2022 Interim Report on the Action Plan for the Improvement of Air Quality in Rustavi: Evaluation by “Gavigudet”

2020-2022 Action Plan for the Improvement of Air Quality in Rustavi is a sectoral policy document, which aims to improve the ambient air quality in Rustavi.

The civil movement “Gavigudet” was involved in the development of the Action Plan and continuously monitors its implementation. According to the official data of the Ministry, the quality of ambient air in Rustavi in 2021 remains unchanged, compared to the baseline level. Concentrations of the particulate matter (PM10, PM2.5) still exceeds the maximum permissible annual norms by about 60%. According to the plan, the baseline rate of the harmful substances, emitted from the stationary sources, should be 14, 151 tons, and the final rate should be 2, 010 tons. Mentioned aim would be realistic in case if all the activities, defined by the plan, were completed timely. However, considering the fact, that most of the enterprises are planning to increase the performance, together with the fact that new factories are being built because the norm for the city load does not exist, given rate becomes more and more unrealistic.

The main challenge for the action plan is implementation of the defined activities in a timely manner. For instance, according to the plan, ten activities should have been fully implemented by 2021, however as of December 31, 2021 six activities were implemented and three of them were completed late. Brief review, prepared by our team, of the 2021 report can be seen here. This report presents interim data for 2022.

According to the interim data for 2022, among the implementing institutions, the central apparatus of the Ministry has made the greatest progress, by fulfilling 100% of its obligations; for the Department of Environmental Supervision, this figure is 81%, for the Environmental Information and Education Centre – 94%, for the City Hall of Rustavi – 67% and for the National Environmental Agency – 61%.

Considering the fact, that solving the problem of the air pollution should be the top priority for the municipality, the level of progress in the implementation of the action plan is very low for Rustavi City Hall. It should also be considered, that the local municipality is responsible for 10 activities out of 30.

It is mentioned in the report, that the main challenge for implementing the Action Plan and solving the problem of air pollution in Rustavi is the improper fulfillment of the air-protection requirements by the large production facilities, including not carrying out the obligation of continuous instrumental self-monitoring.

In 2021, the monitoring of the implementation of continuous instrumental self-monitoring system should have been carried out; and an electronic system for receiving the self-monitoring data should have been created on the basis of the Ministry.

Unfortunately, currently, only 4 out of 17 active entities are registered in the electronic system of the self-monitoring at the base of the Ministry; these are: “MN Chemical Georgia” LLC, “GeoSteel” LLC, “HeidelbergCement Georgia” LLC, “Rustavi Azoti” JSC. It should be noted, that according to the information provided by the enterprises, the vast majority of them (11 enterprises) are planning to run the self-monitoring system by the end of 2022. These are: “Rusalloys” LLC, “Vivacement” LLC, “Max Import” LLC, “Elba Export” LLC, “GeoferroMetal” LLC, “RSM Corp” LLC, “Solo” LLC, “AMB Alloys” LLC, “Mega Cement” LLC, “Gia 2019”
LLC, “Mshenebeli 2004” LLC. We asked the Ministry what would the sanctions be in case these enterprises do not fulfill the obligation by the end of 2022, we think, their answer – “legal measures will be taken” – is general and only the indication, that the agency does not have a specific plan regarding such enterprises. The only company, known as not to able to fulfill this obligation by the end of the year is “Ferro Alloys Production” LLC; and the company, the Ministry has not received any information from, is “Rustavi Steel” LLC.

In 2022 there is almost no progress in the activities, which should be completed during 2021, including:

– Activity 1.1.5 – “Development of a specific plan, determined by the administrative correspondence, for facilities that do not comply with the conditions of the environmental decision or requirements, established by law” – is still mostly (67%) completed.

– Law on “Industrial Emissions” was planned to be adopted at the end of 2021. According to the latest data, it is planned to be presented at the parliamentary hearing at the fall session of 2022. The progress rate for this activity is 30% – the same as in 2021.

– The progress of arranging additional infrastructure for pedestrians is still 50%; and the rate of improvement of the road surface in order to reduce the dispersion of solid particles is 65%. In this regard, within the framework of the working group, we once again wrote to the Ministry that it is necessary to solve the problem of dusting the damaged roads in the production area. The road belongs to Rustavi Municipality, therefore, active involvement of the municipality in solving this problem is necessary.

As it is clear from the Ministry’s answer, our opinion was delivered to the Rustavi City Hall; and they informed that the main road in the production areas is asphalted and well maintained; what is about internal roads, that are directly connected to the enterprises, some have been rehabilitated, while others are planned to be rehabilitated gradually. However, on our letter, sent on August 10, 2022, the Rustavi City Hall responded, that they do not plan to rehabilitate the two roads, which are the major contributors to dusting the production area. Thus, we will once again try to check which information is true and what they mean by internal roads. We will share the received answer with you.

