PROPOSED AMENDMENTS TO THE S21 LISTED ACTIVITIES OF THE AIR QUALITY ACT (ACT 39 OF 2004) Submission to the Portfolio Committee on Water and Environmental Affairs, 7-8 May 2013 Prof. Eugene Cairncross PCWAF hearings on S21 Amendment 7-8 May 2013

 Retired Professor of Chemical Engineering (Cape Peninsula University of Technology), with >15 years’ research and activism as an environmental scientist.  A member of the Coalition for Environmental Justice (CEJ), a mainly WC community based coalition.  Participated in the process of drafting the current S21 Notice pertaining to emission standards for Listed Activities.  Participated as an academic, a representative of CEJ and as technical advisor to LRC and groundwork. Who am I? PCWAF hearing on S21 Amendment 7-8 May 2013

 Context of NEM:AQA  Relationship between emissions and air quality  Health impacts of air pollution  Health costs and burden of disease of air pollution in South Africa  Examples of relaxation of emission standards in the draft amendment to the S21 Listed Activities  Concluding comments PCWAF hearing on S21 Amendment 7-8 May 2013 Overview

Preamble:  the quality of ambient air in many areas of the Republic is not conducive to a healthy environment for the people living in those areas …  the burden of health impacts associated with polluted ambient air falls most heavily on the poor …  air pollution carries a high social, economic and environmental cost that is seldom borne by the polluter  minimisation of pollution through vigorous control, cleaner technologies and cleaner production practices is key to ensuring that air quality is improved … The S21 Listed Activities regulation is an important step towards “minimisation of pollution through vigorous control ….” The Context: The Air Quality Act PCWAF hearing on S21 Amendment 7-8 May 2013

S21 Emission Standards and Ambient Air Quality (the air we breathe) Outdoor air pollutant concentrations reflect pollutant emissions (discharges) from various sources S21 Listed Activities (industries) are major sources of pollutant emissions The S21 LA regulation sets maximum emission values (emission limits) for the common air pollutants for each of the activities listed Relaxing emission limits will result in increased pollutant concentrations, with consequent health effects Mother and child in park PCWAF hearing on S21 Amendment 7-8 May 2013

Air Pollution and health At greater risk from air pollution: Children (including teenagers) People with asthma or another lung disease Healthy adults who are active outdoors People with cardiovascular disease (that’s your heart and blood vessels). Air pollution can contribute to heart attacks, strokes, cardiac arrest, congestive heart failure – and premature death. People in middle age and older are also at risk. In middle age, our risk for heart and lung diseases generally increases – and so does our risk from ozone and particle pollution PCWAF hearing on S21 Amendment 7-8 May 2013 References: WHO Factsheet No. 313 Air quality and health; WHO Air Quality Guidelines - global update; US EPA factsheet Air Quality: Important at Every Age (

* “South African healthcare costs arising from air pollution amount to R4-billion a year. … revealed at the launch of the first South African State of the Air report … in 2005”  SAMJ article: Outdoor air pollution [PM2.5 only] in urban areas in South Africa was estimated (year 2000) to cause  3.7% of the national mortality from cardiopulmonary disease  5.1% of mortality attributable to cancers of the trachea, bronchus and lung in adults aged 30 years and older,  1.1% of mortality from ARIs in children under 5 years of age.  This amounts to or 0.9% of all deaths” (ARIs: Acute Respiratory Infections) State of the air in South Africa PCWAF hearing on S21 Amendment 7-8 May 2013

The proposed amendments contains a number of instances of the relaxation of Emission Limits: Category 2 Petroleum Industry … 2.1 Combustion Installations (PM10 and NOx) Relaxation of standards in proposed amended S21 Listed Activities Pollutant Current emission limits Proposed emission limits PM10 (particulate matter less than 10 microns in diameter) 50mg/Nm 3 70mg/Nm 3 NOx (oxides of nitrogen NO and NO 2 ) 250mg/Nm 3 400mg/Nm 3 PCWAF hearing on S21 Amendment 7-8 May 2013

Category 2 Petroleum Industry … 2.1 Combustion Installations (SO 2 ) Amendment-proposed relaxation of standards PollutantCurrent emission limitsProposed emission limits Sulphur dioxide (SO 2 ) Daily average 0.8kg SO2/ton oil throughput (calculated as the sum of emissions from combustion, sulphur recovery units, flares, catalytic cracking units) Flare emissions not included. Proposed limits to be evaluated against each refinery configuration. Proposed limit for sulphur recovery lax Does not specify minimum plant availability Flaring emissions PCWAF hearing on S21 Amendment 7-8 May 2013

 The proposed amendments to the S21 Listed Activities regulation contains a number of very significant relaxations of current S21 emission limits  Allowing higher pollutant emissions will result in increased outdoor air pollutant concentrations  Increased pollutant concentrations result in an increased burden of disease, including increased mortality rates  The current Listed Activities should be amended strictly only to correct typographical errors and clarification of ambiguities.  A revision of the current S21 Listed Activities regulation should only take place as provided for in the Air Quality Act (Act 39 of 2004) Concluding comments PCWAF hearing on S21 Amendment 7-8 May 2013

Thank you PCWAF hearing on S21 Amendment 7-8 May 2013