January 01, 1996 | Arabic & English
Policy Paper on the Environment in Lebanon, 1996.

State of the Environment
Environmental laws and regulations
Enviromental Management
Two Alternative Scenarios if the Lebanese Environmental Protection Agency is not Formed
Roles of Environmental NGOs
Financing of Enviromental Projects
Short Term Recommendations
Long Term Recommendations
 
This paper presents policy recommendations regarding environmental issues in Lebanon in an effort to contribute to a national environmental strategy. The paper gives a brief description of the state of the environment, and then addresses four inter-related issues affecting the environment, namely, the current environmental laws and regulations, environmental management, the role of Non-Governmental Organizations (NGOs), and the financing of environmental projects.
 
State of the Environment
The environmental stress in Lebanon is a consequence of the poorly managed urban development in the coastal and mountain areas, war-damaged infrastructure, and land and water degradation. The most intense pressure on natural resources is from urban encroachment in open spaces, agricultural and forest lands in the coastal zone and western foothills of the Mount Lebanon range. Land degradation is also acute on the fragile steeplands, where extensive deforestation and soil erosion have resulted in a degraded vegetative cover and threatened biodiversity. Inadequate provision of basic environmental services such as water supply and sanitation and solid waste management are major causes of health problems and water pollution. The shoreline and coastal waters are seriously affected by pollution, and air pollution is likely to be a major health hazard. Most of the country's rich cultural heritage sites are badly neglected and in urgent need of protection.


Environmental laws and regulations
Regulations and laws cover many aspects of environmental management, but their enforcement is almost non-existent and, sometimes, conflicts and overlaps exist between agencies charged with enforcement of regulations. In addition, environmental laws and regulations in Lebanon are characterized by low levels of regulatory enforcement which is caused by the lack of precision in the law and unclear roles of responsibilities.
The existing laws are in need of urgent updating and should include best-practice guidelines and codes of practice for potentially polluting activities. Enforcement of these laws is still a problem and there is a need for the creation of a new environmental enforcement agency. Proposing regulatory controls and fines should take into consideration the economic strains on environmental polluters and must be designed to provide incentives for pollution prevention and control.
Legislation must be drafted in a very concise way covering all details and should be unambiguously interpreted and enforceable. Setting explicit standards is important to provide industry with clear information as to what they are expected to achieve. Environmental legislation should issue permits to industrial operators defining their operations and emissions. This permit would also place them responsible for remediating any environmentally damaging activities. Legislation could increase the role of municipalities as to enforcement of environmental issues. Municipalities could raise revenues from fines for non-compliance or pollution charges as long as a percentage of those fines can be allocated for pollution prevention, control, and remediation.
There is a need to strengthen the existing enforcement capacity by establishing clear and enforceable standards and emission limits for air, soil and water quality. Environmental laws and regulations must be structured to minimally affect efficiency and productivity of the industry. They also must have properly structured incentives to achieve social goals. The costs generated in their implementation should not be excessive as compared to the benefits they generate.
Each ministry should have its own environmental inspectors which would monitor all environmental activities within their own jurisdiction. The duties and responsibilities of each enforcement agency should be clearly defined so that they complement each other and not overlap.
 
