2.2) SWOT Analysis of Water Management Directorates

8/2/2019 2.2) SWOT Analysis of Water Management Directorates

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MINISTRY OF ENVIRONMENT AND WATER

NATIONAL INSPECTORATE FOR ENVIRONMENT

AND NATURE CONSERVATION

Institutional Strengthening of Environmental Inspectorates

Twinning ProjectAddress: Mszros u. 58/a. Budapest, H-1012 Mail: POBox:675 Budapest, H-1539

Phone: +36 1 224 9268/9269/9270 Fax: +36 1 224 9262

SWOT ANALYSIS

12 Water Management Directorates

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SWOT ANALYSIS (1) 20.02.2004

B. 12 WATER MANAGEMENT DIRECTORATES (WMDs)

1. ORGANIZATION, STRUCTURE AND MANAGEMENTPROCEDURES

STRENGTHS

1. In 2002 two ministries have been merged to one ministry for environmental, nature and

water issues, the Ministry of Environment and Water (MoEW).

2. Environmental laws are more or less in line with EU Acquis . They are known by most

(10/12) of the WMDs via publications of laws and decrees. The rest (2/12) says that it

can read them in the official journal.3. All the authorities report about shortcomings or deficiencies in legislation to the

National Water Directorate (NWD).

4. In most cases the authorities get the drafts of the laws to look through and often their

remarks are taken into consideration.

5. The responsibilities are precisely described in the law (100 %).

6. Water management is the main subject of responsibility in the WMDs and all are aware

of that.

7. Most of the WMDs have annual work schedules (83%), regular meetings of leaders (92

%) and regular staff meetings (100 %).

8. The authorities take part as experts in almost all environmental issues ( >30).

9. A lot of other authorities also take part in the work of the WMDs. (>20).

10. Different subject-specified statements are usually integrated by site visits (100%),

negotiations (83%) or meetings (42 %).

11. Differences are resolved by negotiations (100 %) and no ministerial decision is required.

12. Information to the public is given concerning water level, floods, access to water, water

reserve and hydrological data.

13. Half of the WMDs have been involved in different EU projects already.

14. Regular meetings are held with different stakeholders: NGOs (75%), industry (50%)

building enterprises, research institutes a.s.o.

WEAKNESSES

1. There is no guidance on how to carry out the responsibilities/tasks.

2. More than half of the WMDs (58 %) also recognised water pollution as a part of their

work although it is definitely defined as responsibility of the Regional Environmental

Inspectorates (REIs).

3. Only sometimes the WMDs are involved in preparation of the new laws.

4. New recommendations are not spread quickly enough. Merely 17 % had heard of the

EU Recommendation on Minimum Criteria for Inspections.

5. Only one WMD saw the possibility of becoming an authority-centre of excellence for

water issues.6. Guidance is given too seldom (33% get it). More guidance is required at least for the

Water Framework Directive (33 % wish it).

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7. Training seems to be given twice a year in a form of consultation only for the heads of

the directorates.

8. No guidance has been given how to implement the Aarhus Convention.

9. Different subject-specified statements are not handled by teamwork - only 25 % do so.

OPPORTUNITIES

1. The experts of the WMDs should be involved stronger in the law-making process

(preparatory working, they are the expert and know things best).

2. Training/information about new EU directives or recommendations should be given to

the staff as early as possible - not only to the heads - for the sake of professional work in

time.

3. To improve the knowledge about the Recommendation on Minimum Criteria for

Inspections would avoid a lot of mistakes and thus double work.

4. It is an opportunity to combine the water management and water protection tasks once

again in the same organisation in order to save money and time whilst improvingintegrated procedures. Work would improve even more if environmental and water

issues became emerged in one authority as it was in former times.

5. To combine the WMDs wih the environmental and nature bodies could save money,

improve work and support needed integrated green procedures.

6. The EU membership becomes easier the more the authorities got and will get involved

in EU projects.

THREATS

1. All the WMDs said that authority and expert work could not be separated. If you

separate authority and expert work you really need a lot more staff.

2. If not enough guidance is given in different directives such as Water Framework

Directive (WFD) and Aarhus Convention it turns out to become a risk that the practical

implementation varies a lot in different directorates with the known follow ups.

