Evaluation of EU support for waste management and urban wastewater treatment in the Western Balkans region (2016–2022). Volume I, Evaluation report.
Date: 2025-08-19
Institutions: Bisbjerg, Peder, Buhl Nielsen, Eric, Directorate-General for Enlargement and Eastern Neighbourhood, Hutson, Mike, Naletilić, Ivan, Panariti, Narin
Subjects: EU aid, Western Balkans, environmental protection, project evaluation, quality of the environment, report, waste management, wastewater, water treatment

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Prepared by: 

Consortium composed by 

ADE, PEMconsult, and IRAM 

Evaluation leader: PEMconsult 

Consortium leader: ADE s.a 

Contact Person: Edwin Clerckx 

Edwin.Clerckx@ade.eu 

FWC EVA 2020 

EuropeAid/140122/DH/SER/Multi 

Specific Contract N° 300051728 

Authors:  
Eric Buhl Nielsen (Team Leader) 
Ivan Naletilić 
Narin Panariti 
Mike Hutson 
Peder Bisbjerg

    
 
 
 
 
 
 
 
 
 
 
 
 
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ISSN 2529-3338 

doi: 10.2876/9565423 

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Evaluation of EU support for waste management and urban 
wastewater treatment in the Western Balkans region  
(2016 – 2022) 

Evaluation report 

The report consists of two volumes: 

Volume 1 - Main report 
1.  Executive summary 
2.  Introduction 
3.  Key methodological elements, including limitations 
4.  Overall cooperation context, including portfolio analysis 
5.  Findings 
6.  Overall assessment 
7.  Conclusions 
8.  Recommendations 

Volume 2 - Annexes 

1.  Terms of Reference 
2.  Methodology 
3.  Evaluation framework 
4.  Evaluation sample 
5.  Findings at evaluation question level 
6.  Findings at judgement criteria level 
7.  List of persons met 
8.  List of documents consulted 

 
 
 
 
 
Table of contents 

1.  EXECUTIVE SUMMARY ................................................................................................................................... IV 

1.1.  OBJECTIVES AND SCOPE OF THE EVALUATION ................................................................................................... IV 
1.2.  CONTEXT .............................................................................................................................................................. IV 
1.3.  METHODOLOGY ..................................................................................................................................................... V 
1.4.  CONCLUSIONS ........................................................................................................................................................ V 
1.5.  RECOMMENDATIONS ......................................................................................................................................... VIII 

2. 

INTRODUCTION .................................................................................................................................................... 1 

2.1.  EVALUATION CONTEXT ......................................................................................................................................... 1 
2.2.  OBJECTIVES AND SCOPE ........................................................................................................................................ 1 

3.  KEY METHODOLOGICAL ELEMENTS ........................................................................................................... 3 

3.1.  OVERALL EVALUATION APPROACH ....................................................................................................................... 3 
3.2.  EVALUATION METHODS AND TOOLS...................................................................................................................... 3 
3.3.  CHALLENGES AND LIMITATIONS ........................................................................................................................... 5 

4.  OVERALL COOPERATION CONTEXT ............................................................................................................ 5 

4.1.  THE INTERNATIONAL FRAMEWORK AND COMMITMENTS .................................................................................... 5 
4.2.  EU INTERNAL POLICIES INFLUENCING EU SUPPORT TO WASTE MANAGEMENT AND URBAN WASTEWATER 
TREATMENT IN WESTERN BALKANS ................................................................................................................................. 6 
FINANCING INSTRUMENTS ..................................................................................................................................... 6 
4.3. 
4.4.  QUANTITATIVE ANALYSIS OF EU SUPPORT TO WASTE MANAGEMENT AND URBAN WASTEWATER TREATMENT 
- PORTFOLIO ANALYSIS ...................................................................................................................................................... 8 
OVERVIEW........................................................................................................................................................................... 8 
ALLOCATIONS BY INSTRUMENT ........................................................................................................................................... 9 
ALLOCATIONS OVER TIME ................................................................................................................................................... 9 
ALLOCATIONS BY PARTNER COUNTRY ............................................................................................................................... 10 
ALLOCATIONS BY SUB-SECTORS/THEMES .......................................................................................................................... 10 
ALLOCATIONS BY IMPLEMENTING PARTNERS .................................................................................................................... 11 
ALLOCATIONS BY CONTRACT TYPE ................................................................................................................................... 12 
4.5.  THE RECONSTRUCTED INTERVENTION LOGIC DIAGRAM.................................................................................... 13 
DIFFERENT LEVELS OF THE RECONSTRUCTED INTERVENTION LOGIC ................................................................................. 14 

5.  FINDINGS .............................................................................................................................................................. 15 

STRATEGIC RELEVANCE ...................................................................................................................................... 15 
5.1. 
5.2.  RESULTS ............................................................................................................................................................... 17 
5.3.  CROSSCUTTING ASPECTS ..................................................................................................................................... 22 
5.4. 
SUSTAINABILITY .................................................................................................................................................. 26 
5.5.  COOPERATION APPROACH ................................................................................................................................... 28 

6.  OVERALL ASSESSMENT ................................................................................................................................... 32 

7.  CONCLUSIONS ..................................................................................................................................................... 35 

7.1. 
STRATEGIC RELEVANCE ...................................................................................................................................... 35 
CONCLUSION 1: SUPPORT TARGETED NEEDS BUT UNDERESTIMATED CHALLENGES ........................................................... 35 
7.2.  RESULTS ............................................................................................................................................................... 36 
CONCLUSION 2: INFRASTRUCTURE PROJECTS DELAYED .................................................................................................... 36 
CONCLUSION 3: PHYSICAL OUTPUTS WILL BE REACHED BUT NOT AT THE SCALE NEEDED ................................................. 36 
CONCLUSION 4: CAPACITY DEVELOPMENT WAS WEAK AND POLICY LAGS IN IMPLEMENTATION ....................................... 36 
7.3.  CROSS CUTTING ASPECTS .................................................................................................................................... 37 

Evaluation of EU support for waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

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CONCLUSION 5: CROSS CUTTING ASPECTS LARGELY INTEGRATED BUT NOT MONITORED .................................................. 37 
SUSTAINABILITY .................................................................................................................................................. 38 
7.4. 
CONCLUSION 6: PROJECTS WERE BEING OPERATED BUT INSUFFICIENT FINANCE TO MAINTAIN THE FACILITIES ................. 38 
7.5.  COOPERATION APPROACH ................................................................................................................................... 38 
CONCLUSION 7: THE AMBITION LEVEL WENT BEYOND PARTNER READINESS GIVEN THE CHALLENGES ............................. 38 

8.  RECOMMENDATIONS ....................................................................................................................................... 39 

RECOMMENDATION 1: TAILOR THE AMBITION TO THE COUNTRY’S ABSORPTION CAPACITY .............................................. 39 
RECOMMENDATION 2: STRENGTHEN THE PROGRAMMATIC APPROACH .............................................................................. 40 
RECOMMENDATION 3: ENHANCE SUPPORT TO UTILITY LEVEL PERFORMANCE................................................................... 40 
RECOMMENDATION 4: PRIORITISE MUNICIPALITIES WITH CAPACITY AND WILLINGNESS ................................................... 41 
RECOMMENDATION 5: PROVIDE ADDITIONAL SUPPORT ..................................................................................................... 42 
RECOMMENDATION 6: ENHANCE PERFORMANCE IN CROSSCUTTING AREAS ...................................................................... 42 

LIST OF FIGURES 

FIGURE 1: EVALUATION METHODOLOGY, METHODS, AND TOOLS ........................................................................................ 4 
FIGURE 2: EU SUPPORT FOR WASTE MANAGEMENT AND URBAN WASTEWATER TREATMENT IN WESTERN BALKANS ......... 9 
FIGURE 3: WBIF: IPA GRANTS COMPARED TO EU MEMBER STATES GRANTS (2016-2022). SOURCE: WBIF SECRETARIAT 9 
FIGURE 4: EVOLUTION OF EU SUPPORT FOR WASTE MANAGEMENT AND URBAN WASTEWATER TREATMENT IN WESTERN 

BALKANS .................................................................................................................................................................. 10 

FIGURE 5: EU SUPPORT FOR WASTE MANAGEMENT AND URBAN WASTEWATER TREATMENT IN WESTERN BALKANS 

DISTRIBUTED BY COUNTRY ....................................................................................................................................... 10 

FIGURE 6: EU SUPPORT FOR WASTE MANAGEMENT AND URBAN WASTEWATER TREATMENT IN WESTERN BALKANS 

DISTRIBUTED BY SUB-SECTOR AND BROKEN DOWN BY INSTRUMENTS AND SUB-SECTORS......................................... 11 
FIGURE 7: TYPE OF IMPLEMENTING PARTNERS/LEAD IFI (WBIF PROJECTS) ...................................................................... 11 
FIGURE 8: TYPE OF IMPLEMENTING PARTNERS - (IPA BILATERAL CONTRACTS, 2016-2022) ............................................. 12 
FIGURE 9: IPA BILATERAL SUPPORT FOR WASTE MANAGEMENT AND URBAN WASTEWATER TREATMENT IN WESTERN 

BALKANS DISTRIBUTED BY CONTRACT TYPE  ............................................................................................................ 12 
FIGURE 10: EU CONTRIBUTION TO WBIF FOR WASTE MANAGEMENT AND URBAN WASTEWATER TREATMENT IN WESTERN 
BALKANS DISTRIBUTED BY CONTRACT TYPE (2016-2022) ........................................................................................ 13 
FIGURE 11: MAINSTREAMING CROSSCUTTING THEMES: INTEGRATED INDICATORS AND TARGETS IN IPA ANNUAL ACTION 
PROGRAMMES/PLANS (N=8) ..................................................................................................................................... 22 

FIGURE 12: MAINSTREAMING CROSSCUTTING THEMES: INTEGRATED INDICATORS AND TARGETS IN IPA BILATERAL AND 

WBIF-PROVIDED IPA GRANTS ................................................................................................................................. 24 

LIST OF TABLES 

TABLE 1: EVALUATION QUESTIONS..................................................................................................................................... 3 
TABLE 2: RANKING OF EVIDENCE ....................................................................................................................................... 4 
TABLE 3: OVERVIEW OF ORGANISATIONS MET DURING FIELD VISITS ................................................................................... 4 
TABLE 4: NUMBER AND STATUS OF IPA GRANTS PROVIDED THROUGH WBIF (2016-2022) .............................................. 13 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
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ii 

 
 
 
 
  LIST OF ACRONYMS 

AFD 
ALB 
BiH 
CSO 
DAC 
DSIP 
EBRD 
EC 
EFSD 
EIB 
EIP 
EPR 
EQ 
ESIA 
EU 
EUR 
EUSWAM 
EVA 
FBIH 
FWC 
GAF 
GAWB 
GDP 
GGF 
GIZ 
IFI 
IFICO 
IPA 
IPF 
ISWM 
ITS 
JC 
KfW 
MFF 
MKD 
MNE 
MS 
NGO 
NIPAC 
O&M 
PANEL 
PPF 
PUC 
ROM 
SAA 
SDG 
SER 
TA 
ToR 
UN 
UNDP 
UNECE 
WATSAN 
WBG 
WBIF 
WM 
WSS 
WW 
WWT 
WWTP 

Agence Française de Développement 
Albania 
Bosnia and Herzegovina 
Civil Society Organization 
Development Assistance Committee 
Directive Specific Implementation Plans 
European Bank for Reconstruction and Development 
European Commission 
European Fund for Sustainable Development 
European Investment Bank 
Economic and Investment Plan 
Extended Producer Responsibility 
Evaluation Question 
Environmental and Social Impact Assessment 
European Union 
Euro 
EU Support to Waste Management 
Evaluation 
Federation of Bosnia and Herzegovina 
Framework Contract 
Grant Application Form 
Green Agenda for the Western Balkans 
Gross Domestic Product 
Green for Growth Fund 
Deutsche Gesellschaft für Internationale Zusammenarbeit  
International Financial Institution 
IFI Coordination Office 
Instrument for Pre-accession Assistance 
Infrastructure Project Facility 
Integrated Solid Waste Management 
Information Technology System 
Judgment Criteria 
Kreditanstalt für Wiederaufbau (German Development Bank) 
Multiannual Financial Framework 
North Macedonia 
Montenegro 
EU Member State 
Non-Governmental Organization 
National IPA Coordinator 
Operation and Maintenance 
Participation, Accountability, Non-Discrimination and Equality, Empowerment and Legality 
Project Preparation Facility 
Public Utility Company 
Results-Oriented Monitoring 
Stabilization and Association Agreement 
Sustainable Development Goal 
Serbia 
Technical Assistance 
Terms of Reference 
United Nations 
United Nations Development Programme 
United Nations Economic Commission for Europe 
Water and Sanitation Programme 
World Bank Group 
Western Balkans Investment Framework 
Waste Management 
Water Supply and Sanitation 
Wastewater 
Wastewater Treatment 
Wastewater Treatment Plant 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

iii 

 
 
 
 
EXECUTIVE SUMMARY 

Objectives and scope of the evaluation  

This  evaluation  provides  a  comprehensive  and 
independent  assessment  of  the  European  Union’s 
(EU)  support  for  two  major  aspects  of  the  green 
transition 
the  Western  Balkans:  waste 
management  and  urban  wastewater  treatment.  It 
covered all six Western Balkan countries: Albania, 
Bosnia  and  Herzegovina,  Kosovo*  Montenegro, 
North Macedonia, and Serbia. 

in 

The  evaluation  included  country  and  regional 
interventions  under 
the  Instrument  for  Pre-
Accession  Assistance  (IPA)  –  bilateral  IPA 
assistance  managed  by  the  EU  and  IPA  grants 
provided by the EU through the Western Balkans 
Investment  Framework  (WBIF)1  for  investment 
projects through blending with loans provided by 
It 
International  Financial 
assessed both the EU’s spending and non-spending 
interventions.  Where  relevant, 
the  evaluation 
involved  interventions  funded  by  other  donors, 
including  EU  member  states,  in  particular  to 
evaluate  EU  interventions  in  the  context  of  the 
Team Europe approach and the EU’s value added 
in jointly funded interventions, as well as to learn 
from  good  practices  and  experiences  of  other 
donors. 

Institutions 

(IFIs). 

The evaluation focused on the period from 2016 to 
2022, primarily on interventions supported through 
the  IPA  II  envelope.  However,  it  also  examined 
earlier  IPA  bilateral  and  WBIF-provided  IPA 
grants  as  well  as  IPA  III  interventions  to  gain 
historical  perspective  and 
the 
evolution of cooperation approaches. 

insights 

into 

Context 

As  part  of  the  EU  accession  process,  Western 
Balkans  countries  are  required  and  are  making 
efforts to align their policies and regulations with 
those of the EU, including the environmental and 
climate  Acquis  (Chapter  27)  including  waste 
management and urban wastewater treatment. The 
political and economic context for EU support to 
improved  waste  management  and  wastewater 
treatment in the Western Balkans is shaped by the 

EU accession process, economic development, and 
regional cooperation in shared river basins. As part 
of  the  EU  accession  agenda,  Western  Balkan 
countries have committed to a range of reforms and 
initiatives to align their policies and practices with 
EU  standards.  These  commitments  are  aimed  at 
fulfilling 
criteria,  which 
encompass  political,  economic,  and  legislative 
requirements  for  EU  membership.  In  transposing 
the environmental and climate Acquis the Western 
Balkan countries have committed to: 

the  Copenhagen 

Protection:  Adopting 
legislation, 

EU 
Environmental 
environmental 
including  waste 
management  and  water  quality  standards.  This 
includes commitments under the Green Agenda for 
the  Western  Balkans  (GAWB)  to  transition  to  a 
circular economy and reduce pollution. 

including 

Climate  Action:  Aligning  with  the  EU’s  climate 
Paris  Agreement 
the 
goals, 
commitments,  and  implementing  measures  to 
reduce  greenhouse  gas  emissions  and  support 
climate change adaptation. 

The Western Balkan countries utilise a variety of 
EU financing instruments. The first among these is 
the  IPA  instrument,  which  has  been  the  primary 
vehicle  for  EU  support  in  the  region.  This 
instrument 
is  complemented  by  concessional 
finance from IFIs, funding from other donors, and 
market-based instruments. The EU with its partners 
aims  to  harmonise  investments  in  the  sectors 
through  the  WBIF  -  a  joint  initiative  that  brings 
together  the  EU,  IFIs,  bilateral  donors,  and 
their 
beneficiary 
investments. 

coordinate 

countries 

to 

During the period covered by this evaluation, EU 
funding  consisted  of  IPA  II  grants  and  some 
implementation of IPA I and IPA III grants, which 
were  managed  by  the  EU.  In  addition,  the  EU 
provided  IPA  grants  through  the  WBIF  for 
investment projects, blending them with loans from 
IFIs.  

Prior  to  the  2020  Green  Agenda  for  the  Western 
Balkans,  EU  support  in  the  region  was  primarily 
guided  by  Chapter  27  (Environment)  of  the  EU 
accession process, with priorities set on a country-

This designation is without prejudice to positions on status and is in 
line with UN Security Council resolution 1244 and the International 
Court of Justice Opinion on the Kosovo declaration of independence. 

1See Box 1 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

iv 

 
 
 
by-country  basis  reflecting  the  demand-driven 
nature  of  the  support.  The  EU  did  not  provide 
investment  grants  for  waste  management  and 
wastewater treatment projects through WBIF until 
2022, when it approved two investment grants for 
wastewater projects - one in North Macedonia and 
one in Montenegro. 

Methodology 

The  evaluation  examined  EU  support  for  waste 
management and urban wastewater treatment in the 
Western  Balkans  in  terms  of  strategic  relevance, 
cooperation approach, added value, results, cross-
cutting  contribution,  transformative  effects,  and 
sustainability.  It  adopted  a  theory-based,  non-
experimental  mixed  methods  approach  applied 
across  three  main  phases:  inception,  interim,  and 
synthesis. 

indicators,  data 

During the inception phase, a detailed evaluation 
design  was  established,  defining  evaluation 
questions  (EQs)  and  judgment  criteria  (JCs), 
complemented  by 
sources, 
methodological  steps,  and  an  analytical  approach 
for each question. 
In  the  interim  phase,  the  evaluation  reviewed 
available documentation and conducted field visits 
to  six  Western  Balkan  countries.  The  evaluation 
analysed 
intervention-specific 
and 
documentation  to  generate  preliminary  findings 
and identify information gaps and hypotheses for 
testing.  Additional  data  was  collected  through 
fieldwork,  and  identified  hypotheses  were  tested. 
During the field visits, the team consulted with all 
six  EU  Delegations  in  the  Western  Balkans,  17 
national institutions, 14 municipalities and public 
four  consultancies, 
utilities, 
engaging over 120 individuals in these discussions. 

IFIs,  and 

strategic 

four 

In  the  synthesis  phase,  the  evaluation  team 
analysed and triangulated the information collected 
through various means and sources. Based on this 
analysis,  they  answered  the  evaluation  questions 
and  provided  conclusions,  lessons  learned,  and 
recommendations. 

Conclusions 

The  evaluation  formulated  seven  conclusions 
based  on  the  findings  and  grouped  them  in  five 
clusters:  strategic  relevance;  results;  crosscutting 
aspects; cooperation approach and sustainability. 

