and investing in soil erosion prevention measures;
· assessing the environmental needs of the Albanian coastline;
· regenerating severely polluted zones; and
· implementing European level environmental mechanisms.
The Law on Environmental Protection, a key framework statute, was enacted in 1993 and
amended in 1998. It addresses the full spectrum of environmental policy issues. It also requires
the publication of a State of the Environment (SOE) Report. The first official SOE report was
published in 1995, the second in 1999.
In 1998, the Government of Albania created the National Environment Agency (NEA), which
reports directly to the Prime Minister. The NEA's mission is to develop and implement
Government environmental initiatives, set pollution limits, and coordinate policies with other
authorities responsible for environmental protection. The NEA consists of six directorates:
Directorate of Environmental Protection, Directorate of Air and Water Quality and Waste
Management, Directorate of Project Implementation, Directorate of Human Resources and
Services, Directorate of Environmental Impact Assessment, and Directorate of Law and Foreign
Cooperation. The Agency also has twelve regional offices responsible for environmental
protection, one in each prefecture and one in Tirana. The regional offices conduct inspections,
review environmental permit applications, enforce regulations, and provide limited technical
assistance.
The updated National Environment Action Plan (NEAP) of 2002 updated the environmental
policies of the country. The NEAP was approved by the Council of Ministers January 2002 and
published in the official gazette no. 3/1 of February 2002. This updated plan envisages measures
to be taken for the protection of different environmental media, and normative acts to be
approved. In 2003 an intersectorial committee was established for the implementation of the
NEAP. This committee is chaired by the Prime Minister, and comprises 12 members, at the level
of minister or deputy-minister, of the concerned ministries.
Several other Government entities have significant environmental policy roles: the Ministry of
Agriculture and Food, Ministry of Transport, Ministry of Public Economy and Privatization,
Ministry of Public Works, Ministry of Health, National Council on Water, Public Health Institute,
Hydrometeorological Institute, Council on Territorial Adjustment and the Institute of Soils. Much
greater cooperation and coordination is needed among these organizations in order to make the
most efficient use of available resources, increase environmental awareness within Government,
and improve environmental management efforts. Environment is still not a real priority, and
environmental principles and concerns largely fail to be integrated into other sectoral policies in
Albania.
The NGOs in Albania are getting momentum at the time being and are e.g. stakeholders in the
EIA process, where they according the Law on EIA should be invited to the public debate. There
are several in the area around Skadar/Shkodra Lake, as mentioned in the publication by REC
Albania
2.1.1 Environmental legislation in Albania
Albania has made efforts during the last years in preparing a comprehensive legislative
framework. The laws regarding environmental protection take into consideration requirements of
international conventions and treaties and cover a whole range of protective measures. However,
the challenge is not so much in the legislation, which seems to be in place, but in its
4
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
implementation and enforcement. This is due to insufficient work in producing by-laws
(regulations, decisions and other normative acts), inadequate and poorly qualified and equipped
local environmental structures and inspections (Regional Environmental Agencies), low
environmental awareness and performance of public administration, general public and decision
makers.
Activities to be carried out under the Montenegro/Albania Lake Shkodra/Skadar Integrated
Ecosystem Management Project and the implementation of the Environmental Management Plan
will have to conform to current laws in Albania and will be in compliance with relevant
environmental laws, including the following:
· Law on "the Land" (1991)
· Law "On Seeds and Seedlings" (1992)
· Law on "Forestry and Forestry Police" (1992)
· Law on "The Service and Plants' Protection" (1993)
· Law on "Protection of Natural Medical, Ether Oil and Tanifer Plants" (1993)
· Law on "Environmental Protection" (1993, amended in 1998 and 2002)
· Law on "Wildlife Protection and Hunting" (1994)
· Law on "Protection of Horticulture Trees" (1995)
· Law on "Fishing and Aquatic Life" (1995)
· Law on "Pastures and Meadows" (1995)
· Law on "The Regulatory Framework of the Water Supply Sector and of Disposal and
Treatment of Waste Water" (1996)
· Law on "Water Resources" (1996, amended in 1998 and 2000)
· Law on "Protection of Transboundary Lakes" (2003)
· Law on "Protected Areas" (2002)
· Law on "Environmental Impact Assessment" (2003)
The Law on Environmental Protection (1993, amended in 1998 and 2002) forms the basis for
environmental management in Albania. The law addresses the prevention and reduction of
pollution, sustainable management of natural resources, monitoring, how to define pollution
levels. It provides binding provisions for environmental impact assessment and the
implementation of the polluter pays principle.
The Law on Protected areas was approved in June 2002. The purpose of the law is the
declaration, preservation, administrations, management and usage of protected areas and their
natural and biological resources, and regulating conditions for the development of environmental
tourism, information and education of the general public and for economic activities by the local
population, by the state or the private sector. The law regulates the protection of six (6) categories
of protected areas, applied in the territory of the Republic of Albania. The categorization of areas,
status and level of protection for each area is based on the criteria of IUCN. Lake Shkodra is in
the category IV, according to the classification, and e. g. construction is allowed, if a permit is
given by the competent authority, which in this case is the Regional Environmental Agency.
Furthermore, any construction in national parks will have to be approved by the National and
Regional Council for Territorial Readjustment, which is in charge of issuing a construction
ground permit. If a management plan exists for the protected area, any permits given will have to
comply with it. No management plan has been made for the Albanian side of the lake yet.
5
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
The Law on Environmental Impact Assessment was approved in January, 2003. This law defines
the rules and procedures for identifying and assessing the direct and indirect impacts of projects
and activities on the environment. The law establishes provisions for all of the steps necessary to
implement EIA procedures: Presentation of the application, preliminary review, selection and
classification criteria, public consultations, access to information, and duties and rights of other
bodies. The law provides a list of activities that should be subject to an extended EIA process,
such as oil and gas refinery plants, thermal power stations, smelters, exploration of oil and
minerals, incinerators, with a certain capacity, etc. The other list of activities includes e. g.
agricultural projects, forestry projects, aquaculture, quarries, food industries, and other activities
not included in the first list. Activities listed in this annex are subject to a shortened EIA
procedure. The law seems to be close to the EU Directive on the assessment of the effects of
certain public and private projects on the environment (85/337/EC with amendments), and
contains also provisions regarding the application of Strategic Environmental Assessment, and
application of licensed specialist for preparing the EIA report. The law on EIA is considered to be
a state of the art EIA law with similar requirements regarding project description, public
consultations, etc. as in the mentioned EU Directive.
The law on Protection of Transboundary Lakes was approved in July 2003. The law aims at
protecting transboundary lakes, by guaranteeing the appropriate conditions for the development
of life and ecosystems in these lakes, and stopping activities that threaten them. The scope of the
law is to protect the transbounday waters and the watersheds of the Albanian part of Shkodra
Lake, the Albanian part of Ohrid Lake, and the Albanian part of the Prespa Lakes.
Albania is furthermore a signatory to the Espoo Convention since 1991. The convention stipulates
the obligations of Parties to assess the environmental impact of certain activities at an early stage
of planning. It also lays down the general obligation of States to notify and consult each other on
all major projects under consideration that are likely to have a significant adverse environmental
impact across boundaries.
Albania is also a signatory to the Ramsar Convention, and the Albanian part of Skadar/Shkodra
Lake and Bojana/Buna River wetland complex have since 2005 been approved as a Ramsar site
(included in the list of internationally important wetlands, especially as a waterfowl habitat).
2.2 Policy, legal, and administrative framework in the environmental sector in
Montenegro
The major competence regarding environmental policy in the Republic of Montenegro is within
the Ministry of Tourism and Environment, which is the body responsible for most activities
concerning environmental protection. The Ministry currently has 81 employees, divided into 3
sectors: Sector for environmental protection; Sector for tourism; Sector for legal and inspection
affairs. Furthermore, there are two units, responsible for European Integration and Financial
matters. The Ministry has oversight over the following institutions within the environmental area:
Hydrometeorological Institute, Public Enterprise "National Parks of Montenegro", and Centre for
Ecotoxicological Research of Montenegro.
In 1991 the Parliament of the Republic of Montenegro adopted the "Declaration on the Ecological
State of Montenegro", a commitment which is repeated in Article 1 of the Constitution of 1992:
"Montenegro is a democratic, social and ecological state".
6
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Montenegro is moving fast towards European integration and has initiated activities required for
the process of stabilisation and association to the EU. The former Ministry of Environmental
Protection and Spatial Planning (today Ministry of Tourism and Environment) participated in the
preparation of various documents required for establishing the EU partnership, such as realization
of the Action plan for Implementation of European Partnership Recommendations, participation
in the Permanent Enhanced Dialogue Meetings, and preparation of quarterly and annual progress
reports.
After the Johannesburg Summit in 2002, the National Council for Sustainable Development has
been founded. It is headed by the Prime minister, and consists of representatives from different
Ministries, business sector and NGOs. Its role of the Council is the preparation and
implementation of the National Strategy for Sustainable Development (NSSD) and tasks defined
in the document "The Developmental Directions of Montenegro as an Ecological State", as well
as reviewing of strategic documents on development policy, investment programs, support to
public participation, and establishment of international cooperation. For purposes of
implementing concrete activities, the Office for Sustainable Development was opened in 2005.
Presently, the Environmental Protection Agency (EPA) of Montenegro is in the process of
establishment, and it is expected to become operational during 2007.
The EPA mandate will include:
· Environmental permitting and EIA, SEA and IPPC procedures;
· Inspection and enforcement of activities under environmental legislation;
· Collecting and processing environmental monitoring data delivered by
authorized institutions, establishing environmental databases, and
organizing dissemination of information and public access to it;
· Reporting related to the EU environmental acquis, national requirements in
environmental law, and environmental agreements; and
· Publishing State of Environment reports after governmental approval and
communicating all relevant environmental information to interested
stakeholders, including relevant international organizations.
Furthermore, it will include communication activities, like raising public awareness, maintenance
of stakeholder networks (like IMPEL and ECENA), and cooperation with the European
Environment Agency in Copenhagen. In addition, establishment of the Agency will mean a strict
division between the policy-making and legislative tasks that will be the responsibility of the
Ministry, and the executive tasks that will be the responsibility of the Agency.
In the past period, the Montenegrin Government has endorsed several important strategic
documents that define its future development in a sustainable manner. The then Ministry of
Environmental Protection and Spatial Planning initiated the preparation of the NSSD. This is one
of the most important strategic documents of Montenegro, as it allows compliance with and
enforcement of the UN and EU directives and strategies, such as the Millennium Development
Goals, Agenda 21, Johannesburg Plan of Implementation, Mediterranean strategy for Sustainable
Development and European Strategy for Sustainable Development. NSSD includes an action plan
that defines priority activities, measures for their implementation, timeframe and implementing
bodies/partners.
The former Ministry also prepared and adopted a national policy for waste management and
strategic documents for waste water management: Master Plan for Water Supply for Coastal
Regions of Montenegro and Cetinje, Wastewater Feasibility Study Coastal Region, Strategic
7
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Master Plan for Sewage and Waste Waters for Central and North Regions, as well as the Strategic
Master Plan for Waste Management on the Republic Level. Capacity strengthening of the local
public utility companies is ongoing, and activities have been undertaken for the construction of
regional sanitary landfills and recycling stations, and the sanitation of the water supply, sewage,
and water treatment systems in several towns.
Environmental issues have been increasingly incorporated into the developmental policies of
sectors other than the environmental. E.g. the Strategy of energy efficiency (2005-2006) defines
activities that relevant institutions have to undertake in order to create a system of efficient
energy use through promotion of renewable energy sources, minimization of environmental
impacts, and promotion of energy saving schemes.
Finally, in the past few years, the capacities of the NGO sector have been increased, so the public
involvement in environmental issues has risen. Through various activities and campaigns, such as
the one for protection of Tara River against the construction of a hydropower plant, the NGO
sector established itself as an important environmental stakeholder. Consequently, it has been
included in the preparation of many strategic documents, including the NSSD.
2.2.1 Environmental legislation in Montenegro
As stated above, one of the main priorities of the Republic of Montenegro is European
integrations, so it has started the process of harmonising the national legislative with that of the
EU. During 2005, the Montenegrin Assembly has adopted five legal acts: Law on Environmental
Impact Assessment (EIA), Law on Strategic Environmental Assessment (SEA), Law on
Integrated Pollution Prevention Control (IPPC), Law on Waste Management, and Law on
Environmental Noise, which are harmonized with the relevant EU directives, including those
regarding public access to environmental information, public participation in decision-making
and access to justice. In 2007 it is planned to adopt the Law on Air Quality, the Law on
Establishment of the Environmental Fund, the Law on Protection from Ionizing Radiation and
Radiation Safety, and to do the revision of the Law on Environment.
Activities to be carried out in Montenegro under the Montenegro/Albania Lake Skadar/Shkodra
Integrated Ecosystem Management Project and the implementation of the Environmental
Management Plan will have to conform to current laws in Montenegro and will be in compliance
with relevant environmental laws, including the following:
· Law on National Parks (Official Gazette of the RM, No.47/91, 27/94)
· Environmental Law (Official Gazette of the RM, No. 12/96, 55/00)
· Environmental Impact Assessment Decree (Official Gazette of the RM, No. 14/97)
· Law on Nature Protection (Official Gazette of the RM, No. 36/77,2/89)
· Decree on Protection of Rare, Scarce, Endemic and Endangered Plant and Animal
Species (Official Gazette of the RM, No.36/82)
· Law on Freshwater Fishery, (Official Gazette of the RM, No.
39/76,51/76,34/88,29/89,39/89,48/91, 4/92, 17/92, 27/94)
· Law on Waters (Official Gazette of the RM, No. 16/95)
· Decree to Prohibit the Use of Vessels with Engine Power more than 4.5 KS by Physical
Persons On Skadar Lake (Official Gazette of the RM, No.9/86)
· Decision on the Level and the Method of Payment of Charges for the Use of National
Parks Assets, for Conducting Economic Activities and Providing Services (Official
Gazette of the RM, No.31/02)
· Law on the Protection of Cultural Monuments (Official Gazette of the RM, No.47/91)
8
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
· Law on Agricultural Land (Official Gazette of the RM, No.27/94)
· Law on Construction (Official Gazette of the RM, No.55/00)
· Law on Local Self-Government (Official Gazette of the RM, No.75/05)
· Law on Inspection (Official Gazette RCG, No.50/92).
Furthermore, the following laws will be in force from January 2008:
· Law on Environmental Impact Assessment (Official Gazette of the RM, No. 80/05)
· Law on Strategic Impact Assessment (Official Gazette of the RM, No.80/05)
· Law on Integrated Prevention and Pollution Control (Official Gazette of the RM,
No.80/05).
The Law on National Parks was passed for the first time in 1991 and amended in 1994. The law
defines the borders and the level of protection and allowed development measures, exploitation of
resources and how the national parks should be managed. There are four national parks in
Montenegro, being Bogradska Gora, Durmitor, Lovcen, and Skadar Lake. A spatial plan has been
developed for the lake, defining status, development directions, borders, exploitation regime,
environmental measures, and requirements regarding construction in the parks. The Public
Enterprise "National Park" is in charge of preparation and implementation of the spatial plans for
the parks. Construction of tourist and health facilities and infrastructure is allowed in the national
parks, if prior approval has been given by Public Enterprise "National Park", and they are
consistent with the spatial plan. Normally, construction licenses in Montenegro are issued by
Ministry of Finance.
The Environment Law was passed by the Montenegrin Parliament in 1996. The Law describes
the objectives and sets up the basic principles of environmental protection in Montenegro. In
short, the principles are the following: 1) Conservation of natural resources, 2) Preservation of
biological diversity, 3) Reduction of environmental risks, 4) Environmental Impact Assessment,
5) Alternative solutions, 6) Substitution of chemicals, 7) Re-use and re-cycling, 8) Polluter pays,
9) User/consumer pays, 10) Mandatory pollution insurance, 11) Public access and involvement,
and 12) Public information on the state of the environment. The Law also sets up the general
guidelines for environmental protection measures, monitoring, an environmental information
system, liability of environmental pollution, environmental financing, the rights of non-
governmental organisations, supervision of the law and the derived regulations, and describes
penalties.
The first law on Environmental Impact Assessment was approved in 1997, but was revised in
August 2005. Until the law comes into force by January 2008, the first law is still valid. The new
law describes all the procedures necessary for preparing an EIA report, and also mentions that the
study should be elaborated by legal persons or entrepreneurs inscribed in the appropriate registers
for execution of planning and engineering activities and elaboration of studies and analyses. The
law describes the type of projects subject to EIA as being projects that may have significant
impact on the environment or human health, and projects in the field of industry, mining, energy
production, transport, tourism, agriculture, forestry, water management and utilities, The law
takes into account the EU Directive on the assessment of the effects of certain public and private
projects on the environment (85/337/EC with amendments), and even uses the same definitions as
the EU Directive. The GoMN has also approved the annexes describing lists of projects, for
which the impact assessment is mandatory, and lists of projects for which the impact assessment
may be required, in line with the EU Directive. Other regulations under this law are supposed to
be finalized during 2007. All in all, the law is considered to be state of the art EIA legislation, and
9
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
basically a transposition of the mentioned EU Directive into national legislation, even though it
on certain aspects is considered more stringent.
Montenegro is not a signatory to the Espoo Convention, and the status in this regard is not
known. However, the issue is catered for, as Art. 30 of the EIA Law has provisions for providing
all relevant information to other states whose environment could be significantly threatened by
the planned project in advance, as well as any decisions taken on it. Objections raised by the other
states have according to the law to be taken into account, when decisions are taken.
