2021 Report on the Air Quality Improvement Action Plan

The action plan is a sectoral policy document, which aims to improve the ambient air quality in Rustavi. This short report provides an analysis of the activities carried out from 1 January to 31 December 2021, with our remarks and recommendations.

Unfortunately, the report clearly states that by 2021 the quality of ambient air remains unchanged. The lowest solid matters (PM10, PM2.5) are still about 60% higher than the annual limit. Through the efforts of our team, it has been clarified that PM10 exceeds the annual limit by 58% and PM2.5 – by 60%. The report itself says that this is “mostly”[1]due to another reason – improper implementation of the established legislative regulations.

The problem is also the issue of timely implementation of the activities envisaged by the Action Plan, as of December 31, 2021, 20% of the activities of the Action Plan have been implemented. Also, 50% of the activities were mostly completed, and 30% were partially completed. The progress of the implementation of the activities was 64%.

In 2021, the action plan envisaged 6 activities, only the following activities were completed on time:

– Renovation of the municipal bus fleet;

– Increase the range of ambient air quality monitoring in Rustavi by measuring the concentrations of benzene(a)pyrene, cadmium, arsenic, and nickel. Their determination began in December 2021 and the annual average concentration will be presented in December 2022.

As for the activities listed below, they are only partially completed:

– a continuous self-monitoring system for the emission of harmful substances by stationary sources and the establishment of an electronic system for receiving self-monitoring data on the basis of the Ministry (53% fulfilled);

– Develop a specific plan defined by administrative correspondence for enterprises that do not comply with the conditions of the environmental decision, or the requirements set by law (67% fulfilled)

– Adoption of the Law of Georgia on Industrial Emissions (30% fulfilled);

– Provision of additional human resources to the Kvemo Kartli Regional Division of the Department of Environmental Supervision(80% fulfilled);

As you can see, the activities that were supposed to be completed by the end of the IV quarter of 2021 were not fully completed in February 2022 either. Given the fact that the implementation of activities in 2020 was delayed, the impression remains that neither the central nor local governments are taking the issue seriously, no effective steps have been taken by them, and despite the fact that the civil sector is constantly appealing for the timely execution of the legislative changes, they ignore this demand. Such attitude then becomes the reason why entrepreneurs benefit from the postponed processes and 9 months after the enactment of the law (June 1, 2021), in the case of organized emissions of harmful substances, only one enterprise is fulfilling the obligation to continuously determine the actual number of emissions from stationary sources of pollution into the ambient air by the instrumental method. This is a result of the fact that instead of the 4th quarter of 2020, as envisaged in the Action Plan, the Code of Administrative Offenses of Georgia, the Law of Georgia on Ambient Air Protection, and the Law of Georgia on Environmental Protection were amended only in March 2021.
In connection with this law, our team requested the list of enterprises that have the obligation to continuously determine the actual number of emissions from stationary sources of pollution into the ambient air by using the instrumental method. This list was requested from the Ministry of Environmental Protection and Agriculture even before the law came into force and we shared their answer to the society. It was mentioned in the material that the continuous determination of the actual number of emissions into the ambient air by using the instrumental method would be mandatory for the 24 enterprises located in Rustavi.

However, as we read in the “2021 Report on Rustavi Ambient Air Quality Improvement Action Plan (2020-2022)”, “About 15 active entities have been identified, which are related to the obligation of self-monitoring”.

We discussed this issue at a working meeting on February 22 and as the representatives of the Ministry clarified, these 24 enterprises are the most serious polluters and are responsible for 97% of the total share of emissions in Rustavi. However, according to the law enacted on June 1, 22 enterprises are obliged to continuously determine the actual number of emissions from stationary sources of pollution into the ambient air by the instrumental method, and currently only 15 enterprises out of 22 are active.

Our team has already requested a list of these enterprises and you can find detailed information at the following link.

The action plan clearly states that “The main challenge for solving the problem of air pollution in Rustavi is the improper fulfillment of the conditions of air protection legislation and environmental impact permit/environmental decision by large industrial enterprises and the non-fulfillment of the obligation of continuous instrumental self-monitoring.”

