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Air contamination – sources – solutions

INSAPROMA

Air Contaminant: Any substance present in the air which by its nature is capable of modifying the natural constituents of the atmosphere, altering its physical or chemical properties. Its concentration and length of stay in it can cause harmful effects on the health of people and the environment.

The Ministry of Environment has several programs to monitor air pollution and has standards, ie;has set regulations on permitted levels of contaminants. But so far the application of the rules has been focused on two major areas: state power generation and emergency power plants in industries, both controlled via permits and inspections. Both programs appear to be well implemented.

But if you consult the following list of pollution sources then, yo will observe that there remains many of the sources of emissions to be controlled.

STATIONARY SOURCES:

State or private power plants, more than 40MW – Controlled
Private IPP plants less than 40MW, continuous use – Controlled
Private plants not connected 1MW least more and less than 40MW emergency use – Controlled
Private plants over 100kw less than 1MW emergency use – Slightly Controlled

NOT CONTROLLED:

Private plants use less than 100 KW emergency
Municipal landfills (only a few Pilot Projects of the more than 350 in the country!)
Private burning of trash
Burning coal and firewood to cook

MOBILE SOURCES

Heavy cargo vehicles
Buses
Automobiles
Motorcycles 2-stroke engines
Motorcycles 4-stroke engines

SOLUTIONS:

1- Remove all competitive bidding for any diesel vehicle and for motorcycles ban 2 stroke engines – add in tender specifications that the preference will be for electric models now available with price of 1,779.17 dollars (RD $ 98,937.0) from India and even cheaper from China that can use the AMET or POLITUR, EDESUR, ETED, etc.

http://www.autoblog.com/2016/10/04/tork-electric-motorcycle-india/

http://hodamoto.en.made-in-china.com/product/iKIxCUFPanpr/China-Heavy-Carrying-Electric-Motorcycle-Scooter-HD800-Zz.html

View recent incorrect purchases :

– Acquisition of motorcycles for technical safety of regional directorates of the Ministry of Agriculture (MOA) page 2, Qty of 11 motorcycles, 2010

http://www.mic.gob.do/media/9372/Expediente%20de%20licitaci%C3%B3n%20para%20compra%20de%20motocicletas%20para%20el%20Ministerio%20de%20Agricultura.pdf

– Acquisition of vehicles to strengthen the logistics structure and transport the Ministry of Labour 2016, see page 27

http://mt.gob.do/transparencia/images/docs/compras_y_contrataciones/licitaciones-publicas/2016/MT-LPN-002-2016.pdf

– General Mining; TENDER FOR SPECIFIC CONDITIONS PURCHASE OF GOODS AND RELATED SERVICES (3) 2-stroke Motorcycles. 2015, see page 25

http://www.dgm.gov.do/transparencia/images/docs/compras_y_contrataciones/licitaciones_publicas/2015/PLIEGO_DGM-CCC-LPN-001-2015.pdf

– Institutional Memory 2015, Ministry of Environment; 25 off-road motorcycles – 2015, see page 194

http://www.ambiente.gob.do/ambienterd/wp-content/uploads/2016/02/Memoria-Institucional-2015.pdf

2- Prevent importation by the state, wholesalers and individuals of motorcycles with 2-stroke engines as they did in Bogota in 2011

http://www.eltiempo.com/archivo/documento/CMS-8825802

3- Force to include in the statistics of vehicle fleet prepared by the DGII the type of fuel used for vehicles and for motorcycle if have 2 or 4 stroke engine (Now report on the colors !! useless data) so as to monitor and assist in decision-making on air pollution.

VEHICULAR PARK 2015 Published: March 2016 DEPARTMENT OF ECONOMIC STUDIES AND TAX, Statistics Section DEPARTMENT OF INTERNAL REVENUE

parque-vehicular

Of the total number of motor vehicles registered in December 2015, 53.9% were motorcycles, followed by automobiles with 21.4%, cargo vehicles with 10.9% and the remaining 13.9% is distributed between jeeps, buses, heavy machines, dump trucks and others.

4- In all relating to public transport by bus OHMSA, switch to the use of natural gas or electricity.

5- The Ministry of Environment must convert its vehicle fleet to natural gas or hybrid natural gas / electric (other government ministries as well !)

