The Regional Environmental Centre for Central Asia

Transcription

1 The Regional Environmental Centre for Central Asia Overview of the possibilities on introduction of payments for ecosystem services, taking into account the economic conditions and environmental protection mechanisms in Uzbekistan Expert on economic assessment A.Kobzev May 2012 Overview of the possibilities on introduction of payments for ecosystem services, taking into account the economic conditions and environmental protection mechanisms in Uzbekistan 1

2 Content 1. Review of existing economic mechanisms in environment management of the RU Economic mechanisms in nature use management Provisions in national documents and regulatory and legal acts (R&LA) to support the implementation of new financial mechanisms for environmental protection The effectiveness of economic instruments for the environmental protection Role of payments for ecosystem services (PES) in improving the efficiency of environmental regulation Summary Possibility for integration of PES mechanism in the economic context of the Republic of Uzbekistan Possibilities of using PES mechanism in the context of land ownership and land use rights Land use management and national documents, including regulatory and legal acts potentially supporting the introduction of PES in land use sector in Uzbekistan Land ownership and land tax Recommendations on types of PES schemes in the field of land use Possibilities of PES introduction in the biodiversity sector Recommendations on types of PES schemes in the field of biodiversity conservation Opportunities for public participation in the development and implementation of PES schemes Summary Potential benefits of PES in Uzbekistan (Summary) Methods of valuation of ecosystem services in the field of biodiversity conservation Brief review of existing evaluation methodologies Most applicable methods of ecosystem services valuation in the RU in respect of PES Summary General conclusions References

3 1. Review of existing economic mechanisms in environment management of the RU In Uzbekistan financial mechanisms in the system of environment protection and natural resources management are introduced gradually, step by step. The ongoing process of market reforms has not been finished yet. The reforms undertaking in the tax policy are aimed to increase in the budget the share of income generated by the system of environmental protection and natural resources use with further allocation of collected money on rational use of nature resources and improvement in environmental protection efficiency. The important task in the nature conservation policy of the country is gradual introduction and improvement of economic mechanisms in nature resources use (the web site of the State Committee for Nature Protection of the RU). 1.1 Economic mechanisms in nature use management In the area of economic management of natural resources use, the following strategic tasks are identified at the national level: the environmental and economic policies shall be incorporated, i.e. effective environmental considerations shall be incorporated in the system of market relations; the efficient use of natural resource shall be given a more higher priority; the restoration and reproduction of nature resources potential shall be ensured across the country; the efforts to increase financial resources or create new sources of fund for environment protection, restoration and reproduction shall be made; the nature resources users shall be ensured with the economic incentives in the rational use of natural resources and environmental protection. The economic instruments for implementing environmental policy objectives are employed extensively in all major countries around the world. Similarly, in Uzbekistan, the application of economic instruments is based on the polluter pays principle, or nature resources user pays principle. The application of the economic mechanisms and the financial incentive instruments provides actual valuation of natural resources and facilitates their effective and targeted use. It shall be noted that, as Uzbekistan has not been yet exercising the practice on payments for ecosystem services, the potential for their implementation is analyzed on the basis of existing data such as policy development documents, strategies for environmental protection and natural resource management and the acting legislation. This study was focused on those sections of the above mentioned data and information that pertain to the issue of the possible introduction of PES mechanisms in Uzbekistan. The main economic mechanisms employed in Uzbekistan in respect of the environmental protection and natural resources use are as follows: payments; taxes; privileges; licenses. Some types of payments are shown below: environmental fees or charges paid by entities/organizations for emissions or discharges of pollutants into water, soil or air; user charges - charges paid to public/utilities services for provision of clean drinking water after treatment and delivery to the consumer, as well as for the treatment of rainwater and sewage and collection and disposal of solid waste; payments for the use of natural resources abstraction of water, use of biological resources, the fee for the extraction of mineral resources and fossil fuel; 3

4 payments for exceeding emissions and discharges of pollutants into water, soil, air; fines for illegal extraction of biological resources, and the violation of the rules of protected natural areas. One of the important mechanisms designed to increase funding for nature conservation and sustainable use of nature resources refers to environment protection funds. PAYMENTS Prior to 1992 Uzbekistan employed economic instruments in environmental regulation that only set limit for the emission, discharge and disposal of pollutants. In addition, limits have been set in respect of use (withdrawal) of natural resources. In 1992 Uzbekistan introduced charges levied on enterprises and organizations for pollution above established limits thus addressing the economic and environmental issues. To improve the efficiency and the use of funds received as a result of these payments the State Committee for Nature Protection (SCNP) established funds for environmental protection within its system at local and national levels. Payments for the full environmental pollution, that is, for all emissions of pollutants and disposal of waste into the environment were introduced in the second phase. These measures were undertaken in compliance with a phased Program on shifting the economy of Uzbekistan to the payment-based system of natural resources use (the Programme was approved by the Cabinet of Ministers by the Resolution No. 11/27-28 dated June 21, 1995) and the Concept Implementation of scientifically justified economic and legal mechanisms of nature use in the Republic of Uzbekistan (adopted by the Resolution No. 11/27-23 dated June 26, 1996). In the Cabinet of Ministers issued several Resolutions including No. 554 dated On forecast of key macroeconomic indicators and the National Budget of the Republic of Uzbekistan for a year 2000 resulted in reallocation of budget received from payments for environmental pollution: 80% of the funds received allocated to the state budget, 20% - to the environmental funds. Here the payments for environmental pollution were classified as taxes. The next stage in the introduction of economic methods in environmental management has been launched on 1 May 2003 when the incentives and economic instruments have been introduced in environmental management based on the Resolution No.199 of the Cabinet of Ministers of the Republic of Uzbekistan issued on May 1, 2003 On improving the system of payments for environmental pollution and waste disposal on the territory of the Republic of Uzbekistan. According to the Resolution, the compensation payments for environmental pollution and waste disposal introduced in the territory of the Republic of Uzbekistan were charged by the bodies of the State Committee for Nature Protection. The collected payments for compensation were accumulated in the environmental funds and used in compliance with the Regulations on environmental funds. Based on the Resolution No.499 of the Cabinet of Ministers of the Republic of Uzbekistan issued on October 25, 2004 On measures regulating payments to non-budgetary funds of the ministries and agencies the fund allocation system was modified. According to the new procedure entered into force since November 2004: 50% of the revenues were allocated to the state budget and the other 50% - to environmental funds. However at present, the payments charged by the bodies of the State Committee for Nature Protection of the Republic of Uzbekistan as compensation for environmental pollution and waste disposal are allocated in the following proportion: 40% by environmental funds and 60% goes to the budget. Fees for non-rational, non- efficient use of natural resources (water, land, forests, minerals, etc.) and for pollution exceeding the set norms were introduced and the charging mechanism for special nature use was improved. TAXES 4

