safe adria action plan vpa 310112

SAFE ADRIA Project – Action Plan – Pag. 1

SAFE ADRIA Project

Action Plan

Venice, February 2012


Index

1. General introduction .................................................................................................... 4 1.1 Objectives and targets .................................................................................. 4 1.2 Principles ...................................................................................................... 4 1.3 Policies and strategies .................................................................................. 5 1.4 Development axes ........................................................................................ 6 1.5 Structure of the Action Plan ......................................................................... 6

2. Ship generated waste and cargo residues management ............................................. 7 2.1 International Convention MARPOL .............................................................. 7 2.2 European legal framework ........................................................................... 7 2.3 Italian legal framework ............................................................................... 10 2.4 Local legal framework ................................................................................. 13 2.5 Practices developed in the Port of Venice - Ship generated waste and cargo

residues management ...................................................................................... 13 2.6 References to the Montenegrin legislative framework .............................. 17

3. Environmental measurements “port box”: best practices on air, water, energy ...... 18 3.1 International Convention MARPOL ............................................................ 18 3.2 European legal framework on environmental aspects to be measured .... 18 3.3 Italian laws on environmental aspects to be measured ............................. 21 3.4 Local legal framework ................................................................................. 23 3.5 Practices developed in the Port of Venice .................................................. 24 3.6 References to the Montenegrin legislative framework .............................. 31


1. General introduction

The present document has been prepared within the framework of the SAFE ADRIA

project. The drafting of the Action Plan is enclosed in the Activities 2.2 of the Work

Package 2 “Environment protection experiences and action plan”.

SAFE ADRIA Project aims at transferring to Luka Bar practices related to the do-

mains of environment protection developed in the Port of Venice.

This aim will be achieved with cooperative actions between Venice Port Authority

and Luka Bar to improve the capacity in domains of environmental protection in

ports’ activities in Luka Bar, which is currently undergoing a significant port reform.

Indeed port development and environmental protection go hand in hand.

On the other side, environmental sustainability is one of the Venice Port Authori-

ty's main objectives, encouraging it to sponsor projects to cut the environmental

impact of port operations on the city and the lagoon. The goal is pursued through

the “Green Port” policy, that is not simply a slogan or a wish: on the contrary, it

summarizes a concept that revolutionizes the way the port is traditionally con-

ceived and translates into a range of concrete actions. These actions have been

strenuously encouraged by the Venice Port Authority over recent years, and cover

four main areas: air, water, soil, energy.

To that extent is important for Luka Bar, to acquire much knowledge as possible, on

the organization of the port activities, in various domains including environmental

protection.

1.1 Objectives and targets

The main objectives of environmental protection are:

• preservation of human health, ecosystems, natural sites and spatial resources

as well as cultural heritage and anthropogenic resources;

• providing conditions for sustainable management of nature, preservation of

quantity and quality of natural resources as well as preventing dangers and

threats to the environment.

These objectives can be achieved by an efficient interaction and by the exchange of

experiences between the structures involved.

1.2 Principles

Some common and basic principles that underlie the initiatives of environmental

protection are:

• Preservation of natural values - it is essential to maintain or increase quality of

air, water, sea and soil;


• Biological Diversity - preventing any activity that could have harmful effect to

the biological diversity of living organisms and natural properties of eco-

systems;

• Risk Reduction - measures shall be taken as to prevent or to limit the activities

which pose unavoidable risk or danger to the environment;

• Re-use and recycling - re-usable, recyclable or biologically degradable sub-

stances shall have precedence cost-effectively;

• Polluter pays - any polluter shall pay a real price for the harm done to the envi-

ronment;

• Information accessibility - information and policy pertaining to the quality of the

environment are public. Everyone has the right to be informed about the envi-

ronmental quality and to participate in the decision-making process, the im-

plementation of which, may have adverse effects on the environment.

1.3 Policies and strategies

The objectives of the environmental protection shall be acquired by means of the

following activities:

• introduction of environmental education;

• prevention, limitation, monitoring of harmful effects;

• protection of compromised areas, trying to improve their quality;

• maintaining a balanced relationship between the economic development and

environmental protection;

• implementation of technologies able to ensure preservation and protection of

the environment and energy-efficient technologies;

• gradual transition to renewable sources of energy;

• fostering research activities and strengthening institutional organization in field

of the environment at all levels segments thereof;

• informing public on the quality of the environment.

Some of these have already been implemented by Venice Port Authority, through

the strategy “Green Port” concerning:

• energy efficiency of port activities;

• collection of stormwater;

• improving ship waste management procedures and treatment;

• improvement air quality, including projects for “zero emissions”;

• ensure full operation and development opportunities to port activities without

damaging the delicate lagoon system.


1.4 Development axes

The present project belongs to the Know-how Exchange Program (KEP) which is a

grant facility created in 2004 to support transfer of best practice and transforma-

tion experience between partners in order to strengthen the economic develop-

ment together with environmental sustainability.

It acts toward two ways.

One way is to give an active support to the project partner in its field of interest, for

example passing on projects or programs aimed at minimizing the impact of port

activities on the surrounding area and projects or regarding sustainable develop-

ment. This is partially translated in the realization of an Action Plan.

Another way is promoting the collaboration among institutions in member coun-

tries.

1.5 Structure of the Action Plan

The Action Plan is divided into two parts, corresponding to the main actions

planned.

Action 1 regards ship generated waste and cargo residues management, while Ac-

tion 2 consists on a “box” of best practices and actions implemented by Venice

Port, which could be shared by the two partners.

Every action has a title, which briefly defines what is to be done; the relative con-

tents are clearly described and there are indicated the expected results. Also the

institutions in charge are indicated: they are the responsible for performing the ac-

tion envisaged, completing the actions and reporting in time.


2. Ship generated waste and cargo residues management

2.1 International Convention MARPOL

The MARPOL Convention for the Prevention of Pollution from Ships is the main in-

ternational convention covering prevention of pollution of the marine environment

by ships from operational or accidental causes. The Convention was adopted on 2

November 1973 at IMO and covered pollution by oil, chemicals, harmful substances

in packaged form, sewage and garbage. As the 1973 MARPOL Convention had not

yet entered into force, the 1978 MARPOL Protocol absorbed the parent Conven-

tion. The combined instrument is referred to as the International Convention for

the Prevention of Marine Pollution from Ships, 1973, as modified by the Protocol of

1978 relating thereto (MARPOL 73/78), and it entered into force on 2 October 1983

(Annexes I and II). In 1997 a Protocol was adopted to add a new Annex VI.

