Will the newly proposed Air Pollution Control Rules-2021 do much to reduce air pollution in our cities?
Bangladesh has been suffering from the presence of high levels of particulate matter (PM) in its air for about three decades. Air quality monitoring by the Department of Environment (DoE) reveals that air in all of the divisional and commercial cities of the country is polluted with high concentrations of PM 2.5 (PM with aerodynamic diameters equal or less than 2.5 micrometre), especially in the dry season (November-April), when the concentrations of PM 2.5 rise as much as 6-7 times that of the guideline value set by the World Health Organization (WHO).
Dhaka and its neighbouring districts are the most polluted cities while Sylhet is the least polluted. Chittagong is moderately polluted, while Khulna and Rajshahi are highly polluted. This scenario of the country has become global -- thanks to a series of reports published by international organizations such as the WHO and the Institute for Health Metrics and Evaluation, USA.
The State of Global Air 2020 report published by the Global Health Burden project of the Institute for Health Metrics and Evaluation, USA estimated about 214,480 early deaths in 2019 in Bangladesh due to exposure to both ambient and indoor air pollution. Shortening of about four years of the lifespan of people living in South Asian countries has been reported in other research publications. The economic impact of air pollution in this region is enormous.
Mitigating steps not working
A number of mitigating steps have been taken at different times to improve the air quality, especially of Dhaka. Unfortunately, some time after the implementation of those steps, the air pollution levels return to the previous mark due to excessive population influx, boom in industrial and construction activities, brick manufacturing kilns, and activities of other small and medium enterprises.
Once tagged as the “gas chamber” due to excessive emissions of hydrocarbons (HCs) and volatile organic compounds (VOCs) from the two-stroke three-wheeled baby taxis, Dhaka is now the second most polluted capital city in the world due to emissions from brick kilns, biomass burning, constructions, outdated heavy duty vehicles, etc.
After the nine point directions from the, DoE undertook massive enforcement programs including demolition of hundreds of illegal brick kilns in the country; Dhaka South and North City Corporations were also found sprinkling water in the streets during dry season.
Notwithstanding, the air pollution of Dhaka city has been increasing in recent years; the annual PM2.5 concentrations in 2017, 2018, and 2019 were 80.0, 100.0 and 94.0 µg/m3 respectively (US embassy data), while its limit value should be only 15 µg/m3. In these circumstances, a sustainable, cost effective control solution to this calamity becomes imperative in order to systematically improve the air quality without affecting the development of the country.
The Clean Air Act
To make this happen, DoE prepared a draft Clean Air Act (CAA) in 2019 with the consulting services from the Bangladesh Environmental Lawyers Association (BELA) and Bangladesh University of Engineering and Technology (BUET). The Ministry of Environment, Forest and Climate Change (MOEFCC), however, recently reshaped the draft CAA as Air Pollution Control Rules-2021 (APCR-2021) keeping most of the points of the draft CAA unaltered.
The draft APCR-2021 is posted to the website of MOEFCC for public opinion. This article is intended to discuss how the APCR-2021 may be expected to help achieve sustainable improvement in air quality of the country, as well as the challenges of the implementation and enforcement of the rules. Some salient features of the draft APCR-2021 and relevant discussions are as follows:
(a) The APCR-2021 has proposed delegating the Department of Environment to formulate a National Air Quality Management Plan (NAQMP); an outline of such a plan is also provided in the ACPR. The NAQMP would be the fundamental document that will guide all the relevant stakeholders in achieving a sustainable air quality in every region of the country.
This plan would be prepared considering the existing sources, socio-economic conditions, topographical features, meteorological seasonal variations, and other important parameters that influence air quality of a region. It may be expected that the formulation and right implementation of an effective NAQMP could be helpful in managing the current high air pollution of the country.
(b) The government, by this rule, will be able to declare a place as “degraded airshed” if the place continuously shows its air quality over permissible limits. The DoE will prepare a time-based Air Quality Improvement plan in consultation with the local stakeholders to improve the air quality of the degraded airshed. The government will restrict establishment of new industries and/or other settlements that might be considered detrimental to the air quality in that area, and also will relocate the existing sources from the airshed to other places.
(c) The DoE upon the approval from the government can publish a list of events or activities that would be considered detrimental to the environment, health, society, economy, etc of a place. The DoE will issue directives to control those activities.
(d) According to the draft APCR-2021, government organizations involved with the construction activities, especially the local government organizations, are also directed to acknowledge the norms of air quality management (AQM) around the sites of construction/repairing/rebuilding. Several such norms/activities around those sites are suggested in the APCR-2021.
(e) A high level National Executive Committee has been proposed to form. The committee will be comprised of secretary-level government officials from the relevant ministries, government institutions, and public universities. This committee will oversee the progress and effectiveness of the Air Quality Management strategies/activities, and the air quality improvement plan taken in the degraded airshed.
(f) In the draft rule, there is a provision for awarding a person/institute for outstanding contribution to improve the air quality of a region. At the same time, up to two years imprisonment or up to Tk 200,000 fine have been proposed on a person who will be identified guilty as per the rules.
(g) Revisions to the Ambient Air Quality Standards and to the emission standards of all types of sources have also been proposed as schedules of the rules. This is important because the current Ambient Air Quality Standards were set about 15 years ago and a revision to it was highly necessary.
Existing vehicular emission standards are outdated compared to the contemporary world and even compared to the neighbouring countries. Emission standards for several industries are also not so well-defined in the existing rules. The new set of ambient and emission standards proposed is expected to provide the DoE a strong ground to take actions effectively in order to ensure healthy air in the country.
Preparation and implementation
The success of the APCR – 2021 will entirely depend on the preparation and implementation of the Air Quality Management plan/strategy/guideline for the whole country and of the Air Quality Improvement Plan for the degraded airshed area.
Results from a great deal of technical work such as emission inventories, source apportionment, air and meteorology monitoring, dispersion modeling, etc will be the major materials for the formulation of the management and improvement plans.
The APCR – 2021 does not contain any clause regarding the monetary supply and technical capacity buildup of the DoE which will be needed for conducting those technical works and even for the enforcement of those plans.
In the schedule of the APCR – 2021, a brief emission test method, and minimum stack height, have been provided for the brick kiln industries, and also a minimum distance between two kilns is set at 1km. But, it is unclear why such methods and distances are not set for other highly emitting industries like steel mills, cement factories, etc. Setting a minimum distance among the industries is important for averting clustering of the industries, especially to the upwind directions.
It is, therefore, suggested to conduct all-out source inventory and source apportionment studies in the major cities of the country as early as possible so that alternatives to the prime sources and/or proper emission control measures could be considered at an initial stage.
Md Masud Rana is an Air Quality Expert and former consultant to the Clean Air and Sustainable Environment Project of the Department of Environment.