– The rate of improvement of publishing the results of conducted inspections and access to this information is 67% – identical to the 2021 report.

– The renovation project for Rustavi Youth and Recreation Park falls far behind the progress – currently, the rate of progress is 7%, while it should be 100% completed by the end of the year. In 2021, this rate was 6%.

– According to 2022 January-July interim report, out of the activities, to be performed in 2021, one activity was fully performed in June, 2022 –in 2021-2022, 5 new inspectors were added to the Kvemo Kartli regional division of the Department of Environmental Supervision.

In addition to the mentioned activities, that we hope, will be fully implemented in 2022, the Action Plan also includes the following activities:

– 1.4 – “Implementing procedures, defined by the Environmental Assessment Code, for objects, operating with the changes in technological process”. The activity is completed by 42%, after its full implementation, every object, operating with the changes in technological process will go through the screening / Environmental Impact Assessment procedure.

– 1.6 – “Monitoring the implementation of the activities, defined by the administrative correspondence, for the stationary objects, operating in Rustavi”. The activity is implemented by 50%. According to the report, in 2021 inspections were carried out on 3 objects (“GeoSteel” LLC, “Max Import” LLC, “Solo” LLC) in order to monitor the implementation of the measures, defined by the administrative correspondence.

– 1.7 – “Activating the process of fulfilling the obligations of the Waste Management Code for industrial objects in Rustavi”. This activity is implemented by 58%.

– According to the activity 1.1.11, the Department of Environmental Supervision should increase the number of inspections of existing enterprises. The activity is completed by 62%. We would like to remind you, that in total 76 inspections on 44 enterprises were carried out in 2021, details about the inspections can be seen in this article.

– During 2022 January-June reporting period, in total 34 inspections were made on 26 regulated objects. As a result, in case of 5 objects, the violation of the Waste Management Code was detected and the protocols of administrative offenses were made. 12 administrative correspondences were submitted to 7 objects in order to eliminate violations, detected during the inspection, and specific correction measures were determined with appropriate deadlines. The results of the inspections, conducted in Rustavi by the Department of Environmental Supervision in the I-II quarter of 2022 can be seen here.

– By the IV quarter of 2022 it is planned to arrange additional infrastructure for pedestrians and bicycle users.

– For 2022, the plan considers creating new recreational areas and continuation of rehabilitation of existing ones, as well as, maintenance of existing green cover and planting new plants throughout the city.

– Activity 1.3.5 also refers to infrastructural improvement – “wet cleaning of roads in Old Rustavi”. The activity is completed by 44%.

– Enlargement of the network of automatic monitoring of ambient air quality is also planned during the same reporting period – adding one automatic station. The Ministry mentioned that “it is desirable to be purchased and located in Rustavi on time”. Our dissatisfaction is connected to the word “desirable”, since it is the obligation, defined by the Action Plan, accordingly, we asked whether it was manageable to purchase and install the station by the end of 2022. As it is clear from the answer, it is planned to receive tender applications for the purchasing of the station until September 5, and only then it will be possible to specify the dates. Besides, the word “desirable” was replaced by the word “necessary”.

– By the end of 2022 indicative measurements of ambient air should be carried out for 12 stages on 6 points of the city. Only 4 stages of the activity were carried out for 2021, and in the I-II quarters of 2022 2 stages of indicative measurements have been carried out.

– The Plan envisages conducting at least 5 environmental activities, including informational and awareness raising activities on atmospheric air protection. 4 of them have already been conducted.

From the activities to be completed in 2022, 3 of them were completed in advance, including:

– Preparing and distributing informational materials about environmental issues, including air pollution, is completed by 100%.

– Train the inspectors of the Department of Environmental Supervision about new legislative requirements, including air protection issues.

– Involvement of the industrial objects, operating in Rustavi, in the activities related to raising environmental awareness.

The Action Plan will only bring positive changes in case agencies, under the Ministry and, first of all, the municipality will ensure activities to be carried out in a timely manner. With current attitude it seems, that problem solving is not a proper priority for these institutions. Proof of this is the fact, that the Ministry had not developed the proper document about the schedule of the fulfillment of air-protection regulations by the enterprises, before our movement imposed it as a demand of protest action, held on June 5, 2022; until then, the population was not informed about the dates of installing filters and self-monitoring system.

In addition, it is important the discussion of the interim report to be held in the format of the meeting.

You can see the full report of the Ministry on this link.

The short report was prepared with the financial support of “European Endowment for Democracy” in the framework of the project “Defending Our Right to Clean Air in Rustavi”.