Air Quality colloquium

Meeting report

Opening remarks

The Chairperson said the colloquium had been called to focus on air quality and air pollution. Air pollution contributed to a wide variety of respiratory diseases and affected lungs and other major body organs. Children and women in urban industrial areas were particularly vulnerable. According to a World Bank study, air pollution killed 20 000 people annually in South Africa (SA), costing the economy R300 million. This meant that decisive action had to be taken or air pollution would remain problematic, as it reduced the economic value of crops, plant biodiversity and affected other ecosystem services such as clean water, recreational activities and carbon storage.

Air pollution contributed to climate change, and SA understood that the legacy of poor environmental planning during apartheid continued to bedevil the country. Environmental policies of the previous regime had led to an environmental framework that perpetuated social inequality amongst South Africans and located black settlements near industrial areas. This had exposed the predominantly black populace to a heavy incidence of industrial pollution. Limited access to electricity in those unsuitable and highly polluted and overcrowded informal settlements had resulted in the burning of fossil fuels, further compromising air quality. Notably, the mining sector had been largely shielded from governmental regulation, though it was a contributor to air pollution.

Whether it was climate change, air quality or environmental degradation, human vulnerability to their effects was aggravated by the legacies of apartheid, which promoted environmental racism. South Africans’ vulnerability to certain environmental hazards was dictated by both individual and social factors. The livelihood context, location, levels of income, education, assets, gender, age and social class -- all those combined to determine the coping abilities of individuals across communities in SA.

Since 1994, SA had made significant progress in transforming the fragmented environmental governance framework to address the historical legacy of inequality. That was why SA had adopted the following guidelines:

• Sustainable development;
• Equitable access to environmental resources;
• Public participation in all decisions which affected the development and management of natural resources;
• Public right to access to information and the calls on issues of environmental concern;
• An integrated approach to environmental issues that related to all sectors of society;
• Recognition of the integrated nature of the global environment, and the need for both local and international cooperation in policy making.

The constitution of SA further enjoined the government to adopt a rights-based approach to healthy and safe environments that did not affect the health and well-being of South Africans. It was in this context that the work of the Department of Environmental Affairs (DEA) and its entities, as well as other arms of the state, in so far as environmental sustainability was concerned, had been done in a manner consistent with section 24 of the SA constitution. Accordingly the National Environmental Management Act (NEMA) and all other relevant environmental legislation sought to place South Africans at the centre of environmental management. Only through recognising the triple challenges of poverty, unemployment and inequality would government be able to serve South Africans with the integrity befitting the representative nature of the institution their public representatives represented, which was Parliament. The role which Parliament sought to play on environmental matters was through the interactive involvement of communities in Parliamentary processes, including law making and oversight, and public hearings of South Africa’s proposed position on multilateral environmental engagements and outcomes.

It was on the above basis that the Air Quality Act, 2004, had presented a distinct shift from exclusively source-based air pollution control, to holistic and integrated effects-based air quality management. The Act had focused on the adverse effects of air pollution on the ambient environment. It had set standards for pollutants in the ambient air and emissions to minimise the amount of pollution entering the atmosphere. Unless proven otherwise, SA had sufficient legislation for efficient regulation of air quality.

However, the challenge remained with implementation of the law and adherence thereto, especially the granting of postponement applications, despite the plight of South Africans in air pollution hotspots. Notwithstanding that, the Committee had been assured that the DEA did not use a blanket approval approach in processing postponement applications, but the Committee wanted to play a more active role in overseeing the exercise of that public power of granting postponement applications for compliance with minimum emission standards. That power, as delegated by Parliament to the executive, could not be used to defeat the ultimate purpose of the law. Industry, as clients, had to be required to submit compliance roadmaps which indicated when it envisaged to have completed its task regarding investments for pollution control technologies.

Postponements had to be granted only to allow companies to procure technology and retrofit their plants to lower the emissions of the three main pollutants -- particulate matter (PM), sulphur oxides (SOx) and nitrogen oxides (NOx). Parliament had to monitor the acquisition of the technologies and the upgrading by the relevant companies which had been granted postponements.

The Committee had therefore requested the DEA to brief Parliament on all postponement applications to date, those applications which had been granted and the reasons thereof and what the timelines for full compliance had been set at. The colloquium was an opportunity to measure how far the Government had come in implementing the Air Quality Act and in reducing air pollution, especially in identified hotspots.

The colloquium was not a normal Committee meeting, where only members of the Committee contributed. The stakeholders who were in attendance were welcome to give input and engage presentations.

Absence of officials

The Chairperson then read apologies from those that were absent.

Mr Ishaam Abader, Acting Director-General (ADG), DEA, submitted an apology that the Director General (DG) would attend the colloquium later on, but two directors would be present.

The Chairperson asked where the National Air Quality Officer (NAQO) was.

Mr Abader replied that she was engaged in a prior engagement which had been organised a long time ago.

The Chairperson bemoaned the fact that the DG would be late, and that the DEA had only directors before the Committee, without the NAQO, though the Committee support staff had told him that the NAQO had been working closely with them on preparing for the colloquium. He was not impressed, as he felt that it showed contempt for the Committee, because the key person had not indicated that she would be absent on the day, as preparations had been started well in advance. If it were not for the stakeholders that were present, the Committee would have sent the DEA back to return with senior and responsible officials.

The Chairperson said the official who had signed off on the NAQO to be absent from the colloquium had to explain to the Committee what event was more important than the colloquium.

Health Studies in the Declared Priority Areas

Ms Elizabeth Masekoameng, Director: Atmospheric Policy, Regulation and Planning, DEA, said that the DEA’s strategy to address air pollution in dense low-income settlement had been to establish a coordinating structure -- the National Coordination Committee (NCC) -- on residential air pollution. Work in the Vaal Triangle-Airshed Priority Area (VTAPA) and the Highveld Priority Area (HPA) had mostly been driven since 2006 through multi-stakeholder reference groups (MSRGs) and implementation task teams (ITTs), where projects had been established in priority areas so as to develop better interventions over time. The DEA had started the VTAPA health study in 2013 and had completed it by 2016.

History of Point Source Management in South Africa

APPA to AQA Transition

Mr Vumile Senene, Acting Chief Director: Air Quality Management, DEA, said during the transition between the Atmospheric Pollution Prevention Act (APPA), 1965 to the Air Quality Act (AQA), 2004, the DEA had been able to separate two industries -- the old power generation plants and the new plants. Between 2010 and 2015, when the DEA had already promulgated the minimum emission standards, but which would come into effect only in 2015, the existing plants were already complying with the APPA, whereas the new facilities had been required to comply with the new minimum emissions standards (MES) by 2020.

In the past, only facilities used to know what the emission limits were, without the public having similar information but that had changed since the AQA.

The DEA had a programme of strategic MES compliance enforcement, where it selected particular industries which would then be targeted. That was beyond what specific licensing authorities would undertake in their own compliance enforcement exercises. What had been observed about facilities exceeding the MES was that the non-compliance had not been continuous.

