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Schriftenreihe des Europa Institutes Budapest, Band 20:121–138.


Summary: Specificities of the Environmental Policy of Accession


During the past years environmental protection has been gaining increasing significance in the policy of the EU. Nevertheless, it should be clearly seen that it is the operation of the single market and the recently introduced single currency that enjoy first priority in the EU. Environmental protection in comparison to that is of secondary importance only; together with social provision and the protection of consumers the main task of environmental regulation is the operation of the single market free of disturbances. (The market is disturbed when environmental and consumer protection regulations, further on social provision significantly differ in the various countries, because companies of countries implementing a lower level of regulation may acquire competitive advantages in the single market, whereas a more rigorous environmental regulation may lead to discriminating import limitations not desired by the Community.)

Hence even that conclusion can be drawn (the assessment of the EU questionnaires by the Commission, and subsequently supported by the Commission assessment of the year 2000) that environmental protection may even be the arena of political and tactical motivations during the accession process.

It is a key issue for Hungary that the environmental and health parameters of our products should not mean a technical obstacle in trade, as it may affect the competitiveness of companies, exports, the manufacture of certain products, and hence employment.

Hungary is yet in a condition of deficient environmental infrastructure (sewage disposal and purification, waste management), and their development demands huge sums. Whereas in the developed industrial countries the integration of environmental aims into sectoral politics, the broad implementation of recycling, and the development of the systems of environ- mental management of companies are already on the agenda. A marked asymmetry can be observed between the developed West and North European countries and the East-Central European ones wishing to accede: while the per capita utilisation of energy and natural resources is usually higher in the developed countries and lower with us, the efficiency of the utilisation of these resources is higher in the developed countries than with us. In the majority of cases we emit less pollutants and produce less waste per capita, but due to lower technological and productivity levels the specific pollutant emission is higher in our countries.

The Western countries stress only efficiency of those two components and blame the East Europeans. At the accession talks however, attention should be called to the fact that the per capita utilisation of resources and pollutant emission are at least as important as environmental efficiency. We make efforts towards a more efficient utilisation of resources, and hence pressing down specific environmental burdening (which, in fact is realised also as a result of the structural change of the economy and of modernisation), but it should also be noted that the smaller volume of our resource utilisation and pollutant emission by itself results in a lesser burden on the environment.

The EU directives do not always consider the condition of the environment differing by country and how far the environmental elements can be burdened. The essence of directives should be that the general guidelines should be applied in keeping with the specificities of a given country or region. They are however not always taken into consideration. Therefore in a significant part of cases Hungary has to implement costly environmental developments in some respects when the condition of its environment is better than in several developed West European countries. (A typical case is the relatively good condition of our soils and the enormous cost of sewage disposal and purification.)

Obviously there are business interests as well behind these efforts: domestically the objectives of the local governments and interest groups involved and market acquisition by West European companies manufacturing equipment for purification and incineration, i.e. products of environmental industry.

The development of environmental infrastructure is extremely costly, it significantly burdens the state treasury, and the benefits are manifest only indirectly: in a better environmental quality and in improving health status as its consequence. Whereas in the developed industrial countries environmental protection realised on company level, the introduction of eco-taxes and other elements of environmental policy, while also representing a burden, enhance the competitiveness of companies (by saving of resources as well as by the enhancement of the environment-friendly nature of products). Hence they have direct economic advantages even in a traditional sense of the term.

It can also be noted that those tasks of environmental policy have come to the foreground by accession that would rather serve the mitigation of global and European, and not local and domestic problems. (The natural gas programme, and the rapid limitation of the carbon dioxide and sulphur dioxide emission of power stations, but even programmes related to sewage disposal have mostly served the regional aims of reducing pollution crossing over state borders.) Environmental policy enjoys greater support in the case of problems directly affecting the population’s quality of life and less in global issues. Whereas accession to the EU has brought the latter ones to the foreground.


Expectations facing the new entrants

A detailed and reliable wording of the expectations of environmental protection and environmental policy, set for the Associate Members, is given by the 25 August 1997 publication („Guide”) of the Commission.1 The Guide has surveyed the so-called horizontal legislation dealing with the comprehensive and general issues of environmental regulation, including environmental impact study, the directives regulating obligatory information, and legislation related to such horizontal supporting mechanisms of the EU, like the European Environment Agency, or the LIFE-programme. It also dwelt upon problems of environmental law related to the individual environmental elements (quality of air, waste management, quality of water, etc.), or those going beyond general rules, or requiring particular attention, in other words upon all those issues that were not dealt with by the Essen White Paper of 1995.