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2. FINANCES

STRENGTHS

1. All get their budget financed to a certain degree (70-80 %) by the MoEW and they also

get some money (7-30 %) from profit.

2. Almost every WMD foresees that other activities such as permitting, planning

conciliation, providing data, urban planning and inspection could be charged.

3. Most (67 %) of the directorates say that the fees should reflect the amount of work

carried out.

4. Penalties paid could belong to the budget of the WMD (50%) or it could perhaps be

collected in a fund in order to finance water cases at least should it be available in the

special area of responsibility.

5. The personal income has increased since year 2000 for 67 % of the directors.

WEAKNESSES

1. The budget from the MoEW does not cover operational costs and is too low for

maintenance.

2. Only dues and not real fees are charged for permitting procedures by 58 %.

3. Two authorities argue that the society cannot bear higher dues.

4. Almost all directors (83%) do not agree with the existing system of wages. Salaries

only depend on degrees and age. They blame that system for not being flexible enough

to appreciate efficient and well done work.

OPPORTUNITIES

1. It is now the right time to get the budget on track.

2. You could change the system so that the fees from issued permits and other activities

such as inspections, planning, providing data reflect the real work done.

3. The system of wages could be changed that it better reflects the efficiency of the

individual employees.

THREATS

1. In the future the state money will decrease and this will influence the work done by the

authorities and their ability to finance the environmental investments to meet the EU

requirements..

2. If the system of wages wont get changed the people at work will not be motivated in

their work.

3. There is a risk that the best skilled personnel will be bought up by the private sector.

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3. NUMBER OF STAFF

STRENGTHS

1. In total about 5000 persons are working at the WMDs which really is a lot even in

European context and should be enough.

2. Of the staff over 2000 are doing authority and expert work which should be enough too.

3. About 1500 persons are manual workers.

WEAKNESSES

1. 67 % of the directors say that there is a lack of staff.

2. The biggest lack seems to be in flood protection (opinion of 75 %).3. 58 % say that water management plus follow ups and implementing EU law needs more

staff.

4. 50 % say that authority work needs more staff.

5. Although the number of staff is high enough there is a lack of qualified persons for new

tasks.

OPPORTUNITIES

1. It seems that the WMDs have far enough staff even for the future.

2. Now is the time to focus on training and further education of the staff.

THREATS

1. For the authority work academic staff would be needed.

2. If the salaries are not high enough the most qualified staff could go over to the private

sector.

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4. QUALIFICATION OF STAFF

STRENGTHS

1. Academic degrees in many different subjects exist. There are engineers, hydrologists,

geologists, lawyers, economists, environmental engineers, chemists, biologists and even

a few forestry engineers.

2. The personnel has a long experience of working with authority work.

3. Often additional qualifications are required before practising permitting, inspection or

enforcement mostly on-job-training (75 %) , mentoring is also used (33 %).

4. In 2/3 of the directorates some people are warranted or accredited for their special duties

as quality surveyor, technical supervisor, weir-keeper, canal-keeper a.s.o.

5. Several different foreign languages are know to some of the staff.

WEAKNESSES

1. Only 458 persons have a higher academic degree which is only about 9 % of the whole

staff.

2. There are some more persons - in total 554 (11 %) - with a lower academic degree.

3. Most of the directors say they need more academic staff for various issues because of

new tasks.

4. There are many persons without any degree (1.360). A quarter to a third (28 %) of the

employees are without any degree.

5. Although a lot of foreign languages are known to the staff there are not many who really

can speak and write foreign languages; 134 can English (2,7 %), 76 German, 20Romanian, 25 Russian, 9 Croatian, 8 French and some persons can other languages as

Slovakian, Polish and Spanish.

OPPORTUNITIES

1. Now the priority lies on the qualification of staff. The employees should be given the

possibility to take a higher exam.

2. During this twinning project there is a good possibility to get basic facts about several

EU directives.

3. Even ongoing training in different new EU directives should be given and the MoEW

should take part as trainers.4. The staff could get an opportunity to learn foreign languages at work with perhaps

foreign native speaking teachers. There could be courses for different levels. There

could be discussion clubs or academic writing or some courses during which they can

get a certificate.