5 Since 1998 Uzbekistan has introduced a new tax system. In accordance with the Tax Code, the applicable payments for nature resources use were reclassified as taxes. Among them were taxes for the use of water resources, land tax and royalty. The proceeds from these taxes are fully allocated to the state budget. Also, the payment for special nature use was introduced. In particular, the revenues collected from the use of flora and fauna resources based on quotas and licenses were allocated to the state budget, while revenues for violations of environmental regulations in respect of the flora and fauna protection including the payments for damage caused were allocated fully to local environmental funds. Exceptions were made for payments charged for the use and production of wildlife - 50 percent of them allocated to the state budget, the other 50 percent - in the environmental funds. The environmental tax was introduced by the Decree of the President of the Republic of Uzbekistan dated September 27, 1996 On measures deepening the tax reforms due to the state budget of the Republic of Uzbekistan for This decree and the Resolution of the Cabinet of Ministers on the annual forecast of macroeconomic indicators and the national budget of Uzbekistan determined sources and allocation of funds received for environmental tax. The environmental taxes were levied on entities in the amount of 1% of the cost of the products and services produced and were allocated to the national budget before January 1, 2001 and since to local budgets. However, the mechanism and the procedure of the proper use of funds in the field of environmental protection and sustainable use of natural resources were not drawn out. In 2006, the environmental tax was abolished. BENEFITS Benefits and privileges play the role of economic incentives in environmental protection. In Uzbekistan, a number of regulatory and legal acts enabling companies and organizations to assist them in conducting and organizing own activities on environmental protection and take action to green their own production processes and activities. One of the incentives for businesses and organizations was a provision that ensured to reduce the tax base by the amount of contributions to the environmental, health and other charitable funds (if these funds are registered as legal entities), enterprises, institutions and organizations of culture, education, health, welfare, physical culture and sports, but not more than 1 percent of taxable income; (the Law of the RU On taxes from enterprises, associations and organizations, Article 12). Another important privilege was the reduction of the tax base of enterprises, associations and organizations by 30% of those costs that have been made to conduct environmental activities, research and development activities, development of new technologies and products. This privilege acted in accordance with the Letter of the State Tax Committee and the Ministry of Finance of the RU, though it was not applied. In addition to the above said incentives, there is a privilege that exempts from compensation payments those entities for which the sum of the fees calculated for the year does not exceed the amount equivalent to 5 minimum wages. Also on the second phase of implementation of financial mechanisms on improving the situation in the field of environmental protection, and to reduce the financial burden on enterprises some temporary reliefs were established. For example, coefficient of 0.1 was set to the rates of fees for utility companies and Tashmetropoliten Metro operating company. The mining and manufacturing industry were given preferential on fees for waste disposal, and the organizations financed from the state budget were completely exempted from these payments. Then, based on the Resolution No. 199 of the Cabinet of Ministers dated May 1, 2003 the previously established benefits for enterprises - pollutants were partially modified and the additional benefits were introduced to reduce their financial burden. Thus, for the utility companies the coefficient of 0.2 to the charged payments was set while the coefficient of 1.2 to the payments for excessive emissions discharges of pollutants and waste disposal was abolished. 5

6 The most significant incentive was the introduction of a multiplicity factor that enabled to reduced the amount of fees by 5-10 times to those companies that reduced emissions, discharges of pollutants and waste disposal against the established standards (limits) and, conversely, if the volume of emissions, discharges of pollutants and waste disposal exceeded the established limits, the amount of fee increased by 10 times. LICENSE In Uzbekistan, hunting and fishing activities are subject to licensing. Exploration and exploitation of mineral resources are licensed as well. There is a unified system of licenses for hunting and fishing. To obtain a license the state and commercial organizations must apply to the State Administration for the Protection and Use of Flora and Fauna () under the State Committee for Nature Protection of the RU. The individuals can receive licenses in the Society of hunters and anglers. The foreign individuals shall apply to the Gosbiocontrol to obtain the licenses for hunting and fishing. To obtain a license for hunting or fishing by foreign nationals must also apply to Gosbiocontrol. This institution administers and regulates the use of biological resources in accordance with the laws and regulations and sets quotas for hunting and fishing based on the recommendation of the Academy of Sciences. In general, the practice over the last years shows that the reform in the economy, politics and governance in the field of environmental protection are interdependent and mutually reinforcing components of a single process. Any economic development is based on three factors - labor, artificially created means of production and natural resources. Recently, the environmental factor has become increasingly limiting the economic development. However, obviously, the next step should be aimed at the developing and implementing the methodologies for evaluation of enlarged economic damage caused by environmental pollution. ENVIRONMENTAL PROTECTION FUNDS In 1993 the environmental funds were introduced in the system of the State Committee for Nature Protection. The Cabinet of Ministers of the Republic of Uzbekistan by its Resolution No. 246 dated May 24, 1993 approved the Regulations on Foundations. One of the mechanisms of accumulation of funds for implementation of environmental tasks is extra-budgetary environmental funds at the national (EBNEF) and local levels (EBLEF). Their statutory documents define the sources of information and the rules for the use/allocation of funds. The working body of the EBNEF and EBLEF are the Board of respective funds, which accounts for people including specialists from the State Committee for Nature Protection, the leading ministries and agencies and scientists. These funds have become the basis for the formation of new financial relationships in the field of environmental protection and natural resources use. In particular, the Funds provide grants on a competitive basis for environmental projects such as implementation of environmental measures/actions, scientific research, drafting new regulatory and legal acts pertaining to environmental protection and natural resources use. Also the Funds provide grants to NGOs for environmental education projects and other important projects in the field of environmental conservation. It shall be noted that the "concentration of funds in the environmental funds provided an opportunity to start the financing of environmental activities, prioritized scientific research and surveys, development of contemporary regulatory and legal acts in the field of environmental protection and natural resources use that previously funded from the national budget (website of the State Committee for Nature Protection of the RU). The revenues accumulated by the environmental funds show the increasing tendency year by year. For example, the local environmental funds collected about UZS 3.67 billion in 2007 thus exceeding by 35.9% compare to that of the previous 2006 year (National report on environmental protection and natural resources use in the Republic of Uzbekistan ( ). 6