The report states that the capabilities of Kvemo Kartli Regional Division of the Department of Environmental Supervision has improved and the number of on-site inspections has increased dramatically. 76 inspections of 44 enterprises were carried out, as a result of which, in order to eliminate the identified violations, 9 enterprises got administrative correspondence and specific remedial measures were identified with appropriate deadlines. If you want to know which enterprises were inspected in Rustavi in 2021, you can see the informative material prepared by us. The civil movement “Gavigudet” welcomes the activation of the Department of Environmental Supervision, but we think that this is not enough and the they must visit the enterprise zone several times a day and respond daily to the violations, which are often seen by an unarmed eye. Even the daily response of the population to the hotline calls is not enough for effective monitoring. Add to this the fact that there have been cases when the group is late to the enterprise, when the process of unorganized emissions is no longer active and, consequently, the proper response is not possible.

We would like to remind you that from June 1, 2021 to December 31, 2021, for the enterprises located in Rustavi, 15 violation reports were drawn up in accordance with Article 761 of the Code of Administrative Offenses due to non-fulfillment of the obligation to continuously determine the actual amount of emissions from stationary sources of pollution from stationary sources into the ambient air, and based on these reports 8 enterprises were fined, while others received a warning note. Detailed information can be found in our report.

As for the content of solid particles in the air, in 2019 and 2021 the annual rate was 63 mkg/m³ for PM10 and 32 μg/m³, PM2.5. The same rates in 2020 were equal to 58 mkg/m³ and 31 μg/m³. The report states: “Compared to 2020, the regression may be due to an increase in transboundary pollution cases, as in 2021, more than 19 cases of daily PM10 concentrations (69 instead of 50) were due to synoptic processes (the spread of air masses containing desert dust particles on the territory of Georgia) was detected”. However, our recommendation is to study the meteorological conditions, it is interesting how many days in 2021 there was abundant rainfall in Rustavi. According to our observations, there were a lot rainy days in Rustavi in 2020 than in 2019 or 2021. We think this should be an important determinant of the change in the solid particle ratio.

Also, we read in the report that “compared to the basic level, in Rustavi, the mass of solids emitted into the air from stationary sources has been reduced by about 9%, which is a result of better compliance with air defense requirements and maintenance of air dust collector systems by individual industrial facilities on the ground. It is unclear what the reasoning is based on, because as our team got response, the Ministry does not have accurate information about the companies that have filters installed. Consequently, it is impossible to establish a similar correlation. In order to substantiate this reasoning, we have already asked the Ministry to send us a list of enterprises that have installed and use air dust collector devices. Our team will traditionally share the answer with the society.

In addition to the solid particles, you will find information in the report about another major pollutant, nitrogen dioxide. Nitrogen dioxide concentration exceeded the norm at two locations (Kldiashvili St. and Kostava St. N19). However, its annual concentration along the main highway has been reduced by 3 units. It is true that the quality indicator needs to be reduced by another 12 units, but this fact is still gratifying.

According to the report, Rustavi City Hall is slightly behind the planned figure. Progress in the implementation of activities related to the improvement of green infrastructure is 46%, which indicates a slight delay in the implementation of the activities envisaged in the plan. It is also noted that during the reporting period, the indicator provided for in the Action Plan for 2021 in terms of arranging the infrastructure for walking and cycling could not be fully achieved. As both activities were the direct responsibility of the City Hall, we think it is important for the local government to be particularly active and prepared for the responsibilities set out in the Action Plan and to be an example for the central government or other structures.

At the same time, during the meeting, “Gavigudet” responded to the activity 1.3.1. envisaged in the action plan, which includes the transfer of seedlings to schools. Due to the fact that some of the schools in Rustavi are delivered seedlings almost every year, due to improper maintenance, especially watering problems, these trees are drying. “Gavigudeet” suggested the Rustavi City Hall to arrange the irrigation system with the help of the donor of “Gavigudet” at the territory of one of the schools where more than 100 trees would be planted. Indeed, on the second day of the meeting, we were contacted by the Deputy Mayor and with the help of UNDP/GEF SGP for the newly planted trees in the 11th school, the movement “Gavigudet” organized a drip irrigation system.

At the meeting we saw even more clearly the importance of the working group. If not the working group, our team as well as the volunteers would not be able access to a number of documents, and we would not have had the opportunity to discuss in detail the most important issues for Rustavi together with the relevant officials. In addition to the information presented in the report, we have asked other questions, some of which you can read at the following link. We hope that the action plan will not be a one-time case and it will be developed in the coming years, will become much more effective and will enable civil society to be actively involved in it.

The full version of the Action Plan 2021 Monitoring Report can be downloaded from the Ministry’s web-site.

[1] Instead of the word “mostly” the word “maybe” was written in the working version of the report, which after communication with us, the Ministry changed and thus once again emphasized the guilt of the enterprises in pollution.

The report 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.