2021 Action Plan Report – Answers to our questions
2021 Action Plan Report – Answers to our questions
On February 22, the civil movement “Gavigudet” attended the discussion of the report of the “Rustavi Ambient Air Quality Improvement Action Plan 2020-2022”.
The meeting discussed the activities defined by the objectives of the action plan and assessed the timing and effectiveness of their implementation during 2021.
At the meeting, our team clarified several issues, which, we think, will be interesting for the people. Therefore, some of the issues discussed will be presented in a question-answer format.
– We read in the report that “compared to the basic level, the mass of solids emitted into the ambient air from stationary sources has been reduced by about 9% in Rustavi”. What method is used to calculate this percentage?
As in the preparation of the 2021 report, as well as in the development of the initial action plan – in determining the basic data, the Ministry takes into account not only the documentary material provided by the enterprises, but also the data of the Department of Environmental Supervision inspections.
Enterprises report not only final emission data, but also information on productivity, fuel consumption, raw materials used, and emissions. It is true that this information allows the Ministry to see the full picture, but since the situation is often different on paper and in reality, it became necessary to study the violation reports. As the representatives of the Ministry noted, the results of the inspection also show that often the documentary data does not correspond to the reality on the ground.
– How each enterprise’s share of pollution is calculated?
When counting this information, the information provided by stationary sources in Rustavi about both emissions and discharge should be considered. In the event that it becomes clear from the ESD violation reports of a particular enterprise that the enterprise does not comply with the regulations, does not have filters, in order to determine the real share of the enterprise, it is better to consider the information about discharge.
In addition to the issue of compliance/non-compliance from their side, it is necessary to pay attention to the type of enterprise. It is important to consider the sector, field, and the profile of the enterprise. For example, the volume of solid particles produced by cement production is much higher than that of a large metallurgical plant.
– In rainy weather the air is much cleaner, when analyzing the final report and data, we take into account the impact of rain on solid particles?
Meteorological parameters are directly related to air quality. Air quality is affected not only by rain, but also by wind direction, speed, and temperature.
There are meteorological sensors at the station located in Rustavi and the mentioned meteorological processes are being monitored, however, the correlation with its air quality has not been established yet. Neither does European law regulates this, so it can be said that meteorological processes do have an impact on air quality change, though not significantly.
– Today, many enterprises in Rustavi are increasing their productivity. When the city is already in such a difficult situation in terms of air pollution, how much will the filtration system give us relief in conditions of increased productivity? To what extent does the legislation allow the performance norm to be set in the city?
Applying to the ministry to increase productivity can have a positive effect. When an old permit is issued to an enterprise, it is usually ineffective. Re-test and re-evaluation during the increase of the productivity ensures even more strict and complex check.
As for the addition of new enterprises, the implementation of the “Environmental Assessment Code” in 2018 has made the process of environmental impact assessment even more effective, as many issues are being addressed more strongly than before. Particularly noteworthy is the cumulative impact part. Cumulative impact assessment is an effective tool to theoretically determine whether that particular location has the resources to add another enterprise there. Unfortunately, this method is not ideal, but it is effective in determining whether a new enterprise can be built in a particular area or increase productivity for an existing one.
Also, as the representatives of the Ministry noted, in part of the emissions, the enterprises do not provide real information to the Ministry. The only mechanism of the Ministry in this case is modeling. Modeling allows the specialist to determine whether it is possible to set up an additional new enterprise in the area/increase the productivity of the old one.
As for the city resource – in terms of the smallest solid particles, when there is an excess of this size in the city, the representatives of the Ministry also agree that there can be no talk of any additional resources.
– Our team thinks that the 500-meter radius (where the cumulative impact is considered) is too small for the Rustavi production zone and does not reflect reality. Often the Ministry relies on calculations and modeling by consulting companies, which is usually different from the reality.
Misinformation provided by consulting companies is a complex issue and cannot be the responsibility of the Ministry alone. The Ministry often goes to the site to check the existing conditions, however when it comes to the project area, the Ministry is forced to rely on the data of the consulting company.
These documents are strictly checked and analyzed and in the case of Rustavi it is given special attention.
– Is the electronic system of the Ministry functioning? Enterprises often blame the Ministry and its malfunctioned electronic system for non-compliance with the obligation to continuously determine the actual number of emissions from stationary sources of pollution into the ambient air.
There is no challenge for the Ministry in this regard, therefore the fact that the enterprises still think that the process has not been initiated by the Ministry itself, is just a reason for them to justify themselves.
The system has been in operation for almost a year, and various enterprises operating in the country have been involved in it for months. The system is so assembled that the model or manufacturer of the device do not matter. It is not adapted to any particular standard, has no technical specification except that it must measure data within the timeframe required by the technical regulations. The procedure for inclusion is as follows: the IT specialist of the enterprise connects to the server; the IT representative of the Ministry gives it a protocol and a connection is made.
– Why was the adoption of the Law of Georgia on “Industrial Emissions” delayed?
Representatives of the Ministry could not give a specific answer to this question. Please be reminded that this law should have been adopted in the IV quarter of 2021, but now it is planned to discuss it in the spring session of 2022.
– Measurements of new pollutants – benzopyrene, cadmium, arsenic, and nickel – have started in Rustavi. Whether there are current data and how intensively these pollutants are measured?
The methodology is fully in line with the European standard. The instruments are sampled on a continuous basis. The device itself, which tests this sample, is very sensitive and measures pollutants in nanograms. As for the data, only the annual norm is set for all four pollutant, therefore the analysis and evaluation of the data will not be effective until the end of 2022.
The material was prepared within the framework of the project “We are Protecting the Right to Fresh Air in Rustavi”, which is implemented with the support of the European Foundation for Democracy.