What Results did the 2020-2022 Air Improvement Plan Bring to Rustavi?

On October 22, 2020 the 2020-2022 Action Plan for the improvement of atmospheric air quality in Rustavi was approved by the government of Georgia.

“Gavigudet” was involved in the process of developing the action plan, actively monitored the implementation of the activities provided for in the plan, and together with the citizens tried to adapt the process to the needs of Rustavi. However, there were a number of challenges during the implementation of the plan, about which we constantly shared information with the public in the form of informational materials and short reports (Report 1, Report 2, Report 3, Report 4, Report 5).

On February 23, 2023, the presentation of the final results of the action plan was held at the Ministry of Environmental Protection and Agriculture. In a few days, the Ministry will publish the report on the implementation of the action plan, however, until then, we would like to share information about the report and our comments regarding the process of the implementation of the action plan in general.

Let us remind you that the action plan for the improvement of the atmospheric air quality of Rustavi is an official political document, which aims to improve the quality of atmospheric air in Rustavi. The action plan combines five tasks, the implementation of which is responsible for the Ministry of Environment Protection and Agriculture of Georgia, the agencies included in the Ministry and Rustavi Municipality City Hall system.

In 2022, out of 30 activities planned within the action plan, 24 activities were being implemented, and 6 activities were fully implemented in 2020-2021.

What were the main results of the implementation of the action plan?

According to the report, as of December 31, 2022, 63% of the action plan activities were implemented. Also, 30% of the activities were mostly performed, and 7% were partially performed. The progress of implementation of activities was 87%. Does this mean that 87% of the action plan goal has been achieved? Of course not, because doing even 100% of the activities does not mean that the goal has been achieved. We will talk about the reasons for this in terms of tasks.

In our opinion, the most important of the 5 tasks of the action plan is the first task, which was intended to reduce the mass of particulate matter emitted from stationary sources (factories) in Rustavi from 14,151 tons to 2,010 tons. Unfortunately, according to the report, the mass of particulate matter was reduced by only 5705 tons (about 40%) to 8446 tons (instead of the target of 2010 tons). This is the result of the fact that during the implementation of the plan, significant gaps were observed in terms of timely enforcement of regulations imposed by large enterprises and compliance with environmental impact permit/environmental decision conditions. In addition, the annual report also mentions that the majority of the activities (4 out of 5 activities) could not be completed due to improper compliance with the legal requirements by the enterprises. If large industrial facilities do not fulfill the requirements established by the legislation, the average annual concentration of the smallest dust particles in Rustavi cannot be within the standards.

In order to solve the problem of pollution with particulate matter, it is necessary to reduce emissions by another 45%.

In 2022, the concentration of the particulate matter (PM10, PM2.5) decreased by 13-16% compared to the base year 2019, namely the average annual concentration of PM 10 was 55 μg/m3, and PM 2.5 was 27 μg/m3. Which, according to the 2022 report, is largely due to better enforcement of legal regulations by large industrial facilities.

However, the concentrations of solid particles recorded in 2022 still exceed the acceptable amount by 35-37%. Also, the cases of exceeding the daily concentration of PM10 are significantly higher than the norm (35 days), which, according to the report, totaled 187 days in 2022, and 43 of them were due to synoptical processes. We have some questions with the Ministry regarding the validation of these data, because based on the information displayed on the atmospheric air quality portal on December 31, 2022 (see the Screenshot),

we assume that we breathed polluted air for more than 187 days. As soon as we have a meeting with the Ministry on this matter, we will definitely share the information with the public.

It is worth mentioning, that within the framework of this task among the important activities carried out were the steps taken to strengthen the environmental supervision system in Rustavi, within the framework of which 64 inspections of 44 regulatory objects were carried out. In order to eliminate the violations revealed as a result of the inspection, specific remedial measures were determined for 10 objects with appropriate deadlines. In addition, a fifth inspector was added to the local division of the Department of Environmental Supervision.

In 2022, 8 enterprises were registered in the electronic system of self-monitoring (one of them is not functioning), and in 2021, 1 enterprise “MN Chemical Georgia” was added. In Rustavi there are 17 active enterprises, subjected to the environmental decision, which are obligated to do self-monitoring. Out of these 17 entities, 8 active enterprises are registered in the electronic system and another 8 enterprises have purchased a self-monitoring tool and are installing/testing it.

