Institutional and Functional Review of Air Quality Management in North Macedonia December 2024 © 2024 International Bank for Reconstruction and Development / The World Bank 1818 H Street NW Washington DC 20433 Telephone: 202-473-1000; Internet: www.worldbank.org This work is a product of the staff of the World Bank Group with external contributions. The findings, interpretations, and conclusions expressed in this work do not necessarily reflect the views of The World Bank, its Board of Executive Directors, or the governments they represent. The World Bank does not guarantee the accuracy, completeness, or currency of the data included in this work and does not assume responsibility for any errors, omissions, or discrepancies in the information or liability concerning the use of or failure to use the information, methods, processes, or conclusions set forth. 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Washington, DC: World Bank.” All queries on rights and licenses, including subsidiary rights, should be addressed to World Bank Publications, The World Bank Group, 1818 H Street NW, Washington, DC 20433, USA; fax: 202-522-2625; email: pubrights@worldbank.org. Cover design Marieta Vasileva. Contents Acknowledgments iv Acronyms v Executive summary vii 1. Introduction 1 1.1 Air pollution in North Macedonia and its consequences 2 1.2 Rationale and objective of the institutional and functional review 4 1.3 Methodology 5 2. Legal, regulatory, and policy framework for AQM 7 2.1 National framework legislation governing AQM 8 2.2 Alignment with the EU acquis 9 2.3 Air quality planning instruments at the national and local levels 11 2.4 Critical review of the six AQM functions 13 2.4.1 Setting air quality standards and objectives 14 2.4.2 Determining required emission reductions 15 2.4.3 Designing air quality control strategies 16 2.4.4 Implementing air quality control strategies 18 2.4.5 Monitoring implementation and enforcing compliance 20 2.4.6 Air quality monitoring, reporting, and progress evaluation 23 2.5 Recommendations to strengthen the legal and policy framework 24 3. Institutional configuration and capacity for AQM 28 3.1 Ministry of Environment and Physical Planning 29 3.1.1 North Macedonia’s Environmental Information Center 30 3.1.2 Environmental Administration 31 3.1.3 Addressing staff shortages and capacity constraints 31 3.1.4 Institutional reconfiguration to strengthen AQM performance 33 3.2 Local self-government units 37 3.3 State Environment Inspectorate 40 3.4 Other relevant institutions and opportunities for strengthening AQM 41 3.4.1 Ministry of Economy and Labor36 and Ministry of Energy, Mining and Mineral Resources 41 3.4.2 Ministry of Health and Institute for Public Health 41 3.4.3 Other sector ministries and specialized agencies with AQM-related responsibilities 41 3.5 Institutional financing for AQM 43 3.6 Recommendations to strengthen institutional capacity for AQM 44 4. Coordination across sectors and levels of government 46 4.1 Horizontal coordination 47 4.2 Vertical coordination 47 4.3 Recommendations to strengthen vertical and horizontal coordination 48 5. Communication, participation, quality assurance, and accountability 50 5.1 Communication and participation 51 i 5.2 Quality assurance and accountability 52 5.3 Recommendations to strengthen quality assurance and accountability 53 6. Conclusions 54 References 57 Annexes 61 Annex 1: Methodological framework 61 Annex 2: Additional details on North Macedonia’s legal and policy framework for AQM 64 1. EU legislation shaping North Macedonia’s legal and policy framework for AQM 64 2. North Macedonia’s comprehensive AQM regulatory framework 64 3. Regulations for stationary emission sources 65 4. Other legal and policy documents related to air quality and emission management 65 Annex 3: Summary assessment of the legal specifications of AQM functions and their performance in practice 67 Annex 4: The contribution of chimney sweeps to effective AQM - an EU example 69 List of tables Table ES.1: Recommendations by analytical dimension (details provided in Chapters 2–6) xv Table 1: Important EU legislation on air quality and emission control and status of transposition into national law in North Macedonia 10 Table 2: LSGUs obliged to prepare an AQP, by AQP status 13 Table 3: Overview of limit values and guidelines per pollutant, by jurisdiction, and actual measurement in North Macedonia 14 Table 4: Assessment of AQM functions by legal specification and performance in practice 24 Table 5: Recommendations to strengthen the legal and regulatory framework for AQM 25 Table 6: Planned MoEPP budget for AQM, in MKD and EUR, 2024–2026 43 Table 7: Recommendations to strengthen institutional capacity for AQM 44 Table 8: Recommendations to strengthen vertical and horizontal coordination 49 Table 9: Recommendations to strengthen vertical and horizontal coordination on quality assurance and accountability 53 Table A.1: AQM framework: Analytical categories, guiding questions, and review criteria 63 List of figures Figure 1: Air pollution levels in North Macedonia’s cities compared to other European cities (PM2.5) 2 Figure 2: Pollutant emissions by the Nomenclature for Reporting (NFR) sector in North Macedonia, 2021 3 Figure 3: Matrix of AQM functions and analytical dimensions 6 Figure 4: Current organizational structure of MEIC 30 Figure 5: Public versus private sector pay in North Macedonia 32 Figure 6: Scenario 1 (short term): Proposed institutional structure to strengthen AQM 34 Figure 7: Scenario 2 (medium term): Strengthening implementation support functions in MoEPP 35 Figure 8: Scenario 3 (long term): Proposed hierarchy and reporting lines of state administrative bodies subordinate to the Ministry of Environment 37 Figure 9: Mapping recommendations against the six AQM core functions 55 ii INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA List of boxes Box 1: Synergies between air pollution control and climate change mitigation 4 Box 2: The role of emission inventories and source apportionment for AQM 16 Box 3: Guidance and good practice examples for developing AQPs 17 Box 4: Guidance and mechanisms for financing AQP implementation 19 Box 5: The contribution of chimney sweeps to effective AQM - an EU example 21 Box 6: The chimney sweeping system as proposed in the draft law developed by Skopje 22 Box 7: AQM responsibilities covered by MoEPP 29 Box 8: Institutional arrangements for AQM implementation support: Examples from other countries 36 Box 9: AQM with limited capacity and resources: Example of Kumanovo 38 Box 10: Strengthening municipal capacity for AQM and citizen-oriented advisory services: Air quality managers in Slovakia and eco-managers in Poland 38 Box 11: Ensuring accountability for preparing AQPs: An example from Poland 52 CONTENTS iii Acknowledgments This report was prepared by a World Bank core team lead by Klas Sander (Senior Environmental Economist) and Maja Murisic (Senior Environmental Specialist) and included Eolina Petrova Milova (Senior Environmental Specialist) and Gaurav D. Joshi (Senior Environmental Specialist) under the overall guidance of Kseniya Lvovsky (former Practice Manager) and Sanjay Srivastava (Practice Manager). Clemens Gros with inputs from Elena Gavrilova Dimitrovska provided analytical and technical inputs for the preparation of the report. The report additionally benefited from the guidance and leadership of Massimiliano Paolucci (Country Manager for North Macedonia and Kosovo), Xiaoqing Yu (Country Director, ECCWB), Christopher Sheldon (Country Manager, ECCBM), and Ramon Munoz-Raskin (Program Leader, ECCWB). The team would like to express its sincere appreciation and gratitude to the partners in North Macedonia who participated in discussions and interviews and provided information and detailed comments which helped improve this report. Special thanks are due to Aneta Stefanovska, Martina Toceva, and Aleksandra Nestorovska-Krsteska (Macedonian Environmental Information Center, Ministry of Environment and Physical Planning). The logistical and administrative support provided by Linh Van Nguyen, Grace Aguilar, Luan Aliu, and Mario Jankulovski is gratefully acknowledged. iv INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA Acronyms AAP Ambient Air Pollution ADEME  French Environment and Energy Management Agency (Agence de l’Environnement et de la Maîtrise de l’Energie) AQM Air Quality Management AQP Air Quality Plan CAFE Clean Air for Europe CJEU Court of Justice of the European Union CLRTAP Convention on Long-Range Transboundary Air Pollution  EA Environmental Administration EEA European Environment Agency EIA Environmental Impact Assessment EnEV Energy Saving Ordinance EPA Environmental Protection Agency E-PRTR European Pollutant Release and Transfer Register  EU European Union GDP Gross Domestic Product GHG Greenhouse Gas HAOP Croatian Institute for Environmental and Nature Protection (Hrvatska Agencija za Okoliš i Prirodu)  HMS Hydrometeorological Service IEC International Electrotechnical Commission IED Industrial Emissions Directive IFR Institutional and Functional Review IMF International Monetary Fund IPA Instrument for Pre-Accession Assistance IPH Institute for Public Health IPPC  Integrated Pollution Prevention and Control ISO International Organization for Standardization  KÜO Federal Sweeping and Inspection Ordinance (Kehr- und Überprüfungsordnung)  LAAQ Law on Ambient Air Quality LoE Law on Environment LSGU Local Self-Government Unit MAFWE  Ministry of Agriculture, Forestry, and Water Economy MCPD Medium Combustion Plant Directive MEIC Macedonian Environmental Information Center  ACRONYMS v MoE Ministry of Economy MoEL Ministry of Economy and Labor MoEMMR Ministry of Energy, Mining and Mineral Resources MoEPP Ministry of Environment and Physical Planning  MoH Ministry of Health MoI Ministry of Internal Affairs MoLSG Ministry of Local Self-Government MoTC Ministry of Transport and Communications NALAS Network of Associations of Local Authorities of South-East Europe  NAPCP National Air Pollution Control Program NEC National Emission Ceilings NERP National Emission Reduction Plan NFR Nomenclature for Reporting NFR Nomenclature for Reporting NMVOC Non-Methane Volatile Organic Compounds  PAH Polycyclic Aromatic Hydrocarbons SAAAQMS State Automatic Ambient Air Quality Monitoring System  SAŽP Slovak Environment Agency (Slovenská Agentúra Životného Prostredia)  SchfHwG  Chimney Sweep Craft Act (Schornsteinfeger-Handwerksgesetz) SEI State Environmental Inspectorate SLCP Short-Lived Climate Pollutant STAP Short-Term Action Plan UBA German Environment Agency VSL Value of Statistical Life VVD State Environmental Service (Valsts vides dienests)  WHO World Health Organization ZELS Association of Self-Government Units (Zaednica na Edinicite na Lokalna Samouprava)  vi INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents Executive summary Air pollution in North Macedonia and its consequences People in many parts of North Macedonia are exposed significant co-benefits for climate change mitigation. to more toxic particulate matter air pollution than their The country’s long-term Development Framework 2030 neighbors in Western Europe. This is especially true for and the National Development Strategy 2024 frame air residents in urban areas, such as Skopje and Tetovo. Al- quality improvement as an important objective in the coun- though air quality has improved since the 1990s, air pol- try’s efforts to transition to a low-carbon economy, ensure lution levels remain high in most urban locations across economic growth, and tackle climate change. Air pollution North Macedonia, particularly during cold winter months. and climate change share common sources and impacts on In Skopje, average annual ambient fine particulate mat- the environment and human health. Therefore, policies ter1 (PM2.5) pollution concentrations reach eight times the aimed at reducing air pollution can simultaneously address World Health Organization (WHO) Air Quality Guideline climate change, leading to significant co-benefits (Box 1). level of 5 µg/m3, while in Tetovo, pollution levels can even Moreover, curbing air pollution reduces the economic and reach ten times this threshold.2 health burden of AAP and safeguards productivity by pro- tecting human health and well-being. The burning of solid fuels for heating in homes and oth- er buildings is a main driver of high ambient concen- The cost of inaction is high, and the need for more ef- trations of particulate matter air pollution, particularly fective AQM is evident. Effective AQM requires a strategic during the winter months. North Macedonia’s informa- and coordinated approach which has proven challenging tive inventory report and source apportionment analysis in North Macedonia given the country’s relatively slow indicate that, at a national level, the residential sector is progress in reducing air pollution. To tackle this challenge by far the largest source of population exposure to harmful holistically, there is a need to better understand the legal, PM2.5 associated with the burning of solid fuels in homes regulatory, and institutional bottlenecks for AQM in North (MoEPP 2023b; World Bank 2019b). Macedonia. The high levels of air pollution in the country have sig- The objective of this institutional and functional re- nificant negative effects on human health and the econ- view (IFR) is to provide insights and develop recom- omy. A recent study on the effects of air pollution in North mendations for strengthening the legal, regulatory, Macedonia estimated that about 2,800 people die every and institutional framework and capacity for AQM, en- year from causes associated with ambient air pollution abling national and local authorities to deliver better air quality for their citizens. Therefore, the IFR analyzes (AAP) (World Bank 2022). The annual economic cost as- the legal framework and institutional configuration as well sociated with the health damage from AAP in North Mace- as the current practice in policy making and institutional donia is estimated at an average US$1.7 billion, equivalent coordination, enforcement, monitoring and implementa- to 15.9 percent of gross domestic product (GDP) in 2016 tion of air quality plans (AQPs) and investment programs, (World Bank 2022). among other priority areas. It also includes an assessment The Government of North Macedonia has recognized of the institutional capacity of crucial AQM actors in North air quality management (AQM) as a key building block Macedonia, with a view to suggesting suitable capacity toward sustainable economic development, acknowl- strengthening interventions that can make a lasting impact edging the link between AQM and energy policy and its on AQM. ___________________________________ PM2.5 refers to particulate matter with a diameter than 2.5 μm or less. 1  2 Measurements for North Macedonia from 2022 as the most recent year for which comprehensive data are available from MoEPP on its website: https://tinyurl.com/moepp-list-of-zones; all other locations: WHO air quality database: Update 2022, measurement year 2019.  Contents EXECUTIVE SUMMARY vii Analytical framework AQM is organized into six interdependent functions for The six AQM functions are critically reviewed in four this IFR. The common goal of these AQM approaches is to analytical dimensions. This approach will reveal the most deliver impactful action to ensure the best possible quality important legal and regulatory as well as institutional of air, avoiding or minimizing adverse effects on human constraints for effective AQM in North Macedonia. It also health, the environment, and the economy. The six AQM assesses the extent to which horizontal and vertical coor- functions can be viewed as a cyclical process where each dination across sectors and levels of government supports step is embedded in an interdependent sequence of other impactful air pollution control and whether there are com- steps: (1) establishing goals, standards, and objectives; (2) munication and participation, quality assurance, and ac- determining required emission reductions; (3) developing countability mechanisms in place. Recommendations will control strategies; (4) implementing control strategies; (5) be formulated based on the findings from the analysis in monitoring implementation and enforcing compliance; these dimensions. and (6) ongoing air quality monitoring, reporting, and progress evaluation in relation to air quality objectives. Legal, regulatory, and policy framework for AQM North Macedonia has made significant strides in align- EU nor the Ecodesign Directive (2009/125/EC) for smaller ing its framework legislation on air quality with that of appliances (heaters and boilers below 1 MWth) have been the European Union (EU), particularly regarding over- transposed into national legislation. The draft Rulebook arching air quality ambitions, although some gaps re- on the Quality of Solid Fuels for Heating has awaited final- main. The country has transposed 93 percent of the Clean ization in the Ministry of Economy (MoE) for some time. Air for Europe (CAFE) Directive (2008/50/EC), the EU’s Following the change of government in mid-2024, it is now cornerstone legislation on air quality, and 85 percent of the the responsibility of the newly established Ministry of En- Fourth Daughter Directive (2004/107/EC) but not yet Di- ergy, Mining and Mineral Resources (MoEMMR). rective 2015/1480/EC which amends several annexes to An EU-funded project launched in November 2024 to the two aforementioned acts pertaining to reference meth- close the remaining gaps in North Macedonia’s leg- ods for air quality assessment. North Macedonia has fully islative and policy alignment with the EU acquis. The transposed the original National Emission Ceilings (NEC) project ‘Support in the Implementation of Air Quality Di- Directive (2001/81/EC), while the new NEC Directive rectives’ is funded under the EU’s Instrument for Pre-Ac- (2016/2284/EU) stands at only 11 percent transposition cession Assistance (IPA II). With a total financing volume into national legislation. The emission reduction commit- of EUR 1.5 million, three activity packages aim to update ments for five main air pollutants under NEC have not yet North Macedonia’s legal framework to be fully aligned been defined. At the time of writing this report, the com- with the EU acquis, develop new national-level AQPs and mitments were under development by the Ministry of Envi- strategies to replace the outdated documents discussed ronment and Physical Planning (MoEPP) in the framework below, improve air quality monitoring and reporting, and of the EU-funded IPA II project and with inputs from the strengthen the national emission inventory. regional EU4Green project.3 All directives referred to in this paragraph are partially implemented. Two of the country’s main national strategic AQM doc- uments require updating, and there is no systematized Important pieces of EU legislation and national second- information on the progress of their implementation. ary legislation which can significantly reduce emissions The National Plan for Ambient Air Quality Protection from industrial and residential sources have not yet 2013–2018 was adopted in 2012 as the government’s been transposed and adopted. Only 62 percent of the In- overarching air quality planning instrument, as required dustrial Emissions Directive (IED) 2010/75/EU have been under the Law on Ambient Air Quality (LAAQ). The law transposed into national legislation. However, neither the requires MoEPP to report on the plan’s execution to the Medium Combustion Plant Directive (MCPD) 2015/2193/ government biennially, but systematic implementation ___________________________________  ttps://eu4green.eu/about-us/. 3 h viii INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents progress reporting has not taken place. The National cent move to revise its air quality standards, North Mace- Program for Gradual Reduction of Emissions of Certain donia may find it challenging to keep pace with the dynam- Pollutants 2010–2020, also adopted in 2012, defines ic regulatory environment of the EU. measures to reduce annual emissions by key sources to Specific process requirements and an accountability prevent exceedances of the NEC. The document consti- mechanism would be valuable additions to the regu- tutes the National Air Pollution Control Program (NAP- latory framework to ensure the timely and complete CP) as required by the NEC Directive (2001). As a third preparation and adoption of up-to-date air quality planning instrument, in 2018 the government adopted standards. North Macedonia’s laws do not specify the pe- a special Program for Reduction of Air Pollution, to be riodicity or manner in which air quality standards are to be implemented in 2019–2020, but there has been little fol- set. Combined with the institutional capacity constraints in low-up and implementation monitoring to date. MoEPP and other ministries (Chapter 3), this has left sev- At the local level, 15 municipalities and the city of Sko- eral important EU directives yet to be fully transposed into pje are required to prepare an AQP because of pollut- national legislation to set pollution control objectives, such ant limit value exceedances or a population size of over as the industrial emission directive, the medium combus- 35,000 inhabitants. The majority of the municipalities have tion plant directive, and the Ecodesign directive, among prepared a plan only recently with financial and technical others. assistance from MoEPP or international support projects. The ministry leveraged funding from its Environmental In- vestment Program and hired third-party consultants to draft  etermining required emission 2. D the plans. Most AQPs were prepared by the same contrac- reductions tor based in Skopje. Kumanovo, Strumica, and Veles are the The requirement to calculate the amount of emission only local self-government units (LSGUs) that invested their reductions needed to achieve national air quality stan- own financial resources to support the preparation of their dards and objectives is anchored in the LAAQ and the AQP by a team of consultants. Considering this experience corresponding rulebooks. MoEPP takes the lead respon- and to ensure local-level ownership and capacity for AQM, sibility and the process is clearly defined. Following the it is advisable for the ministry to update its 2016 guidelines transposition of the first NEC Directive (2001/81/EC), on AQP development, provide periodic AQM trainings to North Macedonia established emission limit values and municipalities, and reorient its future support toward more adopted process guidelines in the ‘Rulebook on the quan- strategic advice to LSGUs to prepare their own AQPs. tities of upper limits: ceilings of the emission of polluting A detailed review of the existing setup of the six core substances for the purpose of determining projections for AQM functions and their performance in practice con- a certain period of time that refer to the reduction of the firms that North Macedonia’s legal and regulatory quantities of pollutant emissions on an annual basis’ (Of- framework is mostly fit for purpose, except for moni- ficial Gazette no. 2/10, 156/11, and 111/14). The LAAQ toring AQM implementation and enforcing compliance, requires MoEPP to develop a National Program for Gradual especially regarding residential emissions. The findings Reduction of Emissions of Certain Pollutants, which is an of this review are presented by AQM function. NEC requirement. The last program was valid for 2010– 2020 and has since expired. However, North Macedonia has transposed the new 1. Setting standards and objectives NEC Directive (2016/2284/EU) by only 11 percent as North Macedonia’s legal framework clearly assigns re- a basis for establishing emission reduction commit- sponsibilities for setting air quality standards and ob- ments. The Decree on National Emission Reduction jectives, with MoEPP taking the lead role. The country Commitments for NEC pollutants by 2030 is under has adopted the core air quality standards defined in the preparation. The government has not yet calculated the relevant EU directives. For example, EU CAFE directive reduction potentials for the five main pollutants covered pollutant limits have been adopted and anchored along under the NEC directive. Work on this activity has begun with other air quality standards in 16 bylaws, rulebooks, with support from the EU IPA II project, with inputs from and national guidelines. However, capacity constraints in the EU-funded EU4Green project 2022–2025 implement- MoEPP—with no dedicated unit for air quality legislation, ed by the Austrian Environmental Agency. Moreover, the policy, and planning—mean that legislative initiatives are IPA II project is tasked with strengthening the national air tackled relatively spontaneously and somewhat dependent pollutant emission inventory in accordance with the NEC on external support. Considering the existing gaps in the directive. Given the severe air quality impact of solid fuel transposition of the EU air quality acquis, and the EU’s re- combustion for residential heating, the introduction of  Contents EXECUTIVE SUMMARY ix mandatory chimney sweeping can fill the current informa- and energy efficiency potential, and establish an effective tion gap about technology and fuel use in the residential compliance enforcement mechanism. sector to feed granular data into emission inventories. mplementing air quality control strat- 4. I  esigning air quality control 3. D egies strategies Although the responsibilities for implementing air qual- At the national level, MoEPP has the responsibility to ity control measures are relatively well defined at the prepare two crucial plans: the National Plan for Ambi- national and local levels, there is room to strengthen ent Air Quality Protection and the National Program for implementation and progress reporting. The main bottle- Gradual Reduction of Emissions of Certain Pollutants necks are related to accountability, ownership, capacity, and both of which have been overdue for an update for years. financing. The LAAQ does not establish an accountability The need for updating both documents points to systemic mechanism to ensure national or local AQPs are implement- bottlenecks in developing air quality legislation, policies, ed. Neither ministries nor municipalities face consequences and plans. The National Plan for Ambient Air Quality Pro- for failing to take effective measures to reduce air pollution. tection is to be developed by MoEPP, in coordination with Other countries have instituted financial sanctions to ensure the Ministry of Health (MoH) and Ministry of Economy and compliance (see Section 5.2). Since most national and lo- Labor (MoEL). It is the overarching strategy document in cal air quality planning documents have been prepared with which the government lays out its measures to manage air external assistance, ownership of the proposed measures quality within the set limit values per pollutant. The second appears to have remained limited across some sectors and main air quality control document is the National Program in municipalities. Implementation is further constrained by for Gradual Reduction of Emissions of Certain Pollutants, an shortages of qualified staff and financial resources. Most NEC directive requirement that has already been transposed LSGUs face significant budget shortfalls which also affect into the LAAQ. Both documents have been overdue for an AQM. To strengthen the ability of LSGUs to implement update for years. This is mostly due to the limited institu- AQPs, the central government could consider establishing tional capacity dedicated to policy, planning, and implemen- an ‘AQM investment fund’ to finance municipal air quality tation follow-up as well as insufficient funding and therefore control measures, similar to the newly established Energy a tendency to utilize external support. Efficiency Fund to finance investments in energy efficiency in the public sector (Ministry of Finance 2023). Resources At the municipal level, additional staff capacity and could be allocated proportional to population size and se- updated, practical guidelines on AQP preparation verity of the air pollution issue. would be important measures to strengthen local AQM. The majority of the 16 LSGUs required to develop an AQP have never had such a plan before, partly because  onitoring implementation 5. M of limited capacity. Each municipality typically employs and enforcing compliance only a small number of staff members in the environment sector who are responsible for covering all media; there- North Macedonia would benefit from having a work- fore, limited staff resources can be dedicated to AQM. To ing mechanism in place to monitor the preparation reduce the need and dependence on intensive technical and implementation of national and local AQPs. The assistance by MoEPP and increase municipal ownership scarcity of information prevents effective follow-up and over the AQP development process, it would be desirable constitutes a significant barrier to effective AQM. Accord- for the ministry to provide updated, practical guidelines ing to the provisions of the LAAQ, MoEPP is responsible on local-level AQP development and implementation, for reporting on the progress of implementation of the na- in addition to what is prescribed in the corresponding tional AQPs outlined above. Likewise, LSGUs are required rulebook. Moreover, most municipalities do not have to submit annual progress reports on their AQPs and household-level information on the type of heating in- STAPs to MoEPP. Taken together, these sources of infor- stallations, fuel type, and quality used. The absence of mation, if functional, could provide the government with granular local emission inventories limits the amount of a comprehensive overview of whether adequate plans are information that can be used for priority setting in AQPs in place and implementation is progressing as envisaged and constitutes a barrier to the design, implementation, or additional efforts are needed. In practice, the reporting and enforcement of effective air quality control measures. requirements have not been met, so the implementation Chimney sweeping can play an important role in building status of most AQP measures remains unchecked. The a bottom-up inventory of emission sources, offer house- LAAQ does not incentivize timely compliance by minis- hold-specific recommendations on emission reduction tries or municipalities. x INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents There is room to strengthen environmental inspections been developed by the city of Skopje as part of an inter- at the state and local levels to monitor and enforce national twinning project. Chimney sweeps would not compliance of specific installations with environmen- only work toward fire safety and public safety, but they tal and air quality legislation. Compliance monitoring also fulfill extensive functions in inspecting and cleaning of A-integrated environmental permit holders, which are furnaces and fireplaces, measuring emissions, checking larger installations, is done by the State Environmental permissible fuel types and quality, and advising home- Inspectorate (SEI). However, staff shortages and limita- owners on how to reduce emissions, save energy, and save tions in technical expertise and equipment hinder the heating costs. The results of chimney sweep inspections effectiveness of these inspections. Authorized municipal can be used to build up a localized, granular inventory of environmental inspectors, hired by the municipality and emission sources. not reporting to SEI, are tasked with monitoring compli- ance with B-integrated environmental permit applying  ir quality monitoring, reporting, 6. A to smaller installations. Out of 81 LSGUs in North Mace- and progress evaluation donia, only 63 (77 percent) have at least one authorized inspector. In most municipalities that have inspectors, the North Macedonia’s legal and regulatory framework on function is said to be ‘completely unequipped’ regarding air quality monitoring, reporting, and progress evalu- training, experience, equipment, and number of staff, ation is well developed. Constraints in air quality mon- having to cover 28 laws and over 240 bylaws, including itoring data availability and quality are mostly related to air quality legislation. Inter-municipal cooperation on scarce financial and human resources. The provisions on inspections could alleviate this constraint but has been air quality monitoring and reporting in the LAAQ are ex- underutilized. Moreover, the present setup of separate tensive and make it the best established AQM function state- and local-level inspections is prone to inefficiencies from a legal perspective. Regulations are equally detailed. and missed opportunities for making AQM more coherent The Macedonian Environmental Information Center across levels of government. (MEIC), a dedicated unit within MoEPP, carries out the air quality monitoring work. The two laboratories responsible Emissions from residential sources are currently not for calibrating instruments and analyzing samples for air controlled. Chimney sweeps could play a pivotal role in quality measurement are not International Organization the local AQM monitoring and enforcement system, but for Standardization (ISO) accredited, potentially affecting there is currently no legal basis for residential inspection the credibility of North Macedonia’s data. Moreover, the and reporting. A draft law has been prepared and consti- air quality data that are available are not used routinely tutes a promising starting point. Unlike in other countries to review air quality planning documents such as AQPs or and jurisdictions, North Macedonia’s laws and regula- inform an assessment of the effectiveness of AQM at the tions do not define clear legal requirements for residential state or municipality levels. This is again partly due to in- inspections and reporting on heating installations and air stitutional capacity constraints that need to be resolved to pollution emissions from households. The draft law has strengthen AQM, as discussed below. Institutional configuration and capacity for AQM MoEPP is North Macedonia’s main authority respon- term. All other environmental media already have ded- sible for environment and air quality but exhibits a icated departments in the EA. The proposed unit for air critical institutional gap; it does not have a dedicated quality policy, planning and implementation supervision unit for air quality legislation, policy, planning, and within the Department for Air Quality would take on all implementation supervision. Therefore, in an unusual out-of-scope tasks currently performed by MEIC’s Air arrangement, MEIC has taken on these tasks, operating Quality Monitoring Unit such as drafting legislation, reg- well beyond its mandate and stretching its already limited ulations, and strategic planning documents and oversee- capacity which is meant to focus on environmental infor- ing municipal AQM. As MEIC is responsible for reporting mation and reporting. and disseminating data for all environmental domains, not just for air quality, it is suggested that only the Air Establishing a Department for Air Quality, with a new Quality Monitoring Unit is moved from MEIC to the new unit for air quality policy, planning, and implementa- Department for Air Quality