Emission Standard Regulation

Mitsuru Motokura
Jongkyun Lee
Ichiro Kutani
Han Phoumin
© Economic Research Institute for ASEAN and East Asia, 2016
ERIA Research Project FY2016 No.02
Published in August 2017
All rights reserved. No part of this publication may be reproduced, stored in a retrieval system,
or transmitted in any form by any means electronic or mechanical without prior written
notice to and permission from ERIA.
The findings, interpretations, conclusions, and views expressed in their respective chapters
are entirely those of the author/s and do not reflect the views and policies of the Economic
Research Institute for ASEAN and East Asia, its Governing Board, Academic Advisory Council,
or the institutions and governments they represent. Any error in content or citation in the
respective chapters is the sole responsibility of the author/s.
This report was prepared by the Working Group for the ‘Improving Emission Regulations for
Coal-fired Power Plants in ASEAN’ study under the Economic Research Institute for ASEAN
and East Asia (ERIA) energy project. Members of the Working Group, who represent the
participating East Asia Summit (EAS) region countries, have discussed emission regulations
for coal-fired power plants and the current management system situation. The study is aimed
at deriving policy implications, not developed for commercial or business use. The Working
Group is not responsible for any loss caused by using the scenarios in the study outcomes.
Material in this publication may be freely quoted or reprinted with proper acknowledgement.
Foreword
Reserved underground in many Association of Southeast Asian Nations (ASEAN) member countries,
coal allows power generation at a lower cost than other fuels. In the ASEAN member countries,
power consumption has increased along with their economic growth, and further increases in coal-
fired power generation are expected. Coal is one of the cheapest power generation fuels in terms
of cost, but its demerit is that it emits more air pollutants harmful to human health than other fuels.
For this reason, the countries using coal-fired power generation have enacted standards to regulate
air pollutants from coal-fired power plants. The bottom line is whether a management system has
been established and whether it is functioning for effectively monitoring emission standards. This
study examined and compared the emission standards for air pollutants from coal-fired power
plants and their management systems in some Organisation for Economic Co-operation and
Development (OECD) member countries and the ASEAN member countries. This analysis will
provide further policy development options for reducing air pollutants from coal-fired power plants.
It is our hope that the outcomes of this study will serve as a point of reference for policymakers in
ASEAN countries and contribute to the improvement of air pollution in the region as a whole.
Ichiro Kutani
Leader of the Working Group
June 2017
iii
Acknowledgements
This analysis has been implemented by a working group under the Economic Research Institute for
ASEAN and East Asia (ERIA). It is a joint effort of Working Group members from the East Asia Summit
(EAS) countries and The Institute of Energy Economics, Japan (IEEJ). We would like to acknowledge
the support provided by everyone involved. We would especially like to express our gratitude to the
members of the Working Group, ERIA, and IEEJ’s study project team.
Ichiro Kutani
Leader of the Working Group
June 2017
iv
Contents
List of Project Members vi

List of Figures and Tables viii
List of Abbreviations and Acronyms ix
Executive summary x
Chapter 1. Introduction 1
Chapter 2. Summary of Management System in ASEAN, China and India 9
Chapter 3. Summary of Management System in Selected OECD Countries 25
Chapter 4. Comparison of Management System between Selected ASEAN and 35

OECD Countries: Similarity and Difference
Chapter 5. Policy Recommendation 41
Annex 1 Environmental Legislation in Selected Countries 45

Annex 2 Survey Sheet (Selected OECD Countries) 48
Annex 3 Survey Sheet (Selected ASEAN Countries) 76
Annex 4 SOx Regulation 98
Annex 5 NOx Regulation 108
Annex 6 PM Regulation 118
v
List of Project Members
MR ICHIRO KUTANI (WG LEADER): Assistant to Managing Director, Senior Economist, Manager of Global
Energy Group 1, Strategy Research Unit, The Institute of Energy Economics, Japan (IEEJ).
MR SHIGERU KIMURA (ORGANIZER): Special Advisor to President for Energy Affairs, Energy Unit,
Research Department, Economic Research Institute for ASEAN and East Asia (ERIA).
DR HAN PHOUMIN (ORGANIZER): Energy Economist, Energy Unit, Research Department, Economic
Research Institute for ASEAN and East Asia (ERIA).
DR YANFEI LI (ORGANIZER): Energy Economist, Energy Unit, Research Department, Economic Research
Institute for ASEAN and East Asia (ERIA).
MR KIN SOTHEA: Chief of Energy Planning, Energy Development Department, Ministry of Mines and
Energy (MME), Cambodia.
MS SWATI MITCHELLE D’SOUZA: Associate Fellow, Electricity and Fuels Division, The Energy and
Resources Institute (TERI), India.
MR ARIO PANGGI PRAMONO JATI: Electrical Inspector, Directorate General of Electricity, Ministry of
Energy and Mineral Resources (MEMR), Indonesia.
MR MITSURU MOTOKURA: Senior Coordinator, Global Energy Group 1, Strategy Research Unit, The
Institute of Energy Economics, Japan (IEEJ).
MR JONGKYUN LEE: Senior Researcher, Global Energy Group 1, Strategy Research Unit, The Institute
of Energy Economics, Japan (IEEJ).
MS KEI SHIMOGORI: Researcher, Nuclear Energy Group, Strategy Research Unit, The Institute of
Energy Economics, Japan (IEEJ).
MR KHAMSO KOUPHOKHAM: Deputy Director General, Department of Energy Policy and Planning,
Ministry of Energy and Mines (MEM), Lao PDR.
MR MOHD RIZAL B. RAMLI: Head, Capacity Development, Department of Industrial Development and
the Electricity Market Regulation, Energy Commission of Malaysia (ST), Malaysia.
vi
MR HLA MIN OO: Executive Engineer, Electric Power Generation Enterprise, Ministry of Electricity
and Energy (MOE), Myanmar.
MR VORAWUT POONTHARIGPUN: Environmental Scientist, Project Environment Division, Electricity

Generating Authority of Thailand (EGAT), Thailand.
vii
List of Figures and Tables
Figure 1 Share of coal-fired power generation in selected ASEAN 3

countries
Figure 2 Coal-fired power generation in ASEAN 4
Figure 3 Comparison of emission standards in selected countries 39
(SOx)
(NOx)
(PM)
List of Tables
Table 1 Emission standards for CPPs in selected ASEAN countries, China, and 24
India
Table 2 Emission standards for CPPs in selected OECD countries 34
viii
List of Abbreviations and Acronyms
AEC ASEAN Economic Community

AQI Air Quality Index (Australia)
ASEAN Association of Southeast Asian Nations
APAEC ASEAN Plan of Action for Energy Cooperation
ASCC ASEAN Socio-Cultural Community
CAA Clean Air Act
CEMS Continuous Emission Monitoring System
CO2 Carbon Dioxide
CPP Coal-fired Power Plant
DEIA Detailed Environmental Impact Assessment (Malaysia)
DOE Department of Environment (Malaysia)
EAS East Asia Summit
EHIA Environmental and Health Impact Assessment (Thailand)
EIA Environmental Impact Assessment
EMMS Environmental Management and Monitoring Scheme (Indonesia)
EMP Environmental Management Plan (Myanmar)
EPA Environment Protection Authority (Australia)
EPA Environmental Protection Agency (United States)
ERIA Economic Research Institute for ASEAN and East Asia
IEA International Energy Agency
IED Industrial Emission Directive
IEEJ The Institute for Energy Economics, Japan
MoE Ministry of Environment (Cambodia)
MONRE Ministry of Natural Resource and Environment (Lao PDR)
NA not available
NOx nitrogen oxides
NSR New Source Review
NSW New South Wales (Australian state)
OECD Organisation for Economic Co-operation and Development
OEH Office of Environment and Heritage (Australia)
PM particulate matter
ppm parts per million
PSD Prevention Significant Deterioration
SOx sulphur oxides
WG Working Group
ix
Executive Summary
Coal is an optimum power generation fuel for ASEAN countries in terms of both cost and
energy security. However, coal combustion emits air pollutants that are harmful to both
human health and the environment. As a consequence, residents have started campaigns
against coal-fired power plants (CPPs), which have forced some new CPP projects to be
suspended or cancelled. For ASEAN countries, minimizing the emission of air pollutants is a
precondition for the future use of CPPs. But the problem is regulating the emission of air
pollutants from CPPs. In order to reduce the emission of air pollutants, creating regulations
and properly managing and operating CPPs are required. Based on this awareness,
regulations on the emission of air pollutants (including emission standards and
implementation of the regulations) are surveyed in this study.
This survey revealed that ASEAN countries have enacted environmental laws to identify air
pollutants to be regulated and to set emission standards. Compared to the Organisation of
Economic Co-operation and Development (OECD) countries, however, the emission standards
are low in many ASEAN countries. Thus, it is important to raise the current emission standards
of air pollutants from CPPs to the equivalent levels in OECD countries. This is because more
stringent levels are essential for delivering a proper response to campaigns against CPPs and
can reduce the emission of hazardous air pollutants and reduce the health hazards to
residents. On the other hand, raising the level of emission standards leads to either an
increase in environmental expenses or an increase in electricity tariffs. In consideration of
national and government financial capabilities, a gradual tightening of emission standards
may be required.
Installing expensive environmental facilities in CPPs imposes a heavy burden, especially on
low-income countries. The most desirable method of sharing the cost burden is to increase
electricity prices. Passing on increased costs would place a temporary subsidy burden on the
government. This is not sustainable in the long term; therefore, it is recommended to stop
providing subsidies to electricity consumers as early as possible.
Ways of financing capital expenditure include borrowing from financial institutions and using
private funds. For borrowing, there are two options: one is from domestic financial
institutions, the other is from international financial institutions. Domestic financial
institutions are free from exchange risks; however, they may not have the practical knowledge
of large-scale financing for energy. For international financial institutions, long-term
borrowings can be made at low-interest rates; however, there are exchange rate risks and
loan procedures take time due to strict loan terms. Generally, the installation of
environmental facilities can be a good funding destination; however, some financial
institutions put restrictions on loans for new CPP construction. Private funding can include
funding from independent power producers and private finance initiatives. Using private
funds has the advantage of being able to construct new CPPs without increasing public debt,
resulting in the promotion of technology transfer through the operation of companies from
developed countries.
x
With emission standards of air pollutants from CPPs raised to the equivalent level in OECD
countries, ASEAN countries are required to install environmental facilities in CPPs and to
perform the following steps:
1. maintain and/or manage installed facilities for appropriate operation;
2. constantly monitor and/or record the air pollutants concentration level to keep
it below the standard; and
3. disclose the measurement results to local governments and residents to inform
them of the proper operation of the CPP.
With regard to the first step, continued proper operation of environmental facilities serves as
the base to gain support from residents. Regarding the second and third steps, the CPPs need
to show evidence of complying with the laws and regulations to gain the trust of residents.
Without information disclosure, residents living near a CPP could still raise concerns about
the plant even if it is run properly. CPPs are requested to make themselves more open by
continually providing transparent data to protect themselves.
Under these circumstances, a highly transparent system is required to monitor the air
pollutant concentration levels both for CPPs and local regions. This can be a challenge for
countries that have never created such a system. It is recommended to create a system that
will monitor the air pollution situation and to establish an international cooperative
framework for the proper operation and information disclosure, and to provide training to
central and local governments and CPP operators. Cooperation will bring mutual benefits to
both ASEAN countries and cooperating countries, which encourages them to build win–win
relationships.
Table A shows the emission standards of sulphur oxides (SOx), nitrogen oxides (NOx), and
particulate matter (PM) for new CPPs in selected countries. In case they differ depending on
the plant scale, the large-scale case was adopted. In case they differ depending on the period,
the daily basis (or 24 hours) was adopted. SOx and NOx have different units from one country
to another. In the countries where parts per million (ppm) measurement is used, accordingly,
it is converted into milligrams per cubic metre (mg/m3), regarding them as SO2 and NO2,
respectively.
xi
Table A: Emission standards for new CPPs in selected countries
Country SOx NOx PM