The Convention includes regulations aimed at preventing and minimizing pollution

from ships, includes the following Annexes related to ship waste.

Annex I - Regulations for the Prevention of Pollution by Oil (entered into force 2

October 1983): it covers prevention of pollution by oil from operational measures

as well as from accidental discharges. The 1992 amendments to Annex I made it

mandatory for new oil tankers to have double hulls and brought in a phase-in sche-

dule for existing tankers to fit double hulls, which was subsequently revised in 2001

and 2003.

Annex IV - Prevention of Pollution by Sewage from Ships (entered into force 27

September 2003): it contains requirements to control pollution of the sea by se-

wage.

Annex V - Prevention of Pollution by Garbage from Ships (entered into force 31 De-

cember 1988): it deals with different types of garbage and specifies the distances

from land and the manner in which they may be disposed of. The requirements are

much stricter in a number of "special areas" but perhaps the most important fea-

ture of the Annex is the complete ban imposed on the dumping into the sea of all

forms of plastic.

2.2 European legal framework

Directive 2000/59/EC on Port reception facilities for ship-generated waste and

cargo residues

The Directive pursues the same aim as the 73/78 Marpol Convention on the pre-

vention of pollution by ships, which all the Member States have signed. However,

in contrast to the Convention, which regulates discharges by ships at sea, the Direc-

tive focuses on ship operations in European Union ports. It addresses in detail the


legal, financial and practical responsibilities of the different operators involved in

delivery of ship-generated waste and cargo residues.

Ships

This Directive covers:

• all ships, whatever their flag, including fishing vessels and recreational craft,

putting in at a Member State port, apart from warships and ships belonging to

or operated by a State for non-commercial governmental purposes;

• all Member State ports.

Port reception facilities

Member States must ensure that port reception facilities are provided which meet

the needs of the ships using them without causing abnormal delays. These facilities

must be tailored to the size of the port and to the categories of ship calling there.

Waste reception and handling plans

A waste reception and handling plan must be drawn up in each port. These plans

must be approved and assessed by the Member State it relates to. The plans must

be re-approved at least every three years.

Notification

Captains of ships (other than fishing boats and recreational craft authorised to car-

ry no more than 12 passengers) bound for a Community port are required to notify

certain information, in particular the date and the last port in which ship-generated

waste was delivered and the quantity of waste remaining on board.

Delivery of ship-generated waste

Unless exempted, all ships are required to deliver their ship-generated waste be-

fore leaving a Community port, unless the captain can prove that his vessel has

adequate storage capacity. Ships which do not deliver their waste without provid-

ing valid reasons for exemption are not allowed to leave the port until such delivery

has taken place.

Fees for ship-generated waste

Ports must establish cost recovery systems to encourage the delivery of waste on

land and discourage dumping at sea. All ships calling at a Member State port will

bear a significant part of the cost (which the Commission interprets as meaning at

least 30%), whether they use the facilities or not. This cost recovery system com-

prises this built-in, fixed element and, possibly, a variable element according to the

amount and type of waste actually delivered.

Inspections

Ships operating in an EU port may be inspected. There is a 25 % minimum inspec-

tion requirement. Inspections are carried out on ships which have not complied

with the notification requirement and on those suspected of not having delivered

their waste as a priority.

Where it is proven that a ship has put to sea without having delivered its waste and

without benefiting from an exemption, the next port of call is alerted. Moreover,


the ship will not be authorised to leave the second port without the situation hav-

ing been assessed.

Accompanying measures

This Directive provides for a series of accompanying measures. In particular, it pro-

vides for ships that have been unduly delayed owing to the inadequacy of recep-

tion facilities, while they themselves meet the requirements to which they are sub-

ject, must receive compensation.

Evaluation

Every three years, Member States must send the Commission a status report on

the implementation of the Directive, following which the Commission must submit

an evaluation report on the operation of the system to Parliament and the Council.

REFERENCES

Act Entry into

force

Deadline for

transposition in

the Member

States

Official Journal

Directive

2000/59/EC 28.12.2000 28.12.2002 OJ L 332 of 28.12.2000

Amending act(s) Entry into

force

Deadline for

transposition in

the Member

States

Official Journal

Directive

2002/84/EC 29.11.2002 29.11.2003 OJ L 324 of 29.11.2002

Directive

2007/71/EC 13.12.2007 15.06.2009 OJ L 329 of 14.12.2007

Regulation (EC)

No. 1137/2008 11.12.2008 - OJ L 311 of 21.11.2008

Directive 2000/76/EC on the incineration of waste

The aim of the WI Directive is to prevent or to reduce as far as possible negative

effects on the environment caused by the incineration and co-incineration of

waste. In particular, it should reduce pollution caused by emissions into the air,

soil, surface water and groundwater, and thus lessen the risks which these pose to

human health.

This is to be achieved through the application of operational conditions, technical

requirements, and emission limit values for incineration and co-incineration plants

within the EU.

The WI Directive sets emission limit values and monitoring requirements for pollu-

tants to air such as dust, nitrogen oxides (NOx), sulphur dioxide (SO2), hydrogen


chloride (HCl), hydrogen fluoride (HF), heavy metals and dioxins and furans. The

Directive also sets controls on releases to water resulting from the treatment of the

waste gases.

2.3 Italian legal framework

Decree with the force of law 24 June 2003, No 182 - “Accomplishment of the Di-

rective 2000/59/EC on Port reception facilities for ship-generated waste and car-

go residues”

Contents of the decree:

Objectives (Art. 1)

This Decree has the following objectives:

• To reduce ship generated waste/cargo residues discharge at sea (mostly illegal

discharge);

• To improve availability and use of port reception facilities.

Definitions (Art. 2)

There are the definitions of: ship, Marpol 73/78, ship generated waste, cargo resi-

dues, port reception facility, fishing vessel, recreation boat, port, competent Author-

ity (Port Authority or Maritime Authority).

There is also written, that ship generated waste and cargo residues are considerate

as waste according to the Decree with the force of law 5 February 1997, No. 22 and

following amendments.

Application framework (Art. 3)

Like the 2000/59/EC Directive, this Decree covers:

• all ships, whatever their flag, including fishing vessels and recreational craft,

putting in at a Member State port, apart from warships and ships belonging to

or operated by a State for non-commercial governmental purposes;

• all Member State ports;

• the Decree mentions also the responsibilities of the following offices of State:

Ministry of Defense, Ministry of Internal Affairs.