to consolidate all specific tion supervision, in the Environmental Administration AQM-related functions. A new Emission Inventory Unit (EA) of MoEPP would mitigate this issue in the near within the recommended Department of Air Quality is  Contents EXECUTIVE SUMMARY xi proposed to take over air pollution emission inventory-re- for example, emphasizing the benefits packages of public lated tasks currently performed by MEIC, while adding sector jobs. new capacity for building up a granular emission inven- At the local level, municipalities bear the brunt of AQM tory from local sources and data that would be generated implementation responsibilities, considering that the from chimney sweeps. residential sector is the largest contributor of particu- The extensive AQM implementation support tasks cur- late matter air pollution, but limited financial resourc- rently performed by MEIC should be transferred to es and technical expertise hamper the ability of most a dedicated unit for AQM operational support. Three LSGUs to manage air quality effectively. Air quality scenarios are conceivable in the short, medium, and long manager positions could offer some reprieve. Environmen- term. The MEIC experts currently cover a wide range of tal issues, including AQM, are often addressed by one or technical assistance roles, for example, assisting munici- few officials who have a multitude of other environmental palities in developing AQPs. In the short term, a unit for op- responsibilities and cannot devote sufficient time to pur- erational support could be created within the proposed De- sue air quality control measures. North Macedonia could partment for Air Quality. A medium-term solution would use its recently gained access to the EU LIFE program4 to be to consolidate implementation support functions across strengthen local AQM capacity by establishing air quality MoEPP by establishing a separate Program Implementa- manager positions, at least in the 16 LSGUs which are re- tion Department within the EA, with an Air Quality Project quired to prepare and implement AQPs. Successful exam- Implementation and Technical Assistance unit, along with ples for this exist in the region. implementation support units for all other media. In the long term, a new Agency for Environment that is subordi- Municipalities are also responsible for local environ- nated to MoEPP could assume these functions, as proposed mental inspections, a function that faces significant by a recent IPA-funded advisory project on state reorgani- capacity constraints. Inter-municipal cooperation on zation. However, this would require a more comprehensive air quality planning, implementation, and environmen- institutional overhaul. tal inspections could make AQM more effective and yield efficiency gains. Municipalities could share inspectors, or All ministry departments and units with AQM respon- smaller LSGUs pay larger ones for their services. The pres- sibilities are constrained by persistent staff shortag- ent setup of separate state- and local-level inspections es. Vacant staff positions must be filled by addressing suffers from obvious inefficiencies and missed opportu- the public-private wage differential. Between 40 and 60 nities for exploiting synergies and making AQM more percent of AQM-related staff positions envisaged in the coherent and consistent. The EU IPA-funded advisory ministry systematization has remained vacant, according project on state reorganization recommended to establish to recent information from MEIC. This is partly because an Environmental Inspectorate, subordinated to MoEPP, of a dearth of qualified candidates for the highly technical that would take on the functions currently performed AQM roles performed by MoEPP staff. Moreover, public by SEI and the authorized environmental inspectors in sector salaries are perceived not to be competitive com- LSGUs. For coordination, municipalities could be re- pared to private sector pay, making the limited number quired to establish local air quality coordination councils of qualified candidates to seek employment elsewhere. with representatives from neighboring LSGUs, civil soci- Recent data confirm that there is a public-private wage ety, academia, and the private sector. The councils would deficit in North Macedonia, especially for professional, advise on AQP preparation and contribute to supervis- scientific, and technical job categories. Therefore, in a ing implementation and revision. In addition, a manda- relatively small labor market such as North Macedonia, tory AQP peer review process could be institutionalized attracting qualified candidates to a technical function to strengthen the quality and coherence of the planning such as AQM may require providing additional incentives, documents across local jurisdictions. ___________________________________  he program was started in 1992 as the financial instrument for the environment or L’Instrument Financier pour l’Environnement 4 T (LIFE). xii INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents Coordination across sectors and levels of government Effective AQM requires air quality impacts to be con- still allowing for the creation of subordinate thematic, tech- sidered in multiple policy areas beyond a narrow focus nical working groups. A future amendment to the LAAQ on the environment, and in North Macedonia, there is should provide a legislative anchor for this mechanism and room to strengthen coordination on AQM and integra- its decisions to be binding on the participating institutions. tion of air quality policy priorities across sectors. This is The proposed inter-sectoral coordination mechanism especially true for transport, urban development, energy, ought to include a vertical coordination function be- industry and commerce, and agriculture. None of these tween central and local government authorities which sectors routinely reviews the effects of their policies and would strengthen the coherence of AQM policy priori- interventions on air quality comprehensively, and there are ties and enable the sharing of good practices. MoEPP, no specific and time-bound targets related to air quality im- in collaboration with the Ministry of Local Self-Govern- pacts to guide decision-making. ment (MoLSG), would be best placed to determine the Establishing a high-level inter-sectoral coordination structure and process of how LSGUs could be involved. It mechanism for air quality would be an important step in may be worth considering drawing on the capacity of the the right direction. This must build on the lessons learned Association of Self-Government Units (ZELS) as it already from an earlier attempt at coordinating sectors through represents the interests of all 80 North Macedonia’s munic- a technical working group which ultimately faltered. An ipalities and the city of Skopje in national policy processes. inter-sectoral group on air quality was led by MoEPP but Moreover, the MoEPP Department for Cooperation with stopped working in 2020, arguably because the establish- Local Self-Government and Administrative Supervision ment of this mechanism was not legally mandated and in- could play a supportive role in facilitating and moderating stitutionalized and because it was said that the group lead- this exchange together with MoLSG, although the MoEPP ership did not take a transparent and consistent approach Department would need to expand the scope of its work to sharing information and joint strategic planning. Hence, from its current focus on legal and misdemeanor proce- an inter-sectoral coordination mechanism should be estab- dures to provision of strategic and technical support. The lished at the level of state secretaries, with a secretariat led vertical coordination function would directly interact with by the proposed Department for Air Quality in MoEPP while the proposed municipal air quality coordination councils. Communication, participation, quality assurance, and accountability Communication on the state of air quality in North cils could serve as a platform to facilitate participation from Macedonia appears to work well, but mechanisms for diverse audiences. genuine citizen engagement in air quality planning and implementation appear to be limited, pointing to a need Quality assurance and accountability mechanisms for for more guidance on this, especially for municipalities. national- and local-level AQM are not envisaged by law. With most municipal AQPs having been adopted only re- Neither ministries nor municipalities face consequences for cently, experience with proactive involvement of the public failing to manage air quality under national plans, AQPs, or is limited and is underutilized. Anecdotal information sug- short-term action plans (STAPs). This undermines the ef- gests that the draft AQPs were released for public consulta- fectiveness of decentralized AQM. There are no sanctions tion, but few citizens provided input. This is understandable for failure to prepare, implement, or report on air quality given that, in the absence of a tailored strategy to solicit control measures. An enforceable accountability mecha- feedback from the wider public, nontechnical audiences nism is needed to ensure that the latest available evidence will find it difficult to participate in policy and planning pro- informs AQPs and national and local plans are prepared, cesses that are perceived to require specialized knowledge. implemented, and reported on. The experience from Po- To address this situation, MoEPP should include practical land can serve as inspiration. In this example, the regional guidance for municipalities on citizen engagement in AQP inspectorate for environmental protection can impose a development and implementation, something that the 2016 fine of up to EUR 115,000 on the regional parliament for AQP guidance document is not sufficiently explicit about. At failing to prepare an AQP or on the regional government the local level, the proposed air quality coordination coun- for failing to implement it.  Contents EXECUTIVE SUMMARY xiii Recommendations There is an evident need to strengthen the consisten- legislative and regulatory framework for air quality that is cy with which AQM governance framework documents fit for purpose hinges on adequate institutional capacity are prepared and to enhance the institutional capacity that can formulate and enforce it. Therefore, reorganizing required to implement, monitor, and enforce them. The the institutional setup of MoEPP and staffing it sufficiently 17 recommendations emerging from the four analytical di- would be a promising starting point to enhancing its pol- mensions assessed in this report are suitable to strengthen icy-making capacity and implementation oversight func- all six core AQM functions. They aim to address specific tion. A well-staffed and well-resourced Department for Air bottlenecks constraining the AQM functions in the legal Quality in MoEPP could drive a strategic AQM agenda for and regulatory sphere and boost institutional capacity, the country while supporting municipalities in developing horizontal and vertical coordination, and quality assur- and implementing effective air pollution control measures. ance and accountability. In parallel to institutional capacity development, Several recommendations would require profound which will take time, it is important to make the neces- changes to the current institutional configuration and sary legal and regulatory changes (recommendations legislation, albeit with a potentially transformational A.1 through A.7) in the near term to remove AQM-re- effect on how air quality is managed in North Macedo- lated bottlenecks in the EU accession process. Institu- nia. A dedicated Department for Air Quality would enable tional capacity strengthening is a medium- to long-term MoEPP to drive air quality legislation, policy, and imple- endeavor. This should not hold the government back from mentation with strategic foresight. A stronger inspection tackling the legal and regulatory changes to align North function, especially the introduction of mandatory chim- Macedonia with the EU air quality acquis and ensure that ney sweeping for all households, would finally bring res- air pollution control roles and responsibilities are clearly idential emissions within the control of the AQM system. defined and enforceable. Finally, strengthened horizontal and vertical coordination Both dimensions of change—institutional capaci- on AQM could improve the consistency and coherence of ty strengthening and legal and regulatory reform— air pollution control measures across sectors and levels of require strong coordination across sectors and levels government. of government (recommendations C.1 and C.2). This is To prioritize and sequence next steps to strengthen especially important given the co-benefits of AQM and cli- AQM, it is advisable to begin by implementing the rec- mate change mitigation. Therefore, coordination between ommendations on institutional capacity development MoEPP and MoEMMR on air pollution control and the en- (particularly B.1, B.2, and B.3 in Table ES.1). Having a ergy transition is crucial. xiv INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents _____________________________________________________________________________________________________________ Table ES.1: Recommendations by analytical dimension (see Chapters 2–6) No. Recommendation Responsible Legal and regulatory framework A.1 Complete the transposition of EU directives on air quality objectives. MoEPP A.2 Transpose specific EU emission control and related directives. MoEMMR, MoE, MoEPP A.3 Develop a new NAPCP as required by the NEC directive. MoEPP A.4 Update the 2016 guidelines on AQP development, including detailed guidance on citizen MoEPP engagement, and anchor it in the LAAQ (results of public participation in the preparation of the plan must be documented in the AQP). A.5 Short term: Promote inter-municipal cooperation on authorized environmental inspections. MoEPP Long term: Consolidate state and local environmental inspections in a proposed Environ- mental Inspectorate. A.6 Formally and practically embed the function of chimney sweeping in the AQM system, build- MoEPP, ing on the existing draft law. Enforce annual inspections of all buildings and use inspection LSGUs results to build a localized emission inventory and ensure households comply with air qual- ity regulations. A.7 Obtain ISO/IEC accreditation for the Central Environmental Laboratory and the Air Quality MoEPP Calibration Laboratory. Institutional configuration and capacity B.1 Short term: Create a Department for Air Quality in the EA, including a new unit for air qual- MoEPP ity legislation, policy, planning, and implementation supervision and a new unit for imple- mentation support and technical assistance. Medium term: Consolidate implementation support functions across MoEPP in a separate Program Implementation Department, with a unit dedicated to AQM implementation sup- port and technical assistance. Long term: Create a new Agency for Environment that is subordinated to MoEPP focused on implementation support, monitoring, analysis, and reporting functions. B.2 Fill vacant positions and attract qualified technical staff to AQM-related positions in the pub- MoEPP, SEI, lic sector through recruitment drives, emphasizing nonfinancial incentives such as benefits LSGUs packages and exploring opportunities for establishing specialized graduate degree programs in air quality control and environmental management. B.3 Establish air quality manager positions in municipalities, at least in the 16 LSGUs that are MoEPP, required to prepare and implement AQPs, to support AQP preparation and implementation MoLSG and provide citizen-focused advisory services. B.4 Institutionalize inter-municipal coordination on air quality planning with a local air quality MoEPP coordination council in each municipality that includes representatives from neighboring mu- nicipalities and a mandatory peer review of AQPs to strengthen coherence across jurisdictions. B.5 Short term: Promote inter-municipal cooperation on authorized environmental inspections. MoEPP Long term: Consolidate state and local environmental inspections in a proposed Environ- mental Inspectorate. B.6 Upgrade the air quality monitoring network to improve monitoring of heavy metals, black MoEPP carbon, non-methane volatile organic compounds (NMVOC), and polycyclic aromatic hy- drocarbons (PAH).  Contents EXECUTIVE SUMMARY xv No. Recommendation Responsible Horizontal and vertical coordination C.1 Establish a high-level inter-sectoral coordination council on AQM at the level of state secre- MoEPP taries or deputy ministers, with a secretariat managed by MoEPP and subordinate technical working groups, as required, and amend the LAAQ to regulate the establishment, member- ship, and mandate of the council and its members, the secretariat, and the technical working groups. C.2 Include a vertical coordination function on AQM between central and local authorities in the MoEPP, high-level inter-sectoral coordination council (C.1). MoLSG Quality assurance and accountability D.1 Establish a binding quality assurance mechanism for municipal AQPs. MoEPP D.2 Introduce an enforceable accountability mechanism for air quality planning and implemen- MoEPP tation of control measures, including sanctions for nonperformance at the national and local levels. xvi INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents 1Introduction  Contents INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA 1 1.1 Air pollution in North Macedonia and its consequences People in many parts of North Macedonia are exposed North Macedonia, particularly during cold winter months. to more toxic particulate matter air pollution than their In parts of Skopje, Kicevo, and Tetovo, average annual neighbors in Western Europe. This is especially true ambient fine particulate matter (PM2.5)5 pollution for residents in urban areas, such as Skopje and Tetovo. concentrations reach seven times the World Health Orga- Although air quality has improved since the 1990s, air nization (WHO) Air Quality Guideline level of 5 µg/m3 pollution levels remain high in most urban locations across (Figure 1). _____________________________________________________________________________________________________________ Figure 1: Air pollution levels in North Macedonia’s cities compared to other European cities (PM2.5)6 40 Annual avg. ambient PM2.5 EU PM2.5 30 Limit Value (µg/m3) 25 20 WHO PM2.5 10 AQG Value 5 0 Kicevo Tetovo Skopje-Lisice Skopje-Rektorat Strumica Prilep Berovo Bitola 2 Skopje-Centar Athens Ljubljana Zagreb Budapest Prague Bratislava Vilnius Vienna Riga Tallinn Source: WHO. _____________________________________________________________________________________________________________ The burning of solid fuels for heating in homes and A recent study on the effects of air pollution in North other buildings is a main driver of high ambient con- Macedonia estimated that nearly 2,800 people die ev- centrations of particulate matter air pollution, partic- ery year from causes associated with ambient air pol- ularly during the winter months (Figure 2). Source ap- lution (AAP) (World Bank 2022). Based on the estimated portionment analysis indicates that, at a national level, the exposure, about 14 percent of all deaths in North Macedo- residential sector is by far the largest source of population nia are attributable to PM2.5 exposure (World Bank 2022). exposure to harmful PM2.5 associated with the burning of People ages 50 years and older carry about 94 percent of solid fuels in homes (World Bank 2019b). Emissions from the health impacts. Nearly 80 percent of deaths due to AAP power plants also significantly contribute to PM2.5 air pol- occur from ischemic heart disease and stroke, which most- lution, followed by industry, transport, and agriculture. ly affect people older than 65 years. Therefore, this popula- During the cold season, peak pollution episodes are exac- tion group will require particular attention with mitigation erbated by adverse meteorological conditions that limit at- measures to reduce the impacts of air pollution in North mospheric dispersion. Macedonia. ___________________________________  M2.5 refers to particulate matter with a diameter of less than 2.5 μm, while PM10 stands for particulate matter with a diameter of less 5 P than 10 μm. Measurements for North Macedonia from 2022 as the most recent year for which comprehensive data are available from MoEPP on its 6  website: https://tinyurl.com/moepp-list-of-zones; all other locations: WHO air quality database: Update 2022, measurement year 2019. 2 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents _____________________________________________________________________________________________________________ Figure 2: P  ollutant emissions by the Nomenclature for Reporting (NFR) sector in North Macedonia, 2021 100% 80% 60% 40% Fugitive emissions Waste Agriculture 20% Power & heat generation Industry Road transport 0% Residential heating PM10 PM2.5 NOX SO2 Source: MoEPP 2023a. _____________________________________________________________________________________________________________ The annual economic cost associated with the health Federation’s invasion of Ukraine. Real GDP growth is pro- damage from AAP in North Macedonia is estimated at jected at 2.3 percent in 2023 and 3 percent in 2024, as per an average US$1.7 billion, equivalent to 15.9 percent the latest estimates (IMF 2024). The country’s long-term of gross domestic product (GDP) in 2019 (World Bank Development Framework 2030 (Government of North 2022). The economic burden associated with AAP has Macedonia 2022) and the National Development Strate- been quantified using a welfare-based approach to cost- gy 2024–2044 (Government of North Macedonia 2023) ing mortality, multiplying the estimated number of deaths frame air quality improvement as an important objec- from air pollution by the value of statistical life (VSL). The tive in the country’s efforts to transition to a low-carbon significant health and monetary consequences of air pollu- economy, ensure economic growth, and tackle climate tion in North Macedonia highlight the need for a holistic change. The government envisages reducing greenhouse approach to reduce air pollution in the country. gas (GHG) emissions by increasingly switching to renew- able energy sources, cleaner technology, and improving The Government of North Macedonia has recognized energy efficiency. Air pollution and climate change share air quality management (AQM) as a key building block common sources and impacts on the environment and toward sustainable economic development, acknowl- human health. Therefore, policies aimed at reducing air edging the link between AQM and energy policy and its pollution can simultaneously address climate change, significant co-benefits for climate change mitigation leading to significant co-benefits. Moreover, curbing air (Box 1). North Macedonia’s economy is recovering from pollution reduces the economic and health burden of AAP the consecutive shocks of the COVID-19 pandemic and and safeguards productivity by protecting human health a surge in energy prices in 2022, following the Russian and well-being.  Contents INTRODUCTION 3 Box 1:  Synergies between air pollution control and climate change mitigation Air pollutants and GHGs often come from the same sources, such as combustion in coal-fired power plants and diesel-fueled vehicles. Actions that reduce air pollution can have immediate benefits for the climate, partic- ularly through the reduction of short-lived climate pollutants (SLCPs) such as methane, black carbon (a compo- nent of PM2.5), ground-level ozone, and hydrofluorocarbons. SLCPs are more potent in their climate warming ef- fects than carbon dioxide (CO2) and are often released alongside other air pollutants such as PM2.5 (WHO 2022). Climate change, in turn, affects air quality through different transmission channels. For instance, climate change has led to more frequent wildfires, which pollute the air and have been linked to respiratory illnesses and premature births (Nolte et al. 2018). Policies and programs to reduce air pollution can generate important climate co-benefits by reducing GHG and air pollutant emissions. Therefore, maximizing the synergies between climate change mitigation and air pollution control would yield health benefits and reduce major contributors to global warming. Decarbonization strategies that include mitigation of SLCPs can yield significant benefits in the short to medium term, including improved air quality for human health, labor and agricultural productivity, and food security (Sánchez-Triana 2023). Recent World Bank research shows that low- and middle-income countries stand to benefit the most from SLCP mitigation (Sánchez-Triana et al. 2023). It is important to consider the potential trade-offs implicit in some climate change mitigation and air pol- lution control interventions. For example, in North Macedonia, biomass—predominantly wood—is a widely used energy source for residential heating. Sustainable sourcing can make biomass a carbon-neutral fuel. How- ever, burning biomass is an important source of PM2.5 pollution. Additionally, incomplete combustion, which fre- quently occurs in old or inefficient boilers and stoves that are found in many households, releases black carbon, a powerful SLCP. On the other hand, reducing air pollution by curtailing the use of biomass can lead to increased GHG emissions if biomass is substituted with fossil fuels such as gas.  ationale and objective of the institutional 1.2 R and functional review Effective AQM can significantly lower the health and may require introducing legal, policy, and strategic changes economic burden for North Macedonia associated with as well as reconfiguring institutional mandates and compe- illnesses and death from air pollution. The cost of inac- tencies at the national and local levels. tion is high. Tackling the problem of air pollution is crucial This institutional and functional review (IFR) aims to to enhance people’s quality of life and create the conditions contribute to a better understanding of the policy, in- for a thriving economy that ultimately wants to complete stitutional, and organizational bottlenecks for effective the European Union (EU) accession process. AQM in North Macedonia. The report seeks to inform le- The North Macedonia government has recognized the gal, policy, and institutional measures the North Macedonia urgency of addressing air pollution and initiated actions government can take to strengthen AQM and meet the re- to enhance air quality. At the same time, further changes quirements of EU air quality legislation. Therefore, the IFR are needed for a sustained reduction in pollutant levels and analyzes current practice in policy-making and institutional to bring air quality legislation and policies in the country coordination, enforcement, monitoring, and implementa- in line with those of the EU. North Macedonia received EU tion of air quality plans (AQPs) and investment programs, candidate status in December 2005 and the government among other priority areas. It also includes a light-touch committed itself to implement EU-related reforms. The EU capacity needs assessment of crucial AQM actors in North accession process presents an opportunity to learn from the Macedonia, with a view to suggesting suitable capacity experience of other EU countries how to improve air quality strengthening activities that can make a lasting impact on through emissions reductions from key pollution sources. AQM. The analysis will put special emphasis on controlling More importantly, the prospect of joining the EU provides emissions from residential sources because they are the larg- an added incentive to align legislation to the EU acquis. This est emitters of particulate matter air pollution. 4 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents 1.3 Methodology There is no universal definition of what constitutes an Developing control strategies. Depending on a coun- 3.  effective and efficient AQM system. Yet, it is possible to try’s regulatory framework, it may be the responsibility identify common patterns from analyses and experienc- of national, regional, or municipal decision-makers to es of other countries that produce good air quality out- develop emissions prevention and control strategies comes in diverse institutional, social, legal, and cultural that convey how the standards will be met. The design settings.7 and choice of emissions reduction options requires an understanding of the air quality, health, social and eco- For this review, AQM is organized into six interdepen- nomic benefits, and implications of different courses of dent functions (Figure 3). The common goal of these action across relevant sectors. AQM approaches is to deliver impactful action to ensure the best possible quality of air, avoiding or minimizing ad- Implementing control strategies. Roles and respon- 4.  verse effects on human health, the environment, and the sibilities for implementation are assigned in the emis- economy. sions prevention and control strategies. Implemen- tation can involve a broad range of stakeholders that  stablishing goals, standards, and objectives. Goals 1. E extend beyond government entities, for example, by or targets for air emissions or air quality define a pol- requiring households to replace old furnaces or avoid lutant limit value—or standard—that protects health, certain types of fuel for heating. welfare, or the environment. Air quality standards and objectives are typically set at the national level. The EU  onitoring implementation and enforcing compli- 5. M has issued an extensive body of air quality legislation ance. In contrast to air quality monitoring that is used that sets the standards to be adopted by member states to measure prevailing air pollution levels (see below), in line with WHO guidelines. routine implementation monitoring is required to as- sess whether the actions of individuals and institutions  etermining required emission reductions. Once 2. D comply with the provisions of the air control strategies. AAP standards have been set per pollutant, the nec- The enforcement function may require the collabora- essary level of emissions reduction can be identified tion of several government agencies, for example, envi- to attain and maintain the standards. This step de- ronmental protection agencies (EPAs), environmental pends on three prerequisites: air quality monitoring officers of local authorities, and local police. data, an emissions inventory that provides the data needed to calculate actual emissions from sources  ngoing air quality monitoring, reporting, and 6. O that contribute to air pollution, and source attribu- progress evaluation in relation to objectives. The tion that provides data analysis and modeling to de- air quality and emissions are monitored, through a net- termine which sources are the primary contributors work of measurement stations or remote sensing,8 to to air pollution. evaluate if the control strategy is working effectively and emissions reduction objectives are met. ___________________________________  he conceptual organization of AQM and the analytical dimensions draws on a diverse range of AQM concepts as reflected in Awe et 7 T al. (2015); Committee on Air Quality Management in the United States (2004); EEA (2019); and World Bank (2020, 2022). In the EU, emissions from industrial facilities are reported through the European Pollutant Release and Transfer Register (E-PRTR), a 8  Europe-wide register that provides key environmental data from EU member states and in Iceland, Liechtenstein, and Norway.  Contents INTRODUCTION 5 _____________________________________________________________________________________________________________ Figure 3:  Matrix of AQM functions and analytical dimensions Analytical dimensions A. Legal and B. C. D. regulatory Institutional Vertical Information & implementation & horizontal framework accountability configuration coordination AQM 1. Setting standards and objectives functions 2. Determining required emission reductions 3. Designing AQ control strategies 4. Implementing AQ control strategies 5. Monitoring implementation & enforcing compliance 6. AQ monitoring, reporting & progress evaluation Source: Original elaboration for this publication _____________________________________________________________________________________________________________ The six AQM functions will be critically reviewed in four Vertical and horizontal coordination. AQM can only C.  analytical dimensions. This approach will reveal the most be effective at scale if it is coherently integrated into important legal, institutional, and organizational bottle- national and subnational policies, programs, and pro- necks constraining effective AQM in North Macedonia. cesses and across sectors that contribute to air pollu- Recommendations will be formulated based on the find- tion. ings from the analysis in these dimensions: Information and accountability. International expe- D.  Legal and regulatory framework. Effective AQM A.  rience suggests that a functional AQM system is driv- depends on clear definitions of AQM functional tasks en by high-quality air quality data which are used to (‘what must be done’) that are anchored in national inform policy and planning decisions. Accountability and subnational legislation and regulations, unambig- mechanisms must be in place (a) to ensure government uous distribution of roles and responsibilities (‘who institutions fulfill their AQM functions and jurisdic- must act’), and well-defined processes for the functions tions meet their air pollution reduction commitments to be performed (‘how tasks must be implemented’). and (b) to provide citizens with opportunities to par- In the context of North Macedonia’s EU accession pro- ticipate, know their rights, and meet their obligations cess, it is crucial to ascertain that its legal and regulato- under AQM regulations. ry framework is aligned with EU requirements. The analysis presented in this IFR is based on data from a B. I  nstitutional implementation configuration and ca- desk review and informant interviews with key stakehold- pacity. This category will assess whether actors and ers in North Macedonia at the national and subnational institutions are in place and fit for purpose, in line with levels. More detailed information about the methodolog- the legal and regulatory framework; whether man- ical framework and the review questions applied in each dates are aligned with their functional AQM tasks; and analytical category can be found in Annex 1. to what extent existing levels of capacity and resources are sufficient to implement AQM functions. 