3 3
Australia SO3: 200 mg/m NO2: 800 mg/m 80 mg/m3
Germany SOx: 150 mg/m3 NOx: 150 mg/m3 10 mg/m3
SOx: 50 ppm* NOx: 200 ppm
Japan 100 mg/m3
(SO2: 133 mg/m3) (NO2: 383 mg/m3)
SOx: 50 ppm NOx: 50 ppm
Republic of Korea 10 mg/m3
(SO2: 133 mg/m3) (NO2: 96 mg/m3)
United States** SO2: 130 ng/J NOx: 88 ng/J 11 ng/J
Cambodia SO2: 500 mg/m3 NO2: 1000 mg/m3 400 mg/m3
China SO2: 200 mg/m3 NO2: 200 mg/m3 30 mg/m3
India SO2: 80 mg/m3 NO2: 80 mg/m3 100 mg/m3
Indonesia SO2: 750 mg/m3 NO2: 750 mg/m3 100 mg/m3
SO2: 320 ppm NOx: 350 ppm
Lao PDR 120 mg/m3
(SO2: 853 mg/m3) (NO2: 670 mg/m3)
Malaysia SOx: 500 mg/m3 NOx: 500 mg/m3 50 mg/m3
Myanmar SOx: 200 mg/m3 NOx: 400 mg/m3 50 mg/m3
Philippines SO2: 700 mg/m3 NO2: 1000 mg/m3 150 mg/m3
Singapore SO2: 500 mg/m3 NO2: 700 mg/m3 100 mg/m3
Thailand 80 mg/m3
(SO2: 480 mg/m3) (NO2: 383 mg/m3)
Viet Nam SO2: 500 mg/m3 NO2: 650 mg/m3 *** 200 mg/m3
CPP = coal-fired power plant, mg/m3 = milligram per cubic metre, PM = particulate matter, ppm = parts
per million, NO2 = nitrogen dioxide, NOx = nitrogen oxides, SO2 = sulphur dioxide, SOx = sulphur oxides.
Notes: * Based on the CPP’s location, sulphur content of fuel, stack height, etc. the emission standard
varies by CPP. The value is an example of specific CPP based on agreement between CPP and local
government.
**
gross output.
***
coal volatile content >10%.
Source: Authors.
Figures A, B, and C show the comparison of the emission standards of SOx, NOx, and PM for
new CPPs in selected countries.
xii
Figure A: Emission standards for new PPs in selected countries (SOx)
900
(mg/m3)
800
700
600
500
400
300
200
100
0
Korea
Myanmar
Cambodia
Malaysia
Australia
Germany
Singapore
Philippines
Thailand
Viet Nam
Japan
China
India
Indonesia
Lao PDR
CPP = coal-fired power plant, mg/m3 = milligram per cubic metre, SOx – sulphur oxides.
Source: Authors.
Figure B: Emission standards for new CPPs in selected countries (NOx)
1200
(mg/m3)
1000
800
600
400
200
0
Korea
Malaysia
Cambodia
Australia
Germany
Singapore
Japan
Philippines
Thailand
Viet Nam
China
India
Indonesia
Myanmar
Lao PDR
CPP = coal-fired power plant, mg/m3 = milligram per cubic metre, NOx―nitrous oxides.
Source: Authors.
xiii
Figure C: Emission standards for new CPPs in selected countries (PM)
450
(mg/m3)
400
350
300
250
200
150
100
50
0
Japan
China
Malaysia
Australia
Korea
Cambodia
India
Germany
Singapore
Philippines
Thailand
Myanmar
Viet Nam
Indonesia
Lao PDR
CPP = coal-fired power plant, mg/m3 = milligram per cubic metre, PM = particulate
matter.
Source: Authors.
xiv
Chapter 1
Introduction
1. Background and objectives of the study
Reserved underground in many ASEAN member countries, including Indonesia, coal allows power
generation at a lower cost than other fuels. In the Association of Southeast Asian Nations (ASEAN)
member countries, power consumption has increased along with their economic growth, and
further increases in coal-fired power generation are expected. Coal is one of the cheapest power
generation fuels in terms of cost, but its demerit is that it emits more air pollutants harmful to
human health than other fuels. For this reason, the countries using coal-fired power generation
have enacted standards to regulate air pollutants from coal-fired power plants. The bottom line is
whether a management system has been established and whether it is functioning properly for
monitoring the emission standards.
This study analyses essential elements to increase the effectiveness of emission control regulations
for coal-fired power plants in developing countries in ASEAN. In the power sector, air pollution
concerns can become a barrier for developing necessary power stations. As such, the appropriate
implementation of air pollution control regulations is crucial for the sustainable development of the
economy, and hence the study will highlight it.
The study also made a comparative analysis with selected Organisation of Economic Co-operation
and Development (OECD) countries. The analysis is expected to derive policy recommendations for
ASEAN countries to improve their implementation mechanisms.
The study is consistent with the strategic themes in the ‘ASEAN Economic Community (AEC) Blue
Print 2025’ and its subordinate paper, ‘ASEAN Plan of Action for Energy Cooperation (APAEC) 2016–
2025 Phase 1’, and contributes to the ‘Coal and Clean Coal Technology,’ study as it dealt with
emissions from power plants. In addition, the study is consistent with the goal to create a
sustainable society in the ‘ASEAN Socio-Cultural Community (ASCC) Blueprint 2025’, corresponding
to the principles of C.1. Conservation and Sustainable Management of Biodiversity and Natural
Resources, C.2. Environmental Sustainable Cities, C.3. Sustainable Climate, and C.4. Sustainable
Consumption and Production.
1
2. Study method
(A) Survey of the Status of Emission Regulations
The study surveyed the status of regulation and execution systems relevant to air pollution (SOx,
NOx, and PM) from coal-fired power plants (CPP). The survey included:
 Existence or non-existence of regulations (central and/or municipal government)
The following items will be only applied to central government regulations
 Emission standards
 Process of regulation development
 Management system of power company (measurement, record, verification, report)
 Management system of regulator (organization, human resources, checking)
 How to enforce (authorization, order, penalty)
 Support for power company (technical guidelines, finance, education)
(B) Comparative Analysis with Developed Country
The study conducted a comparative analysis of regulations and systems in developed countries such
as Australia, Europe, Japan, and the United States. The subjected country and/or region will be
selected through a preliminary survey. The study will identify the advantages and disadvantages of
existing regulations and systems in ASEAN countries.
Based on each country’s situation and/or standards, the study team will propose ‘common
environmental standards for the coal-fired power generation in the region’.
(C) Derive Policy Recommendations
The study derived policy recommendations for improving the capability of a country to implement
and execute air pollution control regulations for CPP.
2
(D) Set Up Expert Working Group
The study was set up an expert working group to discuss the issue and to share the results, hence
expects to contribute to improve the effectiveness of policy implementation and execution in the
region.
3. Focus area of fiscal year (FY) 2016 study: survey
(A) Why focus on air pollution from CPP?
Figure 1 shows the share of coal-fired power generation in total power generation in selected
ASEAN countries. Except for Myanmar, the share of coal-fired power generation increased from
1995 to 2005 and 2014.
Figure 1: Share of coal-fired power generation in selected ASEAN countries
2014
THA VNM ASEAN
2005
1995
2014
2005
1995
2014
2005
1995
2014
MYS MMR PHL
2005
1995
2014
2005
1995
2014
2005
1995
2014
IDN
2005
1995
(%) 0 10 20 30 40 50 60
ASEAN = Association of Southeast Asian Nations, IDN = Indonesia, MMR = Myanmar, MYS = Malaysia, PHL =
Philippines, THA = Thailand, VNM = Viet Nam.
Source: International Energy Agency (2016), World Energy Balances.
3
As a result of the increased share of coal-fired power generation, output increased greatly as shown
in Figure 2. In the entire ASEAN, from 1995 to 2014 the annual average increase rate of total power
generation output was 14%, but that of coal-fired power generation was 29%.
In ASEAN, coal is an important fuel for power generation and its consumption is expected to
increase along with higher electricity demand. From a viewpoint of energy security, the use of coal
enhances energy self-efficiency in ASEAN because there are coal export countries such as Indonesia.
Figure 2: Coal-fired power generation in ASEAN
300
(TWh)
250
Viet Nam
Thailand
200
Singapore
150 Philippines
Myanmar
100
Malaysia
50 Indonesia
Cambodia
0
1995
1996
1997
1999
2000
2001
2002
2004
2005
2006
2007
2008
2009
2010
2012
2013
2014
1998
2003
2011
Notes: Lao PDR is excluded due to no data availability. Brunei Darussalam has no coal-fired power
generation.
TWh = terawatt hours.
Source: International Energy Agency (2016). World Energy Balances.
4
(B) Necessity to regulate harmful air pollutants
The major harmful air pollutants from coal-fired power plants are sulphur oxides (SOx), nitrogen
oxides (NOx), and particulate matter (PM). SOx, NOx, and PM are harmful as follows.1
a) Sulphur dioxide (SOx)
Short-term exposure to sulphur dioxide (SO2) can harm the human respiratory system and make
breathing difficult. Children, the elderly, and those who suffer from asthma are particularly sensitive
to the effects of SO2.
Emissions that lead to high concentrations of SO2 in the air also lead to the formation of other
sulphur oxides. SOx can react with other compounds in the atmosphere to form small particles.
These particles contribute to PM pollution: particles can penetrate deeply into sensitive parts of
the lungs and cause additional health problems.
At high concentrations, gaseous SOx can harm trees and plants by damaging foliage and decreasing
growth.
SO2 and other sulphur oxides can contribute to acid rain that can harm sensitive ecosystems.
SO2 and other sulphur oxides can react with other compounds in the atmosphere to form fine
particles that reduce visibility (haze).
The deposition of particles can also stain and damage stone and other materials, including culturally
important objects such as statues and monuments.
b) Nitrogen dioxide (NOx)
Breathing air with a high concentration of nitrogen dioxide (NO2) can irritate airways in the human
respiratory system. Such exposure over short periods can aggravate respiratory diseases,
particularly asthma, leading to respiratory symptoms (such as coughing, wheezing, or difficulty
breathing), hospital admissions, and visits to emergency rooms. Longer exposure to elevated
concentrations of NO2 may contribute to the development of asthma and potentially increase
susceptibility to respiratory infections. People with asthma, as well as children and the elderly are
generally at greater health risks from the effects of NO2.
NO2 along with other NOx react with other chemicals in the air to form both particulate matter and
ozone. These are also harmful when inhaled due to the effects on the respiratory system.
1
Source: US Environmental Protection Agency (EPA).
5
NO2 and other NOx interact with water, oxygen, and other chemicals in the atmosphere to form
acid rain. Acid rain harms sensitive ecosystems such as lakes and forests.
The nitrate particles that result from NOx make the air hazy and reduce visibility. This affects the
many national parks that are visited for the view. NOx also contributes to the formation of smog
and acid rain which are harmful for health.
NOx in the atmosphere contributes to nutrient pollution in coastal waters.
c) Particulate matter (PM)
Particulate matter includes:
– PM10: inhalable particles, with diameters that are 10 micrometres and smaller; and
– PM2.5: fine inhalable particles, with diameters that are 2.5 micrometres and smaller.
Particulate matter contains microscopic solids or liquid droplets that are so small that they can be
inhaled and cause serious health problems. Particles less than 10 micrometres in diameter pose the
greatest problems, because they can get deep into people’s lungs, and some may even get into the
bloodstream.
Fine particles (PM2.5) are the main cause of reduced visibility (haze).
4. Working Group activities in fiscal year 2016
To conduct the study, a Working Group (WG) was organized. The WG members consist of experts
from the region and a research team as a secretariat from The Institute for Energy Economics, Japan
(IEEJ).
In fiscal year (FY)2016, a WG meeting was held in February 2017 in Bangkok, Thailand.
First, the meeting explained this study. and proposed two study items. One is financing because
existing and new coal-fired power plants require huge investment for environmental measures. The
other is technical aspects because highly-efficient facilities are required for the environmental
measures. Since analysis results become complicated if multiple elements are contained, it was
acknowledged that FY2016 should focus only on the management system, with the other elements
as topics for the next fiscal year onwards. There were also concerns that the tightening of emission
6
standards might add to the cost of coal-fired power plants, which would cause the loss of cost
competitiveness in comparison with other fuels. It was also proposed that the minimum emission
standards should be compiled by ASEAN and India.
The management system in the selected OECD countries was then explained. The major opinions
are as follows. The technology selection assistance provided by the United States Environmental
Protection Agency is a good reference. Japan’s method of phased tightening of control in
accordance with the operators’ capability to cope and technological advancement is valuable
information for the ASEAN countries. Also, there were questions on the environmental control cost
recovery methods, specific procedures for suspension of operation, and the situation of monitoring
posts as with the Japanese cases.
Finally, there were presentations from the member countries, followed by discussions. Major
discussion points included the levels of emission standards, emission monitoring systems, relations
between the central government and local governments, and the price level of coal and natural gas
for power generation to provide competition, among others.
7
8
Chapter 2
Summary of Management Systems in ASEAN, China, and India
1. Survey of management systems in ASEAN countries
The management systems of coal-fired power emission gases were surveyed in the ASEAN member
countries, based on the following items. The survey was conducted by the WG members in each
country. In Thailand, a hearing was also held at the Ministry of Environment.
 Legislation
 National (Federal, Central)
 Local (State, Municipality, District, City)
 Regulated pollutants (relating to coal-fired power plants)
 Emission standards
 How authorities recognize the existence of facilities that emit air pollutants
 Authority to suspend operation
 Measurement of emissions by operator
 Monitoring
 Reporting
 Inspection
 Archive requirements
 Public announcements
 Compensation for damage and losses
 Penalty
 Assistance (National, Local)
 Ability of local governments
 Relation to local community
 Independent inspector
9
2. Summary of selected ASEAN countries, China, and India
Based on the survey in selected ASEAN countries, the results are summarized covering the legal
system and the management system. See Annexes 3, 4, and 5 for the emission standards in each
country.
The ASEAN countries have different experiences with coal-fired thermal power. For instance,
countries such as Cambodia and Lao PDR started using coal-fired thermal power less than 10 years
ago, while Thailand has used coal-fired power since the 1960s.
2.1. General
(A) Legislation (National)
Cambodia 1. Air Pollution Control Act (Ministry of Environment)
China Environmental Protection Law (1989)
(Emission standards)
GB13223-2011
India Prevention and Control of Pollution Act, 1981 (amended in 1987)
Environment (Protection) Act (No. 29 of 1986, 23 May 1986, last amended in

1991)
The implementation of power plant projects requires clearance from the

Ministry of Environment, Forest and Climate Change (http://envfor.nic.in/) via
an environmental impact assessment. These can be stricter than the national
emission standards. In addition, emission standards set by the State Pollution
Control Boards can be stricter than those set by the Central Pollution Control
Boards (CPCB).
Indonesia a. Law No. 32/2009 Regarding the Protection and Management of Environment
b. Law No. 30/2009 Regarding Electricity
c. Government Regulation No. 14/2012 Regarding Business of Electricity Supply
d. Government Regulation No. 27/2012 Regarding Environmental Licenses
e. Government Regulation No. 41/1999 Regarding Air Emission Control
f. Ministry of Environment Decree No. 21/2008 Regarding Static Emission
Sources Quality Standard for Business and/or Activities of a Thermal Power
Plant
10
Lao PDR Lao PDR National Environmental Standard
Malaysia 1. Environmental Quality Act 1974
2. Environmental Quality (Clean Air) Regulations 2014
Myanmar Environmental Conservation Law 2012
Environmental Conservation Rule 2014
National Environmental Quality (Emission) Guideline (2015)
Environmental Impact Assessment Procedure 2015
Philippines The Philippines Clean Air Act of 1999 (Republic Act No. 8749)
DENR Administrative Order No. 2000 - 81, 7 Nov 2000)
Singapore Environment Pollution Control Act (1 Apr 1999)
Environmental Protection and Management Act (1 Jan 2008)
Environmental Protection and Management (Air Impurities) Regulations (1

Jan 2001, as revised in 2002 and 2008)
Thailand Environmental Act
Factory Act
There is no conflict between the two Acts.
Viet Nam Emission standards are set by the Ministry of Natural Resources and
Environment.
Emission standards for thermal power plants were released on 16 November

2009 and replaced the 2005 standards.
11
(B) Legislation (Local)
Cambodia 1. Air Pollution Control Act allows CPPs to set their own emission standards but
follow the government standard to establish regulations relating to air
pollution emissions.
Indonesia According to the Ministry of Environment Decree No. 21 Year 2008, local
governments may set:
a. Emission quality standards for business and/or activities of a thermal

power plant with the provisions of the same standards or more stringent
than the standards that have been set nationally.
b. Additional parameters outside the emission quality standards for business

and/or activities of a thermal power plant after the approval of the
minister in the environmental field.
Lao PDR Local authorities are involved in providing their recommendation for state of
feasibility study, construction, and operation of coal-fired power plants.
Malaysia Not available
Myanmar Environmental Conversation Law 2012
Environmental Conversation Rule 2014
Thailand The law gives local governments power to establish their own emission
standards. But to date, no local government has set its own emission standards.
(C) Regulated pollutants
Cambodia Air Pollution Control Act: SOx, NOx, PM
Potentially affect the living environment: SO2, NO2, CO, particulates
China Particulates, SO2, NOx, mercury and mercury compounds, opacity
India SO2, NO2, PM10, PM2.5, CO
Indonesia SO2, NOx stated as NO2, total particulates (particulate matter), opacity.
Lao PDR SO2, NO2, PM10, and PM2.5
Malaysia SOx (SO2 and SO3), NOx (NO and NO2), hydrogen chloride, hydrogen fluoride,
carbon monoxide, total particulate matter, mercury, PCDD/PCDF
12
Philippines SOx, NOx, PM
Singapore SO2, NOx, PM
Myanmar SOx, NOx, PM, CO, CO2, TVOC (hydrocarbon), O3, lead
Thailand PM, SO2, NOx
Viet Nam SOx, NOx, PM
(D) The way to recognize the facilities of emitting pollutants
Cambodia Legislation
- Government standards and Ordinance of Ministry of Environment
Voluntary
- Agreement between local government with power plant operator
- Internal targets of power plants (operational standards)
Indonesia Government Regulation No. 14 Year 2012 Article 13 Paragraph (1): Business
licence
Government Regulation No. 27 Year 2012 Article 1 and 2: Environmental

licence
The authority recognizes the power plant facility that emits pollutants based
on the environmental documents (Environmental Impact Analysis or
Environmental Management and Monitoring Scheme) and the environmental
licence.
Lao PDR The central and local government authorities recognize the information during
their environmental impact assessment of coal-fired power plants and
mitigation plans and periodic reports of the plants.
Malaysia All coal fired power plants are required to install continuous emission
monitoring systems (CEMS) that are linked to the Department of Environment
(DOE) in real-time.
Myanmar The owner or occupier of any business, material, or place that causes a point
source of pollution shall install or use an on-site facility or controlling
equipment to monitor, control, manage, reduce, or eliminate environmental
pollution.
13
Thailand Power plants with capacity between 10MW and 100MW are required to have
an environmental impact assessment (EIA)
Power plants with capacity 100MW and more are required to have an
environmental and health impact assessment (EHIA)
Emission permit: not to exceed national standard.
(E) Authority to suspend operation
Cambodia Based on an agreement between local government and the power plant
operator, the CPP can only restart operations after the government considers
that improvements have been satisfactorily made.
Indonesia Authority to suspend operation due to violation of environmental regulation is

given to the licensor of the environment licence: minister in the environmental
field/governor/regent/mayor.
Lao PDR The central government (prime minister) and governors of the provinces have
full power to suspend the operation of the facilities if the pollutants emitted
are above the regulations allowed, based on a daily monitoring unit at the CPP.
Malaysia Department of Environment (DOE)
Myanmar The government department and government organization have the power
to cancel the issued licence, permit, or registration, or suspend it for a limited
period.
Thailand Ministry of Industry has the power to order partial or full suspension of CPP
operations.
(F) Measurement of emission by operator
Cambodia Air Pollution Control Act obligates operators to install public screen monitors
to show emission measurements automatically (SOx, NOx, PM) and to transmit
to the public through telemeters.
Indonesia Ministry of Environment Decree No. 21/2008, Article (9)
- For the CPP with capacity above 25 megawatts (MW) or below 25 MW but
using coal that has sulphur content above 2%, emissions are measured using
a continuous emission monitoring system (CEMS) that is installed in power
plant’s chimney.
14
-For power plants that do not have a CEMS installed, manual measurement
is required and it must be done by the accredited laboratory with minimum
measurement frequency of once every per 6 months.
Lao PDR CPP and provincial operator measure the quantity or concentration of air
pollutants, and keep records.
- Frequency of measuring: SOx: more than every 3 months (total emission

controlling area: continuously [24 hours, 7 days]); NOx: more than every 2
months; PM: more than every 2 months.
Malaysia Malaysian Standards MS1596 or MS 1723 or the Methods published by United

States Environmental Protection Agency or any other standards as determined
by DOE.
Myanmar National Environmental Quality (Emission) Guideline (2015)
Thailand Licensed third party selected by operators check emission data twice a year.
- Monitoring station: 5 kilometres away from CPP
- Monitored pollutants: PM and SO2
Operators should send emission monitoring data to Ministry of Industry with

automatic method.
(G) Assistance (National, Local)
Cambodia MME and MoE explanatory notes provide financial assistance, technical advice,
or other assistance.
Indonesia National and local government provide technical assistance to the CPP owner.
Lao PDR Air Pollution Control Act stipulates: The (national) government shall endeavour
to provide the financial assistance, technical advice, other assistance.
Malaysia Not available
Myanmar The (national) government shall endeavour to provide the technical advice,
other assistance.
Thailand When a regulation is to be enhanced, the central government holds a meeting

with stakeholders before amendment.
15
(H) Relation to local community
Cambodia Environmental Impact Assessment Act requires operator to hold a meeting and
publish hearings with residents for explanation and discussion before they get
a licence. Construction of a new CPP will continue only after residents agree.
Indonesia Based on Government Regulation No. 27/2012 Article 9, the CPP owner must
hold a meeting and public hearing with residents for explanation and
discussion before preparing the EIA document.
Lao PDR Base on concession agreement for CPP
Malaysia Approval of the Detailed Environmental Impact Assessment (DEIA) is a

mandatory requirement in new coal-fired power plant development.
The law does not require periodical meetings with local community. However,
community outreach programmes are usually performed by plant operators as
part of their corporate social responsibility.
Myanmar The law does not require periodical meetings with local community.
Ministry and operator to hold stakeholder meetings and public hearings with
residents for explanation and discussion on the site of the coal-fired power
plant.
Thailand Regular meetings between CPP and residents are held every 3 months.
(I) Ability of local government
Cambodia The implementation is varied based on ability of officers or experts in local

government to judge/interpret the measure or method of measurement.
Indonesia Not available
Lao PDR Ministry of Energy and Mines (MEM) and Ministry of Natural Resource and
Environment (MONRE) had establishment steering committees for CPP
Malaysia Any issue related to development in the specific local area including CPP can
be addressed by local government/council. However, all environmental
compliance monitoring and enforcement activities are conducted by the
Department of Environment (DOE) through headquarters and state and branch
offices.
Myanmar State and regional governments are participating in public consultation,
monitoring, inspection, and meetings with residents.
Thailand There is an expert in local university.
16
2.2. Management system flow
(A) Monitoring
Cambodia Prefectural governors shall continuously monitor the status of air pollution.
Indonesia Irregular monitoring by local government.
Lao PDR Provincial authorities shall continuously monitor the status of air pollution.
Local governments have observing stations.
Myanmar The ministry and state and regional governments shall continuously monitor
the status of air pollution. The owner or occupiers of any business have a
duty to monitor the environmental pollution.
Thailand CPP submit EIA report to Ministry of Environment, Ministry of Natural

Resources, and Ministry of Energy.
Report: CPP  Central Government  Local Government
Local government has a power to check emission data, but this rarely occurs.
(B) Reporting to authority
Cambodia According to an agreement with the government, power plant operator

submits data of air pollution emission every month generally, although CPPs
automatically send data through to telemeter.
Ministry of Environment conducts integrated survey of quantity of air pollution

emission every 3 years.
[Archive Requirement]
All CPP operators should keep important data permanently (6 monthly) after
measuring emissions.
Indonesia Government Regulation 21/2012, Article 9
The responsibility of the power plant is obliged to:
a. Report the results of monitoring and measurement of emissions every 3

months for power plants that are equipped with CEMS to the
regent/mayor with a copy to the governor and minister in the
environmental field.
17
b. Report the results of monitoring and measurement of emissions every 6
months for power plants that manually measure emissions to the regent
mayor with a copy to the governor and minister in the environmental field.
c. Report annual total pollutants (ton/year) emitted for NOx, SOx, and CO2 to
the regent/mayor with a copy to the governor and minister in the
environmental field.
Most CPP owners keep important data permanently.
Lao PDR Ministry of Natural Resource and Environment (MoNRE) or provincial

authorities (EMU) jointly with CPP operators report the status of air pollutant
emissions. MoNRE conducts integrated surveys of quantity of air pollutant
emissions every 6 months.
According to an agreement between CPP operator and local government, an

operator submits the report to local government every month, although CPP
automatically send data through telemeter continuously.
3 years.
Malaysia Continuous Emission Monitoring Systems (CEMS)
Environmental Quality (Clean Air) Regulations 2014:
- The records shall be kept for at least 3 years.
Myanmar The project proponent shall submit a monitoring report to the ministry not
less frequently than every 6 months, as provided in a schedule in the
Environmental Management Plan (EMP), or periodically as prescribed by the
ministry.
Ministry of Electricity and Energy shall require operator to report the status
of air pollutant emissions.
Coal-fired power plant operators keep the important data permanently in the
form of paper and electronic files.
Thailand Twice a year

The law does not require keeping archives.
18
(C) Inspection
Cambodia Ministry of Environment or government should conduct inspection on each

CPP through the telemeter basically.
[Independent inspector]
Air Pollution Control Act stipulates operators have a special environmental

technician for controlling emissions in the plants.
Indonesia Law 32/2009, Article 72
Ministry of Environment or governor/regent/mayor are obliged to conduct

supervision, and may conduct on-site inspections.
Law 30/2009, Article 46
Government (Ministry of Energy and Mineral Resources) or regional

government in accordance with authority to provide guidance and supervision
of the electricity supply business in terms of compliance aspects of
environmental protection, and may conduct on-site inspection.
Lao PDR Environmental management unit joint with provincial authorities conduct
official inspection.
Based on concession agreement for CPP
The law does not require an independent inspector.
Myanmar Screening team, which is organized by the ministry, inspect frequently.

