NVOS is one or more objects with a single purpose, technologically and physically connected to each other and located on one or more land plots. If there is a harmful effect on the environment, such production is put on state records. To do this, find out the procedure for filing an application and obtaining a certificate, which objects need to be registered, and for which it is not necessary.
Please read the application form carefully. An example of filling out a document is highlighted in blue.
Enter your data by analogy with it. Pay attention to the yellow marker in the form.
To view the pictures in full size, click on them with the mouse:
Application for setting up an object, page 1
Application for setting up an object, page 2
Application for setting up an object, page 3
If you want to figure out how to correctly fill out an application for state registration of an object providing NVOS, read this instruction. The document is created through the User Module so that in the future it will be possible to send it to Rosprirodnadzor.
To view the pictures, click on the first image with the mouse and scroll either with its help or with the index arrows on the keyboard:
Registration of objects of NVOS, page 1 Registration of objects of NVOS, page 2 Registration of objects of NVOS, page 3 Registration of objects of NVOS, page 4
Registration of objects of NVOS, page 5 Registration of objects of NVOS, page 6 Registration of objects of NVOS, page 7 Registration of objects of NVOS, page 8
Business entities are required to submit an application for state registration of an object that has a negative impact on nature.
According to the degree of detrimental impact on the environment and human health, objects are divided into categories from I to IV.
Class I has the least impact on nature, and class IV is the most dangerous. The classification was approved by Government Decree No. 1029 dated September 29, 2015.
If the object does not fall under any of these categories, then such productions are not put on state records.
In which register the object will be entered - federal or regional, the head of the enterprise decides, following the Government Decree No. 903 of 08.25.2015.
If an enterprise has several characteristics according to NIS, then it is evaluated according to the most significant factor.
According to the assigned category, the following criteria are determined:
After the NVOS object is put on the state register, a schedule of state inspections of enterprises is established.
The frequency of visits varies depending on the risk category defined for the facility:
As for state supervision enterprises, which are classified as insignificant risk, no inspections are carried out here.
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All enterprises in Russia, one way or another affecting the environment, must put them on the state register of objects that have a negative impact on the environment.
This must be done in pursuance of the Decree “On Amendments to the Federal Law “On Environmental Protection” No. 219-FZ” dated July 21, 2014. The Decree set a two-year period for implementation.
However, during this period, many questions and problems arose. The algorithm for submitting applications was unclear and it is not clear whether this is necessary at all. Therefore, the Government issued several clarifications and additions.
Registration of NVOS objects does not imply this in relation to the individual entrepreneurs or legal entities, but only the objects they operate.
The very fact of the existence of production that negatively affects nature obliges the user of natural resources to solve the problem of registering objects that provide NVOS for state registration.
Responsibilities for maintaining the state federal list of objects providing NVOS are assigned to Rosprirodnadzor.
Such objects are subject to ecological state control and submit applications to the federal territorial bodies of Rosprirodnadzor.
Users of nature that do not harm nature (offices and shops) are subject to regional environmental control. Applications for registration are sent to the executive authorities of the constituent entities of the Russian Federation.
An application for registration of facilities that provide NVOS for state registration must be submitted within six months from the date of putting the production facility into operation.
The body responsible for the registration of objects considers applications no later than 10 days after their receipt. After that, he issues the appropriate document-certificate.
Send an application for the statement of the NVOS object for state registration of objects in in electronic format or personally. It is possible to send documents by registered mail by mail with a list of sent papers.
Users of natural resources are obliged to report in a timely manner about changes in the work or the name of the objects that provide NWOS. This is done to update the available data.
Information is submitted no later than 30 days after the state registration of the changes.
Article 8.46 of the Code of Administrative Offenses establishes a fine in the amount of 30,000-100,000 rubles for failure to complete the task of registering objects that provide NVOS for state registration.
In fact, the punishment occurs for not submitting the application on time.
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An entity does not have an adverse impact if it:
NVOS objects are registered at the location where applications are submitted.
Objects under construction are not registered. This is done only after commissioning. Entering false data is punishable by a fine.
If minor random errors were made, then it is possible to correct them. Documents should be checked carefully before sending.
When registering NVOS objects with Rosprirodnadzor, you can use one of three options:
To work in the online office, you need:
The nature user module is available to absolutely everyone in widespread software that is easy to download from the Rosprirodnadzor website http://rpn.gov.ru/otchetnost.