Strategic relevance 

to 

and 

waste 

tailored 

develop 

political 

strategies 

management 

1.  The EU support was well targeted at partner 
country  needs  but  underestimated  the 
economy 
institutional 
and 
challenges.  The  EU's 
programming  in  urban  wastewater  treatment 
and 
addressed 
environmental  degradation  challenges  in  the 
Western  Balkans  partner  countries.  These 
efforts  were  closely  aligned  with  national 
strategies  and  aimed  at  supporting  accession 
agenda.  Each  partner  country  received  EU 
support 
country 
implementation  plans  for  Chapter  27  of  the 
Acquis. The implementation plans focussed on 
waste  management  and  wastewater  treatment 
as  top  priorities.  The  EU  also  assisted  in 
developing  directive-specific  implementation 
plans,  which  helped  prioritise  activities.  This 
approach emphasised participation and a robust 
local  needs. 
technical  understanding  of 
to 
However, 
institutional constraints and political economy 
dynamics,  which  were 
underestimated. 
Optimistic  assumptions  regarding  national 
commitment and ownership, both at the central 
and municipal levels, did not fully materialise. 
Reluctance  to  adjust  tariffs,  allocate  adequate 
resources  to  the  sector,  and  manage  political 
conflicts 
and 
implementation of the jointly agreed EU action 
plan in the partner countries. 

emerged  due 

challenges 

adoption 

hindered 

the 

Results 

treatment 

2.  Infrastructure  projects  were  complex  and 
subject to delays and in many cases beyond 
the  capacity  of  the  implementing  partners. 
The  wastewater 
and  waste 
management  projects  faced  challenges  that 
exceeded  the  capabilities  of  implementing 
partners  at  both  central  and  municipal  levels. 
Unrealistically optimistic workplans tended to 
overlook  partner  capacity  and  institutional 
context.  This  led  to  significant  project  delays 
and, in North Macedonia, funding withdrawals 
amounting  to  €80 million, primarily  from  the 
environmental  sector.  Meanwhile,  complex 
institutional 
and 
Herzegovina  delayed  projects  because  the 
country lacked the flexibility to adjust contracts 

in  Bosnia 

structures 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

v 

 
and 

timely 

treatment 

slowed  down 

completion.  A 
effective 

lack 
of 
for 
technical 
comprehensive 
assistance,  which 
includes  broader,  more 
holistic  support  aimed  at  long-term  capacity 
building  and  sustainability 
(e.g.,  project 
management  capacity  building,  institutional 
support  prior  to  implementation,  and  post-
project support for operation and maintenance), 
and  a  fragmented  technical  assistance  system 
within  WBIF  for  waste  management  and 
wastewater 
the 
achievement of investment projects’ maturity, 
a requirement for investment in infrastructure, 
and contributed to long  delays. The emphasis 
on 
(i.e., 
engineering 
engineering  consultancy  technical  assistance) 
in  wastewater  projects 
to 
overlooking comprehensive planning for end-
to-end 
such  as 
forecasting sewage generation and addressing 
sludge management needs. As a result, in these 
the  sewerage  networks  were  not 
cases, 
the 
sufficiently  developed 
necessary sewage to the wastewater treatment 
plants. 

requirements, 

to  generate 

contributed 

technical 

specific 

aspects 

3.  The  projects  are  likely  to  achieve  their 
physical  outputs  and  contribute  to  wider 
environmental  and  social  benefits  in  the 
longer  term  but  not  at  the  scale  needed. 
Since 2016, none of the waste and wastewater 
infrastructure  projects  initiated  have  been 
completed.  However,  reports  and  on-site 
verifications  of  earlier  projects  suggest  that 
despite  delays  and  challenges,  they  have 
achieved their intended outputs and are leading 
to significant environmental benefits in waste 
management and wastewater treatment. Based 
on the progress of past and current projects, it 
is probable that ongoing works will finish and 
meet their intended physical outputs. This will 
reduce  untreated  wastewater  discharged  into 
the 
improve  waste 
and 
management through minimisation, recycling, 
landfills. 
and  safe  disposal 
Interventions  in  waste  management  will  also 
empower public authorities, the private sector, 
and  citizens to  participate more  effectively  in 
transition.  Consequently,  EU 
the  green 
collaboration 
in  wastewater  and  waste 
management sectors will contribute to broader 

environment 

in  sanitary 

implement  EU-supported 

environmental, economic, and social benefits. 
Nevertheless,  the  national  capacity  to  absorb 
and 
initiatives 
remains limited compared to the requirements 
for implementing the EU waste and wastewater 
Acquis.  It  will  take  a  long  time  to  achieve 
transformative  and 
lasting  environmental, 
economic, and social change. 

in 

lag 

strategies 

implementation.  In 

4.  Although  there  have  been  some  successes, 
capacity  development  was  not  well 
integrated  into  programmes  and  policy 
the 
reforms 
wastewater sector, infrastructure projects often 
lacked  a  coordinated  approach  that  integrates 
infrastructure development, capacity building, 
and  policy  reforms.  While  financial  and 
operational 
programmes 
improvement 
contributed to capacity development, they were 
not  systematically  applied  across  all  projects 
and were  limited to individual municipalities. 
EU  policy  dialogues  achieved  successes  like 
new water laws in Serbia and Montenegro and 
in  Bosnia  and 
environmental 
Herzegovina, but implementation of reforms to 
meet  EU  standards  has  lagged  behind.  Waste 
management initiatives, particularly under IPA 
III,  were  more 
linking 
infrastructure,  capacity  building,  and  policy 
reforms  compared 
to  wastewater  efforts. 
Examples  include  a  significant  municipal 
waste programme in Kosovo and waste studies 
and  assessments  in  Bosnia  and  Herzegovina. 
Despite  these  efforts,  challenges  such  as 
inadequate  tariffs  and  non-compliance  with 
standards  persist,  despite 
environmental 
aligned 
policies.  Achieving 
comprehensive  wastewater  treatment,  waste 
management,  and  circular  economy  goals 
remains 
a  distant  objective.  However, 
governments  recognise  the  importance  of 
meeting EU standards in these sectors. 

coherent 

national 

in 

Crosscutting aspects 

5.  Climate,  gender,  and  human  rights  were 
taken into account in the programming but 
integrated 
not  monitored  or 
in  result 
reviewed  programme 
frameworks.  The 
documents  discussed  climate,  gender,  and 
human  rights  issues  at  the  country  level,  and 
their integration into the EU support. However, 
unlike  climate  considerations,  gender  and 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

vi 

 
human rights were not consistently included in 
programme-level  log  frames.  Integration  into 
log  frames  was  generally  weak, 
project 
improving  somewhat  over 
time  but  not 
resulting in meaningful integration throughout 
the project cycle. Evaluation findings indicated 
that  the  cross-cutting  objectives,  especially 
gender-related, were often treated as pro-forma 
than  meaningful  requests.  Climate 
rather 
considerations  were  better  mainstreamed, 
particularly  in  waste  projects,  but  lacked 
systematic  tracking  and  reporting.  Similarly, 
reporting  on  gender  outcomes  was  weak  and 
often  lacked  detail  on  integration  challenges 
and  opportunities,  limiting  learning  potential 
across  projects.  Overall,  there  were  missed 
opportunities to better integrate climate, gender 
and  human  rights  aspects  into  planning  and 
evaluation processes. 

Sustainability 

is 

6.  Municipalities were  largely  able  to  operate 
infrastructure  and  provide 
the  new 
improved  services,  but  maintenance  and 
longer-term 
severely 
sustainability 
threatened.  Ensuring  sustainable  wastewater 
and  waste  management 
projects  was 
challenging  due  to  weak  financial,  technical, 
and  institutional  capacities  of  utilities,  and 
sometimes  unstable  municipal  politics.  While 
wastewater utilities were able to manage daily 
operations,  they  struggled  to  cover  long-term 
maintenance costs. They lacked technical skills 
and  had  difficulty  keeping  qualified  staff. 
Utilities  were 
on 
heavily 
municipalities for repair and replacement costs. 
National  authorities  and  municipalities  often 
interfered  in  operations  and  hesitated  to  raise 
water  and  waste  tariffs  to  cover  full  costs  or 
shortfalls. 
provide 
Consequently, utilities lacked the financial and 
managerial  autonomy  needed  for  sustainable 
service improvements. These issues were well 
known  to  the  EU  and  other  stakeholders  and 
were  frequently  highlighted  in  various  EU 
reports. The EU engaged in policy discussions 
on  tariffs  and  technical  assistance  funding 
through operational performance improvement 
programmes  and  innovations  in  the  waste 
management  sector.  Despite  these  efforts, 

dependent 

to  meet 

subsidies 

challenges  remain,  and  it  will  take  time  for 
these measures to take root and for improved 
services to be sustained. 

Cooperation approach 

treatment  sectors 

7.  The complexity and nature of the challenges 
required  a  stronger  programmatic  and 
demand-based  approach 
that  matched 
partner  readiness.  The  waste  management 
faced 
and  wastewater 
significant 
included 
challenges.  These 
financial instability, low citizen awareness, and 
ineffective public administration. These issues 
often  exceeded  the  resources  and  scope  of 
individual  projects,  especially  in  politically 
contested  areas.  The  projects  had  high 
ambitions  but  lacked  step-by-step  plans  to 
address  national  and  local  constraints.  There 
was a need to recognise national ownership and 
the limits of external support. Although the EU 
has established a framework for IPA assistance 
through the EIP, GAWB, and WBIF guidelines 
(see  Chapter  4),  waste  and  wastewater 
interventions  did  not  have  a  clear,  demand-
based 
transition  strategy  with  a  realistic 
timeline for achieving EU standards. Although 
the  choice  of  partners  and  instruments  was 
sound, 
to  develop  a 
comprehensive  programmatic  approach  that 
matched  partner  readiness  and  was  based  on 
demonstrated  ownership  and  demand.  The 
annual  planning  basis  of 
II  was 
problematic, even with a push for a long-term 
vision. This issue is now being addressed under 
IPA  III.  The  IPA  grants  for  waste  and 
wastewater provided through WBIF did not fit 
well  with  a  programmatic  approach  -  as  they 
were  approved  on  a  demand-driven,  project-
by-project basis, rather than being structured to 
support a cohesive cluster of projects that could 
evolve over time, policy reforms, and capacity 
building.  Opportunities  to  use  IFI  budget 
support  and  policy  development  loans  were 
missed.  The  plan  to  finance  infrastructure 
through loans, supported by grants for capacity 
development  and  policy  dialogue,  was  well-
conceived but hard to implement coherently. 

it  was  difficult 

IPA 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

vii 

 
Recommendations 

The evaluation conclusions came to the following 
recommendations. 

and 

shape 

simple 

significantly 

implementation 

and  wastewater 

set  of 
national,  municipal, 

1.  Develop  a 
scenarios, 
and 
integrating 
project- specific considerations, to tailor the 
ambition  level  of  the  EU  support,  for  the 
waste  management 
and  wastewater 
treatment sectors, to the country’s potential 
for 
ensuring 
sustainability.  The  evaluation  found  that  a 
towards  EU  waste 
country's  progress 
management 
treatment 
standards hinges on various complex factors at 
the  national  level.  These  factors,  such  as 
administrative hurdles, political will, financial 
capacity for implementation and sustainability, 
and the ability to drive social and behavioural 
achievable 
changes, 
outcomes.  Aligning  EU  support  with  each 
country's specific capacity and commitment to 
EU  Acquis  approximation  is  important.  This 
alignment  varies  over 
time  and  across 
municipalities. A set of scenarios ranging from 
high to low ambition in the sector can help in 
tailoring  EU  support  appropriately.  These 
scenarios  would  outline  necessary  policy 
reforms, 
institutional  enhancements,  and 
financial  commitments  at  both  national  and 
municipal levels. The scenarios would need to 
be aligned with the countries' strategies and the 
legal and technical requirements of relevant EU 
directives. They should also take into account 
and 
Specific 
reflect 
Implementation  Plans 
(DSIPs),  directive-
specific  timelines  (i.e.,  short,  medium,  and 
long-term objectives), and be realistic in terms 
of investment planning and technical capacity 
building.  

the  Directive 

the 

2.  Strengthen the programmatic approach2 to 
enhance  coherence  of 
investment 
projects and their link to policy, institutional 
and capacity development. The infrastructure 
projects  were  generally  well-planned,  but  in 
some instances, wastewater treatment projects 
were  implemented  in  isolation  to  sewerage 

2Comprehensive approach that integrates infrastructure, policy, and 
capacity development. 

national 

capacities, 

network connections, resulting in underutilised 
facilities – this is now changing and there are 
improvement  works  taking  place  in  some 
municipalities.  The  IPA  grants  provided 
through  WBIF  for  waste  and  wastewater 
management  primarily  operated  on  a  project-
by-project  basis,  missing  opportunities  to 
enhance 
streamline 
administrative  processes,  and  drive  policy 
reforms  that  often  were  beyond  individual 
projects. When grants provided through WBIF 
interventions  were  integrated  into  broader 
investment programmes, such as the Serbia VI 
programme  for  wastewater  treatment,  they 
demonstrated  greater  potential  for  cumulative 
improvements.  Adopting  a  programmatic 
approach to investments would better integrate 
infrastructure  with  wider  initiatives  aimed  at 
capacity development, reform implementation, 
and engagement with stakeholders such as the 
private sector and civil society.  

3.  Enhance 

in 

to 

the 

utility 

support 

project  management 

level 
performance. Municipalities and public utility 
corporations often lack sufficient resources and 
capacity, especially in low-income settings, to 
effectively  manage  both 
complex 
implementation  phase  and  ongoing  operation 
and  maintenance.  Although  IFIs  often  deploy 
project  implementation  units  to  support  these 
and 
entities 
procurement,  there  is  a  need  to  ensure  skills 
transfer for handling larger maintenance tasks 
and  system  expansions.  While  some  projects 
have  introduced  financial  and  operational 
performance improvement programmes, these 
efforts  have  not  been  consistently  applied. 
These  programmes  aim  to  enhance  technical 
capacity  and  strengthen  the  financial  and 
managerial  independence  of  public  utilities, 
enabling  them  to  operate  more  professionally 
along  business  lines.  Positive  outcomes  have 
been observed where such initiatives have been 
implemented. National associations of utilities 
play a crucial long-term role in supporting and 
providing  services  such  as  updating  utility 
billing and financial administration systems.  

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

viii 

 
 
fostering  peer-to-peer  learning.  A  number  of 
examples  of  pre-  and  post-implementation 
support  have  underscored  the  advantages  of 
systematically delivering such assistance on a 
declining basis.  

6.  Enhance  performance  in  climate,  gender 
equality, and human rights. Climate, gender 
equality, and human rights are important cross-
cutting  issues.  However,  there  is  limited 
knowledge  and  understanding  at  national  and 
sub-national levels regarding the integration of 
these  aspects  into  infrastructure,  policy,  and 
empowerment 
interventions.  The  EU's 
requirements for integrating these themes were 
more 
than 
seen  as  artificial/procedural 
meaningful  requests  backed  by  guidance  and 
instructions.  The  lack  of  know-how  and  the 
rationale behind the integration of in particular 
in 
gender 
infrastructure projects contributed to the lack of 
activity 
level.  Generally, 
commitments made  at the programming level 
were  not  consistently 
the 
project’s results frameworks. 

translated 

project 

human 

issues 

rights 

into 

and 

at 

are 

strong. 

4.  Prioritise partners at the municipality level 
where the absorption capacity and political 
willingness 
Successful 
implementation  and  sustainability  hinged  on 
committed  partners,  typically  a  public  utility 
engaged 
corporation 
an 
supported  by 
municipality.  This  was  clear 
for  both 
wastewater treatment and waste management, 
even amidst significant technical and financial 
challenges.  Strong  partners  demonstrated 
leadership  and  effectively  utilised  EU-
supported  innovations  like  extended  producer 
responsibility 
separation. 
Conversely, projects with weak ownership and 
commitment suffered from limited capacity to 
leverage  external  support,  such  as  enhancing 
social  support  for  environmental  initiatives. 
The  alignment  of  partner  objectives  and  their 
willingness to cooperate and implement policy 
reforms  were  the  most  important  factors  in 
achieving  and  maintaining  environmental 
outcomes. 

source 

and 

for  project  management 

5.  Provide  additional  support  to  the  pre  and 
post implementation phases. Few individual 
and 
regional  municipal  corporations  are 
experienced  in  implementing  interventions  at 
the necessary scale and complexity to address 
regional environmental challenges. They often 
technical  assistance  – 
require  substantial 
beyond  engineering  consultancy  support  for 
feasibility  studies,  project  design, 
tender 
documentation  and  similar  -  to  develop  the 
and 
capacity 
institutional changes to ensure good outcomes. 
Successful  EU  interventions  have  benefited 
from a careful pre-project phase that enhanced 
local  ownership.  However,  sustaining  the 
capacity  to  operate  and  maintain  wastewater 
treatment  and  waste  management  facilities 
remains  a  significant  challenge.  This  is  often 
beyond the capabilities of many municipalities 
and  newly 
regional  waste 
management  entities.  A  common  issue  in 
projects is the lack of funding mechanisms for 
major  maintenance.  Strengthening 
these 
capacities  is  best  achieved  locally  through 
public  utility  corporations  and  nationally 
through associations of municipalities, utilities, 
and  private  sector  and  civil  society  groups, 

established 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
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ix 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
1. 

INTRODUCTION  

1.1.  Evaluation context 

The Western Balkans partner countries (partner countries hereafter) have close links with the European Union 
(EU), and the cooperation is focused on securing a stable path towards EU membership. The cooperation aims 
at effective political and economic governance, enabling the partner countries to integrate EU standards in all 
sectors, developing a thriving economy based on EU values. As EU candidate or potential candidate countries, 
the Western Balkans countries need to gradually meet the EU standards in various areas including in Chapter 
27  of  the  EU  acquis,  which  refers  to  "Environment  and  Climate  Change"  in  the  context  of  EU  accession 
negotiations.  The  goal  of  Chapter  27  is  to  ensure  that  the  candidate  or  potential  candidate  country  can 
effectively implement EU environmental and climate change standards and regulations, thereby contributing 
to the broader objectives of environmental protection and sustainability within the EU. This chapter plays a 
crucial role in the EU accession process, as it helps harmonise environmental policies and standards across EU 
member  states  and  candidate  countries,  promoting  a  more  integrated  and  sustainable  approach  to 
environmental and climate issues. 

The EU supports the Western Balkan countries in aligning their standards with those of the EU by providing 
financial and non-financial support for policy reforms, infrastructure development, and capacity building at 
various levels.  

As  part  of  the  European  Green  Deal  and  to  ensure  that  the  Western  Balkans  are  also  on  a  path  toward 
sustainable transition, the European Commission formulated the  “Guidelines for the Implementation of the 
Green  Agenda  for  the  Western  Balkans”  (GAWB).  These,  combined  with  the  “Economic  and  Investment 
Plan” (EIP) tailored specifically to the Western Balkans, constitute the basis of the EU support in the region. 

1.2.  Objectives and scope 

The evaluation served a dual purpose: accountability and learning. The main objectives of the evaluation were: 

• 

• 

to provide a comprehensive and independent assessment of the EU’s support for two major aspects of 
the green transition in the Western Balkans - waste management and urban wastewater treatment;  

to  identify  key  lessons  learnt,  promote  good  practices,  and  produce  recommendations  to  feed  into 
ongoing  and  future  approaches  to  EU’s  engagement  in  waste  management  and  urban  wastewater 
treatment. 

The specific objectives were: 

• 

• 

• 

• 

• 

to assess EU support in the waste management and urban wastewater treatment sectors, including 
policy, implementation linked to infrastructure investments, results achieved, and capacity-building 
efforts in the partner countries (addressed mainly by EQ4 Results but also by EQ1 Strategic 
Relevance); 
to assess the extent of the impact the EU has made in the Western Balkans through reforms and 
investments in waste management and urban wastewater treatment (addressed mainly by EQ6 
Transformative Effects but also by EQ1 Strategic Relevance and EQ5 Crosscutting contribution); 
to assess progress toward pre-accession in Chapter 27 of the acquis, with a particular focus on the 
partner countries' convergence with the EU acquis in integrated waste management and wastewater 
collection and treatment strategies, as well as their sustainability (addressed mainly by EQ1 Strategic 
Relevance but also by EQ4 Results);  
to assess coherence between regional, multi-country, and bilateral envelopes and the synergies 
created (addressed mainly by EQ2 Cooperation Approach but also by EQ3 Added Value); 
to assess the "Working Better Together" approach, specifically the complementarities and synergies 
developed (addressed mainly by EQ2 Cooperation Approach but also by EQ3 Added Value); 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

1 

 
 
• 

• 

to assess the value added by EU-IPA grants in these sectors, especially in facilitating access to 
finance, improving technological standards, transferring know-how, and fostering institutional 
development and capacity building (addressed mainly by EQ3 Added Value but also by EQ4 
Results); 
to assess the sustainability of EU investments, including lessons learned, follow-up on public utility 
companies’ (PUCs) performance, cooperation with municipalities, and financing through tariffs 
(addressed by EQ7 Sustainability). 

The  evaluation  covered  all  six  partner  countries:  Albania,  Bosnia  and  Herzegovina,  Kosovo,  Montenegro, 
North Macedonia, and Serbia. 

The  evaluation  focussed  on  the  period from  2016  to 2022.  Hence,  the  primary focus  was  on  interventions 
supported  through  the  IPA  II  envelope.  However,  the  evaluation  also  examined  some  IPA  I  and  IPA  III 
interventions to gain a historical perspective and insights into the evolution of cooperation approaches. The 
evaluation  included  IPA  bilateral  and  regional  interventions,  as  well  as  IPA  grants  provided  through  the 
Western Balkans Investment Framework (WBIF) (see Box 1 for information on WBIF). It assessed both the 
EU’s spending and non-spending interventions. Where relevant, the evaluation included interventions funded 
by other donors, including EU member states, in particular to evaluate EU interventions in the context of the 
Team Europe approach and the EU’s value added in jointly supported interventions, as well as to learn from 
good practices and experiences of other donors (see Annex 2 for the sampling strategy and Annex 4 for the 
list of desk and field sample interventions).  

The  evaluation  assessed  the  EU’s  support  in  terms  of  its  strategic  relevance,  cooperation  approach,  added 
value, effectiveness regarding outputs, outcomes, transformative results, including crosscutting aspects, and 
sustainability of results.  

Based on a set of findings for each evaluated area, the evaluation provided an overall independent assessment 
of  the  EU's  support,  key  lessons  learned,  and  main  conclusions.  From  this  assessment,  the  evaluation 
formulated a set of recommendations to guide future EU investments and implementation strategies regarding 
waste and wastewater management in the Western Balkans region. 

The main intended users of this evaluation are relevant geographic and thematic units within DG NEAR, the 
EU  Delegations  in  the  Western  Balkans,  IPA  beneficiaries,  the  European  Investment  Bank  and  other 
international financial institutions, the European External Action Service, EU member states, development 
partners, civil society, the private sector, and other donors active in the Western Balkans.  

The evaluation was commissioned by DG NEAR and managed by its Evaluation Unit. The process was steered 
by  a  reference  group  consisting  of  representatives  from  DG  NEAR  and  EU  Delegations  in  the  Western 
Balkans. The evaluation methodology considered potential biases to ensure impartiality in data collection and 
analysis. Information sources and their contributions were independent of any parties with an interest in the 
evaluation.  The  evaluation  team  worked  freely  and  without  interference.  Throughout  the  process,  the 
evaluation was independent, and no conflicts of interest arose. 

