Rico Euripidou

1. Social and economic aspects of Minimum Emission Standards (MES) in Air Quality Priority Areas and perspectives on full compliance with MES Rico Euripidou Rico Euripidou

2. Who we are:

6. groundWork's position on offsets If you have an outdoor air pollution problem (as we do) and an indoor air pollution problem – then you have the responsibility of taking action to address both problems! There is no comparison in the scale of emissions from industrial and domestic sources and interventions to reduce domestic emissions are a responsibility of government and should not depend on offsets. It is particularly galling that government has failed to address domestic emissions in any meaningful way but, over the last decade, has tried to do it on the cheap with the BasanjengoMagogo programme.

7. Summary of some key concerns The use of offsets inverts the mitigation hierarchy. Offsets will always be preferred to mitigation measures if they are cheaper (e.g. Eskom and Sasol’s air quality offset proposals). Hence, there will be pressure to cut costs of the offset. Offsets are used to justify the unjustifiable: projects that should be rejected are permitted on the basis of offset proposals; illegal practices (e.g. exceedance of minimum emission standards) are permitted on the basis of offsets.

8. Summary of some key concerns Regulatory capacity is inadequate to the task and provides no oversight. The assumption that offsetting compensates for weak regulatory and planning capacity is false. To the contrary, it exacerbates it. Offsets will tempt government to abandon responsibilities rather than build capacity to meet them Within specific airsheds, the offsets may be overwhelmed by the accumulation of destructive activities – e.g. air quality offsets fall far short of the scale and geographic spread of industrial pollution (e.g. the Eskom and Sasol proposed offsets). They simply do not tackle the ongoing wider emissions problem.

9. “Air quality offsets” a condition of the Eskom and Sasol postponements Eskom: Implement an offset programme to reduce PM pollution in the ambient/receiving environment. A definite offset implementation plan was expected from Eskom by 31 March 2016 Sasol: Required to implement an offset programme to reduce PM and SO2 pollution in the ambient/receiving environment. A definite offset implementation plan is expected by 30 June 2015. Over a year later, air quality offset guideline was published, recommending offsets where MES postponements are granted.

10. Reality bites…the bitter truth! Although Eskom was granted postponements in 2013/14 and has been emitting surplus PM/NOx/SO2 in accordance with the relaxed AEL limits (and regularly exceeding these), their authorised large-scale Air Quality Offset Implementation Plans (and timeframe), submitted to the DEA in April 2016, remain at a pilot stage (30 houses) with various delays. The obvious conclusion is that in addition to our objection that a ‘properly’ implemented offset of household emissions cannot feasibly counterbalance bulk industrial emissions in general, it clearly is not the case at present. DEA’s implication regarding the timeframe, in that they are permitting the implementation of the Air Quality Offset Plan to drag out and Eskom are enjoying something of a windfall at the moment – postponement with MES and no implementation of the large-scale plan.

11. Figure 37: Percentage distribution of main sources of energy used for cooking by province, 2015

13. Main source of energy used by households, by province

14. Health Care Costs of Air Pollution WHOestimates 7 Million Deaths Linked to Air Pollution in 2012 “Excessive air pollution is often a by-product of unsustainable policies in sectors such as transport, energy, waste management and industry. In most cases, healthier strategies will also be more economical in the long term due to health-care cost savings as well as climate gains” Dr Carlos Dora WHO Coordinator for Public Health, Environmental and Social Determinants of Health Source: World Health Organization (WHO) URL: http://www.who.int/mediacentre/news/releases/2014/air-pollution/en/

15. WHO Annual Global Deaths in 2012 (millions) Source: World Health Organization

16. Coal and community health Particle pollution (PM10, PM2.5, PM1) is one of the most dangerous pollutants for human health. It causes cardiovascular and respiratory disease, asthma, hospital admissions and premature death. PM10& PM2.5 levels in the Vaal and the Highveld exceeded the national annual standard permanently over the last 5 years

19. Air quality limits and public protection • Neither the concentration limits set by governments nor the World Health Organization’s air quality guidelines are fully protective of health

20. Annual Emissions per unit of coal-generated electricity

21. Annual average PM2.5 concentrations in the Waterberg Priority Area 2013-2016 WHO

22. Annual average PM2.5 concentrations in the Highveld Priority Area 2012-2015 Ekurhuleni 50ug/m3!! Tshwane & Jhb 39ug/m3!! SA NAAQS WHO Cairncross, E. (2016). The State of South Africa’s Air Quality Monitoring Network and Its Air Quality. Paper presented at the National Association for Clean Air.

23. Annual average PM2.5 concentrations in the Vaal Triangle Priority Area 2012-2015 SA NAAQS WHO Cairncross, E. (2016). The State of South Africa’s Air Quality Monitoring Network and Its Air Quality. Paper presented at the National Association for Clean Air.

24. DEA MSRG presentation of the State of the Air report 2017

25. Health impacts of delays in meeting emission limit values by coal fired power plants in South Africa Dr Mike Holland (EMRC) mike.holland@emrc.co.uk 26/3/2017 Worked for European Commission, various governments (UK, France, Sweden, China), the European Commission, OECD, World Bank. Report provides estimates of the health impacts and associated economic costs of current emissions of air pollutants from coal fired power stations in South Africa. Results are provided both in aggregate, and disaggregated to individual Eskom power stations.

26. Impact pathway approach Tracks emissions through to impactsusing best available science

27. Starting point: emissions from the power stations

28. Forecast annual average PM2.5 contribution from plant covered by Eskom’s application for emission limit derogation, ug.m-3

29. Map of population distribution

32. Annual impacts of coal fired generation in South Africa

33. Health impacts and associated costs ($int, millions) allocated to individual power stations.

34. http://www.theigc.org/blog/the-cost-of-air-pollution-in-south-africa/http://www.theigc.org/blog/the-cost-of-air-pollution-in-south-africa/

35. Benefits & costs of the Clean Air Act, a law which regulates emissions of sulfur dioxide, oxides of nitrogen, carbon monoxide, and particulate matter in USA were calculated. The ratio of health care cost savings to compliance costswas 25:1 in 2010. For every dollar spent complying with the Clean Air Act, twenty-five dollars were saved in health care costs due to lower disease burden, including a reduction in premature deaths, and cases of bronchitis, asthma, and myocardial infarction. US Environmental Protection Agency Office, 2010

37. Key issues Delink between DEA and DoH! Track pollution & effects in real time! MES postponements responsible for bulk of emissions! MES stds. are not a measure of BAT/BEP! MSRG meetings have become a finger pointing exercise! What are the plans for a just transition by ESKOM to a renewable energy future? Why are there no decommissioning plans in place especially for older polluting plants now there is an excess? Offsets are unjust – electrify instead!

38. Thank you! • All resources available at: www.healthyenergyinitiative.org • Briefing Papers • Fact Sheets • Infographics • Stay in touch: rico@groundwork.org.za