7 1.2 Provisions in national documents and regulatory and legal acts (R&LA) to support the implementation of new financial mechanisms for environmental protection The need for the introduction of economic mechanisms to promote a system of environmental protection and sustainable use of natural resources is mentioned in many national papers, including the 2005 National report Environmental situation and utilization of natural resources in the Republic of Uzbekistan prepared by the State Committee for Nature Protection. The report says that the priority actions to improve the situation are the following economic instruments: - tightening of limited responsibilities in some spheres of environmental enforcement to different organizations that are financed from the national budget and the development of competitive markets so that the business entities polluters become sensitive to price changes; - improvement of the existing banking sector and capital market development, providing access to capital for investment in environmental protection and sustainable utilization of natural resources; - creation of a well-developed market for ecological services, opening the possibility for an alternative choice. In particular, the National Report, paragraph 7 of the section 8 Strategic directions for environmental safety, and mechanisms for their implementation expressly states that it is necessary to improve and further introduce economic mechanism regulating the interaction between governmental bodies of various levels and nature resource users and count environmental requirements in the procedure of evaluation the social and economic efficiency of decision making. The authors of the report emphasize that one of the strategic directions ensuring environmental security in the Republic of Uzbekistan is the necessity of further integration of environmental and economic policies, and introduction of environmental parameters in the market system as well as development of economic incentive mechanisms for natural resources users ensuring sustainable utilization of natural resources and environmental protection. Within this strategy it was supposed to create a system of environmental marketing and governmental incentives encouraging those manufacturers whose produced products and provided services resulting in environmental improvement and who implementing measures on greening its production. The same section in the programme mentions on the allocation and accumulation of financial resources for conservation, restoration and reproduction of the environment. The possibility to introduce payments for ecosystem services is also supported by the norms stipulated in the Programme of Actions on Nature Protection of the Republic of Uzbekistan for adopted by the Resolution of the Cabinet of Ministers of the RU No. 469 dated October 20, Section 2 of the Programme of Actions states, inter alia, that the rational use of natural resources is achieved through consistent work on deepening economic reforms, including creation of conditions for more efficient use of natural resources, ensuring their reproduction, protection and sound reduction in consumption. Further it indicates that the natural resources utilization is ensured through improvement of environmental legislation, introduction of economic mechanisms for nature resources use, and etc. The Programme identifies the directions of activity and describes the tasks that will contribute to the development and introduction of economic mechanisms of natural resources management and the polluter pays principle and user pays principle. The introduction of economic instruments in environmental management practice shall encourage nature resources users and result in: improvement of water saving in all sectors of water use; improvement of quality of natural resources ensuring their protection and reproduction; increase the production of ecologically clean agricultural products; reduction of environmental pollution due to industrial and domestic waste. 7

8 The Programme of Actions on Nature Protection identifies the main components aimed at the introduction of economic mechanisms and increasing their effectiveness: improving the system of payments for natural resources, pollution and environmental damage; improving the system of taxation and the system for provision of loans to nature resources users; creating developed capital markets ensuring access to capital for investment in environmental protection; ensuring developed market for environmental products and services thus providing alternative opportunity. In September 2008, the Programme of Actions on Nature Protection of the Republic of Uzbekistan for has been adopted (based on the Resolution No. 212 of the Cabinet of Ministers of the RU dated ). The document states that this program is designed to implement a package of measures for environmental protection and among other objectives it is stated for improvement and further implementation of effective economic methods in environmental management,.... However, the text of the Programme provides no any clarifications regarding the ways and methods of carrying out this task. Though in the Appendix 2 Activities of the Programme of Actions on Nature Protection..., in the second section Natural resources management and implementation of environmental management practices, item 2.1 Implementing the National Strategy and Action Plan of the Republic of Uzbekistan for the conservation of biological diversity there is a sub-item Development of programme on sustainable use of biological resources. Under this program, the introduction of payment mechanisms for ecosystem services may serve as one of the methods to implement it. The responsible institution for the implementation of this activity is the State Committee for Nature Protection, Institute of Zoology of the Academy of Sciences and the Ministry of Agriculture and Water Management. This item allows introducing the developed payment mechanisms for natural biological resources, since financial arrangements serve as effective means in increasing the sustainability under the growth, reproduction and use of biological resources. The concern of the Government of Uzbekistan and the international community about serious environmental problems and the necessity to take measures aimed at improvement of the conditions in the land and water resources management, as well as the implementation of actions to prevent the loss of ecosystems is expressed in the Country Programme Action Plan (UNDP / Government of Uzbekistan). In particular, the Action Plan states that Environmental problems are most acute in areas such as land degradation, water (including groundwater) resources, desertification and loss of ecosystems. In addition, there is a lack of proper management of industrial and domestic waste. These factors make Uzbekistan especially vulnerable." As for the possibilities on introduction of new mechanisms in the system of environmental protection the Country Programme Action Plan states that the assistance shall be provided at the institutional level in integrating biodiversity conservation issues into policies and activities of national institutions, as well as assistance in the promotion of innovative forms of partnerships and approaches to protect nature. In this case, the introduction of the payment mechanism for ecosystem services shall be treated as such innovative partnership mechanism and increasing funding for the needs of nature conservation. A number of provisions supporting the introduction of payment mechanisms for ecosystem services are prescribed in the Law of the RU On Nature Protection. The law On Nature Protection says that promotion of rational utilization of nature resources and nature conservation is one of the important principles that should be followed by the local public authorities, ministries and agencies, enterprises, institutions, organizations, peasant and cooperative farms, as well as individuals in order to achieve the objectives on nature conservation in the process of economic, administrative and other type of activities (Article 4. Achieving the goals of conservation). 8