The  WBIF  is  a  joint  initiative  of  the  European  Union,  EU  member  states,  international  financial  institutions,  and 
bilateral  donors  that  aims  to  enhance  harmonization  and  cooperation  in  investments  supporting  socio-economic 
development  across  the  Western  Balkans  region.  It  serves  as  the  main  mechanism  for  implementing  the  EU’s 
Economic  and  Investment  Plan  for  the  Western  Balkans  policy  priorities  by  providing  financial  and  technical 
assistance for infrastructure projects in sectors such as energy, environment, transport, and social development. The 
EU and bilateral donors (EU member states and Norway) contribute to WBIF through technical assistance grants for 
project preparation and implementation, as well as investment grants. These investment grants are blended with loans 
from WBIF partner financial organisations like the European Investment Bank, the European Bank for Reconstruction 
and Development, and others, to maximize investment impact. In the waste and wastewater sector, the EU provided 
only technical assistance grants until 2022, when it began contributing through WBIF with investment grants to this 
sector. The decision-making process for WBIF projects involves project identification by Western Balkan countries, 
submission  of  proposals  for  assessment  by  the  WBIF's  Project  Financiers'  Group,  and  approval  by  the  Steering 
Committee for funding. 

BOX 1: WESTERN BALKANS INVESTMENT FRAMEWORK IN A NUTSHELL 

2 

 
 
 
2.  KEY METHODOLOGICAL ELEMENTS 

2.1.  Overall evaluation approach  

The  evaluation  adopted  a  theory-based  and  non-experimental  mixed  methods  approach.  It  followed  an 
intervention logic outlined in section 3.5 to understand the underlying drivers and factors of change or absence 
of  change  in  the  context  of  EU  policy,  technical,  and  financial  assistance  to  identify  causal  relationships 
between the EU support and results achieved at output, outcome, and impact levels.  

The  evaluation  was  framed  around  seven  evaluation  questions  (EQs),  and  a  set  of  judgement  criteria  and 
indicators presented in Annex 3. The findings from the seven evaluation questions were then grouped in five 
main areas of inquiry as outlined in Table 1 below. 

Clusters  

Evaluation Questions (EQs) and Judgement Criteria (JCs) 

Strategic 
relevance 

EQ1 Strategic Relevance – Has EU support in waste management and urban wastewater treatment 
responded to the EU priorities and partner country priorities? (JCs – Partner country needs/ Alignment 
with partner country policies and strategies/ Contribution to the EU’s policy priorities) 

EQ3 Added value - What has been the added value of the EU support? (JC – EU accession as common 
purpose) 

Results  

EQ4 Results – To what extent has EU support contributed to results? (JCs – Waste management results/ 
Urban wastewater treatment results/ factors) 

EQ6 Transformative effect – To what extent has EU support on waste management and wastewater 
treatment  contributed  to  broader  effects?  (JCs  –  Waste  management  results/  Urban  wastewater 
treatment results/ Factors) 

Cross cutting 
aspects 

EQ5 Cross cutting contribution – To what extent were  crosscutting themes mainstreamed into the 
design and implementation of EU support to waste management and urban wastewater treatment? (JCs 
– Gender/ Human Rights/ Climate) 

Sustainability  EQ7 Sustainability – To what extent has EU support on waste management and urban wastewater 
treatment  contributed  with  sustainable  interventions?  (JCs  –  Waste  management  results/  Urban 
wastewater treatment results/ Factors) 

Cooperation 
approach 

EQ2 Cooperation approach – Have the implementation arrangement been conducive for an effective 
and efficient EU support? (JCs – Timely disbursement/ Partners choice/ Instruments) 

EQ3 Added value – What has been the added value of the EU support? (JC - Coordination with MSs 
and others) 

TABLE 1: EVALUATION QUESTIONS 

2.2.  Evaluation methods and tools 

The  evaluation  was  conducted  in  three  phases:  inception  phase,  interim  phase,  and  synthesis  phase.  The 
inception phase set a detailed evaluation design by defining the evaluation questions and judgment criteria, 
complemented  with  indicators,  data  sources,  methodological  steps,  and  the  analytical  approach  for  each 
evaluation question. The evaluation matrix is available in Annex 3. The interim phase involved the review of 
available  documentation  and  field  visits  to  six  partner  countries.  The  evaluation  team  first  reviewed  and 
analysed strategic and intervention-specific documentation (notably in the key sectors concerned) to generate 
preliminary findings and to identify information gaps and hypotheses for testing in the field. The evaluation 
team collected additional data through fieldwork and tested the identified hypotheses. 

The data collected through the document review was ranked as shown in Table 2 below. This ranking was 
evaluated and either adjusted or confirmed during the synthesis phase (see Indicator reports for the rankings). 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

3 

 
 
 
 
Ranking of 
evidence 

Strong 

Explanation of ranking of quality of evidence 

The finding is consistently supported by a range of evidence sources, including documentary 
sources, quantitative analysis and qualitative evidence (i.e. triangulation); or the evidence 
sources, while not comprehensive, are of high quality and reliable to draw a conclusion (e.g. 
strong quantitative evidence with adequate sample sizes and no major data quality or reliability 
issues; or a wide range of reliable qualitative sources, across which there is good triangulation). 

More than 
satisfactory 

There are at least two different sources of evidence with good triangulation, but the coverage of 
the evidence is not complete. 

Indicative but not 
conclusive 

There is only one evidence source of good quality, and no triangulation with other sources of 
evidence. 

Weak 

There is no triangulation and/ or evidence is limited to a single source. 

TABLE 2: RANKING OF EVIDENCE 

During the field visits, the evaluation team consulted with all six EU Delegations in the Western Balkans, 17 
national  institutions,  14  municipalities  and  public  utilities,  four  IFIs,  and  four  consultancies.  More  than 
120 individuals participated in these meetings. An overview is presented in the table below. 

TABLE 3: OVERVIEW OF ORGANISATIONS MET DURING FIELD VISITS 

Detailed information about the fieldwork can be found in Annexes 2 and 4.  

The evaluation sample included 29 projects at the desk stage and 18 projects at the field stage. An overview 
of these projects can be found in Annex 4. The sampling strategies can be found in Annex 2. 

An  overview  of  the  three  phases  of  the  evaluation,  including  the  main  methods,  tools,  and  activities,  is 
presented  in  Figure  1.  Detailed  information  about  the  methodology,  methods,  and  tools,  including  ethical 
considerations, is provided in Annex 2. 

FIGURE 1: EVALUATION METHODOLOGY, METHODS, AND TOOLS 

4 

 
 
 
 
2.3.  Challenges and limitations 

The  evaluation  encountered  a  few  minor  challenges  that  did  not  affect  the  accuracy  and  validity  of  the 
evaluation findings, conclusions, and recommendations. 

Early-stage projects. The main limitation related to the low number of completed projects in the evaluation 
sample.  To  partly  mitigate  this,  the  evaluation  selected  a  few  earlier  projects  and  examined  the  quality  of 
design and implementation processes where outcomes were not yet available. 

Documents.  Another  challenge  and  limitation  related  to  the  retrieval  of  documents  from  International 
Financial Institutions (IFIs). While a satisfactory amount of grant-related documentation for WBIF-provided 
IPA grants for wastewater projects was collected, obtaining project design and progress documents from IFIs 
was not always possible due to their stringent data-sharing procedures. To address data gaps resulting from 
this issue, a follow-up request was made during the field phase of the evaluation and a number of additional 
documents were obtained either through IFIs or directly from the beneficiary.  

Portfolio analysis. Lastly, a few challenges regarding the portfolio analysis process of bilateral IPA assistance 
constituted a minor limitation; however, these were specific to the portfolio itself rather than to the evaluation 
overall. First, the process of filtering out waste and urban wastewater interventions relied on the Development 
Assistance Committee (DAC) coding system, but not all relevant interventions may be accurately coded within 
it. To partially mitigate this, the evaluation relied on short project descriptions to capture the missing projects; 
however,  these  descriptions  were  not  always  sufficiently  comprehensive  to  provide  a  clear  picture  of  the 
funded project activities. As a result, some relevant projects may still have been left out, while some irrelevant 
ones may have been included. Finally, the filtering process was limited by the lack of specific and detailed 
information regarding the wastewater treatment components in water projects. For instance, some projects that 
include wastewater treatment elements also encompass a wide range of other activities, such as water supply 
infrastructure development, irrigation systems, and water resource management, which made it challenging to 
extract  accurate  and  comprehensive  wastewater  treatment  values.  However,  these  portfolio  limitations  are 
rather specific to the portfolio of IPA bilateral assistance itself and do not reflect the challenges related to the 
evaluation  findings,  conclusions,  and  recommendations.  This  is  because  the  data  collection  and  analyses 
relevant to the evaluation questions focused exclusively on the waste and wastewater elements of the reviewed 
projects. 

3.  OVERALL COOPERATION CONTEXT 

This  chapter  provides  an  overview  of  the  cooperation  context,  including  the  international  framework  and 
commitments,  EU  internal  policies  influencing  EU  support  for  waste  management  and  urban  wastewater 
treatment in the Western Balkans, and available financing instruments. It also includes an analysis of the EU’s 
waste  management  and  urban  wastewater  treatment  portfolio  in  the  Western  Balkans,  as  well  as  the 
reconstructed intervention logic for EU support. A detailed political, socioeconomic, and sector context in the 
Western Balkans countries is provided in the evaluation’s inception report. 

3.1.  The international framework and commitments 

As part of the EU accession process, the partner countries are required and are making efforts to align their 
policies and regulations with those of the EU, including the environmental and climate Acquis (Chapter 27) 
including  waste  management  and  urban  wastewater  treatment.  The  political  and  economic  context  for  EU 
support to improved waste management and wastewater treatment in the Western Balkans is shaped by the EU 
accession process, economic development, and regional cooperation in shared river basins.  

As part of the EU accession agenda, the partner countries have committed to a range of reforms and initiatives 
to  align  their  policies  and  practices  with  EU  standards.  These  commitments  are  aimed  at  fulfilling  the 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

5 

 
 
Copenhagen criteria, which encompass political, economic, and legislative requirements for EU membership. 
In transposing the environmental and climate Acquis the partner countries have committed to: 

Environmental Protection: Adopting EU environmental legislation, including waste management and water 
quality standards. This includes commitments under the Green Agenda for the Western Balkans to transition 
to a circular economy and reduce pollution. 

Climate  Action:  Aligning  with  the  EU’s  climate  goals,  including  the  Paris  Agreement  commitments,  and 
implementing measures to reduce greenhouse gas emissions and address climate change adaptation. 

3.2.  EU internal policies influencing EU support to waste management and urban wastewater 

treatment in Western Balkans 

The  European  Union's  internal  policies  on  waste  management  and  urban  wastewater  treatment  have  a 
significant  influence  on  its  support  to  Western  Balkans  in  these  areas.  These  include  various  waste  and 
wastewater  directives  such  as  Waste  Framework  Directive,  Landfill  Directive,  Packaging  and  Packaging 
Waste Directive, Urban Wastewater Treatment Directive. The EU’s support is also shaped by agreements and 
programmes in which the partner countries participate as candidate countries or potential candidate countries. 
These include the Stabilisation and Association Agreements (SAAs), the Economic and Investment Plan (EIP), 
and  regional  agreements,  e.g.,  the  Transport  Community,  the  Energy  Community,  and  the  Regional 
Cooperation Council.  

As  part  of  the  European  Green  Deal  and  to  ensure  that  the  Western  Balkans  are  also  on  a  path  toward 
sustainable transition, the European Commission formulated the “Guidelines for the Implementation of the 
Green Agenda for the Western Balkans” (GAWB). These, combined with the “Economic and Investment Plan” 
(EIP) tailored specifically to the Western Balkans, constitute the basis of the EU support in the region. 

EIP - An Economic and Investment Plan for the Western Balkans (€9 billion of IPA III funding for the period 
2021-2027 to support economic convergence with the EU), was adopted by the European Commission. It is 
the blueprint for EU assistance to bridge the socioeconomic gap between the Western Balkans region and the 
EU and to help its green and digital transition. In addition, the investment capacity of the Western Balkans 
should be boosted by mobilizing a new Western Balkans Guarantee Facility, with the ambition to potentially 
raising investments of up to €20 billion. 

GAWB - Through the Sofia Declaration (2020) the Western Balkans leaders agreed on the Green Agenda for 
the Western Balkans. The Green Agenda for the Western Balkans is a blueprint for possible measures to be 
adopted  jointly  by  the  EU  and  each  of  the  Western  Balkans  partners,  based  on  the  existing  political  and 
technical cooperation frameworks, including in particular the Stabilisation and Association Agreements, the 
Negotiation Frameworks and Economic Reform Programs. The agenda should enable the Western Balkans 
and  the  EU  to  create  stronger  links  between  climate  and  environment  actions,  policy  reforms  and  EU 
approximation.  It  should  also  guide  the  definition  of  financial  and  technical  assistance  strategies  both  at 
bilateral and regional level. The leaders also agreed to a detailed action plan on the Green Agenda at the Brdo 
Summit in 2021. 

Actions are planned around five pillars3, covered also by the European Green Deal. The 2nd pillar on circular 
economy addresses in particular waste, recycling, sustainable production, and efficient use of resources.  

3.3.  Financing Instruments 

Substantial public and private funding, at national, regional, and international level is needed for fulfilling 
Chapter 27 and the implementation of the Green Agenda for the Western Balkans. To contribute to meeting 
these needs and leveraging national and private investment, a range of financing instruments are available, the 

3The five pillars of the Green Agenda: (1) climate action, including decarbonisation, energy and mobility, (2) circular economy, addressing in particular 
waste, recycling, sustainable production and efficient use of resources, (3) biodiversity, aiming to protect and restore the natural wealth of the region, 
(4) fighting pollution of air, water and soil and (5) sustainable food systems and rural areas. 

6 

 
 
 
 
Instrument for Pre-Accession Assistance (IPA), concessional finance from international financial institutions, 
funding provided by other donors (see WBIF example) and market-based instruments. During the timeline 
covered by this evaluation, EU funding was composed of: IPA II grants (and some implementation of IPA I 
and  IPA  III  grants)  provided  and  managed  by  the  EU  (IPA  bilateral  assistance)  often  to  support  reforms, 
institutional  strengthening  and  capacity  building  (both  national  and  regional);  IPA  grants  and  WBIF 
investment projects, through blending EU and bilateral donors’ grants with loans provided by WBIF partner 
financial  organisations.  In  addition  to  the  EU  and  WBIF  bilateral  donors’  funding,  there  were  grants  and 
blended finance provided by multilateral and bilateral agencies for both institutional and investment projects 
such as those of the World Bank Group (WBG), the Kreditanstalt für Wiederaufbau (KfW), and the Agence 
française de développement (AFD).  

As of 2020 the six partner countries received financial aid through the IPA instrument, a funding mechanism 
for  EU  candidate  countries.  The  IPA  is  the  means  by  which  the  EU  has  been  supporting  reforms  in  the 
enlargement region with financial and technical assistance since 2007. For the period 2007-2013, the IPA had 
a budget of €11.5 billion. Its successor, IPA II, was allocated €12.8 billion for the period 2014-2020. For the 
multiannual financial framework period 2021-2027, the IPA III budgetary envelope is €14.162 billion4. The 
IPA bilateral assistance decision-making process includes programming national priorities jointly with the EU 
based  on  reform  needs  and  EU  accession  goals,  funding  proposal  development  by  the  countries,  proposal 
evaluation by the European Commission, and programme implementation with EU oversight. 

For the current Multi-annual Finance Framework (MFF) period, the funding from the EU is guided by  the 
Economic and Investment Plan for Western Balkans. Under this plan there are four investment and 10 technical 
assistance grants for waste and wastewater management that were endorsed in 2020-2022. The EIP will help 
attract  public  and  private  investments,  backed  by  the  Western  Balkans  Guarantee  Facility,  which  has  a 
potential to mobilise up to €20 billion. The funding is provided through IPA III, which foresees a dedicated 
window of the programming framework for the implementation of the Green Agenda. Within environment 
and climate action, IPA includes: i) regional capacity building; ii) bilateral projects on Acquis approximation 
but mostly on necessary infrastructures linked to heavy investment directives on waste and water; iii) cross-
border cooperation programmes on environmental governance, water quality; iv) grants for WBIF investments 
in the public and private sectors. Investments in infrastructure are included in the partner countries’ Single 
Project  Pipelines  or  similar  investment  prioritisation  processes,  for  which  project  promotors,  such  as 
municipalities, often need technical assistance support.  

It is also foreseen that a range of other financial instruments will contribute including: i) the Green for Growth 
Fund (GGF), structured as public private partnership, will  continue to provide financing for green investments; 
ii) the European Fund for Sustainable Development (EFSD+) Open Access Guarantee aims at mitigating the 
risks perceived by the private sector in order to increase the investment capacity of the region for investments 
including water and sustainable cities and iii) market-based instruments such as Natural Capital Investment 
Fund(s) that support projects that have positive community, ecological, economic and environmental impacts, 
but cannot access traditional financing because of perceived risks.  

4 https://neighbourhood-enlargement.ec.europa.eu/enlargement-policy/overview-instrument-pre-accession-assistance_en 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
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7 

 
 
 
 
 
 
 
 
3.4.  Quantitative analysis of EU support to waste management and urban wastewater treatment 

- portfolio analysis  

The portfolio analysis includes EU funded waste and urban wastewater treatment interventions in the Western 
Balkans contracted in the period from 2016 to 2022. It includes IPA bilateral contracts and IPA grants provided 
through the WBIF. It does not include bilateral donors’ grants provided through the WBIF. The analysis was 
conducted based on waste and wastewater interventions contracted by the EU between 2016 and 2022. The 
list  of  WBIF  grants  for  waste  management  and  urban  wastewater  treatment  was  provided  by  the  WBIF 
Secretariat, while the list of IPA bilateral contracts was extracted from the CRIS database.  

Overview 

Overview of EU funding in Western Balkans for waste management (WM) and urban wastewater treatment 
(WWT) in 2016 – 2022 (under IPA II and III), key statistics: 

•  Total WM and WWT amount contracted: EUR 308.4 million  
•  Percentage of WM and WWT funding by instrument: 

o 
o 

IPA bilateral: 65% (EUR 199.4 million) 
IPA provided through WBIF: 35% (EUR 108.9 million) 

•  Percentage of WM and WWT funding by sub-sector:  

o  WWT: 75%  
o  WM: 25%  

•  Percentage of WM and WWT funding in the WBIF that was for WWT projects: 99%. 
•  Percentage of WM and WWT funding in the WBIF that was for WM projects: 1%. 
•  Percentage of WM and WWT funding in IPA bilateral that was for WWT projects: 61%. 
•  Percentage of WM and WWT funding in IPA bilateral that was for WM projects: 39%. 
•  Geographical distribution of EU funding for WM and WWT in Western Balkans: 

o  North Macedonia - 38% 
o  Serbia - 27% 
o  Albania  - 11% 
o  Kosovo - 10% 
o  Montenegro - 9% 
o  BiH - 5% 

8 

 
 
 
 
 
 
Allocations by instrument 

Of the total EU funding for waste management and urban wastewater treatment in Western Balkans contracted 
in the period from 2016 to 2022, 65% were provided through the WBIF, while 35% was IPA bilateral funding 
administered directly by the EU through its Delegations or Commission departments (figure 2). Between 2016 
and 2022, the EU approved a total of 16 waste and wastewater treatment grants through the WBIF, including 
two investment grants signed in 2022, which far exceeded the financial volume of the remaining 14 technical 
assistance grants. Compared to EU member states, the EU’s support for WBIF interventions was higher for 
both technical assistance and investment grants, even though it only began providing investment grants through 
WBIF in 2022 (figure 3). 

FIGURE 2: EU SUPPORT FOR WASTE MANAGEMENT AND URBAN WASTEWATER TREATMENT IN WESTERN BALKANS (2016-2022). SOURCE: 
WBIF SECRETARIAT AND CRIS DATABASE 

FIGURE 3: WBIF: IPA GRANTS COMPARED TO EU MEMBER STATES GRANTS (2016-2022). SOURCE: WBIF SECRETARIAT 

Allocations over time 

In terms of the evolution of allocations over time, it is noticeable that IPA bilateral support had generally been 
increasing until 2020, when it experienced a significant decrease. This decrease can probably be attributed to 
the  launch  of  the  new  IPA  III  programme  in  2021and  the  transition  period  and  administrative  processes 
involved in setting up and implementing IPA III. On the other hand, support provided through WBIF increased 
sharply in 2022 due to the two investment grants signed by the EU (figure 4).  

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

9 

 
 
 
FIGURE 4: 
EVOLUTION OF EU 

SUPPORT FOR WASTE 

MANAGEMENT AND 

URBAN WASTEWATER 

TREATMENT IN 
WESTERN BALKANS 
(2016-2022). 
SOURCE: WBIF 

SECRETARIAT AND 
CRIS DATABASE 

Allocations by partner country 

In terms of geographic distribution, North Macedonia received the greatest proportion of funding for waste 
management and urban wastewater treatment, followed by Serbia and Albania. Kosovo, Montenegro, and BiH 
followed, in decreasing order. In Serbia and Montenegro, funding for waste management was very limited, as 
well as in BiH and Albania. Unlike in these four partner countries, the vast majority of the funding allocated 
to Kosovo was directed towards waste management. Similarly, a significant portion of the funding for waste 
management was allocated to North Macedonia (figure 5). 

FIGURE 5: EU 

SUPPORT FOR WASTE 

MANAGEMENT AND 

URBAN WASTEWATER 

TREATMENT IN 
WESTERN BALKANS 

DISTRIBUTED BY 
COUNTRY (2016-
2022). SOURCE: 
WBIF SECRETARIAT 
AND CRIS DATABASE 

Allocations by sub-sectors/themes 

Regarding thematic distribution, the majority of the funding contracted between 2016 and 2022 was directed 
towards urban wastewater treatment, accounting for 75% of the total. Support for waste management followed 
with 25% of the total. Notably, the funding for waste management was predominantly in the form of IPA 

10 

 
 
 
bilateral  assistance,  whereas  the  urban  wastewater  treatment  funding  was  primarily  provided  through  the 
WBIF (figure 6). 