Montenegro is not a signatory to the Ramsar Convention, but the State Union was, and in 1995
the Skadar Lake National Park was included in the Ramsar list (wetland area of international
significance) as a lake in the State Union. However, Montenegro is at the time being in the
process of re-ratification and is expected to be a signatory soon.
2.3 Comparison of WB guidelines on EA with EIA guidelines in Albania and
Montenegro
Above the EIA legislation in Albania and Montenegro has been examined. In order to make a
comparison it is considered relevant to mention a minimum of the bank's operational policy
regarding EA.
The World Bank has developed a number of Safeguard Operational Policies to ensure that all
possible negative impacts are considered and mitigation measures are spelled out prior to the
implementation of any proposed project. These policies ensure that the quality of operations is
uniform across different settings worldwide. If the decision is taken that a Safeguard Policy
should be applied, mitigation measures and plans must be developed and in place before the
implementation of a proposed project. In this section the description of the system of the bank is
very short. A longer description can be found in Chapter 6 regarding procedures for
environmental screening of project interventions.
An EA according to the Bank's Operational Policy 4.01 evaluates a project's potential
environmental risks and impacts in its area of influence, examines project alternatives, identifies
ways of improving project selection, planning, design, and implementation by preventing,
minimizing, mitigating, or compensating for adverse environmental impacts and enhancing
positive impacts, and includes the process of mitigating and managing adverse environmental
impacts throughout project (or subproject) implementation. During project implementation, the
following need to be reported to the Bank:
a) Compliance with measures agreed with the Bank on the basis of the findings and results
of the EA, including implementation of the Environmental Management Plan (EMP), as
set out in the project documents,
b) The status of mitigatory measures, and
c) The findings of monitoring programmes.
When comparing the WB guidelines with the EIA legislation of the respective countries, only two
specific differences have been identified. Projects in category "B" according to the Bank
guidelines do not require any environmental actions by the national regulations (i.e. biking paths
under Component C) in Albania and Montenegro, but by the banks procedure it will require
preparation of an EMP and a public hearing. Projects in category "A" according to the Bank
guidelines will need two public hearings/consultations, while they only need one according to the
10
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
legislation of Albania and Montenegro. This specific requirement should be taken care of by the
respective ministries, or whom they have delegated it to, implementing the project, by arranging
an extra hearing/consultation, if any of the activities of the project will be categorized as Category
"A". Similarly, activities categorized as category "B", will need the preparation of an EMP and a
public hearing, if they should be financed under this project. The activity under Component D
regarding the clean-up of hazardous waste at the KAP Aluminium Plant has been classified as a
Category "A" activity, and the Ministry of Tourism and Environment in Montenegro will then
have the responsibility of arranging and extra hearing. The timing of these consultations is
proposed in Chapter 6. Apart from that, no major differences have been observed. The EIA
legislation in both countries is built upon the EU legislation on EIA, which is considered an
advantage because of the ambitions of both countries to be future members of the EU.
3. project description
This section will briefly present the project outline and its components. Furthermore, the strategic
goals for each component agreed in the process of finalizing the Joint Strategic Action Plan
prepared by Albania and Montenegro with their corresponding operational objectives and
program targets will to some extent be considered.
3.1 Short Project Description
The overall objective of the Lake Shkoder Integrated Ecosystem Management Project is to assist
the Governments of Albania and Montenegro in achieving more sustainable use of the natural
resources of Lake Shkodra and its watershed. The global environmental objective of the project is
to reduce pollution and conserve the lake and its biodiversity as an internationally important
natural habitat, especially for water birds. Because of the complex nature of the lake's problems,
the project pursues an integrated approach to land and water issues, by promoting cross-sectoral
cooperation throughout the watershed. The project will achieve its objectives by implementing
priority measures as identified in the Lake Skadar/Shkodra Joint Strategic Action Plan prepared
jointly by both countries.
The project will achieve its objectives through three pillars: (i) establishing and strengthening
national and transboundary institutions, systems and capacity for effective ecological
management; (ii) creating an enabling environment for local and national authorities to improve
environmental regulation by building public awareness and support, and by helping local
residents and businesses comply with the requirements; and (iii) helping to eliminate or reduce
some of the most urgent existing threats to the Lake's ecosystem. The project includes both joint
activities and "unilateral" activities
The Project consists of four components:
Component A. Coordinating Lake Management. This component will help to put in place an
institutional structure for coordinating protection and management of Lake Skadar-Shkoder and
its natural resources. The establishment of a transboundary River Basin Authority as called for
by the EU Water Framework Directive is likely to take years, and a phased approach should be
used. The project will support the creation of several bilateral Working Groups to coordinate
implementation of key actions called for in the 2003 Memorandum of Understanding and the
joint Strategic Action Plan. Working Groups will be set up for: (i) design and establishment of a
11
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
permanent transboundary institutional structure (including harmonization of policies, procedures
and legislation as required); (ii) development of a lake-wide zoning and management plan
(complimentary to the individual management plans which are legally required for both of the
Protected Areas); (iii) designing and launching a lake-wide ecological monitoring program; (iii)
developing and launching a public awareness-raising and education program; and (iv) preparing
a coordinated strategy and plan to promote sustainable tourism development.
Component B. Monitoring and Research: This component will support Technical Assistance,
training, the purchase of equipment and incremental operating costs (on a declining basis) needed
to put in place a permanent joint monitoring system, guided by management requirements and by
the parameters outlined in the EU Water Framework Directive and the Ramsar Convention.
Monitoring for specific purposes such as Avian Flu prevention and detailed ornithological
surveys will also be included. The types and amounts of support provided will differ somewhat
between the two countries, based on their existing capacity. An important part of the monitoring
program will be establishing a common data base and networks for information exchange. The
monitoring program and protocols will be designed and overseen by a transboundary Working
Group, supported by the Secretariat, and implemented on the ground by the appropriate national
institutions. The project will also finance a limited amount of "on-demand" research relating to
specific management issues identified through the monitoring program, such as seeking the
causes for declines of particular species or testing different approaches to habitat restoration. In
the first year, the targeted research program will include a detailed socio-economic study and
stakeholder consultations associated with developing a Process Framework relating to possible
increased restrictions on fishing. The research will be contracted to capable research institutions
by the Secretariat on behalf of the Working Group, through a competitive process.
Component C. Protected Area and Natural Resources Management. Ensuring that natural
resources are used sustainably and limiting their ecological impact is an essential and challenging
part of PA management and is an important long term strategic goal for Lake Skader-Shkoder in
both countries. The project will support development of sustainable tourism by helping to create
an attractive and ecologically appropriate environment for nature-based tourism such as well-
marked bicycle and hiking trails, bird observation platforms, informational signs and materials,
restoration of cultural heritage sites and creation of two visitor centers (preferably through
rehabilitation of existing historic buildings). Other types of local economic development will be
supported through partnership initiatives of the PA administrations such as providing technical
assistance for organic agriculture and development of locally branded "Lake Skadar" specialty
food products and handicrafts based on environmentally friendly and sustainable resource use.
The project will support Technical Assistance, training, equipment and materials, and some
incremental operating costs to strengthen the capacity of the PA Administrations and enable them
to practice effective, integrated management of the PAs and their natural resources. This
management will be carried out in coordination with one another (Transboundary) and in
cooperation with local governments and communities and other stakeholders. Specific activities
will include: TA for assessment and revision of policies and regulations (Albania); the
development of zoning and management plans for the PAs (to be incorporated into lake-wide
zoning and management plans) and demarcation of zones; communications and other equipment
to enhance management effectiveness on the ground; small scale infrastructure for PA
management and tourism (including small visitor centers); and TA and incremental operating
costs to establish and improve programs in areas such as tourism promotion/marketing,
community outreach and livelihoods support activities, and education.
Component D. Urgent Environmental Investments . The project will provide financing to help
remediate some hotspots which are identified as high priority in the joint SAP. GEF funding will
12
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
either form part of a larger financing package (e.g. to remove or contain hazardous waste at the
KAP aluminum plant site) or compliment, extend and broaden the benefits of activities being
funded by others (e.g. wastewater treatment facilities for small lakeside villages and isolated
restaurants, complimenting large projects to improve wastewater treatment for large cities and
towns. In addition to addressing existing problems, the project will finance a pilot program to
promote low input/organic agriculture in surrounding areas, as a means of preventing a
resurgence of agrochemical inputs to the lake.
4. Environmental Impacts and mitigative actions
In this section the different components will be assessed for their potential environmental
impacts, taking into account that the project has not been finally designed yet.
4.1 Component A
Taking into account that there are no physical activities in Component A, just strengthening of
legal and institutional framework, establishment of working groups, etc. no negative
environmental impacts have been identified.
4.2 Component B
Component B will deal with monitoring and research, and no negative impacts have been
identified.
Basically, boats that can be used all year round are needed, and equipment for taking samples at
various predetermined locations in the lake. The equipment for taking water samples to be
analyzed for basic physical-chemical parameters may be quite simple and consisting of different
kinds of glassware, but can also be more sophisticated and automated monitoring units, with
built-in transmitting equipment, taking samples and analyzing it automatically and transmitting
results to the responsible laboratory. Equipment for flora and fauna can be different types of nets,
and for benthos (bottom- and sediment living animals), different types of sediment core-samplers
may be used. For water samples to be analyzed for heavy metals and organic chemicals there are
different methods, and the kind of glassware and lids are usually more expensive, as e.g. organic
chemicals in the water samples might adhere to lids, if there are made of silicone in stead of
Teflon, giving dubious analysis results. Furthermore, stainless steel equipment is preferred for
other types of sampling, and thermal boxes are needed for storing the samples on their way back
to the laboratory.
As the monitoring and research activities will be designed by environmental scientists, it must be
a prerequisite that these activities will not be harmful to the environment. Monitoring stations are
supposed to be chosen with proper concern for the environment and disturbing as little as possible
any nesting or spawning sites for birds and fish. The positive environmental impact of the more
systematic monitoring of the lake is that detection of sudden higher levels of certain chemicals or
detrimental effects will be discovered, and be brought to the attention of decision-makers in the
two countries at an early stage. Another positive impact is that the scientist can report on the
13
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
environmental health of the lake on a regular basis, creating awareness of the importance of
protecting its fragile ecosystem.
4.3 Component C
Component C entails activities that could potentially be harmful to the environment. Some of the
proposed activities are classified as Category B according to the World Bank Classification
system. These are the following: 1) Creation of well-marked bicycle and hiking trails, 2)
Construction of bird observation platforms, and 3) creation of two visitor centers. Each of these
activities will be addressed below.
4.3.1 Creation of well marked bicycle and hiking trails
Most national parks have procedures in place for creating bicycle and hiking trails taking into
account the possible environmental impacts, and disturbing the environment as little as possible.
In Skadar Lake National Park in Montenegro, some walking paths have been created with support
from GTZ, and the experience gained in creating the walking paths may be useful in this context.
In Albania similar steps might have been taken in other national parks, but no information was
obtained from the Albanian authorities.
In Albania, the law "on protected areas" is relevant, and it gives the authority to the Regional
Environment Agency to issue permits for construction activities, which afterwards will have to be
approved the Council for Territory Adjustment. In Montenegro it is the "Law on National Parks",
giving the authority to issue a permit to State Enterprise National Parks. This means that prior to
any implementation, permits or licenses should be obtained from the respective authorities in the
two countries, as well as from the World Bank.
The potential Environmental impacts of making bicycle and hiking trails and their mitigating
measures in national parks and nature parks are the following:
Creation of well marked bicycle and hiking trails
Potential environmental impact
Mitigation measures
Vegetation clearance, including possible removal of trees and
Construction phase:
shrubs
Clearing the vegetative cover will be necessary in some
locations. This construction will alter some vegetation cover, but
the impact is considered minimal, if the areas have been properly
investigated before forming the trails.
Destruction of habitats for endemic plants and animals.
Construction phase:
The risk of destroying habitats is very small, but the area to be
used for trails should be properly investigated in order to avoid
destroying habitats for endemic plants and animals. The trails
should be placed, where any impact is minimized, without
destroying the purpose of the trail.
Elevated noise level and disturbance of nesting birds
Construction phase:
A minor and temporary increase in noise level will occur as a result
of normal construction activities associated with trail development.
Construction should occur during non-peak visitor use or on
weekdays when visitation is less, and also take into account the
nesting seasons.
Operation phase:
Once the initial trail development is over, the level of noise should
be barely noticeable as hikers disperse and use the system.
Potential problems with litter from tourists using the bicycle and
Operation phase:
hiking trails
Litter bins can be placed at regular intervals along the trails and a
system should be set up to secure emptying on a regular basis.
Furthermore, park regulations should emphasize that littering is
not allowed and will be fined.
14
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Providing easier access to prohibition zones of the lake
Operation phase:
In some cases it might be necessary to fence the prohibition
zones on land, as well as putting warning signs and mark the
prohibition zones with signs. Furthermore, the rangers should
control the trails with regular intervals and maps in the park
regulations should indicate placements of prohibition zones.
Soil instability or changes in geologic substructure, disruption,
Operation phase:
displacement, erosion, compaction, moisture loss, or over-
A minor amount of soil displacement will occur due to the trail
covering of soil, which would reduce productivity or fertility
construction. Soil disturbance should be minimal and mitigated
by erosion control devices and the inclusion of switchbacks and
meanders on steep slopes. The trail could result in some
compacted, less-productive soil where it is being used. If further
damage occurred during construction, that area could be reseeded
with e.g. a native grass mix.
Introduction and spread of noxious weeds
Operation phase:
The potential for the spread of noxious weeds may increase with
enhanced visitor use of the park on both sides. If not existing,
there might be a need for putting a Weed Control Plan in place. If
noxious weeds exist in the proposed trail areas, trail completion
could actually assist park employees in their control by allowing
easier access into the affected areas.
Fecal contamination of surrounding areas
Operation phase:
Latrines should be constructed at suitable places along the trails
and a system for cleaning at regular intervals should be set up.
These potential impacts and their mitigation measures should be addressed by the competent
authorities in the two countries, when giving their permit. At this point, the information regarding
these "subprojects" will be have to be improved, before the permit can be given, including
planned location, equipment for doing clearance of vegetation, materials to used for "path
coating", maintenance, duration of work etc.
Concerning construction of well-marked bicycle and hiking trails, the following can be
recommended, taking into account the mentioned potential environmental impacts:
The respective laws "on protected areas" in Albania and "National Parks" in Montenegro
should be followed when the bicycle and hiking trails are planned and designed. This means
that prior to any implementation, permits or licenses should be obtained from the respective
authorities in the two countries, being the Regional Environment Agency and approved by
the Council for Territorial Readjustment in Albania, and State Enterprise National Parks in
Montenegro. In addition, the subproject might be categorized as Category "B" according to
the WB system, involving the preparation of an Environmental Management Plan, and a
public consultation (see Section 6). Hiking and bicycle trails are not mentioned specifically in
the Albanian and Montenegrin laws on national parks, but have to be treated as
"construction". The proposed construction of bicycle and hiking trails also has to be
consistent with PA management plans and spatial plans in Montenegro.
If camping sites should be constructed in connection with the hiking trails, permits or licenses
should be obtained from the respective authorities in the two countries, being Regional
Environment Agency and the Council for Territorial Adjustment in Albania, and State
Enterprise National Parks in Montenegro. It could furthermore be considered to let any
camping site live up to the EU criteria for eco-labelling of campsite service (2005/338/EC).
Furthermore, at mentioned above the camping sites should be assessed according
to the WB classification system and be subject to the relevant procedures.
4.3.2 Construction of bird observation platforms
Many national parks have procedures in place for construction of bird observation platforms
taking into account the possible environmental impacts, and disturbing the environment as little
15
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
as possible. In Skadar Lake National Park in Montenegro, four observation towers and one
observation platforms have been constructed with support from GTZ, and the experience gained
in constructing the platform and the four observation towers may be useful in this context.
In Albania similar things might have been done in other national parks, but no information was
obtained in this regard from the Albanian authorities.
In Albania, the law "on protected areas" is the one regulating this issue, and it gives the authority
to the Regional Environment Agency to issue permits for such activities, which also has to be
approved by the Council for Territorial Readjustment. In Montenegro it is the "Law on National
Parks" regulating this issue, giving the authority to issue a permit to the State Enterprise National
Parks.
This means that prior to any implementation, permits or licenses should be obtained from the
respective authorities in the two countries. Furthermore, the activities have to be subject to WB
guidelines concerning this, and procedures by the WB will have to be followed as well, if
financing will be provided by this project.
The potential Environmental impacts of constructing bird observation platforms in national parks
and nature parks are the following:
Construction of bird observation platforms
Potential environmental impact
Mitigation measures
Potential destruction of habitats for endemic plants and animals.
Construction phase:
The risk of destroying habitats is very small, but the area to be
used for bird observation platforms should be properly
investigated in order to avoid destroying habitats for endemic
plants and animals. The placement of the platforms should be
chosen with care, minimizing the potential negative impacts,
without destroying the purpose of the observation platforms.
Elevated noise level and disturbance of nesting birds
Construction phase:
A minor and temporary increase in noise level will occur as a
result of normal construction activities associated with platform
construction. Construction should occur during non-peak visitor
use or on weekdays when visitation is less, and also take into
account the nesting seasons.
Operation phase:
There will be an elevated noise level in the operation phase as
well, which makes the choice of location of the observation even
more important. When maintained, colours matching the
background, without light reflecting surfaces should be used for
the construction.