Port reception facilities (Art. 4)

Member States must ensure that port reception facilities are provided which meet

the needs of the ships using them without causing abnormal delays. These facilities

must be tailored to the size and classification of the port, the traffic of the last

three years, guaranteeing quick operations in the respect of safety for humans and

environment and applying the best available technologies.

These facilities have to be in accordance to fire-fighting legal framework and have

to be authorized according to Decree with the force of law 5 February 1997, No. 22

and following amendments.


The contract authorization to build these facilities and to provide the waste man-

agement services is given through a public tender, according to national and Euro-

pean laws.

The manager of a port reception facility and of the collecting service provides to

communicate the Annual Module with quantity and characteristics of the waste

and to keep updated the related registers.

Waste reception and handling plans (Art. 5 and annex I)

A waste reception and handling plan must be drawn up in each port by the Port Au-

thority (when established, otherwise by the Maritime Authority), after a communi-

cation phase with public and private stakeholders. This plan has to be approved by

the competent Region.

In case of non-fulfillment (after 60 days) of Port Authority, the Region appoints and

officer to draw the waste reception and handling plan.

The same plan can comprehend also other regional ports, referring to their needs.

The plan is updated every 3 years and every time that there are significant opera-

tive changes in the Port.

Notification (Art. 6)

Captains of ships bound for a Community port are required to notify certain infor-

mation through a specific Module (annex III) to the Maritime Authority, with a spe-

cific time schedule. These information are transmitted to: Port Authority, port re-

ception facilities manager, to Maritime Health Department, to the Port – Airport

and Boundary Veterinary Offices.

Delivery of ship-generated waste (Art. 7)

Unless exempted, all ships are required to deliver their ship-generated waste be-

fore leaving a Community port, unless the captain can prove that his vessel has

adequate storage capacity. Ships which do not deliver their waste without provid-

ing valid reasons for exemption are not allowed to leave the port until such delivery

has taken place.

A ship can not to deliver its waste only under an authorization given by the Mari-

time Authority (which has to be helped in this decision by the Health Maritime Au-

thority and by the Port chemist).

Waste produced from sanitary uses and food on ships with international routes are

managed according to a specific legal framework.

Ship generated waste is not submitted to customs duty.

Fees for ship-generated waste (Art. 8)

Ports must establish cost recovery systems to encourage the delivery of waste on

land and discourage dumping at sea. All ships calling at a Member State port will

bear a significant part of the cost (which the Commission interprets as meaning at

least 30%), whether they use the facilities or not. This cost recovery system com-

prises this built-in, fixed element and, possibly, a variable element according to the

amount and type of waste actually delivered.

Referring to ships that do line traffic, and also frequent and regular calls, the waste

management costs are specifically decided by the competent authority.


Referring to ships with a crew with less than 12 components, the competent au-

thority decide for a cheaper fee.

The delivery of waste accidentally took during fishing activity does not oblige to the

payment of a fee.

Exemptions (Art. 9)

The Ministry of Infrastructures and Transports sends to the European Commission,

at least once in a year, the exemptions authorized to ships that do line traffic.

Delivery of cargo residues (Art. 10)

The ship commander has to deliver cargo residues to a port reception facility, in

accordance with Marpol 73/78.

Cargo residues should be delivered, with priority, in order to be recycled or reused,

In accordance with laws.

Fees for the delivery of cargo residues are decided by the competent authority and

asked only to those ships that use this service.

Cargo residues are not submitted to customs duty.

Inspections (Art. 11)

The Maritime Authority carries out inspections in order to verify the compliance

with the way to deliver ship generated waste and cargo residues (Art. 7 and 10),

applying also dispositions given by the Decree 19 April 2000, No. 432 “Accom-

plishment of the Directive 95/21/EC on actuation of international laws for safety

and security of ships, for pollution prevention and for life and work conditions on

board”, this Decree indicates also the minimum percentage of inspections to be

carried out.

To decide the ships to be inspected, the Maritime Authority takes in consideration:

• ships that are not in compliance with notification obligation;

• ships of whom the given information could let suppose not compliance with the

way to deliver ship generated waste and cargo residues (Art. 7 and 10).

If the Maritime Authority makes sure a lack of compliance with the way to deliver

ship generated waste and cargo residues (Art. 7 and 10) arranges that the ship will

not live the Port until it does not deliver waste and cargo residues in an appropriate

amount.

The Maritime Authority that makes sure this kind of lack of compliance has to

communicate it to the maritime Authority of the next port of call of the ship.

Ships operating in an EU port may be inspected. There is a 25 % minimum inspec-

tion requirement. Inspections are carried out on ships which have not complied

with the notification requirement and on those suspected of not having delivered

their waste as a priority.

Where it is proven that a ship has put to sea without having delivered its waste and

without benefiting from an exemption, the next port of call is alerted. Moreover,

the ship will not be authorized to leave the second port without the situation hav-

ing been assessed.


Accompanying measures

This Directive provides for a series of accompanying measures. In particular, it pro-

vides for ships that have been unduly delayed owing to the inadequacy of recep-

tion facilities, while they themselves meet the requirements to which they are sub-

ject, must receive compensation.

2.4 Local legal framework

Decision of the Regional Government No. 42 of 10/07/2008 approving the “Plan

of management of waste from ships in the Port of Venice”

Ordinance 89/08 enacted by Venice Port Commander

Ship generated waste notification module

Waste discharge/delivery

Authorization not to discharge

On board inspections

Ordinance 337/10 enacted by Venice Port Authority

Contract authorization of management of ship-generated waste and cargo resi-

dues, for the period: 1st June 2010 – 31st May 2030, to a local enterprises group

composed by: “VERITAS S.p.A. – Guardie ai Fuochi del Porto di Venezia Soc. Coop.

P.A. – CO.NE.PO. Servizi S.c.a.r.l. – Berengo S.p.A. – C.M.E.V. Soc. Coop. – SACAIM

S.p.A.”

