1. National Association for Clean Air
Presentation to the Parliamentary Portfolio Committee on the
Air Quality Bill
3 Feb 2004

2. What is NACA?
Non-governmental organization promoting air quality, 34 year history, 6 local branches
450 members representing local authorities, research organizations, industry and private citizens
Good depth of air quality related expertise
Activities:
Publishes a Journal and newsletter
Provides bursaries for air pollution studies
Produces information material for schools
Local seminars and discussion forums
Annual conference
Members involved in drafting of local regulations, draft national ambient air quality standards

3. Purpose of the presentation
Support for the principles of the Bill
Point out some discrepancies
Indicate areas for possible improvement
Concern about implementation

4. Principles of the Bill supported
Use of ambient air quality as point of departure
Devolvement of control to local authorities
Recognition of necessity for management planning including all sources, as well as a variety of control strategies
Entrenched principle of public involvement in standard setting and licensing process

5. Some discrepancies noted
In practice, priority areas (art 18,19) will probably be declared in number of areas (Durban South, Vaal area etc) which moves responsibility up to province and removes it from local authority.
Provision for public involvement made but not carried through, e.g.
Air quality management plans (art 18,19) and listing of activities (art21) only follow consultative process after preparation
lack of provision for public communication & consultation during DEAT’s transitional phase project scheduled to be initiated this month. This projects aims at air quality and emission standard setting, Act implementation manual development (etc.). Provision is only made in the TOR for one stakeholder workshop.

6. Remaining concerns (Bill)
Lack of provisions for management on air shed basis (similar to catchment management for water) – Bill allows, but does not enforce
Air quality management process not clearly defined
Transition period to Bill may be too short
Important issues are left to regulations
Lack of integration with EIA requirements

7. Implementation concerns (1)
Implications of lack of capacity at local level
Cost, time required for provision and training of staff
Delays in Air Quality Management Plans and licensing process
Possible cost of licensing process
Can be alleviated by consolidating management at air shed level

8. Implementation concerns (2)
Implications of delay in standard-setting process for ambient air quality
Act cannot function without standards
Proposed standards were based on internationally documented health thresholds and globallly accepted good practice
Needs to proceed urgently
Similar process required for emission standards – stakeholders should be consulted

9. Implementation concerns (3)
DEAT proposed actions indicate that requirements for public participation is underestimated
Highly complex process, large number of stakeholders
DWAF policy/strategy development process provides excellent example of how stakeholders can be involved