Vegetation clearance, including possible removal of trees and
Construction phase:
shrubs
Clearing the vegetative cover will be necessary at the chosen
locations for the platforms. This construction will alter some
vegetation cover, but the impact is considered minimal, if the
areas have been properly investigated before constructing the
platforms.
Potential problems with litter from tourists using the bird
Operation phase:
observation platforms
Litter bins should be placed at the bird observation platforms,
and a system should be set up to secure emptying on a regular
basis. Furthermore, park regulations should emphasize that
littering is not allowed and will be fined.
Providing easier access to prohibition zones at the banks of the
Operation phase:
lake
In some cases it might be necessary to fence the prohibition
zones on land, as well as marking the prohibition zones with
signs. Furthermore, the rangers should control the bird
observation platforms with regular intervals and maps in the park
regulations should indicate placements of prohibition zones.
Risk of contamination of soil during maintenance of platform
Operation phase:
(cleaning and painting) and leakage of impregnation substances
During maintenance of the platform, spills of the impregnating
from wooden building materials
substances should collected by plastic covers on the ground or
foundation of the platform. If made of wood, not freshly
16
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
impregnated wood should be used, but reused or reutilized wood
where leakage of impregnation substances is minimal, as some
substances in impregnation are toxic to the environment.
Establishment or spread of noxious weeds
Operation phase:
The potential for the spread of noxious weeds may increase with
enhanced visitor use of the park on both sides. If not existing,
there might be a need for putting a Weed Control Plan in place. If
noxious weeds exist in the proposed placement of the platform,
platform completion could actually assist park employees in their
control by allowing easier access into the affected areas.
Fecal contamination of surrounding areas
Operation phase:
Latrines could be constructed at each bird observation platform
and a system for cleaning at regular intervals should be set up.
These potential impacts and their mitigation measures should be addressed by the competent
authorities in the two countries, when giving their permit. At this point, the information regarding
these "subprojects" will be have to be improved, before the permit can be given, including
planned location, equipment for doing clearance of vegetation, materials to used for construction,
maintenance, duration of work etc.
Concerning construction of bird observation platforms, the following can be recommended,
taking into account the mentioned potential environmental impacts:
The respective laws "on protected areas" in Albania and "National Parks" in Montenegro
should be followed when the construction of bird observation platforms is planned. This
means that prior to any implementation, permits or licenses should be obtained from the
respective authorities in the two countries, being the Regional Environment Agency and
approved by the Council for Territorial Readjustment in Albania, and State Enterprise
National Parks in Montenegro. In addition, the subproject might be categorized as Category
"B" according to the WB system, involving the preparation of an Environmental
Management Plan, and a public consultation (see Section 6). The proposed construction of
bird observation platforms also has to be consistent with PA management plans.
As mentioned, the Skadar Lake National Park in Montenegro has already four bird
observation towers and one platform constructed with assistance from GTZ, and experiences
gained might be useful in Montenegro in this context.
4.3.3 Construction of visitor centers
A visitor center is already present in Montenegro, and it is for all 4 national parks in Montenegro,
even though it is placed next to the lake. It is placed close to a highway going through the park
and also houses the park administration, and is new and modern. Together with it is placed a shop
for local wine from the area, and a parking area has also been created. The center in Montenegro
has proper waste water treatment facilities in form of a mini wastewater treatment plant close to
the center. The exhibition in the center presents as mentioned also information regarding the three
other national parks in Montenegro, and it gives a good impression.
It should also be taken into account that a visitor center has been built in Shirog in Albania, very
close to the Lake, financed by the national budget. The center has not been taken in use yet, and
detailed information concerning the construction could not be obtained in English. A quick
inspection of the center did not indicate the presence of a septic tank or other collection or
treatment of waste water. The visitor center appeared small and not really suited for the purpose,
and its placement did not allow for parking of more than a few vehicles.
17
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Therefore, it has to be considered, whether more centers are needed, or investment from the
project should be used for improving the existing centers.
The potential Environmental impacts of constructing visitor centers in national parks and nature
parks and their corresponding mitigation measures are among others the following:
Construction of visitor centers
Potential environmental impact
Mitigation measures
Contamination of surroundings during construction with
Construction phase:
all types of construction waste (building materials,
A waste management plan should be prepared, covering
packaging, solvents, paints, plastic, etc.)
the whole construction phase. Waste containers with locks
could be placed at the building site for different kind of
waste, and frequent inspections should be done by the
monitoring authority. A special container should be made
for hazardous waste, incl. solvents, paints, and other toxic
chemicals.
Destruction of habitats for endemic plants and animals
Construction phase:
The risk of destroying habitats is very small, but the area
to be used for visitor centers should be properly
investigated in order to avoid destroying habitats for
endemic plants and animals. The placement of the centers
should be chosen with care, minimizing the potential
negative impacts. The visitor centers do not have to be
placed close to prohibition areas but should be placed
near access roads, as parking should be available for
visitors.
Elevated noise levels and general disturbance, depending
Construction phase:
on site
A minor and temporary increase in noise level will occur as
a result of normal construction activities associated with
center construction. Construction should occur during non-
peak visitor use or on weekdays when visitors are fewer.
Other mitigation measures are not necessary.
Operation phase:
There will be an elevated noise level in the operational
phase as well, which makes the choice of location of the
visitor center important. No mitigation measures are
necessary, but it could be mentioned in the park
regulations that noisy behaviour is generally not accepted
inside the park and destroys the chances for observing
wildlife at close range.
Potential problems with litter from tourists using the
Operation phase:
visitor centers
Litter bins should be placed at the visitor center, and a
system should be set up to secure emptying on a regular
basis. Furthermore, park regulations should emphasize
that littering is not allowed and will be fined
Problems with domestic waste water from toilets at the
Operation phase:
centers, if no proper sanitation solutions have been
The visitor centers should be equipped with proper
installed, providing bad examples for local inhabitants
sanitation facilities, taking care of domestic waste water.
and restaurants.
It can either be in the form of a mini waste water
treatment plant, as installed in the existing visitor center
in Skadar Lake National Park in Montenegro, or a modern
septic tank. If a septic tank solution is chosen, a system
for emptying the tank should be set up, transporting the
sludge to a safe disposal site outside the park.
18
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
These potential impacts and their mitigation measures will among other things be relevant for the
competent authorities in the two countries, if it is decided to include construction of visitor
centers in the final project description. At this point, the information regarding these
"subprojects" will be have to be improved, before the permit can be given, including planned
location, equipment for doing clearance of vegetation, materials to used for construction,
maintenance, duration of work etc. In this case the centers already exist, but the same kind of
information is needed, if improvements/extensions are planned.
Concerning construction/extension of two visitor centers, the following can be recommended,
taking into account the mentioned potential environmental impacts:
The respective laws "on protected areas" in Albania and "National Parks" in Montenegro
should be followed when the construction of bird observation platforms is planned. This
means that prior to any implementation, permits or licenses should be obtained from the
respective authorities in the two countries, being the Regional Environment Agency and
approved by the Council for Territorial Readjustment in Albania, and State Enterprise
National Parks in Montenegro. In addition, the subproject might be categorized as Category
"B" according to the WB system, involving the preparation of an Environmental
Management Plan, and a public consultation (see Section 6). Construction is mentioned in
both Albanian and Montenegrin laws on national parks. The proposed construction of visitor
centers also has to be consistent with PA management plans. The details are mentioned under
the respective descriptions of the environmental legislation in Albania and Montenegro.
As mentioned, the Skadar Lake National Park in Montenegro has already four bird
observation towers and one platform constructed with assistance from GTZ, and experiences
gained might be useful in Montenegro in this context.
4.3.4 Establishment of an effective protected area management and zoning system
The establishment of an effective protected area management and zoning system of the lake,
mentioned as operational objective in the Joint Strategic Plan, will have positive environmental
impacts, as it will restrict the access to vulnerable areas of the lake, such as spawning sites for
certain fish species and nesting places for birds. It was mentioned in Montenegro that one
enterprise had permission to exploit sand and gravel from the lake sediments, and that they often
came to close to such vulnerable areas. In the absence of zoning, it is difficult to enforce
protection of these areas. In the lake it could e. g. be done with buoys, marking the prohibition
zones.
It is therefore recommended:
The positive environmental impact of the establishment of an effective protected area
management and zoning system of the lake should be used in promotion of the project to
the public, as one of the positive impacts.
4.4 Component D
Component D entails activities that could potentially be harmful to the environment. One of the
proposed activities is classified as Category A according to the World Bank Classification
system, namely the one regarding clean-up at KAP. The others are classified as Category B. The
activities are the following: 1) Removal or containment of hazardous waste at the KAP
19
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
aluminium plant site, and 2) Support to wastewater treatment facilities for small lakeside villages
and isolated restaurants. Each of these activities will be addressed below.
4.4.1 Removal or containment of hazardous waste at the KAP aluminum plant site
Whenever a clean-up of a contaminated site such as the hazardous waste dump at KAP, should be
initiated, a thorough pre-investigation should be carried out. The pre-investigation will determine
the amounts of contaminated soil, the type of contaminants, and the options to remediate the
threat. Furthermore, it will specify the equipment, the duration, the pollution during the clean-up,
occupation health issues, etc. When this has been done, the different options to remediate the
threats should be considered, taking into account that the plant is still producing aluminium and
therefore also waste, meaning that any solution should cater for waste solutions for the coming
years. The next step is to finalize the EIA study and forward it to the competent authority.
A rough estimate from the Center for Ecotoxicological Research concerning the hazardous waste
dump indicates an amount of 300,000 tonnes of hazardous waste, covering an area of app. 3
acres, and in a layer of app. 7 metres2. According to current knowledge of waste from aluminium
factories, the main waste product is red mud with high pH, containing oxides of alumina, silicon,
iron, titanium, sodium, calcium and other elements. This red mud is currently being stored in two
big basins within the premises of the plant. Furthermore, hazardous waste from alumina plants
normally include spent sulphuric acid from descaling in tanks and pipes. Information concerning
handling of this waste was not given during the site visit at KAP, and attempts to get information
in English through the Center for Exotoxicological Research have not been successful, but it
should be obtained as part of the pre-investigation. From the smelter an amount from 40-60 kg of
mixed solid waste per ton of product is produced, with spent cathodes being the major fraction.
Such waste contains normally aluminium and silicon oxides, fluorides, and cyanide compounds
(about 400 ppm of the latter).
There are three options for the hazardous waste dump site after the pre-investigation has been
carried out. Either a new landfill is constructed at another location within the premises of KAP,
a lining is put in place, and the hazardous waste is moved to the new place, where there should
be place for land filling of waste for the coming e.g. 10 years. The second option is capping the
present landfill with an impermeable cover, preventing rain water from penetrating it and
transporting contaminants to the groundwater and eventually to the river. This solution still
requires the construction of a new landfill for new waste, but the movement of the `old' waste
from its present location is not necessary. The movement itself will increase the air pollution in
the form of dust. The third option is to construct a landfill outside the premises of KAP, move
the hazardous waste there, and use the landfill for waste from other factories as well. The
construction of the landfill in all three options is supposed to be according to regulations
stipulated in the EU directive on the landfill of waste (1999/31/EC).
The potential Environmental impacts and environmental issues of removing or contain hazardous
waste at the KAP aluminum plant site are among others the following:
Remediation of hazardous waste at KAP
Potential environmental issue and impact
Mitigation measures
Determination of content and amounts of waste
Preparation phase:
Pre-investigation or technical feasibility study, determining
2 A report is under preparation by Center for Exotoxicological Research, but not in English.
20
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
content and amount of waste, including options for removal and
design of hazardous waste landfill. Any placement of the landfill
will have to be consistent with the Spatial Plan for Podgorica
Municipality
Movement of hazardous waste will create dust and spread the
During the movement of the contaminated soil, modest spraying
contaminated soil to adjacent land.
with water can be done, if dust is a problem. The waste is not
considered a serious health hazard, but the proposed pre-
investigation will determine the type of mitigation necessary.
In case of movement in a season with increased precipitation,
Construction/preparation phase:
increased leakage of contaminants to groundwater and
It is proposed to do the movement in the months with lesser
subsequently to the river and from there to the lake
precipitation, e.g. during the spring and summer. If water is still a
problem, water leaking to the bottom of the excavation can be
pumped to a tanker, which should be emptied at a place, where
the water will not go to the lake
In case of capping with impermeable membrane, risk for
According to information from Montenegro, the risk for flooding
spreading to adjacent land and the river in case of flooding or
is very modest. It should be possible to avoid landslides by
landslide
proper placement of the landfill.
Contamination of groundwater resulting from leachate that can
A leachate control system should be put in place, with regular
leak through the liner system.
monitoring of leachate
Consistency with the overall land-use planning in the area.
The Municipality of Podgorica should be part of the preparations
for the pre-investigation, and they should ensure that the
placement of the landfill will be consistent with the spatial plan
for Podgorica.
Landfill not large enough to accommodate the hazardous waste
Allocation of sufficient land for landfill. Depends on reliable
from KAP for a reasonable time (10 to 30 years).
production figures from KAP and whether others than KAP will
be allowed to use the landfill for hazardous waste disposal.
These issues should among others be addressed by the competent authority in Montenegro, when
considering their approval of the EIA study. Furthermore, these issues should be taken account by
the separate approval by the World Bank. At this point, the information regarding this
"subproject" will be have to be improved, before the approval can be given, including all the
results of the pre-investigation, the planned location of the landfill, equipment to be used for
moving the hazardous waste, materials to used for membrane, durability of membrane, duration
of work etc. The competent authority for this kind of projects in Montenegro is the Ministry of
Tourism and Environment.
Based on the above mentioned potential environmental impacts, the following is recommended:
Terms of Reference for a pre-investigation should be prepared by the involved authorities in
Montenegro or the Project Secretariat, or a consultant hired by it. The outcome of the pre-
investigation should be a project document or technical feasibility study living up the
requirements for project description under the EIA Law of Montenegro, which will be in
force from January 2008, concerning documentation. Any existing documentation concerning
the hazardous waste should be collected and analyzed and if necessary translated to English,
before or during the pre-investigation, constituting a so called zero state study. Furthermore,
this technical feasibility study should live up to the requirement of the World Bank, as their
approval is equally important.
The developed project description should be used for an application of approval to the
Ministry of Tourism and Environment and follow the normal EIA procedures, and likewise
be submitted to the World Bank. Movement of hazardous waste and construction of a landfill
for hazardous waste will be on the list for preparation of a mandatory EIA study according to
the Law on EIA in Montenegro. An extra hearing/consultation apart from the obligatory one
according to the Montenegrin EIA Law should be initiated by the implementing ministry or
somebody whom it has been delegated to, as soon the project description is ready in order to
live up the WB requirements for Category "A" projects.
21
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Most likely, expertise for this kind of remediation and construction of landfills for hazardous
waste is not present in the Ministry, as no landfills for hazardous waste to date has been
constructed in Montenegro or Serbia. It is therefore recommended that international expertise
should be used for that part of the pre-investigation.
If the EIA study is approved, implementation should be initiated according to the conditions
given by the Ministry of Tourism and Environment, including monitoring requirements.
Furthermore, the EIA study should be approved by the World Bank, and an Environmental
Management Plan should be prepared. The Ministry will be responsible for monitoring the
implementation.
4.4.2 Treatment of wastewater from small lakeside villages and isolated restaurants
As already documented in the TDA, the joint SAP, and other documents, small lakeside villages
exist in both countries without proper wastewater treatment. In Albania there are furthermore
quite a few small restaurants at lakeside, without proper wastewater treatment. According the
environmental legislation in both countries, such activities should be approved by the competent
authorities, if they are within national or nature parks. As mentioned earlier, the competent
authorities are State Enterprise National Parks, and Regional Environment Authority, in
Montenegro and Albania, respectively.
The potential environmental impacts of discharging untreated wastewater from small lakeside
villages and isolated restaurants and their respective mitigation measures are among others the
following:
Treatment of wastewater from small lakeside villages and isolated restaurants
Potential environmental issue and impact
Mitigation measures
Contamination of surroundings during construction with all types
A waste management plan should be prepared, covering the
of construction waste (packaging, solvents, paints, plastic, etc.)
whole construction phase. Waste containers with locks could be
placed at the building site for different kind of waste, and
frequent inspections should be done by the monitoring authority.
A special container should be made for hazardous waste, incl.
solvents, paints, and other toxic chemicals.
Contamination of the lake with domestic waste water, containing
Different solutions for treating wastewater should be considered,
fecalia, pathogens and contaminants (e.g. detergents,
including sand filters, mini wastewater treatment plants, and
disinfectants, chlorine, etc.)
modern septic tanks. If septic tank solutions are used, a system
for emptying the tanks should be put in place.
Destruction of recreational values because of odours, tainting of
First of all, and environmental awareness campaign is necessary
the water at outlets, etc.
in order to stop new construction projects on primarily the
Albanian side of the lake. Secondly, the local environmental
authorities on both sides of the lake prepare a prioritization list of
possible projects, pinpointing hotspots
Health risks near outlets
The local environmental authorities on both sides of the lake
should see to it that the future monitoring programmes analyse
water samples for E. coli and coliforme bacteria in order to be
able to give the public information on health risks in the lake
Oxygen depletion because of high organic content in waste water
Oxygen content should as part of the future monitoring
programmes be measured on a regular basis
Eutrophication because of high phosphorus content of waste
As mentioned above, different solutions for treating the
water
wastewater should be considered, including sand filters, mini
wastewater treatment plants, and modern septic tanks.