FIGURE 6: EU SUPPORT FOR WASTE MANAGEMENT AND URBAN WASTEWATER TREATMENT IN WESTERN BALKANS DISTRIBUTED BY SUB-SECTOR 
(2016-2022) AND BROKEN DOWN BY INSTRUMENTS AND SUB-SECTORS (2016-2022). SOURCE: WBIF SECRETARIAT AND CRIS DATABASE 

Allocations by implementing partners 

2.9% 

Bank 

When it comes to implementing partners, the European Investment Bank (EIB) implemented the majority of 
EU assistance to waste management and urban wastewater treatment provided through WBIF – as much as 
71.4% of the total EU assistance channelled through WBIF. Kreditanstalt für Wiederaufbau (KfW) and the 
World 
Group 
Bank 
(WBG)follow,  with  23.6% 
respectively, 
and 
while a small portion of the 
EU  contribution  to  WBIF 
was  implemented  by  the 
for 
European 
Reconstruction 
and 
Development  (EBRD)  and 
the  Agence  française  de 
développement 
(AFD). 
Overall,  the  EIB  was  the 
implementer  of 
primary 
waste 
support 
management 
and 
treatment 
wastewater 
projects 
the  Western 
in 
Balkans  provided  through 
the  WBIF.  It  was  followed 
by  KFW  and  AFD  (figure 
7). 

FIGURE 7: TYPE OF IMPLEMENTING PARTNERS/LEAD IFI (WBIF PROJECTS, 2016-2022). SOURCE: 
WBIF SECRETARIAT 

for 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

11 

 
 
 
As figure 8 shows, most of the IPA 
bilateral  funds  allocated  for  waste 
management 
and  wastewater 
treatment  were  implemented  by 
public  entities  in  recipient  partner 
countries,  including  central  and 
local  governments,  among  others. 
Third  county  government  -  the 
German  Agency  for  International 
Cooperation (GIZ)  -  was  entrusted 
with  a  significant  portion  of  the 
for  both  waste  and 
funding 
wastewater treatment projects and it 
is the leading bilateral implementer. 
When it comes to IFIs, KfW was a 
entrusted 
implementer, 
notable 
with 17% of the total IPA bilateral 
assistance for waste, while EIB implemented 5% of the total funding allocated for urban wastewater treatment. 
Additionally, some funds were distributed to Non-Government Organisations (NGOs) and the private sector. 

FIGURE 8: TYPE OF IMPLEMENTING PARTNERS - (IPA BILATERAL CONTRACTS, 2016-2022). 
SOURCE: CRIS DATABASE 

Allocations by contract type 

In terms of the type and nature of IPA bilateral contracts, the majority for both waste and urban wastewater 
treatment  were  Contribution  and  Delegation  agreements,  followed  by  procurement  contracts  (consultancy, 
supplies, services, studies, and similar) and grants (figure 8).  

FIGURE 9: IPA BILATERAL SUPPORT FOR WASTE MANAGEMENT AND URBAN WASTEWATER TREATMENT IN WESTERN BALKANS DISTRIBUTED BY 
CONTRACT TYPE (2016-2022). SOURCE: CRIS DATABASE 

Of  the  EU  grants,  for  waste  management  and  urban  wastewater  treatment  that  were  provided  through  the 
WBIF, 88% were provided as investment grants, while the rest covered technical assistance for investments – 
as noted above the 88% related to two  investment grants signed in 2022. Almost entire (99%) EU funding 
provided through the WBIF was allocated to wastewater treatment projects (figure 10). 

12 

 
 
 
 
FIGURE 10: EU CONTRIBUTION TO WBIF FOR WASTE MANAGEMENT AND URBAN WASTEWATER TREATMENT IN WESTERN BALKANS 
DISTRIBUTED BY CONTRACT TYPE (2016-2022). SOURCE: WBIF SECRETARIAT 

There were a total of 16 waste management and urban wastewater treatment grants provided through the WBIF 
in the period from 2016 to 2022. Six grants were completed by end-2022 and only two out of 16 grants were 
provided for waste projects.  

Partner country 
Urban wastewater treatment 
Albania  
Bosnia and Herzegovina  
Kosovo 
Montenegro 
North Macedonia 
Serbia 
Waste management 
Albania  
Bosnia and Herzegovina  
Kosovo 
Montenegro 
North Macedonia 
Serbia 
Total 

Ongoing  
10 
1 
3 
1 
4 
1 
0 
2 
0 
0 
0 
0 
0 
0 
10 

Completed 
4 
0 
1 
0 
1 
2 
0 
2 
2 
0 
0 
0 
0 
0 
6 

Total 
14 
1 
4 
1 
5 
3 
0 
2 
2 
0 
0 
0 
0 
0 
16 

TABLE 4: NUMBER AND STATUS OF IPA GRANTS PROVIDED THROUGH WBIF (2016-2022). SOURCE: WBIF SECRETARIAT 

In  summary,  the  EU  funding  for  waste  management  and  urban  wastewater  treatment  in  Western  Balkans 
contracted in the period from 2016 to 2022 was Euro 308.4 million. Of this, 65% was provided through the 
WBIF, while the remaining 35% of the funding was in the form of IPA bilateral contracts (figure 2). Regarding 
thematic distribution, the majority of the funding contracted between 2016 and 2022 was directed towards 
urban wastewater treatment, accounting for 75% of the total. Support for waste management followed with 
25% of the total (figure 6). Notably, the funding for waste management was predominantly channelled through 
IPA bilateral contracting, whereas the urban wastewater treatment funding was primarily provided through the 
WBIF (figure 7). In terms of geographic distribution, North Macedonia received the greatest proportion of 
funding for waste management and urban wastewater treatment, followed by  Serbia  and Albania. Kosovo, 
Montenegro, and BiH followed, in decreasing order (figure 4). 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

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3.5.  The reconstructed intervention logic diagram 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

13 

 
 
 
Different levels of the reconstructed intervention logic 

The  theory  of  change  outlines  four  key levels from  inputs to  impact:  i)  main  inputs  for  core  activities;  ii) 
outputs from these activities; iii) short and long-term outcomes; and iv) impacts. 

The inputs are of various types and made by various actors and can for simplicity be categorised as follows: 

•  National resources: contributions from government, civil society, and the private sector. 

•  Promoter-Specific Resources: Local administrations, utilities, industries raising finance, often through 

loans. 

•  EU non-spending and technical Assistance: Policy dialogue and technical assistance. 

•  EU investment: Concessional finance through grants and blending with IFIs. 

Activities  to  Outputs:  National  and  promoter  resources  focus  on  improving  waste  and  wastewater 
management policies and practices, supported by EU's policy dialogue, technical assistance, and financing. 
This results in outputs like the timely review of Chapter 27, increased political commitment, and transposition 
of EU directives. Enhanced capacity among promoters ensures sustainable project implementation. 

Outputs to Outcomes: Improved policies and practices lead to: 

•  Greater social and political support for Chapter 27 

• 

Increased access to water and wastewater services 

•  Better environmental conditions 

•  Reduced health risks 

•  Enhanced performance of duty bearers in respecting gender and human rights 

Outcomes to Impact: Long-term outcomes include advanced EU enlargement prospects, improved health, 
better ecosystems, increased climate resilience, and enhanced economic activity. These contribute to achieving 
the Sustainable Development Goal (SDGs), particularly SDGs 1, 3, 6, 11, 12, 13, 14, and 15. 

Drivers: Key drivers include EU environment and climate policies, the Economic and Investment Plan (EIP), 
EU enlargement policy, and the Green Agenda for the Western Balkans. These provide resources, guidance, 
and commitment for waste and wastewater management, reflecting strong citizen and political support. 

Assumptions: Main assumptions5 are: 

•  Valid needs analysis for Chapter 27 

•  Timely capacity development 

•  Availability of promoter and IFI finance. 

•  Donor coordination around Chapter 27 

•  Stability without geopolitical conflicts or financial crises 

•  Continued political commitment to enlargement and Chapter 27 

•  Positive citizen perceptions on enlargement 

•  Financial sustainability of projects 

5The assumptions were reconstructed based on EU strategies, progress reports, and interviews with EU delegations in the Western Balkan countries. 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
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4.  FINDINGS 

This chapter presents findings for the evaluation questions, organised into five clusters: strategic relevance, 
results,  cross-cutting  aspects,  sustainability,  and  cooperation  approach  (as  in  Table  1).  Volume  2  of  the 
evaluation report (Annexes) offers more detailed information, with further explanations and evidence at the 
evaluation question level (Annex 5) and judgement criteria level (Annex 6).  

4.1.  Strategic Relevance  

The  national  waste  and  wastewater  policies/  strategies  in  support  of  Chapter  27  reflected  partner 
country  needs  and  the  ambition  to  implement  EU  waste  and  wastewater  Acquis.  The  waste  and 
wastewater policies and strategies of the Western Balkan partner countries were based on a solid assessment 
of the current needs of the sectors. The national strategies were supported by technical assistance from the EU 
and others such as GIZ and EBRD. They were also informed by strategic environmental assessment studies 
and public consultations. Other organizations' reports, such as the UNECE 3rd Environmental Performance 
Reviews,  confirm  the  needs  assessed  in  these  strategies.  Examples  of  the  national  strategies  within  waste 
management  include:  Albania's  waste  strategy  which  focuses  on  expanding  waste  collection  services, 
eliminating illegal dumpsites, promoting recycling, and transitioning to a circular economy; Kosovo's new 
strategy  (2021-2030)  which  aims  to  improve  waste  management  infrastructure,  enhance  capacities,  and 
transition to a circular economy and; Serbia's Waste Management Programme (2022-2031) which  targets full 
compliance with EU waste laws, strengthening administrative capacities, and sustainable financing. Within 
wastewater treatment the strategies include Albania’s draft 2020-2030 National Wastewater Strategy  which 
addresses infrastructure challenges and low investment levels. Kosovo's National Water Strategy 2017-2036 
which emphasises treating wastewater and regulating industrial discharges and Serbia's Water Management 
Strategy which highlights the need for improved sewerage networks and wastewater treatment plants. At the 
policy and legal level there are also examples, such as in Serbia, where a new water law and a national water 
sector  reform  process  were  underway,  aligning  broadly  with  the  EU  waste  and  wastewater  Acquis.  In 
Montenegro,  a  new  waste  law  was  adopted  in  response  to  EU  waste Acquis  ready  in  the  Parliament  of 
Montenegro in April 2024. IPA II supported waste studies and legal  framework assessments in Bosnia and 
Herzegovina where the EU advocated for and facilitated the development of the Environmental Approximation 
Strategy. Directive Specific Implementation Plans (DSIPs) were developed to aid implementation.  

National  policy, programming and planning documents did not fully recognise the political economy 
and other institutional obstacles to achieving meaningful changes. All of the partner countries to varying 
degrees  are  affected  by  slow  administration  and  investment  decisions  based  on  political  factors.  In  North 
Macedonia, for instance, the policies and strategies reflect the technical needs but do not fully recognise the 
political economy (for example, policy inconsistency and uncertainty resulting from political obstructions and 
competing interests at national and local levels) and other obstacles to be faced. The national programmes and 
plans  in  Bosnia  and  Herzegovina  outlined  regulatory,  institutional,  and  financial  improvements,  including 
capacity building, to ensure the operational and financial viability of water services but they did not sufficiently 
address political economy risks such as administrative delays influenced by political factors and bureaucratic 
inefficiencies. Over time, the policy and programming became more realistic. For example, in Kosovo, the 
previous waste strategy lacked some important elements, such as recycling targets, reduction of the waste flow 
to  landfills,  adoption  of  a  transition  period,  improvement  in  regional  inter-municipal  cooperation,  and 
strengthening of the institutional framework which are now being introduced in the new amended strategy as 
per the requirements of the Acquis.  

The EU support programmes reflected EU policy and were aligned to the partner countries’ policies and 
strategies as they evolved. The EU supported programmes aimed at transposing and implementing the waste 
and  wastewater Acquis. An  increasing  focus  was  put  on  waste  reduction,  separation,  and  recycling  and  in 
Kosovo and North Macedonia, for example, there were projects promoting Extended Producer Responsibility 
(under  #C-383609).  Across  the  region,  wastewater  activities  included  expanded  sewerage  networks, 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
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15 

 
 
Wastewater  Treatment  Plant  (WWTP)  construction,  and  improved  wastewater  utilities  performance.  The 
European Commission (EC) Progress Reports and IPA documents for the waste and wastewater management 
sub-chapter under Chapter 27 of the Acquis were prepared based on the information gathered on the current 
situation and dynamics in the partner countries' efforts.  

EU support projects were complementary, built upon each other, exploited synergies with other projects 
and avoided contradictions, overlapping and duplication. The EU support programmes were developed in 
a sequence. In Albania, for example, the IPA 2018 action was built on IPA 2016, while the IPA 2016 programme 
itself capitalized on the experience built through previous IPA-supported interventions in the sector. In BiH, 
the “WATSAN Federation programme” was built upon the findings of the Technical Assistance (TA) carried 
out  under  two  previous  Infrastructure  Project  Facility  (IPF)  contracts  (IPF2  and  IPF3).  In  Serbia,  Project 
Preparation Facility PPF-6, PPF-7, and PPF-8 were implemented by two companies under the same contractor 
consortium (alternating the leading company in the consortium). Contractors of the 3 parallel ongoing PPF 
actions obtained synergies in the use of their resources by sharing the short-term experts. Good synergies in 
terms  of  expert  involvement,  lessons  learned,  sharing  of  project  implementation  data,  logistics,  and 
backstopping were achieved between all three PPF Actions. The planning and monitoring procedures avoided 
project contradictions, overlap and duplication. 

Partner countries were consulted, and their active involvement in programming improved over time. 
Sector working groups, comprising representatives from ministries and civil society, provided input during 
programming consultations in all partner countries. Civil society engagement was extensive, with over 250 
organisations involved in North Macedonia alone. Stakeholder input, including written submissions, informed 
document revisions to the extent possible. Involvement and performance of the partner countries’ stakeholders 
in the policy/ programming dialogue have improved over time also due to capacity-building efforts, although 
staff turnover and integration fatigue posed challenges. In Serbia, highlighting an improvement in consultation, 
it was noted “now the project no longer starts by being presented with the contract.” However, the quality of 
dialogue and engagement was influenced by participants' professional level and by political factors. Capacity-
building  projects  for  stakeholders,  including  public  administration,  utility  companies,  and  Civil  Society 
Organisations (CSOs) were effective in enhancing collaboration and effectiveness in dialogues, influencing 
sector support adjustments under IPA III in Serbia, Montenegro, and BiH. Efforts were made under an IPA III 
project  to  reinforce  coordination  and  consultation  mechanisms  through  inclusive  approaches  involving 
government representatives, non-government stakeholders, academia, and donors. However, the field visits 
revealed frequent staff turnover during the evaluation period (e.g. in Montenegro and Kosovo environmental 
administration),  lack  of  full  stakeholders’  ownership  of  the  process  (e.g.  in  North  Macedonia)  and  limited 
knowledge and practical experience with the evolving waste and wastewater Acquis. These, combined with 
fatigue with the EU requirements (e.g. in BiH) affected the quality of the dialogue. The field visits revealed 
that civil society organisations in the waste and wastewater sector are still weak and  "unable to act as the 
watchdog or the corrector of government policy” (e.g. in Kosovo) or their involvement has slightly declined 
lately” (e.g. in Albania). 

The  value  of  the  EU’s  support  was  primarily  in  the  guidance  and  financing  provided  for  the 
transposition of the waste and wastewater Acquis. The partner countries continued transposing the waste 
Acquis,  including  the  Waste  Framework  Directive,  Single-Use  Plastics  Directive,  and  Urban  Wastewater 
Treatment  Directive.  They  rely  heavily  on  EU/international  support  for  capital  investments  due  to  low 
domestic financial capacity. The WB partner countries use the Classification of the Functions of Government 
(COFOG) for public expenditure, with figures consistently below the EU average of 0.8% of GDP. In Albania 
(2016-2022), Public Environmental Expenditure ranged from 0.09% (2018) to 0.34% (2022). Kosovo's 2016 
expenditure was 0.3%. In BiH (2020), the expenditure was insignificant. Serbia's environmental protection 
spending is a third of comparable Central and Eastern European countries. Low tariffs and affordability issues 
result in underbudgeting and reliance on external support, with many rural areas lacking waste and wastewater 
services. Illegal dumpsites and non-compliant landfills remain prevalent, with low landfill fees and low safe 

16 

 
 
 
disposal rates (often below 25%). While EU Acquis has heavy investment requirements, state and municipal 
budgets are insufficient, keeping the partner  countries far from compliance. Some progress includes North 
Macedonia's producer-financed waste stream investments and IPA co-financing, Serbia's co-financed Krusevac 
WWTP, Albania's state-funded pipelines and recent seasonal financing for coastal municipalities, and Kosovo's 
government co-financing an EU project by 50%. 

4.2.  Results  

The findings in this section are based on an in-depth analysis of the perspectives, opinions, and interests of 
different stakeholder groups (see Section 2.2, Table 3).  

During  most  of  the  period  from  2016  to  2022,  the  environment  was  not  a priority for the  WBIF,  as 
priorities were primarily set by the Western Balkan countries themselves. There were only two large-
scale wastewater projects (and no waste management projects) supported by EU investment grants. In 
the  period  2016-2022,  there  were  only  two  major  wastewater  infrastructure  projects  supported  by  EU 
investment grants through WBIF mainly due to the lack of explicit EU strategic priorities until the introduction 
of the 2020 Green Agenda for the Western Balkans. Prior to that, EU support in the region was largely guided 
by Chapter 27 (Environment) of the EU accession process, with priorities set on a country-by-country basis 
reflecting the demand-driven nature of the support.6 During this period, the demand was for connectivity and 
energy, which is why the WBIF’s focus was on these areas – for example, in 2015, the European Commission 
set aside up to €1 billion in grants until 2020, from  IPA, to support the connectivity agenda and the 2020 
connectivity package included six projects in the areas of sustainable transport and clean energy7.  With the 
2020 Green Agenda and the new programming starting in 2021, the EU now provides both technical assistance 
and investment grants. Waste and wastewater projects were complex, often of long duration and  subject to 
delays.  None of  the  projects initiated  from  2016  onwards  have been  completed.  Only  six out  of the  wider 
sample of 19 WBIF infrastructure projects involving EU and bilateral donors’ grants have been completed 
since 2009 – all these projects started before 2016.All of the completed projects were wastewater treatment, 
and none were waste management. The average duration from the start of the project to completion was just 
under eight years. This duration is typical of the sector as confirmed by other evaluations. Project workplans 
were  often  unrealistically  optimistic  and  tended  to  overlook  partner  capacity  and  the  institutional  context. 
There were cases of very long delays and in the case of North Macedonia this led to significant decommitments 
(Euro 80m for combined transport and environment sector, with most in the environment sector). In Bosnia 
and Herzegovina projects were significantly delayed due to the country’s complex institutional set-up that was 
unable  to  respond  with  the  flexibility  to  make  the  changes  needed  and  amend  contracts  to  ensure  timely 
completion of projects. For the same reasons, the administration and implementation of IPA grants (IPA 2018) 
faced severe delays, jeopardising implementation across all municipalities participating in the FBIH WATSAN 
programme.  Not  all  projects  were  delayed.  Where  there  was  strong  ownership  combined  with  highly 
professional project management the projects were completed on time (examples in Serbia (Kruševac) and 
North Macedonia (Kichevo). The presence of supportive IFIs involving pre- and post-project support, skilled 
Project Implementation Unit support, along with a good working relationship between the municipality and 
the public utility corporation were crucial factors as was the level of ownership and political engagement both 
at central and municipal level. The Kruševac WWTP was part of the Serbia VI wastewater programme, which 
follows  a  programmatic,  multiphase,  performance-based  approach  structured  into  two  main  phases:  (1) 
technical  documentation  and  capacity-building  activities  to  support  municipalities  in  meeting  specific 
performance  and  capacity  standards  prior  to  direct  investment,  and  (2)  direct  investments,  including  the 
construction of treatment plants and upgrading of sewer systems. 

6 Evaluation of the EU’s support to climate action and environment in Enlargement and Neighbourhood regions 
7 https://www.wbif.eu/sectors/connectivity-agenda 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

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The  delivery  of  results  was  seriously  delayed  due  to  a  combination  of  inherent  weaknesses  in  the 
implementing  beneficiary  organisations,  state  bureaucracy,  and  Covid-19.  None  of  the  wastewater  or 
waste management infrastructure projects supported by EU grants through the WBIF from 2016 onwards have 
been completed. Nevertheless, the evaluation supported by evidence in the field found that the projects are 
likely to deliver on the physical outputs, albeit with some longer-than-average delays caused by Covid-19, 
insufficient capacity of implementing organisations and the issues mentioned above. Projects that began well 
before 2016 and are complete also experienced significant implementation delays due to weak capacities of 
the implementing organisations in managing complex and large infrastructure investments. Across the region, 
addressing project management capacity gaps was either limited in scope or came at a later stage. For instance, 
in Montenegro, the beneficiary in Pljevlja (WBIF #PRJ-MNE-ENV-020) was initially under-capacitated but 
showed better performance in the second phase of the wastewater investment due to improved TA support and 
better  collaboration  with  TA  providers.  However,  a  challenge  to  providing  capacity  development  to 
implementing agencies at the local level was that they were only likely to be involved in a single project and 
thus building capacity for one project would have had little long-term benefit and may even have added to 
delays during project implementation. Some recent projects have given more weight to longer-term capacity 
development  –  for  example,  the  EUSWAM  project  in  Albania  (#C-393193)  is  a  dedicated  capacity 
development project that works through an association of public utilities and thus anchors capacity nationally. 
The project supported six utilities for a few years after construction working both at municipal level and with 
regulatory body, the association of public utilities and the ministry of environment. In addition to local capacity 
issues, inefficiencies in public administrations also caused delays. In BiH, delays were partly due to low local 
capacities but were largely attributed to inefficiencies in the public administration of IPA funds and political 
factors affecting supervision contracts. The country’s institutional set-up was slow and an under-capacitated 
administration and a lack of political will to move things forward were among the main causes of significant 
delays  in  wastewater  projects.  As  one  local  government  official  noted:  “The  implementation  and 
administration of IPA funds have been problematic – it led to significant delays and issues with contractors 
stopping construction works and demanding late payment interest.” Covid-19 led to delays in many of the 
projects started after 2016 as it affected key consultation and planning phases.  