THREATS

1. If the staff is not well qualified it will be difficult to manage all the new EU

requirements.

2. If the persons especially in authority work get not sufficiently trained in foreignlanguages it could become difficult to really understand the directives and take part in

some important networks like IMPEL.

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5. RECRUITMENT OF STAFF

STRENGTHS

1. The WMDs always tender the new jobs, mostly they publish advertisements in

newspapers (83 %), they also involve labour agencies (58 %) and national media (42

%). Even other sources exist as universities, colleges a.s.o.

2. Tendering replacements of persons is used by 42 % of the authorities and mostly they

use regional newspapers or involve labour agencies.

3. The recruitment is always (100 %) based on precise task-description.

4. The selection of new staff is always based on written documents and interviews.

5. The director of the authority decides whether a person will be taken or not after that the

head of department has suggested the person. The ministry does not play a role here.

WEAKNESSES

1. No real weaknesses in the recruitment procedure.

2. The tendering of long lasting replacements happens seldom.

OPPORTUNITIES

1. When recruiting new personnel it is good to remember the qualifications and the skills

in foreign languages.

THREATS

1. If not well qualified people are recruited it will be difficult to manage foremost the

implementation of the Water Framework Directive and other new water directives as

well.

2. If the salaries do not reflect the importance of the job the motivation of the staff will

decrease.

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6. TRAINING OF STAFF

STRENGTHS

1. Each authority has nominated a person being responsible for training.

2. All WMDs have regular professional training programmes. 5 of them (42 %) include

training in IT.

3. Additional training is given in flood protection, technical inspection, fire prevention,

work protection, new laws, Water Framework Directive and sewage water directive.

4. 83 % of the WMDs say that the training requirements of individual members are

assessed against necessary qualifications, skills and experience.

5. Most training is required in the following directives: WFD 204, Dangerous Substances

in Water 194, EIA 52, Urban Waste Water Treatment 51, IPPC and BAT 35, Reporting

27, Habitats 25, Waste Management 11, Minimum Criteria 10, Hazardous Waste

Management 9 and Wild Birds 7 persons.6. Training is also required in supervision procedures 370, integrated permitting 124,

monitoring 73 and Aarhus Convention 70.

7. The need of training is recognised. For 1240 persons training is said to be necessary.

8. The success of training is assessed by 58 % of the WMDs; normally by the head of

department and sometimes by the director or the training administrator.

9. All the directors say that relevant technical, policy and regulatory developments are

maintained in the WMDs.

10. The skills of the staff is kept up by giving possibilities to take part in further

professional education or training courses, have a completely updated CD Law

collection and get access to the standards and EU directives.

WEAKNESSES

1. Not every WMD has recognised the need of training in different directives as example

for the WFD the need varies from 0 100 and for Dangerous Substances in Water

from 0 150.

2. Only 3 (25 %) WMD offer regular training in English languages.

3. 0 % provide training in public administration.

OPPORTUNITIES

1. As this twinning project is strongly focusing on training in different directives andpermitting and supervision procedures the right time has come to take part in the

training.

2. Parallel to the training programme concerning EU Directives there should also be

offered a language training programme.

THREATS

1. The amount of training given in this project will not be enough to get in-depth

knowledge of all the EU directives that could need to be further declared.

2. The language training given is not enough for communication with EU officials and the

networks such as IMPEL.

3. If there is not an ongoing training (ETA) after the project has been finished the results

are not sustainable.

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7. PERMITTING, LICENSING PROCEDURES

STRENGTHS

1. All the WMDs say that there are sufficient instructions in the decree how to make an

application.

2. Most of the WMD say that there is guidance how to write permits it is in the law. And

they add that the water permits are 100 years old - so tradition exists in writing permits.

3. All authorities are easily able to describe the necessary steps in permit procedures.

4. More than half of the authorities (58 %) think that the licensing procedures are in line

with EU requirements.

5. An appeal address exists always in the permit so that the persons concerned can send in

their appeals.6. Written statements from parties involved are given in 75 % of the WMDs.

WEAKNESSES

1. Only 2 WMD could imagine that competencies could be divided into two levels,

regional and local, if the local level was getting better qualified.