2.5 Practices developed in the Port of Venice - Ship generated

waste and cargo residues management

Action general scheme

SAFE ADRIA ENVIRONMENTAL ACTION PLAN DRAFT

ACTION N. TITLE DESCRIPTION RESULT

INSTITUTIONS

IN CHARGE

ACTION 1 WASTE

MANAGEMENT

COMPARISON OF WASTE MAN-

AGEMENT PROCEDURES IN OR-

DER TO OBTAIN AN OPERATIVE

SCHEME FOR THE PORT OF BAR

EXCHANGE OF EXPERIENCES AND PROCEDURES TO MAN-

AGE SHIP GENERATED WASTE AND CARGOES RESIDUES

VPA & PORT

OF BAR PROPOSAL OF GUIDELINES IN ORDER TO MANAGE SHIP

GENERATED WASTE IN PORT OF BAR


Practices implemented by Venice Port Authority

There are waste from ship treatment plants, in the areas of competence of the Port

Authority; they are managed by a local enterprises group (the sites are indicated in

the following figure).

According to the analysis carried out in the Plan, the majority of waste to be

managed in the port area consist primarily of:

• bilge oils (EWC

130403*);

• black water (EWC

200304);

• municipal waste (EWC

200301).

Detailed quantitative in-

formation about waste

can be found on the

same Plan. The monitor-

ing of waste provides to

the Port Authority the

opportunity to develop

projects and then allo-

cate funds for the im-

plementation of any new

waste treatment plants. In particular in recent

years the production of

waste with code

"200304" has increased;

however, the treatment

is not critical, as it is done in a properly sized treatment plant of Fusina.

As established by Legislative Decree 182/03 the managing enterprise provide with

the implementation of the annual communication (called: Unique Form of Declara-

tion); a copy of the same model is also forwarded to the Port Authority, informing

(as defined in the terms of contract of service) about waste data.

Port Authority is going to take appropriate indicators to monitor the level of diffe-

rentiation of the waste and their destination; in this way it will be possible to test

the efficiency and effectiveness of the operators entrusted with waste treatment

services.

According to the Legislative Decree 182/03, Venice Port Authority has drawn up the

“Plan of management of waste from ships in the Port of Venice” triennial updating

and is now requesting Veneto Region to verify if the updated Plan is subjected to

the Strategic Environmental Assessment.

An interesting aspect of waste management is related to bilge oils, which are

currently treated in a recovery barge plant. The plant is located in the “Industriale

Nord” channel and managed by the company “Guardie ai Fuochi del Porto di

Venezia”. The authorized treatments are mass storage of waste, recycling and


recovery of organic substances not used as solvent, limited to the separation of wa-

ter / hydrocarbon and preliminary storage only for non-recoverable substances.

The barge is equipped with 10 storage and treatment tanks, passing through which,

oil, water, hydrocarbons mixtures are separated by different density.

Materials resulting from the treatment, are brought to authorized plants complet-

ing the recovery process.

Picture: plant layout

In order to improve the liquid waste management, as suggested also by the

production data reported in the “Plan of management of waste from ships in the

Port of Venice” approved in 2008, the plant will be replaced by a fixed plan for the

treatment of oily bilge water, that is currently in final design. The latter plant,

which will occupy a surface area of 3.290 m2, will be placed in the same location as

the previous; it will be constructed and managed by a local enterprises group. The facility will treat the following liquid waste types and quantities:

- bilge oils: 19,000 t / year,

- washing water: 950 t / year,

- septic water: 9,000 tons / year.


By treatment through spin-dryers will be obtained sludges 100÷120 t / year and as

recoverable materials:

- oils: 5.000÷9.000 t / year,

- gasoline: 50 t / year,

- salts: 25 t / year.

Treatment must guarantee the destruction of hydrocarbons, oils, heavy metals

present in these wastes to levels that ensure the ability to discharge the treated

material into sewer.

Pictures: plant planimetry and layout


2.6 References to the Montenegrin legislative framework

From 2006 until today the following laws have been adopted in the field of envi-

ronment:

• Law on Environment (Official Gazette of Montenegro, no. 48/08),

• Environmental Protection Act (Official Gazette of Montenegro, no. 51/08,

21/09),

• Waste Management Law (Official Gazette of the RM, No. 80/05) creates basic

legal frame, for managing wastes and sets conditions for implementation of the

national Strategic Master Plan for Solid Waste. Provisions of the Law:

o prescribe the requirements for the elaboration of waste management

plans;

o define competences, responsibilities and obligations related to waste

management; and set out principles for managing particular waste

streams, incineration, disposal and storage of waste, monitoring, and set-

ting the fines and penalties.

Further harmonization with the EU waste legislation is under way, through e.g.

preparation of the Law on Packaging and Packaging Waste and a set of bylaws on

specific waste streams.

The environmental policy, as a part of the overall Montenegrin integration process

in relevant international frame, initiates changes in sustainable exploitation and

management of natural resources, institutional reforms and the fostering of institu-

tional national capacities, harmonization of national legislative with the European

ones and establishing of the implementation mechanisms.

Many projects cover the research on the marine and coastal protection; some of

the technologically oriented projects were also present like the project dealing with

the research on the possibility of industrial waste valorization, treatment of waste

waters, solid waste management and plants for waste waters treatment .

According to Montenegro 2011 Progress Report from EC some progress was made

on maritime transport and the process of ratification of relevant IMO conventions

was also initiated. Progress was made in the fields of pollution from vessels and

handling of waste, with the adoption in April 2011 of a new Law on “Protection of

the sea from pollution by vessels”; preparation and adoption of Montenegro Na-

tional Contingency Plan for Marine Pollution from vessels.

Management of communal and other types of solid waste is not very adequate and

contributes to overall pollution levels. Even though some important steps to reduce

pollution from waste have been undertaken – including introduction of separate

collection and recycling, and construction of the first sanitary landfill (Lovanja)

wastes from all the coastal municipalities are still disposed on inappropriate loca-

tions and in an inadequate manner.


3. Environmental measurements “port box”: best practices on

air, water, energy

3.1 International Convention MARPOL

The MARPOL Convention for the Prevention of Pollution from Ships includes also

the following technical Annex regarding air pollution:

Annex VI Prevention of Air Pollution from Ships (entered into force 19 May 2005):

the regulations in this annex set limits on sulphur oxide and nitrogen oxide emis-

sions from ship exhausts as well as particulate matter and prohibit deliberate emis-

sions of ozone depleting substances. Emission control areas set more stringent

standards.

In 2011, IMO adopted mandatory measures to reduce emissions of greenhouse

gases (GHGs) from international shipping, with a new Annex VI chapter 4 on energy

efficiency for ships, to make mandatory the Energy Efficiency Design Index (EEDI),

for new ships, and the Ship Energy Efficiency Management Plan (SEEMP) for all

ships. These regulations are expected to enter into force on 1 January 2013.