This is the list of registered active enterprises:

– LLC “Emen Chemical Georgia” – production of manganese oxide and manganese sulfate;

– “Rustavi Azot” – chemical industry;

– “Geosteel” LLC – metallurgical production;

– “HeidelbergCement Georgia” LLC – cement production;

– “Max Import” LLC – cement production;

– “GIA-2019” LLC – cement production;

– “Solo” LLC – cement production” (the web service is being prepared for running);

– “Mshenebeli 2004” LLC – cement production (the web service is is being prepared, besides the documentation for receiving the permission should be arranged).

Also, the cement producer “Lev 2019” LLC was registered in the system (the web service is being arranged), the enterprise is currently nonfunctional.

Regarding the first task, although 6 of the 11 activities of the first task have been fully implemented, and 5 have been largely fulfilled, the goal that the activities should have resulted in is not achieved yet.

As for the second task – reduction of emissions from motor vehicles in Rustavi. Despite the fact that 2 out of 4 activities were fully implemented, and two – to a greater extent, unfortunately, the situation almost did not change compared to the baseline level and has even worsened a little. The baseline figure was 55 μg/m3 and after the implementation of the action plan, this figure should be reduced to 40 μg/m3. However, along the main highway in Rustavi, the annual average concentration of nitrogen dioxide (NO2) in 2022 was 56 μg/m3 (which is 1 μg/m3 higher than the baseline). Also, the excessive concentration of nitrogen dioxide in two locations of the city (on Kldiashvili and Kostava streets) is a problem, the reason for which is the outdated car fleet in the country, including Rustavi.

As we read in the plan, this circumstance once again indicates that the activities provided by the action plan are insufficient to solve the problem of nitrogen dioxide pollution, and additional activities are necessary, more ambitious measures need to be planned and implemented on a national and local level.

Besides all this, our team is constantly discussing the problems, and in 2020 we demanded that the Rustavi-Tbilisi intercity transport issue be included in the plan. And let us remind you, that up to 25,000 people travel from Rustavi to Tbilisi every day for studies or work. Due to irregular transportation and the problem of getting to work, many Rustavi citizens have already bought cars, and many are planning to do the same in the future. Consequently, this increases the traffic emissions in both Rustavi and Tbilisi. It is true that a bus intended for students has been appointed in the direction of Isani, however, this only slightly solves the problem of transportation and more effective steps need to be taken. We are now trying to advocate this issue within the Central Zone Air Management Plan working group, and since this issue does not concern only Rustavi, we have received a promise that within the framework of the Tbilisi agglomeration air quality improvement plan, there will be a discussion of this specific issue.

As for the third task, in terms of improving the green infrastructure in Rustavi, the total area of green zones in Rustavi increased by 2 h. in the reporting period, which is 14 h more than the base level, and amounted to 999 h, however, the target figure was 1008 h. In 2022, 6 parks were arranged in the city and arrangement of 1 park is in progress, a 3,700 m2 bicycle path was arranged, more than 84,000 m2 of road surface and more than 20,000 m2 of sidewalks were rehabilitated and arranged, more than 2,200 trees and plants were planted. Maintenance of the green cover was regularly carried out and, as we read in the report, the wet treatment of the streets (Megobroba, Gagarini, Modebadze streets) was carried out. But unfortunately, the progress of the development of recreational opportunities of Rustavi parks is only 9%.

Regarding the fourth task result indicator, there are some challenges, because the purchasing of an additional automatic station with donor funding was not possible due to the delay in the procurement procedures during the reporting period. The station will be installed in New Rustavi at the end of 2023 instead of 2022. Regarding increasing the monitoring points and spectrum of atmospheric air quality in the city within the framework of this task, from December 2021, the gravimetric method of measuring the concentrations of benz(a)pyrene, cadmium, arsenic and nickel began. Fortunately, their average concentrations fall sharply below the maximum allowable norm.

In 2022, significant progress was made in terms of the implementation of the fifth task (increasing the number of environmental awareness-raising measures in Rustavi and the number of participants involved in it) by fully achieving the target rate in the reporting period – 18 environmental awareness-raising measures were carried out.

As we can see, a number of important steps have been taken in terms of the implementation of the action plan, however, many challenges remain.

It is mentioned in the report that the main challenge for solving the problem of air pollution in Rustavi is the improper fulfillment of air protection legislation and environmental impact permit/environmental decision conditions by large production facilities. However, apart from the challenges on the part of the enterprises, it is worth noting the unfortunate practice of delaying the activities to be carried out by the public agencies themselves, including the timely adaptations of legislative changes.

Our team is involved in the development of the Atmospheric Air Quality Management Plan (2023-2025) for the Central Zone and we hope that the new plan will be much more effective and efficient for Rustavi and will actually reduce the level of air pollution in the city. On the goal-achieving journey, the active involvement of society and monitoring of the process is of crucial importance.