Inspection team is organized by the relevant ministries and/or organizations.
The law does not appear to have a requirement for an independent

inspector.
Thailand Department of Estate, Ministry of Industry inspects every industry plant.
If CPP is large, there is no site-visit.
In case of a severe accident, Ministry of Environment inspects.
Local government has a power to inspect, but there is no case.
19
Independent inspector is not required.
(D) Public Announcements
Cambodia Ministry of Environment or government collect environment data from various

facilities and publish the status of air pollution on screen monitors.
Indonesia Ministry of Environment and Forests is currently developing an online reporting

system, where the results of such reporting can be accessed by the public.
Currently the Directorate General of Electricity is also developing information
systems for monitoring power plant emissions by taking a pilot project of one
power plant site (CPP Cirebon 1 x 660 MW).
Lao PDR Provincial authorities and EMU make public the status of air pollution within
the prefecture.
Malaysia Announcement through official portal (website) of Department of Environment

and newspapers.
Regular updates of Malaysia Air Pollutant Index (API)
Myanmar Coal-fired power plants publish the status of air pollution on LED screens in
front of their power plants (example of Tigyit Coal-fired Thermal Power
Plant).
Thailand Operators' annual report.
Local government does not publish emission data.
(E) Penalty
Cambodia Violation of Air Pollution Control Act requires CPP operator to pay a fine or CPP
licence could be cancelled or plant shut down.
[Compensation for Damage and Losses]
Strict Liability
Indonesia Based on Law No. 32/2009, penalty:
- Administrative sanction
- Fine and imprisonment
Anyone who violates the emissions quality standards shall be punished with
20
imprisonment of 3 years and a maximum fine of Rp 3 billion. Criminal offence
can only be imposed if administrative sanctions that have been imposed are
not complied with or the offences are committed more than once.
Strict Liability
Law 32/2009, Article 54
Anyone who pollutes and damages the environment is obligated to do

environmental recovery.
Lao PDR Bases on concession agreement
Strict Liability
Malaysia Any person who contravenes or fails to comply with any provisions of
Environmental Quality (Clean Air) Regulations 2014 shall be liable to a fine not
exceeding RM100,000 or imprisonment for a term not exceeding 2 years or
both.
Environmental Quality Act 1974:
Section 46E: ‘the person so convicted to pay the other person the costs and
expenses incurred or compensation for loss or damage to the property and any
other costs, in the amount as the court considers fit’.
Myanmar Environmental Offences and Penalties
Penalties
US$2,500 to US$10.000 or equivalent kyats
Specific Administrative Punishment of the Ministry
-Issue Enforcement Notice
-Suspension of Approval of EMP, EMP-CP, or EMP-OP in whole or in part
-Revocation of Approval of EMP, EMP-CP, or EMP-OP in whole or in part
Failure to take reasonable steps to prevent an imminent threat of damage to

the environment, social, human health, livelihoods, or property, where
applicable based on the EMP, EMP-CP, EMP-OP
21
Thailand Industry Act
Ministry of Industry can pose fines, maximum B200,000.
Central government requires CPP to pay compensation, but there is no case to

date.
(It is difficult to find responsibility of air pollution and evaluate damage and
losses.)
Operators pay damages and losses voluntarily, i.e. hospital expenses, medical
examination, etc.
2.3. Summary
The following discussion outlines the survey results of the selected ASEAN countries.
(A) General
 At the central government-level in each country, environment-related acts have been enacted,
regulated air pollutants have been identified, and emission standards have been stipulated.
Cambodia, Indonesia, and Thailand authorize their local governments to enact the emission
standards. As with Japan, Cambodia has further set the emission standards voluntarily with the
CPP operator.
 Authority to suspend operation varies as follows.
 Central government: Malaysia, Myanmar, Thailand
 Central and local government: Indonesia, Lao PDR
 Local government: Cambodia (based on agreement between CPP and local

government)
 Periodical meeting with a local community after starting CPP operation
 Lao PDR: Dependent on an agreement with the CPP
 Thailand: Implemented every 3 months
 Other countries: Not obligated
(B) Management process
 The local governments implement regular monitoring in Cambodia, Lao PDR, and Myanmar. In
these countries, coal-fired power generation started after the 2000s.
 Reports should be submitted as follows.
22
 Central government: Cambodia, Malaysia, Myanmar, Thailand
 Local government: None
Archive requirements are not enacted by law, except in Thailand.
 As with submission of reports, inspection agencies vary as follows.
 Central government: Cambodia, Malaysia, Myanmar, Thailand
 Local government: None
 Public announcements vary as follows.
 Cambodia: Central government publishes it through screen monitors.
 Indonesia: Central government is developing an online system.
 Lao PDR: Local government publishes the status.
 Malaysia: Central government’s website
 Myanmar: CPP publishes the status on LED screen in front of the plant
 Thailand: CPP operator’s annual report
 The following compares the national emission standards from the CPPs in the selected ASEAN
countries. Where the standards differ depending on the start year of operation of the plant,
the case of a newly constructed CPP was adopted. Where they differ depending on the plant
scale, the large-scale case was adopted. Where they differ depending on the period, the daily
basis (or 24 hours) was adopted. SOx and NOx have different units from one country to another.
In the countries where parts per million (ppm) measurement is used, accordingly, it is
converted into mg/m3, regarding them as SO2 and NO2, respectively.
 Like Cambodia and Lao PDR, some countries have been regulating pollutants more strictly than
the national emission standards, based on the agreements concluded between the CPP and
the local government.
23
Table 1: Emission standards for CPP in selected ASEAN countries, China, and India
Country SOx NOx PM
Cambodia SO2: 500 mg/m3 NO2: 1000 mg/m3 400 mg/m3
China SO2: 200 mg/m3 NO2: 200 mg/m3 30 mg/m3
India SO2: 80 mg/m3 NO2: 80 mg/m3 100 mg/m3
Indonesia SO2: 750 mg/m3 NO2: 750 mg/m3 100 mg/m3

Lao PDR 120 mg/m3
(SO2: 853 mg/m3) (NO2: 670 mg/m3)
Malaysia SOx: 500 mg/m3 NOx: 500 mg/m3 50 mg/m3
Myanmar SOx: 200 mg/m3 NOx: 400 mg/m3 50 mg/m3
Philippines SO2: 700 mg/m3 NO2: 1000 mg/m3 150 mg/m3
Singapore SO2: 500 mg/m3 NO2: 700 mg/m3 100 mg/m3

Thailand 80 mg/m3
3 3
(SO2: 480 mg/m ) (NO2: 383 mg/m )
Viet Nam SO2: 500 mg/m3 NO2: 650 mg/m3 * 200 mg/m3
(Reference) Germany SOx: 150 mg/m3 NOx: 150 mg/m3 10 mg/m3
ASEAN = Association of Southeast Asian Nations, CPP = coal-fired power plant, mg/m3 = milligrams per cubic
metre, NO2 = nitrogen oxide, NOx = nitrogen oxides, PM = particulate matter, SO2 = sulphur dioxide, SOx =
sulphur oxides.
Note: *coal volatile content >10%.
Source: Authors.
24
Chapter 3
Summary of Management Systems in Selected OECD Countries
1. Survey of management systems in OECD countries
Based on the same survey items as in the ASEAN countries, a survey was conducted on the
management systems for emission gases from coal-fired power plants in the selected OECD
countries. See Section 1 chapter 1 for survey of management systems in ASEAN countries for the
survey items. The surveyed selected OECD countries include Australia, Germany, Japan, the
Republic of Korea, and the United States. The survey was conducted by referring to the websites,
among others, of the related agencies in each country. In the case of Japan, hearings were held with
coal-fired power plant operators.
2. Summary of selected OECD countries
Australia, Germany, Japan, and the United States are summarized for each survey item. The
Republic of Korea was also surveyed, but its management system was omitted in this study because
it is similar to the one in Japan. Because the survey is mainly focused on the regulations of the
central government, the situation of local governments are1 surveyed in a limited manner.
First, general items including the legal systems are described, followed by the management systems.
See Annexes 3, 4, and 5 for the emission standards in each country.
2.1. General
(A) Legislation (National)
Australia - National Environment Protection (National Pollutant Inventory) Measure

1998
- National Environment Protection (Ambient Air Quality) Measure
Germany - Air quality regulation is aligned with the European Union (EU) air quality
legislation
25
- Industrial emission is regulated under the Directive 2010/75/EU or Industrial
Emission Directive (IED)
- Federal Emission Control Act (in German, BImSchG)
Japan Air Pollution Control Act (Ministry of the Environment)
(A CPP which is authorized by the Electricity Business Act is exempted from

the Air Pollution Control Act.)
United States Clean Air Act (CAA)
- Section 108: Air quality criteria and control techniques

- Section 111: Standards of performance for new stationary sources
- Section 112: Hazardous air pollutants
(B) Legislation (Local)
Australia Each state establishes environmental legislation. Procedures vary from state to
state.
Germany Provisions on air quality control at federal state level
Japan Local governments can establish necessary regulations relating to air pollutant
emissions (in general more stringent than that of the central government).
United States Not available
(C) Regulated pollutants
Australia SO2, NO2, PM10, and PM2.5
Germany SO2, NOx, PM, carbon, metals, volatile, asbestos, cyanides, chlorine, asbestos,
etc.
Japan SOx, NOx, PM
(example Yokohama: Ordinance relating to living environment (cadmium,

chlorine, lead, etc.)
United States CO, lead, NO2, O3, PM, SO2, mercury, etc. 189 pollutants (Sections 108, 111,
112)
26
(D) The way to recognize the facilities of emitting pollutants
Australia Each occupier of a facility is to be required to provide information. (example,

NSW state: through licensing)
Germany - Permit of authorities must take into account the whole environmental
performance of the plant.
- Operators shall submit to the authority a baseline report before starting

operation of an installation.
Japan CPPs shall notify items (facility structure, pollutant control way etc.) to the
prefectural governor.
(E) Authority to suspend operation
Australia (ex) NSW state: Protection of the Environment Operations Act 1997
Clean-up, Prevention and prohibition notices are provided for under the
legislation. Only the minister can issue a prohibition notice on the
recommendation of the Environment Protection Authority (EPA).
Germany The authority may decide to suspend activities of a plant in whole or in part.
Japan Local governor has power to order emitters to suspend operation when they
violate the regulations.
When it continuously emits more than limit, local governor can order for
improvement until it is completed.
United States Title V of CAA requires major sources of air pollutants to obtain and operate in
compliance with an operating permit. Sources with ‘Title V permits’ are
required by the CAA to certify their permits at least annually.
(F) Measurement of emission by operator
Australia Australian Standards
Germany According to the Technical Instruction on Air Quality Control, SO2, NO2, PM shall
be measured continuously.
Japan Operator shall measure the quantity or concentration of air pollutant more
than every 2 months, keep records.
27
(In actual) Data are being monitoring continuously, and automatically
transmitted to local governor through telemeter.
United States Follows EPA Regulation 40 CFR Part 60 Subpart Da under CAA Section 111.
(G) Assistance (National, Local)
Australia Not available
Germany State shall encourage the development and application of emerging

techniques.
Japan The (national) government shall endeavour to provide financial assistance,

technical advice, other assistance.
Local governments also convene explanatory meetings to CPP operator when

the law is amended.
United States New Source Review (NSR) and Prevention of Significant Deterioration (PSD)
require large industrial facilities to install state-of-the-art air pollution controls
when they build new facilities or make modifications.
(H) Relation to local community
Australia (ex) NSW state: The law does not require periodical meetings with local
community.
Germany Relations take place at the measuring and monitoring stage, which gathers
from local Länder and federal agency.
Japan Air Pollution Control Act does not require periodical meeting with local
community.
Another law requires CPP developers to hold meetings with residents before
new construction of CPP.
United States The regulation does not require periodical meetings with local community.
28
(I) Ability of local government
Australia (ex) NSW state: The EPA offers a 2-day course which has been designed to equip
authorized officers to fulfil their responsibilities as outlined in the Protection of
the Environment Operations Act 1997.
Germany The mid-level administrative bodies have permitting authority.
Japan Generally high, there are experts of measuring method in local government.
2.2. Management system
(A) Monitoring
Australia Areas with populations greater than 25,000 are required to install monitoring
stations.
(ex) NSW state: The Office of Environment and Heritage (OEH) operates air
quality monitoring network.
Data from network is presented online as an index (air quality index, AQI)
based on hourly data and stored in a searchable database.
Germany - Monitoring networks are operated by (i) German Federal Environment

Agency, which measures stations far away from cities and (ii) German’s Lander
monitoring networks, which monitor the quality of the populated areas.
- The data from the two monitoring networks provide the foundation of the
country’s air quality.
Japan - Prefectural governors shall continuously monitor the status of air pollution.
- Local governments have observing stations.
United States (ex) PM: Operator of a facility shall install, calibrate, maintain, and operate
opacity monitoring systems (COMS), and record the output of the system for
measuring the opacity of emissions discharged to the atmosphere.
(B) Reporting to authority
Australia (ex) NSW state. The law does not require licensees to report emission data to
EPA periodically. Instead, licensees are required to publish pollution monitoring
data.
29
[Archive Requirement]: Not available
Germany Operator shall supply the monitoring results to the authority regularly and at
least annually.
Publications shall be lodged in the archives of the German Patents Office for
safe custody and reference.
Japan National and local governors may require operator to report the status of air
pollutant emissions.
(In actual) According to an agreement, operator submits the report to local

governments every month generally, although CPP automatically send data
through telemeter continuously.
3 years. (In actual) most operator keeps important data permanently.
United States Performance test data from the continuous monitors must be reported to the
administrator. The owner or operator of the facility shall submit a signed
statement.
Record-keeping requirements
(C) Inspection
Australia (ex) NSW state: Protection of the Environment Operations Act 1997
Operators must notify pollution incidents. Mandatory audits may be required
as a condition of licence if the EPA reasonably suspects.
The law does not require it.
Germany The law requires mandatory environmental inspections to be done at least

every 1 to 3 years.
Each inspection plan shall include a general assessment of relevant significant

environmental issues.
30
Japan National and local governor may conduct official inspection.
On-site inspection by national governor: On an irregular base, every 5 or 6

years.
On-site inspection by local governor: it depends on an agreement between CPP

operator and local government, one inspection per year generally, in
Environment Month typically.
United States EPA’s policy: Incentives for self-policing (discovery, disclosure, correction, and
prevention)
On-site visit by EPA, civil investigations, record reviews, information requests
The law does not require
(D) Public Announcements
Australia (ex) NSW state: Requirements for publishing pollution monitoring data
- The law requires licensees to publish pollution monitoring data instead of

reporting.
- There are offences for failure to publish monitoring data and for publishing
false or misleading data.
It is necessary monthly meaningful summary of monitoring data on website, or

required frequency where monitoring occurs less than monthly.
Germany All data on air quality are published on the internet shortly after they are
gathered, providing information on current pollution level.
The EU Pollutant Release and the Transfer Register (E-PRTR) is a public register
intended to provide environmental information and include data on emissions
as reported by the state.
Japan Local governments collect environmental data from various facilities and
publish the status of air pollution at screen monitors in their city hall. Everyone
can see the situation in anytime.
Local governments also publish environmental report periodically.
31
United States Everyone can access the air monitoring results on website.
(https://www.epa.gov/outdoor-air-quality-data)
(E) Penalty
Australia (ex) NSW state

Environmental Offences and Penalties
Strict liability
Germany Severe cases of non-compliance can result in criminal liability. Criminal

sanctions include imprisonment and fines (up to €50,000).
Strict liability
Japan Violation of Air Pollution Control Act including disclosure of name of subjected
operator. Punishment includes imprisonment and fine.
Strict Liability
United States - If a civil defendant is found liable or agrees to a settlement: monetary penalty,
injunctive relief, additional actions to improve the environment.
- If a criminal defendant is convicted or pleads guilty: monetary fine, restitution,

incarceration.
Strict liability.
3. Summary
 The OECD countries have effective and comprehensive regulation and management systems.
 Consistency of legislation from national to local government, wide scope of regulating air
pollutants, precise and transparent monitoring, reporting and public announce system.
 Local emission standards are likely more stringent than the national standard.
32
 In general, local governors are stricter than central governors in regulating air pollutant
emissions. It may reflect the importance of the actual management system nearby
residents and the local governor’s abilities of controllership.
 In general, periodical meetings with local communities are not required, except before
the new construction of a CPP, which is stipulated by another law.
 The penalties for violating air pollution control acts are strict. Penalties include suspending
power generation facilities, imprisonment, and/or fines.
 Overall, except for the regulation standards for air pollutants, the OECD countries have stricter
regulation standards and systems to monitor the air pollution status and publish it for the
residents.
 Table 2compares the national emission standards from the CPPs in the selected OECD countries.
Where the standards differ depending on the operation start year of the plant, the case of a
newly constructed CPP was adopted. Where they differ depending on the plant scale, the large-
scale case was adopted. Where they differ depending on the period, the daily basis (or 24
hours) was adopted. SOx and NOx have different units from one country to another. In the
countries where ppm is used, accordingly, it is converted into mg/m3, regarding them as SO2
and NO2, respectively.
33
Table 2: Emission standards for CPP in selected OECD countries
Country SOx NOx PM
Australia SO3: 200 mg/m3 NO2: 800 mg/m3 80 mg/m3
Germany SOx: 150 mg/m3 NOx: 150 mg/m3 10 mg/m3
SOx: 50 ppm *1 NOx: 200 ppm