6 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents 2Legal, regulatory, and policy framework for AQM  Contents LEGAL, REGULATORY, AND POLICY FRAMEWORK FOR AQM 7 In light of North Macedonia’s ambition to join the EU, cy and planning instruments and identifies room to this chapter reviews the extent to which the country’s strengthen the six core functions of effective AQM. formal governance arrangements align with the EU’s Recommendations are presented at the end of the air quality legislation and policy. It also assesses the chapter. state of the national- and local-level air quality poli- 2.1 National framework legislation governing AQM The EU accession process has shaped North Macedonia’s The LAAQ defines which national and local air quality efforts over the past 20 years to strengthen and align its planning instruments must be adopted, already incor- legal and regulatory framework with EU standards. Two porating the pivotal CAFE directive requirement for laws stand out as laying the foundations for environmental AQPs in zones and agglomerations where the concen- and air quality governance. trations of pollutants exceed limit values. AQPs are a key instrument for AQM and assess the state of air quality The Law on Environment (LoE), first adopted in 2005 within a zone, pollution sources, and measures to be taken and subsequently amended,9 establishes important by local authorities to reduce air pollution. The limit values principles, obligations, and ways of working, including adopted by North Macedonia are aligned to those of the EU the subsidiarity principle and the polluter pays princi- (Table 3). Where there is a risk of alert threshold exceed- ple. The law assigns extensive rights and duties to munic- ances by one or more pollutants, short-term action plans ipalities to “protect and improve” the environment in all (STAPs) must be prepared. areas “which are not in the exclusive competence of the state,” as discussed further below. It also stipulates that le- At the national level, MoEPP is North Macedonia’s main gal and natural entities that pollute the environment must authority responsible for environment and air quality. pay charges and fines that should be used to pay for envi- The ministry is tasked with aligning legislation with the ronmental and AQM initiatives. EU acquis, developing national air quality planning doc- uments, supervising their implementation, and reporting The Law on Ambient Air Quality (LAAQ) is North progress to the Government. Macedonia’s cornerstone framework instrument gov- erning AQM. The LAAQ and its subsidiary regulations Local self-government units (LSGUs) in North Macedo- mandate the government to manage air quality in line nia have extensive responsibilities in the field of envi- with EU standards. The LAAQ was first adopted in 2004 ronmental protection and AQM, following the principle and amended repeatedly10 to incorporate more recent of subsidiarity. AQPs are the most important instrument EU lawmaking. The LAAQ and its bylaws (see Annex 2 for air quality governance at the level of local self-govern- for a complete list) establish an AQM system for North ment. The LoE underscores that municipalities “have the Macedonia that is broadly aligned with the EU’s Clean right and duty in their area to take all measures and activ- Air for Europe (CAFE) Directive and related lawmak- ities for the protection and improvement of the environ- ing. According to the LAAQ, AQM is to be based on an ment” (Art. 11).11 The LAAQ assigns mayors the respon- assessment of ambient air quality. This is primarily the re- sibility to develop and implement five-year AQPs in case sponsibility of the Ministry of Environment and Physical pollutant limit values are exceeded. Following the latest Planning (MoEPP), while the Ministry of Health (MoH) is amendment of the LAAQ in 2021, every municipality with responsible for assessing the health risks associated with a population over 35,000 inhabitants is obliged to develop air pollution. an AQP, irrespective of whether pollutant limit values were exceeded in the previous year. ___________________________________  fficial Gazette of the Republic of North Macedonia, N° 53/05, 81/05, 24/07, 159/08, 83/09, 48/10, 124/10, 51/11, 123/12, 93/13, 187/13, 9 O 42/14, and 44/15. Official Gazette of the Republic of North Macedonia, N° 67/04, 92/07, 35/10, 47/11, 59/12, 163/13, 10/15, 146/15. 10  The Law on Local Self-Government further underscores the responsibilities of municipalities to safeguard the environment and nature. 11  This includes implementing measures to prevent pollution of water, air, and land as well as protecting against noise and non-ionizing radiation. This is reinforced by Amendment XVII, which grants decision-making authority on environmental protection matters to the national level. Similarly, the Law on the city of Skopje contains a parallel provision concerning environmental protection. Specifically, it mandates that the city is tasked with overseeing protection measures and pollution prevention related to water, air, land, nature, noise, and non-ionizing radiation within the Skopje city area. 8 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents 2.2 Alignment with the EU acquis North Macedonia has made significant strides in align- aged, including air quality planning and reporting. It stip- ing its framework legislation on air quality with that of ulates that AQPs are developed for pollutants that exceed the EU, particularly regarding overarching air quality ambient air quality standards within an air quality zone. ambitions. The country formally applied for EU member- AQPs define the state of air quality within a zone, pollu- ship in 2004 and became an official candidate for acces- tion sources, and measures to be taken by local authori- sion in 2005. Over the years, the EU has adopted an exten- ties to reduce air pollution. An assessment concluded that sive body of legislation on air quality, mostly in the form North Macedonia has transposed 93 percent of the CAFE of directives that define goals which all member states directive into national legislation (MoEPP and EEA 2018). must achieve. North Macedonia has continuously worked The country has not yet transcribed Directive 2015/1480/ to adapt its legal and regulatory environment to the EU EC which amends several annexes to the CAFE and Fourth acquis, although progress appears to have slowed as of late. Daughter Directives to lay down the rules concerning ref- erence methods, data validation, and location of sampling The latest EU directives on emission limit values have points for the assessment of ambient air quality. not yet or only partially been transposed (Table 1). North Macedonia has fully transposed the original Nation- However, a significant amount of work is still to be done al Emission Ceilings (NEC) Directive (2001/81/EC), but in the EU approximation process to achieve full legisla- the new NEC Directive (2016/2284/EU) stands at only 11 tive alignment in the area of air quality, especially in the percent transposition into national legislation. The country field of industrial emissions and the residential sector. has begun work to set emission reduction commitments for Only 62 percent of the Industrial Emissions Directive (IED) five main air pollutants: nitrogen oxides (NOX), sulfur ox- 2010/75/EU have been transposed into national legisla- ides (SOX), ammonia (NH3), non-methane volatile organ- tion (MoEPP and EEA 2018). The ministry expects the new ic compounds (NMVOC), and PM2.512 North Macedonia draft Law on Industrial Emissions to be adopted by the end has also transposed 85 percent of Directive 2004/107/EC, of 2024, which will complete the IED transposition. The the so-called Fourth Daughter Directive, setting limit val- IED regulates fuel combustion emissions in large plants ues for arsenic (As), cadmium (Cd), mercury (Hg), nickel with a rated thermal input greater than 50 megawatts (Ni), and polycyclic aromatic hydrocarbons (PAH) in ambi- thermal (MWth). The Medium Combustion Plant Directive ent air (MoEPP and EEA 2018). (MCPD) 2015/2193/EU covers plants of 1–50 MWth and is meant to fill the regulatory gap between the IED and the North Macedonia has mostly transposed the CAFE Di- Ecodesign Directive for smaller appliances (heaters and rective (2008/50/EC), the EU’s cornerstone legislation boilers below 1 MWth). However, the MCPD has not yet on air quality, and related EU acts into national legis- been transposed into national legislation in North Mace- lation, although some gaps remain. The CAFE directive donia. The Ecodesign Directive has been partially trans- merges most of the existing, diverse legislation on air qual- posed through the Decree on Ecodesign Products (Official ity into a single directive.13 It sets legally binding limit val- Gazette no. 100/2011) to establish a framework for setting ues for key pollutants, such as PM2.5, PM10, sulfur dioxide ecodesign requirements for energy-related products. Based (SO2), and ozone (O3). These have been adopted by North on the North Macedonia’ Energy Efficiency Law, a new De- Macedonia (see Table 3). The directive also defines the key cree on Ecodesign is planned to be adopted with full trans- components of how air quality should be assessed and man- position envisaged by 2027. ___________________________________  he transposition of the new NEC Directive (2016/2284/EU) into national legislation stands at 11 percent and is planned to be 12 T completed with support from the European Commission’s Instrument for Pre-Accession Assistance (IPA). However, the IPA project was tendered already in 2021, but the process was not successful. Therefore, the tender was relaunched in September 2023 and implementation of the project started in November 2024.. The project is also expected to support the preparation of a new LAAQ and relevant bylaws. See ‘EU air quality standards’, https://environment.ec.europa.eu/topics/air/air-quality/eu-air-quality-standards_en. The EU has revised 13  the CAFE Directive with a Council decision on 14 October 2024, with implications for North Macedonia, as discussed further below.  Contents LEGAL, REGULATORY, AND POLICY FRAMEWORK FOR AQM 9 _____________________________________________________________________________________________________________ Table 1: I mportant EU legislation on air quality and emission control and status of transposition into national law in North Macedonia Directive No. Title and purpose Status of transposi- tion14 Core Legislation on Air Quality Management 2008/50/EC CAFE, sets legally binding limit values for key pollutants 93% and establishes a system for air quality planning and re- porting 2004/107/EC Fourth Daughter Directive, sets limit values for As, Cd, Hg, 85% Ni, and PAH 2015/1480/EC Amends several annexes to the CAFE and Fourth Daughter Not transposed Directives, establishes rules concerning reference meth- ods, data validation, and location of sampling points for air quality assessment 2011/850/EU Reciprocal exchange of information and reporting on am- Mostly compliant but not bient air quality. Establishes reporting rules for CAFE and transposed Fourth Daughter Directive: States must report observation data to the EEA as soon as they are produced, even if the necessary validation process is not completed. Air Pollution Emission Control 2016/2284/EU NEC Directive, sets emission reduction commitments for 11% NOX, SOX, NH3, NMVOC, and PM2.5 2010/75/EU IED governing large plants (>50 MWth rated thermal in- 62% put) 2015/2193/EU MCPD (1–50 MWth) Not transposed 2009/125/EC Ecodesign Directive (<1 MWth) Partially transposed Important pieces of EU legislation and national second- has not yet brought the transposition to completion. The ary legislation which can significantly reduce emissions ministry has also worked on a Rulebook on the Quality of from residential sources have not yet been adopted, in- Solid Fuels for Heating which awaits finalization. Given cluding the Ecodesign Directive, energy labeling legis- that a significant share of air pollution emissions from the lation, and the Rulebook on the Quality of Solid Fuels residential sector stems from the poor quality of solid fuel for Heating. The Ecodesign Directive 2009/125/EC sets a (for example, burning of wet wood or waste products) and framework for performance criteria which manufacturers inefficient combustion, the transposition of the relevant must meet to legally bring their product to market. Based EU directives and the adoption of the rulebook are import- on this, Commission Regulation 2015/1186, 2015/1189, ant milestones for improving air quality throughout North 813/2013, and others define ecodesign requirements to re- Macedonia. duce emissions and ensure energy efficiency of household heating equipment such as solid fuel boilers and space As traffic can be a sizable source of air pollution, the heaters. For each product group, the EU’s energy labeling government has advanced efforts to regulate emissions legislation defines energy efficiency classes to help consum- from mobile sources in line with EU standards, with im- ers identify the desired product category.15 The Ministry of portant measures to take effect in 2024. North Macedo- Economy and Labor (MoEL) leads on these policy areas but nia has met European standards for fuel quality since 2009 ___________________________________ Source: MoEPP and EEA 2018, and verbal updates provided by MoEPP to the authors in 2024. 14  For an overview of ecodesign and energy labeling legislation by product group, see https://energy.ec.europa.eu/topics/energy- 15  efficiency/energy-label-and-ecodesign/list-energy-efficient-products-regulations-product-group_en 10 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents (World Bank 2019b), following several amendments to the ments, the European Commission (2023) noted that “lim- Rulebook on the Quality of Liquid Fuels which transposes ited progress was made on air quality monitoring and no the EU Directive on fuel quality (98/70/EC) and owing to legislative developments on air quality were made during the transposition of the EU Directive on Sulphur Content the reporting period.” This can be attributed to both insti- of Liquid Fuels (2016/802). However, an aging but grow- tutional capacity constraints, discussed below, and delays ing vehicle fleet—the average passenger car was nearly 20 in setting up an EU-funded support project to facilitate the years old as of 202116—has caused considerable air pollut- adoption of updated legislation. The European Commis- ant emissions, especially in cities with intense road traffic. sion further found that concrete measures to reduce air Therefore, regulatory changes were introduced from Jan- pollution at the national and local levels were insufficiently uary 2024, imposing higher taxes on owners of older vehi- implemented and in need of strengthening. cles with less stringent emission standards. An EU-funded project launched in November 2024 to The country is working to transpose and implement close the remaining gaps in North Macedonia’s legisla- other international agreements relevant to AQM, at tive alignment with the EU acquis. The project ‘Support varying stages of progress. North Macedonia is party to in the Implementation of Air Quality Directives’ is funded the Convention on Long-Range Transboundary Air Pol- under the EU’s IPA II. With a total financing volume of EUR lution and has ratified eight protocols of the convention. 1.5 million, three activity packages aim to update North However, the amendments of the last three protocols Macedonia’s legal framework to be fully aligned with the have not yet been ratified.17 The government has draft- EU acquis, develop new national-level air quality plans and ed but not yet adopted a Law on Climate Action which lays the foundation for the preparation of GHG emission strategies to replace the outdated documents discussed be- inventories and the establishment of a measuring, report- low, and improve air quality monitoring and reporting (Eu- ing, and verification system, as required under EU climate ropean Union 2023). However, issues with the tendering legislation and the UN Framework Convention on Climate process led to the project being re-advertised in 2023, and Change. a final launch date in November 2024. Overall, the European Commission recently noted lim- The following section analyzes the state of national and ited progress on advancing AQM and saw implementa- municipal air quality policy and planning instruments tion as a concern. On the other hand, in its 2023 accession against the requirements of North Macedonia and EU leg- negotiation progress report that assesses recent develop- islation.  ir quality planning instruments at the national 2.3 A and local levels The National Plan for Ambient Air Quality Protec- ligations stemming from international agreements. An es- tion 2013–2018 was adopted in 2012 as the govern- timation of the financial resources required to implement ment’s overarching air quality planning instrument, the proposed actions was included. The plan was meant to as required per the LAAQ, but implementation was not cover a period of at least five years, but its updating was not monitored and the plan was never updated. The plan regulated. The law requires MoEPP to report to the govern- included a stocktaking of pollutant emissions and identi- ment biennially, and while an inter-sectoral working group fied over 100 concrete measures which were assigned to followed the implementation of the plan for some time, an specific institutions, with specific time frames, to improve implementation progress report was not submitted to the air quality. The measures covered the most relevant sec- government. tors and intervention areas, including emission reductions from energy, industry, transport, and agriculture, waste The National Program for Gradual Reduction of Emis- management, strengthening of human health protection, sions of Certain Pollutants 2010–2020, also adopted AQM, and specific actions to meet North Macedonia’s ob- in 2012, defines measures to reduce annual emissions ___________________________________  ee ‘MK-NI 055: Average Age of Road Motor Vehicles’, MoEPP website: http://tinyurl.com/MK-NI-055-vehicle-age (accessed 12 July 16 S 2024). North Macedonia is yet to accept amendments to the Protocol on Heavy Metals, the Aarhus Protocol on Persistent Organic Pollutants, 17  and the Gothenburg Protocol to the Air Convention (UNECE 2019).  Contents LEGAL, REGULATORY, AND POLICY FRAMEWORK FOR AQM 11 by key sources to prevent exceedances of the NEC. ing systems and to improve the energy efficiency of public The document constitutes the National Air Pollution buildings. Control Program (NAPCP) as required by the NEC direc- tive and complies with the Convention on Long-Range The National Emission Reduction Plan (NERP) for Large Transboundary Air Pollution (CLRTAP). The specific air Combustion Plants is for 2018–2027. It was drawn up to pollutants targeted in the program are SO2, NOX, NH3, meet North Macedonia’s obligations as a member of the NMVOC, total suspended particular matter, and carbon Energy Community for southeast Europe and as an instru- monoxide (CO). A new NAPCP is planned to be devel- ment to implement the EU directives on large combustion oped to be in compliance with the new NEC Directive plants and industrial emissions (Directives 2001/80/EC and (2016/2284/EU). 2010/75/EU). The NERP includes all eight existing large combustion plants from the energy sector. The latest data In 2018, the government adopted a special Program from 2022 show that North Macedonia complied with its for Reduction of Air Pollution, to be implemented in emissions reporting obligations (Energy Community 2023). 2019–2020, but there was little follow-up and imple- However, a major increase in the emissions of all three pol- mentation monitoring was not done. The program was lutants (SO2, NOX, and dust) was observed, exacerbating also devised in response to a 2017 report by the European the already significant noncompliance with the NERP ceil- Environment Agency (EEA) that ranked North Macedonia ings. Therefore, the Energy Community Secretariat referred as having the worst air quality in terms of annual mean an infringement case to the Ministerial Council in July 2023 concentrations of PM2.5 among all European countries. and stated that “the long-standing noncompliance with the Skopje, Bitola, and Tetovo were identified to be among the National Emission Reduction Plan ceilings remains unad- 10 most polluted cities in Europe at the time (EEA 2017). dressed. Emission abatement measures must be taken im- The objective of the program was to achieve a “reduction mediately to address this.” (Energy Community 2023) of air pollution by 50 percent in Skopje” and 30–50 percent in other urban centers. Measures included improving air At the local level, 16 LSGUs (15 municipalities and the quality monitoring, raising public awareness, and reducing city of Skopje) are required to prepare an AQP because air pollutant emissions from domestic heating, waste man- of pollutant limit value exceedances or population size. agement, transport, industry, and construction. A moni- The majority of the LSGUs have prepared a plan recently, toring and reporting mechanism was to be established to although only seven have formally adopted it. Only one track the implementation of the program. The document municipality has not made efforts to update its outdated also acknowledged the important role but limited capac- AQP (Table 2). Most municipalities developed their AQPs ities of the environmental inspectorate and the need to with intensive support from MoEPP. The ministry leveraged improve its performance. This was to be accomplished by resources from its Environmental Investment Program and increasing the number of staff and amending legal acts to hired third-party consultants to draft the plans. Most AQPs change the institutional setup, which would enable more were prepared by the same contractor. Kumanovo, Strumi- regular inspections and contribute to a more efficient sys- ca, and Veles are the only municipalities that invested their tem of inspections. However, the program’s proposed mea- own financial resources to pay for the consultants that sures were only sketched out in bullet-point format; imple- drew up their local AQP. Tetovo prepared and adopted an mentation responsibilities and financial resources were not AQP with support from an EU-funded technical assistance assigned. Therefore, it was unclear how the goals of the project back in 2016. Most of the measures in the plan were program were to be achieved. No progress reports have focused on the 2017–2022 implementation period, while been prepared. In addition to the special program 2019– some longer-term measures extended until 2027. The plan 2020, annual Programs for Reduction of Air Pollution were was supposed to be updated in 2022, but there is no in- prepared for 2019, 2020, and 2021 and implemented by formation about efforts having been made in this respect. the General Secretariat of the government. The measures Only Skopje and Tetovo developed STAPs in 2017, but both mainly focused on the substitution of non-ecological heat- documents are outdated. 12 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents _____________________________________________________________________________________________________________ LSGUs obliged to prepare an AQP, by AQP status18 Table 2:  No. Name of LSGU Population Year in which obligation to prepare AQP AQP status was determined (based on list of zones and agglomerations prepared by MoEPP) 1 Kumanovo 98,104 2022 2 Bitola 85,164 2022 3 Gostivar 59,770 2022 Adopted and 4 Kavadarci 35,733 2022 up-to-date 5 Prilep 69,025 2023 6 Ohrid 51,428 2024 7 Veles 48,463 2023 8 City of Skopje 526,502 2022 9 Struga 50,980 — 10 Strumica 49,995 2022 Prepared, not 11 Stip 44,866 — yet adopted 12 Kichevo 39,669 2022 13 Kochani 31,602 2022 14 Gevgelija 21,582 2022 15 Berovo 10,890 2023 Not started 16 Tetovo 84,770 2022 Outdated 2.4 Critical review of the six AQM functions The analysis above shows that North Macedonia has al- performed in practice. For each function, the review ex- ready aligned much of its framework legislation on AQM amines whether a clear functional task definition exists to the EU acquis but gaps remain, and formal require- (‘what must be done?’), roles and responsibilities are as- ments are only partially followed, especially regarding signed (‘who must do it?’), and process requirements are the development and updating of air quality planning and established (‘how must it be done?’). A summary rating strategy documents. table is included at the end of the chapter, with details provided in Annex 3. This section applies the analytical framework introduced in chapter 1.3 and looks in more detail at how each of The institutional capacity constraints that help explain the six core AQM functions is designed in the legal and some of the shortcomings in the practical performance of regulatory framework of North Macedonia, and how it is the six AQM functions are analyzed in chapter 3. ___________________________________  he list of zones and agglomerations obliged to prepare an AQP is published annually by MoEPP on its website: https://tinyurl. 18 T com/moepp-list-of-zones. Population figures from Census 2021 (State Statistical Office 2021). AQP status as of December 2024, information obtained from MoEPP.  Contents LEGAL, REGULATORY, AND POLICY FRAMEWORK FOR AQM 13 2.4.1. Setting air quality standards task (see Annex 1). An accountability mechanism refers and objectives to a procedure to ensure compliance with a functional re- quirement, typically in the form of incentives or sanctions. The LAAQ and LoE, as well as sector-specific legisla- Regarding process requirements, the LAAQ only contains tion such as the Law on Energy and the Law on Energy a general provision that the national government must set Efficiency, establish broad task definitions to set air air quality and pollution limit and target values. It does quality-related standards and objectives. These pertain not specify the periodicity or manner in which this is to be to defining air quality standards, limit and target values done. Moreover, there are no consequences for not setting for air pollutant emissions, and legislation on contribut- or updating air quality standards. Combined with the in- ing factors such as quality of fuels and vehicle technology stitutional capacity constraints in MoEPP and other minis- standards. tries, discussed further below (Chapter 3), this has led to a Responsibilities to set air quality standards and objec- backlog of EU directives yet to be fully transposed into na- tives are clearly defined, with MoEPP taking the lead tional legislation to set pollution control objectives, such as role. Sector ministries are responsible for setting air quali- the IED, MCPD, and the Ecodesign Directive, among others ty-related objectives within their remit. MoEPP is primarily (see Table 1). responsible for setting limit values for ambient air pollutants, In practice, North Macedonia has adopted the core air in consultation with the MoH. The newly established Minis- quality standards and objectives defined in the relevant try of Energy, Mining, and Mineral Resources (MoEMMR), EU directives (Table 3), but limited institutional capaci- in cooperation with MoE and MoEPP, defines limit values for ty may make it difficult to keep national legislation and the permissible type and content of harmful substances in regulations up-to-date. The country has adopted the EU fuel for transport and heating as well as other requirements CAFE directive pollutant limit values and anchored these with a potential effect on pollutant emissions, such as ener- and other air quality standards in 16 bylaws, rulebooks, gy efficiency standards, use of renewable sources in energy and national guidelines. However, significant capacity con- production, and vehicle standards. straints in MoEPP—with no dedicated unit for air quality The current legislation does not specify process re- legislation, policy, and planning—mean that legislative quirements and accountability mechanisms that would initiatives are tackled ad hoc and mostly dependent on ex- ensure the timely and complete preparation and adop- ternal support, such as the IPA II project described above. tion of up-to-date air quality standards. As a result, al- The existing gaps in the transposition of the EU air quality though North Macedonia has made significant progress, acquis, and the EU’s recent move to revise its air quality it still has considerable work to do to transpose important standards (European Commission 2022b), raise questions EU directives relevant to AQM. Process requirements de- about whether North Macedonia will be able to keep pace fine the steps to be followed in performing a functional with the dynamic regulatory environment of the EU. _____________________________________________________________________________________________________________ Table 3: O  verview of limit values and guidelines per pollutant, by jurisdiction, and actual measurement in North Macedonia Pollutant WHO EU EU North North Macedonia (2021)19 (2008)20 (2024)21 Macedonia (highest measured, (2013)22 2022)23 PM10 15 μg/m3 40 μg/m3 20 μg/m3 40 μg/m3 53.3 μg/m3 annual annual mean annual mean annual mean annual mean mean (Strumica) 45 μg/m3 50 μg/m3 45 μg/m3 50 μg/m3 143 exceedances of 24-hour mean 24-hour mean 24-hour mean* 24-hour mean 24-hour mean (Kicevo) ___________________________________ 19 WHO 2021.  20 2008/50/EC (CAFE directive).  21 Revision of EU air quality standards (European Commission 2024c), adopted by Council decision on 14 October 2024.  22  Decree on the limit values of the levels and types of polluting substances in the ambient air and alert thresholds, deadlines for limit values achievement, margins of tolerance for the limit values, target values and long-term targets (Official Gazette of the Republic of North Macedonia, N° 50/05, 4/13). Data from MoEPP, showing highest measured values (at measurement station), and number of exceedances of the indicated time- 23  bound limit value. 14 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents Pollutant WHO EU EU North North Macedonia (2021)19 (2008)20 (2024)21 Macedonia (highest measured, (2013)22 2022)23 PM2.5 5 μg/m3 25 μg/m3 10 μg/m3 25 μg/m3 35.2 μg/m3 annual mean annual mean annual mean annual mean annual mean (Kicevo) 15 μ g/m3 25 μg/m3 24-hour mean 24-hour mean* O3 60 μg/m3 120 μg/m3 120 μg/m3 120 μg/m3 23 days exceeding 120 peak season 8-hour mean 8-hour mean* 8-hour mean μg/m3 (Miladinovci) 100 μg/m3 8-hour mean NO2 10 μg/m3 40 μg/m3 20 μg/m3 40 μg/m3 31.6 μg/m3 annual annual mean annual mean annual mean annual mean mean (Kumanovo) 25 μ g/m3 200 μg/m3 50 μg/m3 200 μg/m3 1: Number of hours 24-hour mean 1-hour mean 24-hour mean* 1-hour mean exceeding 200 μg/m3 200 μg/m3 200 μg/m3 (Skopje Lisice) 1-hour mean 1-hour mean† SO2 40 μg/m3 125 μg/m3 20 μg/m3 125 μg/m3 No exceedances 24-hour mean daily mean annual mean daily mean registered, based on 500 μg/m3 350 μg/m3 50 μg/m3 350 μg/m3 MoEPP records. 10-minutes 1-hour mean daily mean* 1-hour mean Highest annual mean mean 350 μg/m 3 measured in Prilep 1-hour mean† (6.6 μg/m3) Note: * Not to be exceeded more than 18 times per calendar year. † Not to be exceeded more than three times per calendar year. North Macedonia urgently needs dedicated institutional capacity to develop a strategic vision and adopt a holistic approach to AQM, especially regarding setting and maintaining air quality standards and objectives. 