Obviously it was the experiences of negotiations conducted with countries wishing to accede that prompted the Brussels bureaucracy to prepare the Guide. Though the Guide was ostensibly written in the ‘spirit of’ the White Paper, it is essentially more comprehensive for environmental issues than the White Paper had been. The 1995 White Paper contained all those requirements (and not only the environmental ones) that were necessary to the appearance of countries wishing to accede in the single market of the EU, but it covered only about 36 directives and 11 regulators of the totality of about 300 legal documents, whereas the Guide dealt with almost twice as many, namely with about 70 directives and 21 regulators. In addition the Guide made efforts to entirely cover the area in depth as well. The novelty of the document was that it dealt with questions of implementation rather extensively. The Guide revealed that implementation strategy should be convincing in view of the possibilities of economic realisation and the legal approach was to extend over the sanctioning mechanisms as well.

In our domestic legal approach it has been mostly the strictness of rules and norms that was put in focus and resolute steps were taken to assert the environmental principles of the EU, such as the principle that the pollutant should pay, the principle of integrated pollution preventing and the principle of subsidiarity in Hungarian environmental legislation. Whereas the Brussels bureaucracy, obviously not accidentally, focused on such elements of the institutional system of environmental legislation like the elaborated mechanisms of social participation and the involvement of stakeholders in general in the entire process of legislation and the implementation of law. The Guide especially focused on the issue of the ‘respective offices’ in the horizontal and detailed legislation as well, namely that we have to document convincingly that the ‘respective offices’ do possess the necessary professional skill and certificates that they are really ‘respective’ ones, but the Guide ‘raises’ also the issue of conflicting interests in relation to the ‘respective offices’: an authorising office cannot also promote a ‘project’.2


Differences in the social assessment and support of environmental protection

Environmental protection is a Janus-faced chapter of our accession to the European Union. This area is characterised by positive features (per capita environmental loading is modest, good indicators in the area of the protection of nature and of biodiversity, etc.) besides the grave problems (sewage disposal and purification, urban air pollution, the unsolved issue of waste disposal, etc.). What is rather alarming is that while the demand for a clean and healthy environment has been significantly revaluated in the developed countries, and the condition of the environment has become one of the most important components of the quality of life, in the countries wishing to accede environmental protection is not considered a problem that worries society most because of more urging economic and social problems, namely that some regions and social strata are lagging behind, poverty is becoming massive, and there is unemployment. This difference by itself provokes some reservation in the citizens of the EU Member States towards those wishing to accede. Citizens of the EU usually regard countries applying less rigorous regulations as ‘free riders’ (because that way they obtain competitive advantage in the single market), and they are also mistrustful towards food and other products coming from there.

The financing of environmental protection in the EU, in keeping with the principle of integrating environmental aims into economic policy, increasingly comes from the Cohesion Fund, the Structural Fund and agricultural subsidies and not from resources earmarked for environmental protection.

Hungary’s environmental achievement and the major characteristics of its environmental policy

The condition of the natural environment of Hungary may be regarded as mediocre in international comparison, and usually more favourable if compared to the other former East European countries. During the past ten years the trend of the set of conditions of domestic environmental policy experienced two breakages. The first one was caused by economic recession and the change of the system following it, and the second one by preparations for accession to the EU.

Economic recession primarily hit the heavy industrial sectors significantly polluting the environment and as a result significant improvement could be experienced in the so-called traditional forms of burdening the environment (sulphur-dioxide, nitrogen oxides, dust, heavy metals, etc.). Structural change of the Hungarian economy resulted in a favourable breakage of the trend regarding the age of applied technology, and the efficiency of the utilisation of matter and energy. Changes in the orientation of Hungarian economy in the external markets, and hence the market requirements of the EU becoming decisive had positive side effects. It can be felt in the solution of domestic environmental problems. An almost 70% share of the EU markets in Hungarian exports has made the prevalence of the quality requirements of the EU general in the domestic market as well. MOL (Hungarian Oil Company) for instance has been able to achieve significant results in altering the chemical composition of fuels, and it was partly due to this change that petrol of lead content could be eliminated from the market from May 1999 onwards.

