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5.4 Summary

6.2.3 Funding AQM Implementation

An AQM strategy is regarded as resource-intensive, requiring inputs into tools to determine the state of the air and implement controls to improve air quality. Local government in South Africa is dealing with a major service backlog, where many areas of the country do not have access to basic services such as potable water and sanitation, and is charged with local economic development of their jurisdiction to revitalise previously disadvantaged regions. However, local government remains the most appropriate level of government to situate the majority of AQM activities, and the imperative is accompanied by difficulties in bringing policy to fruition. Access to financial and human resources are the greatest challenge to municipalities, and are a severe constraint to implementing the AQA.

Funding is needed for equipment, such as monitoring devices and the associated upkeep, training of staff in aspects of pollution control and AQM, and supplementing the current staffing quota to carry out technical duties, such as sample analysis and maintenance of monitoring stations.

Municipalities should examine all avenues of funding available, as there are a number of different agencies that are currently involved in implementing the AQA, as well as provisions in the AQA itself for implementing authorities to acquire revenue for implementation. National government is the level of government with the greatest access to resources, being directly funded by the National Treasury but also being able to receive international aid from donor agencies and international governments.

These resources may be channelled for local application from the higher authority. Provincial government, the DAEA in KZN, has more limitations in terms of accessing funding than national, nevertheless is ably funded as well and possibilities exist for receiving assistance from this source as well. The donation by the DAEA of five complete monitoring stations with automatic analysers and cellular phone communication capabilities demonstrates the ability of provincial government to allocate funds capably and access resources.

Some municipalities may also form partnerships with donor agencies independently and receive assistance, of both monetary and technical resources, to set up their AQM programmes. Ethekwini municipality in KZN has established a working relationship with Norwegian authorities and has established a programme with laudable results in air quality improvements in the South Durban Basin.

In addition, Section two ofNEMA makes provision among its principles for using the 'polluter pays' principle and is carried through to the AQA, although the development of economic instruments for AQM is still at its conception. Economic taxes and atmospheric user charges are possible expressions and intend to incur costs upon emitters and make emissions to the atmosphere an economic good with associated costs.

The concept of an 'unfunded mandate' was raised in Umhlatuze municipality as a number of functions have been re-assigned from other tiers of government to local government, and the likelihood exists that the funding to carry out these new responsibilities has not been transferred as well. A more in- depth analysis of the situation by authorities may be necessary to determine the level of responsibilities now given to local government and the nature of funding resources available to municipalities to implement them. A viability assessment with recommendations and tools for municipalities, and other government tiers to assist, is a possible format.

Related to funding and staffing needs is the compounding factor of the limited pool of qualified personnel to address AQM. South Africa has a shortage of individuals suitably trained in the management and technical capabilities of air pollution control, with limited opportunities for training and skills transfer. Tertiary institutions offer isolated programmes at higher levels for individuals looking to attain knowledge in AQM, and industry remains the most significant avenue in which to train and obtain technical expertise. Further initiatives for training need to be developed and available opportunities increased. Bursaries and scholarships are a means of improving the capabilities of individuals entering the pollution control field. There is a need, especially, for technically skilled personnel to operate and maintain monitoring stations, including calibration and equipment maintenance, conduct modelling runs and validation, carry out inventories and maintain the information systems of the programme.

In the study, respondents carried environmental health qualifications but had limited exposure to air pollution control concepts, with 72% receiving instruction in air pollution-related coursework while pursuing environmental health diplomas. Increasing funding to air quality-related initiatives promotes AQM qualifications as an opportunity for individuals and presents a distinct method of increasing capacity in the necessary fields, thereby, making more personnel available to municipalities for inclusion in AQM programmes. Provided that necessary funding can be made available by municipalities for securing personnel, this measure could also provide a means for reducing the reliance on consultants and improving the sustainability of municipal programmes.

An innovative approach, proposed by Uthukela municipality, was the use of self-regulation by industries, with reporting of incidences of non-compliance and municipalities auditing the emissions records. This approach addresses funding limitations and can be implemented by less-funded municipalities, as fewer resources are needed and a limited amount of monitoring. Emitters are charged with monitoring stack and other emissions resulting from their activities and keeping records of emissions, both compliant and non-compliant, and making note of the latter. The regulating authorities regularly review the records to determine the performance of the emitter and make regulatory decisions accordingly. The approach can be expanded to place an emissions minimisation and cleaner technology responsibility on larger, or more environmentally conscious, emitters to show continual improvements in records. These measures are frequently adopted by industries that trade internationally or serve a sector where environmental concerns are an issue; the improvements and introduction of new technology also provide a public relations opportunity.