2.4.2 Determining required emission However, North Macedonia has still not fully transposed reductions the new NEC Directive (2016/2284/EU) as a basis for establishing emission reduction commitments, and the The requirement to calculate the amount of emission Decree on National Emission Reduction Commitments reductions needed to achieve national air quality stan- for NEC pollutants by 2030 is still not drafted. The gov- dards and objectives is anchored in the LAAQ and the ernment has not yet calculated the reduction potentials for corresponding rulebooks. MoEPP bears the lead respon- the five main pollutants covered under the NEC directive. sibility. The process is clearly defined. Following the trans- This is planned to be done with support from the EU-fund- position of the first NEC Directive (2001/81/EC), North ed EU4Green project 2022–202524. Moreover, the IPA II Macedonia established clear emission limit values and project is tasked with developing an updated national air adopted process guidelines in the ‘Rulebook on the quan- pollutant emission inventory in accordance with the NEC tities of upper limits: ceilings of the emission of polluting directive. substances for the purpose of determining projections for North Macedonia mostly meets the prerequisites for a certain period of time that refer to the reduction of the determining required emission reductions but faces quantities of pollutant emissions on an annual basis’ (Of- data gaps, especially regarding fuel and technology ficial Gazette no. 2/10, 156/11, and 111/14). The LAAQ use in the residential sector. Calculating the quantity of requires MoEPP to develop a National Program for Grad- reductions necessary to stay within the established pollut- ual Reduction of Emissions of Certain Pollutants. The last ant limit values depends on three ‘ingredients’: air quality program was valid for 2010–2020 and has since expired. monitoring data, an emissions inventory that provides data ___________________________________ For details, see https://eu4green.eu. 24   Contents LEGAL, REGULATORY, AND POLICY FRAMEWORK FOR AQM 15 that are needed to calculate actual emissions from sources relatively comprehensive emission inventories that are re- that contribute to air pollution, and source attribution that ported under the CLRTAP (MoEPP 2023b). However, given provides data analysis and modeling to determine which the severe air quality impact of solid fuel combustion for sources are the primary contributors to air pollution (see residential heating, there is a need to build a more granular Box 2 for the relationship between emission inventories and emission inventory of residential sources, including data on source apportionment). The country has a solid track record the type and quality of the fuel used and the type and effi- on monitoring and reporting air quality data and maintains ciency of heating appliances. Box 2: T  he role of emission inventories and source apportionment for AQM Emission inventories. The purpose of an emission inventory is to determine the key emission sources affecting air quality in a geographic location. Different categories of sources are typically distinguished, including point sources (for example, smokestacks), area sources (for example, residential neighborhoods), and mobile sources (for exam- ple, road traffic, trains, and airplanes). The inventory data can be used to identify strategies to reduce pollution by helping air quality control agencies understand the types and quantities of different pollutants emitted in and around an area. A second use of the in- ventory is to establish the temporal and spatial distribution of pollutant emissions in a region through reporting and tracking. In many cases, knowing the types and quantities of emissions within a large geographic region may not be enough to explain observed air pollution patterns. Understanding where emissions occur, or when changes in emis- sions take place, can help regulators verify expected emissions and track progress in planned reductions over time. Source apportionment refers to the practice of identifying the amount that each known emission source contrib- utes to concentrations of air pollutants. Source apportionment is needed because there is no linear correlation between emission and concentration levels due to varying dispersion characteristics, atmospheric chemistry, and topography, among other factors. One of the main approaches to conduct source apportionment is to use data from emission inventories. Another approach is through receptor-oriented models that apportion the measured mass of an atmospheric pollutant at a given site, called the receptor, to its emission sources by using multivariate analysis. Therefore, source apportionment is an important decision tool to inform the design of air pollution control strat- egies. The World Bank conducted source apportionment analysis for North Macedonia relatively recently (World Bank 2019b). The study found the residential sector to be by far the largest source for population-weighted PM2.5 exposure, with residential heating contributing 36 percent of total primary particular matter emissions. The introduction of mandatory chimney sweeping can tries. The National Plan for Ambient Air Quality Protection fill the information gap about technology and fuels is to be developed by MoEPP, in coordination with MoH used in the residential sector, in addition to providing and MoEMMR. It is the overarching strategy document in valuable advisory services to households, as discussed which the government lays out its measures to manage air further below (Section 2.4.5). quality within the set limit values per pollutant. The pro- cess requirements and content of the plan are prescribed 2.4.3 Designing air quality control in the Rulebook on the Detailed Content and Manner of strategies Preparation of the National Plan for the Protection of Am- bient Air (Official Gazette no. 108/09). The second main At the national level, the LAAQ assigns MoEPP the re- air quality control document is the National Program for sponsibility to prepare two crucial plans for protecting Gradual Reduction of Emissions of Certain Pollutants, con- the quality of ambient air in line with the established stituting the NAPCP which is required under the NEC di- air quality goals: the National Plan for Ambient Air rective, as described above. Quality Protection and the National Program for Grad- ual Reduction of Emissions of Certain Pollutants. The Both national planning documents were developed law demands an integrated approach to protect the quality only once and have been outdated for years, pointing of ambient air, water, and soil; safeguard people’s health to systemic constraints in developing air quality legis- in the working and living environment; and avoid negative lation, policies, and plans. The National Plan for Ambient effects on the environment on neighboring or other coun- Air Quality Protection was developed for 2013–2018 and 16 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents never updated. The National Program for Gradual Reduc- AQP before, partly because of limited capacity and because tion of Emissions of Certain Pollutants was valid from 2010 of a change in legislation (the population size criterion was until 2020; an update is overdue. Overall, the preparation only introduced in 2021). Each LSGU typically employs only of national-level air quality legislation, policies, and plans a small number of staff members in the environment sector happens irregularly and is dependent on external financ- who are responsible for covering all media, including air, ing and support. This appears mostly due to the limited water, and waste management. Limited staff resources can institutional capacity dedicated to policy, planning, and be dedicated to AQM. For example, only the city of Skopje implementation follow-up as well as insufficient funding, has one staff member dedicated to air quality monitoring. as discussed in further detail below. Therefore, most municipalities drew on the support offered At the municipal level, the LAAQ requires mayors to by MoEPP. The ministry mobilized external funding and develop and implement five-year AQPs if pollutant lim- hired a consulting company based in Skopje to develop the it values are violated or if the population size exceeds AQPs for 11 municipalities. Kumanovo, Strumica, and Veles 35,000 inhabitants. For air quality zones and agglomer- are the only smaller municipalities that used their own fund- ations that comprise several municipalities, MoEPP de- ing to hire the same consultants to develop its AQP. In 2024, cides which LSGU must lead the AQP development. The Strumica drew on financial support from UNDP to update process of designing the AQPs is prescribed in LAAQ Art. its AQP. To reduce the need and dependence on this level 27 and the Rulebook on the Detailed Content and Manner of intensive technical assistance by MoEPP and increase of Preparation of a Plan to Improve Air Quality (Official municipal ownership over the AQP development process, it Gazette no. 148/14). During the plan preparation, the is advisable for the ministry to provide detailed, practical, responsible municipality is obliged to cooperate closely and up-to-date guidelines on local-level AQP development with ‘all relevant stakeholders’, including state adminis- and implementation, including good practice examples. An trative bodies, scientific and expert organizations, legal EU-funded advisory project developed draft guidelines for entities, and natural persons who are owners of station- AQP preparation in North Macedonia in 2016 (Vilarova and ary pollution sources. The local administration must also Dimitrovski 2016). The 25-page document provides a help- communicate and cooperate proactively with MoEPP to ful outline of the required content of an AQP and the process ensure that guidance and inputs from the national level steps to develop the plan, but it does not include detailed ad- are taken into account. vice and instructions on how to craft each required element After a prolonged period of not having had valid AQPs, of an AQP nor does it discuss the crucial aspect of financing 14 out of the 16 LSGUs that are required to prepare an AQPs, a significant bottleneck to implementation in North AQP have done so recently, mostly using ministry fund- Macedonia. It is recommended that MoEPP draw on the ex- ing to outsource the task to third-party consultants. The tensive guidance and good practice examples that have been majority of the 16 LSGUs (see Table 2) have never had an compiled more recently (Box 3). Box 3: Guidance and good practice examples for developing AQPs Several EU initiatives have developed comprehensive, practical guidance and good practice collections on AQP development. In an early example, the German Environmental Agency (UBA) worked with the Government of Bul- garia to create a ‘Guideline on Air Quality Plans’ that is tailored to the local context (Lorentz and Müller 2016). More comprehensively, a partnership of four EU member states and six cities compiled a ‘Code of good practice for designing and implementing Air Quality Plans’ which includes detailed methodologies and tools for elaborating an AQP, good practice examples, and a dedicated section to citizen awareness and participation in the development of the plan (Partnership on Air Quality 2019), also available on the EU’s Futurium platform online.25 Relevant guid- ance includes the following:  hy to develop an AQP: Compliance with EU legislation, health protection and other issues, additional benefits W  ontent: Mandatory elements, suggested structure, integration with other plans and programs, strategic envi- C ronmental assessment, and e-reporting formats ___________________________________ 25 https://futurium.ec.europa.eu/it/urban-agenda/air-quality/news/partnership-air-quality-delivers-tools-help-cities-and-member- states-overcome-challenge-air.  Contents LEGAL, REGULATORY, AND POLICY FRAMEWORK FOR AQM 17  ow to develop an AQP: Process steps, checklist, key factors H  ow to manage and implement an AQP: Citizen awareness; participatory approaches; funding opportunities; H monitoring, reporting, and reviewing  ethodologies and tools for elaborating an AQP M  toolkit on communicating on air quality and health. A The UK Department for Environment, Food, and Rural Affairs has also compiled a list of six good practice examples of adopted Air Quality Action Plans from across the country (UK Department for Environment 2024). The development of AQPs also suffers from data con- 2.4.4 Implementing air quality control straints. The lack of granular local emission inventories strategies limits the amount of information that can be used for priority setting in the AQPs and constitutes a barrier to The LAAQ designates MoEPP as the institution with the the design, implementation, and enforcement of effec- overall responsibility for implementing the National tive air quality control measures. Most municipalities Plan for Ambient Air Quality Protection (Art. 25). For do not have household-level information on the type of each measure outlined in the plan, the document assigns heating installations, fuel type, and quality used, aside the implementation responsibility to a specific actor. For from self-reported population averages. Therefore, the other national policy and planning instruments, re- there is a shortage of robust evidence that can guide pri- sponsibilities are less clearly defined by law. In the absence ority setting, for example, on how many heating installa- of a functional reporting and accountability mechanism, tions in a given municipality should be replaced and how the status of most activities remains uncertain. The out- many houses need to be thermally modernized. Chim- of-date National Plan for Ambient Air Quality Protection ney sweeping can play an important role in building a 2013–2018 provides an analysis of the main drivers of air pollution and defines 118 measures to improve air quali- bottom-up inventory of emission sources, offer house- ty. For each action, the plan designates one institution hold-specific recommendations on emission reduction responsible for implementation and sets a time frame for and energy efficiency potential, and establish an effec- completion. Individual activities are not costed. Instead, tive compliance enforcement mechanism, as discussed the plan estimates the financial resource requirement for in more detail in Section 2.4.5. the envisaged emission reductions per pollutant. Overall, STAPs are another important AQM instrument at the the list of detailed measures, responsibilities, and timelines local level but have remained underutilized. A STAP set out in the National Plan constitutes a robust foundation must be developed for each zone or agglomeration where for effective AQM implementation. The LAAQ demands there is a risk of exceeding the alarm threshold of one or that MoEPP reports on the implementation of the plan ev- more pollutants. In the STAP, the responsible LSGU de- ery two years. However, this reporting requirement has not fines short-term measures to be taken to bring pollution been fulfilled. North Macedonia does not have a mecha- levels to below the critical thresholds. The process and nism in place to monitor implementation of the national air content of the STAP are defined in the Rulebook on the quality control strategies, and there are no consequences Detailed Content and Manner of Preparation of Short- for failing to implement or report on progress. Term Action Plans for Ambient Air Protection (Official At the local level, the responsibilities for implementing Gazette, no. 148/14). Every year by March 31, MoEPP AQPs are clearly defined in the LAAQ. However, most publishes a list of zones and agglomerations at risk of ex- municipalities have only adopted AQPs recently, and the ceeding pollutant limit values, based on recent air qual- few that have had them previously have not reported on ity monitoring data. However, only Skopje and Tetovo implementation progress. Bitola (in 2012) and Skopje and developed STAPs once in 2017. Both documents are now Tetovo (both in 2016) were the first LSGUs to adopt AQPs outdated. and therefore the only municipalities with potential imple- Additional staff capacity in LSGUs and practical guidelines mentation experience. Although the LAAQ requires LSGUs on how to develop AQPs and STAPs would be an import- to submit annual progress reports on their AQPs to MoEPP, ant contribution toward effective AQM in the pollution this was not done. Only Skopje’s latest draft AQP for 2023– hotspots where it is most urgently needed. 2027 includes an activity-wise report on 51 measures from 18 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents the previous plan. It concludes that “82% of the measures from Skopje, Bitola, and Tetovo, was mostly externally have been fully or partially implemented” (Zdraveva and driven and funded, with extensive technical support from Mirakovski 2022). An assessment of the extent to which MoEPP and private consulting companies. Ownership by the measures were effective in improving air quality has the municipalities appears to have remained limited. Once not been provided. the AQPs are in place, the municipalities are responsible for implementation but are constrained by limited staff The reasons for incomplete implementation and prog- capacity, technical expertise, and financing. To strengthen ress reporting appear fourfold: accountability, own- the ability of LSGUs to implement AQPs, the central gov- ership, capacity, and financing. Besides the reporting ernment may consider establishing an ‘AQM investment requirement from LSGUs to MoEPP, the LAAQ does not fund’ to finance municipal air quality control measures, establish an accountability mechanism to ensure AQPs similar to the newly established Energy Efficiency Fund to are implemented. There are no consequences for munic- finance investments in energy efficiency in the public sec- ipalities for not preparing or implementing AQPs. Oth- tor (Ministry of Finance 2023). Resources could be allocat- er countries have instituted financial sanctions to ensure ed proportional to population size and severity of the air compliance (see Section 5.2). Therefore, the development pollution issue. Alternative approaches to financing AQPs of the majority of AQPs, including the earliest examples are outlined in Box 4. Box 4: Guidance and mechanisms for financing AQP implementation Financing the implementation of AQPs is a significant concern for LSGUs in North Macedonia, with most consider- ing themselves unable to mobilize the resources required to act on all proposed AQP measures. The European Investment Bank Advisory Hub has created guidance on financing AQPs for cities and local authori- ties (European Investment Advisory Hub 2019). The document provides insights into how to analyze AQPs to cate- gorize measures into non-financially sustainable and financially sustainable measures. The guidance identifies the types of funding sources that LSGUs can harness for each category and how to leverage these resources. Examples include the following:  ser charges: Payment in exchange for a particular service usually aimed at cost recovery of collective services. U The fee can be based on a quantity or quality of pollutants released into the environment. Example: Private ve- hicle owners can be forced to pay when entering a pollution-restricted area.  ompensation measures: Payment of a fee to offset an action that, albeit lawful, entails negative impacts on C air quality. Example: Developers can be forced to pay surplus costs for the construction of buildings subtracting agricultural areas.  onetizing added value: Revenues come directly generated by the development or improvement of the goods M or services offered. Example: Investment in eco districts would allow to improve buildings and infrastructure in the area, increasing the real estate economic value.  osts savings: Due to increased operational efficiency of a system. Example: Energy efficiency interventions C allow to save costs of energy consumption.  ax credits (for the local authority): Tax credits allow taxpayers to save costs by subtracting the amount of the T credit they have accrued from the total they owe. Example: Tax credit mechanisms incentivize homeowners to undertake energy efficiency modernization.  oft loans: Soft loans represent a mechanism coming between revenue models and nonrevenue models. These S are forms of support where borrowers repay investments at better-than-market conditions (for example, low or nonexistent interest rates), usually foundations or public authorities. Example: Loans can be channeled through state-owned banks at interest rates ranging from zero to just marginally below commercial interest rates for pollution abatement investments.  Contents LEGAL, REGULATORY, AND POLICY FRAMEWORK FOR AQM 19 In summary, AQP preparation and implementation updated if in their third year of existence they have still is insufficiently institutionalized. This needs to be ad- failed to resolve the situation. It is advisable for North dressed through changes in the legal framework and by Macedonia to create the regulatory environment and ca- investing in institutional capacity for implementation pacity conditions to enable the level of rigor and agility and coordination. An accountability mechanism should in AQM that the updated EU directive on air quality will be anchored in the law to ensure that national- and lo- require. cal-level actors fulfill their implementation and reporting obligations. MoEPP and the LSGUs that must prepare AQPs need expert personnel dedicated to air quality poli- 2.4.5 Monitoring implementation cy, planning, and implementation. An AQM coordination and enforcing compliance mechanism between levels of government should be en- North Macedonia does not have a working mechanism shrined in the law for it to become standard practice. It is in place to monitor the preparation and implementa- worth nothing that the pilot AQPs first adopted by Skopje, tion of national and local AQPs. This lack of information Bitola, and Tetovo were all developed with support from prevents effective follow-up and constitutes a significant the EU-funded twinning project ‘Further Strengthening barrier to effective AQM. According to the provisions of of the Capacities for Effective Implementation of the Ac- the LAAQ (Art. 27a and 34), MoEPP is responsible for re- quis in the Area of Air Quality’. Each plan suggested that porting on the progress of implementation of the national “there should be periodic checks on the implementation AQPs outlined above. Likewise, LSGUs are required to sub- of the measures at the local level, under the supervision mit annual progress reports on their AQPs and STAPs to of [MoEPP]. Coordination between the administration MoEPP. These sources of information, if functional, could at the local and central level is recommended in order to provide the government with a comprehensive overview of check the effectiveness of the adopted measures and to whether adequate plans are in place and implementation is evaluate the impact of each implemented measure on the progressing as envisaged. The data would provide the basis reduction of air pollution. Furthermore, the exchange of for determining whether improvements in air quality can information between local and national authorities and be expected or additional efforts are needed. In practice, bodies is of particular importance in order to synchro- the institutional capacity dedicated to air quality issues is nize measures at the local and national level” (MoEPP limited at both levels of government. Reporting require- and Finnish Meteorological Institute 2016). It was even ments have not been met, so the implementation status of suggested that the first AQPs should be updated after most AQP measures remains unchecked. The LAAQ does only two years to incorporate the learnings from this lo- not incentivize timely compliance by ministries or munic- cal-to-central government coordination and information ipalities. exchange. In short, the need for strong implementation The environmental inspection is tasked with mon- coordination was acknowledged from the outset but nev- itoring and enforcing compliance of specific instal- er materialized. lations according to environmental and air quality North Macedonia would benefit from strengthen- legislation, but this function is not adequately capac- ing AQP development and implementation quickly. itated, especially at the local level. The integrated pol- Otherwise, the country risks remaining at odds with lution prevention and control (IPPC) permitting system EU air quality legislation which will soon become more in North Macedonia, based on the EU’s IPPC Directive demanding. The EU is overhauling its air quality legisla- 96/61/EC, recognizes two types of integrated permits. tion. In late February 2024, the European Council and The A-integrated environmental permit applies to larger Parliament reached a provisional political agreement on installations covered by Annex I of the IED and is issued the European Commission’s proposal to update EU air at the central level by the Environmental Administration quality standards in pursuit of achieving a “zero-pollu- (EA) within MoEPP. Compliance monitoring is done by tion objective” (European Commission 2022b, 2024c; the State Environmental Inspectorate (SEI). However, European Council 2024). The new directive will tighten staff shortages and limitations in technical expertise and AQP requirements, among others, to specify minimum equipment hinder the effectiveness of these inspections information to be included in the plans. The AQPs will (Gjorgievski, Hadji-Zafirov, and Trajkovska 2021). The have to provide an estimate of the effect of planned air B-integrated environmental permit for smaller installa- quality measures in terms of pollutant concentration re- tions (below the Annex I threshold) is written by the local duction (in μg/m³) at all sampling points in exceedance administration of the municipality where the installation as well as a compliance perspective, that is, by when the is located, except for installations located in protected ar- reduction will be achieved. Exceedance situations will eas. In these cases, B-permits are issued by MoEPP. Au- need to be resolved within three years. AQPs must be thorized municipal environmental inspectors, hired by 20 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents the municipality and not reporting to SEI, are tasked with equipment to carry out environmental inspections rele- monitoring compliance. Out of 81 LSGUs in North Mace- vant to AQM. donia, only 63 (77 percent) have at least one authorized Potentially the most consequential gap in the existing inspector. In most municipalities that have inspectors, the system of monitoring AQM implementation and en- function is said to be ‘completely unequipped’ regarding forcing compliance is the lack of effective control over training, experience, equipment, and the number of staff, residential heating installations. Household-level emis- having to cover 28 laws and over 240 bylaws, including sion sources are essentially unmonitored. In practice, the air quality legislation. inspection system does not cover pollution sources that do Inter-municipal cooperation on inspections could not fall under the IPPC permitting scheme. Furthermore, alleviate this constraint but has been underutilized, most LSGUs would not have enough staff capacity or tech- partly because of a misalignment in the incentive nical expertise to monitor residential emissions. structure for municipalities to invest in local envi- Chimney sweeps could play a pivotal role in the local ronmental inspections. When authorized inspectors of AQM monitoring and enforcement system, but there is municipalities issue fines for installations in violation of currently no legal basis for residential inspection and their B permit, the income does not accrue to the munici- reporting, and only few professional sweeps are oper- pal budget but goes to the national level, with few excep- ating in North Macedonia. Unlike in other countries and tions. Although LSGUs have strong reasons from an en- jurisdictions, the North Macedonia’s laws and regulations vironmental and health perspective to maintain good air do not define clear legal requirements for residential in- quality with the help of stringent inspections, this is not spections and reporting on heating installations and air underpinned by a financial incentive to invest in inspec- pollutant emissions. In Germany and other EU countries, tions. Legal changes are needed to align revenue flows chimney sweeps not only work toward fire safety and pub- and reporting lines with municipal incentive structures. lic safety, but they also fulfill extensive functions in in- A second viable step to strengthen local-level inspections specting and cleaning furnaces and fireplaces, measuring would be to encourage inter-municipal cooperation. emissions, checking permissible fuel types and quality, Municipalities could share inspectors, or smaller LSGUs and advising homeowners on how to reduce emissions, could pay neighboring municipalities for their inspection save energy, and save heating costs (see an example in services, which would also increase cost efficiency. A re- Box 5; details in Annex 4). Importantly for North Mace- cent change to the Law on Environmental Inspection (Of- donia, the results of chimney sweep inspections can eas- ficial Gazette 99/2022) empowers municipalities to form ily be used to build up a localized, granular inventory of organizational zones to share permit writing and inspec- emission sources. This will enable authorities to follow tion duties. This means that the ground is prepared le- up with house owners if their installations do not comply gally, but the majority of LSGUs still require training and with regulations, ultimately improving air quality. Box 5: The contribution of chimney sweeps to effective AQM - an EU example Germany and Austria have arguably the most stringent chimney sweeping regulations and the most advanced chim- ney sweep service sector among the EU member states. Similarly, Finland’s chimney sweeping sector is highly active and successful, but it is less comprehensively regulated, as is the case in some parts of Italy. Germany has a long history of chimney sweeps overseeing inspection and maintenance of all fireplaces in the coun- try. The authorized district chimney sweep is officially assigned to one district for seven years by the local admin- istrative authority. The sweep typically oversees 2,000 or more households. Only the authorized district chimney sweep has the legal competency to (a) carry out the official inspection of furnaces and fireplaces, including the issuance of an inspection certificate, and (b) maintain a sweep-book containing a list of all furnaces and fireplaces and their technical specifications in the district. The official inspection of furnaces and fireplaces must take place at the earliest three, at the latest five years after the last official inspection. An official inspection comprises a holistic assessment for certifying operational furnac- es and fireplaces and ensuring fire safety. It covers controlling the firing equipment, connectors, chimneys, flues, combustion air supply, fuel quality including fuel wood moisture, decommissioning, or retrofitting of solid fuel fire- places, among other tasks. After completing the holistic assessment, the authorized district chimney sweep issues an inspection certificate.  Contents LEGAL, REGULATORY, AND POLICY FRAMEWORK FOR AQM 21 The inspection certificate informs house and apartment owners about the schedules of the annual inspection, mea- surement, and sweeping requirements as defined in the Federal Sweeping and Inspection Ordinance. Depending on the type of furnace or fireplace used and the intensity of use, routine sweeps must occur one to three times per year. These annual inspections are mandatory, even in years without an official inspection carried out by the authorized district chimney sweep. Following a revision of the law in 2013, the annually recurring cleaning and measurement can be done by qualified contractors. Previously, the authorized district chimney sweep did both the official inspection every three to five years as well as the annual measurement and sweeping. House and apartment owners are responsible for implementing in a timely manner any repairs, upgrades, or other tasks assigned to them in the inspection certificate, and they must be able to prove it to the authorized district chimney sweep. For this, the contractor who conducts the annual cleaning and measurement fills out a compliance form which the house owner must forward to the authorized district chimney sweep to be recorded in the sweep-book. If house or apartment owners are in violation of the legal provisions, the authorized district chimney sweep is obliged to report the incident to the responsible district authority. Such incidents include the non-submission of required forms, not initiating the statutory activities (for example, tasks assigned in the inspection certificate), refusing household inspections, or operating unapproved furnaces or fireplaces. The house owner will then receive an official advisory from the responsible authority. In case of continued noncompliance, the authority imposes fines on the owner of the residence ranging from EUR 5,000–50,000 (US$5,500–55,000). A chimney sweeping law has been drafted in North the type and quality of the fuel used, measurement values, Macedonia, along with a practical proposal for how and any issues and recommendations to be resolved by the to develop professional chimney sweeping services at household. Each chimney sweep inspection and cleaning scale. This constitutes a strong starting point for the gov- would effectively contribute to creating a fine-grained bot- ernment to initiate the necessary legal and policy changes. tom-up emission inventory. The twinning project already In 2021, in a twinning project and with technical assistance developed a software product to serve as the data registry from the German city of Nuremberg, the city of Skopje de- of the municipality. Each LSGU would share its data with veloped a draft chimney sweeping law (Box 6), inspired MoEPP which will thereby gain access to a localized emis- by Germany’s proven practices in this area. The law would sion inventory covering the entire country. The project also make annual inspection and cleaning mandatory for all developed a curriculum for chimney sweep training in vo- households in North Macedonia. Chimney sweeps will be cational schools for certification by the Ministry of Educa- required to collect and record household-level data on the tion, to ensure that the required technical and staff capaci- relevant metrics, including the type of heating installation, ty can be built over time. Box 6: The chimney sweeping system as proposed in the draft law developed by Skopje26 The draft law makes chimney sweeping mandatory for all households once per year by a qualified professional. The frequency of sweeps is higher for restaurants and some other business categories. Based on a pollution map to be provided by MoEPP, municipalities will define chimney sweeping zones. For each zone, they approve and appoint one professional sweep to service this operating area. To qualify as an authorized municipal chimney sweep, the person must complete vocational training, obtain the appropriate equipment as to be defined in bylaws, purchase professional insurance, and have two years of working experience. ___________________________________  s the draft chimney sweeping law was not available for review, this information is based on key informant interviews with people 26 A familiar with the matter in Skopje and with staff from the city administration of Nuremberg who were involved in the twinning project. 22 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents Households will be obliged to admit the sweep onto their premises and provide access to their chimney to be cleaned. Their compensation will be regulated across the country using a tariff code for chimney sweeping fees and expenses. If a household refuses to let the sweep onto their premises, the draft law foresees fines of EUR 50 to 150, depending on whether it is a personal or legal entity. Within one year of adoption of the law, the government is required to provide a rulebook defining the details of the chimney sweep’s tasks, including on what they measure and the type of data they collect. The law stipulates that chimney sweeps must collect household-level data on cleaning and maintenance and enter this into a registry for completed chimney sweeping activities. If the chimney sweep identifies issues to be fixed, for example, regarding the type or quality of fuel used, heating equipment or maintenance, they issue a recommendation to the household specifying a deadline by when the issue must be corrected. After not less than 15 days of the deadline’s passing, the sweep may check whether the rec- ommendation was implemented. In case of noncompliance, the issue is referred to the municipal environmental inspection, which can decide to impose a fine. The city of Skopje could submit the draft law and the monitoring data availability and quality are mostly related supporting documentation developed as part of the to scarce financial and human resources. The provisions twinning project to MoEPP to take the legislative pro- on air quality monitoring and reporting in the LAAQ (Art. cess forward. The draft law is the product of the coopera- 36–47) are extensive and make it the best established AQM tion between the cities of Skopje and Nuremberg, with the function from a legal perspective. Regulations are equal- Skopje city administration being the process and product ly detailed: six rulebooks provide detailed, authoritative owner. The draft law has been ready for review since late guidance on air quality monitoring methodology, assess- 2021. However, the city of Skopje is yet to share it with ment, data sharing and reporting, maintaining emission other institutions or parliamentarians, which is a prereq- inventories, keeping a cadastre of polluters and pollut- uisite for advancing the legislation toward adoption. It is ants, and technical specifications for sampling and mea- suggested that MoEPP should be the lead ministry respon- surement. MoEPP is responsible for the monitoring and sible for environment and air quality. This is because one of reporting function. The North Macedonia’s Environmental the objectives of the draft law is to harmonize the formal Information Center (MEIC), a dedicated unit within the oversight over chimney sweeping. Chimney sweeping falls ministry, carries out the work, although the LAAQ formally under communal affairs and, according to MoEPP, oper- assigns this responsibility to the EA. As this section focuses ates under the responsibility of the Ministry of Transport on the legal and regulatory design of this AQM function, and Communications (MoTC). However, a legal analysis the financial, technical, and capacity constraints are dis- conducted as part of the twinning project between Skopje cussed in Section 3.1. and Nuremberg indicated that chimney sweeps also for- The number of air quality monitoring stations at the mally operate under the scattered and partially competing national level is in accordance with the requirements purview of multiple ministries: MoEMMR, Ministry of In- of North Macedonia’s legislation and EU directives. The ternal Affairs (MoI), MoEPP, MoH, and even the Ministry monitoring network consists of one mobile station and 21 of Defense. It is suggested that MoEPP should take the lead fixed automatic ambient air monitoring stations.27 responsibility going forward. The two laboratories responsible for calibrating instru- ments and analyzing samples for air quality measure- 2.4.6 Air quality monitoring, reporting, ment are not ISO accredited, affecting the credibility of and progress evaluation North Macedonia’s air quality data. MoEPP operates two laboratories: the Central Environmental Laboratory and North Macedonia’s legal and regulatory framework on the Air Quality Calibration Laboratory. The Central Envi- air quality monitoring, reporting, and progress assess- ronmental Laboratory fulfills crucial AQM-related respon- ment is well developed. Constraints regarding air quality sibilities, including gravimetric measurements of solid par- ___________________________________  he 21 fixed automatic stations are distributed as follows: five in Skopje, two in Bitola, and one each in Veles, Kichevo, Miladinovci, 27 T Kumanovo, Kochani, Tetovo, Kavadarci, Strumica, Gostivar, Lazaropole, Gevgelija, Berovo, Prilep, and Ohrid.  