Structural transformation that has taken place since the change of the political system and the moderation of personal consumption, further on the reduction of the energy consumption of the country3 has had a favourable impact on the environment. It was particularly the crisis of iron and aluminium metallurgy and of heavy chemical industry that was felt in the improvement of the quality of air, and facilitated the implementation of some international agreements on the environment (primarily the agreement on sulphur-dioxide). The quantity of sulphur-dioxide emitted to the air was reduced by almost 30% between 1985 and 1990 (Table 1.), largely because the use of coal was restricted. Sulphur-dioxide emission dropped by another 30% between 1990 and 1995, partly as a result of economic recession (emission by industry and agriculture), and partly because the natural gas programme was continued (emission by the population). The favourable impact of the reconstruction of power plants was beginning to be felt only during the recent few years (1999). Due to technological limitations changes of the emission of sulphur-dioxide by power plants was not significant between 1990 and 1997.


Table 1
Distribution of the total SO2 (kiloton/year) by sources of emission
between 1985 and 1997 in Hungary

Source of emission















Thermal plants





















A similar change has taken place in respect of particulates. The first radical reduction took place between 1985 and 1990 (from 491 kiloton/year to 205 kiloton/year), and a continuous improvement can be observed since that time. Emission by the population was reduced by about half (34.4 kiloton/year) as a result of the natural gas programme between 1990 and 1997, while emission originating from transport has been growing here too.

The annual changes of the emission of nitrogen-oxides were characterised by a rapid reduction between 1985 and 1992 (Table 2), and then by slow growth after 1992. The rapid decrease up to 1992 was characterised by a moderation of the emission of nitrogenous gases by the industry and the population. Whereas increase after 1992 is unambiguously related to the growth of emission by transport and power plants. Thus the ‘environmental gift effect’ of economic transformation in respect of nitrogen-oxides can hardly be demonstrated on the basis of aggregate data, because the emission of productive sectors has decreased but the emission of nitrogen-oxides has increased more as a result of growing motorisation and the production of electric energy. (Table 2).


Table 2
Distribution of the emission of nitrogen-oxides (kiloton/year) by the more significant sources of emission between 1985 and 1997 in Hungary

Source of emission















Thermal plants





















All in all the emission data of nitrogen-oxides may be regarded favourable since the growth of output of the productive sectors has been achieved parallel to decreasing emission. Transport emission however gives cause to anxiety in so far as the growth of nitrogen-dioxide emission is a consequence of a surge ahead of road transport and of a deteriorating performance of public transport. In addition growth has emerged despite the fact that emission per one ton, or one passenger kilometre shows a decreasing tendency due to a favourable change in the technical condition of the fleet of vehicles.

As far as methane emission, playing a significant role in greenhouse effect is concerned, there was no sizeable change between 1985 and 1997. As a result of decreasing animal husbandry and coal mining methane emission was less by about 100 and 42 kilotons respectively in 1996 than it had been in 1985. At the same time methane emission due to the transportation of natural gas grew by 85, and emission deriving from household wastes by 87 kilotons during the same period.

The EU makes significant efforts to regulate the emission of carbon dioxide, considered to be the most important greenhouse gas. It can be regarded an achievement that we are able to meet our international obligations in this respect too. Carbon dioxide emission was falling up to 1995, then it again started to grow with economic upturn. The carbon dioxide emission of the industrial sector, showing a significant improvement of performance and mostly producing economic growth has been evenly decreasing and the carbon dioxide emission of the population has also been falling (Table 3). In the latter case obviously it is the increasing price of energy that encourages savings.


Table 3
Changes of the annual carbon dioxide emission in Hungary
between 1990 and 1997 (kiloton/year)*

Emitting sector





18 560

14 300

12 623


8 779

7 470

10 543

Thermal plants

19 661

21 500

22 280


18 845

12 670

11 153


3 470

1 788

1 950


76 043

63 452

64 782

* Source: Ministry of Environment, Division for the Protection of Environmental Elements


Favourable changes are moderated by the structural transformation of transport degrading environmental performance in this case too (Table 4).


Table 4.
Changes of the structure of transport in Hungary between 1996 and 1998*





Transport of goods in million freight ton kilometres

24 874

24 789

27 144

Of which: by road

10 182

10 430

12 592

Of which: by rail

7 634

8 149

8 150

Distance passenger transport in million passenger kilometres

21 161

21 924

22 585

Local passenger transport, million passenger kilometres

10 495

9 386

9 613

* Source: Annual data of the Central Statistical Office (http://www.ksh.hu Table 6.23)


As data of the Table show, the growing performance of transport increasingly takes place along roads the environmental consequences of which are alarming not only regarding carbon dioxide emission. In the transport sector contradictory processes take place from the angle of environmental effects. While the emission of transport decreased as a result of economic depression and following the shrinking of economic activities working with large volumes of matter, in addition to the improvement of fuel quality, a surging ahead of motorisation and the decrease of the use of rail and public transport enhance environmental harm.