You can use third-party software if you use the open XML format, which is located at http://rpn.gov.ru/node/27639. The file is called "Companies with a corporate environmental accounting system."
All legal entities, individual entrepreneurs conducting economic activities, starting from January 1, 2015, within 2 years are required to put on state accounting objects in property that have a negative impact on the environment. A special form of application for state registration of objects of NVOS has been developed. Regulatory Law - Clause 3, Article 11, No. 219-FZ of July 21, 2014
Thus, if an enterprise contains potentially dangerous objects, then by January 1, 2017 they need to.
Failure to fulfill or untimely fulfillment of the obligation to file an application for state registration of objects of NVOS is classified as an administrative offense (Administrative Code of the Russian Federation, Article 8.46). The amount of the fine:
The specialists of EcoPromCentre figured out and practically worked out the process of registration. Let's just say it wasn't easy! But all the difficulties have been overcome and now we have received the first Registration Certificates for our clients!
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(In accordance with paragraph 1, article 4.2, FZ-7)
The procedure for state registration is established by the “Law on Environmental Protection” dated July 21, 2014 No. 219-FZ. published Rules for creating and maintaining state register objects that have a negative impact on the environment. We present the document in full (source - State Information Portal):
An application form has been established for objects that have had a negative impact on state registration by law No. 554-FZ of December 23, 2013 (http://publication.pravo.gov.ru/Document/View/0001201). This document enters into force immediately after approval the procedure for creating and maintaining the state register of objects providing NVOS. http://regulation.gov.ru/projects#npa=20507
State registration of objects that have a negative impact on the environment– is a mandatory procedure in order to comply with the requirements of legislation in the field of environmental protection. abbreviated this operation called - staging on the state. accounting of NVOS objects.
"An object that has a negative impact on the environment- an object capital construction and / or another object, as well as their combination, united by a single purpose and / or inextricably linked physically or technologically and located within one or more land plots"(v.1, federal law dated 10.01.2002 N 7-FZ)
In accordance with paragraph 1, Art. 4.2 of the Federal Law of 10.01.2002 N 7-FZ "On Environmental Protection", objects that have a negative impact on the environment, depending on the level of such impact, are divided into four categories:
The criteria on the basis of which the objects that provide NEOS are classified as objects of categories I, II, III and IV are approved by Decree of the Government of the Russian Federation of September 28, 2015 N 1029.
State registration of objects that have a negative impact on the environment must be carried out by all legal entities and individual entrepreneurs conducting economic and/or other activities.
Registration is carried out by filling out an Application for state registration of objects that have a negative impact on the environment (hereinafter referred to as the Application).
Application form approved by Order of the Ministry of Natural Resources of Russia dated December 23, 2015 N 554 (as amended on September 27, 2016) "On approval of the application form for placing objects that have a negative impact on the environment on state records, containing information for entering into the state register of objects that have a negative impact on the environment, including in the form of electronic documents signed with an enhanced qualified electronic signature".
An application for registration is submitted to the authorized federal agency executive authority or executive authority of the constituent entity of the Russian Federation. Having previously determined to which supervision the object belongs.
If the object does not meet the criteria established by the Decree Government of the Russian Federation dated August 28, 2015 N 903 "On approval of criteria for determining objects subject to federal state environmental supervision", means this object belongs to regional environmental supervision.
An application for registration is submitted by legal entities and / or individual entrepreneurs after the commissioning of facilities providing NVOS, this must be done within 6 months.
Do not forget that information about objects that have a negative impact on the environment, subject to updating in connection with the submission by legal entities and individual entrepreneurs of information:
Updating information must be completed on time no later than thirty days from the date of state registration of such changes. After filing up-to-date information the category of an object that has a negative impact on the environment can be changed.
To apply, you must prepare the following documents:
draw your attention to to the fact that most refusals to register are due to incorrectly determined coordinates (objects, stationary sources, releases into water bodies, ODP). To accurately determine the coordinates you can use one of the following resources: Public cadastral map, Yandex map, Google Maps.
An application can be made and submitted in several ways:
Regardless of the method, when uploading to the Personal Account The application is assigned a unique number.