The successful implementation and results of wastewater projects heavily depended on a) realistic step-
by-step project planning, and b) ownership and good management by the utilities. Successful wastewater 
treatment projects tended to demonstrate integrated end-to-end8 planning (where the project was coherently 
managed from start to finish continuously). They recognised the importance of a fully functioning sewerage 
system to ensure adequate sewage flow to new treatment facilities and the significance of sludge treatment and 
disposal. Several projects struggled to deliver adequate sewage to the new treatment facility. For example, in 
BiH,  the  state-of-the-art WWTPs in Mostar  and  Široki  Brijeg  were  not  sufficiently  connected to  sewerage 
networks  meaning  that  there  is  unlikely  to  be  sufficient  sewage  to  justify  the  plant  without  additional 
investment in the network. Similarly, a field visit to Montenegro (Pljevlja municipality) found that a lack of 
comprehensive preparation and proper sequencing in wastewater infrastructure investments in water treatment 
and  sewerage  network  compromised  the  likely  environmental  results  that  will  be  achieved.  Project 
management planning often did not consider constraints such as land issues and realistic scheduling, which 
hampered project implementation as the project team struggled to meet unrealistic deadlines; most plans and 
schedules were optimistic. Additionally, project planning failed to ensure robust operation and maintenance 
capacity, including financial and human resources. Where implementation was successful this was linked to 
active and committed implementing agencies with strong project ownership and comprehensive consultancy 
support. In North Macedonia, field visits revealed that good management of the public utility company and a 
supportive municipality were key factors for success in the case of the Kichevo wastewater treatment project, 
probably the most successful in North Macedonia. Similarly, in Serbia (Kruševac WWTP), active involvement 

8Comprehensive technical assistance aimed at capacity building and sustainability – including project management capacity building and institutional 
support prior to implementation, as well as post-project support in terms of operation and maintenance. 

18 

 
 
 
 
from  the  IF  (KfW),  the  beneficiary  and  a  TA  consultant  helped  overcome  systemic  problems  like  land 
acquisition, highlighting the importance of project ownership. Ownership and the origination of the Subotica 
waste  management  project  in  Serbia  by  the  7  municipalities  prior  to  EU  involvement  was  crucial  for  the 
ultimate success of that project, along with  a strong collaboration between the municipality and the public 
utility corporation. However, the WBIF (within waste and wastewater) and IPA processes made end-to-end 
project  development  difficult  for  the  waste  management  and  wastewater  treatment  sub-sectors.  Strong 
ownership and management by the Public Utility Company (PUC) were challenging to evaluate in advance 
and were generally not sufficiently major criteria in project selection. 

Waste management initiatives had a stronger policy and capacity development component, with some 
partner  countries  placing  significant  emphasis  on  enhancing  the  legal  framework  within  the  sector. 
Waste management projects were, in many cases, explicitly designed to facilitate transformation and systemic 
shifts.  Some  of these  projects included a  policy  component, particularly  in  areas  governing the collection, 
transport, and disposal of municipal solid waste. In Kosovo, for instance, the EU had a significant programme 
implementing  the  legal  framework  for  municipal  waste  management  at  the  local  level.  In  Bosnia  and 
Herzegovina, support under IPA II focused on conducting waste studies and legal framework assessments. 
This aimed to prepare the sector for infrastructure investments and evaluate the potential for circular economy 
principles.  In  Montenegro,  the  emphasis  was  on  policy  development  to  prepare  the  sector  for  significant 
infrastructure investments - the EU strongly advocated for a new waste law, facilitating the development of 
this legislation and associated waste management plans. It is too early to judge whether these interventions 
will  achieve  the  expected  policy  results.  Waste  management  projects  recognised  capacity  development  as 
crucial and offered a wide range of capacity-building initiatives. These addressed not only the technical aspects 
of solid waste management, extended producer responsibility (EPR) schemes (such as the twinning programme 
in North Macedonia), and waste electronics but also softer skills like financial, budget, and business planning. 
The Support to Waste Management Services in Kosovo (#C-413041), for instance, was a flagship project that 
provided extensive training initiatives to enhance waste management operations nationwide.  

The majority of wastewater projects focused on infrastructure rather than trying to address wider policy 
issues or develop capacity. The log frames in the Annual Action Plans, in particular the target outputs, give a 
good  indication  of  the  projects’  focus  on  physical  infrastructure.  Delivering  improved  wastewater 
infrastructure will, of course, be a major policy contribution to compliance with EU standards and this has 
likely driven the focus on infrastructure. However, the annual Enlargement Progress Reports made it clear that 
many  of  the  agreed  policy  developments  were  still  outstanding.  Underestimated  needs  for  capacity 
development for the effective management of complex infrastructure projects was an evident problem. The 
lessons learnt section of the annual action documents clearly recognised the need for capacity development to 
strengthen capacity at all levels in project identification, development, and implementation in order to reduce 
delays and bottlenecks (and to reduce the associated cost increases). This capacity gap was in three main areas: 
technical skills, coordination across stakeholders (in particular related to land acquisition issues), and project 
management.  

The results in the waste sector varied – there were cases of both successful and less successful capacity 
development and policy initiatives. Over its three-year duration, the Support to Waste Management Services 
project in Kosovo (#C-413041) conducted diverse training and capacity-building activities. These ranged from 
coaching  expert trainers at  the  Kosovo  Institute for  Public Administration  to  working  with  informal  waste 
pickers.  Some  of  these  efforts  led  to  tangible  outcomes;  for  instance,  in  Kosovo,  waste  collection  rates 
increased to nearly 90%, and over 1,000 illegal dumpsites were closed using procedures and training provided 
by  the  project.  Despite  this,  most  waste  collection  equipment  in  Kosovo  remained  in  poor  repair,  and  the 
sanitary landfills were still not compliant with the EU Waste Directive. The Extended Producer Responsibility 
project in North Macedonia was much needed, performing as best it can under very challenging conditions – 
it faced challenges, such as the difficulty in traceability of the waste, but there was also promising progress 
and  buy-in  from  the  municipality  and  others.  The  2014  integrated  solid  waste  management  system 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

19 

 
 
implemented  in  Mostar  (BiH)  by  the  EU  and  World  Bank  (#C-271148)  was  not  working  properly.  The 
recycling  facility  only  managed  to  recover  3.2%  of  the  waste  stream,  meaning  that  the  waste  flow  to  the 
sanitary landfill was much higher than planned, greatly shortening the lifespan of the landfill cell. Hence, the 
project’s aspiration of contributing to improved waste in Mostar and its surrounding municipalities was not 
achieved due to deep-seated local complexities that were outside of the project’s scope. Strong ownership and 
a  close  collaboration  between  seven  municipalities  led  to  excellent  results  for  the  Subotica  (Serbia)  waste 
management project (#C-394045). Nevertheless, meeting EU standards generally remained challenging for 
waste management services across these partner countries, indicating a considerable distance to traverse before 
policy translates into practice. Towards the end of IPA II and as part of IPA III, efforts were undertaken to 
advance  circular  economy  policies,  encompassing  the  management  of  waste  electronics  and  electrical 
equipment,  construction  and  demolition  waste,  and  end-of-life  vehicles,  although  these  initiatives  are  still 
predominantly in the developmental stage. 

There were notable successes in the EU's policy dialogue efforts. In Serbia, a new water law and a national 
water  sector  reform process  are  underway, aligning  broadly  with the  EU  waste and  wastewater Acquis. In 
Montenegro,  a  new  waste  law,  developed  in  response  to  EU  waste Acquis,  was  recently  adopted  in  the 
Parliament of Montenegro. This new legislation will pave the way for the development of a national waste 
management plan, expected to provide a conducive framework for large-scale infrastructure investments. In 
Bosnia  and  Herzegovina,  the  EU  advocated  for  and  facilitated  the  development  of  the  Environmental 
Approximation Strategy, a prerequisite for IPA II support. Currently, an Agglomeration Master Plan is being 
developed alongside DSIPs, addressing a recognised need in the water sector. IPA II support in the waste sector 
focused  on  waste  studies  and  legal  framework  assessments  to  prepare  for  infrastructure  investments  and 
explore circular economy principles. In Bosnia and Herzegovina, in support of the accession agenda, concepts 
were  developed  and  adopted  as  programmatic  documents  in  2022,  aimed  at  enhancing  water  services  and 
utilising anticipated financial and technical assistance. Based on the programmes’ action plans, water service 
laws  are  being  prepared  in  both  entities  to  legally  regulate  the  provision  of  water  services  in  a  new  and 
sustainable manner, specifying the rights and obligations of local government units and utility companies, as 
well as their competencies and responsibilities in providing water services. The laws will, inter alia, define 
tariff methodologies. 

Although  EU  accession,  sector  reforms  and  transition  were  among  the  ultimate  objectives  and  the 
national governments were increasingly aware of the needs, the progress towards these aims has been 
limited  in  terms  of  policy  implementation.  The  national  governments  have  largely  adopted  many  of  the 
policies and strategies needed to comply with Chapter 27 and various waste-related directives. It was evident 
that in all six partner countries, EU-supported initiatives were in line with EU directives on wastewater and 
waste management, aligned with Chapter 27 and environmental sector reforms. However, the implementation 
of  difficult  and  politically  costly  reforms  has  not  advanced  as  much  in  practice.  According  to  the  EU 
Enlargement Progress Reports for 2022, all six partner countries still face challenges. For wastewater, a key 
issue  has  been  setting  cost-reflective  tariffs,  which  was  difficult  for  politicians  since  raising  costs  was 
unpopular with voters. Further hindering rate increases was the lack of perceptible improvements in service 
delivery, which made it hard to justify higher water fees. In the waste management sector, illegal and temporary 
waste disposal was common, and much of the generated waste did not reach EU-compliant sanitary landfills 
even where these existed. Generally, adherence to environmental impact assessment requirements was weak 
in terms of standards for effluent discharge, landfill gas collection and treatment, and a daily soil cover, and 
there was still a need to close non-compliant dumpsites and increase investments in waste reduction, source 
separation,  and  recycling.  Field  visits  revealed  that  all  partner  countries  faced  challenges  in  meeting  EU 
Directive standards for the entire waste management cycle, from waste avoidance through to proper disposal. 
Waste  was  often  not  source-separated  due  to  a  lack of  bins  or  citizen  participation.  Remote  areas  avoided 
transporting waste to sanitary landfills to save costs, leading to local dumping. Existing disposal sites lacked 
proper leachate treatment, landfill gas collection, and environmental measures. Regional materials recovery 
facilities  received  poorly  sorted  materials  and  performed  below  targets.  Consequently,  achieving  a 

20 

 
 
 
comprehensive circular economy and effective waste management remains a distant goal despite significant 
efforts.  Nonetheless,  there  was  confirmation  that  governments  had  acknowledged  and  understood  the 
complexities and potential advantages of both wastewater and waste management sectors as part of their efforts 
to  comply  with  EU  standards.  This  is  an  encouraging  development,  although  it  falls  short  in  terms  of 
implementing reforms and accelerating progress toward EU accession. 

While both wastewater and waste management projects are likely to contribute to wider environmental 
benefits and long-term socio-economic effects, the scale of national initiatives and EU intervention is 
minor compared to the needs, and significant challenges remain. The EU accession criteria, Chapter 27, 
and the new focus on the circular economy have increased attention to environmental and climate benefits. 
The EU’s wastewater and waste management projects in the Western Balkans aimed to  contribute to these 
objectives. Wastewater projects primarily focussed on improving river quality through wastewater collection 
and  treatment.  These  interventions  have  the  potential  to  improve  cleanliness  and  living  conditions  in 
beneficiary communities. However, wider socio-economic benefits take time to materialise, as reducing river 
pollution requires sustained effort across entire river basins and cross-sectoral collaboration as, for example, 
river quality is also dependent on other sectors such as agriculture. The evidence of these wider environmental 
and socio-economic benefits being achieved was limited because the projects that started in the period 2016 
to 2022 were not mature, or in many cases, even completed. Even for those that started long before 2016 it 
was too early for tangible or measurable beneficial effects. For instance, in Uskoplje municipality in Bosnia 
and Herzegovina, there were no transformative effects, as the installed sewage collection system was not yet 
connected to a wastewater treatment plant, and the raw sewage was therefore discharged directly to the Vrbas 
River without treatment. Elsewhere in Bosnia and Herzegovina, in both Mostar and Široki Brijeg, sewage is 
collected, or will be, from less than 50% of the households, due to incomplete infrastructure. This means that 
it will be difficult to measure a significant improvement in the local river water quality even though some of 
the necessary infrastructure has been or will soon be put into place. Similar issues were observed at the Pljevlja 
wastewater treatment plant in Montenegro but deficiencies and oversights in earlier phases of the project in 
Pljevlja were recognised by the EU and partners, and a new phase of the project is now underway to implement 
improvement works to ensure optimal operation of the sewerage system and the WWTP. In this new phase, 
IPF  consultants  (IPF10)  have  been  engaged  to  update  the  feasibility  study,  detailed  design,  and  tender 
documentation. 

The direct impact of EU-supported wastewater and waste management projects was also limited due to the 
small scale of investments relative to national needs. For example, the 12 wastewater projects initiated since 
2016 will serve 2.4 million people out of a regional population of nearly 18 million. The number of operational 
sanitary landfills, even with EU support, meets only a fraction of the needs, and they receive only a small 
proportion of generated waste. Kosovo has seen the most comprehensive waste management improvements in 
the Western Balkans over the past twenty years. All the country’s regions now have regional sanitary landfills, 
and most waste is collected. As a result, Kosovo is significantly cleaner than it was two decades ago, with no 
more plastic bags littering the landscape or dumpsites outside villages. While this is a promising example of 
wider benefits, it strongly indicates the time needed for change. Across the region, achieving broader systemic 
changes requires a more comprehensive approach and greater engagement with the private sector and civil 
society. Opportunities for such approaches exist through the Green Agenda for the Western Balkans (GAWB) 
and the new directions of IPA III. 

The  transformation  of  both  wastewater  and  waste  management  sectors  was  mainly  hindered  by  the 
partner countries' absorption capacities. Despite being far below the sectors' needs, the interventions were 
ambitious  in  that  they  were  not  optimised  and  aligned  with  the  partner  countries'  absorption  capacities. 
Examples  include  the  WATSAN  programme  in  BiH,  Pljevlja  WWTP  in  Montenegro,  long  delays  and 
significant commitments in North Macedonia, as noted earlier. In all partner countries, the needs in terms of 
financial,  human,  and  technical  resources  far  exceed  current  interventions.  However,  the  weak  absorption 
capacity called for a targeted and phased approach to investment, aiming for an ambition level that aligns with 
the  country's  absorption  capacity  to  ensure  optimal  utilisation  of  resources.  Most  of  the  challenges  in 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
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21 

 
 
transforming  the  wastewater  and  waste management sectors  to achieve  broader benefits  lie in the national 
environment and were beyond the direct reach of EU cooperation, at least at a technical level. For example, as 
noted in  the Annual Action  Programme for  Bosnia  and  Herzegovina  (2018):  “There  have been substantial 
delays  in  absorbing  EU  funds  in  the  environment  sector,  primarily  due  to  insufficient  administrative  and 
professional capacity”. The lack of counterpart absorption capacity was evident in most projects. 

Results monitoring in wastewater projects was focussed on tangible outputs with less emphasis on the 
result’s logic and the wider level impacts. The results frameworks/log frames focus on the direct outputs of 
new  sewers  and  new  wastewater treatment  plants  but  are  less  clear  on  a) important  related  outputs;  b) the 
overall intervention logic and in particular indicators for higher-level impacts; and c) how to monitor the future 
results. Important related outputs include items such as industrial wastewater which may need pre-treatment 
by industries before discharge to public sewers; sludge treatment and disposal, which can be a serious problem; 
and how households will be connected to the new sewers and who will pay the cost of making connections. 
The definition, logic, and measurement of achieving higher-level impacts such as the improved water quality 
of receiving waters arising from the EU-supported projects was a challenge and was generally not reported on 
in part because there were many sources of pollution beyond the individual wastewater projects.  

The  evaluation  did  not  identify  any  unintended  or  unexpected  results  beyond  those  associated  with 
weaknesses in project design and implementation, as discussed in this Chapter. 

4.3.  Crosscutting aspects 

eight 

frame 

Crosscutting  themes  were  taken  into  account  in  annual  partner  country  programming  for  the 
environment  but,  except  for  climate,  they  were  often  not  reflected  in  the  log  frames.  The  reviewed 
programme documents generally discussed climate, gender, and human rights issues at partner country level 
and  their  integration  into  the  EU  support.  However,  gender  and  human  rights  considerations  were  not 
consistently  incorporated 
into  programme-level  log 
Gender 
frames. 
considerations were rarely 
into  concrete 
translated 
indicators 
log 
although more so in waste 
management 
than 
wastewater programming. 
waste 
Of 
management 
programmes, 
gender 
compared to one out of eight urban wastewater programmes. The reviewed programmes briefly touched on 
human  rights,  with  a  particular  focus  on  vulnerable  groups  such  as  the  Roma  and  Egyptian  communities. 
Whilst  there  was  a  commitment  to  implementing  projects  in line  with  good  governance  and  human  rights 
principles, no human rights-related indicators were explicitly integrated into programme log frames. It was 
assumed  that  measures  would  be  taken  during  implementation  to  address  equal  participation  and  non-
discrimination.  Some  programmes  addressed  socio-economic  inequalities  and  vulnerabilities  related  to 
sanitation and clean water access, but the examination of human rights through the lens of PANEL9 principles 
was inconsistent, except for occasional mentions of equal participation and non-discrimination. On the climate 
front, climate contexts were, for the most part, adequately researched, and climate was put as a principal (Rio 
Marker 2) or significant (Rio Marker 1) objective in many cases, addressing both adaptation and mitigation. 
Five out of eight waste management programmes considered climate action as a significant objective and six 

FIGURE 11: MAINSTREAMING CROSSCUTTING THEMES: INTEGRATED INDICATORS AND TARGETS IN IPA 
ANNUAL ACTION PROGRAMMES/PLANS (N=8) 

four  had 
indicators, 

9 Participation, Accountability, Non-Discrimination, Empowerment and Legality 

22 

 
 
 
 
 
 
in total defined climate-relevant indicators and targets, covering aspects like the circular economy, EU climate 
legislation in waste management, energy efficiency, etc. In urban wastewater programming, six out of eight 
programmes  designated  climate  as  a  significant  or  principal  objective,  establishing  pathways  for  climate 
action, including for energy efficiency, alignment with EU climate legislation, climate-resilient infrastructure 
development, and greenhouse gas emission reduction. 

Gender mainstreaming at project level was generally weak, but it was more prominent within WBIF-
provided IPA grants (WBIF projects hereafter), with a focus on increasing women's participation in 
decision-making. Among the 23 project log frames that were reviewed, only six incorporated gender-relevant 
indicators10 and targets. Among these, two were associated with waste management, both emphasizing strong 
circular economy aspects. For example, the integrated waste management and circular economy project in 
Kosovo (#C-413041) outlined two gender-relevant outputs, while a WBIF project focusing on regional waste 
management in North Macedonia (WBIF #PRJ-MKD-ENV-012) integrated a specific component aimed at 
promoting gender equality within the solid waste sector. The remaining four projects with a pathway toward 
gender impact were WBIF urban wastewater infrastructure projects. These four projects featured indicators 
and targets focused on increasing women's participation in decision-making processes.  

While  attention  to  gender  in  IPA  programming  increased  with  time,  it  was  not  consistently  applied 
throughout the project cycle. The data regarding waste management programmes suggested an increase in 
gender  mainstreaming  between  2016  and  2022.  Notably,  most  programmes  with  gender  indicators  were 
developed in 2021, aligning with the EU Gender Action Plan III (2021-2025). Programmes without gender 
indicators were primarily developed before 2021. In the case of IPA urban wastewater projects, a possible shift 
was  observed,  with  one  from  2012 in  Bosnia  and  Herzegovina  (WWTP  in  Mostar,  #C-311097) excluding 
gender considerations and another from 2019 in Albania (EUSWAM, # C-393193) actively working towards 
a  gender  equality  agenda,  potentially  indicating  enhanced  gender  consideration  in  IPA  bilateral  urban 
wastewater  projects.  While  these  examples  all  point  to  more  attention  to  gender  in  recent  years  of  IPA 
programming, the evidence collected in the field pointed to weak implementation of programmatic and project 
commitments. For example, it was noted in Serbia, Montenegro, and BiH, that gender mainstreaming at project 
level was pro-forma guesswork and a box-ticking exercise, especially in WBIF-supported projects through the 
grant application forms (GAFs). The ambition to enhance gender activity at the project level lacked meaningful 
requests  to  partners  for  integrating  these  aspects  throughout  the  project  cycle.  The  ambition  was  also  not 
supported by necessary guidance and capacity-building initiatives. As one interlocutor put the opinion shared 
by many: “What we need are meaningful requests, supported by guidance and capacity; what we certainly do 
not need are artificial demands“. Indeed, across the Western Balkan partner countries, it was confirmed that 
gender  mainstreaming  was  poor  at  the  project  level,  with  gender  targets  and  the  potential  for  gender 
contribution often not well thought out. Gender results were reported only in a few instances, mainly focusing 
on increased women's participation in decision-making or equal participation of men and women in project 
activities. However, these reports often lacked sufficient detail on the opportunities and challenges for gender 
integration, thereby limiting the learning potential. In some cases, gender contribution  was underestimated, 
such as in a waste project in Serbia (C-347344). Although gender was not initially part of the project design, 
the project led to increased women's employment in waste sorting at the facility, highlighting the potential for 
gender mainstreaming in waste management projects. 