Prior to the change of the political system and following it hazardous wastes caused the most significant socio-environmental conflicts. Besides the real problems the chaos experienced in this area is also caused by the uncertainties of information and the ‘unwelcome activities of political adventurers’. Despite the fact that the area has been in the crossfire of constant political manoeuvres, the Ministry of the Environment has the data in Table 5 at its disposal for the period between 1993 and 1997.


Table 5
Annual changes of the quantity of hazardous wastes in Hungary
between 1993 and 1997 in t/year*







Wastes of vegetal and animal origin

680 954

583 659

556 115

310 119

320 846

Wastes of mineral origin

141 621

189 475

191 979

928 891

2 438 226

Metallic wastes

   2 022

   3 013

   2 693

   20 558

   14 789

Wastes of chemical transformation

1 707 260

1 547 446

1 515 164

437 426

287 670

Wastes of settlements and institutions

   19 203

   20 250

   8 358

222 435

157 970

Hospital wastes




   5 274

   5 723

Total without red slime

2 551 060

2 343 843

2 274 309

1 924 703

3 225 233

Red slime

1 343 545

993 993

1 149 297

660 031

404 927


3 894 605

3 337 836

3 423 606

2 584 734

3 630 160

* Source: Ministry of the Environment, VEHUR and HAWIS databases.


The data are more suited for deterrence than for the elaboration of some kind of environmental strategy. According to the Table the quantity of hazardous wastes had hardly changed between 1993 and 1997, despite all efforts, what is certainly not true. The quantity of red slime (a remnant of aluminium production) for instance was reduced to its less than one-third, and the hazardous wastes of food processing industry dropped to less than half. It is worth noting about the latter one that a large part of it does not cause irreversible changes in the environment. The quantity of the wastes of the truly hazardous chemical transformations was one-sixth in 1997 of the quantity in 1993. And the quantitative growth of hazardous wastes of settlements and institutions should be welcomed for it means that we have succeeded in collecting separately an increasing part of the hazardous wastes that formerly had been put into communal waste (batteries, dry batteries, dyes, solvents, etc.).

The distortion of aggregate data is caused by the radical growth of the wastes of mineral origin between 1996 and 1997. Clearly it is the waste-rock of mining activities that is classified as hazardous waste of Class III by the government decree No. 102/96. This ‘item’ however totally hides all those achievements we have ‘accomplished’ in the prevention of the production of hazardous wastes. The inverted commas are justified by the fact that a large part of the achievements is due to the structural change of the economy, but the effect of those efforts is also significant that has been provoked by problems deriving from the productive sphere, by the radical growth of the expenses of the disposal of wastes, and from the administrative and social resistance to the disposal of hazardous wastes. As it is seen, the aggregate data hide these favourable tendencies, thus projecting a worse than real image of the condition of our industry and not only of our environment at the threshold of EU membership.

As a result of the transformation of agriculture the utilisation of fertilizers per hectare has dropped below 50 kilos, that is one-tenth of the quantity of fertilizers used in the Netherlands or Denmark per hectare. The utilisation of other chemicals by agriculture has also radically dropped, together with burdening the environment with chemicalization. The setback of the utilisation of fertilizers and herbicides was due to the reduction of the production volume and of the solvency of large-scale farming in agriculture. Animal husbandry was drastically cut, together with the most polluting pig-breeding with fluid manure. The favourable environmental effect however is partly diminished by the lack of control over the use of chemicals by small farmers.

The other break of trend is the consequence of our preparation for accession to the European Union. Priorities have changed in the field of environmental protection, in keeping with the EU requirements. The environmental legislation and practice of countries at first concentrates on the solution of environmental problems directly affecting the population, and cross-border problems and obligations deriving from international treaties would only come next. As a consequence of our intention to accede issues that presumably would have been dealt with only later on were promoted. Support of environmental policy is greater for environmental problems directly affecting the quality of life of the population and less for global issues, whereas accession to the EU has brought the latter ones to the foreground. (For instance, this was the case of the gas programme for the moderation of carbon dioxide emission, whereas urban air pollution is a direct health hazard affecting masses of the Hungarian population; such an extent of a domestic programme for sewage disposal and purification primarily serves the purity of the Carpathian basin as a catchment area and hence the interests of the Danube and the Black Sea, while we are struggling against the maintenance of clean drinking water that affects a significant proportion of the Hungarian population; we make rather expensive efforts to reduce sulphur-dioxide emission, while we are unable to deal with our grave problems of public health and labour hygiene.)