When submitting an Application on paper, it is necessary to issue a cover letter in accordance with the order of Rosprirodnadzor dated November 24, 2016 No. 756 "On the implementation of the Government Decree Russian Federation dated June 23, 2016 No. 572".
Do not forget that failure to submit or untimely submission of an Application for registration or updating data about an object, entails the imposition administrative fine on officials in the amount 5-20 thousand rubles; for legal entities - 30-100 thousand rubles(CAO Art. 8.46).
1. Who does not need to apply for registration of an NVOS object?
According to the existing legislation, the formation and accumulation of waste are not the criteria for classifying an object as one of the four categories of NVOS, and directly in the application for the registration of an NVOS object, only information on the placement of waste at the NVOS object is provided. In this regard, a group of organizations has emerged that generally you do not need to submit this application.. For this 2 conditions must be met simultaneously:
Such enterprises may include: separate offices, schools, kindergartens, shops, etc., such organizations are not counted as objects of NVOS. (Article 69 of Law No. 7 FZ.).
2. The question of setting the state. accounting as objects of NVOS objects under construction.
Entry in the register of objects under construction and objects not put into operation, not provided. (letter of Rosprirodnadzor dated October 31, 2016 No. AS-09-00-36/22354).
It would not be superfluous to recall that during the construction of facilities it is necessary comply with environmental requirements, including obtaining permits in the field of waste management (develop waste passports, develop PNOLR and obtain limits or submit reports to SMSP) and in the field of air emissions (develop a draft MPE and obtain an emission permit), as well as the fulfillment of the project documentation environmental protection measures (letter of the Ministry of Natural Resources of Russia dated October 28, 2016 No. 12-50/8692-OG).
For all questions, including if you need help or want order registration of NVOS objects write to us - our Contacts.
From the activities of each organization, regardless of the size, production and consumption wastes are generated. In law for each waste, waste passports must be developed and agreed upon, and the enterprise must also develop PNOOLR, or annually submit reports to the SMSP (reporting on waste for small and medium-sized businesses).
Many organizations require develop a draft MAP and obtain permission to release pollutants into the air. To understand if you need it, go to the page
Now we have entered the hottest time for environmentalists - the reporting campaign is on the nose. And right now, when environmentalists are already up to their necks in business, it turns out that there is another matter of the highest importance, which we hoped to postpone, but our hopes did not come true - the setting of facilities that have a negative impact on the environment (hereinafter - NEOS) , for state registration.
We all waited and hoped that the registration deadlines would be postponed, because. according to the requirements of the legislation, setting can only be carried out using the state information system(hereinafter - GIS), and this very system did not exist until the end of November. Amendments were being prepared to postpone the deadlines for registering objects that provide NVOS for registration in the form of a concise draft Federal Law:
Part 3 of Article 11 of Federal Law No. 219‑FZ of July 21, 2014 “On Amendments to the Federal Law “On Environmental Protection” and Certain Legislative Acts of the Russian Federation”[…]the words "within two years" shall be replaced by the words "within three years".
The deadline for setting was coming to an end, and the draft law was still “hanging” at the stage “ public discussions with regard to the text of the draft normative legal act and independent anti-corruption expertise”. The only anchor keeping businesses from panic was the absence of GIS as a registration tool.
At the same time, the movement to fill out applications and attempts to register has been made by individual enthusiasts among nature users since September. However, the territorial bodies of Rosprirodnadzor and executive authorities in many constituent entities of the Russian Federation refused to accept applications sent in various ways - in paper form, through the Nature User Module, etc.
At the same time, we learned about the start of the work of the GIS a week earlier, when the Order of Rosprirodnadzor dated November 24, 2016 No. 756 “On the execution of the Decree of the Government of the Russian Federation dated June 23, 2016 No. 572” was issued (together with methodological recommendations on filling out the application form for placing an object that has a negative impact on the environment for state registration, approved by Order of the Ministry of Natural Resources of Russia dated December 23, 2015 No. 554, using software and hardware for accounting for these objects) (hereinafter - Order No. 756).
So, registration is done in the following order:
1. The applicant submits an application for registration of an object providing NEOS using the Nature User Module or the Nature User's Personal Account.
2. If the applicant has an electronic signature (hereinafter - ES), he uploads the application in XML format, signs it with an ES and sends it through the web portal for receiving reports to the territorial body of Rosprirodnadzor or the executive authority of the subject of the Russian Federation at the location of the object. The application is assigned a unique number and date of submission (download).