Environmental Management
In Lebanon, the quality of life is being threatened as result of air, soil, and water pollution, destruction of forests, degradation of agricultural lands, and uncontrolled exploitation of natural resources. To reverse this trend and preserve the integrity of the natural resource base of the environment, both for present and future generations, an environmental management team or organization needs to be actively involved in all environmental aspects. This organization should have the capability, both legal and otherwise, to intervene and implement new environmental strategies when the national interest of the country, as described above, is being threatened.
Environmental management hierarchy is complex and inefficient and there is a need for a radical change. The experience gained from examining the role that the Ministry of Environment (MOE) has played since its formation, as well as the role of the Urban Planning Authority and other government agencies is not very encouraging. It is clear that government, with its bureaucracy, inefficiency, and lack of vision cannot deliver what the Lebanese people look up to in managing the environment and the natural resources of the country (land, air, water, and wildlife). The main reason is that there is no continuity in program development, implementation, and management and no master planning. Each ministry has its own agenda, and this situation can have negative consequences on environmental programs that are often long term programs.
The creation of a new autonomous agency that would be in charge of protecting and maintaining the country's natural resources and providing for better physical planning would be an important step toward a better environmental management in Lebanon. This agency will be called the Lebanese Environmental Protection Agency or LEPA. The LEPA will focus its role and responsibilities on planning, organization & control.
In the planning phase, the LEPA will plan master projects for natural resource exploitation for the next 10, 20, & 50 years. The policy of this agency will be geared toward providing a well studied economical and sustainable growth without affecting the environment. The LEPA will also determine the need for future environmental projects, such as deciding on new landfill placements, wastewater expansion projects, etc. The LEPA could also be used to identify mine-quarries in Lebanon where their exploitation would not effect the aesthetics and ecology of the surrounding regions.
The organizational structure of the LEPA should be based on one simple principle: maintain a clear and well coordinated informational flow between the agency and the Ministries. This can be accomplished by continuous monitoring of environmental operations and constant meetings with officials at the ministries.
At the microlevel the LEPA will be managed by a team of highly qualified scientists, engineers, and economists with extensive experience in environmental consultancy and management. The staff of the LEPA will be responsible at a minimum for the following:
Policy formulation; preparation, formulation, and interpretation of regulations; setting minimum environmental standards, rules and regulations for ministries, municipalities, and industry; management of natural resources; management of all environmental remedial activities, which includes recommending remediation action plans to the appropriate ministries for immediate implementations; coordination with all ministries; environmental research and development; managing the environmental monitoring process in the country, including a state-of-the-art laboratory to conduct all necessary environmental tests; environmental impact assessment reviews and approvals of new industrial, urban, and other major real estate development projects; MIS/GIS center operations; reviewing master plans; and public awareness on environmental issues.
The macrolevel organizational structure of the LEPA could be very similar to the organizational structure of the Lebanese Central Bank which has an autonomous structure. The experience gained from the formation of the central bank can be duplicated in the formation of the LEPA. The president of the LEPA could be elected for six years under a decree set by the council of ministers. The President must have proper academic degrees and expertise to fulfill this position. Under his authority is a vice-president, also elected by a decree with the consultation of the President of the LEPA. The LEPA could have a Steering Committee, which would meet at least once a month, and could be composed of the President, Vice-President, General Directors of Ministry of Environment, Municipalities, Agriculture, Hydraulic and Electric Resources (all acting as representative of the government), and a representative of the Council of Development and Reconstruction (CDR).
The LEPA could also have a consulting committee composed of ten members. Six members would be experts in the field of water resources, air pollution, environmental remediation, hazardous pollution, urbanism, and agro-ecology. Two members expert in the field of economics and strategic planning and the last two members could be Lebanese professors in the field of physical planning and natural resources. The role of this committee would be to submit, at the request of the President, technical and economic studies and recommendations related to physical planning and natural resource issues.
An overall administrative reform and reorganization of all ministries would be needed to ensure better coordination with the LEPA and to ensure continuity. Roles and responsibilities of Ministries should be clearly defined so that no overlapping and duplication of work is performed in conjunction with the LEPA. The LEPA will ensure that environmental projects implemented by Ministries conform to the standards set.
 