6- In the importation of emergency power plants, allowing only the importation of those where their specifications respect the rules ENVIRONMENTAL AIR QUALITY STANDARDS AND CONTROL EMISSIONS June 2003 or newer if any (urgent updating – its in draft reform 1 year)

http://www.ambiente.gob.do/transparencia/wp-content/uploads/2015/06/Normas-Ambientales-de-Calidad-Aire-y-Control-de-Emisiones.pdf

7- Train customs staff on new restrictions on imports. Machinery and produce list of approved vehicles for rapid clearance of these, and have the appropriate specifications for each type of vehicle to determine if the equipment is not in the allowed list, can be met according to the manufacturer’s specifications. Publish on the websites of Environment Ministry and DGII these specifications and list of equipment and vehicles already approved.

8- Making investments in the stability of the electric distribution network so as to prevent blackouts and dependence on small and medium size  emergency power plants that produce high levels of pollution. “… In addition, some private sector actors see a direct government intervention in the power generation as unnecessary, saying that investments should go, instead, to improve the areas of transmission and distribution that are in need of modernization. The decision to invest in coal power generation is also facing criticism, because coal is considered a source of “dirty” … energy “(A report from the Economist Intelligence Unit” the future in the electricity sector of the Republic Dominican 2015)

http://www.adie.org.do/documents/articulos/Funglode_ElectricitySectorReport_Spanish_FINAL.pdf

Article of Interest;

http://www.listindiario.com/la-republica/2007/05/06/11908/las-ciudades-se-ahogan-en-monoxido-de-carbono

9- Solicitations for large public generating plants remove options for coal and other fuels derived from oil and add renewable energy and leave natural gas in the tender specifications.

View new licitation where as a result, will surely perpetuate energy production by dirty methods:

http://www.edesur.com.do/wp-content/uploads/2016/08/es-site-cdeee-licitacion-lpi-001-2016-publicaion-oficial-2016-08-24.pdf

View the current specification (marked in yellow, reads: ..” which fuel can be natural gas, coal, fuel oil No6, No2 or mixed fuel; (c) for a total contracted capacity of up to 900 MW”)

licitation-de-plantas-900-mw-2016

In power generating plants in the country, impose the strictest standards and short deadlines to conform or convert their plants if not be subjected to fines and even boycotting purchase of energy by the state. Incentives for those who comply and penalties for others who do not must exist.

10- restrict or prevent the importation of any equipment such as power plants and vehicles that do not meet the standards ENVIRONMENTAL STANDARDS AIR QUALITY AND EMISSION CONTROL – 2003 or its latest version

Note in the draft document dated October 2015

http://www.ambiente.gob.do/transparencia/wp-content/uploads/2016/02/Borrador-Norma-Ambiental-de-Calidad-de-Aire.pdf

on page 67 we find the following table:

limites-de-emisiones-motocicletas

Although it has changed the emission limits for 2-stroke engine to 2,000 ppm of HC, if this type of engine emits 4 times more HC than 4-strokes, why allow its use? If you consider that there are nearly 2 million motorcycles in the country and perhaps half are 2-stroke engines (100% of the scooters are), perpetuating its use lacks logic. These regulations of 2008 are outdated, why not use more stringent Euro IV standards? Lapsus – error? It must be corrected. (The 2003 standard is in way of an upgrade since October 2015 … 13 years! While in Europe they have gone from Euro III to IV, V and VI that is at least 3 updates. The country cannot be so lethargic !, less from the body that must monitor the environment!)

For such purposes of enforcing the prevention of importation of vehicles that do not meet the standards, Senator Diaz Amado deposited on September 30, 2016 a bill: http://ciudadoriental.com/amado-diaz-deposita-primer-proyecto-ley/

In its Chapter IV, Article 11, paragraph 1 states that:

“The Directorate General of Customs will arrange for the publication of motor vehicles that can enter the country, according to the manufacturer’s technical data and in relation to the emission of air pollutants.”

Also this very interesting law project (though perhaps difficult to implement because of costs to users) provides:

“Article 6 – Typicality. The owner of a motor vehicle of any type is required to install a particulate filter or gas emissions control system, provided that the vehicle does not have a system similar control included by the manufacturer, or for the car exceeds the limits set by regulation issued for this purpose by the Ministry of Environment and Natural Resources.”

If such law could be applied, such measures would result in greater environmental sanitation as it would treat the existing fleet in the country of more than 3.8 million vehicles.

11- As for burning in landfills, obviously the state must urgently establish sanctions to municipalities for negligence or lack of supervision, permit burning in these places. The high content of plastics, when burned, produce highly toxic fumes that are of great danger for the population located near these landfills.

