How was the Air Quality Management Plan Implemented in the First Half of 2024?

shualeduri_angarishi The civil movement “Gavigudet” is a member of the working group for the 2023-2025 Air Quality Management Action Plan for the Central Zone. Accordingly, we received a working version of the interim report from the Ministry, which we studied and shared our notes and comments in writing with the Ministry. Before moving on to the monitoring report itself, we remind you that on August 6, 2024, information was published on “Gavigudet” website about activities to be implemented from January to June 2024 according to the Central Zone Atmospheric Air Quality Management Plan. You can view the information material at the given link.

General Progress of the Plan:

In the monitoring report, we read that out of 27 activities planned within the action plan in January-June 2024, 22 activities were being implemented. As of June 30, 2024, 15% of the action plan activities (4 activities) were completed. Also, by the end of the reporting period, 30% of activities (8 activities) were mostly completed, while 44% (12 activities) were partially completed. During the reporting period, the progress in implementing the action plan activities was 48%.

Activities to be Completed by June 30, 2024:

Preparation of Rustavi Floodplain Forest Restoration Plan

– According to the action plan, this activity should have been fully completed by December 31, 2023. Currently, the activity is 100% completed, though with a 6-month delay.

– The responsible body for implementing this activity is the Ministry of Environmental Protection and Agriculture/Biodiversity and Forestry Department.

Identification of activities subject to environmental technical regulations that represent significant sources of pollution and establishing specific mandatory actions to reduce particulate matter pollution

– According to the action plan, this activity should have been fully completed by June 30, 2024, however, it was only partially completed – 50%.

– The responsible body for implementing this activity is the Ministry of Environmental Protection and Agriculture/Environment and Climate Change Department. The consolidated status report states that a survey of global mitigation practices for reducing air pollution from inert material extraction and crushing was conducted. Based on this survey, a draft amendment to Government Resolution #17 of January 3, 2014, “On Approval of Environmental Technical Regulations” was developed to reduce air pollution from relevant activities, which is currently under internal review.

Assessment of Rustavi city population’s exposure to excessive concentrations of harmful substances (PM10, PM2.5, NO2)

– According to the action plan, this activity should have been fully completed by June 30, 2024. In this case, the deadlines were met and the activity is 100% completed.

– The responsible body for implementing this activity is the LEPL – L. Sakvarelidze National Center for Disease Control and Public Health.

We’re sharing our group’s comments prepared for written submission to the Ministry and the Ministry’s feedback on each of our comments:

– In one of the report’s chapters – “Challenges and Recommendations,” it’s mentioned that the main challenge in solving Rustavi city’s air pollution problem with particulate matter is the inadequate compliance with air protection requirements by major industrial facilities in the zone. “Gavigudet” agrees with the recommendation that active supervision measures must continue, and proactive monitoring of data provided by enterprises connected to the continuous self-monitoring electronic system of air emissions is necessary. It is also essential that the main inspection results be made public; however, in addition to publishing inspection results, self-monitoring results must be continuously available to the public.

Regarding this comment, the Ministry responded that they researched European practices and found that publishing continuous self-monitoring emission data is not common practice in EU countries. This also involves risks related to production confidentiality. Additionally, it is not a legislative obligation.

It is also important that the action plan monitoring report presentation be held online, and attending public members have the opportunity to ask questions.

If an online meeting is not held, we request DES (Department of Environmental Supervision) to provide a list of measures they plan to implement to improve the situation in this direction.

According to the Ministry’s response, the policy planning guide does not obligate the secretariat to publish a 6-month progress report on policy document implementation. Nevertheless, the report is prepared, discussed in the working group, and published on the Ministry’s website, ensuring key stakeholders’ involvement in monitoring the action plan implementation.

The Ministry also shared an appendix listing facilities they plan to inspect in 2024. From this appendix, we learn that only one facility (LLC “Global Trade Group”) is planned for routine inspection in Rustavi.

It is unfortunate that in Rustavi’s case, where industrial pollution is the main problem, the Ministry has scheduled only one routine facility inspection.

– In the report’s detailed discussion of Objective 1.3, it’s mentioned that during the reporting period, a pilot study on air pollution’s impact on the health of Rustavi’s population over 30 years of age was completed, and its results were presented to interested parties.

We note that the study results were presented in a presentation format, which only a small portion of interested parties could attend. Therefore, it’s important that the study and its results be published publicly. Even the majority of the “Gavigudet” team is not familiar with this study’s results, let alone the general public.

We asked the Ministry to share the study report with us and provide information about when the study results will be published publicly.

Ministry’s response: According to the secretariat, no report preparation is planned for the study, and its results were shared in presentation format. However, the results of this study will be briefly integrated into the final EU project report. For additional information, please contact the National Center for Disease Control and Public Health.

– One of the activities to be completed by June 30, 2024 – identifying activities subject to environmental technical regulations that represent significant pollution sources and establishing specific mandatory actions to reduce particulate matter pollution – has only been completed 50%.

Our group is asking the Ministry to specify in the given report the reason for the delay of this activity and the estimated timeframes for 100% completion.

The Ministry responded: A baseline study was conducted on environmental challenges in relevant activities, along with targeted inspection of activity subjects. Best international practices were researched, which the Ministry adapted to national-level challenges. This is why the development of the legal act draft was delayed. The approval of changes to environmental technical regulations is planned by the end of this year.

– The monitoring report states that during the reporting period, DES conducted 213 inspections of 185 facilities in the central zone, including 38 inspections in Rustavi city, which represents the central zone’s hot spot (1.1.3). Additionally, municipalities in the central zone conducted 70 inspections to reduce particulate matter emissions during construction and dusty construction materials storage-distribution processes (1.1.2). This process during the reporting period mainly had a preventive character regarding violations under Articles 1525-1529 of Georgia’s Administrative Offenses Code, and warnings/information were given to persons handling, placing, and transporting dusty materials. We asked the Ministry to attach a list of inspected facilities and inspection results as an appendix to the action plan monitoring report.

As revealed from the Ministry’s response, information about the list of inspected facilities and results is being prepared and will be published in September on the Department of Environmental Supervision’s website (des.gov.ge) along with previous year’s results.

– In the report, we read that a legal act draft was developed to reduce air pollution from inert materials extraction and crushing activities. We also requested sharing this act draft.

According to the Ministry representative’s explanation, only a working version of the act is currently developed, which may change after discussions. As promised, they will share the act draft with us after the final version is established.

– During the reporting period, 8 samples of diesel and gasoline were taken from 3 gas stations in the central zone to check automotive fuel quality (1.2.7). We requested sharing the inspection results.

We haven’t received the document showing the results, but the Ministry representative explained that no violations were found in any samples.

“Gavigudet” continues active communication with the Ministry regarding the monitoring report and, of course, will share all updates with you as well.

You can read the full January-June 2024 monitoring report at this link.

The material was prepared with the financial support from USAID National Governance Program.