Two Alternative Scenarios if the LEPA is not Formed
1.Strengthening the role of existing environmental SIUsThe European Community (EC) had and continue to fund the use of European knowledge by bringing in international experts and stationing them in various ministries under a special section called sector implementation unit (SIU). Their role is to help and train various ministries (for example: MOE, Ministry of Hydraulic & Electrical Resources, Ministry of Agriculture, etc..) in their daily operational routine. This role could be expanded by:
  Hiring additional Environmental sius in all other ministries and;
  Consolidating all the sius into one location or increase cooperation and coordination between them.
At this point all SIUs could develop a better strategic environmental plan which then be relayed to each ministry. With additional funding, the SIUs could be slowly phased out by hiring local environmental expert which would then form an advisory council on environmental affairs. This advisory council could then be expanded to form part the Lebanese Environmental Protection Agency.
2. Strengthening the role of existing ministries
Prior to creating the LEPA, existing ministries should undergo administrative reforms:
Ministers should appoint highly qualified staff to give advice, implement, and monitor projects that have impact on the environment. Ministries should coordinate more often with each other through the heads of planning departments in each ministry. In addition, the budget for each Ministry should be increased for the sole purpose of creating an environmental department.
Ministries should strengthen their role in monitoring environmental activities and applying existing environmental laws. More qualified field inspectors should be hired which would allow a higher collection of fines and proper environmental monitoring. Ministries should be equipped with GIS/MIS systems to efficiently manage their department and the current environmental state of the country. This would allow them to track hot spots in the country and follow-up on progress. The GIS/MIS system would serve as an interactive database for issues relating to environmental management.
 
Roles of Environmental NGOs
Environmental NGOs have the potential to play an important role in public awareness and implementation of local projects and programs. NGOs in Lebanon are mainly represented by a large blend of people from all faucets of life and are mainly involved in conservation and public awareness. This blend brings out an active and imaginative participation in all its operations in the areas of concern. The number of Environmental NGOs already established in Lebanon exceeds fifty associations. They have proved the potential to form a nucleus for raising environmental awareness among the community. Their achievements include the establishment of environmental clubs at schools and universities; the rise of environmental concerns as a part of the daily life; the establishment of nature reserves; organized reforestation activities; and other activities related to sustainable development.
The limitations of these NGOs consist of uncoordinated approaches, uneven commitment to participatory planning and program, limited impact and commitment, frequent unwillingness to engage in thematic/sectorial/intersectorial programming exercises, and shortage of financial support.
Nevertheless, some collectives have been established and are attempting to organize themselves by designing a common constitution in order to formulate their policy for action, priority for action, and sustainable coordination between the member NGOs.
In general, most NGOs are involved in environmental education and awareness to draw attention to environmental problems and human health issues. Some NGOs are involved in specific environmental issues such as pollution prevention, waste minimization, reforestation, afforestation and terrace rehabilitation, and establishment and management of protected zones. NGOs activities are usually focused on local issues within their area of influence. Their role in the rehabilitation of the environment is very limited due to the lack of sustainable financial resources, and lack of human and technical resources to support their activities.
The advantage of strengthening NGOs would be to spread their reach to poor communities in remote areas. NGOs usually promote local participation and increase public awareness about environmental issues. Most NGOs members are volunteers and offer to work at no charge on projects related to the environment. Financial assistance to cover part of the wages for full time dedicated members should be considered.
NGOs are well suited in identifying local needs. They rely on existing resources and technologies to solve environmental matters. NGOs should be more involved with their local communities and in particular with their own schools. At that level, NGOs should perform seminars by presenting their agenda and activities to the new generation of students. This involvement may at a later stage increase their membership due to the involvement of students and their parents.
Most NGOs have limited self sustainability. They lack administrative and technical capabilities and planning. There is considerable potential for increasing the involvement of NGOs in environmental management such as environmental monitoring and testing. NGOs can be involved in environmental management on a limited scale such as in areas of non-compliance reporting and breaking of environmental laws. NGOs should be informed of all environmental activities in the country, specially the availability of local and international financial aids and grants. A full time position for a representative of all NGOs at the Ministry of Environment (MOE) or at CDR would be responsible for sending out memos to all NGOs in Lebanon about activities relating to their organizations and other related issues.
NGOs should be equipped with electronic means for better communication and coordination. An Internet system with the E-mail would be the perfect tool. The NGO at the MOE or CDR would have an easy task to reach all of them at the same time. NGOs could use this system to advertise their activities and thus increase their membership. The increase in membership would increase their capability in performing more environmental projects. An NGO newsletter for all NGOs in Lebanon would be important to publish. The NGO newsletter, similar to the Internet system, could be used to solicit funds from private investors and corporations. The NGO newsletter would be distributed to the media and press which in return would give the NGOs a good public exposure and eventual positive feedback on their projects.
A well-publicized NGO hot-line should be in-place. This telephone number(s) will allow its users to ask about information on environmental NGOs in Lebanon. The telephone operators would be trained to direct users' complaints or inquiries to its proper local NGO.
An independent agency should publish a yearly performance book describing all NGOs activities. This book would be called the "green book". The current activities and future goals of the NGOs will also be listed including their accomplishments since their conception. The green book main purpose is to bring more exposure to the NGOs in Lebanon and let donors such as private individuals, corporations, foundations, and international NGOs know who is doing what, and how active and competent they are. The green book will also have a section on how to start an NGO, where to get technical environmental help, and would also list names and addresses of funding sources. The green book will include a special section on new environmental laws and legislation that could affect daily activities of NGOs. The green book can also be a reference for NGOs to know more about government officials. The green book will contain views and voting records of ministers and parliament members on environmental issues. The green book will try to rate government officials on their environmental performance during their term.
 