Japan 100 mg/m3
3 3
(SO2: 133 mg/m ) (NO2: 383 mg/m )
SOx: 50 ppm NOx: 50 ppm

Republic of Korea 10 mg/m3
(SO2: 133 mg/m3) (NO2: 96 mg/m3)
United States *2 SO2: 130 ng/J NOx: 88 ng/J 11 ng/J
CPP = coal-fired power plant, mg/m3 = milligrams per cubic metre, ng/J = nanogram per joule,
NO2 = nitrogen oxide, NOx = nitrogen oxides, OECD= Organisation for Economic Co-operation and
Development, PM = particulate matter, ppm – parts per million, SO2 = sulphur dioxide, SOx = sulphur oxides.
Notes: *1 Based on the CPP’s location, sulphur content of fuel, stack height, etc. emission standards vary by
CPP. The value is an example of a specific CPP based on an agreement between the CPP and local government.
*2 gross output.
Japan and Republic of Korea: More stringent standards in agreements between the CPP and local
government than the national standard.
Source: Authors.
34
Chapter 4
Comparison of Management Systems between Selected ASEAN and
OECD Countries: Similarities and Differences
This chapter selects several survey items to compare the situation in the selected OECD countries
and selected ASEAN countries.
1. General
(1) Legislation
As with the selected OECD countries, the selected ASEAN countries have enacted environment-
related acts and regulation standards for air pollutants. In many countries, the regulation values are
sorted for each sector, regulating power generation as a sub-sector.
In the selected OECD countries, the local governments are generally authorized to enact stricter
emission standards than national ones. In the selected ASEAN countries, Cambodia, Indonesia,
Myanmar, and Thailand grant such authority to their local governments. In Thailand, however, no
local government has actually set its own emission standards to date.
In Japan and the Republic of Korea among the OECD countries, coal-fired power plants (CPP) and
local governments have concluded agreements to set stricter emission standards than the national
ones. Among the ASEAN countries, Cambodia and Lao PDR are following suit. In both countries, the
coal-fired power plants started operation less than 10 years ago. However, Cambodia and Lao PDR
seem to be rare cases that follow Japan’s experience to allow a CPP and local government to
conclude an agreement to set stricter emission standards than the national ones.
(2) Regulated pollutants
All the countries have set national emission standards for the typical air pollutants emitted from
the CPPs, namely SOx, NOx, and PM.
(3) Authority to suspend operation
Where the CPPs violate the emission standards in the selected OECD countries, the local
35
governments generally have the authority to suspend operation. In the selected ASEAN countries,
on the other hand, the central government has the authority to suspend operations in Malaysia,
Myanmar, and Thailand, while both the central and local governments have the authority in
Indonesia and Lao PDR, and the local government has it in Cambodia.
(4) Relation to local community
When a new CPP is constructed, many countries require holding an advance meeting with the local
community. Once the CPP starts operation, however, it is presumed that few countries request for
a periodical meeting with the local community. In the selected OECD countries, once the CPP starts
operation, it is not legally required to hold a periodical meeting with the local community. In the
selected ASEAN countries, it was confirmed in Thailand that the CPP holds periodical meetings with
the local community every 3 months. In Lao PDR, the CPP has to hold periodical meetings with the
local community according to the agreement with the local government.
(5) Summary
When comparing the selected OECD and ASEAN countries, there are a few differences in the general
sections of the legislation, despite the existence of some cases where the central or local
government has authority.
2. Management systems
(1) Monitoring
In the selected OECD countries, monitoring is conducted by the central government, local
government, or the CPP. This is also the case with the selected ASEAN countries. Monitoring is
conducted by the local government in Cambodia and Lao PDR. In Indonesia, the local government
conducts it irregularly. In Malaysia, it is conducted by the central government. In Myanmar, it is
conducted by both the central government and local government. In Thailand, the CPP conducts
the monitoring and submits the results to the central government.
(2) Reporting to authority
In the selected OECD countries, the situation differs from one country to another. In the case of
New South Wales in Australia, it is not obligated to report emission data. Accordingly, it is not
obligatory to keep the emission data. Instead, the CPP must publish the air pollution status. In
Germany, a CPP operator must periodically report the monitoring results. In Japan, the central or
36
local government may require the CPP operator to report the status of air pollutant emissions. In
the United States, the CPP operator must report the continuous monitoring status. The situation
varies among the selected ASEAN countries as well. In Cambodia and Lao PDR, the CPP must submit
the emission data every month based on the agreement with the local government. In Indonesia,
the CPP must submit the emission data to the central and local governments based on the law. The
frequency of submission is every 3 months when continuous emission monitoring systems (CEMS)
are used, and every 6 months when manually measuring. Malaysia has a CEMS. In Myanmar, the
CPP must submit the emission data to the central government at least every 6 months based on the
law. In Thailand, the CPP must submit data twice a year.
Archive requirements also vary among the selected OECD and ASEAN countries. Australia and
Thailand for example, have no archive requirements. Even in the countries with archive
requirements, the archiving period varies from 6 months to 3 years.
(3) Inspection
The situation differs among the selected OECD countries. In NSW, Australia, mandatory audits may
be required as a condition of a licence if the Environment Protection Authority (EPA) reasonably
suspects violation of emission standards. In Germany, the law requires mandatory environmental
inspections to be done at least every 1 to 3 years. In Japan, the national or local government may
conduct official inspections. In the United States, the EPA’s policy is self-policing.
Among the selected ASEAN countries, the central government inspects with telemeters in
Cambodia. In Indonesia and Lao PDR, inspections are conducted by the central and local
governments. In Malaysia, Myanmar, and Thailand, inspections are conducted by the central
government.
No independent inspector is legally requested in either the selected OECD or ASEAN countries.
(4) Public announcement
Air pollutants are emitted from industrial boilers and vehicles as well as CPPs. Accordingly, the
regional air pollution status consists of a combination of different emission sources of air pollutants.
The selected OECD countries regulate the regional air pollution status as well as emissions of air
pollutants from the CPP. This is also the case with the selected ASEAN countries.
In regulating the air pollutants, it is important for the local community to always know the air
pollution status. In the selected OECD countries, the central or local government generally publishes
the air pollution status through websites or on screen monitors. The situation differs among the
37
selected ASEAN countries. In Cambodia, the central government publishes the air pollution status
through its website, while in Malaysia the status is published on a screen monitor. In Lao PDR, the
local government publishes the regional air pollution status. In Myanmar, the CPPs publish the air
pollution status inside the plants. In Thailand, the air pollution status is published in the annual
report submitted by the CPP’s operator. In Indonesia, the central government is developing a data
collecting and publishing system.
(5) Summary
The management system status differs among the selected OECD and ASEAN countries.
3. Emission standard for CPPs
Figures 3 to 5 compare the national emission standards for CPPs for SOx, NOx, and PM. It is
necessary to note that the data are not actual emission values. Where the standards differ
depending on the operation start year of the plant, a newly constructed CPP was adopted. Where
they differ depending on the plant scale, the large-scale case was adopted. Where they differ
depending on the period, the daily basis (or 24 hours) was adopted. SOx and NOx have different
units from one country to another. In the countries where ppm is used, accordingly, it is converted
into mg/m3, regarding them as SO2 and NO2, respectively.
SOx is higher in the selected ASEAN countries than in the selected OECD countries. NOx is lower in
the selected OECD countries except for Australia. For PM, the regulation values in the selected
ASEAN countries are approximately the same as those in Australia and Japan, except for Cambodia.
38
Figure 3: Comparison of emission standards in selected countries (SOx)
mg/m3 = milligrams per cubic metre, SOx = sulphur oxides.

Note: Japan: Example of Agreement of specific CPP. China: Regulation in key region.
Source: Authors.
Figure 4: Comparison of emission standards in selected countries (NOx)
mg/m3 = milligrams per cubic metre, NOx = nitrogen oxides.

Note: China: Regulation in key region.
Source: Authors.
39
Figure 5: Comparison of emission standards in selected countries (PM)
mg/m3 = milligrams per cubic metre, PM = particulate matter.

Note: China: Regulation in key region.
Source: Authors.
40
Chapter 5
Policy Recommendations
1. Campaign against CPPs
The merit of coal is that it is less expensive than other fuels and can generate power at low cost. In
countries with a low electrification rate, coal is an optimum power generation fuel for enhancing
the electrification rate at low cost. Furthermore, the world’s largest thermal coal export country,
Indonesia, is in the ASEAN region and the world’s second largest thermal coal export country,
Australia, is located close to ASEAN.2 With lignite included, many ASEAN member countries have
coal reserves. From a viewpoint of energy security, coal is a procurable fuel in the ASEAN region or
from a neighbouring country; its utilization helps enhance self-sufficiency in the ASEAN region.
Thus, coal is an optimum power generation fuel for ASEAN in terms of both cost and energy security.
However, the combustion of coal emits air pollutants, such as sulphur oxides (SOx), nitrogen oxides
(NOx), and particulate matter (PM), harmful to human health and the environment. Consequently,
campaigns against existing CPPs have been launched, and have started other campaigns against the
construction of new CPPs, forcing some new projects to be halted or cancelled. For ASEAN countries,
minimizing the emission of air pollutants is a precondition for the future use of CPPs. But here the
problem is regulating the emission of air pollutants from CPPs. To reduce the emission of air
pollutants, it is required to create regulations and properly manage and operate them.
Based on this awareness, this study surveys the regulations on the emission of air pollutants
(including emission standards and implementation of the regulations).
2. More stringent level of emission standards of air pollutants from CPPs
This survey revealed that in ASEAN countries environmental laws have been enacted to identify the
air pollutants to be regulated and to set emission standards. The problem is the emission standard
2
Source: International Energy Agency, Coal Information 2016.
41
level. Compared to OECD countries, the emission standards are low in many ASEAN countries
depending on the country or the type of air pollutants.
Thus, it is important to raise the current emission standards of air pollutants from CPPs to the level
equivalent to OECD countries. This is because a more stringent level of emission standards is
essential for responding properly to the campaign against CPPs occurring in ASEAN countries.
Additionally, making the level of emission standards more stringent can reduce the emission of
hazardous air pollutants from CPPs and contribute to the reduction of health hazards to residents.
However, a gradual tightening of emission standards may be required according to each country’s
capability. Raising the level of emission standards can lead to an increase in environmental expenses
or an increase in electricity tariffs. The importance of strengthened regulations cannot be
understated, but national and government financial capabilities also need to be considered.
3. Finance and international cooperation
Expensive environmental facilities need to be installed in CPPs to reduce hazardous air pollutants
by tightening the emission standards of air pollutants. This imposes a heavy burden, especially on
low-income countries in the ASEAN region. The most desirable method of sharing the cost burden
is to pass on additional costs to end-consumers according to their electricity consumption. If passing
on increased costs is difficult, it may put a temporary subsidy burden on the government. This is
not sustainable in the long term; therefore, it is recommended to stop providing subsidies to
electricity consumers as early as possible.
There are several ways of financing capital expenditure. For borrowing, there are two options: one
is from domestic financial institutions, the other is from international financial institutions.
Domestic financial institutions are free from exchange risks; however, they may not have the
practical knowledge of large-scale financing for energy. For international financial institutions, long-
term borrowings can be made at low interest rates; however, there are exchange rate risks and loan
procedures sometimes take time due to strict loan terms. Generally, the installation of
environmental facilities can be a good funding destination. On the other hand, financial institutions
have their own view of loans for coal-fired power generation alone. Some financial institutions put
restrictions on loans for new CPP construction, which may limit the funding sources. There are many
types of loans and there is no one special way. A careful decision is required in view of the
circumstances including the factors mentioned in this document.
42
A combination of financing options can be used to construct new coal-fired power plants. For
example, private funds such as independent power producers and private finance initiatives can be
used for construction. These approaches have the advantage of constructing a new CPP without
increasing public debt, resulting in promoting technology transfer through the operation of
developed countries’ companies.
4. Monitoring system
Raising emission standards of air pollutants from the CPPs to the level equivalent to OECD countries
and installing environmental facilities in the CPPs will not be the end of the matter. As a first step,
the installed facilities need to be maintained/managed for proper operation. Second, constant
monitoring and recording are required to ensure that the facilities can provide guaranteed
performance and the air pollutants concentration level is kept below the standard. Third,
measurement results need to be released to local governments and residents for assuring proper
operation of the CPPs.
The first step is nothing special; however, some facilities cannot guarantee performance in the CPPs
in developing countries due to the lack of operational experience and maintenance. The continued
proper operation of environmental facilities serves as the base to gain an understanding of residents.
Regarding the second and third steps, the CPPs need to show evidence of complying with the laws
and regulations to gain the trust of residents. Without information disclosure, residents living near
a CPP have no means of knowing if the air pollutants emission level is kept below the standard.
Therefore, the residents may still raise concerns about the CPP, even if they run properly. Hazardous
air pollutants are emitted not only from CPPs but also from industrial boilers and automobiles. A
negative image of CPPs, however, prevents residents from distinguishing among these pollution
sources. CPPs are requested to continually provide transparent data to protect themselves.
Under these circumstances, a highly transparent system is required to monitor the air pollutants
concentration level both for CPPs and local regions. This can be a challenge for countries that have
never created such a system. It is recommended to create a system to monitor the air pollution
situation and to establish an international cooperative framework for proper operation and
information disclosure on the system, and to provide capacity building for central and local
governments and CPP operators. Cooperation will bring mutual benefits to both ASEAN countries
and cooperating countries, encouraging them to build a win–win relationship.
43
44
Annex 1
Environmental Legislation in Selected Countries
OECD Countries
Australia
The National Environment Protection (Ambient Air Quality) Measure (1998)
Amendment: 2003, 2011
National Environment Protection (National Pollutant Inventory) Measure (2008)
Germany
Germany (Federal)
Federal Emission Control Act (1990)
Latest amendment: 2000
European Union (EU) Directive
Industrial Emission Directive (IED – 2010/75/EU)
Large Combustion Plant Directive (LCPD – 2001/80/EC)
National Emission Ceilings for Certain Atmospheric Pollutants Directive (NECD – 2001/81/EC)
European Union Emissions Trading Scheme (EU ETS 2009/29/EC)
Japan
Basic Law for Environmental Pollution Control (1967)
Basic Environment Law (1993)
Republic of Korea
Environmental Protection Law (1978)
Basic Law for Environmental Policy (1991)
NO (1979)
CO, NO2, dust, ozone, hydrocarbon (1983)
Lead (1991)
Sulphurous acid gas, hydrocarbon (new standard, 1993)
45
United States
Clean Air Act (CAA) of 1963 and its 1970 amendments
Clean Air Act Amendment of 1977
ASEAN, China, and India

Cambodia
Law on Environmental Protection and Natural Resources Management (1996)
Law on Standards of Cambodia (2007)
Sub-decree on Air Pollution and Noise Disturbance (2000)
The Sub-decree on Environment Impact Assessment (1999)
Indonesia
Law No. 32 Year 2009 Regarding the Protection and Management of Environment
Law No. 30 Year 2009 Regarding Electricity
Government Regulation No. 14 Year 2012 Regarding Business of Electricity Supply
Government Regulation No. 27 Year 2012 Regarding Environmental License
Government Regulation No. 41 Year 1999 Regarding Air Emission Control
Ministry of Environment Decree No. 21 Year 2008 Regarding Static Emission Sources Quality
Standard for business and/or activities of a Thermal Power Plant
Lao PDR
National Environmental standard (2009)
Malaysia
Environmental Quality Act 1974
Environmental Quality (Clean Air) Regulations (1978)
Myanmar
Environmental Conversation Law 2012
Philippines
Philippines Clean Air Act of 1999
National Emission Standards (DENR Administrative Order No. 2000 - 81, 7 Nov 2000)
46
Singapore
Environment Pollution Control Act (EPCA) (1999)
Environmental Protection and Management Act (EPMA) (2008)
Clean Air (Standards) Regulations (1978)
Environmental Protection and Management (Air Impurities) Regulations (2001)
Amendment: 2002, 2008
Thailand
Enhancement and Conservation of National Environmental and Quality Act (1992)
Ambient Air Standards (1995, 2004, 2010)
Emission standard from Coal-fired power plants (1996, 2001, 2010)
Viet Nam
Emission standards for Industrial sources (1995)
Emission standards for thermal power plants (2005 replaced by 2009)
China
Emission standards for air pollutants from coal-fired power plants (GB13223-2011) (2012)
India
Prevention and Control of Pollution Act (1981) (amendment: 1987)
Environment (Protection) Act (1986) (Latest amendment: 1991)
National Ambient Air Quality Standards (2009)
47
Annex 2
Survey Sheet (Selected OECD Countries)
Australia
Regulation of Air Pollutants from Coal-fired Power Plants

(Blue letters: stipulated in law, green letters: actual situation, red letters: example of New South Wales
state)
Legislation
National (Federal, Central)
National Environment Protection (National Pollutant Inventory) Measure 1998
National Environment Protection (Ambient Air Quality) Measure
Local (State, Municipality, District, City)

Each state establishes environmental legislation. Procedures vary from state to state.
Regulated pollutants (relating to coal-fired power plants)

SO2, NO2, PM10, and PM2.5
Emission standards
Details are described in an annex.
How can authorities recognize the existence of facilities that emit air pollutants?
The occupier of each reporting facility is to be required to provide information.
(Example of New South Wales [NSW] state)

Licensing.
Authority to suspend operation
(Example of NSW state, Protection of the Environment Operations Act 1997)

Clean-up notices, prevention notices, and prohibition notices are the environment protection
notices that are provided for under the legislation. Only the minister can issue a prohibition notice,
on the recommendation of the Environment Protection Authority (EPA).
48
Measurement of emission by operator
Methods for pollutant monitoring: Australian standards
Monitoring
The law requires monitoring stations to be installed in areas with populations greater than 25,000.
(Example of NSW state)

The Office of Environment and Heritage (OEH) operates a comprehensive air quality monitoring
network to provide the community with accurate and up-to-date information about air quality.
Air quality monitoring sites are set up in Sydney and regional areas of NSW.
Data from the monitoring network are presented online as ambient concentrations and air quality
index (AQI) values which are updated hourly and stored in a searchable database.
In 2010, OEH, in partnership with the Upper Hunter coal and power industries, established the
Upper Hunter Air Quality Monitoring Network.
Reporting

The law does not require licensees to report emission data to EPA periodically. Instead of
reporting, the law requires licensees to publish pollution monitoring data.
Inspection
(Example of NSW state, Protection of the Environment Operations Act 1997)

Duty to notify pollution incidents
The act provides that mandatory audits may be required as a condition of a licence if the EPA
reasonably suspects.
Powers of investigation: Authorized officers' powers include powers to require information or
records, powers of entry and search of premises, powers to question and identify persons, powers to
disable intruder alarms, and powers with respect to vehicles and vessels.
Archive Requirement

Unknown.
49
Public Announcements
(Example of NSW state, Requirements for publishing pollution monitoring data)
Pollution monitoring data that is required to be collected by a licence condition must be published
by the licensee. There are offences for failure to publish monitoring data and for publishing false or
misleading data.
Publish monthly meaningful summary of pollution monitoring data on website, or required
frequency where monitoring occurs less than monthly.
NSW EPA publishes the current situation of air quality on the website.
Compensation for Damage and Losses
Negligence
Penalty