3.2 European legal framework on environmental aspects to

be measured

European Directives

A wide range of EU policies and legislation address specific problems evidenced in

marine and coastal environments; all the plans, programs and activities affecting

coastal and sea areas have to be conform to specific EU Directives and Regulations.

Among them, the most relevant are:

Water Framework Directive 2000/60/EC

The European Union (EC) has established a framework for the protection of:

o inland surface waters

o groundwater

o transitional waters

o and coastal waters.

This Framework-Directive has a number of objectives, such as preventing and re-

ducing pollution, promoting sustainable water usage, environmental protection,

improving aquatic ecosystems. Its ultimate objective is to achieve “good ecological

and chemical status” for all Community waters by 2015.


Directive 2008/56/EC establishing a framework for community action in the field

of marine environmental policy

This Directive establishes a framework within which Member States shall take the

necessary measures to achieve or maintain good environmental status in the ma-

rine environment by the year 2020 at the latest. For that purpose, marine strate-

gies shall be developed and implemented in order to:

a) protect and preserve the marine environment, prevent its deterioration or,

where practicable, restore marine ecosystems in areas where they have been ad-

versely affected;

b) prevent and reduce inputs in the marine environment, with a view to phasing

out pollution as defined in Article 3(8), so as to ensure that there are no significant

impacts on or risks to marine biodiversity, marine ecosystems, human health or le-

gitimate uses of the sea.

Each Member State shall, in respect of each marine region or subregion concerned,

develop a marine strategy for its marine waters consisting of preparation (initial

assessment, determination of good environmental status, establishment of envi-

ronmental targets and monitoring programmes) and programs of measures.

Directive 1999/32/EC relative to the emissions from Maritime Transport

Air pollutant emissions from maritime transport can be transported over long dis-

tances and thus increasingly contribute to air quality problems in the EU. The The-

matic Strategy on air pollution from 2005 concluded that sulphur emissions from

shipping were forecast to exceed those from all land-based sources in the EU by

2020. Directive 1999/32/EC regulates sulphur emissions from ships by limiting the

maximum sulphur content of marine fuel. This Directive was amended by Directive

2005/33/EC that designated the Baltic Sea, the North Sea and the English Channel

as sulphur emission control areas (SECAs) and limited the maximum sulphur con-

tent of the fuels used by ships operating in these sea areas to 1.5% (frequently

asked questions). This fuel standard applies also to passenger ships operating on

regular service outside SECAs. However, already at the time of adoption the SECA

fuel standard was widely recognised as being insufficient to address observed envi-

ronmental impacts from shipping.

Due to the international dimension of the shipping industry, environmental, securi-

ty and safety standards are developed by the International Maritime Organization

(IMO), a United Nation's specialized agency. Directive 1999/32/EC as amended

transposes provisions of Annex VI of IMO's Marine Pollution Convention, MARPOL

73/78. The Commission called for action at the International Maritime Organization

(IMO) to further reduce emissions and in October 2008 an amended Annex VI was

adopted that further reduces the maximum sulphur content of marine fuels inside

and outside of SECAs.

The European Parliament and the Council requested the Commission to report on

the implementation of the Directive and to consider submitting a proposal for an

amendment. Following this request and considering the development at the IMO in

2008, the Commission carried out a review of the Directive and adopted a proposal

for its revision on 15 July 2011.


Directive 2008/50/EC relative to the ambient air quality and cleaner air for Eu-

rope

The Directive includes the following elements:

o the merging of most of existing legislation into a single directive (except

for the Fourth Daughter Directive) with no change to existing air quality

objectives;

o new air quality objectives for PM2.5 (fine particles) including the limit val-

ue and exposure related objectives – exposure concentration obligation

and exposure reduction target;

o the possibility to discount natural sources of pollution when assessing

compliance against limit values;

o the possibility for time extensions of three years (PM10) or up to five years

(NO2, benzene) for complying with limit values, based on conditions and

the assessment by the European Commission.

Urban Waste Water Treatment Directive 91/271/EC

Its objective is to protect the environment from the adverse effects of urban waste

water discharges and discharges from certain industrial sectors (see Annex III of the

Directive) and concerns the collection, treatment and discharge of domestic waste

water, mixture of waste water, waste water from certain industrial sectors (see

Annex III of the Directive).

The four main principles are laid down in the Directive are: planning, regulation,

monitoring information and reporting.

Specifically the Directive introduces:

o a requirement for pre-authorization of all discharges of urban wastewa-

ter, of discharges from the food-processing industry and of industrial dis-

charges into urban wastewater collection systems;

o monitoring of the performance of treatment plants and receiving waters;

o controls of sewage sludge disposal;

o treated waste water re-use whenever it is appropriate.

Other significant Directives to adopt an ecosystem-based approach are:

• Strategic Environmental Assessment - 2001/42/EC and Environmental Impact

Assessment - 97/11/EC Directives;

• Directives 79/409/EC “Birds” and 92/43/CEE “Habitats”;

• Bathing Waters Directive - 2006/7/EC;

• Directive 2010/75/EC on industrial emissions, concerning IPPC - Integrated Pol-

lution Prevention and Control. Industrial production processes account for a

considerable share of the overall pollution in Europe (for emissions of green-

house gases and acidifying substances, wastewater emissions and waste). In or-

der to take further steps to reduce emissions from such installations, its aim is

to achieve significant benefits to the environment and human health by reduc-

ing harmful industrial emissions across the EU, in particular through better ap-

plication of Best Available Techniques.


3.3 Italian laws on environmental aspects to be measured

In the Italian coastal areas environmental risk is particularly high due to several fac-

tors, such as the intense maritime and port activities and the physical formation of

the Mediterranean Sea, in particular in the Adriatic basin, a sort of semi-closed,

shallow sea, characterized by a slow water change and by physical, biological and

environmental features that make it extremely vulnerable. As a consequence, all

the safety measures aimed at the protection of the coastal area and to prevention

of incidents and pollution are extremely important, including the ones imple-

mented over the borders of port and territorial waters (12-mile zone).

The incidence of international traffic is connected both to Italy’s geographic charac-

teristics, and to continually evolving economic conditions and regulations decided

at higher levels: international and European (e.g. the Port of Venice main interna-

tional activities are associated to its adhesion to its participation in EU funded

projects in the framework of the Trans European Transport Networks, TEN-T; the

port is also located at the intersection of three main European corridors: corridor

Helsinki – Valletta, corridor Mediterraneo; Adriatic – Baltic corridor).