Discussion

Mr R Purdon (DA) said that previously the DEA had said that EnviroServ was situated in the Eastern Cape, but here DEA was saying EnviroServ was in Roodepoort. He needed clarity on that. Was the list of non-complying facilities available publicly?

Mr Z Makhubele (ANC) asked whether the VTAPA health study had any legal status, on the basis that household surveys depended on the truthfulness of respondents without verifying the authenticity of what the respondent would have said. How relevant had the VTAPA health study been to the AQA?

The non-compliance uncovered seemed to be mostly because of old technology and poor quality coal, which was deliberate by industry. It was not as if SA did not have good quality coal, but the good quality coal was being exported. He hoped that in future the DEA would not be lenient on industry if the trend continued.

He also wanted the list as requested by Mr Purdon, especially of companies which had not complied and had not applied for a postponement as well.  

It was counterproductive to bemoan air quality monitoring as a concurrent function, when the DEA knew that local municipalities did not have the capacity to monitor, license and enforce MES. What had the DEA done so far to assist local government in that regard?

Ms J Edwards (DA) wanted to know the year and dates when the acute health risks community surveys were conducted.

Ms Elana Greyling, Waterberg Communities, said that the communities felt that their voice was not being heard. Bad quality coal had a lot of SOx, and the new good quality coal was being removed from the bushveld, leaving only SOx coal. To date it was well known that the Matimba Power Station in Lephalale was emitting twice as much SOx as the entire Great Britain. Medupi Power Station at full power would be emitting twice as much SOx as Britain in one year. The only conclusion was that with Medupi at half capacity, and Matimba at full, anyone travelling in the bushveld was already inhaling SOx. Waterberg had a lot of other challenges, but to tell its residents to allow postponements of up to ten years when there were toddlers was unacceptable.

The environmental waste management and air quality official in the Waterberg region was doing his utmost best but lacked the capacity. There were only two air quality officials in that region, and they were not stationed in Lephalale.

There were currently seven other coal-fired power stations in various processes of authorisation and licensing in the Waterberg, and more than eight proposed coal mines, apart from Grootgeluk Coal Mine which was servicing Medupi and Matimba, which were also in various stages of authorisation. All these coal utilities depended on the bad SOx coal, and Ms Greyling felt that if the proposed benefits of those had not been derived yet, why could the bad coal not just be left underground? The only things that had increased in the Waterberg region had been the crime rate, the burden of disease and unemployment, as everyone had now rushed to Lephalale because of the coal extraction.

Ms Nicole Loser, Attorney, Centre for Environmental Rights (CER), asked why the DEA was continuing to authorise new proposed coal-fired power stations in areas where there was non-compliance with Ambient Air Quality (AAQ) standards, specifically in the Waterberg. Even if the new plants’ designs were expected to make them compliant with the MES, the point was that they would contribute to an already unacceptable and non-compliant AAQ. The air quality framework required that decision makers had to consider the additive contribution, and not only the individual contribution, of new coal developments.

Ms Nomcebo Makhubelo, Highveld Environmental Justice Network (HEJN), said her concern had been that as stakeholders, the HEJN had brought itself to the colloquium at a high cost, whereas others had been accommodated financially.

Ms Zodwa Rannyabi, Women’s Evangelical Exchange Forum (WEEF), asked whether the DEA during the VTAPA health study had asked low-income residents why they did not go to public health care facilities when they knew they also could not afford private health care. Could Ms Masekoameng give the percentages based on the figures she had presented on acute health outcomes in the community survey?

Ms H Kekana (ANC) said tuberculosis (TB) incidence was quite high in Rustenburg around her constituency. Could the DEA go and monitor the air quality there?

The Chairperson said that at the Committee’s previous engagement, there had been problems with non-operational air quality monitoring stations. What was the current situation of those non-functional air monitoring stations?

The Committee had resolved that it wanted a full day or two to receive a comprehensive briefing on MES. The Committee wanted to know what had been approved thus far, what the outstanding applications were, and the reasons for approvals during that future planned briefing.

Seeing that new plants had to comply with the 2020 MES and with the existing plants complying by 2020; there was also provision for extensions, according to his reading of the current regulations. There seemed to be no limit for extensions. Would the DEA continue granting extensions indefinitely?

DEA response

Mr Abader replied that EnviroServ Eastern Cape was the name of an incinerator located in Roodeport.

The DEA would make the list of non-compliant facilities available to the Committee.

In the VTAPA health study, the child respiratory health survey had been a more scientific study. The community health survey had not been truly an indicative study of community health or air quality effects study, though the move had been towards a finding a study which would correlate health effects and air quality.

The DEA expected that new plants had to comply with MES, but the challenges that DEA were dealing with were historical, in that they were trying to get old plants to be compliant with the new MES.

Regarding capacitation of local government, the area was complex in that air quality officials at that level were quite sought after and there was a high turnover rate. Indeed, the DEA had programmes where it tried to increase the capacity at the local government level, and it also liaised with provincial DEAs to assist in that regard.  

The dates of when the surveys had been conducted would be submitted in writing to the Committee.

The Waterberg was a priority area and in comparison to the Vaal, the Waterberg region was still developing. The DEA’s intention was that even before the proposed developments, it would look at air quality.

Regarding Ms Loser’s question, Mr Abader said that the DEA had to consider alternative energy generation sources and there was provision for mixed energies. The DEA was required to consider applications for new coal fired power stations, but it would do that having assessed their implications.

The DEA would certainly oblige Ms Kekana’s request to look into Rustenburg. The Department had noted the Committee’s request for a whole day briefing on MES.

The extension would not infinite but as the DEA had responded, it was dealing with old plants to bring them to comply, and new plants that had to be complying from the outset.

Mr Senene said that a number of interventions had been planned for air quality stations which the DEA had deemed strategic, for what it called its ‘missionary quality indicator.’ The DEA would roll-out a programme to assist the identified stations to ensure that over the next five years, the stations would be maintained so that they could give the DEA data. That did not mean, however, the other stations would not be prioritised. The figures of prioritised stations would be submitted to the Committee in writing.

In terms of poor versus good quality coal, the DEA had received through its communication with the Department of Mineral Resource (DMR) a policy on coal usage which it was currently seeking comments on. It had been clear that good quality coal continued leaving SA, and therefore the DEA would revisit the policy with the DMR to indicate the effects of coal in AAQ high priority areas.

Together with Bojanala, Rustenburg fell under the Waterberg priority area, and the DEA had established MSRGs and ITTs since the implementation of the Air Quality Management Plan (AQMP). He invited Ms Greyling to engage the DEA within those platforms so that together with local Government communities, the DEA could respond to community issues.

The Chairperson reiterated his question as to whether there would be a time where the DEA would not accept postponement applications.

Mr Senene replied that though the legislation did not appear to limit how many times a facility could apply for postponements, his opinion was that the intention was not to grant extensions forever. The idea for the DEA had been that by 2020, all plants would be complying with MES, as envisioned by the AQA.

