1. Italian Committee of United Cities (CICU) PHARE - twinning Project SK02/IB/EN01 Slovak Hydrometeorological Institute Amendment of Pollution Reduction Programme Administrative measures on Monitoring, Revision of DS list, EQSs, Emission Limits, Derogation

2. Italian Committee of United Cities (CICU) PHARE - twinning Project SK02/IB/EN01 Slovak Hydrometeorological Institute Amendment of Pollution Reduction Programme 1.Set up of a specific monitoring of dangerous substances (relevant and potentially relevant) to explore actual concentrations and trends (network, frequency, competent authorities)

3. Italian Committee of United Cities (CICU) PHARE - twinning Project SK02/IB/EN01 Slovak Hydrometeorological Institute Amendment of Pollution Reduction Programme 2.Periodical revision of the list of relevant and potentially relevant substances (5 years). Accounting of results of DS monitoring establishment of new EQSs or their revision recent statistics of market/production of DS The list of relevant and potentially relevant substances will likely be updated to current status

4. Italian Committee of United Cities (CICU) PHARE - twinning Project SK02/IB/EN01 Slovak Hydrometeorological Institute Amendment of Pollution Reduction Programme 3.Technical Committee appointed to: –Propose the 17 missing EQSs of relevant DS, according to the procedure stated by WFD (Annex V, point 1.2.6) –Proposal of provisional EQSs, defined according to expert judgement, when data for the procedure required by WFD are lacking –Periodical re-examination of the list of DS as of point 2, above

5. Italian Committee of United Cities (CICU) PHARE - twinning Project SK02/IB/EN01 Slovak Hydrometeorological Institute Amendment of Pollution Reduction Programme –Design of a national Data Base for dangerous pollutants and toxicological and ecotoxicological data

6. Italian Committee of United Cities (CICU) PHARE - twinning Project SK02/IB/EN01 Slovak Hydrometeorological Institute Amendment of Pollution Reduction Programme 4.Chapter 6.2.1 of PRP “Calculation of Limit Pollution Values”: The formula for the calculation of emission limits should be given for transparency

7. Italian Committee of United Cities (CICU) PHARE - twinning Project SK02/IB/EN01 Slovak Hydrometeorological Institute Amendment of Pollution Reduction Programme Maximum allowable load of the substance at a point discharge (mass/time) Discharge flow rate Number of discharges of the same DS in the same water basin River flow rate at the discharge point

8. Italian Committee of United Cities (CICU) PHARE - twinning Project SK02/IB/EN01 Slovak Hydrometeorological Institute Amendment of Pollution Reduction Programme 5.Possibility to give derogation. The set up of EQS-based emission limits will result in three different pictures: Industrial sites with no need of reducing their current emission (no need of derogation) Industrial sites with a discharge of the same order of magnitude of “our” predicted safe emission limits (possible need of derogation) Industrial sites that cannot to comply with the DS emission (need of derogation)

9. Italian Committee of United Cities (CICU) PHARE - twinning Project SK02/IB/EN01 Slovak Hydrometeorological Institute Amendment of Pollution Reduction Programme 5.Possibility to give derogation. a)Industrial sites with a discharge of the same order of magnitude of “our” predicted safe emission limits That means: some plants able to improve their process up to full compliance, others in the need to get some kind of support for technical improvement

10. Italian Committee of United Cities (CICU) PHARE - twinning Project SK02/IB/EN01 Slovak Hydrometeorological Institute Amendment of Pollution Reduction Programme 5.Possibility to give derogation. b)Industrial sites that cannot comply with the DS emission due to extremely low EQS and/or small recipients and/or STRONG technical limits Derogation could be avoided only by: Diversion of the outlet to greater recipients Revision of the specific EQSs End of the process responsible for emission

11. Italian Committee of United Cities (CICU) PHARE - twinning Project SK02/IB/EN01 Slovak Hydrometeorological Institute Amendment of Pollution Reduction Programme 5.Possibility to give derogation. In any case the compulsory requirements for derogations should be: No derogation is allowed for any of the 25 priority hazardous substances (Decision 2455/2001 EC) TIME derogation for a period to be determined case-by- case, can be given IF the application of BAT is ongoing AND/OR investments on environmental technology are demonstrated TIME derogation can also be given until an EQS is under revision

12. Italian Committee of United Cities (CICU) PHARE - twinning Project SK02/IB/EN01 Slovak Hydrometeorological Institute Amendment of Pollution Reduction Programme 5.Possibility to give derogation. PERMANENT TIME OR AREA derogation is the extreme measure and must be limited only to: substances outside of the Decision 2455/2001 EC when all the above measures are unsuccessful or unfeasible and the reference EQS is not exceeded AT END OF BASIN

13. Italian Committee of United Cities (CICU) PHARE - twinning Project SK02/IB/EN01 Slovak Hydrometeorological Institute Amendment of Pollution Reduction Programme 5.Possibility to give derogation. Other requirements: Compulsory fulfilment of article 4, point 4 of WFD Derogation should be excluded in Protected Areas.

14. Italian Committee of United Cities (CICU) PHARE - twinning Project SK02/IB/EN01 Slovak Hydrometeorological Institute Amendment of Pollution Reduction Programme 5.Possibility to give derogation. Other requirements: Reasons and duration of derogation should be technically and economically based and demonstrated reporting to competent authority. The measures adopted to achieve the environmental objective and the compliance to the limit of discharge and to the Eqs, should be clearly reported.

15. Italian Committee of United Cities (CICU) PHARE - twinning Project SK02/IB/EN01 Slovak Hydrometeorological Institute Amendment of Pollution Reduction Programme 5.Possibility to give derogation. Final comments In allowing permanent time or area derogation, a political debate should carefully weight the advantages to preserve employment and, more generally, welfare against the drawbacks on environment and public health