Such conditioning is particularly significant in safety matters and in environmental

performances; infect, the international character of the market and the different

legislations in force in the various tracts of sea, limit the possibility of national deci-

sion-makers to influence both maritime transport and integrated coastal area man-

agement.

Legal Decree No. 152 of April 3, 2006

Containing environmental regulations, this decree represents the most recent re-

formulation of environmental right in Italy, besides being, in its Part III, the outline

law on water protection against pollution. This legal Decree replaces, and explicitly

abrogates, most of the previously existing regulations on environmental issues. The

fields affected by legal Decree 152/06 are:

• Environmental Impact Assessment (EIA) and Strategic Environmental Assess-

ment (SEA);

• soil and water protection;

• waste management and remediation of polluted sites;

• air protection and reduction of emissions into the atmosphere;

• compensation for environmental damage.

One of the main objectives of the Decree is to merge in a consolidated act former

directives from Law No. 183/1989 “General rules for territorial organisational and

functional rearrangement”, from Law No. 36/1994 “General rules on water re-

source protection”, from the legal Decree 152/1999 “General Rules on water pro-

tection against pollution and on incorporation of EU Directive 91/271/EU concern-

ing urban waste-water management and EU Directive 91/676/EU on water protec-

tion against agricultural nitrate pollution”; and from Directive No. 2000/60/EU of

October 23, 2000, outlining a European action plan on water issues.

For marine environment, the key-concepts of the Legal Decree No. 152/06 are as

follows:


• identification and definition of quality indicators, such as reference parameters

for the assessment of the quality status and the classification of coastal types of

environment;

• adoption of an integrated approach for the study of marine-coastal ecosystem,

owing to the necessity to characterize and evaluate in an integrated way the

biotic and abiotic matrices, as well as their respective factors in terms of human

pressure;

• paying the utmost attention to program aspects, by means of a tight co-

ordination with those responsible for planning, who should be supplied with all

necessary information for laying out suitable planning policies and intervention

programs for coastal management, to fit the quality objectives to be pursued.

Thus it does not consider noise pollution.

Law October 26, 1995, n. 447 “Framework law on noise pollution” In 1995 there is a new awareness in national political policies toward the fight

against noise pollution; in fact, Law no. 447/95 was passed destined to rule in all

sectors including transportation and relative infrastructure, measurement metho-

dologies and noise monitoring, etc. After Law 447/95, specific norms have been es-

tablished for the following topics: railway, road and airport, but not for port infra-

structures that are still missing about specific decrees.

Law No. 84/1994 containing the “Reorganization of port legislation” with later

amendments and integrations, by which the Port Authority has been established.

The Port Authority’s competences, defined by the Law 84/94, are the following:

• direction, programming, coordination, promotion and control of port opera-

tions in accordance with art.16, par. 1, and other commercial and industrial ac-

tivities conducted in the ports with regulations and control including the safety

and the hygienic work conditions;

• ordinary and extraordinary maintenance of the common or shared parts of the

port area, including the maintenance of the seabed;

• granting and control of the activities related to the supply by payment to port

users of general services;

• regulation and control of port operations such as unloading, handling, storage,

and general movement of goods and other materials practiced within the port

area;

• granting and allocation of state areas, quays, various equipment and buildings

reserved to the port activities.


3.4 Local legal framework

Considering of all the laws and decrees existing, it becomes clear that all regional

planning actions should take place in a wider pre-existing context of environmental

and maritime safety regulations.

In particular, Law No. 84/94 on reorganization of port legislation required the crea-

tion of special Port Regulator Plans by the competent Port Authorities aimed at

management and development of port activities.

Venice Port Authority activities are also based on three-year operational plans.

All initiatives and policies of environmental protection are summarized in the

document entitled “Venice Green Port”.

Law No. 192 of July 28, 2004 modifying and integrating the Special Law for Venice,

it has regulated discharges of storm water surfaces run-off discharged into the Ve-

nice Lagoon. It prescribes to present an adjustment plan to the Water Authority to

reduce the pollutant load carried by stormwater runoff discharging into the lagoon.

Decree of Environmental and Public Works Ministers of 30th

July 1999 (Ronchi –

Costa Decree) - "Limits of industrial and civil discharges into Venice Lagoon and

into rivers of Watershed on the basis of 5th point of Interministerial Decree of 23rd

April 1998 establishing requirements for water quality and purification plants

characteristics for the protection of the Venice Lagoon". It establishes the lowest

worldwide limits for wastewater discharge (e.g. the concentration limit for arsenic

is set at 1 µg/liter, which is an order of magnitude lower than that established for

human consumption waters, 10 µg/liter; that value is hardly obtained even by

using BAT).

Law No. 206 of May 31, 1995 - Urgent measures for the rehabilitation and

adaptation of the disposal systems of waste water and sanitation facilities in city

centers and the islands of Venice and Chioggia.

Law No. 139 of February 5, 1992 - Interventions to Venice and its lagoon

safeguard; about the maintenance and defense of the city and the integration of

financial resources.

Law No. 171 of April 16, 1973 - known as the first special law for Venice, concerns

interventions to Venice safeguard.

Law No. 366 of March 5, 1963 - New regulations relating to the lagoons of Venice

and Marano, concerning Transports - Maritime Security - Provisions relating to

navigation, ships and personnel.


3.5 Practices developed in the Port of Venice

Action general scheme

SAFE ADRIA ENVIRONMENTAL ACTION PLAN - DRAFT

ACTION N. TITLE DESCRIPTION RESULT INSTITUTIONS IN

CHARGE

ACTION 2

ENVIRONMENTAL

PRACTICES

“PORT BOX” DATA

SHARING

MEASUREMENTS OF RELEVANT ENVI-

RONMENTAL PARAMETERS IN ORDER

TO OBTAIN A STATE OF THE ART OF THE

ENVIRONMENT SITUATION IN THE TWO

PORTS AND COMPARE THEM

DEFINITION OF RELEVANT PARAMETERS IN ACCOR-

DANCE TO EUROPEAN LEGAL FRAMEWORK

VPA & PORT OF

BAR

DEFINITION OF INDEXES

GENERAL DESCRIPTION OF BOX DEVICES AND TOOLS

AND SOFTWARE

PERMANENT MONITORING OF THE ENVIRONMENT

IN THE TWO PORTS - COMPARISON OF DIFFERENCES

Practices implemented by Venice Port Authority

Wastewater and rainwater management for the Passenger Terminal - Marittima

The port's quaysides have been designed to avoid any contamination seeping from

the land into the lagoon or the water table.