Mr Abader said that the total number of air monitoring stations in SA was 157. The government owned 118 of those, and 39 stations belonged to the private sector. All stations in high priority areas were functional; six were in the VTAPA, five in the HPA and six in the Waterberg-Bojanala Priority Area (WBPA).

Mr Makhubele wanted to know whether the stations, though functional in high priority areas, belonged to the government or the private sector.

Ms Masekoameng said the DEA had used a scientifically robust approach in how it had conducted the VTAPA health surveys. It would have done better if it had respiratory indices from the Department of Health (DoH), in a similar manner to those of HIV, but the DoH did not require clinics to keep such information.

The DEA had not asked why low income residents in the VTAPA region had not gone to clinics in its survey, as it was outside what it wanted to measure. Anecdotally though, DEA investigators had come across reports that some respiratory illness sufferers felt their problems were not serious enough, others used traditional healers, and those who went to clinics and hospitals had not been captured, as that was not a DoH requirement.

The VTAPA health study had been commissioned around October/November 2013.

The stations owned by it in high priority areas in partnership with the South African Weather Services (SAWS) were five in the HPA, six in the VTAPA, and three in the WBPA. The Mpumalanga DEA owned four ambient air quality monitoring stations which were currently under resuscitation.

Mr Senene said that since the debate had been about why SA was not moving to alternative and renewable power sources, and why the DEA was not approving new entrants into the power generation market, it had considered whether SA was at a stage where it could switch power generation, as it aspired to have made the coal-fired plants comply by 2020. Additionally, the DEA had considered whether it would not be keeping SA dependent on coal by focusing on old plants, and at what point would extensions not be granted any longer? The MES acknowledged that there needed to be a transition from one source of power to another, but the devil was in the detail.

Further discussion

Mr Purdon said he was disturbed by the revelation that the health study at VTAPA had been commissioned in 2013, since four year old statistics meant nothing to him.

Ms Keitumetse Modise, Zamdela community, Sasolburg, said she disagreed that there were six functional air monitoring stations at VTAPA. She had attended a Sasol community engagement, where her community had asked the company why it kept giving them the same statistics. Sasol had replied that seeing the community did not understand the use of the monitoring stations, it kept stealing copper cables used at the stations. Her community had then asked Sasol to install solar panels to measure ambient air quality with Sasol. She wanted to know which municipalities in the Vaal were attending the community engagements when Sasol was engaging communities.

Professor Leslie Petrik, University of Western Cape (UWC), said that to her knowledge SA had become a signatory to the Montreal Protocol in 2016, but the DEA was saying that according to the AQA, the only things to be worried about were PM, SOx and NOx. There were many other pollutants that the DEA were not monitoring, though it had picked up quite a few chemicals when assessing facilities. When would the DEA start monitoring those chemicals which were also contributing to bad air quality?

Mr Tafadzwa Mandova, Research Assistant, ISAT laboratory, UWC, said he was concerned about the distribution of the DEA’s sensors, as that affected the quality of the data that it collected. The South African Air Quality Information System (SAAQIS) said that it had about 12 to 13 stations in and around Cape Town, where there was one station in Table View and another one in Bellville. Did the DEA think it appropriate to use data from one sensor to conclude that an area had air pollution or not? 

Ms Robyn Hugo, Programme Head: Pollution & Climate Change, CER, said that every least-cost electricity model showed that SA had no need for any new coal or nuclear energy source. Postponements were in essence exemptions which the CER felt were illegal, and as such it was of the view that a power producer that did not comply with MES had to decommission that station. The CER wanted to know whether the NAQO would consider reviewing and withdrawing postponements which she had already granted.

Mr Bongani Mthembu, Durban South Communities, said that industries were a law unto themselves. For example, the communities which he represented hosted two major chemical utilities -- Engen and SA Pulp and Paper Industries (SAPPI) -- with a host of other air polluting industries. Had the Government actually ever studied the diseases caused by air polluting industries and compared those to the money government spent on treating those diseases and how much it taxed air polluting industries annually?

Had the DEA finalised its Air Quality Management Plan (AQMP) or was it still at the draft stage?

The eThekwini Metropolitan Municipality was a region highly hazardous in terms of air pollution. It lacked an emergency evacuation and AQMP, while it hosted one of the biggest chemical storage facilities in the southern hemisphere. Could the Committee follow up on whether eThekwini had emergency evacuation plans for chemical and air pollutant events? The municipality had also stopped making available air quality data publicly since 2010, and the reason given was that the sensors no longer functioned or that they had to go through the SAAQIS.

Ms Greyling said she was confused about why Eskom’s Medupi Power Station was applying for a postponement when it was a new station, because she had attended meetings where Eskom had said that it had no plans to retrofit Matimba as well. She bemoaned the fact that Lephalale had only two monitoring stations when it was the biggest settlement in the WBPA. Even though the new plants with new technology would have reduced SOx and NOx emissions, there would be higher CO2 emissions which had an effect on the ozone, meaning that climate change effects would also be more severe.

Ms Miche Koyama, Attorney, CER, wanted to know whether the repeat offending companies on non-compliance had been fined, or what enforcement action had been taken against them? Had the enforcement action been effective and was that information available? How many air quality officials had been appointed to date at the local government level? Were they representative of their local municipalities? Would the appointments increase in future?

The Chairperson said that hopefully the South African Local Government Association (SALGA) could assist the DEA in responding to the questions on local government. Officials from the City of Cape Town and the Mpumalanga DEA could also assist with some of the questions that had been put to the DEA.

Mr Ian Geldenhuys, Specialised Environmental Health, City of Cape Town said there were 13 monitoring sensors around the city. The number of stations installed was guided by the national framework based on population -- that is, per 100 000. To date, Cape Town had doubled that requirement, though the cost of installing a monitoring station was expensive because it rounded up to R2.5 million. There were other methods of monitoring, like screening tools but the city had adequate monitoring tools to have a representative idea of the air quality.

He had a team of eight staff who were air quality monitors on the ground, with three in supervisory level capacities and an official who ran the city’s air quality network. Though not enough, it had been evident since taking on the function in 2010 that local government had gone through an unprecedented scale of legislation, as about 12 new pieces of legislation had been promulgated to date, while their staff complement had remained the same.

Ms Sally Benson, Air Quality Planning & Information Management, DEA, Western Cape (WC), said that the WC government had 11 monitoring stations which were functional. They had co-located sensors in Khayelitsha and Vissershok, with the City of Cape Town. The remaining nine were spread across the WC and since there 30 municipalities in the WC, there were 30 air quality officers as well. There was a team for air quality monitoring and a separate team for compliance inspection, and there was an air quality planning and information management team.