9 One of the significant principles of the above mentioned law is that the law establishes payment basis for the special use of natural resources while the general use is subject to no payment. The right of the special natural resources use is given to enterprises, institutions, organizations and citizens on the payment basis of special permits for conduction of manufacturing and other activities (Article 6). In accordance with the law, the establishment of maximum size of payment for the use of natural resources, as well as benefits to levy fees is the prerogative of the Legislative Chamber and Senate of Oliy Majlis of the Republic of Uzbekistan (Article 7). At the same time, the Cabinet of Ministers of the RU is a competent body for establishing the payment procedures for the use of natural resources, environmental pollution, waste disposal and other hazards, as well as limits on the use of natural resources, waste disposal (Article 9). Function for charging the payments for the use of natural resources, as well as issuing and revocation of permits for the use of natural resources is the responsibility of local government and local bodies in charge of environmental protection (Article 10). In addition to the above -said, the local authorities are responsible for conduction of control over the environmental protection, making decisions on the suspension, termination and realigning the activity of the local facilities adversely impacting on the environment. The important land use issue is specified in the Law On Nature Protection. It says that the soil is used for natural and cultivated crops without reducing its fertility (Article 17). Moreover, it emphasizes that the humus layer of soil under any structure is subject to removal and transfer to other places to improve soil fertility. The law defines soil as a fertile earth s crust that functioning together with the vegetation cover with the ongoing vital activity. An important notice about biodiversity conservation and cleanliness of water resources, as well as the establishment of contractual relations and payments for ecosystem services is indicated in the Article 19 Conditions for use of water resources and water bodies. It is said that the local authorities, forestry and water management bodies are required to carry out reforestation and afforestation in the areas of river flow formation, coastal strips of water bodies and to provide their security. It shall be noted that the Law On Nature Protection indicated a much larger number of types of financial mechanisms and incentives encouraging nature resources users than currently used. The economic mechanisms of nature protection specified in the Law (Article 33) ensure: fees for special use of natural resources, tax, loan and other benefits provided to enterprises, institutions, organizations and individuals if they implement low-waste and resource-saving technologies or implementing the activities resulting in nature conservation and restoration effect; introduction of a special tax levied on enterprises, institutions and organizations for the use of environmentally hazardous technologies and implementing other environmentally hazardous activities; application of economic sanctions imposed on natural resources users for wasteful and extra use of natural resources and employment of economic incentives for their saving and rational use; responsibilities imposed on enterprises, institutions, organizations and citizens to restore the disturbed condition of a favorable environment; incentive rates and allowances for environmentally friendly products. Also the Law On Nature Protection, Article 33 The economic mechanism to ensure the protection of nature stipulates: licenses (permits) for the right to release, discharge pollutants or perform other environmentally harmful activities; fees levied as compensation in compliance with the set procedure for loss due to damage or destruction of natural objects; 9

10 complete or partial abolishment of bonuses and other rewards provided to officers or other employees based on the results of their basic activity in case of failure to comply with the plans and measures for nature protection, violation of regulatory, technical and other requirements of the legislation in the field of environmental protection; material incentives of teams and employees of the state, cooperative, public and other enterprises, institutions and organizations, as well as individuals who have achieved the highest results in the field of nature protection and in the production of environmentally friendly products. In addition, Article 34 specifies several important issues on potential introduction of PES, namely: the amount of payments for protection and restoration of natural resources are set by the Cabinet of Ministers of the RU; fees for the use of natural resources, their protection and reproduction are allocated in the state budget; payment for the use of natural resources and compensation for environmental pollution does not exempt legal entities and individuals on their obligation to perform environmental measures and to indemnify the damage caused. The latter provision is very important in the context of the possibilities of implementing the ecosystem services in respect of soil remediation and reforestation. 1.3 The effectiveness of economic instruments for the environmental protection Most of the funds derived from taxes for the use of natural resources, environmental charges and fines are allocated in the national budget. According to the first Environmental Performance Review, the level of collection of charges (until recently) remained low and the efficiency of payment systems is limited. However, the situation with the collection of payments in recent years has been improved significantly and the share of fees collected amounted to: 35%; 78.8%; 51.3%; 97.9 % and 100% in 2007, 2008, 2009 and 2010, accordingly. Also the total amount of revenues to environmental funds has been increased (see the Table 1). Table 1. Revenues to the national and local environmental funds (UZS mln) Inflow from sources/year Total , , , ,978.7 Local (excluding immigrant remittances) , , ,549.4 National Source: State Committee for Nature Protection, 2009 According to the first Environmental Performance Review (EPR-1) low efficiency of financial mechanisms for nature protection is associated with a rather small amount of charge imposed for pollution. The amount of payment is not high enough to impact on the interest of enterprises and organizations in implementation of new, more improved technologies. Most often, it is rather profitable to businesses to pay the fines than to invest heavily in upgrading or repair of sewage treatment facilities. In addition to the above said, the cost for monitoring over a large number of pollutants for which payment shall be made, is deemed as very high. Also the Review indicates that, for example, for a period a very small share of investment in environmental protection was planned, i.e. 0.02% of the total investments. The main findings of the EPR-1, with regard to the economic tools are as follows: it is necessary to develop the use of economic instruments for environmental management; 10

11 methods and instruments used by the state in financing the environmental protection activities are weak and insufficient; to a large extent, these problems pertain to the financial constraints in some enterprise causing lack of financing allocated for environmental programs by the enterprises themselves. One of the major findings of the EPR-1 is the fact that the nature restoration and conservation in Uzbekistan requires more resources than are currently allocated. The operation of financial instruments on collection of funds aimed at nature conservation cannot be considered effective as well because all taxes collected for the use of water, land and other resources are allocated in the budget. This is a biggest portion of all payments collected for the use of natural resources. In addition to the above mentioned, payments for environmental pollution are allocated in the national budget and the environmental funds in the proportion: 60 and 40 percent, accordingly. However, after 2006 a significant progress was observed in the issues on strengthening the financial sanctions imposed on companies and organizations due to the reforms implemented in the tax system. For example, if the company increases the pollution by several times compared to the approved standards (limit) on emissions, discharges of pollutants into the environment, then the amount of compensation may be increased to 10- times against the original size (according to the Annex 5, the Resolution No.199 dated June 1, 2003). The positive aspect in strengthening the economic mechanisms for the nature protection is the improvement in the operation of environmental funds. Thus, according to the second Environmental Performance Review, the increase of funds accumulated in the National Environmental Fund allowed to finance the higher portion of activities than planned in the Country Programme for environmental protection and rational use of natural resources for Given these positive aspects, it is supposed to finance up to 16% of environmental activities set in the new Programme for Environmental Protection from the National Fund for Environmental Protection. However, some unresolved issues are remained in the environmental funds employed as the economic instruments for environmental situation improvement. There is no mechanism of decision-making in respect of financing of activities, selection criteria for projects are not clearly defined. Also there is a lack of evaluation of efficiency of spent funds. The issue on greater access of population to information on the activities of funds is also need improvement (EPR-2). Also, the provision exempting organizations fully funded by the state budget from the environmental pollution payment does not contribute to the effective implementation of economic instruments. Businesses and organizations financed exclusively from the state budget, do not pay compensation for environmental pollution and waste disposal in the territory of the Republic of Uzbekistan. At the same time, such entities and organizations shall pay compensation in accordance with the procedure set in the applicable legislation (Annex No.5 to the Resolution No. 199 dated June 1, 2003) in terms of other sources of income. In general, as the nature protection does not take a leading place in the priority list, and then the overall effectiveness of environmental activities is consequently low. There is no any real economic mechanism that may considerably stimulate the natural resources users to more environmentally friendly forms of interaction with nature due to small amount of money collected by the environmental funds. Also it is necessary to recognize that the fines for environmental pollution being the only sanctions for noncompliance of environmental legislation, does not fulfill its role of a constraint factor in preventing repeat violation of the law. This conclusion is supported by the data of annual statistics in terms of fines paid by businesses. The statistics shows that businesses prefer to pay fines year by year making no major changes in their production in order to avoid the violation of the law. As for other legislative measures such as 11

