According to the assessment of the World Health Organization, if the concentrations of PM 2.5 particles in 11 cities in Serbia were reduced by only 10μm /m3, premature mortality due to air pollution would decrease from 3,585 to 1,862 citizens per year. If this reduction were 20μm /m3, the number of premature deaths due to air pollution would be 301. Close to four million citizens of Serbia are exposed to excessively polluted air, according to the data of the Report on the State of Air Quality for 2021. All eight agglomerations and 12 cities on the territory of Serbia are in the excessively polluted category.
The list of cities with excessive pollution in 2021 included: Valjevo, Novi Pazar, Kraljevo, Zaječar, Kragujevac, Čačak, Loznica, Paraćin (Popovac), Subotica, Sombor, Sremska Mitrovica i Zrenjanin. The status of agglomeration in Serbia is: Beograd, Novi Sad, Niš, Pančevo, Smedervo, Kosjerić, Bor i Užice and in all eight the air is (was) excessively polluted.
In all cities and agglomerations where there is excessive pollution, we are talking about an excessive concentration of suspended PM 10 and PM 2.5 particles. These particles, which essentially represent a mixture of soot, dust and smoke, are created primarily through the combustion of solid fuels for the production of heat and electricity.
The inventory of the origin of pollutants as part of this year's report leaves no room for a dilemma - pollution by suspended particles primarily originates from heating plants of less than 50MW and individual heating.
The exception is Bor, where, in addition to particle pollution, there are high concentrations of sulfur dioxide of industrial origin were also recorded. Due to the nature of air pollution in Bor, which is also dangerous in the short term, as well as due to the frequency of overshooting limit values on a daily and hourly level, this city is stands out from the others in terms of the seriousness of the air pollution problem.
Do we have enough data?
It is evident that the scope of air quality monitoring has improved compared to the previous year, primarily in terms of the amount of data submitted to the Environmental Protection Agency from the local level. This year, the official measurements and assessment of air quality included data from as many as 201 measuring stations places. The makers of the Agency's report state that it is the largest the flow of data on air quality by local governments registered this year, which means that all local governments that finance air quality monitoring have fulfilled their legal obligation. We can remember that it was not always like that case, and that last year, Belgrade did not submit data from local networks to the Agency, despite several repeated requests.
In addition, the quality of the data, that is, the availability of valid data hourly values, varied depending on the polluting substance, so the Environmental Protection Agency has the most available valid data on the concentration of sulfur dioxide (91%), and the least about ozone concentration (83%). The importance of expansion air quality monitoring in Serbia is also reflected in the fact that the area of cities where official air quality monitoring has been established constitutes approximately 25% of the total territory Republic of Serbia.
Inventory of the origin of pollutants in the assembly of this year's report leaves no room for dilemma - pollution with suspended particles primarily originates from heating plants of less than 50MW and individual heating.
However, it still does not exist in numerous areas throughout Serbia comprehensive monitoring of air quality, and it is unfounded concluding that the air in those environments is clean. Even 42 stations (out of 72 included in this year's report of the Agency) the concentration of suspended PM2.5 particles is not measured. In ten cities, where the air is rated as clean based on of measurement results from measuring stations, the concentration of suspended PM2.5 particles is not measured.
Some of these places are: Šabac, Kostolac, Vranje and Kikinda. The Agency's report shows data on the results of indicative measurements of suspended particles, however, these results are not taken into account in the official assessment of air quality, because the measurement was not carried out in sufficient volume. Gornji Milanovac stands out as an example this year, in which the measurement of PM10 concentration is indicative of particles was carried out for 56 days, apropos, 56 samples were taken. In that limited period, as many as 23 were recorded days with excessive pollution and a mean concentration of 52 µg/m3. The above data provide a clear picture of the air quality category in which Gornji Milanovac would be classified in this case establishment of continuous monitoring.
Due to the nature of air pollution in Bor, which is dangerous in the short term, as well as because of the frequency exceeding the limit values on the daily and hourly level, this city stands out from the rest by the seriousness of the air pollution problem.
The importance of establishing continuous monitoring of pollution of air in the territory of the entire country, in accordance with the Law on Air Protection, is also reflected in the results of air monitoring obtained from the civic network. When looking at the cross-section of the state data from the civic air quality monitoring network, which the Belgrade Open School and the National Ecological Association made in June of this year, it can be seen that the problem with air pollution exists in numerous areas where it is still there is no official monitoring. Sensors from the civic network recorded the highest pollution in Šabac. In addition to Šabac, the following places had over 100 days of excessive PM10 pollution until June: Knjaževac, Zaječar, Požarevac and Kučevo. Annual limit of 35 days of excessive pollution prematurely Leskovac, Gornji Milanovac, Aleksinac, Negotin, Sremska Mitrovica, Kula, Prokuplje, Majdanpek, Prijepolje, Brodarevo, Bosilegrad, Trstenik, Požega, Kruševac, Kovačica, Bela Palanka, Surdulica, Bečej, Senta, Ruma, Arandjelovac, Mladenovac, Kovin, Osečina. (Complete results can be seen at this link).
