In a joint note, the associations interested in the problem write that the Extraordinary Commissioner - sole responsible for the implementation (RUA) of the Program Agreement of the SIN Bacino Fiume Sacco - at the end of June formally requested the initiation of the procedure for the re-measurement of the SIN “Basin of the Sacco River” pursuant to art. 17-bis of Law Decree 152/202. (ref. note prot. n. 638207 of 28/06/2022, acquired by the Ministry under prot. n. 81240 of 30/06/2022)
The request is justified "following the need to reassess the existence of the requirements pursuant to article 252 for all areas currently falling within the perimeter of the Valle del Sacco, also in light of the results of the investigations and investigations carried out as part of the requests received for the various authorizations".
The associations have already expressed their position contrary to this hypothesis because they consider it inconceivable to throw away the work of the Service Conferences for the re-measurement of the SIN, in which the territory of the Sacco Valley participated compactly: from local administrations, to professional associations, to citizens' associations.
The request for suspension of the SIN perimeter received a categorical response from the MITE, on 12 July 2022: a decisive rejection of the request of the Region, which leaves a single road open to the possibility of perimeter loss.
The SIN explains to non-experts that art. 17-bis of the decree law 6 November 2021 n. 152, converted, with amendments, into law no. 29, states:
"1. With one or more decrees of the Minister of ecological transition, to be adopted within one year from the date of entry into force of the law of conversion of this decree, after consulting the Region and the Local Authorities concerned, the reconnaissance and re-measurement of contaminated sites currently classified of interest national for remediation purposes, excluding areas and territories that no longer meet the requirements referred to in article 252, paragraph 2, of the legislative decree 3 April 2006, n. 152".
Therefore, it is technically possible to carry out a re-measurement by excluding the areas that no longer meet the terms of the law and this procedure remains in the hands of the MITE.
The MITE however, with extreme clarity, retracing the path that led to the current perimeter of the SIN Bacino del Fiume Sacco, categorically reiterates that in the present case there are no legal prerequisites to initiate NEW - after a few years and in the absence of significant elements that have arisen - the procedure for verifying the requirements set out in art. 252.
On the note of the MITE we read that the Lazio Region remains with only one possibility, (foreseen in the ordinary way by art.36-bis, paragraph 3, of the law decree 22 June 2012 n.83, converted, with modifications, by law 7 2012 of August 134) which reads as follows: "At the request of the region concerned, by decree of the Minister of the environment and the protection of the territory and the sea, after consulting the local authorities concerned, it can be redefined the perimeter of the sites of national interest, it being understood that they remain of competence regional the necessary verification operations and possible remediation of the portion of sites which, as a result of this redefinition, you are excluded from the site of national interest".
In this case, to make it possible to start the procedure, the Lazio Region will have to formulate specific application accompanied by the relative technical documentation; in this case they may possibly be valued "the results of the investigations and inquiries carried out as part of the requests received for the various authorizations”, As recalled by the Commissioner, however acquired outside the remediation procedures of ministerial competence.
Then the Lazio Region it can legitimately propose - motivating it to the ministry that must issue the decree - the exclusion of some areas from the perimeter of the SIN, but it remains in charge of all the preparatory activities for any reclamation, starting with the production of technical and preliminary documentation.
This last step, specifies the SIN, it still leaves a door open to the political-economic appetites burdening the territory, even if in our opinion the current law makes it difficult to implement.
If this is the result, at the moment, of the request by the Lazio Region for re-measurement of the SIN, it seems important to us to understand who has moved, and in what way, to ask for this intervention, highlights the note.
Everything seems to start from the case of the resignation of the Catalent company in the Anagni plant on which we have already expressed our reasoned reflection. (https://legambienteanagni.com/2022/06/27/sin-bacino-del-fiume-sacco-la-storia-di-catalent-non-ci-convince/ ).