These issues should be addressed by the competent authorities in the two countries, when
assessing the environmental impact of the subprojects. At this point, the information regarding
these "subprojects" does not exist, and all kind of details, including location, equipment to use,
materials, duration of work, etc. In fact, what is needed are small feasibility studies for selected
22
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
projects, and criteria for selection should be developed as well. The feasibility studies should as
well address the needs for documentation needed by the World Bank.
Concerning construction of treatment facilities for wastewater from small lakeside villages and
isolated restaurants, the following can be recommended, taking into account the mentioned
potential environmental impacts and proposed mitigation measures:
The respective laws "on protected areas" in Albania and "National Parks" in Montenegro
should be followed when the feasibility studies for small lakeside villages and isolated
restaurants are prepared and prioritized. This means that prior to any implementation, permits
or licenses should be obtained from the respective authorities in the two countries, being the
Regional Environment Agency and approved by the Council for Territorial Readjustment in
Albania, and State Enterprise National Parks in Montenegro. In addition, the subproject might
be categorized as Category "B" according to the WB system, involving the preparation of an
Environmental Management Plan, and a public consultation (see Section 6). Wastewater
treatment is not mentioned specifically in the Albanian and Montenegrin laws on national
parks, but has to be treated as "construction". The proposed construction of smaller
wastewater treatment facilities also has to be consistent with PA management plans and
spatial plans in Montenegro.
Terms of Reference for feasibility studies are prepared by the project secretariat, which goes
through the different options for wastewater treatment for small lakeside villages and isolated
restaurants, living up to both national legislation and EU legislation (The EU Directive
concerning Urban Wastewater (91/271/EC) and EU Water Framework Directive). Based on
that, a number of subprojects with proper documentation should be designed by the Project
Secretariat or consultants recruited by it taking into account the economic frames set, using
the recommended options. Criteria for selection, including e.g. possibilities for owners to co-
finance, should be prepared.
For the selected projects, the EIA procedures for the respective countries should be followed,
taking into account the proposed mitigation measures. As the projects might have a potential
for Transboundary pollution, a common procedure based on the MoU between the two
countries and following Espoo principles should be established. As usual, the selected
projects should also be assessed according to the WB classification system, and apart from
the EIA study, an EMP should be prepared, if they are classified as belonging to category
"B".
5. analysis of alternatives
The following is a short discussion of the alternatives to the proposed project. Concerning the two
components with potential environmental impacts, it will not address specific solutions at this
point, because of the lack of precisely described activities. For all components the 'without
project' scenario will be considered.
5.1 Alternatives to Component A
Component A has no potential negative impacts of any of the described activities. However, the
proposed outline of objectives will improve the coordination of activities around the lake, and
possibly avoid conflicting approaches from the two countries. The `without project' scenario
23
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
would not improve transboundary cooperation concerning protection and exploitation of natural
resources of the lake, and it not considered a good alternative.
5.2 Alternatives to Component B
Component B has no potential negative impact of any of the described activities either, and will
through the monitoring give a good picture of the environmental situation of the lake, and also
provide basis for decisions of reducing sources of pollution by the respective governments, as
part of the monitoring programme will assist in identifying sources of pollution. In this context it
is important to mention that the monitoring institutions on both sides should as soon as possible
be brought up to the same technical level, as the assessment of the ecological status of the lake
will be very difficult, if expertise, equipment, frequency differ too much between the two
countries.
The `without project' scenario will not bring any benefits, as an overall monitoring programme
will not be brought in place and it will not be possible to describe the ecological and
environmental situation of the lake and take actions accordingly.
5.3 Alternatives to Component C
Component C has some potential negative impacts of some activities, but they are not considered
to belong to Category "A", but "B". There are different ways of increasing tourism activities, but
the approach here is to cautiously assess possible impacts, before activities are initiated, and
implement the necessary precautionary and mitigative actions along any implementation. The
suggested activities regarding formation of well-marked bicycle and hiking trails, construction of
bird observation platforms, creation of two visitor centers are normal activities in national parks
and serving a purpose.
However, it can always be discussed how massive the interventions should be, and how close to
nesting sites of the birds, the observation platforms and bicycle and hiking trails should be placed.
It is here important to strike a balance between the wish of not disturbing the birds and the wish
to bring the visitors to the parks close to the wildlife in order to show them the birds properly. It
will probably not bring a lot of visitors, if all observation platforms and towers are far away from
the nesting sites, and only professional ornithologist with strong binoculars will be able to see the
birds. An option is to restrict the access to some of the platforms and towers at specific times of
the year, if it can be felt that the birds are too disturbed. Furthermore, it can be considered to
camouflage some of the platforms, and even coat their interior with noise dampening material and
put roofs on. It is therefore suggested that some of the platforms should be relatively near to some
of the nesting sites of some of the birds, and that restrictions should be made at certain times of
the year, if negative effects are discovered.
It is also important to take into account that it should be possible to evacuate visitors in case of
wildfires or accidents. This put some extra demands on the cover of the trails, but on the other
hand, there should also be access for pick-ups emptying the wastebins, and renovation teams for
cleaning the latrines.
The placement of the visitor centers on the other hand, does not have to be close to nesting birds.
Rather they should be placed at the edge of the park, close to access roads, and with parking
possibilities. Here it is considered more important that the pollution resulting from the center is
minimal (that wastewater is treated, and waste collected), and that options for refreshments and
parking are available.
24
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
The `without project' alternative will not meet the objective of developing tourism, as it probably
will stay at the same level, as it is now or even lower, if the public gets the impression that the
parks on either side have nothing to offer. It will not create awareness of the value of protecting
the lake and might in the long term be negative for the development of activities around the lake.
5.4 Alternatives to Component D
This component aims at providing financing to help remediate some hotspots which are identified
as high priority in the joint SAP. There are several alternatives for Component D, and a few will
be mentioned here.
Concerning the more concrete activities, they are still rudimentarily described, but it is mentioned
that the hazardous waste at KAP aluminium plant could either be contained or removed. What
will be the best solution depends on the result of the proposed pre-investigation. It is possible that
by far the cheapest solution might be to contain the waste at its location, but it might not take into
consideration that the factory continuously needs a storage place for its hazardous waste, and a
new landfill will have to be constructed anyway. The placement of the landfill is another aspect
that has to be investigated. However, these activities will improve the environmental situation of
the present landfill and of the lake.
However, there might also be other environmental problems at KAP, besides the hazardous
waste. One of the obvious aspects to consider is the huge energy consumption, and subsequent
consumption of fossil fuels. An energy audit of the factory might possible reveal that it is possible
to reduce the energy consumption substantially. Another option is to investigate if any cleaner
technology solutions might be available, as well as looking at the content of the emissions to air
from the chimneys and the discharges to the river from the wastewater treatment plant.
Another hotspot to consider is the discharge of untreated wastewater from Shkodra directly to the
lake, whenever the pumping station pumping the the wastewater to the Boyana/Buna River due to
power failure does not work. That is a serious and very visible environmental problem for the
lake that could be addessed under this component as well.
Concerning wastewater treatment facilities for small lakeside villages and isolated restaurants
there is also no closer description of the activities, but the implementation will lead to
environmental improvements in the form of less problematic discharges to the lake. The
alternative of removing the isolated restaurants or demand by force that treatment facilities should
be provided will not bring any benefits, and is probably not feasible.
The `without project' alternative is environmentally not sound, as it will deteriorate the
environmental situation of the lake, because 1) Contaminants from KAP will continue to leak to
the river and ultimately to the lake, and 2) The small lakeside villages and already established
restaurants will continue to contaminate the lake.
6.
Procedures for environmental screening of component
interventions
25
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
6.1 Procedures for Environmental Assessments
Below are described the procedures to be followed during project implementation by the
Albanian Ministry of Environment, Forests and Water Administration (MEFWA) and the
Montenegrin Ministry of Tourism and Environment, who will have the overall responsibility for
implementation of the project. The underlying principle of the development of these procedures
would be that environmental issues are best addressed when they are made an integral part of the
project cycle - in this particular case, it would be early in the project cycle for all activities to be
funded under the project. The process to be put in place would consist of the steps described
below.
6.2 Environmental Screening
For any subproject, the respective ministry or who this authority has been delegated to will carry
out an appropriate Environmental Assessment (EA) for activities under the main project. Before
approving a subproject, the Project Secretariat verifies (through its own staff, outside experts, or
existing environmental institutions) that the subproject meets the environmental requirements of
appropriate national and local authorities and is consistent with the OP 4.01 and other applicable
environmental policies of the Bank. The Project Secretariat will submit the EA to the Bank for
the final approval the results of the EA review.
An environmental screening will be undertaken to determine the appropriate extent and type of
EA. The proposed subprojects will be classified according on the type, location, sensitivity and
scale of the project and the nature and magnitude of its potential environmental impacts. The
highest rating given to individual sub-project will determine the category of the EA.
(a) Category A: A proposed project is classified as Category A if it is likely to have significant
adverse environmental impacts that are sensitive, diverse or unprecedented. These impacts may
affect an area broader than the sites or facilities subject to physical works. EA for a Category A
project examines the project's potential negative and positive environmental impacts, compares
them with those of feasible alternatives (including the "without project" situation), and
recommends any measures needed to prevent, minimize, mitigate or compensate for adverse
impacts and improve environmental performance.
(b) Category B: A proposed project is classified as Category B if its potential adverse
environmental impacts on human populations or environmentally important areas - including
wetlands, forests, grasslands, and other natural habitats - are less adverse than those of Category
A projects. These impacts are site-specific; few if any of them are irreversible; and in most cases
mitigation measures can be designed more readily than for Category A projects. The scope of EA
for a Category B project may vary from project to project, but it is narrower than that of Category
A EA. Like Category A EA, it examines the project's potential negative and positive
environmental impacts and recommends any measures needed to prevent, minimize, mitigate or
compensate for adverse impacts and improve environmental performance.
(c) Category C: A proposed project is classified as Category C if it is likely to have minimal or
no adverse environmental impacts. Beyond screening, no further EA action is required for a
Category C project.
Table 6. 1 on the next page shows, how the screening can be done, and differences between the
systems in the two countries and the World Bank:
26
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Table 6.1: Criteria for Albanian or Montenegrin and World Bank EA procedures under the Project
Category As Per Albanian Legislation
r
y
Procedure To Be Followed
Category As Per Montenegrin Legislation
B
o
Law on Environmental Impact
(Meeting either Albanian or Montenegrin
Law on Environmental Impact Assessment
W
a
t
e
g
C
Assessment, No.8990, dated
and World Bank standards)
(Official Gazette of the RM, No. 80/05)
23.1.2003
·
An EIA study should be
·
An EIA study should be prepared by the
prepared by the Project
Project Secretariat or consultant hired by
Secretariat or consultant hired
it and submitted or to local
by it and forwarded to the
environmental authorities
Regional Environmental Agency
·
An EIA study will be prepared by the
(municipalities) or to the Ministry of
(REA). After review of the
Project Secretariat or consultant hired
Tourism and Environment (at the time
category, REA will send it to the
by it to meet either Albanian or
being the competent authority, until the
Ministry for decision-making,
Montenegrin legislation on EIA and
new EPA is created).
with their remarks.
World Bank requirements
·
·
The GoMN will pass regulations
All projects and activities
·
Extensive Executive Summary (ES)
prescribing a list of projects for which
described in Appendix 1 of the
and Environmental Management Plan
the EIA is mandatory, meaning the ones
law should undergo a profound
(EMP) will be prepared in English
with potential strongest negative impact
process of EIA.
·
Two Public consultations will be held
·
on the environment. Until passed, old
If in a protected area and in
·
Approval of EIA will be obtained
EIA regulations are still valid.
appendix 2, a profound EIA
from either the Albanian or the
·
The impact assessment procedure shall
process should also be made, if
Montenegrin ministry, and the
include: 1) decision on the need for the
assessed as having significant
relevant Environmental Approval with
EIA study, 2) definition of the content
impact on the environment
specified mitigation, prevention
·
and scope of the EIA study.
The local authorities shall within
measures and monitoring issued.
·
Within a month the competent authority
A
a month organize a public
·
The World Bank will review (ES and
shall organize a public
debate/consultation upon request
EMP) and provide no-objection to the
debate/consultation on the EIA
by the Ministry of Environment
consultation result and final EIA
·
application.
A committee will be assessing
·
A committee will be assessing the EIA
the EIA and if approved, the
study and if approved, the Ministry will
Ministry will issue the permit
issue the permit.
·
An EIA/EMP will be prepared by the
Project Secretariat or consultant hired
by it (to meet World Bank
requirements).
·
·
Two public consultation will be held
There are no obligations to
·
·
There are no obligations to prepare an
Approval of EIA/EMP by the ministry
prepare an Environmental
Environmental Management Plan (EMP)
in which the project takes place, will
Management Plan (EMP) as part
as part of the Montenegrin EIA
be obtained, and the relevant
of the Albanian EIA legislation
legislation
environmental approval issued.
·
The World Bank will review and
provide no-objection to the
consultation result and final
EIA/EMP.
·
An EIA will be prepared by the
Project Secretariat or a consultant
hired by it to meet either the Albanian
·
or the Montenegrin legislation on
A summary EIA should be
Environmental Impact Assessment)
prepared by the Project
·
·
The second list of projects of the law are
Environmental Management Plan
Secretariat or consultant hired
for projects for which the impact
(EMP) will be prepared in English
by it.
assessment may be required.
B
·
·
One public consultation will be held.
All projects and activities
·
·
The competent authority shall decide on
MEPPPC approval of EIA/EMP will
described in Appendix 2 of the
the need of the impact assessment in
be obtained, and the relevant
law should undergo a summary
each individual case of projects
environmental approval issued.
process of EIA.
·
The World Bank will review and
provide no-objection to the
consultation result and final
EIA/EMP.
27
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Table 6.1: Criteria for Albanian or Montenegrin and World Bank EA procedures under the Project
Category As Per Albanian Legislation
r
y
Procedure To Be Followed
Category As Per Montenegrin Legislation
B
o
Law on Environmental Impact
(Meeting either Albanian or Montenegrin
Law on Environmental Impact Assessment
W
a
t
e
g
C
Assessment, No.8990, dated
and World Bank standards)
(Official Gazette of the RM, No. 80/05)
23.1.2003
·
EMP only prepared as required by
WB.
·
Relevant Ministry approval of EMP
will be obtained, and the relevant
environmental approval issued.
·
There is not a third category in
·
There is not a third category in the
C
·
For this category no EIA is required.
the Albanian EIA law.
Montenegrin EIA law.
Public Consultation and Disclosure
For all Category "A" and "B" subprojects, during the EA process, the respective ministry will
consult project-affected groups and local nongovernmental organizations (NGOs) about the
project's environmental aspects and take their views into account. For Category "A" projects, the
respective ministry or whom they have delegated it to consults these groups at least twice: (i)
shortly after environmental screening; and (ii) once a draft EA report is prepared. In addition, the
respective ministry consults with beneficiaries on a continuous basis during project
implementation through public relations campaigns. The respective ministry will provide relevant
material in a timely manner prior to consultation with project-affected groups and local NGOs
and in a form and language that are understandable and accessible to the group being consulted.
For a Category "A" project, the respective ministry provides for the initial consultation a
summary of the proposed project's objectives, description and potential impacts. In addition, the
respective ministry ensures that EA reports for Category A subproject are made available in a
public place accessible to affected groups and local NGOs. Any separate Category B project
report is made available to project-affected groups and local NGOs. Only one subproject has been
categorised as Category A, namely the removal or containment of the hazardous waste at KAP
Aluminium Plant in Montenegro, and only for that subproject two consultations will be
necessary.
7. environmental management plan and monitoring
As mentioned above, some of the activities have explicit negative impact on the environment and
thus require a specific plan to institute and monitor mitigation measures and take desired actions
as timely as possible.
The following content is developed based on WB OP 4.01 Annex C, and adapted to the Lake
Skadar/Shkodra Integrated Ecosystem Management Project. An Environmental Management Plan
(EMP) must be kept as simple as possible, clearly describing adverse impacts and mitigation
actions that are straight forward to implement. The scale of the subproject will determine the
length of the EMP. A small scale subproject's EMP can be elaborated in a few paragraphs or in a
tabular format, keeping it as possible with concrete mitigation actions, timelines and responsible
persons.
As noted in the earlier section, EMPs will be required for projects that fall in World Bank
Category A and B. It is suggested that the following information be included:
28
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
(a) Responsible Party: The authors who prepared the EMP along with the date of preparation.
(b) Project Description: Present a brief description of the subproject. Include the nature of the
investment, the location, and any characteristics of the area that are of particular interest (e.g. near
a protected area, area of cultural or historical interest, sensitivity of the area).
(c) Mitigation Plan: This should include a description of the steps to be taken to identify all
anticipated significant effects, to mitigate the major potential impacts on land, water, air and other
media during the planning, design, construction and operation phases.
(d) Monitoring Plan: This should include a description of the key parameters to be monitored
(including monitoring locations, schedules and responsible entities) and reporting procedures to
ensure that the construction and operation of the project is in conformance with either Albanian
or Montenegrin law and other relevant norms and standards, and conditions set by the WB. If
such details are covered by permits or construction or monitoring contracts these can be
referenced as attachments.
(e) Institutional Arrangements: There should be a narrative discussion that provide a brief
presentation on how the monitoring data is going to be used for sound environmental
performance - who collects the data, who analyzes it, who prepares reports, who are the reports
sent to and how often, what is done by the responsible authorities after they receive the
information; and how is non-compliance with the EMP treated. This should also include (a)
technical assistance programs, (b) procurement of equipment and supplies, and (c) organizational
changes.