3. If there is no ES, the application filled in the Nature User Module is downloaded in XML format and sent there. The applicant prints out the application with a unique number and sends it with cover letter to the territorial body of Rosprirodnadzor or the executive authority of the constituent entity of the Russian Federation by mail or personally. In this case, the date of receipt of the application is the date of its submission to the body.
4. An employee of the department of Rosprirodnadzor or an executive authority of a constituent entity of the Russian Federation checks the application and sends the applicant a certificate of registration of the facility providing NVOS, electronic through the web portal for receiving reports or the Personal Account (or notification of refusal to register).
An instruction on registration has appeared on the website of Rosprirodnadzor, which provides for filing an application through the Subsoil User Module with (without) an ES at the enterprise, through the Personal Account of a nature user with an ES (in this case, it is necessary to register in the Unified Identification and Authentication System and confirm the account in several ways, including EP). The instruction tells in detail about registering on the portal, filling out and sending an application, and receiving the result.
On November 25, Rosprirodnadzor employees received a letter No. 176-08-04-41 / 24183 “On the commissioning of GIS”, which reminded that the records are kept by employees of Rosprirodnadzor and executive authorities of the constituent entity of the Russian Federation (federal and regional environmental supervision). For regional supervision, it is necessary to appoint responsible employees of the executive authorities, provide them with access to the GIS and instruct them in the use of the GIS. The letter separately emphasized that the deadline for registering objects is 12/31/2016.
At first glance, everything is clear. We install the Nature User Module or register in the Personal Account, send an application and receive a certificate. However, when filling out the application, questions immediately arose: is it necessary to enter into the application data on the solid municipal waste landfill (hereinafter referred to as MSW), where the waste of the enterprise is buried under the contract? How to enter data on objects located in different regions of the Russian Federation, but belonging to the same legal entity?
As a result, Rosprirodnadzor, swamped with questions, expectedly began to answer them in its favorite format - explanatory letters.
The most informative is Letter No. AS-09-00-36/22354 dated October 31, 2016 “On Maintaining the State Register of Objects that Have a Negative Impact on the Environment” (hereinafter referred to as Letter No. AS-09-00-36/22354).
Objects under construction and the need to register them. According to letter No. AC-09-00-36/22354, there is no such need, because according to the law, only those objects that have already been put into operation are put on record, and they must be registered no later than within 6 months after the start of operation.
Registration of objects located on the territory of several subjects. The answer to this question was given in paragraph 19 of the Rules for the creation and maintenance of the state register of objects that have a negative impact on the environment, approved by Decree of the Government of the Russian Federation of June 23, 2016 No. 572 (hereinafter referred to as the Rules for Maintaining the Register). The object is registered at the location, and the application is submitted to the appropriate territorial authority.
Assigning an object toIIIorIVcategories. If according to the criteria for classifying objects that have a negative impact on the environment as objects of categories I, II, III and IV, approved by Decree of the Government of the Russian Federation of September 28, 2015 No. about the scope and volumes economic activity carried out at the facility, then for categories III and IV the criteria are not so unambiguous:
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from Criteria
III. Criteria for classifying objects that have an insignificant negative impact on the environment as category III objects
4. Operation of research nuclear installations of zero power, radiation sources containing only radionuclide sources of the fourth and fifth categories.
5. Carrying out economic and (or) other activities not specified in Sections I, II and IV of this document and not corresponding to the levels of environmental impact defined in Section IV of this document.
IV. Criteria for classifying objects that have a negative impact on the environment as objects of category IV
6. Availability simultaneously the following criteria:
a) presence of stationary sources at the facility environmental pollution, the mass of pollutants in emissions into the atmospheric air of which does not exceed 10 tons per year, in the absence of emissions of substances of I and II hazard classes, radioactive substances;
b) the absence of discharges of pollutants in the composition of wastewater into centralized sewerage systems, other facilities and systems for the disposal and treatment of wastewater, with the exception of discharges of pollutants resulting from the use of water for domestic needs, as well as the absence of discharges of pollutants into the environment.
7. Implementation of activities at the facility to ensure electrical energy, gas and steam (using equipment with design heat output less than 2 Gcal/h when consuming gaseous fuel) subject to the compliance of such an object with the criteria provided for in subparagraph "b" of paragraph 6 of this document.