Mr Mandlenkosi Mahlalela, Provincial Air Quality Officer, DEA, Mpumalanga, said he came from an area where historically no one had attended to air quality specifically, but there had been a pollution and waste management directorate. Across the three districts in Mpumalanga, there were pollution and waste management officials. Around 2013, an air quality unit had been established, though it was still not fully fledged, as he still was the only air quality official for all of Mpumalanga. However, all three districts had air quality officers appointed and the province had established an air quality management unit. Indeed, the capacity was not commensurate to the task at hand.

Mpumalanga owned five monitoring stations, where the supply chain management requirements of the Public Finance Management Act (PFMA) had, at the point of changing service providers, become an obstacle and caused delays. Mpumalanga also hoped that by not going out to tender and simply arranging for the SAWS to manage its monitoring stations for the next three years, it would allow the province to gather capacity, and to take back the function after three years. Mpumalanga also conducted forums where it engaged communities on air quality management.

Mr Jacob Legadima, Gauteng Provincial Air Quality Officer, said that Gauteng had 29 air monitoring stations. Ten were at Ekurhuleni, nine from the City of Johannesburg (CoJ), another nine from the City of Tshwane (CoT), and the remaining districts had two stations each. More than 20 monitoring stations were operational and Gauteng had allocated a two-year tender, ending in 2019, where the province funded the stations at the municipal level, because the province used to have seven stations but had since donated those to the municipalities. There were two sub-committees in the province -- one was responsible for monitoring and the other was responsible for licensing. In 2016, Gauteng had acquired a service provider to train municipal staff on air quality monitoring.

Mr Mnikeli Ndabambi, General Manager, SAWS, said that SAWS plan with Mpumalanga was to capacitate the province so that in future it could deal with air quality management on its own.

Ms Tyhileka Madubela, Committee Secretary, said she had received a request to accommodate stakeholders through travel vouchers and accommodation. The list of attendees had changed so much that by the time of applying for the travel vouchers from Parliament, it had been too late and the staff could not arrange the vouchers.

The Chairperson said that the NAQO had been given the power to grant postponements, and he belaboured the point again that it was unacceptable that the colloquium was at that point without her being able to account.

DEA’s response

Mr Abader said the DEA had noted the Sasolburg matter of communities requesting solar panels being installed at the monitoring stations. The DEA would certainly want to engage Professor Petrik on the many other pollutants that the DEA were not monitoring.

The DEA would reply in writing to the question about what it had done about non-compliance, but as an analogy, the DEA’s enforcement had started in 2009 with notifying Eskom about its compliance. In 2011 and 2013 it had repeated the notice, but the compliance action detail would be contained in the written response.

Mr Senene said that the location of monitoring stations was determined by a few issues. Security was one, and irrespective of who owned a sensor, the DEA regularly encountered a station that would be down because of a power failure or cables missing. The stations were operational, but encountered problems now and again.

Mr Senene said he had oversight of the three ITTs in the Vaal. One had been located in Sedibeng, another in Johannesburg, and across the boundary between Gauteng and the Free State. Meetings were held regularly.

Regarding the Montreal protocol on ozone-depleting substances and why SA had decided not to monitor them, he said the DEA had categorised pollutants so that from a health perspective this would have a significant impact. Though it would be ideal to monitor other pollutants, costs had to be factored into the monitoring involved, and that also spoke to the number of stations that would have to be put in place. In addition to what DEA already monitored, it monitored carbon monoxide (CO), ozone and other organic compounds. The reason for the focus on SOx, NOx and PM had been because they had been identified as the most prevalent and sickness causing pollutants. 

Each of the three priority areas had an AQMP which outlined the objectives and goals to be achieved in a particular AQMP.

In the AQA, a ‘new activity’ had been defined as one that had obtained authorisation after 2010, with the recognition that the activity would be in line with MES. The reality was also that it would have taken years to authorise facilities.

One of the challenges that the DEA faced was the ‘revolving door’ of air quality personnel, but the DEA endeavoured to fill any vacancies that occurred.

The Chairperson said that the Committee had resolved that it wanted a briefing by the DEA on air quality. What had delayed the submission of the study to the Minister and Cabinet?

Ms Masekoameng said the study, though commissioned in 2013, had been finalised in 2016.

South African Local Government Association (SALGA)

Ms Annette Deppe, Ward Councillor: City of Johannesburg (CoJ), and member of the provincial SALGA, said SALGA was disappointed with the no-show by the NAQO and other senior officials of the DEA. SALGA was honoured to be before the Committee to speak on the environmental management of the implementation of the AQA by its member municipalities. It was important for the colloquium to reflect on the ability of municipalities to lead in their obligations, as well as recognise the challenges they faced in fully discharging their responsibilities.

Ms Telly Chauke, Specialist: Environmental Management & Climate Change: SALGA, said that SALGA had been established in terms of the law to be the voice of local government. Since a lot of questions had been directed at local government, which had a moral obligation for environmental performance, it had to be recognised that the air quality function resided within district and metropolitan municipalities. Local municipalities were merely required to have plans in place to assist air quality officials. Therefore the air quality function was concurrent between the two spheres of government, as stated above, in that local municipalities developed policies and by-laws for enforcement and monitoring. Furthermore local municipalities had to ensure that sector plans were aligned to their integrated development plans (IDPs).

When looking at the AQA, SALGA found that there some issues that were mandatory, and those functions which SALGA felt were discretionary:

• Licensing
• Planning
• Consultation
• General functions.

Local municipalities always received a bad narrative, where the technical response referred to capacity deficiencies and under-resourcing. There were, however, high performing municipalities as Cape Town, which had demonstrated in its response.  

In 2015, the DEA had developed a national strategy on monitoring of air quality, where it had benchmarked Cape Town with regard to of infrastructure. Subsequently, SALGA had done a study of its own where it had realised that costs excluded a lot of drivers that were attributed to operating a functional air quality sensor.

Regarding how many air quality officials there were in local government, there 257 municipalities, eight of which were metros. The capacity in the metros possibly tended to overtake the capacity at local municipalities. In 2011 SALGA had commissioned a study on organisational capacity at local municipalities, where it had recommended that a municipality needed to have at least four air quality officials. SALGA had developed a finance policy position on how to improve financing for the environment sector at the local government level.

Ms Chauke said that all the work that SALGA had been doing in terms of AQA had been in consultation with the DEA. SALGA had also realised that even though local government was autonomous, it could not work in silos from national government and play the blame game during accounting.

She said that SALGA was proposing that municipalities needed at least four officials to carry out air quality monitoring. eThekwini Metro did have a disaster management team and plan, together with an off-site plan as well. Moreover district municipalities had a responsibility for primary health care and as SALGA, they had not been able to articulate how much air quality monitoring impacted on district health.

Human exposure and health effects of air pollution in priority areas

Mr Rico Euripidou, Environmental Health Campaign Manager, Groundwork, said that Groundwork was the “Friends of the Earth SA,” and its work was geared towards improving the quality of life of vulnerable people in South Africa. The people most affected by air pollution were the people least responsible for its creation, and also the least for whom people did something about that air pollution.