(f) Implementation Schedule and Cost Estimates: For all three aspects (mitigation, monitoring,
and capacity development), the EMP provides (a) an implementation schedule for measures that
must be carried out as part of the project, showing phasing and coordination with overall project
implementation plans; and (b) the capital and recurrent cost estimates and sources of funds for
implementing the EMP. These figures are also integrated into the total project cost tables.
(g) Consultations with affected groups and non-governmental organizations. The following
should be included: Date(s) of consultation(s); Location of consultation(s); Details on attendees
(as appropriate); Meeting Program/Schedule: What is to be presented and by whom; Summary
Meeting Minutes (Comments, Questions and Response by Presenters) Agreed actions.
The involved stakeholders in Montenegro or Albania (e.g. the respective ministries and the
municipalities of Podgorica and Shkodra) must participate in the development of the EMP, since
local knowledge is important in identifying, designing and planning the implementation. In
addition, the success of the implementation of the EMP will depend on community support and
action; ownership is essential. The EMP for the activities under the four components potentially
affecting the environment in a negative way can be found as Annex 3. Details as mentioned under
The EMP should be part of the Project Implementation Manual. If further activities are designed,
they should be addressed and added to the EMP if relevant.
7.1 Institutional Strengthening
29
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
In order for the project to be successful, it is important to touch upon possible institutional
strengthening of the involved institutions in Albania and Montenegro. Below the proposed roles
of the mentioned institutions will be described as well as necessary strengthening.
7.1.1 Institutions in Albania
Nature Park Administration, Shkodra.
According to the joint SAP, the administration of the managed natural reserve of Skadar/Shkodra
Lake in Albania is composed by ten employees (Rangers), who depend on the Ministry of
Environment, Forests and Water Administration. This Ministry is charged with drafting the
administration regulations, the management plan and the monitoring programme of the managed
natural reserve of Skadar/Shkodra Lake in cooperation with local government, non profitable
organizations, community representatives and scientific institutions.
At present, the nature park administration consists of 10 rangers. None of them have managerial
experience, and according to information obtained in Shkodra the inspection level is low, and job
descriptions for their tasks probably do not exist. A director for the park has not been appointed
yet. The park administration is supposed to be in charge of the daily operation of the park, and
enforcement of the regulations for the park, when prepared. Furthermore, it is foreseen that part
of the inspection of on-going activities in the park will be done by the park administration.
It is recommended that:
A manager is appointed as soon as possible and that regulations for the park are prepared
accordingly.
The employed rangers will get training courses matching their tasks, including training in
enforcement of regulations in force in the nature park, such as actions against illegal fishery,
illegal construction, illegal disposal of waste etc. The training should be conducted in
cooperation with the Regional Environment Agency Shkodra.
Regional Environmental Agency Shkodra
The agency has an important role in issuing and monitoring permits for construction within the
nature park and screening EIA projects in the region, before submitting them to the Ministry in
Tirana. Other approved EIA projects in the region are also inspected by the REA. The Project
Secretariat will have to cooperate closely with the agency, and all activities of the project on the
Albanian side should be coordinated with the agency, including awareness activities. It is the
perception that the agency is not very visible in Shkodra, and the project could enhance this, by
providing training in environmental auditing and inspection.
It is recommended that:
The project should support training for staff of the agency in environmental auditing and
inspection.
University of Shkodra
The university has got the specialists necessary for doing most of the monitoring of flora and
fauna in the lake. It seems though that they will have to be supplemented in some of the
disciplines by the Faculty of Natural Sciences, University of Tirana, e.g. freshwater invertebrates
and fish. Concerning measurements of physico-chemical parameters, which might have to be
measured quite often, it is not considered a good idea to involve the University of Shkodra, as
30
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
they because of their lectures generally have difficulties in finding much time for such activities
Anyhow, they should be part of the working group designing the overall monitoring programme,
which should be in accordance with the preparation of surface water status for lakes in the EU
Water Framework Directive (2000/60/EC, Annex V).
It is recommended that:
The University of Shkodra should be involved in the monitoring of the flora and fauna of the
lake and the design of the overall monitoring programme for the lake, in accordance with the
EU Water Framework Directive (2000/60/EC, Annex V).
University of Tirana, Faculty of Natural Sciences
As mentioned above, the university should assist the University in some of the disciplines
required for monitoring of the freshwater invertebrate fauna of the lake, as they have a broader
range of expertise and has more staff than the corresponding faculty in Shkodra. Furthermore, the
university could be involved in the measurements of heavy metals and organic chemicals, if the
monitoring programme is ready, before the Hydrometeorological Institute has the necessary
expertise.
It is recommended that:
The University of Tirana assists the University of Shkodra in monitoring the fauna of the
lake, e.g. on monitoring of freshwater invertebrates and fish
The University of Tirana assists in monitoring organic chemicals and heavy metals, if the
Hydrometeorological Institute is not having the necessary expertise in place, when the
monitoring starts.
Hydrometeorological Institute of Academy of Sciences, Tirana
The Hydrometeorological Institute has been assessed to be the institution best positioned to do the
monitoring of heavy metals and organic compounds on the Albanian side of the lake. The
institute is at the time receiving support by an EU project (Strengthening of the
Environmental Monitoring System in Albania, StEMA), providing them with all
necessary equipment as well as training, and they have environmental monitoring as a core task
for the institution.
It is recommended that:
The Hydrometeorological Institute should be involved in the design of the overall monitoring
programme for the lake, and they should in the future be the main institution responsible for
monitoring of heavy metals and organic compounds. Until they are ready to take up the task,
technical assistance should be given to the institute by the University of Tirana, Faculty of
Natural Sciences.
It is recommended that the institute participates in intercalibration with other laboratories in
the region, as soon as they master their new equipment. Furthermore, it is recommended that
they get accreditations for analysis of heavy metals and a number of relevant organic
pollutants.
7.1.2 Institutions in Montenegro
31
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Public Enterprise National Parks of Montenegro
This institution under the Ministry of Tourism an Environmental Protection is in charge of the
four national parks in Montenegro, and also the competent authority regarding environmental
protection in the parks. The management of the Skadar Lake National seems to be performing
very well, and is the only national park in Montenegro that has been able to create a financial
surplus on their activities. The park administration has the role of inspecting all on-going
activities in the park, including construction activities.
Nature Protection Institute
This institute has relevant expertise regarding monitoring of flora and fauna in the Montenegrin
part of the lake. It is not under the Ministry of Tourism and Environment, but under the Ministry
of Culture. It has a very low budget for monitoring of flora and fauna in the whole of
Montenegro, only around EUR 12,000 per year. It has relevant experience from the lake and has
been cooperating with University of Shkodra on the monitoring of biota.
It is recommended that:
The Nature Protection should be participating in the process of designing the overall
monitoring programme of flora and fauna for the lake, and also be an active partner in the
future monitoring, along with staff of the Skadar Lake National Park staff.
It is recommended that the project finances the participation of the institute in the monitoring
of the lake, at least for the first two years.
Public Institution "Center for ecotoxicological research"
The center has high expertise in analysing pollutants in different media and is considered an asset
for Montenegro in environmental monitoring. The center has accreditations for several analyses
and participates on a regular basis in intercalibrations with other European laboratories. It has
been doing analyses on samples from the lake and has also been training other institutions in the
region. Furthermore, the center is working for KAP Aluminium Plant on a commercial basis, and
has a good knowledge of the environmental problems in the country.
It is recommended that:
The center should be involved in the design and implementation of the overall monitoring
programme for the lake of physico-chemical parameters, heavy metals, and organic
chemicals.
The center is probably the only one in the region that will be able to do the pre-investigation
of the hazardous waste land fill at KAP and should be used for that purpose.
The analyses of samples to be done at KAP should be done by the center.
The staff of the center may be used as trainers for the other monitoring institutions in
Montenegro
Hydrometeorological Institute
The institute has relevant expertise in environmental monitoring, but still needs more equipment
for heavy metals and organic chemicals and training in using it. The institute has no
accreditations and is not participating in any intercalibration exercises with other laboratories.
The economy of the institute is very modest, and they have only funding for monitoring the lake
in the summer months of the year. The institute should be involved in the preparation of the
design of the overall monitoring programme, and should be responsible for measurements of
physico-chemical parameters. In the future they could be seen as the responsible institution for
measurements of all physico-chemical parameters.
32
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
It is recommended that:
The institute should be involved in designing the overall monitoring programme for physico-
chemical parameters for the lake, and at this point be involved in the measurements of basic
physico-chemical parameters in the Montenegrin part of the lake. In the longer term, when
capacity building has been made and proper equipment purchased, the institute might also be
responsible for measurements of heavy metals and organic chemicals.
7.2 Management arrangements
The management arrangements of the project are touched upon briefly below. Before the project
is commenced, these issues should be agreed between the respective ministries and the Bank.
7.2.1 Project Secretariat
Normally when such projects are established, a project secretariat or project support unit is put in
place in order to have a smooth implementation and a daily management of the project. At this
point two Project Implementation Units are established in Albania and Montenegro, but when the
project starts a secretariat should be in place, or recruited shortly after initiation.
The placement of the secretariat will also have to be decided, but it is not seen as something very
important regarding the secretariat and its functions. Below can be seen of the basic tasks of the
project secretariat:
The secretariat should be the daily management of the project, in contact with both
implementing ministries on a regular basis.
The secretariat should prepare annual work plans and budgets
The secretariat should be able to draft terms of reference for consultants, negotiate rates
and contract them.
The secretariat should be able to do procurement, according to both WB guidelines and
procurement acts in the respective countries
The secretariat should be reporting on progress on the project on a regular basis (e.g.
quarterly), both technically and financially
The secretariat act as secretariat for the Steering Committee, including sending
invitations and writing the minutes the meetings. The agenda should be agreed between
the two ministries even though a standard agenda would normally be used, reporting on
progress etc.
The secretariat could set up a website for the project, enabling the public to be informed
about progress and initiatives.
The staffing of the secretariat should as a minimum include the following:
Executive secretary, with at least 10 years of experience, including managerial and
administrative experience from the private or public sector. It does not necessarily have
to be a person with a background in engineering, chemistry, biology or environmental
science, because more than just technical skills are needed. The executive secretary
should be fluent in English.
33
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Two environmental specialists, one from each country, with at least 6-8 years of
experience in environmental management, and/or conservation issues. Both should be
fluent in English.
An experienced accountant, familiar with procurement, in at least one of the countries.
Should also be fluent in English.
An office manager/secretary, also fluent in English. Should be able to arrange workshops
and basic logistics.
7.2.2 Project Steering Committee
As seen above, it is also proposed to have a Project Steering Committee (PSC) for the project.
The PSC could e. g. comprise representatives from the two ministries, the Regional Environment
Agency Shkodra, Skadar Lake National Park, the municipality of Shkodra, the municipality of
Podgorica, and the World Bank. When a proper management of the nature park on the Albanian
side has been set up, the representative from the Regional Environment Agency could be replaced
by a representative from the park.
The PSC approves annual work plans and budgets as well as progress reports. The Project
Steering Committee meets quarterly or as needs arise. The chairman of the PSC should be a
representative from one of the ministries, and it could be agreed that it would change every year
between the two countries. The decisions should be taken by consensus and Terms of
Reference/Rules of Procedure of the PSC should be agreed on at its first meeting.
34
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
8. References
Joint SAP, 2006. The strategic Action Plan for Skadar/Shkodra Lake Albania & Montenegro.
APAWA, SNV Montenegro, CETI.
REC, 2004. Roles and Responsibilities of Skadar/Shkodra Stakeholders in Albania and
Montenegro. REC project.
REC, 2005. Local Environmental Action Plan (LEAP) for Shkodra.
TDA, 2005. Lake Shkoder Transboundary Diagnostic Analysis Albania & Montenegro. Royal
Haskoning, Netherlands.
World Bank Group. 1998. Pollution Prevention and Abatement Handbook Toward cleaner
production. Washington D.C., USA.
World Bank, 1991. Environmental Assessment Sourcebook. Volume I: Policies, Procedures, and
Cross-Sectoral Issues. World Bank Technical Paper Number 139. Washington D.C., USA.
World Bank, 2006. Draft Appraisal Document: Montenegro/Albania Lake Skadar-Shkoder
Integrated Ecosystem Management Project.
35
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
ANNEX 1:
TERMS OF REFERENCE
ENVIRONMENTAL IMPACT ASSESSMENT
LAKE SHKODER/SCADAR INTEGRATED ECOSYSTEM MANAGEMENT
PROJECT
I. BACKGROUND
1.
Lake Shkoder/Skadar Background
Lake Shkoder/Skadar is a karstic lake of Neolithic origin. It is the largest lake in Balcans
with a surface area that varies from about 370 to 540 km2. Its watershed area is estimated
at about 5,490 km2, with about 80 % of this area in Montenegro and 20% in Albania. The
lake is shallow, with an average depth of about 3 meters. The Moraca River in
Montenegro is the largest tributary to the lake. Its average discharge is about 200 m3/s.
Significant additional flows come from groundwater flows and springs that discharge in
the northern part of the lake. The lake drains to the Adriatic Sea through the Buna /
Boyana River. The estimated outflow is about 330 m3/s. In an 1846 storm, the River
Drini diverted its primary channel into the Buna River a few kilometers below its origin
in Shkodra Lake.The massive amounts of sediment this catastrophic change brought to
the Buna River raised the channel bed substantially and increased the water residence
time in Shkodra Lake. The resulting increase in water level in the lake flooded the
surrounding lowlands and has maintained a higher lake level since that time. Currently
water residence time is about 120 days.
The lake is a wetland site of international importance. It has a unique and rich flora and
diverse fauna that includes numerous endemic species. It is one of the most significant
wintering sites for water birds in Europe, including many species that are globally
threatened. Ninety percent of the bird species are migratory. The lake has a diverse fish
community with high productivity. Fishing is an important source of income for the local
population.
The Albanian side of Lake Shkoder/Skadar is proclaimed "Managed Natural Reserve"
and belongs to the forth category (IUCN convention) of protection. In Montenegro the
lake is proclaimed National Park. The lake is Ramsar site as well.
2.
Overview of the ecological situation in Lake Shkoder/Scadar
Main pressures and threats
Lake Shkoder/Skadar and its basin are experiencing various impacts from different
sources and facing numerous threats. The following have been identified: Pollution
(industries, municipalities, solid waste, liquid waste), Hunting and fishing, Lakeshore
development, Water management measures.
36
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
a. Pollution: In general, the quality of the lake water is within acceptable (EU) limits,
in part because of the high "turn-over rate" of the lake water. However, there are some
areas where nitrate concentrations and oxygen depletion, sedimentation, and possibly
heavy metal concentrations and persistent organic pollutants are a concern. This is
particularly at the mouths of inflowing rivers and in areas where there are contaminated
sediments from previous industrial activities. There may also be a problem of
contaminated groundwater infiltrating into the lake. Overall, there are three main
sources of pollution: chemical pollution by factories such as the KAP and Steelworks
Niksic; organic pollution by the wastewaters from the cities and towns; and non-point-
source organic pollution from agricultural runoff. Pollution is likely to increase with
growing economies, increasing prosperity, and a steady population growth.
b. Hunting and fishing: Lake Shkoder is an important area for bird migration in the
Mediterranean region. In recent years bird numbers have declined drastically.
Uncontrolled hunting is one suspected cause for the decline in bird numbers. The
fishing situation is characterized by over-fishing by both licensed and unlicensed
fishermen, use of destructive methods, such as dynamite and electro fishing, lack of
access through the Buna / Bojana River for migrating species, invasion of exotic species,
potential toxic contamination, and habitat alterations. Strong decline of fish stock is
observed. There is an indication that some fish populations are declining, which might
be associated with over-fishing, and/or disturbance or pollution of key spawning sites.
c. Unsustainable tourism: Tourism related development is growing rapidly,
particularly in parts of the Albanian side of the lake. Much of this development is
unplanned and does not include measures to protect the environment. Tourism
development is expected to grow even faster in the future with general economic
recovery, and as a result of investments such as the rehabilitation of historic sites and
buildings.. Unplanned and unregulated tourism development presents an environmental
threat, but if the tourist facilities and attractions are set up in an ecologically sustainable
way, negative impacts on flora and fauna may be limited. Impacts can even be positive if
tourism earnings are invested in nature protection and development.
d.
Residential constructions on the lake shore: In addition to tourism development,
the growing economy has promoted individuals to build homes and businesses in
attractive areas near the shores of Lake Shkoder/Skadar. Again, most of this
development is unplanned and unregulated. If this continues unregulated, habitats will
be destroyed and the wildlife disturbed by human influence.
e. Big development projects on/ near the lake: Ideas are being launched by both
private investors and government agencies for development projects like marinas, tourist
resorts and recreational areas along the lake shore. The negative impacts of these
projects on flora and fauna and the lake ecosystem are likely to be big and irreversible.
f. Projects changing the lake level and level dynamics: There are proposals to dredge
the Buna-Bojana and change the lake level and/or level dynamics. If implemented, this
would have an enormous impact on flora and fauna as large wetland areas would
disappear as the lake level was lowered.
g. Illegal logging and tree cutting and over-grazing: these are widespread in the
lake's basin and especially in AL side,. including within the protecting areas. Due to
37
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
over grazing the mountain pastures on both sides are partially degraded, which
stimulates more active soil erosion.
