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S21 Notice

S21 Notice. Submission by CAIA. Outline. National Air Quality Management Framework Current status of Notice Combustion installations Chemicals Waste Conclusions and Way forward. National Air Quality Management Framework. Standard setting factors to be considered

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S21 Notice

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  1. S21 Notice Submission by CAIA

  2. Outline • National Air Quality Management Framework • Current status of Notice • Combustion installations • Chemicals • Waste • Conclusions and Way forward

  3. National Air Quality Management Framework • Standard setting factors to be considered √X Health, safety and environmental objectives √ Analytical methodology X Technical feasibility X Monitoring capability X Socio economic consequences

  4. National Air Quality Management Framework (2) • Listed activities X Informed by cost benefit analysis X Approach to ensure no unjustified economic impacts X√ BPEO based on BAT X √ Used for point sources i.e. stacks and vents

  5. National Air Quality Management Framework (3) • Compliance timeframes X Informed by industry cycles X Minimum timeframes ; more restricted by license √ Possible extensions √Atmospheric impact report

  6. Status of current notice • List intended to target activities where economic benefits of regulation outweigh cost of regulation (largely derived from APPA) • Intention to address errors in 2010 Notice • Revised version published for comment in 2012 for comment over December • Extension granted to 23 January 2013 • New activities and requirements Included resulted in significant challenges

  7. Status of current notice (2) • Compliance timeframes • No recognition given for the fact that errors in 2010 notice prevented upgrade or that new requirements have been added • Extent of re-engineering required not possible in less than 2 years • Legal certainty essential for planning • Multiple postponements do not provide certainty • New requirements in this notice

  8. NOx emissions/production

  9. Combustion installations • Waste as a fuel was not excluded in 2010 • Consequences of exclusion were not discussed • Internationally waste of known composition used as fuel on same site is treated differently from when incinerated by service provider along with other waste of unknown origin • Current practice should be permitted to continue until technical and economic feasibility has been assessed • Waste regulations prohibit landfill disposal of waste that can be used as fuel

  10. Chemicals

  11. Chemicals (2)

  12. Chemicals (3)

  13. Burning grounds • New activity: consequences not discussed • Very specialised activity to achieve compliance with Explosives Act • Should not be regulated in a manner conflicting with Explosives Act • Should be removed until requirements of NAQF are complied with.

  14. Conclusions NAQF not complied with: • Cost benefit analysis of listing not done • Best available technology not always recognised • Technical feasibility not done • Socio economic consequences not determined

  15. Way forward • All new activities to be removed until requirements of NAQF have been met • Compliance timeframes to be reviewed • Finalisation of Notice to be done in compliance with technical process in NAQF

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