The World Health Organisation’s (WHO) conclusion that seven million deaths worldwide were linked to air pollution was based on epidemiological and scientific data. The DEA’s study focus had been on respiratory outputs from self-reporting on respiratory outcomes. The communities with which Groundwork engaged had indicated that the interventions were subjective and were driven by different circumstances. The health-seeking behaviour of poor people on the bread line was quite different from the health-seeking behaviour of other people in society, and when poor people did report they self-reported issues which were very different.

He said there were better measures of objective health outcomes from air pollution -- diseases and deaths linked to heart disease, and those linked to obstructive pulmonary disease. It was impossible to misreport or under-report the above health statistics.

He referred to Eskom’s forecast annual average PM2.5 (atmospheric particulate matter that has a diameter of less than 2.5 micrometers) contribution from plant covered in its application for emission limit derogation, and said from the work of Dr Mike Holland, of the European Marketing Research Centre (EMRC), it had become apparent that PM2.5 was a regional contaminant.

Mr Euripidou said that even if the cost to economy, as presented, was wrong at R2 billion -- or even half that -- the justified cost of making industry meet the MES in SA would be recovered in a couple of years.

The Chairperson said Eskom could reply to some of the discussion questions after it had presented first.

Eskom’s response to Minimum Emission Standards

Mr Thava Govender, Group Executive (GE): Transmission, Eskom, said that MES were indeed needed to reduce the harmful effects of air pollution in SA. He then read through the presentation with the Committee.

The Chairperson asked Eskom to elaborate on section 5.4.3.3 of the National Framework for Air Quality Management in the Republic of South Africa

Mr Deidre Herbst, Senior Manager: Environmental Management, Eskom, said that the provision spoke to cost-benefit analysis and to approach air quality from a holistic view, which meant consideration of parameters such as cost, water use and other socio-economic aspects. Eskom had never had a cost-benefit analysis until 2017, when the DEA had enforced that requirement. Eskom had undertaken that analysis for its next postponement application. Hopefully that analysis would be done in cooperation with industry and the DEA, so that it could inform decision-making through addressing priorities and high priority areas on health and socioeconomic perspectives.

Discussion

Ms Hugo wanted to know when Eskom would eventually comply with the requirements for SOx and NOx at its other 13 power stations. 

Ms Makhubelo said the reason why low income South Africans did not self-report or seek public health care was that there often were no medicines in the clinics.

She did not understand whether Eskom cared more about profit, compared to people’s lives. During the apartheid regime in Soweto, residents had been paying a flat rate for electricity and no one had been indebted to Eskom then. Now Soweto residents had Eskom bills. She also wanted to know whether Eskom inducted its meter reading officials, because they had a tendency of reading one meter in one street and then speculating and extrapolating meter readings of the next four houses in the same lane. How were the tariffs determined, because in the Free State, R200 purchased sufficient kilowatt hours (Kwh) for a whole month, but in Soweto one had to buy R100 of Kwh for every second day of the week.

Ms Christine Redell, Attorney, CER, said that Sasol had claimed in print media that its off-set programmes had been successful, in that the programmes had resulted in a reduction in energy requirements. However, it had also acknowledged that the impact of the off-set programmes on ambient levels had been less clear, when in fact Sasol was required in terms of its postponements application to implement off-sets that would reduce PM and SOx pollution in the ambient environment. What kind of compliance monitoring was the DEA taking to ensure that the conditions of Sasol’s postponements were met and that the off-set programmes achieved the objectives set out?

Ms Greyling said that the local residents had told Eskom before the commissioning and construction of Medupi Power Station that Lephalale was water scarce and the SOx content of Waterberg was quite high, so that compliance with MES would be challenging, but Eskom had gone ahead despite the information. The power utility was then telling stakeholders that SA had to wait for emission-abating technology to be installed, and that would result in higher tariffs. The expectation, therefore, was that Eskom expected the Waterberg communities to pay with its health, safety, environment and the future of its children for decisions Eskom had made, knowing what the challenges would be.

Mr Makhubele said that SALGA and the DEA were quite aware that government currently was short staffed for the management of air quality monitoring stations, so unless they were both to undertake to the capacitation of personnel at local government, by the time the SAWS three-five year up-skilling contracts expired, local government would be unable to take over the function fully.

Was the country in a position to manufacture the equipment for monitoring stations, instead of ordering and importing equipment?

As the DEA responded to MES being exceeded in high priority areas, Groundwork had argued that there had been minimal impact from compliance monitoring on reducing the excesses. What was the view of the DEA in that regard?

Mr Purdon asked if the Committee could be furnished with a document providing information on the age of power stations and their MES compliance status, and when they were due to be decommissioned.

The Chairperson referred to a compliance projection slide, where the projected amount had been put at R63 billion. Postponements had been projected at R75 billion, and R300 billion for full compliance. He wanted clarity on whether the amounts related to all the power stations in the country, and whether a cost-benefit analysis was still on the way, so that if the cost was too high there would be non-compliance, since R300 billion was a large figure. Was there an option for Eskom simply not to comply with MES?

Ms Chauke said that SALGA possibly was not the correct entity for capacitation at local government, but academia would be able to do it. SALGA could assist in ensuring that the environment at local government would be able to absorb the skills. It could lobby the Department of Cooperative Governance and Traditional Affairs (COGTA) to develop an institutional framework that would enable the implementation of benchmark organograms. It was already assisting some cities and local municipalities to create those environments to absorb skills at local government through benchmarking.

SALGA also worked with the Local Government Sector Education and Training Authority (LGSETA) on skills development, where it was trying to get staff complements at existing air quality monitoring stations on a par with what the industry norms and standards were. It also ran a virtual academy that looked at leadership, but would extend that to the operational level, to see how best municipalities could capacitate.

Lastly, there was a skills development grant that was directed at engineering services, where municipalities were subsidised to recruit talent. Together with the DEA, SALGA was lobbying COGTA to extend that grant to include environmental services as well.

SALGA had also worked with the National and Provincial Treasuries (NT and PT) on the South Africa National Treasury Cities’ Support Program (CSP), to look at how government tailored services. Water utilities, municipal roads and all other municipal services always had an air quality component , but government had not fully accounted for the level of skill, support and funding needed at the local government level, apart from engineering to do the work at monitoring stations.

Ms Chauke wondered whether the cost tariffs had been factored in by Eskom with its projection of R300 billion for full compliance by all its stations. Her concern was that in a developmental state, such costs got shifted to consumers through tariff increases and that would mean municipalities would have to pay and charge more for power when they were already indebted to Eskom. How could Eskom externalise that amount?

Responses

Mr Senene said that the measuring of offsets was simply a positive improvement on the air quality where the offset was being implemented. To date, all those that had offset programmes to be implemented had been followed up by the DEA.

