This paper shows that there is still not sufficient information to establish the true air pollution price of the Coega Harbour and IDZ Project

The following key questions remain unanswered;

• Why has there never been a detailed analysis of current air quality at the proposed Coega site?
• Why has there never been a detailed meteorological assessment at the proposed Coega site?
• Why has there never been a public health assessment of local communities?
• Why has there never been an analysis of the air pollution effects of the projected development as a whole?
• What exactly are the dust mitigation measures that are supposed to keep fugitive dust emissions in check? Why has there been no quantitative modelling done to establish the effectiveness of these measures?
• Why have there never been figures released for the short-term sulphur dioxide emissions during the operation of the smelter?
• Why has there never been any quantitative analysis of the accumulation of heavy metals on-site and in the surrounding environment?
• Why has there been no modelling of the distribution and concentration of pollution under inversion layer conditions?
• Why do the air pollution standards fail to consider the effect of sulphur dioxide and dust in combination?
• Why has there never been a comprehensive risk assessment of the fall out from an accident during operation of the smelter?

The importance of establishing the facts about the air pollution impact of the Coega development can not be overstated. Given the proximity of residential communities to the Coega project, air pollution has the potential to have a serious effect on public health, and may even lead to a substantial increase in mortality rates. SAEP believes that approval for the Coega development prior to addressing the questions raised in this paper represents a dangerous game of air pollution Russian roulette.

The proposed Coega IDZ is a heavy industrial development to be sited at the mouth of the Coega River on the outskirts of Port Elizabeth. The anchor project is a zinc smelter to be constructed by London based multinational, Billiton, and it is proposed that a deep-water harbour will be constructed by Portnet to service the IDZ.

The Southern Africa Environment Project (SAEP) has been a prominent voice in raising a range of issues concerning this development. The focus in this paper will be on the air pollution impacts of the Coega harbour and IDZ development.

The paper is based on a detailed analysis of the Environmental Impact Reports for this project prepared by African Environmental Solutions, which included specialist air pollution reports prepared by Environmental Management Services (henceforth referred to collectively as the "consultants" and "the Coega EIRs").

A list of references for this paper is available on request.

The consultants acknowledge that "some dust may already be present at the Coega precincts due to existing brickwork's in the area", and feedback from the local community suggests that the area is well-known to suffer from short bursts of intense sulphur dioxide (commonly known as "rotten egg gas") pollution. These represent localised pollution effects which can only be monitored on-site. However, at no stage has there been an on-site baseline air quality assessment.

It is clearly impossible to measure the true air pollution impact of the development without this fundamental baseline data.

It is well known that the Coega site has a number of specialised micro-climatic features (e.g., the consultants discuss the existence of localised inversion layers at certain times in the year). However, there has never been an on-site meteorological assessment.

The consultants themselves note that their physical modelling is critically dependent on accurate baseline meteorological data (particularly with regard to wind speeds and directions, and seasonal variations in these conditions). Thus, the absence of on-site data undermines the entire basis of the physical modelling used for the impact projections in the Coega EIRs.

Despite an explicit call from the consultants for a full public health assessment to be done for the local communities which will be impacted by air pollution from this development, this has still not been done.

It is impossible to determine the true risk posed by additional air pollution from the Coega development until such an assessment has been conducted.

The environmental impacts of the project have been considered in a piecemeal fashion. At no stage have the environmental impacts of the harbour and IDZ development as a whole been considered. In particular, it is important to consider the impacts not only of the anchor tenant, the Billiton zinc smelter, but also of the proposed heavy industrial satellite tenants.

Until an analysis of the project as a whole is done, it is impossible to determine the true impacts of the air pollution generated by the development.

The fugitive dust emissions during the construction of the smelter are predicted to be extremely high. Of further concern is that, once again, there has been no consideration of cumulative impacts due to simultaneous construction of the harbour and other IDZ tenants.

The Coega EIRs state that certain "dust mitigation measures" will be employed to keep dust levels below guidelines. It is crucial that these measures are specified and that quantitative analysis is done to determine their true effectiveness.

Recent evidence from the British Medical Journal (Volume 314, June 1997) suggests that exposure to short time period, high concentration spikes of sulphur dioxide pollution can lead to grave health problems. The Coega EIRs completely fail to address this issue. In fact, they provide no cumulative (baseline plus impact) sulphur dioxide emission projections over either hourly or daily averaging periods.

Of particular concern is the finding that such serious health effects may occur at levels below generally accepted air pollution standard thresholds, with the crucial factor being the size of the spike rather than the level of the regular background concentration. This is a very serious issue, and must be investigated fully in order to determine the true health implications of the pollution levels projected for this development.

Experience from similar zinc smelters around the world has been that there have been substantial problems with heavy metal contamination of soils and groundwater.

It is extremely irresponsible for this danger to be assumed away in the Coega EIRs.

As mentioned in Section 1.2, the consultants themselves acknowledged the existence of localised inversion layers which inhibit dispersion under certain conditions. However, there is no modelling of the consequences of such an inversion layer occurring during operation of the smelter.

The consultants acknowledge that there exists a synergistic effect whereby health problems due to sulphur dioxide are worsened under conditions of co-existent dust pollution. This happens because the dust particles transport sulphur dioxide deeper into the lungs than would otherwise be the case.

The Coega EIRs noted that "the EU's ambient air quality standards for SO₂ reflect this synergistic relationship by making the SO₂ standard contingent upon the level of smoke present". It is then rather mysterious as to why this example of international best practice has not been followed in the recommendations of the Coega EIRs.

The consultants made an explicit call for a comprehensive risk assessment to be conducted to consider the possible emissions in the case of a catastrophic failure in the operation of the smelter. This has never been done, and thus represents a very important element of risk that has not been considered in the air pollution price of the project.

This paper makes it clear that there is still not sufficient information to establish the true air pollution price of the Coega Harbour and IDZ Project.

In particular, it can be seen that the Coega EIRs have been grounded in baseline data that is speculative at best, and that this implies that all of the projected impacts in the Coega EIRs, determined from physical modelling based on this baseline data, are intrinsically suspect. Furthermore, there is no quantitative analysis presented for such crucial features as the dust mitigation, the short-term sulphur dioxide emissions and the heavy metal accumulation. The EIRs have also failed to address issues such as the impact of inversion layers on dispersion of pollution, the health implications of the synergistic effect between dust and sulphur dioxide pollution, and the risk of pollution fall out from an accident during operation of the smelter.

The importance of establishing the facts about the air pollution impact of the Coega development can not be overstated. Given the proximity of residential communities to the Coega project, air pollution has the potential to have a serious effect on public health, and may even lead to a substantial increase in mortality rates. SAEP believes that approval for the Coega development prior to addressing the questions raised in this paper represents a dangerous game of air pollution Russian roulette.