The two breaks of trend have been accompanied by several favourable consequences, but resulted in an unbalanced development. The framework law on environmental protection and the emission limit values meet the requirements of the EU, but the setting up of institutions have developed unevenly and the necessary conditions are missing to the operation of institutions having a decisive authorisation in environmental protection. For instance, the local governments have several authorisations in environmental protection to which neither the personal nor the objective conditions are sufficient. The Ministry of the Environment does not consider the experts of inspectorates and even less those of the local governments sufficiently skilled for the tasks to be solved, hence it is centralising authorisations whereas the issues cannot be managed centrally. The citizens have little trust either in the authorities or in the so-called independent experts. Often more efforts are spent on the identification of responsibility than on the solution of problems exactly because of the underdevelopment of the set of institutions. Presumably the problem of environmental policy that is most difficult to remedy is not so much supplementing the conspicuous deficiencies of the infrastructure but the elimination of mistrust towards the set of institutions. The adverse consequences of the latter one are manifest most in waste management, and particularly in that of hazardous wastes. The development of the necessary institutions in keeping with the principle of subsidiarity is more time-consuming than it was originally assumed by the time-span of EU-harmonisation. The development of such institutions was not accorded adequate attention, thus we have hardly succeeded in reducing lags in this area.

The focal points of our tasks for environmental policy

The Hungarian economy (disregarding agriculture) generally still pollutes the environment more than the economies of developed countries due to its still relatively backward structure and technological level4. It means that the emission of pollutants and the utilisation of resources of a thermal plant, an industrial one, a means of transport, machine or equipment, etc. of the same profile would be higher in most cases than in the developed industrial countries, and there is less money available for the elimination of environmental damages. At the same time the volume of economic activities, per capita consumption and the level of motorisation are much lower than they are in the industrially developed countries, therefore the situation in most cases is more favourable in our country in the area of per capita emission. This fact ought had to be emphatically stressed during the course of accession negotiations.

We are laggard in three important fields: in sewage disposal and purification, in waste management and in clean air. (The first two areas are often referred to as the infrastructure of environmental protection.) The 1995 Act on environmental protection and a series of subsequent supplementary laws and orders, the five-year comprehensive programme for legal harmonisation and the six-year National Programme for Environmental Protection point forward even independently of approximation and have created an expressly good framework for an environmental policy that is acceptable even by the EU. The acts on product charges have opened the way for the charging of environmental fees and their newer forms, and instruct members of the business world as well as citizens and make them accept that the use and pollution of the environment has a price to be paid or the shift to less polluting modes of production and consumption should be undertaken. The elaboration of the National Environmental Health Action Programme and of the National Programme for Agro-Environmental Protection is also remarkable. In addition the acts and regulations on animal hygiene, the act on foraging and food products, the acts on the protection of nature and on the protection of animals should also be underlined, as all of them harmonise with the regulations and practice of the EU Member States. In the area of sewage disposal and purification, and the protection of clean air the evolution of adequate domestic regulation is still missing. A further shortcoming is that no act has been drafted so far on plant protection, plant hygiene and for the regulation of industrial gene technology. Legal regulation should also be strengthened in the area of protection against noise and risk analysis related to hazardous materials and accidents.

The Commission of the EU, when assessing the questionnaires, acknowledged results achieved in environmental legislation, and stated that full harmonisation could be accomplished in the area of environmental law in medium term, on the other hand it held that the observance of environmental requirements could be hoped for only after lasting investments of significant levels and for administrative efforts in a series of areas (urban sewage disposal, quality of drinking water, some areas of waste management and air pollution), that may be solved after a ‘long’, or ‘very long time’ by Hungary.

The difference between the opinion of the Commission and the domestic experts was presumably explained by the fact that the condition of the environment unfolding from the answers of the Hungarian government was more adverse in several respects than the real one. The examples quoted by the EU Commission also mostly derived from the unjustified and partly distorted self-assessment (condition of the soils, sewage purification, wastes, quality of air). The Hungarian answer mentioned, for instance, intensive agriculture as a significant problem, further on also the nitrogen and phosphor load of waters of agricultural origin. As it was mentioned above, these were not in harmony with the data of specific fertiliser utilisation.

Naturally there are environmental problems in domestic agriculture, but Hungarian agricultural production has never been so intensive as the West European one.