12 suspension or termination of operation, they are usually not applied as the priority of economy prevails over the values of a healthy environment. Despite significant progress and success in the collection and increasing rate of charges for environmental pollution the remaining problem with indexation and revision of fees and rates on regular basis considering the general rise in prices needs to be solved. 1.4 Role of payments for ecosystem services (PES) in improving the efficiency of environmental regulation The introduction of payments for ecosystem services will bring new opportunities to improve the financing of environmental activities. First of all, this approach can be employed in implementation of objectives aimed at rehabilitation of forests and degraded soils, strengthening protection regime for the conservation of flora and fauna, raising incentives for local community in enforcement of regime set for protected natural areas, as well as improvement of insufficient funding in environmental protection and scientific research activities, especially in protected nature areas. The introduction of the practice on the use of environmental charges will contribute in solving a number of important issues including land degradation. Here the main issue shall be the organization of a realistic assessment of damage caused to the environment including the long term assessment. According to the most optimistic estimates based on the statistic data of the State Committee for Nature Protection of the RU, in 2008 saline land (i.e. degraded) covered 50.7% while to other estimates this figure reaches about 60% of the irrigated land in Uzbekistan. Such land degradation is mainly caused by irrational, extensive practice of agriculture. With the increasing number of market services, purchasers and providers of such services the market mechanisms determining the full and adequate value of natural resources will be developed. In particular, the methodology for the setting of environmental payments shall be clarified. Currently, for example, payment for environmental pollution does not count the full cost of restoring the disturbed natural environment. Basically the current pollution charges reflect the financial capacity of enterprises- polluters and include the estimated cost of cleanup. However, in fact, the payments are low and do not cover the costs of environmental protection. The introduction of payments for ecosystem services (ES) shall increase the financing of environmental activities it selves and ensure organization of actions to provide ES which essentially increases the number of environmental measures. Moreover, the earmarked spending of collected funds will be aimed at improving the state of ecosystems, while at present part of the funds derived from fees and taxes is allocated to the budget and another part covers the cost of environmental conservation activities and the costs of administrative structures in charge of environmental protection. The implementation of contractual obligations under the PES will result in creation of one more efficient and working economic mechanism protecting the right for nature existence and the rights of the people to maintain clean environment. The replication of PES instruments shall have a direct impact on saline lands. For example, the adoption of amendment on reducing the payment for land (or privileges) under the condition of that farmer conducts land rehabilitation measures shall contribute to the systematic and massive improvement of saline lands. It shall be noted that simple technologies allowing restoring soil fertility without reducing crop yields and with increase in productivity after a year or two due to improved soil quality, are available and have already been tested, particularly in the framework of the SGP/GEF in Uzbekistan. The other advantage of the PES introduction shall be the availability/occurrence of one more additional institution for financing environmental activity. 12

13 Presently, except to the budget programs, which can not cover the entire spectrum of environmental issues in terms of adequate scope, and funding from international donors, who tend to work only on the pilot areas for demonstration of new technique, the main tools, which eventually should provide greater assistance in addressing environmental problems are remaining the environmental funds. However, they are administered by the state authorities and due to the absence of competitiveness and control from the public side, the efficiency of spending their funds remains an open issue. The PES, in essence, is the market tool, the contractual mechanism that reflects the actual conditions of ecosystems and, in view of these specific features it may serve as an additional and important tool in direct financing of environmental activities. 1.5 Summary One of the important objectives of environmental policy in Uzbekistan is a gradual introduction and improvement of the economic mechanisms of environmental management. The main economic mechanisms used in Uzbekistan in the sphere of environment protection and utilization of natural resources are shown below: payments; taxes; benefits/privileges; licenses. In addition to the above mentioned the environmental funds are also considered as one of the important mechanisms designed to strengthen the financing of activity on nature protection and sustainable use of nature resources. Some basic types of payments pertaining to environmental protection and the utilization of natural resources are listed below: environmental fees or charges paid by entities/organizations for emissions or discharges of pollutants into water, soil or air; user charges - charges paid to public/utilities services for provision of clean drinking water after treatment and delivery to the consumer, as well as for the treatment of rainwater and sewage and collection and disposal of solid waste; payments for the use of natural resources abstraction of water, use of biological resources, the fee for the extraction of mineral resources and fossil fuel; payments for exceeding emissions and discharges of pollutants into water, soil, air; fines for illegal extraction of biological resources and the violation of the rules of protected natural areas. Presently, the payments charged by the bodies of the State Committee for Nature Protection of the Republic of Uzbekistan as compensation for environmental pollution and waste disposal are allocated in the following proportion: 40% to environmental funds and 60% goes to the budget. Since 1998 in Uzbekistan in accordance with the Tax Code, the applicable payments for nature resources use were reclassified as taxes. The proceeds collected from these taxes are fully allocated in the state budget. The environmental tax was levied on legal entities in the amount of 1% of the cost of the products produced; however, the mechanism and the procedure of the proper use of collected funds for earmarked spending in the field of environmental protection were not drawn out. In 2006, the environmental tax was abolished. The most significant incentive and privilege for enterprises environmental polluters was the introduction of a multiplicity factor that enabled to reduced the amount of fees by 5-10 times to those companies that reduced emissions, discharges of pollutants and waste disposal against the established standards (limits) and, conversely, if the volume of emissions, discharges of pollutants and waste disposal exceeded the established limits, the amount of fee increased by 10 times. 13