The positions of the various actors in this story
The president of Unindustria Lazio Angelo Camilli, at the assembly of his association on 28 April 2022, explicitly requested a simplification of all the authorization procedures, while guaranteeing maximum collaboration for the implementation of all the interventions that are part of the logic of " Circular Economy ”, he said that environmental permits are used as an ideological tool against industrial investments. The response of President Zingaretti, in the same venue (https://www.retuvasa.org/comunicato-stampa/sin-bacino-del-fiume-sacco-la-regione-lazio-completa-confusione) - speaks of suspension of the perimeter with the exception of riparian areas only, with a substantial go-ahead on areas directly contaminated by industrial settlements where any new investments would be located.
Also interesting is the position taken on 10 May 2022 by the order of architects, planners, landscape architects and conservators of the province of Frosinone, and that of the chemists and physicists of Lazio, Umbria, Abruzzo and Molise: on the one hand they propose a characterization procedure for macro-areas that would significantly reduce the cost and on the other ask for the delimitation of the SIN; to which it is not clear why to make a proposal to reduce costs, and probably time, of reclamation and then ask for delimitation, all preceded by the affirmation that hundreds of jobs would have already been lost.
At the Federlazio conference on 2 June 2022, if Eng. Mauro Annarelli - President of the Order of Engineers of Frosinone - affirms that "it is essential that we arrive at a procedural approach of the authorization procedures, univocal, together with a continuous training of instructors in the field of implementation" in the wake of a rationalization of administrative tools, the mayor of Anagni, Daniele Natalia, states that “It is clear that as it was conceived, regulated, managed and implemented, the SIN Valle del Sacco is an absurdity. The investments lost due to bureaucratic cumbersome and old environmental data, are the demonstration that must be urgently reviewed ”where the need to rationalize procedures is clearly combined with the pure and simple reduction of the perimeter of the SIN.
Finally, we cite the press release of the President of the Lazio Industrial Consortium Francesco De Angelis, who on April 14, 2022, comes to propose that the authorization procedures be delegated to ASI, under the usual pretext of the Catalent case; although the share of non-public members by statute cannot exceed 30%, the character of ASI is certainly not that of a public institution such as the Region and the real weight often does not correspond to the formal shares; vice versa, consortia, like all associative networks, can make a contribution to a radical ecological transformation of the territory.
From this brief excursus, highlights the SIN, a collection of proposals for rationalization of procedures emerges, where the objective of simplification puts in first place the substantial reduction of the area subject to the constraints of the regulations that apply to the Sites of National Interest in the SIN Sacco river basin.
Since the issuance of the perimeter decree of the SIN, 22 November 2016, if a real collaboration between regional and local administrations, control agencies, business and professional networks under the coordination of the Region has not been appreciated in order to perform the tasks that the institution of the SIN had entrusted to the latter, much less have we witnessed a real collaboration for the design of a development model of our territory according to the logic of the Circular Economy. The PNRR attributes approximately 40% of the resources to actions that can be classified under the sign of Ecological Transition and Circular Economy; as we have been repeating for years, well before the definition of the PNRR, the widest cooperation - between all the components of society, none excluded - is necessary to define a project of our territory in the name of environmental and social justice, aware of the fact that a revolution is made in a single territory, but from a territory a proposal to the national context can be born - must be born - with the aim of sharing the same methodology with the other territories.
The current intertwining of environmental, climatic, social and health crises requires a radical change far beyond the pursuit of particular interests coalesced to assault public funds. emphasizes the SIN.
Immediately, the associations that issued the joint note, call the local administrations and the political class at all levels to order, so that they keep the complex and long-standing theme of the reclamation of this sick territory out of the electoral propaganda, expressing themselves in the merit in a clear and unequivocal way and substantiated by any appropriate technical administrative support.
The associations in question forcefully ask that, should new actions by the Lazio Region be justified for the exclusion of portions of the territory from the perimeter of the SIN, the administrations will actively work to bring citizenship requests to the appropriate locations.