air quality management plan for the city of tshwane
Transcription
air quality management plan for the city of tshwane
Project done on behalf of City of Tshwane Metropolitan MunicipalityDepartment of Social Development AIR QUALITY MANAGEMENT PLAN FOR THE CITY OF TSHWANE METROPOLITAN MUNICIPALITY 2006 - 2008 Report No.: APP/05/CTMM-02a Rev 2 DATE: December 2005 Authors: Hanlie Liebenberg-Enslin Gillian Petzer Airshed Planning Professionals (Pty) Ltd PO Box 5260 Halfway House 1685 Tel : +27 (11) 254 4929 Fax : +27 (11) 805 7010 e-mail : [email protected] COPYRIGHT WARNING With very few exceptions, the copyright in all text and other matter (including the manner of presentation) is the exclusive property of Airshed Planning Professionals (Pty) Ltd and the City of Tshwane. It is a criminal offence to reproduce and/or use, without written consent, any matter, technical procedure and/or technique contained in this document. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page i EXCECUTIVE SUMMARY 1. INTRODUCTION According to the Constitution, municipalities have the executive authority in respect of air pollution control. The new National Environmental Management: Air Quality Act of 2004 1 has shifted the focus away from centralised air pollution governance to the decentralisation of power, placing the responsibility of air quality management on the shoulders of local authorities. These responsibilities include the characterisation of baseline air quality, the management and operation of ambient monitoring networks, the licensing of listed activities, and the development of emissions reduction strategies. In order to fulfil these responsibilities local authorities will be required to develop Air Quality Management Plans (AQMP) as part of their Integrated Implementation Plans. The main objective of the act is to ensure the protection of the environment and human health through reasonable measures of air pollution control within the sustainable (economic, social and ecological) development framework. The City of Tshwane Metropolitan Municipality (CTMM) identified the necessity for the development of strategic planning processes to enable environmentally sustainable development within the municipality. The Tshwane Integrated Environmental Policy (TIEP) has been formulated by the Housing, City Planning and Environmental Management Department (Environmental Management Division) to form the foundation from which all the departments within the CTMM can develop medium-term environmental management strategies. This TIEP will form an integral part of the Integrated Development Plan (IDP) process, incorporating both the State of the Environment Report and the Environmental Implementation Plan. Air quality management falls within the system of pollution minimisation, management and prevention, and aims to improve it in areas with poor air quality, and maintain it in areas with good air quality. It is within this context that the Environmental Health Division initiated the development of an Air Quality Management (AQM) Plan for the CTMM. The main purpose of developing an Air Quality Management (AQM) Plan is to empower the metro to meet its obligations as outlined in the Air Quality Act (AQA). The AQMP will initiate ‘best practice’ in air quality management and ensure the reduction of emissions in a cost effective and equitable way. This will ensure the improvement of air quality within CTMM and subsequently the reduction of environmental and health risks, which is also in line with the requirements of the TIEP. The main goals to be achieved by the CTMM through its development, implementation, review and revision of air quality management plans were as follows: • To achieve and sustain acceptable air quality levels throughout the CTMM. • To minimize the negative impacts of air pollution on health, well-being and the environment. 1 The National Environmental Management: Air Quality Act (Act no.39 of 2004) commenced with on the 11th of th September 2005 as published in the Government Gazette on the 9 of September 2005. Sections omitted from the implementation are Sections 21, 22, 36 to 49, 51(1)(e),51(1)(f), 51(3),60 and 61. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page ii • To promote the reduction of greenhouse gases so as to support the council's climate change protection programme. • To reduce the extent of ozone depleting substances in line with national and international requirements. Specific objectives included: • To promote cleaner production and continuous improvement in best practice as it pertains to air pollution prevention and minimisation. • To promote energy efficiency within all sectors including industrial, commercial, institutional, mining, transportation and domestic energy use. Based on the requirements of AQA and the TIEP, the Department of Social Development initiated the development of an Air Quality Management Plan for the CTMM. Airshed Planning Professionals (Pty) Ltd was appointed to assist the Environmental Health Division in formulating a detailed Air Quality Management Plan. Although Airshed represented the lead consultancy, Airshed sub-contracted Zitholele Consulting to provide support services for the project. Zitholele was responsible for public notification of the project and for consultation with interested and affected parties. 1.1 Scope of Work To achieve the set-out objectives, it was proposed that the project had two focus areas: • Baseline assessment of air pollution concentrations and air quality management practices within CTMM, and inventory of national and provincial requirements pertaining to AQMP development. • Development of an Air Quality Management Plan for CTMM, taking into account: • operational and functional structure requirements • air quality management system component requirements • source identification and prioritisation • emission reduction measures implementable • mechanisms for facilitating inter-departmental co-operation in the identification and implementation of emission reduction measures for certain sources • human resource development (training) requirements The integration of technical evaluation and public issues were considered paramount in the AQMP development process to ensure that the project team do not function in isolation. The AQMP development process was divided into three components for planning and administrative processes, viz. a technical process, an advisory process and a consultation process. The technical process comprised all information syntheses, issue analyses and document drafting tasks to be completed by technical members of the project team. The advisory process refers to consultation between the project team and the Steering Committee, Technical Working Group and Stakeholder Group. The consultation process Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page iii included the dissemination of information and invitations for public participation, organisation of discussion workshops, and collection and collation of comments for communication to the technical team. The AQMP is intended to be used as the management and performance-monitoring tool for air quality control and to provide a baseline assessment of air quality issues within the CTMM. The purpose of the plan was to address various categories of air pollutants including: toxic and odoriferous substances, greenhouse gases and ozone depleting substances. Although greenhouse gas emissions were included, these were not addressed in detail since it was assessed as part of the Energy Strategy Report developed for CTMM in parallel to the AQMP process. The plan also omitted noise and radioactivity since it was addressed internally by the municipality. The main objectives of the comprehensive AQMP to be drafted for the CTMM were: • An Air quality Management Plan (AQMP), including targets and projections; a financial plan – short, medium and long term – linked to the Integrated Development Plan of CTMM; best abatement measures – plan, project and programmes for CTMM. • A source inventory is a comprehensive, accurate and current account of air pollutant emissions and associated data from specific sources over a specific time period. In the establishment of data based fields for the CTMM source inventory the greenhouse gas emissions inventory and reporting requirements of the metropolitan had to be taken into account. • An Air Quality Management Information System with all air quality data compatible with acceptable modelling requirements and management information system requirements. • The development and implementation of the AQMP has critical implications in terms of human resources, training and cost requirements. These implications had to be thoroughly explored as part of the project and the system tailored to ensure the practical feasibility of the AQM system to be proposed for implementation as part of the CTMM AQMP. • Participatory workshops on the draft and final reports. To achieve these objectives, the following process was followed in terms of preparation for the drafting of the plan, plan compilation and consultation with technical peers and air quality stakeholders: (1) Completion of an air quality baseline assessment comprising: • identification of sources, pollutants and areas of concern; • inventory of current management and operational structures within the Metro; • inventory of current procedures and methods adopted by the Metro, GDACE and national authorities to combat air pollution within the region; • determine national and provincial requirements pertaining to AQM planning within the City of Tshwane; and, Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page iv • review best international practices pertaining to AQMP development and implementation. (2) Propose pertinent actions to be taken by relevant Departments within the CTMM in the short- and medium-terms with regard to: • operational and functional structure optimisation; • air quality management system development; • source quantification and assessment; • emission reduction measure implementation; and, • emission reduction measure investigation. (3) Conduct meetings with Technical Working Groups to discuss proposed measures. (4) Consolidation of proposed measures within discussion documents. Two discussion documents were compiled, viz.: (i) proposed air quality management policy framework, and (ii) air quality management system design, and emission quantification and reduction programme. (5) Workshopping of measures included in the discussion documents with the Technical Working Group and Air Quality Stakeholder Group. (6) Revision of the content of the discussion documents based on comments received at the workshops, where applicable. (7) Compilation of the Draft Air Quality Management Plan on the basis of the revised discussion documents. Presentation of the contents of the draft plan to Technical Working Group and workshopping of the draft plan. (8) Workshopping of the contents of the plan with the public (1 December 2005), collation of comments and addressing of issues prior to plan finalisation. (9) Integration of comments received and compilation of a Draft-Final Air Quality Management Plan. Submission of the draft-final plan to CTMM, the Technical Working Group and Air Quality Stakeholder Group and placing of the document in public places(2). (10) Submission of the Final AQMP to CTMM (December 2005), with copies of the plan circulated to Technical Working Group and Air Quality Stakeholder group members and placed in public places for general access. 2 2.1 BASELINE CHARACTERISATION Background Information CTMM is located directly north of Johannesburg and extends from Centurion in the south to Temba in the north, covering an area of 2,200 km². The municipal boundaries are mainly 2 Copies of the Draft-Final Air Quality Management Plan were placed in all municipal libraries within the City of Tshwane after 1 December 2005. Advertisements were placed in the press to notify people of the availability of these documents and to invite their comments. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page v within the Gauteng Province with a small area in the north falling within the North West Province. The population of CTMM borders onto 2 million (according to the 2001 Cencus) of which most reside in Pretoria, Centurion, Temba, Soshanguve and Mabopane districts with the highest population density within the latter two. The topography of the area consists of hills, ridges and undulating plains. The only topographical feature that might influence the dispersion potential of the metro is the Magaliesberg. This mountain range stretches from the northern suburbs in the east to Rustenburg in the west forming shallow valley within the central part of Pretoria and the Crocodile River regions called the Magalies Moot. The dispersion potential of the metropolitan region are predominantly influenced by mesoscale processes including thermo-topographically induced circulations, the development and dissipation of surface inversions, and the modification of the low-level wind field and stability regime by urban areas. Northerly to north-westerly winds prevail during much of the year due to the prevalence of the high pressure system. Although such winds continue to dominate during winter months, the northward shift of the high pressure belt and resultant influence of westerly wave disturbances on the region gives rise to an increase in the frequency of winds from the south to south-westerly sector. An increase in the frequency of northerly to easterly winds during spring and summer months is the result of the southward migration of the high pressure belt, with airflow being influenced both by anticyclonic subsidence and easterly wave systems. 2.2 Priority Pollutants within CTMM Criteria pollutants are pollutants commonly found from various sources and for which healthbased criteria (science-based guidelines) have been established as the basis for setting permissible levels. Typical pollutants include: particulates (including soot, fly ash and aerosols), sulphur oxides (SOx), oxides of nitrogen (NOx), carbon monoxide (CO), carbon dioxide (CO2), volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), methane (CH4), ammonia (NH3), hydrogen chloride (HCl), hydrogen sulphide (H2S), ozone (O3) and other photochemical oxidants (as secondary pollutants) and various trace elements. Organic compounds released include formaldehyde, benzene, poly-aromatic hydrocarbons, PCBs and dioxins and furans. Limited ambient monitoring data exists for the CTMM. Currently two monitoring stations are operated by the CTMM, the Rosslyn station and the Pretoria West station. The Rosslyn monitoring station measures PM10, SO2, NO2, NO, NOx, CO and ozone whereas the Pretoria West only measures PM10. Historically, SO2 and smoke (particulates) were monitored at nine locations within the CTMM. In addition, lead monitoring has been conducted since 1987 to 1998 as part of the DEAT Lead Monitoring Project. From the limited monitored data available, the priority pollutants that should be considered within the short-term (first two years) are particulates (PM10), sulphur dioxide (SO2), and nitrogen dioxide (NO2). Greenhouse gas pollutants (CO2, CH4, ozone, etc.) are addressed in more detail in the CTMM Energy Strategy. In the medium (3-5 years) to long-term attention should be paid to other pollutants such as Benzene and PM2.5. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page vi 2.3 Priority Sources within CTMM CTMM is not a highly industrialised area and comprises of a few large industries, various commercial activities, domestic fuel burning, mining operations, transportation sources and waste treatment and disposal. Sources of emission identified as occurring within the CTMM are summarised in Table 1. The significance of transboundary sources through their contribution to the regional aerosol component is noted in the table despite such sources not being located within the region. Pollutants released by each source are indicated. Table1: Sources of atmospheric emissions within the CTMM and their associated emissions Sources PM SO2 NOx CO CO2 CH4 HAPs Vehicle-tailpipe emissions Industrial operations, energy generation and commercial fuel burning appliances Domestic fuel burning Biomass burning Vehicle-entrainment of road dust Aviation emissions Mining activities Landfills Incineration Agricultural activities Tyre burning Wind-blown dust from open areas x x x x x x x x x x x x x x x x x x X x x X X X x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x Regional aerosol x (from distant sources) HAP - hazardous air pollutants (includes toxins and carcinogens) x - indicates pollutant is emitted by particular source type 2.4 Priority Areas with CTMM The main areas of concern within the CTMM are those located near industrial areas such as Pretoria West and the Moot. The Moot area is furthermore affected by the location of numerous brickworks within the area resulting in low-level emissions resulting in poor dispersion due to the topography of the area. Secondly, areas in close proximity to highways and busy intersections will be affected by vehicle emissions. Informal settlements likely to used coal and wood as energy source will be affected due to the low level releases of emissions and especially during the winter months when more fuel is consumed. The first step in designing an ambient air quality monitoring network is to identify the main pollutants of concern and the priority areas potentially impacted by these pollutants. Table 2 provides a synopsis of the main pollutant, sources of pollutants and potential impacting areas within the CTMM. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page vii Table 2: Summary of Priority Pollutants, Sources and Areas Pollutants PM10, PM2.5 NO2 (Nitrogen dioxide) Ozone SO2 (Sulphur Dioxide) VOCs (Volatile Organic Compounds) CO (Carbon monoxide) Air Toxics Main Contributing Sources - Power generation (Rooiwal and Pretoria West power stations) - Industrial (e.g. Ceramic, Cement and Iron& Steel) - Household fuel combustion - Other (vehicle entrainment of road dust, wild fires, tyre burning – significant in terms of episodes) - Transport (diesel vehicle emissions) - Transport (petrol vehicles, diesel vehicles) - Power stations (Rooiwal and Pretoria West power stations) - Industrial processes (e.g. Ceramic, Cement and Iron& Steel) - Household fuel combustion - Wild fires, tyre burning, etc. as minor sources - Secondary pollutant associated with NOx and other precursors releases - Transport (petrol vehicles as key contributor, also diesel vehicles) - Household fuel combustion - Industrial processes - Wild fires - Power stations (Rooiwal and Pretoria West power stations) - Industrial and non-domestic fuel burning sector (e.g. Cement and Iron & Steel) - Transport - Household fuel combustion - Wild fires, tyre burning - Transport (petrol vehicles as key contributor, also diesel vehicles) - Household fuel combustion - Industrial processes (e.g. Ceramics, Cement and Iron& Steel) - Wild fires - Transport - Household fuel combustion - Power stations (Rooiwal and Pretoria West power stations) - Industrial processes (e.g. Ceramics, Cement and Iron& Steel) - Wild fires, tyre burning Incinerators, specific industries (printers, dyers, spray painters, etc.) Key Impacted Areas Elevated concentrations over much of the CTMM resulting in widespread health risks, with significant health effects anticipated in residential fuel burning areas. Elevated concentrations expected in close proximity to busy roadways (i.e. N1, N4, N14) Pretoria West and Moot area due to Power Station and industries. Monitoring is required to confirm ozone levels. Elevated concentrations over much of the CTMM. Pretoria West and Moot area. Informal settlements during winter months. Main impact zones should be established after monitoring and modeling efforts. Notably elevated concentrations near busy roadways. Pretoria West and Moot area. In close vicinity to sources. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page viii 2.5 Air Pollution Control and Air Quality Management Capabilities within the CTMM In assessing CTMM’s capacity to effectively develop and implement an air quality management planning approach it was necessary to understand the current resources and functions of the metro. Two divisions are currently engaged in air pollution control and air quality management functions, viz. the Environmental Health Division and the Environmental Management Division. Air quality management planning falls within the Environmental Health Division, under the Chief Health Officer for Air Quality Management. The Chief Environmental Health Practitioners within the Environmental Health Section are responsible for all complaint investigation including air pollution complaints. A complaints database exists which records date of complaint, complaint type (e.g. air pollution), and complainant details. The Environmental Resource Management section is situated within the Environmental Management Division of the Housing, City Planning and Environmental Management Department. The main responsibilities concerning air pollution for this Division are the compiling of the State of the Environment Report (SOER) for CTMM and the development of the Tshwane Integrated Environment Policy (TIEP). Critical tools for effective air quality management include a comprehensive and current emissions inventory, an air quality monitoring network and reporting function, and an atmospheric dispersion modelling function. CTMM has initiated an ambient air quality and meteorological strategy which were to be implemented during the first half of 2006. An effective data transfer system has not been established and no skills existed within the CTMM to support dispersion modelling. No emissions inventory have been established other than the one as part of the AQMP development. 3 DEVELOPMENT OF AN AIR QUALITY MANAGEMENT PLAN A clear air quality management policy was required to inform air quality management plan development, implementation, review and revision. The drafting of this policy was informed by: (i) the Constitution and Bill of Rights and national environmental policy, as documented in the General Environmental management Policy for South Africa, the National Environmental Management Act (NEMA) and the Integrated Pollution and Waste Management (IP&WM) White Paper, (ii) National Environmental Management: Air Quality Act (No 39) of 2004 published by the Department of Environmental Affairs and Tourism (which reflects the vision and principles expounded by the national environmental policies), and (iii) International trends in air quality management policies. The air quality management policy embodied a paradigm shift from end-of-pipe air pollution control to pollution prevention and minimization through proactive and integrated air quality Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page ix management planning. The integration of air quality considerations into development, transportation, land use planning and housing policies and programmes and the involvement of the public in the air quality management process represent key components of the policy. The overarching principles of the Constitution, the General Environmental Policy for South Africa and the Integrated Pollution and Waste Management Policy underpinned the proposed local air quality management policy. 3.1 Local Air Quality Objectives Air quality guidelines and standards and other evaluation criteria are fundamental to effective air quality management, providing the link between the potential source of atmospheric emissions and the user of that air at the downstream receptor site. The AQA adopted the Department of Environmental Affairs and Tourism (DEAT) guidelines as interim national standards for several criteria pollutants (including particulates, sulphur dioxide, oxides of nitrogen, lead and ozone). It is however likely that the SANS limit values will be adopted as national ambient air quality standards. Although the AQA does not make provision for or the setting of legally binding local air quality standards by local authorities, local authorities may define air quality guidelines as internal objectives or targets to assist in ambient air quality management. In the selection of pollutants for which local guidelines were established attention was paid to the following: • commonly occurring pollutants within the CTMM that give rise to relatively widespread exposures; • pollutants for which national air quality guidelines currently exist and for which national air quality standards are in the process of being established; and • pollutants for which guidelines/standards/goals are initially issued by other countries. A tiered approach was advocated for the purpose of setting air quality evaluation criteria for CTMM. It was recommended that the following thresholds be established for specific pollutants-averaging periods: • Limit values are to be based on scientific knowledge, with the aim of avoiding, preventing or reducing harmful effects on human health and the environment as a whole. Limit values are to be attained within a given period and are not to be exceeded once attained. • Information and investigation thresholds are intended to highlight pollutant concentrations at which the public need be informed that the most sensitive individuals may be impacted and/or at which investigations into reasons for the elevated levels need to be initiated. • Alert thresholds refer to levels beyond which there is a risk to human health from brief exposure. The exceedance of such thresholds necessitates immediate steps. A synopsis of the limit value or guideline selected for each pollutant-averaging period combination is given in Table 3. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page x Local guidelines to be adopted for implementation by the CTMM. Values Table 3: are expressed in µg/m3 and where appropriate ppb (the volume standardised at a temperature of 25°C and a pressure of 101,3 kPa.) Pollutant Averaging Period Sulphur dioxide 10 minute running average 1-hr 24-hr annual Nitrogen dioxide Nitrogen oxide Oxides nitrogen PM10 Carbon monoxide Lead Ozone PM2.5 of instantaneous peak 1-hr 24-hr 1-month annual instantaneous peak 1-hr 24-hr 1-month annual instantaneous peak 1-hr 24-hr 1-month annual 24-hr annual 1-hr 8-hr running average calculated on 1-hourly averages quarterly-average annual instantaneous peak 1-hr 8-hr running average calculated on 1-hourly averages 24-hr annual average Benzene annual average Guideline (ppb) 191 Guideline (µg/m3) 500 133 48 350 125 19 50 500 104 100 80 21 900 600 300 200 150 1400 800 400 300 200 955 200 191 153 40 1125 750 375 250 188 2080 1132 566 403 284 75 40 30 000 10 000 26 000 8 700 1.5 0.5 255 102 61 500 200 120 To be determine during the development of the AQMP To be determine during the development of the AQMP 5 Basis for Guideline Current revised SA guideline, WHO, SANS 1929 EC, UK Current revised SA guideline, SA, WHO, EC, UK, SANS 1929 Current revised SA guideline, SA, WHO, SANS 1929 Current SA WHO, EC, UK, SANS 1929 Current SA Current SA WHO, EC, UK, SANS 1929 Current SA Current SA Current SA Current SA Current SA Current SA Current SA Current SA Current SA Current SA SANS 1929 SANS 1929, EC - phase 1 WHO, EC, SANS 1929 WHO, EC, SANS 1929 Current SA WHO, EC, UK, Australia, SANS 1929 Current SA Health criteria, SANS 1929 EC target based on WHO, SANS 1929 SANS 1929 Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xi The four-band scale recommended for use in the evaluation of dustfall is outlined below and target, alert and action levels indicated. Dustfall rates shall be expressed in units of (mg/m2/day, 30-day average). 1 BAND DESCRIPTION LABEL RESIDENTIAL 2 INDUSTRIAL 3 ACTION 1 200 < D < 2 400 4 ALERT 2 400 < D BAND NUMBER DUST-FALL RATE (D) (mg m-2 day-1, 30-day average) D < 600 600 < D < 1 200 COMMENT Permissible for residential and light commercial Permissible for heavy commercial and industrial Requires investigation and remediation if two sequential months lie in this band, or more than three occur in a year. Immediate action and remediation required following the first exceedance. Incident report to be submitted to relevant authority. Target, Action and Alert Thresholds for ambient dustfall are proposed as follows: DUST-FALL RATE (D) (mg m-2 day-1, 30-day average) 300 600 LEVEL TARGET ACTION RESIDENTIAL ACTION INDUSTRIAL ALERT THRESHOLD AVERAGING PERIOD Annual 30 days 1 200 30 days 2 400 30 days PERMITTED FREQUENCY OF EXCEEDANCES Three within any year, no two sequential months. Three within any year, not sequential months. None. First exceedance requires remediation and compulsory report to authorities. Alert and information thresholds recommended for use by the CTMM are outlined in Table 4 but will need to be finalised at a later date. Table 4: Alert and information thresholds to be investigated for use by the CTMM nitrogen dioxide Averaging Period 10-minute average 3 consecutive hours 1-hour average carbon monoxide 3 consecutive hours 8-hour average ozone 8-hour average Pollutant sulphur dioxide Information Threshold 532 µg/m3 200 ppb 573 µg/m3 (300 ppb) 17.4 mg/m3 (15 ppm) 180 µg/m3 (90 ppb) Alert Threshold 1064 µg/m3 400 ppb 350 µg/m3 (130 ppb) 764 µg/m3 (400 ppb) 3 400 µg/m (209 ppb) 23.2 mg/m3 (20 ppm) 360 µg/m3 (180 ppb) Basis for Threshold UK 15-min bands EC alert threshold UK bands EC alert threshold UK bands UK bands Although the protection of health is the main criteria recommended, the need to protect the broader environment is accepted as is evident from the vision statement. Reference to Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xii certain criteria for the protection of vegetation and ecosystems issued by the EC, UK and US is given in Table 5. Table 5: Thresholds specified by other countries specifically for vegetation and ecosystems Pollutant Threshold (ppb/ppm) Threshold (µg/m3 or mg/m3) 3.7 - 11.1 ppb(a) 7.4 ppb(b) 20 ppb(c) 8 - 9 ppm(e) 10 - 30 µg/m3(a) 20 µg/m3 (b) 30 µg/m3 (c) 4 - 4.5 mg/m3(e) 3 ppm/h(f) 1.5 mg/m3(f) Averaging Period sulphur dioxide annual average nitrogen oxides (NOx) ozone annual average AOT40 (daylight hours, 3 months)(d) AOT40 (daylight hours, 3 months)(d) (a) Represents the critical level for ecotoxic effects issued by the WHO for Europe; a range is given to account for different sensitivities of vegetation types (b) EC and UK limit value to protect ecosystems (c) EU limit value specifically designed for the protection of vegetation (d) AOT40 means the sum of the differences between hourly concentrations greater than 80 µg/m3 or 40 ppb 3 and 80 µg/m over a given period. The 3-month window to be selected according to the growing season of the selected sensitive receptor and the climate in the specific region - if the growing season exceeds 3 months the most sensitive period should be used. Daylight hours are set at 8-20 h Central European Time (e) EC target value given for vegetation (f) EC long-term objective for vegetation For the assessment of impacts from non-criteria pollutants for which no guidelines or standards have been established, it was recommended that inhalation health risk screening procedure be adopted by CTMM. A synopsis of the specific actions required and timeframes for establishing various local air quality objectives is given in the table below: Action: Target Date Short-term Adoption of local ambient air quality objectives and dustfall evaluation criteria On adoption of the AQMP Revision of local ambient air quality objectives and dustfall evaluation criteria Immediately following the replacement of the interim National Air Quality Standards by the DEAT Medium-term Determine target timeframes for meeting local air quality objectives June 2007 Determination of local air quality objectives for PM2.5 (excluding timeframes for compliance) June 2008 Definition of local alert and information thresholds June 2008 Motivation of DEAT and GDACE for the investigation of air quality criteria suited to the protection of local vegetation and ecosystems December 2008 Adoption of local objectives for the protection of vegetation and ecosystems January 2010 - Pending completion of DEAT/GDACE investigation Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xiii 4 AIR QUALITY MANAGEMENT SYSTEM An AQMP cannot be successfully implemented and revised in the absence of an effective air quality management system (AQMS). It was proposed that the CTMM establish a system in the short-term (first two years after approval). Although air quality objectives represent important AQM 'tools’, other essential tools include an emissions inventory, air quality and meteorological monitoring and atmospheric dispersion modelling. On the basis of a comprehensive emissions inventory, the application of monitoring, in combination with modelling, facilitates the effective characterisation of spatial and temporal variations in air pollutant concentrations. Such concentrations are evaluated based on local guideline values to determine the need for devising emission control strategies. Dispersion modelling is used to predict ambient air pollutant reductions possible through the implementation of specific emission control strategies. Emission control strategies may then be selected which are able to ensure compliance with the local guideline value, the socio-economic acceptability and technological feasibility of such strategies having been assessed. The control measures selected need to be enforced and if these are not achieved after a reasonable period of time the emission control measures may need to be revised. An integrated air quality management system to be implemented by CTMM is illustrated in Figure 1. System components proposed for implementation in the short-term are indicated by solid lines, with components to be added at a later stage indicated by dashed lines. It was also recommended that CTMM consult with DEAT and GDACE during the development of the AQMS to ensure synergy between the systems develop by adjacent metropolitans, the Gauteng province and on national level. Figure 1: Air quality management system proposed for implementation by CTMM Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xiv It was proposed that CTMM develop a comprehensive and accurate emissions inventory reflecting the current status quo. This should reflect all point and non-point (fugitive) sources. The first level emissions inventory developed during the Baseline Assessment for CTMM in 2005 could be used as basis. In the development of an ambient air quality and meteorological monitoring network, careful consideration had to be given to the monitoring objectives, the parameters to be monitored and the locations of the stations. The main air quality monitoring objectives adopted by CTMM were: • to determine compliance with air quality guidelines and standards; • to assess exposure of people, addressing both the highest levels and the levels in other areas where the general population is exposed; • make adequate information available to the public; • provide objective inputs to air quality management, transportation and land use planning; • tracking progress made by pollution control measure implementation; • source contribution determination (e.g. receptor modelling); • spatial and temporal trend analysis; and, • to be used to validate dispersion modelling. Based on the main pollutants of concern identified during the baseline assessment and the lack of background concentration information, it was decided to focus on priority pollutants in the short-term. Site selection was based on various factors such as source locations in relation to sensitive receptor areas (i.e. residential areas, hospitals, schools etc.), population density (specifically in informal settlements), topography (such as the moot area), and the dispersion potential of the region (predominant wind fields). In addition, use was made of the dispersion simulation results as conducted during the baseline assessment. The locations of existing and proposed monitoring stations are presented in Table 6. It should be noted that the locations are not necessarily permanent and will be moved to record at all the main impacted areas within the CTMM. Table 6: Proposed CTMM air quality and meteorological monitoring sites Site Name Site Type Site Classification Minimum Parameters to be Measured Rosslyn Stationary (existing GDACE-sponsored station) Within industrial area PM10, SO2, NO, NO2, NOx, CO & Ozone Pretoria West Semi-stationary (existing CTMM station) Within industrial area – close to residential areas PM10, Wind speed, direction, sigma-theta Mamelodi Stationary (new station proposed for commissioning by March 2006) Residential – household fuel burning wind PM10, SO2, NO, NO2, NOx, CO & Ozone Wind speed, wind direction, sigma-theta Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xv Site Name Moot – western section Centurion – central Centurion – Highveld near N1/N14 intersection Pretoria East – near N1/N4 intersection Site Type Stationary (new station proposed for commissioning by March 2007) Stationary (new station proposed for commissioning by March 2007) Mobile station (new station proposed for commissioning by March 2006) Mobile station (new station proposed for commissioning by March 2006) Centurion – Elardus Park Mobile station (new station proposed for commissioning by March 2006) Centurion – Rooihuiskraal/ The Reeds Mobile station (new station proposed for commissioning by March 2006) Temba Mabopane/ Ga-Rankuwa Pretoria West Pretoria North – Akasia Pretoria CBD Lyttelton Rooihuiskraal Sunderland Ridge Mobile station (new station proposed for commissioning by March 2006) Mobile station (new station proposed for commissioning by March 2006) Mobile station (new station proposed for commissioning by March 2006) Mobile station (new station proposed for commissioning by March 2006) Mobile station (new station proposed for commissioning by March 2006) Smoke and SO2 sampling - Previously funded by DEAT with monitoring undertaken Site Classification Residential – proximity to industry Residential – possible impacts from industrial sources to the north Residential/Commerc ial - vehicle emissions Residential - vehicle emissions Residential – trans boundary pollution from EMM & potential pollution transfer from CTMM Residential – trans boundary pollution from City of Joburg & potential pollution transfer from CTMM Minimum Parameters to be Measured PM10, SO2, NO, NO2, NOx, CO & Ozone Wind speed, wind direction, sigma-theta PM10, SO2, NO, NO2, NOx, CO & Ozone Wind speed, wind direction, sigma-theta PM10, PM2.5, SO2, NO, NO2, CO, lead, benzene & Ozone Wind speed, wind direction, sigma-theta PM10, PM2.5, SO2, NO, NO2, CO, lead, benzene & Ozone Wind speed, wind direction, sigma-theta PM10, PM2.5, SO2, NO, NO2, CO, lead, benzene & Ozone Wind speed, wind direction, sigma-theta PM10, PM2.5, SO2, NO, NO2, CO, lead, benzene & Ozone Wind speed, wind direction, sigma-theta Residential Residential PM10, SO2, NO, NO2, & Ozone Wind speed, wind sigma-theta PM10, SO2, NO, NO2, & Ozone Wind speed, wind sigma-theta PM10, SO2, NO, NO2, & Ozone Wind speed, wind sigma-theta PM10, SO2, NO, NO2, & Ozone Wind speed, wind sigma-theta PM10, SO2, NO, NO2, & Ozone Wind speed, wind sigma-theta Smoke & SO2 Smoke & SO2 Residential Smoke & SO2 Residential – household fuel burning Residential – household fuel burning Residential – proximity to Pretoria West Industrial Residential – proximity to Rosslyn Commercial / Business – reference point NOx, CO direction, NOx, CO direction, NOx, CO direction, NOx, CO direction, NOx, CO direction, Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xvi Site Name Erasmuskloof Myburgh Street Atteridgeville Site Type by Local Authorities (Environmental Health Depts) – ceased in 2001 (proposed to recommission) Mamelodi CSIR Sammy Marks building Site Classification Residential Residential Residential – household fuel burning Residential – household fuel burning Residential / Commercial CBD Minimum Parameters to be Measured Smoke & SO2 Smoke & SO2 Smoke & SO2 Smoke & SO2 Smoke & SO2 Smoke & SO2 For the data from the monitoring network, it is important that data quality objectives, data processing and reporting protocols, and monitoring methods must be established. It is imperative that the software to be used is open-ended to allow for the interaction with any database. Dispersion models calculate ambient air concentrations primarily as functions of source configurations, emission strengths, terrain features, and meteorological characteristics, hence forming an integral part of air quality management and planning. It was proposed that an urban-scale dispersion model be selected, capable of modelling area, point, and line sources and chemical transformation (specifically ozone formation). It should be windows based and compatible with other software and databases. An important aspect of the Air Quality Act is the involvement of the public in decision making processes. It is therefore pertinent to make information regarding air quality within CTMM available to the public, stakeholders and I&APs. This necessitates a reporting protocol to ensure a standardised methodology and reporting format. In addition, a public consultation process should be followed taking into account specific aims and objectives to be met and what media or other methods to be used. The current complaints register should be updated to allow for automatic logging and reporting. It was also recommended that public meeting be held every six months at a central venue for the majority of I&APs. A synopsis of the specific actions required and timeframes for establishing and operating the AQMS is given in the table below: Action: Target Date: Short-term Consolidation of an ambient air quality and meteorological monitoring network, including: the three new stationary stations and the nine mobile stations, and automated data transfer and firstorder validation Consult with industries required to fund ambient air quality monitoring and integration of data from such monitoring into CTMM’s air quality data base Update and integrate the electronic, centrally-accessible complaints register June 2006 On-going July 2006 Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xvii Evaluation and costing of passive diffusive monitoring and biomonitoring campaigns Update of source and emissions data for all major sources (ongoing) Define and implement a schedule for routine reporting Extend ambient air quality and meteorological monitoring network to include 2 additional stations. Possible stations and sites include: (i) stationary site in Western Moot; and (ii) stationary site in Centurion. Arrange, advertise and conduct 6-monthly public meetings Purchase and install Emissions Inventory and Air Dispersion Modeling software Medium-term Investigate the feasibility of designating an air pollution hotline and air quality information and liaison officer duties Collation of source and emissions data for all major sources (ongoing) and initial population of Emissions Inventory software Population of the Air Dispersion Modeling software and simulation of ambient air pollutant concentrations across the Metro 4.1 December 2006 December 2006 March 2007 March 2007 July 2007 December 2007 December 2008 December 2008 July 2008 Source Quantification and Emissions Reduction Strategies The main aim in developing an AQMS is to identify and implement emission reduction measures to improve air quality over a given period of time. Thus, it is important to ensure that the main sources of ambient air pollution impacting on the receiving environment are targeted and that emission reduction measures or strategies proposed are indeed feasible and cost effective. 4.1.1 Domestic Fuel Burning It was considered crucial that national, provincial and local initiatives aimed at reducing household fuel burning are conducted in a coordinated manner. The initiatives prioritized for implementation by CTMM would therefore reflect the priorities of national departments such at DME and the Department of Housing. The main strategies over the short-term and medium-term are outlined in Table 7. Table 7: Emissions reduction strategies for Domestic Fuel Burning to be implemented by CTMM over the short-and medium term. Strategy Short-term (1 to 2 years) CTMM negotiate with the DME and DEAT to sponsor a similar project for Mamelodi and Marabastad as the Tembisa Basa Njengo Magogo (BNM) project. CTMM personnel will have to be involved in the project and will require training from DME in the BNM method of ignition Involve the public and other organization in the education of the BNM method. The National Zoo has indicated their willingness to train school groups on the use of the BNM as part of their education programme. Nissan SA recommended that a DVD Responsible parties Initiation (duration) CTMM EHPs DME July 2006 (18 months) CTMM, DMS, DEAT & Industries July 2006 (18 months) Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xviii Strategy be made on the BNM method to be distributed to all industries as part of staff training and education programmes. Considering the integration of energy efficiency measures in new low-cost housing areas. This should include solar passive designs, better insulation (specifically under tin roofs etc) and research into alternative building materials (such as certain inert waste materials that can be used) Medium term (3-5 years) CTMM to implement the Basa Njengo Magogo project in Soshanguve and Atteridgeville CTMM should continue the surveys of households initiated buy the State of Energy study in order to track progress made by the BNM Projects within the areas where it was launched. This in turn should be reflected in the revised Air Quality Management Plan and State of Energy report Update emissions quantification and impacts predictions (dispersion model) with new information on domestic fuel burning. CTMM to setup an urban air quality dispersion model to simulate pollution concentrations associated with domestic fuel burning emissions. CTMM to facilitate the investigation and identification of suitable alternatives to household fuel burning to look at low-smoke fuels, renewable energy, energy demand management etc.) Responsible parties Initiation (duration) CTMM Housing Division March 2006 (on-going) CTMM EHPs January 2008 – (12 months per settlement) CTMM Air Quality Section CTMM EHPs DME July 2008 (6 months) CTMM Air Quality Section January 2009 (on-going) CTMM Air Quality Section January 2009 (on-going) CTMM Air Quality Section January 2009 (on-going) The energy efficiency measures intended for implementation in the short- and medium-terms are in line with the DME Energy Efficiency Strategy (March 2005) and the National Energy Regulator’s Regulatory Policy on Energy Efficiency and Demand Side Management (EEDSM) for South African Electricity Industry (May 2004). 4.1.2 Road Transportation Collaboration between local, provincial and national government is required to secure the effective regulation of vehicle emissions. Transportation management measures and emission testing strategies by local authorities are likely to be more successful if implemented uniformly across neighbouring cities and metros. Critical to the success of the implementation of any emission reduction strategies within CTMM is the relationship between various departments within the metro, i.e. transport planning, land-use planning and housing divisions. Emission reduction strategies proposed over the short- and medium-terms are provided in Table 8. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xix Table 8: Emissions reduction strategies for Transportation to be implemented by CTMM over the short-and medium term. Proposed Strategy Short-term (1 to 2 years) CTMM to establish an Inter-departmental Transport Liaison Group (ITLG) between the Environmental Health, Environmental Management, Transport, Housing and Land-use planning divisions. This group must meet every month to establish information sharing systems and subsequently the implementation of short-term measures. The Integrated Transport Plan should be used as basis and must be updated continuously. It is recommended that the Inter-departmental Transport liaison Group contact the same Groups within EMM and Joburg to learn form their experience and to establish an inter-municipal relationship for future planning purposes and to standardise procedures within the Gauteng Province. GDACE can be contacted to coordinate these meetings which should take place quarterly. Current diesel vehicle testing procedures to be standardised and expanded to be conducted once a month, with a target number of vehicles to be tested. The CTMM fleets should be tested first. The results should be reported to the Transport division who needs to report to the ITLG. Get the corporation of the Metro Police to support the diesel vehicle testing CTMM to design a more comprehensive and effective vehicle emission testing programme for implementation in the medium-term in consultation with the City of Joburg and EMM and the Gauteng province (1). This may include a feasibility assessment to conduct vehicle emission testing at the licensing facility as part of vehicle license renewal. The funds from fines can be used for research into cleaner technology. Reporting of monitored data from the mobile stations located near main highway intersections (see Section 5) to the Transport Division and Inter-departmental Transport Liaison Group to inform transport planning and highlight air quality issues. Determine how the transport model currently used by the CTMM Transport Division (EMME/2) can be utilized to better inform transportation emissions calculation and how this can be used by the Air Quality Management Section. Establish the capacity within the Transport division required to update this model annually with relevant traffic count data. Determine how Metro police can be used to assist in gathering this type of information. Research should be encouraged on cleaner transportation technologies through liaising with the Transportation Planning project manager on the Clean Transport Technology Project via the ITLG. CTMM will also have to liaise with GDACE to integrate findings from their cleaner technologies initiative and to avoid duplication. Medium term (3-5 years) Implementation of diesel and vehicle emissions testing procedures developed during the short-term. Implementations of the customized EMME/2 traffic model for providing emissions data for the Air Quality Section if proofed to be feasible. Implement systems to update vehicle count data annually as determined during the short-term Responsible parties Initiation (duration) CTMM divisions Coordinated by Air Quality Section January 2006 (6 months to establish, thereafter ongoing) CTMM ITLG GDACE June 2006 (on-going) CTMM Transport Division & ITLG January 2006 (on-going) CTMM Transport Division January 2007 (12 months) CTMM Air Quality Transport ITLG April 2006 (on-going) CTMM Air Quality Transport ITLG April 2006 (on-going) CTMM ITLG GDACE June 2006 (on-going) CTMM ITLG January 2008 (36 months) CTMM Air Quality Section CTMM Transport January 2009 (every 3 years) January 2008 (annually) Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xx Proposed Strategy Responsible parties Division Initiation (duration) CTMM to liaise and encourage the Airforce to conduct an emissions CTMM Air inventory and impact assessment for all their airports within CTMM. January 2008 Quality The data should be incorporated into the CTMM emissions (on-going) Section database. CTMM to liaise with Transnet and private rail companies on CTMM Air quantification of emissions emanating from railroad, especially January 2008 Quality within the Capital Park area. The data should be incorporated into (on-going) Section the CTMM emissions database. CTMM Air CTMM to setup an urban air quality dispersion model to simulate January 2009 Quality pollution concentrations associated with vehicle emissions – also (on-going) Section assessment of peak traffic periods Dispersion modeling results to be communicated to the Transport CTMM Air January 2009 Division to assist in transport strategy development and Quality (on-going) implementation Section Based on information received from various tools the aim should be to increase on-and off- ramps onto highways from congested roads, identify development of alternative routes, bicycle lanes to be CTMM January 2008 introduced, Bus lanes to be increased (encourage private bus Transport (on-going) companies to bus services on main routes using bus lanes thus no Division traffic congestion & will encourage people using own transport to use this service). Encourage these to use CNG and/or LPG driven busses. Notes: (1) This will not be required if DEAT establishes new regulations pertaining to vehicle emissions testing within the next 2 years under the Air Quality Act of 2004. 4.1.3 Industrial Sources For the purpose of this document industrial sources include all scheduled and non-scheduled processes, and energy generation activities within the CTMM. A total of 103 permits have been issued for scheduled processes in the CTMM, including power generation activities. Very little information was available on control technology implemented by these scheduled and non-scheduled processes. Various smaller industrial and commercial operations are currently operational within the CTMM. This would include activities such as spray painting, sand blasting, dry cleaning, small boiler operations and incineration process, materials handling etc. A total of 281 fuel burning appliance certificates have been issues by the CTMM to date. No information was available on the actual amount of fuel used, the frequency and duration of operation, and control equipment in place at each of these locations. No information was available on other smaller industries within the CTMM and hence most of these operations are not monitored. Recommended strategies for scheduled and non-scheduled processes are provided in Table 9. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxi Table 9: Recommended emission reduction strategies for scheduled and nonscheduled processes within the CTMM. Responsible parties Proposed Strategy Initiation (duration) Short-term measures Update of current CTMM emissions inventory • Scheduled processes need to provide permit certificates and have to demonstrate compliance with permit conditions. • Non-scheduled processes need to provide process descriptions and any available emissions information. • CTMM must identify industries and commercial/institutional concerns undertaking combustion processes to compile emissions inventories and report source and emissions data to the Metro. CTMM will have to compile questionnaires to be sent out to these industries. Review current emission reduction strategies reported to ensure it is in line with best available international practice • CTMM to encourage industries to investigate implement best available control technology and • Power Stations to investigate and implement feasible desulphurisation options. Use coal with lower sulphur and ash content. Develop relationships with National and Provincial Government, and related CTMM departments (i.e Environmental Management & Environmental Health). • • Until the relevant sections of the AQA pertaining to emission licences have commenced, CAPCO need to inform CTMM of any new scheduled process developments within CTMM or any changes to existing permits. Town planning division needs to inform the Air Quality section of any new industrial development zones and/or applications. CTMM Air quality section Environmental Health January 2006 (12 months) January 2006 (12 months) DEAT CAPCO January 2006 (24 months) CTMM Air quality section January 2006 (24 months) CTMM Air quality section DEAT CAPCO January 2006 (24 months) GDACE • All EIA information pertaining to industrial development must be obtained from GDACE. CTMM must update the existing database on fuel burning appliances to include: • location of appliance • company name and contact details • type of appliance • type of fuel in use • sulphur and ash content of fuel (where appropriate) • quantity of fuel used • scheduling of operation (continuous, intermittent - two hours per day, etc.) • control measures in place and control efficiency of these measures • stack parameters (height, inner stack diameter, gas exit temperature, and gas exit velocity or volumetric flow) CTMM Air quality section & OHPs January 2006 (24 months) Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxii Proposed Strategy • stack monitoring data (where available) Any new fuel burning appliances must be reported to the metro Medium-term measures Based on the outcome of the DEAT emissions licence review (2) project , review permits based on updated emissions inventory and information on control equipment Set specifications on combustion efficiency applicable to all new coal fired boilers in collaboration with the project initiated by DME (3) . The project looks at fuel switching, abatement technology implementation, and improvements in energy efficiency. Liaise with Eskom on demand side management measures applicable to the commercial and industrial sectors. Electricity generated by Pretoria West power station can be replaced by residential gas usage. Investigate the potential for introducing alternative tariff structures for the purpose of encouraging on-site co-generation and the introduction of renewable energy. Waste gas streams from industries to be utilised as energy source – possible incentives. Investigation of the potential for introducing market incentives and disincentives for the purpose of encouraging emission reduction by industrial and power generation processes. Examples include: • Iron & Steel manufacturing: waste gas recovery and use &improve fugitive dust emissions; • Cement manufacturers: minimising fuel usage by preheating and precalcination (to the extend possible given the existing kiln system configuration) & heat recover from waste gas • Initiation (duration) CTMM Air quality section DEAT January 2008 (36 months & on-going) CTMM Air quality section January 2008 (36 months & on-going) DME CTMM Air quality section DME & Eskom January 2008 (36 months & on-going) CTMM Air quality section Eskom January 2008 (36 months & on-going) CTMM Air quality section Environmental Management Environmental Health January 2008 (36 months & on-going) Clay brick manufacturers: fuel switching from coal to gas This process will be enhances by forming a relationship between the main industrial role-players in the metro and CTMM CTMM should investigate the feasibility of decommissioning the Pretoria West power station and replace it with gas reticulation network CTMM to setup an urban air quality dispersion model to simulate pollution concentrations associated with vehicle emissions – also assessment of peak traffic periods CTMM to update emissions inventory to include emission reduction due to measures implemented during the short-term. CTMM should develop a system to liaise with DEAT and Gauteng government to ensure CTMM are up to date with any new developments on the control of industrial and commercial sources. The proposed National Air Quality database should be investigated to ensure information generated by CTMM can be incorporated into this database and information from this database can be used. Notes: Responsible parties CTMM Air quality section Environmental Management CTMM Air Quality Section January 2008 (36 months & on-going) January 2009 (on-going) (1) Criteria to be used by CTMM to determine which operations are required to undertake emissions inventories are provided in Appendix. (2) DEAT has called for tenders for the Atmospheric Licensing Project which aims to capture all existing Registration certicicates and the review thereof. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxiii Possible emission reduction measures to be implemented include: • Iron & Steel manufacturing emissions • Cement manufacturers - minimising fuel usage by preheating and precalcination (to the extend possible given the existing kiln system configuration) heat recover from waste gas • Clay brick manufacturers 4.1.4 - waste gas recovery and use &- improve fugitive dust - fuel switching from coal to gas Waste and Disposal Treatment Medical waste incineration is controlled by the Department of Health. Incineration also represents a 'Scheduled Process' in terms of APPA and as such requires a permit to operate from the DEAT. No information was available on the types of incinerators and the amount of waste being disposed off. CTMM currently operates 9 general waste disposal sites. The permitting of landfill sites will in future become the responsibility of DEAT. The Environmental Health Division of CTMM has drafted a Waste Minimisation Strategy in June 2005 with the main objective to minimise waste within the CTMM. Recommended strategies for waste facilities are provided in Table 10. Table 10: Recommended emission reduction strategies for waste disposal facilities within the CTMM. Proposed Strategy Short-term measures CTMM to require all waste disposal facilities to meet DWAF minimum requirements. Large general sites not meeting the DWAF requirements should provide CTMM with a speciated substance emissions inventory based on surface gas network sampling, dispersion modelling results showing predicted impacts together with a health risk screening assessment and odour assessment. CTMM should require a quantitative health risk to be undertaken should the reported results indicate the potential for health risks. Finalisation and implementation of the Waste Minimisation Strategy. The Environmental Health Division should report quarterly on the progress on the implementation of the strategy and provide information on the quantities and waste streams to each facility. CTMM should provide residential bins for segregation of domestic waste (i.e. glass and other). Responsible parties Initiation (duration) CTMM Environmental Health CTMM Environmental Health January 2006 (12 months) CTMM Environmental Health January 2006 (24 months) CTMM Environmental Health January 2007 (on-going) Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxiv Proposed Strategy Sewage and wastewater treatment facilities to compile emissions inventories, commission ambient air quality monitoring, undertake impact and risk screening studies. Undertake health risk assessments should the findings of he screenings studies indicate a potential for such a risk. This should be reported to the CTMM annually. CTMM to update emissions inventory with monitored and estimated emissions from landfill sites and wastewater and sewage treatment works. Medium-term measures The Waste Minimisation Strategy proposes education of the public and including stakeholders. This can be done in collaboration with other environmental awareness campaigns. CTMM could publish tips on waste recycling and reduction on its website and on billboards to inform and educated the public. Determine additional waste segregation and recycling strategies applicable for implementation within CTMM. Investigate alternative waste treatment and disposal options. The cement industry can be approach to investigate the feasibility of hazardous waste incineration at cement kilns. CTMM to setup an urban air quality dispersion model to simulate pollution concentrations associated with waste disposal facilities and wastewater and sewage treatment works. CTMM to update emissions inventory with monitored and estimated emissions from landfill sites and wastewater and sewage treatment works. 4.1.5 Responsible parties Initiation (duration) CTMM Environmental Health Air Quality Section January 2006 (12 months) CTMM Environmental Health January 2007 (12 months) CTMM Environmental Health January 2008 (36 months & CTMM Air quality section DEAT CTMM Air quality section PPC CTMM Air Quality Section CTMM Air Quality Section January 2008 (36 months & on-going) January 2008 (36 months & on-going) on-going) January 2009 (on-going) January 2009 (on-going) Mining Activities There are a total of 27 mines in operation within the CTMM, excluding various smaller sand quarries not listed. These mining operations are almost exclusively quarries operated by means of opencast or surface mining techniques which are notorious for the generation of dust. Recommended strategies for other sources are provided in Table 11. Table 11: Recommended emission reduction strategies for mining operations within the CTMM. Proposed Strategy Short-term measures CTMM must require representation on the inter-departmental committee tasked with the regulation of mining activities Require mining companies to provide CTMM with emissions inventories for their operations, including mineral processing plants. Responsible parties CTMM t DWAF, DME & GDACE CTMM Air Quality Environmental Management Initiation (duration) July 2006 (on-going) January 2007 (12 months) Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxv Proposed Strategy All mines in close proximity to residential areas to implement dust fallout monitoring networks. Results must be reported monthly to the mine management and 6-monthly to the CTMM. All opencast mines to compile and implement comprehensive dust management plans as part of their EMPRs and report this to CTMM. Responsible parties CTMM Air Quality Environmental Management CTMM Air Quality Environmental Management Initiation (duration) January 2007 (12 months) January 2007 (12 months) Medium-term measures CTMM request that DME ensure all mines: • have approved EMPRs, • can demonstrate compliance with EMPR commitments and National ambient air quality standards • have determined the financial quantum and provide for the prevention & management of air pollution CTMM Environmental Management DME & GDACE July 2008 (on-going) • fines for mines not complying with the EMPR requirements All mines closing must comply with their closure commitments, specifically with dust management plans and rehabilitation objectives CTMM to setup an urban air quality dispersion model to simulate pollution concentrations associated with fugitive dust from mining facilities CTMM to update emissions inventory with monitored and estimated emissions from mining sites. Also to include implemented mitigation measures and associated reductions 4.1.6 CTMM Environmental Management DME & GDACE CTMM Air Quality Section CTMM Air Quality Section July 2008 (on-going) January 2009 (on-going) January 2009 (on-going) Other Sources Other sources that rose concern mainly form the public within CTMM include veld fires, tyre burning, agricultural emissions (such as wind blown dust from open areas), vehicle entrainment on unpaved roads, and railway transport. Recommended strategies for other sources are provided in Table 12. Table 12: Recommended emission reduction strategies for other sources within the CTMM. Proposed Strategy Short-term measures Identify and quantify emissions from other sources, i.e. vehicle entrainment of unpaved roads, agricultural activities (i.e. land tilling), veld fires, tyre burning, and railway emissions. Establish routine data retrieval mechanisms for the purpose of updating the emissions inventory (e.g. Fire Departments - request data be kept on locations of veld fires and extent of areas burned). Rendering plants treating waste from abattoirs should provide an Responsible parties CTMM Air Quality Section CTMM Air Quality Section CTMM Air Initiation (duration) July 2006 January 2007 January 2007 Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxvi Proposed Strategy inventory of waste received and treatment methodologies. Emissions should be quantified for the facilities and provided to CTMM to be incorporated into the emissions database. Control the burning of grass by municipal worker's and contractors along highways and elsewhere. Responsible parties Quality Section Support national legislation aimed at controlling copper wire burning for the purpose of wire stripping CTMM Air Quality Section CTMM Air Quality Section Initiation (duration) July 2006 July 2006 Investigate the use of by-law implementation for the purpose of: • Tyre burning, • controlling trackout from construction sites, • stipulating the need for dustfall monitoring and reporting of results during large-scale construction and demolition projects Expand and enhance the Environmental Health one-Stop Service and electronic complaints register to feed into Management Information System. Ensure action procedures for incidences of tyre burning and uncontrolled veld fires Establish a Communication Plan to underpin the AQMP. This should include strategies for disseminating relevant Air Quality Related information to the public. Make use of private and commercial sectors in distributing information (i.e. National Zoo’s Education Plan, Industry Staff Training Programmes, Media, Billboards, etc.) Medium-term measures Identification of emission reduction measures for other sources predicted on the basis of the quantitative emissions inventory and in-house atmospheric dispersion modelling or external studies to be significant in terms of health risks or nuisance impacts. 4.2 CTMM Air Quality Section July 2006 CTMM Air Quality Section OHP July 2006 CTMM Air Quality Section July 2006 CTMM Air Quality Section July 2006 Research Initiatives In order to ensure the effective implementation of the Air Quality Management Plan various research efforts will need to be undertaken internally by CTMM (see Table 13). Table 13: Research initiatives recommended for implementation in the short- and medium-term. Research Required Purpose Assess the problems and challenges faced by the City of Joburg and EMM in the implementation of their AQMPs CTMM should learn from the experience from the neighbouring metros to fast track their AQMP implementation Determine whether the existing traffic model could be used to estimate vehicle emissions based on locally developed emission factors Responsible Schedule CTMM Air Quality Section Jan 2006 – June 2006 CTMM Air Quality & Traffic Division July 2006 – June 2007 Short-term Assess the existing emissions quantification tools within the CTMM (viz. EMME2 traffic model) and how useful this is for application within the Air Quality Division Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxvii Research Required Purpose Determine what emissions quantification methods and tools are available for use by CTMM taking into consideration the specific sources that will have to be quantified by the municipality (i.e. waste disposal facilities, domestic fuel burning etc.) and ensure the potential for changing algorithms to suit local considerations and source types. Assess and cost suitable passive diffusive and biomonitoring methods to determine the potential for their implementation within Tshwane for the purpose of informing air quality management Even though CTMM cab request emission inventories to be developed by industrial sources and mines, CTMM will have to quantify emissions from remaining sources inhouse Assess the ability of the current/and proposed software (Opsis system) utilized by CTMM monitoring stations to (i) integrate with other databases such as MS Access or MS Excell, (ii) how this can be established automatically, and (iii) how it compare to other municipality/provincial systems Liaise closely with the University of Pretoria on the development of a tree-dimensional diagnostic Winfield model. Assessment of (i) current air pollutant concentrations, (ii) contributing sources, (iii) feasible implementation periods for select abatement measures, and (iv) nationally set permissible compliance timeframes (if available) Assess the most suitable placement for the additional 2 stationary monitoring stations based on updated emissions data, results from proposed monitoring network (March 2006) and air pollution complaints received. Annual literature survey on international best practice in Air Quality Management and the new focus areas Determine whether passive diffusive and/or biomonitoring should be conducted within CTMM – and if so select suitable programmes for such monitoring CTMM must determine how to seamlessly integrate all air quality related data (including monitoring) into one database to be used by various divisions within CTMM, provincial and national government This model will be useful to fill in the gasps where no emeteorlogical data has been recorded (i.e. northern part of CTMM). It can also be used for real-time dispersion modeling and forecasting Stipulation of permissible timeframes for ensuring compliance with local air quality objectives and national air quality standards The most suitable placement of the 2 additional stationary monitoring stations can be guided by the results from the “soon to be implemented” monitoring network. Since an AQM System is dynamic CTMM should stay in abreast with international trends Responsible Schedule CTMM Air Quality July 2006 – June 2007 CTMM Air Quality & Environmental Health July 2006 – June 2007 CTMM Air Quality & Environmental Health July 2006 – June 2007 CTMM Air Quality University of Pretoria July 2006 – June 2008 CTMM Air Quality Section July 2006 – June 2007 CTMM Air Quality Nov 2006 – March 2007 CTMM Air Quality July 2006 – on-going CTMM Air Quality July 2006 – June 2007 CTMM Air Quality July 2006 – June 2007 Medium-term Selection of suitable information and alert thresholds taking into account (i) measured air pollutant concentrations, (ii) international air quality criteria, (iii) the socio-economic and technical feasibility of attaching specific reporting, investigation and mitigation requirements to such thresholds. Identify suitable local PM2.5 guidelines and related compliance timeframes taking into account: (i) local PM2.5 concentrations, (ii) source contributions, (iii) feasible implementation periods for select abatement measures, and (iv) internationally and nationally set PM2.5 standards and compliance timeframes (if available) Finalisation of a set of information and alert air quality thresholds and associate information reporting, investigation and mitigation requirements Stipulation of suitable local PM2.5 guidelines and permissible compliance timeframes Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxviii Research Required Source data collation and emission quantification through emission factor application and/or emission modelling and/or acquisition of emission measurements undertaken by sources – this could be a Master’s degree for a post-graduate student Undertaking atmospheric dispersion modelling, with model validation based on monitored results, for the purpose of identifying non-compliance areas in terms of both local air quality guidelines and national standards Annual literature survey on major sources (focusing on the most current information on pollutant types, emission estimation techniques, controls, etc.) Identification of suitable dose-response thresholds for local vegetation types CTMM is involved in the EnerKey project which is a medium- to long term intervention (1) . CTMM to form close relationships with the University of Pretoria, UNISA and Tshwane University of Technology. Notes: Purpose Collation of first comprehensive emissions inventory for CTMM Determination of noncompliance zones within CTMM (1) Informing the maintenance and further development of the emissions inventory (2) Reporting of results of surveys on vehicular pollution to Transportation Planning Identification of local air quality guidelines able to protect vegetation This project could be very useful in building design alternatives such as better insulation of low-cost housing, use of solar panels for energy supply etc Utilise post-graduate studies for specific requirements on emissions inventories or research initiatives. Be informed of any relevant research to benefit the CTMM Air Quality Management practices. Responsible Schedule CTMM Air Quality July 2006 – June 2007 CTMM Air Quality Jan 2007 – Dec 2007 CTMM Air Quality On-going starting July 2006 External consultants (possibly via GDACE or DEAT) July 2007 – Jun 2008 CTMM SEED person & Air Quality On-going starting Nov 2005 CTMM Air Quality On-going starting Nov 2005 (1) The University of Johannesburg and the University of Stuttgart has formed the EnerKey project which aims at to promote the sustainable transformation of the urban region of greater Johannesburg by initiating adapted and integrated energy projects as a key factor for sustainability. A workshop was recently held in Johannesburg (3 & 4 November 2005) to determine the main areas of research. The City of Tshwane, the City of Joburg and Ekurhuleni are partners in this research project. 4.3 Capacity Building CTMM should develop the capacity and tools to fulfil the requirements of Air Quality Management over the medium- and long-term. This will ensure efficient and cost-effective service delivery with respect to air quality management and planning. Table 14 provides the resource implications for the CTMM given national requirements and international practice. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxix Table 14: Resource implications for the CTMM given national requirements and international practice with regard to principle air quality management functions and existing local resource availability. Functions Setting of local ambient air quality standards 3 Defining Considerations National Requirements(3) International Good Practice - Provision is made for an effects Setting of multiple levels of based approach, viz. impact standards for ambient air quality is management through ambient common place in Europe & the standards USA. Ambient standards which - Provision is made for the define satisfactory air quality to designation of specific standards for ensure human health and welfare, defined geographical areas the protection of the natural and - National standards are to be build environment, and finally the established by DEAT. prevention of significant decline in - Provision is made for the setting of the quality of air are used. Such more stringent standards by standards provide the objectives for provincial governments. air quality management. Multiple - No provision is made for the levels of standards provide the setting of standards by local basis for both ‘continued authorities. (It is however accepted improvements’ in air quality and for that local authorities may determine long-term planning in air quality local air quality objectives for the management. Although maximum purposes of air quality levels of ambient concentrations are management.) set at a national level, more stringent ambient standards are implemented by metropolitan authorities. Existing Local Resources Resource Implications for CTMM Local air quality objectives have been established during the AQMP development process. No clear capacity however exists for establishing permissible compliance timeframes, for revising such objectives or for extending criteria to include information and alert thresholds and objectives for the protection of ecosystems. Additional expertise required in the field of air quality standards and dose-response relationship evaluation & local standard development As informed by Air Quality Act. Cognisance should be taken of the possible adoption of the SANS limit values to replace the current outdated standards. Final Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxx Functions Setting of emission standards local Defining Considerations (3) National Requirements International Good Practice Provision is made for the setting of National emission limits for various emission standards for the criteria pollutants are issued by standardisation of controls on national governments with more 'Controlled Emitters' and stringent local standards being widespread sources (e.g. industrial permitted in certain instances for processes, vehicle emissions, selected source categories household and commercial fuel combustion) (Specific reference is not currently made to the development of more stringent local emission standards. Provision is, however, made for passing by-laws within which this is possible.) Existing Local Resources Resource Implications for CTMM No clear capacity exists for the drafting of local emissions standards for gaseous criteria and toxic emissions (e.g. mercury) for specific source categories (e.g. vehicles, industries, domestic fuel burning appliances) If required, receptor information could be gathered (including permissible and existing levels of a pollutant), and backward dispersion modelling undertaken for the entire CTMM to determine suitable local emission limits for a source category. Meso-scale dispersion modelling capabilities will however need to be developed within CTMM to facilitate this. Final Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxxi Functions Emissions inventory development maintenance & Defining Considerations (3) National Requirements International Good Practice - Reference made to maintenance - Emissions inventory development of emissions inventory for on-going as a comprehensive, accurate and data transfer and reporting current account of air pollutant purposes emissions from all sources - Although specific sources to be - Inclusion of all source and inventoried not explicitly stated, emissions data required for input to such sources are implied through emission calculations and their inclusion in the AQM Planning dispersion modelling (e.g. stack section (sources include: industry; heights, gas exit velocities & residential fuel burning; transport temperatures, area source related emissions including motor dimensions), etc. vehicles, trains, aircraft, boats and - Inclusion of temporally-resolved ships; hazardous and offensive emissions data (e.g. hourly sources of emission; sources of emissions data, or total annual noise; waste disposal and treatment emissions with diurnal and seasonal related emissions; fugitive dust trends in emissions indicated) sources related to mining, construction, demolition, agriculture & vehicle entrainment; noise emissions) - Inventory of greenhouse gas and ozone depleting substance emissions required - Standardization of emissions inventory data bases nationally, provincially & locally implicit in requirements Existing Local Resources Resource Implications for CTMM First level emissions inventory was developed for CTMM as part of the baseline characterisation study including the main sources of emissions. This inventory need to be revised and updated to include smaller sources and all fugitive sources. Preparation of the first comprehensive emission inventory would require several person-years of effort and considerable cost. A dedicated post would be required to update the inventory in order to keep it comprehensive, accurate and current. Special projects may be needed to be initiated at various intervals for complex/special sources (e.g. vehicle emissions, wild fires, toxic emissions from landfills). Final Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxxii Functions Air quality monitoring Defining Considerations (3) National Requirements International Good Practice - Monitoring to be carried out by - Trend towards on-line, real-time relevant local/provincial monitoring used in Europe and the governments in accordance with US for: methodologies and requirements to (a) compliance demonstration be formulated by the DEAT and (b) dispersion model validation & published by the SABS calibration - Data from air quality monitoring (c) early warnings during pollution instrumentation to be stored in a episodes format compatible with national (d) quantification of actual air quality guidelines & forwarded in electronic improvements of emission reduction form to the DEAT for inclusion in a strategies national air quality data base Metropolitan authorities - Calibration of air quality monitoring responsible for: instrumentation according to the (a) planning and coordination of specifications of a recognised ambient monitoring networks certification body (b) collection & collation of data - Monitoring to make use of existing (c) information reporting national expertise. Training to be (d) annual network reviews undertaken to ensure continuity Existing Local Resources Resource Implications for CTMM The existing monitoring network for CTMM comprises of 2 permanent monitoring stations. Air quality monitoring is currently being conducted by Environmental Health personnel. Such stations do not report data in real-time nor is air quality monitoring data currently consolidated in a single database. CTMM will need to review the contract with the contractors in the short-term pending: (i) the publication by the SABS of national monitoring and data manipulation requirements, (ii) discussions with lab and network accreditation bodies (e.g. SANAS), and (iii) possible decisions to extend national air quality standards to other pollutants. This will apply in the medium-and long-term to CTMM staff who will be responsible for the operation and management of these stations. CTMM proposed with the expansion of the monitoring network to include 3 additional permanent stations and 9 mobile stations, to be managed and operated by contractors. These contractors must train CTMM technicians to be able to operate these stations in the medium-to long-term Final Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxxiii Functions Source control Defining Considerations (3) National Requirements International Good Practice - Responsibility for administering the Trend towards periodic license application process for permit/license review for industrial ‘listed activities’ to be undertaken by sources to account for (i) cumulative local government. impacts in developed areas, (ii) - Local authorities also to be integration of continuous responsible for vehicle emissions, improvement principles by household fuel burning, dust industries emissions from mining and possibly - Trend towards use of accredited also landfill gas emission impact environmental management system regulation development for the purpose of - General reference is made to the compliance demonstration by potential application of voluntary various sources agreements, penalties and - Encouragement of economic incentives (i.e. economic incentives (positive and negative) instruments, pollution charges) above pure source-based controls (e.g. emission limits) Existing Local Resources Resource Implications for CTMM - Limited expertise and experience exists with regard to the control of fuel-burning appliances - 'Scheduled Processes' are not currently controlled by local government - The current capacity for the investigation and development of alternative types of source control (e.g. economic incentives, voluntary agreements) is limited - The capacity for the periodic review of source permits/licenses to ensure continued compliance and facilitate continuous improvement depends on the outcome of the DEAT permit review project. CTMM will need to develop experience with regard to other sources not traditionally controlled (e.g. landfills, fugitive dust sources) - Capacity would need to be developed for the management of 'listed activities' by way of atmospheric emissions licenses. DEAT indicated the facilitating of training for local authorities. Final Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxxiv Functions Emissions monitoring Defining Considerations (3) National Requirements International Good Practice - Emissions monitoring to be carried Trend towards continuous out by the holder of the emission monitoring by industry and regular license in the case of industry extensive data transfer to authorities - No specific reference made to (e.g. 'data graveyards' in Germany) emission monitoring of other sources to date. It is however likely that local authorities will continue to be responsible for vehicle emission monitoring – alternatively this could become a requirement of testing stations. Existing Local Resources Resource Implications for CTMM CTMM currently makes provision for emissions monitoring of diesel powered vehicles twice annually. No other emissions monitoring is currently being undertaken. It has been recommended that CTMM’s current diesel vehicle emission testing programme be extended to be more frequent with an additional number of vehicles being tested per month. This will require changes in the method employed and additional person hours. The addition of local government responsibilities for intermittent source monitoring of non-traditional sources (e.g. wild fire emissions) or other sources by national authorities will similarly have implications in terms of monitoring equipment and personnel. It is, however, possible that such monitoring would be undertaken as part of specialised field campaigns, i.e. outsourced special projects) Final Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxxv Functions Information management reporting Atmospheric dispersion modelling & Defining Considerations (3) National Requirements International Good Practice - National requirements to be - Trend toward standardization of established to facilitate emissions and air quality data bases standardization of emissions and air and information reporting quality data storage, manipulation, mechanism not only within but also transfer and information reporting across countries (e.g. Airbase used - Reporting of greenhouse gas and by EC countries) ozone depleting substance emissions required - DEAT has contracted the CSIR to develop a framework for a National Air Quality Database which intends to house all source and emissions data from every municipality and monitoring data No direct regard. requirements in this - Distinct trend towards the replacement of extensive and costly air quality monitoring networks by on-line dispersion modelling coupled with key monitoring sites for model calibration and validation (particularly in Europe). - In Europe, regional models coupling street- and urban-scale (gridded) models with regional Gaussian Plume models (e.g. AERMOD) within a GIS data base management framework are being applied Existing Local Resources Resource Implications for CTMM Comprehensive electronic emissions and air quality data bases have not been established to date nor provision made for the integration of such data based within a GIS framework - Emissions and air quality data will need to be consolidated within a single data base the structure of which will be influence by national/provincial criteria (i.e National Air Quality Database) - Given the need for data base integration, emission and air quality monitoring data collation & management should preferably be done at a centralised level within CTMM - To facilitate the effective communication of information to the general public it is advisable that an air quality information liaison officer be designated - No capacity currently exists to support regional atmospheric dispersion modelling - Internal capacity (expertise, software, hardware) will need to be established for dispersion modelling applications Final Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxxvi Functions Human health & environmental risk assessment Cost-benefit analysis Air Quality Management Plan development & implementation Defining Considerations (3) National Requirements International Good Practice - No direct requirements in this A tiered approach to the ranking of emission reduction strategies is regard. Initially, rankings are - Ambient air quality standards favoured. adopted by the Air Quality Act to be based on (i) total emission used in health risk screening (i.e. reductions, (ii) ambient air quality improvements to be achieved, (iii) compliance assessment) human and environmental risk and - No direct requirements in this damage reductions, and finally (iv) benefit maximization which takes regard. external costs and benefits into account. Due to time- and expertise- required by the latter two ranking criteria, such ranking not widely implemented and is usually undertaken on an intermittent (special project) basis Provision made for the development - Air Quality Management Plans are and implementation of Air Quality developed, regularly reviewed and Management Plans by local revised by metropolitan air quality authorities (integrated into their authorities (specifically within 'hot Integrated Development Plans) spots' which are declared as 'local air quality management zones e.g. UK; or within non-compliance areas, e.g. State Implementation Plans, US) - A public hearing process / public participation process is usually implemented as part of the plan development process Existing Local Resources Resource Implications for CTMM No clear capacity currently exists to assess human health and/or environmental risk potentials arising due to air pollutant concentrations - Internal capacity will need to be established if the impact of air pollution on human health, vegetation and the built environment to be assessed No clear capacity currently exists to undertake cost-benefit analysis of emission reduction measures. (Information required for the costing of externalities, e.g. hospitalisations, are not routinely available in South Africa to readily facilitate such studies) Given the absence of local expertise and the lack of data to support comprehensive CBA studies, it is envisaged that such analysis will be restricted to qualitative and semiquantitative evaluations. Alternatively CBA could be outsourced on a project-by-project basis. - Air quality management plan drafting requires strong policy and planning skills. Technical expertise is required for the effective characterisation of source-receptor relationships that provides the basis for emission strategy evaluation. The Tshwane Integrated Environmental Policy (TIEP) provides a framework for the development and revision of the Air Quality Management Plan. However, capacity does not exist to fulfil this function within the CTMM. Final Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxxvii 4.3.1 Proposed Structure of CTMM Air Quality Unit The implementation, coordination and management of the AQMP role out would require specific functions and capabilities within the municipal structure. During the development of an AQMP for CTMM, an Energy Strategy was developed and concerted affords were made to ensure synergy between the two. Thus, with the level of integration required between Sustainable Energy and Climate Change Management and Air Quality Management, it was recommended that the two units be implemented as a single unit from the start. The three options proposed for CTMM include the following: • Option 1: Agency outside of CTMM (external option) • Option 2: Internal Air Quality Management Division or Core Group (internal option) • Option 3: High level Strategic Coordination (internal option). The most preferred Option for CTMM will depend on the Municipal Systems Act Section 78 (S78) process (review of internal and external service delivery mechanisms). Option 1: Agency outside of CTMM Figure 3 provides an example of the proposed CTMM Air Quality and Sustainable Energy Agency. The main purpose of an Agency is to be established as a Municipal Entity outside the organisational structure of the CTMM. It would assume the form of a private company, a service utility or a multi-jurisdictional service utility. The functions of the proposed positions are discussed herewith. The associated cost for this option is given in Table 15. • Chief Executive Officer (CEO): This person will be the link between the Board of Directors and shareholders. This person would assume all responsibility for the business and operations of the Agency. • Chief Operational Officer (COO): This person should not be the Air Quality Officer, but rather someone that can oversee the integration of multidisciplinary technical information. This person should preferably have scientific/engineering background with technical and management experience. • Air Quality Officer (AQO): This person should have specialised technical skills with specific relevance to industry (on all the aspects of air quality management, i.e. emissions inventory, modelling, monitoring, control technology etc.). The AQO is responsible for coordinating matters pertaining to air quality management in the municipality. The AQO must ensure that air quality governance is carried out efficiently and effectively. Final Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxxviii MUNICIPAL MANAGER Air Quality Management, Energy & Climate Change Division/Unit Head Chief Officers in CTMM Office of the Municipal Manager Chief Executive Officer Chief Finacial Officer Chief Operation Officer Secretarial/ Support Staff Climate Change Specialists Air Quality Officer Senior Technician Sustanable Energy Specialists Air Quality Public Liaison Officer Senior Scientist Technician Atmospheric Scientist AQ Practisioner Technician Atmospheric Scientist AQ Practisioner Knowledge Management Figure 3: Proposed structure for an Air Quality Management, Energy and Climate Change Agency. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xxxix • Air Quality Practitioners (AQP): This person should have technical skills and would mainly be responsible for data collection and the inspection of emissions reduction measures. • Senior Technician: This person should have both management and technical skills specifically to the monitoring equipment and data analysis. • Technicians: This person should have technical skills pertaining to the maintenance of monitoring equipment. • Senior Atmospheric Scientist: This person should have both management and specialised technical skills pertaining to emissions inventories, dispersion modelling and database management and GIS. • Atmospheric Scientists: This person should have technical skills in emissions inventory development, dispersion modelling, database management and GIS (persons per task could also be appointed) • Air Quality Information Officer: This person should have data management and communication skills Table 15: Option 1 - Agency outside of CTMM (1) Function Chief Executive Officer Chief Operational Officer Air Quality Officer Senior Atmospheric Scientist Senior Technician Atmospheric Scientist Air Quality Practitioner Technicians Position Strategic Executive General Manager Manager Deputy Manager Deputy Manager Chief Officer EHPs (C2-2-D1) EHPs (C2-2-D1) SUB-TOTAL Unit Price per Annum R500 000 – R600 000 R400 000 – R500 000 R350 000 – R400 000 R241 212 – R312 996 R241 212 – R312 996 R330 096 – R456 432 R248 232 – R311 568 R248 232 – R311 568 R2 558 984 – R3 205 560 Software and Hardware Requirements ADMS Urban GIS Software (optional) EMIT / IPIECA (optional) Computers Urban Airshed Dispersion Model Emission Models (Quantity - 8) SUB-TOTAL R 280 000 – R300 000 R 20 000 R 20 000 R 64 000 R384 000 – R404 000 Other Functions Role-out of BNG project 20 000 households (2) TOTAL COST (3) Notes: (1) R 400 000 – R 1 million R3 342 984 – R4 609 560 It is likely that the Agency would have similar salary scales and would require the same number of people and positions to fulfil the task at hand. (2) Lower range is when campaign is done internally and the upper range is when it is out-sourced. (3) Assuming 2 x Atmospheric Scientists, 2 x AQPs, 2 x Technicians, 8 x PCs, 1 x ADMS license, 1 x GIS license, and 20 000 households. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xl Option 2: Internal Air Quality Management Division or Core Group The option of the Internal Core Group will have a similar structure as the Agency. The only difference is that the head of the Division (Chief Operating Officer) will report to the Office of the Municipal Manager. Figure 4 provides an example of the proposed Internal Management Division with the estimated budget provided in Table 16. The main purpose of an Agency is to be established as a Municipal Entity outside the organisational structure of the CTMM. It will be a similar structure than the Agency with the exception that it is established internally within the Strategic Centre. • Chief Operational Officer (COO): This person should not be the Air Pollution Control Officer, but rather someone that can oversee the integration of multidisciplinary technical information. This person should preferably have scientific/engineering background with technical and management experience. • Air Quality Officer (AQO), Air Pollution Practitioners (APP), Senior Technician, Technicians, Senior Atmospheric Scientist, Atmospheric Scientists and Air quality Information Officer – same requirements as for Option 1. Table 16: Option 2 - Internal Air Quality Management Division or Core Group Function Unit/Division Head Air Quality Officer Senior Atmospheric Scientist Senior Technician Atmospheric Scientist Air Quality Practitioner Technicians Position General Manager position Manager Deputy Manager Deputy Manager Chief Officer EHPs (C2-2-D1) EHPs (C2-2-D1) SUB-TOTAL Unit Price per Annum R400 000 – R600 000 R350 000 – R400 000 R241 212 – R312 996 R241 212 – R312 996 R330 096 – R456 432 R248 232 – R311 568 R248 232 – R311 568 R2 058 984 – R2 705 560 Software and Hardware Requirements ADMS Urban GIS Software (optional) EMIT / IPIECA (optional) Computers Urban Airshed Dispersion Model Emission Models (Quantity – 8) SUB-TOTAL R 280 000 – R300 000 R 20 000 R 20 000 R 64000 R384 000 – R404 000 Other Functions Role-out of BNG project TOTAL COST Notes: (1) (2) 20 000 households (1) R 400 000 – R 1 million R2 842 984 – R4 109 560 Lower range is when campaign is done internally and the upper range is when it is out-sourced. (2) Assuming 2 x Atmospheric Scientists, 2 x AQPs, 2 x Technicians, 8 x PCs, 1 x ADMS license, 1 x GIS license, and 20 000 households on lower range. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xli MUNICIPAL MANAGER Air Quality Management, Energy & Climate Change Division/Unit Head Office of the Municipal Manager Chief Financial Officer Chief Officers in CTMM Secretarial/ Support Staff Unit Head Climate Change Specialists Air Quality Officer Senior Technician Sustainable Energy Specialists Air Quality Public Liaison Officer Senior Scientist Technician Atmospheric Scientist AQ Practisioner Technician Atmospheric Scientist AQ Practisioner Knowledge Managemen t Figure 4: Proposed structure for an Air Quality Management, Energy and Climate Change Core Group. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xlii Option 3: High level Strategic Coordination. The third structure proposed for CTMM is that only the core functions as stipulated in the Air Quality Act be accommodated within the CTMM structure with the outsourcing of all other functions to contractors and consultants. Crucial functions that need to be implemented in the Energy, Climate Change and Air Quality Unit include: • Chief Operation Officer (COO): This person should be heading the entire division and don’t have to be restricted to air quality alone. This function should rather be to integrate all air quality related information and make the links between air quality, energy and climate change. • Air Quality Officer (AQO): This position is a requirement of the National Environmental Management: Air Quality Act of 2004. If the APP functions are allocated to the existing EHP’s there should be a clear line of reporting to the APCO since he/she will have to rely strongly on this information to fulfil his/her legal obligation. Careful consideration should be given to this since the EHPs might fall into different divisions. In addition, the EHPs might not be able to absorb the additional workload implicated by air quality management. • Senior Scientist: If all other functions are outsourced, this person would be the main supporting person to the APCO. He/she would be responsible for collating all data from the contractors and consultants an oversee the database management and provide sensible information to the CAPCO Functions that can be outsourced include the following: - Coordinate and standardise functions undertaken across regions (Air Pollution Practitioners) Maintain central database comprising statistics and legal action taken by regions (thus oversee database maintained by Senior Atmospheric Scientist) Periodic review of capacity within regions to undertake air pollution control functions an coordinate capacity building Provide support in terms of the interpretation and enforcement of legislation and regulations related to air pollution control Licensing and control of non-domestic fuel burning and listed activities (information obtained form Assistants) Liaise closely with Senior Technician and Senior Environmental Officer Report to Division Manager The preliminary budget calculations for Option 3 is included in Table 17. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xliii Table 17: Option 3 High level Strategic Coordination Function Unit/Division Head Air Pollution Control Officer Senior Atmospheric Scientist Position General Manager Manager Deputy Manager SUB-TOTAL Unit Price per Annum R400 000 – R600 000 R350 000 – R400 000 R241 212 – R312 996 R991 212 – R1 312 996 Outsourced Functions Technical Section Atmospheric Scientist Contractors for all monitoring & maintenance functions Consultants to compile emissions inventory, populate and run dispersion modelling SUB-TOTAL R300 000 R200 000 - R300 000 (1) R500 000– R600 000 Software and Hardware Requirements ADMS Urban GIS Software (optional) EMIT / IPIECA (optional) Computers Urban Airshed Dispersion Model Emission Models (Quantity – 4) SUB-TOTAL R 280 000 – R300 000 R 20 000 R 20 000 R 32 000 R352 000 – R372 000 Other Functions Role-out of BNG project TOTAL COST Notes: 20 000 households (1) (2) R 400 000 – R 1 million R2 243 212 – R3 284 996 (1) Upper range is for the first year to set everything up and the lower range is from the second year onwards mainly for maintenance and upkeep. (2) 1 x ADMS license (even though the dispersion modelling function is outsourced, ADMS is only sold to cities), 1 x GIS license, 4 x PCs and 20 000 households. 4.3.2 General Requirements Irrespective of which of the three proposed models are chosen, it is imperative that the following structures be in place over the short-term: 4 • CTMM Council to understand the necessity of a specialised Air Quality Management section/unit and approve it. This can be any of the three proposed models. • The two crucial positions over the short-term is the appointment of a Senior Atmospheric Scientist and an Air Quality Officer. This is necessary so to ensure the relevant training in the interim to ensure the ability to fulfil the required functions as set out in the AQMP. • The Senior Atmospheric Scientist and Air Quality Officer will be responsible within the short-term for the execution of all identified tasks to be initiated and implemented. Thus, in the interim very little distinction will be made between the responsibilities of the Senior Atmospheric Scientist and Air Quality Officer. It is expected that the atmospheric licensing functions will only become the responsibility of the local authorities within two years4. This is dependant on the outcome of the Atmospheric Licensing project to commence in the beginning of 2006 and run for a period of 18 months. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xliv • The DEAT is in the process of defining capacity building requirements and training programmes for provincial and local authorities. CTMM will communicate its specific training requirements to DEAT and will determine DEAT's anticipated timeframe for the provision of such support. • In the short-term it is recommended that the Contractors appointed to implement and manage the ambient monitoring stations, train the EHPs on the maintenance and data capturing methods. This will ensure that this function become in-house expertise over the medium- and long term. • It will be crucial that the persons responsible for the AQMP implementation within the short-term form good relationships with all relevant divisions within the CTMM (viz. Environmental Health, Environmental Management, Traffic Divisions, Housing and City Planning). The cooperation from these divisions will be crucial in the implementation of the AQMP. • Dispersion modelling software should be purchased within the short-term. The emissions inventory should be updated and emissions database should be established. All monitoring data must be downloaded onto a base-station and stored in a central database. It is important that provision be made for a back-up system at CTMM. • Integration of existing complaints register to automatically inform the Air Quality Officer of incidences reported and what action should be taken. Capacity to be incorporated over the medium-term: • During this phase the Air Quality Officer should be responsible for reviewing and issuing atmospheric licences to all listed activities within the CTMM. Given the requirement that all sources of air pollution should have been identified during the short-term and that all industries should have supplied the CTMM with emissions inventories, the task of the Air Quality Officer should be lightened. • The emissions inventory should be updated annually to account for an accurate and current reflection of the air pollution sources within CTMM. The urban airshed dispersion model should be set-up and operational at this stage with the capability to run future scenarios. This information will be used by the Air Quality Officer to review and issue emissions licences. • During this phase it is advised that a Section Head be appointed in the case of Option1 or Option 3. This person should be responsible for the management of the Air Quality Section and to ensure that the AQMP be implemented and revised. The Head of the AQM section will also be responsible to ensure that the communication systems operate smoothly and inter-departmental information sharing continue. This person will also be the link to provincial and national departments to ensure data sharing and involvement in all air quality management projects initiated by province and national governments. • Depending on the atomisation of the complaints register and how well air quality issues are capture and responded to, an air quality public liaison officer could be appointed to fulfil this function within the Air Quality Section. It will remain important that the complaints register for air pollution issues continue to be incorporated into the general complaints register. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xlv 4.4 AQM Approval and Review Process During the development process of the AQMP for CTMM a Technical Working Group was established to provide specialised technical input. Members included representatives of the CTMM Departments, provincial and national government departments, academic institutions and the private sector. The Air Quality Stakeholder groups were also involved in the process which included all interested and affected parties. The approval of the AQMP is however not only dependant on the stakeholder and general public acceptance but also on the review and authorisation by provincial and possibly national governments. The methodology for the AQMP approvals has not yet been established. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xlvi TABLE OF CONTENT 1 INTRODUCTION .......................................................................................................................5-1 1.1 PURPOSE AND SCOPE OF AN AIR QUALITY MANAGEMENT PLAN ...............................................5-3 1.2 LEGISLATIVE AND REGULATORY FRAMEWORK FOR AIR QUALITY MANAGEMENT AND PLANNING ..5-5 1.2.1 National Environmental Management: Air Quality Act of 2004 – Introducing a New Approach to Air Quality Management ........................................................................................5-5 1.2.2 Enabling Legislation for Local Government....................................................................5-6 1.2.3 Delineation of National, Provincial and Local Government Responsibilities ...................5-7 1.2.4 Status of National Legislative and AQM Framework Development Process ..................5-8 1.2.5 International Trends in Air Quality Management and Planning ....................................5-13 1.3 RECOMMENDED APPROACH FOR THE AQMP DEVELOPMENT AND DOCUMENTATION................5-13 1.4 CTMM AQMP DEVELOPMENT PROCESS .............................................................................5-15 1.5 REPORT OUTLINE ..............................................................................................................5-17 2 CITY OF TSHWANE METROPOLITAN MUNICIPALITY REGION.........................................6-18 2.1 GEOGRAPHICAL SETTING....................................................................................................6-18 2.2 BACKGROUND INFORMATION ...............................................................................................6-20 2.2.1 Industrial Activities and Power Generation...................................................................6-20 2.2.2 Household Energy Use ................................................................................................6-22 2.2.3 Biomass Burning..........................................................................................................6-23 2.2.4 Mining Operations........................................................................................................6-23 2.2.5 Transport Related Emissions .......................................................................................6-23 2.2.6 Waste Treatment and Disposal....................................................................................6-25 2.3 PRIORITY SOURCES, POLLUTANTS AND AREAS .....................................................................6-27 2.3.1 Priority Pollutants .........................................................................................................6-27 2.3.2 Priority Sources ...........................................................................................................6-28 2.3.3 Priority Areas ...............................................................................................................6-36 2.4 AIR POLLUTION CONTROL AND AIR QUALITY MANAGEMENT CAPABILITIES ..............................6-38 2.4.1 Organisational Structure within the CTMM...................................................................6-38 2.4.2 Review of Current Air Quality Management Tools .......................................................6-41 3 AIR QUALITY MANAGEMENT POLICY FRAMEWORK..........................................................7-1 3.1 VISION, MISSION AND OBJECTIVES ........................................................................................7-3 3.1.1 Vision.............................................................................................................................7-3 3.1.2 Mission and Commitment ..............................................................................................7-3 3.1.3 Strategic Goals and Objectives......................................................................................7-3 3.2 APPROACH TO AIR QUALITY MANAGEMENT ............................................................................7-4 3.3 KEY CONSIDERATIONS IN THE AQMP DEVELOPMENT PROCESS ..............................................7-5 4 LOCAL AIR QUALITY OBJECTIVES.......................................................................................8-1 4.1.1 4.1.2 4.1.3 Air Quality Objectives for Criteria Pollutants ..................................................................8-1 Criteria and Approach for Setting Local Air Quality Objectives ......................................8-3 Definition of Timeframes for Compliance with Local Objectives: ....................................8-6 TABLE 4-2: ALERT AND INFORMATION THRESHOLDS TO BE INVESTIGATED FOR USE BY THE CITY OF TSHWANE .................................................................................................................8-7 TABLE 4-3: THRESHOLDS SPECIFIED BY OTHER COUNTRIES SPECIFICALLY FOR VEGETATION AND ECOSYSTEMS.................................................................................................8-8 4.2 5 ACTIONS REQUIRED AND TARGET DATES .............................................................................8-10 AIR QUALIY MANAGEMENT SYSTEM ...................................................................................9-1 Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xlvii FIGURE 5-2: AIR QUALITY MANAGEMENT SYSTEM PROPOSED FOR IMPLEMENTATION BY CTMM ...............................................................................................................................................9-2 5.1 EMISSIONS INVENTORY.........................................................................................................9-3 5.2 AMBIENT AIR QUALITY AND METEOROLOGICAL MONITORING ...................................................9-4 5.2.1 Monitoring Objectives ....................................................................................................9-5 5.2.2 Parameters to be Monitored...........................................................................................9-6 5.2.3 CTMM Monitoring Network Proposed for Initiation – Short-term ....................................9-7 5.3 ATMOSPHERIC DISPERSION MODELLING ..............................................................................9-10 5.4 REPORTING PROTOCOL ......................................................................................................9-11 5.5 PUBLIC CONSULTATION APPROACH .....................................................................................9-14 5.5.1 Aims and Objectives: ...................................................................................................9-14 5.5.2 Media/methods to be considered for use: ....................................................................9-14 5.5.3 Designation of an Air Quality Information Liaison Officer .............................................9-14 5.5.4 Complaints Register.....................................................................................................9-15 5.5.5 Reporting Air Quality Information .................................................................................9-15 5.5.6 Public Meetings ...........................................................................................................9-16 5.6 AIR QUALITY MANAGEMENT SYSTEM DEVELOPMENT - ACTIONS REQUIRED ............................9-16 6 SOURCE QUANTIFICATION AND EMISSIONS REDUCTION MEASURES .........................10-1 6.1 DOMESTIC FUEL BURNING ..................................................................................................10-3 6.1.1 National and Provincial Government Interventions ......................................................10-3 6.1.2 Proposed Emission Reduction Strategies ....................................................................10-5 6.1.3 Proposed Emission Reduction Strategies ....................................................................10-5 6.2 ROAD TRANSPORTATION ....................................................................................................10-6 6.2.1 National and Provincial Government Strategies...........................................................10-7 6.2.2 Proposed Emission Reduction Strategies ....................................................................10-8 6.3 INDUSTRIAL SOURCES ...................................................................................................... 10-11 6.3.1 Scheduled Processes ................................................................................................ 10-11 6.3.2 Non-Scheduled Processes ........................................................................................ 10-12 6.3.3 Proposed Emission Reduction Strategies .................................................................. 10-12 6.4 WASTE AND DISPOSAL TREATMENT ................................................................................... 10-15 6.4.1 National and Provincial Government Strategies......................................................... 10-15 6.4.2 Proposed Emission Reduction Strategies .................................................................. 10-16 6.5 MINING ACTIVITIES ........................................................................................................... 10-17 6.5.1 National and Provincial Government Strategies......................................................... 10-17 6.5.2 Proposed Emission Reduction Strategies .................................................................. 10-18 6.6 OTHER SOURCES ............................................................................................................. 10-19 6.6.1 Proposed Emission Reduction Strategies .................................................................. 10-20 7 RESEARCH INITIATIVES.......................................................................................................11-1 8 CAPACITY BUILDING ............................................................................................................12-1 8.1 PROPOSED STRUCTURE OF CTMM AIR QUALITY UNIT........................................................ 12-10 8.1.1 Option 1: Agency outside of CTMM ........................................................................... 12-11 8.1.2 Option 2: Internal Air Quality Management Division or Core Group ........................... 12-15 8.1.3 Option 3: High level Strategic Coordination. .............................................................. 12-20 8.1.4 General Requirements............................................................................................... 12-23 8.2 BUDGET REQUIREMENTS .................................................................................................. 12-25 9 AQMP APPROVAL AND REVIEW PROCESS .......................................................................13-1 9.1 9.2 10 AQMP APPROVAL .............................................................................................................13-1 AQMP REVIEW .................................................................................................................13-2 REFERENCES ....................................................................................................................14-1 WHO (2000). AIR QUALITY GUIDELINES, WORLD HEALTH ORGANISATION, GENEVA........14-2 Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xlviii LIST OF FIGURES Figure 1-1: Location of the City of Tshwane Metropolitan Municipality............................. 5-1 Figure 2-1: Tshwane Metropolitan Municipality boundaries.............................................. 6-18 Figure 2-2: Population density within the CTMM as taken from the 2001 Census data. .. 6-19 Figure 2-3: Location of the two power stations and industries within the CTTM............... 6-21 Figure 2-4: Oxides of nitrogen emissions as predicted by the VISUM model (from CTMM State of Energy Report, 2005) .................................................................................... 6-24 Figure 2-5: Contributions form the various sectors within the CTMM to total inhalable particulate (PM10) emissions. .................................................................................... 6-29 Figure 2-6: Contributions form the various sectors within the CTMM to total sulphur dioxide (SO2) emissions. ......................................................................................................... 6-30 Figure 2-7: Contributions form the various sectors within the CTMM to total oxides of nitrogen (NOx) emissions. ........................................................................................... 6-30 Figure 2-8: Contributions form the various sectors within the CTMM to total benzene emissions.................................................................................................................... 6-31 Figure 2-9: Contributions form the various sectors within the CTMM to total organic compounds (TOC) emissions. .................................................................................... 6-31 Figure 2-10: Contributions form the various sectors within the CTMM to total carbon monoxide (CO) emissions. ......................................................................................... 6-32 Figure 2-11: Contributions form the various sectors within the CTMM to carbon dioxide (CO2) emissions (greenhouse gasses). ...................................................................... 6-32 Figure 2-12: Contributions form the various sectors within the CTMM to total methane (CH4) emissions (greenhouse gasses). ................................................................................ 6-33 Figure 5-1: Development of an air quality management strategy through the implementation of select air quality management tools (after WHO, 2000). .......................................... 9-1 Figure 5-2: Air quality management system proposed for implementation by CTMM ........ 9-2 Figure 5-3: Example for a National Emissions Inventory (from Mark Zunkel, CSIR, IQPC Conference, 15 & 16 February 2005, Sandton Convention Centre) ............................. 9-4 Figure 5-4: Proposed locations of permanent and mobile monitoring stations, including existing stations. ........................................................................................................... 9-9 Figure 8-1: Proposed structure of the Air Quality Section at CTMM. .............................. 12-10 Figure 8-2: Proposed structure for an Energy, Climate Change and Air Quality Management Agency...................................................................................................................... 12-12 Figure 8-3: Proposed structure for an Energy, Climate Change and Air Quality Management Core Group. .............................................................................................................. 12-17 Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page xlix LIST OF FIGURES Table 1-1: National, provincial and local government functions as informed by the Air Quality Act................................................................................................................................. 5-7 Table 1-2: Timing for the rollout of the National Air Quality Management Plan ................ 5-12 Table 2-1: Sources of atmospheric emissions within the CTMM and their associated emissions.................................................................................................................... 6-29 Table 2-2: Summary of Priority Pollutants, Sources and Areas ........................................ 6-37 Table 4-1: Local guidelines to be adopted for implementation by the City of Tshwane. Values are expressed in µg/m3 and where appropriate ppb (the volume standardised at a temperature of 25°C and a pressure of 101,3 kPa.) .................................................. 8-4 Table 4-2: Alert and information thresholds to be investigated for use by the City of Tshwane ....................................................................................................................... 8-7 Table 4-3: Thresholds specified by other countries specifically for vegetation and ecosystems................................................................................................................... 8-8 Table 5-1: Proposed CTMM air quality and meteorological monitoring sites...................... 9-7 Table 5-2: Frequency and content of reports to be considered by CTMM in the short-term (next two years) in defining its medium- and long-term reporting commitments and targets......................................................................................................................... 9-13 Table 6-1: Emissions reduction strategies for Domestic Fuel Burning to be implemented by CTMM over the short-and medium term..................................................................... 10-5 Table 6-2: Emissions reduction strategies for Transportation to be implemented by CTMM over the short-and medium term................................................................................. 10-9 Table 6-3: Recommended emission reduction strategies for scheduled and non-scheduled processes within the CTMM. .................................................................................... 10-13 Table 6-4: Recommended emission reduction strategies for waste disposal facilities within the CTMM. ................................................................................................................ 10-16 Table 6-5: Recommended emission reduction strategies for mining operations within the CTMM. ...................................................................................................................... 10-19 Table 6-6: Recommended emission reduction strategies for other sources within the CTMM. .................................................................................................................................. 10-20 Table 7-1: Research initiatives recommended for implementation in the short- and mediumterm............................................................................................................................. 11-1 Table 8-1: Resource implications for the City of Tshwane given national requirements and international practice with regard to principle air quality management functions and existing local resource availability............................................................................... 12-2 Table 8-2: Option 1 - Agency outside of CTMM (1) .......................................................... 12-25 Table 8-3: Option 2 - Internal Air Quality Management Division or Core Group ............. 12-26 Table 8-4: Option 3 High level Strategic Coordination .................................................... 12-27 Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page l LIST OF ABREVIATIONS APPA AQA / NEMAQA - Air Pollution Prevention Act - National Environmental Management: Air Quality Act AQMP - Air Quality Management Plan BNM - Basa Njengo Magogo CAPCO - Chief Air Pollution Control Officer CO / CO2 Carbon monoxide / carbon dioxide CTMM DAPC - City of Tshwane Metropolitan Municipality DEAT - Department of Environmental Affairs and Tourism, South Africa EC - European Community EHP EIA - Environmental Health Practitioners - Environmental Impact Assessment EMM EU - Ekurhuleni Metropolitan Municipality GDACE - Department of Agriculture, Conservation and Environment HPa - Hecto pascal mg/m²/day - Milligrams per square meter per day NAQMP - National Air Quality Management Plan NEMA NO / NO2 / NOx - National Environmental Management Act - Nitrogen oxide / Nitrogen dioxide / Oxides of nitrogen PM10 - Particulate Matter with an aerodynamic diameter of less than 10 µm PM2.5 - Particulate Matter with an aerodynamic diameter of less than 2.5 µm ppb - Parts per billion ppm - Parts per million SANS - South Africa National Standards SO2 - Sulphur Dioxide TOC - Total Organic Compounds tpa - Tonnes per annum tpd - Tonnes per day tpm - Tonnes per month TSP - Total Suspended Particulates µg/m³ - Micrograms per cubic meter US-EPA - United States Environmental Protection Agency VOCs WB - World Bank Group WHO - World Health Organisation Division of Air Pollution Control (DEAT) European Union Volatile Organic Compounds Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page li AIR QUALITY MANAGEMENT PLAN FOR THE CITY OF TSHWANE METROPOLITAN MUNICIPALITY 5 INTRODUCTION The City of Tshwane is the administrative capital of the Republic of South Africa and is situated in the province of Gauteng (Figure 1-1). It came into being on 5 December 2000 when the 13 municipalities serving the Greater Pretoria area were amalgamated to form the City of Tshwane Metropolitan Municipality (CTMM) (SOE, 2004). Various sources of emissions are located within the CTMM, including industrial sources and power generation, vehicle tailpipe emissions, household fuel burning appliances, waste disposal activities, sand and dolomite quarries, biomass burning and fugitive dust emissions from exposed areas, vehicle entrainment, materials handling and agricultural activities. Figure 5-1: Location of the City of Tshwane Metropolitan Municipality The impacts of atmospheric emissions emanating from these sources within the Metro have not only local but also regional and global implications. Local scale effects include impacts on human health and the biophysical environment due to exposures within the region. Atmospheric emissions from local sources might also impact on the air quality of neighbouring regions, such as Ekurhuleni (located to the southeast) and the City of Joburg (located to the south and southwest). On a global scale, the contribution of greenhouse Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-1 gases from sources within the Metro to climate change is of concern and should be addressed. According to the Constitution, municipalities have the executive authority in respect of air pollution control. The new National Environmental Management: Air Quality Act of 2004 5 has shifted the approach of air quality management from source-based control only, to the control of the receiving environment. Whereas the Air Pollution Prevention Act of 1965 centralised air pollution governance at National level, the new Act focuses on the decentralisation of power down to provincial and local authority levels. This has placed the responsibility of air quality management on the shoulders of local authorities that will be tasked with baseline characterisation, management and operation of ambient monitoring networks, licensing of listed activities, and emissions reduction strategies. In order to fulfil these responsibilities local authorities will be required to develop Air Quality Management Plans (AQMP) as part of their Integrated Implementation Plans. The main objective of the act is to ensure the protection of the environment and human health through reasonable measures of air pollution control within the sustainable (economic, social and ecological) development framework. CTMM has identified the necessity for the development of strategic planning processes to enable environmentally sustainable development within the municipality. The Tshwane Integrated Environmental Policy (TIEP) has been formulated by the Housing, City Planning and Environmental Management Department (Environmental Management Division) to form the foundation from which all the departments within the CTMM can develop medium-term environmental management strategies. This TIEP will form an integral part of the Integrated Development Plan (IDP) process, incorporating both the State of the Environment Report and the Environmental Implementation Plan. The main objective of the TIEP is to ensure the incorporation of the environmental principle of sustainability in the decision making processes, the development of strategies and programmes, the development and planning of landuse, and the management of resources and activities. The overarching goal of the TIEP regarding Environmental Health Management is to promote an environment that is not detrimental to human health and well-being through: • effective environmental health management; • the implementation of an integrated waste management and minimisation strategy at all levels within Tshwane; and, • the establishment of an integrated system of pollution minimisation, management and prevention. Air quality management falls within the system of pollution minimisation, management and prevention, and aims to improve it in areas with poor air quality, and maintain it in areas with good air quality. It is within this context that the Environmental Health Division initiated the development of an Air Quality Management (AQM) Plan for the City of Tshwane. 5 th The National Environmental Management: Air Quality Act (Act no.39 of 2004) commenced with on the 11 of September 2005 as published in the Government Gazette on the 9th of September 2005. Sections omitted from the implementation are Sections 21, 22, 36 to 49, 51(1)(e),51(1)(f), 51(3),60 and 61. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-2 5.1 Purpose and Scope of an Air Quality Management Plan The main purpose of developing an Air Quality Management (AQM) Plan for the City of Tshwane is to empower the metro to meet its obligations as outlined in the Air Quality Act (AQA). The AQMP will initiate ‘best practice’ in air quality management and ensure the reduction of emissions in a cost effective and equitable way. This will ensure the improvement of air quality within CTMM and subsequently the reduction of environmental and health risks, which is also in line with the requirements of the TIEP. The main goals to be achieved by the CTMM through its development, implementation, review and revision of air quality management plans are as follows: • To achieve and sustain acceptable air quality levels throughout the City of Tshwane. • To minimize the negative impacts of air pollution on health, well-being and the environment. • To promote the reduction of greenhouse gases so as to support the council's climate change protection programme. • To reduce the extent of ozone depleting substances in line with national and international requirements. Specific objectives include: • To promote cleaner production and continuous improvement in best practice as it pertains to air pollution prevention and minimisation. • To promote energy efficiency within all sectors including industrial, commercial, institutional, mining, transportation and domestic energy use. Based on the requirements of AQA and the TIEP, the Department of Social Development initiated the development of an Air Quality Management Plan for the City of Tshwane Metropolitan Municipality (CTMM). Airshed Planning Professionals (Pty) Ltd was appointed to assist the Environmental Health Division in formulating a detailed Air Quality Management Plan. Although Airshed represents the lead consultancy, Airshed sub-contracted Zitholele Consulting to provide support services for the project. Zitholele was responsible for public notification of the project and for consultation with interested and affected parties. To achieve the set-out objectives, it was proposed that the project had two focus areas: • Baseline assessment of air pollution concentrations and air quality management practices within CTMM, and inventory of national and provincial requirements pertaining to AQMP development. • Development of an Air Quality Management Plan for CTMM, taking into account: • operational and functional structure requirements • air quality management system component requirements • source identification and prioritisation • emission reduction measures implementable Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-3 • mechanisms for facilitating inter-departmental co-operation in the identification and implementation of emission reduction measures for certain sources • human resource development (training) requirements The integration of technical evaluation and public issues were considered paramount in the AQMP development process to ensure that the project team do not function in isolation. The AQMP development process was divided into three components for planning and administrative processes, viz. a technical process, an advisory process and a consultation process. The following structures were therefore established: CTMM Project Manager Technical Working Group Airshed Project Team Air Quality Stakeholder Group The technical process comprised all information syntheses, issue analyses and document drafting tasks to be completed by technical members of the project team. The advisory process refers to consultation between the project team and the Steering Committee, Technical Working Group and Stakeholder Group. The consultation process included the dissemination of information and invitations for public participation, organisation of discussion workshops, and collection and collation of comments for communication to the technical team. The Technical Working Group (TWG) comprised persons from various sectors within CTMM able to contribute to the process through providing input into the air quality management system design; assisting with emission reduction measure drafting and with assessing the feasibility and cost implications of implementing measures within the industrial, mining, domestic fuel usage and transport sectors. Representatives from the various CTMM departments responsible for environmental management, environmental health, municipal infrastructure, housing, transport and spatial planning were invited to participate in the technical working group. Representation was also invited from Academic institutions such as the University of Pretoria and the Tshwane University of Technology. The Gauteng Department of Agriculture, Conservation and Environment (GDACE), the Department of Environmental Affairs and Tourism (DEAT) and the Department of Minerals and Energy (DME) were also asked to nominate representatives. In addition, consultants involved in the development of the State of Energy Report for CTMM were involved to ensure not only relevant and matching information sharing but also seamless integrations of both projects into the TIEP and IDP. A list of the persons represented on the Technical Working Group and their relevant affiliations is given in Appendix A. Air Quality stakeholder group representatives were identified by Zitholele Consulting on the basis of a consultative process. The main functions of the Air Quality Stakeholder Group included: (i) assisting in the categorisation of issues raised during the broad consultation process; (ii) assisting in identifying the potential for trade-offs and compromises where conflicting views are given by various stakeholders; and (iii) acting as a "sounding board" to assist the project team in determining whether the key issues have effectively been communicated in the documents scheduled for distribution. The consultation process Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-4 included the dissemination of information and invitations for public participation, organisation of discussion workshops, and collection and collation of comments for communication to the technical team. The AQMP is intended to be used as the management and performance-monitoring tool for air quality control and to provide a baseline assessment of air quality issues within the CTMM. The plan addressed various categories of air pollutants including: toxic and odoriferous substances, greenhouse gases and ozone depleting substances. Although greenhouse gas emissions were included, these were not addressed in detail since it is discussed in the Energy Strategy Report. The plan did not address the quantification, monitoring and management of noise and radioactivity. 5.2 Legislative and Regulatory Framework for Air Quality Management and Planning In the development of Tshwane’s AQMP, consideration must be given to national and provincial requirements, AQMP development by other metropolitans and cities within RSA and international best practice pertaining to AQMP development and implementation. In order to pre-empt impending national and provincial requirements pertaining to AQM Planning the project team liaised closely with national and provincial departments on developments with regard to guidelines for local AQMP development. Reference was also made to the National Environmental Management: Air Quality Act of 2004. Information was obtained from other metros, including the Cities of Joburg and Cape Town, Ekurhuleni and Ethekwini Metropolitan Municipalities, regarding progress made in their AQM development processes. Criteria defining international 'best practice' as it pertains to AQMP development and implementation were collated and considered. 5.2.1 National Environmental Management: Air Quality Act of 2004 – Introducing a New Approach to Air Quality Management Under the Air Pollution Prevention Act (Act No 45 of 1965) (APPA) the focus is mainly on sourced based control with permits issued for Scheduled Processes. Scheduled processes, referred to in the Act, are processes which emit more than a defined quantity of pollutants per year, including combustion sources, smelting and inherently dusty industries. Best Practical Means (BPM), on which the permits are based, represents an attempt to restrict emissions while having regard to local conditions, the prevailing extent of technical knowledge, the available control options, and the cost of abatement. The Department of Environmental Affairs and Tourism (DEAT) is responsible for the administration of this Act with the implementation thereof charged to the Chief Air Pollution Control Officer (CAPCO). The APPA is outdated and not in line with international best practice. It also proves inadequate to facilitate the implementation of the principles underpinning the National Environmental Management Act (NEMA) and the Integrated Pollution and Waste Management (IP&WM) white paper. In this light, the National Environmental Management: Air Quality Act (Act no. 39 of 2004) was promulgated, shifting the approach from source based control to decentralised air quality management through an effects-based approach. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-5 The new National Environmental Management: Air Quality Act 2004 has shifted the approach of air quality management from source-based control to the control of the receiving environment. The act has also placed the responsibility of air quality management on the shoulders of local authorities that will be tasked with baseline characterisation, management and operation of ambient monitoring networks, licensing of listed activities, and emissions reduction strategies. The main objective of the act is to ensure the protection of the environment and human health through reasonable measures of air pollution control within the sustainable (economic, social and ecological) development framework. The Air Quality Act (AQA) makes provision for the setting of ambient air quality standards and emission limits on National level, which provides the objective for air quality management. More stringent ambient guidelines may be implemented by provincial and metropolitan authorities. Listed activities will be identified by the Minister and will include all activities regarded to have a significant detrimental effect on the environment, including health. Emission limits will be established on National level for each of these activities and an atmospheric emission licence will be required in order to operate. With the decentralisation of power down to provincial and local authority level, district and metropolitan municipalities will be responsible for the issuing of licences for listed activities. In addition, the Minister may declare priority pollutants for which an industry emitting this substance will be required to implement air pollution prevention plans. An air quality officer appointed by local authorities and responsible for the issuing of atmospheric emission licences, may also require from a company (or person) to submit atmospheric impact reports in order to demonstrate compliance. 5.2.2 Enabling Legislation for Local Government The decentralisation of AQM and associated new responsibilities for local government is made feasible given the recent promulgation of enabling legislation for local government. The Municipal Structures Act, together with the Local Government: Municipal Systems Act 32 of 2000, have firmly established Local Government as an autonomous sphere of government having specific functions defined by the Constitution. The Access to Information Act, 95 of 2000 aims to promote transparency, accountability and effective governance of all public and private bodies through educating everyone to effectively scrutinise, and participate in, decision-making by public bodies that affect their rights. The Promotion of Administrative Justice Act, 96 of 2000 aims to give effect to section 33 of the Constitution. In terms of this Act, local government can be held responsible for its actions and decisions by the public and is required to act in an efficient and transparent manner. New responsibilities for local government arising due to recent legislative changes include facilitation of public participation, transparency, accountability and access to information. According to Section 156(1) of the Constitution a municipality has the executive authority in respect of, and has the right to administer the local government matters listed in, Part B of Schedule 4 of the constitution that deals with air pollution. Section 156(2) makes provision for a municipality to make and administer by-laws for the effective administration of the matters which it has the right to administer so long as such by-laws do not conflict with national or provincial legislation. The repealing of Local Government Transition Act, Act no. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-6 209 of 1993 on 5 December 2000 removed legislative obstacles to the application of Section 156 of the Constitution by municipalities. 5.2.3 Delineation of National, Provincial and Local Government Responsibilities In accordance with the IP&WM Policy, the DEAT indicates that it will delegate the responsibility for air quality management strategy implementation and regulation enforcement to the 'appropriate sphere of government'. The anticipated delineation of responsibilities between national, provincial and local government, as informed by the Air Quality Act, are outlined in Table 1-1. National Government is tasked with the enforcement of the national AQM legislative framework with provincial and local government being required to operate within this framework. Provincial government is permitted to develop their own legislation and policies to meet their obligations in terms of the national policy. Local government are permitted to develop and implement local AQM programmes, guidelines and by-laws in line with national and provincial policy and legislation. Table 5-1: National, provincial and local government functions as informed by the Air Quality Act NATIONAL Government Functions and Responsibilities Establish & review national framework PROVINCIAL Government Functions and Responsibilities Air quality monitoring LOCAL Government Functions and Responsibilities Air quality monitoring Identify priority pollutants Establish national air quality standards Monitor municipality performance Identify priority pollutants Emission monitoring Identify priority pollutants Establish national emission standards Establish provincial air quality standards Establish local emission standards Appoint national AQ officer Establish provincial emission standards Appoint AQ officer Integrate AQMPs into their Environmental Management Plans Appoint provincial AQ officer Declare priority areas Integrate AQMPs into their Environmental Management Plans Develop and implement AQMP as part of their Integrated Development Plans (IDP) Collaborate with national & provincial government (within priority areas) Prepare priority areas AQMP Declare priority areas List activities Declare controlled emitters Set requirements for pollution prevention plans Set regulations for dust, odour, noise Prepare priority areas AQMP List activities Declare controlled emitters Declare and set requirements for controlled fuels Perform emission licensing authority functions (metros and district municipalities) (Perform emission licensing authority functions if no capacity by local authorities) Declare and set requirements for controlled fuels Investigate & regulate transboundary pollution Investigate potential international agreement contraventions Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-7 5.2.4 Status of National Legislative and AQM Framework Development Process Rollout components of the National Air Quality Management Framework were given by the DEAT as comprising: (1) National air quality management approach (2) New air quality management legislation (3) Institutional model for effective implementation of the new legislation (4) Organisational development and capacity building for the effective implementation of the new legislation (5) Setting of ambient air quality standards (6) Managed transition from APPA to the new legislation (7) National air quality monitoring programme (8) Standard methods for ambient air quality monitoring, sample analysis and reporting (9) Standard methods for point-source emission monitoring, sampling analysis and reporting (10) Standard ambient air quality modelling (11) Air quality management strategy guidelines National government vision with respect to the National Air Quality Management Plan is that the programme will develop, implement and maintain an air quality management regime that contributes to sustainable development and a measurable improvement in the air quality life of all. This will be achieved by harnessing the energy and commitment of all South Africans for the effective prevention, minimisation and control of atmospheric pollution (Peter Lukey6, Implementing the Air Quality Act Conference, 24 – 25 October 2005, The Castle, Kyalami). The National Air Quality Management Plan (AQMP) has seven strategic goals in achieving sustainable air quality management, viz.: 1. Effective Institutional framework and legislation 2. Pollution prevention and impact management 3. Holistic and integrated planning 4. Participation and partnerships in Air Quality Management Governance 5. Empowerment and education in Air Quality Management 6. Information management 7. International cooperation Delays have been experienced by DEAT in its rollout of various of the above-mentioned air quality management components. Progress made to date has been drawn from a 6 Peter Lukey is the Chief Director: Air Quality Management and Climate Change at the Department of Environmental Affairs and Tourism. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-8 presentation given by Peter Lukey (Implementing the Air Quality Act Conference, 24 – 25 October 2005, The Castle, Kyalami). The role-out strategy by DEAT followed a phased approach, with the first phase focussing on the translation of the IP&WM Policy into strategy, legislative framework and initial implementation action plan for air quality management. PHASE I: NAQMP Definition Phase I outputs included an air quality management framework strategy and initial action plan in the form of a draft AQMP, and the AQA that provides the legislative framework for the implementation of the IP&WM an NAQMP. • National Environmental Management: Air Quality Act – The Air Quality Bill was gazetted for public comment during 2003, submitted to the National Council of Provinces during November 2003 and was discussed in parliament in February 2004. Due to concerns raised during the public hearings held as part of the parliamentary session it was decided that the DEAT review the Bill and consult with interested and affected parties prior to the Bill being resubmitted to parliament. The Bill was resubmitted to the National Assembly Portfolio Committee on Environmental Affairs and Tourism and amended and accepted by this Committee in August 2004. The Bill was again tabled before the National Council of Provinces in October 2004. The Bill was approved by the National Assembly and sent to the President’s office for signature. The Act was signed by the President on the 21st of February 2005 and published in the Government Gazette. On the 11th of September 2005 the National Environmental Management: Air Quality Act (Act no.39 of 2004) commenced with, excluding certain sections from the act pertaining to listed activities and associated licensing responsibilities7. Thus the APPA still regulates “scheduled activities”. • Air Pollution Prevention Act (Act No. 45 of 1965) to Air Quality Act transitional programme – The CSIR was appointed by DEAT during the first half of 2004 to undertake this 18 month project. The transitional phase project includes the finalisation of the National Air Quality Management Programme, the compilation of an implementation manual for the Air Quality Act, the training of Provincial air quality managers, and the drafting of regulations required for Act implementation. This project is proposed to be finished by the end of 2005. PHASE II: Transition Phase II concentrates on ensuring a smooth transition from the APPA to the AQA. This has been done through the implementation of various projects. • 7 The Durban South Multipoint Plan – The pilot project already underway will be used to test and inform strategies for dealing with air pollution 'hot spots' and local government roles and responsibilities. Sections omitted from the implementation are Sections 21, 22, 36 to 49, 51(1)(e),51(1)(f), 51(3),60 and 61. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-9 • NEDLAC Air Quality Study – This study investigated the social and economic impact of the phasing out of dirty fuels in the country over a period of time, and aimed to provide specific guidance on supply side measures to support the process. • The SO2 ambient standard setting initiative – This project was completed in 2002 with the recommended interim guidelines for South Africa by the DEAT (Government Gazette, 21 Dec. 2001) • The SABS standard setting approach - The SABS was engaged to assist the DEAT in the facilitation of the development of ambient air quality standards. A technical committee was established to oversee the development of standards. Three working groups were established by this committee for the drafting of ambient air quality standards for (i) sulphur dioxide, particulates, oxides of nitrogen and ozone, (ii) lead and (iii) volatile organic compounds, specifically benzene. Two documents were produced during the process, viz.: SANS 69 - South African National Standard - Framework for setting & implementing national ambient air quality standards SANS 1929 - South African National Standard - Ambient Air Quality - Limits for common pollutants The latter document includes air quality limits for particulate matter less than 10 µm in aerodynamic diameter (PM10), dustfall, sulphur dioxide, nitrogen dioxide, ozone, carbon monoxide, lead and benzene. The SANS documents were approved by the technical committee for gazetting for public comment. These draft documents were made available for public comment during the May/June 2004 period and were finalized and published during the last quarter of 2004. These limit values as outlined by SANS is likely to replace the interim outdated ambient air quality standards adopted by AQA in the interim. Standard methods for ambient air quality monitoring – SANS 1929 provides guidance on macro- and micro-siting of monitoring stations, selection of suitable numbers of stations, data quality objectives, and gives reference methods for measuring pollutant concentrations. Standard ambient air quality modelling – SANS 1929 provides guidance on the use of atmospheric dispersion modelling for compliance demonstration. • The Danida support NAQMP Phase II and IIB Projects – initiated in April 2004, these projects aim to develop an NAQM programme and website, train provincial air quality officers, providing an AQA implementation training manual and AQA implementation course. It also aims to develop pollutant prioritisation and standard setting process protocols, and provide the initial list of listed activities, controlled emitters, regulations and an Action Plan Development Manual. Outputs also associated with the projects will include AQ information review and AQ Information System framework development. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-10 • The fuel reformulation initiative – the DME’s cleaner production initiative include the phasing out of leaded fuel by January 2006 and reduction of sulphur content within diesel fuel. • The vehicle emissions strategy – This project is linked to the DME’s fuel reformulation initiative. • The Norad support licensing capacity development programme – based on the experience from the Durban South Multipoint Plan the aim is to develop a draft template for Atmospheric Emissions Licenses that can be used nationally. • The Vaal Triangle SEA – the multi-stakeholder initiative to undertake a strategic environmental assessment of the Vaal Triangle to inform management of priority areas. • The APPA permit review project – the project will commence following the conclusion of a tender process and aims to capture, sort and store all current APPA Registration Certificates. This will inform an initial list of priority air polluters. The prioritised Registration Certificates will be reviewed jointly by National, Provincial and local governments to ensure practical and reasonable amendments. Training of licensing authority staff to apply procedures, protocols, standard formats etc. for developing an atmospheric emissions licence. • AQM enforcement initiatives – air pollution cases considered serious have been prioritised for enforcement action by the Environmental Management Inspectorate (so-called Green Scorpions). • The priority area identification initiative – the department is currently working on this initiative to allow for the concentration of limited air quality management capacity to improve this in the short- and medium terms, to prescribe cooperation governance, and to provide air quality management methodologies that take into account all contributors to air pollution (i.e. Airshed air quality management). • The residential air pollution initiative – The DME has embarked on the implementation of the Integrated Clean Household Energy Strategy to reduce the use of biomass burning as energy source in households. This project has three strategic phases, namely: o promote the Basa njengo Magogo (BNM) method of making a fire; o manufacturing and distribution of acceptable and affordable low smoke fuel; o require housing insulation and energy efficient housing designs PHASE III: Capacity Development Project associated with the Phase III implementation of the NAQMP are listed as follows: Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-11 • Accredited Air Quality Management Qualifications – tertiary institutions to rollout formal accredited air quality management courses for both private sector and government. • The NAQMP Information Series – the department will publish a number of books and booklets to advance the understanding of air quality management. • The National AQIS rollout – the department will rollout the national air quality information system (AQIS) that will provide accurate, current and comprehensive air quality information. PHASE IV: Maintenance and Review The final phase of the NAQMP rollout deals wit the maintenance of efficient and effective air quality programmes in South Africa. This phase will also include the continuous monitoring and review of the implementation and management of the NAQMP. The timeframe as laid out by DEAT in the rollout of the strategy is reflected in Table 1-2. Table 5-2: Timing for the rollout of the National Air Quality Management Plan NAQMP PHASE 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 PHASE I: Definition PHASE II: Transition PHASE III: Capacity Building PHASE IV: Maintenance & Review Every effort was made to ensure that the City of Tshwane Metropolitan Municipality’s AQMP was informed by and reflects national and provincial regulatory changes. Given that various of the regulations are still in development and the sections pertaining to the licensing obligations by local authorities were excluded from the promulgation of the AQA, it is crucial that the CTMM AQMP be reviewed following: • Promulgation of the Air Quality Act in its final form (including the sections pertaining to listed activities and atmospheric emissions licensing requirements) • Completion of the Air Quality Act implementation manual, regulations, standards and guidance documents compiled during the Transitional Phase Programme In the implementation of the CTMM AQMP it is also important that attention be paid to: Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-12 • Recommendations regarding local air quality management measures, emission reduction strategy implementation and local government responsibilities from the Durban South Project • Guidance on local government responsibilities and on mechanisms for coordinating responsibilities between national, provincial and local spheres of government (as an outcome of the Gauteng AQM Strategy Project) CTMM adopted a proactive approach in its development and implementation of an AQMP ahead of it being required to do so by law. Similar approaches are being adopted by other local authorities. The City of Joburg has had an air quality baseline assessment undertaken and air quality management plan developed, with this plan having been approved for implementation by the local council during September 2003. Ekurhuleni Metropolitan Municipality (EMM) completed their baseline characterisation study and AQMP in January 2005 with the approval for the implementation thereof by local council during August 2005. Ethekwini and Cape Town have similarly completed situation analyses and are in the process of air quality management planning. Despite the current absence of national guidelines on air quality management planning, these cities and metropolitan municipalities are following similar approaches. 