Financing of Environmental Projects 
The interaction between environment and economic system has become increasingly important as we realize the impact of economic decisions on the sustainability and quality of the ecosystem. Environmental quality deterioration is shown to have adverse effects on human health and well being, resulting in losses in productive efforts. Environmentally sensitive economic sectors such as agriculture, commercial fisheries, and tourism are also adversely impacted. Even when deterioration of the environmental quality does not lead to reduced capacity to produce conventional goods and services, natural system services that are consumed directly, such as recreation and aesthetics are affected.
Sustained economic and social development requires the maintenance of adequate levels of ambient environmental quality. The government can take an active role in managing environmental quality. There is a wide array of policy instruments available for designing an effective environmental policy. These instruments can be broadly categorized as command and control regulations, market oriented economic instruments, in addition to direct government provision of environmental services.
Traditionally, regulatory instruments regulations have formed the basic foundation of environmental protection policy. Command and control regulations represent a system of rules established by the government authorities that could take the form of
1.Outright prohibitions of emissions or activities that are extremely hazardous,
2.Emissions standards in terms of specifying maximum rate of discharge from a pollution source, and
3.Input requirements or technology requirements.
 
Once the standards are set, the polluters' compliance is mandatory and sanctions are used for non-compliance. The use of standards as a policy option to control pollution must be considered carefully since successful implementation requires adequate resources to monitor compliance with standards or to enforce penalties for non-compliance. The policy option undertaken must be one that minimizes the need for explicit monitoring.
In general, the effectiveness of regulatory strategies is a function of the ability of responsible agencies to detect violations, prosecute those who fail to comply, resist interest group pressures to modify regulations; and most importantly, it depends on the compatibility of environmental laws with the prospect of long term economic growth.
Recently, as a result of wider acceptance of the 'Polluter Pays Principle' and an increasing need for raising revenues to finance environmental protection, market oriented instruments have been used. The basic idea behind these instruments is to impose economic costs on conducts that create pollution and reward conducts that encourage less polluting behavior. This approach aims to influence the behavior of the polluter towards choosing activity levels that are environmentally more desirable. The dominance of the private sector in the Lebanese economy makes it possible to use market based instruments for environmental management. Economic instruments include, but are not limited to, charges, subsidies, deposit-refund systems, market creation, and financial responsibility.
There is a substantial range of environmental services that the public sector must provide directly or create incentives for regulated Build Operate Transfer (BOT) or Build Operate Own (BOO) projects. Technically efficient provision of certain services such as water supply, wastewater management, and urban infrastructure that exhibit economies of scale require a single producer. Some environmental services are, to some extent, consumed collectively. The decision to consume is not made by consumers in the marketplace; hence, it is difficult to exclude non-payers from consuming the benefits of the service. Furthermore, some environmental services such as clean drinking water is a 'merit service' and a minimal amount must be provided to all citizens.
A review of the proposed public sector expenditures programs in the Horizon 2000 for Reconstruction and Development document reveals considerable commitment towards direct provision of certain fundamental environmental services. For instance, the capital outlay for wastewater collection and treatment services is estimated at US $720 million with an operations and maintenance costs in the neighborhood of US $72 million/year. The total value of investments in physical infrastructure for water supply, wastewater and solid waste management is approximately US $1,300 million. Solid waste management is being delegated to private sector operation.
The environmental impact of public expenditures programs will be beneficial to the environment. However, financing of environmental programs will impose a considerable cost burden on the people. The Government of Lebanon should intensify its lobbying to obtain grants and aids from the European Union, Arab Funds, and other funding agencies to cover at least part of the capital expenditures associated with environmental projects. Full cost recovery measures for operations, maintenance, and upgrading charges should be implemented on the basis of resource use.
