Problems of Assessing the Amount of Damage Caused to Soils by Pollution

Abstract

The article addresses the issues arising in cost assessment of damage caused to soils, when applying the «Methodology for calculating the amount of damage caused to soils as an object of environmental protection» approved by the Order of the Ministry of Natural Resources of July 8, 2010 No. 238: 1) the practice of establishing the fact of pollution, according to which a number of chemical elements and compounds are considered as contaminants; 2) the use of the ambient content of elements and compounds in soils as a normative value, resulting in an unjustified overestimation of the degree of damage caused to soils; the use of the ambient content of substances concentration of which according to the results of laboratory analysis is expressed as “below the detection limit”; 3) the high role of the subjective factor, due to the possibility of interpreting the provisions of the current methodology, allowing subjective decisions in the performance of supervisory activities. Finally, the authors conclude that it is impossible to apply the Methodology for calculating the amount of damage caused to soils in forensic environmental examinations. To increase the objectivity of the results it is necessary to develop a list of pollutants, considering the real harm that can be caused when their concentrations increase, and threshold concentrations of harmful substances below which they are not considered as pollutants.