II. GEF
PROJECT
a. Project
objectives
The overall objective of the Lake Shkoder Integrated Ecosystem Management Project is
to assist the Governments of Albania and Montenegro in achieving more sustainable use
of the natural resources of Lake Shkodra and its watershed. The global environmental
objective of the project is to reduce pollution and conserve the lake and its biodiversity as
an internationally important natural habitat, especially for water birds. Because of the
complex nature of the lake's problems, the project pursues an integrated approach to land
and water issues, by promoting cross-sectoral cooperation throughout the watershed. The
project will achieve its objectives by implementing priority measures as identified in the
Lake Shkodra National and Joint Strategic Action Plan prepared jointly by both
countries.
b.
Project Description, Activities, Outputs and Outcomes
The project will achieve its objectives through three pillars: (i) establishing and
strengthening national and transboundary institutions, systems and capacity for effective
ecological management; (ii) creating an enabling environment for local and national
authorities to improve environmental regulation by building public awareness and
support, and by helping local residents and businesses comply with the requirements; and
(iii) helping to eliminate or reduce some of the most urgent existing threats to the Lake's
ecosystem. The project includes both joint activities and "unilateral" activities
c.
The Project consists of four components
Component A. Coordinating Lake Management. This component will help to put in
place an institutional structure for coordinating protection and management of Lake
Skadar-Shkoder and its natural resources. The establishment of a transboundary River
Basin Authority as called for by the EU Water Framework Directive is likely to take
years, and a phased approach should be used. The project will support the creation of
several bilateral Working Groups to coordinate implementation of key actions called for
in the 2003 Memorandum of Understanding and the joint Strategic Action Plan. Working
Groups will be set up for: (i) design and establishment of a permanent transboundary
institutional structure (including harmonization of policies, procedures and legislation as
required); (ii) development of a lake-wide zoning and management plan (complimentary
to the individual management plans which are legally required for both of the Protected
Areas); (iii) designing and launching a lake-wide ecological monitoring program; (iii)
developing and launching a public awareness-raising and education program; and (iv)
preparing a coordinated strategy and plan to promote sustainable tourism development
38
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Component B. Monitoring and Research: This component will support Technical
Assistance, training, the purchase of equipment and incremental operating costs (on a
declining basis) needed to put in place a permanent joint monitoring system, guided by
management requirements and by the parameters outlined in the EU Water Framework
Directive and the Ramsar Convention. Monitoring for specific purposes such as Avian
Flu prevention and detailed ornithological surveys will also be included. The types and
amounts of support provided will differ somewhat between the two countries, based on
their existing capacity. An important part of the monitoring program will be establishing
a common data base and networks for information exchange. The monitoring program
and protocols will be designed and overseen by a transboundary Working Group,
supported by the Secretariat, and implemented on the ground by the appropriate national
institutions. The project will also finance a limited amount of "on-demand" research
relating to specific management issues identified through the monitoring program, such
as seeking the causes for declines of particular species or testing different approaches to
habitat restoration. In the first year, the targeted research program will include a detailed
socio-economic study and stakeholder consultations associated with developing a Process
Framework relating to possible increased restrictions on fishing, as described in Section
XXX. The research will be contracted to capable research institutions by the Secretariat
on behalf of the Working Group, through a competitive process
Component C. Protected Area and Natural Resources Management. Ensuring that
natural resources are used sustainably and limiting their ecological impact is an essential
and challenging part of PA management is an important long term strategic goal for Lake
Skader-Shkoder in both countries. The project will support development of sustainable
tourism by helping to create an attractive and ecologically appropriate environment for
nature-based tourism such as well-marked bicycle and hiking trails, bird observation
platforms, informational signs and materials, restoration of cultural heritage sites and
creation of two visitor centers ((preferably through rehabilitation of existing historic
buildings). Other types of local economic development will be supported through
partnership initiatives of the PA administrations such as providing technical assistance
for organic agriculture and development of locally branded "Lake Skadar" specialty food
products and handicrafts based on environmentally friendly and sustainable resource use.
The project will support Technical Assistance, training, equipment and materials, and
some incremental operating costs to strengthen the capacity of the PA Administrations
and enable them to practice effective, integrated management of the PAs and their natural
resources. This management will be carried out in coordination with one another
(transboundary) and in cooperation with local governments and communities and other
stakeholders. Specific activities will include: TA for assessment and revision of policies
and regulations (Albania); the development of zoning and management plans for the PAs
(to be incorporated into lake-wide zoning and management plans) and demarcation of
zones; communications and other equipment to enhance management effectiveness on
the ground; small scale infrastructure for PA management and tourism (including small
visitor centers); and TA and incremental operating costs to establish and improve
programs in areas such as tourism promotion/marketing, community outreach and
livelihoods support activities, and education.
39
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
COMPONENT D. Urgent Environmental Investments . The project will provide
financing to help remediate some hotspots which are identified as high priority in the
joint SAP. GEF funding will either form part of a larger financing package (e.g. to
remove or contain hazardous waste at the KAP aluminum plant site) or compliment,
extend and broaden the benefits of activities being funded by others (e.g. wastewater
treatment facilities for small lakeside villages and isolated restaurants, complimenting
large projects to improve wastewater treatment for large cities and towns. In addition to
addressing existing problems, the project will finance a pilot program to promote low
input/organic agriculture in surrounding areas, as a means of preventing a resurgence of
agrochemical inputs to the lake.
III. OBJECTIVE OF THE ASSIGNMENT
To carry out an Environmental Assessment that will identify any potential negative
impacts of implementation of the proposed Lake Shkoder/Skadar Integrated Ecosystem
Management Project , and to develop an Environmental Management Plan (EMP) which
outlines the actions, approaches and procedures that will be undertaken by various
stakeholders to avoid, reduce and mitigate these adverse impacts. The EA and EMP
should meet the legal requirements of the Governments of Albania and of Montenegro,
and of the World Bank (in accordance with WB Operational Policy 4.12).
IV. SPECIFIC TASKS
Consultant's specific tasks of the EIA are:
· Review the relevant Albanian and Montenegrin legislations and procedures
relating to EA, and describe what legal instruments exist to prevent or minimize
negative environmental impacts. Identify gaps, if any, between local laws,
national laws and the requirements of the World Bank's Operational Policies
relating to EA, and also between the local/national laws and any international
conventions and agreements to which Albania and Montenegro are part (such as
those covering trans-boundary lakes and wetlands). Description of the legislative
and the institutional context in which the Project will be implemented.
· Description of the kind of activities that the project is expected to finance.
· Description of the kinds of positive and negative environmental impacts that may
arise from these kinds of activities
· Outline options to mitigate or compensate the negative impacts on natural
resources, the lake ecosystem and nearby terrestrial ecosystems, vulnerable
species (particularly any rare and threatened or endangered species),
· Outline of the procedures that will be followed for carrying out environmental
screening of the specific investments at the time that they are identified and for
carrying out, approving and monitoring the implementation of investment-specific
EAs/EMPs for those investments which require it.
· Develop an Environmental Management Plan based on the activities proposed in
the project. The EMP should be written in a way to facilitate its incorporation into
40
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
the Project Implementation Manual. This EMP should focus on: Mitigation
measures, institutional strengthening and monitoring.
¾ Mitigation of environmental impact: Recommend feasible and cost-
effective measures to prevent or reduce significant negative impacts to
acceptable levels. Estimate the impacts and costs of those measures.
Consider compensation to affected parties for impacts that cannot be
mitigated.
¾ Institutional strengthening: Identification of institutional needs to
implement environmental assessment recommendations. Recommend any
additional support that should be provided to them so that the management
and monitoring plans in the environmental assessment can be
implemented.
¾ Monitoring: Prepare arrangements for monitoring mitigating measures and
the impacts of the project during implementation.
The description of these procedures should include:
· Description of any EA procedures required by Albanian and Montenegrin law,
including identification of which agencies or parties are responsible for each part
of these screening, approval, implementation and monitoring procedures
· An assessment of whether implementation of these legally required procedures
would be sufficient to fulfill WB requirements as well.
· To the extent that the legal national procedures are not sufficient to meet WB
requirements describe what additional procedures should be carried out under the
project in order to ensure WB requirements are met
· An assessment of the capacities of the various parties identified, to carry out their
responsibilities and where the capacity is not sufficient, give recommendations for
capacity building measures to be funded by the project.
V. KEY PROJECT STUDIES
The following studies and papers will be available to the consultants:
Social Assesments (Montenegro and Albania): treats the social economic situation of
the population in the catchments area, their means of living, natural resources and access
of different stakeholders to these resources, their improving or adverse impact on nature,
demography with regard to migration and emigration, cultural assessment, law
enforcement and perspectives of the area's sustainable development.
Social Action Plan Operationalizes the Social Assessment findings for the Strategic
Action Plan and the World Bank Project Appraisal Document. Its objectives were:
identify potential socio-economic impacts of the project and appropriate mitigation
measures; develop realistic socio-economic objectives, targets and indicators for the
project; identify mechanisms for effective communication/outreach and stakeholder
participation in project implementation; identify appropriate institutional arrangements
for implementation of activities at community level.
41
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Transboundary Diagnostic Analysis: a scientific-technical assessment of the state of
environment and the trends in natural resource use and condition in Lake Shkoder and its
watershed. It should identify and quantify the environmental threats to the lake, identify
options to address the identified problems and develop strategic recommendations for the
lake's conservation that fit the scope of the funding available for this project through the
GEF, gather relevant physical, chemical, biological, and legal data about the lake,
identify key natural resource and environmental data gaps and recommend the most
practical and cost effective ways to fill these data gaps, predict the most important
potential environmental impacts for altering lake water levels, the potential impacts to
critical fish spawning and bird habitats, the relative importance of overfishing,
destructive fishing practices, habitat change, and pollution as sources of the declines in
commercial fish populations in the lake, inventory farming practices in the watershed and
assess the impacts on water quality, propose a pathway towards a suitable, bilateral
management structure for Lake Shkoder
Strategic Action Programme: aimed to assist the government institutions and other
interested groups/institutions of Albania to define actions and projects in national level,
aiming to improve the environmental management and supporting sustainable economic
use of the natural resources of Shkodra Lake and its surrounding areas; to facilitate the
provision of information and its exchange among the stakeholders, to create a large-based
framework for future cross-border and cross-sectoral actions for the management of the
lake and to define and describe the initiatives and procedures that should be taken for
accomplishment of these objectives.
Assessment of the Management of Shared Lake Basins in Southeastern
Europe/Capacity Building Paper"
Additional scientific papers (see Attachment)
VI. RELEVANT LAWS IN ALBANIA.
· Law "On the Land" (1991)
· Law "On Seeds and Seedlings" (1992)
· Law "On Forests and Forestry Police" (1992)
· Law "On the Service of Plants Protection" (1993)
· Law "On Protection of Natural Medical, Ether Oil and Tanifer Plants" (1993)
· Law "On Protection of Wild Fauna and Hunting" (1994)
· Law "On Protection of Horticulture Trees" (1995)
· Law "On Fishing and Aquatic Life" (1995)
· Law "On Pastures and Meadows" (1995)
· Law "On Water Reserves" (1996)
· Law "On the Regulatory Framework of the Water Supply Sector and of Disposal
and Treatment of Waste Water (1996)
· Law "On Environment Protection" (2002)
· Law "On Protected Areas" (2002)
· Law "On Protection of Marine Environment from Pollution and Damage" (2002)
42
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
· Law "On Protection of Trans-border Lakes" (2003)
· Law "On Environmental Impact Assessment" (2003)
VII. RELEVANT NATIONAL AND LOCAL PLANS IN ALBANIA
· National Strategy for Tourism Development in Albania. Al Gov/WB
· Regional Economic and Social Development in the North of Albania and
Perspectives of European Integration.
· Local Environmental Action Plan (LEAP) for Shkodra. REC, 2005
· Strategy of Economic Development of Shkodra Municipality.WB
· Regional Plan for Shkodra Lezha 2005 2020. EPTIZA/EC
· Strategic Action Programme of Lake Shkoder WB/APAWA
VIII. RELEVANT INSTITUTIONS IN ALBANIA
· Ministry of Environment, Tirana,
· Regional Environmental Agency Shkodra
· University of Shkodra
· Maize and Rice Institute Shkodra
· Regional Environmental Center for Central and Eastern Europe (REC), Project
Office in Shkodra.
· University of Tirana, Faculty of Natural Sciences
· Hydrometeorological Institute of Academy of Sciences, Tirana,
IX. RELEVANT LAWS IN MONTENEGRO:
· Law on National Parks (Official Gazette of the RM, No.47/91, 27/94)
· Environmental Law (Official Gazette of the RM, No. 12/96, 55/00)
· Environmental Impact Assessment Decree (Official Gazette of the RM, No.
14/97)
· Law on Nature Protection (Official Gazette of the RM, No. 36/77,2/89)
· Decree on Protection of Rare, Scarced, Endemic and Endangered Plant and
Animal Species (Official Gazette of the RM, No.36/82)
· Law on Freshwater Fishery, (Official Gazette of the RM, No.
39/76,51/76,34/88,29/89,39/89,48/91, 4/92, 17/92, 27/94)
· Law on Waters (Official Gazette of the RM, No. 16/95)
· Decree to Prohibit the Use of Vessels with Engine Power more than 4.5 KS by
Physical Persons On Skadar Lake (Official Gazette of the RM, No.9/86)
· Decision on the Level and the Method of Payment of Charges for the Use of
National Parks Assets, for Conducting Economic Activities and Providing
Services (Official Gazette of the RM, No.31/02)
· Law on the Protection of Cultural Monuments (Official Gazette of the RM,
No.47/91)
43
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
· Law on Agricultural Land (Official Gazette of the RM, No.27/94)
· Law on Construction (Official Gazette of the RM, No.55/00)
· Law on Local Self-Government (Official Gazette of the RM, No.75/05)
· Law on Inspection (Official Gazette RCG, No.50/92).
X. MOST IMPORTANT LAWS THAT WILL BE IMPLEMENTED FROM
2008 IN MN:
· Law on Environmental Impact Assessment (Official Gazette of the RM, No.
80/05)
· Law on Strategic Impact Assessment (Official Gazette of the RM, No.80/05)
· Law on Integrated Prevention and Pollution Control (Official Gazette of the RM,
No.80/05).
XI. LIST OF RELEVANT PLANS AND PROGRAMS IN MONTENEGRO
· Physical Plan of Skadar Lake National Park (Official Gazette of the RM, No.
46/01)
· Program on Protection and Development of the Skadar Lake NP 2005-2010
· Master plan of Tourism Development, 2001
· Fishery Strategy, 2006
XII. RELEVANT ORGANIZATIONS IN MONTENEGRO
· Ministry of Tourism and Environmental Protection
· Public Enterprise National Parks of Montenegro
· Ministry of Agriculture, Forestry and Water Resources
· Ministry of Economic Development
· Local Authorities (3 municipalities: Podgorica, Bar and Cetinje)
· Nature Protection Institute
· Public Institution "Center for ecotoxicological researches"
· Hydrometeorological Institute
· Montenegrin Academy of Sciences and Arts
· Companies (Aluminum Plant etc.)
XIII. CONSULTANT'S REPORTING OBLIGATIONS
An inception report should be submitted two weeks after the contract signature, including
an annotated outline of the contents of the EA and EMP and describing the methodology
to be followed.
Draft final EA and EMP should be submitted four weeks after contract signature. This
report should be submitted in English (in hard copies and in electronic format).
44
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
The draft EA and EMP will be publicly disclosed in both Montenegro and Albania, and
the respective Project Coordinators will be responsible for providing the consultants with
any comments received from the public and will agree with the consultants on which
comments should be addressed/ incorporated in the final report. The consultant will
submit the final report within 2 weeks of receiving the comments.
XIV. CONSULTANT'S QUALIFICATIONS
The consultant should have:
· Technical knowledge of environmental issues relevant to the project
· Demonstrated experience in preparing EAs and EMPs for similar projects,
preferably including doing so in the context of projects to be financed by the
World Bank
· Previous familiarity with the relevant laws and regulations of the Republic of
Albania, and the Republic of Montenegro, will be an advantage.
· Good knowledge of the English Language
XV. DURATION OF THE ASSIGNMENT.
The assignment will require four weeks of work, to be completed within a period of 2
months. .
Attachment 1
Other Available Background Studies
· Dhora, Dh. & Sokoli, F. 2000. Liqeni i Shkodres Biodiversiteti [Shkodra Lake
the Biodiversity]. UNDP, GEF, SHRMMNSH. Shkoder.
· Dhora, Dh. 2005. Liqeni i Shkodres [Shkodra Lake]. Camaj-Pipa. Shkoder.
· Karaman, G. & Beeton, A. 1981. The Biota and Limnology of Lake Skadar.
Titograd.
· REC. 2003. Biodiversity database of Shkodra/Skadar Lake (Checklist of species
with their conservation status). REC project.
· REC. 2004. Roles and Responsibilities of Skadar/Shkodra Stakeholders in
Albania and Montenegro. REC project.
· Schneider-Jacoby, M., Dhora, D., Sackl, P., Savelic, D., Schwarz, U., Stumberger,
B., 2004. Rapid assessment of the ecological values of Buna/Bojana Delta.
EURONATURE, APAWA.
· Ziu, T. Filipovic, S. 2003. Final report on Skadar/Shkodra Lake Potentials and
Risks (REC project).
· Dhora, D.H. and F. Sokoli. 2000. Shkodra Lake Biodiversity. Available from
Shkodra University, Faculty of Natural Sciences, Shkodra, Albania. 80 pp. In
Albanian.
