5.4 Summary
6.2.4 The Public as Stakeholders
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.
should be fostered, especially, in municipalities lacking in AQM capabilities and In other municipalities to the extent that the overall goal of protecting public health is realised.
The benefits wrought from greater inclusion of the public in AQM extend beyond filling in the gap for municipalities lacking in capacity. Addressing the needs of the public in decision-making, participation, consultation and communication creates an informed civil society able to actively participate in decision-making and contribute meaningfully to its outcomes. Communication is an important aspect of empowering the public to claim the desired environmental quality, creating an awareness of the choices that influence public policy and government action, with participation expanding the ambit of influence to introduce mechanisms where change can be affected by public choice and encouraging civil society to define an identity and opinion on issues. Consultation is a means whereby stakeholder communication can be maintained during processes, where although decisions may not necessarily be made, attitudes and perspectives can be proffered. All these tools can be utilised to coax civil society to assume an active role, which facilitates transparent and inclusive decision-making, and possibly leading to greater public support for implementation and improved perceptions of authorities and their initiated projects. It is a means of fostering buy-in for, even unpopular, measures as the risks and necessity can be transmitted adequately and fairly, and relying on the understanding imparted to individuals to motivate further.
Care must be taken to create a flow of information, and not simply conduct episode management, and requires on-going effort to keep the public 'in the loop' of communication. A public committee or board presents the most-readily implemented measure; however, the formal structure may prove too cumbersome and restrictive to allow good communication flow and the individual circumstances of municipalities should dictate the ideal implementing tool. The funding mechanism and co- management approach of the RBCAA in Umhlatuze municipality offers a promising option for other municipalities. The organisation is funded by contributions from industries in the municipality, in proportion to individual contributions to the total pollutant load, re-iterating the concept of economic incentives and, specifically, the atmospheric user charge mentioned briefly in the implementation funding section. The local municipality also contributes to the costs of monitoring and other AQM activities, including the employment of a dedicated AQO. A management board of directors runs the RBCAA and individual programmes are under the authority of sub-committees, with emitters, authorities and the public constituting the membership. Gathering stakeholders together in a non- aligned forum, leads to greater participation of all stakeholders, and a greater degree of interaction produces more effective outcomes.
In examining the mechanisms currently in use by municipalities, 56% of respo~dents used various media as a communication tool, and although this signifies a high percentage of use, these are generally restricted to ad-hoc communiques for episode management and awareness. There was no
consistent means of communication used by municipalities, with the exception of the RBCAA in Umhlatuze and there is room for improvement in these municipalities as the profile of air quality issues can be raised effectively using pre-existing methodologies.
Fora present an interesting option, similar to that of the public board discussed, and presents a multi- stakeholder platform for issues affecting any group to be discussed and allows for solutions to be developed and reconstructed by individuals affected by pollution impacts, authorities responsible for regulation and regulated emitters. It is used by 22% of respondents although there are possibilities for extending the reach of municipal education initiatives using fora as the vehicle for increasing awareness, capability and interaction on air quality. Urnhlatuze holds fora with major industries, Umtshezi had an environmental forum with local industries and Uthukela uses a district health forum and municipal health committees. The membership of these fora were principally industries and authorities, with the public allowed to address the forum and attend meetings. By expanding the membership of fora and incorporating the public in a tangible way, the effectiveness can be increased and a dialogue created. There are difficulties in sustaining interest in fora though, as Respondent 1 commented, "Generally, forums start out with a bang, [and are] not sustained well or not what we expected". Mechanisms to sustain interest and adapt processes to address issues better are needed to elevate fora to a useful tool for effecting change.
6.2.5 Technical Capability Emphasis
Evident throughout the respondent comments is the stress on technical components of AQM above other functions related to planning and decision-making, where enforcement and monitoring especially, were listed more often than responses on AQMP development and AQO appointment. To illustrate further, identified responsibilities from the AQA were monitoring and enforcement at 94%
and 53% respectively, with licensing identified by 35% of respondents. In contrast, the responses were negligible relating to non-technical aspects with AQMP's listed by 12% and AQO appointment by 6%. The emphasis on technical capabilities can be explained perhaps, by the outcomes, as monitoring and other technically associated AQM activities produce tangible outcomes that can be implemented in a visible manner. Monitoring stations, compliance inspections and licence documents are results that can be publicised, produced to emitters and motivated for in budgeting exercises. An AQMP is a planning document, and while it provides invaluable insight in determining the direction of an AQM programme, it requires deliberation and is essentially a policy-making exercise; therefore, generating less interest and publicity. The appointment of an AQO is a similar process, with the bureaucracy of these exercises stifling their importance in AQM. Non-technical activities necessitate innovation and inquiry and are inherently more intensive to develop than technical skills.