In the Marittima, rainwater is collected and filtered before flowing into the main

pipes. The operating system, “Stormfilter”, is able to treat almost the whole preci-

pitation by continuous filtrating waters; then, water in discharged in lagoon.

The investment is about 1.000.000 € for the treatment plant, which is in fact the

largest plant in Europe to use the innovative “Stormfilter” technology.


The project involves a 140.000 m2 wide area, in which there are parks, docks traffic

and buildings for 30.000 m2.

The data used for the design of the plant are:

• maximum rainfall expected (164.000 m3/year),

• rain events (average 29 mm/hour - 65 mm/day).

Two different scenarios have been evaluated:

• scenario 1 – first rain water storage tank,

• scenario 2 – Storm-Filter system,

and, while the former resulted not suitable, the latter have been considered func-

tional and innovative, for two reasons:

• the system is able to treat 95 % of annual rainfall, instead of the first 5 millime-

ters,

• the plant works instantaneously, not needing great storage volumes; the treat-

ment capacity is also constant over time and for each rain event so that the wa-

ter directly discharged is extremely reduced.

Picture: Works yard for Stormfilter plant

The plant characteristics

are:

• 4 tanks,

• Total plant volume 316

m3,

• Treatment capacity:

352 liter/second,

• Number of filters con-

tained 352.


Pictures: Configuration scheme of the Storm Filter system

The performance expectations are confirmed by various parameters, as follows:

Parameter Expected trend

pH Neutralization

COD Reduction

Phosphorous Overall reduction of total P

Nitrogen Up to 40% reduction of total N

Suspended solids Elevate removal

Oils and fats Reduction up to < 5 mg/l

Metals Removing between 30% and 80%

According to Law No. 192 of July 28, 2004, to begin the authorization procedure,

Venice Port has presented to the Venice Water Authority a Plan of adjustment of

waste water run – off for Passenger Terminal West Pier.

The plan has been approved by positive judgment in:

• Inquiry Service Conference – 12/12/2005,

• Decision Service Conference – 24/01/2006.

The plant has been authorized with some prescriptions, consisting in particular in

including in the filtering system management procedures, the maintenance and

even the substitution of the filters, if one or more parameters indicated reach limit

values indicated in Table A, sections 1, 2 and 4 of the Ministerial Decree 30.7.1999.


Air quality and fine dust from ships in Venice historical centre

Port activities impacts on environment have been studied over recent years, trying

to find out solutions in order to reduce them, both in the historical centre of Ve-

nice, where the passenger terminal is located, and in Porto Marghera area, where

the commercial terminals are located. The two areas are characterized by different

kind of activities and different problems.

The strong connection between the passenger terminal and the historical part of

the city and its inhabitants, pushed Venice Port Authority to sign a voluntary

agreement in 2007 and 2008, known as Venice Blue Flag.

These agreements were signed by VPA, Harbor Master, Venice Passenger Terminal

and ship Lines in order to reduce sulfur content used by ships entering in Venice

historical center, through Giudecca Channel: ship-owners have pledged to use fuel

with an increasingly lower level of sulfur when calling at the Port of Venice.

The agreement established that VPA should evaluate environmental impacts on air

of passenger ships, within the historical center of the city.

For this reason, in 2007, 2008 and 2009, VPA teamed up with CNR and Venice uni-

versity in order to understand ship emissions impact and to evaluate the voluntary

agreement effects.

This action has resulted in a reduction in sulfur dioxide from 236 Kg in 2007, to 186

Kg in 2008, to 159 Kg in 2009, on a daily basis; as the results show, the direct con-

tribution of ships to the amount of particulate matter PM10 and PM2.5 (fine dust

are classified on the diameter of the particulates: particulate matter with aerody-

namic diameter of 10 µm / 2.5 µm - ref. Legal Decree no. 155/2010) ranges be-

tween 2% and 8% during transit and between 14% and 15% when docked.

The PM and SO2 decrease in the last few years, is confirmed also by ARPAV (Envi-

ronmental protection Agency of Veneto Region) and municipality independent stu-

dies.

The conclusions have been extremely interesting, since measurements showed up

the use of oil with less % of sulfur: since 2007, ships are really using more "envi-

ronmental friendly" kind of oil.

More than 500.000 € were expensed to realize these studies.

The campaigns will be repeated for the year 2012.

In addition to air quality monitoring and assessment, the port has started up a

number of projects aimed at cutting dangerous emissions (also promoting in some

case, the use of alternative energy). VPA signed also an agreement with ENEL, a

utility company, in 2010 for the feasibility study of the so called "Cold Ironing Sys-

tem". This plant allows ships to turn off the engines when mooring, giving them

electricity from the shore side. Estimated costs for the realization of 4 berth shore

side system are 55.000.000 €.

A joint study is being conducted with ENEL, to assess the use, in the Marittima Pas-

senger port, of electrically powered vehicles only.

In Autumn 2010, the Venice Port Authority started using LED technology to illumi-

nate the Passenger Port (lighting accounts for one fifth of all electricity consumed);

compared with the conventional systems, the new 23 m spotlights have enabled

the port to save 70% more energy.


In 2011, photovoltaic panels will be installed on some 18,000 m2 of rooftops in the

port’s facilities, and there are already plans to extend the surface covered.

These solutions cover the terminal’s power needs and, when the cruise season fi-

nishes, they put back into the grid the power absorbed in peak periods.

Dust from Porto Marghera commercial activities

Recently Venice Port Authority and S.O.I. (Integrated Operating System) have been

involved in a prevention campaign concerning port activities of loading, unloading,

handling of powdery goods. Indeed, the presence of dust in the port areas is a risk,

for both environment and workers.

Dusts are generally caused by handling of rinfuse through unloading with bucket

and subsequent movement and also by formation of mounds or storage in the yard

and workers in the hold, crane operators, ground workers are particularly exposed

categories.

In 2001 APV asked companies operating in port to draw up a dust prevention plan

to explain the preventive measures taken, then, in 2009 it has been necessary to

upgrade the plan.

Legal Decree No. 152 of April 3, 2006 - Article 271 states specific requirements for

containing and maintaining dusts coming from dusty materials production, han-

dling, transport, loading/unloading, storage activities.

Indeed, fine dust treatment in port area is not adequately regulated. So action is

needed to appoint procedures and specific measures.