45
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
· Kashta, L. D. Dhora, F. Sokoli, M. Rakaj, M. Hoti, I. Beka, A. Bekteshi, T. Ziu
(Albania) and V. Pulevi , S. Had iablahovi , G. Kasom, J. Rako evi -Nedovi ,
S. Nik evi , V. Pesi , A. Ra natovi , R. irovi , D. Savelji ,V. Buskovi , B.
Micey, S. Filipovic, B. Fusti , M. Radulovi , and O. i i -Velimirovi .
(Montenegro). 2001. Bibliography on Shkodra/Skadar Lake. Published by the
Project for Promotion of Networks and Exchanges in the Countries of South East
Europe. 162 pp. Available from the World Bank
· Hoti, M., A. Bekteshi, I. Beka, F. Bushati, A. Neziri, N. Bushanti, and N. Dibra.
2002. Final Report for the Project "Integrated Monitoring of Shkodra Lake."
Available from Shkodra University, Faculty of Natural Sciences, Shkodra,
Albania. 31 pp.
· Hydrometeorological Institute of Montenegro. 2001. Monitoring of the quantity
and quality of the water of Skadar Lake from 1978-2001. In Serbian.
· Ziu, T. and S. Filipovic. 2001. Final Report on Skadar Lake Risks and Potentials.
Published by the Project for Promotion of Networks and Exchanges in the
Countries of South East Europe. 27 pp. Available from the World Bank
ANNEX B: CONSULTANT'S PERSONNEL
Mr. Ole K. Jensen, Team Leader
Mr. Jan Pock-Steen, Home Office Support
ANNEX C:
CONSULTANT'S REPORTING OBLIGATIONS
An inception report should be submitted two weeks after the contract signature, including
an annotated outline of the contents of the EA and EMP and describing the methodology
to be followed.
46
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Draft final EA and EMP should be submitted four weeks after contract signature. This
report should be submitted in English and Albanian language (in hard copies and in
electronic format).
The draft EA and EMP will be publicly disclosed in both Montenegro and Albania, and
the respective Project Coordinators will be responsible for providing the consultants with
any comments received from the public and will agree with the consultants on which
comments should be addressed/ incorporated in the final report. The consultant will
submit the final report within 2 weeks of receiving the comments.
47
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
AnneX 2 people met
Date Institution
People
met
15/02/07
· LSIEMP Secretariat, Mr. Agim Shimaj, Coordinator, Shkodra, Albania
Shkodra
20/02/07
· Regional
Ms. Djana Bejko, Project Manager
Environmental
Center, Shkodra
· University of
Dr. Marash Rakaj, Department of Biology-
Shkodra
Chemistry
21/02/07
· LSIEMP Secretariat, Mr. Viktor Subotic, Coordinator, Podgorica,
Podgorica
Montenegro
· Ministry of Tourism Mr. Sinisa Stankovic, Deputy Minister
and Environment
22/02/07
· Municipality of
Ms. Nada Mugosa, Head of Department for
Podgorica
Physical Planning and Environmental Protection
· Center for
Ms. Danijela Sukovic, Deputy Director
Ecotoxicological
Research of
Montenegro
· Hydrometeorological Mr. Radivoje Vuckovic, Vice Director
Institute of
Ms. Pavle Djuraskovic, Head of Department of
Montenegro
Environment
· Institute for the
Mr. Vasilije Buskovic, Associated Expert
Protection of Nature
Dr. Dragan Roganovic,
Ms. Jelena Simicevic,
Ms. Vesna Jovovic
23/02/07
· Ministry of
Mr. Zoran Jankovic, Director for Water
Agriculture,
Management Systems Department
Forestry and Water
Management
· Kombinat
Dr. Marat M. Mursalinov, Chief Specialist for
Aluminijuma
Ecology and Quality Control
Podgorica
(aluminium factory)
· National Park Skadar Mr. Zoran Mrdak, Director
Lake
26/02/07
· NGOs, Montenegro
Ms. Natasa Durakovic, "Green Home"
Mr. Aleksandar Drljevic, "Greens of Montenegro"
Mr. Darko Saveljic, "Center for the Protection and
Research of Birds"
Mr. Miodrag Lekovic, "Nvo Godinje"
27/02/07
· Regional
Mr. Dritan Dhora
Environmental
Agency, Shkodra
· Shkodra Fishery
Mr. Rasim Suma, Fishery Inspector
Inspection
48
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
· Municipality of
Mr. Ridvan Sokoli, Head of Economic
Shkodra
Development Office
28/02/07
· Institute of
Prof. Dr. Mitat Sanxhaku, Director
Hydrometeorology,
M. Sc. Emirjeta Adhami, Head of Environmental
Tirana
Deparment
· Ministry of
Dr. Samir Dedej, Director of Nature Protection
Environment,
Policy Directorate
Forestry, and Water
Administration
· University of Tirana Dr. Sajmir Beqiraj, Hydrobiologist, Faculty of
Science
· StEMA Project (EU) Ass. Prof. Gunnar Pritzl, Team Leader
49
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
1
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
ANNEX 3: Mitigation and Monitoring Plan
Mitigation and Monitoring Plan for construction of bicycle and hiking trails
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
The risk of
Supervision
destroying habitats
and
is very small, but
monitoring
Costs
the area to be used
should be
During
Costs
cannot be
for trails should be
done by the
construction
cannot be
estimated
properly
park
and at
estimated at
at this
n
investigated in
Park
management
finalization
this point,
point,
Management
in
of works.
c
t
i
o
order to avoid
before
before
Site
u
Destruction of habitats for
destroying habitats
or contractor
Montenegro.
Frequency
s
tr
endemic plants and animals.
placement
placement
inspection
n
for endemic plants
hired by Park
In Albania it
during
and lengths
and
Co
and animals. The
Management
is the
construction
of trails
lengths of
trails should be
Regional
will depend
have been
trails have
Park
placed, where any
Environment
on duration
decided.
been
Management
impact is
Agency, until
of works
decided.
minimized, without
a park
destroying the
management
purpose of the trail.
is in place
2
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
A minor and
temporary increase
in noise level will
occur as a result of
normal construction
activities associated
with trail
Elevated noise level and
development.
No extra
No extra
Site
disturbance of nesting birds
Construction should
costs
costs
inspection
occur during non-
peak visitor use or
on weekdays when
visitation is less,
and also take into
account the nesting
seasons.
Supervision
and
Clearing the
monitoring
vegetative cover
Costs
should be
During
will be necessary in
Costs
cannot be
done by the
construction
some locations.
cannot be
estimated
park
and at
This construction
estimated at
at this
management
Park
in
finalization
Vegetation clearance,
will alter some
this point,
point,
Management
Montenegro.
of works.
including possible removal
vegetation cover,
before
before
Site
or contractor
In Albania it
Frequency
of trees and shrubs
but the impact is
placement
placement
inspection
hired by Park
during
considered
and lengths
and
is the
Management
construction
minimal, if the
of trails
lengths of
Regional
Park
will depend
areas have been
have been
trails have
Environment
Management
on duration
properly
decided
been
Agency, until
of works
investigated before
decided
a park
forming the trails.
management
is in place
3
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
Once the initial trail
development is
Elevated noise level and
over, the level of
No extra
No extra
No
Site
disturbance of nesting birds
noise should be
costs
costs
installments
inspection
barely noticeable as
hikers disperse and
use the system.
Supervision
and
monitoring
Litter bins can be
Costs
should be
placed at regular
During
Costs
cannot be
done by the
intervals along the
construction
r
a
t
i
on
cannot be
estimated
park
pe
trails and a system
and at
estimated at
at this
management
O
should be set up to
Park
in
finalization
Potential problems with litter
this point,
point,
secure emptying on
Management
Montenegro.
of works.
from tourists using the
before
before
Site
a regular basis.
or contractor
In Albania it
Frequency
bicycle and hiking trails
placement
placement
inspection
Furthermore, park
hired by Park
during
and lengths
and
is the
regulations should
Management
construction
of trails
lengths of
Regional
emphasize that
will depend
have been
trails have
Environment
littering is not
on duration
decided
been
Park
Agency, until
allowed and will be
of works
decided
Management
a park
fined.
management
is in place
4
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
In some cases it
might be necessary
Supervision
to fence the
and
prohibition zones
monitoring
Costs
on land, as well as
should be
During
Costs
cannot be
putting warning
done by the
construction
cannot be
estimated
signs and mark the
park
and at
estimated at
at this
prohibition zones
Park
management
finalization
Providing easier access to
this point,
point,
with signs.
Management
in
of works.
prohibition zones at the
before
before
Site
Furthermore, the
or contractor
Montenegro.
Frequency
banks of the lake
placement
placement
inspection
rangers should
hired by Park
In Albania it
during
and lengths
and
control the trails
Management
is the
construction
of trails
lengths of
with regular
Regional
will depend
have been
trails have
Park
intervals and maps
Environment
on duration
decided
been
Management
in the park
Agency, until
of works
decided
regulations should
a park
indicate placements
management
of prohibition
is in place
zones.
5
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
A minor amount of
soil displacement
will occur due to the
Supervision
trail's construction.
and
Soil disturbance
monitoring
should be minimal
should be
and mitigated by
Costs
done by the
During
erosion control
Costs
cannot be
park
management
construction
Soil instability or changes in
devices and the
cannot be
estimated
in
and at
geologic substructure,
inclusion of
estimated at
at this
Park
Montenegro.
finalization
disruption, displacement,
switchbacks and
this point,
point,
Management
In Albania it
of works.
erosion, compaction, moisture
meanders on steep
before
before
Site
or contractor
is the
Frequency
loss, or over-covering of soil,
slopes. The trail
placement
placement
inspection
hired by Park
Regional
during
which would reduce
could result in some
and lengths
and
Management
Environment
construction
productivity or fertility
compacted, less-
of trails
lengths of
will depend
productive soil
have been
trails have
Agency, until
on duration
where it is being
decided
been
a park
of works
used. If further
decided
management
damage occurred
is in place
Park
during construction,
Management
that area could be
reseeded with e.g. a
native grass mix.
6
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
The potential for
Supervision
the spread of
and
noxious weeds may
monitoring
increase with
should be
enhanced visitor
done by the
Costs
use of the park on
park
During
Costs
cannot be
both sides. If not
management
construction
cannot be
estimated
existing, there
in
and at
estimated at
at this
might be a need for
Montenegro.
finalization
this point,
point,
Establishment or spread of
putting a Weed
In Albania it
of works.
before
before
Park
Site
noxious weeds
Control Plan in
is the
Frequency
placement
placement
Management
inspection
place. If noxious
Regional
during
and lengths
and
weeds exist in the
Environment
construction
of trails
lengths of
proposed trail
Agency, until
will depend
have been
trails have
areas, trail
a park
on duration
decided
been
completion could
management
of works
decided
actually assist park
is in place
Park
employees in their
Management
control by allowing
easier access into
the affected areas.
7
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
Supervision
and
monitoring
Costs
should be
During
Costs
cannot be
done by the
construction
Latrines should be
cannot be
estimated
park
and at
constructed at
estimated at
at this
management
Park
finalization
suitable places
this point,
point,
in
Fecal contamination of
Management
of works.
along the trails and
before
before
Montenegro.
Site
surrounding areas
or contractor
Frequency
a system for
placement
placement
In Albania it
inspection
hired by Park
during
cleaning at regular
and lengths
and
is the
Management
construction
intervals should be
of trails
lengths of
Regional
Park
will depend
set up.
have been
trails have
Environment
Management
on duration
decided
been
Agency, until
of works
decided
a park
management
is in place
8
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Mitigation and Monitoring Plan for construction of bird observation platforms
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
The risk of
destroying habitats
is very small, but
Supervision and
the area to be used
monitoring
for bird observation
should be done
platforms should be
Costs
by the park
During
properly
cannot be
Costs cannot
management in
construction
investigated in
estimated at
be estimated
Montenegro. In
and at
order to avoid
this point,
at this point,
Albania it is the
n
Park
finalization
destroying habitats
before
before
Regional
Management
of works.
c
t
i
o
placement,
placement,
Environment
Site
u
Destruction of habitats for
for endemic plants
or contractor
Frequency
s
tr
endemic plants and animals.
and animals. The
design and
dimensions
Agency, until a
inspection
n
hired by Park
during
placement of the
material of
and material
park
Co
Management
construction
platforms should be
the
of the
management is
Park
will depend
chosen with care,
platforms
platforms has
in place
Management
on duration
minimizing the
have been
been decided.
of works
potential negative
decided.
impacts, without
destroying the
purpose of the
observation
platforms.
9
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
A minor and
temporary increase
in noise level will
occur as a result of
normal construction
activities associated
with platform
At regular
Elevated noise level and
construction.
No extra
No extra
Site
intervals
disturbance of nesting birds
Construction should
costs
costs
inspection
during
occur during non-
construction
peak visitor use or
on weekdays when
visitation is less,
and also take into
account the nesting
seasons.
Clearing the
vegetative cover
will be necessary at
Costs
the chosen
Supervision and
During
cannot be
Costs cannot
locations for the
monitoring
construction
estimated at
be estimated
platforms.
This
should be done
and at
this point,
at this point,
by the park
Vegetation clearance,
construction will
Park
finalization
before
before
management in
including possible removal
alter some
Management
of works.
placement,
placement,
Montenegro. In
Site
of trees and shrubs
vegetation cover,
or contractor
Frequency
design and
design and
Albania it is the
inspection
.
but the impact is
hired by Park
during
material of
material of
considered
Management
Regional
construction
the
the platforms
minimal, if the
Park
Environment
will depend
platforms
have been
areas have been
Management
Agency, until a
on duration
have been
decided.
properly
park
of works
decided.
investigated before
management is
constructing the
in place
platforms.
10
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
There will be an
elevated noise level
in the operational
Costs
phase as well,
cannot be
Costs cannot
which makes the
estimated at
be estimated
choice of location
this point,
at this point,
Park
of the observation
before
before
Elevated noise level and
Management
Supervision and
even more
placement,
placement,
Site
r
a
t
i
on
disturbance of nesting birds
or contractor
monitoring
important. When
design and
design and
inspection
pe
hired by Park
should be done
O
maintained, colours
material of
material of
Management
by the park
matching the
the
the platforms
management in
background,
platforms
have been
Park
Montenegro. In
without light
have been
decided
Management
Albania it is the
reflecting surfaces
decided
or contractor
Regional
should be used for
hired by Park
Environment
the construction.
Management
Agency, until a
park
management is
in place
11
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
Litter bins should
Supervision and
be placed at the
monitoring
During
bird observation
should be done
construction
platforms, and a
by the park
and at
system should be
management in
Park
Montenegro. In
finalization
Potential problems with litter
set up to secure
Costs
Costs cannot
Management
Albania it is the
of works.
from tourists using the bird
emptying on a
cannot be
Site
be estimated
or contractor
Regional
Frequency
observation platforms
regular basis.
estimated at
inspection
at this point.
hired by Park
during
Furthermore, park
this point.
Park
Environment
Management
construction
regulations should
Management
Agency, until a
will depend
emphasize that
park
on duration
littering is not
management is
of works
allowed and will be
in place
fined.
In some cases it
might be necessary
to fence the
Supervision and
prohibition zones
monitoring
on land, as well as
should be done
During
marking the
by the park
construction
prohibition zones
management in
and at
with signs.
Park
Montenegro. In
finalization
Providing easier access to
Costs
Furthermore, the
Costs cannot
Management
Albania it is the
of works.
prohibition zones at the
cannot be
Site
rangers should
be estimated
or contractor
Regional
Frequency
banks of the lake
estimated at
inspection
control the bird
at this point.
hired by Park
Environment
during
this point.
observation
Management
Agency, until a
construction
platforms with
park
will depend
regular intervals
management is
Park
on duration
and maps in the
in place
Management
of works
park regulations
should indicate
placements of
prohibition zones.
12
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
During
maintenance of the
platform, spills of
Supervision and
the impregnating
monitoring
substances should
should be done
collected by plastic
by the park
Costs
covers on the
management in
During
cannot be
Costs cannot
ground or
Montenegro. In
construction
Risk of contamination of soil
estimated at
be estimated
foundation of the
Albania it is the
and at
during maintenance of
this point,
at this point,
platform. If made
Park
Regional
finalization
platform (cleaning and
before
before
of wood, not
Management
Environment
of works.
painting) and leakage of
placement,
placement,
Site
freshly impregnated
or contractor
Agency, until a
Frequency
impregnation substances
design and
design and
inspection
wood should be
hired by Park
park
during
from wooden building
material of
material of
used, but reused or
Management
management is
construction
materials
the
the platforms
reutilized wood
in place
will depend
platforms
have been
where leakage of
on duration
have been
decided.
impregnation
of works
decided
substances is
minimal, as some
Park
substances in
Management
impregnation are
toxic to the
environment.
13
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
The potential for
the spread of
noxious weeds may
increase with
enhanced visitor
Costs
use of the park on
Costs cannot
cannot be
During
both sides. If not
be estimated
estimated at
construction
existing, there
at this point,
Park
Supervision and
this point,
and at
might be a need for
before
monitoring
Management
before
finalization
putting a Weed
placement,
In Albania it
should be done
Establishment or spread of
placement,
of works.
Control Plan in
design and
is not likely
by the park
Site
noxious weeds
design and
Frequency
place. If noxious
material of
management in
to be made
inspection
material of
Park
during
weeds exist in the
the bird
before a
Montenegro. In
the bird
Management
construction
proposed placement
observation
management
Albania it is the
observation
will depend
of the platform,
platforms
Regional
is in place
platforms
In Albania it
on duration
platform
have been
Environment
have been
is not likely
of works
completion could
decided
Agency, until a
decided
to be made
actually assist park
park
before a
employees in their
management is
management
control by allowing
in place
is in place
easier access into
the affected areas.