8. The use of equipment at the facility solely for research, development and testing of new products and processes (pilot production enterprises, research institutes, experimental design bureaus), provided that such facility meets the criteria provided for in paragraph 6 of this document.
Letter No. AS-09-00-36/22354 explains the assignment of objects to category III, which do not meet any of the conditions of paragraphs. 1-3, 7 and 8 Criteria. Category III includes only those facilities where the impact levels specified in paragraph 6 of the Criteria are exceeded, i.е. there must be either emissions of more than 10 t/year, or radioactive emissions, or discharges of non-domestic wastewater into the sewer, as well as any discharges not into the sewer. All other objects belong to category IV or are not objects at all that provide NVOS.
“Is it possible that even schools, offices and kindergartens will have facilities that provide NEE?” - this question immediately came to mind when the bill on the categorization of objects that provide NVOS first appeared.
Letter No. АС-09-00-36/22354 reminds that in order to classify an object as category IV, it is necessary to have stationary sources of emissions, emissions of more than 10 tons / year, or emissions of radioactive substances, wastewater discharges generated when water is not used for domestic needs. .
At the same time, the legislation in the field of water supply and sanitation was considered in detail, on the basis of which the following conclusion was made. If the business uses water not for production processes specified in Appendix No. 4 to the Rules for Cold Water Supply and Sanitation, approved by Decree of the Government of the Russian Federation No. 644 dated July 29, 2013 (as amended on October 14, 2015), and is not required to have local treatment facilities and standards for permissible discharges of pollutants, other substances and microorganisms (in accordance with Decree of the Government of the Russian Federation of March 18, 2013 No. 230 “On the categories of subscribers for whose facilities the standards for permissible discharges of pollutants, other substances and microorganisms are established”), then it uses water for domestic needs. Accordingly, such an object belongs to category III, subject to other conditions.
Objects that are not subject to registration. If there are no “non-domestic” drains at the facility, there are no stationary sources and there are no signs from paragraphs. 1-3, 7 and 8 of the Criteria, then such an object does not carry out NVOS and is not subject to registration.
The same applies to facilities where the only impact on the environment is the formation, accumulation and even transportation of waste - such facilities do not apply to facilities that provide NVOS. The criterion for classifying objects that provide NEOS as objects of categories I and II is the activity for the neutralization or disposal (storage and disposal) of waste (subclause "p" clause 1, subclause "r" clause 2 of the Criteria).
The collection, processing and disposal of waste in and of themselves are also not criteria for classifying as facilities providing NEI. Therefore, if an enterprise, for example, has only vehicles for transporting waste from a place of accumulation to a place of disposal (and no longer has any signs of being classified as an NWOS facility), then such “carriers” can avoid registration.
If a person does not have objects that provide NVOS, then he can apply for registration, but will receive a notification of refusal on the basis of the absence of signs of classifying the object as objects providing NVOS. Such a person does not provide NEI and, in accordance with the law, is exempt from environmental reporting and payment for NEI, as well as persons operating objects of category IV. Pay attention to this explanation, because. subsequently, a new clarification will be released, in which the position of the Ministry of Natural Resources of Russia will change somewhat.
Errors and inaccurate information in the application. If you provided false information, then, although the verification of reliability is not provided for by the Rules for maintaining the register, nevertheless, if such a fact is revealed, the applicant is denied registration, and is also held accountable under Art. 8.5 of the Code of the Russian Federation on administrative offenses(as amended on 05.12.2016; hereinafter referred to as the Code of Administrative Offenses of the Russian Federation). If this minor mistakes(typos, technical inaccuracies), then the application can be finalized and resubmitted in the working order.
Assigning a category to an object. The registry rules do not specify what to do if the object does not correspond to the declared category, but according to letter No. AC-09-00-36 / 22354, in this case, Rosprirodnadzor assigns the object the category that is determined by the Criteria. In addition, if an object meets the criteria of several categories at once, it is assigned the highest possible one.
Rent of facilities providing NVOS. According to letter No. AC-09-00-36/22354, the tenant submits the application, i.e. one who directly operates the object. If the lease agreement is subsequently terminated, you must not forget to submit an application for updating information about the object in the prescribed manner, otherwise you will face liability under Art. 8.46 of the Code of Administrative Offenses of the Russian Federation.