However, an AQM programme that lacks the elements of policy and planning addressed by AQO appointment and an AQMP is remiss in the guidance and planning of action and can deliver outcomes that could be futile with regard to the issues they were intended to ameliorate. Poor quality data and incorrect locations are examples of an improperly planned monitoring programme, and the targeting of the wrong emitters for reduction, the result of incorrect data or poorly considered control measures.
Ignoring or implementing a substandard QA/QC protocol can deliver poor quality data, and incorrect locations can mean an oversight on the part of micrositing details such as a shadow from nearby trees or in the broader perspective, figures that fail to indicate the maximum ground-level or exposure concentrations. Targeting motor vehicles over industries, when the latter are the emitters of concern, illustrates well the instance of ill-advised control measures, where success in control will not achieve air quality objectives.
The emphasis on monitoring, and the data produced, as the basis for decision-making and planning is a positive aspect of the technical focus of municipalities, and refers to Hibiscus Coast, Umtshezi, and Umhlatuze local municipalities specifically. Hibiscus Coast intends using monitoring data as an overall planning tool and in particular in the development of an AQMP to identify problem areas and determine strategies to address them. Umtshezi has not initiated formal processes of decision-making and planning although monitored data will be used to examine the air quality in the area in detail, identify pollution problems and control solutions. Monitoring is an important component of the AQM strategy in Umtshezi. The air quality study conducted in Urnhlatuze made extensive use of monitored and modelled data in the delineation of buffer zones for development (Liebenberg-Enslin and Jordan, 2005). Other municipalities did not express interest in using monitoring data as a component of the planning and decision-making processes. This may be motivated by the lack of data to utilise, as these municipalities are not currently monitoring air quality. In the future, as municipalities become increasingly aware of their responsibilities for AQM and are able to allocate resources accordingly, monitoring may be more commonplace and a greater number of municipalities will be able to access data and utilise these datasets for decision-making.
The existing level of awareness signals that municipalities realise the importance of obtaining the baseline characterisation of air quality in the municipality using actual measurements before embarking on planning a strategy for control. Measured concentrations provide a significant advantage when planning an AQM programme as they can be regarded as evidence of the extent of pollution and a solid foundation for decision-makers to base actions upon. Monitoring that is conducted well and at representative sites can prove useful for strategic decisions, and highlights the role of monitoring as an essential component of an AQMS, although not at the expense of other tools in the system. The quality of data influences the integrity of decisions based upon monitored data and QAlQC must be stressed, as an integrated function with monitoring, as well as to other stakeholders and decision-makers.
Good quality data is a significant a factor as obtaining monitoring data, and SANAS certification in Umhlatuze and the attempts at Umtshezi give direction for other municipalities to place their focus.
Independent assessment of monitoring facilities, such as those offered through SANAS certification, allows for confidence in the quality of data produced from both users and stakeholders, such as the public and industry, should issues of credibility of measurements arise. The latter condition is particularly relevant where industry sponsorship of monitoring or the datasets from industrial self- monitoring are used, as all possibility of bias is excluded. In order to achieve accreditation, exacting standards of data quality, which are comparable to international norms, must be demonstrated. In the absence of assured data quality, further inputs into the AQMS are questionable and compromises all control measures implemented. While obtaining equipment and implementing AQM dominate the current outlook of municipalities, an understanding of errors and uncertainties and their quantification, where possible, through QAlQC procedures is a necessity as these tools form the basis upon which decision-making and policy rest. Therefore, the emphasis on technical capabilities should extend to ensuring that the data produced are adequate for the purposes envisioned before confidently placing it at the heart of a strategy.
