How Was the Air Management Action Plan Performed in 2023?

gegmis_angarishi On August 7, 2023, the government decree N1431 approved the “2023-2025 Action Plan for the Management of Atmospheric Air Quality for the Central Zone”. In order to properly monitor the implementation of the plan, annual and 6-month summary monitoring reports are published.

“Gavigudet” is a member of the action plan working group. Accordingly, before publishing the monitoring report, we share comments/recommendations regarding the report to the Ministry of Environmental Protection and Agriculture.

In this material, we briefly share the main issues related to Rustavi and our recommendations in the 2023 monitoring report:

1) During the reporting period, 1 automatic air quality monitoring station in Rustavi continuously measured the concentration of hazardous substances, including particulate matter (PM10, PM2.5) in the atmospheric air. According to the station, the average annual concentration of PM10 was 41 μg/m3, and PM2.5 was 24 μg/m3. These indicators exceed the maximum permissible norm of PM10 (40 μg/m3) by 2.5%, and the norm of PM2.5 (20 μg/m3) by 20%. However, it represents a significant improvement compared to the 2022 baseline (PM10 – 55 μg/m3, PM2.5 – 27 μg/m3). Accordingly, the data for 2023 are 25% and 11% less compared to 2022, and compared to 2019 – by 35% and 25%. However, it is important that the daily concentration of PM10 exceeded the norm (35 days), which totaled 97 days in 2023.

The report mentions that the improved average annual quality indicators are likely due to better enforcement of legal regulations imposed by large industrial facilities.

However, we asked the Ministry to add to the report that the improvement is also related to the fact that ferroalloy enterprises located in Rustavi have temporarily stopped production as the price of ferroalloys has fallen on the international market. The Ministry took this recommendation into account and reflected it accordingly in the final version of the report.

2) The average annual concentration of NO2 in Rustavi in 2023 exceeded the norm (40 μg/m3) at two monitoring points (Kldiashvili St. and Kostava St. N19) and amounted to 54 μg/m3 and 48 μg/m3.

In order to prevent the concentration of nitrogen dioxide from increasing, it is important to solve the problem of intercity transport, so that the people of Rustavi do not buy private cars because of this problem and additionally pollute the environment. However, it should be noted that 20 new buses were added to Rustavi during the reporting period.

In addition to the transport, it is important to avoid chaotic urban development and its accompanying traffic jams, which will further pollute the air.

3) The average concentration of SO2, CO, O3, Pb, Cd, As, Ni, C6H6 and C20H12 recorded at the monitoring points located in the central zone does not exceed the norm.

4) In 2023, 475 inspections of 374 objects were carried out in the central zone, including 28 planned and unplanned inspections. From them, 69 inspections of facilities located in Rustavi.

5) from September 4, 2023, In Rustavi, road monitoring of visible emissions from motor vehicles is carried out, within the framework of which 430 penalty receipts have been issued.

6) We asked the Ministry to emphasize even more the importance of detection and prevention of the facts of dry processing of dusty materials, because even during the rehabilitation works carried out by the City Hall of Rustavi municipality, dusty materials were processed dryly throughout the city. This further pollutes the air in the city. The Ministry also considered this recommendation and emphasized the issue of processing fragile material in the report. However, the implementation of this recommendation is the obligation of the Rustavi City Hall. If the City Hall itself does not require its contractors to comply with the law, then the inspections conducted by them and the fining of several individuals or legal entities are meaningless.

7) In terms of improving the system of atmospheric air pollution impact on human health, it should be noted that the a pilot study of the impact of air pollution on health was held in Rustavi, using the World Health Organization’s quantitative research tool – AirQ+. As soon as the research results are made public, our team will share the information with you.

8) Unfortunately, the Ministry still has no information on when the data from the station located in the yard of the N20 school of Rustavi will be reflected on the atmospheric air quality portal (www.air.gov.ge). It is important to solve this issue in a timely manner so that the population has continuous information about the air quality in their settlement.

9) The report mentions that in 2023, 8 industrial facilities in the central zone were fined for non-fulfillment of the obligation of continuous self-monitoring by the instrumental method (Article 761 of the Civil Code). In addition, 12 enterprises have been fined or are undergoing administrative proceedings within the framework of continuous self-monitoring due to exceeding the permissible emission norms for the emission of harmful substances into the atmospheric air.

The majority of enterprises in Rustavi (subjected to this obligation) have installed a self-monitoring system. However, our team will once again request public information on which other enterprises besides “Rustavi Steel” remain violators of the law and whether there is any enterprise located in Rustavi among the 12 fined enterprises.

The introduction of a self-monitoring system is important, as it is an important prerequisite for the proper operation of dust collection devices in the respective enterprises.

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Importantly, the report highlights the challenges that prevent the proper improvement of air quality. Among these challenges, it is worth noting:

– Insufficient supervisory activities for the prevention of pollution not only in the means of particulate matter, but also of other sources of pollution;

– along with the implementation of the activities described in the plan to reduce nitrogen dioxide pollution, the need to plan and implement additional activities at the national level;

– Challenges in the practice of wet-sweeping of the streets;

– lack of effective supervision of processing, placement and transportation of dusty materials, and regarding this only giving information/warning may not play a proper role in pollution prevention;

– Gaps in terms of timely enforcement of regulations by large enterprises and fulfillment of environmental impact permit/environmental decision conditions;

– Challenges in the direction of introducing the self-monitoring system;

– Necessity of determining mandatory actions for small enterprises / activities subject to environmental technical regulations, which are a significant source of pollution with particulate matter. It is necessary to determine the mentioned actions in time, so that the subjects of these activities can complete their obligation by the end of 2025.

We also agree with the Ministry’s opinion that it is necessary to proactively monitor the data provided by the enterprises already included in the electronic self-monitoring system, in which the Department of Environmental Supervision has the main role.

We are also pleased that the report reflects our recommendation from previous workshops that key inspection findings should be made public to inform interested parties.

Finally, these recommendations mustn’t remain unheard, and the activities described in the action plan are not only formally implemented,in addition, we try to protect and improve air quality with our daily actions beyond the activities determined by the action plan.

The full version of the monitoring report of the 2023 action plan can be found on the website of the Ministry: https://mepa.gov.ge/Ge/Reports.