We have drawn a similarly negative image of waste production and management, when we ourselves stated that „the specific and absolute values of production and communal wastes accruing in Hungary are high in international comparison.” Data used to assessment were mostly distorted ones, as neither building rubble nor discarded machines were considered by environmental waste cadastres in international practice. International comparison calls attention precisely to the lack of reliability and contradictory nature of domestic data, in other words, the above statement would obviously require more precision. Consequently we have to improve the domestic system of waste cadastre, but the solution of waste management problems is still awaited.

The assessment by the Commission and the examples quoted warn us to pay more attention to what image we are projecting about ourselves to the world. All this does not modify the fact that the three areas should continue to constitute the focal tasks of our environmental policy.

Our lagging behind the implementation of laws and regulations is partly a cognitive and partly a financial issue. The lack of money is primarily related to our low level of economic development. Domestic companies (those in domestic ownership) do not have sufficient means for environment-friendly technological development, and the state budget is unable to adequately finance the environmental executive organs and networks that are supposed to make the rules or norms observed. Often it is a mistaken decision of legal policy, the lack of intention, a missed transformation of organisation, or the lack of information that are behind the low level of implementation. The conditions of accession affect the set of institutions in several respects. As it is commonly known, subsidies from the Cohesion and Structural Funds of the EU can be obtained primarily for regional development, agriculture and environmental protection. Though the size of those Funds and the extent of subsidies that may open up sometime in the future are highly uncertain (more over, even the long-term existence of those Funds is uncertain), the support system of regional development and agriculture must be made ‘EU-conform’ by all means so that potentially we may become suited for winning those subsidies. Regional development is ‘by itself’ an environmental and land use issue, and as far as agriculture is concerned the most recent developments in the EU show that support is being increasingly linked to cultivation sparing the environment, to the preservation of biodiversity and its development.

The introduction of subsidiarity as the principle of optimisation among the decision-making levels also touches upon the set of institutions. In addition to strengthening the general process of democratisation and favourably influencing it, that principle plays a similar role to the introduction of West European principles and language of environmental policy, and the development of ‘EU-conform’ systems of support: we have to approximate the practice and decision-making structure of the EU member states in this area too.

Similarly to the unjustified negative image drawn by the Hungarian answers to the Commission’s questions about the condition of the environment, an excessively positive picture of legal practice and the level of the development of the institutions were suggested. The discrepancy between the answers given to questions related to the condition of the environment and of the set of institutions can be easily explained: the condition of the environment is an external factor influenced by other sectors, by the ‘pollutants’ for the Ministry of the Environment, whereas the creation and development of the set of institutions, including legal regulation, is its internal task and competency. And it is almost natural that we are more critical about the work of others and more lenient towards our own. The negative image painted about the condition of the environment evokes doubts of economic nature in the officials of the EU: how could infrastructure developments and programmes for environmental rehabilitation be financed? And the more favourable assumption mediated about the set of institutions raises the issue of the effectiveness of the set of institutions: if the set of institutions is adequate then why is the condition of the environment so poor?

It is clearly seen on the basis of the 1997 Guide that it is expedient to present the condition of the environment more exactly and to be somewhat more critical about the achievements in the development of the institutional system. The doubts of the EU bureaucracy can hardly be dispersed without it, since the EU has passed the level of development regarding environmental protection when norms declared by legislation would count as achievements by themselves. The respect and enforcement of norms guarantee environmental safety. If any condition of it is missing (either social attitude, or money) one cannot speak about environmental safety. One of the important messages, if not the most important one of the Guide is that there may be unsolved problems, but there cannot be problems we do not know about and we do not have programmes for their solution.

The 2000 assessment of the Commission on the progress of Hungary in the area of meeting the requirements of environmental protection does not give a very favourable picture. The opening sentence states that „...last year there was a small extent of progress made in legal approximation compared to the ambitious National Programme for Environmental Protection and to the 1999 National Programme for the Adoption of the Acquis Communautaire ”. The summary of general assessment is not more flattering either: „So far only limited progress can be experienced in the area.”