10Gender disaggregated data and gender responsive capacity building. 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

23 

 
 
 
 
 
 
a 

included 

Overall, WBIF-provided IPA grants for waste management and wastewater treatment exhibited more 
attention to the crosscutting themes at the design stage compared to IPA bilateral projects. Among the 
six  gender-targeted  projects,  five  were  WBIF  infrastructure  projects  led  by  the  WBIF  partner  financial 
institutions. However, only one out of these five projects were in the waste sector. Out of the 12 IPA bilateral 
projects managed directly by the EU, only one incorporated gender-relevant indicators. In some cases, gender 
was not recognised as a concern within the sector (e.g., #C-383743), while in others, it was primarily viewed 
through the lens of equal opportunities for both 
women and men to engage in project activities 
(e.g., #C-410938; #C-418296). Interestingly, an 
IPA project related to solid waste management 
in Albania was considered gender-neutral (#C-
393193),  whereas  a  similar  WBIF  project  in 
North  Macedonia 
specific 
component  dedicated  to  promoting  gender 
equality  within  the  solid  waste  sector  (WBIF 
Furthermore, 
#PRJ-MKD-ENV-012). 
compared  to  other  projects,  WBIF  waste 
management 
greater 
consideration  for  human  rights  during  the 
design  phase.  Three  out  of  four  reviewed 
projects  acknowledged 
importance  of 
ensuring equitable access to and fair distribution of project benefits. For instance, a waste management project 
in  Albania  (WBIF  #PRJ-ALB-ENV-013)  focused  on  establishing  socially  acceptable  tariffs  with  a  special 
emphasis  on  the  Roma  and  Egyptian  communities. Similarly,  the  Bosnia  and  Herzegovina  Regional  Solid 
Waste  Landfill  project  (WBIF  #PRJ-BIH-ENV-016)  planned  mechanisms  for  equitable  access  and  benefit 
distribution. In the climate domain, three out of four WBIF projects integrated climate considerations, while 
only  four  out  of  eight  IPA  bilateral  waste  projects  defined  climate-related  indicators.  Likewise,  all  WBIF 
wastewater projects included climate considerations, with some marked as Rio Marker 1 (denoting climate as 
a principal objective), whereas none of the IPA bilateral wastewater projects integrated climate aspects into 
their log frames. 

FIGURE 12: MAINSTREAMING CROSSCUTTING THEMES: INTEGRATED 
INDICATORS AND TARGETS IN IPA BILATERAL AND WBIF-PROVIDED IPA 
GRANTS 

displayed 

projects 

the 

Climate considerations were better integrated in waste management than wastewater projects, focusing 
on  climate  legislation,  capacities,  energy  efficiency,  and  circular  economy. About  half  of the reviewed 
waste  management  projects  included  climate  change  mitigation  and/or  adaptation  indicators  in  their  log 
frames. These projects aimed to, inter alia, 1) enhance capacities for environmental and climate legislation 
(#C-383743); 2) advance circular economy practices (#C-413041); 3) reduce greenhouse gas emissions (WBIF 
#PRJ-MKD-ENV-012); 4) improve energy efficiency (WBIF #PRJ-KOS-ENV-016); and 5) construct flood 
protection systems (#C-369086). In contrast, climate considerations were mainstreamed into only three out of 
ten urban wastewater projects reviewed for this evaluation. For example, the WATSAN programme in FBiH 
(WBIF #PRJ-BIH-ENV-003) targeted climate impact by reducing the climate risks by climate proofing and 
adapting the project/infrastructure to climate change, as well as energy efficiency by optimisation of existing 
water and wastewater systems and, the introduction of modern telemetry systems for more efficient monitoring 
and control resulting in a reduction in losses, savings in energy and enhanced operating efficiencies. Another 
example  is  addressing  climate  change  impacts  through  urban  drainage  improvements  in  the  wastewater 
treatment plant in Ulcinj, Montenegro (WBIF #PRJ-MNE-ENV-022). 

Climate achievements were not systematically tracked and reported on. The assessment of climate results 
revealed a lack of systemic climate reporting in project progress reports. While some climate-relevant results 
were identified, particularly in the waste sector, there were examples of climate-relevant projects that did not 
report on results in their progress or final reports. For instance, the ISWM project in Albania (#C-383743) 
aimed  to  enhance  capacities  for  environmental  and  climate  legislation,  but  the  direct  connection  between 

24 

 
 
 
 
capacity-building efforts and climate-related capabilities was unclear, and no measurement or reporting of the 
desired impact  on  climate capacities  was  evident.  Similarly, the  Shkodra/Skadar  Lake  area  project  (WBIF 
#PRJ-ALB-ENV-013), despite being marked with Rio Marker 1, did not report climate-relevant results in its 
final  report.  Additionally,  the  EUSWAM  project  in  Albania  (#C-393193)  did  not  report  energy  efficiency 
results  in  its  2021  final  project  report,  despite  its focus  on  optimizing  wastewater  treatment  processes  and 
offering energy-saving recommendations. Likewise, a waste project in Serbia (#C- 394045) had climate high 
on the agenda and achieved good results but did not report them.  

There were climate-relevant projects that did not incorporate climate aspects into their log frames. Some 
projects  in  both  the  waste  management  and  wastewater  sectors  addressed  climate-related  issues  without 
explicitly  reflecting  them  in  their  log  frames.  For  example,  the  Regional  Sanitary  Landfill  project  in  BiH 
(WBIF #PRJ-BIH-ENV-016) despite reportedly contributing to greenhouse gas emissions did not establish a 
clear climate-related objective or conduct a baseline analysis. A waste management project in Albania (WBIF 
#PRJ-ALB-ENV-013) marked climate change adaptation and mitigation as significant objectives but failed to 
reflect  it  in  the  log  frame.  Furthermore,  the  EUSWAM  project  in  Albania  (#C-393193)  proposed  energy 
efficiency measures for utility companies but did not quantify relevant indicators in the log frame, which was 
noted in the ROM 2020 report: “EUSWAM could address the climate change priorities by quantifying relevant 
measures  and  indicators  in  the  action  plans.  This  would  contribute  to  the  Government’s  energy  strategy 
targets, and to the financial sustainability of the sector” (p7). The Mitrovica/Giljan wastewater project (WBIF 
#PRJ-KOS-ENV-012)  was  marked  as  not  contributing  to  climate  change  mitigation  or  adaptation,  but  the 
ESIA  report  recognized  its  energy-efficient  technology  choices  to  help  limit  net  energy  consumption. 
Likewise, a number of wastewater treatment facilities across the WB region included biogas production but 
climate and environmental benefits in the case of use of biogas were rarely discussed and quantified at the 
design stage.  

Human  rights  were  considered  for  equal  participation  and,  in  a  few  cases,  access  to  benefits,  but  it 
proved challenging to fully address the issues involved. Among the reviewed projects, only an IPA project 
in  Kosovo  (#  C-413041)  incorporated  the  inclusion  of  vulnerable  communities  into  both  design  and 
implementation.  An  indicator  was  established  for  this  purpose:  'Engaging  200 individuals from  vulnerable 
communities (Roma, Egyptian, Ashkali) in the waste value chain' (Description of the Action, 2019, p40). In 
most  cases,  it  was  assumed  at  design  that  the  entire  population  would  benefit  from  expected  outcomes, 
including clean air, environmental protection, enhanced environmental services, improved waste management, 
and  better  public  health.  In  contrast,  a  wastewater  treatment  project  in  Albania  (#C-393193)  planned  to 
investigate subsidies for household tariffs and connections targeting low-income households to improve the 
institutional framework and provision of drinking water and sanitation services in line with the basic human 
right to water and sanitation, including aspects of availability, quality, attainability, and affordability.  

In places where it seemed more plausible to address human rights issues (the rights of Roma and Egyptian 
communities), such as in Kosovo and North Macedonia, the projects were more sensitive to human rights. 
However, achieving success proved challenging. In Kosovo, for instance, special attention was dedicated to 
vulnerable groups such as the Roma, Ashkali, and Egyptian communities in an attempt to integrate them into 
the waste management system. Despite these efforts, success was not attained as these groups rejected the idea 
of  association.  It  was  deemed  necessary  that  before  making  efforts  to  incorporate  vulnerable  groups,  an 
integrated  waste  management  system  must  first  be  established,  along  with  conducive  working  conditions 
within the system. 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
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4.4.  Sustainability 

Ensuring the sustainability of wastewater and waste management projects was a challenge since nearly 
all the operating utilities were weak financially, technically, and institutionally.  The project reports for 
both  wastewater  and  waste  management  showed  a  consistent  picture  of  weak  operating  institutions  that 
struggle to cover their day-to-day operation and maintenance (O&M) costs, have limited technical skills, and 
find  it  difficult  to  recruit  and  retain  qualified  staff.  This  was  generally  confirmed  by  the  visits  to  partner 
countries, although there were examples of wastewater systems operating adequately on a day-to-day basis but 
still vulnerable to long-term sustainability. For example, in Serbia, the recently completed KfW-funded WWTP 
in the city of Kruševac was operating satisfactorily, benefiting from technical staff transferred from the PUC 
and from a small tariff increase that covered at last day-to-day operating costs. However, even in Kruševac, 
the WWTP is starting to experience maintenance problems with replacing worn-out equipment and struggles 
to recruit and retain staff. Similarly, in North Macedonia, the newly built WWTP in the city of Kichevo was 
well  operated,  but  the  utility  staff  could  not  guarantee  that  major  maintenance  events  could  be  covered. 
Generally, the lack of capacity is a country-wide issue. In Montenegro, for example,  the shortage of water 
engineers, and brain drain, especially from rural areas, exacerbates this problem. O&M capacities, even when 
successfully built are uncertain to continue in the long run. From a financial perspective, municipalities are 
hesitant to raise water tariffs to ensure cost recovery due to political (elections) and practical reasons—"we 
can’t charge the citizens if we can’t provide the new service”. In Montenegro, in the municipality of Pljevlja 
(WBIF # PRJ-MNE-ENV-020), the WWTP operating costs are currently funded by the city through subsidies 
from the general budget. It was not feasible to raise water tariffs to cover operating costs due to the incomplete 
wastewater network—they cannot provide all the services. Additionally, tariff regulation falls under a national 
agency, not the local utility. While the utility submits tariff proposals, the agency makes the final decision - 
effective tariff adjustments may also imply national tariff reform. On the waste front, in Montenegro, in the 
city of Bar (#C-399895), there was an explicit recognition of the lack of capacity, financial and technical, to 
operate and maintain highly sophisticated technology solutions for waste separation and recycling. 

While the EU and its partners acknowledged the importance of tariff reform and enhancing the financial 
performance of utilities, only a few projects specifically addressed these areas. However, these initiatives 
were  mainly  limited  in  scope  and  failed  to  address  broader  challenges.  The  annual  action  plans  and 
enlargement reports highlight the need to strengthen the operation and maintenance capacity in the operating 
utilities  in  order  to  ensure  sustainable  operation  and  maintenance  of  the  infrastructure.  However,  as  noted 
earlier, most of the projects were focused on the construction of physical infrastructure. Only four of the 16 
wastewater  projects,  reviewed  as  part  of  the  desk  work,  included  a  capacity-building  component,  some  of 
which targeted improved financial performance. One of these was a wastewater treatment project in Albania 
(#C-412150), which included a specific result of “Strengthened management of the wastewater infrastructure 
at the municipal level applying affordable combined water supply and sewerage cost recovery tariff systems”. 
However,  the  indicator  for  this  result  was  a  rather  narrow  staffing  measure:  “Number  of  certified  (or 
equivalent) Managerial, operational and administrative/ financial Staff in Water Supply and Sanitation (WSS) 
utilities.” The issue was broader – the visits to partner countries highlighted the finance and human resources 
challenges for sustainable O&M. The best practice of introducing and supporting Financial and Operational 
Performance Improvement Programmes (FOPIPs) was only rarely evident. Overall, the initiatives were rather 
limited and ad-hoc with little evidence of an overall plan as to how financial improvements could be done in 
a consistent and effective way at the local and national level. 

Raising water tariffs was both a local-level implementation as well as a national tariff reform challenge. 
The  visits  to  partner  countries  showed  a  nuanced  picture.  Municipalities  in  some  partner  countries  (North 
Macedonia and Serbia) were able to raise tariffs to cover day-to-day operating costs. In these cases, the newly 
built WWTPs were functional, and new service was provided to citizens. A significant factor in the success of 
the  WWTP  project  in  Serbia  (Kruševac)  was  the  provision  of  end-to-end  consultants  (to  enable  coherent 
support from start to finish in a continuous manner) and substantial O&M capacity support, including post-

26 

 
 
 
construction assistance and advice. However, it was not possible (or politically acceptable) in these  partner 
countries to raise tariffs enough to cover more substantial medium-term maintenance costs for replacing worn-
out  equipment.  In  general,  operation  was  covered  but  maintenance  was  not.  Therefore,  it  appeared  that 
effectively raising tariffs was less an issue of national tariff reform and more about a) sensitising the population 
to accept increased water tariffs and b) establishing a local mechanism to fund larger but intermittent costs 
associated with equipment replacement. Specifically, in Serbia, the country visit found no evidence of national 
interventions regarding financial performance and noted that tariff reform at national level and related financial 
performance were less of an issue than previously thought. On the other side, in Bosnia and Herzegovina, the 
EU contributed to a UNDP-run programme that worked with municipalities and public utility companies to 
improve  public  service  delivery  in  wastewater (and waste).  However,  these  improvements  were  subject  to 
operational  and  functional  infrastructure  -  a  justifiable  increase  in  water  tariffs  across  the  municipalities 
participating in the WATSAN  programme  would mean  improved  services  for citizens,  but this  has  not yet 
materialised  -  partly  due  to  overambition  and  a  lack  of  holistic,  step-by-step  planning  of  infrastructure 
investments, as explained earlier. Similarly, in Montenegro, in the municipality of Pljevlja, raising water tariffs 
was not possible due to the insufficient secondary network for the new WWTP. The sequence of wastewater 
infrastructure  development  in  Pljevlja  was  suboptimal,  as  the  WWTP  was  established  before  addressing 
sewerage network weaknesses.  

Generally, the EU’s support for sustainability in the waste sector was aimed at increasing the potential 
for future sustainability through wider policy and legal level improvements that are necessary but not 
sufficient to achieve sustainability. Recognising the weaknesses and gaps in national legislative frameworks, 
the EU’s support for waste management in Albania, Montenegro, and BiH has focused on policy development 
to prepare the sectors for sustainable infrastructure investments. In BiH, support under IPA II was directed 
towards  waste  studies  and  legal  framework  assessments  to  facilitate  sector  preparation  for  infrastructure 
investments and to assess the potential for adopting circular economy principles. In Montenegro, in response 
to the EU waste Acquis, the EU strongly pushed for a new waste law, which was recently adopted - a success 
for the EU policy dialogue. Based on the new law, the country will develop a national waste management plan, 
which is expected to provide a conducive framework for large infrastructure investments. However, established 
legal frameworks do not guarantee sustainable investments. For example, in partner countries with favourable 
policy frameworks and EU institutional support for waste management, sustaining the level of service has 
proven  difficult.  Despite  comprehensive  EU  support  for  waste  in  Kosovo—including  capacity  building, 
equipment,  and  infrastructure  -  many  of  the  systems  that  were  built  before  2007  have  fallen  short  of 
expectations once operational. The regional landfills established in Kosovo during the period 2007-2013 were 
intended to operate according to EU standards but unfortunately, this is not the case. This older infrastructure 
is  currently  in  poor  condition;  the  leachate  and  landfill  gas  collection  systems  are  non-functional,  and  the 
landfills do not comply with the conditions set out in the EU Landfill Directive, illustrating the severe challenge 
that even the newer systems will have in ensuring proper long-term O&M. In all partner countries, the financial 
resources and behavioural changes required are considerable.  

Effective  interventions  to  ensure  sustainable  operating  wastewater  utilities  and  waste  management 
entities  were  not  sufficiently  guided  by  a  transition  strategy  that  outlined  a  feasible  and  progressive 
pathway  to  the  attainment  of  EU  standards.  The  EU  interventions  lacked  a  transition  strategy  with  a 
timeline  for  progressively  and  feasibly  attaining  EU  standards  in  either  wastewater  treatment  or  waste 
management. The plans did not sufficiently address fundamental constraints at both national and local levels. 
Across the partner countries, the ambition level was high, as noted earlier, but a step-by-step transition was 
not  in  place.  To  some  extent,  this  approach  was  being  attempted  by  the  EBRD-financed  regional  waste 
management programme in North Macedonia, supported by the WBIF, which focused on the collection and 
safe  disposal  of  waste  before  addressing  source  separation  and  waste  treatment.  Similarly,  in  Bosnia  and 
Herzegovina,  the  EBRD  selected  municipalities  and  provided  comprehensive  step-by-step  support  for 
wastewater infrastructure investments. In contrast, the source separation introduced in Bosnia and Herzegovina 
in the city of Mostar (and surrounding municipalities), coupled with the recycling facility funded by a 2014 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
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27 

 
 
IPA grant, was  overly ambitious  in its intention  to ensure a high level of resource recovery for the region. 
However, most aspects of this plan did not work - source separation was never successfully implemented in 
any part of the project area, and although the recycling  facility is operational, the current level of resource 
recovery (12%) is presumably well below the intended 2014 target. In Kosovo, wastewater utilities and waste 
management entities cannot and are not expected to attain EU standards within the next ten years. A step-by-
step transition, which recognises that less than 70% of wastewater will reach a treatment facility even after ten 
years was missing. For example, only about 2% of wastewater in Kosovo was treated in 2018, which grew to 
about 8% in 2023, according to available public data.1112 

4.5.  Cooperation approach  

Infrastructure projects were complex, and subject to long delays due mainly to institutional issues that 
were well recognised by the EU and others with improvements taking place during IPA II and IPA III – 
in some partner countries more than others. The causes of delay in providing infrastructure and improved 
services have been well researched by special studies and internal EU reflection and point mainly to inadequate 
promoter capacity in project preparation and implementation. Even though the factors causing delay were well 
known and recognised in the underlying sector analysis and programme documentation it was not, in practice, 
with the tools available to the EU support, easy to address them. Many of the issues were not possible to tackle 
at the project level. The issues were at the sector or even national level and involved complex topics such as 
staffing levels, the relationship between central and local government and obligations on co-financing. This 
meant that projects often resorted to responding to such issues by identifying them as assumptions with an 
often-optimistic assessment that the assumptions would be fulfilled. Mitigating action identified at the project 
level  was  seldom  enough  to  address  the  issues.  Projects  were  then  subject  to  delay  when  the  assumptions 
turned out to be overly optimistic. The reasons for these optimistic assumptions were various, including an 
underestimation of contextual complexities and associated risks, overestimation of positive and transformative 
outcomes,  and  a  lack  of  political  economy  analyses  to  support  ambitious  national  strategies  and  plans  for 
implementing  the  EU  waste  and  wastewater Acquis. A  study  focusing  on  a  programme  of  improvement 
measures based on the Serbian experience during IPA II found that it was feasible to reduce delays in project 
implementation. This was achieved by emphasizing the development of strategically relevant, high-quality, 
and  sustainable  projects  that  considered  institutional  realities.  A  number  of  measures  were  introduced, 
including establishing a consistent balance between grants and local co-financing at the local level; providing 
communication  and  training  on  the  new  policy  and  law  to  institutions  at  all  levels;  clarifying  institutional 
responsibilities  for  implementation  in  the  sector;  using  project  preparation  resources  more  effectively; 
strengthening  administrative  capacity,  particularly  for  procurement,  to  facilitate  implementation.  These 
measures were largely implemented and have reduced delays. For instance, the Raška wastewater project, in 
Serbia,  made  use  of  an  end  user  agreement  to  clarify  responsibilities  which  streamlined  project 
implementation.  Nevertheless,  in  some  partner  countries,  the  delays  continued  especially  for  large 
infrastructure  projects  implemented  under  IPA  such  as  in  North  Macedonia,  Bosnia  and  Herzegovina  and 
Montenegro.  