Assistance (National, Local)

Unknown.
Ability of local governments

The EPA offers a 2-day course which is designed to equip authorized officers within local
government with the necessary competencies to fulfil their responsibilities as outlined in the
Protection of the Environment Operations Act 1997.
Relation to local community

The law does not require periodical meeting with local community.
Independent inspector

The law does not require independent inspector.
50
Detail of Emission Standards
(Relating to coal-fired power plant)
Australia
Standards for pollutants

Maximum Maximum
Pollutant Averaging period concentration allowable
standard exceedances
1 hour 0.12 ppm 1 day a year
NO2
1 year 0.03 ppm None
SO2 1 day 0.08 ppm 1 day a year
1 day 50 μg/m3 None
PM10
1 year 25 μg/m3 None
1 day 25 μg/m3 None
PM2.5
1 year 8 μg/m3 None
Goal for Particles as PM2.5 by 2025

Pollutant Averaging period Maximum concentration
1 day 20 μg/m3 by 2025
NO2.5
1 year 7 μg/m3 by 2025
51
Outline of Protection of the Environment Operations (Clean Air) Regulation 2010
Schedule 3 Standards of concentration for scheduled premises: activities and plant used for specific
purposes
Electricity generation
Air impurity Activity or plant Standard of concentration
Group 1 400 mg/m3
Any activity or plant using a liquid or solid Group 2, 3, or 4 250 mg/m3
PM
standard fuel or a non-standard fuel Group 5 100 mg/m3
Group 6 50 mg/m3
Any boiler operating on a fuel other than
gas, including a boiler used in connection Group 1, 2, 3, or 4 2,500 mg/m3
NO2 with an electricity generator that forms Group 5 800 mg/m3
part of an electricity generating system Group 6 500 mg/m3
with a capacity of 30 MW or more
Schedule 4 Standards of concentration for scheduled premises: general activities and plant
General standards of concentration
Group 1 200 mg/m3
SO3 Any activity or plant
Group 2, 3, 4, 5 or 6 100 mg/m3
An activity carried out, or plant operated

Group 1: Before 1 January 1972
Group 2: After 1January 1972 and before 1 July 1979
Group 3: After 1 July 1979 and before 1 July 1986
Group 4: After 1 July 1986 and before 1 August 1997
Group 5: After 1 August 1997 and before 1 September 2005
Group 6: After 1 September 2005
52
Germany

(Blue letters: stipulated in law, green letters: actual situation)
Legislation
- German regulations on air quality are aligned with the provisions adopted by the European Union
(EU) air quality legislation. Current standards are contained in the Directive 2008/50/EC
(European Parliament (EP) & Council of European Union (CEU), 11 June 2008) on ambient air
quality and cleaner air for Europe, and the Fourth Daughter Directive 2004/107/EC (EP & CEU
2004), relating to arsenic, cadmium, mercury, nickel, and polycyclic aromatic hydrocarbons in
ambient air.
- Industrial emissions within the EU are regulated under the Directive 2010/75/EU or Industrial
Emissions Directive (IED) aiming to reduce harmful industrial emissions across the EU basically
through a better application of Best Available Techniques (BAT). According to the IED, Member
States (MS) may choose to grant a permit to one responsible operator for each installation or to
split the responsibility amongst several operators of different parts of an installation. The
provision of emission permits depends on the evaluation of plants based on BAT.
- Entered into force on 6 January 2011, the IED was to be adopted in MS national legislation by 7
January 2013. The IED provides an integrated permitting procedure (covering also issues related
to water, soil, waste management, energy efficiency, and accident prevention) that allows to
coordinate different permits and permitting procedures and to achieve the protection of
environment as a whole, avoiding the transfer of pollution to other media.

Federal Immission Control Act 3 (Bundes-Immisionsschutzegesetz, BImSchG). Long title: Act on
Prevention of Harmful Effects on the Environment caused by Air Pollution as amended and
promulgated on 14 May 1990 (Federal Law Gazette I. p. 880), as last amended by Art. 1 of the Act of
3 May 2000 (Federal Law Gazette I. p. 632).
Four strategies to control emissions:

- Laying down environmental quality standard
- Emission reduction requirements according to the BAT
- Product regulations
- Laying down emission ceilings
3
Even though the word “Immission” may sound strange here, it is used in the English version of the Act as in
appears in several official government websites. In particular, the Federal Ministry of the Environment, Nature
Conservation, Building and Nuclear Safety explains the use of the word Immission instead of Emissions in its
website: “Immission relates to the effects of emissions on the environment”
(http://www.bmub.bund.de/en/topics/air-mobility-noise/air-pollution-control/general-information/ ).
53
Local (State, Municipality, District, City):
In addition to the BImSchG, there are also provisions on air quality control at Federal State levels.
Basically, they represent the local enforcement of the BImSchG legal measures.

Target values are established by the IED 2010/75/EU, Annex II.
AIR
- SO2 and other Sulphur compounds
- NOx and other nitrogen compounds
- Carbon monoxide
- Volatile organic compounds
- Metals and their compounds
- Dust including fine particulate matter
- Asbestos (suspended particulates, fibres)
- Chlorine and its compounds
- Fluorine and its compounds
- Arsenic and its compounds
- Cyanides
- Substances and mixtures which have been proved to possess carcinogenic or mutagenic properties which may
affect reproduction via the air
- Polychlorinated dibenzodioxins and polychlorinated dibenzofurans
According to the IED, different approaches of controlling emissions into air, water, or soil separately
may encourage the shifting of pollution from one environmental medium to another. The IED favours
an integrated approach to prevent and control pollutants and includes among the polluting
substances also those affecting water (for a detailed list on water pollutants see Annex II of IED -
2010/75/EU).
Emission standards
- The emission limit values (mg/Nm3), i.e. concentrations that must not be exceeded in a given
period, are established by the EU legislation (IED 2010/75/EU) and ensure that, under normal
conditions, emissions do not exceed the emission levels associated with the BAT. The limit values
are determined through standards stipulated in European air pollution control directives and then
transposed into German law.
- Emission limit values shall apply at the point where the emissions leave the installation, and any
dilution prior shall be disregarded. Setting of emission limit values must not exceed the levels
associated with BAT.
Alternatively, different emission limits, in terms of values, periods of time and reference
54
conditions, can be set. In this case, the competent authority shall assess results at least annually
to ensure that emission levels do not exceed those associated with BAT.
- According to the IED regulation, competent authorities in the MS shall grant a permit if the
installation emits polluting substances listed in Annex II and other polluting substances, as
required by the IED, Art. 14, para. A), and undertaking the industrial activities listed in Annex I of
the IED. Usually, they are industrial installations that have the potential to impact air quality and
cause air pollution (mainly iron, steel, coal, cement, chemicals, machinery, vehicles, machine
tools, electronics, automobiles, food and beverages, shipbuilding, textiles).
- The permits must take into account the whole environmental performance of the plant, in
accordance with the integrated approach of the IED regulation.
- Operators shall submit to the competent authority a baseline report before starting operation of
an installation. The report shall contain the information necessary to determine the state of soil
and groundwater contamination.
- The permit conditions are based on BAT as defined by the BAT Reference Documents (BREFs) set
after consultations of experts from MS, industry and environmental organizations. The
conclusions reached in BREFs are adopted by the Commission as Implementing Decisions and
constitute the reference for setting permits conditions.

Operators are required to suspend operations in case of non-compliance with requirements.
According to BImSchG, Art. 20, the competent authority may decide to suspend activities of a plant
in whole or in part. The competent authority shall order the closure of an installation built without
necessary authorization or if it cannot guarantee the adequate protection of the neighbouring
environment.

Methods: The Technical Instructions on Air Quality Control (Technische Anleitung zur Reinhaltung der
Luft, TA Luft) lay down requirements for calculations, which are based on the Lagrangian particle
dispersion model and computed through a computer programme called AUSTAL2000.
- The analytical methods used are standardized internationally, with air quality data gathered by
international data centres and used for computer modelling. The Federal Republic of Germany
cooperates with other countries in the framework of the Convention on Long-range
Transboundary Air Pollution (CLRTAP): the international control instrument under this framework
is the European Monitoring and Evaluation Programme (EMEP), which measures transboundary
air pollution from 25 countries.
55
Compliance with emissions limit values (IED, Part 4):
- If continuous measurements are required, compliance depends on:
- No validated monthly average exceeding limit values;
- No validated daily average exceeding 110% of limit values;
- In case of combustion plants using coal with a total rated thermal input below 50 MW,
no validated daily average exceeding 150% of limit values;
- 95% of all the validated hourly average values over the year not exceeding 200% of limit values.
- If continuous measurements are not required:
- Compliance if the results of each of the series of measurements do not exceed the limit values.
For example, for fine dust (PM10) a maximum permitted average annual level of 40μg/m³ and a
maximum permitted daily level of 50μg/m³, with a maximum of 35 exceeding days per year.
Frequency of measures
- The concentrations of SO2, NOx, and dust shall be measured continuously. The German Federal
Environment and the Agency German’s Länder monitoring networks measure data on ambient air
quality several times a day.
- For combustion plants firing coal or lignite, the emissions of total mercury shall be measured at least
once per year.
Monitoring
According to IED, Part 6, sampling and analysis of all polluting substances including dioxins and furans
as well as the quality assurance of automated measuring systems and reference measurement
methods to calibrate them shall be carried out according to CEN-standards.4 If CEN standards are not
available, ISO, national or other international standards which ensure the provision of data of an
equivalent scientific quality shall apply.
Air quality is measured by a sophisticated national air quality monitoring network. German air
monitoring networks are operated by:
- German Federal Environment Agency (Umweltbundesamt [UBA]), which measures stations far
away from densely populated areas and cities. Situated in rural areas, the stations of the Federal
Environmental Agency (so-called background stations) collect concentration and deposition data
for the investigation of widely dispersed air pollution in rural areas and measure the quality of air
masses transported over long distances and across national frontiers. (UBA monitoring sites:
Westerland; Zingst, Neuglobsow; Waldhof; Schmücke; Langen; Schauinsland; Zugspitze).
- German’s Länder monitoring networks, which monitor the quality of the air comprehensively.
They operate measuring stations in cities, in conurbations, in areas with high traffic density as
well as in rural regions, to monitor and determine local and regional air quality.
4
Comité européen de normalization (CEN) or European Committee for Standardization.
56
The data from the UBA and the Länder monitoring networks provide the foundation for the
presentation of the country’s air quality. They are gathered in the centre of air monitoring situated in
Langen (Hesse) near Frankfurt/Main.
Reporting
According to the IED, installations operating in accordance with a permit shall supply the competent
Authority regularly, and at least annually, with information on the basis of results of emission
monitoring (measurement methodology, frequency and evaluation procedure) in order to enable the
authority to verify compliance with permit conditions.
Inspection
The IED requires mandatory environmental inspections to be done at least every 1 to 3 years (usually
1 year maximum for installations posing the highest risks and 3 years for installations posing the
lowest risks).
According to the BImSchG the Federal Government is authorized, with the consent of the Bundesrat,
to organize the inspections.
Each inspection plan shall include a general assessment of relevant significant environmental issues;
the geographical area covered by the inspection plan; a register of the installations covered by the
plan; procedures for drawing up programmes for routine environmental inspections; procedures for
non-routine environmental inspections; provisions on the cooperation between different inspection
authorities.
Archive Requirement
Publications shall be lodged in the archives of the German Patents Office for safe custody and
reference. The ordinance shall indicate the date of publication and full particulars of the source
reference (BImSchG, Art. 7).
All data on air quality are published on the internet shortly after they are gathered in Langen,
providing information on current pollution level.
MS shall ensure that the public has effective opportunities to participate in the procedures of granting
a permit for new installations, following any substantial change or updating (Art. 24). When a decision
on permits is taken, it shall be available to the public, including on the internet.
The IED ensures to the public the right to participate in the decision-making process and to be
informed on its consequences by having access to permit applications, permits and the results of the
monitoring of releases (IED, Annex IV).
57
The EU Pollutant Release and the Transfer Register (E-PRTR) is a public register intended to provide
environmental information on major industrial activities and include data on emissions as reported
by MS. The register contributes to transparency and public participation. It implements for the EU
Community the UN/ECE PRTR Protocol to the Aarhus Convention on Access to Information, Public
Participation on Decision-making and Access to Justice in Environmental Matters.

Clean-up of soil, water, or damaged goods can be requested if there is a causal connection between
the air pollution and the damage. If the responsible party is unwilling or unable to execute the clean-
up, the authorities can do so at the polluter’s cost.
Penalty
Severe cases of non-compliance can result in criminal liability. Criminal sanctions include
imprisonment and fines (up to €50,000).

MS shall ensure that operators afford the competent authorities all necessary assistance to enable
those authorities to carry out any site visits to gather the information necessary (IED, Art. 23).
MS shall encourage the development and application of emerging techniques, in particular for those
emerging techniques identified in BAT documents.

- Germany is a Federal Republic with 16 federal states whose competent bodies may differ since
each federal state has its own laws regulating the administration. As a rule, the mid-level
administrative bodies of the federal states (Landramtsamt or Regierungspräsidium) have
permitting authority.

The most relevant relation between local and national authorities takes place at the measurement
and monitoring stage, which gathers data from local Länder and German Federal Environment Agency
monitoring networks.
Independent inspections are not required.
58
Germany
According to IED (Annex V), all emissions limit values shall be calculated at a temperature of 273,15 K, a
pressure of 101,3 kPa and after correction for the water vapour content of the waste gases and at a
standardized O2 content of 6% for solid fuels, 3% for combustion plants, other than gas turbines and gas
engines using liquid and gaseous fuels, and 15% for gas turbines and gas engines.
a) For permits granted before 7 January 2013 (for details see IED, Art. 30, par.1), emission limit values
are the following:
1. SO2
Emission limit values (mg/Nm3) for SO2
Total rated thermal input (MW) Coal and lignite
50–100 400
100–300 250
>300 200
2. NOx
Emission limit values (mg/Nm3) for NOx
50–100 300 (400 in case of pulverized lignite combustion)
100–300 200
>300 200
3. DUST
Emission limit values (mg/Nm3) for dust
50–100 30
100–300 25
>300 20
59
b) For all permits not covered by paragraph 2 (IED, Art. 30, par. 3), emission limit values are the following:
1. SO2
Emission limit values (mg/Nm3) for SO2
50–100 400
100–300 200
>300 150 (200 in case of circulating or pressurized
fluidized bed combustion)
2. NOx
Emission limit values (mg/Nm3) for NOx
50–100 300 (400 in case of pulverized lignite combustion)
100–300 200
>300 150 (200 in case of pulverized lignite combustion)
3. DUST
Emission limit values (mg/Nm3) for dust Total Combustion plants using solid or liquid fuels except gas
rated thermal input (MW)
50–300 20
>300 10
60
Japan

Legislation
1. Air Pollution Control Act (Ministry of the Environment, MoE), which includes relevant Cabinet Order
and Ordinance of MoE.
2. Following cases will be exempted from application of Air Pollution Control Act.
- Coal-fired power plant (CPP) which has an authorization of Electricity Business Act. (Ministry of
Economy, Trade and Industry, METI) *
- Event of accidents
* The Electricity Business Act implies the same level of emission standard.

1. Air Pollution Control Act allows prefectures to set their own emission standards (which in general
more stringent than that of the central government).
2. Air Pollution Control Act allows local governments to establish necessary regulations (Ordinance)
relating to air pollutant emissions.
3. Local governments can establish their own ordinance which is not directly regulating but potentially
affect air emission of CPP.
e.g. Yokohama city where Isogo CPP locate, establishes ordinance relative to living environment.

Air Pollution Control Act: SOx, NOx, PM
Yokohama city (Ordinance relating to living environment):

‒ Cadmium/cadmium compound
‒ Chlorine/hydrogen chloride
‒ Fluorine
‒ Hydrogen fluoride
‒ Silicon fluoride
‒ Lead/lead compound
‒ Ammonia
‒ Cyanogen compound
‒ NOx
‒ SO2
‒ Hydrogen Sulphide
61
Emission standards
Regal mandate: Details are described in an annex
1. Ordinance of MoE (general)
2. Local government ordinance (specified areas, more stringent)
Voluntary:
3. Agreement between local government and power plants operator (more stringent)
4. Internal targets of power plants (operational standards, most stringent)
Standards for Controlling the Total Emissions

Air Pollution Control Act stipulates that prefectural governor shall set standards for controlling the
total emissions in an area with a concentration of factories or workplaces.
Coal-fired power plants shall provide the following items to the prefectural governor.
‒ Name and address
‒ Location
‒ Type of air pollutant
‒ Structure of facilities
‒ Way of disposing of air pollutants, etc.

Prefectural governors have the power to order emitters to suspend the operation of facilities when
they violate the regulation.
Order for Improvement

Prefectural governors have the power to order a CPP to improve performance when it continuously
emit more than regulated limit.
Based on an agreement between local government and CPP operator, when CPP is going to restart
after the order for improvement, the local government can resist its restart until improvement has
been satisfactorily made. This mechanism lets the CPP operator to comply with voluntary target to
avoid receiving order for improvement by the local government.
CPP operator shall measure the quantity or concentration of air pollutant, and keep its record.
- Frequency of measuring:
SOx: more than every two months (Total emission controlling area: continuously(24hr-7d))
NOx: more than every two months
PM: more than every two months
- Measuring methods are stipulated in Law.
62
Coal-fired power plants set observing stations, for example, 10km, 20km, 30km away from CPP, to
monitor the emission continuously. The data is automatically transmitted to local government
through telemeter.
CPP operator signed agreement with local government, which stipulates, in most cases, stringent
emission standards and more frequent measurement. For example:
SOx: monitor quantity and concentration continuously
NOx: monitor quantity and concentration continuously
PM: every month
Monitoring
Prefectural governors shall continuously monitor the status of air pollution.
Local governments have observation stations.
Reporting
MoE or governor of prefecture may require CPP operator to report the status of air pollutant
emissions.
MoE conducts integrated survey of quantity of air pollutant emission every three years.
According to an agreement between CPP operator and local government, an operator submits the
report to local government every month, although the CPP automatically sends data through
telemeter continuously.
Inspection
MoE or a prefectural governor may conduct official inspection.
On-site inspection by METI: On an irregular base, every 5 or 6 years.

On-site inspection by local government depends on an agreement between CPP operator and local
government, once in a year generally, in Environment Month typically.
Archive Requirement
3 years.
Generally, most CPP operators keep important data permanently.
63
Prefectural governors shall make public the status of air pollution within the prefecture.
Local governments collect environmental data from various facilities and publish the status of air
pollution at screen monitor in their city hall. Everyone can see the situation in anytime. Local
governments also publish environmental report periodically.
In case of accident, CPP operator publishes the status of air pollutant emissions through a press
release.