Enforcement is the critical component of employing this approach, as industries can easily manipulate records to portray a more agreeable scenario without the knowledge of regulators. The installation of source monitoring devices and the analysis of raw data is a method of discouraging misrepresentations in reports, as well as the establishment of affable relationship between emitters and regulatory agencies, where healthy communication leads to outcomes that are workable for both parties.

Authorities that are perceived as uncooperative or unreasonable may receive far greater resistance from polluters in terms of participation and voluntary compliance. On the part of regulators or municipalities, resources for the greater number of AQM tools and activities are unnecessary as the emitters subsume these functions, together with the costs of conducting them. A reasonable number of well-trained individuals, in proportion to the number of emitters in the area, that are capable of auditing records, maintaining relationships with emitters and with an understanding of pollution control concepts can provide the core for implementing AQM. Ambient monitoring, to a far lesser degree, that addresses general areas of exposure and with an element of compliance monitoring is needed to demonstrate compliance with regulations.

The investment of large resources in assessing and controlling air pollution should be accompanied by a means of determining the degree of success enjoyed by introducing each measure, ensuring that the benefits are consistent with the costs involved in running an AQM programme. Consideration is given to the incremental benefits of introduction, where initial controls capture greater improvements and subsequent controls achieve incremental gains comparatively. An element of justification should be found in investing in the measures against improvements in air quality. Aside from control measures and tools, the functioning and efficiency of management should be assessed as an aspect of success, or default, and improvements in that area sought. Poor management with little relevance to practically experienced scenarios, as well as being far removed from other stakeholders, can have greater effect on a programme of pollution control than actual controls. Assessment of management can be done using more established methodologies borrowed from business administration and related disciplines.

Therefore, following the assignment of funding, an important component is assuring the viability of the venture as well. Research and development can present a significant part of determining the efficiency of measures, and increasing the efficiency over time. New measures can be developed to achieve greater gains for less funding input; an example is emissions trading and other economic instruments that have been favoured in innovative legislation internationally. A portion of funding should be allocated for the development of improvements in strategy.

An additional observation on the funding of municipal AQM initiatives was the instances of greater capability evident in larger municipalities with more available financial resources as compared to smaller municipalities. This was juxtaposed against the lack of significant deterioration in air quality in smaller municipalities that was noted in the larger, and more industrialised, municipalities. The observation highlights the local context of the contrast and relationship between increasing economic output and environmental degradation that is the accepted outcome of development (Atkinson, 1997).

While developed countries have attempted the decoupling of increased economic growth from the destruction of environmental quality, including the atmosphere, the path of industrialisation has been seen as the norm. Municipalities can expect to challenge this established model of development, by pursuing sustainable development through activities such as eco-tourism and sustainable communities, and placing an emphasis on the maintenance of natural stock and suitable forms of development for the local setting (Tietenberg, 2004). By avoiding, or minimising, the degradation of the environment altogether, the allocation of resources for management, monitoring, and rehabilitation are significantly less than municipalities where the benefits and costs of industrialisation are clear.

Umhlatuze local municipality is highly industrial in nature, having a number of industrial plant and other activities emitting a varied mix of pollutants into the atmosphere. It is also well funded and has a large tax base of both residential and commercial entities. In contrast, other municipalities in Uthungulu, for example Umlalazi, are rural or peri-urban in character, with agricultural activity dominating the economy of the area, with contributions from tourism and other activities associated

with a low pollutant load (uThungulu District Municipality, 2002). These economies are not developed to the extent of Umhlatuze, having limited resources available for allocation to municipal services. In terms of pollution, Umhlatuze has high ambient concentrations with exceedances of standards, and other municipalities have no recorded pollution episodes, with the exception of sugar cane burning and associated emissions occasionally; Umhlatuze has significant resources allocated for monitoring the effects on the ambient pollutant effects whereas other municipalities have little to none allocated. The illustration provides detail on the statements made earlier; however, a balanced approach to pollution control is needed in view of the developments of the AQA, where the absence of monitored incidents does not indicate compliance with standards. All municipalities should be able to provide evidence on the ambient concentrations of pollutants relative to standards and develop a programme of action following the assessment.