He said that the SAWS had indicated that there was a normative plan for air monitoring functions to be taken over by the DEA provincial and local officials at local government, as the SAWS had earlier indicated regarding how it was assisting Mpumalanga. Going forward, the DEA was reviewing the kind of monitoring going on at stations to ensure that it was more streamlined and efficient and there was an ultimate plan for all municipalities to monitor by themselves sometime in the future.

In the field of air quality, there were particular standards set across the world for equipment. However, the challenge was that not all standards were best practice, and the DEA aspired to get the best, and he was not aware whether SA currently produced any air quality equipment. The DEA was developing an asset management system to address issues that came up when it had to procure equipment from outside SA.

Mr Senene said though the numbers for MES excesses were high, as presented by Groundwork, over the period measured there had been a reduction in emissions because DEA’s monitoring went back beyond 2012. DEA acknowledged that the numbers were not anywhere near what was desired, but there had been improvements, especially in PM2.5.

What was impossible to see from the graphs was that SA was mostly fine through the year in respect of pollutants, but in the months of May to September, pollutants increased in the ambient environment.

Ms Lauren Rota, Response Lead, Policy & Sustainability, Sasol, said Sasol had a comprehensive baseline from where it reported on its offsets, but the information would be contained in its annual report for 2017. It had offsets for Zamdela near Sasolburg, and eMbalanhle near Secunda. Sasol was not only monitoring ambient air quality, but indoor pollution and indoor temperatures, because the colder it was the more energy was needed to keep warm, and Sasol’s offset plans had been geared towards less energy use to keep warm in winter, especially for wood and coal use. Sasol had also undertaken to do quality of life surveys, as it believed there were particular co-benefits that could be developed through offsets beyond air quality improvement.

Mr Govender said the R300 billion projections for compliance included a 10% tariff cost. The amount was for compliance at all Eskom’s power stations. There was no option for Eskom to not comply, because it was the law that everyone had to comply.

The work planned for Medupi would include private sector participation.

The cost benefit analysis involved a conjugated mix, since Eskom had to consider that it would not make sense to spend over R300 billion on environmental compliance across its plants, when some of those plants were to shut down in three years time. Another side of the coin where compliance was concerned, was that Eskom had to comply with the reduction treaties which SA had signed in terms of coal burning and producing carbon dioxide (CO2). The only way to do the latter was implementing the integrated resource plan (IRP) so that coal-fired power stations could be decommissioned in favour of the energy mix.

 Eskom would provide the age analysis format as requested by Mr Purdon.

The Chairperson asked whether the Committee could be told which power stations were to be decommissioned.

Mr Govender said Eskom had put flue-gas desulphurisation (FGD) at Kusile, and would prioritise Medupi second. Matimba would follow Medupi, but from a particular emissions view, it was the older stations, together with Thuthuka, that were to be decommissioned. The work was based on prioritisation in terms of economic value, the Integrated Resource Plan (IRP) and MES exceedence.

The Chairperson said that from his understanding, the IRP had to have been tabled and released in September 2017.

Mr Govender replied that the latest information he had from the Department of Energy (DoE) had been that the IRP would be implemented from February 2018, as it was still out for comment.

He said when planning for Medupi and other stations, there had been no requirement for Flue-gas Temperature Distribution (FTD), and there had been sufficient water for the whole power station and three FTD plants. Water had not been the issue, but what had hindered progress at Medupi were the new requirements that the FTDs had to be retrofitted with FGDs. There was a water augmentation scheme which would come online by 2021.

He said that with all the work Eskom undertook, it ensured meeting all the requirements around localisation in terms of work force. An example was the Grootvlei work.

Eskom were still compliant with all 13 SO2 requirements, but the cost of an FTD was like fitting another power station around an existing station, and was not cheap.

The Chairperson acknowledged that in hindsight, the Committee should have invited the DoH, but the list of presenters had been long when the Committee was still planning. While acknowledging the DEA’s case by case approach to postponement applicants, the Committee wanted to be kept abreast and hands on in each case.

Mr Mthembu, of Durban South Communities, asked if after lunch the Committee would allow stakeholders to question the presentations of the morning, as he had outstanding questions.

The Chairperson said that was in order. The Committee broke for lunch.

Afternoon Session

Mr Mthembu said he had noted a trend at local government for municipalities to employ unskilled people to fill critical posts. There was a lot of talent which had been developed through public funding being lost to the private sector because of patronage and nepotism. If there were competent people in local government, there would surely not be a 60% backlog in the licensing of companies in terms of the AQA. Businesses such as Engen, Sasol and other big players, were required to pay under the pay-per-listed activity, and if that indeed were an occurrence, then companies would have no funds for the skilling of their work forces, and certainly would not be able to invest in professionalising them.

SA had to become like China, if that was the only way it could start making its own equipment. Procurement of big and expensive equipment was problematic, and components would have to be sourced from different parts of the world to keep it functional. In such circumstances, industry would escape being monitored.

Ms Chauke said that though SALGA did not condone malpractice, participants in the colloquium had to guard against over generalisation. She acknowledged that competence was a challenge, but this was not the situation across the board, although there were pockets where municipalities failed SA citizens. The incompetence she was referring to was when one official in a municipality did the work of four different people, and that was a systemic matter. Local government was probably the most over regulated sphere of government in the country, to the extent that even accounting for a building structure was regulated by COGTA. That was why she had suggested in her presentation that SALGA, with COGTA, had to reflect on who presided over the local government space. SALGA had started benchmarking for local government, including what kind of minimum competencies a particular post would require. All of this required working through the regulatory regime, from COGTA to National Treasury.

In cases where there were competent people, there was a “revolving door,” which meant that the environment at some municipalities was not attractive to them. SALGA was trying to influence local government to offer competitive salaries. There had to be a development of confidence-building by the private sector in local government, having noted the language used when referring the local government.

Council for Scientific and Industrial Research (CSIR)

Prof Rebecca Garland, Natural Resources and the Environment Unit, CSIR, described trends in air pollution in South Africa, and said that the focus of the sub-group was on air quality and environmental health. This involved:

• Air quality modelling;
• Health risk and impacts from air quality and climate change;
• Air quality-climate change linkages;
• The use of models and existing data to improve understanding of atmospheric science in the region through some primary data collection, but generally in collaboration with others.

The goal was to provide an evidence base to support decision makers in air quality and climate change

In considering the Environmental Performance Index (EPI) PM2.5 comparisons of the average of priority areas, the CSRI had looked at other international data trends. However, international datasets needed to be tested for their applicability and utility, and she questioned what could they be used for, as they tended to underestimate PM2.5 ground-level values.

Proper measurement of ambient air quality

Prof Eugene Cairncross said he had retired from the Cape Peninsula University of Technology (CPUT), and that in the previous four years he had been working on environmental rights issues, especially air quality. His presentation would be based on work he had done in 2016 in connection with a burden of disease study he had carried out with the Medical Research Council (MRC). His role during that study had been to review the ambient air quality data available, since at the centre of the research had been a need to know the concentration of pollutants, especially PM2.5, an estimate of the exposure to the air which was respirated, and the health impacts therefrom. When he had requested data from the SAWS across all the air quality monitoring stations, he had found that the amount of data was not as great as he had expected.