On November 25, the Rosprirodnadzor Notification “On the procedure and features of setting objects that have a negative impact on the environment on state registration” (hereinafter referred to as the Notification) was issued.
Normative acts regulating registration. Clause 1 of the Notification provides a complete (and rather extensive) list of regulations governing the registration of objects that provide NVOS.
Also, the Notice again emphasizes that the objects that provide NVOS are registered on the basis of an application submitted by persons directly operating this object.
Federal and regional supervision. According to the criteria for determining objects subject to federal state environmental supervision, approved by Decree of the Government of the Russian Federation of August 28, 2015 No. 903, objects that provide NEI are divided into objects subject to federal and regional supervision. Objects subject to federal supervision must send applications to the territorial body of Rosprirodnadzor, regional - to the local executive authority. If the application is sent to the wrong place, it will be redirected to the jurisdiction within 5 days from the date of registration, of which the applicant will be notified.
Determining the boundaries of an object. The question was repeatedly raised, how to correctly identify an object if it is associated with other objects? It got to the point that each individual machine is an object that provides NVOS.
According to Art. 1 of the Federal Law of February 10, 2002 No. 7-FZ “On Environmental Protection” (as amended on July 3, 2016; hereinafter referred to as Federal Law No. 7-FZ), an object providing NVOS is a capital construction object and (or) another object , as well as their totality, united by a single purpose and (or) inextricably linked physically or technologically and located within one or more land plots.
Accordingly, we are not talking about machine tools and also not about individual land plots.
Notification Fragment
[…]
1.5. […]
An object that has a negative impact on the environment may include several sources of negative impact (including sources of emissions, discharges, waste disposal sites) and must meet the requirement territorial connectivity. In the event that a legal entity, an individual entrepreneur carries out economic and (or) other activities in 2 or more production areas that are at a considerable distance from each other and are not connected by pipelines, railways or otherwise (technically), it is necessary to register two or more production facilities with the corresponding submission of an application for each facility.
According to clause 19 of the Rules, if the facility is located within the territory of 2 or more constituent entities of the Russian Federation, a legal entity, an individual entrepreneur carrying out economic and (or) other activities at this facility, send an application for registering the facility with one of the territorial bodies Federal Service on supervision in the field of nature management or the executive authority of the constituent entity of the Russian Federation in accordance with their competence at the location of such an object at its discretion.
However, when registering linear objects NVOS Rosprirodnadzor recommends determining the boundaries of the NVOS object within municipalities
and not the subjects of the Russian Federation as a whole.
[…]
Speaking about linear facilities, Rosprirodnadzor, apparently, primarily has in mind pipelines. True, it is not entirely clear how to determine the boundaries within the framework of municipalities and, most importantly, why?
For example, the gas pipeline runs through the entire region, across the territory of dozens of municipalities, so it must be divided into dozens of segments - objects that provide NEP? And one way or another, submit applications for objects to the Rosprirodnadzor body for the subject, because would such a facility be subject to federal oversight? The question remains open.
Information about emissions, discharges, waste. To provide reliable data in the application, Rosprirodnadzor recommends using statistical reporting enterprises for 2016 (forms No. 2-TP (air), No. 2-TP (water management) and No. 2-TP (waste)), as well as data on industrial environmental control and reporting on payment for NVOS.
Placement of enterprise waste. This issue has already been covered in letter No. AC-09-00-36/22354. With the introduction of registration in the Subsoil User Module, the issue arose again, because The program has a “Waste Disposal Facility” tab, and at first many people tried to fill it in, choosing as the object the landfill where they transfer their waste for disposal under an agreement.
According to the Notice, this tab should be used only if the enterprise has its own waste disposal facility (included in the GRORO), i.e. if the balance sheet includes a waste landfill, a sludge storage facility, etc. If you are just generating and accumulating waste, as we said earlier, you do not need to indicate this in the application. If you have such a facility, then it is necessary to provide in the application information on monitoring the state and pollution of the environment on the territory of the waste disposal facility and within the limits of its impact on the environment.
Monitoring is not carried out only if the facility: is decommissioned; located in a territory where the placement of such objects is prohibited; is a special facility for radioactive waste; is a cattle burial ground; used to dispose of medical waste.