Contents LEGAL, REGULATORY, AND POLICY FRAMEWORK FOR AQM 23 ticles present in the air and performing chemical analyses Overall, a significant amount of useful air quality on collected air samples using reference methods outlined monitoring data are generated and publicly available, in national legislation. The Air Quality Calibration Labora- but there is room to strengthen the use of the data to tory, established in 2004, is responsible for calibrating and inform air quality control strategies and evaluate the maintaining the measuring instruments in the state auto- effectiveness of AQM at the country and local levels. matic monitoring system for ambient air quality. However, While the network of air quality monitoring stations may it is not accredited under the ISO/IEC 17025 standard on not be without flaws, the data it produces are sufficient general requirements for the competence of testing and to indicate that air pollution is a significant concern and calibration laboratories (ISO 2017). While the Central En- must be addressed effectively. Still, the available air qual- vironmental Laboratory has been accredited under ISO/ ity information is not used routinely to review air quality IED 17025 since 2021, its accreditation did not cover any planning documents such as AQPs and inform an evalu- methods related to air quality. Although the accreditation ative judgment of the effectiveness of AQM at the state process would be demanding and time-consuming, it can or municipality levels. Impactful AQM requires a system- help increase public confidence in air quality monitoring atic and holistic effort across sectors and levels of gov- results. The successful accreditation would also underscore ernment, instead of a piecemeal approach of individual the legitimacy of measurements, which is particularly im- measures. North Macedonia’s air quality data provide a portant in situations when limit value exceedances trigger good-enough basis for taking action, but this has not yet air pollution control measures that may be perceived to be been done at scale. unpopular or overly restrictive. 2.5 Recommendations to strengthen the legal and policy framework The prevailing legal and regulatory setup is increas- for improvement in de facto operationalization. This is ingly aligned with the EU acquis, but the limited rate partly due to gaps in the legal framework and partly due to of implementation reveals that North Macedonia does the institutional capacity limitations discussed in the next not yet approach AQM as a continuous, iterative pro- chapter. cess of designing, executing, monitoring, and refining The implementation of air quality control measures air quality objectives and measures. Instead, advances in and enforcement of compliance (functions 4 and 5) will AQM depend on the occasional impetus of specific actors, require prioritized attention. Because progress reports predominantly MEIC in MoEPP, or on the opportunities of- do not exist for most policy and planning instruments, fered through external project funding. their implementation status is unknown. Operational Table 4 summarizes the findings presented in this chap- monitoring and enforcement mechanisms do not exist or ter. It illustrates that nearly all AQM functions are mod- are under-capacitated, as in the case of the environmental erately or well defined de jure but leave significant room inspection function. _____________________________________________________________________________________________________________ Assessment of AQM functions by legal specification and performance in practice28 Table 4:  AQM functions Task Role Process Performance definition assignment management in practice ('what') ('who') ('how') 1. Setting standards and objectives 2 3 2 2 Determining required emission 2.  3 3 3 2 reductions ___________________________________ See Annex 3 for summary justifications of the ratings. 28  24 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents AQM functions Task Role Process Performance definition assignment management in practice ('what') ('who') ('how') Designing air quality control 3.  3 3 3 2 strategies Implementing air quality control 4.  3 3 2 1 strategies Monitoring implementation and 5.  1 2 1 1 enforcing compliance Air quality monitoring, reporting, 6.  3 3 3 2 and progress evaluation Note: • Task definition: Assesses whether the function and its essential tasks are formally defined (‘what is to be done?’). • Role assignment: Reviews whether roles and responsibilities are clearly assigned to specific actors or institutions, without duplication or ambiguity (‘who must do it?’). • Process management: Considers whether required process steps are clearly defined, guidance is provided, and necessary resources are allocated (‘how must it be done?’). Color coding: 1 Nonexistent or only rudimentary provisions; not done 2 Incomplete, requires clarification or improvement 3 Formally well defined; well performed in practice The following recommendations are aimed at closing legal and regulatory gaps while strengthening the implementa- tion of the six AQM functions. _____________________________________________________________________________________________________________ Table 5:  Recommendations to strengthen the legal and regulatory framework for AQM No. Recommendation Responsible A.1 Complete the transposition of important EU directives on air quality objectives: MoEPP  AFE Directive (2008/50/EC) C  ourth Daughter Directive (2004/107/EC) F  irective 2015/1480/EC, amending CAFE and Fourth Daughter Directive annexes D  EC Directive (2016/2284/EU) N Decree on national emission reduction commitments for 2030  ED I  CPD M A.2 Transpose specific emission control and related directives of the EU: MoEPP (for I  ED IED and M  CPD MCPD) MoE,  codesign Directive (2009/125/EC) and related regulations E MoEMMR  U energy labeling legislation E  inalize and adopt the Rulebook on the Quality of Solid Fuels for Heating F  Contents LEGAL, REGULATORY, AND POLICY FRAMEWORK FOR AQM 25 No. Recommendation Responsible A.3 Develop a new NAPCP as required by NEC. MoEPP The LAAQ Art. 23 currently stipulates that two separate national air quality planning doc- uments must be created; this is not necessary under EU legislation. The new NAPCP could cover more than the five NEC pollutants and replace the outdated National Plan for Ambi- ent Air Quality Protection 2013–2018. The new plan should be aligned with other strategy documents of North Macedonia covering related areas, including the Just Transition Road- map (MoE 2023), the Strategy for Energy Development until 2040 (MoE 2019), and the Long-Term Strategy on Climate Action and Action Plan (MoEPP 2021). A.4 Update the 2016 guidelines on AQP development, including detailed guidance on fi- MoEPP nancing and citizen engagement, and anchor it in the LAAQ (results of public partici- pation in the preparation of the plan must be documented in the AQP). In addition to the respective rulebook on AQP development, the guidance should specify the type of analysis required, information to be included, calculation of required emission reductions, definition of control strategies, and estimation of the extent to which imple- mentation of control strategies will achieve emission reductions. The guidelines should also provide guidance on proactive citizen engagement on AQM, as discussed in more de- tail in Section 5. Clear responsibilities for all stakeholders and ways to implement and monitor results must be defined. The guidance should be anchored in the LAAQ to make it binding and subject to review and accountability. MoEPP should offer periodic orientation on the guidance in the form of trainings or consultation sessions. A.5 Short term: Promote inter-municipal cooperation on authorized environmental in- MoEPP spections. Long term: Consolidate state and local environmental inspections in a proposed En- vironmental Inspectorate. A recent change to the Law on Environmental Inspection (Official Gazette 99/2022) em- powers municipalities to form organizational zones to share permit writing and inspection duties, an opportunity to pool capacities, resources, and gain efficiency. This means that the ground is prepared legally, but the majority of LSGUs still require training and equip- ment to carry out environmental inspections relevant to AQM. If, after a transition period, LSGUs are still hesitant to cooperate on inspections, coopera- tion could be made mandatory by law for municipalities below a certain size. A more fundamental institutional reorganization will require more time but appears to be needed. The government should establish an Environmental Inspectorate, subordinated to MoEPP, that would take on the functions currently performed by SEI and the authorized environmental inspectors in LSGUs (discussed in more detail in Section 3.3). A.6 Formally and practically embed the function of chimney sweeping in the AQM sys- MoEPP tem, building on the existing draft law. Enforce annual inspections of all buildings and use inspection results to build a localized emission inventory and ensure that households comply with air quality regulations. The existing draft law, developed by the city of Skopje as part of an international twinning project, should be handed over to MoEPP to enable the ministry to build on existing efforts and drive the legislative process forward. 26 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents No. Recommendation Responsible A.7 Obtain ISO/IEC accreditation for the Central Environmental Laboratory and the Air MoEPP Quality Calibration Laboratory. The Central Laboratory fulfills crucial AQM-related responsibilities, including conducting gravimetric measurements of solid particles present in the air and performing chemical analyses on collected air samples using reference methods outlined in national legislation. The Air Quality Calibration Laboratory, established in 2004, is responsible for calibrating and maintaining the measuring instruments in the state automatic monitoring system for ambient air quality. Neither is accredited under the ISO/IEC 17025 standard on general requirements for the competence of testing and calibration laboratories, which affects the credibility or air quality measurements.  Contents LEGAL, REGULATORY, AND POLICY FRAMEWORK FOR AQM 27 3Institutional configuration and capacity for AQM 28 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents This chapter reviews the setup and capacity of the key in- Other relevant stakeholders are discussed in brief to high- stitutions that have the primary responsibilities to man- light issue areas with room for improvement. age air quality: MoEPP, LSGUs, and SEI. 3.1 Ministry of Environment and Physical Planning MoEPP is North Macedonia’s main authority responsi- The ministry is the competent institution leading on air ble for environment and air quality. While its AQM re- quality legislation, policy and planning, monitoring and sponsibilities are extensive (Box 7), the ministry’s organi- data, air quality assessment, reporting, and international zational structure has a critical gap regarding air quality cooperation. It manages all types of pollution of environ- policy and planning. mental media, including air. Box 7: AQM responsibilities covered by MoEPP Air quality monitoring and data:  ubmit the monitoring data to relevant international S D  efine zones and agglomerations and conduct organizations. assessments of air quality within these designated  evelop and publish annual emission reports and an- D areas. nual ambient air quality reports.  stablish and maintain a comprehensive state air E Legislation, policy, and planning: quality monitoring system and network.  ranspose EU directives related to air quality into na- T  ather and process information on air quality and G tional legislation. emissions.  ropose pollutant limit values, alert, and informa- P  evelop and maintain a National Environmental D tion thresholds; deadlines for reaching the limit and Information System that encompasses emissions target values for certain pollutants; margins of tol- and air quality data. erance for limit values; target values and long-term  repare an annual air quality monitoring program. P goals for individual pollutants.  raft the methodology for environmental monitor- D  repare national planning documents: National Plan P ing. for Ambient Air Quality Protection (every five years) P  repare and update the list of accredited entities and and the NAPCP (every five years). scientific organizations for monitoring of environ-  stablish and regularly reevaluate the definition of E mental media. zones and agglomerations for air quality planning (every five years). Assessment:  pprove AQPs prepared by LSGUs. A  ssess air quality. A  rescribe criteria, methods, and procedures for the P A  ssess transboundary air pollution, in cooperation assessment of ambient air quality. with the competent authorities of the neighboring countries. International cooperation: A  ssess the health risk related to the quality of am-  nform neighboring countries when air pollution ex- I bient air. ceeds the alert threshold in areas close to the borders.  ake measures to control transboundary impacts of T Reporting: poor air quality.  reate and publish reports related to various aspects C  ollaborate with other countries in implementing the C of air quality. LAAQ, where applicable.  Contents INSTITUTIONAL CONFIGURATION AND CAPACITY FOR AQM 29 Two entities within MoEPP stand out because they car- trends regarding all environmental media that is compre- ry out the majority of AQM-related tasks: MEIC and hensive, accurate, transparent, and publicly accessible. the EA. The following sections review whether the staff The segments covered by MEIC are air, water, soil, noise, capacity and institutional structure of MEIC and the EA waste, nature, and protected areas. are fit for purpose to lead AQM effectively. All staff currently in position are considered techni- cally qualified. However, all four units in MEIC are 3.1.1 North Macedonia’s Environmental understaffed (Figure 4). Out of 25 positions formally Information Center established for MEIC in the ministry’s administrative sys- tematization, only 16 were filled as of early 2024. This MEIC is a departmental entity within MoEPP, compris- situation has persisted for an extended period. ing four units with a mandate to collect, analyze, and share data about the environment. The department is Nearly half of all positions with a responsibility for organized into the following sections: air quality monitor- AQM are vacant in MEIC, leaving air quality-related ing, analytics and reporting, cadastre and modeling, and functions significantly under-capacitated. Of the nine po- information technology. They serve the principal man- sitions with specific AQM responsibilities, four are vacant. date of MEIC to establish, maintain, and regularly update The Air Quality Monitoring Unit particularly is short on the base of relevant, properly processed (systematized staff to calibrate, maintain, and service the State Automat- and standardized) information on the state, quality, and ic Ambient Air Quality Monitoring System (SAAAQMS). _____________________________________________________________________________________________________________ Current organizational structure of MEIC29 Figure 4:  1 Head of Dept. Macedonian Environmental Information Center (MEIC) 1 Deputy Head of Dept. Air Quality Monitoring Unit Analysis and Reporting Unit Cadaster and Modeling (3/6 positions vacant) (1/3 positions vacant) Unit (3/6 positions vacant) 1 Head of unit 2 Advisers for air emission Information Technology Unit data collection, analysis and (3/6 positions vacant) 1 Adviser for air quality data validation, verification and reporting analysis 1 Adviser for air quality data 2 Advisers for calibration of collection, analysis and the State Automatic Ambient reporting (vacant) Air Quality Monitoring System (1 position vacant) 2 positions not relevant to AQM, filled 2 Advisers for maintenance and servicing of the SAAAQMS (2 positions vacant) Source: Original elaboration for this publication _____________________________________________________________________________________________________________ ___________________________________  s of February 2024, based on information provided by MEIC. Number of positions established as indicated in the Regulations for 29 A the Systematization of Positions in MoEPP (2017). 30 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents MoEPP does not have a unit dedicated to air quality A-integrated permits that cover larger installations. It per- legislation, policy, planning, or implementation su- forms on-site inspection of the installation for which an pervision, a consequential structural and capacity gap. integrated environmental permit or a permit for compli- Therefore, the Air Quality Monitoring Unit in MEIC and ance with an operational plan is sought. It also exchanges staff from the Analysis and Reporting Unit have assumed data with other administrative entities, especially SEI and these functions outside their mandates, overstretching LSGUs. The latter are responsible for issuing B-integrated their capacity. Although the main tasks of the MEIC units permits for smaller installations. The IPPC unit reviews are overseeing air quality monitoring, analysis, and re- B-permits for compliance with an operational plan issued porting, they—and primarily the Air Quality Monitoring by the LSGU. If deficiencies are identified, the IPPC unit Unit—have stepped up to fill the void. The staff at the Air informs the competent authorities, provides guidance for Quality Monitoring Unit cover a wide array of crucial tasks implementing the procedure for B-integrated environ- ranging from drafting legislation and developing policies mental permits or B-permits for compliance with an oper- and standards to leading on national air quality planning ational plan, and processes B-permits for installations in and providing essential support to municipalities in de- protected areas or when the municipality does not have veloping AQPs. This is often done by raising, managing, capacity to process them. Lastly, the IPPC unit also main- and implementing financial and technical assistance proj- tains a register of all A- and B-integrated environmental ects from international partners. De facto, MEIC fulfills permits. Test reports based on emission measurements three roles—(a) policy making; (b) implementing and for all media, in line with the permit’s prescribed mea- implementation support; and (c) monitoring, analysis, surement frequency, must be submitted to the IPPC unit. and reporting—although only the latter falls within its The IPPC permits are the basis for environmental mandate. With 50 percent of positions in the Air Quality inspections and therefore an integral part of North Monitoring Unit vacant, the staff members in place carry Macedonia’s pollution prevention and control system, out multiple functions beyond their job descriptions and but the permit writing capacity in the IPPC unit is sig- significantly overextending their resources. nificantly limited. The unit currently employs only two There is an urgent need to create dedicated institu- A-permit writers; two more positions are established in tional capacity for air quality policy, planning, and im- the systematization but remain vacant. The two A-permit plementation support within MoEPP and reflect this in writers cover all installations across the country, current- the organizational structure independent of MEIC. A ly around 130, and must keep track of 240 procedures for proposal for how this could be realized in the EA is out- permit issuance. The process of obtaining an IPPC takes a lined further below. minimum of 90 days by law and should be completed as quickly as possible. In practice, MoEPP staff estimate that the average time needed to issue a permit is one year. This 3.1.2 Environmental Administration is mainly due to a shortage of staff in the unit. The EA is an organizational entity within MoEPP that is tasked with establishing and operating an integrat- 3.1.3 Addressing staff shortages ed environmental protection system. Its five depart- and capacity constraints ments are environment, nature, water, waste, and indus- trial pollution and risk management. The EA carries out Important staff positions for carrying out AQM func- professional work and supervision over protected areas, tions in MEIC and the EA appear to remain vacant pri- land, water, and air. It proposes expert technical solutions marily because of a shortage of qualified candidates, to reduce or prevent pollution and degradation of life and in addition to governmental budget constraints. Most nature, prepares professional documentation in the field of the AQM functions performed within MEIC and the EA of protection and improvement of the environment and are highly technical. Applicants often do not possess the nature, and measures and monitors the conditions and requisite education or experience commensurate with the changes in the environment and nature. requirements of the job. Therefore, positions in MoEPP have been unsuccessfully repeatedly re-advertised. The IPPC unit within the EA department for Industrial Pollution and Risk Management fulfills an important Moreover, public sector salaries are perceived not to AQM function as it issues permits under the EU’s IPPC be competitive compared to private sector pay, mak- directive 96/61/EC. Integrated environmental permits ing the limited number of qualified candidates seek specify emission limit values for all environmental media employment elsewhere. An analysis of recent data and are issued in A and B categories, as outlined in Sec- confirms a public-private wage deficit for technical and tion 2.4.5. The EA’s IPPC unit is primarily responsible for scientific job profiles in North Macedonia (Figure 5).  Contents INSTITUTIONAL CONFIGURATION AND CAPACITY FOR AQM 31 Reviewing the average monthly remuneration for pub- higher than private sector wages for workers with simi- lic versus private sector employment in North Macedo- lar socioeconomic characteristics, across all countries.30 nia confirms that there is a public-private wage deficit, The public sector premium tends to decrease with the lev- at least in comparison to the professional, scientific, and el of economic development, ranging from an average of technical job category which is the profile that would be nearly 12 percent in emerging market economies, such as required for performing AQM tasks in MoEPP. However, North Macedonia, down to 5 percent in advanced econo- this pay gap does not exist when contrasting public sector mies. However, there are numerous EU countries where wages with remuneration across all sectors in the coun- the average public sector pay is lower than private sector try. In fact, a distinct public-private wage premium can remuneration, such as France, Finland, and Sweden. In be observed for most years. Except for 2022, the average the region, Slovenia exhibits a public-private wage premi- monthly net wage in the public sector was higher than um of around 5 percent, while in Bulgaria, Romania, and the average pay across sectors. A recent analysis by the the Czech Republic, public sector wages are 5 to 7 percent International Monetary Fund (IMF) shows that this is lower than private sector pay (Coady, Jirasavetakul, and not unusual (Coady, Jirasavetakul, and Abdallah 2023). Abdallah 2023). On average, public sector wages are around 10 percent _____________________________________________________________________________________________________________ Figure 5:  Public versus private sector pay in North Macedonia Average monthly net wage per employee (MKD), and public-private pay gap (%), by sector Premium Denars /month Pay gap Deficit 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Avg. monthly net wage, all sectors Professional, scientific and technical services Public administration and defence Public sector pay gap (% of prof. services) Source: Based on data from State Statistical Office. Methodological notes: https://www.stat.gov.mk/MetodoloskiObjasSoop_en.aspx?id=40&rbrObl=14 Note: Average net wage earned in December of the respective year. _____________________________________________________________________________________________________________ ___________________________________  here are many potential reasons explaining a public wage premium, including regulation, collective bargaining power, political 30 T considerations, inelastic labor demand in the public sector, and public policy objectives such as signaling to the private sector, promoting gender equity, reducing poverty, and reducing income equality (Coady, Jirasavetakul, and Abdallah 2023). 32 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents In a relatively small labor market such as North Mace- exploring establishing university degree programs, for donia, attracting qualified candidates to a technical example, on air quality control, possibly as a specializa- function such as AQM may require providing addition- tion under environmental management. Examples from al financial or other incentives to offset the public-pri- other countries can serve as inspiration.31 vate wage differential for technical and scientific staff. The incentives could emphasize benefits such as social and health insurance benefits, retirement contributions, 3.1.4 Institutional reconfiguration and paid leave days. The incentives could be considered to strengthen AQM performance as a short- to medium-term measure to close the public The absence of a lead entity overseeing and driving sector pay gap for professional positions, a differential the AQM agenda within MoEPP is an important gap that does not exist anymore compared to other areas that should be closed. Currently, the Air Quality Mon- when looking at average wages across sectors. itoring Unit within MEIC fulfills most AQM tasks across the functional spectrum, from setting policy objectives to When specialized AQM positions cannot be filled, overseeing implementation and monitoring air quality, tailored technical training and on-the-job qualifica- as indicated above. This unusual arrangement hampers tion can be considered. Outsourcing some tasks would not only the ability of MEIC to fulfill its core mandate, be an option if the challenges persist. As a medium- to focusing on air quality monitoring, data analysis, infor- long-term solution, specialized graduate curricula for air mation, and reporting, but it also leaves North Macedonia quality control and environmental management could ill-equipped to manage and improve its air quality stra- be established at universities. As the staff shortages pri- tegically and holistically. Three scenarios for holistically marily affect AQM policy-related tasks, air quality mon- strengthening AQM in MoEPP are presented below. itoring and SAAAQMS operation and maintenance, it may be worth expanding the pool of potential applicants. In the first scenario, the creation of a Department for Well-qualified public policy graduates or professionals Air Quality in the EA can mitigate this issue in the near could receive bespoke training on AQM. Engineers and term, with a new unit for air quality policy, planning, other professions with relevant technical expertise and implementation supervision and emission control experience, though not necessarily in the air quality (Figure 6). Most importantly, the new Department for field, can receive on-the-job training and mentoring to be Air Quality would include a newly created unit for air brought up to speed with the requirements of the respec- quality policy, planning, implementation supervision, tive specialized task. Twinning arrangements and mento- and emission control. This unit would take on all out-of- ring are also feasible, either within North Macedonia or in scope tasks currently performed by MEIC’s Air Quality the region where well-developed air quality monitoring Monitoring Unit, for example, drafting legislation, devel- networks are run, for example, in Bosnia. If none of these oping national AQPs, and liaising with LSGUs on devel- measures bear fruit, the ministry may consider outsourc- oping and implementing municipal AQPs. The latter part ing selected functional tasks to the private sector, such as on operational supervision is crucial because experience operation and maintenance of the air quality monitoring has shown that, while North Macedonia has had national- network. In the medium to long term, to increase the pool and local-level AQPs, implementation has remained lim- of graduates with requisite qualifications, it may be worth ited and progress unmonitored. ___________________________________  he University of Stuttgart, Germany, offers a Master of Science (MSc) curriculum in Air Quality Control, Solid Waste and Waste Water 31 T Process Engineering (https://www.uni-stuttgart.de/en/study/study-programs/Air-Quality-Control-Solid-Waste-and-Waste-Water- Process-Engineering-WASTE-M.Sc-00001./). The University of Colorado Boulder runs an MSc program in Air Quality in its College of Engineering and Applied Science (https://www.colorado.edu/mechanical/academics/ms-programs/master-science-thesis-program/ air-quality-ms-curriculum). The University of the West of England, Bristol, offers an MSc in Environmental Management with a specialization in Air Quality Management (https://courses.uwe.ac.uk/F1N21/environmental-management).  Contents INSTITUTIONAL CONFIGURATION AND CAPACITY FOR AQM 33 _____________________________________________________________________________________________________________ Figure 6:  Scenario 1 (short term): Proposed institutional structure to strengthen AQM Environmental Administration (EA) Macedonian Environmental Environment Department Nature Department Water Department Information Center (MEIC) Industrial Pollution Air Quality Department Waste Department Air Quality Monitoring Unit and Risk Management (1 head + 1 dept. head) (6 positions) Department Analysis and Reporting Unit Policy, Planning and (5 positions) Implementation Supervision Unit (4 positions) Cadaster and Modeling Unit (6 positions) Air Quality Monitoring Unit (6 positions) Information Technology Unit (6 positions) Emission Inventory Unit (5 positions) Implementation Support & Technical Assistance Unit Could also be placed in the IPA (3 positions) Implementation Department Source: Original elaboration for this publication _____________________________________________________________________________________________________________ The Air Quality Monitoring Unit would move from porting and the positions covering the other environmen- MEIC to the new Department for Air Quality in the EA. tal media.32 If North Macedonia adopts new legislation The experts in this unit would continue leading the daily to introduce mandatory chimney sweeping, as suggested monitoring of data derived from the SAAAQMS, ensuring in Section 2.4.5, this activity would create a new suite of data validation and verification. They also manage the granular inventory data from the residential sector which monitoring network. This includes maintaining and servic- could be processed in this unit. A fourth position in the ing stations and samplers, changing filters, replacing parts, Emission Inventory Unit would be tasked with supervising and calibrating the instruments. Their responsibilities ex- and managing the data reported by LSGUs. tend to measurements and sample preparation, including It is advisable for MoEPP to continue providing prac- the preparation of samples for chemical analysis of heavy tical AQM implementation support to municipalities metals from suspended particles, as well as the processing and sector ministries while AQPs are still a new con- and analysis of the acquired data. Based on this informa- cept for most LSGUs and air quality is not yet priori- tion, they continue compiling daily, monthly, and annual tized consistently across sectors. In the ministry’s cur- air quality reports. rent structure, MEIC performs numerous tasks that fall A new Emission Inventory Unit is suggested to take in the category of project implementation and hands-on over air pollution emission inventory-related tasks technical support, for instance, in hiring third-party con- currently performed by MEIC while adding new capac- sultants to assist LSGUs in drafting their AQPs. Without ity for building up a granular emission inventory from this operational assistance, LSGUs may find it difficult to local sources. The Analysis and Reporting Unit in MEIC sustain the current momentum in the AQM agenda. More- covers various environmental media (air, water, waste, over, cross-sectoral coordination and integration of air and noise). The new Emission Inventory Unit would take quality as a priority in plans and programs is limited, as over the MEIC positions dedicated to emission inventory discussed further below. This area can also be supported work, that is, air emission data collection, analysis, and re- by MoEPP. ___________________________________  he five suggested positions comprise one head of unit and one staff member each for energy, industry, agriculture and waste, and 32 T transport. 