When the government is the producer of a good or service, it must raise funds to finance the project. Alternative financing schemes for governmental projects include but are not limited to taxation, debt finance, user charges, and donations. Government finance often has significant effects on the private choices made by citizens. Taxes can affect the willingness of individuals to produce and invest. User charges affect the levels of consumption of those goods on which they are levied; they also indirectly affect the consumption of substitute and complements to government supplied services. The use of debt finance can affect the market equilibrium rate of interest and the willingness of investors to make private investments.
No single criterion exists by which to evaluate alternative means of government finance. In reality, the system of government finance that emerges is one that makes trade offs among such normative criteria as equity, efficiency, and administrative ease. Efficient taxes are likely to be considered inequitable by many citizens, but equitable taxes might be costly to administer and could entail losses in efficiency.
An evaluation of the existing fiscal policies in Lebanon is needed in order to conduct the development and reconstruction activities in a fashion that preserves the long run productivity of natural systems and that minimizes deterioration in environmental quality. The emerging environmental management policies should, in turn, address the specific environmental problem without imposing major constraints on other economic activities.
Lebanon can learn a great deal from the experiences of other countries in designing effective environmental policies. In general, there is a tendency towards reduced government intervention in the society, both in a financial and regulatory sense. Privatization and deregulation are common phenomena in today's economies. There is also a move away from end-of-pipe pollution abatement and towards preventative measures.
What follows are some short term and long term policy recommendations that could be implemented to partly finance environmental projects.
 
 Short Term Recommendations
1.Intensive lobbying to obtain grants and aids from the European Union, Arab Funds, and other funding agencies
2.Long term loans
3.Incentive for regulated Build Operate Transfer (BOT) projects
4.Environmental tax on tourists and foreign workers
5.Special Bonds issued by the Lebanese Government
6.Fines on local municipalities and industries for non-compliance
7.Disposal charges for wastes
8.Product or raw material charges
9.Tax on gasoline for environmental projects
10.Remove/reduce excise duty on new vehicles with catalytic converters
11.Price incentive for unleaded gasoline
12.Amend price structure for water and energy
13.Set up an environmental fund as a source of environmental protection financing
 
Long Term Recommendations
1.Support for waste minimization
2.Promote recycling and reprocessing
3.Development charges
4.Subsidies/grants to encourage conservation of buildings/land
5.Deposit refund schemes for certain wastes (e.g. batteries, pesticide, containers, etc.)
6.Develop hydroelectric power generation
7.Strategy for increasing the use of cogeneration systems
8.Strategic plan for increasing the use of gas (LNG/LPG) in energy production, industrial applications, and automative
 
At the Micro Level some of the funds can be collected from the following:
1.Fines from landlords not responsible for cleaning up their properties and land
2.Fines from landlords for burning their yard waste
3.Fees from the rental of portable toilets
4.Fees from the rental of dumpsters for construction debris
5.Fines from illegal littering on the street
6.Sale of recycled products at special collection and recycling centers
7.Sale of composting material
 
Each short term and long term recommendation should be studied and conceived into a detailed plan. This plan would then be submitted as a decree to the council of ministers for approval. As an example, if we want to promote an effective and sustainable recycling in Lebanon, a detailed economical study based on a national redemption program between manufacturers and end users should be performed. This program would create at the micro-level a large group of entrepreneurial run recycling centers which would collect recyclable materials at predetermined locations. At the macro-level the program would create an efficient collection system between the recycling centers and industries benefiting from their usage. This study would result in formulating action plans to create a sustainable recycling system throughout the country.