Recognizing the growing problem of air pollution in urban cities in Sri Lanka, Air Resource Management Center (AirMAC), Ministry of Environment and Natural Resources has formulated the “Clean Air 2015: Action Plan for Air Quality Management”, with the overall vision of reducing air pollution related diseases by maintaining air quality at desirable levels through minimizing emission of harmful air pollutants resulting from all human activities. Development of emission standards for different sources of air pollution and their effective enforcements are among the key strategies/actions proposed. Although, emission standards for mobile sources have been already enforced in Sri Lanka, the country has not yet adopted legally enforceable standards for emissions from stationary sources. Recently, a draft The Environment Pollution Division of Central Environmental Authority (CEA), as the implementation agency, has previously prepared a document titled “Revised & Proposed Environmental Standards”, which comprise two sections: Ambient Air Quality Standards and Atmospheric Emission Standards for Stationary Sources. A research study was initiated to revise the emission limits specified in the section on Atmospheric Emission Standards for Stationary Sources, with the objective of developing a set of standards that is more appropriate for Sri Lanka.
The proposed emission standards for stationary sources in Sri Lanka intend to cover all levels of industrial plants and processes listed under National Environment Act No. 47 of 1980. As a result, it represents a comprehensive set of standards covering variety of fuels, raw materials, chemicals and pollutants. In order to have a systematic means of application of the standards, a three-tier approach is provided, where the equipment-based standards (including power plants) are specified under Tier 1, followed by specific process/industry-based standards under Tier 2. Finally, in Tier 3, specific pollutants based standards are specified, covering all stationary sources. Please refer the attached document for more information on the important features of the proposed standards.
Although the three-tier approach is developed to simplify the presentation of standards, the process of implementation could still be a challenging task, particularly in the context of the availability of limited resources and experiences (of both the implementing agencies and industries). Further, lack of local emission data / emission inventory could lead to concern over the specific emission limits specified in the standards. Therefore, prior to endorsing the proposed standards and gazette, the implementation agency (CEA) seeks comments and suggestions from stakeholders to formulate a sound and locally acceptable set of emission standards for stationary sources in Sri Lanka. With this brief note, we now are opening up the discussion to all of you. In order to have a more effective and fruitful discussion, it is planned to have a set of selected topics, and each topic is to be discussed during a week period. At the end of the week, I will synthesis the main points highlighted during the discussion and submit to CEA for appropriate actions. This will be followed by posting of a new topic for the subsequent discussion. Followings are the topics for discussion in the first four weeks:
1st Week: Suitability/Applicability of the three-tier approach used in the proposed emission standards and the adequacy or excessiveness of the coverage of equipment, industrial processes and pollutants.
2nd Week: Potential barriers/challenges for successful implementation of the proposed emission standards, remedial actions/strategies (including phases of implementation) and international best practices.
3rd Week: Appropriateness of concentration based standards (or per unit volume/mass) over load based standards (or per unit energy) and related issues on measuring techniques/equipment.
4th Week: Emission control technologies and associated issues (including costs).
As stated above, the discussion topic in the first week includes the overall features of the proposed emission standards including the three-tier approach used and the industries / pollutants covered in each tier. The basic information on these aspects in the standards is given in the attached document. You may address the following aspects, but not limited to, in responding to this week topic.
- Is there a need for implementing emission standards for stationary sources? (how do you rank this among other activities in the Air Quality Management in Sri Lanka?)
- If yes, what are the key industries and processes to be included (in addition to those already in)?
- Are there industries and processes that are not (or less) important? Should these be removed from the list (or consider in a second phase of implementation)?
- Are the pollutants selected adequate? Are there pollutants to be added or removed?
- Is three-tier approach rational? If not, any alternative approach?
We earnestly look forward for your active participation and inspiring comments.