The Belgrade Open School (BOS) and the Regulatory Institute for Renewable and Environmental Regulatory Institute (RERI) organized the second round of public consultations on the Air Quality Plan for Belgrade on January 22., via the Zoom platform. This event is a continuation of the public consultations launched by RERI and BOS in December 2020, with an aim of involving the public in the process of drafting a new Air Quality Plan for Belgrade.

This is a document of great importance, since the city of Belgrade is faced with permanent air pollution, that the concentrations of pollutants exceed the permitted limit values, that air pollution is one of the primary threats to public health, which according to the World Health Organization, results with about 1800 premature deaths of Belgrade citizens and that the existing level of pollution would result in further shortening of the life expectancy of Belgrade residents - estimated over 75,000 years of life lost (YLL) for Belgrade residents in the next 10 years [1].

There was little information about the development of the new Plan during 2020, and there was no opportunity for the public to get involved in this process. It was only on January 15 that the City of Belgrade published an announcement on the Draft of the Air Quality Plan, as well as an invitation to the interested public to submit comments on the Draft of the Plan by January 30^th 2021.

As part of the public consultations, introductory speeches were given by Mirko Popović and Hristina Vojvodić (RERI), Aleksandar Macura (RES Foundation) and Ognjan Pantić (Belgrade Open School), after which other participants joined.

As key shortcomings of the presented Draft Plan, the participants in the public consultation stated the following:

1) Procedural objections:

• The current process does not meet the basic criteria of a public hearing. The notice of public insight was published on January 15, and the deadline for submitting comments was 30^th of January. Public presentation is not anticipated by official bodies;
• The draft of the Plan did not provide a documentary basis on which the Plan was prepared;
• No analysis of the effects of the previous Air Quality Plan (2016-2020) was provided;
• The decision not to start the preparation of the strategic impact assessment for the draft Air Quality Plan was made contrary to the laws of the Republic of Serbia. The Air Quality Plan for Belgrade meets all the criteria set out in the Law on Strategic Impact Assessment, in terms of what documents must be approached for the preparation of a strategic impact assessment. The implementation of the measures listed in the draft Plan would imply the implementation of projects for which it will be necessary to conduct an impact assessment.

2) Remarks regarding the content:

• The Draft of the Plan was not prepared in accordance with the Rulebook on the content of Air Quality Plans;
• The Draft  of the Plan does not offer a vision of reducing pollution and improving air quality;
• The Draft of the Plan does not contain air pollution reduction objectives, which would provide a starting point for measuring the success of the implementation of the Plan;
• The proposed measures do not include an analysis in terms of profits and costs, as well as the impact on health and the environment;
• The Draft of the Plan does not contain a thorough analysis of the impact of air pollution on the health of citizens;
• The short-term measures, listed in the Short-Term Action Plan, do not contain: precise deadlines for implementation - each measure is stated to be implemented continuously, which is not a deadline; there are no precise data on the effects of the measures; there are no indicators of impact on pollution reduction and elimination of consequences; short-term measures apply to industry in general, only to traffic and public information;
• Measures related to the reduction of pollution originating from thermal power plants, listed in the Plan, were implemented mainly in the period up to 2004. The developer of the study does not provide any information about the measures in the period from 2014 to 2020.
• There is no measure to reduce sulfur dioxide emissions from thermal power plants; In this period, and especially in the period from 2018 to 2020 (the period of validity of the previous Plan), the observed sulfur dioxide emissions were 4 times higher than the emissions allowed by the NERP (National Emission Reduction Plan, should have been in force until 01.01.2018.).
• The measures listed in the Draft of the Plan are measures over which the City of Belgrade has no competence in terms of implementation - the bearers of measures are the Government of the Republic of Serbia, the Ministry of Environmental Protection and Electric Power Industry of Serbia (EPS), without the current mechanism through which the City could influence these institutions;
• The measures and indicators listed in the Draft of the Plan are imprecise and descriptive, which makes monitoring the implementation of measures practically impossible;
• The Draft of the Plan does not contain an assessment of the planned improvement in air quality and the time period required to achieve these objectives;
• There is no inventory of pollution emissions; the pollution emission inventory is planned as a measure within the Plan, and not as a previously implemented measure that would be part of the Plan;
• The results of periodic measurements of the concentration of PM10 particles are not adequately presented - instead of percentiles, but through the number of days with exceeding;
• The Draft of the Plan does not contain detailed data on total emissions from pollution sources (by tons per year);
• The Draft of the Plan does not contain detailed data on individual furnaces, but within the framework of the Draft it is still planned to make a list of individual furnaces, which should be a measure that precedes the plan.

Participants in the public consultation agreed that the proposed Draft of the Plan should be withdrawn from the procedure, as it does not meet the basic criteria and standards that the Air Quality Plan should meet, and that the adoption of this document and the implementation of these measures will not respond to the urgent need to the problem of air pollution in Belgrade is solved. 

The problem of air pollution in Belgrade is extremely complex, since it is a densely populated city, through which in besides the city traffic, regional and international traffic passes, that in the relative vicinity of the city are huge installed capacities of thermal power plants, and that the city is exposed to pollution coming from that wider environment, which the Draft of the Plan in question partially talks about. The process of public debate on the Draft of this Plan, as well as the content of the Draft, fit into the broader picture of public policies in the field of environmental protection: the Republic of Serbia does not currently have the Air Protection Strategy adopted, the National Plan to Reduce Emissions from Thermal Power Plants is largely not respected, and the public is faced with an extremely narrow space for participation in extremely important decision-making processes on legal and planning documents.

We invite all interested parties to send their comments on the draft Air Quality Plan by 30^th of January, via e-mail to pkv.bg@beograd.gov.rs.

Author of the photo: Belgrade Open School