34 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents There are different options for how the implemen- (Figure 6, bottom). The new unit could provide hands- tation support function could be integrated into the on support to municipalities as well as work with sector ministry’s organizational structure. MoEPP has exten- ministries to help integrate and promote AQM priorities. sive experience with providing implementation support However, this new unit could also be placed within the IPA from within its existing organizational structure, but it Implementation Department, as long as a strong focus on is not currently dedicated to AQM. The ministry oper- AQM is maintained. ates a Department for IPA Implementation, with units on A medium-term option would be for the ministry to es- program design, technical implementation, and internal tablish a Program Implementation Department with a coordination and control. There is also a separate Proj- dedicated AQM unit (Figure 7). In this scenario, a new ect Department in MoEPP focused on IPA infrastructure Program Implementation Department would house dis- grants. A different setup is needed to ensure that AQM-re- tinct project implementation and technical assistance lated implementation support is provided adequately and units, one per environmental media. Slovakia has followed sufficiently capacitated. this model successfully (Box 8). The units within this de- In the short term, an Implementation Support and partment could have project-specific responsibilities and Technical Assistance Unit could be added to the pro- provide more general, technical support, for example, to posed Department for Air Quality within MoEPP municipalities in designing or implementing AQPs. _____________________________________________________________________________________________________________ Figure 7:  Scenario 2 (medium term): Strengthening implementation support functions in MoEPP Environmental Administration (EA) Environment Department Nature Department Water Department Industrial Pollution Program Implementation Air Quality Department and Risk Management Waste Department Department (1 head + 1 dept. head) Department Air Quality Policy, Planning and Project Implementation & TA Unit Implementation Supervision Unit (4 positions) Environment Project Implementation & TA Unit Air Quality Monitoring Unit Nature (6 positions) Project Implementation & TA Unit Water Emission Inventory Unit Project Implementation & TA Unit (4 positions) Waste Management Project Implementation & TA Unit Industrial Pollution & Risk Mgmt. Project Implementation & TA Unit Source: Original elaboration for this publication _____________________________________________________________________________________________________________  Contents INSTITUTIONAL CONFIGURATION AND CAPACITY FOR AQM 35 Box 8: Institutional arrangements for AQM implementation support: Examples from other countries Separate EPA Some countries maintain large and relatively independent environmental protection agencies that support their min- istry of environment on a range of functions related to technical, scientific, advisory, and grant management tasks, including for AQM. Examples include the EPA in the United States; the German Environment Agency (UBA), and the French Environment and Energy Management Agency (ADEME). Latvia provides an example for how a small country such as North Macedonia might structure this institution in the long term. A small EU member state, the country affords having a separate EPA, the State Environmental Service (Valsts vides dienests, VVD), with over 300 staff (VVD 2023). While Latvia’s population size is nearly identical to that of North Macedonia, its GDP per capita is nearly double the Macedonian figure. Therefore, it may not be realistic to im- plement this model in North Macedonia in the near term, given the cost implications and the already existing shortage of qualified technical personnel. Environmental protection institution within the ministry of environment Croatia (Institute for Environmental and Nature Protection [HAOP])33 and Slovenia (Slovenian Environment Agency [ARSO])34 have established environmental agencies or institutions that perform similar roles to an EPA but operate under the overall organizational structure of their ministry. This offers obvious advantages from an efficiency perspec- tive. Slovakia: AQM focused department and implementation support units within the Ministry of Environment The Slovak Republic also operates a separate EPA, Slovak Environment Agency (SAŽP).35 However, the country’s Ministry of Environment features a promising structure that can serve as inspiration for North Macedonia (Slovak Ministry of Environment 2023). Similar to what has been proposed above, the Slovak Ministry of Environment houses a department for climate and air protection. Within the department, distinct units are dedicated to emission reduction, air protection including policy and planning, and a separate unit responsible for coordinating activities under the EU-funded LIFE project on air quality improvement. Most significantly, the ministry has established a separate Department for Program Implementation. It comprises 12 units, one each per environmental media including air, and units for other specialized areas such as flood protection and for cross-cutting services such as technical assistance and human resources. As a long-term solution, a recent proposal suggest- posing to consolidate all implementation-related tasks in ed to consolidate implementation functions in a a newly created Agency for Environment under MoEPP new Agency for Environment that is subordinated to (Gruberte, Antonovs, and Kube 2021). However, for a rel- MoEPP (Figure 8). In many countries, technical services atively small country such as North Macedonia, establish- and support tasks related to the environment are separat- ing and maintaining a separate institution may be costly ed from the more legislative and policy-focused ministry and ultimately inefficient, although it may be a viable to an EPA or similar entity. A recent IPA-funded advisory solution in the long term. project on state reorganization followed this model, pro- ___________________________________ https://www.haop.hr/index.php/hr 33  34 https://www.arso.gov.si https://www.sazp.sk 35  36 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents _____________________________________________________________________________________________________________ Figure 8: S  cenario 3 (long term): Proposed hierarchy and reporting lines of state administrative bodies subordinate to the Ministry of Environment Ministry of Environment Directorate for Environment Climate Change and Administrative Transition Directorate Support Directorate Agency for Environment Environment Inspectorate Source: Based on Gruberte, Antonovs, and Kube 2021. Note: The institutions subordinated to the ministry would be legally subordinated to the Minister, while the arrows describe working level relationship between subordinated institutions and directorates. _____________________________________________________________________________________________________________ As AQM-related support to municipalities will likely re- benefit from continued guidance and support in operation- main an important function to be performed by MoEPP, alizing their AQPs. Therefore, it is recommended to adopt any future scenario should be coordinated with MoLSG a coordinated approach with the ministry responsible for and the MoEPP Department for Cooperation with Lo- LSGUs and draw on the experience of MoEPP in this area. cal Self-Government and Administrative Supervision. Additional entry points for strengthening the AQM capaci- It is foreseeable that local self-governments would greatly ty of LSGUs are assessed in the following section. 3.2 Local self-government units Municipalities bear the brunt of AQM implementation leadership and the level of public awareness of air qual- responsibilities, considering that the residential sector ity issues. Where local leaders or civil society do not con- is the largest contributor of particulate matter air pollu- sider air quality to be a priority, little is done to implement tion. Following the principle of subsidiarity, LSGUs should AQM. The prioritization of air quality by the local leader- take charge of a wide range of air quality control measures: ship is often contingent on the extent to which residents reducing emissions from municipal sources, that is, those perceive clean air as important and requiring attention. owned or operated by the municipality; supporting resi- Moreover, in most LSGUs, AQPs have only been adopted dents in reducing emissions from their heating installations, recently, providing a strategic framework for approaching for example, by supporting boiler replacements and thermal AQM systematically going forward. insulation of houses; developing renewable energy sources; Funding for the implementation of municipal AQPs is supporting activities to improve energy efficiency; imple- limited and mostly contingent on international, proj- menting activities to reduce emissions from transport; coop- ect-specific support. Municipalities are said to often erating with businesses to reduce emissions from industrial struggle with financing their basic staffing and opera- and service installations; and promoting ecological educa- tional costs. Allocations to AQM-related tasks out of the tion and raising the level of public air quality awareness. municipal budget are not institutionalized and tend to be The extent to which municipalities actively implement small. Therefore, the scale and effectiveness of air pollu- AQM measures significantly depends on their political tion control measures remain limited (Box 9).  Contents INSTITUTIONAL CONFIGURATION AND CAPACITY FOR AQM 37 Box 9: AQM with limited capacity and resources: Example of Kumanovo Kumanovo is the second largest LSGU in North Macedonia, after Skopje, with a population of around 100,000. The municipal administration employs five staff members in the environment sector, responsible for covering all media, including air quality. The municipality has already made significant investments in reducing emissions from publicly owned buildings by upgrading heating installations and connecting them to the gas network. Although the local administration has identified households as a key contributor to local air pollution, with wood being the cheapest energy source for heating in the area, it has not found the means to tackle this issue at scale. From a legal and regulatory perspective, the municipality does not see a basis for intervening to curb residential emissions. Therefore, Kumanovo has experimented with a subsidy scheme for households to get connected to the gas network, incentivizing citizens to switch to a cleaner energy source for heating. Per household, the subsidy amount was around EUR 250 out of a total estimated cost of EUR 1,000 per connection. In the end, 106 households benefited from the subsidy. While the subsidy scheme constitutes a valuable starting point, the constraints in administrative capacity and fund- ing have meant that the limited reach of the intervention has been insufficient to address the air pollution problem with the urgency and scale that is required. The limited organizational capacity, technical exper- financing in 2023. In addition to leading and coordinating tise, and human resources significantly constrain the the municipalities’ AQP implementation, local-level air ability of most municipalities to effectively manage air quality managers can perform important advisory and out- quality. Environmental issues, including AQM, are often reach functions, creating a link between the administration addressed by one or a few officials who must cover a multi- and households whose cooperation is required to achieve tude of other environmental responsibilities and cannot de- compliance with air quality standards and objectives. Dif- vote sufficient time to pursue air quality control measures. ferent operating modalities are conceivable. In Poland and Municipal employees tasked with AQM often have limited Slovakia, the AQM professionals are integrated into the technical knowledge of the required functional tasks, and local government administration. In Germany, chimney they do not have the time or expertise to provide guidance sweeps are private sector contractors who can get an addi- and technical advice to citizens in the area of AQM. tional professional qualification as eco-advisers, specializ- ing in advice on energy efficiency and thermal moderniza- North Macedonia could use its recently gained access tion. In North Macedonia, the government could provide to the EU LIFE program to strengthen local AQM capac- incentives for the start-up phase, for example, through ity by establishing air quality manager or eco-adviser vouchers for eligible households to use the services of an positions, at least in the 14 LSGUs that are required to eco-adviser. The German model would fulfill the need for prepare and implement AQPs. Successful examples for citizen-oriented AQM services but does not increase mu- this exist in the region (Box 10). North Macedonia joined nicipal capacity for AQP implementation and coordination the EU’s LIFE program for environment and climate action as in the examples from Poland and Slovakia. Box 10: Strengthening municipal capacity for AQM and citizen-oriented advisory services: Air quality managers in Slovakia and eco-managers in Poland Slovakia and Poland’s Małopolska region both used funding from the EU’s LIFE program to strengthen AQM at the local level. The LIFE program is the EU’s funding instrument for the environment and climate action. Air quality managers in Slovakia In early 2021, the EC referred Slovakia to the Court of Justice of the European Union (CJEU) because of poor AQM, evidenced by sustained high levels of PM10 pollution. To manage air quality better, the Ministry of Environment successfully applied for EU funding to set up the LIFE-IP SK Air Quality Improvement project. The total funding volume of EUR 15 million includes an EU contribution of EUR 9 million for the 2020–2027 implementation period (European Commission 2024a). 38 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents The project established air quality managers as a key pillar for effective AQM. A total of 14 positions were estab- lished to cover the entire territory of the country. Air quality managers operate within the eight territorial units of self-governing regions and cooperate directly with municipalities, prioritizing settlements where air pollution from residential emissions is particularly prevalent. Air quality managers coordinate and work to improve AQM measures directly with the most affected municipalities. Their tasks include the following:  ropose measures to improve regional air quality in cooperation with state institutions, self-government, the P industry, educational system, NGOs, and the public.  rovide direct assistance to regional and local authorities in implementing AQPs. P  onitor the implementation of individual measures included in local AQPs and report to the competent govern- M ment authority.  hare information on funding opportunities from national and EU funds, and prepare projects and grant appli- S cations for AQM.  esign and run public information and awareness raising campaigns and educational programs, including on D social media, to advise citizens on concrete means for reducing pollution and improving air quality (Populair 2024). Eco-managers in Poland’s Małopolska region The region of Małopolska is home to Poland’s second largest city, Krakow, and a major coal producer. Coal is also a popular energy source for residential heating, along with other low-quality solid fuels. Combustion in obsolete boilers has contributed significantly to air pollution, making it one of the EU’s most polluted regions in terms of PM10 pollution. Małopolska started implementing the LIFE project ‘Małopolska in a healthy atmosphere’ already in 2015, with a total funding of EUR 16.5 million—including an EU contribution of nearly EUR 10 million—until 2025 (Europe- an Commission 2024b). Based on a consultative process involving all 90 municipalities in the region with AQP implementation responsibilities, the regional government developed the concept of eco-managers as a pivotal instrument for strengthening local AQM (Deloitte 2015). Eco-managers have been employed in 55 municipalities benefiting from the EU LIFE program. They undergo a one-year university course on AQM specifically designed to prepare them for their roles in municipalities. Their tasks include the following:  rovide AQM advisory and administrative services to residents. P  ncourage citizens to replace old boilers with clean, energy-efficient devices and to undertake thermal modern- E ization of their homes.  onduct environmental education in schools and for the general public, promoting environmentally friendly C behavior.  ontrol compliance with AQM regulations. C  upport municipalities in obtaining funds from the EU and national sources to implement air quality control S measures. The regional government reports that, to date, eco-managers have held nearly 1.4 million advisory consultations with citizens, conducted 28,000 inspections of suspected incidents of waste burning (which is illegal in Małopol- ska), and prepared projects worth EUR 97 million in co-financing, thereby more than compensating the cost of maintaining the eco-manager positions. Overall, municipalities that employ eco-managers are perceived to be more effective in implementing AQP mea- sures than those not benefiting from their advisory support and outreach activities.  Contents INSTITUTIONAL CONFIGURATION AND CAPACITY FOR AQM 39 Municipalities are also responsible for local environ- Better inter-municipal cooperation on AQP develop- mental inspections, a function that faces significant ment and implementation, and on environmental in- capacity constraints, as outlined earlier. The authorized spections, could improve the coherence and consisten- municipal environmental inspectors, hired by the munici- cy with which air quality control measures are taken pality and not reporting to SEI, are tasked with monitoring and enforced. There are several possible options. Munic- compliance with IPPC B-permits. Among many other tasks, ipalities could be required to engage in a mandatory AQP they assess whether installations have the required mea- peer review. This would ensure that air quality control suring instruments for emission monitoring in place and measures are harmonized across local governments, to in good working order, check whether emission reporting the extent relevant, and that good practices promulgate requirements are met, and determine whether the actual more quickly throughout the country. Another possibility pollutant emissions are within the limit values specified in is to institutionalize a local coordination council on air the permit. Out of 81 LSGUs in North Macedonia, only 63 quality for neighboring municipalities. The council could (77 percent) have at least one authorized inspector (Gjor- be put in charge of facilitating technical assistance and gievski, Hadji-Zafirov, and Trajkovska 2021). In most mu- AQP implementation support, as well as communication nicipalities that have inspectors, the function is said to be with MoEPP. Moreover, LSGUs should make use of the ‘completely unequipped’ regarding training, experience, option to cooperate on authorized environmental inspec- equipment, and number of staff, having to cover 28 laws tions, as discussed in Section 2.4.5. and over 240 bylaws, including air quality legislation. 3.3 State Environment Inspectorate SEI performs an important AQM function in monitoring tives for technical experts from the private sector to join the and enforcing compliance with IPPC A-integrated per- Inspectorate. However, SEI salaries are already reported to mits for emissions from industrial sources. This involves be 30 percent higher than the average for comparable public verifying the use of approved measurement instruments, sector positions owing to risk premiums. as per the instrument verification procedure, and ensuring Financing pollutant sample analysis is another rele- their proper maintenance and use; monitoring data report- vant constraint from the perspective of monitoring and ing to the relevant authority; ascertaining whether pollutant enforcing compliance with air quality regulations. SEI limit values are adhered to; and assessing whether the op- conducts around 3,000 inspections annually. The techni- erator implements the prescribed measures outlined in the cal equipment needed for carrying out inspections on the permit. In case of noncompliance, an inspector can lodge a basis of IPPC permits is said to be up-to-date, following re- misdemeanor procedure but can also use softer instruments cent investments from international cooperation projects. such as settlement or mediation. In this case, the operator is However, the SEI budget only allocates EUR 10,000 to ex- granted a period within which to achieve compliance, pay traordinary sampling and measurement which are used to a fee, or compensate for the damage done. The LAAQ also ascertain whether installations comply with the provisions envisages the possibility of offering educational training to of their permits. This amount is reported to be vastly insuf- the polluter to support rectifying the infringement. ficient to operate a credible monitoring and enforcement The inspection function is understaffed, with limited air mechanism that can follow through in cases of suspected quality-related capacity. This problem will likely be exac- permit infringements. erbated by a wave of retirements in the coming three to five The national-level SEI and the authorized environmen- years, unless action is taken now. Out of 53 positions for SEI tal inspectors of the municipalities currently work in in the government systematization, the institution employs disjointed operational spheres, without a common re- only 22 inspectors and four administrative staff. Two inspec- porting line. A proposal exists for consolidating both in a tors are expected to retire soon, or 10 percent of the active newly established Environment Inspectorate. The present workforce. SEI’s leadership estimated that it would require setup of separate state- and local-level inspections suffers a minimum of 40 inspectors to fulfill its function adequately from obvious inefficiencies and missed opportunities for across the entire territory. Given that qualified candidates exploiting synergies and making AQM more coherent and are scarce in the labor market, it is advisable for the govern- consistent. The EU IPA-funded advisory project on state re- ment to act quickly to prevent reduced capacity for effective organization recommended establishing an Environmental AQM-related inspections in SEI. Similar to what was dis- Inspectorate, subordinated to MoEPP, that would take on cussed for staffing in MoEPP (Section 3.1.3), there may be a the functions currently performed by SEI and the autho- need to pursue targeted recruitment drives and offer incen- rized environmental inspectors in LSGUs (Gruberte, An- 40 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents tonovs, and Kube 2021). The findings of this IFR strongly for more effective AQM in North Macedonia at the national support the necessity to strengthen the inspection function and local levels.  ther relevant institutions and opportunities 3.4 O for strengthening AQM This section briefly reviews other institutions relevant to The adoption of the Rulebook on the Quality of Solid AQM with links to pollutant emissions from the residen- Fuels for Heating is another important AQM instru- tial sector and its health impacts. Specific challenges and ment but has been delayed due to capacity constraints opportunities for strengthening AQM are highlighted. in the former energy department of MoE. The systemati- zation formally places 30 people in this entity, but 18 posts remain vacant, constraining the ability of MoE to drive a 3.4.1 Ministry of Economy and Labor36 clean energy agenda forward. Following the recent insti- and Ministry of Energy, Mining and tutional restructuring, MoEMMR is now the competent au- Mineral Resources thority for the adoption of the Rulebook on the Quality of In mid-2024, a range of responsibilities with relevance Solid Fuels, while the supervision will be carried out by the to AQM that were previously held by MoE have been State Market Inspectorate. transferred to the newly established MoEMMR. Until Strengthening staff capacity in all relevant units should be recently, MoE was responsible for regulation and policy on prioritized to ensure the timely completion of the import- energy and mineral resources, supporting industry, trade, ant AQM initiatives as outlined above. tourism, market regulation for small and medium enter- prises, and consumer protection. In July 2024, the Govern- ment of North Macedonia established MoEMMR to oversee 3.4.2 Ministry of Health and Institute for the nation’s energy policy, promote renewable energy, and Public Health manage mineral resources sustainably. The ministry is also responsible for overseeing key infrastructure projects, sup- The MoH and its Institute for Public Health (IPH) play porting the transition to green energy, enforcing regula- important roles regarding air quality monitoring and as- tions, and ensuring transparency in the operations of state- sessment of health risks and impacts. The ministry is re- owned energy companies. Alongside with transferring these sponsible for or contributes to assessing the health risks from mandates, the relevant sectoral employees of the MoE have air pollution, proposing pollutant limit values, providing in- been transferred into the new MoEMMR. As of November formation and alert thresholds, setting deadlines for reach- 2024, MoEMMR employs 63 staff organized into sectors that ing the limit and target values for certain pollutants, and address specific areas such as electricity, renewable energy, defining margins of tolerance for limit values and target val- energy efficiency and climate, oil and gas, geology and min- ues and long-term goals for individual pollutants. Together ing, international cooperation, and administration. with MoEPP and MoE, it prescribes the detailed content and method for preparation of the National Plan for the Ambi- Staff capacity constraints, similar to those that were ent Air Quality Protection and the Program for Air Pollution identified for MoEPP, hinder the ability of MoEL to ad- Reduction and Ambient Air Quality Improvement. MoH also vance important initiatives that will have significant supports MoEPP in determining the criteria for choosing the air quality impacts, such as the transposition of the EU locations and setting up the air quality monitoring network Ecodesign Directive. The Internal Market Department stations. The ministry should also review AQPs with a view covers 16 laws, several of which have direct links to AQM, to assessing impacts on human health, although the extent including motor vehicle legislation, compliance regulations to which the MoH was substantively involved in reviewing for technical equipment, the free movement of goods, and the recent batch of municipal AQPs is unclear. consumer protection. The Ecodesign Directive falls into the latter area and urgently needs to be transposed to increase Until recently, IPH carried out air quality monitoring the quality of boilers and stoves on the North Macedonia’s focused on selected pollutants. Since the practice was market. Out of 21 positions envisaged in the systematization discontinued due to outdated equipment, it is advisable of these tasks, 12 are vacant, with 9 staff members scram- for MoEPP to take up this function. IPH ran two stations to bling to keep up. monitor heavy metals, black carbon, and dust until 2021. ___________________________________ 36 Since July 2024 the Ministry of Economy has been restructured and now is Ministry of Economy and Labor.  Contents INSTITUTIONAL CONFIGURATION AND CAPACITY FOR AQM 41 The pollutants are particularly relevant for analyzing emis- for Forestry and Hunting, the State Market Inspectorate, the sions from burning wood and other solid fuel for residen- State Labor Inspectorate, and the Public Revenue Office to tial heating. However, the inability to maintain and keep run ‘Gora’, an initiative to prosecute crimes related to ille- the equipment up-to-date meant that the monitoring pro- gal logging and timber trading. Since its inception, the op- cess eventually differed from the reference methods out- eration has brought criminal charges against thousands of lined in national legislation. Therefore, IPH stopped mea- perpetrators (Nikolov and UNECE 2004; Stefanovski, Danai- suring these emissions. lovska, and Georgievska 2021). Given the importance of the three substances for AQM, it The Ministry of Transport and Communications (MoTC) is suggested that the Air Quality Monitoring Unit in MoEPP fulfills mandates that pertain indirectly yet tangibly to AQM. takes on the task that was discontinued by IPH. Similar to MAFWE and MoI, MoTC participates in working groups to design interventions to reduce air pollutant emis- sions from the transport sector. The ministry feeds the corre- 3.4.3 Other sector ministries sponding data into pollutant emission inventories. The law and specialized agencies on construction and subordinate regulations can have air with AQM-related responsibilities quality impacts, for example, regarding permissible materi- The Ministry of Agriculture, Forestry, and Water Econ- als or processes (for example, dust management), but AQM omy (MAFWE) participates in working groups to define is not consistently integrated into this legislation. Environ- measures to reduce pollutant emissions from the agricultur- mental Impact Assessments (EIAs) are a prerequisite for al sector. It also provides data necessary for the compilation every building permit and include a section on air quality. of the inventory of air pollutants from the agricultural sec- However, the extent to which EIA conclusions and recom- tor. Since fuelwood is the cheapest heating option in North mendations are followed on site appears to vary. Moreover, Macedonia, the ministry plays a key AQM role in supervising zoning and construction regulations can have significant ef- the state-owned forestry company Nacionalni Šumi (‘Na- fects on air quality, for example, by ensuring adequate ven- tional Forests’) which officially supplies around 90 percent tilation corridors, but these responsibilities have been de- of retail fuelwood on the North Macedonia’s market. The volved to municipalities in North Macedonia. MoTC can only company controls the wood for moisture content, an import- provide nonbinding opinions on the urban plans of LSGUs. ant step because excessive moisture decreases combustion Similarly, the ministry exercises oversight over the Sustain- efficiency and increases emissions of PM2.5 and other pol- able Urban Mobility Plans that must be prepared by munici- lutants. However, illegal logging has become a significant palities. MoTC is to provide the ‘no objection’ for each plan, concern in North Macedonia. The total volume of illegally but the extent to which municipalities consider air quality harvested wood has been estimated to make up as much impacts in their plans and whether they can follow through as 30 percent of the fuelwood used by households in North vary between LSGUs. The ministry itself faces comparable Macedonia (Nikolov and UNECE 2004; Stefanovski, Danai- capacity constraints. Around 150 out of 400 staff positions lovska, and Georgievska 2021). MAFWE has begun to tack- in MoTC’s have remained vacant, as of early 2024. Engineers le this issue together with MoI, as outlined below. MAFWE are said to be in particular short supply. indicated that it would be generally interested in contribut- The Hydrometeorological Service (HMS) under MAF- ing to stronger cross-sectoral coordination on AQM, but its WE is the main institution responsible for systematic hy- own capacity for this was limited due to staffing constraints. drometeorological and climate observations. The HMS is MoEPP would need to provide leadership. responsible for organizing and managing the network of MoI performs numerous functions that are highly rele- meteorological stations in North Macedonia. It conducts vant to AQM. It contributes to defining measures to reduce observations and measurements to provide weather fore- pollutant emissions from the transport sector and regularly casts and information on dangerous meteorological condi- furnishes data on the number and types of vehicles that feed tions, aerology, climatology, and agrometeorology, among into the compilation of the air pollutant emission inventory. other tasks. Recently, the scope of the HMS was extend- When pollutant limit values are exceeded, MoI oversees the ed beyond classic weather observation and forecasting implementation of obligations arising from STAPs during to modeling and providing predictions related to climate emergency situations, including restricting or redirecting change, water resource management, and mitigation of en- traffic; limiting the organization of cultural, sports, and oth- vironmental degradation. In addition, the HMS is obliged er outdoor events; and restricting the use of public transport to monitor and control transboundary air pollution, to- and private vehicles, if needed. The ministry also plays a role gether with MoEPP, as well as measure the impact of at- in combating illegal logging. While MoI does not have a sep- mospheric air pollution on climatic processes in the atmo- arate department dedicated to environmental crime, since sphere. However, the institutional capacity to perform the 2014 it has cooperated with MAFWE, the State Inspectorate latter task appears limited. 42 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents 3.5 Institutional financing for AQM The financial investment in AQM at the national and MoEPP planned budget for 2024–2026 shows an almost local levels is generally considered to be insufficient exclusive focus on air quality monitoring (Table 6). Fund- in North Macedonia. Budgets are sufficient only to cover ing for strategic legislative, policy and planning work is operational costs but are not enough for strategic air qual- expected to come from the EU-funded ‘Support in the ity planning which is dependent on external resources. Implementation of Air Quality Directives’ project (IPA II) The European Commission’s Progress Reports on North which will finance the development of new national-lev- Macedonia have long stated that air quality control is in- el air quality plans and strategies to replace the outdated sufficiently resourced and “the country needs to consider- documents that currently exist. ably step up ambitions” (European Commission 2022a). _____________________________________________________________________________________________________________ Planned MoEPP budget for AQM, in MKD and EUR, 2024–202637 Table 6:  Objective Financial resource needs per year 2024 2025 2026 Regular maintenance of the State automatic MKD 11,962,471 15,000,000 20,000,000 monitoring system for ambient air quality EUR 194,220 243,537 324,716 Procurement of instruments for the State MKD 10,000,000 monitoring system for ambient air quality EUR 162,358 Finalization of SAAAQMS with automatic MKD 9,000,000 monitoring stations EUR 146,122 Preparation of locations for the installation MKD 700,000 of 1 new automatic monitoring stations EUR 11,365 Accreditation of the Calibration Laboratory MKD 1,080,750 366,150 366,150 EUR 17,547 5,945 5,945 Procurement of new air conditioners for the MKD 300,000 300,000 300,000 needs of SAAAQMS EUR 4,871 4,871 4,871 Total per year MKD 23,043,221 25,666,150 20,666,150 EUR 374,125 416,710 335,531 Although municipalities are required to allocate fund- tralized functions such as kindergartens, fire protection, ing to AQM by law, most face severe constraints in dis- and social services. Only 1.5 percent stays with the mu- cretionary budgets. The LAAQ stipulates that “budgets nicipalities. The latest Public Finance Review of the World of municipalities and of the City of Skopje shall allocate Bank confirms that LSGUs do not have an effective meth- financial resources for ambient air quality protection and odology to calculate spending needs, have limited reve- improvement, as well as other financial sources specified nues to cover the needs identified, and have little revenue by law” (Art. 64). According to the Association of Self-Gov- autonomy to prioritize spending the scarce resources at ernment Units (ZELS) in North Macedonia, an analysis of their disposal (World Bank 2019a). the 2023 national budget showed that 9.5 percent of the total budget was transferred to municipalities, of which 8 Therefore, AQM-related spending by municipalities ap- percent is considered ‘pass-through’ financing for decen- pears to go toward ad hoc, piecemeal initiatives, as re- ___________________________________ 37 Based on information obtained from MEIC as of December 2023.  