12- As for burning garbage in private landfills, on abandoned lots, municipalities should be instructed to close them down, fence off the land if necessary and try to discover the inhabitants who engage in this practice. There should be sanctions for these environmental crimes. But the discontinuance of this practice is directly intertwined with the availability of organized garbage collection by the municipalities and outlying rural areas. Unfortunately these have no budget allocations for these purposes in amounts sufficient to reverse the situation. This is at the level of national budgets and priorities for now. We think that the Ministry of Environment falling short in their own budget needs, although it is up to it to generate alerts, alarms and press the government to implement national plans for collection and disposal of waste, hence we can see that burning trash in informal or municipal dumps will continue for decades.

13- As for burning coal and wood for cooking, the solution can not be punitive as this segment of the population suffers enough. What we must have is through the Ministry of Environment the donation to 300,000 families using coal and wood, propane stoves and 10 Gal tanks (easy to carry in the fields), and include these families to the program Bonogas for households (BGH). What is the annual cost of planting trees, since year 2000 for the Ministry of Environment? and what is the purpose if 300,000 families continue to cut trees? – We must eradicate the source of the problem not patch it up through band-aids.

Consider this exercise, cost estimation:


Reforestation budget, 3 years $786,300,000 Source
Propane gas cooking kit
 $US  $RD
2 burner stoves $15.00 $690.00 Source
10 gal tank $20.00 $920.00 Source
Regulator $2.00 $92.00 Fuente
6 ft hose $1.25 $57.50


$1,759.50
Logistics importation & distribucion, per family $861.50


Total Cost of program per family $2,621.00 
Benefited Families, material  300,000 $527,850,000
Logistics importation & distribucion total (amply covered – surely less) $258,450,000

Total Cost of cooking kit program – (Equivalent to reforestation budget) $786,300,000
Program similar in Peru, greater scope Source

Time to make an impact on air pollution:

Cooking Kit: IMMEDIATE (low emissions – Pollution Prevention)

Planting trees: 10-20 years depending on type (absorption and filtration – that is mitigation or neutralization of the source of contamination, after damages have occurred)

Other benefits are that with this program, besides having extremely positive effects on aspects of air pollution and deforestation, help to escape from poverty and improve the living conditions of thousands of families, not to mention improving the health of families who were cooking by burning charcoal and firewood in the house.

14- To Public Procurement, the Ministry of Environment should produce a list of specifications for the import of equipment and vehicles (listed in paragraph Source above). These specifications regarding allowable levels for each pollutant. The same should be included in all public procurement for all state agencies that the award not only be based on other technical aspects and pricing. Further, in this specification should be recommendations on technology, fuel etc., so that these factors are considered preferred at time of buying. It should also be that positive specifications of products offered, with regards to affectation or preservation of the environment, would have a weight of Veto in decisions on the evaluation matrix, ie for same price and technical specifications, the equipment with the highest positive environmental score, should result in purchase of the latter.

15- Grants to adequate or convert vehicles. The now discontinued gas transport subsidy which benefited the public transport providers, their business, their profits ?Why not provide a subsidy for the conversion to natural gas, or exhaust catalysts or equipment that benefit the environment? Heavy vehicles and diesel buses are old and produce many harmful fumes. Convert or adapt vehicles up to 4-5 years old would change quite change the picture. There would not be subsidies for older vehicles, but the requirement obligation (as the bill proposes Senator Amado Diaz) to adequate their vehicle.

Conclusions:

From the proposals or solutions described above, it can be noted that only through stricter regulations can an improvement in the situation in controlling air pollution for the future be achieved. There are currently too many holes that permit non-respect of the environment regulations.

The country must implement prevention solutions and not be waiting years for wanting, after observing the facts to late, to punish, repair, remedy, which as we see are more the type of activities of the Ministry of Environment.

We see days dedicated to the cleaning of beaches and rivers, but we not for organized garbage pickup and recycling projects, even see deployment of trash cans and containers in public places high affluence. They are always in reaction, not prevention. We like the awareness projects in grade schools, but it will be in 12 years that we will have a population more respectful of the environment, that effect is as slow as planting trees.

The private importer looking for the lowest cost in equipment and vehicles for a public mostly poor, forces the importer to go towards the simplest products and mostly these products do not comply with the slightest environmental regulations. You will confer that the ideal supplier is China, still a haven for the manufacturer who is not required to produce equipment that meet environmental regulations. This is why its up to the country (DR) to prevent that, if not, the importer will continue to bring in products that harm the environment wheter they are from China, India or another country.

The above described proposals are simple, many fast to implement and most of all almost at no cost to the state. The Ministry of Environment should impose itself to all importers (or buyers of improper products already in the country) private and public, and plug the hole.