Object location coordinates. In accordance with paragraph 2.6 of the Instructions, the coordinates of the corner points of the object are given in decimal degrees format, in WGS 84 projection, precision - 6 decimal places. It is recommended to use either available documentation for the object, or, in case of its absence or use in it local system coordinates, public cadastral map.
For point features, a single point is specified; for areal - at least three points, while turning points must be indicated in the order they follow along the perimeter of the object; for linear - at least three points, while the points must be indicated in the order in which they appear. Linear objects are pipelines, railway lines and other similar structures.
The available documentation for the object is title documentation (certificate of ownership, etc.), a cadastral extract or other certificate from Rosreestr. As a rule, at large enterprises such information is available, but for small enterprises, especially those who rent facilities that provide NEI, such data may not be available, in which case you will have to use a public cadastral map. In some regions, it is directly advised to use google maps, Yandex, etc.
The best available technologies. Clarifications on this issue are relevant for enterprises that have objects of categories I and II.
DICTIONARY
Best Available Technology(hereinafter - BAT) is a technology for the production of products (goods), performance of work, provision of services, determined on the basis of modern achievements in science and technology and the best combination of criteria for achieving environmental protection goals, provided that it is technically possible to use it.
Information on BAT should be taken from special directories, which can be freely accessed on the Rosstandart website. If a reference book has not yet been developed for your technology, BAT information is not indicated in the application.
At the beginning of December, information from Rosprirodnadzor “Who should not apply for state registration of objects of negative impact” appeared.
In addition to the already known information about land plots and individual equipment that cannot be recognized as a separate object providing NEI, the letter contains a list of conditions under which the enterprise does not determine the object that provides NIS: the enterprise generates and accumulates waste, but does not carry out activities for disposal of waste independently and does not have other types of environmental impacts specified in the Criteria (presence of stationary sources of emissions, emissions over 10 tons/year, emissions of radioactive substances, non-domestic discharges and all types of impacts specified in paragraphs 1-3, 7 and 8 Criteria). The setting of objects that are not referred by the Criteria to any category is not provided.
However, what about enterprises that do not have facilities that provide NVOS? In the letter, Rosprirodnadzor clarifies that the issues of calculating and charging fees for the NEI are not directly related to the determination of the facility providing the NVOS, therefore, the preparation of relevant reports and the payment of fees is carried out in accordance with paragraph 1 of Art. 16.1 of Federal Law No. 7-FZ and the requirements of Federal Law No. 89-FZ of June 24, 1998 “On Production and Consumption Waste”.
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from Federal Law No. 7-FZ
Article 16.1. Persons obliged to pay for negative environmental impact
1. Legal entities and individual entrepreneurs engaged in the territory of the Russian Federation, the continental shelf of the Russian Federation and in the exclusive economic zone of the Russian Federation, economic and (or) other activities that have a negative impact on the environment (hereinafter referred to as - persons obliged to pay a fee), with the exception of legal entities and individual entrepreneurs carrying out economic and (or) other activities exclusively at objects of category IV.
The payers of the fee for the negative impact on the environment during the disposal of waste, with the exception of municipal solid waste, are legal entities and individual entrepreneurs, in the course of which economic and (or) other activities generated waste. The payers of the fee for the negative impact on the environment during the disposal of municipal solid waste are regional operators for the treatment of municipal solid waste, operators for the treatment of municipal solid waste, carrying out activities for their placement.
[…]
Thus, only those enterprises that have objects of category IV are exempted from the fee. However, it turns out that enterprises that do not provide NEI are obliged to pay for it? And category IV, the impact of which, although minimal, but there is, will not pay anything and will not draw up environmental reporting. By the way, it seems that reporting at such “objectless” enterprises also remains. However, if all that an enterprise can pay for is the placement of MSW, then the enterprise will also get rid of this payment according to the law: now the regional operator for the treatment of MSW pays for MSW. This does not apply to other types of waste that do not belong to MSW, however, today there is no clear list of which wastes are MSW and which are industrial wastes.
DICTIONARY
Municipal solid waste- waste generated in residential premises in the process of consumption individuals, as well as goods that have lost their consumer properties in the process of their use by individuals in residential premises in order to meet personal and domestic needs. MSW also includes waste generated in the course of activities of legal entities, individual entrepreneurs and similar in composition to waste generated in residential premises in the process of consumption by individuals.
