Ms
Tyhileka Madubela
Coordinator:
Portfolio Committee on Water & Environmental Affairs Committee Section
Parliament of RSA
PO Box 15
Cape Town
8000
By email:
tmadubela@parliament.gov.za
1.
I hereby make submissions regarding the proposed draft
amendments to the National Environmental Management: Air Quality Act, 2004 (Air
Quality Act) section 21 list of activities which result in atmospheric
emissions which have or may have a significant detrimental effect on the
environment, including health, social conditions, economic conditions,
ecological conditions or cultural heritage (listed activities). I make these
submissions in my capacity as a resident of Zamdela in Sasolburg.
2.
Zamdela
forms part of the highly industrialised Vaal Triangle Airshed Priority Area
(VTAPA). There are many contributors to the extremely poor air quality in the
area. Sasolburg is part of an industrial complex in Free State and is a major
centre for the chemical industry. Zamdela is one of the areas that is faced with high
sulphur dioxide emissions and fine particulate matter concentrations
experienced in many urban areas due to household activities, as well as
industrial and power generation sectors.
3.
But there is one main industry that contributes largely
to atmospheric emissions -Sasol Chemical Industry. For over 50 years, communities in
Zamdela,Sasolburg, has been bearing the brunt of pollution - mainly from Sasol
Chemical Industry and other surrounding industries.
4.
Industry brought jobs and
growth to Sasolburg. People were unaware of the dangerous impacts of exposure
to hazardous chemicals, flares burning night and day, air pollution and strong
odours. People were made to choose between short term survival in the
form of employment by industry, and long term environmental and health damage. Government
sees industrial pollution as a necessary evil for the sake of economic
development.
5. For many years, air quality
management remained on the back-burner of environmental policies, mainly
because air pollution is not always visible and not restricted by geographical
boundaries.
6.
Communities and individuals saw the need to act
against Sasol. With the assistance of groundWork, a committee called the Sasolburg
Air Quality Monitoring Committee was established. The Committee’s focus was on
monitoring air quality, engagement with both Government and industries,
mobilisation and organising of communities, and raising awareness about the
environmental injustices and environmental health concerns due to this
industrial pollution.
7.
Zamdela
communities made submissions before Parliament during the Air Quality Act
hearings. These inputs paid off because the Vaal Triangle Airshed was the first
area to be declared a priority area in South Africa. This meant that there was
recognition that the air we breathe is not conducive to human health and wellbeing.
8.
The Air
Quality Act sets out to protect and enhance air quality in South Africa and to
secure ecologically sustainable development through reasonable air pollution
prevention measures. This can be achieved through the development of air quality
management plans and by involving all spheres of government and the public
sector.
9. The Air Quality Act’s
objectives do not need any translation – it aims to protect the environment by providing
reasonable measures for the protection and enhancement of the quality of air in
the Republic. The Air Quality Act is supposed to give effect to section 24(b)
of the Constitution in order to enhance the quality of ambient air for the sake
of securing an environment and well-being of people. The viability of the new air
quality approach will however depend on effective and timely capacity building
at all tiers of government and within the private sector.
10.
To
achieve the objective of the Air Quality Act and to control the atmospheric
emissions of these industries, Government should set section 21 emissions
standards based on the scientifically researched levels of impact of these
pollutants. Listed activities can be detrimental to health and require an
atmospheric emission licence (AEL). The AEL must require that an industry
report all its air pollution sources. Government must build the capacity of the
local air quality officers so that municipalities only grant AELs if the applicant
industry can prove that they can comply with the requirements as set out in the
Air Quality Act. Government should not be lenient when they grant these AELs,
and industries should be compelled to compile comprehensive emission inventories
for the entire site where a listed activity will be conducted.
11.
Our
main concern with air pollution is the amount of pollution that eventually
reaches ground level, where it is then inhaled by humans. There are number of
people already suffering from respiratory illnesses such as asthma, cancer and
other health problems associated with the inhalation of polluted air. Many
people in Zamdela are suffering from irritation of their eyes, noses and
throats. These pollutants comprise various compounds such as sulphur dioxide,
oxides of nitrogen, carbon monoxide, benzene, ozone and dust.
12.
Although
Sasol has been publicising that they have spent much money reducing incidents
and emissions, the community in Zamdela - located in the zone that is
westerly-downwind of the heavy industry, where residents live with the constant
ll of a variety of chemical pollutants released both by normal production and
by periodic incidents - can tell a different story.
13. Industries such as Sasol have
blamed high atmospheric emissions on communities for burning coal in winter for
cooking, but also for space heating and to provide light. In the Vaal Triangle,
it was found that coal burning contributes on averages 37% to the atmospheric
particulate load, rising to 65% in winter (Engelbrecht). The coarser
particulate matter (PM10) emissions have been exceeded in Sasolburg;
this has been proven by Government’s monitoring station that has been placed in
Zamdela. It has been acknowledged by the Department of Environmental Affairs that these
particles are not only as a result of coal burning in the area, but industries’
activities exacerbate the increase of PM10. If industries are let
off the hook, this will also spoil the intention of the declaration of the
VTAPA - to effectively
and efficiently bring the air quality into sustainable compliance with National
Ambient Air Quality Standards.
14. The first step in air quality
management is to determine the quality of air i.e. its fitness for human
consumption. In 2009, the Department of Environmental Affairs
15. published the State of Air Report
2005 for South Africa with the purpose of providing insight into the sources of
emission and the associated human health, welfare, and broader environmental
effects. The report sets out to identify significant sources, pollutants and
areas of impact in combination with existing air quality management practices.
Monitoring of air pollution is still restricted to a few criteria pollutants
with little information on ozone and benzene. The available data did, however,
flag sulphur dioxide and fine particulates as the main pollutants of concern in
Zamdela. These are primarily a result of household fuel-burning, industrial
operations, vehicles and power generation.
Managing this industrial pollution and understanding the significance of its contribution to health and environment will help to achieve the necessary emissions reductions.
Managing this industrial pollution and understanding the significance of its contribution to health and environment will help to achieve the necessary emissions reductions.
16. But the challenges are in
the absence of a system for regularly
reviewing and, where necessary, revising registration certificate and AEL
conditions in line with best practice, and the absence of coherent and routine
monitoring - by both government and businesses - to assess compliance with
registration certificate and AEL conditions
17. Due to the need to manage air
quality to within acceptable limits, the relevant air quality officer may
require the licence-holder to appoint an emission control officer to: introduce
cleaner production technologies; ensure compliance with licence conditions and
report non-compliance promptly. These
officers must be appointed - the bottom line is that we need someone to ‘do
their homework’ with regard to understanding their emissions and associated
impacts, and to consider cleaner production technologies and practices for the
industry to continue operating in the long term.
18. In conclusion, to date,
communities have not yet realised the good intention of declaring the VTAPA as
a pollution hotspot. We have not yet enjoyed the realisation of the objectives
of the Air Quality Act.
19. The public has been promised
protection from impacts on our health and wellbeing due to air pollution,
including odour, dust and noise. We hope
that the Government will honour that promise by not being lenient to profit-making
industries, and will realise that industries have no any other motives than
making profit by continuing to pollute and not wanting to change their
technologies.
20. If section 21
standards are weakened, communities in Zamdela and other areas will have to
breathe air that is even more dangerous to their health than the current
situation.
21. In these circumstances, I strongly object to the draft
amendments to the listed activities.
Yours sincerely
Caroline Ntaopane
Zamdela resident