The prohibition of the sale of leaded petrol and the setting up of the data base for the quality of air figure as positive measures. The report stresses the critical situation in relation to the passing of the Act on waste management. The Commission criticised Hungary for not implementing the short-term priorities of the Accession Partnership regarding the enforcement of the IPPC guideline, radiation safety and the environmental impact study.5 Activities in the area of sewage management of settlements and the protection of nature are praised. „Further efforts are needed to approximate the acquis communautaire, particularly in the following areas: horizontal regulation in view of assuring access to environmental information, stipulations for the implementation of waste management regulations, water quality standards for drinking water, baths, aquatic environment and sewage management, the prevention and reduction of industrial pollution, limitation of noise emission by building industry equipment and household gadgets ... Administrative capacity should also be further strengthened ...the systems of monitoring and data base should be further developed in the area of the protection of air, soil and against noise.” These were the tasks the performance of which was expected from us by the Commission.6


Economic and social impact study of accession

The adoption of the environmental law of the EU has been progressing in good speed. The most frequently raised question in this respect is how much it would cost to Hungary to meet EU requirements. Economic analyses so far performed have given contradictory answers moving within rather broad limits to this question. The gravest tasks appear in three or four areas. In addition to the estimated cost of about HUF 2300-2500 thousand million at 1997 prices of harmonisation tasks related to water, air pollution, waste management, and the directives of integrated pollution prevention and control (IPPC) the cost of the harmonisation of the other directives for the protection of the environment and nature appear to be insignificant. According to analyses the most significant item is sewage management, and particularly gap between closing the water supply and the development of sewage systems. It is precisely this area where the greatest difference of opinion has emerged among experts, perhaps because the survey of tasks is the most detailed one in this field, and it should be added that technologically it is the best founded. The discussion is first and foremost about the actual cost of building one km of sewage conduit (the so-called sewage estimate), about the desirable solutions of sewage disposal and purification, the environmental sensitivity of domestic areas and about the desirable proportions of sewage conduit system. Makers of the plans for development, starting from the literal implementation of the EU directives, considered supplying sewage system to 100% of settlements having more than 2000 inhabitants, and calculated the per km cost on the basis of the central estimate, while according to practical experience costs depend on actual conditions, and sewage conduits have been built in settlements for less than half of that estimate. The experts also challenge the need for the general implementation of the ‘activated sludge’ treatment of wastewater regarded as the only true one. According to the opinion of several of them the cost of the harmonisation of environmental law and the extent of the necessary derogation have been rather overestimated by studies, including those that were made in the framework of the Green Entry researches of the Hungarian Academy of Sciences. One source of overestimation has been the different interpretation of the periods available for legal harmonisation. Currently we have considered only those expenses that are expected to emerge up to 2010, and the prices were calculated on the 1997 level. We made efforts to present low cost alternatives as well, if possible, first of all in the case of sewage disposal that would ensure the desirable environmental condition but presuppose a more flexible interpretation of the EU directive.


Social and economic effects

The different specificities of geographic, social and economic factors make the consistent implementation of the principle of regionalism necessary when environmental policy is elaborated and realised. Regional inequalities that manifest also in the quality of the environment are intertwined with social and economic differences, therefore the development of regions and settlements has an important role in the prevention and solution of environmental problems. Part of the existing environmental problems is explained by the underdevelopment of the infrastructure in the country, at the same time the potential negative environmental consequences of inevitable future developments may be reduced if environmental considerations are integrated into the plans and programmes of regional development. As a result both sectors may account for dual benefit while strengthening each other’s position: financing and the access to the development resources of the European Union may become more effective.

Environmental protection and the preservation of nature are also two areas helping and supplementing each, while the corresponding activities should be closely coordinated. The sustainable use of our natural resources and the preservation of our values are not only moral obligations, but also long-term economic and social interests, this is why the Basic National Plan for the Protection of Nature (NTA) was passed together with the general plan of implementation of the National Environment Programme. The environmental costs of accession would be dominantly manifest in the development of the infrastructure for the protection of clean air, waste management, sewage disposal and monitoring. It is the tasks related to the implementation of the IPPC directive that influence most the performance and competitiveness of the economy. In addition the study of costs extends over the cost of the establishment of institutions assisting implementation and enforcement (including educational and training demands as well). So far analyses have not considered the impact of costs on the future redistribution of incomes in the environmental context (neither in other areas to our knowledge). The impact on income distribution may be studied in several dimensions. Here it is expedient to mention two of them briefly. The first area is the impact of redistribution among sectors. While certain sectors are expressly bearers of the expenses of the desired improvement of environmental performance, other sectors get into an expressly more favourable situation as a result of the implementation of environmental requirements.

Sectors shouldering the burden
of growing demands

Sectors enjoying the benefit of growing demands and of the improving condition of the environment

Energy industry


Chemical industry

Branches of environmental industry


Building industry


Bank and insurance service providers

Light industries (textile, leather, paper, etc.)