As a result, we have a slightly different point of view. Category IV is unequivocally exempted from paying for NWOS, but enterprises without specific facilities providing NWOS, if they generate and accumulate waste that is not MSW, will pay for NWOS and, most likely, submit environmental reports.
We have reviewed last news, recommendations and clarifications in the global campaign for state registration of objects that provide NVOS, which, we hope, will fulfill its function of streamlining and structuring data on nature users.
Organizations and individual entrepreneurs that operate facilities that have a negative impact on the environment (NEOS) must put such facilities on state records (clause 1, article 69.2 of the Federal Law of 10.01.2002 No. 7-FZ).
Recall that the NVOS object is a capital construction object or another object, as well as their combination, united by a single purpose or inextricably linked physically or technologically and located within one or more land plots (Article 1 of the Federal Law of 10.01.2002 No. 7- FZ). Objects under construction are subject to state registration after they are put into operation.
We will tell you about the procedure for registering NVOS objects in our consultation.
Separate pieces of equipment are not considered as independent objects of NVS, as well as land. Objects that do not meet the criteria for classifying objects in categories I, II, III or IV, which are approved, are not objects of NVOS and are not registered. So, for example, open parking lots and similar areas are not stationary sources of emissions (Letter of the Ministry of Natural Resources of September 18, 2015 No. 12-44/22962). However, in relation to garages (even those used only for storage, entry and exit of vehicles) that are equipped with exhaust ventilation, the exhaust ventilation pipe will be a stationary source of pollutant emissions into the atmospheric air. Therefore, it will be necessary to register a garage and other similar buildings, structures or premises (Letter of Rosprirodnadzor dated February 14, 2018 No. RN-04-03-27 / 2839).
At the same time, it should be taken into account that the formation and accumulation of waste alone are not the criteria for classifying an object in one of the four categories of negative environmental impact. Therefore, if an organization or individual entrepreneur (for example, offices, schools, kindergartens, etc.) generates waste (without carrying out waste disposal activities on their own) and at the same time does not have other types of negative environmental impact specified in the Government Decree dated 09/28/2015 No. 1029, then in this case, they do not have NIOS objects.
The procedure for registering an object as an NVOS is provided for in Art. 69.2 of the Federal Law of January 10, 2002 No. 7-FZ. For each object that has a negative impact on the environment, an application is formed (clause 3 of article 69.2 of the Federal Law of 10.01.2002 No. 7-FZ). The application form was approved by the Order of the Ministry of Natural Resources of December 23, 2015 No. 554.
You can download the application form for registration of NVOS objects in Word format.
The application can be submitted electronically, handed over in person or sent by mail with a description of the attachment and a notification of receipt.
We will describe below how to prepare an application for registration of an NVOS object in electronic form.
To register NVOS objects with Rosprirodnadzor, an application can be prepared in electronic form in the following ways:
To work in personal account needed:
As for the nature user module, this is free software that can be downloaded from the Rosprirodnadzor website http://rpn.gov.ru/otchetnost.
It is also possible to prepare an application for registration of an NVOS object in third-party software, provided that an open XML format is used, published at http://rpn.gov.ru/node/27639 (file "For Companies with a corporate accounting system in the field of ecology" ).
An application for state registration of objects of negative impact is submitted at the location of the object (Article 65 of the Federal Law of 10.01.2002 No. 7-FZ):
Recall that objects of NVOS that are subject to federal environmental supervision are:
No fee is charged for filing an application and registering an NVOS object (clause 15, article 69.2 of Federal Law No. 7-FZ of 10.01.2002).
On the basis of applications, objects of NVOS are included in the register of registration of objects of negative impact.
Within 10 calendar days from the date of receipt of the application, the territorial body of Rosprirodnadzor or the executive authority of the constituent entity of the Russian Federation are obliged to put the object on state registration with the assignment of a code and category of the object to it, as well as issue a certificate of state registration of such an object to the organization or individual entrepreneur (clause 4 article 69.2 of the Federal Law of 10.01.2002 No. 7-FZ).
Information about the NVOS objects is subject to updating in connection with the submission by organizations or individual entrepreneurs of information (clause 6, article 69.2 of the Federal Law of 10.01.2002 No. 7-FZ):
When updating information about the NVOS object, the organization or individual entrepreneur within no more than 10 working days from the date of submission of supporting documents receives a certificate of updating accounting information (