Fine dust are now considered within the Project SAFEPORT “The port and industrial

and environmental risk management”, a cross border Cooperation Program Italy-

Slovenia (2007-2013). The project promotes the development of strategies and / or

joint plans for the prevention and reduction of environmental and industrial ha-

zards in the port areas of Ravenna, Chioggia, Venice, Monfalcone, Nogaro, Trieste

and Koper, facilitating the harmonization of systems and methodologies for envi-

ronmental protection between the ports of the Adriatic.

The project has a cost of 2.730.000 € and a term of 3 years and includes, in gener-

al, the following activities (identified as common needs during the preparatory

meetings):

• definition of guidelines for the management of emergencies in the port;

• implementation of the conceptual model of diffusion and emission of port sec-

tor;

• study of the effects of a pollutant spilled into the sea and definition of common

methods of intervention;

• development of common methodologies in the collection, coding and analyzing

data on accidents at work;

• analysis of risks arising from handling of dangerous goods in port.

The project is characterized by an intervention proposal concerning:

• classification of goods,

• defining of common procedures for dusty good handling,


• signature of Memorandum of Understanding between the Adriatic ports to be

translated into appropriate "directives" to the subjects addressed.

The project aims to draw up common guidelines about requirements and proce-

dures that port companies have to ensure to contain, to break down or to mitigate

the rinfuse handling dust diffusion, acting on equipment, storage modalities, han-

dling modalities.

For example concerning equipment the considered practices are, as follow:

• plants and machines for cleaning/wetting the port squares;

• closed vehicles to bring materials;

• storage areas equipped with system for airborne dust breakdown, containment,

mitigation and moistening of heaps;

• dust collecting devices;

• closed and covered areas for long - lasting materials storage;

• appropriate areas for the washing of vehicles;

• personal protective equipment,

and concerning handling/storage modalities:

• storage areas must be at a safe distance from the edge of the quay and from

wells of discharge and collecting rainwater and / or sewer lines;

• use of windbreaks;

• (possibly) provide a dampening system;

• provide proper foundation;

• moving materials only during suitable weather conditions (not high wind);

• activities must be carried out only through the indicated equipment;

• it’s important avoiding/limiting spreading both in the quay and in the water,

during material handling.

Noise pollution: monitoring and characterization

Currently, the framework law on noise pollution, Law 447/95, does not regulate

completely noise coming from port activities.

VPA still has undertaken and concluded in June 2008 an investigation to know and

comprehend noise pollution from great ships, through Eco.Port. Project “Noise cha-

racterization of ports: system for the control and monitoring of noise pollution in

ports”. The Project is proceeding in 2012.

By Eco.Port. Project an acoustic characterization method has been defined, regard-

ing vessels moored or in transit as sound sources and has been realized a model to

reproduce typical situations of transiting or mooring ships.

The study realized the absence of problems correlated to the ship transit in Giudec-

ca Channel but also potential critical situations: a preliminary survey of the places

showed that the ships moored along wharves are the main noise sources, specifi-

cally to the Venice Port. So it was decided to proceed with the acoustical characte-

rization of the kind of ships listed below:

1) inland navigation ships (main sources: diesel generator and ventilation fans);


2) ferries (main source: ventilation fans);

3) cruises - large size (main source: funnels);

4) cruises - small size (main source: ventilation fans).

The study has been a potentially useful instrument on planning port areas and ac-

tivities, but also to predispose a possible new legislation that would regulate and

contain noise pollution caused by port activity.

The aim was to realize a software able to predict noise generated by vessels incom-

ing Port of Venice and so to allow comparisons with normative values and finally to

study hypothesis of containment and remediation.

Venice Port noise mapping interested in particular these areas:

• Commercial Port area where big cruises and ferries are moored and a very po-

pulated residential area stands in the vicinity;

• San Basilio area, where small cruises and inland navigation ships are moored; in

front of that area, along the Giudecca Canal, ferries and cruises pass by;

• Riva Sette Martiri area, where small cruises and inland navigation ships are

moored and in front of, on the lagoon, ferries and cruises pass by; very popu-

lated residential areas (green) are near.

The digital building model has been developed using the software package

SoundPLAN by which, the built-up of the city of Venice is represented.

Input data for the PC model were:

• digital Ground Model (DGM) and Building Model (DBM), from cartography pro-

vided by Veneto Region;

• noise limits established by City Acoustical Plan, provided by the Local Authori-

ties of Venice;

• number of residents and dwellings district by district, provided by the Local Au-

thorities of Venice;


• sound power of the noise sources, by means of in situ acoustical characteriza-

tion measurements;

• meteorological data, split into three periods of the day, provided by ARPAV

(Veneto Region Environmental Protection Agency).

In conclusion the technical activities for the study have been as follows:

• noise sources acoustical characterization by means of source-related measure-

ments;

• environmental noise monitoring by means of receiver-related measurements;

• noise mapping, presentation to the public;

• noise management.

Since 2000, several surveys and assessments wave motion have also been con-

ducted to detect the effects of the transit of ships and ferries on Venice’s artistic

heritage. The conclusion shows that large ships do not change the background

wave motion in any significant way.

3.6 References to the Montenegrin legislative framework

From 2006 until today the following laws have been adopted in the field of envi-

ronment:

• Law on Environment (Official Gazette of Montenegro, no. 48/08)

• Law on air quality (Official Gazette of RM, br.48/07)

• Law on the ratification of the Kyoto Protocol to the UN Framework Convention

on Climate Change (Official Gazette of RM, no. 17/07)

• Environmental Protection Act (Official Gazette of RM, no. 51/08, 21/09)

• Law on chemicals (Official Gazette of Montenegro, No. 11/07)

• Law on Sea (Official Gazette of Montenegro, no. 17/07, 06/08).

Major environmental problems include:

• old and polluting industry (technology) – contamination of specific locations

and negative environmental effects of major pollutants (for exemple Aluminum,

steel from Factories, thermal power plant; industrial liquid wastes discharged to

rivers;

• high levels of urban pollution – solid waste, liquid waste, undeveloped infra-

structure – is also an obstacle to economic development and especially for tour-

ism, the state of infrastructure and facilities and equipment for water supply

being generally poor; large amount of water losting;

• unsustainable use of resources such as energy, water and forests;

• increased impact of traffic – both road and maritime – lack of measures for ad-

dressing pollution caused by ships/ boats;

• threats to biodiversity.

safe adria action plan vpa 310112

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