Pulse Point Newsletter for March 15, 2000
Published by Alliance Consulting International
Partners in Environmental and Occupational Health and Safety
By Enrique Medina, MS, CIH

In our previous issue we reported on last month’s unveiling of an air quality plan for the Mexicali, Baja California municipality (bordering California’s Imperial Valley), by Mexico’s Secretariat of Environment, Natural Resources and Fisheries (SEMARNAP). The Mexicali plan was preceded by a similar plan for the Paso del Norte region, which encompasses Ciudad Juarez, Chihuahua across the border from El Paso, Texas, and will be followed by the Tijuana, B.C. plan (neighboring San Diego, California) to be issued later this year.

The border air quality plans are the most comprehensive attempts to date addressing the growing air pollution problems faced by U.S. and Mexican border cities. The Spanish-language documents are very readable and contain statistical, historical and policy information to support their conclusions and recommendations.

As the documents are very extensive, this article will focus on industrial source issues in the Mexicali and Ciudad Juarez plans, which are heavily represented by the foreign-owned maquiladora industry.

The plans’ breakdown of pollution sources by sector contains several interesting revelations. According to the emission inventories compiled by the National Institute of Ecology (INE, the permitting arm of SEMARNAP), Ciudad Juarez’s industrial sources accounts for approximately 1% of total air pollution, which includes particulates (PM-10), carbon monoxide (CO), sulfur dioxide (SO2), nitrogen oxides (NOx), and hydrocarbons (HC). Industry also accounts for 17% of total SO2 emissions. Area sources, mainly unpaved streets and soil erosion account for approximately 8% of total pollution, but almost 97% of particulates. The largest source of emissions is transportation with 88% of total pollutants, including 99% of CO, as well as 91 % of NOx and 71% of HC, both of which are ozone precursors.

Looking at the industrial pollution sources more closely, Ciudad Juarez’s emissions inventory data show that of 436 fixed sources, 329 belong to the maquiladora sector. However, only 10% of the plants account for approximately 80% of the total industrial pollution output.

Mexicali’s 1996 emissions inventory breakdown reflects a different source composition. Industry accounts for 18% of total air pollutants, including 75% of SO2 emissions, while area sources produced 23% of total contaminants and 98% of particulates. The transportation sector is responsible for over half of all emissions, including 91% of carbon monoxide, 80% of NOx and 60% of hydrocarbons. With only 112 of 1100 fixed sources reporting, 16 facilities (14%) account for over 90% of all air emissions.

Both plans rely on voluntary measures to cut emissions of volatile organic compounds (VOCs) in the maquiladora sector by 85% to approximately 1,500 tons per year in Juarez, and 1,200 tons/yr. in Mexicali through a combination of existing and proposed programs.

One existing measure is the Clean Industry Certificate, which the Attorney General for Environmental Protection (PROFEPA- the enforcement arm of SEMARNAP), issues to companies that complete their action plans resulting from voluntary audits, as incentives to increase participation in PROFEPA’s audit program. The fact that only 12 Clean Industry Certificates have been issued in Juarez, suggests that the program has seen limited success to date.

Other voluntary measures designed to promote cooperation in the industrial sector include SIRG (Integrated Direct Regulation and Environmental Management System), a regulatory permit streamlining program, which enables companies to use a “one-stop” process to take care of most environmental permits and reporting requirements.

A less well-known part of this program, the Voluntary Environmental Management Program (PVG) enables companies to establish internal, self-regulated environmental management systems and audit programs in collaboration with PROFEPA, which then accepts the compliance reports in good faith, although subject to verification.

A new element mentioned in the plans refers to implementation of Mexico’s RETC (Pollutant Release and Transfers Registry), equivalent to EPA’s Toxics Release Inventory (TRI). RETC uses facility data reported as part of SIRG to compile the National Environmental Information System, which provides the public with information on industrial pollution generation. While the information will only be available grouped by municipality and not on a facility-specific basis, it has nonetheless caused concern among the regulated community in Mexico.

Although the public’s right to environmental information was established in the 1996 reforms to the federal environmental law, the actual mechanism for releasing information has not been completely implemented to date. For this reason it is noteworthy that the Paso del Norte Plan states that SEMARNAP will release summary findings and action plans of PROFEPA facility audits to the public.

It seems that the regulatory agency is using the “carrot” of self-regulation, streamlined permitting and Clean Industry certificates, with the “stick” of public disclosure of emissions and audit information, to encourage industry’s participation in the voluntary emissions reduction program. While it is too early to tell how effective these measures will be, SEMARNAP may be hoping to duplicate the significant drops in emissions, discharges and waste generation that occurred in the US after implementation of the TRI.

One key challenge will be whether the existing local, national and international public and private institutions working on border issues have the necessary technical and financial resources and coordination to effectively carry out the goals and objectives presented in the plans. Already there are signs of differences over priorities, such as Mexicali’s reluctance to accept responsibility for operating the air quality monitoring network established by the federal agency with EPA’s assistance, without adequate assurances of continued budgetary and technical support for such a move.

The success of these plans may well depend on how they are received by local government, the public, and the regulated community in each region. One key factor is the reliability of the assumptions on which the programs’ goals are based. This issue can only be resolved as the quality of information improves with the implementation of some of the proposed measures.

If you have questions about how specific elements of the air quality plans may impact your current or future operations, please contact us at (619) 297-1469 or send us an email at emedina@pulse-point.com.

Alliance Consulting International
Partners in Environmental and Occupational Health and Safety
3361 28th St.
San Diego, California 92104
(fax (619)297-1023

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