He then read through the presentation with the Committee, stressing the importance of air quality monitoring, and describing the provisions of the National Environmental Management Air Quality Act (NEM-AQA) and the framework.

He said proper air quality monitoring involved:

 

• Production of good (acceptable according to criteria) quality data;
• Spatial distribution and number of monitoring stations, and pollutants monitored, taking cognisance of factors such as the characteristics and sources of pollution, population distribution, etc;
• Proper management of data;
• Accessibility of data.

The figures on record had to be checked whether they had been submitted for proper quality assurance processes. Referring to data accessed through the South African Air Quality Information System (SAAQIS) website, he said one could observe a series of low data values at the Eskom Marapong PM2.5 measuring site. One of the data management procedures was to see whether there was nothing wrong with the recordings, and reporting whether the instrument had been calibrated correctly, or if there was something else which was faulty with the instrument.

He said the solid red line in the graphs represented the air quality standard for pollutants. Where it was flat lined, it meant there had been no data reported to SAAQIS for that period, possibly because of the problems he had referred to about calibration, or the reported data not being available on the website.

He said PM2.5 was a particle smaller than 2.5μ, which was important because not only was it a pollutant resulting from heavy industry and vehicles, but was also a secondary pollutant formed because of SO2 and NOx reacting in the atmosphere. It was therefore a dangerous health impact pollutant, and not monitoring for it was to miss out on an air pollutant with adverse health effects.

Centre for Environmental Rights (CER)

Ms Robyn Hugo said that the CER comprised a group of attorneys that advocated and litigated for the right to a healthy and safe environment. Working with Groundwork, they had formed the “Life After Coal” campaign to accelerate the retirement of the existing coal infrastructure and to encourage and enable a transition to renewable energy systems.

The Highveld Priority Area (HPA) was home to 12 of Eskom’s coal power stations and Sasol’s Secunda refinery, among many hundreds of mines and other facilities. Ten years ago, following demands by civil society for intervention to address the significant air pollution, the Highveld was declared the second priority area (after the Vaal Triangle) under the Air Quality Act (AQA), The DEA had declared that “people living and working in these areas do not enjoy air quality that is not harmful to their health and well-being”, as required by s24 of the Constitution. Four years later, in November 2012, the Air Quality Management Plan (AQMP) was published, stating the main aim for ambient air quality in the HPA was to comply with all health-based national ambient air quality standards (NAAQS). Standards were set under the AQA that ambient air must meet in order for people to breathe that air without damaging their health. Specific objectives committed the DEA, the Mpumalanga and Gauteng provinces, and the affected municipalities to start tackling the air quality problems, and these were to be reviewed after five years.

Seven goals had been set to achieve the objectives, with timeframes and measurement levels. However, key findings were that air quality in the HPA remained poor and out of compliance with the health-based NAAQS, despite a decade having passed since the HPA was declared. The DEA’s own mid-term review of the AQMP, published in February 2017, confirmed that emissions had not decreased significantly – if at all -- over this period. Continued non-compliance with the NAAQS was likely, mainly due to the failure of key major industrial facilities to reduce their emissions either adequately, or at all. The NAQO’s decision in early 2015 to grant postponements from compliance with the minimum emission standards (MES) to the biggest polluters in the HPA – Eskom and Sasol – had made it significantly more difficult for air pollution in the HPA to be reduced.

Discussion

The Chairperson said he was concerned about the report by Prof Cairncross that only 20% of the 36 monitoring stations with usable data satisfied an annual data recovery benchmark of 80%, especially considering monitoring stations in metros, and asked for comments.

Mr Euripidou said he had noted that all three presentation tended to interlink, but the summary shown by the CER on exceedances on the MES, presented by the DEA itself, indicated that exceedances on single occasions could be very high. The averages over a year, or a period of many years, were smooth, but the slides of instances of high emissions told him a different story. Only where there were regulators that were immediately aware of those peaks occurring in real time, and were acting in partnership with health authorities, could government put out messages to the public for their own protection.

The Chairperson was also concerned about the report from the CER that the years down the line there had been no improvement in the HPA. What was the purpose of declaring an area a priority if no attention was given to that area? Was there a forum where the DEA and industry met on a regular basis to monitor and follow-up on compliance issues and challenges? How regular were such gatherings?

Mr Makhubele said part of the allegations by the CER had been that DEA was not showing any seriousness that air quality was a priority in its agenda. Furthermore, the CER had claimed that the DEA had demonstrated no motivation to enforce MES norms and standards by suspending licences when there was non-compliance. The Committee had visited Eskom and Sasol, and though he was not defending industry during those visits, it had found industry presenting its own data where it exhibited meeting some of the MES. He wanted to know, since the DEA had said it was unable to apportion blame for the ambient pollution taking place, the extent to which it could point to how and where Sasol had polluted. Considering the work which had been presented by stakeholders, was the DEA in a position to reconsider enforcement against particular polluters?

Mr Purdon said that the facts on the health impacts as presented by Groundwork and the CER were concerning, especially the fact that Medupi had the highest numbers though it was among the newest power stations. He wanted more detail on when the deaths had occurred.

Prof Cairncross said that on the exceedance of PM10 (particles of less than 10 microns in diameter), polluters tended to shift the blame about who had polluted. When the AQMP was published in 2012, it had included all the sources of PM10 and in modeling, ambient concentrations had been included when speaking to pollutants. In his presentation of pollutants per power station, it had been source apportioned and had shown which areas had low levels of ambient concentrations by source. The information was there, where what citizens respirated was related to the source of the pollutant. The emission of PMs was 98% industry-originated, so there was no question about the sources of pollutants. If one were to take, for example, a burning tyre from a house, indoor pollution would be originating from that burning tyre. He referred to the hydrogen sulphide graph, where Sasol emissions had been captured, and commented that nowhere else in the world would that magnitude of hydrogen sulphide MES exceedance be found. There were cases were sources of air pollution could not be disputed, and others where a correlation could be found regarding the origin of the pollutants.

The Chairperson asked Prof Cairncross to respond on the graphs where no reliable data could be obtained from the SAAQIS website, including for the stations in Mamelodi, Khayelitsha Diepsloot and others, as he had presented. What percentage overall would Prof Cairncross say constituted air monitoring stations with unreliable data?

Prof Cairncross responded that, as captured in his presentation, in 2012 only 11 stations were monitoring PM2.5. A few more PM2.5 stations could have been added, but the monitoring of PM2.5 remained very poor. His assertion was that possibly up until 2017 data was being collected by the mentioned stations, but the information was not available on the SAAQIS. As a result he could not tell what percentage data on PM2.5 was being collected.