Health insurance




Local governments


Public administration


On the one side environmental policy related to accession to the EU obviously burdens some actors of the economy, whereas on the other side it creates new business opportunities. (A growing market, for instance, for building or environmental industry, a growing income expressed even in the number of days spent by tourists due to a cleaner environment, and an improving quality of the environment may mean a population of improving health condition for health insurance even if the latter ones may be sensed in a longer run.) These effects should be considered at financing, hence the expenses of environmental development should not be necessarily collected only from the polluting sectors. In other words, the polluting sectors should not be burdened by further environmental taxes during the preparatory period as it would be more expedient to press them for accepting voluntary obligations by contracts. It would better serve the realisation of the criteria of economic efficiency and would be in full harmony with the objectives spelt out by the IPPC directive. It is expedient however to involve branches profiting more from an improving quality of the environment in financing environmental development for the reason that they are going to be the beneficiaries of a speeded up development because of the growth of their price income or the lowering of their costs (even in shorter /building industry, environmental industry/, or a longer term /tourism, health insurance, etc./).

Another dimension not to be disregarded is the impact of environmental measures on the income structure of households. Meeting the environmental requirements would have a significant influence primarily through the growing price of energy, of fees for water and sewage disposal and for waste management, but it may have a differentiated impact on households depending on income levels. As the expected increase of the public utility charges will only marginally affect the expenses of strata in the top income categories, more over their energy-saving measures would return to them, in the case of those belonging to lower income categories the increase of public utility charges represents an unbearable burden (in cases taking up 20-25% of the family income).

The territorial distribution of strata belonging to the different income categories rather enhances and does not reduce problems. Higher income strata usually live in areas with good public utility supply, while in the case of people living in areas of poor supply there is no chance of their contribution to the necessary developments. If the 3 or 4 times average per capita income difference between the eastern and western parts of the country is considered then obviously the possibility for the inhabitants for contributing to the development of public utilities, the so-called ‘absorption capacity’ is missing in many settlements in the eastern part of the country. From an environmental aspect accession to the Union may have obstacles that are not primarily due to the economic performance and load-bearing capacity of the country. The real problem is caused by spending resources available for investment on the development of such local infrastructure that is less important and efficient as a consequence of lobbying by the local business and political circles. This distracts resources from the most burning issues and from solutions that are most efficient on the level of the national economy.

There is a realistic opportunity for acquiring and utilising EU resources serving the reduction of regional differences only if we prepare ourselves for these problems and are capable of handling them.

Meeting the environmental conditions of accession is accompanied by a respectable profit. Well-founded international analyses show that the returns of environmental investments consistently exceed the average rates of return realised by investments in other areas. They are mostly benefits that cannot be expressed numerically but rather appear in the condition of the environment (revaluation of natural capital), in improving human health, and in effects favourably influencing and encouraging other sectors and spreading further in circles of waves.



The space of movement of environmental policy in relation to accession to the Union is strongly influenced by the income position of the population, as the greatest backwardness is found in such areas of environmental infrastructure like the availability of sewer system, or waste management. The estimated cost of the building of aquatic public utilities itself only would be between HUF 500 to 800 thousand million, hence those opinions are understandable that stress primarily problems of financing in relation to accession to the EU and to environmental protection.

In our view the management of those social conflicts is even more important than financing that hamper decision-making in the area of community investments trying to achieve equally optimal efficiency regarding the environment as well as the economy. Experience shows that budgetary subsidies serve the interests of economic development as well as environmental protection with deteriorating efficiency. Decreasing efficiency is partly a natural phenomenon, but it is quite probable that the ‘pressure’ of regions and strata in a too strong position of interest assertion would considerably deteriorate environmental effectiveness, and this is the reason by which we really risk meeting the requirements of accession to the Union.




Guide to the Approximation of European Union Environmental Legislation. Commission Staff Working Paper. Commission of the European Communities, Brussels, 1997.


Page 26 of Guide. Obviously the Guide refers to the solution of conflicting interests related to local governments in connection with environmental impact study.


From 1316 PJ in 1989 to 1043 PJ. In 1994 and after the beginning of economic growth even the value for 1998 was only 1046 PJ.


This statement covers up extremities miles apart, as incoming working capital usually represents the most developed technological standards.


The realisation of the IPPC guideline is a long-term task even for Member States, therefore we are somewhat at a loss to receive that criticism.


Annual report of the European Commission, 2000, Chapter 22.