Bergen op Zoom, 2 maart 2005
Aan de Besturen van Kamers
van Koophandel van
Zeeland, West- en Midden Brabant,
Rotterdam, Rivierenland
en Centraal Gelderland
Geachte Besturen,
Bij vier waterschappen ben ik bestuurlijk actief, waarvan drie ten behoeve van de categorie bedrijfsgebouwd, o.a. in het werkgebied van Uw Kamer.
Op dit moment is waterschappelijk Nederland bezig met (de voorbereiding van) de implementatie van de Europese Kaderrichtlijn Water (KRW).
De KRW blijkt steeds meer een doos van Pandora. Tot nu toe is de ervaring dat het (regionale) bedrijfsleven zich onvoldoende bewust is van de ernstige (financiële) bedreigingen die de KRW in zich draagt.
Ook is de inbreng van het bedrijfsleven tot op heden minimaal in het (deels landelijke) overlegcircuit inzake de implementatie (het bedrijfsleven is niet vertegenwoordigd),
terwijl op zeer korte termijn een deel van de Nederlandse wetgeving tot stand aan het komen is.
Om enige aanzet te geven omtrent de ernst van de situatie een paar feiten:
– Uit de ambitienota van het Kabinet blijkt dat zij rekening houdt met een verdubbeling (in euro’s van nu) van de zuiveringslasten (waterkwaliteitsheffing) tot 2015.
– Het CPB heeft in een quick scan aangegeven zelfs niet in ruwe termen iets te kunnen zeggen over de kosten van de KRW.
– Uit de in omloop zijnde stukken blijkt tot op heden dat er geen economische effect analyse wordt/is gemaakt.
Een economische effect analyse is buitengewoon belangrijk omdat de economische effecten de enige legale route is om te komen tot fasering van de maatregelen (derogatie).
Wat ronduit verontrustend is, is het gegeven dat het bedrijfsleven ontbreekt in het landelijk bestuurlijk overleg (LBOW), waarin betrokken zijn V&W, UvW, IPO en VNG.
Binnen de waterschappen gaat men er van uit dat de meeste verplichtingen, voortkomend uit de KRW, inspanningsverplichtingen zijn. Ondergetekende vreest dat men zich daarin vergist.
Nederland kent ten aanzien van (mede)overheden een gedoogcultuur. Europa kent een naar- de-letter-van-de-Wet handhavingscultuur. Nederland is recent reeds door de EC gedaagd voor het Europese Hof van Justitie wegens het niet (tijdig) omzetten van de KRW in wetgeving.
Gezien de aard van de KRW en de scherpe eisen zou het kunnen zijn dat de overheden wederom kiezen voor de voor hen makkelijkste weg: eisen stellen aan de puntemissies in plaats van bijvoorbeeld de diffuse bronnen. Kortom, zowel uit kostenoogpunt en bedrijfsvoeringmogelijkheden is vooral het industriële vestigingsklimaat hier bedreigd.
Kamers en benoemende organisaties zouden alles in het werk moeten stellen om bij het overleg over de implementatie van de KRW, zowel op landelijk als regionaal niveau, betrokken te worden. Hier zal, buiten oog voor de financiële zaken, ook een technische inbreng van belang zijn. Nu reeds is het belangrijk dat de Kamers in een stroomgebied (Schelde, Maas, Rijn, Eems) gezamenlijk optrekken. Dit betekent voor de Kamers in mijn waterschappelijk werkgebied:
– Zeeland en West-Brabant in het stroomgebied van de Schelde
– o.a. West en Midden-Brabant en Rotterdam in het stroomgebied van de Maas
– o.a. Rotterdam, Rivierenland en Centraal Gelderland in het stroomgebied van de Rijn
Samenwerking om te komen tot deelname in de stroomgebiedoverleggen is noodzakelijk, zodat vooral de economische effect rapportage in de stroomgebiedsplannen worden betrokken en mede overwogen.
Gaarne tot nadere informatie bereid,
hoogachtend,
L.H. van der Kallen
o.a. lid AV Waterschap Zeeuwse Eilanden
lid AV Waterschap Rivierenland
lid AV Waterschap Brabantse Delta
Muchas gracias. ?Como puedo iniciar sesion?
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