14 In 1993 the environmental funds were introduced in the system of the State Committee for Nature Protection. These funds have become the basis for the formation of new financial relationships in the field of environmental protection and natural resources use. In particular, the funds provide grants on a competitive basis for environmental projects such as implementation of environmental measures/actions, scientific research, drafting new regulatory and legal acts pertaining to environmental protection and natural resources use. Also the Funds provide grants to NGOs for environmental education projects and other important projects in the field of environmental conservation. In Uzbekistan, the environmental documents including the Law of the RU On Nature Protection, the National Report Environmental situation and utilization of natural resources in the Republic of Uzbekistan, the Programme of Actions on Nature Protection in the Republic of Uzbekistan and others have a number of provisions supporting the introduction of financial instruments in environmental management and environmental protection. However, they provide no direct references to the necessity or possibility to employ the mechanisms of payment for ecosystem services. The term itself has not been used yet. The efficiency of environmental mechanisms is generally low therefore it is necessary to strengthen the methods and instruments used by the state in financing the environmental protection activities. Financing allocated for environmental programs by the enterprises themselves are weak and insufficient; in general, the nature restoration and conservation in Uzbekistan requires more resources than are currently allocated. However, after 2006 a significant progress was observed in the issues on strengthening the financial sanctions imposed on companies and organizations due to the reforms implemented in the tax system. For example, if the company increases the pollution by several times compared to the approved standards (limit) on emissions, discharges of pollutants into the environment, then the amount of compensation may be increased to 10- times against the original size. The positive aspect in strengthening the economic mechanisms for the nature protection is the improvement in the operation of environmental funds. However, some unresolved issues are remained in the environmental funds such as decision-making mechanism in respect of financing of activities; transparency in projects selection criteria, evaluation of efficiency of spent funds and on greater access of population to information on the activities of funds. The provision exempting organizations fully funded by the state budget from the environmental pollution payment does not contribute to the effective implementation of economic instruments. Also it is necessary to recognize that the fines for environmental pollution being the only sanctions for non-compliance of environmental legislation do not fulfill its role of a constraint factor in preventing repeat violation of the law. As for other legislative measures such as suspension or termination of operation, they are usually not applied as the priority of economy prevails over the values of a healthy environment. The introduction of payments for ecosystem services will bring new opportunities to improve the financing of environmental activities. First of all, this approach can be employed in implementation of objectives aimed at rehabilitation of forests and degraded soils, strengthening protection regime for the conservation of flora and fauna, raising incentives for local community in enforcement of regime set for protected natural areas, as well as improvement of insufficient funding in environmental protection and scientific research activities, especially in protected nature areas. The introduction of the practice on the use of environmental charges will lead to earmarked spending of funds on improvement of ecosystem conditions while at present the part of collected proceeds from the payments and taxes is allocated in the budget. 14

15 2. Possibility for integration of PES mechanism in the economic context of the Republic of Uzbekistan 2.1 Possibilities of using PES mechanism in the context of land ownership and land use rights This section describes the basic provisions on the land ownership, land management, land utilization and other issues, given that this information could be used in the preparation of agreements, contracts for the provision of ecosystem services. Details given in the section can help to identify the existing and additional opportunities for the introduction of PES in Uzbekistan and gap identification, unregulated issues or legal requirements that must be taken into account when drawing up contracts and further work. Situation with land resources Effective land management is one of the most pressing and sensitive issues of state regulation in the field of protection and utilization of natural resources in Uzbekistan. This is primarily due to the value of land as the national wealth, which has a basic intrinsic value, as a place of human life. In Uzbekistan, the land resources have a value of a source of agricultural production. Also they are considered as a significant source of tax revenues from all forms of farming and land use. Land is the object of investment and at the same time it serves as one of the major constraint factors of socio-economic development. Preservation, reproduction and sustainable use of agricultural land is the main prerequisite for ensuring sustainable development of agricultural complex in Uzbekistan and serving the basis for agricultural production. Therefore the environmental policy is aimed at carrying out work on rational land use, improvement of irrigated land with regard of its conservation and increasing fertility. Soil fertility directly affects the cost of agricultural production and, in general, the efficiency of agriculture, for both livestock and crop production. At the same time the land in agricultural land use is considered not only as an object of utilization though human activities, but, above all, as the main component of the biosphere. Preserving the fertility of irrigated land, without exaggeration, is a matter of national environmental security as agriculture is the source of livelihood for a major share of the population of Uzbekistan. Due to climatic conditions, the bulk of agricultural production can only be produced on irrigated lands which reserves accounts for 7-10 million ha (the total land suitable for irrigation in Uzbekistan). The intensive land development during the period of led to expansion of irrigated area from 2.8 to 4 million hectares causing full utilization of its own water resources with a negative impact on the state of the Aral Sea. Now the area of irrigated land is about 4.3 million hectares. Also, there is a high risk of secondary salinization due to existing, gradually accumulated and ancient salization coupled with soluble salt accumulated in the upper layers of soil due to very high evaporation caused by the dry climate and scarcity of precipitation. Despite a series of measures aimed at improving the land conditions, there is a tendency in overall deterioration of environmental situation and soil fertility. The following issues are the most typical for irrigated land: increase in the area of saline land; reduction in topsoil and humus in the soil; topsoil compaction of irrigated arable land; deterioration of land conditions and reduction in irrigated area. Saline irrigated land accounting about 55% of the total irrigated land directly affects the cost of produced products. The annual losses of agricultural production are estimated at about US$ 2 billion due to only the impact of soil salinisation. 15

