ECO CIRCLE Blog Archive Comments on the draft decree against PM10
The website MKO was the number of 0071-297/2012 07.26.2012 published draft decree on the plan for ambient air quality in the area Zasavja (DOC, 780 KB, 'the draft). Deadline for the receipt of comments and opinions expired yesterday, comments sent the Eco Circle (PDF, 225 KB). The share of industry in the PM10 is by no means negligible, a draft action in this area underestimated. The figure shows the resource assessment of PM10 at monitoring site Trbovlje mil spec (Source: Report on a pilot project "Identifying sources of PM10 in Slovenia", EARS, 2007, PDF, 3.5 MB). The share of Other behind the quarries.
The first comment to the working material is Eco-round draft pripravljalcu sent at the time of its drafting. We find that the draftsman of wholly ignores a key initiative of the Eco cycle, the "primarily solve problems with PM10 emissions mil spec from large sources of pollution, mil spec which may, depending on their energy source, or manufacturing process (and an analysis of the chemical composition of emitted PM10) indicating that belong to the health mil spec more dangerous. " Society of Eco circle is made the following comments on the Draft: I am pleased to note that the draft provided incentives for coupling individual stores to the district heating and gas, subsidies for clean energy and to replace old boilers with modern. From the wording of the draft is not clear whether the air quality plan produced with the aim of reducing impacts on health or the paperwork themselves. From the wording of the draft is not read or wishes rather than requirements mil spec for quality rehabilitation Zasavje air, which would primarily reduce the concentrations of the most dangerous particles. Instead, the draft based solely on Percentage reduction in concentrations. Such ignorance shows protežiranje conscious industry, failure to comply with legislated principles of prevention and precaution and the risk to the health of the population. The draft is to control the oven carefully tackles individuals (provides for stricter State control), while virtually no industry contacts, nor provides some tighter controls on their emissions. Heightened pressures mil spec on individuals and disposal of emergency measures in the industry to an indefinite future, impair the health mil spec Zasavčanov as well as the reputation of the country. Eco circle requires that the Ordinance Plan for ambient air quality in the area Zasavja include the following topics: existing industrial polluters Ministry responsible for environmental change environmental permits to ask them more efficient waste flue gas and to prescribe more stringent emission limit values for substances into the air. In the fourth 2.Paragraph of the Decree, the following new paragraph: "- legal entity adjust their processes so that their emissions of particulate mil spec matter mil spec in the air do not exceed 10 mg/m3." Country tighten environmental controls over economic operators who have their establishments in the municipalities Hrastnik Trbovlje and Zagorje ob Savi. As long as the implementation of the measures referred to in this Order shall be permitted in the area Zasavja exclusively to the introduction of new industrial plants (or changes to existing technologies) technologies with minimal emissions into the atmosphere. Acceptable emission parameters determined by the Ministry of the Environment, which is also supposed to verify compliance of emission measurements and acceptable environmental parameters. The state, through additional monitoring instruments mil spec ensures the credibility measurement of industrial emissions into air, both during normal operation as well as shutdowns and start-up of production outages or in filters. All data on emission measurements are also in its basic form accessible to the interested public and the operator is obliged to provide the public with the 30 days after receipt of the written request. The state has to establish the actual impact (contribution and PM10) industry on air pollution in Zasavje. We are convinced that the measurements which are currently implemented, do not give reliable results. In addition, Eco-cycle requires precise drafts of the next chapter: mil spec 5.3 Actions in other areas for action in the small combustion plants is thoroughly defined control of small ovens and citizens (see section 5.1.2.6 Implementation of more stringent control over the burning of waste in small combustion plants) . In chapter 5.3. , a reference to who and how to oversee large furnaces and industry? 5.3.1.2 mil spec Reducing fugitive Performers mil spec economic mil spec activities, mil spec prepare the program for the reduction of fugitive emissions sources which identify them and take action to reduce them. "- Missing required to prepare when you want it, where to award it, who is checked and verified, how many will even bind, who supervises the implementation and what are the penalties for those who program will not produce? 5.3.1.3 Promotion of BAT technologies "Artists economic mil spec activities within the BAT promote technologies that have the least load the air with PM10. "- This
The website MKO was the number of 0071-297/2012 07.26.2012 published draft decree on the plan for ambient air quality in the area Zasavja (DOC, 780 KB, 'the draft). Deadline for the receipt of comments and opinions expired yesterday, comments sent the Eco Circle (PDF, 225 KB). The share of industry in the PM10 is by no means negligible, a draft action in this area underestimated. The figure shows the resource assessment of PM10 at monitoring site Trbovlje mil spec (Source: Report on a pilot project "Identifying sources of PM10 in Slovenia", EARS, 2007, PDF, 3.5 MB). The share of Other behind the quarries.