Strict Liability
Penalty
Violation of Air Pollution Control Act including disclose of name of subjected operator.
Punishment includes imprisonment and fine.

Air Pollution Control Act stipulates the following.
The (national) government shall endeavour to provide financial assistance, technical advice, other
assistance.
MoE, in collaboration with Ministry of Economy, Trade and Industry (METI) in some cases, convenes
explanatory meetings with CPP operator when the law is amended.
Local governments also convene explanatory meetings with CPP operator.
MoE and local government post explanatory documents and application/report forms on their
website for easy download.

Ability of officers in local government is high. There are experts of measuring method in local
government.

Air Pollution Control Act does not require periodical meeting with local community.
Another law requires companies to hold a meeting with residents for explanation and discussion
when they apply Environmental Impact Assessment before new construction of a CPP.
64
Air Pollution Control Act does not require independent inspector.
If a coal-fired power plant has ISO 14001 certification, the plant is audited every year.

Japan
1. SOx
Air Pollution Control Act
q = K * 10-3 * He2
q: Maximum permissible limit of SOx (m3N/h)
He: Adjusted height of the Outlet (m)
K: Area of classification
General regulation K: from 3.0 to 17.5
Special regulation (new construction, specified area) K: from 1.17 to 2.34
He = Ho+0.65 (Hm+Ht)
Hm = 0.795√(Q*V) /{1+(2.58/V)}
Ht = 2.01*10-(3*Q*(T-288)*{2.30logJ+(1/J)-1}
J = (1/√(Q*V))[1460-296*{V/(T-288)}]+1
He Adjusted height of the Outlet (m)
Ho Actual height of the Outlet (m)
Q Quantity of emission at 15℃ (m3/s)
V Discharge rate of emission (m/s)
T Temperature of emission (absolute temperature)
Life Environment relevant ordinance (Yokohama City)

Sulphur content in emission: 4 SO2 equivalent grams/1 fuel oil equivalent kg combustion
65
2. NOx
200ppm (O2: 6%)

NO2: 100ppm
NOx: 200ppm
3. PM
100mg/m3N (O2: 6%)

0.05g/m3N
Republic of Korea

Legislation
1. Air Pollution Control Act (Ministry of the Environment [MoE]), which includes relevant Cabinet
Order and Ordinance of MoE.
2. Basic Environment Act (MoE) also stipulates the air emission standards which is not directly
regulating the air emission of CPP but potentially affect the living environment.

1. Air Pollution Control Act allows prefectures of the more than 500,000 population to set their own
emission standards (which in general more stringent than that of the central government).
2. Air Pollution Control Act allows local governments to establish necessary regulations (Ordinance)
relating to air pollutant emissions.
3. Air Pollution Control Act stipulates that local governments should report to the MoE and take
necessary measures to enable stakeholders to know when their own emission standards are set and
amended.

Directly regulating the air emission of CPP (Air Pollution Control Act)
‒ SOx, NOx, PM
66
Potentially affect the living environment (Basic Environment Act)
‒ Sulphur dioxide (SO2)
‒ nitrogen dioxide (NO2)
‒ Carbon monoxide (CO)
‒ Micro-dust (PM)
‒ Ozone (O3)
‒ Lead (Pb)
‒ Benzene
Emission standards
Legal mandate: Details are described in annexes 4, 5, and 6
1. Ordinance of MoE (General)
* In matters of the special measure areas, MoE can set the more stringent emission standards
than the general emission standards.
2. Local government ordinance (more stringent than the central government’s standards)
Voluntary
3. Agreement between local government and power plants operator (more stringent)
4. Operator’s internal targets of power plants (operational standards, most stringent)
Standards for Controlling the Total Emissions

Air Pollution Control Act stipulates that MoE can set standards for controlling the total emissions
in an area if the air pollution condition exceeds the standards or it is concentrated at factories or
workplaces.
Coal-fired power plants should report the following items to the prefectural governor.
‒ Location
‒ License of facilities
‒ Planning of controlling the air pollutant, etc.

Prefectural governor has the power to order emitters to all or partially suspend the operation of
facilities when they violate the regulation.
67
Order for Improvement
Prefectural governor has the power to order CPP for improvement within 1 year* when it
continuously emit more than regulated limit.
* In case of not improving within 1 year with the force majeure, the operator should apply for
the extension of 1 year more to prefectural governor.
Based on an agreement between local government and CPP operator, when CPP is going to restart
after the order for improvement, local government can resist its restart until the government regard
improvement has been satisfactory made. This mechanism let CPP operator to comply with voluntary
target to avoid receiving order for improvement by the local government.
Air Pollution Control Act obligates operators to install the telemeter in the stack of CPP for measuring
emission automatically and continuously.
- Telemeter installation object: Power generation plant（hydro, nuclear power is exemption）
- Measuring pollutants: SOx, NOx, PM
CPP operator signed an agreement with local government, which stipulate, in the most cases, very
stringent emission standards and real-time measurement.
Monitoring
The central and prefectural governors shall continuously monitor the status of air pollution.
Local governments should monitor through the own observing stations and report to the MoE the
monitoring results.
Reporting
MoE or prefectural governor may require operators to report the status of air pollutant emissions.
report to local government if necessary anytime, although CPP automatically send data through
Inspection
Prefectural governor should conduct inspection on every CPP through the telemeter basically and
report to the MoE by the end of March every year.
On-site inspection by local government: it depends on an Agreement between CPP operator and local
government.
68
Archive Requirement
For 6 months after measuring the emission.
Generally, most CPP operators keep the important data permanently in the form of electronic files.
Air Pollution Control Act stipulates MoE shall predict the air pollution status and announce the results
on press release or in the other ways. For this, MoE may require operators to submit the necessary
documents.
Local governments collect environmental data from various facilities and publish the status of air
pollution at screen monitor in their city hall and on the road. Everyone can see the situation in
anytime. Local Governments also publish environmental report periodically.
In case of accident, CPP operators publish the status of air pollutant emissions through press release.

Strict Liability
Penalty
Violation of Air Pollution Control Act: penalties include fine imposed on operator, suspension of
operation, cancellation of licence, or plant shutdown.

Air Pollution Control Act stipulates the following.
The (national) government shall endeavour to provide financial assistance, technical advice, other
assistance.
MoE and local government post explanatory documents and application and report forms on their
website and everyone can easily download them when the law is amended.
Ability of officers in local government is generally high. There are experts of measuring method in
local government.
69
Air Pollution Control Act does not require periodical meeting with local community.
Environmental Impact Assessment Act requires operators to hold a meeting and public hearing with
residents for explanation and discussion before they try to get a license and construct a new CPP.
Until the residents agree to construct the CPP, operators should continue such a process.
Air Pollution Control Act does not require independent inspector. But act stipulates operators to have
a special environmental technician for controlling the emission in the plants.

Republic of Korea
1. SOx
- Established before 1996: 100ppm (O2: 6%)
- Established after 2015: 50ppm (O2: 6%)
Voluntary (Operators of new CPP)
- In-cheon: 20 to 25ppm (O2: 6%)
- Dang-gin: 40ppm (O2: 6%)
- Yeou-su: 30 ppm (O2: 6%)
2. NOx
- In-cheon: 15ppm (O2: 6%)
- Yeou-su: 30 ppm (O2: 6%)
70
3. PM
- Established before 2001: 25mg/Sm3 (O2: 6%)
- Established after 2001: 20mg/Sm3 (O2: 6%)
- In-cheon: 5mg/Sm3 (O2: 6%)
- Yeou-su: 8mg/Sm3 ppm (O2: 6%)
United States

Legislation
Clean Air Act (CAA)
Section 108 (Air quality criteria and control techniques)
National Ambient Air Quality Standards (NAAQS)
EPA Regulation: 40 CFR part 50
Section 111 (Standards of performance for new stationary sources)
New Source Performance Standards (NSPS)
EPA Regulation: 40 CFR part 60 subpart Da
Standards of Performance for Electric Utility Steam Generating Units
Section 112 (Hazardous air pollutants)
National Emission Standards for Hazardous Air Pollutants (NESHAP)
EPA Regulation: 40 CFR part 63

Section 108, CAA (EPA Regulation 40 CFR part 50)
‘criteria’ air pollutants: six
CO, Lead, NO2, O3, PM, SO2
Section 111, CAA (EPA Regulation :40 CFR part 60 subpart Da)
§60.42Da Standards for particulate matter (PM)
§60.43Da Standards for sulphur dioxide (SO2)
71
§60.44Da Standards for nitrogen oxides (NOx)
Section 112, CAA
Currently 189 pollutants
EPA’s latest regulation: mainly mercury
Emission standards
Details are described in annexes 4, 5, and 6

Title V of CAA (Operating Permits)
Title V of CAA requires major sources of air pollutants, and certain other sources, to obtain and
operate in compliance with an operating permit. Sources with these ‘title V permits’ are required by
CAA to certify compliance with the applicable requirements of their permits at least annually.

40 CFR part 60 subpart Da
§60.48Da Compliance provisions
§60.49Da Emission monitoring
§60.50Da Compliance determination procedures and methods
Monitoring
§60.49Da Emission monitoring
(Example of PM)
An owner or operator of an affected facility must monitor the opacity of emissions discharged
from the affected facility to the atmosphere.
The owner or operator of an affected facility shall install, calibrate, maintain, and operate an
opacity monitoring system (COMS), and record the output of the system, for measuring the opacity
of emissions discharged to the atmosphere.
Reporting
§60.51Da Reporting requirements
For SO2, NOX, PM, and NOX plus CO2 emissions, the performance test data from the initial and
subsequent performance test and from the performance evaluation of the continuous monitors
(including the transmissometer) must be reported to the administrator.
72
(For SO2 and NOx: each 24-hour period)
The owner or operator of the affected facility shall submit a signed statement.
Inspection
EPA’s policy: Incentives for Self-policing: Discovery, Disclosure, Correction, and Prevention of
Violations
On-site visit by EPA
Civil investigations
Record reviews: EPA, state, or local offices
Information requests
(https://www.epa.gov/compliance/how-we-monitor-compliance)
Archive Requirement
§60.52Da Recordkeeping requirements
Air Monitoring
https://www.epa.gov/outdoor-air-quality-data

- Environmental civil liability is strict; it arises simply through the existence of the environmental
violation. It does not take into consideration what the responsible party knew about the law or
regulation they violated.
- Environmental criminal liability is triggered through some level of intent.
Penalty
If a civil defendant is found liable or agrees to a settlement, the result can be:
- a monetary penalty
- injunctive relief (actions required to correct the violation and come into compliance, e.g., install
pollution control equipment), and/or
- additional actions taken to improve the environment
If a criminal defendant is convicted or pleads guilty, the result can be:
- a monetary fine paid to the US Treasury, and/or
- restitution (reimbursing the government for the cost of clean-up or response, compensating for
the harm caused by the violation, e.g. paying for medical testing for people exposed to asbestos)
- incarceration
73
New Source Review (NSR) and Prevention of Significant Deterioration (PSD) require certain large
industrial facilities to install state-of-the-art air pollution controls when they build new facilities or
make modifications to existing facilities.
EPA homepage: Investigations of coal-fired power plant sector have identified a high rate of
noncompliance with NSR/PSD when old plants are renovated or upgraded.
CAA (Section 108) requires EPA to develop information on pollution control techniques.
The Clean Air Technology Center

The EPA regulation does not require periodical meeting with local community.
The EPA regulation does not require independent inspector.

(Relating to coal-fired power plants)
United States
40 CFR part 50 (air quality)

Primary/ Averaging
Pollutant Level Form
Secondary time
98th percentile of 1-hour daily
primary 1 hour 100 ppb maximum concentrations, averaged
over 3 years
NO2
primary
and 1 year 53 ppb Annual Mean
secondary
primary 1 year 12.0 μg/m3 annual mean, averaged over 3 years
secondary 1 year 15.0 μg/m3 annual mean, averaged over 3 years
PM PM2.5 primary
98th percentile, averaged over 3
and 24 hours 35 μg/m3
years
secondary
74
primary
Not to be exceeded more than once
PM10 and 24 hours 150 μg/m3
per year on average over 3 years
secondary
SO2 over 3 years
secondary 3 hours 0.5 ppm
per year
Primary standards provide public health protection, including protecting the health of ‘sensitive’
populations such as asthmatics, children, and the elderly. Secondary standards provide public welfare
protection, including protection against decreased visibility and damage to animals, crops, vegetation,
and buildings.
40 CFR part 60 subpart Da (stationary source)

Applicability:
That is capable of combusting more than 73 MW (250 MMBtu/hr) heat input of fossil fuel.
SO2 NOx PM
1971–1978 520 ng/J heat input 300 ng/J heat input 43 ng/J heat input
Sep 1978–1997 520 ng/J heat input and subbituminous: 210 ng/J 13 ng/J heat input
90% reduction (or 70% heat input
reduction where <260 other coal types: 260 ng/J
ng/J); heat input
1978–Mar 2005 180 ng/J gross output New plant: 200 ng/J gross
65 ng/J heat input output
Reconstructed: 65 ng/J
heat input
Commenced construction: 180 ng/J gross output 130 ng/J gross output 18 ng/J gross output
Mar 2005–May 2011 95% reduction 6.4 ng/J heat input
Commenced 180 ng/J gross output 130 ng/J gross output Or: 13 ng/J input and
reconstruction: Mar 2005– 65 ng/J heat input 47 ng/J heat input 99.9% reduction
May 2011 95% reduction
Modified: Mar 2005–May 180 ng/J gross output 180 ng/J gross output 18 ng/J gross output
2011 65 ng/J heat input 65 ng/J heat input 6.4 ng/J heat input
90% reduction Or: 13 ng/J input and
99.8% reduction
Construction or 130 ng/J gross energy 88 ng/J gross output 11 ng/J gross output
reconstruction after: 3 May output 95 ng/J net output 12 ng/J net output
2011 140 ng/J net energy
output
97% reduction
Modified after: 3 May 2011 180 ng/J gross output 140 ng/J gross output 18 ng/J gross output
90% reduction 6.4 ng/J heat input
Or: 13 ng/J input and
99.8% reduction
75
Annex 3
Survey Sheet (Selected ASEAN Countries)
Cambodia

Legislation
1. Air Pollution Control Act (Ministry of Environment [MoE])
1. Air Pollution Control Act allows CPP to set their own emission standards but follow the
government standard and follow to establish regulation that relating to air pollution
emission.

Air Pollution Control Act: SOx, NOx, PM
Potentially affect the living environment
‒ Sulphur dioxide (SO2)
‒ Nitrogen dioxide (NO2)
‒ Carbon monoxide (CO)
‒ Particulates
Emission standards
Regal mandate details are described in annexes 4, 5, and 6
‒ The government standard and Ordinance of Ministry of Environment
Voluntary
‒ Agreement between local government with power plant operator
‒ Internal targets of power plants (operational standards)
Coal-fired power plants should report the following items to the prefectural governor
‒ Location
76
‒ Planning to control air pollutant
Based on an agreement between local government with power plant operator, when CPP is going to
restart after the order for improvement and local government can stand up to its restart until the
government regard improvement has been satisfactory made.
Air pollution Control Act obligates operator to install a public screen monitor to show emission
measurements automatically (SOx, NOx, PM) and transmit to the public through a telemeter.
Monitoring
Prefectural governors shall continuously monitor the status of air pollution.
Reporting
According to agreement with the government, a power plant operator submits data air pollution
emission every month generally, although CPP automatically send data through to telemeter.
Ministry of Environment conducts integrated survey of quantity of air pollution emission every 3
years.
Inspection
Ministry of Environment or government should conduct inspection on each CPP through the
telemeter.
Archive Requirement
All CPP operators should be keep the important data permanently every 6 months after measuring
the emission.
MoE or government collect environment data from various facilities and publish the status of air
pollution to show on public screen monitor.

Strict Liability
Penalty
Violation of Air Pollution Control Act: penalties include fine imposed on operator, suspension of
operation, cancellation of licence, or plant shutdown.
77
Ministry of Mines and Energy (MME) and Ministry of Finance (MoE) shall provide financial assistance,
technical advice, or other assistance.

The implementation largely depends on the ability of officers or experts in local government to judge
and interpret the method of measuring the compliance of CPP.

Environmental Impact Assessment Act requires operator to hold a meeting and publish hearing with
residents for explanation and discussion before they get a licence and continue the process of
constructing a new CPP after the residents agree.
Air Pollution Control Act stipulates operators have a special environmental technician for controlling
the emission in the plants.

Cambodia
Emission Unit Cambodian standard World Bank standard

Sulphur dioxide (SO2)
mg/Nm3 500 2000
Dry, 00c, 1atm, 6% O2
Nitrogen oxide(SO2) mg/Nm3 1,000
750
Dry, 00c, 1atm, 6% O2
Particulates mg/Nm3 400
50
Dry, 00c, 1atm, 6% O2
78
Indonesia

Legislation
a. Law No. 32 Year 2009 Regarding the Protection and Management of Environment
b. Law No. 30 Year 2009 Regarding Electricity
c. Government Regulation No. 14 Year 2012 Regarding Business of Electricity Supply
d. Government Regulation No. 27 Year 2012 Regarding Environmental License
e. Government Regulation No. 41 Year 1999 Regarding Air Emission Control
f. Ministry of Environment Decree No. 21 Year 2008 Regarding Static Emission Sources Quality
Standard for business and/or activities of a Thermal Power Plant

According Ministry of Environment Decree No. 21 Year 2008, local government may set:
a. emission quality standards for business and / or activities of a thermal power plant with the
provisions of the same or more stringent than the standard that has been set nationally;
b. Additional parameters outside the parameters of the emission quality standards for business
and/or activities of a thermal power plant after the approval of the minister in the environmental
field.

Sulphur dioxide (SO2), nitrogen oxide (NOx) stated as NO2, total particulate (particulate matter), and
opacity.
Emission standards
The detail is in annexes 4, 5, and 6
How can authorities recognize the existence of facilities that emit air pollutant?
- Government Regulation No. 14 Year 2012 Article 13 Paragraph (1) and Government
Regulation No. 27 Year 2012 Article 1 and 2
Government Regulation No. 14 Year 2012 states that to obtain a business licence in electricity
supply, an applicant must meet the administrative, technical, and environmental
requirements. In terms of environmental requirement, in Government Regulation No. 27 Year
2012, it is explained that an environmental licence is a prerequisite to obtain business and/or
activity licence. An environmental licence is obtained through several stages of activities
including:
79
1. Preparing the Environmental Impact Analysis (EIA) or Environmental Management and
Monitoring Scheme (EMMS) (for power plant < 100 MW in one location)
2. Assessment
3. Application and issuance of environmental licence.
The authority can recognize the power plant facility that emit pollutants based on the
environmental documents (Environmental Impact Analysis or EMMS) and the environmental
licence, which was drafted at the beginning stages of planning the power plant as well as on
the reporting of the implementation of the monitoring of air emissions that are routinely
prepared by the company to be submitted to the technical authority.

