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

Who we are:

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 Basa njengo Magogo programme.

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.

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.

“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.

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.

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

Main source of energy used by households, by province

Health Care Costs of Air Pollution WHO estimates 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/

WHO Annual Global Deaths in 2012 (millions) Deaths from indoor and outdoor air pollution: http://www.who.int/mediacentre/news/releases/2014/air-pollution/en/ combined aprrox. 3x more than HIV, TB and Malaria combined! HIV/AIDS: http://www.unaids.org/en/resources/campaigns/globalreport2013/factsheet TB: http://apps.who.int/iris/bitstream/10665/91355/1/9789241564656_eng.pdf Malaria: http://www.who.int/malaria/media/world_malaria_report_2013/en/ Source: World Health Organization

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

Health effects of coal combustion

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

Annual Emissions per unit of coal-generated electricity This slide shows that if we compare the time period over which the HPA has existed, Eskom coal generated electricity is as “dirty” and polluting as it was nearly a decade ago. And yet, they have been given exemption

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

Annual average PM2.5 concentrations in the Highveld Priority Area 2012-2015 Tshwane & Jhb 39ug/m3!! Ekurhuleni 50ug/m3!! SA NAAQS WHO An area may be declared a Priority Area if the “Minister …. reasonably believes that... ambient air quality standards are being, or may be, exceeded in the area ..”. [National Environmental Management: Air Quality Act 39 of 2004, Chapter 4] The concentrations of ambient PM2.5, which consists of primary emissions and secondary PM2.5 from the precursor gases SO2 and NOX, are high in each of the PAs. The annual average PM2.5 concentrations in the HPA (figure 2) and VTPA (figure 3) mostly exceeded the World Health Organisation (WHO) guideline of 10 μg/m3 and the National Ambient Air Quality Standard (NAAQS) of 20 μg/m3 for the period 2012-2015. In the adjacent densely populated metropolitan areas of Tshwane and Johannesburg/ Ekurhuleni the annual average PM2.5 concentrations of 39 μg/m3 and 50 μg/m3 respectively in 2012 were also far in excess of air quality standards (Cairncross, 2016). 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.

Annual average PM2.5 concentrations in the Vaal Triangle Priority Area 2012-2015 SA NAAQS WHO both Eskom and Sasol (operator of the CTL plant) have been granted postponements from 2020 until 2025 to comply with more stringent emission standards 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.

DEA MSRG presentation of the State of the Air report 2017

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.

Impact pathway approach Tracks emissions through to impacts using best available science

Starting point: emissions from the power stations

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

Map of population distribution

Annual impacts of coal fired generation in South Africa

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

http://www.theigc.org/blog/the-cost-of-air-pollution-in-south-africa/ START DATE / END DATE 4 January 2016 - 31 March 2017 The high cost of air pollution The Global Burden of Disease (GBD) reported in 2012 that three million people die prematurely each year around the globe due to ambient air pollution (WHO, 2012), with low- and middle-income countries suffering the worst effects. Developing countries, that have a heavy reliance on fossil fuels, like South Africa and China, face the bulk of the health and productivity losses as well as mortality associated with high concentrations of air pollution. The associated economic costs can also be high. For China, which relies on coal for 75% of its primary energy, the economic burden of air pollution is estimated at 3.8% of their GDP (World Bank, 2007). The WHO estimates that air pollution costs European economies US$ 1.6 trillion a year in mortality and morbidity (WHO European Region, 2015). The South African case South Africa relies on coal for 97% of its primary energy. The costs of air pollution on human health and economic growth in South Africa are as of yet unknown. Fine particulate matter (PM) is one of the most lethal pollutants, and higher concentrations are known to cause increased mortality. “Fine particulate matter (PM) is one of the most lethal pollutants, and higher concentrations are known to cause increased mortality” The GBD study estimated that South Africa had 1800 deaths in 2012 attributable to fine PM. This number was based on global satellite and modelling views on the severity of air pollution in the country. However, measured PM values are 3-4 times higher than the GBD estimates. Moreover, at monitoring stations where the PM data was available, only one station met the health guidelines recommended by the World Health Organization. In our recent IGC study (‘Human Health Costs of Energy-Related Air Pollution in South Africa’), we set out to calculate the number of premature mortalities due to the actual air pollution levels in South Africa, and to quantify the associated economic costs. pic1-sa Using the United States Environmental Protection Agency’s Environmental Benefits Mapping and Analysis Program (BenMAP), they developed a South African BenMAP model with local data. This required spatially-explicit information on the population, mortality rates, locally measured air pollution values, and economic data. Air pollution monitoring data, provided by the South African Air Quality Information Service, was compared to background values. Background values indicate the concentrations that would be expected if there was no human-derived pollution. pic2-sa Because fine PM associated mortality derives from chronic exposure, the BenMAP analysis uses annual averages. For the year 2012, the South African National Standards annual average fine PM limit of 20 µg/m3 was exceeded at 13 stations. All stations except one exceeded the more stringent WHO guideline of 10 µg/m3. Stations with consistently high PM concentrations typically occurred near townships, which are commonly poor, overcrowded and inadequately serviced areas. The main sources of PM included domestic combustion, pollution emanating from highly industrialized areas such as Secunda (a town built amidst the coalfields of the Mpumalanga province of South Africa and the largest source point of CO2 in the world), coal yards and commonly adjacent coal burning power stations, many of which were previously moth-ball producing plants that have since been re-commissioned due to power shortages. Key results The South African BenMAP model calculated that 27,000 premature mortalities across South Africa are currently due to high levels of fine PM. This is in stark contrast to the 1800 deaths estimated by the GBD study. “This work indicates that 7.4% of all deaths in South Africa are due to chronic exposure to fine PM” Therefore, this work indicates that 7.4% of all deaths in South Africa are due to chronic exposure to fine PM. Densely populated regions such as Cape Town, Durban, and the Johannesburg-Pretoria mega city area suffer the largest loss of life. These premature deaths cost the economy $20 billion (2011 International $), or 6% of South Africa’s 2012 GDP. This is the first estimate of the significant economic costs incurred by the air pollution health burden in South Africa. Policy lessons Due to a lack of local epidemiological studies, this study relied on information from the developed world. While there is a plethora of epidemiological studies that quantify the relationship between mortality due to air pollution in North America, Europe, and China, there is a dearth of similar data for developing countries in Africa. Local differences in the composition of PM, living conditions, when and how people are exposed to pollution, and most pressingly, vulnerability due to high rates of TB and HIV/AIDS infection, suggest there is a critical need for South Africa-specific studies on the association between air pollution and mortality. “Vulnerability due to high rates of TB and HIV/AIDS infection, suggest there is a critical need for South Africa-specific studies on the association between air pollution and mortality” Therefore, this study highlights the need for increased fine PM monitoring around South Africa. The South African BenMAP model developed in this study is a tool for policy makers that can be used for health impact assessments and cost-benefit analyses of air pollution reduction policies. http://www.theigc.org/blog/the-cost-of-air-pollution-in-south-africa/

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 costs was 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 The USEPA also undertook a similar exercise to estimate the full lifecycle costs of implementing the Clean Air Act. They found that the ratio of health care cost savings to compliance costs was 25:1 in 2010.

This is a flow chart/infographic we created to help conceptualize what we mean when we say energy choices affect health. There are several pathways through which this happens, and they are important to understand for health professionals, energy policy decision-makers, and the general public.

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!

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