The strategy we've been waiting for, the program that we waited
At the Government session, held on December 8th, the document under entitled "Air Protection Program in Serbia 2022−2030" whose place in the legal system of the Republic of Serbia is not entirely clear. Namely, program in the sense of Article 14 of the Law on Planning System is "a document of public policy, narrower scope than the strategy which, according to as a rule, elaborates a special goal of a strategy or another plan documents in accordance with which it is adopted (Development Plan, Program Government, local government development plan, policy concept)". However, it is not clearly in accordance with which strategy the Protection Program is created air and what special goals of the strategy or another plan documents are elaborated.
If the content of the program is compared with the articles of the Air Protection Act, which regulate the protection strategy air, it is clear that this is not a program, which is hierarchical a lower public policy document than a strategy, but a basic strategic document in the field of air protection.
Adoption of the Air Protection Program should create a new dynamics in the implementation of measures to improve air quality in Serbia, at all levels. The ambition of this document is best reflected in the vision that by 2030 the citizens of Serbia will breathe clean air, as well as estimated financial means for his implementation - 2.6 billion euros.
EXCESSIVELY DELAY
Publication of annual reports on the state of quality air is an obligation of the Environmental Protection Agency (SEPA), which stems from the Law on Protection air. However, although the Law stipulates that the deadline for publication of the report on February 28th of the current year for previous, in practice reports have been published at the end of August or beginning of September for years. And the report for 2021. was published only in November of this year.
The report generates data from the national network of automatic stations managed by the Agency, as well as the station which are under the jurisdiction of local self-governments.
In the Republic of Serbia, air quality is measured in three zones and eight agglomerations, and an integral part of the report is the assessment of air quality. Depending on the degree pollution, the air quality can be rated as clean or slightly polluted (I category), moderately polluted (II category) and excessively polluted (III category).
Air quality plans
Air quality assessment, provided by the Environmental Protection Agency of the environment, is the starting document in the further creation of legal acts and public policies in the area of air protection, since the Air Protection Act stipulates that in agglomerations where category III air must adopt Air Quality Plans, which, among other things, prescribe the measures that the competent authorities will be required to implement in order to reduce pollution. Bearing in mind that all agglomerations are in the third category of air quality, it is necessary that all agglomerations have valid air quality plans. In addition to agglomerations, the following should have air quality plans: Kragujevac, Kraljevo, Zaječar, Valjevo, Novi Pazar, Paraćin, Čačak and Loznica.
It is evident that the scope of quality monitoring air improved compared to the previous year, primarily in terms of the amount of data that was submitted to the Environmental Protection Agency from the local level. This year is official measurements and assessment of air quality entered data from as many as 201 measuring points.
In numerous areas throughout Serbia, there is still no comprehensive monitoring of air quality, so it is unfounded to conclude that it is the air in those environments is clean.
The results of air quality monitoring, which it combines Environmental Protection Agency, are the basis for the adoption of the Regulation on determining the list of air quality categories by zones and agglomerations on the territory of the Republic of Serbia, adopted by the Government of the Republic of Serbia once a year for the past calendar year. However, the Government continued to passes these decrees one year late and that's it adopted this regulation for 2019 in February 2021, while the regulation for 2020 was adopted at the end of 2022.
(Non)work of the Working Group
Working group for the systemic solution of air protection issues in Serbia was formed on January 17th 2020. with the task of, among other things, it proposes measures for the systemic solution of air pollution and coordinates the positions of the competent authorities that deal with issues of air protection from pollution. RERI, despite several submitted requests and decisions of the commissioner, which are ordered submission of the requested data, has so far failed to obtain data on the activities of this working group. Almost three years later, again facing public pressure over pollution air, the holders of the highest state positions announced again formation of a working group to solve the problem of air pollution.
Air protection is the protection of human rights
According to the assessment of the World Health Organization, if concentrations of PM2.5 particles in 11 cities in Serbia decreased by only 10µg/m3, premature mortality due to air pollution would decrease from 3,585 to 1,862 citizens per year. If this reduction would be 20µg/m3, the number of premature deaths due to of air pollution would be 301.
According to the opinion of the United Nations Special Rapporteur there are seven key steps that states must take in exercising the right to clean air: monitor air quality and impact on human health, assess sources of air pollution, make information available to the public (including advice for public health), establish laws, regulations, standards and air quality policies, develop air quality action plans at local, national and, where appropriate, regional levels, implement the air quality action plan and enforce standards and assess progress and, if necessary, strengthen the plan to ensure that standards are met.
Working group for systemic issue resolution of Air Protection in Serbia was formed on January 17th in 2020 with the task of, among other things, proposes measures for the systemic solution of air pollution and coordinates the positions of competent authorities dealing with air protection issues from pollution. RERI, despite several submitted requests and decisions of the trustees, ordering the submission of the requested data, he has not been able to do so to date obtain data on the activities of this Working Group.
Finally, it is high time that the decision makers and everyone else stakeholders view air pollution through the prism of the protection of basic human rights. Without enjoying the right to a healthy environment and the right to health, it is not possible to enjoy a wide range of other human rights, and every human being has the right to enjoy the highest attainable standard health that favors a dignified life.
States must not violate the right to clean air by their own actions, and they have a positive obligation to protect the right from violations by third parties, especially businesses, where they must establish, apply and enforce laws, policies and programs in order to ensure the full enjoyment of rights.
Ognjan Pantić and Lazar Jovčić, Belgrade Open School, Hristina Vojvodić and Ana Filipović, RERI
*The complete analysis is available on the Belgrade open school website and the Regulatory Institute for Renewable Energy and Life the middle.
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