5.2.5 International Trends in Air Quality Management and Planning The scope and content of AQMPs developed by cities and regions within various countries were reviewed to inform the development of local air quality management plans, including Australia (Perth), United Kingdom (London), USA (Los Angeles, San Francisco, State of Massachusetts, Boston), Canada (Fraser Valley Regional District), Mexico (Mexico City) and China. Critical success factors for an AQMP were identified based on international experience. Such factors were used as the basis for the development of an AQMP Development Framework and for drafting of a comprehensive list of contents for consideration in terms of the structuring the AQMP. 5.3 Recommended Approach for the AQMP Development and Documentation CTMM is a neighbouring metropolitan municipality to the City of Joburg (to the south and southwest) and EMM (to the southeast). All three these municipalities are located within the Gauteng Province. Since AQMPs have been developed for both the City of Joburg and EMM, it was decided to follow a similar approach in AQMP development as for these two metros. This will ensure for easy comparison between the AQM strategies of these three adjoining metros and assist in establishing inter-municipal management strategies for transboundary pollution control. Furthermore, it will facilitate the task of Provincial Government to integrate these plans into the Provincial Air Quality Management strategy. (1) Identification of priority pollutants, sources and key impact areas (2) Setting of air quality management objectives, targets and timeframes (3) Air pollution reduction strategy development, including: Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-13 (3.1) Establishment of a control strategy development programme (3.2) Identification of control measures implementable in the short-, mediumand long-term (3.3) Evaluation & prioritisation of control measures based on air quality improvements, exposure reductions, technical feasibility and socioeconomic acceptability (3.4) Performance indicator definition and progress monitoring design (3.5) Demonstration of target realisation given air pollution reduction strategy implementation (4) Capacity building and training programmes design (5) Gap analysis and outline of research initiatives (6) Information dissemination programme design (7) Development of public consultation and AQMP approval processes (8) AQMP documentation Taking into account local, national and international considerations the proposed content and structure of an AQMP for the CTMM is outlined in Exhibit 1. This content was used as the starting point for the development of the CTMM AQMP. EXHIBIT 1 Proposed Contents and Structure of an AQMP for the City of Tshwane Metropolitan Municipality (1) Executive Summary (2) Introduction - Purpose - Legislative and regulatory context (3) City of Tshwane Metropolitan Municipality Planning Area - Geographical area - Air quality setting ~ priority pollutants, contributing sources, key impacted areas ~ future projections (4) Air Quality Management Policy Framework - CTMM Vision and mission statement - CTMM Strategic goals and objectives - key considerations in the development of an AQMP (5) Local Air Quality Objectives - Ambient air quality guidelines and targets - Schedule for meeting targets (5) Air Quality Management System - Ambient air quality monitoring programme - Emissions inventory - Air pollution dispersion modelling - Reporting protocol - Public consultation procedures (6) Air Pollution Reduction Strategy Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-14 - Control strategy development programme - Case studies of successful reduction initiatives (if required by national regulations) - Prioritised control measures and mitigation schedule ~ Short-term controls ~ Medium-term controls ~ Long-term strategies - Demonstration of target achievement - Performance monitoring and progress reporting (7) Research Initiatives - Source quantification and contribution determination initiatives - Air quality impact assessment studies - Air pollution reduction opportunities under investigation - Schedule for research outcomes (8) Capacity Building and Training Programmes - Training of AQM Section personnel - Stakeholder capacity building initiatives (9) Information Dissemination and Public Consultation Processes (10) Air Quality Management Plan Approval and Review Processes (11) References Appendices 5.4 CTMM AQMP Development Process The Air Quality Management Plan for CTMM is intended to be used as the management and performance-monitoring tool for air quality control and to provide a baseline assessment of air quality issues within the area. It was understood that the main aims of the comprehensive Air Quality Management Plan drafted for the City of Tshwane Metropolitan Municipal area were: • An Air quality Management Plan (AQMP), as described above (including targets and projections; a financial plan – short, medium and long term – linked to the Integrated Development Plan of CTMM; best abatement measures – plan, project and programmes) for CTMM. • A source inventory is a comprehensive, accurate and current account of air pollutant emissions and associated data from specific sources over a specific time period. In the establishment of data based fields for the CTMM source inventory the greenhouse gas emissions inventory and reporting requirements of the metropolitan was taken into account. • An Air Quality Management Information System with all air quality data compatible with acceptable modelling requirements and management information system requirements. • The development and implementation of the AQMP described above has critical implications in terms of human resources, training and cost requirements. These implications will be thoroughly explored as part of the current project and the system Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-15 tailored to ensure the practical feasibility of the AQM system to be proposed for implementation as part of the CTMM AQMP. • Participatory workshops on the draft and final reports. To achieve the objectives as outline above, the following process was followed in terms of preparation for the drafting of the plan, plan compilation and consultation with technical peers and air quality stakeholders: (11) Completion of an air quality baseline assessment comprising: • identification of sources, pollutants and areas of concern • inventory of current management and operational structures within the Metro • inventory of current procedures and methods adopted by the Metro, GDACE and national authorities to combat air pollution within the region • determine national and provincial requirements pertaining to AQM planning within the City of Tshwane • review best international practices pertaining to AQMP development and implementation (12) Propose pertinent actions to be taken by relevant Departments within the CTMM in the short- and medium-terms with regard to: • operational and functional structure optimisation • air quality management system development • source quantification and assessment • emission reduction measure implementation • emission reduction measure investigation (13) Conduct meetings with Technical Working Groups to discuss proposed measures. The names and affiliations of the persons participating in the activities of the technical work group are given in Appendix A. (14) Consolidation of proposed measures within discussion documents. Two discussion documents were compiled, viz.: (i) proposed air quality management policy framework, and (ii) air quality management system design, and emission quantification and reduction programme. (15) Workshopping of measures included in the discussion documents with the Technical Working Group and Air Quality Stakeholder Group. Members of the Air Quality Stakeholder Group participating at the various workshops are listed in Appendix B. (16) Revision of the content of the discussion documents based on comments received at the workshops, where applicable. (17) Compilation of the Draft Air Quality Management Plan on the basis of the revised discussion documents. Presentation of the contents of the draft plan to Technical Working Group and workshopping of the draft plan. (18) Workshopping of the contents of the plan with the public (1 December 2005), collation of comments and addressing of issues prior to plan finalisation. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-16 (19) Integration of comments received and compilation of a Draft-Final Air Quality Management Plan. Submission of the draft-final plan to CTMM, the Technical Working Group and Air Quality Stakeholder Group and placing of the document in public places(8). (20) Submission of the Final AQMP to CTMM (December 2005), with copies of the plan circulated to Technical Working Group and Air Quality Stakeholder group members and placed in public places for general access. 5.5 Report Outline The following section describes the CTMM planning area in terms of its geographical setting, priority sources, pollutants and impact areas. Reference is also made to factors affecting air quality within CTMM and to existing functional structures pertaining to air pollution control and air quality management. The policy framework for air quality management plan implementation is outline in Section 3 and local air quality objectives presented in Section 4. Section 5 comprises a description of the air quality management system to be implemented by CTMM. The emission quantification and reduction programme to be implemented is outlined in Section 6. Research requirements and capacity building needs are covered in subsequent sections, with the AQMP implementation and revision process being addressed in Section 8. 8 Copies of the Draft-Final Air Quality Management Plan were placed in all municipal libraries within the City of Tshwane after 1 December 2005. Advertisements were placed in the press to notify people of the availability of these documents and to invite their comments. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 5-17 6 6.1 CITY OF TSHWANE METROPOLITAN MUNICIPALITY REGION Geographical Setting The City of Tshwane, located north of Johannesburg, extends from Centurion in the South to Temba in the North (Figure 1-3). The CTMM is the administrative capital of South Africa, housing a large diplomatic community. The municipal boundaries are mainly within the Gauteng Province with a small area in the north falling within the North West Province. The total area covered by the metropolitan municipality is approximately 2,200 km². Figure 6-1: Tshwane Metropolitan Municipality boundaries. According to the 2001 Census data, a total population of 1,985,983 resides within the CTMM of which 73% are Black Africans and 24% are white with the remaining 1.5% and 1.9% being Asian and Coloured, respectively. Most of the people live in the Pretoria, Centurion, Temba, Soshanguve and Mabopane districts with the highest population density within the latter two Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-18 areas. These are more informal rural settlements located on the northern outskirts of the metro (see Figure 2-2). Figure 6-2: Population density within the CTMM as taken from the 2001 Census data. The topography of the CTMM consists of hills, ridges and undulating plains. There are no mountains apart from the more modest western end of the Magaliesberg, which starts in the northern suburbs of Pretoria and stretches westwards toward Rustenburg in the Northwest Province. The same mountain range forms a shallow valley within the central part of Pretoria and the Crocodile River regions, called the Magalies Moot area. Elevations range from approximately 1050 metres above mean sea level (mamsl) in the northern plains to ~1665 mamsl on the Magaliesberg in the east-central parts of CTMM. The Pretoria and Centurion wards are mainly at an elevation of between 1,200 to 1,500 mamsl. The current land uses in the region include industrial and commercial processes, surface mining activities, agricultural activities (mainly on the outskirts of the municipality boundaries), and formal and small residential communities. The industrial, commercial and formal residential areas are confined predominantly to the Pretoria, Centurion, and Akasia regions with the remaining regions more focused on mining and agricultural activities. Macro-ventilation characteristics of a region are determined by the nature of the synoptic systems that dominate the circulations of the region, and the nature and frequency of occurrence of alternative systems and weather perturbations over the region. The dispersion potential of the metropolitan region are predominantly influenced by meso-scale processes including thermo-topographically induced circulations, the development and dissipation of surface inversions, and the modification of the low-level wind field and stability Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-19 regime by urban areas. During winter months the region is dominated by the continental high pressure system which is characterized by large-scale subsidence, clear skies, light winds and strong temperature inversions. Northerly to north-westerly winds prevail during much of the year due to the prevalence of the high pressure system. Although such winds continue to dominate during winter months, the northward shift of the high pressure belt and resultant influence of westerly wave disturbances on the region gives rise to an increase in the frequency of winds from the south to south-westerly sector. An increase in the frequency of northerly to easterly winds during spring and summer months is the result of the southward migration of the high pressure belt, with airflow being influenced both by anticyclonic subsidence and easterly wave systems. Multiple elevated inversions occur in the middle to upper troposphere as a result of largescale anticyclonic subsidence. Three distinct elevated inversions, situated at altitudes of approximately 700 hPa (~3 km), 500 hPa (~5 km) and 300 hPa (~7 km), were identified over southern Africa. The height and persistence of such elevated inversions vary with latitudinal and longitudinal position. During winter months the first elevated inversion is located at an altitude of around 3 km over the plateau. In summer this inversion is known to increase in to 4 to 5 km over the plateau (Diab, 1975; Cosijn, 1996). Given the elevation of CTMM it is evident that the dispersion of air pollutants is frequently confined within the 1,300 to 1,500 m of atmosphere above the ground. Due to the occurrence of nocturnal, surface-based temperature inversions the mixing layer may range diurnally from a depth of 0 m during the night-time to the base of the lowest-level elevated inversion during unstable, day-time conditions (i.e. 1,300 to 1,500 m). 6.2 Background Information 6.2.1 Industrial Activities and Power Generation The CTMM is not a highly industrialized area such as EMM or the Vaal Triangle. There are however a few large industrial activities such as power generation, iron and steel making, and cement manufacturing within the metropolitan. The large number of ceramic processes located within this conurbation is also notable (including PPC, Wesbrix, Sabrix, Pretoria Brickworks, Corobrik, Cullinan Refractories, Era Stene, Excelsior Brickworks). Such processes include brick manufacturers, refractory operations and cement producers. Refractory operations primarily use tunnel kilns with clamp kilns being used in the manufacture of clay bricks. Cement manufacturers use rotary kilns. Further sources of emissions within this sector include combustion sources such as small boilers and incinerator operations, used by schools, hospitals and within agricultural industries. Industrial activities within the CTMM are widely spread with the larger industrial areas mainly confined to the north, the west, the east and to a smaller extend the south (see Figure 2-3). The main areas of industrial activity can be grouped as follow: Pretoria North Pretoria West - Akasia including Rosslyn and Klerksoord Wonderboom (Rooiwal Power Station). Kirkney, Capital Park, disport, Hermanstad, Wespark, Pretoria Industrial. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-20 Pretoria East Pretoria South - Waltloo Lyttleton, Rooihuiskraal Extention. Figure 6-3: Location of the two power stations and industries within the CTTM Power generation sources include emissions from industrial boilers in addition to emissions from the two power stations within the City of Tshwane, viz. Pretoria West Power Station and Rooiwal Power Station. Power generation sources contribute significantly to SO2 (92%), NOx (83%), CO (81%), CO2 (56%), and particulate (69%) emissions. Gas and coke processes comprise the second largest contribution to SO2 and CO2 and the largest to HC (81%) emissions, with iron and steel processes representing the second largest source of particulate emissions (11%) in the province. The contribution of ceramic processes, which include all brickfields emissions, contributes significantly to CO and particulate emissions in the municipality. “Other" sources of SO2 emissions include: Cement Processes, Gas, Coke and Charcoal Processes, Asbestos Processes, Fluorine Processes, Copper Processes, Galvanising Processes and Vanadium preparation Processes. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-21 Non-Scheduled Fuel Burning Appliances are appliances capable of burning fuel at a rate of <10 tons/hour. Various fuel burning appliances, including boilers at schools and hospitals, pizza ovens, stand-by generators, air heaters, (etc.) due to their more restricted fuel combustion rates are not required to have a permit to operate. No source and emissions data for any of these sources are currently being comprehensively collected and stored by the national, provincial or local authorities. 6.2.2 Household Energy Use According to the 2001 Census data there are 562,655 households within the CTMM with 620,900 households estimated for the year 2004 by Africon. Of these households approximately 80% make use of electricity for lighting purposes, 72% for cooking and 76% for heating purposes. Even so, a significant number of households still use fuels such as coal, wood, paraffin and LPG for cooking, space heating and lighting. Coal burning was estimated to be responsible for over 90% of the total particulate, sulphur dioxide, carbon monoxide and carbon dioxide emissions associated with household fuel burning. Coal burning was also responsible for ~70% to 80% of the PM10, VOC, NOx and methane emissions. Despite the relatively small number of households burning wood, wood burning was estimated to contribute significantly to PM10, NOx, methane, benzene and VOC emissions due to the quantity of wood required to meet household energy requirements and the extent of emissions from fuel burning. In addition, coal and wood burning also emits large amounts of polycyclic aromatic hydrocarbons (PAHs) such as benzo(a)pyrene, and various toxins. For most of the informal settlements within Gauteng, the use of coal and wood for domestic fuel burning is part of everyday life. In Tshwane, domestic fuel burning only ranked third on the list of main SO2 contributors and fourth for inhalable particulates. Even so, this source is regarded as one of the most significant sources of emissions to be controlled within the CTMM due to the low-level emissions in high population density areas, hence areas with high human exposure potentials. In addition, these emissions reflect clear seasonal (winter months) and diurnal (morning and evening) trends. Other pollutants associated with this source are CO, CO2, methane and benzene. According to the NEDLAC ‘Dirty Fuels’ project findings, domestic fuel burning was estimated to result in the greatest non-carcinogenic health risk across all conurbations9. In the CTMM, this source accounted for ~24% of all respiratory hospital admissions (RHA) predicted (Scorgie et al., 2004). These fuels continue to be used for primarily two reasons: (i) rapid urbanisation and the growth of informal settlements has exacerbated backlogs in the distribution of basic services such as electricity and waste removal, and (ii) various electrified households continue to use coal due particularly to its cost effectiveness for space heating purposes and its multifunctional nature (supports cooking, heating and lighting functions). Coal is relatively inexpensive and is easily accessible in CTMM due to the proximity of the region to coal mines and the well-developed local coal merchant industry. 9 The conurbations in the Fridge study included: the CTMM, the City of Joburg, EMM, the Vaal Triangle, the City of Cape Town, Ethekwini and the Mpumalanga highveld. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-22 6.2.3 Biomass Burning Crop-residue burning and general wild fires (veld fires) represent significant sources of combustion-related emissions associated with agricultural areas. Emissions were estimated for areas within CTMM based on information provided by the Fire Department and the burn scars from satellite imagery. Biomass burning is an incomplete combustion process with carbon monoxide, methane and nitrogen dioxide being emitted during the process. About 40% of the nitrogen in biomass is emitted as nitrogen, 10% remains in the ashes and it is assumed that 20% of the nitrogen is emitted as higher molecular weight nitrogen compounds. The visibility of smoke plumes from vegetation fires is due to their aerosol content. 6.2.4 Mining Operations Mining operations within the CTMM almost exclusively include clay, fire clay and sand mining, and gravel and aggregate mining. All these operations are done by means of opencast or surface mining techniques which are notorious for the generation of dust. A total of 27 mines are operational within the municipality and located mainly in the east, west and south of the municipal boundaries. There are many non-listed sand mining and other mining related operations in the CTMM not reflected in the table. This will be included in the management planning to update the emissions inventory for CTMM. Fugitive emissions from quarrying and mining operations mainly comprise of land clearing operations (i.e. scraping, dozing, and excavating), materials handling operations (i.e. tipping, off-loading and loading, conveyor transfer points), vehicle entrainment from haul roads, wind erosion from open areas and drilling and blasting. These activities mainly result in fugitive dust releases with small amounts of NOx, CO, SO2, methane, CO2 being released during blasting operations. 6.2.5 Transport Related Emissions Emissions as a result of transportations are a concern within the CTMM due to the vast distances travelled by commuters between work locations and residential areas. Sources of transport related emissions can be grouped into the following main categories: • • • Vehicles (roads); Railroad; and, Airport. The main vehicle emissions are from the M1 and N1 highways linking Pretoria with Johannesburg. This is mainly due to people living in the CTMM and working in Midrand and Johannesburg. The opposite also applies but to a lesser extend. On average, the highest vehicle density is therefore restricted to the central, southern and eastern parts of CTMM. 6.2.5.1 Vehicle Emissions Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-23 Air pollution from vehicle emissions may be grouped into primary and secondary pollutants. Primary pollutants are those emitted directly into the atmosphere, and secondary, those pollutants formed in the atmosphere as a result of chemical reactions, such as hydrolysis, oxidation, or photochemical reactions. The significant primary pollutants emitted by motor vehicle exhausts include CO2, CO, HCs, SO2, NOx, particulates and lead. Secondary pollutants formed due to vehicle exhaust emissions include: NO2, photochemical oxidants (e.g. ozone), HCs, sulphuric acid, sulphates, nitric acid, sulphates, nitric acid and nitrate aerosols. Emission estimates were conducted as part of the baseline assessment for the CTMM AQMP development process. These emission rates were based on fuel sales provided for the year 2004 and distinguished between petrol (leaded and unleaded) and diesel fuels. Africon in the development of the State of Energy Report also estimated vehicle emissions. These were based on traffic count information as predicted by the CTMM’s EMME/2 regional transportation model and converted to the VISUM model. Emission estimations were presented spatially as represented in Figure 2-4 for NOx. Figure 6-4: Oxides of nitrogen emissions as predicted by the VISUM model (from CTMM State of Energy Report, 2005) Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-24 6.2.5.2 Airports The CTMM comprises of three airports, viz. Wonderboom Airport in the north of Pretoria, Swarkops Airport in Centurion and Waterkloof Airport in the southeast. All three these airports are small and utilised by light commercial aircrafts, with Swartkops and Waterkloof Airports exclusively used for military aircrafts. The main sources of emission associated with airport operations include: (i) vehicle tailpipe emissions from airport arrival-departure activities, airport ground-support services and airport access traffic routes, (ii) aircraft engine emissions during aircraft idling, taxing, takeoff and landing, (iii) auxiliary power units, and (iv) evaporative emissions during fuel handling and storage. Pollutants released include oxides of nitrogen, carbon monoxide, carbon dioxide, hydrocarbons, sulphur dioxide, lead, particulates, methane and various volatile organic compounds. Based on the low air traffic of the airports within the CTMM in comparison to Johannesburg International, it was deemed unlikely that any of the pollutants deriving from these thee airports would flag and hence as not quantified. 6.2.5.3 Railway Trains in operation typically include electric, steam and diesel-powered locomotives with the latter being prominent in the transportation of bulk materials to and from industrial sites. Pollutants released from railway transport include carbon dioxide, carbon monoxide, volatile organic compounds, Due to a lack of detailed information emissions resulting from railway activities within the CTMM were nor quantified. 6.2.6 Waste Treatment and Disposal Waste treatment and disposal methods in the CTMM of interest in terms of their atmospheric emission potential include: incineration, landfilling, and liquid waste ponds used for the treatment, storage and disposal of liquid wastes. 6.2.6.1 Landfill Operations The majority of the waste collected by the local authority is disposed to landfill, usually within 10-20 km radius of the residential areas within which the waste was generated. At present, CTMM has 9 regional disposal facilities under its jurisdiction as depicted in Table 2-1 and one privately owned waste disposal site. All the waste disposal sites within the CTMM are predominantly used for general waste disposal, including domestic, residential and commercial, business and industrial waste. It is unknown to what extend co-disposal of domestic and industrial/commercial hazardous waste occurs at the general waste sites. Limited information is available on the practical volumes and quantities of hazardous waste disposed of to landfill sites in Tshwane, or on the volumes and masses of hazardous waste stored on-site by industrial, power generation and mining operations. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-25 Landfill gases of concern associated with the general or co-disposal landfill options include a range of odiferous and toxic gases. Landfill gas usually contains between 40% and 60% methane and similar percentages of carbon dioxide. Other gases constitute only a small fraction of the total gas, and include both inorganic products and a large number of organic compounds. Studies indicate that over 200 compounds can be encountered in a landfill site. Odorous substances most frequently considered in local air quality impact assessment studies for such operations include hydrogen sulphide, butyric acid and limonene. High concentrations of amine constituents have also been observed to be responsible for odour impacts of various local landfills. Carcinogenic substances frequently measured at waste disposal sites include methylene chloride and benzene. Air quality impact assessment conducted for large hazardous and general landfill sites in South Africa (including the Chloorkop, Holfontein and the closed Margolis waste sites) have generally indicated that: • significant health risks, given good landfill facility management, are restricted to within 500 m of the landfill boundary; • odour impact distances can vary from 200 m to 5 km depending on facility management; and • nuisance dust impacts are generally restricted to within the immediate boundary of the facility. Given the range of pollutants emitted from landfill operations (and the difficulties in controlling emissions at sites with histories of poor management) it is recommended that landfill sites be classified as possible "toxic hotspots" for air quality management purposes. Landfill operations are also significant sources of greenhouse gas emissions. 6.2.6.2 Incinerator Operations Incineration became a Scheduled Process in October 1994. Permit requirements for such operations include operating temperature, combustion retention time and emission standard stipulations. Since March 1998, Environmental Impact Assessments have been required for proposed incinerator operations. Heavy metal, dioxin and furan emissions from waste incineration represent a considerable air quality and health risk concern related to such operations. Particulate emissions from incinerators may also comprise heavy metals such as chromium and cadmium, which are suspected human carcinogens. Incinerators have however to date represented the only viable alternative for the dispose of all medical wastes. (New methods currently under development include plasma converter technologies.) Data on the volumes of health case wastes are limited. Based on the number of hospital beds, and the average waste generation rate of 1.95 kg/beg/day Tshwane could be expected to produce a significant volume of medical waste requiring incineration and safe disposal. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-26 6.2.6.3 Waste Water Treatment Works Information still needs to be obtained on the number of waste water treatment facilities within the CTMM. The potential for emissions of volatile organic compounds (VOCs) during wastewater treatment is a cause for concern. Species measured at local waste water treatment works have included: hydrogen sulphide, mercaptans, ammonia, formaldehyde, acetone, toluene, ethyl benzene, xylenes, perchloroethylene, butyric acid, propionic acid, valeric acid and acetic acid. Species which represent the most important odorants included: hydrogen sulphide, mercaptans, ammonia, and the various fatty acids (butyric, propionic, valeric and acetic). Odour sensation may lead to a number of secondary effects such as nausea, vomiting, loss of appetite, sleeplessness, and triggering of hypersensitivity reactions. There is no conclusive evidence that human health is seriously affected by odour. Odour impacts may however be a serious source of annoyance to the local community, and have been shown in various cases to affect property values and development. 6.3 Priority Sources, Pollutants and Areas 6.3.1 Priority Pollutants A few air pollutants are commonly found as a result from various sources and activities. These pollutants can injure health, harm the environment, and damage property. These pollutants are called criteria pollutants since health-based criteria (science-based guidelines) have been established as the basis for setting permissible levels. One set of limits (primary standard) protects health; another set (secondary standard) is intended to prevent environmental and property damage. Typical pollutants to be addressed include: particulates (including soot, fly ash and aerosols), sulphur oxides (SOx), oxides of nitrogen (NOx), carbon monoxide (CO), carbon dioxide (CO2), volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), methane (CH4), ammonia (NH3), hydrogen chloride (HCl), hydrogen sulphide (H2S), ozone (O3) and other photochemical oxidants (as secondary pollutants) and various trace elements. Organic compounds released include formaldehyde, benzene, polyaromatic hydrocarbons, PCBs and dioxins and furans. Limited ambient monitoring data exists for the City of Tshwane. Currently two monitoring stations are operated by the CTMM, the GDACE donated Rosslyn station and the CTMM Topas station in Pretoria West. The Rosslyn monitoring station measures PM10, SO2, NO2, NO, NOx, CO and ozone whereas the Topas only measures PM10. Problems are currently experienced in obtaining the data from the Topas monitor and only 8 non-consecutive months of data was available for the Rosslyn station. Even so, SO2 and NO2 were noted to exceed hourly and daily standards. This also clearly indicated the two main sources contributing to air pollutants within the Rosslyn area, namely vehicles and industrial activities. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-27 Historically, SO2 and smoke (particulates) were monitored at nine locations within the CTMM. Of these, three were located in Centurion and six were located in and around Pretoria. The monitoring methodology however, is not specific and can only be used to investigate trends in these two pollutants. Long-term trends indicated increased average ground level SO2 concentrations of 2.2 times between the periods 1996/97 and 2001/02. Similarly increases in smoke levels (1.1 times) were noted for the same period. Lead monitoring has been conducted since 1987 to 1998 as part of the DEAT Lead Monitoring Project. These historical trends indicated a decrease in lead concentrations during the previous decade (1990’s) from 1.5 µg/m³ to below 0.4 µg/m³. Unfortunately, no lead measurements were made in Pretoria since 1998 due to “personnel problems” and “sampler problems”. A three-week monitoring campaign was conducted as part of a study for Sasol Oil to establish typical air concentrations of pollutants emanating from vehicle emissions at residential area, near major highways, filling stations, toll plazas and road tunnels. The pollutants of concern were particulate matter, sulphur dioxide, oxides of nitrogen, carbon monoxide, lead vapours, and non-methane hydrocarbons. The highest levels of pollutants were observed at Marabastad in Pretoria with PM10 exceedances of the existing South African daily average standard. Metals such as iron were noted and significant lead levels were recorded. Nitrogen dioxide was also clearly shown to be a function of vehicle volumes. From the limited monitored data available, the priority pollutants that should be considered within the short-term (first 2 years) are particulates (PM10), sulphur dioxide (SO2), and nitrogen dioxide (NO2). Greenhouse gas pollutants (CO2, CH4, ozone, etc.) are addressed in more detail in the CTMM Energy Strategy. In the medium (3-5 years) to long-term attention should be paid to other pollutants such as Benzene and PM2.5. 6.3.2 Priority Sources The characterisation of baseline air quality and the identification of priority sources, pollutants and areas represent the basis of effective air quality management and planning. The collation, analysis and presentation of relevant and recent existing information on sources and emissions was undertaken during the baseline assessment (Liebenberg-Enslin & Petzer, 2005). Sources of emission identified as occurring within the CTMM are summarised in Table 2-1. The significance of transboundary sources through their contribution to the regional aerosol component is noted in the table despite such sources not being located within the region. Pollutants released by each source are indicated. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-28 Table 6-1: Sources of atmospheric emissions within the CTMM and their associated emissions Sources PM SO2 NOx CO CO2 CH4 HAPs Vehicle-tailpipe emissions Industrial operations, energy generation and commercial fuel burning appliances Domestic fuel burning Biomass burning Vehicle-entrainment of road dust Aviation emissions Mining activities Landfills Incineration Agricultural activities Tyre burning Wind-blown dust from open areas x x x x x x x x x x x x x x x x x x X x x X X X x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x Regional aerosol x (from distant sources) HAP - hazardous air pollutants (includes toxins and carcinogens) x - indicates pollutant is emitted by particular source type Contributions from every source category are depicted in Figures 2-5 to 2-9 for all main atmospheric pollutants. Figure 6-5: Contributions form the various sectors within the CTMM to total inhalable particulate (PM10) emissions. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-29 Figure 6-6: Contributions form the various sectors within the CTMM to total sulphur dioxide (SO2) emissions. Figure 6-7: Contributions form the various sectors within the CTMM to total oxides of nitrogen (NOx) emissions. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-30 Figure 6-8: Contributions form the various sectors within the CTMM to total benzene emissions. Figure 6-9: Contributions form the various sectors within the CTMM to total organic compounds (TOC) emissions. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-31 Figure 6-10: Contributions form the various sectors within the CTMM to total carbon monoxide (CO) emissions. Figure 6-11: Contributions form the various sectors within the CTMM to carbon dioxide (CO2) emissions (greenhouse gasses). Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-32 Figure 6-12: Contributions form the various sectors within the CTMM to total methane (CH4) emissions (greenhouse gasses). 6.3.2.1 Industrial Sources Stack, vent and fugitive emissions from industrial operations - industrial emissions include various criteria pollutants (as SO2, NOx, CO and particulates), greenhouse gases (CO2 and CH4), volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), various heavy metals and other toxins such as dioxins and furans. Industries in the region include the following: • • • • 6.3.2.2 Ceramic processes (Wesbrix, Sabrix, Pretoria Brickworks, Corobrik, Cullinan Refractories, Era Stene, Excelsior Brickworks); Cement Manufacturing (PPC); Iron and Steel Industry (Mittal Steel Pretoria); Smaller combustion processed (incinerator, steam generation, gas-fired boilers etc.) Power Generation The two municipal power stations in Tshwane include Pretoria West and Rooiwal Power Stations. Due to the elevated height at which these power stations emit, the impacts from these sources are expected to be further a field. The main emissions from such electricity generation are carbon dioxide, sulphur dioxide, nitrogen oxides and ash (particulates). Fly ash particles emitted comprise various trace elements such as arsenic, chromium, cadmium, Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-33 lead, manganese, nickel, vanadium and zinc. Small quantities of volatile organic compounds are also released from such operations. 6.3.2.3 Mining operations Various mining operations are in place in the CTMM. These mainly include sand, clay and dolomite and dolerite mining with a few mining quartzite and granite. These mines are spatially distributed all over the CTMM, mainly on the outskirts of the municipal boundary. Fugitive emissions from quarrying and mining operations mainly comprise of land clearing operations (i.e. scraping, dozing, and excavating), materials handling operations (i.e. tipping, off-loading and loading, conveyor transfer points), vehicle entrainment from haul roads, wind erosion from open areas and drilling and blasting. These activities mainly result in fugitive dust releases with small amounts of NOx, CO, SO2, methane, CO2 being released during blasting operations. 6.3.2.4 Transport related emissions Emissions as a result of transportations are a concern within the CTMM due to the vast distances travelled by commuters between work locations and residential areas. Sources of transport related emissions can be grouped into the following main categories: • • • Vehicles (roads); Railroad; and, Airport. Air pollution from vehicle emissions may be grouped into primary and secondary pollutants. Primary pollutants are those emitted directly into the atmosphere, and secondary, those pollutants formed in the atmosphere as a result of chemical reactions, such as hydrolysis, oxidation, or photochemical reactions. The significant primary pollutants emitted by motor vehicles include carbon dioxide (CO2), carbon monoxide (CO), hydrocarbons (HCs), sulphur dioxide (SO2), oxides of nitrogen (NOx), particulates and lead. Secondary pollutants include: nitrogen dioxide (NO2), photochemical oxidants (e.g. ozone), HCs, sulphur acid, sulphates, nitric acid, nitric acid and nitrate aerosols. Toxic hydrocarbons emitted include benzene, 1.2butadiene, aldehydes and polycyclic aromatic hydrocarbons (PAH). Benzene represents an aromatic HC present in petrol, with 85% to 90% of benzene emissions emanating from the exhaust and the remainder from evaporative losses. Atmospheric emissions associated with airport activities, and the pollutants released by each source, are depended on the mode of operation of the aircraft. Other than water vapour and carbon dioxide, NOx represents the largest emission related to aircraft engine emissions and CO the second largest. Smaller amounts of VOCs, SO2, non-methane volatile organic compounds (NMVOCs), methane, lead and particulates are also emitted. The extent of the SO2 emissions is dependent on the sulphur content. CO and HC emissions, which result from incomplete or poor combustion, are generally greater during taxi and idle operations. Whereas the production of NOx, which is associated with the oxidation of atmospheric nitrogen during combustion processes, is greatest during take-off when the aircraft engine is Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-34 producing maximum power. Carbon dioxide emissions are directly related to the amount of fuel combusted. Trains in operation typically include electric, steam and diesel-powered locomotives with the latter being prominent in the transportation of bulk materials to and from industrial sites. The main pollutants of concern associated with train activities include CO2, CO, VOC, NOx, particulates, SO2, lead, N2O, methane and non-methane VOCs. 6.3.2.5 Household fuel combustion It is likely that certain households within local communities/settlements use coal or wood for space heating and/or cooking purposes. Pollutants arising due to the combustion of wood include respirable particulates, carbon monoxide and sulphur dioxide with trace amounts of polycyclic aromatic hydrocarbons (PAHs), in particular benzo(a)pyrene and formaldehyde. Coal burning emits a large amount of gaseous and particulate pollutants including SO2, heavy metals, total and respirable particulates including heavy metals and inorganic ash, CO, polycyclic aromatic hydrocarbons (PAHs) such as benzo(a)pyrene, NO2 and various toxins. Pollutants from wood burning include respirable particulates, NO2, CO, PAHs (benzo(a)pyrene and formaldehyde). Particulate emissions from wood burning have been found to contain about 50% elemental carbon and about 50% condensed hydrocarbons. Areas that would fall within this category include Mamelodi, Soshanguve, Mabopane, GaRankuwa. Eskom is currently busy with an electrification project specifically in Ga-Rankuwa. 6.3.2.6 Biomass burning Crop-residue burning and general wild fires (veld fires) represent significant sources of combustion-related emissions associated with agricultural areas. Biomass burning is an incomplete combustion process with carbon monoxide, methane and nitrogen dioxide being emitted during the process. About 40% of the nitrogen in biomass is emitted as nitrogen, 10% remains in the ashes and it is assumed that 20% of the nitrogen is emitted as higher molecular weight nitrogen compounds. The visibility of smoke plumes from vegetation fires is due to their aerosol content. 6.3.2.7 Fugitive Dust Sources Fugitive dust emissions may occur as a result of vehicle entrained dust from local paved and unpaved roads, wind erosion from open areas and dust generated by agricultural activities (e.g. tilling) and mining. The extent of particulate emissions from the main roads will depend on the number of vehicles using the roads and on the silt loading on the roadways. The extent, nature and duration of agricultural activities and the moisture and silt content of soils is required to be known in order to quantify fugitive emissions from this source. The quantity of wind blown dust is similarly a function of the wind speed, the extent of exposed areas and the moisture and silt content of such areas. These fugitive dust sources are more likely to be a problem in the less urbanized areas of the CTMM. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-35 6.3.3 Priority Areas The main areas of concern within the CTMM are those located near industrial areas such as Pretoria West and the Moot. The Moot area is furthermore affected by the location of numerous brickworks within the area resulting in low-level emissions resulting in poor dispersion due to the topography of the area. Secondly, areas in close proximity to highways and busy intersections will be affected by vehicle emissions. This mainly includes the central business district and residential areas transacted by highways, on-ramps and main feeder roads. Informal settlements likely to used coal and wood as energy source will be affected due to the low level releases of emissions and especially during the winter months when more fuel is consumed. These areas include Mamelodi, Soshanguve, Mabopane, Ga-Rankuwa. The establishment of the contributions of various source types to total emission represents a means of ranking sources by their emissions. In order to assess the significance of sources with regard to their potential impact it is necessary to account for various additional factors, including: atmospheric dispersion potentials, source configurations (particularly height of emission), proximity of potentially sensitive receptors, and the carrying capacity of the receiving environment. It is for this reason that the analysis of trends in ambient air quality is imperative. Temporal and spatial variations in ambient air pollution concentrations can be determined through primarily two approaches: (i) through implementing ambient air pollution monitoring at representative sites to directly measure pollution concentrations; and, (ii) through the development of a comprehensive emissions inventory and the application of an atmospheric dispersion model, using relevant source, emissions and meteorological data as input, to simulate ambient air pollutant concentrations. The implementation of a combination of monitoring and modelling will produce the best results. Monitoring data generally provides accurate "snapshots" of air pollution concentrations at specific points with dispersion models, which are by their nature associated with a greater level of uncertainty, serving to "paint the whole picture". The first step in designing an ambient air quality monitoring network is to identify the main pollutant of concern and the priority areas potentially impacted by these pollutants. Table 22 provides a synopsis of the main pollutant, sources of pollutants and potential impacting areas within the CTM. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-36 Table 6-2: Summary of Priority Pollutants, Sources and Areas Pollutants PM10, PM2.5 NO2 (Nitrogen dioxide) Ozone SO2 (Sulphur Dioxide) VOCs (Volatile Organic Compounds) CO (Carbon monoxide) Air Toxics Main Contributing Sources - Power generation (Rooiwal and Pretoria West power stations) - Industrial (e.g. Ceramic, Cement and Iron& Steel) - Household fuel combustion - Other (vehicle entrainment of road dust, wild fires, tyre burning – significant in terms of episodes) - Transport (diesel vehicle emissions) - Transport (petrol vehicles, diesel vehicles) - Power stations (Rooiwal and Pretoria West power stations) - Industrial processes (e.g. Ceramic, Cement and Iron& Steel) - Household fuel combustion - Wild fires, tyre burning, etc. as minor sources - Secondary pollutant associated with NOx and other precursors releases - Transport (petrol vehicles as key contributor, also diesel vehicles) - Household fuel combustion - Industrial processes - Wild fires - Power stations (Rooiwal and Pretoria West power stations) - Industrial and non-domestic fuel burning sector (e.g. Cement and Iron & Steel) - Transport - Household fuel combustion - Wild fires, tyre burning - Transport (petrol vehicles as key contributor, also diesel vehicles) - Household fuel combustion - Industrial processes (e.g. Ceramics, Cement and Iron& Steel) - Wild fires - Transport - Household fuel combustion - Power stations (Rooiwal and Pretoria West power stations) - Industrial processes (e.g. Ceramics, Cement and Iron& Steel) - Wild fires, tyre burning Incinerators, specific industries (printers, dyers, spray painters, etc.) Key Impacted Areas Elevated concentrations over much of the CTMM resulting in widespread health risks, with significant health effects anticipated in residential fuel burning areas. Elevated concentrations expected in close proximity to busy roadways (i.e. N1, N4, N14) Pretoria West and Moot area due to Power Station and industries. Monitoring is required to confirm ozone levels. Elevated concentrations over much of the CTMM. Pretoria West and Moot area. Informal settlements during winter months. Main impact zones should be established after monitoring and modeling efforts. Notably elevated concentrations near busy roadways. Pretoria West and Moot area. In close vicinity to sources. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-37 6.4 Air Pollution Control and Air Quality Management Capabilities In assessing CTMM’s capacity to effectively develop and implement an air quality management planning approach it is necessary to understand the current resources and functions of the metro. Important resource considerations include: the availability of staff and the skills and experience held by staff members, and the availability of air quality management tools (e.g. emissions inventories, monitoring, atmospheric dispersion modelling, and environmental reporting). 6.4.1 6.4.1.1 Organisational Structure within the CTMM Existing Air Pollution Control and Air Quality Management Practices Two divisions are currently engaged in air pollution control and air quality management functions, viz. the Environmental Health Division and the Environmental Management Division. Primary responsibility for air quality management planning vests with the Chief Health Officer for Air Quality Management within the Environmental Health Division. He/she has been tasked with overseeing the air quality management plan development process and will be responsible for ensuring the adoption, implementation and review of this plan in future years. Currently the Chief Health Officer for Air Quality Management is responsible for the development and implementation of a holistic approach to air pollution and to encourage the attainment of clean air, to ensure a clean, healthy aesthetically pleasing and comfortable living, working and recreational environment for all people and to explore alternative sources, ways and possibilities to provide sustainable energy without any detrimental effect on the environment. Functions currently being undertaken pertaining specifically to air pollution control and air quality management are as follows: • Air pollution control strategy development (primarily Chief Health Officer for Air Quality Management) • Monitoring instrument procurement and inventory (primarily Chief Health Officer for Air Quality Management) • Ambient and meteorological air quality monitoring • Diesel vehicle exhaust testing • Collation, analysis and reporting of complaints (respective Chief Environmental Health Practitioners of the regions) • Issuing of notices and legal action (where required) • Collation of information on boiler operations The Chief Environmental Health Practitioners within the Environmental Health Section are responsible for all complaint investigation including air pollution complaints. A complaints database exists which records date of complaint, complaint type (e.g. air pollution), and complainant details. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-38 The Environmental Resource Management section is situated within the Environmental Management Division of the Housing, City Planning and Environmental Management Department. The main responsibilities concerning air pollution for this Division are the compiling of the State of the Environment Report (SOER) for CTMM and the development of the Tshwane Integrated Environment Policy (TIEP). 6.4.1.2 Air Pollution Control Strategy Development The Environmental Resource Management Section has identified the need for a strategy and implementation plan for integrated pollution control for the CTMM. They put together the Tshwane Integrated Environment Policy (TIEP) intended to, amongst others, manage air quality in order to improve it in areas with poor air quality and maintain it in areas with good air quality. One of the objectives of the TIEP is to implement an Air Quality Management Plan (AQMP). The Environmental Health Division has committed itself to integrating its knowledge and ideas into the air quality management plan development process. Key aspects of the strategy to develop an AQMP are as follows: • Recognition of the importance of quantifying emissions – including temporal trends in emissions – and of assessing the percentage contribution of sources to total emissions. • Emphasis on the importance of establishing the height of emissions and the likelihood of human exposure (through dispersion model analysis). • Current emission reduction measures, including: Domestic fuel burning: Mining activities Traffic & transportation: Industrial emissions & fuel burning appliances: Other sources: 6.4.1.3 Recognize DME’s Integrated Clean Household Energy Strategy Educate and create awareness on top down ignition method and smokeless mbawulas Working in collaboration with DME. Standardisation of vehicle emissions testing across regions Regular emission testing campaigns for metro buses and trucks Responsibility of each industry to: characterize its emissions & comply to emission limits monitor it activities and provide proof of compliance Gather information on non-domestic fuel burning appliances to facilitate emission quantification & modelling Ensure new fuel burning appliances & renovations to existing appliances require Metro notification Enforce combustion efficiencies Monitor illegal burning of tyres and other material (with fire departments) Control illegal dumping Ambient Air Quality and Meteorological Monitoring by the CTMM Monitoring activities range from on-going maintenance of permanent ambient air quality monitoring stations to air quality monitoring campaigns undertaken in response to complaints received. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-39 Limited ambient air quality monitoring data exists within the CTMM region. The Environmental Health Division of CTMM is responsible for ambient air quality monitoring and data analysis and reporting. Currently, two monitoring stations are in operation, namely the GDACE station at Rosslyn and the Topas Sampler in Pretoria West. The station at Rosslyn measures PM10 and various criteria gases (SO2, NO2, CO, O3) in addition to meteorological parameters. Currently the data is being downloaded by a consulting firm with the intention to have real-time data transfer via on-line technology to the Air Quality Management Section within the Environmental Health Division. The Topas Sampler in Pretoria West, with the operational responsibility in the hands of CTMM. The Environmental Health Practitioner (EHP) is responsible for the data retrieval at this monitoring station and to date no data has been successfully downloaded. Monitoring responsibilities include routine operational checks on the monitoring equipment, data retrieval from automatic instruments (e.g. Topas) and laboratory services. Historical data is available on the smoke and SO2 sampling campaign, which was continued by CTMM after DEAT ceased funding of the campaign in 1998. This monitoring network was operational until 2001. CTMM plans to expand this monitoring network over the next two financial years (2005/2006 and 2006/2007), hence in the short-term. During the first phase it is planned to include one additional permanent monitoring station and nine mobile stations and two additional permanent stations during the second phase (2006/2007)10. These stations will mainly monitor for criteria pollutants such as SO2, PM10, NO, NO2 and CO. Responsibility within CTMM will reside with the Environmental Health Division. 