16 2.1.1 Land use management and national documents, including regulatory and legal acts potentially supporting the introduction of PES in land use sector in Uzbekistan A series of decrees and regulations have been adopted in the RU regarding the irrigation land degradation demonstrating the importance of the issue for the RU. Amongst them only the regulatory and legal acts that have been adopted within the last 5 years are the following: Decree of the President of the RU On measures on radical improvement of land reclamation condition (No.DP-3932 dated October 29, 2007), Decree of the President of the RU On organization of fund under the Ministry of Finance of the RU for improvement irrigated land reclamation conditions (No.DP-718 dated October 31, 2007), Decree of the President of the RU On state programme for improvement of reclamation conditions of irrigated land in the period (No. DP-817 dated March 19, 2008). For the implementation of the above outlined important goals the amount of financing allocated for reclamation work accounted for UZS 75 billion in In particular, the funds of the Land Reclamation Programme (and making appropriate amendments to the successor - programme) can be used as pilot payment for ecosystem services on restoration of soil fertility. Uzbekistan has adopted a Land Code of which the most recent amendments were made in In the section of basic principles of the Code, the first item defines that the land legislation is based on the principles of preservation of land resources, improvement of quality of soil, increase soil fertility as the most important natural resource - the basis of life of citizens. Among the other priority principles of the Land Code are identified the following ones: provision of public and other support in the implementation of measures aimed at improvement of the fertility of agricultural land, improvement of reclamation conditions of soil and protection of land; prevention of damage to the earth and the whole environment, ensuring ecological safety; variety of forms of ownership and land use, equity participants of land relations, the protection of their legitimate rights and interests. At the national level the Cabinet of Ministers is responsible for adoption of legal acts regulating land relations in compliance with the Land Code and other legislative acts, and approval of the state programs on improvement of soil fertility, soil management and land protection. The competence of the authorities at the regional level (oblast administration) and the city of Tashkent include such aspects as: provision of legal entities with land for possession, use or lease to meet agricultural and other governmental and public needs; development and implementation of regional programs on improvement of soil fertility, soil management and land protection; state control over the earmarked, rational and efficient use of land resources, enforcement of land protection. According to the provisions of the Land Code, at the rayon level the competence of the rayon government covers the regulation of the following matters: provision of individuals and legal entities with the land plot/withdrawal of land plot up to ten hectare per landowner and land user for possession, use or renting; provision of citizens with rental land for conduction of farming; provision of citizens and legal entities with land from the reserve fund, regardless of the size of the land plot for possession, use or rental; sale of land plot along with of the objects of trade and service to individuals and legal entities for possession; sale of land plot through the auction to individuals for lifetime possession with hereditary succession. 16

17 In addition to the above mentioned, they administer the issues of land tenure and land use with regard to agricultural and forestry enterprises, institutions and organizations in the cases of their establishment, reorganization and liquidation. All land (Land Fund) in Uzbekistan is classified into the following categories: 1) agricultural land - land allocated for agriculture or designated for this purpose. Agricultural lands are divided into irrigated and non-irrigated (rainfed) land, arable land, land occupied by hayfields, pastures, perennial fruit plantations and vineyards; 2) land of settlements (cities, towns and villages) - land located within the boundaries of cities, towns and villages; 3) land of industrial, transportation, communications, defense and other purposes - land allocated to legal entities for these purposes; 4) land - land occupied by protected natural areas, land having the prioritized ecological, scientific, cultural, aesthetic, recreational and health-sanitary significance; 5) the land of historical and cultural significance - lands occupied by the material objects of cultural heritage; 6) land of forest resources fund - land covered and not covered with forest but provided for the needs of forestry; 7) land of water resources fund- land occupied by water bodies, water facilities and the right of way along the banks of water bodies; 8) reserved lands. Amongst the above listed categories of land, land pertaining to categories 1, 4, 6 and 8 can potentially be used for provision of ecosystem services: 1. Agricultural land; 4. Land of environmental, health and recreational purposes; 6. Forest Fund, and 8. Reserves. Inventory of all lands and identification of unused, inefficiently used or inappropriately used land on systematic basis is a part of the functions related to the sector-wised land use management which is fulfilled by the bodies of the land use management agencies based on the decision of the Cabinet of Ministers of the RU, a local public authority or at the request of individuals and legal entities Land ownership and land tax Land ownership All land in Uzbekistan is a property of the state. The land treated as the national wealth is subject to the rational use. It is under the protection of the state and is not subject to purchase/sale, exchange, donation, and pledge except as established by legislation of the Republic of Uzbekistan. In accordance with Article 17 of the Land Code, the legal entities may hold land plot on the right of permanent possession, permanent use, fixed-term (temporary) use, lease and property. Individuals may hold land plot for lifetime possession with hereditary succession right, permanent use, fixed-term (temporary) use, lease and property. As for the provision of ecosystem services, the most appropriate shall be the land provided for lifetime ownership with hereditary succession right and for permanent use as getting tangible outcome resulted from the ecosystem services require the latter to be provided within long-term period. Under the right of the citizens of the RU on the use of land for lifetime inheritable possession, among other purposes of land use is mentioned the operation of peasant farming, joint running of horticulture and viticulture. The fixed-term land use provides the short-term up to three years, and the long-term of land use ranging from three to ten years. Twenty-five year term can be provided to agricultural enterprises, institutions and organizations for using the land plot for distant-pasture cattle breeding. 17

18 Administrations of Rayons (Khokim) and cities are entitled (have a right) in provision of citizens and legal entities with land plot for lease. According to the legislation, agricultural enterprises, institutions and organizations can secure land for the tenants as on-farm lease but only for agricultural production purposes. That is, if a contract for the provision of ecosystem services is supposed to be concluded, then in addition to rehabilitative and other works on improvement of land and water resources conditions, there must be ensured conduction of agricultural works. The sub-leasing of the land plot or part of it is prohibited, except as provided by the law. The law also states that land designated for agricultural purposes may be leased for up to fifty years, but no less than thirty years. This provision envisages the long-term planning of tenant s activity and aimed at reservation of land fertility. All legal entities and individuals having the land plot in possession, use and ownership shall make payment for the land. Fee for the land is charged in the form of an annual land tax. The rate of the land tax depends on the quality, location and water availability of the land plot. In case of allocation of land plot for lease the charge shall be levied in the form of land rent. The land rent is equivalent to the land tax. The issues on provision (sale) of land into possession, use, rent and ownership are considered at special Commissions established under the Cabinet of Ministers of the Republic of Uzbekistan and public authorities at local levels. The Commissions include representatives of the following bodies: Land Resources and State Cadastre (Secretary of the Commission), agriculture and water management, environmental protection, architecture and building, geology and mineral resources, state property management, sanitaryepidemiological service, bodies of local self-governance and others. The legislation of the RU contains a provision on the priority (first) duty of land holder, land user, tenant and owner of the land. It says that they shall be responsible for rational use of land in accordance with the designated purpose; improvement of soil fertility, application of environmentally friendly technologies, prevention of worsening in environmental situation due to their economic activities (Article 40 of the Land Code of the RU). In accordance with the laws, the land of agricultural purposes may be provided to: 1) agricultural cooperatives (shirkats), other agricultural enterprises, institutions and organizations for conducting commodity agricultural production; 2) research and development organizations and other agricultural agencies and organizations, including experimental-productive, training, educational-experimental and training-productive farms - for research and educational purposes, operation of commodity agricultural production and best practices promotion; 3) citizens of the Republic of Uzbekistan - for farming; 4) citizens of the Republic of Uzbekistan - for operation of household farming, individual gardening, horticulture and animal husbandry; 5) citizens of the Republic of Uzbekistan - for joint gardening, horticulture and viticulture; 6) non-agricultural enterprises, institutions and organizations - for operation of a subsidiary agriculture. Agricultural land for other purposes, are usually provided for temporary use under the provision that the user of land shall subsequently after the completion of its term to bring the land into a condition suitable for agricultural purpose. The Land Code prescribes duties to holders, users and tenants utilizing land of agricultural purpose: 1) action plan aimed at improvement of soil fertility and sustainable land use shall be ensured by the business plan; 2) introduction of scientifically justified crop rotations and the most efficient and economically rational cropping pattern in compliance with zonal conditions and line of farm production; 18