Ms Hugo said that the data as presented in her presentation had shown the increases annually of domestic fuel burning (DFB) in the high priority areas and its health impacts, including deaths. Regarding steps on how atmospheric emission licences (AELs) could be suspended, compliance notices were one measure, while some kind of legal enforcement action could also be taken since compliance and enforcement efforts to date were not yielding the required significant results. For instance, the information that CER had made available to the DEA on non-compliance by Eskom and its various current relaxed postponement emissions limits, was very worrying for the CER. Eskom had said that though it would decommission some stations, it was also considering extending the lives of some of its coal-fired power stations, and it was applying for rolling postponements. This meant that HPA residents were having their constitutional rights to an environment not harmful to health and wellbeing violated on an ongoing basis.

Prof Garland said that though there were indeed trends of decreasing exceedances, she wondered how effective those were against the AQMP. Her other question had been why ozone had not been prioritised for measurement. Because ozone exceedances were quite high, that had to be another area of focus.

Whether in terms of the AQMP, or whether in the particular facilities and institutions particulates could be identified, emissions did not point to relationships about what people respirated. Emissions had no correlation with people experiencing them in the manner they were released. For example, when emissions were released in higher concentrations, more people would be affected generally. Similarly, more people could be impacted by the same emissions with a smaller amount. Ground level sources could still have large impacts to people living not just in the designated areas. There was evidence of DFB and aerosols’ dust being transported to great distances. Therefore, using just industry emissions only to categorise who was impacting ambient levels was not enough. There were multiple sources of pollution – at low levels and aloft -- and multiple impacts of pollution as captured in her presentation.

There was a need to understand proportion and all of the sources. SA had the skills for modeling, but there was a need for modeling, monitoring and tracing the particular industries or particular facilities, which was achievable. There was also a need for monitoring data to compare the former -- for example, if the input was from one source, then the modeling would be to that source alone and would be contributing to ambient levels.  

Although the CER had indicated that DFB was increasing, the only source of that data which she had seen had been from the census in which the data was quite flawed, because the census had changed questions and captured only what was required. Data from the Human Science Research Council (HSRC) had shown that most people used different fuels for different activities, depending on the time of the month as well.

Mr Euripidou said the Medupi death figures were deaths per annum attributable to that station. They had been determined by looking at the sum of the factors related to the emissions at a particular power plant. Therefore the data could be disaggregated, not only in cumulative emissions, but in respect of breaking down emissions per power station.  

Mr Shadley Mackenzie, Head: Air Quality Monitoring, City of Cape Town, said the fact that there was no MES PM10 data for the Khayelitsha monitoring station for 2016-17 did not mean the station had been non-operational. The station measured PM10 and a few other pollutants and the fact that the data was missing spoke to another challenge that municipalities had. If a particular instrument went down, municipalities did not have the luxury of replacing it immediately. Repairs or maintenance to various instruments and the issues around supply chain management (SCM) meant that instruments took some time to be returned to their monitoring stations.    

Mr Senene said it was clear that AAQ monitoring was a challenge and that the DEA accepted and conceded there were gaps experienced in the past which continued bedeviling the DEA for a number of reasons which he had outlined earlier. There were plans in place to address the challenges, as the DEA had outlined in its presentation, and he hoped that everyone would take comfort in that knowledge. The DEA hoped there would be improvement in the management of the air monitoring stations, with the SAAQIS study which was under way, together with better reporting.

Regarding exceedances, what the DEA had normally found was that exceedances occurred while there were averages as well, and the information had been consciously put out as a measure of transparency and to pinpoint at what times of the year exceedances occurred and why they occurred at those times. More detailed information was shared and discussed in the ITTs and MSRGs. This was done without diverting attention from important instances, for the analysis told the DEA that for the better part of the year MES was below the set standards. The DEA accepted that there were peaks between May and September and even exceedances, and as Prof Garland had pointed out, the reasons for those were multiple and the DEA was focusing on them.

Contrary to the perception that no improvement had occurred in high priority areas, the DEA maintained that it had seen some improvement -- not only in the data, but also in the institutional regimes, particularly in the capacity of municipalities. As the previous NAQO used to say, prior to the 2010 legislation coming into effect the DEA had five officials at the national level in charge of all the resources across the country. That NAQO had felt that if there could even be only one person at a district or local municipality in charge of air quality monitoring, the capacity would be increased in the provinces. There had been progress in that regard, even if there was ‘moonlighting,’ as SALGA had pointed out. The DEA certainly would engage all stakeholders on where areas of improvement could be facilitated across the board.

Mr Senene said that every new policy and guideline on air quality monitoring was piloted in all the declared priority areas. Health studies had been done there, and the DEA was conducting a source apportionment study. Those that were from the VTAPA would be aware that the DEA had established a task team which looked at specific issues of awareness which had not been done anywhere else. Therefore he disputed the statement that the DEA was not serious about air pollution in priority areas.

Mr Abader recalled that the DEA had specified that in the priority areas, all monitoring stations were operational. As evidenced by the CSIR presentation, the message had been that if the DEA was not doing anything, the situation could be a lot worse.

Prof Garland said that in her presentation she had indicated she did not know what the situation would have been, as it would have needed modeling, and the increase in SO2, as per the international database, had not been locally verified. There had been a decrease in SO2 per gross domestic product (GDP), as could be seen in the stagnated intensity.

The Chairperson commented that it did not sound like Prof Garland had completely agreed with how Mr Abader had summarised her presentation.

Mr Abader said that the DEA could do a comprehensive presentation in relation to specific sites regarding compliance monitoring and enforcement, and what the progress was.

Mr Senene said that in the priority areas, the DEA had the ITTs together with MSRGs as forums of engagement between government, businesses, communities and any interested parties, to discuss ways of improving and for industries to indicate their status of compliance. Everyone was held accountable through those forums and the advocacy was for the creation of an atmosphere of trust and transparency between stakeholders.

The Chairperson reiterated his question on the regularity of such meetings.

Mr Senene said the ITTs met on a quarterly basis, where the current three priority areas would each have about three ITTs. The MSRGs meetings occurred twice per year.

The Chairperson said he hoped that the forums were not finger-pointing exercises where nothing progressed, but were structured meetings where follow-ups occurred and compliance was monitored and enforced.

The suggestion, that there should be no postponement applications granted in priority areas unless there were exceptional circumstances, was sound.

The ITTs and MSRGs had to be perfected and the DEA had to report back regularly to Parliament on the progress of their meetings.

He understood why the CER and the CSIR felt that the DEA was not serious about air quality monitoring, as their presentations were not contradictory. What was being done had not been enough to date.

He said there would be another colloquium in the fourth quarter, but the DEA had to ensure that the NAQO would be present as the Committee would not appreciate her absence again. The Committee would looking at the postponement applications, especially in the priority areas.

The functioning of monitoring stations had to be reviewed through an intergovernmental forum from national and provincial government, to districts and local municipalities, because it was unacceptable that since the enactment of the AQA the DEA was still struggling with the capacitation of local governments in respect of monitoring.

The Chairperson thanked all those who had attended the colloquium.

The colloquium was adjourned.