6.4.1.4 Diesel Vehicle Testing All 8 regions within CTMM are currently undertaking the testing of diesel vehicle emissions, in accordance with the Atmospheric Pollution Prevention Act of 1965, using a Hartridge meter. Generally testing is done at bus depots or busy roads (e.g. Zambesi Road). Although the relevant Chief Environmental Health Practitioner of each region is responsible for diesel vehicle monitoring, the metro police department provide their cooperation and assistance in the vehicle emission testing process. The target for both the North and South Division (consisting of 4 regions each) is to do vehicle emission testing for at least 2 days per region per year. Although a Diesel Vehicle Monitoring Policy exists for the testing of emissions from diesel vehicles, there are a number of procedures that are not included, viz.: • number of vehicles tested, and • how vehicles are selected for testing. Results from vehicle testing are currently held by the respective Deputy Managers of the North and South Division. 10 The tender is currently open for suppliers of monitoring equipment to fulfil the requirements of Phase 1. The tender closed on the 2nd of November 2005. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-40 6.4.1.5 Collation of Source Information Source and emissions information on boiler operations and industrial processes are kept by Occupational Health Officers. Lists of boiler operations only have details on the type of boiler (e.g. John Thompson) and the type of fuel used (e.g. coal). No information exists on quantity of fuel used or boiler specifications. No comprehensive, current source and emissions data for industrial sources or non-domestic fuel burning appliances is kept by CTMM. 6.4.2 6.4.2.1 Review of Current Air Quality Management Tools Emissions Inventory Data Base An emissions inventory database in which source and emissions data for all significant sources of atmospheric emission are stored represent a critical component of effective air quality management. No such database is currently maintained within the CTMM. However, a database is being developed with the aim to include all scheduled processes, diesel vehicle testing results, and ambient monitored data. 6.4.2.2 Air Quality Monitoring Network and Reporting Practices Ambient air quality and meteorological monitoring is currently being conducted by various departments and groups within the metro, including: CTMM, GDACE, and South African Weather Services (meteorological stations). Effective data transfer mechanisms have not been established between the various parties responsible for monitoring. The data from the GDACE station (Rosslyn) is transferred automatically to GDACE. Although the CTMM will be responsible for the future maintenance of the station it is not currently clear how the metro will receive access to the data. Data from the CTMM Topas station (Pretoria West), currently maintained by Health Care personnel, has not yet been received due to maintenance not being preformed regularly (e.g. filters were not changed on the PM10 monitor, and data received was not downloaded off the PC). Such data are currently only accessed by personnel within the Health Care unit. Meteorological data is currently obtained from three stations operated by the South African Weather Services within the CTMM located at Irene, Unisa and Pretoria (Eendracht School). This information needs to be obtained from the SA Weather Services. The Rosslyn station records meteorlogical parameters (i.e. wind speed, wind direction, and temperature) but the data availability was poor at the time of the baseline assessment. The coordination of air quality and meteorological monitoring activities within the CTMM is a fundamental requirement for successful air quality management. In instances where monitoring is being conducted (or to be conducted) by other parties effective mechanisms could be put in place to facilitate timely access to data and data sharing. In future, the plan is to implement a centralised electronic emissions and data base by acquiring a software package and data logger system that will be installed at the two existing air quality monitoring stations (Rosslyn and Pretoria West) and the newly proposed stations. The raw Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-41 data will be transferred to a single administrator (Chief Health Officer for Air Quality Management) where the data will be calculated automatically and then sent to selected LAN users in a report format. 6.4.2.3 Atmospheric Dispersion Modelling No skills or tools currently exist within the CTMM to support atmospheric dispersion modelling. Such modelling is important for the purpose of effective baseline air pollution characterisation and for assessing the air quality benefits of implementing proposed management and mitigation strategies. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 6-42 7 AIR QUALITY MANAGEMENT POLICY FRAMEWORK A clear air quality management policy is required to inform air quality management plan development, implementation, review and revision. The drafting of this policy was informed by: (i) the Constitution and Bill of Rights and national environmental policy, as documented in the General Environmental management Policy for South Africa, the National Environmental Management Act (NEMA) and the Integrated Pollution and Waste Management (IP&WM) White Paper, (ii) National Environmental Management: Air Quality Act (No 39) of 2004 published by the Department of Environmental Affairs and Tourism (which reflects the vision and principles expounded by the national environmental policies), and (iii) international trends in air quality management policies. The air quality management policy outline in subsequent subsections embodies a paradigm shift from end-of-pipe air pollution control to pollution prevention and minimization through proactive and integrated air quality management planning. The integration of air quality considerations into development, transportation, land use planning and housing policies and programmes and the involvement of the public in the air quality management process represent key components of the policy. The overarching principles of the Constitution, the General Environmental Policy for South Africa and the Integrated Pollution and Waste Management Policy underpin the proposed local air quality management policy. Principles that are of significance to air quality management include the following: Key Principles Implications for Air Quality Management Accountability Capacity-building Education Government is accountable for policy formulation, monitoring and enforcement. and All people must have the opportunity to develop the understanding, skills and capacity for effective participation in achieving sustainable development and sustainable use of air as a resource. Custodianship It is the constitutional duty of government to protect the environment, including air quality, for the benefit of current and future generations. Its responsibilities include the duty to act as custodians of the nation's resources, to protect the public interest in and ensure equitable access to such resources, and generally to ensure that all South Africans enjoy an environment of acceptable quality. Demand management The price of goods and services must include the environmental cost, including costs related to air quality impacts, of sustaining the rate of supply over time. Due process Due process must be applied in all air quality management activities. This includes adherence to the provisions in the Constitution dealing with just administrative action and public participation in environmental governance. Duty-of-care Any institution which generates air pollution is always accountable for the management of this pollution and will be penalised appropriately for any and every transgression committed. Equity ALL sources of air pollution need be identified and managed relative to their Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 7-1 Key Principles Implications for Air Quality Management contributions to ambient concentrations. Environmental justice Government must integrate environmental considerations, including air quality considerations, with social, political and economic justice and development in addressing the needs and right of all communities, sectors and individuals. Full cost accounting Decisions must be based on an assessment of the full social and environmental costs and benefits of policies, plans, programmes, projects and activities that impact on the environment. Air quality management plans, policies and programmes should similarly be assessed in this manner. Freedom of information Provides motivation for an air quality information system comprising the maintenance of air quality and emissions inventory databases and the generation of air quality status reports. Air quality reporting should seek to provide information which enables people to protect their health and well-being and protect the environment from the negative effects of air pollution, and participate effectively in air quality governance. Good governance The government is obliged to give effect to people's environmental rights - including the right to acceptable air quality, by: taking responsibility for developing and implementing air quality management policy, responding to public needs and encouraging public participation in air quality governance by providing for the mutual exchange of views and concerns between government and people, and monitoring and regulating actions that impact on air quality. Inclusivity Air quality management processes must consider the interests, needs and values of all interested and affected parties in decision-making to secure sustainable development. Integrated planning and environmental management Provides the incentive for the integration of air quality issues into transportation and land use planning processes. Polluter pays The full cost associated with pollution (including monitoring, management, clean-up and supervision) should be met by the organizations responsible for the source of the pollution. Pollution prevention Measures must continue to be taken to reduce emissions at sources (i.e. sourcebased controls) Precautionary principle Need to provide for instances where environmental tolerances are not known. This principle also provides the incentive for the setting of multiple levels of air quality standards which not only define suitable levels to ensure human health and welfare, and the protection of the natural and built environment, but also levels for the prevention of significant decline. Public participation Provides motivation for the effective integration of the public into the air quality management plan development and impact assessment processes. Subsidiarity (i.e. Decentralisation of responsibilities at the most local level consistent with effective performance.) Control of pollution shall be exercised at the lowest effective level of regulatory authority, with appropriate mechanisms to avoid inconsistency of control. Transboundary movement Potential transboundary effects on human health and the environment, including air quality, must be taken into account. Universal applicability of regulatory instruments All industrial, agricultural, domestic/household and governmental operations will be subject to the same air quality management regulatory system Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 7-2 The CTMM's vision, mission, overarching principles and general approach to air quality management should reflect the vision, principles and approach adopted in terms of national and provincial policy in addition to local goals. 7.1 Vision, Mission and Objectives 7.1.1 Vision An internationally acclaimed African capital of excellence that empowers the community to prosper in a safe and healthy environment. 7.1.2 Mission and Commitment To enhance the quality of life of all the people in the City of Tshwane through a development system of local government and the rendering of efficient, effective and affordable services. As a result of the CTMM’s activities improvements in air quality are envisaged despite countervailing trends in population, development, and transportation growth. In achieving such improvements, the CTMM is committed to: 1 Establishing a set of shared goals and strategies for air quality improvement. 2 Establishment and continued implementation of a comprehensive air quality monitoring and management system. 3 Involving and educating the public with the purpose of minimizing pollution and facilitating the effective participation of the public in air quality governance. 4 Integrating air quality considerations into housing, transportation and spatial planning developments. 5 Making greater use of innovative approaches to reducing pollution. 6 Conducting sound research and effectively use new information technologies. 7 Respond creatively and vigorously to new challenges and emerging issues. 8 Improve the working partnership of personnel responsible for air quality management at all levels of government. 9 Facilitate effective inter-departmental and inter-governmental cooperation for the purpose of accurate source quantification and identifying and implementing effective emission reduction measures. 7.1.3 Strategic Goals and Objectives With the purpose of supporting the development, implementation and maintenance of air quality management planning within the CTMM, the study goals and objectives were outlined as follows: Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 7-3 • implementing the Air Quality Management Plan to ensure a holistic air quality management approach; • assigning clear responsibilities for air quality management in Tshwane; • identifying and monitoring pollution sources that impact negatively on air quality; • determining which current air emissions in Tshwane must be reduced and the extent of the required reduction in consultation with all relevant authorities and stakeholders; • clarifying the respective roles within local government with regards to air quality management and monitoring; • developing and implementing a system to manage air emissions in Tshwane on a sustainable basis, including addressing service delivery (such as electricity) to rural areas; • establishing a framework for compliance to national and international policies, legislation, norms and standards; • determining the resources required to execute air quality management; • ensuring that air quality management forms part of the integrated EMIS; • developing and implementing air quality management programmes and projects; • developing a communication strategy for air quality management to ensure transparency and involvement of stakeholders and the public; • enforcing relevant air quality legislation and regulations; • undertaking air quality management in Tshwane in the context of and in close cooperation with authorities in neighbouring metropolitan areas in order to facilitate integration of environmental management with these areas; • implementing the noise policy and noise guidelines in consultation with all relevant authorities and stakeholders; and, • doing appropriate land-use and development planning such that noise producing activities are planned, designed and managed to minimise noise pollution in noise sensitive areas. 7.2 Approach to Air Quality Management A shift from end-of-pipe air pollution control through the exclusive implementation of command-and-control measures to effects-based air quality management using proactive, flexible, varied and fair measures is supported by the new policy. The key approaches that are to be implemented in order to achieve policy objectives may be individually listed as follows: • Adoption of a receiving environment approach which requires the setting of local air quality objectives Such objectives are needed to define what constitutes satisfactory air quality to ensure human health and welfare, the protection of the natural and build environment, and finally the prevention of significant decline. • Establishment of a sound technical basis for air quality management and planning. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 7-4 This would include the building of technical expertise and the development and implementation of various tools such as an emissions inventory, a meteorological and air pollution monitoring network, atmospheric dispersion model, impact assessment methodologies (etc.). • -Control and management of all significant sources of air pollution relative to their contributions to ambient air pollutant concentrations. This will ensure that improvements in air quality are secured in the most timely, evenhanded and cost-effective manner. • Implementation of a range of tools in the prevention of air pollution including: sourcebased command-and-control measures, market incentives and disincentives, voluntary initiatives and self-regulation and education and awareness methods. The integration of a wide range of emission reduction measures is required given the diversity in the nature of air pollution sources. Such an approach will ensure innovative and flexible plans of action tailored to suit specific source types and local circumstances. • Identification and implementation of emission reduction measures that are: (i) environmentally beneficial taking all media into account, (ii) technically feasible, (iii) economically viable, and (iv) socially and politically acceptable. • Provision will be made for the integration of air quality issues into the transportation, housing and land use planning process to ensure that air quality issues are addressed in the long term. • Empowerment of communities by providing easy access to ambient air quality information, including information on air pollution concentrations and environmentally harmful practices. • Facilitation of public consultation and encouragement of public participation in the air quality management and planning process. 7.3 • Key Considerations in the AQMP Development Process Focus on air quality management framework development in the short-term Effective air quality management has as its basis a comprehensive management framework including the required organisational and functional structures and an integrated air quality management system comprising an emissions inventory, air quality and meteorological monitoring, dispersion modelling and environmental reporting (etc.). An effective air quality management framework is not currently in place within the City of Tshwane Metropolitan Municipality due to manner in which air pollution has historically Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 7-5 been controlled. Without such a system: (i) insufficient data exists for certain sources on which to determine whether or not the implementation of certain emission reduction measures are justified, and (ii) progress made by control measure implementation can not be quantified. In the short-term emphasis thus needs to be placed on establishment of an air quality management framework, including air pollution control and air quality management skills, organisational and functional structures and AQM system tools. • Emphasis on the implementation of emission reduction measures for major sources. Given the need to focus resources on the establishment of the air quality management framework in the short-term it is imperative that emission reduction measures be carefully selected to ensure that the most significant sources, in terms of potentials for impacts on human health and well-being, are targeted. • Identification of sources for which the implementation of emission reduction measures in the short-term is justified. For specific sources sufficient evidence exists that their emissions impact significantly on either the health and/or well being of people to justify the identification and implementation of emission reduction measures in the short-term. Such evidence typically comprises the integrated assessment of preliminary emission estimates, ambient air quality monitoring and health risk studies. Examples include: household fuel burning and fugitive dust from partially rehabilitated or disturbed mine tailings impoundments. Vehicle tailpipe emissions were noted during the Baseline Assessment to be one of the most significant emerging air pollution issues on the basis of: (i) preliminary emission estimates, (ii) anticipated increases in traffic volumes and congestion rates, (iii) elevated NOx concentrations measured within the Metro, and (iv) the identification of this sector as being of primary concern by many developing countries. There is thus sufficient motivation for short-term actions to be taken aimed at addressing vehicle emissions in the medium- to long-term. • Identification of sources for which further assessment is required to determine the need for and/or most suitable types of emission reduction measures implementable. Sources of concern in terms of the emission of air toxins and odourous compounds include incinerators, landfills and waste water treatment works. Insufficient information currently exists to determine the impact of individual operations. Attention is thus focused on the quantification of the impacts of these sources and on the implication of the minimum control requirements stipulated for such sources in the short-term. The intention being to implement further controls in the medium term on individual operations found to be associated with significant impacts. Tyre burning and the informal combustion of waste were also identified during the Baseline Assessment as resulting in air toxins. Given that these sources are illegal it is justifiable that control measures be proposed in the short-term. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 7-6 Other sources that are not currently quantifiable in terms of emissions or impacts include industrial and commercial fuel burning appliances, wild fires, fugitive releases from agricultural activities and vehicle entrainment of dust from roads. The quantification of such sources and their impacts prior to implementing emission reduction measures is advocated. • Need to facilitate inter-departmental co-operation in the identification and implementation of emission reduction measures for certain sources. Local authorities are not directly responsible for the regulation of certain sources identified during the Baseline Assessment as potentially impacting significantly on pollution potentials within the Metro (e.g. waste incineration and disposal). The implementation of emission reduction measures for certain sources would require that the CTMM Environment Health and Environmental Management Divisions set up cooperative arrangements with other local departments (e.g. the identification and implementation of traffic volume reduction opportunities would require co-operation with the Department of Transportation Planning; the regulation of mining operations needs to be done in consultation with Department of Minerals and Energy). For the source types listed above, attention needs to be focused in the short-term on the establishment of inter-departmental co-operative structures or the effective utilization of existing structures in order to support the identification and implementation of effective emission controls in the medium- and longer-terms. • Focus on the implementation of air quality management planning approaches by specific sources rather than on isolated individual emission reduction measures. Air quality management planning approaches are advocated rather than implementation of emission reduction measures in a fragmented manner (e.g. implementation of dust management planning by mines and the integration of air quality issues into comprehensive environmental management assessment and planning approach by landfill sites). Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 7-7 8 LOCAL AIR QUALITY OBJECTIVES Air quality guidelines and standards and other evaluation criteria are fundamental to effective air quality management, providing the link between the potential source of atmospheric emissions and the user of that air at the downstream receptor site. The ambient air quality guideline values indicate safe daily exposure levels for the majority of the population, including the very young and the elderly, throughout an individual’s lifetime. Air quality guidelines and standards are normally given for specific averaging periods. These averaging periods refer to the time-span over which the air concentration of the pollutant was monitored at a location. Generally, five averaging periods are applicable, namely an instantaneous peak, 1-hour average, 24-hour average, 1-month average, and annual average. The Department of Environmental Affairs and Tourism (DEAT) issued ambient air quality guidelines for several criteria pollutants, including particulates, sulphur dioxide, oxides of nitrogen, lead, ozone and carbon monoxide. The National Environmental: Air Quality Act, which commenced with on the 11th of September 2005, adopted these guidelines as national interim standards. According to Peter Lucky it is likely that the SANS limit values will be adopted as national ambient air quality standards within the AQA. The Air Quality Act (AQA) does not make provision for the setting of legally binding local air quality standards by local authorities. It is however recognised that local authorities may define air quality guidelines as internal objectives or targets to assist in ambient air quality management. Such local targets may need to be made more stringent than national limits in order to protect particularly sensitive environments, or due to appeals made by local communities. 8.1.1 8.1.1.1 Air Quality Objectives for Criteria Pollutants Selection of Priority Pollutants for which Objectives are to be established In the selection of pollutants for which local guidelines were established attention was paid to the following: • commonly occurring pollutants within the CTMM that give rise to relatively widespread exposures; • pollutants for which national air quality guidelines currently exist and for which national air quality standards are in the process of being established; and • pollutants for which guidelines/standards/goals are initially issued by other countries. Based on the above considerations the following pollutants were selected for the establishment of local guidelines: • particulate matter with an aerodynamic diameter of < 10 µm (PM10) • nitrogen dioxide (NO2) Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 8-1 • sulphur dioxide (SO2) • carbon monoxide (CO) • ozone (O3) • lead (Pb) • benzene • dustfall Air quality standards are being issued by other countries for metals in addition to lead and for volatile organic compounds (VOCs) in addition to benzene. The EC is, for example, in the process of issuing air quality targets for mercury, nickel, cadmium, arsenic and poly aromatic hydrocarbons (PAHs) in addition to the pollutants listed above (with the exception of dustfall). The United Kingdom has also recently added 1,3-butadiene to the list of seven common pollutants (as listed above; excludes dustfall). The South African Technical Committee on air quality standard setting have proposed that national air quality standards initially be put in place for the pollutants associated with the most widespread exposures. The Committee decided that standards should initially be set for lead and benzene, with additional standards for other metals and VOCs being set at a latter date (as was the EC and UK's practice). Air quality standards are not defined by all countries for dust deposition although some countries may make reference to annual average dustfall thresholds above which a 'loss of amenity' may occur. In the South African context, widespread dust deposition impacts occur as a result of wind blow mine tailings material and other fugitive dust sources. It is for this reason that the SABS Technical Committee on air quality standards has recommended the establishment of target levels and alert thresholds for dustfall. The adoption of local dustfall guidelines by the CTMM is therefore recommended. Particulate matter less than 2.5 µm (PM2.5) was initially selected for inclusion in the list of pollutants for which local air quality guidelines are to be established. The reason being that particles generated from combustion processes are mostly smaller than 2.5 µm whereas particles from mechanical processes tend to be larger. Usually the fine mode is characterised by chemical constituents such as sulphate, nitrate, ammonium, lead, elemental carbon, metals and hundreds of different organic carbon compounds. The coarse mode is characterized by materials typical of the earth's crust (oxides of iron, calcium, silicon and aluminium) and sea spray (sodium and chloride). The finer particles also have a longer residence time in the atmosphere and can penetrate deeper into the human lung. It has been suggested that the PM2.5 fraction may therefore play a more important role in the longterm effects attributable to particles than either PM10 or PM10-2.5. Following the review of the literature on PM2.5 it was recommended that the setting of a local guideline for this particulate size fraction be postponed to the first revision of the AQMP, which will follow this study. The reasons for placing emphasis initially on the PM10 fraction prior to including guidelines for PM2.5 are as follows: • with regard to air quality measurement equipment, inter-comparisons between different types of equipment are being performed for PM10 but are at present not widely done for PM2.5 or finer fractions Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 8-2 • a very important fraction of the health effect studies undertaken to date is based on TSP or PM10 measurements and exposures • PM10 concentrations show an acceptable correlation to PM2.5 levels • there is limited international experience on the setting of PM2.5 standards Countries, blocks and organisations which have adopted PM10 standards, guidelines or objectives to date including: South Africa, USA, Australia, New Zealand, the EC, various individual Member States including the UK, Germany, Sweden (etc.), Poland, Romania, Slovenia, the World Bank, the WHO, Tanzania, Zimbabwe (etc.). Only three countries have issued PM2.5 standards to date, viz. the US (standard currently being contested), New Zealand and Australia. It is however noted that several countries are known to be in the process of investigating the potential for setting standards for a particle size range below PM10 including the EC and the UK. Although it is suggested that a local guideline for PM2.5 be established at a later date, it is recommended that monitoring of this particulate size fraction be undertaken at sites coinciding with PM10 monitoring. Such monitoring will assist in characterising local PM2.5 concentration levels in terms of their magnitude and spatial and temporal variations, and in terms of typical ratios of PM2.5 to PM10. The gathering of this information in the interim will assist in informing the setting of a suitable PM2.5 at a future date. 8.1.2 Criteria and Approach for Setting Local Air Quality Objectives A tiered approach is advocated for adoption by the CTMM for the purpose of setting air quality evaluation criteria. It is recommended that the following thresholds be established for specific pollutants-averaging periods: • Limit values are to be based on scientific knowledge, with the aim of avoiding, preventing or reducing harmful effects on human health and the environment as a whole. Limit values are to be attained within a given period and are not to be exceeded once attained. • Information and investigation thresholds are intended to highlight pollutant concentrations at which the public need be informed that the most sensitive individuals may be impacted and/or at which investigations into reasons for the elevated levels need to be initiated. • Alert thresholds refer to levels beyond which there is a risk to human health from brief exposure. The exceedance of such thresholds necessitates immediate steps. The limit values and associated averaging periods recommended for adoption by the CTMM are primarily based on human health effect data given for specific averaging periods. In the selection of suitable limit values to be used as the basis for local guidelines, reference was primarily made to the lowest observed adverse effect level (LOAEL) rather than exclusively to the standards adopted by other countries. The reason being that other country-specific considerations that may not be applicable in SA may have been taken into account in the standard setting process. It was however noted that the standards more recently promulgated (e.g. limit values of the EC, UK and certain of the Australian standards) closely coincide with LOAELs. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 8-3 It was considered beyond the scope to consider primary health studies as the basis for selecting suitable local guidelines as part of the air quality management plan development process. The review was therefore restricted to the consideration of the major metaanalyses undertaken by various countries and organisations for the purpose of setting ambient air quality guidelines and standards. Such meta-studies have been conducted for select pollutants by the WHO, the EC, the UK, Australia, US-EPA, the California Air Resources Board and Canada. 8.1.2.1 Limit Values to be Implemented to Protect Human Health and Well-being A synopsis of the limit value or guideline selected for each pollutant-averaging period combination is given in Table 4-1. Current SA guidelines are indicated for pollutantaveraging period combinations for which no local guidelines have been set (indicated in shading). It is necessary to acknowledge these since the City of Tshwane will also need to prove compliance with such guidelines. On finalisation of the national ambient air quality standards regulations this table will however need to be revised to remove reference to current guidelines and to review proposed local guidelines in order to ensure that they are equivalent to or lower than the new national standards. Local guidelines to be adopted for implementation by the City of Table 8-1: Tshwane. Values are expressed in µg/m3 and where appropriate ppb (the volume standardised at a temperature of 25°C and a pressure of 101,3 kPa.) Pollutant Averaging Period Sulphur dioxide 10 minute running average 1-hr 24-hr annual Nitrogen dioxide Nitrogen oxide Oxides nitrogen PM10 of instantaneous peak 1-hr 24-hr 1-month annual instantaneous peak 1-hr 24-hr 1-month annual instantaneous peak 1-hr 24-hr 1-month annual 24-hr annual Guideline (ppb) 191 Guideline (µg/m3) 500 133 48 350 125 19 50 500 104 100 80 21 900 600 300 200 150 1400 800 400 300 200 955 200 191 153 40 1125 750 375 250 188 2080 1132 566 403 284 75 40 Basis for Guideline Current revised SA guideline, WHO, SANS 1929 EC, UK Current revised SA guideline, SA, WHO, EC, UK, SANS 1929 Current revised SA guideline, SA, WHO, SANS 1929 Current SA WHO, EC, UK, SANS 1929 Current SA Current SA WHO, EC, UK, SANS 1929 Current SA Current SA Current SA Current SA Current SA Current SA Current SA Current SA Current SA Current SA SANS 1929 SANS 1929, EC - phase 1 Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 8-4 Pollutant Carbon monoxide Lead Ozone PM2.5 Averaging Period 1-hr 8-hr running average calculated on 1-hourly averages quarterly-average annual instantaneous peak 1-hr 8-hr running average calculated on 1-hourly averages 24-hr annual average Benzene annual average Guideline (ppb) 26 000 8 700 Guideline (µg/m3) 30 000 10 000 1.5 0.5 255 102 61 500 200 120 To be determine during the development of the AQMP To be determine during the development of the AQMP 5 Basis for Guideline WHO, EC, SANS 1929 WHO, EC, SANS 1929 Current SA WHO, EC, UK, Australia, SANS 1929 Current SA Health criteria, SANS 1929 EC target based on WHO, SANS 1929 SANS 1929 The four-band scale recommended for use in the evaluation of dustfall is outlined below and target, alert and action levels indicated. Dustfall rates shall be expressed in units of (mg m-2 day-1, 30-day average). 1 BAND DESCRIPTION LABEL RESIDENTIAL 2 INDUSTRIAL 3 ACTION 1 200 < D < 2 400 4 ALERT 2 400 < D BAND NUMBER DUST-FALL RATE (D) -2 -1 (mg m day , 30-day average) D < 600 600 < D < 1 200 COMMENT Permissible for residential and light commercial Permissible for heavy commercial and industrial Requires investigation and remediation if two sequential months lie in this band, or more than three occur in a year. Immediate action and remediation required following the first exceedance. Incident report to be submitted to relevant authority. An enterprise may submit a request to the authorities to operate within the Band 3 ACTION band for a limited period, providing that this is essential in terms of the practical operation of the enterprise (for example the final removal of a tailings deposit) and provided that the best available control technology is applied for the duration. No allowance will be made for operations that result in dustfall rates in the Band 4 ALERT. Target, Action and Alert Thresholds for ambient dustfall are proposed as follows: Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 8-5 LEVEL TARGET ACTION RESIDENTIAL ACTION INDUSTRIAL ALERT THRESHOLD DUST-FALL RATE (D) (mg m-2 day-1, 30-day average) 300 600 AVERAGING PERIOD Annual 30 days 1 200 30 days 2 400 30 days PERMITTED FREQUENCY OF EXCEEDANCES Three within any year, no two sequential months. Three within any year, not sequential months. None. First exceedance requires remediation and compulsory report to authorities. Dustfalls that exceed the specified levels but that can be shown to be the result of some extreme weather or geological event shall be discounted for the purpose of enforcement and control. Such event might typically result in excessive dustfall rates across an entire metropolitan region, and not be localised to a particular operation. Natural seasonal variations, such as dry windy periods will not be considered extreme events for this definition. 8.1.3 Definition of Timeframes for Compliance with Local Objectives: To inform the schedule for the meeting of targets it will be necessary for the City of Tshwane to undertake the following work: (i) project future air pollution concentrations given a 'business as usual scenario', i.e. no emission reductions implemented but increased emissions due to population growth, industrial growth, etc. taken into account; (ii) projected air pollution concentrations given the implementation of combinations of short-, medium- and long-term control measures; and (iii) selection of measures for implementation which are socio-economically acceptable and technologically possible. This assessment can only be undertaken following the establishment of the air quality management system, which includes: the establishment of a comprehensive emissions inventory, the establishment of the air pollution monitoring network and the acquisition and implementation of an atmospheric dispersion model. The selection of suitable timeframes for compliance with local guidelines will be determined during the AQMP development process for the CTMM. Note: Should DEAT in the interim publish air quality standards with timeframes for compliance being stipulated, CTMM will need to adopt the given timeframes as maximum periods for compliance. Shorter timeframes could however still be set as a guide for local compliance assessment. 8.1.3.1 Alert and Information Thresholds for Priority Pollutants Alert and information thresholds recommended for use by the City of Tshwane are outlined in Table 4-2. These thresholds will need to be finalised at a later date, this will involve: • the selection of appropriate thresholds selected for each pollutant; • the definition of information to be provided and the manner in which it will be provided following the exceedance of an 'information threshold'; and • indication of specific action to be taken on exceedance of an 'alert threshold' Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 8-6 The finalisation of information on alert thresholds will be undertaken once the following has been undertaken: (i) at least one year of air pollutant concentrations recorded for the pollutant for which the thresholds are to be set, (ii) source contributions to ambient air pollutant concentrations established, and (iii) possible actions assessed in terms of their socio-economic acceptability and technical feasibility. Locally-defined alert and information thresholds will also be revised should national thresholds be issued. Various of the recommended thresholds given in Table 3-2 are based on UK bands, such bands represents a means of categorizing the ambient concentrations of a particular pollutant in low, moderate, high and very high air pollution categories. The information threshold level is set equivalent to the "high" pollution level with the alert threshold indicative of "very high" pollution levels. The UK defines the implications of such levels as follows: • High pollution levels - "Significant effects may be noticed by sensitive individuals and actions to avoid or reduce these effects may be needed (e.g. reducing exposure by spending less time in polluted areas outdoors.) Asthmatics will find that their 'reliever' inhaler is likely to reverse the effects on the lung." • 'Very high' pollution levels - "The effect on sensitive individuals described for 'high' levels of pollution may worsen." Table 8-2: of Tshwane Alert and information thresholds to be investigated for use by the City nitrogen dioxide Averaging Period 10-minute average 3 consecutive hours 1-hour average carbon monoxide 3 consecutive hours 8-hour average ozone 8-hour average Pollutant sulphur dioxide 8.1.3.2 Information Threshold 532 µg/m3 200 ppb 573 µg/m3 (300 ppb) 17.4 mg/m3 (15 ppm) 180 µg/m3 (90 ppb) Alert Threshold 1064 µg/m3 400 ppb 350 µg/m3 (130 ppb) 764 µg/m3 (400 ppb) 400 µg/m3 (209 ppb) 23.2 mg/m3 (20 ppm) 360 µg/m3 (180 ppb) Basis for Threshold UK 15-min bands EC alert threshold UK bands EC alert threshold UK bands UK bands Thresholds related to Vegetation and Ecosystems Although it is recommended that local air quality guidelines for the City of Tshwane be based initially on thresholds able to protect human health, the need to protect the broader environment is accepted as is evident from the vision statement. It is recommended that in the short-term the City of Tshwane should motivate DEAT and GDACE to identify guidelines for vegetation suited to local ecosystem. (National and provincial authorities are mandated to set more stringent air quality limits according to the Air Quality Act). In the interim, the CTMM personnel will make reference to internationally defined air quality criteria given for Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 8-7 the protection of vegetation for information purposes. Reference to certain criteria issued by the EC, UK and US for this purpose is given in Table 4-3. Table 8-3: Thresholds specified by other countries specifically for vegetation and ecosystems Pollutant Averaging Period sulphur dioxide annual average nitrogen oxides (NOx) ozone annual average AOT40 (daylight hours, 3 months)(d) AOT40 (daylight hours, 3 months)(d) Threshold (ppb/ppm) Threshold (µg/m3 or mg/m3) 3.7 - 11.1 ppb(a) 7.4 ppb(b) 20 ppb(c) 8 - 9 ppm(e) 10 - 30 µg/m3(a) 20 µg/m3 (b) 30 µg/m3 (c) 4 - 4.5 mg/m3(e) 3 ppm/h(f) 1.5 mg/m3(f) (g) Represents the critical level for ecotoxic effects issued by the WHO for Europe; a range is given to account for different sensitivities of vegetation types (h) EC and UK limit value to protect ecosystems (i) EU limit value specifically designed for the protection of vegetation 3 (j) AOT40 means the sum of the differences between hourly concentrations greater than 80 µg/m or 40 ppb 3 and 80 µg/m over a given period. The 3-month window to be selected according to the growing season of the selected sensitive receptor and the climate in the specific region - if the growing season exceeds 3 months the most sensitive period should be used. Daylight hours are set at 8-20 h Central European Time (k) EC target value given for vegetation (l) EC long-term objective for vegetation 8.1.3.3 Proposed Procedure for Assessment of Non-Criteria Pollutants Ambient air quality guidelines and standards are not published by countries and organizations for all possible air pollutants to which the public may be exposed. Such guidelines and standards are typically only set for commonly occurring air pollutants that result in relatively widespread public exposures (e.g. particulate matter and sulphur dioxide). In order to ensure that a sound approach is adopted in the assessment of the potential for health impacts from non-criteria pollutants the following inhalation health risk screening procedure will be adopted for implementation within the City of Tshwane: (1) Determine ambient(11) near ground(12) air pollutant concentrations through ambient air quality monitoring and/or atmospheric dispersion modelling. For ambient air quality monitoring use must be made of a credible monitoring device and methodology. The detection level of the instrument must be below the level at which health effects are known or suspected to occur. Monitoring must be undertaken for the averaging period for which health thresholds are available (e.g. hourly averages). 11 Ambient air is defined for the purpose of implementing this procedure as being beyond the fencelines of specific industrial and mining operations in areas where public exposures are possible. 12 It is recommended that concentrations be established at about 1.5 m above ground level. This is typically set as the receptor height for assessing human exposures. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 8-8 For atmospheric dispersion modelling use must be made of provable source and emissions data. Emission rates may either be measured or calculated based on mass balance equations, engineering calculations or applicable emission factors. Site-specific meteorological and topographical data should be used in the modelling. Attention should be paid to the guidelines for dispersion modelling outlined in SANS 1929. (2) Obtain inhalation-related dose-response thresholds for the air pollutant under investigation from credible, preferably refereed sources. Recommended information sources and types of thresholds are as follows: Recommended Information Sources: United States Environmental Protection Agency Integrated Risk Information System (IRIS) California Environmental Protection Agency – Office of Environmental Health Hazard Assessment US federal Agency for Toxic Substances and Disease Registry (ATSDR) World Health Organisation Threshold Type: Averaging Period: Website: Sub-chronic inhalation reference concentrations Chronic inhalation reference concentrations Cancer unit risk factors Sub-chronic – weeks to months www.epa.gov/iris Chronic – 1 year average or longer www.epa.gov/iris Chronic – 1 year average or longer (Exposures over 70 year lifetime assumed) Acute – typically 1 hour average ranging to 8-hourly average depending on pollutant Chronic – 1 year average or longer www.epa.gov/iris Acute Reference Exposure Levels (RELs) Chronic Reference Exposure Levels (RELs) Minimal Risk Levels (MRLs) Guideline Values and Tolerable Concentrations Cancer Unit Risks www.oehha.ca.gov www.oehha.ca.gov http://www.atsdr.cdc.gov/ mrls.html Various averaging periods, including: 30-minutes 1-hour 24-hour annual average Chronic – 1 year average or longer (Exposures over 70 year lifetime assumed) http://www.who.int/en/ http://www.who.int/en/ (3) Determine the major exposure pathway for the pollutant under investigation, i.e. inhalation, ingestion or dermal contact. For pollutants for which inhalation is not the major exposure pathway recognize that a comprehensive health risk assessment in which multiple-exposure pathways are taken into account is needed. (4) For pollutants for which inhalation represents the major exposure pathway, assess predicted and/or measured air pollutant concentrations based on applicable doseresponse thresholds. Ensure that the averaging period for such concentrations are relevant to the exposure period for which the threshold is stipulated. (5) For non-carcinogenic effects, exceedances of applicable dose-response thresholds should be taken to indicate the need for a more comprehensive quantitative health risk assessment. In instances where pollutant concentrations are within such thresholds, health risks may be considered unlikely to occur. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 8-9 (6) 8.2 For carcinogens, calculate possible maximum exposed individual (MEI) cancer risks through the application of unit risk factors. In cases where calculated cancer risks are greater than 1: 1 million (i.e. one person contracting cancer out of every million exposed) consult with decision makers and affected communities to determine the acceptability of the incremental cancer risk calculated(13). In instances where cancer risks are considered unacceptable a comprehensive quantitative health risk assessment is required. Such health risk assessments quantify actual exposures, rather than assuming maximum possible exposures, and as such are less conservative. Actions Required and Target Dates A synopsis of the specific actions required and timeframes for establishing various local air quality objectives is given in the table below: Action: Target Date Short-term Adoption of local ambient air quality objectives and dustfall evaluation criteria On adoption of the AQMP Revision of local ambient air quality objectives and dustfall evaluation criteria Immediately following the replacement of the interim National Air Quality Standards by the DEAT Medium-term Determine target timeframes for meeting local air quality objectives June 2007 Determination of local air quality objectives for PM2.5 (excluding timeframes for compliance) June 2008 Definition of local alert and information thresholds June 2008 Motivation of DEAT and GDACE for the investigation of air quality criteria suited to the protection of local vegetation and ecosystems December 2008 Adoption of local objectives for the protection of vegetation and ecosystems January 2010 - Pending completion of DEAT/GDACE investigation 13 Alternatively, a comprehensive quantitative health risk assessment can be commissioned prior to consultation with decision makers and communities to determine, less conservatively, the extent of possible cancer risks. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 8-10 9 AIR QUALIY MANAGEMENT SYSTEM An AQMP cannot be successfully implemented and revised in the absence of an effective air quality management system. The CTMM AQMP therefore has as a focus the establishment of a system in the short-term (first two years after approval). Air quality goals or objectives represent an important air quality management 'tools' as discussed in the previous section. Other essential tools in any air quality management system are: emissions inventory, air quality and meteorological monitoring and atmospheric dispersion modelling (Figure 5-1). Figure 9-1: Development of an air quality management strategy through the implementation of select air quality management tools (after WHO, 2000). On the basis of a comprehensive emissions inventory, the application of monitoring, in combination with modelling, facilitates the effective characterisation of spatial and temporal variations in air pollutant concentrations. Such concentrations are evaluated based on local guideline values to determine the need for devising emission control strategies. Dispersion modelling is used to predict ambient air pollutant reductions possible through the implementation of specific emission control strategies. Emission control strategies may then be selected which are able to ensure compliance with the local guideline value, the socioeconomic acceptability and technological feasibility of such strategies having been Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-1 assessed. The control measures selected need to be enforced, and if the standards are achieved, they need continued enforcement. If the standards are not achieved after a reasonable period of time (i.e. within the permissible timeframe to be stipulated), the emission control measures may need to be revised. An integrated air quality management system, which comprises components such as an emissions inventory and air quality monitoring and modelling, forms the basis of effective air pollution control and air quality management. The configuration of the management system to be implemented by CTMM is illustrated in Figure 5-2. System components proposed for implementation in the short-term are indicated by solid lines, with components to be added at a later stage indicated by dashed lines. Figure 9-2: Air quality management system proposed for implementation by CTMM Components of the Basic Air Quality Management System proposed for implementation by the CTMM within the short-term, i.e. next 1-2 years, include the following: • Setting of local air quality objectives (see Section 3) • Development of a comprehensive emissions inventory • Establishment of air quality and meteorological monitoring network • Atmospheric dispersion modeling • Routine reporting mechanisms and protocols - including procedures for internal reporting and for reporting to DEAT, GDACE and the public. • Public liaison and consultation mechanisms Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-2 Based on the outputs of the basic air quality management system, health risk assessments and damage assessments can be undertaken and impacts costed in the medium-term (Years 3-5). Such assessment may be undertaken in the following ways: (i) (ii) (iii) 9.1 inhouse, through the selection and acquisition of suitable models and acquisition and preparation of locally-derived input data, inhouse, though the application of manual calculations based on locally-derived data and international protocols, or externally, through the appointment of consultants on a project-by-project basis. Emissions Inventory The first step in the development of an Air Quality Management System is the establishment of a comprehensive, accurate and current emissions inventory. An emission inventory is an account of air pollutant emissions and associated source configuration data from specific sources over a specific time period. Source and emission data need to be collated for routine, upset and accidental emissions to provide a representative account of the potential for impacts that exist. Emission inventories represents the key elements in all programmes aimed at air pollution management, aiding in the identification of pollutants and sources of concern and therefore in the selection of effective air pollution abatement measures. In addition to containing information on present emission levels from the various source categories, an emission inventory could also indicate projected future emissions for longterm planning purposes. The emissions inventory developed for the CTMM during the baseline assessment followed the gross estimation approach instead of a detailed emissions inventory (Liebenberg-Enslin & Petzer, 2005). Taking the objectives of the study into account and the timeframe for its completion the rapid survey method was followed. This includes the use of both reference documents and summary data for area sources in addition to infield data collection for major sources. The CTMM should use the first level emissions inventory developed to extend and update this inventory. All sources of emissions, including point and non-point (fugitive) sources should be identified for inclusion into the emissions inventory. Methodologies typically employed to determine source strengths include: • Sampling or direct monitoring; • Emission factor application; • Engineering calculations; and, • Mass balances. Emission factors and emission estimation methods suitable for the quantification of various sources within the CTMM were documented in the Baseline Assessment document to provide guidance for the establishment of an electronic emissions inventory (LiebenbergEnslin & Petzer, 2005). There are two general approaches to the establishment of an electronic emissions inventory: Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-3 • Emission estimation using various emission models - manual integration into common emissions inventory data base. • Selection of emissions inventory software - includes emission estimation algorithms for all required sources (NB - ensure potential for changing algorithms to suit local considerations and source types) - Recommended The implementation of a software package comprising an emissions inventory data base, in addition to data base facilities for other data sets (air pollution and meteorological monitoring data, exposure data, etc.), a dispersion modelling component and a GIS-interface is recommended. In its selection of such a package, it is recommended that CTMM consult with DEAT and GDACE personnel and with the departments responsible for air quality management within adjacent cities and metropolitans. CTMM should also explore existing tools within the metro such as the EMME/2 traffic model which can calculate emission rates for vehicles. This will ensure that software be purchase that can be seamlessly integrated into the software used by EMM and the City of Joburg, Gauteng and National Government. The CSIR has proposed a framework for a National Emissions Inventory to be developed as reflected in Figure 5-3. Cognisance should be given to trends at national and provincial levels. National Emissions Inventory Western Cape Dist 1 Dist 2 etc Eastern Cape KwaZulu Natal Free State Limpopo North West Mpumalanga Gauteng Northern Cape City of CT Point sources Industry 1 Industry 2 Etc Mobile sources Light MV Heavy MV Etc Domestic sources Area sources Biogenic sources Figure 9-3: Example for a National Emissions Inventory (from Mark Zunkel, CSIR, IQPC Conference, 15 & 16 February 2005, Sandton Convention Centre) 9.2 Ambient Air Quality and Meteorological Monitoring The second step in the development of an AQM System is the development of an ambient air quality and meteorological monitoring network to provide consistent and reliable information on the status of air quality at designated sites. In the design of a monitoring network for CTMM the following aspects were considered: Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-4 • monitoring objectives defined • data quality objectives defined • priority pollutants selected • suitable numbers of stations determined for each pollutant • locations of stations selected and justified • stations classified • suitable monitoring methods established • averaging periods for data reporting determined • sampling durations defined • suitable mechanisms and protocols for data transfer and storage identified Other factors taken into account in the establishment of the network included the existing initiative of CTMM to expand the existing monitoring network, the cost of the network and practical requirements for the establishment of a station at a specific site (e.g. security, power supply, representiveness of site). 