While the choice of partners was appropriate, the selection was not always supported by a thorough 
understanding of their absorption capacities and incentives to engage. Wastewater treatment infrastructure 
was generally implemented through utilities and local government. Whereas a wider mix of local government, 
private sector and civil society partners were chosen for waste management. The importance of the role of the 
municipal authorities and their relationship with the public utility companies tended to be underestimated. The 
selection  of  municipalities  for  large  infrastructure  projects  was  typically  guided  by  master  plans  with 
insufficient emphasis on testing the political and administrative readiness to manage and contribute towards a 
complex project. In Bosnia and Herzegovina, North Macedonia, and Montenegro in particular the incentives 

11 https://me.rks-gov.net/en/blog/cornerstone-of-the-wastewater-treatment-plant-placed-in-gjakova/ 
12 https://www.naturvardsverket.se/en/international/cooperation/bilateral/kosovo/ 

28 

 
 
 
 
and drivers for municipal engagement and involvement were not easy to understand or well-researched. The 
2020 evaluation of local authorities noted that the EU has been increasingly recognising local authorities as 
relevant  “policy  interlocutors  and  development  actors  (p2)”  with  an  active  role  that  goes  beyond  being a 
passive recipient of infrastructure. New partners such as civil society and the private sector were considered 
particularly for  driving  innovations  in  waste  management  and  circular  economy.  This  made  sense  as  such 
innovations would need to be proven before they could enter into the workplan and budget of a public sector 
entity.  IPA  II  and  particularly  IPA  III  in  waste  management  focussed  more  on  the  private  sector  (e.g.  in 
promoting extended producer responsibility) and to a lesser extent on civil society, especially where awareness 
raising  was  involved.  The  Youth  Drive  partnership  (#C-410938)  for  waste  management  in  BiH  and 
Montenegro was an example of a civil society project.  

Partner  capacity  was  generally  weak,  and  projects  tended  to  make  over-optimistic  assumptions  on 
capacity and ownership and overlook the political economy. As noted earlier, partners lacked sufficient 
administrative  capacity both  at  the  national  and  local  levels,  particularly  for  identifying, planning, and 
managing projects. In North Macedonia's Multiannual Programming Document (2014-2016) it was noted that 
"Institutional  capacity  for  management  assistance  was  not  sufficient,  in  particular  for  IPA  projects 
(identification,  preparation,  participation  in  implementation,  supervision)  both  at  central  and  local  level. 
(p24)" This was a common observation made throughout the region and confirmed during the field visits. In 
more  recent  reviews,  the  emphasis  has  been  placed  on  both  low  implementation  capability  and  low 
enforcement  capacity  for  environmental  regulations.  Although  it  was  widely  acknowledged  that  partner 
capacity and past attempts at capacity building had been insufficient, the underlying political economy issues 
were  rarely  investigated.  Optimistic  assumptions  were  made  on  staffing  levels  and  the  partner’s  financial 
sustainability and ability to continue to finance recurrent costs after the EU support. Although at the country 
engagement  level  there  is  evidence  that  political  economy  risks  were  identified,  the  implications  were 
overlooked at the project level and in general partners were not subject to institutional due diligence. As noted 
earlier, where ownership was high, solutions to even the most difficult problems could be found as evidenced 
in Kichevo in North Macedonia and Kruševac in Serbia. As noted by one local government official: “All the 
delays and issues can be traced back to political issues.” 

There was a trade-off between aiming at meaningful and transformative results and keeping the project 
simple  and  not  relying  excessively  on  factors  outside  project  control.  The  waste  management  and 
wastewater treatment sectors faced a range of deep-seated challenges related to poor financial viability, low 
citizen awareness, ineffective public sector administration and the wider political economy. These challenges 
went beyond the project/programme time scale, resources, and scope - especially considering the critical mass 
needed  to create  a  sustainable transformation of the sector.  This forced  project design  to  make  a series  of 
assumptions that in many cases were not realistic. It also tended to lead to overly ambitious projects at least 
where the context was fragile as in most of the partner countries. The examples that stand out most clearly 
here are the infrastructure programmes in wastewater treatment in North Macedonia, Bosnia and Herzegovina, 
and Montenegro that were simply beyond the political, administrative, and technical capacity of the partners. 
The WATSAN programme in Bosnia and Herzegovina was dispersed across the country with relatively small 
ticket sizes. It lacked a strategic, step-by-step approach and did not adequately address key areas such as 1) 
incentives  and  willingness,  2)  capacity  building,  and  3)  transformative  effects.  In  an  attempt  to  simplify 
complex infrastructure investments, significant risks and assumptions regarding transformative outcomes were 
taken. However, there was some evidence, particularly in more recent projects, of a step-by-step transition 
strategy, such as piloting, linking to incentives to change and seeking out those partners that had the greatest 
willingness to change. An example is in North Macedonia where there is a recognition that an earlier strategy 
of focussing on where there was the greatest  environmental need should increasingly be complemented by 
prioritising those towns that have the greatest readiness to make good use of the infrastructure. However, in 
general,  the  projects  appear  quite  ambitious  and  do  not  seem  to  have  systematically  adopted  a  strategic 
approach to managing the trade-off between risk and ambition.  

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
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29 

 
 
The policy dialogue agenda and potential policy leverage of EU support were not explicit at project or 
even programme level however greater attention was put on these aspects in IPA III. The EU accession 
process provided effective policy guidance for the waste management and wastewater treatment sector and 
ensured that the efforts of donors were coordinated. However, the policy agenda and policy leverage were not 
explicit. The WBIF brought together the EU as well as Member States and international institutions which 
ensured  that  waste  management  and  wastewater  treatment  infrastructure  projects  were  consistent  with  the 
overall  enlargement  agenda.  Also,  within  soft  projects  aiming  at  policy  and  capacity  development,  it  was 
evident that bilateral projects were informed by and contributed to a coherent agenda set by the EU accession 
process. Although there was a general consistency between the strategic aims of accession and the project 
objectives,  at  an  operational  level  the  link  between  the  projects  and  any  policy  leverage,  conditionality  or 
change in the incentive environment was not evident or at least not explicit. Some projects had an indirect link 
between policy change and the project activities. An example is the Twinning project for Extended Producer 
Responsibility  in  North  Macedonia  (under  #C-383609)  where  policy  objectives  are  done  in  tandem  with 
practical  and  operational  efforts  to  develop  capacity  and  enhance  institutional  performance.  More  than  in 
earlier  periods,  IPA  II  focussed  on  the  role  of  economic  reforms  and  the  linkage  to  wider  environmental 
governance  frameworks  including  public  participation,  access  to  information,  access  to  justice  in 
environmental matters and environmental reporting, involvement of civil society and also local and regional 
governments  as  well  as  research  and  innovation.  Greater  attention  was  put  on  policy  dialogue  and  non-
spending tools for the green agenda in IPA III. This is evident in the GAWB communication document which 
draws attention to the importance of working within existing political and technical cooperation frameworks. 
The use of a multi-year planning in IPA III also opens up the possibility for adopting a programmatic approach 
and working more closely with IFIs and others to link policy dialogue with policy lending instruments and 
budget support where relevant. 

The selection and use of different instruments was well founded although  a programmatic approach 
across  the  different  instruments  was  weak.  There  were  missed  opportunities  to  use  the  full  palette  of 
instruments and coordinate with IFIs in adopting a programmatic approach. The sequence of infrastructure 
financing through loans and capacity development/institutional strengthening and then also policy dialogue 
via grants was well conceived but there were missing opportunities in use of budget support and linking more 
closely  to  the  policy  development  loans  of  the  IFIs  where  reform  issues  could  have  been  linked  to  the 
disbursement of the loans. IPA II was problematic because it was based on annual planning when partners 
were encouraged to adopt a long-term vision (this was changed with IPA III and, so far, found to be working 
better, at least in Serbia). The WBIF-provided IPA grants for waste management and wastewater did not fit in 
with the programmatic approach – as they were approved on a demand-driven, project-by-project basis, rather 
than  being  structured  to  support  a  cohesive  cluster  of  projects  that  could  evolve  over  time.  This  makes  it 
difficult for IFIs to integrate other funding sources – a multi-year programme that is not tied to specific projects 
makes it easier for IFIs to mobilize and use funding from other sources because the funding does not need to 
be available in a specific year for a particular project. IFIs have their own approval processes, and it is easier 
to align the WBIF and IFI approval processes when the funding supports a multi-year programme rather than 
being restricted to a specific project and timeline. There were some instances of indirect management with 
GIZ  and  other  member  state  agencies  and,  in  general,  this  was  found  to  have  been  well  considered.  For 
example, in Kosovo, implementation was delegated to GIZ for waste management projects, capitalising on the 
long experience of GIZ on that topic in Kosovo. The evaluation of the local authority programme (2020) found 
that  the  range  of  instruments  for  engaging  with  local  authorities  was  used  to  good  effect.  “EU  has  also 
progressively been using a wider set of modalities and instruments to assist local authorities, and in conductive 
environment this has led to comprehensive and truly integrated approaches, which could drive transformative 
changes, enabling local authorities, benefiting local citizens and businesses as well as improving downward 
accountability and effective service delivery (p3)”. 

The administration of WBIF Infrastructure Project Facilities (IPFs) was perceived as complex, with 
related  consultancy  engagements  lacking  continuity  and  consistency.  The  evidence  from  Bosnia  and 

30 

 
 
 
Herzegovina,  Montenegro,  Serbia,  and  North  Macedonia  suggests  that  IPF  consultancy  contracts  are 
characterised by a complex bureaucratic setup and heavy transaction costs. The EIB manages the overall IPF 
contract  on  behalf  of  the  EU  Commission  (IPFs  1-3  were  directly  managed  by  the  EC),  while  the  IFI 
Coordination  Office  (IFICO)  develops  the  Terms  of  Reference.  The  Grant  Application  Forms  (GAFs)  are 
developed by beneficiaries, endorsed by an IFI, and approved by the WBIF Steering Committee. The process 
has faced criticism regarding inefficiencies, with complexities and delays stemming from, but not limited to, 
communication gaps between stakeholders and fragmented consultancy packages over the project cycle. As 
one  government  interlocutor  pointed  out:  “If  an  IPF  contract  runs  out,  an  IFI  may  bring  in  another 
consultancy, which leads to fragmentation. Then the new consultancy might not be satisfied with the activities 
of the previous phase, so they want to redo parts.” 

Coordination  mechanisms  were  in  place,  but  effectiveness  varied  depending  on  partner  country 
ownership  and  capacity  to  coordinate.  The  EU  assistance  was  coordinated  at  three  levels:  1)  externally 
between the partner countries and donor agencies; 2) internally within each partner country’s administration; 
and 3) among the various donor agencies. National coordination mechanisms, though varying in effectiveness, 
supported the waste management sub-chapter of Chapter 27 in all partner countries. National IPA coordinators 
(NIPACs) coordinated IPA programming and were the main counterparts of the European Commission for 
strategic planning, implementation monitoring, and reporting in Albania, Montenegro, North Macedonia, and 
Serbia. In some partner countries, donor coordination was split between institutions. For example, in BiH, the 
Directorate for European Integration coordinated EU donors, while the Ministry of Finance managed other 
donors and IFIs. In Serbia, environmental policy coordination was led by the Ministry of Environment, while 
the Ministry of European Integration oversaw EU funds. Coordination also took place through the National 
Investment  Committee  frameworks.  Sector-specific inter-ministerial  bodies  were  established for  waste  and 
wastewater management. In Albania, sectoral coordination involved various inter-ministerial groups. Serbia 
had  nine  sector  working  groups  for  external  assistance  programming  and  monitoring.  Coordination 
effectiveness varied; North Macedonia needed better governmental and donor coordination, while internal and 
donor coordination in BiH was often ad-hoc. The main factor affecting coordination was the extent to which 
the  partner  country  institutions  involved  had  the  ownership  and  capacity  to  take  the  lead.  Donor  led 
coordination mechanisms also supported waste management. In Albania, KfW led EU coordination, with the 
Austrian and Swedish agencies managing water resources. In BiH, the EU Delegation, UN organizations, and 
IFIs organized sector meetings. In Serbia, the EU held regular consultations with major financial institutions 
but lacked coordination with China and other financiers, affecting EU policy leverage. There was informal 
work  division  among  donors  in  some  partner  countries,  but  in  others,  like  North  Macedonia,  other  donor 
activities sometimes overlapped with EU support. Regional coordination by WBIF was effective, providing a 
platform for stakeholders to identify and implement priority projects. However, partner countries felt the need 
for better mechanisms to exchange lessons and best practices. 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
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5.  OVERALL ASSESSMENT 

EU support for waste management and wastewater treatment in the Western Balkans is crucial as it addresses 
significant and worsening environmental degradation. Reversing this degradation, caused by inadequate waste 
and wastewater management, is a major challenge for the region. External support was essential for progress 
towards EU accession and for improving the quality of life for current and future generations.  

After  decades  of  neglect,  the  waste  management  and  wastewater  treatment  sectors  needed  extensive 
infrastructure  investments,  major  policy  reforms,  and  enhanced  institutional  capacity,  especially  at  the 
municipal level. While some interventions were funded through IPA grants, the extent of infrastructure needs 
required a comprehensive investment program that because of the scale of finance needed could only be met 
by long term loans. The WBIF was the primary tool for providing loan finance through a coordinated blend of 
grants and loans. However, the environment was not prioritised during most of the evaluation period due to 
the lack of explicit EU strategic priorities until the introduction of the 2020 Green Agenda for the Western 
Balkans. Prior to that, EU support in the region was largely guided by Chapter 27 (Environment) of the EU 
accession process, with priorities set on a country-by-country basis reflecting the demand-driven nature of the 
support. The EU started providing investment grants for waste and wastewater projects through the WBIF only 
in 2022 when it signed two investment grants for wastewater projects. 

Although  it  was  recognised  that  infrastructure  development  must  be  accompanied  by  policy  reform,  tariff 
adjustments,  and  increased  municipal  capacity,  the  scale  of  these  challenges  was  underestimated.  The  EU 
program adopted participatory approaches and supported directive-specific implementation plans to define and 
prioritize  action  programs.  However,  assumptions  about  political  will,  ownership,  and  implementation 
capacity were not adequately tested. Varying commitment from national to local levels, along with institutional 
barriers,  hindered  progress  in  completing  infrastructure,  developing  capacity,  and  implementing  policy 
reforms.  

The  delivery  of  physical  infrastructure  faced  delays  due  to  weaknesses  in  the  implementing  beneficiary 
organizations, state bureaucracy, and the impact of Covid-19. Despite these setbacks, based on past and current 
progress, it is likely that the projects will eventually deliver their physical outputs and contribute to a cleaner 
environment.  While  both  wastewater  and  waste  management  projects  are  expected  to  provide  broader 
environmental  benefits  and  long-term  socio-economic  effects,  the  scale  of  national  initiatives  and  EU 
intervention  remains  minor  compared  to  the  needs,  Nevertheless,  the  national  capacity  to  absorb  and 
implement  national  and  EU-supported  initiatives  remains  limited  compared  to  the  requirements.  It  will 
therefore take a long time to achieve transformative and lasting environmental, economic, and social change. 

Most wastewater projects focused on infrastructure rather than addressing broader policy issues or capacity 
development.  The  log  frames  in  the  Annual  Action  Plans  prioritized  physical  infrastructure  over  policy 
implementation and capacity building. In contrast, waste management initiatives had a stronger emphasis on 
policy and capacity development, with some partner countries significantly enhancing their legal frameworks. 
Particularly  from  2020  under  IPA  III,  efforts  were  made  to  stimulate  the  green  transition  through  waste 
minimization, reuse, and recycling. However, results in the waste sector were mixed, with both successful and 
less successful capacity development and policy initiatives. 

There were notable successes in the EU's policy dialogue efforts, such as the new water law and a national 
water sector reform process in Serbia, and a new waste law developed in response to the EU waste Acquis in 
Montenegro.  However,  the  main  challenge  remains  moving  from  policy  to  practice,  as  progress  in 
implementing and enforcing these policies and laws has been limited. 

Crosscutting themes including climate, gender and human rights were taken into account in annual partner 
country programming for the environment but, except for climate, they were often not formally reflected in 
the log frames. Gender mainstreaming at project level was generally weak, but it was more prominent within 
WBIF-provided IPA grants, with a focus on increasing women's participation in decision-making. Climate 
considerations were better integrated in waste management than wastewater projects with a focus on climate 

32 

 
 
 
legislation,  capacities,  energy  efficiency,  and  circular  economy.  Human  rights  were  considered  for  equal 
participation  and,  in  a  few  cases,  access  to  benefits,  but  it  proved  challenging  to  fully  address  the  issues 
involved. 

Ensuring the sustainability of wastewater and waste management projects was a challenge since nearly all the 
operating  utilities  were  weak  financially,  technically,  and  institutionally.  The  public  utility  companies 
struggled to cover their day-to-day operation and maintenance costs and found it difficult to recruit and retain 
qualified staff. While the EU and its partners acknowledged the importance of tariff reform for securing the 
financial performance of utilities, only a few projects specifically addressed these areas.  

The waste management and wastewater treatment sectors faced numerous deep-seated challenges, including 
poor financial viability, low citizen awareness, ineffective public sector administration, and broader political 
economy  issues.  These  challenges  exceeded  the  project/programme  time  scale,  resources,  and  scope, 
particularly given the critical mass needed for sustainable sector transformation. Consequently, project designs 
often  made  unrealistic  assumptions  and  tended  to  be  overly  ambitious,  especially  in  the  fragile  contexts 
common to many countries. Notable examples include the wastewater treatment infrastructure programs in 
North Macedonia, Bosnia and Herzegovina, and Montenegro, which were beyond the political, administrative, 
and technical capacity of the partners involved. 

The EU interventions lacked a transition strategy with a timeline for progressively and feasibly attaining EU 
standards  in  either  wastewater  treatment  or  waste  management.  The  plans  did  not  sufficiently  address 
fundamental constraints at both national and local levels. Across the partner countries, the ambition level was 
high, but a step-by-step transition was not in place. 

The  choice  of  partners  and  selection  and  use  of  different  instruments  were  well-founded.  However,  the 
programmatic approach across these instruments was weak. There were missed opportunities to fully utilize 
the range of instruments and coordinate with IFIs for a cohesive programmatic strategy. The sequencing of 
infrastructure  financing  through  loans,  followed  by  capacity  development,  institutional  strengthening,  and 
policy dialogue via grants, was well-conceived but difficult to deliver in practice. However, there were missed 
opportunities  to  use  budget  support  and  to  align  more  closely  with  IFIs'  policy  development  loans,  where 
reforms could have been tied to loan disbursements. 

IPA II was problematic due to its annual planning basis, despite partners being encouraged to adopt a long-
term vision. This issue was addressed with IPA III, which has shown better results, particularly in Serbia. The 
WBIF, for waste management and wastewater treatment, did not fit the programmatic approach well, as it was 
designed  for  individual  projects  rather  than  clusters  of  projects  that  could  evolve  over  time.  IFIs  found  it 
challenging, for waste management and wastewater treatment, to work with WBIF and integrate other funding 
sources. There were some instances of indirect management with GIZ and other member state agencies, which 
were generally well considered. For example, in Kosovo, GIZ was delegated to manage waste management 
projects, leveraging their extensive experience in the region. The evaluation of the local authority program in 
2020 found that a range of instruments for engaging with local authorities was effectively utilized. 

Coordination mechanisms to guide the EU support were in place but effectiveness varied depending on partner 
country  ownership  and  capacity  to  coordinate.  National  coordination  mechanisms,  though  varying  in 
effectiveness, supported the waste management sub-chapter of Chapter 27 in all partner countries. There were 
very few cases of overlap or duplication across the donor supported projects.  

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

33 

 
 
 
 
 
 
 
Lessons learnt 

•  Ownership and political cooperation at the local level were key factors of success – where these 
were in place, it was possible to sort out and resolve most other issues even if highly challenging. The 
choice of partners and locations needed to be guided not just by the environmental needs but also by 
the absorption capacity and readiness of the project promoters.  

•  A good working relationship between the municipality and the public utility corporation was 
crucial to both delivery of infrastructure and its operation and maintenance – there were a number 
of inspiring examples where close to insurmountable obstacles were overcome through the combined, 
pragmatic, and dedicated efforts of utilities and municipalities working together. Examples include the 
finalisation  and  operation  of  the  Subotica  waste  management  facility  in  Serbia  or  the  Kichevo 
wastewater treatment plant in North Macedonia.  

•  When external support was coherent across the project cycle to manage complex infrastructure 
projects, it worked well – capacity and institutional constraints meant that a project implementation 
unit approach that provided coherent and consistent support throughout the project cycle from start to 
finish was necessary both at central and local levels. A clear withdrawal strategy is needed alongside 
external support to prevent long-term dependency.  

•  Post construction support working through national organisations such as associations of public 
utilities offered many advantages – an example of this was found in a project in Albania where 6 
utilities were supported for a few years after construction working both at municipal level and with 
regulatory body, the association of public utilities and the ministry of environment.  

•  Political unwillingness to raise tariffs is a major threat to financial and technical sustainability 
– whilst infrastructure could be operated on a day-to-day basis, larger maintenance works tended to be 
deferred due to insufficient tariff. This is likely to lead to early rehabilitation and a shorter life span 
for the infrastructure. 

•  Assumptions regarding partner capacity and readiness for managing major infrastructure were 
overly  optimistic  –  a  transition  strategy  is  needed  that  matched  but  also  aimed  at  enhancing  the 
absorption capacity and readiness of local partners to implement and sustain the service improvements.  

•  Thorough and step-by-step planning for wastewater infrastructure investments is crucial for a 
fully  operational  sewerage  system  –  end-to-end  planning,  including  consideration  of  sewage 
generation and sludge management, is essential to develop the necessary sewerage network for the 
wastewater treatment plant. 

34 

 
 
 
 
6.  CONCLUSIONS 

The conclusions are organised around the five clusters of findings introduced in Chapter 4. These in turn reflect 
the evaluation questions as shown below: 

6.1.  Strategic relevance 

Conclusion 1: Support targeted needs but underestimated challenges 

The EU support was well targeted at partner country needs but underestimated the institutional and 
political economy challenges. 

This conclusion is based mainly on EQs 1 and 3.  