Authority to suspend operation due to violation of environmental regulation is the licensor of
environment licence: minister in the environmental field/governor/regent/mayor.

Ministry of Environment Decree No. 21 Year 2008 Article (9)
- For the CPP with capacity above 25 MW or below 25 MW but using coal that has sulphur
content above 2%, emissions are measured using Continuous Emission Monitoring System
(CEMS) that is installed in power plant’s chimney.
- For a power plant that does not have a CEMS installed, manual measurement is required and
it must be done by the accredited laboratory with minimum measurement frequency every
6 months.
In practice, even though a CEMS is installed, manual measurement is still required and it is conducted
by accredited laboratory every 6 months. The results from manual measurements are used as
comparative data and the result is also reported to the regent/mayor with a copy to the governor and
Monitoring
Irregular monitoring by local government.
Reporting
Government Regulation 21 Year 2012 article 9
The responsible of the power plant is obliged to
a. Report the results of monitoring and measurement of emissions every 3 months for the
power plant that equipped with CEMS to the regent/mayor with a copy to the governor and
80
b. Report the results of monitoring and measurement of emissions every 6 months for the
power plant that manually measured the emission to the regent/mayor with a copy to the
governor and minister in the environmental field.
c. Report annual total emission (ton/year) emitted for NOx, SOx, and CO2 to the regent/mayor
with a copy to the governor and minister in the environmental field.
Inspection
Law 32 Year 2009 article 72
Ministry of Environment or governor/regent/mayor are obliged to conduct supervision, and may
conduct on-site inspection.

Government (Ministry of Energy and Mineral Resources) or regional government in accordance with
authority to provide guidance and supervision of the electricity supply business in term of compliance
aspects of environmental protection, and may conduct on-site inspection.
Archive Requirement
Generally, most CPP owners keeps important data permanently.
Ministry of Environment and Forests is currently developing an online reporting system, where the
results of such reporting can be accessed by the public. The Directorate General of Electricity is also
developing information systems for monitoring power plant emissions by taking a pilot project of one
power plant location (CPP Cirebon 1 x 660 MW).

Strict Liability
Anyone who pollutes and damages the environment is obligated to do the environmental recovery.
Penalty
Based on Law No. 32 Year 2009, penalty:
- Administrative sanction
- Fine and imprisonment
Anyone who violates the emissions quality standards shall be punished with imprisonment of 3 years
and a maximum fine of Rp3 billion. A criminal offence can only be imposed if administrative sanctions
that have been imposed are not complied with or the offences are committed more than once.
81
National and local government provide technical assistance to the CPP owner.

Not available
Based on Government Regulation No. 27 Year 2012 article 9, the CPP owner must hold a meeting and
public hearing with residents for explanation and discussion as requirement for preparing an EIA
document.
Not available

Indonesia
Static Emission Sources Quality Standard for CPP
Maximum level
No. Parameter (mg/Nm3)
A B
1. Sulphur dioxide (SO2) 750 750
Nitrogen oxide (NOx) stated as NO2 850 750

2.
3. Total particulate 150 100
4. Opacity 20% 20%
A. For CPP that has been operation before 1 December 2008.

B. For CPP that has been operation since 1 December 2008.
Notes:
a. Gas volume is measured under standard condition (25oC and 1 atm).
b. Opacity is used as a practical indicator for monitoring.
c. All parameters corrected by O2: 7 %.
d. For a CPP with CEMS installed, the imposition of emission quality standard is for 95% of
normal operation time for 3 months.
82
Lao PDR

Legislation
National Environmental standard (Lao national environmental standard)
Local authorities are involved in providing their recommendation for state of feasibility study,
construction and operation of coal-fired power plants.
SO2, NO2, PM10, and PM2.5
Emission standards
Details are described in annexes 4, 5, and 6
The central and local government authorities recognize the information during their review EIA of
coal-fired power plants and mitigation plans and periodic reports of the plants.
The central government (prime minister) and provincial governors have full power to suspend the
operation of the facilities if the pollutants emitted are above the regulations allowed based on daily
monitoring at the CPP.
CPP and provincial operator measure the quantity or concentration of air pollutant, and keep its
record. Frequency of measuring: SOx: more than every 3months (total emission controlling area:
continuously (24hr-7d)) NOx: more than every 2 months PM: more than every 2 months
Monitoring:
Provincial authorities shall continuously monitor the status of air pollution.
Local governments have observation stations.
Reporting
Ministry of Natural Resource and Environment (MoNRE) or provincial authorities (EMU) jointly with
CPP operator to report the status of air pollutant emissions. MoNRE conducts integrated survey of
quantity of air pollutant emission every 6 months.
report to local government every month generally, although CPP automatically sends data through
83
Inspection
Environmental management unit jointly with provincial authorities conduct official inspection.
Archive Requirement
3 years.
Provincial authorities and EMU make public the status of air pollution within the prefecture.

Strict Liability
Penalty
Base on concession agreement.

Air Pollution Control Act stipulates the (national) government shall endeavour to provide financial
assistance, technical advice, other assistance.

MEM and MONRE have established steering committees for CPPs.

Base on concession agreement for CPP.
Base on concession agreement for CPP.
84
Lao PDR
Ambient Air Quality Standard

Average time unit (mg/m3)
Parameters Symbol Hours 1 1 Method of measurement
1hr 8hr 24hr month year
Carbon Non-dispersive infrared

CO 30 10.26
monoxide detection
Chemiluminescence
Nitrogen dioxide NO2 0.32
method
UV Fluorescence (1hr, 24hr,
Sulphur dioxide SO2 0.78 0.30 0.10 1yr) or Pararosaniline (1hr,
4hr)
Total suspended Gravimetric

TSP - 0.33 0.10
particulate
Particulate Gravimetric of beta ray or
matter taper element oscillating

PM10 - 0.12 0.05
less than 10 microbalance or dichotomous
microns
Chemiluminescence or UV
Ozone O3 0.20
Absorption photometry
Atomic absorption
Lead Pb 1.5
spectrometer
85
Air Emission Standard for Power Plants
Type of
No. substances or Source Permitted emission value
pollutant
Coal or gas power plant ppm mg/m3
1. With the capacity of not more than 640 NA

300 MW.
1 Sulphur dioxide
2. With the capacity above 300 450 NA
MW, not more than 500 MW
3. With the capacity above 500 MW 320 NA
2 Sulphur dioxide - Natural gas power plant 20 NA
Power plant generating electricity from:

3 Nitrogen oxides
1. Coal 350 NA
2. Fuel 180 NA
3. Natural gas 120 NA
Power plant generating electricity from:

4 Particulate 1. Coal NA 120
substances
2. Fuel NA 120
3. Natural gas NA 60
86
Malaysia

Legislation
1. Environmental Quality Act 1974
a. Any premises used for any industrial or trade purpose, or on which matter is burnt
in connection with any industrial or trade purposes including burning of waste,
whether or not the premises are under section 18 of the act;
b. Any other premises or process that discharges or is capable of discharging air
pollutants into the open air;
c. Any industrial plant; and
d. Any fuel burning equipment.
(Obligation to comply on or before the expiry of five years on which Regulations
come into operation.)
Not available
Environmental Quality (Clean Air) Regulations 2014
1. SOx (SO2 and SO3)
2. NOx (NO and NO2)
3. Hydrogen chloride
4. Hydrogen fluoride
5. Carbon monoxide
6. Total PM
7. Mercury
8. PCDD/PCDF
87
Emission standards
Pollutant Capacity Limit value
SOx >10 MWe 500 mg/m³

NOx >10 MWe 500 mg/m³
HCl >10–<100 MWe 200 mg/m³
HCl ≥100 MWe 100 mg/m³
HF >10–<100 MWe 30 mg/m³
HF ≥100 MWe 15 mg/m³
CO >10 MWe 200 mg/m³

PM >10 MWe 50 mg/m³
Hg >10 MWe 0.03 mg/m³
PCDD/PCDF >10 MWe 0.1 ng TEQ/m3
All coal-fired power plants are required to install continuous emission monitoring systems (CEMS)
that are linked to the Department of Environment (DOE) in real-time.

Department of Environment (DOE)

Malaysian Standards MS1596 or MS 1723 or the Methods published by United States Environmental
Protection Agency or any other standards as determined by DOE.
Monitoring
Reporting
CEMS
Inspection
88
Archive Requirement
Environmental Quality (Clean Air) Regulations 2014:
 The records shall be kept for at least 3 years.
Announcement through official portal (website) of Department of Environment and newspapers
Regular updates of Malaysian Air Pollutant Index (API)
Environmental Quality Act 1974:
Section 46E: ‘the person so convicted to pay the other person the costs and expenses incurred or
compensation for loss or damage to the property and any other costs, in the amount as the court
considers fit’.
Penalty
Any person who contravenes or fails to comply with any provisions of Environmental Quality (Clean
Air) Regulations 2014 shall be liable to a fine not exceeding RM100,000 or imprisonment for a term
not exceeding 2 years or both.

Any issue related to development in the specific local area including CPPs can be addressed by local
government/council. However, all environmental compliance monitoring and enforcement activities
are conducted by DOE through headquarters and state and branch offices.

Approval of the Detailed Environmental Impact Assessment (DEIA) is a mandatory requirement in the
new coal-fired power plant development, being the prescribed activity under the Environment
Quality (Prescribed Activities) (Environmental Impact Assessment) Order 1987. Potential impact to
local community (both positive and negative) and planned interventions will be identified and
assessed under DEIA.
The law does not require a periodical meeting with the local community. However, community
outreach programmes are usually performed by plant operators as part of their corporate social
responsibility.
The law does not require independent inspector.
89
Malaysia

HCl >10–<100 MWe 200 mg/m³
HCl ≥100 MWe 100 mg/m³
HF >10–<100 MWe 30 mg/m³
HF ≥100 MWe 15 mg/m³
CO >10 MWe 200 mg/m³

Hg >10 MWe 0.03 mg/m³
PCDD/PCDF >10 MWe 0.1 ng TEQ/m3
90
Myanmar

Legislation

SOx, NOx, PM, CO, CO2, TVOC (hydrocarbon), O3, lead
Emission standards
Details and describe in annexes 4, 5, and 6
The owner or occupier of any business, material, or place that causes a point source of pollution shall
install or use an on-site facility or controlling equipment to monitor, control, manage, reduce, or
eliminate environmental pollution. If it is not practical, it shall arrange to dispose the waste in
accordance with an environmentally-sound method.
The ministry shall, if the person obtained the prior permission who was impose with administrative
penalty under section 25 fails to comply with the terms and conditions, inform the relevant
government department, government organization authorized to issue licence, permit, or register for
the relevant business, work-site or factory, work shop to enable to take action as may be necessary.
The government department, government organization that received information under
subsection(a) may, after making necessary inquiries, if it is found that any terms and conditions of
environmental conservation contained in the prior permission is not complied with, cancel the issued
licence, permit or register or suspend it for a limited period.
91
Monitoring
The ministry and state and regional government shall continuously monitor the status of air pollution.
The owner or occupiers of any business have the duty to monitor the environmental pollution.
Reporting
The project proponent shall submit monitoring report to the ministry not less frequently than every
6 months, as provided in a schedule in the EMP, or periodically as prescribed by the ministry.
The monitoring reports shall include:
(a) documentation of compliance with all conditions;
(b) progress made to date on implementation of EMP against the submitted implementation
schedule;
(c) difficulties encountered in implementing the EMP and recommendations for remedying those
difficulties and steps proposed to prevent or avoid similar future difficulties;
(d) number and type of non-compliance with the EMP and proposed remedial measure and timelines
for completion of remediation;
(e) accidents or incidents relating to the occupational and community health and safety, and the
environment; and
(f) monitoring data of environmental parameters and conditions as committed in the EMP or
otherwise required.
Ministry of Electricity and Energy shall require operator to report the status of air pollutant emissions.
Inspection
Screening team that is organized by the Ministry inspect frequently. Inspection team that is organized
by the relevant ministries and/or organizations.
Archive Requirement
Generally, coal-fired power plant operator keeps the important data permanently in paper and
electronic files.
Coal-fired power plant publish the status of air pollution at LED screen board in front of power plant.
(example of Tigyit Coal-fired Thermal Power Plant)
92
Non-compliance Penalties Specific administrative
punishment of the ministry
Failure to take reasonable US$2,500 to US$10,000 or -Issue Enforcement Notice
steps to prevent an imminent equivalent Myanmar kyats -Suspension of approval of
threat of damage to the EMP, EMP-CP, or EMP-OP in
environment, social, human whole or in part
health, livelihoods, or -Revocation of approval of
property, where applicable, EMP, EMP-CP or EMP-OP in
based on the EMP, EMP-CP, whole or in part
EMP-OP
Penalty

The (national) government shall endeavour to provide technical advice, other assistance.

State and regional governments participate in public consultation, monitoring, inspection, and
meeting with residents.

The law does not appear to require periodical meetings with local community.
Ministry and operator to hold a stakeholder meeting and public hearing with residents for explanation
and discussion of the situation of coal-fired power plant.
The law does not appear to require an independent inspector.
93
Myanmar
Parameter Unit Guideline value

Coal preparation plant
Conveying, storage, and preparation, gas opacity % 10
Pneumatic coal cleaning equipment opacity % 10
Pneumatic coal cleaning equipment particulate mg/Nm3a 40
Thermal dryer gas opacity % 20
Thermal dryer gas particulate mg/Nm3 70
Ammonia mg/Nm3 30
Carbonyl sulfide + carbon disulfide mg/Nm3 3
Heavy metals(total) mg/Nm3 1.5
Hydrogen sulphide mg/Nm3 10
Mercury mg/Nm3 1
Nitrogen oxides mg/Nm3 200–400b
Particulate matter PM10c mg/Nm3 30–50b
Sulfide dioxide mg/Nm3 150–200b
Volatile organic compound mg/Nm3 150
a
Milligrams per normal cubic meter at specified temperature and pressure.
b Lower value for plants of >100 MW thermal equivalent, higher value for plants of <100 MW thermal
equivalent.
c
Particulate matter 10 micrometres or less in diameter.
94
Thailand

Legislation
Environmental Act
Factory Act
There is no conflict between two acts.
Ministry of environment and Ministry of Industry work with collaboration usually.
The law gives local governments power to establish own emission standard.
But no local government has set own emission standards to date.

PM, SO2, NOx
Power plants with capacity between 10MW and 100MW are required to have an Environmental
Impact Assessment (EIA)
Power plants with capacity 100MW and more are required to have an Environmental and Health
Impact Assessment (EHIA)
Emission permit: not to exceed national standard
Ministry of Industry has power to order suspend CPP operation partially or fully.
20 years ago, Mae Moh CPP was ordered to reduce emissions.
Licensed third party selected by operators check emission data twice a year.
Monitoring station: 5 km away from CPP, monitored pollutants: PM and SO2
Operators should send emission monitoring data to Ministry of Industry with automatic method.
Monitoring
CPP submit EIA report to Ministry of Environment, Ministry of Natural Resources and Ministry of
Energy.
Report: CPP  Central Government  Local Government
Local government has the power to check emission data, but this rarely occurs.
95
Reporting
Twice a year
Inspection
Department of Estate, Ministry of Industry inspects every industry plant.
In case of a large CPP, there is no site visit.
In case of severe accident, Ministry of Environment inspects.
Local government has the power to inspect, but there has been no case to date.
Archive Requirement
The law does not require keeping archives.
Operators' annual report.
Local government does not publish emission data.
During coal transportation by truck, dust is emitted, which is more problematic than air pollution by
CPP in Thailand.

Central government requires CPP to pay compensation, but there is no case.
(It is difficult to find a responsibility of air pollution and evaluate damage and losses.)
Operators pay damages and losses voluntarily, i.e. hospital expanse, medical examination, etc.
Penalty
Industry Act.
Ministry of Industry can pose fines, maximum B200,000.

When a regulation is enhanced, the central government holds a meeting with stakeholders before
amendment.

There is an expert at the local university.

Regular meeting between CPP and residents is held every 3 months.
96
Independent inspector is not required.