2. Internet is used in less than half of the WMDs to inform the applicants about their

responsibilities.

3. The instructions in the decree for the applicants could need some supplement in

application forms. That is still missed in Internet.4. No real guidance for permit writers exist - it is only mentioned in the decree. At least

guidance about the integrated permit procedure is required.

5. Even if the authorities think their permitting is in line with EU requirements there has

still much to be done at least for the IPPC permits which shall contain specific limit

values and be based on Best Available Techniques (BAT). Even the use of water is

going to be a part of these permits.

6. In the description of the permit procedure there is no clear place for the involving of the

public.

7. Almost every WMD (92 %) says that the time limit given in the law is insufficient at

least in complex cases with a lot of documents and if the documents are not complete.

Also the involvement of expert authorities needs more time.

8. No knowledge of BAT at all could be recognized.

9. Making of integrated permits is not known. Only one WMD says there are statements

from expert authorities. Anyhow, only a statement is not what EU means with an

integrated permit procedure.

10. The Aarhus Convention is not really taken on board yet. Only 4 WMD said it has been

implemented in the permit procedure. Information in the newspapers is given in 42 %

and meetings are held only in 17 % of the WMDs.

OPPORTUNITIES

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1. It could be of advantage to elaborate application forms combined with some guidance

on how to fill them in for the operators. They could be put in Internet.

2. It could be helpful to support the permit writers with guidance. In addition there should

be found a way to ensure a unified permitting practice in the country e.g. via elaborating

permit models.

3. There should be offered a special training program for practising integrated permitprocedures. The first step had been made by the Twinning Project on IPPC.

Unfortunately this training had been provided for only a few number of persons.

THREATS

1. If there is no connection between the REI and the WMD in cases of IPPC permits

Hungarian authorities will not achieve integrated permitting procedures.

2. If the Aarhus Convention is in practice not considered in the permit procedure the public

wont get involved in the right way and there will be no sufficient transparency in the

procedure.

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8. APPEALS

Deleted

9. MONITORING SYSTEM

STRENGTHS

1. Data base for monitoring water exists.

2. Quality of data taken by the agencies is acceptable.

3. There are practical guidance for carrying out the monitoring such as technical

instructions made by VITUKI and NWD; they even have a handbook on it.

4. Data from monitoring water are used both in permitting and inspection work and

additionally in planning, for water supply, for flood forecast, research and development

and other needs.5. The operators make self-monitoring of emissions.

6. The monitoring results have been used for further enforcement actions as penalties,

fines or introducing water restrictions.

7. There is a system for monitoring the impact on both water quantity and water quality.

8. The degree of compliance by controlled installations after they got their license is good

(50 %) or feasible (42 %).

WEAKNESSES

1. In the monitoring of water there are overlapping systems so that both the WMDs and the

REIs take samples of water.

2. Only 58 % of the WMDs monitor emissions to water.

3. 42 % of the WMDs argue that the data from operators self-monitoring is not always

available and reliable.

4. Merely in 30 % of the cases the results of self-monitoring can get verified by the

authority.

OPPORTUNITIES

1. Monitoring of both the state of the environment and the emissions to the environment is

very important also in the future and now is the time to make good integrated

monitoring programmes so that you can have reliable results to report.

2. The monitoring could be done in an electronic form so that reporting e.g. to EU

becomes easier in future times.

3. The system of monitoring of impacts of installations can be improved by developing

methods for the assessment of impacts on soil and by data exchange on soil qualities.

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THREATS

1. If the monitoring results are not controlled regularly and thus in a reliable way you will

not gain a sufficient picture of what the state of environment is and what the emissions

from different operations are.2. The different authorities involved in monitoring and data collection must be willing to

co-operate and to provide their data to the other agencies.

3. If the technical provisions for a data exchange are not developed, the exchange will

raise a lot of additional work and thus create resistance in the participants.

4. The development of practical guidance that are not too complex and that can be used

without practical problems needs a lot of experience and competence. Some answers of

the agencies suggest that this expertise is not available in the inspectorates.

5. The lack of soil data will make it impossible to fulfil the obligations of the EU-Water

Framework Directive.