9.2.1 Monitoring Objectives Monitoring networks are established with various objectives in mind, i.e. to determine seasonal and diurnal trends in air pollution, to establish compliance with ambient air quality standards, to determine impacts on human health and/or the environment etc. These objectives directly influence the design of the monitoring network, determining the preferred locations, the type of monitoring equipment, pollutants to be included, and the frequency intervals of monitoring. One of the main findings of the baseline assessment conducted as part of the Air Quality Management Plan for CTMM was the lack of comprehensive ambient air quality data for the region. The lack in information was found to be both on the spatial extent and on the types of pollutants measured. In this light, the following air quality monitoring objectives have been adopted by CTMM: • to determine compliance with air quality guidelines and standards • to assess exposure of people, addressing both the highest levels and the levels in other areas where the general population is exposed • make adequate information available to the public • provide objective inputs to air quality management, transportation and land use planning • tracking progress made by pollution control measure implementation • source contribution determination (e.g. receptor modelling) • spatial and temporal trend analysis • to be used to validate dispersion modelling The following were explicitly excluded from the objectives of monitoring during the shortterm: Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-5 • assessment of exposure of vegetation and ecosystems • quantification and assessment of indoor air quality • stack monitoring • monitoring of near ground pollution in areas where maximum pollution concentrations do not coincide with exposure • quantification of 'air toxins', dustfall and oderiferous pollutants is typically localised and traceable to a specific source. (The need for such monitoring will be determined on a needs assessment basis with the source likely to be held responsible for the costs incurred.) 9.2.2 Parameters to be Monitored Based on the main pollutants of concern identified during the baseline assessment and the lack of background concentration information, it was decided to focus on priority pollutants in the short-term. The pollutants recommended to be monitored, include: • PM10 • PM2.5 • NO2 (NOx, NO) • SO2 • CO • O3 • Lead • Benzene It is further intended that CTMM re-instate the smoke and SO2 sampling campaign at the nine locations previously monitored. These monitoring methods are fairly inexpensive and will support long-term trend analysis and the characterization of spatial variations in air pollutant concentrations. Dustfall monitoring was excluded for the reason given previously, i.e. dustfall impacts are typically localised and traceable to a specific source with the source responsible for these impacts likely to be held responsible for the costs incurred. PM2.5 monitoring is deemed necessary due to the health implications of finer particulate fractions and due to the need to inform the setting of a local guideline for PM2.5 in the short- to medium-term. Meteorological parameters that are required to be monitored include, as a minimum, wind speed and direction, ambient temperature, sigma-theta, relative humidity and rainfall. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-6 9.2.3 9.2.3.1 CTMM Monitoring Network Proposed for Initiation – Short-term Locations of Monitoring Stations Site selection for the proposed monitoring stations was based on various factors such as source locations in relation to sensitive receptor areas (i.e. residential areas, hospitals, schools etc.), population density (specifically in informal settlements), topography (such as the moot area), and the dispersion potential of the region (predominant wind fields). In addition, use was made of the dispersion simulation results as conducted during the baseline assessment. It should be noted that the dispersion simulations did not account for all source emissions within the CTMM, but only those included in the first level emissions inventory developed. The sources taken into account included domestic fuel burning, vehicle tailpipe emissions, and main industrial sources and power generation (scheduled processes). Background combustion sources were also considered and were taken from the NEDLAC Dirty Fuels study. This study was conducted as part of a DEAT initiative in 2003 to determine the potential socio-economic impact of measures to reduce air pollution from combustion. Source and emissions data were collected for fuel burning activities within all sectors (transport, industrial, domestic, agriculture) for various conurbations throughout South Africa, including the Gauteng and Highveld region. These simulation results allowed for an indication of cumulative impacts due to trans-boundary pollution. The locations of existing and proposed monitoring stations are presented in Figure 5-3. Table 5-1 lists the locations of the existing monitoring stations, the proposed re-instated monitoring stations and the proposed new monitoring stations. It should be noted that the locations are not necessarily permanent and will be moved to record at all the main impacted areas within the CTMM. Table 9-1: Proposed CTMM air quality and meteorological monitoring sites Site Name Site Type Site Classification Minimum Parameters to be Measured Rosslyn Stationary (existing GDACE-sponsored station) Within industrial area PM10, SO2, NO, NO2, NOx, CO & Ozone Pretoria West Semi-stationary (existing CTMM Topas) Within industrial area – close to residential areas PM10, Wind speed, direction, sigma-theta Mamelodi Moot – western section Centurion – central Centurion – Stationary (new station proposed for commissioning by March 2006) Stationary (new station proposed for commissioning by March 2007) Stationary (new station proposed for commissioning by March 2007) Mobile station (new Residential – household fuel burning Residential – proximity to industry Residential – possible impacts from industrial sources to the north Residential/Commerc wind PM10, SO2, NO, NO2, NOx, CO & Ozone Wind speed, wind direction, sigma-theta PM10, SO2, NO, NO2, NOx, CO & Ozone Wind speed, wind direction, sigma-theta PM10, SO2, NO, NO2, NOx, CO & Ozone Wind speed, wind direction, sigma-theta PM10, PM2.5, SO2, NO, NO2, Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-7 Site Name Highveld near N1/N14 intersection Pretoria East – near N1/N4 intersection Site Type station proposed for commissioning by March 2006) Mobile station (new station proposed for commissioning by March 2006) Centurion – Elardus Park Mobile station (new station proposed for commissioning by March 2006) Centurion – Rooihuiskraal/ The Reeds Mobile station (new station proposed for commissioning by March 2006) Temba Mabopane/ Ga-Rankuwa Pretoria West Pretoria North – Akasia Pretoria CBD Lyttelton Rooihuiskraal Sunderland Ridge Erasmuskloof Myburgh Street Atteridgeville Mamelodi CSIR Mobile station (new station proposed for commissioning by March 2006) Mobile station (new station proposed for commissioning by March 2006) Mobile station (new station proposed for commissioning by March 2006) Mobile station (new station proposed for commissioning by March 2006) Mobile station (new station proposed for commissioning by March 2006) Smoke and SO2 sampling - Previously funded by DEAT with monitoring undertaken by Local Authorities (Environmental Health Depts) – ceased in 2001 (proposed to recommission) Site Classification ial - vehicle emissions Residential - vehicle emissions Residential – trans boundary pollution from EMM & potential pollution transfer from CTMM Residential – trans boundary pollution from City of Joburg & potential pollution transfer from CTMM Minimum Parameters to be Measured CO, lead, benzene & Ozone Wind speed, wind direction, sigma-theta PM10, PM2.5, SO2, NO, NO2, CO, lead, benzene & Ozone Wind speed, wind direction, sigma-theta PM10, PM2.5, SO2, NO, NO2, CO, lead, benzene & Ozone Wind speed, wind direction, sigma-theta PM10, PM2.5, SO2, NO, NO2, CO, lead, benzene & Ozone Wind speed, wind direction, sigma-theta Residential Residential PM10, SO2, NO, NO2, & Ozone Wind speed, wind sigma-theta PM10, SO2, NO, NO2, & Ozone Wind speed, wind sigma-theta PM10, SO2, NO, NO2, & Ozone Wind speed, wind sigma-theta PM10, SO2, NO, NO2, & Ozone Wind speed, wind sigma-theta PM10, SO2, NO, NO2, & Ozone Wind speed, wind sigma-theta Smoke & SO2 Smoke & SO2 Residential Smoke & SO2 Residential Residential Residential – household fuel burning Residential – household fuel burning Residential / Commercial Smoke & SO2 Smoke & SO2 Residential – household fuel burning Residential – household fuel burning Residential – proximity to Pretoria West Industrial Residential – proximity to Rosslyn Commercial / Business – reference point NOx, CO direction, NOx, CO direction, NOx, CO direction, NOx, CO direction, NOx, CO direction, Smoke & SO2 Smoke & SO2 Smoke & SO2 Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-8 Site Name Site Type Sammy Marks building SANS limit values Frequency of exceedance Minimum Parameters to be Measured Site Classification CBD Smoke & SO2 Exisitng monitoring stations Proposed permanent monitoring stations Proposed mobile monitoring stations Figure 9-4: Proposed locations of permanent and mobile monitoring stations, including existing stations. 9.2.3.2 Monitoring and Data Processing and Reporting Protocols Data quality objectives, data processing and reporting protocols and monitoring methods must be established. It is intended that the data quality objectives be made equivalent to those outlined in Annex C of SANS 1929 and that the reference methods in Annex D of SANS 1929 be taken into account in the purchase of new instruments. These protocols are Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-9 the same as was recommended for the City of Joburg and EMM. It is important that the CTMMs monitoring and data processing protocols be in line with the ones being implemented by the two neighbouring metros to ensure data sharing and reporting to Provincial Government. In determining data transfer, validation and storage protocols reference is made to the standards published by South African National Accreditation Services (SANAS), viz.: • The ISO/IEC Guide 25 for calibrating laboratories (also contained in the code of practice SABS 0259-1990). • ISO 17025 requirements for the operation of testing laboratories and the ISO 9000 series for manufacturers to demonstrate the quality of operations. • NLA supplementary requirements for the accreditation of continuous ambient air pollution monitoring station (which are additional to those specified in the ISO/IEC Guide 25). For the smoke and sulphur dioxide monitoring stations reference should be made to the CSIR method for the determination of smoke and sulphur dioxide (CSIR Special Report, SMOG 3, Methods recommended for the measurement of air pollution in South Africa, Determination of Smoke and Soot (fine suspended matter), 1974; CSIR Special Report SMOG 5, Methods recommended for the measurement of air pollution in South Africa, Determination of Sulphur Dioxide, 1971). Sampling durations will be continuous, where applicable. Preference will be given to data transfer methods which allows for near real-time, continuous and reliable data transfer wherever possible. Potential methods include: telemetry, continuous download via satellite and transfer via radio link. In defining data storage procedures attention will be paid to SANAS accreditation requirements include the following: (i) raw data to be kept, (ii) data to be kept for minimum of 3 years, and (iii) all manipulations of data must be recorded. It is pertinent that the software used is open-ended to allow for the interaction with any database. The CSIR was recently (mid-2005) appointed by DEAT to develop the framework for a National Air Quality database. This database is intended to house all emissions data and ambient air quality data for the entire country. The idea is that each municipality and province would be able to download ambient air quality data automatically into the central database where data will be validated. This data can then be accessed at any time with built-in tools for data manipulation and analysis. 9.3 Atmospheric Dispersion Modelling Atmospheric dispersion modelling forms an integral component of air quality management and planning. Dispersion models calculate ambient air concentrations primarily as functions of source configurations, emission strengths, terrain features, and meteorological characteristics. Dispersion modelling is typically used to determine compliance with ambient air quality standards, assist in health and environmental risk assessment, provide information for Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-10 monitoring network design and to assess source contributions to air quality concentrations. Very important for local authorities is the use of dispersion models to assist with land-sue planning, specifically for future planning scenarios and “what if” investigations. It can also be used to delineate of buffer zones around existing emissions sources or areas where no additional sources should be allowed. It is often said that air quality monitoring provides "snap-shots", whereas air quality modelling helps to provide the whole picture. In Europe and elsewhere, there is a distinct trend towards the replacement of extensive and costly air quality monitoring networks by on-line dispersion modelling coupled with key monitoring sites for model calibration and validation. Careful consideration should be taken in the selection of a suitable dispersion model for the purpose at hand. Based on the responsibilities of CTMM in the management of air quality, criteria to be met by the dispersion model to be implemented must include the following: • urban-scale dispersion model; • comprising a combined Eularian/Lagrangian model combining modules for area, line and point sources; • as minimum, first order chemical transformation (ozone formation); • Microsoft Windows based; • compatibility with local LAN; • compatibility with emissions inventory software (if system not integrated with emissions estimation and inventory component); • GIS-based; and, • Strong data base tools. The most widely-used commercially available packages suited to the application include: • Norwegian AirQUIS (currently favoured for application in Durban, GIS-based) • UK ADMS Urban (potential for local support in longer term through WSP; GIS-based with extensive interactive interface; purchased by City of Joburg) • Swedish Air Quality Management Model (GIS-based, combines Operational Street Pollution Model with AERMOD; copy in use in Rustenburg by Anglo Platinum) • European AirBase The selection of a suitable dispersion model (or package comprising dispersion modelling, air quality and meteorological data base and emissions inventory components) will be done in consultation with DEAT and GDACE personnel and with the departments responsible for air quality management within adjacent metros and cities. Again the importance of utilising a compatible model than the ones used by the neighbouring municipalities need to be stressed. 9.4 Reporting Protocol An important aspect of the Air Quality Act is the involvement of the public in decision making processes. It is therefore pertinent to make information regarding air quality within CTMM Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-11 available to the public, stakeholders and I&APs. This necessitates a reporting protocol to ensure a standardised methodology and reporting format. CTMM is committed to the implementation of a comprehensive reporting protocol including the following: • All monitoring information reporting to a central data base including: air quality and meteorological data (automatic transfer or other depending on station), source and emissions data, diesel vehicle test results, soiling index monitoring results (etc.). • The air quality management database (comprising air pollution monitoring data, meteorological monitoring data and source and emissions data) will be archived on a monthly basis. Three copies will be made: (i) one to be retained by the Air Quality Management function, (ii) one to be sent to the DEAT for archive, and (iii) one copy to be sent to GDACE for archive. Once the National Air Quality Database14 has been developed, this function should hopefully be automated with web access to the database. • Source and emissions data and air pollution and meteorological monitoring results to be made available to DEAT and GDACE on request in an electronic format compatible with their inhouse data bases. Again, with the development of a National Air Quality Database this obligation would be included. • Air quality and meteorological monitoring data to be made available (in raw data format) to technikons and universities on request for use in academic projects. • Routine and special reports to be generated by CTMM will be determined in the shortterm. Possible reporting requirements to be considered are outlined in Table 4-2. • Results from the ambient and meteorological monitoring network to be published on the City of Tshwane website on at least a monthly basis. This should allow for the indication of areas where non-compliance was experienced (see Table 4-2). 14 The CSIR is currently in the process of developing the framework for a National Air Quality Database on behalf on DEAT. This database is aimed to host all source and emissions data, and ambient air quality data recorded within each municipality and province, allowing easy access and manipulation of data from any sphere of government. It is our understanding that the processed information be published on a website for the public to access. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-12 Table 9-2: Frequency and content of reports to be considered by CTMM in the short-term (next two years) in defining its medium- and long-term reporting commitments and targets. Frequency Content Non-compliance reporting on a daily basis (only report when exceedances occur) Pollutant exceedances Site location at which exceedance was measured Threshold exceeded (national standard, local guideline, local alert threshold) Magnitude of exceedance (area) Reason for exceedance (if known) Action to be taken (where appropriate) Daily (routine report) Monthly (routine report) Report on previous day's pollution levels including: Air quality index calculated per station Identification of specific pollutant(s) responsible for high index values For non-compliance days - inclusion of brief information on the reasons for the episode (if known) Daily average pollution concentrations recorded at each station Maximum hourly pollution concentrations recorded at each station Report on previous day's pollution levels including: Air quality index calculated per station Identification of specific pollutant(s) responsible for high index values For non-compliance days - inclusion of brief information on the reasons for the episode (if known) Air quality monitoring results Quarterly report) (routine Results testing Quarterly report) (routine Results from complaints register Daily (routine report) from diesel vehicle emission Departments to which Reports should be circulated CTMM departments of landuse planning, Environmental Health & Environmental Management DEAT GDACE Environment & Tourism Health & Social Development Environment & Tourism Health & Social Development Website(15) CTMM Intranet Local newspapers Environment & Tourism Health & Social Development DEAT DACE Environment & Tourism Health & Social Development DEAT DACE Environment & Tourism Environmental Health 15 Reference will be made on the website to national air quality standards and local air quality guidelines and alert thresholds to inform people's review of the measured air pollution levels. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-13 Frequency Annual (routine report) Content Synopsis of: air quality monitoring data for year diesel vehicle emission testing emission estimates Identification of sources, pollutants and areas of concern Departments to which Reports should be circulated Environment & Tourism Health & Social Development Council DEAT DACE Website Evaluation of progress made with regard to control measure implementation (extent to which controls implemented, emission reductions achieved, air quality improvements realised) 9.5 Public Consultation Approach The public consultation approach proposed for implementation by CTMM is as follows: 9.5.1 Aims and Objectives: • Inform I&APs of the monitoring pollution levels within CTMM on a regular basis. • Allow I&APs an opportunity to comment on the progress of the AQMP. • Allow I&APs an opportunity to voice their concerns with regard to pollution issues. 9.5.2 Media/methods to be considered for use: • Internally maintained complaints register • Air pollution “hotline” • Newspapers • Website • Radio advertisements • Public meetings (get Ward Councillors to take ownership of information distribution such as Air Quality issues) 9.5.3 Designation of an Air Quality Information Liaison Officer Based on the current structure within the CTMM regarding capacity for AQM planning, the feasibility of a designating air quality information liaison officer to be considered by the CTMM is not regarded a priority in the short-term. The current complaints register (as discussed below) should rather be optimised to ensure that the Air Quality Officer automatically is informed of the complaint and what action is required. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-14 The appointment of an Air Quality Information Liaison Officer should be investigated in for the medium- to long-term. It is understood that such an officer would be designated to undertake the following duties (can be an existing liaison officer with other duties): • inventory air quality related complaints received via a designated 'hot-line' for the Metro • coordinate responses to air quality related complaints received - both those received directly and those received by the Service District Regions • collate and disseminate information to newspapers and radio stations • ensure that information is routinely reported for display on the website • organise and facilitate public meetings • assist in the design and implementation of awareness raising campaigns 9.5.4 Complaints Register The Environmental Management Division has developed an electronic complaints register for all environmental concerns. The register allows for the capturing of the following information: • date of complaint received, • the region and suburb, • what type of complaint (viz. air pollution), • the duration of the incident the complaint is for; and, • the type of report that should be generated. The Environmental complaints register automatically allocates a reference number and allows for the indication whether action have been taken, either inspection, notice to be served, legal action, or complaint resolved. It is intended that this register should be automated to inform the Air Quality officer via email regarding a complaint and what action is required. The air quality officer should then reply stating what action has been taken, when it was taken and if the matter has been resolved. A formal written response should be sent out in response to all air pollution related complaint received by each region. This letter will acknowledge that the complaint has been received, and where applicable, indicate what measures were taken. Statistics from the complaints register (e.g. number and types of complaints, % of complaints addressed, etc.) will be collated and reported on a quarterly basis. 9.5.5 Reporting Air Quality Information Air quality information will be made available in local newspapers and on the CTMM website. The frequency and format of such information will be determined in the short-term. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-15 9.5.6 Public Meetings Public meetings will be held every 6 months at a venue central to the majority I&APs. These meeting should be coordinated with other information dissemination events organised by other divisions within the CTMM. The second consideration will be that of availability of safe and secure parking for attendants and the proximity of public transport routes given that many I&AP may not have private transport. Some I&APs will only be able to attend during working hours, and others only after working hours, therefore, it is recommended that two meeting be held on the same day. The first being during working hours and the second being in the evening, allowing I&APs enough opportunity to get the venue after work. The format of the meetings will be as follows: • Introduction and welcome • Presentation of issues that will be raised at the meeting (I&APs should be allowed an opportunity to nominate topics for discussion prior to the meeting, either by fax, post or e-mail. Only written correspondence is allowed to ensure that no misunderstanding of the issues is recorded) • Presentation of: • monitoring results • progress against key performance indicators • progress made with air quality management plan implementation • proposed developments for the following six months • Question relating to the presentation only. • Discussion of topic listed for discussion. • General. • Set date for next meeting. • Closure. Meetings will be advertised at least four weeks in advance to allow I&APs an opportunity to submit topics for discussion and to arrange transport if need be. Advertising of the public meeting is likely to be in the form of: • Invitations sent out to all I&APs identified during the current study and additional I&APs who have registered since the study was completed. • Advertising in the local press. • Advertising on the radio. • Advertisements put up at community centres, libraries and possible churches. 9.6 Air Quality Management System Development - Actions Required A synopsis of the specific actions required and timeframes for establishing and operating the air quality management systems outlined in previous subsections is given in the table below: Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-16 Action: Target Date: Short-term Consolidation of an ambient air quality and meteorological monitoring network, including: the three new stationary stations and the nine mobile stations, and automated data transfer and firstorder validation Consult with industries required to fund ambient air quality monitoring and integration of data from such monitoring into CTMM’s air quality data base Update and integrate the electronic, centrally-accessible complaints register Evaluation and costing of passive diffusive monitoring and biomonitoring campaigns Update of source and emissions data for all major sources (ongoing) Define and implement a schedule for routine reporting Extend ambient air quality and meteorological monitoring network to include 2 additional stations. Possible stations and sites include: (i) stationary site in Western Moot; and (ii) stationary site in Centurion. Arrange, advertise and conduct 6-monthly public meetings Purchase and install Emissions Inventory and Air Dispersion Modeling software Medium-term Investigate the feasibility of designating an air pollution hotline and air quality information and liaison officer duties Collation of source and emissions data for all major sources (ongoing) and initial population of Emissions Inventory software Population of the Air Dispersion Modeling software and simulation of ambient air pollutant concentrations across the Metro June 2006 On-going July 2006 December 2006 December 2006 March 2007 March 2007 July 2007 December 2007 December 2008 December 2008 July 2008 Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 9-17 10 SOURCE QUANTIFICATION AND EMISSIONS REDUCTION MEASURES The main aim in developing an Air Quality Management System is to identify and implement emission reduction measures to improve air quality over a given period of time. Thus, it is important to ensure that the main sources of ambient air pollution impacting on the receiving environment are targeted and that emission reduction measures or strategies proposed are indeed feasible and cost effective. The protocol proposed in the development of emission reduction strategies are as follows: 1. Identify main pollutants of concern 2. Identification of main sources of emissions for each pollutant a. Rank sources of emissions based on emission contributions i. Take into account the quantity of emissions ii. Take into account the frequency of emission releases (temporal patterns in extent of emissions) iii. Take into account the height of emissions releases (i.e. ground level, medium and high elevated sources) b. Rank sources of emissions based on likelihood of human health exposures and impacts on the receiving environment 3. Identification of air pollution reduction strategies a. List and describe possible emission reduction strategies for a specific source and pollutant b. Implementation procedure for each strategy. This should include the following: i. Source description, current “uncontrolled” emission rate and target control efficiency to be reached ii. Identify the person/s responsible for the implementation of the emissions reduction measures iii. Description of emission reduction method iv. Procedures of how it need to be implemented v. Procedures on how to track the emission reduction progress c. Quantification of reduction of ambient concentrations as a result of implementation of each strategy through use of dispersion model analysis d. Cost-benefit analysis of controlling each source with each strategy. Costbenefit analyses should include the consideration of: i. source characteristics (i.e. percentage contribution, height of emission, and exposure index) - to select the sources to be controlled ii. reduction of ambient concentrations as a result of implementation of each strategy - identify most effective strategies for ambient pollution abatement Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-1 iii. technical feasibility of each strategy iv. socio-economic impacts of each strategy - determine the feasibility of strategies within the socio-economic context Emissions reduction strategies should be based on sound information for the quantitative assessment for priority settings and resource allocation. The baseline assessment conducted for the CTMM was done to identify all main sources of pollution within the metro and to determine the main areas of impact associated with these sources and specific pollutants. This study can be seen as a first attempt to determine the status quo of the metro and were limited due to various gaps in information used. At present, the CTMM does not have an effective Air Quality Management System in place and aim to establish this within the short-term (1 to 2 years). This will overcome several of the limitations as noted below: • The baseline assessment conducted as part of the AQMP development attempted a first level emissions inventory for the CTMM. Subsequently, not all sources of emissions and all pollutants of concern were identified and quantified. This hinders the justification of certain emissions reduction measures to be implemented and the progress made by these measures. • Ambient air quality data within the CTMM was sparse, with information obtained from one monitoring station over a short and incoherent period of time. In order to overcome this limitation use was made of various monitoring campaigns conducted within the CTMM over the past few years to achieve a better understanding of the spatial extent of pollution levels. • Due to the limited monitored data available, use was made of a dispersion model to indicate the main areas of impact mainly from criteria pollutants. Use was made of information from the Nedlac Dirty Fuels study (FRIDGE) and included all main combustion sources (i.e. power stations, industrial sources, boilers, vehicle emissions and domestic fuel burning) within the greater Gauteng and Mpumalanga region. This study did however exclude the northern parts of CTMM. • The rigorous assessment of the technical feasibility and socio-economic viability of emission reduction measures was beyond the scope of this study. Close attention was however made to previously conducted national and international studies on the feasibility of measures recommended. In the interim source-specific actions to be undertaken by CTMM will include the quantification of all potentially significant sources and emission reduction measures for major sources already identified (see Section 5). It is intended that priority over the short-term be given to the reduction of emissions of priority pollutants from key sources with the aim of reducing exposures in highly impacted areas, even though a comprehensive AQM system is not yet in place. With source quantification and AQM system implementation to be undertaken in the short-term, facilitating the identification of other pollutants and sources requiring control in the medium- to long-terms. The main sources of emissions identified for emissions reduction consideration over the short- and medium-terms were based on the following: Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-2 • Source ranking based on emissions (emission rates as quantified during the baseline assessment were used) • Source ranking based on potential impacts (consideration was given to the height of release; i.e. low-, medium- and high level releases, and the potential impacts in high population density areas) The three main sources of emissions within the CTMM mainly based on the potential for health risks were identified to be: • domestic fuel burning; • vehicle emissions; and • power generation. Other industrial sources and fuel burning appliances were also included for emission reduction considerations. In addition attention was given to waste disposal facilities, biomass burning and other smaller sources of emissions. 10.1 Domestic Fuel Burning Under the Atmospheric Pollution and Prevention Act (Act 45 of 1965), local authorities were responsible for the regulation of emissions from domestic fuel combustion under the powers conferred by the Minister of the DEAT. According to the AQA, Air Quality Management Plans must address the effects of emissions from the use of fossil fuels in residential applications. Emission reduction strategies for domestic fuel burning are most likely one of the biggest challenges facing national, provincial and local government. 10.1.1 National and Provincial Government Interventions The Department of Minerals and Energy (DME) has published the Energy Efficiency Strategy of the Republic of South Africa in March 2005. This strategy aims to make energy affordable to all and to minimize the effects energy usage has on the environment and human health. The target set out in this strategy for the residential sector is a reduction of 10% in energy demand by 2015, implying an annual reduction of 1% over the next 10 years. It recognizes that much of the energy usage in the residential sector is in the form of biomass burning, specifically in rural areas. Even so, the approach mainly focuses on energy efficiency in higher income areas and setting standards for energy efficient housing also to be applied to state-subsidised housing. Savings can be brought about by incorporating energy efficiency measures (thermal insulation) in new housing, mainly through education and awareness campaigns and standards for housing and appliance labeling. Even though the Energy Strategy does not directly address the problem of domestic fuel burning devises, it does make provision in Phase 1 for research into fossil- and biomass-using appliances, setting of fuel standards and the development of awareness raising programmes. The DME also developed a strategy on Integrated Clean Household Energy that was adopted by the Minister in 2003. The Integrated Clean Household Energy Strategy refers to methods classifiable as refining, replacing and reducing and included the following methods: Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-3 • REFINE combustion & appliances • Top-down ignition method “Basa Njengo Magogo” • Stove maintenance programme • Replacement of mbawula/old conventional stoves • REPLACE coal with: – Electricity – Low-Smoke Fuels (LSF) – Alternative fuels – gas, paraffin, methanol, etc – Renewable energy e.g. solar • Reduce energy requirements of dwelling • Solar passive designs - new homes • Insulation - existing homes Facing the challenges of changing habitual fire-making methods in low-income residential areas where the main drive is on day-to-day survival, the DME recognises that applying strategies resulting in additional costs are not feasible. Thus the most obvious approach is the promotion of the “Basa Njengo Magogo” method in the short- to medium-term. “Basa Njengo Magogo”, which translates to mean ‘the way in which the old lady lights a fire’, is a method of ignition involving a top down approach to fuel loading in mbawulas and stoves. DME conducted a pilot study in Orange Farm during the winter of 2003, with the following main findings: • 76% of households reported less smoke in their homes; • 67% reported less smoke in the streets after one month of using this method; and, • 99% of the households reported a saving of R26 per week by using this method in comparison to the conventional method (bottom-up fire). To substantiate these qualitative findings, the DME appointed the CSIR in 2004 to conduct an experiment to determine the reduction in particulate emissions associated with the Basa Njengo Magogo method. The main finding of this study was that inhalable particulate matter (PM10) reduced by approximately 80% due to the top-down fire making approach of the Basa Njengo Magogo method. It was also found that this method would result in a fuel consumption reduction of approximately 20%. National rollout of the Basa Njengo Magogo (BNM) technology will occur over the next 12 years (2003-2015). The DME sponsored a BNM project in the EMM settlement of Tembisa. This project was to run from September 2004 to October/November 2005. The project targeted 20 000 households (Scorgie & Watson, 2005). Although housing insulation was initially under investigation it is currently considered by the DME to be too costly for implementation at brownfield sites. Alternatives being investigated in terms of stove maintenance and replacement included low-cost options of using appropriate chimney lengths to local stove manufacturing. These alternatives are however also considered costly for brownfield sites. Interventions comprising coal replacement that are supported by DME include electrification and the development of a low-smoke fuel. On-going electrification of households is Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-4 supported. A National Standard for Low Smoke Solid Household Fuels is being compiled by the DME and a pilot facility proposed for the testing of such fuels. It is however expected that the development and introduction of a LSF to the household sector will take at least another five years (personal communication, Tony Surridge, DME, 28 July 2004). The Department of Housing is currently undertaking research to support the possible compilation of a policy on integrating energy efficiency measures into housing developments. Research previously funded by the DME is being sourced by this department to assist with the development of this policy. The low-cost and no-cost energy efficient housing measures published by the International Institute for Energy Conservation (IIEC) are being implemented in certain provinces on a project-by-project basis. Measures which are currently being implemented within local cities include: • smokeless mbawulas (City of Johannesburg) • top-down ignition method • air quality monitoring for awareness raising purposes • energy efficient housing projects (on case study basis) 10.1.2 Proposed Emission Reduction Strategies It is considered crucial that national, provincial and local initiatives aimed at reducing household fuel burning are conducted in a coordinated manner. The initiatives prioritized for implementation by CTMM will therefore reflect the priorities of national departments such at DME and the Department of Housing. The main strategies over the short-term and mediumterm are outlined in Table 5-1. 10.1.3 Proposed Emission Reduction Strategies It is considered crucial that national, provincial and local initiatives aimed at reducing household fuel burning are conducted in a coordinated manner. The initiatives prioritized for implementation by CTMM will therefore reflect the priorities of national departments such at DME and the Department of Housing. The main strategies over the short-term and mediumterm are outlined in Table 6-1. Table 10-1: Emissions reduction strategies for Domestic Fuel Burning to be implemented by CTMM over the short-and medium term. Strategy Short-term (1 to 2 years) CTMM negotiate with the DME and DEAT to sponsor a similar project for Mamelodi and Marabastad as the Tembisa Basa Njengo Magogo (BNM) project. CTMM personnel will have to be involved in the project and will require training from DME in the BNM method of ignition Involve the public and other organization in the education of the BNM method. The National Zoo has indicated their willingness to train school groups on the use of the BNM as part of their Responsible parties Initiation (duration) CTMM EHPs DME July 2006 (18 months) CTMM, DMS, DEAT & Industries July 2006 (18 months) Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-5 Strategy education programme. Nissan SA recommended that a DVD be made on the BNM method to be distributed to all industries as part of staff training and education programmes. Considering the integration of energy efficiency measures in new low-cost housing areas. This should include solar passive designs, better insulation (specifically under tin roofs etc) and research into alternative building materials (such as certain inert waste materials that can be used) Medium term (3-5 years) CTMM to implement the Basa Njengo Magogo project in Soshanguve and Atteridgeville CTMM should continue the surveys of households initiated buy the State of Energy study in order to track progress made by the BNM Projects within the areas where it was launched. This in turn should be reflected in the revised Air Quality Management Plan and State of Energy report Update emissions quantification and impacts predictions (dispersion model) with new information on domestic fuel burning. CTMM to setup an urban air quality dispersion model to simulate pollution concentrations associated with domestic fuel burning emissions. CTMM to facilitate the investigation and identification of suitable alternatives to household fuel burning to look at low-smoke fuels, renewable energy, energy demand management etc.) Responsible parties Initiation (duration) CTMM Housing Division March 2006 (on-going) CTMM EHPs January 2008 – (12 months per settlement) CTMM Air Quality Section CTMM EHPs DME July 2008 (6 months) CTMM Air Quality Section January 2009 (on-going) CTMM Air Quality Section January 2009 (on-going) CTMM Air Quality Section January 2009 (on-going) The energy efficiency measures intended for implementation in the short- and medium-terms are in line with the DME Energy Efficiency Strategy (March 2005) and the National Energy Regulator’s Regulatory Policy on Energy Efficiency and Demand Side Management (EEDSM) for South African Electricity Industry (May 2004). The DME policy provides specific targets for reducing energy demand by 2014 within given demand sectors, with an overall target of 12% reduction in consumption. The identification of renewable energy alternatives is in line with the White Paper on the Promoting of Renewable Energy and Clean Energy Development, Part One, Promotion of Renewable Energy, Department of Minerals and Energy, Pretoria, August 2002. 10.2 Road Transportation Part of the Atmospheric Pollution Prevention Act (APPA) No.45 of 1965 makes provision for the control of air pollution by fumes emitted by vehicles. Regulations concerning the control of noxious or offensive gases emitted by diesel driven vehicles were published in the government gazette on the 20th of September 1974. These regulations prescribed the procedure, known as the free acceleration test, of performing an opacity test using a BPHartridge meter. The Environmental Health Division of CTMM developed a policy for diesel vehicle monitoring. Each of the eight Chief Environmental Health Practitioners is responsible for the diesel vehicle monitoring in their respective regions. Monitoring is expected to be done according to approved work procedure for at least 2 days per year per region. Legal action should be taken against the owner of a vehicle exceeding the prescribed limits in an area. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-6 The Chief: Air Quality Management in the Environmental Health Programmes sub-section is responsible for the maintenance and calibration of all equipment. After discussions with some of these Environmental Health Practitioners, it was clear that the 2 days per year are not sufficient to monitor emissions from vehicles. 10.2.1 National and Provincial Government Strategies The Joint Implementation Strategy for the Control of Exhaust Emissions from Road-going Vehicles in South Africa was published in the Government Gazette of 12 December 2003 to be a strategy of DEAT in collaboration with DME. The main measures recommended as part of this final draft are as follows: • stipulation of Euro technologies for new petrol-driven vehicles (Euro 1 by 2004, Euro 2 by 2008, Euro 4 by 2012); • stipulation of ECE technologies for new diesel-driven vehicles (within the 2006 to 2012 period) • reduction in the sulphur content of unleaded petrol to 500 ppm from 2004 and to 50 ppm from 2010 • restriction of the benzene content in petrol to 1% and aromatic content to 35% from 2010 • prohibition of the addition of lead from 2006 and the addition of manganese to unleaded petrol from 2006 and in lead replacement petrol from 2008 • reduction in the sulphur content of diesel to 500 ppm from 2006 and making available of a second diesel grade with a maximum sulphur content of 50 ppm on a voluntary and selective basis. Diesel with a maximum sulphur content of 50 ppm to be made nationally available by 2010 In the event that the above measures are implemented within the next ten years substantial changes in the nature and extent of vehicle emissions would be anticipated. National approaches to legislative control have internationally included: • vehicle technology changes; • emission limits; • enforced implementation of tailpipe control equipment; • accelerated retirement of vehicles (may also be implemented through market incentives of disincentives); • changes in fuel composition and properties; and • introduction of inspection and maintenance programmes. The stipulation of vehicle technology changes and fuel composition changes are evident in the DEAT/DME Draft Strategy outlined above. The impending Air Quality Act also makes provision for the Minister or Provincial MECs to declare vehicles or a certain category of vehicles as a ‘controlled emitter’ with emission limits and related monitoring requirements set for such emitters. Furthermore the impending Act makes provision for the declaration of a substances or a mixture of substances as a ‘controlled fuel’ with the potential for standards to be established for the use, manufacture, sale, composition (etc.) of that fuel. Alternatively Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-7 the manufacture, sale or use of the controlled fuel could be prohibited. These clauses within the impending Air Quality Act readily facilitate the regulation of liquid and solid fuels by national and provincial governments. In addition to legislative controls, various countries are implementing transportation management measures to reduce vehicle emissions. Such measures are typically implemented at a local government level and include: • Transportation alternatives to single-occupancy vehicles, e.g. encouraging carpooling; promotion of energy efficient and easily accessible public transport; construction and dedication of bus or high-occupancy-vehicle (HOV) lanes in congested areas; encouragement and funding of bicycle projects; employer-based travel reduction programmes. • Transportation management and planning, e.g. traffic calming measures; traffic light synchronization; parking management; congestion charging schemes. • Land use development and urban design measures; e.g. design of compact cities; shifting of growth to the urban core by realigning housing and transportation subsidy systems. The Gautrain Rapid Rail Link, which is one of ten Spatial Development Initiatives of the Gauteng Provincial Government, was announced in February 2000 and is in line with the aims of the National Land Transportation Act of 2000. The rail will link the City of Tshwane with Midrand, Joburg, Ekurhuleni and Rhodesfield (Kempton Park). From a CTMM perspective, this project is expected to reduce the use of private vehicles, particularly single occupancy vehicles travelling on the congested N1 highway and R21 main road. The proposed pricing of tickets makes it unlikely that the Gautrain will draw passengers from existing public transportation systems such as taxis. The projection of buffer zones or set back distances from roadways for specific land uses represents a measure implementable in the short-term. It should be noted that this measure is aimed at reducing the potential for impact of vehicle emissions rather than the restriction of emissions. In air quality impact assessment studies being undertaken for proposed regional and national roadways, buffer zones in excess of the servitude normally designated for such roadways have been recommended. Such set back distances were based primarily on the predicted NOx, CO and diesel particulate air concentration levels. 10.2.2 Proposed Emission Reduction Strategies Collaboration between local, provincial and national government is required to secure the effective regulation of vehicle emissions. National government is primarily responsible for legislative controls with transportation management measures most frequently being implemented by provincial and local government. Transportation management measures and emission testing strategies by local authorities are likely to be more successful if implemented uniformly across neighbouring cities and metros. Thus one of the main commitments from CTMM must be to form a close relationship between the City of Joburg and EMM, and the Gauteng provincial departments in developing an Integrated Transport Plan (ITP). Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-8 Critical to the success of the implementation of any emission reduction strategies within CTMM is the relationship between various departments within the metro. Transport planning will directly influence the strategies as laid out in the Air Quality Management Plan and visa versa. These strategies are also influenced by decisions in land-sue planning and housing divisions. This is already evident in the poor planning strategies within the western parts of Centurion where the development of numerous cluster complexes along with insufficient road networks result in the increasing congestion of traffic during peak morning and afternoon hours. This directly influences the air quality through enhanced tailpipe emissions of particulate matter and increased re-entrainment of dust on roadways. Unless this relationship is recognised and channels of communication established between local and regional agencies responsible for land use planning, air quality management and transportation planning, air quality management in unlikely to succeed Local governmental departments tasked with air quality management in the UK have found that the successful management of vehicle emission can only be achieved by means of the integration of air quality considerations into Local Transport Plans (LTPs) (Woodfield et al., 2004). Similar experiences are documented for the US and various Asian and European countries. It is therefore recommendable that the Environment and Tourism Department aim to use existing transportation planning processes for the achievement of vehicle emission reductions. Emission reduction strategies proposed over the short- and medium-terms are provided in Table 6-2. Table 10-2: Emissions reduction strategies for Transportation to be implemented by CTMM over the short-and medium term. Proposed Strategy Responsible parties Initiation (duration) Short-term (1 to 2 years) CTMM to establish an Inter-departmental Transport Liaison Group January 2006 CTMM (ITLG) between the Environmental Health, Environmental (6 months to divisions Management, Transport, Housing and Land-use planning divisions. establish, Coordinated This group must meet every month to establish information sharing thereafter onby Air Quality systems and subsequently the implementation of short-term going) Section measures. The Integrated Transport Plan should be used as basis and must be updated continuously. It is recommended that the Inter-departmental Transport liaison Group contact the same Groups within EMM and Joburg to learn form their experience and to establish an inter-municipal CTMM ITLG June 2006 relationship for future planning purposes and to standardise GDACE (on-going) procedures within the Gauteng Province. GDACE can be contacted to coordinate these meetings which should take place quarterly. Current diesel vehicle testing procedures to be standardised and CTMM expanded to be conducted once a month, with a target number of Transport January 2006 vehicles to be tested. The CTMM fleets should be tested first. The Division & (on-going) results should be reported to the Transport division who needs to ITLG report to the ITLG. Get the corporation of the Metro Police to support the diesel vehicle testing CTMM to design a more comprehensive and effective vehicle CTMM January 2007 emission testing programme for implementation in the medium-term Transport (12 months) in consultation with the City of Joburg and EMM and the Gauteng Division Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-9 Proposed Strategy province (1). This may include a feasibility assessment to conduct vehicle emission testing at the licensing facility as part of vehicle license renewal. The funds from fines can be used for research into cleaner technology. Reporting of monitored data from the mobile stations located near main highway intersections (see Section 5) to the Transport Division and Inter-departmental Transport Liaison Group to inform transport planning and highlight air quality issues. Determine how the transport model currently used by the CTMM Transport Division (EMME/2) can be utilized to better inform transportation emissions calculation and how this can be used by the Air Quality Management Section. Establish the capacity within the Transport division required to update this model annually with relevant traffic count data. Determine how Metro police can be used to assist in gathering this type of information. Research should be encouraged on cleaner transportation technologies through liaising with the Transportation Planning project manager on the Clean Transport Technology Project via the ITLG. CTMM will also have to liaise with GDACE to integrate findings from their cleaner technologies initiative and to avoid duplication. Medium term (3-5 years) Implementation of diesel and vehicle emissions testing procedures developed during the short-term. Implementations of the customized EMME/2 traffic model for providing emissions data for the Air Quality Section if proofed to be feasible. Implement systems to update vehicle count data annually as determined during the short-term Responsible parties Initiation (duration) CTMM Air Quality Transport ITLG April 2006 (on-going) CTMM Air Quality Transport ITLG April 2006 (on-going) CTMM ITLG GDACE June 2006 (on-going) CTMM ITLG January 2008 (36 months) CTMM Air Quality Section CTMM Transport Division January 2009 (every 3 years) January 2008 (annually) CTMM to liaise and encourage the Airforce to conduct an emissions CTMM Air inventory and impact assessment for all their airports within CTMM. January 2008 Quality (on-going) The data should be incorporated into the CTMM emissions Section database. CTMM to liaise with Transnet and private rail companies on CTMM Air quantification of emissions emanating from railroad, especially January 2008 Quality (on-going) within the Capital Park area. The data should be incorporated into Section the CTMM emissions database. CTMM Air CTMM to setup an urban air quality dispersion model to simulate January 2009 Quality pollution concentrations associated with vehicle emissions – also (on-going) Section assessment of peak traffic periods Dispersion modeling results to be communicated to the Transport CTMM Air January 2009 Division to assist in transport strategy development and Quality (on-going) implementation Section Based on information received from various tools the aim should be to increase on-and off- ramps onto highways from congested roads, identify development of alternative routes, bicycle lanes to be CTMM introduced, Bus lanes to be increased (encourage private bus January 2008 Transport companies to bus services on main routes using bus lanes thus no (on-going) Division traffic congestion & will encourage people using own transport to use this service). Encourage these to use CNG and/or LPG driven busses. Notes: (1) This will not be required if DEAT establishes new regulations pertaining to vehicle emissions testing within the next 2 years under the Air Quality Act of 2004. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-10 10.3 Industrial Sources For the purpose of this document industrial sources include all scheduled and nonscheduled processes, and energy generation activities within the CTMM. According the Air Quality Act 2004 16 local authorities will be charged with implementing the atmospheric emissions licensing system of all listed activities as defined by National Government. Listed activities are defined as activities resulting in atmospheric emissions which may have a significant detrimental effect on the environment and health. All sections pertaining to this responsibility were however excluded from the current implementation of the act. Subsequently the requirements for scheduled processes as stipulated under the APPA still prevail. This implies that all industries undertaking scheduled processes in terms of the APPA are controlled by CAPCO through Best Practicable Means (BPM) using permits. Scheduled processes referred to in APPA, are processes that are expected to emit a significant quantity of pollutants and include large combustion sources, smelting, electricity generation and inherently dusty industries. Listed activities under the AQA are expected to include current Scheduled Processes with the possibility of additional sources added to the list. A limitation of the permitting approach under APPA is that insufficient attention was paid to the potential of cumulative impacts from industrial sources located within close proximity of each other. This has resulted in instances where unacceptable ground level concentrations occurred even though industries were within compliance of their permit stipulations. Under the AQA the focus has shifted to the receiving environment approach with the development of emissions reduction strategies to ensure compliance with ambient air quality objectives. Non-scheduled processes such as small-scale non-domestic fuel burning appliances (e.g. boilers capable of burning fuel at a rate of <10 tons per hour) are currently controlled by local authorities in terms of Part III of the APPA. Under the AQA the Minister or MEC may declare an activity(s) or appliance a controlled emitter with relating permissible emission standards. The minister or MEC may also declare a substance(s) which is used as fuel in a combustion process a controlled fuel with relating standards for use, manufacturing and allowable concentrations for that fuel. 10.3.1 Scheduled Processes Scheduled processes within the CTMM have been listed and discussed in the Background Information Document (Liebenberg-Enslin & Petzer, 2005). A total of 103 permits have been issued for scheduled processes in the CTMM, including power generation activities. The emissions inventory was taken from the National Emissions Inventory for 1995 and was updated where information was available. Two power stations are owned and managed by the CTMM. 16 The National Environmental Management: Air Quality Act 2004 (Act No. 39 of 2004) commenced with on the 11th of September 2005 with the exclusion of sections 21, 22, 36 to 49, 51(1)(e), 51(1)(f), 51(3), 60and 61. It was published in the Government Gazette on the 9th of September 2005. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-11 Very little information was available on control technology implemented by these scheduled and non-scheduled processes. The following industries have control equipment in place or are currently undertaking measured to reduce emissions: • PPC Hercules, one of the prominent industries within CTMM, has an electrostatic precipitator on the conditioning tower to reduce particulate emissions from the two cement kilns. Particulate emission rates from the stacks are measured and reported on a regular basis to verify the control efficiency of the equipment. • The Coke & Chemicals division of Mittal Steel Pretoria plans to upgrade their existing Gas Purification Plant to reduce H2S and ammonia emissions. The off-gas from the Coke Oven Gas Plant is utilised in other areas of the works which will also positively influence emissions reduction from these sources. This will most likely be implemented within 2 to 5 years (medium-term). • SABRIX, a clay manufacturer in the western “Moot” area, implement fulltime water tankers to reduce fugitive dust emissions from the internal road surfaces. • Both Pretoria West and Rooiwal Power Stations have control equipment in place to minimise particulate emissions. Pretoria West currently operates centrifugal grit arrestors to reduce particulate emissions. No stack monitoring has been conducted to verify the control efficiency of the control equipment. Bag filters are in use at Rooiwal Power Station and isokenetic tests at one of the boilers conducted in 2003 confirmed 99.9% control efficiency. 10.3.2 Non-Scheduled Processes Various smaller industrial and commercial operations are currently operational within the CTMM. This would include activities such as spray painting, sand blasting, dry cleaning, small boiler operations and incineration process, materials handling etc. Since the municipality is responsible for the control of small boiler operations (<10 ton per hour), information for these sources was obtained. A total of 281 fuel burning appliance certificates have been issues by the CTMM to date. No information was available on the actual amount of fuel used, the frequency and duration of operation, and control equipment in place at each of these locations. Coal-fired boilers were identified as the most significant industrial sources grouping during the FRIDGE study. It was estimated that this source group accounted for 4% of the RHA and mortality cases. No information was available on other smaller industries within the CTMM and hence most of these operations are not monitored. This was a limitation identified during the baseline assessment conducted as part of the AQMP development process and will be addressed in the short- and medium-term. 10.3.3 Proposed Emission Reduction Strategies Recommended strategies for scheduled and non-scheduled processes are provided in Table 6-3. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-12 Table 10-3: Recommended emission reduction strategies for scheduled and nonscheduled processes within the CTMM. Responsible parties Proposed Strategy Initiation (duration) Short-term measures Update of current CTMM emissions inventory • Scheduled processes need to provide permit certificates and have to demonstrate compliance with permit conditions. • Non-scheduled processes need to provide process descriptions and any available emissions information. • CTMM must identify industries and commercial/institutional concerns undertaking combustion processes to compile emissions inventories and report source and emissions data to the Metro. CTMM will have to compile questionnaires to be sent out to these industries. Review current emission reduction strategies reported to ensure it is in line with best available international practice • CTMM to encourage industries to investigate implement best available control technology and • Power Stations to investigate and implement feasible desulphurisation options. Use coal with lower sulphur and ash content. Develop relationships with National and Provincial Government, and related CTMM departments (i.e Environmental Management & Environmental Health). • • Until the relevant sections of the AQA pertaining to emission licences have commenced, CAPCO need to inform CTMM of any new scheduled process developments within CTMM or any changes to existing permits. Town planning division needs to inform the Air Quality section of any new industrial development zones and/or applications. CTMM Air quality section Environmental Health January 2006 (12 months) January 2006 (12 months) DEAT CAPCO January 2006 (24 months) CTMM Air quality section January 2006 (24 months) CTMM Air quality section DEAT CAPCO January 2006 (24 months) GDACE • All EIA information pertaining to industrial development must be obtained from GDACE. CTMM must update the existing database on fuel burning appliances to include: • location of appliance • company name and contact details • type of appliance • type of fuel in use • sulphur and ash content of fuel (where appropriate) • quantity of fuel used • scheduling of operation (continuous, intermittent - two hours per day, etc.) • control measures in place and control efficiency of these measures • stack parameters (height, inner stack diameter, gas exit temperature, and gas exit velocity or volumetric flow) CTMM Air quality section & OHPs January 2006 (24 months) Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-13 Proposed Strategy • stack monitoring data (where available) Any new fuel burning appliances must be reported to the metro Medium-term measures Based on the outcome of the DEAT emissions licence review (2) project , review permits based on updated emissions inventory and information on control equipment Set specifications on combustion efficiency applicable to all new coal fired boilers in collaboration with the project initiated by DME (3) . The project looks at fuel switching, abatement technology implementation, and improvements in energy efficiency. Liaise with Eskom on demand side management measures applicable to the commercial and industrial sectors. Electricity generated by Pretoria West power station can be replaced by residential gas usage. Investigate the potential for introducing alternative tariff structures for the purpose of encouraging on-site co-generation and the introduction of renewable energy. Waste gas streams from industries to be utilised as energy source – possible incentives. Investigation of the potential for introducing market incentives and disincentives for the purpose of encouraging emission reduction by industrial and power generation processes. Examples include: • Iron & Steel manufacturing: waste gas recovery and use &improve fugitive dust emissions; • Cement manufacturers: minimising fuel usage by preheating and precalcination (to the extend possible given the existing kiln system configuration) & heat recover from waste gas • Initiation (duration) CTMM Air quality section DEAT January 2008 (36 months & on-going) CTMM Air quality section January 2008 (36 months & on-going) DME CTMM Air quality section DME & Eskom January 2008 (36 months & on-going) CTMM Air quality section Eskom January 2008 (36 months & on-going) CTMM Air quality section Environmental Management Environmental Health January 2008 (36 months & on-going) Clay brick manufacturers: fuel switching from coal to gas This process will be enhances by forming a relationship between the main industrial role-players in the metro and CTMM CTMM should investigate the feasibility of decommissioning the Pretoria West power station and replace it with gas reticulation network CTMM to setup an urban air quality dispersion model to simulate pollution concentrations associated with vehicle emissions – also assessment of peak traffic periods CTMM to update emissions inventory to include emission reduction due to measures implemented during the short-term. CTMM should develop a system to liaise with DEAT and Gauteng government to ensure CTMM are up to date with any new developments on the control of industrial and commercial sources. The proposed National Air Quality database should be investigated to ensure information generated by CTMM can be incorporated into this database and information from this database can be used. Notes: Responsible parties CTMM Air quality section Environmental Management CTMM Air Quality Section January 2008 (36 months & on-going) January 2009 (on-going) (1) Criteria to be used by CTMM to determine which operations are required to undertake emissions inventories are provided in Appendix. (2) DEAT has called for tenders for the Atmospheric Licensing Project which aims to capture all existing Registration certicicates and the review thereof. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-14 Possible emission reduction measures to be implemented include: • Iron & Steel manufacturing emissions • Cement manufacturers - minimising fuel usage by preheating and precalcination (to the extend possible given the existing kiln system configuration) heat recover from waste gas • Clay brick manufacturers 10.4 - waste gas recovery and use &- improve fugitive dust - fuel switching from coal to gas Waste and Disposal Treatment Medical waste incineration is controlled by the Department of Health. Incineration also represents a 'Scheduled Process' in terms of the second schedule of the Atmospheric Pollution and Prevention Act, Act 45 of 1965 and as such requires a permit to operate from the DEAT. GDACE is also involved in the inventorying of incinerator operations and in undertaken inspections on the medical waste incinerators operating within CTMM. In terms of Air Quality Act, incineration will be declared a ‘listed activity’ with District Municipalities and Metropolitan Municipalities being made responsible for the issuing, review and revision of such licenses. These sources falls under the previous section on industrial sources. CTMM currently operates 9 general waste disposal sites. The Rosslyn landfill site, which is a privately owned site, has been proposed to be upgraded to a hazardous waste facility but no approvals for this has yet been given. Typical problems associated with landfill operations in South Africa which are associated with atmospheric emission potentials include: fires, inadequate daily cover practices, acceptance of hazardous waste types by general landfill operations. Section 20 of the Environment Conservation Act, 1989 (Act 73 of 1989) stipulates that no person may dispose of waste unless under the authority of a permit issued by the Minister of Water Affairs and Forestry. Waste disposal sites are regulated by the Department of Water Affairs and Forestry (DWAF) by means of the Minimum Requirements for the Waste Disposal by Landfill (Second Series, 1998). Depending on the landfill classification and size landfill requirements may include: • Various types of landfill lining and capping systems • Operational controls, e.g. daily cover of work surface with cover material • Gas monitoring and management systems • Restrictions on ambient methane concentrations 10.4.1 National and Provincial Government Strategies DWAF and GDACE have started to initiate coordinated programmes to address such noncompliance issues. The evaluation checklist used by both DWAF and GDACE personnel for site inspection purposes are both based on the Minimum Requirements. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-15 In future responsibility for permitting landfill sites will be transferred from DWAF to DEAT. With the AQA it is likely that local government will take more responsibility for the regulation of landfill operations in future. (Waste management is a core mandate of local government according to Schedules 4b and 5b of the Constitution.) It is also notable that the DWAF is currently in the process of revising its Minimum Requirements document and that the revision is expected to deal more holistically with the management of atmospheric emissions and impacts of landfill operations. The National Strategy on Waste Management, which advocates a tiered approach to waste management with waste prevention, treatment and recycling being prioritized, also needs to be taken into account in the identification of emission reduction measures. The Environmental Health Division of CTMM has drafted a Waste Minimisation Strategy in June 2005 with the main objective to minimise waste within the CTMM. The aim is to encourage the reduction, re-use, and recycling of waste by educating residents to be environmentally responsible and involving other stakeholders (Aphane & Nkosana, 2005). 10.4.2 Proposed Emission Reduction Strategies Recommended strategies for waste facilities are provided in Table 6-4. Table 10-4: Recommended emission reduction strategies for waste disposal facilities within the CTMM. Proposed Strategy Short-term measures CTMM to require all waste disposal facilities to meet DWAF minimum requirements. Large general sites not meeting the DWAF requirements should provide CTMM with a speciated substance emissions inventory based on surface gas network sampling, dispersion modelling results showing predicted impacts together with a health risk screening assessment and odour assessment. CTMM should require a quantitative health risk to be undertaken should the reported results indicate the potential for health risks. Finalisation and implementation of the Waste Minimisation Strategy. The Environmental Health Division should report quarterly on the progress on the implementation of the strategy and provide information on the quantities and waste streams to each facility. CTMM should provide residential bins for segregation of domestic waste (i.e. glass and other). Responsible parties Initiation (duration) CTMM Environmental Health CTMM Environmental Health January 2006 (12 months) CTMM Environmental Health January 2006 (24 months) CTMM Environmental Health January 2007 (on-going) Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-16 Responsible parties Initiation (duration) CTMM Environmental Health Air Quality Section January 2006 (12 months) CTMM Environmental Health January 2007 (12 months) Proposed Strategy Sewage and wastewater treatment facilities to compile emissions inventories, commission ambient air quality monitoring, undertake impact and risk screening studies. Undertake health risk assessments should the findings of he screenings studies indicate a potential for such a risk. This should be reported to the CTMM annually. CTMM to update emissions inventory with monitored and estimated emissions from landfill sites and wastewater and sewage treatment works. Medium-term measures The Waste Minimisation Strategy proposes education of the public and including stakeholders. This can be done in collaboration with other environmental awareness campaigns. CTMM could publish tips on waste recycling and reduction on its website and on billboards to inform and educated the public. Determine additional waste segregation and recycling strategies applicable for implementation within CTMM. CTMM Environmental Health January 2008 (36 months & CTMM Air quality section DEAT CTMM Air quality section PPC CTMM Air Quality Section CTMM Air Quality Section January 2008 (36 months & on-going) January 2008 (36 months & on-going) Investigate alternative waste treatment and disposal options. The cement industry can be approach to investigate the feasibility of hazardous waste incineration at cement kilns. CTMM to setup an urban air quality dispersion model to simulate pollution concentrations associated with waste disposal facilities and wastewater and sewage treatment works. CTMM to update emissions inventory with monitored and estimated emissions from landfill sites and wastewater and sewage treatment works. 10.5 on-going) January 2009 (on-going) January 2009 (on-going) Mining Activities There are a total of 27 mines in operation within the CTMM, excluding various smaller sand quarries not listed. These mining operations are almost exclusively quarries operated by means of opencast or surface mining techniques which are notorious for the generation of dust. 10.5.1 National and Provincial Government Strategies Previously under the Atmospheric Pollution Prevention Act, the Chief Air Pollution Control Officer (CAPCO) of the DEAT was responsible for the control of dust from industry and waste dumps. Dust control from mine dumps was the result of consultation between the Government Mining Engineer and CAPCO. The control of dust was undertaken using best practicable means through notice in writing. Powers for dust control have selectively been delegated to local authorities within designated dust control zones. Under the National Environmental Management: Air Quality Act of 2004 it stipulates that all sources should be addressed as part of the Air Quality Management plan. This includes point- and non-point sources. Section 32, Chapter 4 of the AQA states that the Minister or Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-17 MEC may prescribe measures for the control of dust in specified places or areas, steps that must be taken to prevent nuisance by dust; or other measures aimed at the control of dust. In Section 33 reference is made to the ceasing of mining operations where a mine has to notify the Minister 5 years prior to closure, clearly stating plans for rehabilitation and prevention of pollution of the atmosphere by dust after those operations have stopped. In terms of Section 28 of the National Environmental Management Act of 1998 significant or potentially significant environmental impact must be “investigated, evaluated and assessed” and further “every person who, causes, has caused or may cause significant pollution must take reasonable measures to prevent that from occurring, continuing to occur, continuing or recurring”. In terms of Section 28 the CTMM may request mining companies with potentially significant impact to air quality to firstly assess and monitor their impact and secondly to take reasonable measures to prevent significant impact on air quality. A summary of air quality relevant aspects of the Minerals & Petroleum Resources Development Act of 2004 is set out below. Salient points applicable to air quality management include certain of the requirements that mines have to meet in order to ensure the conversion of “old order” mineral rights to “new order” mineral rights. • Status of mining authorisations and EMPR approvals • • Standard of EMPR and commitment of rehabilitation objectives • • The EMPR should define environmental and rehabilitation objectives, i.e. commitments with respect to operational control and rehabilitation objectives and standards. EMPR Compliance to commitments and requirements of the DME approved EMPRs. • • All operating mines and quarries need an Environmental Management Programme Report (EMPR) detailing a programme which the mine commits to undertake to manage its impact on the environment including air quality. This is mandatory for all mines. A formal assessment and report on the status of compliance to EMPR commitments in terms of operational control, rehabilitation objectives and standards is required to convert mineral rights. Determination of the financial quantum as required by the Mineral and Petroleum Resources Development Act of 2004 • The financial quantum is defined as the costs based on the approved EMPR and closure plan and shall include a detailed itemisation of all actual costs required for: • premature closure regarding to the rehabilitation of the surface of the area, the prevention & management of pollution to the atmosphere, and the prevention & management of pollution of water & soil. • decommissioning and final closure of the operation; and, • post-closure management of residual and latent environmental impacts. 10.5.2 Proposed Emission Reduction Strategies Recommended strategies for other sources are provided in Table 6-5. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-18 Table 10-5: Recommended emission reduction strategies for mining operations within the CTMM. Proposed Strategy Short-term measures CTMM must require representation on the inter-departmental committee tasked with the regulation of mining activities Require mining companies to provide CTMM with emissions inventories for their operations, including mineral processing plants. All mines in close proximity to residential areas to implement dust fallout monitoring networks. Results must be reported monthly to the mine management and 6-monthly to the CTMM. All opencast mines to compile and implement comprehensive dust management plans as part of their EMPRs and report this to CTMM. Responsible parties CTMM t DWAF, DME & GDACE CTMM Air Quality Environmental Management CTMM Air Quality Environmental Management CTMM Air Quality Environmental Management Initiation (duration) July 2006 (on-going) January 2007 (12 months) January 2007 (12 months) January 2007 (12 months) Medium-term measures CTMM request that DME ensure all mines: • have approved EMPRs, • can demonstrate compliance with EMPR commitments and National ambient air quality standards • have determined the financial quantum and provide for the prevention & management of air pollution CTMM Environmental Management DME & GDACE July 2008 (on-going) • fines for mines not complying with the EMPR requirements All mines closing must comply with their closure commitments, specifically with dust management plans and rehabilitation objectives CTMM to setup an urban air quality dispersion model to simulate pollution concentrations associated with fugitive dust from mining facilities CTMM to update emissions inventory with monitored and estimated emissions from mining sites. Also to include implemented mitigation measures and associated reductions 10.6 CTMM Environmental Management DME & GDACE CTMM Air Quality Section CTMM Air Quality Section July 2008 (on-going) January 2009 (on-going) January 2009 (on-going) Other Sources Other sources that rose concern mainly form the public within CTMM include: • Veld fires; • Tyre burning; • Agricultural emissions (such as wind blown dust from open areas); • Vehicle entrainment on unpaved roads, and, Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-19 • Railway transport. 10.6.1 Proposed Emission Reduction Strategies Recommended strategies for other sources are provided in Table 6-6. Table 10-6: Recommended emission reduction strategies for other sources within the CTMM. Proposed Strategy Short-term measures Identify and quantify emissions from other sources, i.e. vehicle entrainment of unpaved roads, agricultural activities (i.e. land tilling), veld fires, tyre burning, and railway emissions. Establish routine data retrieval mechanisms for the purpose of updating the emissions inventory (e.g. Fire Departments - request data be kept on locations of veld fires and extent of areas burned). Rendering plants treating waste from abattoirs should provide an inventory of waste received and treatment methodologies. Emissions should be quantified for the facilities and provided to CTMM to be incorporated into the emissions database. Control the burning of grass by municipal worker's and contractors along highways and elsewhere. Support national legislation aimed at controlling copper wire burning for the purpose of wire stripping Responsible parties CTMM Air Quality Section CTMM Air Quality Section CTMM Air Quality Section CTMM Air Quality Section CTMM Air Quality Section Initiation (duration) July 2006 January 2007 January 2007 July 2006 July 2006 Investigate the use of by-law implementation for the purpose of: • Tyre burning, • controlling trackout from construction sites, • stipulating the need for dustfall monitoring and reporting of results during large-scale construction and demolition projects Expand and enhance the Environmental Health one-Stop Service and electronic complaints register to feed into Management Information System. Ensure action procedures for incidences of tyre burning and uncontrolled veld fires Establish a Communication Plan to underpin the AQMP. This should include strategies for disseminating relevant Air Quality Related information to the public. Make use of private and commercial sectors in distributing information (i.e. National Zoo’s Education Plan, Industry Staff Training Programmes, Media, Billboards, etc.) Medium-term measures Identification of emission reduction measures for other sources predicted on the basis of the quantitative emissions inventory and in-house atmospheric dispersion modelling or external studies to be significant in terms of health risks or nuisance impacts. CTMM Air Quality Section July 2006 CTMM Air Quality Section OHP July 2006 CTMM Air Quality Section July 2006 CTMM Air Quality Section July 2006 Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 10-20 11 RESEARCH INITIATIVES In order to ensure the effective implementation of the Air Quality Management Plan various research efforts will need to be undertaken internally by CTMM (Table 6-.1). The finalisation of permissible timeframes for compliance with local air quality objectives will, for example, require that the current pollutant concentrations and contributing sources to such concentrations be assessed and the feasible implementation periods for abatement measures identified. The scheduling of such research efforts will frequently be dependent on the timeframe for putting in place certain air quality management tools (e.g. monitoring, modelling). These timeframes were outlined in Sections 3 and 4. Table 11-1: Research initiatives recommended for implementation in the short- and medium-term Research Required Purpose Assess the problems and challenges faced by the City of Joburg and EMM in the implementation of their AQMPs CTMM should learn from the experience from the neighbouring metros to fast track their AQMP implementation Determine whether the existing traffic model could be used to estimate vehicle emissions based on locally developed emission factors Even though CTMM cab request emission inventories to be developed by industrial sources and mines, CTMM will have to quantify emissions from remaining sources inhouse Responsible Schedule CTMM Air Quality Section Jan 2006 – June 2006 CTMM Air Quality & Traffic Division July 2006 – June 2007 CTMM Air Quality July 2006 – June 2007 CTMM Air Quality & Environmental Health July 2006 – June 2007 CTMM Air Quality & Environmental Health July 2006 – June 2007 CTMM Air Quality University of Pretoria July 2006 – June 2008 Short-term Assess the existing emissions quantification tools within the CTMM (viz. EMME2 traffic model) and how useful this is for application within the Air Quality Division Determine what emissions quantification methods and tools are available for use by CTMM taking into consideration the specific sources that will have to be quantified by the municipality (i.e. waste disposal facilities, domestic fuel burning etc.) and ensure the potential for changing algorithms to suit local considerations and source types. Assess and cost suitable passive diffusive and biomonitoring methods to determine the potential for their implementation within Tshwane for the purpose of informing air quality management Assess the ability of the current/and proposed software (Opsis system) utilized by CTMM monitoring stations to (i) integrate with other databases such as MS Access or MS Excell, (ii) how this can be established automatically, and (iii) how it compare to other municipality/provincial systems Liaise closely with the University of Pretoria on the development of a tree-dimensional diagnostic Winfield model. Determine whether passive diffusive and/or biomonitoring should be conducted within CTMM – and if so select suitable programmes for such monitoring CTMM must determine how to seamlessly integrate all air quality related data (including monitoring) into one database to be used by various divisions within CTMM, provincial and national government This model will be useful to fill in the gasps where no emeteorlogical data has been recorded (i.e. northern part of CTMM). It can also be used for real-time dispersion modeling and forecasting Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 11-1 Research Required Assessment of (i) current air pollutant concentrations, (ii) contributing sources, (iii) feasible implementation periods for select abatement measures, and (iv) nationally set permissible compliance timeframes (if available) Assess the most suitable placement for the additional 2 stationary monitoring stations based on updated emissions data, results from proposed monitoring network (March 2006) and air pollution complaints received. Annual literature survey on international best practice in Air Quality Management and the new focus areas Purpose Stipulation of permissible timeframes for ensuring compliance with local air quality objectives and national air quality standards The most suitable placement of the 2 additional stationary monitoring stations can be guided by the results from the “soon to be implemented” monitoring network. Since an AQM System is dynamic CTMM should stay in abreast with international trends Responsible Schedule CTMM Air Quality Section July 2006 – June 2007 CTMM Air Quality Nov 2006 – March 2007 CTMM Air Quality July 2006 – on-going CTMM Air Quality July 2006 – June 2007 CTMM Air Quality July 2006 – June 2007 CTMM Air Quality July 2006 – June 2007 CTMM Air Quality Jan 2007 – Dec 2007 CTMM Air Quality On-going starting July 2006 External consultants (possibly via GDACE or DEAT) July 2007 – Jun 2008 CTMM SEED person & Air Quality On-going starting Nov 2005 Medium-term Selection of suitable information and alert thresholds taking into account (i) measured air pollutant concentrations, (ii) international air quality criteria, (iii) the socio-economic and technical feasibility of attaching specific reporting, investigation and mitigation requirements to such thresholds. Identify suitable local PM2.5 guidelines and related compliance timeframes taking into account: (i) local PM2.5 concentrations, (ii) source contributions, (iii) feasible implementation periods for select abatement measures, and (iv) internationally and nationally set PM2.5 standards and compliance timeframes (if available) Source data collation and emission quantification through emission factor application and/or emission modelling and/or acquisition of emission measurements undertaken by sources – this could be a Master’s degree for a post-graduate student Undertaking atmospheric dispersion modelling, with model validation based on monitored results, for the purpose of identifying non-compliance areas in terms of both local air quality guidelines and national standards Annual literature survey on major sources (focusing on the most current information on pollutant types, emission estimation techniques, controls, etc.) Identification of suitable dose-response thresholds for local vegetation types CTMM is involved in the EnerKey project which is a medium- to long term intervention (1) . Finalisation of a set of information and alert air quality thresholds and associate information reporting, investigation and mitigation requirements Stipulation of suitable local PM2.5 guidelines and permissible compliance timeframes Collation of first comprehensive emissions inventory for CTMM Determination of noncompliance zones within CTMM (1) Informing the maintenance and further development of the emissions inventory (2) Reporting of results of surveys on vehicular pollution to Transportation Planning Identification of local air quality guidelines able to protect vegetation This project could be very useful in building design alternatives such as better insulation of low-cost housing, use of solar panels for energy supply etc Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 11-2 Research Required CTMM to form close relationships with the University of Pretoria, UNISA and Tshwane University of Technology. Notes: Purpose Responsible Schedule Utilise post-graduate studies for specific requirements on emissions inventories or research initiatives. Be informed of any relevant research to benefit the CTMM Air Quality Management practices. CTMM Air Quality On-going starting Nov 2005 (1) The University of Johannesburg and the University of Stuttgart has formed the EnerKey project which aims at to promote the sustainable transformation of the urban region of greater Johannesburg by initiating adapted and integrated energy projects as a key factor for sustainability. A workshop was recently held in Johannesburg (3 & 4 November 2005) to determine the main areas of research. The City of Tshwane, the City of Joburg and Ekurhuleni are partners in this research project. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 11-3 12 CAPACITY BUILDING CTMM should develop the capacity and tools to fulfil the requirements of Air Quality Management over the medium- and long-term. This will ensure efficient and cost-effective service delivery with respect to air quality management and planning. These capacities and tools typically include: human resources (staff availability, expertise, experience), facilities, source and ambient monitoring equipment, emission calculation methodologies, hardware, software (etc.). The resources and tools required are informed by national regulatory requirements (available in draft form), international good practice and the current availability and local resources and competence. Requirements given recent draft national regulations and current international good practice are compared with existing resource availability in Table 7-1 and the resultant implications of such requirements noted. ACTION: Staff training programmes will be developed and additional staff acquired (where necessary) to provide the human resources necessary for effective air quality management, including AQMP implementation, review and revision. The DEAT is in the process of defining capacity building requirements and training programmes for provincial and local authorities. CTMM will communicate its specific training requirements to DEAT and will determine DEAT's anticipated timeframe for the provision of such support. In the interim CTMM has identified the need for training on air quality management within the Environmental Health Division. First level training will be provided internally during which individuals will be identified to receive more in-depth training with the purpose of future functions to be fulfilled within the metro. In addition, as part of the tender specifications of the monitoring equipment suppliers training will be given in the short-term on the monitoring equipment operation, calibration, data retrieval and data interpretation and validation. This will ensure that CTMM personnel will manage and operate these monitoring stations within the medium- to long term. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-1 Table 12-1: Resource implications for the City of Tshwane given national requirements and international practice with regard to principle air quality management functions and existing local resource availability Functions Setting of local ambient air quality standards 17 Defining Considerations National Requirements(17) International Good Practice - Provision is made for an effects Setting of multiple levels of based approach, viz. impact standards for ambient air quality is management through ambient common place in Europe & the standards USA. Ambient standards which - Provision is made for the define satisfactory air quality to designation of specific standards for ensure human health and welfare, defined geographical areas the protection of the natural and - National standards are to be build environment, and finally the established by DEAT. prevention of significant decline in - Provision is made for the setting of the quality of air are used. Such more stringent standards by standards provide the objectives for provincial governments. air quality management. Multiple - No provision is made for the levels of standards provide the setting of standards by local basis for both ‘continued authorities. (It is however accepted improvements’ in air quality and for that local authorities may determine long-term planning in air quality local air quality objectives for the management. Although maximum purposes of air quality levels of ambient concentrations are management.) set at a national level, more stringent ambient standards are implemented by metropolitan authorities. Existing Local Resources Resource Implications for CTMM Local air quality objectives have been established during the AQMP development process. No clear capacity however exists for establishing permissible compliance timeframes, for revising such objectives or for extending criteria to include information and alert thresholds and objectives for the protection of ecosystems. Additional expertise required in the field of air quality standards and dose-response relationship evaluation & local standard development As informed by Air Quality Act. Cognisance should be taken of the possible adoption of the SANS limit values to replace the current outdated standards. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-2 Functions Setting of emission standards local Defining Considerations (17) National Requirements International Good Practice Provision is made for the setting of National emission limits for various emission standards for the criteria pollutants are issued by standardisation of controls on national governments with more 'Controlled Emitters' and stringent local standards being widespread sources (e.g. industrial permitted in certain instances for processes, vehicle emissions, selected source categories household and commercial fuel combustion) (Specific reference is not currently made to the development of more stringent local emission standards. Provision is, however, made for passing by-laws within which this is possible.) Existing Local Resources Resource Implications for CTMM No clear capacity exists for the drafting of local emissions standards for gaseous criteria and toxic emissions (e.g. mercury) for specific source categories (e.g. vehicles, industries, domestic fuel burning appliances) If required, receptor information could be gathered (including permissible and existing levels of a pollutant), and backward dispersion modelling undertaken for the entire CTMM to determine suitable local emission limits for a source category. Meso-scale dispersion modelling capabilities will however need to be developed within CTMM to facilitate this. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-3 Functions Emissions inventory development maintenance & Defining Considerations (17) National Requirements International Good Practice - Reference made to maintenance - Emissions inventory development of emissions inventory for on-going as a comprehensive, accurate and data transfer and reporting current account of air pollutant purposes emissions from all sources - Although specific sources to be - Inclusion of all source and inventoried not explicitly stated, emissions data required for input to such sources are implied through emission calculations and their inclusion in the AQM Planning dispersion modelling (e.g. stack section (sources include: industry; heights, gas exit velocities & residential fuel burning; transport temperatures, area source related emissions including motor dimensions), etc. vehicles, trains, aircraft, boats and - Inclusion of temporally-resolved ships; hazardous and offensive emissions data (e.g. hourly sources of emission; sources of emissions data, or total annual noise; waste disposal and treatment emissions with diurnal and seasonal related emissions; fugitive dust trends in emissions indicated) sources related to mining, construction, demolition, agriculture & vehicle entrainment; noise emissions) - Inventory of greenhouse gas and ozone depleting substance emissions required - Standardization of emissions inventory data bases nationally, provincially & locally implicit in requirements Existing Local Resources Resource Implications for CTMM First level emissions inventory was developed for CTMM as part of the baseline characterisation study including the main sources of emissions. This inventory need to be revised and updated to include smaller sources and all fugitive sources. Preparation of the first comprehensive emission inventory would require several person-years of effort and considerable cost. A dedicated post would be required to update the inventory in order to keep it comprehensive, accurate and current. Special projects may be needed to be initiated at various intervals for complex/special sources (e.g. vehicle emissions, wild fires, toxic emissions from landfills). Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-4 Functions Air quality monitoring Defining Considerations (17) National Requirements International Good Practice - Monitoring to be carried out by - Trend towards on-line, real-time relevant local/provincial monitoring used in Europe and the governments in accordance with US for: methodologies and requirements to (a) compliance demonstration be formulated by the DEAT and (b) dispersion model validation & published by the SABS calibration - Data from air quality monitoring (c) early warnings during pollution instrumentation to be stored in a episodes format compatible with national (d) quantification of actual air quality guidelines & forwarded in electronic improvements of emission reduction form to the DEAT for inclusion in a strategies national air quality data base Metropolitan authorities - Calibration of air quality monitoring responsible for: instrumentation according to the (a) planning and coordination of specifications of a recognised ambient monitoring networks certification body (b) collection & collation of data - Monitoring to make use of existing (c) information reporting national expertise. Training to be (d) annual network reviews undertaken to ensure continuity Existing Local Resources Resource Implications for CTMM The existing monitoring network for CTMM comprises of 2 permanent monitoring stations. Air quality monitoring is currently being conducted by Environmental Health personnel. Such stations do not report data in real-time nor is air quality monitoring data currently consolidated in a single database. CTMM will need to review the contract with the contractors in the short-term pending: (i) the publication by the SABS of national monitoring and data manipulation requirements, (ii) discussions with lab and network accreditation bodies (e.g. SANAS), and (iii) possible decisions to extend national air quality standards to other pollutants. This will apply in the medium-and long-term to CTMM staff who will be responsible for the operation and management of these stations. CTMM proposed with the expansion of the monitoring network to include 3 additional permanent stations and 9 mobile stations, to be managed and operated by contractors. These contractors must train CTMM technicians to be able to operate these stations in the medium-to long-term Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-5 Functions Source control Defining Considerations (17) National Requirements International Good Practice - Responsibility for administering the Trend towards periodic license application process for permit/license review for industrial ‘listed activities’ to be undertaken by sources to account for (i) cumulative local government. impacts in developed areas, (ii) - Local authorities also to be integration of continuous responsible for vehicle emissions, improvement principles by household fuel burning, dust industries emissions from mining and possibly - Trend towards use of accredited also landfill gas emission impact environmental management system regulation development for the purpose of - General reference is made to the compliance demonstration by potential application of voluntary various sources agreements, penalties and - Encouragement of economic incentives (i.e. economic incentives (positive and negative) instruments, pollution charges) above pure source-based controls (e.g. emission limits) Existing Local Resources Resource Implications for CTMM - Limited expertise and experience exists with regard to the control of fuel-burning appliances - 'Scheduled Processes' are not currently controlled by local government - The current capacity for the investigation and development of alternative types of source control (e.g. economic incentives, voluntary agreements) is limited - The capacity for the periodic review of source permits/licenses to ensure continued compliance and facilitate continuous improvement depends on the outcome of the DEAT permit review project. CTMM will need to develop experience with regard to other sources not traditionally controlled (e.g. landfills, fugitive dust sources) - Capacity would need to be developed for the management of 'listed activities' by way of atmospheric emissions licenses. DEAT indicated the facilitating of training for local authorities. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-6 Functions Emissions monitoring Defining Considerations (17) National Requirements International Good Practice - Emissions monitoring to be carried Trend towards continuous out by the holder of the emission monitoring by industry and regular license in the case of industry extensive data transfer to authorities - No specific reference made to (e.g. 