Contents INSTITUTIONAL CONFIGURATION AND CAPACITY FOR AQM 43 cent experiences from Skopje illustrate. In FY2022, the received a subsidy of up to MKD 4,000 (EUR 65) to buy a bi- city of Skopje allocated budget resources to various initia- cycle, and 377 were granted an amount of up to MKD 8,000 tives aimed at improving local air quality through measures (EUR 130) to buy an electric scooter. With a population of implemented by the 10 municipalities within its jurisdiction. over half a million, the scale of these interventions is small, For example, throughout 2022, to incentivize citizens to with limited impact on air quality. Moreover, the subsidies switch from wood to cleaner heating systems, Skopje award- are often awarded on a first come, first served basis, and it is ed 316 subsidies capped at MKD 62,000 (EUR 1,000) each unclear to what extent targeting occurs based on need. This for citizens to purchase air conditioners. Another 265 house- shows that even the largest LSGU in North Macedonia has holds each received MKD 1,200 (EUR 20) to encourage the limited resources and capacity to make strategic investments use of chimney sweeping services. A total of 1,349 citizens in AQM at any significant scale.  ecommendations to strengthen institutional 3.6 R capacity for AQM It is evident that the institutional setup leaves room for constraints for effective AQM, particularly in MoEPP, and improvement to strengthen AQM, most notably given the the inspection function at the state and municipal levels. absence of a dedicated unit for air quality legislation, The following recommendations are designed to address policy, and planning. All institutions face staff capacity this. _____________________________________________________________________________________________________________ Table 7:  Recommendations to strengthen institutional capacity for AQM No. Recommendation Responsible B.1 Short term: Create a Department for Air Quality in the EA, comprising four units: MoEPP Air quality policy, planning, and implementation supervision Air quality monitoring Emission inventories  mplementation support and technical assistance, especially to municipalities in the process I of designing and implementing AQPs. Medium term: Establish a separate program implementation department in MoEPP with a dedicated air quality implementation support unit, following the example from Slovakia. Long term: Create a new Agency for Environment that is subordinated to MoEPP. This would require implementing proposal developed by the IPA-funded advisory project on state reorganization (Gruberte, Antonovs, and Kube 2021). B.2 Fill vacant positions and attract qualified technical staff to AQM-related positions in the MoEPP, SEI, public sector through conducting a dedicated recruitment drive, emphasizing incentives, LSGUs or exploring opportunities for establishing specialized graduate degree programs in air quality control and environmental management as a medium- to long-term solution. All sectoral ministries, SEI, and municipalities report difficulties in filling open positions be- cause of a shortage of qualified applicants and budget constraints. MoEPP may consider award- ing sign-on bonuses or temporary salary top-ups to attract the requisite expertise. Since this may be difficult to finance, the ministry may emphasize the nonfinancial benefits of public sec- tor jobs (for example, job security, pension scheme, and health insurance). In addition, targeted recruitment drives at universities or job fairs may be another avenue to pursue. In the medium to long term, to increase the pool of graduates with the requisite qualifications, MoEPP could collaborate with universities to establish graduate degree programs, for example, on air quality control, possibly as a specialization under environmental management. 44 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents No. Recommendation Responsible B.3 Establish air quality manager positions in municipalities, at least in the 16 LSGUs that are MoEPP, required to prepare and implement AQPs. MoLSG In addition to leading and coordinating the municipalities’ AQP implementation, local-level air quality managers can perform important advisory and outreach functions, creating a link be- tween the administration and households whose cooperation is required to achieve compliance with air quality standards and objectives. The positions can be stand-alone, or they can be fulfilled by chimney sweeps, as is the case in some EU countries. North Macedonia may be able to use EU LIFE program resources for this. There are at least two options for the operating modality:  ublic sector: The position is established in the municipality (public service). P  rivate sector: It can be offered as an add-on professional qualification for eligible contrac- P tors; training is offered by technical colleges or institutions certified by the government:  he government can provide incentives for the start-up phase (for example, vouchers for • T eligible households to use the services of an eco-adviser) B.4 Institutionalize inter-municipal coordination on air quality planning with a local coordi- MoEPP nation council on air quality and a mandatory peer review of AQPs. Better inter-municipal cooperation on AQP development and implementation could improve the coherence and consistency with which air quality control measures are taken and en- forced.  coordination council on air quality can be stipulated by law for neighboring municipalities A that are required to develop an AQP. Each council would consist of municipal staff (including from neighboring municipalities), representatives of academia, civil society, and the private sector. The council would advise on AQP preparation, especially the selection of measures, and contribute to implementation supervision once the AQP is adopted.  n the context of the coordination councils, municipalities could be required to engage in a I mandatory AQP peer review. This would ensure that air quality control measures are harmo- nized across local governments, to the extent relevant, and that good practices promulgate more quickly throughout the country. The peer review must be anchored in the LAAQ.  n annual or biennial peer learning platform should be established for key municipal stake- A holders involved in AQM to exchange experiences and lessons learned. B.5 Short term: Promote inter-municipal cooperation on authorized environmental inspec- MoEPP tions. Long term: Consolidate state and local environmental inspections in a proposed Envi- ronmental Inspectorate. A recent change to the Law on Environmental Inspection (Official Gazette 99/2022) empow- ers municipalities to form organizational zones to share permit writing and inspection duties, an opportunity to pool capacities, resources, and gain efficiency. This means that the ground is prepared legally, but the majority of LSGUs still require training and equipment to carry out environmental inspections relevant to AQM. If, after a transition period, LSGUs are still hesitant to cooperate on inspections, cooperation could be made mandatory by law for municipalities below a certain size. A more fundamental institutional reorganization will require more time but appears to be needed. The government should establish an Environmental Inspectorate, subordinated to MoEPP, that would take on the functions currently performed by SEI and the authorized en- vironmental inspectors in LSGUs (discussed in more detail in Section 3.3). B.6 Upgrade the air quality monitoring network to improve monitoring of heavy metals, MoEPP black carbon, NMVOC, and PAH. This is partly to take over the monitoring functions discontinued by IPH.  Contents INSTITUTIONAL CONFIGURATION AND CAPACITY FOR AQM 45 4Coordination across sectors and levels of government 46 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents Coordination between levels of government and between This chapter takes stock of current coordination arrange- sectors is important for ensuring that AQM is adequately ments from a legal and practical perspective. prioritized in all spheres of governance and planning and implementation are coherent and effective. 4.1 Horizontal coordination Coordination on AQM and integration of air quality on air quality in 2012, comprising representatives of the policy priorities across sectors are limited, partly be- relevant ministries, SEI, IPH, the HMS, and later ZELS cause MoEPP does not have a dedicated unit to drive and the city of Skopje to ensure local perspectives were this work. Effective AQM requires air quality impacts to be taken into account. The group met occasionally, with a fo- considered in multiple policy areas beyond a narrow focus cus on the heating season when air pollution would be at on the environment, especially in transport, urban devel- its worst. From late 2017, the Deputy Minister of MoEPP opment, energy, industry and commerce, agriculture, and started chairing the meetings to garner political support health, as briefly outlined below. None of these sectors rou- for the nonbinding recommendations issued by the group tinely review the effects of their policies and interventions (UNECE 2019). However, the group is said to have stopped on air quality comprehensively, and there are no specific working in 2020, arguably because it only involved tech- and time-bound targets related to air quality impacts to nical staff who were not able to raise sufficient buy-in and guide decision-making. For example, the National Trans- commitment from their sector institutions and because the port Strategy of the Ministry of Transport does not signifi- group leadership did not take a transparent and consistent cantly tackle air pollution issues, although the sector is a approach to sharing information and joint strategic plan- key contributor. Similarly, the MAFWE oversees the sector ning. An inter-sectoral coordination mechanism should be providing fuelwood, North Macedonia’s most widely used reestablished at the level of state secretaries, with a secre- energy source for residential heating. However, illegal log- tariat led by the proposed Department for Air Quality in ging and provision of low-quality biomass with excessive MoEPP. The high-level coordination body could be sup- moisture content are common challenges with significant ported by thematic, technical working groups, for exam- air pollution impacts, none of which have been addressed ple, on residential heating, transport, or industry. A future in an integrated manner. amendment to the LAAQ should provide a legislative an- chor for this mechanism and its decisions to be binding on The LAAQ does not provide the basis for a binding co- the participating institutions. ordination mechanism to govern AQM planning and implementation. The law does not stipulate coordinating Inter-institutional cooperation specifically on air qual- bodies, working groups, inter-sectoral councils, or other ar- ity monitoring and data sharing functions relatively rangements that would require or facilitate collaboration well, owing to good working relationships between across sectors. MoEPP, MoH, and IPH. The three institutions share re- sponsibilities regarding air quality assessment, risks, and Establishing a high-level inter-sectoral coordination impacts on human health. It is not surprising that this is mechanism for air quality would be an important step the AQM area in which coordination works best, given that in the right direction. This must build on the lessons air quality monitoring and analysis is the only function learned from an earlier attempt at coordinating sectors for which MoEPP has significant institutional capacity in through a technical working group which ultimately fal- the form of the well-performing, albeit overstretched, Air tered. MoEPP started convening an inter-sectoral group Quality Monitoring Unit in MEIC. 4.2 Vertical coordination The LAAQ does not stipulate legal provisions that Genuinely bidirectional AQM coordination between would require vertical coordination on AQM. Aside from the national government and municipalities is limited, the regular lines of authority and reporting, which are im- despite the efforts of MEIC to strengthen local-level air plicitly assumed, the law does not mandate MoEPP or the quality planning by supporting AQP development. In- municipalities to invest time or resources in coordinating stitutional capacity for AQM is weak on both sides. MEIC their air quality control efforts. performs air quality policy, planning, and implementation  Contents COORDINATION ACROSS SECTORS AND LEVELS OF GOVERNMENT 47 support functions that are completely outside its mandate, ZELS collects and consolidates feedback from municipal- and municipalities do not have sufficient staff or technical ities on legal and strategic documents and works as liaison expertise to dedicate to AQM, as discussed above. There- between the central and local authorities. It also organizes fore, there is little exchange on policy priorities, strategic trainings and conferences for its members on various top- planning, or experiences and best practices. The hands-on ics, based on need and demand. support to municipalities provided by MEIC in developing their AQPs is appreciated to be helpful technical assistance, However, ZELS’ ability to represent municipalities in but several municipalities that were interviewed as part of central government policy processes and act as an this review indicated that they do not feel consulted or in- effective go-between is currently limited because of volved in strategic AQM that would connect the national to limited staff capacity. As ZELS is established as a non- the local level in a meaningful way. governmental nonprofit organization, it is dependent on membership fees—not all of which are forthcoming—and ZELS has the mandate and some experience to contrib- external project funding. One staff member currently cov- ute to vertical AQM coordination. ZELS is a nonprofit ers three thematic areas: AQM, sustainable mobility, and organization and the only national association in which social affairs. While ZELS constitutes a suitable platform all 80 municipalities of North Macedonia and the city of for soliciting policy inputs from municipalities in general, Skopje are members. The association was founded in 1972 there is no systematic mechanism for engaging and incor- but was reconstituted in 1995 when the new Law on Local porating proposals put forth by the organization in policy, Self-Government was adopted. It is a full member of the planning, or decision-making. A future amendment to the Network of Associations of Local Authorities of South-East LAAQ could accommodate such a provision. Europe (NALAS) which brings together similar entities from 14 countries. ZELS employs 14 full-time staff and is Vertical coordination on AQM could be led by MoEPP in funded mostly from membership fees paid by the munic- cooperation with MoLSG, as part of the horizontal in- ipalities as well as through contracts with international ter-sectoral coordination mechanism, while drawing on partners and projects. Two of the organization’s primary the experience and municipal representation of ZELS. objectives are to encourage cooperation and information Within MoEPP, the Department for Cooperation with Lo- sharing among its members and to promote consistent, cal Self-Government and Administrative Supervision could constructive cooperation between LSGUs and the central play a supportive role in facilitating and moderating this state authorities. This is especially relevant when there is exchange, if it expands the scope of its work from its cur- a need for consultation between MoEPP and the LSGUs. rent focus on legal procedures to practical applications.  ecommendations to strengthen vertical 4.3 R and horizontal coordination Limited coordination across sectors constitutes a ences does not exist, aside from the one-off AQP devel- missed opportunity for prioritizing air quality issues opment support provided by MoEPP to municipalities. in all relevant policy areas. Moreover, regular vertical Two recommendations may be suitable to nurture pro- coordination between central and local authorities on ductive interactions between sectors and levels of gov- air quality policy priorities, best practices, and experi- ernment (see Table 8). 48 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents _____________________________________________________________________________________________________________ Table 8:  Recommendations to strengthen vertical and horizontal coordination No. Recommendation Responsible C.1 Establish a high-level inter-sectoral coordination council on AQM at the level of state MoEPP secretaries or deputy ministers, with a secretariat managed by MoEPP and subordinate technical working groups, as required, and amend the LAAQ to regulate the establish- ment, membership, and mandate of the council and its members, the secretariat, and the technical working groups. This approach works well in other countries. For example, Poland has created a Steering Committee for its National Air Quality Plan under the leadership of the Prime Minister’s Plenipotentiary responsible for coordinating Poland’s Clean Air program. The Steering Com- mittee comprises representatives of 13 sector ministries. In Bulgaria, a similar coordination council was established as part of the process of drafting the strategic AQM programs, and a proposal has been made to elevate this Clean Air Council at the deputy minister level and make it a more permanent entity rather than one focused on a specific activity (drafting of strategic AQM programs). C.2 Include a vertical coordination function on AQM between central and local authorities MoEPP in the high-level inter-sectoral coordination council (C.1). The design of the coordination mechanism could be led by MoEPP in collaboration with MoLSG. The two ministries could consider the possibility of giving ZELS a formal role in this mechanism, given that it has a mandate to represent the interests of its municipal member- ship in national-level policy processes.  Contents COORDINATION ACROSS SECTORS AND LEVELS OF GOVERNMENT 49 5Communication, participation, quality assurance, and accountability 50 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents Proactive communication on the state of air quality and Quality assurance and accountability in AQM refer to planned measures to improve it is an essential ingredient mechanisms to ensure that air quality policies and plans for effective, citizen oriented AQM. It sensitizes constitu- are prepared based on evidence and are suitable to re- encies to the problem and generates understanding for re- duce air pollution and they are implemented and com- quired air pollution control measures, even if unpopular. plied with to deliver the best possible air quality to all citi- zens. It would also include a commitment to transparency Beyond information sharing, a government can establish about the extent to which air quality objectives are being participation mechanisms to give citizens an opportunity met. to shape decisions that affect them. Engaging with people also provides authorities with insights into their interests and constraints. 5.1 Communication and participation Communication and public participation are processes, Macedonia. The software presents real-time and historical not single events, that run across the six AQM functions data from SAAAQMS as well as more than 50 unofficial to both inform the public and obtain input for central monitoring stations across North Macedonia. This applica- and local authorities. Transparent and participatory AQM tion triggered considerable public interest in air quality-re- can strengthen the design, public acceptance, and com- lated issues. Moreover, in recent years, a growing number pliance with air quality standards and air quality control of competitions and other types of public events have been strategies. Public participation provides stakeholders with held with the objective of generating proposals and solu- an opportunity to influence decisions that affect their lives. tions for tackling air pollution. In one of the latest exam- Stakeholders include anyone with an interest or stake in ples, students from Skopje participated in a hackathon and an issue, including individuals, interest groups, and whole developed an app called ‘Breathe.mk’. The application will communities. Depending on the form of participation allow users to submit air pollution reports with date, time, sought, public engagement for AQM can make use of a vari- live location, and the perceived level of pollution direct- ety of tools and techniques. The objective is typically to in- ly to the authorized environmental inspection of the city form the public, solicit input, and, in some cases, build con- of Skopje. The intention is to prompt the inspectors into sensus and reach agreement. Meaningful communication action to follow up with the polluter directly (Sloboden and transparent participation channels can help the central Pechat 2023). and local governments engage with different constituencies to understand their interests and constraints and generate Municipalities are required by law to provide participa- support for specific air quality control measures. tion mechanisms when preparing local-level AQPs and STAPs. With most plans having been adopted only recently, MEIC proactively shares information about air qual- experience with proactive citizen engagement is limited, al- ity monitoring data through a user-friendly online though it appears to be underutilized. The LAAQ stipulates platform. The web portal38 maintained by MEIC offers that municipalities “take all measures to inform the public comprehensive and up-to-date information about current and ensure access to information and participation in con- levels of air quality by pollutant and shares guidance and nection with the preparation and adoption of the plans” recommendations for when thresholds are exceeded. MEIC (Art. 33). The majority of LSGUs obligated to develop an air also prepares information brochures and annual reports on quality control strategy have prepared their first AQP within the state of air quality in North Macedonia. the last two years, as discussed in Section 2.4.3. Anecdotal An increasing number of private initiatives engage in information suggests that the draft plans were released for air quality monitoring and advocacy, contributing to public consultation, but citizen engagement remained limit- increased public awareness. As early as 2015, a group ed overall. This is understandable given that, in the absence of young developers created a smartphone application of a tailored strategy to solicit input from the wider public, and website for accessing air quality monitoring data, Moj nontechnical audiences will find it genuinely difficult to par- Vozduh (‘my air’), which was later subsumed under the ticipate in policy and planning processes that are perceived AirCare app catering to a wider audience beyond North to require specialized knowledge. ___________________________________ 38 https://air.moepp.gov.mk.  Contents COMMUNICATION, PARTICIPATION, QUALITY ASSURANCE, AND ACCOUNTABILITY 51 Practical guidance and, at least in this early phase of The municipal air quality coordination councils, pro- locally led AQM, technical support may be required posed in Section 3.6, could provide a platform for di- to ensure meaningful citizen engagement. MoEPP has verse participation in AQM throughout the planning, provided extensive hands-on assistance to municipalities implementation, and supervision cycle. They would in developing their AQPs. To reduce the need for this re- include staff from neighboring LSGUs, academia, civil so- source-intensive method and strengthen LSGU ownership, ciety representatives, and the private sector. The councils it is advisable for MoEPP to develop practical guidance could advise on suitable engagement modalities for specif- on AQP development. This should include recommended ic audiences. action items on citizen-oriented communication and par- ticipation in air quality planning and the implementation of measures. 5.2 Quality assurance and accountability Quality assurance and accountability mechanisms particular matter pollution exceedances (Right to Clean for national- and local-level AQM are not anchored Air 2019). It has referred Poland and Bulgaria to the CJEU in the law. The LAAQ does not foresee quality checks in which ruled against the two countries for “systematically preparing national or municipal AQPs nor are there con- and continuously” exceeding daily and annual pollutant sequences for not developing plans or implementing the limit values and for failing to implement effective AQM measures defined therein, as shown in this report (see measures (CJEU 2017, 2018). Moreover, in 2019, the Section 2.4.3). CJEU issued a judgment stipulating that individual citi- Neither ministries nor municipalities face conse- zens have the right to bring cases to their national courts quences for not managing air quality with national with the objective of enforcing EU air quality legislation plans, AQPs, or STAPs. This poses a risk in light of the in their country (CJEU 2019). This means that, as North EU accession process because infringement cases are like- Macedonia proceeds with the accession to the EU, it could ly, and breaches of EU law can result in costly financial face significant legal and financial consequences for not sanctions. In the past, the European Commission has putting in place an effective system of air quality planning issued formal warnings to 16 member states because of and implementation at the national and local levels. Box 11: E  nsuring accountability for preparing AQPs: An example from Poland Poland has been a member of the EU since 2004. The country is divided into 16 provinces (voivodeships). Admin- istrative authority in each province is shared between a governor (the voivode) who is appointed by the central government, an elected assembly (the provincial parliament or Sejmik), and an executive board chosen by that assembly. A voivodeship Marshall leads the executive board. The country’s Environmental Protection Law requires the provincial parliament to adopt an AQP within 18 months from the date of receiving air quality monitoring results indicating that the alarm threshold for a pollutant has been exceeded in a particular zone. Since AQPs must be adopted as resolution by the Sejmik, they carry considerable legal weight. The Marshall as the leader of the provincial executive is ultimately responsible for implementing the AQP. The Voivodeship Inspectorate for Environmental Protection monitors the timely adoption and implementation of AQPs at provincial level. In the event of irregularities, for example, failure to prepare an AQP on time or to imple- ment the measures defined therein, the Inspectorate is obliged to impose a fine of up to PLN 500,000 (approx. EUR 115,000) on the provincial parliament for non-preparation or the Marshall for non-implementation. This consti- tutes a significant incentive for the provincial government to comply with their air quality planning obligations. However, although the provinces generally comply with the requirement to develop AQPs, the scope and quality of the plans still varies considerably across the country (World Bank 2020). As in North Macedonia, the provincial administrations frequently rely on commercial contractors to help prepare their AQP. The level of expertise and professionalism of these consulting companies is said to differ. 52 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents The lack of a binding quality assurance mechanism stipulate that the ministry’s comments must either be ad- risks undermining the effectiveness of decentralized dressed, or justification must be given for not incorporat- AQM, especially as municipalities will have to take on ing a suggestion. the responsibility of developing AQPs in the future. The assistance provided by MoEPP to most LSGUs to se- An enforceable accountability mechanism is urgently cure funding and hire a consulting company to develop needed to ensure the latest available evidence informs their AQPs meant that the absence of a quality assurance AQPs and national and local plans are prepared, imple- function was not felt as much. However, it is unlikely that mented, and reported on. Although North Macedonia the ministry can or should provide this level of support has a relatively robust air quality monitoring and infor- going forward. Municipalities will be asked to take own- mation sharing system, it is not evident that this informa- ership of the air quality planning process. Therefore, it is tion is used to review and revise AQM decision-making advisable for MoEPP to provide detailed practical guide- periodically. Moreover, implementation progress reports lines on local-level AQP development and implementa- on most national- and local-level air quality strategies and tion. Examples exist from other countries (Lorentz and plans do not exist. This limits the ability of government Müller 2016). In addition, a mandatory peer review sys- authorities across sectors to prioritize and step up efforts tem should be introduced whereby LSGUs share and pro- if actions fall short of the set air quality objectives and the vide inputs on each other’s AQPs. In a second step, AQPs lack of transparency constrains the ability of citizens to must be shared with MoEPP for review. The law should interrogate or participate the AQPs that affect them.  ecommendations to strengthen quality 5.3 R assurance and accountability Municipalities require practical guidance to promote air quality planning (Section 2.5). Therefore, the follow- meaningful citizen engagement and participation, as ing recommendations focus on quality assurance and ac- mentioned in the recommendation to strengthen local countability. _____________________________________________________________________________________________________________ Table 9: R  ecommendations to strengthen vertical and horizontal coordination on quality assurance and accountability No. Recommendation Responsible D.1 Establish a binding quality assurance mechanism for municipal AQPs. MoEPP The drafting of AQPs should be led by LSGUs. The full draft must be shared with MoEPP for quality assurance. Feedback and guidance must be provided within a given time frame. It will be necessary to strengthen the capacity of MoEPP to fulfill this quality assurance function because the ministry currently does not have a unit mandated to provide policy guidance and expertise to municipalities. D.2 Introduce an enforceable accountability mechanism for air quality planning and im- MoEPP plementation of control measures, including sanctions for nonperformance at the na- tional and local levels. Sanctions or fines should apply to central government authorities and LSGUs in cases when they do not develop the required national planning documents or local AQPs or when they deliver poorly designed documents or when measures end up not achieving air quality tar- gets. Soft measures could complement the sanctions mechanism, for example, by publish- ing the list of municipalities required to develop and implement AQPs, with the status of preparation or implementation, to incentivize performance through ‘naming and shaming’.  Contents COMMUNICATION, PARTICIPATION, QUALITY ASSURANCE, AND ACCOUNTABILITY 53 6 Conclusions 54 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents This IFR has shown that North Macedonia’s legal and ect support for updating legislation and taking on crucial regulatory framework is at an advanced stage of align- AQM policy initiatives. ment with the EU acquis, with some gaps that are yet to The 17 recommendations from the four analytical be addressed. Multiple EU directives are yet to be trans- dimensions assessed in this report are suitable to posed in full, and the country must prepare or update na- strengthen all six core AQM functions (Figure 9). The tional air quality planning documents that have been long World Bank’s 2019 report on air pollution management outdated. in North Macedonia (World Bank 2019b) already includ- The institutional capacity required to complete the ed a range of high-level proposals for how AQM can be legislative alignment process is currently severely con- improved. The recommendations presented in this re- strained. This applies not only to MoEPP, which has most view are designed to address specific bottlenecks con- AQM-related responsibilities, but also to all other minis- straining the AQM functions in the legal and regulatory tries and municipalities with AQM responsibilities. If the sphere and regarding institutional capacity, horizontal present capacity limitations remain unaddressed, North and vertical coordination, and quality assurance and ac- Macedonia will continue to be dependent on external proj- countability. _____________________________________________________________________________________________________________ Figure 9:  Mapping recommendations against the six AQM core functions A.1 Transpose EU Directives on air quality objectives 2 A.2 Transpose specific EU emission control directives 1 1. Set standards & objectives 5 A.3 Develop a new NAPCP 2 A.4 Develop guidelines for AQP development 1 A.5 Strengthen env. inspection at state and local level 1 A.6 Make chimney sweeping mandatory 1 2. Determine required emission reductions 4 A.7 Obtain ISO IEC accreditation for laboratories 1 B.1 Strengthen MoEPP policy, planning & implementation capacity 5 B.2 Fill vacant AQM positions with qualified staff 6 3. Design control strategies 11 B.3 Establish AQ Manager positions in LSGUs 3 B.4 Inter-municipal cooperation on AQ planning 2 B.5 Inter-municipal cooperation on inspections 1 B.6 AQ monitoring network upgrade for selected pollutants 1 4. Implement control strategies 7 C.1 High-level AQ coordination council 4 C.2 Vertical coordination mechanism 3 Monitor implementation & enforce 5.  compliance 9 D.1 Binding quality assurance mechanism 2 D.2 Enforceable accountability system 3 6. AQ monitoring & progress evaluation 3 Recommendations (# of functions strengthened) AQM functions (# of recommendations) Source: Original elaboration for this publication. _____________________________________________________________________________________________________________ To prioritize and sequence next steps to strengthen al setup of MoEPP and staffing it sufficiently would be a AQM, it is advisable to begin by implementing the rec- promising starting point to enhancing its policy-making ommendations on institutional capacity development, capacity and implementation oversight function. A well- particularly B.1, B.2, and B.3. Having a legislative and staffed and well-resourced Department for Air Quality in regulatory framework for air quality that is fit for purpose MoEPP could drive a strategic AQM agenda for the country hinges on adequate institutional capacity that can formu- while supporting municipalities in developing and imple- late and enforce it. Therefore, reorganizing the institution- menting effective air pollution control measures.  