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10. INSPECTIONS

STRENGTHS

1. The inspection can be done either by an individual inspector or by a team of inspectors

depending on the case.

2. All authorities underline the quality of their annual plan for inspections.

3. Site visits are common in specific cases (sewage canal works, water works, and when a

plant start to work) they control regularly.

4. The WMDs always write protocols of the site visits and the protocols get even signed by

both the authority and the operator.

5. The WMDs are used to have extra meetings and negotiations with the applicant. The

meetings can be held at the site or at the directorate. Many different issues can be

discussed as: clearing of facts, informing the applicant or the authority, conciliation,planning, permission problems, anything in connection with the application, irrigation,

pumping, water supply, canalisation a.s.o.

6. The WMDs report annually on their inspections to the NWD. The reports are quite large

and contain a. o.: number of permits (new, modified, withdrawal, corrections, ceasing

the procedure, appeals) and expert opinions, carrying out of plans, unusual inspections,

fulfilment of the annual inspection plan, statistical data of inspections, experiences and

proposals.

7. In 92 % data system exists for the reports of inspection .

WEAKNESSES

1. Only 25 % of the authorities have a practical guidance for carrying out inspections

elaborated by the NWD; some 30 % elaborated their own ones. That means that there is

no unified practice in carrying out of inspections across the country.

2. With one exception the WMDs could not imagine involving e.g. local bodies in order to

overtake inspection work to a certain degree.

3. Only one of 12 WMD was informed about the EU Recommendation on minimum

criteria.

OPPORTUNITIES

1. Now is the right time for a national institute to provide the WMDs with inspectionguidance.

2. The data system for inspections exists and will be helpful to support the Hungarian

reports on Minimum Criteria required by the EU after accession.

THREATS

1. If there wont be delivered nationwide guidance differences will occur in how the

inspections are carried out with all bad follow ups to the environment and the

competitive situation of Hungarian firms.

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11. ENFORCEMENT

STRENGTHS

1. The instruments of enforcement in cases of non-compliance are in all WMDs fines,

enforcement notices, offences and criminal procedures.

2. A lot of enforcement actions had taken place in 2002: in total 894 cases: 381 fines, 461

enforcement notices, 52 offences and 0 criminal procedures.

WEAKNESSES

1. The WMDs were not able to imagine that competencies for enforcement could be

divided into several levels.

2. In spite of the high numbers of enforcement actions it is not certain that they are leadingto more environmental protection because it is easy for the companies to pay fines

which are too low.

3. The authorities enumerated a lot of problems linked to enforcement procedures: lack of

money, lack of law, foreigners cannot be enforced, penalty is not strong enough, long

appeal and court procedures, lack of successful enforcement instruments, lack of

intention to follow the law and last but not least too complicated procedures.

OPPORTUNITIES

1. The whole scale of enforcement instruments exists. Authorities should be encouraged torealize them for the sake of water protection.

2. A nationwide guidance on how to run enforcement successfully would help the

authorities.

3. The laws about enforcement should be changed in order to increase fines and turn

procedures less complicated.

4. The necessary change of attitude among the operators could be reached by more co-

operation between authorities, operators, NGOs and citizens.

THREATS

1. If the operators get away with only small fines they do not realise the importance of the

compliance with the permits.

2. If the enforcers were not provided with intelligent guidance and were not skilful enough

they would not win the enforcement and appeal battles.

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12. REPORTING

STRENGTHS

1. All of the WMDs report about their work in annual work reports. Additionally

occasional reports are given by 75 % and quarterly reports by 33 %.

2. The activities are published to the public quite often (83 %) in occasional reports (42

%), press conferences (67 %) and Internet presentations 42 %.

3. Data on water quality is reported in 33 % from the WMD to the NWD.

4. Data on water quantity is reported by most WMD to either VITUKI or NWD.

5. 50 % of the WMDs say that data reported to the national Authorities are put in a

common report. The press gets also a report about the impact on waters.

WEAKNESSES

1. With one exception the authorities have not set up a public service office.

2. Internet is only used by 25 % of the WMDs!

3. Meetings and press conferences about their work are given only by half of the

authorities.

4. Only one WMD says that the annual report is available for the public.

5. Without one exception the WMDs had never heard of the EU-Directive on freedom of

access to information on the environment.

