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