Contents CONCLUSIONS 55 In parallel to institutional capacity development, which Both dimensions of change—institutional capacity will take time, it is important to make the necessary strengthening and legal and regulatory reform—re- legal and regulatory changes (recommendations A.1 quire strong coordination across sectors and levels of through A.7) in the near term to remove AQM-related government (recommendations C.1 and C.2). This is bottlenecks in the EU accession process. Institutional ca- especially important given the co-benefits of AQM and cli- pacity strengthening is a medium- to long-term endeavor. mate change mitigation. 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Zdraveva, Pavlina, and Dejan Mirakovski. 2022. “Proposal: Plan for Improving Air Quality in the Skopje Planning Re- gion, 2023–2027.” Skopje: City of Skopje; MoEPP; UNDP. 60 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents Annexes Annex 1: Methodological framework The methodological approach is organized into four main analytical categories that are suitable to assess the current state of AQM governance and to identify room for improvement and gaps in relation to the EU air quality acquis. 1. Legal and regulatory framework. Effective AQM depends on clear definitions of AQM functional tasks (‘what must be done’) that are anchored in national and subnational legislation and regulations, unambiguous distribution of roles and responsibilities (‘who must act’), and well-defined processes for the functions to be performed (‘how tasks must be implemented’). 2. Institutional/implementation configuration. This category will assess whether actors and institutions are in place and fit for purpose, in line with the legal and regulatory framework; whether mandates are aligned with their functional AQM tasks; to what extent existing levels of capacity and resources are sufficient to implement AQM functions; and whether there is leadership commitment to enable effective AQM. 3. Vertical and horizontal coordination. AQM can only be effective at scale if it is coherently integrated into national and subnational policies, programs. and processes and across sectors that contribute to air pollution. Monitoring, evaluation, and accountability. International experience suggests that a functional AQM system 4.  is driven by high-quality air quality data which are used to inform policy and planning decisions. Accountability mechanisms must be in place (a) to ensure that government institutions fulfill their AQM functions and jurisdictions meet their air pollution reduction commitments and (b) to enforce citizen compliance with AQM regulations. For this review, AQM is organized into six interdependent functions or steps (Figure 3). The common goal of these AQM approaches is to deliver impactful action to ensure the best possible quality of air, avoiding or minimizing adverse effects on human health, the environment, and the economy. The six AQM can be viewed as a cyclical process where each step is embedded in an interdependent sequence of other steps (Committee on Air Quality Management in the United States 2004; Wijetilleke and Karunaratne 1995; World Bank Group 2020). 1. Establishing goals, standards, and objectives. Goals or targets for air emissions or air quality define a pollution level—or standard—that protects health, welfare, or the environment. Defining limits on emissions and particulate matter pollution, requires information generated by scientific research on the health and welfare impacts of air pollution. Air quality standards and objectives are typically set at the national level. The EU has also issued an extensive body of air quality legislation that sets boundaries for the standards to be adopted by member states in line with WHO guidelines. Therefore, governments typically establish ambient air quality standards following the EU and WHO parameters and design regulations that require regional, district, or municipal jurisdiction—to achieve these standards within a specified period. 2. Determining required emission reductions. Once AAP standards have been set per pollutant, the necessary level of emissions reduction can be identified to attain and maintain the standards. This step depends on three prerequisites: air quality monitoring data, an emissions inventory that provides a list of sources that contribute to air pollution along with data that are needed to calculate actual emissions, and source attribution that provides data analysis and modeling to determine which sources are the primary contributors to air pollution (see Box 2 for the relationship between emission inventories and source apportionment). Developing control strategies. Depending on a country’s regulatory framework, it may be the responsibility of 3.  national, regional/state, or municipal decision-makers to develop emissions prevention and control strategies that convey how the standards will be met. The design and choice of emissions reduction options requires an understanding of the air quality, health, social and economic benefits and implications of different courses of action across relevant  Contents ANNEXES 61 sectors. Each jurisdiction then agrees and adopts a control strategy along with a detailed, comprehensive, and legally binding plan to meet the standard by a future date. Implementing control strategies. Roles and responsibilities for implementation are assigned in the emissions 4.  prevention and control strategies. Implementation can involve a broad range of stakeholders that extend beyond government entities, for example, by requiring households to replace old furnaces or avoid certain types of fuel for heating. The implementation of control strategies is closely linked with compliance measures and enforcement oversight to ensure the effectiveness of the AQM regime. 5. Monitoring implementation and enforcing compliance. In contrast to air quality monitoring that is used to measure prevailing air pollution levels (see below), routine implementation monitoring is required to assess whether the actions of individuals and institutions comply with the provisions of the air control strategies. For example, authorities may need to determine whether households comply with a ban of certain fuels or equipment modernization requirements. If infringements are detected, mechanisms must be in place to enforce compliance. The monitoring and enforcement functions are not necessarily assigned to the same entity. For example, chimney sweeps may be obligated to conduct annual chimney checks and report noncompliant household heating equipment to government authorities to follow up and enforce compliance. The enforcement function may require the collaboration of several government agencies, for example, EPAs, environmental officers of local authorities, and local police. Regardless of the regulatory design, the performance of the monitoring and enforcement function is critical to achieve emission reductions that can be detected in the last step, air quality monitoring. 6. Ongoing air quality monitoring, progress measurement, and evaluation in relation to objectives. The air quality and emissions are monitored, through a network of measurement stations or remote sensing,38 to evaluate if the control strategy is working effectively and emissions reduction objectives are met. If not, or if the standards or goals are to be adjusted, the air quality monitoring data informs the redefinition of standards and control strategies. Communication and public participation are processes, not single events, that run across the six functions to both inform the public and obtain input from them. Transparent and participatory AQM can strengthen the design, public acceptance, and compliance with air quality standards and air control strategies. Public participation provides stakeholders the opportunity to influence decisions that affect their lives. Stakeholders include anyone with an interest or stake in an issue, including individuals, interest groups, and whole communities. Depending on the form of participation sought, public engagement makes use of a variety of tools and techniques to inform the public, generate public input, and, in some cases, build consensus and reach agreement. The information that comes from these processes can enable analysis of costs of control measures across a range of sectors as compared to the benefits of undertaking these programs. The results can be expressed either as a cost-benefit comparison in one sector or presented in terms of cost-effectiveness, that is, identifying the amount of health benefit, energy savings, or expected productivity gains across different sectors. This can help administrative or environmental officials speak to different constituencies whose support will be needed to adopt measures by demonstrating how emissions reductions support multiple sustainable development objectives. ___________________________________ 38 In the EU, emissions from industrial facilities are reported through E-PRTR. 62 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents _____________________________________________________________________________________________________________ Table A.1: AQM framework: Analytical categories, guiding questions, and review criteria Analytical category Guiding questions Review criteria A. Legal and Does the legal and regulatory Clear functional task definition (‘what’). regulatory framework framework clearly define AQM  oles and responsibilities are assigned for all functions R tasks, responsibilities, and (‘who’). processes for all core AQM  rocess requirements are established (‘how’). P functions?  unctional and process requirements as envisaged F Is the current legal and regulatory in the EU air quality acquis are incorporated into framework aligned with the EU national law; gaps are identified. acquis on air quality? B. Institutional Is the current setup of actors  ssential actors and institutions are in place. E implementation and institutions fit for purpose  andates are aligned with requirements of their M configuration to design, implement, monitor, functional tasks. and enforce air quality control  apacity is in place regarding the following elements C measures? • Adequate staffing levels • Technical expertise in-house • Access to external expertise where required • Resources are available • Financial •N onfinancial (for example, equipment and infrastructure). C. Vertical and Is AQM coherently integrated into  ertical: V horizontal national and subnational policies, •I ntegration: AQM is integrated into national and coordination programs, and processes and subnational policies, programs, and processes. across sectors that contribute to •C oherence: Regarding rules, plans, and actions air pollution? across levels of government.  orizontal: H •I ntegration: AQM is integrated into sector policies, programs, and processes and across sectors that contribute to air pollution. •C oherence: Regarding rules, plans, and actions across sectors. D. Information, Do mechanisms exist to generate,  ata generation and reporting mechanisms are in D participation, quality report and disclose information, place for each function, where relevant. assurance, and track and evaluate progress,  ata are available and accessible to inform function- D accountability promote public participation, and al task performance (for example, comprehensive hold institutions to account and emission inventories; air quality modeling). ensure citizen compliance?  uality assurance processes are defined to ascer- Q tain that air quality plans and processes are evidence based and results focused.  ccountability mechanisms hold institutions A to account (including to ensure air quality plans are prepared, evidence is used to inform plans and decisions, air quality control strategies are implemented, emission reduction targets are met).  ncentives are structured to encourage citizen I compliance and facilitate enforcement.  ublic participation and engagement encouraged P along the AQM planning and implementation process.  nformation on air quality and air quality-related I rules and regulations are effectively communicated to the public.  Contents ANNEXES 63 Annex 2: Additional details on North Macedonia’s legal and policy framework for AQM 1. EU legislation shaping North Macedonia’s legal and policy framework for AQM The most important EU legislation related to air quality includes the following: Directive 2008/50/EC on ambient air quality and cleaner air for Europe Directive 2004/107/EC relating to arsenic, cadmium, mercury, nickel, and polycyclic aromatic hydrocarbons in  ambient air Commission Directive (EU) 2015/1480 amending several annexes to Directives 2004/107/EC and 2008/50/EC  2011/850/EU: Commission Implementing Decision of 12 December 2011 laying down rules for Directives 2004/107/  EC and 2008/50/EC of the European Parliament and of the Council as regards the reciprocal exchange of information and reporting on ambient air quality; The Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants (National Emission Ceilings Directive, NECD), amending Directive 2003/35/EC and repealing Directive 2001/81/EC The Directive (EU) 2015/2193 on the limitation of emissions of certain pollutants into the air from MCPs known as  the Medium Combustion Plant Directive (MCPD) The Directive 2010/75/EU of the European Parliament and the Council on industrial emissions (the Industrial  Emissions Directive or IED). 2. North Macedonia’s comprehensive AQM regulatory framework The national air quality-related legislation and subsidiary regulation consists of the following instruments: LoE  L AAQ  Rulebook on the detailed content and method of preparation of the national plan for ambient air protection  Rulebook on the detailed content and manner of preparation of the program for reduction of pollution and  improvement of ambient air quality Rulebook on criteria, methods, and procedures for ambient air quality assessment  Rulebook on the detailed requirements for the performance of certain type of professional work in respect of  equipment, appliances, instruments and related business premises to be fulfilled by entities performing specific professional work for ambient air quality monitoring Rulebook on the contents and the manner of transmission of data and information on the status of the ambient air  quality management Rulebook on the methodology for ambient air quality monitoring  Rulebook on the detailed content and method of preparation of the action plan for ambient air protection  Rulebook on the detailed content and manner of preparation of the National Plan for Ambient Air Protection  Rulebook on detailed content and manner of preparation of the plan for ambient air quality improvement  List of zones and agglomerations for ambient air quality  Decree on limit values for levels and types of pollutants in ambient air and alert thresholds, deadlines for achievement  of limit values, margins and tolerances for limit values, target values, and long-term goals Guidelines for application of the Decree on limit values for levels and types of pollutants in ambient air and alert  thresholds, deadlines for achievement of limit values, margins, and tolerances for limit values, target values, and long-term goals 64 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents Decree on Determining Combustion Facilities to take measures to protect ambient air from pollution  Rulebook on emission limit values and types of pollutants in waste gases and vapors emitted from stationary sources  into air Rulebook on the quantities of emission ceilings for the purpose of establishing projections for a specific period of time  relating to the annual reduction of quantities of pollutants emissions Rulebook on methodology, methods, procedures, methods, and means of measuring air emissions from stationary  sources Rulebook on the form and content of ambient air emissions data submission forms from stationary sources, the  manner, and time of submission in accordance with the installation capacity, content, and manner of maintaining the ambient air emissions log Rulebook on the form, methodology, and manner of managing and maintaining the Cadaster of air pollutants and air  polluting substances (herein Cadaster) Rulebook on the methodology for inventorying and determining the level of emissions of pollutants into the  atmosphere in tonnes per year for all types of activities, as well as other data for submission of the European Air Monitoring Program (EMEP) Rulebook on emission limit values and types of pollutants in waste gases and vapors emitted from stationary sources  into air Rulebook on the form, methodology, and manner of keeping the cadaster of polluters and pollutants  Rulebook on detailed conditions for performance of certain types of technical activities with regard to equipment,  devices, instruments, and appropriate business premises to be met by entities performing certain technical activities in the area of ambient air quality monitoring Rulebook on criteria, methods, and procedures for ambient air quality assessment.  3. Regulations for stationary emission sources The following legal instruments regulate stationary emission sources: Rulebook on the limits of permissible emissions levels and types of polluting substances in waste gases and vapors  released from stationary sources into the air Decree on determination of large combustion capacities that should undertake measures for ambient air quality  protection Rulebook on the format and content of the forms for submission of data on ambient air emissions from stationary  sources, manner and time interval of submission based on the capacity of the installation, content, and manner of keeping the journal of emissions into the ambient air Rulebook on the methods, manners, and methodology of measuring the air emissions from stationary sources.  4. Other legal and policy documents related to air quality and emission management Draft Law on Climate Action and its supporting bylaws  Long Term Strategy on Climate Action  Action Plan for implementation of the Law and the Long Term Strategy on Climate Action  Enhanced Nationally Determined Contribution (adopted in December 2020)  National Energy and Climate Plan  The Strategy for Energy Development of the Republic of North Macedonia until 2040 (adopted in December 2019)  • Law on Energy  Contents ANNEXES 65 Energy Efficiency Law compliant with Directive 2012/27/EU on Energy Efficiency and Energy Performance of  Buildings Directive 2010/31/EU Regulation on Labelling of energy-related products 2010/30/EU and Directive on Eco-design of energy related  products 2009/125/EC Bylaws for renewable energy  National strategy for sustainable development 2009–2030  Draft National transport strategy 2018–2030  National strategy for agriculture and rural development for the period 2021–2027  National strategy on water resource management  Law on water resource management  Waste management strategy 2008–2012  Law on waste management  Skopje Sustainable Energy Action Plan.  66 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents Annex 3: Summary assessment of the legal specifications of AQM functions and their performance in practice AQM Task definition Role assignment Process management Performance functions (‚what‘) (‚who‘) (‚how‘) (Rating 1-3) in practice (Rating 1-3) (Rating 1-3) (Rating 1-3) 1. 2 Broadly defined, 3 Responsibility clear- 2 Process requirements 2 Core air quality Setting without details on ly defined in LAAQ: for setting standards standards have standards which air quality MoEPP, in cooper- and objectives are been set accord- and standards and ation with relevant defined only in a ru- ing to the CAFE objectives objectives have sector ministries. dimentary manner; directive, but insti- to be set; there- evidence require- tutional capacity fore, incomplete ments and participa- constraints hinder transposition of EU tion mechanism not transposition of the laws. sufficiently defined, remaining relevant especially at the directives and national level. keeping national legislation up-to- date. 2. 3 Defined in LAAQ 3 Clearly assigned in 3 Clearly defined in 2 Emission reduction Deter- and rulebook LAAQ to MoEPP Rulebook on the commitments are mining Quantities of Upper calculated for na- required Limits (no. 2/10, tional plans and to emission 156/11, 111/14) meet international reductions commitments, but several plans are outdated. Emission reduction commit- ments and likely effects on air qual- ity are not estimat- ed for local-level AQPs. 3. 3 Defined in LAAQ 3 LAAQ assigns 3 For AQP: Rulebook 2 Most AQPs have Designing and bylaws on MoEPP the lead on the Detailed Con- been prepared air quality types and content responsibility at the tent and Manner of only recently, control of planning docu- national level; may- Preparation of a Plan heavily reliant on strategies ments ors and municipali- to Improve Air Qual- external funding ties are responsible ity (Official Gazette and expertise, and at the LSGU level. no. 148/14). technical support For STAP: Rulebook from MoEPP. on the Detailed Con- STAPs have only tent and Manner of been developed Preparation of Short- once by Skopje and Term Action Plans for Tetovo. Both are Ambient Air Protec- outdated. tion (Official Gazette, no. 148/14).  Contents ANNEXES 67 AQM Task definition Role assignment Process management Performance functions (‚what‘) (‚who‘) (‚how‘) (Rating 1-3) in practice (Rating 1-3) (Rating 1-3) (Rating 1-3) 4. 3 The LAAQ and cor- 3 Overall implemen- 2 The process for 1 Plans are either not Imple- responding bylaws tation responsibili- resourcing and im- implemented or the menting establish which na- ties are assigned to plementing AQPs is progress of activity air quality tional and local air MoEPP (national only broadly defined, implementation is control quality plans and level) and munici- lacking an account- unclear because it strategies programs must be palities (local-level ability mechanism to is not reported on. implemented. AQPs). ensure implementa- tion. 5. 1 The LAAQ only 2 MoEPP is responsi- 1 Process requirements 1 AQM progress Monitoring sets rudimentary ble for reporting on are not defined; there reports do not implemen- provisions on the the implementation is no mechanism to exist. The status of tation and frequency of prog- of national plans ensure follow-up if implementation of enforcing ress reporting. every other year; implementation is most plans at the compliance municipalities must not monitored or national and local report on the imple- enforced. levels is unclear. mentation of AQPs annually. 6. 3 Detailed require- 3 Based on the LAAQ, 3 Six rulebooks pro- 2 A significant Air quality ments for air qual- MoEPP carries the vide detailed process amount of good monitor- ity monitoring and lead responsibility, requirements for air and regular air ing, report- reporting are pro- with MEIC as the quality monitoring quality monitoring ing, and vided in the LAAQ competent unit con- and reporting. data are generat- progress (Art. 36–47). ducting the work. ed and reported, evaluation constrained by financial, techni- cal, and human resources, especial- ly in monitoring network mainte- nance, upgrades, and expansion. Note: • Task definition: Assesses whether the function and its essential tasks are formally defined (‘what is to be done?’). • Role assignment: Reviews whether roles and responsibilities are clearly assigned to specific actors or institutions, without duplication or ambiguity (‘who must do it?’). • Process management: Considers whether required process steps are clearly defined, guidance is provided, and necessary resources are allocated (‘how must it be done?’). Color coding: 1 Nonexistent or only rudimentary provisions; not done 2 Incomplete, requires clarification or improvement 3 Formally well defined; well performed in practice 68 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents Annex 4: The contribution of chimney sweeps to effective AQM – an EU example Chimney sweeps fulfill important fire safety and public safety functions, but they can also play important and extensive roles in inspecting and cleaning furnaces and fireplaces, measuring emissions, checking permissible fuel types and quali- ty, and advising homeowners on how to reduce emissions, save energy, and save heating costs. Germany and Austria have arguably the most stringent chimney sweeping regulations and the most advanced chimney sweep service sector among the EU member states. Similarly, Finland’s chimney sweeping sector is highly active and suc- cessful, but it is less comprehensively regulated, as is the case in some parts of Italy. To illustrate how chimney sweeps can contribute to effective AQM, this annex briefly summarizes key features of the Ger- man chimney sweeping system. According to Germany’s Federal Association of Chimney Sweepers, around 11.7 million so-called single-room firing sys- tems are installed in Germany. At the same time, the association reports that the number of traditional coal stoves is decreasing, while the number of modern wood and coal burning stoves and featured fireplaces is increasing. About 27 percent of German households have such stoves in addition to a central heating system. To counteract any worsening of air quality, the first ordinance of the implementation of the Federal Immission Control Act (Ordinance on Small and Medium-sized Firing Installations - 1st BImSchV) determines the fuels permissible for use in boilers and stoves as well as technical and emission-related requirements and demands for their supervision by the district chimney sweep. The Federal Immission Control Act (BlmSchV) and its regulations are implemented by Germany’s 16 states, with municipalities and administrative districts being responsible for air pollution control tasks. For an effective enforcement of boiler, stove, and fuel standards, the German government requires all house and apartment owners to have their fireplaces checked on a regular basis. Who can do the inspection of a fireplace? Germany has a long history of chimney sweeps being in charge of inspecting and maintaining all fireplaces in the country. Until recent legal changes, chimney sweeps had a full monopoly on passing and checking chimneys and gas heating—Ger- man home and apartment owners had a legal duty to use their local sweep to carry out servicing and inspection work at fixed prices. The market started to open in 2009, when Germany was pressured to allow in chimney sweeps from other EU countries. But low statutory prices made the move unappealing to most foreign firms. In 2013, the new Chimney Sweep Craft Act (Schornsteinfeger-Handwerksgesetz, SchfHwG) came into force, bringing Ger- many in line with EU directives on liberalizing the service sector. Under the new rules, house and apartment owners are authorized to hire licensed free contractors, instead of authorized district sweeps, for measuring, cleaning, and inspection of fireplaces. Further, the traditional allocation of districts to chimney sweeps was changed. Now, chimney sweeps must formally apply to work for a district at the responsible authority (Bauordnungsbehörde). According to § 3 SchfHwG, the chimney sweep register provides an overview of who fulfills the requirements for the independent exercise of chimney sweep work. The master chimney sweep is officially assigned to one district for seven years, typically overseeing 2,000 or more households. After a term of seven years, the master sweep can apply again for the same or any other district. S/he is responsible for carrying out so-called sovereign activities (hoheitliche Tätigkeiten). Only the authorized district chimney sweep may (a) carry out the public inspection of fireplaces (Feuerstättenschau) including the issuance of an inspection certificate (Feuerstättenbescheid) (§ 14 SchfHwG) and (b) maintain a sweep-book (Kehrbuch) with a list of all the fireplaces and their technical specifications in the district (§§ 13, 19 SchfHwG).  Contents ANNEXES 69 How often does a fireplace need to be inspected and what is checked? The public inspection of fireplaces (Feuerstättenschau) should take place at the earliest three, at the latest five years after the last public inspection (§14 SchfHwG). A public inspection comprises a holistic system assessment for certifying oper- ational fireplaces and ensuring fire safety. The public inspection is carried out for all fuel systems (solid, liquid, gaseous) and contains the following tasks inspecting All furnaces in one house (heaters, fireplaces and stoves); All associated smoke and flue pipes, chimneys, and ventilation systems; The distances to components of flammable building materials; The installation room and fuel supply; Additional facilities, such as nonflammable templates in front of firing openings; and Collection of various data for the official register held by the responsible administrative authority (age of the heat-  ing, dust emissions, and so on). In addition, the central government has stipulated further regulations, for example, the Energy Saving Ordinance (EnEV) and the 1st BlmSchV, including these tasks to verify Whether old boilers that had to be decommissioned in accordance with the EnEV were decommissioned; Whether heat distribution and hot water pipes and fittings to be insulated are now insulated; Classification of solid fuel fireplaces regarding decommissioning or retrofitting; and Determining the wood moisture content. The authorized district chimney sweep issues an inspection certificate after completing the holistic public system assess- ment. The inspection certificate informs house and apartment owners about the implementation and schedule of regular sweeping, measuring, and inspection tasks, defined in the Federal Sweeping and Inspection Ordinance (KÜO). The an- nual inspection, sweeping, and measuring tasks (freie Tätigkeit)—different from the overall public inspection carried out only by the authorized district chimney sweep every three to five years—can also be implemented by qualified free con- tractors, following the new SchfHwG of 2013. The KÜO specifies how often chimneys must be cleaned and how modern heating and ventilating systems must be inspected: “Occasionally used fireplaces” only need to be swept once a year.  “More than occasional but not regularly used fireplaces” should be swept twice a year. “Fireplaces used regularly during the usual heating period” should be swept three times a year. What are the responsibilities and costs for house owners? With the new SchfHwG being in force, the responsibility to ensure that required fireplace inspections are carried out on time has been transferred to house owners. House owners can choose between the district chimney sweep and a licensed free contractor for regular tasks specified in the household inspection certificate. If chimney sweep work is carried out by a free contractor, the house or apartment owner must prove to the authorized district chimney sweep that specified tasks have been carried out in a timely manner. For this, the commissioned chimney sweep fills out a compliance form that the house owner forwards to the authorized district chimney sweep to be recorded in the sweep-book (Kehrbuch, a register). In Germany, the costs depend on the respective activities carried out by the chimney sweep. Since 2013, house owners have been free to choose their chimney sweep and thus negotiate their own prices with the chimney sweep for inspection, sweeping, and measuring work. For the so-called sovereign tasks of the authorized district chimney sweep, such as cer- tification of new chimneys and fireplaces, a uniform fee schedule continues to apply. The KÜO, which has been in effect since 2010, allows chimney sweeps to charge “work values” for the public inspection of a stove according to the amount of time spent. 70 INSTITUTIONAL AND FUNCTIONAL REVIEW OF AIR QUALITY MANAGEMENT IN NORTH MACEDONIA  Contents What happens in case of noncompliance? In the event of violation of the legal provisions by house and apartment owners, the authorized district chimney sweep is obliged to report the incident to the responsible administrative authority, the district administration authority (Kreisverwaltungsbehörde). Such incidents include not submitting required forms, not initiating the statutory activities, refusing household inspections, or operating unapproved fireplaces. The house owner receives a reminder by the responsible authority. If noncompliance continues, the authority imposes fines on the house owner, between EUR 5,000 and EUR 50,000. Who controls the work of chimney sweeps? Following § 21 SchHwG, the authorized district chimney sweeps are subject to the supervision of the administrative au- thority. The authorized district chimney sweep must, upon request, provide the administrative authority free of charge with the sweep-book and documents required for keeping the sweep-book. The administrative authority can check district chimney sweeps at any time regarding the performance of tasks assigned to the sweep and compliance with legal obliga- tions. If authorized district chimney sweeps do not or do not properly perform the duties and obligations defined under SchHwG, the administrative authority can issue a written reprimand or impose a warning fee of up to EUR 20,000. What are the main challenges regarding existing control strategies? Although district chimney sweeps are obligated by law to provide administrative authorities with information registered in the sweep-book, some authorities face difficulties in receiving requested information for review. The household infor- mation is of great value for emission inventories, assessment of air quality, and formulation of policies. However, chimney sweeps might be hesitant to insist on compliance with existing regulations to not lose their clients—the house owners. As the chimney sweep’s income depends, at least partly, upon the household’s request to implement so-called free activi- ties—inspection, cleaning, and measuring—the chimney sweep may prioritize to maintain the client relationship instead of implementing stringent standards. What is the role of chimney sweeps in providing advice to households in matters relating to energy efficiency and air pollution? Until now, it has been challenging for administrative authorities in Germany to increase the uptake of energy efficiency measures and renewable energies. Chimney sweeps have a unique knowledge about combustion devices used across the districts and they have direct and regular contact with house and apartment owners. Therefore, they are important in- termediaries to inform a large number of households on energy efficiency measures and options for adopting renewable energies. However, chimney sweeps are less interested in the promotion of energy efficiency and renewables, as ultimate- ly, they would lose clients with the switch of households to other energy options that do not require chimneys or firing devices. A new development is the option for chimney sweeps to qualify as certified energy advisers. Chimney sweeps can advise household and apartment owners on, for example, energy efficiency, sustainable construction of buildings, and renewable energy options.  Contents ANNEXES 71 Institutional and Functional Review of Air Quality Management in North Macedonia