6. It seems as if there exists a bit of confusion to whom the WMDs have to report data andwhat kind of data should be reported.

OPPORTUNITIES

1. It is the right time to develop the reporting in order to install a functioning electronic

data base which is continuously available to everybody.

2. The authorities own image could be improved by developing a reporting system in order

to inform to the public about their water protecting work.

THREATS

1. The EU demands cannot be fulfilled if the commission does not get data concerning

water from the WMDs. This might provoke severe difficulties with European bodies

and in some cases even penalties.

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13. INFORMATION + DATA

STRENGTHS

1. 92 % of WMD have got or are planning a web site.

2. The web sites are used for a wide variety of information (news 90%, organisational

83%, tasks 60%)

3. 92% of WMD use online data collecting systems. The systems are widely used in daily

work (75 to 100%), mainly databases of water flow.

4. There is a data exchange between the authorities under the umbrella of the MoEW

83% local and regional only 58% national.

5. They get enough information of neighbouring authorities for prevention of

environmental impacts, accidents etc. (92%). Interactions between public and WMD per

email takes place partly.

WEAKNESSES

1. 92% of the WMD say, web sites are not continuously updated.

2. Plans are not published.

3. The domestic EIONET-Network and its rules are unknown.

4. WMD-Data are not involved in Integrated Environmental Economic Information

System.

6. Only in 50% they have access to factory-own results of measuring.

5.

6. Only one WMD benefits from the combined system of EIONET Network+UNEP/GRID-Budapest and only 2 WMD use databases for air quality.

7. No WMD uses databases for Waste.

8. There is no data base for soil treatment and soil protection.

9. Although there is some information from neighbouring authorities, it is not enough; it

should improve.

10. An IT-data base for the factory-own results of measuring is lacking.

11. Web sites need components for public interaction.

OPPORTUNITIES

1. Web-Information should be managed in a central way.

2. All data collecting systems should be transformed into electronic online-systems.

3. Data exchange on a national level is needed.

THREATS

1. The optimal way to fulfil the EU-requirement for reporting is to improve and complete

electronic-based and online-based data collecting systems.

2. The data exchange especially in a local and national way must to be improved to get an

environmental overview in Hungary.

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14. IT-EQUIPMENT

STRENGTHS

1. There is the awareness, that it would be necessary to built up a modern and powerful IT-equipment-system for daily work. 67 % of the WMDs say their IT-Equipment meets the

demand of the daily work.

2. The necessity for general user knowledge (100 %), further knowledge (75 %) and

special knowledge (67 %) is acknowledged.

WEAKNESSES

1. The IT infrastructure is not sufficient for comprehensive IT Management like unified

databases and data conversion.

2. Hardware doesnt get modernised and software doesnt get updated.

OPPORTUNITIES

1. The improvement of the IT infrastructure should be prepared by an IT conception which

fits to the actual needs, makes use as far as possible of the existing infrastructure and is

intensively negotiated with the recent IT users.

2. Public information on internet should be done by help of a software and web server

suitable for group work.

3. Many data are already available in the WMDs. Growing data stock will immediatelygive rise to the need for a registry of these data in order to sustain the overview and the

availability of appropriate data for a given purpose. A meta data system should be

developed (or adopted e.g. from the German Environmental Information Register

[Umweltdatenkatalog, UDK]) in order to support the work.

4. A modern and powerful IT-equipment must be built up for the different authorities,

because that is the main base for handling data in the daily work. This will be the rules

having an unified database and the ability to make any decision on the same information

and data status.

THREATS

1. Aarhus convention and EU Freedom of Information guideline require a free access for

every person to a wide range of information about nature, the environment, legislation

and organisational data, using digital media as far as possible. The existing IT

infrastructure obviously does not support this.

2. The reporting and monitoring obligations of the EU, especially those laid down in

integrative directives like Natura 2000 or Water Framework Directive describe the need

of data from other fields (soil, air, nature protection, waste)! These data are not present

and not used in the work of the WMDs so far and so these obligations can hardly be

fulfilled in this moment. One major reason is the lack of possibility to get a digital

access to these data.

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Documents

2.2) SWOT Analysis of Water Management Directorates