The first comment to the working material is Eco-round draft pripravljalcu sent at the time of its drafting. We find that the draftsman of wholly ignores a key initiative of the Eco cycle, the "primarily solve problems with PM10 emissions mil spec from large sources of pollution, mil spec which may, depending on their energy source, or manufacturing process (and an analysis of the chemical composition of emitted PM10) indicating that belong to the health mil spec more dangerous. " Society of Eco circle is made the following comments on the Draft: I am pleased to note that the draft provided incentives for coupling individual stores to the district heating and gas, subsidies for clean energy and to replace old boilers with modern. From the wording of the draft is not clear whether the air quality plan produced with the aim of reducing impacts on health or the paperwork themselves. From the wording of the draft is not read or wishes rather than requirements mil spec for quality rehabilitation Zasavje air, which would primarily reduce the concentrations of the most dangerous particles. Instead, the draft based solely on Percentage reduction in concentrations. Such ignorance shows protežiranje conscious industry, failure to comply with legislated principles of prevention and precaution and the risk to the health of the population. The draft is to control the oven carefully tackles individuals (provides for stricter State control), while virtually no industry contacts, nor provides some tighter controls on their emissions. Heightened pressures mil spec on individuals and disposal of emergency measures in the industry to an indefinite future, impair the health mil spec Zasavčanov as well as the reputation of the country. Eco circle requires that the Ordinance Plan for ambient air quality in the area Zasavja include the following topics: existing industrial polluters Ministry responsible for environmental change environmental permits to ask them more efficient waste flue gas and to prescribe more stringent emission limit values for substances into the air. In the fourth 2.Paragraph of the Decree, the following new paragraph: "- legal entity adjust their processes so that their emissions of particulate mil spec matter mil spec in the air do not exceed 10 mg/m3." Country tighten environmental controls over economic operators who have their establishments in the municipalities Hrastnik Trbovlje and Zagorje ob Savi. As long as the implementation of the measures referred to in this Order shall be permitted in the area Zasavja exclusively to the introduction of new industrial plants (or changes to existing technologies) technologies with minimal emissions into the atmosphere. Acceptable emission parameters determined by the Ministry of the Environment, which is also supposed to verify compliance of emission measurements and acceptable environmental parameters. The state, through additional monitoring instruments mil spec ensures the credibility measurement of industrial emissions into air, both during normal operation as well as shutdowns and start-up of production outages or in filters. All data on emission measurements are also in its basic form accessible to the interested public and the operator is obliged to provide the public with the 30 days after receipt of the written request. The state has to establish the actual impact (contribution and PM10) industry on air pollution in Zasavje. We are convinced that the measurements which are currently implemented, do not give reliable results. In addition, Eco-cycle requires precise drafts of the next chapter: mil spec 5.3 Actions in other areas for action in the small combustion plants is thoroughly defined control of small ovens and citizens (see section 5.1.2.6 Implementation of more stringent control over the burning of waste in small combustion plants) . In chapter 5.3. , a reference to who and how to oversee large furnaces and industry? 5.3.1.2 mil spec Reducing fugitive Performers mil spec economic mil spec activities, mil spec prepare the program for the reduction of fugitive emissions sources which identify them and take action to reduce them. "- Missing required to prepare when you want it, where to award it, who is checked and verified, how many will even bind, who supervises the implementation and what are the penalties for those who program will not produce? 5.3.1.3 Promotion of BAT technologies "Artists economic mil spec activities within the BAT promote technologies that have the least load the air with PM10. "- This
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