The modelling of air pollution dispersion was poorly represented across the study, with little implementation or technical capability noted in responses, with Umhlatuze municipality being the exception using modelling to track non-compliant sources, especially in relation to complaints received. Dispersion modelling is useful for planning and the identification of problem areas, singling out areas for focused AQM intervention using the various model categories. Screening models are basic, working with simple assumptions and operating in isolation; however, for a relatively unpolluted area, can assist in identifying the impacts of development on air quality. Complex models allow for detail in inputs through the consideration of more variables in calculations, and can determine concentrations for units across a managed area, interpolating monitored data for a more complete picture of air quality. A grasp of the uncertainties and assumptions made by models IS
essential for the correct use of modelling data.
Internationally, control agencies and private companies have developed a number of models, and some well-developed and researched models are available without charge on the websites of agencies such as the US EPA. Municipalities could access these models and ascertain the impacts of planned developments, of existing emitters on air quality, and the spatial and temporal extent of impacts using simple screening models or more complex models such as Gaussian puff models. The level of input data and time and computing power necessary to run the models does increase with complexity. An agency with greater funding resources and AQM capabilities should carry the responsibility for modelling rollout, such as provincial or national authorities, as it provides a central structure as well as being able to generate more capacity internally to support the project. An element of training is necessary; however, upon designation of a responsible individual, training can progress quickly with
only very complex models being inhibitive in their use. Expertise can be developed over time though continual exposure to modelling concepts and viewing the capability as a progressive skill. Modelling is an invaluable tool in an AQMS, and should be incorporated into municipal programmes wherever possible as it provides coverage over a greater spatial extent than monitoring, allowing for a more accurate assessment of compliance, and extends the reach of monitoring investments through interpolation.
Overall observations on AQM capabilities revealed that municipalities with the perception of good air quality placed less emphasis on the challenges to implementation and implementation as a whole, as well as relative to municipalities with identified air pollution problems. However, perceptions are, largely, value-based judgements, and the AQA is based on scientific proof of compliance. As such, the basis for an assessment of air quality is ambient air quality standards, for which interim values are available, with revised standards currently in process. The emphasis placed on standards as the concluding authority was weak throughout the study, with visual observation and complaints enjoying greater influence on issues of compliance. Although monitoring and non-compliance were mentioned often as issues by municipalities, 11% of respondents mentioned standards as an aspect of AQM and in relation to compliance. Umtshezi local municipality was in the process of identifying the threshold pollutant limits experienced in the town of Estcourt using monitoring data, and Uthukela district municipality recognised the existence of standards and levels, which were exceeded by local industries in Ladysmith.
Standards are the guideline for action and exceedances, or the risk of, indicate the need for controls on emitters and polluting activities. Judgements on poor air quality should be based on comparisons to standards, and following confirmation, action can be taken. Ambient air quality standards require greater emphasis as they are recognised as the fundamental premise of AQM, and the necessity should be communicated to municipalities as currently, air pollution issues are identified based on other criteria and following a stronger drive for enforcement by national authorities, based on standards, municipalities might be caught unaware on some issues. The stringency of standards proposed by the AQA coupled with the relative inexperience of municipalities indicate the possibility of NO x and CO being exceeded in highly trafficked areas and S02 and PMIO shorter-term standards being exceeded in industrialised areas of municipalities or in settlements reliant on domestic fuel burning.
For example, Estcourt in Umtshezi municipality focused on S02 and particulate matter as control issues, however, the presence of a major national road in the municipality may result in exceedances of NOx and CO; and Ugu district experiences high traffic volumes during vacation periods and NOx exceedances may be unexpected by the municipality. Additionally, Ladysmith in Uthukela district highlighted particulate matter, S02 and dust as problem pollutants without further elaboration through monitoring or other means. Empangeni in Umhlatuze municipality has large traffic volumes of goods
vehicles, especially diesel-powered trucks on a highly trafficked major highway and PMIO
exceedances are a possibility although Richards Bay and surrounds captures the greatest attention in terms of relative air quality. The examples provide illustrations of the importance of using standards as a foundation for judgement and not perceptions. The comparison of measured values against standards to identify exceedances according to the AQA may surprise municipalities and require significant adjustments to the current management strategy.