Abstract
Air quality offsets in South Africa are intended to counterbalance the harm caused by atmospheric emissions and deliver a net ambient air quality benefit in the affected airshed. In practice, they are implemented as a condition of leniency from compliance with the Minimum Emission Standards, and they focus on converting solid fuel burning households in low-income communities to cleaner forms of energy. Air quality offsets are not supported by all stakeholders, with non-governmental organisations in particular voicing vociferous objections. To date, there have only been very limited analyses of the ethical dimensions of air quality offsets. In this paper, air quality offsets and the Minimum Emission Standards are examined and compared from the perspective of three notions of environmental justice: distributive justice, which focuses on the distribution of environmental burdens and benefits; procedural justice, which considers inclusion and exclusion in decision- and policy-making processes; and justice as recognition, which focuses on the cultural and institutional processes that determine recognition, misrecognition and non-recognition of various groups. It is found that air quality offsets should guide action which promotes distributive justice because they are focussed on reducing polluting emissions in vulnerable, low-income communities that are exposed to the highest levels of ambient pollution. From a procedural justice perspective, South Africa’s legislative processes provide for involving most stakeholders in decision-making processes. Air quality offset initiatives should be evaluated once they have been implemented at scale to determine whether they have indeed aided in redressing injustices. Assessment criteria could include whether the air quality-related health risk of vulnerable communities has been reduced, whether community members have participated in the design and implementation of interventions, and whether marginalised members of the community have benefitted from the interventions.
Highlights
Air quality offsets are one of several measures introduced by the South African government to improve ambient air quality
To provide the necessary background for the evaluation of air quality offsets from an environmental justice framework, legislation pertaining to air quality offsets in South Africa is reviewed, and offset implementation programmes are discussed based on Eskom and Sasol’s plans, since between them they account for the majority of offsets initiatives
In the case of the South African Highveld, almost everyone is responsible for the poor air quality in some way, but the greatest responsibility rests with large industries, power stations and related activities such as mining (DEA, 2011), high income individuals who own their own vehicles and consume a lot of electricity and other commodities, and solid/liquid fuel-burning households (who in some cases contribute the greatest amount of pollution to ambient levels in areas that experience the worst air quality in the country (e.g. Chidhindi et al, 2019))
Summary
Air quality offsets are one of several measures introduced by the South African government to improve ambient air quality They are implemented by polluting facilities as a condition of a postponement of compliance with the Minimum Emission Standards. Environmental justice here is taken to mean the ways in which the environment and social difference are intertwined, and the justice of this interrelationship (after Walker, 2012) An analysis of this nature is perhaps premature, given that air quality offsets have not been implemented at scale yet, and so the promotion (or not) of justice through the offsets programme cannot be evaluated. Thereafter, suggestions are made for evaluating the offset implementations from an environmental justice perspective
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