The EU strategies and programming within wastewater treatment and waste management responded to the 
challenges of environmental degradation in the region. The EU programming was well aligned to national 
strategies and the overall strategic objective of supporting accession. The EU supported each partner country 
to develop country-specific implementation plans for Chapter 27 of the Acquis with waste management and 
wastewater treatment being one of the highest priorities. Good progress was made in approximation of the 
legislation including areas such as preventive action, the polluter pays principle and waste minimisation. 
The EU also supported the directive  specific implementation plans which helped to prioritise the action 
needed. The approach was participatory and based on a sound technical appreciation of the needs. However, 
the institutional constraints and political economy challenges were underestimated, and well-meaning but 
overly optimistic assumptions were made about the degree of ownership and national commitment to the 
shared goals both at central level and at the level of the municipalities. The reluctance to increase tariffs, to 
assign sufficient resources to the sector, and to ensure that political obstructions and competing interests at 
national and local levels did not impede progress meant that the EU programme of action, although jointly 
agreed in advance, was not entirely owned at the partner country level.  

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
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35 

 
 
 
 
6.2.  Results  

Conclusion 2: Infrastructure projects delayed 

Infrastructure projects were complex and subject to delays and in many cases beyond the capacity of 
the implementing partners. 

This conclusion is based mainly on EQs 4 & 6. 

The wastewater treatment and regional waste management infrastructure projects were demanding and at a 
scale and complexity that went beyond the experience and capacity of the implementing partners both at 
central and municipal level. Workplans were often unrealistically optimistic and tended to overlook partner 
capacity  and  the  institutional  context.  There  were  cases  of  very  long  delays  and  in  the  case  of  North 
Macedonia  this  led  to  significant  decommitments  (Euro  80m  for  combined  transport  and  environment 
sector, with most in the environment sector). In Bosnia and Herzegovina, projects were significantly delayed 
due to the partner countries complex institutional set up that was unable to respond with the flexibility to 
make  the  changes  needed  and  amend  contracts  to  ensure  timely  completion  of  projects.  A  lack  of 
comprehensive project implementation support and in the case of the WBIF, for waste management and 
wastewater  treatment,  a  fragmented  system  for  providing  technical  assistance,  meant  that  projects  were 
subject to  discontinuity  in the  project  management  approach,  which  led  to long delays.  The  wastewater 
projects  focussed  on  the  narrow  engineering  requirements  of  designing  and  building  a  new  wastewater 
treatment  plant.  They  failed  to  fully  plan  for  the  end-to-end  technical  requirements  such  as  taking  into 
account the likely generation of sewage and the need to manage sludge. As a result, there were cases where 
the sewerage network was not sufficiently developed to generate the sewerage necessary for the wastewater 
treatment plant.  

Conclusion 3: Physical outputs will be reached but not at the scale needed  

The projects are likely to achieve their physical outputs and contribute to wider environmental and 
social benefits in the longer term but not at the scale needed. 

This conclusion is based mainly on EQs 4 & 6  

None of the infrastructure projects started since 2016 have yet been completed. However, reporting and 
field verification of some of the projects from earlier periods that have been completed strongly indicate 
that despite delays and many challenges the projects have achieved their intended outputs and are leading 
to significant environmental benefits both within waste management and wastewater treatment. Thus, it is 
likely that, based on progress of past and ongoing projects, works will be completed and the physical outputs 
reached. This will mean that less untreated wastewater is discharged into the environment and waste is better 
managed  through  waste  minimisation,  recycling,  collection,  and  safe  disposal  in  sanitary  landfills. 
Moreover, and especially as a result of interventions in the waste management sector, public authorities, the 
private sector, and citizens will be better positioned to engage in the green transition. Thus, EU cooperation 
in wastewater and waste management sectors will contribute to wider environment, economic and social 
benefits. However, the national absorption capacity and the scale of the national and EU supported initiatives 
is minor compared to the needs and likely to take a long time to reach the end objectives and create the 
irreversible  and  transformative  change  necessary  to  sustain  the  environmental,  economic,  and  social 
benefits.  

Conclusion 4: Capacity development was weak and policy lags in implementation 

Although  there  have  been  some  successes,  capacity  development  was  not  well  integrated  into 
programmes and policy reforms lag in implementation. 

This conclusion is based mainly on EQs 4 & 6  

36 

 
 
 
 
 
 
 
In the wastewater sector, infrastructure projects and programming log frames rarely identified a coordinated 
sequence of outputs where infrastructure, capacity development and implementation of policy reforms were 
combined.  Financial  and  operational  performance  improvement  programmes  contributed  to  developing 
capacity but were not systematically put into place across all projects and seldom brought beyond the level 
of individual municipalities. EU policy dialogue efforts saw some important successes such as the new water 
laws in Serbia and Montenegro and an environmental approximation strategy in Bosnia and Herzegovina. 
However practical implementation of reforms that would lead to EU standards being met has lagged behind. 
Waste  management  initiatives  particularly  under  IPA  III  were  more  focused,  than  those  of  wastewater 
treatment, on linking infrastructure, capacity development and implementation of policy reforms.  Waste 
management projects aimed to transform and shift systems. For example, the EU implemented a significant 
municipal  waste management  program  in  Kosovo  and  supported  waste studies and  legal  assessments in 
Bosnia and Herzegovina to prepare for infrastructure investments and circular economy principles. While 
early results of these interventions remain uncertain, the EU strongly advocated for new waste laws and 
associated  management  plans,  emphasizing  capacity  development  through  extensive  training  initiatives. 
Across both wastewater treatment and waste management, despite national governments adopting policies 
aligned with EU directives, challenges persist in implementing cost-reflective tariffs, illegal disposal and 
non-compliance  with  environmental  standards  are  common.  Achieving  comprehensive  wastewater 
treatment  and  waste  management  and  circular  economy  goals  remains  distant,  though  governments 
acknowledge the importance of these sectors in meeting EU standards.  

6.3.  Cross cutting aspects 

Conclusion 5: Cross cutting aspects largely integrated but not monitored 

Climate, gender, and human rights were taken into account in the programming but not monitored 
or integrated in result frameworks. 

This conclusion is based mainly on EQs 5 

The reviewed programme documents generally discussed climate, gender, and human rights issues at the 
partner country level and their integration into EU support. However, unlike climate considerations, gender 
and  human  rights  issues  were  not  consistently  incorporated  into  programme-level  log  frames.  The 
integration of these themes into project log frames was generally weak, although it did improve over time 
in  programming  and  at  the  project  level.  However,  this  did  not  translate  into  meaningful  integration 
throughout  the  project  cycle.  Many  evaluation  interlocutors  noted  that  the  cross-cutting  objectives, 
especially regarding gender, were more pro forma requests than meaningful demands. The integration of 
gender  was  typically limited  to increasing  women’s participation  in project  activities or, in  some  cases, 
decision-making processes. While climate considerations experienced better mainstreaming than gender and 
human rights, they were not systematically tracked and reported on. While some climate-relevant results 
were identified, particularly in the waste sector, there were examples of projects with climate relevance that 
did not report results in their progress or final reports, indicating missed opportunities for better integration 
of climate aspects. Gender results were reported only in a few instances, primarily focusing on increased 
women’s participation in decision-making or achieving equal participation of men and women in project 
activities.  However,  these  reports  often  lacked  sufficient  detail  on  the  opportunities  and  challenges  for 
gender  integration, thereby  limiting the learning  potential.  There  were  also  missed  opportunities  for  the 
integration of gender and human rights aspects. 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
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37 

 
 
 
 
6.4.  Sustainability 

Conclusion 6: Projects were being operated but insufficient finance to maintain the facilities 

Municipalities were largely able to operate the new infrastructure and provide improved services, but 
maintenance and longer-term sustainability is severely threatened. 

This conclusion is based mainly on EQs 4 & 7 

Ensuring  the  sustainability  of  wastewater  and  waste management  projects  was challenging  due  to  weak 
financial, technical, and institutional capacities of utilities and in some cases the political stability of the 
municipalities.  Although  utilities  were  able  to  operate  the  facilities  on  a  day-to-day  basis,  they  were 
generally not able to secure coverage of longer-term maintenance costs. Moreover, they lacked technical 
skills  and  had  difficulty  retaining  qualified  staff.  Utilities  were  highly  dependent  on  a  close  working 
relationship  with  their  municipalities  to  cover  repair  and  replacement  costs.  National  authorities  and 
municipalities often interfered in the operations and hesitated to raise water and waste tariffs to full cost-
reflective levels or provide guaranteed subsidies to meet the shortfall. As a result, utilities generally did not 
have sufficient financial and managerial autonomy to secure a sustainable improvement in services. These 
issues were well recognised, and the EU engaged on policy dialogue on tariff issues as well as funding 
technical assistance including through financial and operational performance improvement programmes and 
innovations in the waste management sector. However, the challenges still remain, and it is likely to take a 
long time for these measures to take root and for the improved services to be sustained.  

6.5.  Cooperation approach  

Conclusion 7: The ambition level went beyond partner readiness given the challenges 

The complexity and nature of the challenges required a stronger programmatic and demand-based 
approach that matched partner readiness. 

This conclusion is based mainly on EQs 2,3,6,7 

The waste management and wastewater treatment sectors faced deep-seated challenges, including financial 
instability, low citizen awareness and ineffective public administration. These challenges often exceeded 
the scope and resources of individual projects, particularly in politically contested and fragile contexts. The 
ambition level and time scale were high and were not matched with step-by-step plans to address national 
and local constraints in a way that recognised the importance of national ownership and the limits of external 
support. EU interventions were not sufficiently guided by a clear and demand-based transition strategy with 
a realistic step by step timeline for achieving EU standards. While the choice of partners and instruments 
was in principle sound, it was challenging to develop an encompassing programmatic approach that matched 
partner readiness and was based on demonstrated ownership and demand. IPA II’s annual planning basis 
was problematic, despite a push for long-term vision - an issue now being addressed under IPA III. The 
WBIF, at least for the waste management and wastewater treatment subsector, was designed for individual 
projects and did not fit well with a programmatic approach - as they were approved on a demand-driven, 
project-by-project basis, rather than being structured to support a cohesive cluster of projects that could 
evolve over time. This makes it difficult for IFIs to integrate other funding sources - a multi-year programme 
that is not tied to specific projects makes it easier for IFIs to mobilize and use funding from other sources 
because the funding does not need to be available in a specific year for a particular project. IFIs have their 
own approval processes, and it is easier to align the WBIF and IFI approval processes when the funding 
supports a multi-year program rather than being restricted to a specific project and timeline. There were 
missed opportunities to fully utilize and coordinate with the range of instruments such as IFI budget support 
and policy development loans. Although the intended sequencing of infrastructure financing through loans 
complemented by capacity development and policy dialogue via grants, was well-conceived, the situation 
made it highly challenging to coherently implement it in practice.  

38 

 
 
 
 
 
 
7.  RECOMMENDATIONS 

The figure below shows major links between EQ clusters, conclusions, and recommendations.  

Recommendation 1: Tailor the ambition to the country’s absorption capacity 

Develop a set of simple scenarios, integrating national, municipal, and project-specific considerations, 
to tailor the ambition level of the EU support, for the waste management and wastewater treatment 
sectors, to the country’s potential for implementation and ensuring sustainability. 

Linked to conclusions 1, 2, and 3. 

Rationale – The evaluation found that the capacity of the countries to progress towards EU standards in 
waste management and wastewater treatment is dependent on a number of complex factors at country level 
that influence the results that can be achieved. These include administrative bottlenecks, the level of political 
will and engagement, the capacity to finance, implement and sustain the facilities as well as to bring about 
the social, behaviour and other changes needed to advance on the green agenda. It is important that the EU 
support is well matched to the country capacity and priority placed on waste management and wastewater 
treatment and the commitment to approximation to EU Acquis. This varies overtime and can also vary from 
municipality to municipality. A set of scenarios from high to low ambition to the sector could help identify 
and  adjust  the  scale and type  of  EU support. The  scenarios could  define  the  policy reform,  institutional 
improvements and financial commitment needed to justify a higher level of support at country level as well 
as the minimum requirements at municipal level. The scenarios would need to be aligned with the countries’ 
strategies and the legal and technical requirements of relevant EU directives. They should also  take into 
account and reflect the Directive Specific Implementation Plans (DSIPs), directive-specific timelines (i.e., 
short, medium, and long-term objectives), and be realistic in terms of investment planning and technical 
capacity building. An example of a step-by-step ambition level at the project level was observed in North 
Macedonia where an EBRD implemented initiative on regional waste management, supported through the 
WBIF, informed by a feasibility assessment, focussed first on collection and safe disposal before attempting 
more ambitious source separation and sophisticated waste treatment facilities. 

Implementation measures – This recommendation can be implemented through the following measures: 

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

39 

 
 
 
 
 
•  Re-assess the realism of the national programmes, including DSIPs, as part of the periodic reporting 
on EU support by examining the commitment and willingness to engage by the partners based on 
the experience and track record to date. 

•  Periodically assess new opportunities especially on mobilising and working with the private sector 

• 

and civil society on areas of the green agenda. 
In close coordination with the national authorities develop scenarios for different levels of ambition 
in terms of scope and timescale for the EU cooperation, linked to progress on implementing reforms. 
These measures should, led by the EU, be implemented in collaboration between the EUDs and the relevant 
national stakeholders. 

Urgency – This is important and of short to medium term urgency.  

Recommendation 2: Strengthen the programmatic approach  

Strengthen the programmatic approach to enhance coherence of the investment projects and their 
link to policy, institutional, and capacity development.  

Linked to conclusions 4 and 7. 

Rationale  –  The  infrastructure  projects  were  generally  well-conceived  but  in  some  cases  wastewater 
treatment projects were carried out in isolation to sewerage network connections leading to underutilised 
facilities. The WBIF  instrument  for  the  waste  management  and  wastewater  treatment  interventions  was 
mainly based on a project-by-project approach. Many of the infrastructure projects missed the opportunity 
to develop national capacities, reduce administrative burden, and advance policy reforms in part because 
these broader issues fell beyond the scope of any individual project. When WBIF intervention was linked 
to a wider programme of investment, such as the Serbia VI programme for wastewater treatment, it was 
better positioned to contribute to cumulative improvements. A programmatic approach to investments would 
more closely link the infrastructure to wider efforts to develop capacity, implement reforms and engage with 
the private sector, civil society, and others.  

Implementation measures – This recommendation can be implemented through the following measures: 

•  Take  advantage  of  and  strengthen  the adoption  of the  multi-year  planning  facility  of  IPA  III  for 
wastewater  treatment  and  waste  management  interventions,  realising  that  they  are  long  term 
ambition. 

•  As necessary, conduct and use political economy analyses to adapt policy and institutional reforms 

recommendations to local contexts.  

•  Link infrastructure projects more closely to the grant IPA resources available for supporting policy 

and institutional reforms, awareness raising and capacity development. 

•  Examine means to simplify and improve the WBIF technical assistance grant application process 

for project preparation and the provision of technical assistance.  

These measures should, led by the EU, be implemented in collaboration between the EUDs, the IFIs and 
the relevant national stakeholders. 

Urgency – This is important and of medium-term urgency.  

Recommendation 3: Enhance support to utility level performance 

Enhance support to utility level performance.  

Linked to conclusions 6 and 7. 

Rationale – Municipalities and public utility corporations are generally weak and unable in the context of 
low income and inadequate human resources to manage either the complex implementation phase or the 
subsequent operation and maintenance. While IFIs often use project implementation units to support the 
public utility corporations in project management and procurement there is a need to ensure some transfer 

40 

 
 
 
 
of  skills  to  cater  for  larger  maintenance  events  and  extension  of  the  systems.  Financial  and  operational 
performance  improvement  programmes  have  been  introduced  as  part  of  some  projects  but  not 
systematically. As building technical capacity, these programmes strengthen the financial and managerial 
autonomy  of  the  public  utilities  allowing  them  to  be  professionally  run  on  business  lines.  Where  such 
programmes  or  elements  of  them  have  been  introduced  the  results  have  been  encouraging.  National 
associations of utilities have a longer-term role in supporting and providing services such as update of utility 
billing, financial administration systems. 

Implementation measures – This recommendation can be implemented through the following measures: 

•  Put more emphasis on undertaking financial and institutional diagnosis to guide a programme of 

financial and operational performance improvement programmes. 

•  Allocate resources to implement financial and operational performance improvement plans together 

with infrastructure projects. 

•  Build  capacity,  where  feasible,  of  national  associations  and/or  peer  learning  and  support 

mechanisms between municipalities.  

These measures should,  led by the EU, be implemented in collaboration between the EUDs and the relevant 
municipalities  and  national  bodies  that  have  oversight  of  the  sector  as  well  as  the  relevant  national 
associations of utilities. 

Urgency – This is important and of medium-term urgency.  

Recommendation 4: Prioritise municipalities with capacity and willingness 

Prioritise partners at the municipality level where the absorption capacity and political willingness 
are strong.  

Linked to conclusions 1 and 4. 

Rationale – A key factor behind successful implementation and sustainable operation was the presence of 
committed partners – usually a public utility corporation backed up by a supportive municipality. This was 
clear both for wastewater treatment and waste management even where there were significant technical and 
financial challenges. In such cases, the partners demonstrated capacity to take the lead and make use of 
innovations introduced by the EU support such as extended producer responsibility and source separation 
at source. Conversely where ownership and commitment to the project objectives was weak, the capacity to 
absorb  and  make  use  of  external  support  was  low,  for  example  in  increasing  the  social  support  for 
environmental and green economy initiatives. The degree to which the partners shared the project objectives 
and their readiness to cooperate and implement policy reforms was the most important element for achieving 
and sustaining environmental outcomes. 

Implementation measures – This recommendation can be implemented through the following measures: 

•  Undertake a partner readiness assessment as part of early feasibility considerations as a basis for 
partner selection and prioritising where interventions were likely to be successful. The readiness 
assessment should assess evidence of managerial competence of the implementing partners as well 
as  the  degree  of  operational  autonomy  granted  to  them  and  the  financial  commitment  of  the 
municipality.  
Intervene where there are credible plans for improvement initiated by partners, municipalities, and 
their public utility corporations. 

• 

•  Assess the degree of readiness of key stages of the project preparation and be prepared to delay or 

withdraw if the ownership and commitment is not evident.  

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
2022) Evaluation Report – November 2024 

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These measures should, led by the EU, be implemented in collaboration between the EUDs and the relevant 
national stakeholders 

Urgency – This is important and of short-term urgency.  

Recommendation 5: Provide additional support 

Provide additional support to the pre and post implementation phases.  

Linked to conclusions 2 and 6. 

Rationale  –  Few  individual  and  regional  municipal  corporations  have  experience  in  implementing 
interventions at the scale and complexity needed to respond to the environmental challenges in the region. 
Considerable  support  is  often  needed  to  develop  the  capacity  to  manage  these  projects  and  make  the 
necessary institutional changes to ensure that the interventions are successful. A key factor behind successful 
EU interventions was a careful pre-project phase of support that built on local ownership. During the post 
project  phase,  developing  sufficient  capacity  to  operate  and  maintain  wastewater  treatment  and  waste 
management facilities and engage with the private sector and civil society is a long-term challenge that is 
often beyond the capacities of individual municipalities or newly set up regional waste management entities. 
A common weakness in many projects was the absence of a mechanism to fund significant maintenance 
works. Developing these capacities is a process that is best driven at the local level through the public utility 
corporations and at national level through associations of municipalities, utilities, as well as private sector 
and  civil  society  associations  that  can  provide  peer  to  peer  learning.  A  number  of  examples  of  EU 
cooperation providing pre- and post-implementation support have demonstrated the benefits of offering such 
support more systematically and on a declining basis. 

Implementation measures – This recommendation can be implemented through the following measures: 

•  Allocate resources to both pre- and post-project phases with a clear withdrawal strategy. 
•  Develop relationships with associations of municipalities, utilities, as well as private sector and civil 

society associations that can provide peer to peer learning. 

These measures should, led by the EU, be implemented in collaboration between the EUDs, the IFIs, and 
the relevant national stakeholders including the municipalities and associations.  

Urgency – This is important and of medium-term urgency.  

Recommendation 6: Enhance performance in crosscutting areas 

Enhance performance in climate, gender equality, and human rights.  

Linked to conclusion 5.  

Rationale - Climate, gender equality, and human rights are important cross-cutting issues. However, there 
is limited knowledge and understanding at national and sub-national levels regarding the integration of these 
aspects into infrastructure, policy, and empowerment interventions. The EU's requirements for integrating 
these  themes  were  more  seen  as  artificial/procedural  than  meaningful  requests  backed  by  guidance  and 
instructions. The  lack  of  know-how  and  the  rationale  behind  the  integration  of  in  particular  gender  and 
human rights issues in infrastructure projects contributed to the lack of activity at project level. Generally, 
commitments  made  at  the  programming  level  were  not  consistently  translated  into  the  project’s  results 
frameworks. 

Implementation measures – This recommendation can be implemented through the following measures: 

•  Provide guidance, already available, for project implementers and stakeholders on how to better 
estimate contribution to and integrate climate, gender equality, and human rights into infrastructure 

42 

 
 
 
projects.  Ensure  this  guidance  includes  best  practices  and  case  studies  that  illustrate  successful 
integration strategies. 

•  Use the programmatic approach (recommendation #2) to link infrastructure projects with policy, 

institutional, and capacity development in climate, gender equality, and human rights. 

•  Strengthen  the  consistency  between  commitments  made  at  the  programming  level  and  project 

results frameworks. 

These measures should, led by the EU, be implemented in collaboration between the EUDs and the relevant 
national stakeholders. 

Urgency – This is important and of medium-term urgency.  

Evaluation of EU support for the waste management and urban wastewater treatment in the Western Balkans region (2016 – 
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