MRS LUDMILA PETKOVA
CHAIRMAN OF
THE INTERAGENCY WORKING GROUP
ABOUT: the proposals discussed in an interdepartmental working group (MRG), established by Order P-7 of 9.01.15/XNUMX/XNUMX.
DEAR MRS PETKOVA,
KRIB approves the approaches and methodologies for determining the fee for household waste based on the "polluter pays" principle. We believe that the adoption of the "polluter pays" principle will lead to a reduction in the number of persons who unlawfully avoid paying such a fee, which will also lead to a reduction in the revenues associated with this fee.
We support the idea that the components of the cleaning fee (old name "household waste fee") to be 3 as follows:
1. collection and transportation of household waste to facilities and installations for their treatment;
2. treatment of household waste in facilities and installations;
3. maintaining the cleanliness of the territories for public use in populated areas.
We believe that the bases for each of the listed components should be determined separately in order to increase the transparency in determining this fee, which as a result would lead to the elimination of innate mistrust on the part of citizens and businesses. In this way, greater clarity will be achieved regarding the reasons for paying the fee and the "polluter pays" principle will be effectively applied. The grounds from which the respective owner/user shall have the right to choose are in principle three, and divided by components of the fee for maintaining cleanliness to be distributed as follows:
A. Basics for the componentcollection and transportation of household waste to facilities and installations for their treatment“:
- number of users of the service in the property, with the number of users of the property being declared by its owner/user and:
- the individual amount due per user is determined by dividing the municipality's expenditure for each of the 3 components of the fee for which this basis is chosen by the total number of users
- the household waste fee for properties for which the number of users has been declared is determined by multiplying the individual amount due by user by the number of declared users;
- the amount of household waste for the property, determined according to the number and capacity of the necessary containers for collecting household waste;
B. Basics for the componenttreatment of household waste in facilities and installations“:
- number of users of the service in the property, as the number of users of the property is declared by its owner/user and:
- the individual amount due per user is determined by dividing the municipality's expenditure for each of the 3 components of the fee for which this basis is chosen by the total number of users
- the household waste fee for properties for which the number of users has been declared is determined by multiplying the individual amount due by user by the number of declared users;
- the amount of household waste for the property, determined according to the number and capacity of the necessary containers for collecting household waste;
C. Basics for the componentmaintaining the cleanliness of the territories for public use in populated areas“:
- number of users of the service in the property, as the number of users of the property is declared by its owner/user and:
- the individual amount due per user is determined by dividing the municipality's expenditure for each of the 3 components of the fee for which this basis is chosen by the total number of users
- the household waste fee for properties for which the number of users has been declared is determined by multiplying the individual amount due by user by the number of declared users;
Note: We believe that the basis "individually measured amount of household waste per property" can be very difficult to apply to a user for the properties of natural persons. Our understanding is that this hardly means that the truck that collects the waste is equipped with a measuring device and each time measures each amount of waste it generates and at the end of the year makes a report for each property how much waste it has generated, for to be able to charge him approximately the same estimated amount next year, which in practice cannot be realized. This is also impossible for enterprises that are served with the "beaver" type containers (1 cubic m), since one truck collects the contents of 20 such containers.
KRIB presents several principle proposals to be discussed in the working group, as follows:
1. To indicate a legal definition in units of measurement of the term "quantity of household waste"
2. To make an assessment of the MRG regarding the impact of the discussed changes in different municipalities, according to the five categories specified in the Unified Classifier of Administrative and Administrative-Territorial Units, respectively to assess how the introduction of these changes will affect businesses and citizens .
3. The owner/occupier shall have the choice, each year, to determine different types of bases to be applied to the 3 separate components of the cleanliness fee.
4. To give the possibility of exemption from the first two components for properties in which facilities of the energy technical infrastructure are located, during the operation of which no domestic waste is generated and the enterprises operating these facilities have declared this fact by October 31 of the previous year in municipality and location of the property.
4a. To give the possibility of exemption from the first two components for properties for which the owner enterprises use licensed companies for the servicing of these components and the enterprises have declared this circumstance by October 31 of the previous year in the municipality of the location of the property.
5. To release the properties automatically (and not by express declaration), which fall within the territorial limits for which the "cleanliness maintenance fee" services are not provided.
6. To have provided incentives for:
- separate collection, incl. an alternative approach that acts as a motivation, e.g. through the purchase of bags with a certain capacity;
- when an investment is made in the relevant municipality in facilities and installations for disposal, disposal and overall treatment/management of household waste
6. That the Municipal Council has no right to choose what basis and/or method to apply to a specific property.
7. Broader discussion of changes with affected parties, incl. various municipalities and large manufacturing enterprises.
With respect,
Eugene Ivanov
Ex. director
http://www.turbulence.tech