Supported by the Ministry of Foreign Affairs of the Czech Republic
Obstacles for PRTR implementation in B&H from the perspective of pollution victims presented by Dr.sc. Samir Lemeš president of NGO "Eco forum" Zenica Workshop "PRTR Register in B&H: How acces to information can reduce industrial pollution?" Sarajevo, 14.11.2014
Obstacles for PRTR implementation in B&H from the perspective of pollution victims
Good examples from B&H legislative: air pollution tax Shortcomings: Lack of accredited bodies Shortcomings: Diffuse emissions Shortcomings: Lack of polluters cadastre Shortcomings: Corrupted stakeholders
B&H legislative related to PRTR
Law about freedom of access to information of B&H ("Official gazette of B&H", 28/00, 45/06) Environmental protection law of FB&H ("Official gazette of FB&H ", 33/03, 39/09) Air protection law of FB&H ("Official gazette of FB&H ", 33/03, 04/10) Regulation on the types of fees and criteria for calculating air pollutant fees ("Official gazette of FB&H ", 73/11 /2.11.2011) Rules on monitoring of emissions of pollutants into the air ("Official Gazette of FB&H", 12/05)
Regulation on the types of fees and criteria for calculating air pollutant fees
The amount of emissions in tons per calendar year of certain pollutants are calculated on the basis of the results of measurements in the manner defined by the Rules on the monitoring of pollutant emissions, or on the basis of the assessment results and / or the calculations in accordance with internationally recognized methodologies. A fine of 250 to 3.500 € shall be imposed if:
fails to submit reports on the annual emissions fails to pay the prescribed fee
Air pollutant fees: 19 €/ton of SO2, 18 €/ton of NO2, 85 €/ton of PM10 Annual AMZ emissions: 10.000 t SO2 = 190.000 €
Rules on monitoring of emissions of pollutants into the air
Emission measurement results should be reported to the ministry who issued the environmental permit (Federal or Cantonal Ministry of Environment). Laboratory that performs measurements must possess accreditation issued by the Institute for Accreditation of B&H (meets the requirements of EN ISO/IEC 17025:2000) Authorized testing body should annually review the system if the operator performs emissions monitoring. Emissions monitoring should be performed once every 1/2/3 years, or permanently, depending on installed power, emissions rate or environmental permit
Lack of accredited bodies
Only 5 accredited bodies for environmental monitoring 4 accredited bodies for emissions monitoring:
INSPEKT RGH Sarajevo (Kakanj, Tuzla, Bihać, Orašje, Zvornik, Brčko, Doljani, Tešanj, Zenica) DVOKUT PRO Sarajevo TQM Lukavac ZAGREBINSPEKT Mostar
Diffuse emissions ď ˝
ď ˝
Reporting for the purpose of "air pollution fee" collection includes only measurements at chimneys or similar measurement points. Diffuse emissions are not being measured/reported
Diffuse emissions
Diffuse emissions
Strongly advertised "huge environmental project" worth 6M€ intended to reduce dust emissions from department that contributed only 2,2% to total emissions After we criticized it, the corporation explained that "their report did not include diffuse emissions"?!?
Lack of polluters cadastre ď ˝
Who to blame? How big are individual contributions?
Trying to find the connections
increase in pollution follows the trend of increase in production pollution is relatively larger than in 1980s
Lack of polluters cadastre
Still not enough data about air polluters:
industry households traffic small/medium boilers
A chance for excuses, speculations and hiding the real causes of pollution Need for PRTR
Flaws in air quality monitoring ď ˝
ď ˝
Uncalibrated air quality measurement equipment Measurement stations at non-representative positions (rooftops)
Corrupted stakeholders
In June 2013, master's thesis defended at the local university, claiming that ArcelorMittal contributes only 10-15% to air pollution in Zenica. Numerical simulation was compared with air quality results from imissions monitoring data Instead of measurement results, the data from "Plan of activities for Environmental permit" was used for input Regression with R2=1 was obtained by fitting the 3rd order polynom through 4 points Complaint to the Ethical committee had no result After media disclosure, the professors from the thesis commitee sued the whistleblower for slander
Misuse of "scientific" results
How long must we wait?
2008
2009
2010
2011
2012
2013
2014
...?
Supported by the Ministry of Foreign Affairs of the Czech Republic