5.2 The Need to have an Integrated to Approach to Licensing

Currently there is no system for monitoring and licensing polluting sources in Tanzania. The practice has been the issuing of pollution licenses targeted at one environmental media, in such a way that, a facility discharging waste-water and emitting air pollutants, is required to obtain one license for waste-water discharges and another for air pollutants. This sectoral approach to licensing fails to consider the inter-related nature of a facility's operations and therefore, increases the likelihood that reduction of emissions in one media will translate into increased emission in another. For instance-, a reduction in waste-water discharges may lead into those same wastes being degenerated into solid form.

An integrated approach to licensing examines the facility's operations as a whole, considers the entire process and thus, enables the facility and the regulator to assess the trend of the discharges from one media to another, and prevent the possibility that environmental gains in one media will result in losses in another. (UNEP, 1992)

A holistic approach to licensing takes into consideration the facility's entire operations, whereas the single media approach limits itself to the end-of-pipe measures as a means to reducing emissions. The single media licensing
approach also complicates the institutional mechanism for enforcing compliance with pre-set standards, because one institution will be regulating air emissions requirements while another inspects it to ensure compliance with waste- water discharge limits.

Indeed, integrated approach to licensing would require the facility owners or operators to supply all information in respect of potential environmental consequences which may arise from their activities. The permit would reflect all the facilities discharges, including waste-water discharges, solid waste and air emissions.

In order to eliminate duplication and inefficiency in inspection and enforcement efforts, it is indispensable that the government should adopt an integrated approach to licensing. Incorporating all affected environmental media in one permit will, enable NEMC to co-ordinate the enforcement efforts among sector ministries and in order to conserve resources NEMC will need to prioritise polluters targeting first on the most polluting ones.