Supervision and
monitoring
During
Costs
should be done
construction
cannot be
Costs cannot
by the park
Latrines should be
and at
estimated at
be estimated
management in
constructed at each
Park
finalization
this point,
at this point,
Montenegro. In
Faecal contamination of
bird observation
Management
of works.
before
before
Albania it is the
Site
surrounding areas
platform and a
or contractor
Frequency
placement
placement
Regional
inspection
system for cleaning
hired by Park
during
and lengths
and lengths
Environment
at regular intervals
Management
construction
of trails
of trails have
Agency, until a
should be set up.
will depend
have been
been decided
park
on duration
decided
management is
Park
in place
of works
Management
14
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
15
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Mitigation and Monitoring Plan for construction of visitor centers
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
A waste
management plan
should be prepared,
covering the whole
construction phase.
Costs
Waste containers
cannot be
Costs cannot
with locks could be
estimated at
be estimated
Contamination of
placed at the
Supervision and
this point,
at this point,
Contractor
Weekly
n
surroundings during
building site for
before
before
hired by the
monitoring
during
c
t
i
o
construction with all types of
different kind of
placement,
placement,
Park
should be done
Site
construction,
u
construction waste (building
waste, and frequent
by the park
s
tr
design and
design and
Management
inspection
and at
n
materials, packaging,
inspections should
material of
material of
or Project
management in
decommissio
Co
solvents, paints, plastic, etc.)
be done by the
the visitor
the visitor
Secretariat
Park
Montenegro. In
ning
monitoring
center have
center have
management
Albania it is the
authority. A special
been
been decided.
Regional
container should be
decided.
Environment
made for hazardous
Agency, until a
waste, incl.
park
solvents, paints,
management is
and other toxic
in place
chemicals.
16
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
The risk of
destroying habitats
is very small, but
Supervision and
the area to be used
monitoring
for visitor centers
should be done
should be properly
by the park
investigated in
management in
Costs
order to avoid
Montenegro. In
During
cannot be
Costs cannot
destroying habitats
Albania it is the
construction
estimated at
be estimated
for endemic plants
Regional
and at
this point,
at this point,
and animals. The
Park
Environment
finalization
before
before
placement of the
Management
Agency, until a
of works.
Destruction of habitats for
placement,
placement,
Site
centers should be
or contractor
park
Frequency
endemic plants and animals.
design and
dimensions
inspection
chosen with care,
hired by Park
management is
during
material of
and material
Park
minimizing the
Management
in place
construction
the visitor
of the visitor
Management
potential negative
will depend
center have
center have
impacts. The visitor
on duration
been
been decided.
centers do not have
of works
decided.
to be placed close
to prohibition areas
but should be
placed near access
roads, as parking
should be available
for visitors.
17
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
A minor and
temporary increase
in noise level will
occur as a result of
normal construction
activities associated
with center
Elevated noise level and
construction.
No extra
No extra
Site
general disturbance
Construction should
costs
costs
inspection
occur during non-
peak visitor use or
on weekdays when
visitors are fewer.
Other mitigation
measures are not
necessary.
Clearing the
vegetative cover
may be necessary at
Costs
Supervision and
the chosen location
Costs cannot
cannot be
monitoring
for the center.
be estimated
During
estimated at
should be done
This construction
at this point,
by the park
construction.
Vegetation clearance,
this point,
Park
will alter some
before
management in
Frequency
including possible removal
before
Management
vegetation cover,
placement,
Montenegro. In
Site
during
of trees and shrubs
placement,
or contractor
but the impact is
design and
Albania it is the
inspection
construction
.
design and
hired by Park
considered
material of
will depend
material of
Management
Regional
minimal, if the
the center
on duration
the center
Park
Environment
areas have been
have been
of works
have been
Management
Agency, until a
properly
decided.
decided.
park
investigated before
management is
constructing the
in place
center.
18
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
There will be an
elevated noise level
in the operational
phase as well,
which makes the
Costs
choice of location
cannot be
Costs cannot
of the visitor center
estimated at
be estimated
important. No
this point,
at this point,
mitigation
Park
before
before
Elevated noise level and
measures are
Management
Supervision and
placement,
placement,
Site
r
a
t
i
on
general disturbance
necessary, but it
or contractor
monitoring
design and
design and
Park
inspection
pe
could be mentioned
hired by Park
should be done
O
material of
material of
in the park
Management
Management
by the park
the visitor
the visitor
regulations that
or contractor
management in
center have
center have
noisy behaviour is
hired by Park
Montenegro. In
been
been decided
generally not
Management
Albania it is the
decided
accepted inside the
Regional
park and destroys
Environment
the chances for
Agency, until a
observing wildlife
park
at close range.
management is
in place
19
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
Supervision and
monitoring
should be done
by the park
staff in
Litter bins should
Montenegro.
be placed at the
visitor center, and a
system should be
Park
In Albania, the
Only
set up to secure
Park
Management
rangers will
Potential problems with litter
Costs
considered a
emptying on a
Costs cannot
Management
have the
from tourists using the
cannot be
Site
problem in
regular basis.
be estimated
or contractor
responsibility.
visitor center
estimated at
inspection
the
Furthermore, park
at this point.
hired by Park
this point.
The overall
operational
regulations should
Management
responsibility
phase.
emphasize that
will be the
littering is not
Regional
allowed and will be
Environment
fined.
Agency, until a
park
management is
in place
20
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
The visitor centers
should be equipped
with proper
sanitation facilities,
The cost of
taking care of
either a
The cost of
domestic waste
mini waste
either a mini
water. It can either
water
waste water
be in the form of a
During
treatment
treatment
mini waste water
construction
plant or a
plant or a
treatment plant, as
and at
Problems with domestic
septic tank
septic tank
installed in the
Park
decommissio
waste water from toilets at
solution
solution
existing visitor
Management
Supervision and
ning.
the centers, if no proper
cannot be
cannot be
Site
center in Skadar
or contractor
monitoring
Frequency
sanitation solutions have
estimated,
estimated,
inspection
Lake National Park
hired by Park
should be done
during
been installed
without
without
in Montenegro, or a
Management
by the park
construction
knowing
knowing the
modern septic tank.
management in
will depend
the design
design and
If a septic tank
Park
Montenegro. In
on duration
and the
the planned
solution is chosen,
Management
Albania it is the
of works
planned
capacity of
a system for
in
Regional
capacity of
the visitor
emptying the tank
Montenegro.
Environment
the visitor
center.
should be set up,
In Albania,
Agency, until a
center.
transporting the
the Ministry
park
sludge to a safe
until a park
management is
disposal site
management
in place
outside the park.
is in place.
21
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Mitigation and Monitoring Plan for remediation of hazardous waste dump site at KAP
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
The pre-
investigatio
n is
Pre-investigation or
The budget
estimated to
To be
technical feasibility
for the
cost app.
determined.
study, determining
remediation
During
80-100,000
If the landfill
content and amount
and the
constructi
US dollars.
will not
of waste, including
construction
on and
The budget
serve other
n
options for removal
and the
operation.
for the
Contractor
operation of
than KAP
Frequency
c
t
i
o
and design of
construction
hired by the
Site
u
Determination of content
Aluminium
hazardous waste
the landfill
during
s
tr
and amounts of waste
of the land
Project
Plant, it
inspection
n
landfill. Any
cannot be
constructi
fill and the
Secretariat
could be the
Co
placement of the
determined
on will
clean up
Municipality
landfill will have to
before the
depend on
cannot be
of Podgorica.
be consistent with
pre-
duration
determined
If it is placed
the Spatial Plan for
investigation
of works
before the
Ministry of
on the
Podgorica
has taken
pre-
Tourism and
premises of
Municipality
place.
investigatio
Environment
KAP, they
n has taken
will operate
place.
it.
22
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
To be
During the
determined.
movement of the
If the landfill
contaminated soil,
will not
The costs
modest spraying
The costs
serve only
cannot be
with water can be
cannot be
KAP
estimated,
done, if dust is a
estimated,
Aluminium
Movement of hazardous
before
Contractor
Remediati
problem. The waste
before
Plant, it
waste will create dust and
amounts
hired by the
Site
on and
is not considered a
amounts and
could be the
spread the contaminated
and type of
Project
inspection
movement
serious health
type of waste
Municipality
soil to adjacent land.
waste has
Secretariat
phase
hazard, but the
has been
of Podgorica.
been
proposed pre-
properly
If it is placed
properly
Ministry of
investigation will
determined
on the
determined.
Tourism and
determine the type
premises of
Environment
of mitigation
KAP, they
necessary.
will operate
it.
It is proposed to do
the movement in
the months with
lesser precipitation,
During
e.g. during the
In case of movement in a
constructi
spring and summer.
season with increased
on.
If water is still a
It will not
It will not
precipitation, increased
Contractor
Frequency
problem, water
add costs to
add costs to
KAP, if it is
Ministry of
leakage of contaminants to
hired by the
during
leaking to the
do it during
do it during
within their
Tourism and
groundwater and
Project
constructi
bottom of the
the spring
the spring
premises.
Environment
subsequently to the river
Secretariat
on will
excavation can be
and summer
and summer
and from there to the lake
depend on
pumped to a tanker,
duration
which should be
of works
emptied at a place,
where the water
will not go to the
lake
23
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
According to
information from
In case of capping with
No extra
Montenegro, the
No extra
impermeable membrane,
costs are
risk for flooding is
costs are
Contractor
risk for spreading to
implicated
During
very modest. It
implicated
hired by the
Site
adjacent land and the river
by proper
constructi
should be possible
by proper
Project
KAP, if it is
Ministry of
inspection
in case of flooding or
placement
on.
to avoid landslides
placement of
Secretariat
within their
Tourism and
landslide
of the
by proper
the landfill.
premises.
Environment
landfill.
placement of the
landfill.
The
The costs of
Leachate,
a leachate
which is a
The costs of
control
liquid that
r
a
t
i
on
a leachate
pe
system
has passed
control
O
should be
through or
system
determined
emerged
Contamination of
A leachate control
should be
when type
Contractor
from the
groundwater resulting from
system should be
determined
of
hired by the
KAP, if it is
landfill
4-6 times
leachate that can leak
put in place, with
when type of
contaminati
Project
within their
waste,
per year
through the liner system.
regular monitoring
contaminatio
on, amount
Secretariat
should be
of leachate
n, amount of
premises, or
of material,
analyzed for
material, and
contractor
Ministry of
and
relevant
placement of
hired by the
Tourism and
placement
contaminants
landfill has
Project
Environment or
of landfill
determined
been decided
Secretariat
contractor hired
has been
as a result of
by it.
decided.
the pre-
investigation
24
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
The Municipality
of Podgorica
should be part of
the preparations for
Before
Consistency with the
the pre-
Consistency
final
overall land-use planning in
investigation, and
No extra
No extra
Municipality
with spatial
approval
the area.
they should ensure
costs.
costs.
of Podgorica
plan should
of
that the placement
be checked
placement
of the landfill will
Ministry of
of landfill
be consistent with
Tourism and
the spatial plan for
Environment
Podgorica.
Allocation of
sufficient land for
No extra
No extra
landfill. Depends
costs within
costs within
Landfill not large enough to
on reliable
Before
KAP
KAP
KAP, if it is
accommodate the
production figures
Contractor
final
premises.
premises.
within their
hazardous waste from KAP
from KAP and
hired by the
Site
approval
Outside
Outside
premises, or
for a reasonable time (10 to
whether others than
Project
inspection
of
depending
depending
contractor
30 years).
KAP will be
Secretariat
placement
on area of
on area of
hired by the
allowed to use the
of landfill
land to be
land to be
Project
Ministry of
landfill for
used.
used.
Secretariat
Tourism and
hazardous waste
Environment
disposal.
25
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Mitigation and Monitoring Plan for treatment of wastewater from small lakeside villages and isolated restaurants
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
A waste
management plan
should be prepared,
Supervision
covering the whole
and
construction phase.
monitoring
Waste containers
. Costs
should be
During
Costs
with locks could be
cannot be
done by the
construction
cannot be
Contamination of
placed at the
estimated
park
and at
estimated at
n
surroundings during
building site for
at this
Park
management
finalization
this point,
point,
Management
in
of works.
c
t
i
o
construction with all types of
different kind of
before
Site
u
construction waste
waste, and frequent
before
or contractor
Montenegro.
Frequency
s
tr
technical
inspection
n
(packaging, solvents, paints,
inspections should
technical
hired by Park
In Albania it
during
feasibility
Co
plastic, etc.)
be done by the
feasibility
Management
is the
construction
study has
monitoring
study has
Regional
will depend
been
Park
authority. A special
been
Environment
on duration
prepared.
Management
container should be
prepared.
Agency, until
of works
made for hazardous
a park
waste, incl.
management
solvents, paints,
is in place
and other toxic
chemicals.
26
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
Supervision
and
Different solutions
monitoring
for treating
should be
wastewater should
Costs
During
Costs
done by the
be considered,
cannot be
construction
cannot be
park
Contamination of the lake
including sand
estimated
and at
estimated at
management
with domestic waste water,
filters, mini
at this
Park
finalization
this point,
in
containing fecalia, pathogens
wastewater
point,
Management
of works.
before
Montenegro.
Site
and contaminants (e.g.
treatment plants,
before
or contractor
Frequency
technical
In Albania it
inspection
detergents, disinfectants,
and modern septic
technical
hired by Park
Park
during
feasibility
is the
chlorine, etc.)
tanks. If septic tank
feasibility
Management
management
construction
study has
Regional
solutions are used,
study has
will depend
been
Environment
a system for
been
on duration
prepared.
Agency, until
emptying the tanks
prepared.
a park
of works
should be put in
management
place.
is in place
27
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
Supervision
First of all, and
and
environmental
monitoring
awareness
should be
campaign is
done by the
necessary in order
Park
park
Costs
During
to stop new
Costs
management
management
cannot be
construction
construction
cannot be
and Regional
and
estimated
and at
projects on
estimated at
Environment
municipalitie
Destruction of recreational
at this
finalization
primarily the
this point,
al Agency in
s in
values because of odours,
point,
of works.
Albanian side of
before
Albania. Park
Park
Montenegro.
Site
tainting of the water at
before
Frequency
the lake. Secondly,
technical
management
management
In Albania it
inspection
outlets, etc.
technical
during
the local
feasibility
and
and Regional
is the
feasibility
construction
environmental
study has
Montenegrin
Environment
Regional
study has
will depend
authorities on both
been
municipalitie
al Agency in
Environment
been
on duration
sides of the lake
prepared.
s around the
Albania. Park
Agency, until
prepared.
of works
prepare a
lake
management
a park
prioritization list of
and
management
possible projects,
Montenegrin
is in place
pinpointing
municipalitie
hotspots
s around the
lake
The local
environmental
authorities on both
Monitoring
sides of the lake
teams from
Regional
Monitoring
should see to it that
the different
Environment
teams from
Collect
the future
institutions.
al Protection
the different
Once per
samples of
monitoring
Shkodra
Agency in
institutions.
month or in
water and
Health risks near outlets
programme
No extra
No extra
University in
Albania and
Shkodra
line with
r
a
t
i
on
analyze them
analyses water
costs
costs
Albania and
frequency for
pe
municipalitie
University in
for relevant
O
samples for E. coli
Center for
s around the
Albania and
other
bacteriologic
and coliforme
Ecotoxicolog
lake in
Center for
parameters
al parameters
bacteria in order to
ical Research
Montenegro
Ecotoxicolog
be able to give the
in
ical Research
public information
Montenegro
in
on health risks in
Montenegro
the lake
28
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
Cost
Institutional Responsibility
Monitoring
e
as
Issue
Mitigating Measure
h
P
Install
Operate
Install
How
When
Operate
Monitoring
Monitoring
Monitoring
teams from
teams from
the different
the different
institutions.
Oxygen content
institutions.
Hydrometeor
Once per
should continue to
Hydrometeor
Regional
ological
Oxygen depletion because of
month or in
be part of the
ological
Environment
Institute in
high organic content in waste
No extra
No extra
Analysis on
line with
monitoring
Institute in
al Protection
Albania and
water
costs
costs
water sample
frequency for
programmes and be
Albania and
Agency in
Center for
other
measured on a
Center for
Albania and
Ecotoxicolog
parameters
regular basis
Ecotoxicolog
municipalitie
ical Research
ical Research
s around the
in
in
lake in
Montenegro
Montenegro
Montenegro
Supervision
and
monitoring
As mentioned
should be
Costs
During
above, different
Costs
done by the
cannot be
construction
solutions for
cannot be
park
estimated
and at
treating the
estimated at
management
at this
Park
in
finalization
Eutrophication because of
wastewater should
this point,
point,
Management
Montenegro.
of works.
high phosphorus content of
be considered,
before
Site
before
or contractor
In Albania it
Frequency
waste water
including sand
technical
inspection
technical
hired by Park
Park
during
filters, mini
feasibility
is the
feasibility
Management
management
construction
wastewater
study has
Regional
study has
will depend
treatment plants,
been
Environment
been
on duration
and modern septic
prepared.
Agency, until
prepared.
of works
tanks.
a park
management
is in place
29
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
30
Environmental Impact Assessment of the Lake Skadar/Shkodra Integrated Ecosystem Management Project
Final Report
31