Analysis of the «Methods of developing standards for permissible discharges of substances and microorganisms into water bodies for water users» against the background of the water protection legislation
(for discussion)

Summary

The analysis of the current edition of the «Methods of developing standards for permissible discharges of substances and microorganisms into water bodies for water users», approved by the Order of the Ministry of Natural Resources of Russia dated December 17, 2007 No. 333 for consilience and compliance with the regulations of the water protection legislation, is carried out. Uncertainty of the application of the Methods in the conditions of the impact of natural and anthropogenic factors that are independent of a specific water user on the quality of water has been identified. The provisions of the Methods contradict the principles of regulating the impact on water bodies based on the best available technologies shown on the examples of approved process indicators of the concentrations of various industrial pollutants in wastewater. An analysis of the system of regulating the permissible impact on water bodies and the geographical differentiation of water quality standards within the boundaries of the Russian Federation, together with the system of water quality targets, also showed that the Methods do not comply with the basic principles of the water protection legislation.

Key words

water quality , best available techniques , water object , permissible discharge norm , regulatory standard of the permissible impact