19 3) running of agricultural production with employment of methods preventing salinization and waterlogging of irrigated land, pollution and contamination of land and water sources. Agricultural land is also provided to agricultural cooperatives (shirkats) consolidating individual members - the owners of property shares, directly involved in the production activities of cooperative, based primarily on the family (joint) contract. Also, the land is provided to farmers who are independent economic agents with the rights of legal entity, that running commodity agricultural production with the employment of land plots provided for rent. As for land of protected natural areas, they may be provided to legal entities and individuals for environmental purposes. Any activity inconsistent with designated purposes is prohibited in these lands. This type of land includes land of state reserves; complex (landscape) reserves; natural parks; national nature monuments; sites for preservation, reproduction and restoration of some natural objects and complexes; protected landscapes; areas for management of some particular natural resources and the land of state of biosphere reserves. Land of Forest fund may be provided to agricultural enterprises, institutions and organizations on a lease basis for temporary use to run agriculture. The decision to grant such lands shall be made by Khokim (Governor) of rayon in coordination with the state bodies of forestry. The law states that in order to ensure the protection of land, landowners, land users and tenants shall carry out measures on restoration and improvement of soil fertility, as well as other properties of land and measures on protection of land from various forms of degradation. The separate article in the Land Code (Article 82) spells out economic incentives encouraging rational (sustainable) use and protection of land. The economic incentives of sustainable land use and protection of land are aimed at raising the interest of land holders, land users and tenants in the preservation and reproduction of soil fertility, protection of land against adverse impact caused by industrial activity. The incentives include: provision of benefits in terms of land tax on newly developed land and the land of existing irrigation under the process of reclamation, as per the procedure specified by the law; provision of tax, credit and other benefits to legal entities and individuals who carrying out activities on protection and restoration of land through implementing low-waste and resource-saving technologies; benefits for improvement of land quality, implementation of scientifically justified crop rotation, improvement of soil fertility in land of agricultural and forestry purposes and for production of environmentally friendly (clean) products; allocation, if necessary, funds from the state or local budget for the restoration of lands disturbed by no fault of the land holders, land users and tenants; implementation of cultural control, forest ameliorative and other soil conservative measures; payment of partial compensation from the state budget for the loss in income resulted from the temporary abandonment of land plots disturbed by no fault of the land holders, land users and tenants. Land tax Different rates and factors such as soil class quality (bonitet), coefficient of city remoteness and etc are taken into account in calculating tax on agricultural land in Uzbekistan. In accordance with the Annex No. 19 to the Decree of the President of the RU No. DP-1675 dated December 30, 2011, new land tax rates imposed on legal entities and individuals have been introduced since The rate of land tax levied on agricultural land varies depending on the category of land (the base rate per 1 ha for land of class 1, in UZS): 19

20 1. irrigated public agricultural lands (from UZS 5,436 to 17,873); 2. rainfed land, fallow and perennial plantings; this class encompasses three zones: 2.1 flat zone (no precipitation available); 2.2 piedmont zone (precipitation half available) and 2.3 foothill and mountain zone (precipitation available); for these zones the land tax rates per 1 ha vary by region from UZS 926 to 2,191; 3. non-irrigated hay lands and pastures are considered by region they pertain to and depending on the altitudinal zones are divided into three zones: chul, adyr and tau; the land tax rate ranges from UZS 154 to 447 per 1 ha; 4. other lands that are not used in the agricultural and forestry production. Note: the exchange state rate as of March 2012: 1 US$= UZS 1,835. Irrigated agricultural land in Uzbekistan can be divided into 10 classes depending on their quality, as measured based on soil quality scale (bonitet scale ranging from 0 to 100, increasing from poor to very fertile). Correction factors to the basic rates of land tax charged for irrigated public farmland Class of land I II III IV V VI VII VIII IX X Soil quality by bonitet (score) Factor (Basic rate) Nonestimated land Increase in taxes levied on agricultural land due to improved quality of land and increased soil quality score may serve as one of the economic arguments supporting the introduction of PES in Uzbekistan. As can be seen from the table above, with increasing the class of agricultural land, for example, from 3 rd to the 7 th, and adequately soil quality score by points, the coefficient that increasing the basic rate of the land tax is equal to Accordingly, if the contract for the provision of ecosystem services on improvement of the fertility class of the land is concluded, then the cost of payment for ecosystem services may be within the amount equivalent to 5 folds rate of the tax on land. In this case, the government will benefit in getting the land which soil fertility increased as minimum by two times and income growth due to land tax is increase by 1.75 times. This is an optimistic scenario, though such opportunity exists and needs to be employed Recommendations on types of PES schemes in the field of land use 1. PES mechanism: Public-private scheme of payment Location: the RU, lands of farming enterprises and dekhans farms; Problem: soil fertility decrease; Provided ecosystem service: measures aimed at improvement of soil fertility (implementation of crop rotation, cultivation of Lucerne and other crops); Potential buyers: the state through a National program on improvement of use of the land fund, conservation, improvement and restoration of soil fertility for ; Program on improvement of land reclamation conditions of for land or program-successor; Potential sellers: farming enterprises and dekhans farms; Possible intermediate organization: ecological NGOs, Water Users Association; 20