'data graveyards' in Germany) emission monitoring of other sources to date. It is however likely that local authorities will continue to be responsible for vehicle emission monitoring – alternatively this could become a requirement of testing stations. Existing Local Resources Resource Implications for CTMM CTMM currently makes provision for emissions monitoring of diesel powered vehicles twice annually. No other emissions monitoring is currently being undertaken. It has been recommended that CTMM’s current diesel vehicle emission testing programme be extended to be more frequent with an additional number of vehicles being tested per month. This will require changes in the method employed and additional person hours. The addition of local government responsibilities for intermittent source monitoring of non-traditional sources (e.g. wild fire emissions) or other sources by national authorities will similarly have implications in terms of monitoring equipment and personnel. It is, however, possible that such monitoring would be undertaken as part of specialised field campaigns, i.e. outsourced special projects) Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-7 Functions Information management reporting Atmospheric dispersion modelling & Defining Considerations (17) National Requirements International Good Practice - National requirements to be - Trend toward standardization of established to facilitate emissions and air quality data bases standardization of emissions and air and information reporting quality data storage, manipulation, mechanism not only within but also transfer and information reporting across countries (e.g. Airbase used - Reporting of greenhouse gas and by EC countries) ozone depleting substance emissions required - DEAT has contracted the CSIR to develop a framework for a National Air Quality Database which intends to house all source and emissions data from every municipality and monitoring data No direct regard. requirements in this - Distinct trend towards the replacement of extensive and costly air quality monitoring networks by on-line dispersion modelling coupled with key monitoring sites for model calibration and validation (particularly in Europe). - In Europe, regional models coupling street- and urban-scale (gridded) models with regional Gaussian Plume models (e.g. AERMOD) within a GIS data base management framework are being applied Existing Local Resources Resource Implications for CTMM Comprehensive electronic emissions and air quality data bases have not been established to date nor provision made for the integration of such data based within a GIS framework - Emissions and air quality data will need to be consolidated within a single data base the structure of which will be influence by national/provincial criteria (i.e National Air Quality Database) - Given the need for data base integration, emission and air quality monitoring data collation & management should preferably be done at a centralised level within CTMM - To facilitate the effective communication of information to the general public it is advisable that an air quality information liaison officer be designated - No capacity currently exists to support regional atmospheric dispersion modelling - Internal capacity (expertise, software, hardware) will need to be established for dispersion modelling applications Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-8 Functions Human health & environmental risk assessment Cost-benefit analysis Air Quality Management Plan development & implementation Defining Considerations (17) National Requirements International Good Practice - No direct requirements in this A tiered approach to the ranking of emission reduction strategies is regard. Initially, rankings are - Ambient air quality standards favoured. adopted by the Air Quality Act to be based on (i) total emission used in health risk screening (i.e. reductions, (ii) ambient air quality improvements to be achieved, (iii) compliance assessment) human and environmental risk and - No direct requirements in this damage reductions, and finally (iv) benefit maximization which takes regard. external costs and benefits into account. Due to time- and expertise- required by the latter two ranking criteria, such ranking not widely implemented and is usually undertaken on an intermittent (special project) basis Provision made for the development - Air Quality Management Plans are and implementation of Air Quality developed, regularly reviewed and Management Plans by local revised by metropolitan air quality authorities (integrated into their authorities (specifically within 'hot Integrated Development Plans) spots' which are declared as 'local air quality management zones e.g. UK; or within non-compliance areas, e.g. State Implementation Plans, US) - A public hearing process / public participation process is usually implemented as part of the plan development process Existing Local Resources Resource Implications for CTMM No clear capacity currently exists to assess human health and/or environmental risk potentials arising due to air pollutant concentrations - Internal capacity will need to be established if the impact of air pollution on human health, vegetation and the built environment to be assessed No clear capacity currently exists to undertake cost-benefit analysis of emission reduction measures. (Information required for the costing of externalities, e.g. hospitalisations, are not routinely available in South Africa to readily facilitate such studies) Given the absence of local expertise and the lack of data to support comprehensive CBA studies, it is envisaged that such analysis will be restricted to qualitative and semiquantitative evaluations. Alternatively CBA could be outsourced on a project-by-project basis. - Air quality management plan drafting requires strong policy and planning skills. Technical expertise is required for the effective characterisation of source-receptor relationships that provides the basis for emission strategy evaluation. The Tshwane Integrated Environmental Policy (TIEP) provides a framework for the development and revision of the Air Quality Management Plan. However, capacity does not exist to fulfil this function within the CTMM. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-9 12.1 Proposed Structure of CTMM Air Quality Unit The implementation, coordination and management of the AQMP role out would require specific functions and capabilities within the municipal structure. During the development of an AQMP for CTMM, an Energy Strategy was developed and concerted affords were made to ensure synergy between the two. Thus, with the level of integration required between Sustainable Energy and Climate Change Management and Air Quality Management, it is recommended that the two units be implemented as a single unit from the start. The focus of this section is on the functions required for the implementation of the AQMP for CTMM. The links and relations with the Sustainable Energy and Climate Change Management will be indicated with the detail provided in Section 5 of the Energy Strategy. It is considered pertinent that an Air Quality Section be developed to fulfill the core task of the AQMP implementation, management and revision within CTMM. Provided the tasks at hand required, capacity building should not only include the expansion of existing staff expertise but also identifying and recruiting additional people to fulfill the function. Based on the existing structure within the CTMM, three optional models are proposed. Figure 8-1 provides the structure as is currently in place in the City of Cape Town and that is in the process of being implemented in the City of Joburg. Figure 12-1: Proposed structure of the Air Quality Section at CTMM. The three options proposed for CTMM include the following: • Option 1: Agency outside of CTMM (external option) • Option 2: Internal Air Quality Management Division or Core Group (internal option) • Option 3: High level Strategic Coordination (internal option). Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-10 The most preferred Option for CTMM will depend on the Municipal Systems Act Section 78 (S78) process (review of internal and external service delivery mechanisms). 12.1.1 Option 1: Agency outside of CTMM Figure 8-2 provides an example of the proposed CTMM Air Quality and Sustainable Energy Agency. The main purpose of an Agency is to be established as a Municipal Entity outside the organisational structure of the CTMM. It will assume the form of a private company, a service utility or a multijurisdictional service utility. Appendix C provides the model and description of the Agency as was provided in the CTMM Energy Strategy. The functions of the proposed positions are discussed herewith. The associated costs are provided for each of the three models under Section 8-3. • Chief Executive Officer (CEO) This person will be the link between the Board of Directors and shareholders. This person would assume all responsibility for the business and operations of the Agency. Equivalent CTMM level: Strategic Executive. Tasks: - Management of agency - Setup and manage communication links with various departments and divisions, flow of information between the division and regions - Coordination of SE/CC/AQM activities between CTMM and DEAT, DME and GDACE. - Responsible for fund raising - Responsible for public sector management - Report to Council • Chief Operational Officer (COO) This person should not be the Air Pollution Control Officer, but rather someone that can oversee the integration of multidisciplinary technical information. This person should preferably have scientific/engineering background with technical and management experience. Equivalent CTMM level: General Manager. Tasks: - Management of AQO and specialists - ensure the division fulfil it s obligations as set out in the Air Quality Act - Setup and manage communication links with various departments and divisions, flow of information between the division and regions - liaise with Provincial and national government on related projects and information sharing - responsible for the implementation and revision of the air Quality Management Plan - co-ordination of emissions and air quality reporting co-ordination of rafting and implementation of local by-laws. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-11 MUNICIPAL MANAGER Air Quality Management, Energy & Climate Change Division/Unit Head Chief Officers in CTMM Office of the Municipal Manager Chief Executive Officer Chief Finacial Officer Chief Operation Officer Secretarial/ Support Staff Climate Change Specialists Air Quality Officer Senior Technician Sustanable Energy Specialists Air Quality Public Liaison Officer Senior Scientist Technician Atmospheric Scientist AQ Practisioner Technician Atmospheric Scientist AQ Practisioner Knowledge Management Figure 12-2: Proposed structure for an Air Quality Management, Energy and Climate Change Agency. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-12 • Air Quality Officer (AQO) This person should have specialised technical skills with specific relevance to industry (on all the aspects of air quality management, i.e. emissions inventory, modelling, monitoring, control technology etc.) Equivalent CTMM level: Manager Tasks The AQO is responsible for coordinating matters pertaining to air quality management in the municipality. The AQO does not have to be a specialist air quality manager but must ensure that such specialists are available to ensure that air quality governance is carried out efficiently and effectively. The AQO should however have knowledge of air quality management. - Responsible for air quality management in the municipality Middle to senior level manager Person who has broad knowledge and understanding of air quality relate issues and air quality management Have to represent and negotiate municipality positions in meetings with other AQO’s Must have sufficient authority to make decisions on day-to-day air quality issues Coordinate and standardise air quality functions undertaken across regions (Air Pollution Practitioners) Review of provisional emissions licenses and atmospheric emissions licenses, and subsequently may request atmospheric impact reports May establish programmes for public recognition of significant achievements in the area of pollution prevention Manage central database comprising statistics and legal action taken by regions (thus oversee database maintained by Senior Atmospheric Scientist) Periodic review of capacity within regions to undertake air pollution control functions an coordinate capacity building Provide support in terms of the interpretation and enforcement of legislation and regulations related to air pollution control Licensing and control of non-domestic fuel burning and listed activities (information obtained form Assistants) Liaise closely with Senior Technician and Senior Environmental Officer Report to Division Manager • Air Quality Practitioners (AQP) This person should have technical skills Equivalent CTMM level: EHPs (preferably one representative per region). Tasks - Collect information from all pollution sources (permits, air pollution prevention plans, impact assessments, emissions inventories, stack and ambient monitoring data undertaken by industries etc.) - Assist in rolling out the emissions reduction strategies (i.e. inspect industries, control of non-domestic fuel burning, assist in role-out of Basa Njengo Magogo, etc.) - Public awareness raising on air quality issues - Response to complaints (action taken) and recording and reporting to a central electronic complaints register - Vehicle testing – provide information to APCO Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-13 - Report to APCO • Senior Technician This person should have both management and technical skills. Equivalent CTMM level: Deputy Manager Tasks - supervise technicians manage lab coordinate external calibrations administration of accreditation document validate and analyse data from monitoring stations report to Air Pollution Control Officer and Division Manager • Technicians This person should have technical skills pertaining to the maintenance of monitoring equipment Equivalent CTMM level: EHP’s Tasks - site visits an instrument checks span and zero checks instrument maintenance responsible for data collation (if via telecom and software, responsible for this) report to Senior technical • Senior Atmospheric Scientist This person should have both management and specialised technical skills. Equivalent CTMM level: Deputy Manager Tasks - - manage atmospheric scientists oversee emissions inventory development oversee dispersion modelling oversee database management and GIS functions assist with Air Quality Management Plan development and implementation responsible for the integration of information – emissions inventory, dispersion modelling, ambient monitoring and GIS (assessment of human health risk and environmental impacts and damage related to measured/predicted air pollution concentrations) the part in brackets could be outsourced. responsible for emission reduction strategies development (rankling of sources and reduction opportunities) in collaboration with the Air Pollution Control Officer evaluate EIA’s, EMPRs and air quality assessments Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-14 • Atmospheric Scientists This person should have technical skills in emissions inventory development, dispersion modelling, database management and GIS (persons per task could also be appointed) Equivalent CTMM level: Chief Officers Tasks - develop and maintain an on-going comprehensive emissions inventory (identification and quantification of all sources) - report to common AQ database - rankling of sources and reduction opportunities based on emissions inventory - integration of emissions inventory and air quality & meteorological monitored data into common database, - dispersion modelling (simulation of ground level concentrations) for compliance assessment - evaluate dispersion modelling results based on ambient monitored data - review ambient monitoring station locations based on dispersion simulations - rank sources based on ambient concentrations and determine reduction measures required for compliance - report to Air Pollution Control Officer and Division Manager • Air Quality Information Officer This person should have data management and communication skills Equivalent CTMM level: Chief Officer Tasks - Inventory air quality related complaints receive via “one stop service” - Coordinate responses to air quality related complaints received – directly and those received by regional APPs - Collate and disseminate information to newspapers and radio stations - Ensure information is routinely reported for display on website - Organise and facilitate public meetings - Assist in the design and implementation of awareness raising campaigns - Report to APCO 12.1.2 Option 2: Internal Air Quality Management Division or Core Group The option of the Internal Core Group will have a similar structure as the Agency. The only difference is that the head of the Division (Chief Operating Officer) will report to the Office of the Municipal Manager. Figure 8-3 provides an example of the proposed Internal Management Division. The main purpose of an Agency is to be established as a Municipal Entity outside the organisational structure of the CTMM. It will be a similar structure than the Agency with the exception that it is established internally within the Strategic Centre. Appendix C provides the model and description of the Core Group as was provided in the CTMM Energy Strategy. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-15 • Unit/Division Head (UH) This person should not be the Air Pollution Control Officer, but rather someone that can oversee the integration of multidisciplinary technical information. This person should preferably have scientific/engineering background with technical and management experience. Equivalent CTMM level: General Manager. Tasks: - Management of AQO and specialists - ensure the division fulfil it s obligations as set out in the Air Quality Act - Setup and manage communication links with various departments and divisions, flow of information between the division and regions - liaise with Provincial and national government on related projects and information sharing - responsible for the implementation and revision of the air Quality Management Plan - co-ordination of emissions and air quality reporting co-ordination of rafting and implementation of local by-laws - Report to Council • Air Quality Officer (AQO) This person should have specialised technical skills with specific relevance to industry (on all the aspects of air quality management, i.e. emissions inventory, modelling, monitoring, control technology etc.) Equivalent CTMM level: Manager Tasks The AQO is responsible for coordinating matters pertaining to air quality management in the municipality. The AQO does not have to be a specialist air quality manager but must ensure that such specialists are available to ensure that air quality governance is carried out efficiently and effectively. The AQO should however have knowledge of air quality management. - Responsible for air quality management in the municipality Middle to senior level manager Person who has broad knowledge and understanding of air quality relate issues and air quality management Have to represent and negotiate municipality positions in meetings with other AQO’s Must have sufficient authority to make decisions on day-to-day air quality issues Coordinate and standardise air quality functions undertaken across regions (Air Pollution Practitioners) Review of provisional emissions licenses and atmospheric emissions licenses, and subsequently may request atmospheric impact reports May establish programmes for public recognition of significant achievements in the area of pollution prevention Manage central database comprising statistics and legal action taken by regions (thus oversee database maintained by Senior Atmospheric Scientist) Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-16 MUNICIPAL MANAGER Air Quality Management, Energy & Climate Change Division/Unit Head Office of the Municipal Manager Chief Financial Officer Chief Officers in CTMM Secretarial/ Support Staff Unit Head Climate Change Specialists Air Quality Officer Senior Technician Sustainable Energy Specialists Air Quality Public Liaison Officer Senior Scientist Technician Atmospheric Scientist AQ Practisioner Technician Atmospheric Scientist AQ Practisioner Knowledge Managemen t Figure 12-3: Proposed structure for an Air Quality Management, Energy and Climate Change Core Group. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-17 - Periodic review of capacity within regions to undertake air pollution control functions an coordinate capacity building Provide support in terms of the interpretation and enforcement of legislation and regulations related to air pollution control Licensing and control of non-domestic fuel burning and listed activities (information obtained form Assistants) Liaise closely with Senior Technician and Senior Environmental Officer Report to Division Manager • Air Quality Practitioners (APP) This person should have technical skills Equivalent CTMM level: EHPs (preferably one representative per region). Tasks - Collect information from all pollution sources (permits, air pollution prevention plans, impact assessments, emissions inventories, stack and ambient monitoring data undertaken by industries etc.) - Assist in rolling out the emissions reduction strategies (i.e. inspect industries, control of non-domestic fuel burning, assist in role-out of Basa Njengo Magogo, etc.) - Public awareness raising on air quality issues - Response to complaints (action taken) and recording and reporting to a central electronic complaints register - Vehicle testing – provide information to APCO - Report to APCO • Senior Technician This person should have both management and technical skills. Equivalent CTMM level: Deputy Manager Tasks - supervise technicians manage lab coordinate external calibrations administration of accreditation document validate and analyse data from monitoring stations report to Air Pollution Control Officer and Division Manager • Technicians This person should have technical skills pertaining to the maintenance of monitoring equipment Equivalent CTMM level: EHP’s Tasks - site visits an instrument checks span and zero checks instrument maintenance responsible for data collation (if via telecom and software, responsible for this) report to Senior technical • Senior Atmospheric Scientist This person should have both management and specialised technical skills. Equivalent CTMM level: Deputy Manager Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-18 Tasks - - manage atmospheric scientists oversee emissions inventory development oversee dispersion modelling oversee database management and GIS functions assist with Air Quality Management Plan development and implementation responsible for the integration of information – emissions inventory, dispersion modelling, ambient monitoring and GIS (assessment of human health risk and environmental impacts and damage related to measured/predicted air pollution concentrations) the part in brackets could be outsourced. responsible for emission reduction strategies development (rankling of sources and reduction opportunities) in collaboration with the Air Pollution Control Officer evaluate EIA’s, EMPRs and air quality assessments • Atmospheric Scientists This person should have technical skills in emissions inventory development, dispersion modelling, database management and GIS (persons per task could also be appointed) Equivalent CTMM level: Chief Officers Tasks - develop and maintain an on-going comprehensive emissions inventory (identification and quantification of all sources) - report to common AQ database - rankling of sources and reduction opportunities based on emissions inventory - integration of emissions inventory and air quality & meteorological monitored data into common database, - dispersion modelling (simulation of ground level concentrations) for compliance assessment - evaluate dispersion modelling results based on ambient monitored data - review ambient monitoring station locations based on dispersion simulations - rank sources based on ambient concentrations and determine reduction measures required for compliance - report to Air Pollution Control Officer and Division Manager • Air quality Information Officer This person should have data management and communication skills Equivalent CTMM level: Chief Officer Tasks - Inventory air quality related complaints receive via “one stop service” - Coordinate responses to air quality related complaints received – directly and those received by regional APPs - Collate and disseminate information to newspapers and radio stations - Ensure information is routinely reported for display on website - Organise and facilitate public meetings - Assist in the design and implementation of awareness raising campaigns - Report to APCO Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-19 12.1.3 Option 3: High level Strategic Coordination. The third structure proposed for CTMM is that only the core functions as stipulated in the Air Quality Act be accommodated within the CTMM structure with the outsourcing of all other functions to contractors and consultants. Crucial functions that need to be implemented in the Energy, Climate Change and Air Quality Unit include: • Chief Operation Officer (COO) This person should be heading the entire division and don’t have to be restricted to air quality alone. This function should rather be to integrate all air quality related information and make the links between air quality, energy and climate change. • Air Quality Officer (AQO) This position is a requirement of the National Environmental Management: Air Quality Act of 2004. If the APP functions are allocated to the existing EHP’s there should be a clear line of reporting to the APCO since he/she will have to rely strongly on this information to fulfil his/her legal obligation. Careful consideration should be given to this since the EHPs might fall into different divisions. In addition, the EHPs might not be able to absorb the additional workload implicated by air quality management. • Senior Scientist If all other functions are outsourced, this person would be the main supporting person to the APCO. He/she would be responsible for collating all data from the contractors and consultants an oversee the database management and provide sensible information to the CAPCO Functions that can be outsourced include the following: - Coordinate and standardise functions undertaken across regions (Air Pollution Practitioners) Maintain central database comprising statistics and legal action taken by regions (thus oversee database maintained by Senior Atmospheric Scientist) Periodic review of capacity within regions to undertake air pollution control functions an coordinate capacity building Provide support in terms of the interpretation and enforcement of legislation and regulations related to air pollution control Licensing and control of non-domestic fuel burning and listed activities (information obtained form Assistants) Liaise closely with Senior Technician and Senior Environmental Officer Report to Division Manager • Air Pollution Practitioners (APP) This person should have technical skills Equivalent CTMM level: EHPs (preferably one representative per region). Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-20 Tasks - Collect information from all pollution sources (permits, air pollution prevention plans, impact assessments, emissions inventories, stack and ambient monitoring data undertaken by industries etc.) - Assist in rolling out the emissions reduction strategies (i.e. inspect industries, control of non-domestic fuel burning, assist in role-out of Basa Njengo Magogo, etc.) - Public awareness raising on air quality issues - Response to complaints (action taken) and recording and reporting to a central electronic complaints register - Vehicle testing – provide information to APCO - Report to APCO • Senior Technician This person should have both management and technical skills. Equivalent CTMM level: Deputy Manager Tasks - supervise technicians manage lab coordinate external calibrations administration of accreditation document validate and analyse data from monitoring stations report to Air Pollution Control Officer and Division Manager • Technicians This person should have technical skills pertaining to the maintenance of monitoring equipment Equivalent CTMM level: EHP’s Tasks - site visits an instrument checks span and zero checks instrument maintenance responsible for data collation (if via telecom and software, responsible for this) report to Senior technical • Senior Atmospheric Scientist This person should have both management and specialised technical skills. Equivalent CTMM level: Deputy Manager Tasks - - manage atmospheric scientists oversee emissions inventory development oversee dispersion modelling oversee database management and GIS functions assist with Air Quality Management Plan development and implementation responsible for the integration of information – emissions inventory, dispersion modelling, ambient monitoring and GIS (assessment of human health risk and environmental impacts and damage related to measured/predicted air pollution concentrations) the part in brackets could be outsourced. responsible for emission reduction strategies development (rankling of sources and reduction opportunities) in collaboration with the Air Pollution Control Officer Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-21 - evaluate EIA’s, EMPRs and air quality assessments • Atmospheric Scientists This person should have technical skills in emissions inventory development, dispersion modelling, database management and GIS (persons per task could also be appointed) Equivalent CTMM level: Chief Officers Tasks - develop and maintain an on-going comprehensive emissions inventory (identification and quantification of all sources) - report to common AQ database - rankling of sources and reduction opportunities based on emissions inventory - integration of emissions inventory and air quality & meteorological monitored data into common database, - dispersion modelling (simulation of ground level concentrations) for compliance assessment - evaluate dispersion modelling results based on ambient monitored data - review ambient monitoring station locations based on dispersion simulations - rank sources based on ambient concentrations and determine reduction measures required for compliance - report to Air Pollution Control Officer and Division Manager • Air quality Information Officer This person should have data management and communication skills Equivalent CTMM level: Chief Officer Tasks - Inventory air quality related complaints receive via “one stop service” - Coordinate responses to air quality related complaints received – directly and those received by regional APPs - Collate and disseminate information to newspapers and radio stations - Ensure information is routinely reported for display on website - Organise and facilitate public meetings - Assist in the design and implementation of awareness raising campaigns - Report to APCO • Senior Technician and Technicians It is recommended that the Senior Technician function together with the technicians be outsourced to a single contractor. It is also recommended that the contractor reports directly to the Senior Scientist. All functions as stipulated for Senior Technicians and Technicians (see Section 8.1.1.) should form the terms of reference for the contractor. • Atmospheric Scientists This supporting function to the Senior Scientist could be outsourced to a consultancy. The Consultancy could provide the services in one of two ways, namely by providing a dedicated person to sit at the municipality one day a week, or to complete certain tasks and deliver the product to the municipality. It is recommended that the consultancy develop an emission inventory database for the municipality and populate the dispersion model as is the tasks stipulated under Section 8.1.1. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-22 • Air Pollution Practitioners (APP) The air pollution practitioners are an optional function that can be fulfilled by the EHPs. Again, caution should be taken to ensure that the EHPs can absorb these additional tasks. 3. Air quality Information Officer This function could be handled by the Environmental Management division with an Air Quality sub-function. 12.1.4 General Requirements Irrespective of which of the three proposed models are chosen, it is imperative that the following structures be in place over the short-term: 18 • CTMM Council to understand the necessity of a specialised Air Quality Management section/unit and approve it. This can be any of the three proposed models. • The two crucial positions over the short-term is the appointment of a Senior Atmospheric Scientist and an Air Quality Officer. This is necessary so to ensure the relevant training in the interim to ensure the ability to fulfil the required functions as set out in the AQMP. • The Senior Atmospheric Scientist and Air Quality Officer will be responsible within the short-term for the execution of all identified tasks to be initiated and implemented. Thus, in the interim very little distinction will be made between the responsibilities of the Senior Atmospheric Scientist and Air Quality Officer. It is expected that the atmospheric licensing functions will only become the responsibility of the local authorities within two years18. • The DEAT is in the process of defining capacity building requirements and training programmes for provincial and local authorities. CTMM will communicate its specific training requirements to DEAT and will determine DEAT's anticipated timeframe for the provision of such support. • In the short-term it is recommended that the Contractors appointed to implement and manage the ambient monitoring stations, train the EHPs on the maintenance and data capturing methods. This will ensure that this function become in-house expertise over the medium- and long term. • It will be crucial that the persons responsible for the AQMP implementation within the short-term form good relationships with all relevant divisions within the CTMM (viz. Environmental Health, Environmental Management, Traffic Divisions, Housing and City Planning). The cooperation from these divisions will be crucial in the implementation of the AQMP. • Dispersion modelling software should be purchased within the short-term. The emissions inventory should be updated and emissions database should be established. All monitoring data must be downloaded onto a base-station and stored in a central database. It is important that provision be made for a back-up system at CTMM. This is dependant on the outcome of the Atmospheric Licensing project to commence in the beginning of 2006 and run for a period of 18 months. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-23 • Integration of existing complaints register to automatically inform the Air Quality Officer of incidences reported and what action should be taken. Capacity to be incorporated over the medium-term: • During this phase the Air Quality Officer should be responsible for reviewing and issuing atmospheric licences to all listed activities within the CTMM. Given the requirement that all sources of air pollution should have been identified during the short-term and that all industries should have supplied the CTMM with emissions inventories, the task of the Air Quality Officer should be lightened. • The emissions inventory should be updated annually to account for an accurate and current reflection of the air pollution sources within CTMM. The urban airshed dispersion model should be set-up and operational at this stage with the capability to run future scenarios. This information will be used by the Air Quality Officer to review and issue emissions licences. • During this phase it is advised that a Section Head be appointed in the case of Option1 or Option 3. This person should be responsible for the management of the Air Quality Section and to ensure that the AQMP be implemented and revised. The Head of the AQM section will also be responsible to ensure that the communication systems operate smoothly and inter-departmental information sharing continue. This person will also be the link to provincial and national departments to ensure data sharing and involvement in all air quality management projects initiated by province and national governments. • Depending on the atomisation of the complaints register and how well air quality issues are capture and responded to, an air quality public liaison officer could be appointed to fulfil this function within the Air Quality Section. It will remain important that the complaints register for air pollution issues continue to be incorporated into the general complaints register. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-24 12.2 Budget Requirements Budget requirements are outlined in Tables 8-2, 8-3 and 8-4, reflecting the three proposed models. It should be noted that this is based on ballpark figures over an annual average. The estimated salary structures are based on the former Greater Pretoria Metropolitan Council scale. These salary structures are however only ballpark estimates and should be researched and refined by the Hyman Resource Divisions. • Option 1: Agency outside of CTMM (external option) • Option 2: Internal Air Quality Management Division or Core Group (internal option) • Option 3: High level Strategic Coordination (internal option). Table 12-2: Option 1 - Agency outside of CTMM (1) Function Position Unit Price per Annum Chief Executive Officer Strategic Executive R500 000 – R600 000 Chief Operational Officer General Manager R400 000 – R500 000 Air Quality Officer Manager R350 000 – R400 000 Senior Atmospheric Scientist Deputy Manager R241 212 – R312 996 Senior Technician Deputy Manager R241 212 – R312 996 Atmospheric Scientist Chief Officer R330 096 – R456 432 Air Quality Practitioner EHPs (C2-2-D1) R248 232 – R311 568 Technicians EHPs (C2-2-D1) R248 232 – R311 568 SUB-TOTAL R2 558 984 – R3 205 560 Software and Hardware Requirements ADMS Urban Urban Airshed Dispersion Model GIS Software (optional) R 280 000 – R300 000 R 20 000 EMIT / IPIECA (optional) Emission Models R 20 000 Computers (Quantity - 8) R 64 000 SUB-TOTAL R384 000 – R404 000 Other Functions Role-out of BNG project TOTAL COST Notes: (1) 20 000 households (2) (3) R 400 000 – R 1 million R3 342 984 – R4 609 560 It is likely that the Agency would have similar salary scales and would require the same number of people and positions to fulfil the task at hand. (2) Lower range is when campaign is done internally and the upper range is when it is out-sourced. (3) Assuming 2 x Atmospheric Scientists, 2 x AQPs, 2 x Technicians, 8 x PCs, 1 x ADMS license, 1 x GIS license, and 20 000 households. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-25 Table 12-3: Option 2 - Internal Air Quality Management Division or Core Group Function Position Unit Price per Annum Unit/Division Head General Manager position R400 000 – R600 000 Air Quality Officer Manager R350 000 – R400 000 Senior Atmospheric Scientist Deputy Manager R241 212 – R312 996 Senior Technician Deputy Manager R241 212 – R312 996 Atmospheric Scientist Chief Officer R330 096 – R456 432 Air Quality Practitioner EHPs (C2-2-D1) R248 232 – R311 568 Technicians EHPs (C2-2-D1) R248 232 – R311 568 SUB-TOTAL R2 058 984 – R2 705 560 Software and Hardware Requirements ADMS Urban Urban Airshed Dispersion Model GIS Software (optional) R 280 000 – R300 000 R 20 000 EMIT / IPIECA (optional) Emission Models R 20 000 Computers (Quantity – 8) R 64000 SUB-TOTAL R384 000 – R404 000 Other Functions Role-out of BNG project TOTAL COST (2) Notes: (1) 20 000 households (1) R 400 000 – R 1 million R2 842 984 – R4 109 560 Lower range is when campaign is done internally and the upper range is when it is out-sourced. (2) Assuming 2 x Atmospheric Scientists, 2 x AQPs, 2 x Technicians, 8 x PCs, 1 x ADMS license, 1 x GIS license, and 20 000 households on lower range. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-26 Table 12-4: Option 3 High level Strategic Coordination Function Position Unit Price per Annum Unit/Division Head General Manager R400 000 – R600 000 Air Pollution Control Officer Manager R350 000 – R400 000 Senior Atmospheric Scientist Deputy Manager R241 212 – R312 996 SUB-TOTAL R991 212 – R1 312 996 Outsourced Functions Technical Section Atmospheric Scientist Contractors for all monitoring & maintenance functions Consultants to compile emissions inventory, populate and run dispersion modelling SUB-TOTAL R300 000 R200 000 - R300 000 (1) R500 000– R600 000 Software and Hardware Requirements ADMS Urban Urban Airshed Dispersion Model GIS Software (optional) R 280 000 – R300 000 R 20 000 EMIT / IPIECA (optional) Emission Models R 20 000 Computers (Quantity – 4) R 32 000 SUB-TOTAL R352 000 – R372 000 Other Functions Role-out of BNG project TOTAL COST Notes: (2) 20 000 households (1) R 400 000 – R 1 million R2 243 212 – R3 284 996 (1) Upper range is for the first year to set everything up and the lower range is from the second year onwards mainly for maintenance and upkeep. (2) 1 x ADMS license (even though the dispersion modelling function is outsourced, ADMS is only sold to cities), 1 x GIS license, 4 x PCs and 20 000 households. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 12-27 13 AQMP APPROVAL AND REVIEW PROCESS 13.1 AQMP Approval The following process was followed in the drafting of the Tshwane AQMP: • Establishment of the following structures to provide guidance to the AQMP development project team: - Technical Working Groups (TWGs) - established to review the technical merit and feasibility of the plan during the development phase. TWG members included representatives from CTMM Departments responsible for transport, housing, urban planning, environmental health and environmental management. In addition GDACE personnel (provincial government) and DEAT (national government) were presented along with Academics from the University of Pretoria and Tshwane University of Technology. Various experts within the private sector was also part of the TWG.. - Air Quality Stakeholder Group (AQSG) - comprising interested and affected parties including parties affected by air pollution and those whom may be impacted by interventions aimed at reducing the impacts of air pollution, e.g. business, industry, NGOs, CBOs and labour. • Compilation of Discussion Documents and a Draft Air Quality Management Plan for distribution to and workshopping with the Technical Working Groups and the Air Quality Stakeholder Group (August to November 2005). • Integration of all comments received from the TWGs, AQSG and CTMM and compilation of the Draft Final Plan (4 November 2005). • Presentation of the Draft Final AQMP at a Public Workshop (1 December 2005) and placement of copies of the Draft-Final Plan in public places for review. • Integration of all comments received from the TWGs, AQSG, EMM and the public and compilation of the Final AQMP (21 December 2004). AQMP approval is however dependent not only on stakeholder and general public acceptance but also on review and authorisation by provincial and possibly by national governments. The guidelines for how AQMP approvals will take place have not yet been established by either. It is however anticipated that such guidelines will be issued within the next two years. It is intended that the AQMP be approved and implemented by CTMM in the interim with the Plan being revised and submitted to the necessary national and/or provincial authorities for approval once the necessary guidelines are in place. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 13-1 13.2 AQMP Review Once approved by CTMM in consultation with DEAT and GDACE, the AQMP and the functional and operational framework within which the plan is implemented will be reviewed regularly to ensure its continuing suitability, adequacy and effectiveness. The aim of the review is primarily to address the possible need for changes to functional and operational structures, AQM systems, management objectives (etc.) in light of poor performances, changing circumstances and the commitment to continual improvement. In the coming year(s) the Air Quality Management Plan will be reviewed based on: • final stipulations within the National Air Quality Management Act • national regulations pertaining to revised ambient air quality standards • national regulations pertaining to ambient air quality monitoring for compliance assessment purposes • national regulations pertaining to emission standards • national regulations for source monitoring methods suited to assessing compliance with emission standards • proposed guidance reports to be issued on: (i) air quality assessments, (ii) the use of indirect methods for air quality characterisation (e.g. modelling), and (iii) air quality management plan development and implementation. • new DEAT and GDACE criteria pertaining to air quality management and air pollution control Progress made in AQMP implementation will be reported on annually. Based on the examples of other municipalities it is anticipated that the AQMP for CTMM will only be launched towards mid 2006. The initiation of the AQMP was therefore taken to be June 2006 for planning purposes. The AQMP will initially be revised in two years (i.e. June 2008), following which it will be revised every 5 years unless otherwise required by DEAT or GDACE. The draft revised AQMP will be submitted to the DEAT and GDACE for approval and made available to the public for comment prior to finalisation. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 13-2 14 REFERENCES Africon (2005). Tshwane State of Energy Report. Report compiled on behalf of the City of Tshwane Metropolitan Municipality, Report No. Final Draft, 26 October 2005. CEPA/FPAC Working Group (1998). National Ambient Air Quality Objectives for Particulate Matter. Part 1: Science Assessment Document, A Report by the Canadian Environmental Protection Agency (CEPA) Federal-Provincial Advisory Committee (FPAC)on Air Quality Objectives and Guidelines. Cosijn C. (1995). Elevated Absolutely Stable Layers: A Climatology for South Africa, Unpublished MSc. Proposal submitted to the Department of Geography and Environmental Studies, University of the Witwatersrand, Johannesburg. Diab R.D. (1975). Stability and Mixing Layer Characteristics over Southern Africa, Unpublished MSc Thesis, University of Natal, Durban, 203 pp. Diab, R. (1995) Local Agenda 21: State of the Air Environment in the Greater Durban Metropolitan Area, Proc NACA Annual Conf, 22-24 November 1995. DME (2000). Guideline for the Compilation of a Mandatory Code of Practice on Mine Residue Deposits, Mine Health and Safety Inspectorate, South African Department of Minerals and Energy, DME 16/3/2/5-A1, 30 November 2000 (effective date: 31 May 2001). ERI (2001). Preliminary Energy Outlook for South Africa, Energy Research Institute, University of Cape Town, 10 October 2001. Liebenberg-Enslin H and Petzer G (2005). Background Information Document – Air Quality Baseline Assessment for the City of Tshwane Metropolitan Municipality. Report compiled on behalf of the City of Tshwane Metropolitan Municipality, Report No. APP/05/CTMM-01 rev1, June 2005. SABS (1998). South African Standards: Code of Practice, Mine Residue, South African Bureau of Standards, SABS 0286:1998. SANS 69:2004. South African National Standard - Framework for setting & implementing national ambient air quality standards, Standards South Africa, Pretoria. SANS 1929:2004. South African National Standard - Ambient Air Quality - Limits for common pollutants, Standards South Africa, Pretoria. Scorgie Y, Annegarn HJ and Burger L (2003). Review of International Air Quality Guidelines and Standards for the Purpose of Informing South African Air Quality Standards, Report compiled on behalf of the Technical Committee on National Air Quality Standards - Working Group I, 5 March 2003. Scorgie Y, Watson R and Fischer T (2005). Air Quality Management Plan for the Ekurguleni Metropolitan Municipality, Report compiled on behalf of Ekurhuleni Metropolitan Municipality, Report No. APP/04/EMM-02c, 25 January 2005. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 14-1 Scorgie Y, Paterson G, Burger LW, Annegarn HJ and Kneen M (2004). Study to Examine the Potential Socio-Economic Impact of Measures to Reduce Air Pollution from Combustion, Task 4a Supplementary Report: Quantification of Health Risks and Associated Costs Associated with Fuel Burning Source Groups, Report compiled on behalf of the Trade and Industry Chamber. Terblanche P, Nel M E, Opperman L and Nyikos H (1993). Exposure to Air Pollution from Transitional Household Fuels in a South African Population, Journal of Exposure Analysis and Environmental Epidemiology, 3(1), 15-22 Terblanche P (1996). Impacts of Removing Air Pollution: Health Aspects, Report compiled on behalf of Department of Minerals and Energy, Report No. ES 9411, May 1996. von Horen C (1996). The Cost of Power: Externalities in South Africa's Energy Sector, Energy & Development Research Centre, University of Cape Town. WHO (2000). Air Quality Guidelines, World Health Organisation, Geneva. Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page 14-2 APPENDIX A MEMBERS OF THE TECHNICAL WORKING GROUP Project Manager - CTMM Chief HO: Air Quality Juan Mostert Management- Environmental Health Technical Project Manager - Airshed Hanlie LiebenbergAirshed Planning Professionals Enslins (Pty) Ltd CTMM Departmental Representatives Jerry Motsamai Joseph NS Mutswari Johan Human Gopaul Rangasamy Isaac Magagula M de Wet CT Meyer P Nel Rina Nel Manager: Environmental Health SEED Advisor Chief EHP: Region 5 Chief EHP: Region 3 Chief EHP Chief EHP Deputy Manager: South Chief Noise Control Officer Chief EHP: Inspection Services [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] Academic Institutions Hannes Rautenbach University of Pretoria Tshwane University of Koos Engelbrecht Technology National and Provincial Departments [email protected] Nadine Koning Shirley Moroka [email protected] [email protected] GDACE DEAT [email protected] Industry and Commercial Sector Jaco Joubert Joe Prinsloo Nic van der Merwe PPC Hercules Mittal Steel Pretoria Mittal Steel Pretoria [email protected] [email protected] [email protected] Consultant – State of Energy Study Lungi Mbanga Linsey Dyer Analyst: Africon Africon [email protected] [email protected] Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page A-1 APPENDIX B AIR QUALITY STAKEHOLDER GROUP MEETING – ATTENDANCE LIST Tuesday, 28 June 2005, Sammy marks Auditorium, Pretoria Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page B-1 APPENDIX C COMPARISON OF POSSIBLE UNIT GOVERNANCE MODELS (from CTMM Energy Strategy, 2005) Model Option1:Agency Description □ Established outside CTMM organisational □ □ □ □ □ □ □ □ □ Option 2: Core Group □ □ □ structure as a Municipal Entity, assuming the form of a private company, a service utility or a multijurisdictional service utility CTMM would be sole shareholder if a private company is formed Board would include representatives from DEAT, DME and NDoT Would report to the Office of the Municipal Manager (OMM), within the Strategic Centre. Would be funded by the municipality and possibly by external sources. Would have authority through the OMM to catalyse, drive, and coordinate SE/CC/AQM activities within CTMM Delivery Core High level, multidisciplinary expertise required to lead and staff the Agency May access resources such as technicians and equipment from the Delivery Core Mechanisms for interaction between Agency and Delivery Core would be clearly defined Air Quality Officer sits in the OMM, and delegates Air Quality Management functions to the Agency Like external Agency, but established internally within the Strategic Centre Would report to the OMM. Would be funded by the municipality and Advantages □ Would not add to CTMM’s existing staff Disadvantages □ May be perceived as “too far” complement □ May have preferential access to external □ □ □ □ □ □ □ □ □ funding due to ringfenced status and perceived independence Would have the capacity to raise funding Would be able to dedicate resources to SE/CC/AQM Would have a strong integrating capability Would be able to access innovative Knowledge Management solutions More flexible and shorter decision-making cycle Of all models, provides the most scope for establishing and operating to KPIs. Assumption of a legal personality would support sustainability of the function Assumption of a legal personality would also support air quality enforcement Could fulfil an ombudsman role □ Perception of greater administrative and political control in comparison to Agency □ Would have better access to external funding than High Level Strategic Coordination □ □ □ □ □ from CTMM inner workings to achieve certain operational objectives Implementation may take longer than for the other options. Cost of compliance with companies-related legislation may be high (applies only in the case of a private company). Required expertise may be expensive Interaction between Agency and Delivery Core may take on an “us and them” quality MSA S78 process may be time-consuming □ Requirement to recruit new staff, resulting in Increased salary burden on Council, in conflict with current CTMM Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page C-1 Model □ □ □ □ Description possibly by external sources for special projects Would have authority through the OMM to catalyse, drive, and coordinate SE/CC/AQM activities within CTMM Delivery Core High level, multidisciplinary expertise required to lead and staff the Core Group May access resources such as technicians and equipment from the Delivery Core Air Quality Officer sits in the OMM, and delegates Air Quality Management functions to the Core Group Advantages Disadvantages policy □ Would be able to dedicate resources to SE/CC/AQM □ Would have a strong integrating capability □ In comparison to the Strategic Coordination option, would better support air quality enforcement □ Possibility of resources being □ □ □ □ Option 3: High Level Strategic Coordination □ Consists of key individuals reporting on □ CTMM could build on an existing functional □ common objectives through a committee structure, similar to the current Sustainable Energy Tshwane (SET) Committee □ Driven by a key individual from an interested department, most likely Social Development □ Would be funded by the municipality and possibly by external sources for special projects, such as the provision of a SEED Advisor □ Would facilitate access to funding for special projects to be implemented in line departments structure □ Would not add to CTMM’s staff complement or salary burden □ □ □ □ diluted for other functions – end result may be further human resources recruitment requirement Because of AQA requirements having the force of law, SE/CC functions may become subordinate to air quality functions Required expertise may be expensive Decision-making bound by CTMM decision-making cycle MSA S78 process may be time-consuming Resources would not be dedicated solely to SE/CC/AQM Because of AQA requirements having the force of law, SE/CC functions may become subordinate to air quality functions Decision-making bound by CTMM decision-making cycle Required expertise may be expensive Would be difficult to drive Knowledge Management Draft Air Quality Management Plan for the City of Tshwane Metropolitan Municipality Report No.: APP/05/CTMM-02a Page C-2