Thailand
Emission standard
Type and Size of Power Plant
(PM) (mg/m3) (SO2) (ppm) (NOx) (ppm)
New Power Plant (since 15 January 2010)
1. Power Plant Size < 50 MW 80 360 200
2. Power Plant Size > 50MW 80 360 200
Power Plant (31 January 1996–15 January 2010)
1. Power Plant Size > 500 MW 320
2.Power Plant Size 300–500 MW 120 450 350
3. Power Plant Size < 300 MW 640
Existing Power Plant (before 31 January 1996)
1. Mae Moh
Unit 1–3 180 1300 500
Unit 4–7
180 320 500
Unit 8–13
Total SO2 Loading of Mae Moh Unit 1–13 shall not be more than 11 ton/hr
2. Other Power Plant 320 700 400
97
Annex 4
SOx Regulations
1. Selected OECD countries

Australia
(A) National5
The current standards and goals for the Ambient Air Quality NEPM (National Environment
Protection Measure)
Maximum Maximum
SO2 1 day 0.08 ppm 1 day a year
The National Guidelines for Control of Emission of Air Pollutants from New Stationary
Sources 1985
Pollutant Plant type Emission limits (mg/m3)
fuel-burning equipment 200 (expressed as SO3) 0.075
sulphuric acid mist and sulphur
sulphuric acid plants or plants kg/t of 100% acid or equivalent
trioxide (as SOx)
producing sulphur trioxide
(B) (Example of State) New South Wales (NSW)6

Schedule 4 Standards of concentration for scheduled premises: general activities and
plant
General standards of concentration
Group 1 200 mg/m3
SO3 Any activity or plant
Group 2, 3, 4, 5 or 6 100 mg/m3

Group 2: After 1 January 1972 and before 1 July 1979
5
Source: IEA Clean Coal Centre.
6
Source: Outline of Protection of the Environment Operations (Clean Air) Regulation 2010.
98
Germany7
Emission limit values for coal combustion plants in German legislation: TA-Luft 2002
Applicable to plants with a thermal input of less than 50 MW
Pollutant Plant size (MWth) Daily emission limit value (mg/m3)
All 1300 (for hard coal)
SO2 (SO2 + SO3) All 1000 (other fuels)
All 3501 (fluidised bed combustion)
Applicable to new plants (in operation after 7 January 2014) with a thermal input of 50
MW or more.
Plant size Emission limit value (mg/m3)
Pollutant (MWth) Daily mean value Half-hourly mean Annual mean value
value
50-100 400 800
350 (fluidised bed) 700 (fluidised bed)
>100-300 200 400
SOx (SO2 + SO3) >300 150 300
200 (circulating or 400 (circulating or
pressurised fluidised pressurised fluidised
bed) bed)
Applicable to existing plants (in operation before 7 January 2014) with a thermal input of
50 MW or more.
Pollutant Plant size Emission limit value (mg/m3)
(MWth) Daily mean value Half-hourly mean Annual mean value
value
50–100 400 800
350 (fluidised bed) 700 (fluidised bed)
SOx (SO2 + SO3) >100–300 200 400
>300 150 300
200 400
7
99
Japan
(A) Air Pollution Control Act
q = K * 10-3 * He2
q: Maximum permissible limit of SOx (m3N/h)
He: Adjusted height of the Outlet (m)
K: Area of classification
General regulation K: from 3.0 to 17.5
Special regulation (new construction, specified area) K: from 1.17 to 2.34
He = Ho+0.65 (Hm+Ht)
Hm = 0.795√(Q*V) /{1+(2.58/V)}
Ht = 2.01*10-3*Q*(T-288)*{2.30logJ+(1/J)-1}
J = (1/√(Q*V))[1460-296*{V/(T-288)}]+1
He Adjusted height of the Outlet (m)
Ho Actual height of the Outlet (m)
Q Quantity of emission at 15°C (m3/s)
V Discharge rate of emission (m/s)
T Temperature of emission (absolute temperature)
(B) Life environment relevant ordinance (Yokohama City)

Sulphur content in emissions: 4 SO2 equivalent grams/1 fuel oil equivalent kg
combustion
Republic of Korea
- In-cheon: 20 to 25ppm (O2: 6%)
- Yeou-su: 30 ppm (O2: 6%)
100
United States
(A) 40 CFR part 50 (air quality)
Primary/ Averaging
Secondary time
primary 1 hour 75 ppb 99th percentile of 1-hour daily
maximum concentrations, averaged
SO2 over 3 years
secondary 3 hours 0.5 ppm Not to be exceeded more than once
per year
Primary standards provide public health protection, including protecting the health of "sensitive"
and buildings.
(B) 40 CFR part 60 subpart Da (stationary source)

Applicability:
SO2
1971–1978 520 ng/J heat input
Sep 1978–1997 520 ng/J heat input and 90% reduction (or 70% reduction where <260 ng/J)
180 ng/J gross output
1978 Mar 2005
65 ng/J heat input
Commenced construction: 180 ng/J gross output
Mar 2005–May 2011 95% reduction
Commenced reconstruction:
65 ng/J heat input
Mar 2005–May 2011
95% reduction
Modified: Mar 2005–May 2011 65 ng/J heat input
90% reduction
130 ng/J gross energy output
Construction or reconstruction after:
140 ng/J net energy output
3 May 2011
97% reduction
Modified after: 3 May 2011
90% reduction
101
2. ASEAN countries, China, and India
Cambodia8
Sulphur Dioxide (SO2)
mg/Nm3 500 2000
Dry, 0 0c, 1atm, 6% O2
China9
Emission standards for air pollutants from coal-fired power plants (GB13223-2011)
GB13223-2011 came into force on 1 January 2012, replacing GB13223-2003
Pollutant Application Emission limit value Location of monitoring and emission control
100
New boilers
200a
SO2, mg/m3 Stack and flue
200
Existing boilers
400a
a
Emission limits apply to plants in Guangxi Zhuang Autonomous Region, Chongqing Municipality, Sichuan
Province, and Guizhou Province.
Special air pollutant emission control requirements for key regions

Coal-fired power plants located within the key regions should meet the special emission limit values in
the following table. The key regions include Beijing City, Tianjin City, Hebei Province, Yangzi River Delta,
Pearl River Delta, Central Liaoning Province, Shandong Province, Wuhan City and surrounding areas,
Changsha City, Zhuzhou City, Xiangtan City, Chengdu and Chongqing City, coastal areas of Fujian Province,
Central and Northern Shanxi Province, Guanzhong Region of Shaanxi Province, Gansu Province, Ningxia
Province, and Wulumuqi (Ürümqi, Xinjiang Uyghur Autonomous Region).
SO2, mg/m3 all 50 Stack and flue
8
Source: WG member
9
Source: IEA Clean Coal Centre
102
India10
(A) Stack heights for thermal power plants

Power generation capacity Height (m)
(MW)
<200/210 H-14(Q)0.3 where Q is the emission rate of SO2 in kg/h and H is the stack
height in metres
≥200/210–<500 220
≥500 275
Steam generating capacity, Height, m
t/h
<2 half times the neighbouring building height or 9 m (whichever is more)
>2–5 12
>5–10 15
>10–15 18
>15–20 21
>20–25 24
>25–30 27
>30 30 or H = 14(Q)0.3 where Q is the emission rate of SO2 in kg/h and H is
the stack height in metres (whichever is more)
(B) National Ambient Air Quality Standards

Time weighted Concentration in ambient air Measurement method
average Industrial, residential, Ecologically sensitive
Pollutant
rural and other areas area (notified by
central government)
Annual 50 20 improved West and
3
SO2, μg/m 24 hours 80 80 Gaeke ultraviolet
fluorescence
10
Source: IEA Clean Coal Centre
103
Indonesia11
Maximum level (mg/Nm3)

Parameter
A B
Sulphur Dioxide (SO2) 750 750
A. For CPP in operation before 1 December 2008.

B. For CPP in operation after 1 December 2008.
Notes:
a. Gas volume is measured under standard condition (25°C and 1 atm).
c. All parameters corrected by O2: 7 %
d. For CPP with CEMS installed, the imposition of emission quality standard is for 95% of normal
operation time for 3 months.
Lao PDR12
(A) Ambient Air Quality Standard
Average time unit: mg/m3
Pollutant Hours Method of measurement
1 month 1 year
1 hr 8 hr 24 hr
UV Fluorescence (1 hr, 24 hr, 1 yr)
SO2 0.78 - 0.30 - 0.10
or Pararosaniline (1 hr, 4 hr)
(B) Air Emission Standard for Power Plants

Pollutant Source Permitted emission value
Coal or Gas Power Plant ppm mg/m3
1. With the capacity of not more than 300 MW 640
SO2 2. With the capacity above 300 MW, not more than
450
500 MW
3. With the capacity above 500 MW 320
11
Source: WG Member.
12
Source: WG Member.
104
Malaysia13
Myanmar14
Air Emission Level
Pollutant Unit Guideline value
SO2 Mg/Nm3 150-200
Lower value for plants of > 100 MW thermal equivalent, higher value for plants of <100 MW thermal
equivalent.
Philippines15
National Emission Standards for Sulphur Oxides for Stationary Sources (DENR
Administrative Order No. 2000 - 81, 7 Nov 2000)
Existing source New source
fuel burning fuel burning
other source other source
equipment equipment
emission limit, mg/m3 1500 as SO2 1000 as SO3 700 as SO2 200 as SO3
Singapore16
Environmental Protection and Management (Air Impurities) Regulations (effective from 1
Jan 2001, as revised in 2002 and 2008)
Standards for air pollutants emissions from stationary sources
Pollutant Plant type Emission limit value, mg/m3
SO2 any trade, industry or process (non-combustion 500
sources)
The emissions of sulphur dioxide into the air from fuel combustion are controlled by limiting the sulphur
content in fuels used by industries to not more than 1% by weight. Industries sited near urban areas are
required to use fuel with a lower sulphur content.
13
Source: WG Member.
14
Source: WG Member.
15
16
105
Thailand17
(1) Emission standard from coal-fired power plants
(A) New Power Plant (since 15 January 2010)
Pollutant Power plant size Unit Emission standard
<50 MW ppm 360
SO2
>50 MW ppm 180
Notification of the Ministry of Natural Resources and Environment published in the Royal Government
Gazette, Vol.127 Part 7, 15 January 2553 (2010).
(B) Power Plant (31 January 1996 – 15 January 2010)

Pollutant Power Plant Size Unit Emission standard
>500 MW ppm 320
SO2 300-500 MW ppm 450
<300 MW ppm 640
Notification of the Ministry of Science, Technology and Environment published in the Royal Government
Gazette, Vol.113 Part 9, page 220, 30 January 2539 (1996).
(C) Mae Moh Power Plant

Pollutant Power Unit Unit Emission Standard
Unit 1–3 ppm 1300
Unit 4–7 ppm 320
SO2
Unit 8–13 ppm 300
Unit 1–13 Total SO2 Loading not exceed 11 tons/hour
Notification of the Ministry of Science, Technology and Environment No.3, B.E.2544 (2001), 29 January
B.E.2544 (2001), published in the Royal Government Gazette, Vol.118 special Part 24, 16 March B.E.2544
(2001).
(2) Ambient Air Standards

Pollutant Average Emission Standard
1 year Not exceed 0.04 ppm (0.10 mg/m3)
SO2 24 hr Not exceed 0.12 ppm (0.30 mg/m3)
1 hr Not exceed 0.3 ppm (780 μg /m3)
Notification of National Environmental Board No.10, B.E.2538 (1995) under the Enhancement and
Conservation of National Environmental Quality Act B.E.2535 (1992), published in the Royal Gazette No.112
Part 52, 25 May B.E.2538 (1995).
Part 104 D, 22 September B.E.2547 (2004).
17
Source: WG Member.
106
Viet Nam
Emission standards for thermal power plants were released on 16 November 2009
Vietnam’s standards are based on the size of operation and location of the
facility. The relevant emission standard for a pollutant is calculated using the following
formula:
Emission limit in mg/m3 = C x Kp x Kv
where C is the concentration parameter
Kp is the power plant size coefficient
Kv is the region coefficient.
Concentration parameter, mg/Nm3
Pollutant Existing plants operating before 17 October Plants operating since 17 October 2007 and
2007 and valid until 31 December 2014 all plants after 1 January 2015
SO2 1500 500
Power plant size, MW Kp coefficient

P ≤ 300 1.0
300 <P ≤ 1200 0.85
P> 1200 0.7
Zoning area Kv coefficient

cities, historic, cultural or natural heritage 0.6
inner city and urban suburbs 0.8
industrial zones, suburbs, and outskirts 1.0
rural 1.2
rural mountains 1.4
107
Annex 5
NOx Regulations
Australia
(A) National18
The current standards and goals for the Ambient Air Quality NEPM (National Environment
Protection Measure)
Maximum Maximum
NO2
Sources 1985
Pollutant Plant type Emission limits, mg/m3
power generating boiler >30 MWe 800
Nitrogen oxides (as NO2) power generating boiler <30 MWe 500
industrial steam boiler 500

Schedule 3 Standards of concentration for scheduled premises: activities and plant used
for specific purposes
Emission standards for NOx
Industry Activity or plant Standard of concentration
boiler, operating on fuel other than gas, Group 1, 2, 3, or 4 2500 mg/m3
Power including one used in connection with an Group 5 800 mg/m3
generation electricity generating system with a Group 6 500 mg/m3
capacity of ≥30 MW
18
19
108
Group 5: After 1August 1997 and before 1 September 2005
Germany20
Pollutant Plant size, MWth Daily emission limit value, mg/m3
≥10 400
NOx (NO + NO2) <10 500
all 300 (fluidised bed combustion)
MW or more.
Pollutant Plant size Emission limit value (ELV), mg/m3
MWth Daily mean value Half-hourly mean Annual mean value
value
50–100 300 600 250
400 (pulverised lignite) 800 (pulverised 250
>100–300 200 lignite) 100
NOx (NO + NO2) >300 150 400 100
200 (pulverised lignite) 300 100
400 (pulverised
lignite)
20
109
50 MW or more.
Pollutant Plant size Emission limit value (mg/m3)
value
50–100 300 600
400 (pulverised lignite) 800 (pulverised
NOx (NO + NO2) >100–300 200 lignite)
>300 200 400
400
Japan
200ppm (O2: 6%)
NO2: 100ppm
NOx: 200ppm
Republic of Korea
- In-cheon: 15ppm (O2: 6%)
- Yeou-su: 30 ppm (O2: 6%)
110
United States
Primary/ Averaging
secondary time
over 3 years
NO2
primary
and 1 year 53 ppb Annual Mean
secondary
and buildings.

Applicability:
NOx
subbituminous: 210 ng/J heat input;

Sep 1978–1997
other coal types: 260 ng/J heat input
New plant: 200 ng/J gross output;

1978–Mar 2005
Reconstructed: 65 ng/J heat input
Mar 2005–May 2011
130 ng/J gross output;

Commenced reconstruction: Mar 2005–May 2011
47 ng/J heat input

Modified: Mar 2005–May 2011
65 ng/J heat input

Construction or reconstruction after: 3 May 2011
95 ng/J net output
Modified after: 3 May 2011 140 ng/J gross output
111
Cambodia21
Nitrogen Oxide (NO2)

mg/Nm3 1000 750
Dry, 0 0c, 1atm, 6% O2
China22
NOx (as NO2), 100

all stack and flue
mg/m3 200a
a.
Emission limit applies to arch fired furnaces, existing Circulating Fluidized Bed (CFB) power generating
boilers, and power generating boilers commissioned or which received approval for construction before 31
December 2003.

NOx (as NO2),

all 100 Stack and flue
mg/m3
21
Source: WG member.
22
112
India23
(A) National Ambient Air Quality Standards
Time-weighted Concentration in ambient air Measurement method
average Industrial, Ecologically sensitive

Pollutant
residential, rural, and area (notified by
other areas Central Government)
Annual 40 30 modified Jacob &
24 hours 80 80 Hochheiser (Na-

NO2, μg/m3
Arsenite)
chemiluminescence
Indonesia24

Parameter
A B
Nitrogen oxide (NOx) stated as NO2 850 750
A. For CPP that have been operated before 1 December 2008;
B. For CPP that have been operated after 1 December 2008.
Notes:
c. All parameters corrected by O2: 7 %
d. For CPP with CEMS installed, the imposition of emission quality standard is for 95% of normal
23
24
Source: WG Member.
113
Lao PDR25
Average time unit: mg/m3
Pollutant Hours Method of measurement

1 month 1 year
1 hr 8 hr 24 hr
NO2 0.32 - - - - chemiluminescence method

Power plant generating electricity from: ppm mg/m3

Oxide of Nitrogen
1. Coal 350
Malaysia26
Myanmar27
Air Emission Level
Pollutant Unit Guideline Value
Nitrogen oxides Mg/Nm3 200-400
equivalent.
Philippines28
National Emission Standards for Nitrogen Oxides for Stationary Sources (DENR
Existing source New source
fuel burning fuel burning
other source other source
equipment equipment
Emission limit, mg/m3 1500 as NO2 1000 as NO2 1000 as NO2 500 as SO2
25
Source: WG Member.
26 Source: WG Member.
27 Source: WG Member.
28 Source: IEA Clean Coal Centre.
114
Singapore29
Environmental Protection and Management (Air Impurities) Regulations (effective 1 Jan
2001, as revised in 2002 and 2008)
NOx asNO2 any trade, industry, process, or fuel burning 700
equipment
Thailand30
(1) Emission standard from coal-fired power plants
Pollutant Power Plant Size Unit Emission standard
<50 MW ppm 200

NOx as NO2
>50 MW ppm 200
Gazette, Vol.127 Part 7, 15 January B.E.2553 (2010).
(B) Power Plant (31 January 1996–15 January 2010)

Pollutant Unit Emission standard
NOx as NO2 ppm 350
Gazette, Vol.113 Part 9, page 220, 30 January B.E.2539 (1996).

Pollutant Power Unit Unit Emission standard
Unit 1-3 ppm 500
NO2 Unit 4-7 ppm 500
Unit 8-13 ppm 500
Notification of the Ministry of Science, Technology and Environment No.3, B.E.2544 (2001) 29 January
(2001).
29
30
Source: WG Member.
115
Pollutant Average Emission standard
1 year Not exceed 0.17 ppm (0.32 mg/m3)

NO2
1 hr Not exceed 0.03 ppm (0.057 mg/m3)
Part 52, 25 May B.E.2538 (1995).
Viet Nam
Viet Nam’s standards are based on the size of operation and location of the facility. The
relevant emission standard for a pollutant is calculated using the following formula:

Pollutant Existing plants operating before 17 October Plants operating since 17 October 2007
2007 and valid until 31 December 2014 and all plants after 1 January 2015
650 with coal volatile content >10%

NOx (as NO2) 1000
1000 with coal volatile content ≤10%
P ≤ 300 1.0
300 <P ≤ 1200 0.85
P> 1200 0.7
116
cities, historic, cultural, or natural heritage 0.6
rural 1.2
rural mountains 1.4
117
Annex 6
PM Regulations
Australia
(A) National31
The current standards and goals for the Ambient Air Quality National Environment
Protection Measure (NEPM)
Maximum Maximum
1 day 50 μg /m3 None
PM10
1 year 25 μg /m3 None
1 day 25 μg /m3 None
PM2.5
1 year 8 μg /m3 None
The advisory reporting standards and goals for PM2.5 are:

Pollutant Averaging period Maximum concentration
1 day 20 μg/m3 by 2025
NO2.5
1 year 7 μg /m3 by 2025
The review was completed in 2011.
Sources 1985
Pollutant Plant type Emission limits, mg/m3
power plant boiler 80
other coal-burning boiler 250
Particulate any other trade, industry process, 250
industrial plant, or fuel-burning
equipment
31
118
Schedule 3 Standards of concentration for scheduled premises: activities and plant used
for specific purposes
Emission standards for particulates
Group 1 400 mg/m3
Any activity or plant using a liquid or solid Group 2, 3, or 4 250 mg/m3
PM
standard fuel or a non-standard fuel Group 5 100 mg/m3
Group 6 50 mg/m3

Germany33
Pollutant Plant size, MWth Daily emission limit value, mg/m3
≥5 20
Dust
<5 50
MW or more.
Pollutant Plant size, Emission limit value (ELV), mg/m3
value
all 10 20
Dust
>300 10
32
33
119
50 MW or more.
Plant size, Emission limit value (ELV), mg/m3

Pollutant MWth Daily mean value Half-hourly mean Annual mean value
value
all 20 40 10
Dust
>300
Japan
100mg/m3N (O2: 6%)

0.05g/m3N
Republic of Korea
- Established before 2001: 25mg/Sm3 (O2: 6%)
Voluntary (operators of new CPP)
- In-cheon: 5mg/Sm3 (O2: 6%)
- Yeou-su: 8mg/Sm3 ppm (O2: 6%)
120
United States
Primary/ Averaging
Secondary time
primary 1 year 12.0 μg/m3 annual mean, averaged over 3 years
secondary 1 year 15.0 μg/m3 annual mean, averaged over 3 years
PM2.5 primary
98th percentile, averaged over 3
and 24 hours 35 μg/m3
PM years
secondary
primary
PM10 and 24 hours 150 μg/m3
per year on average over 3 years
secondary
and buildings.

Applicability:
PM
Sep 1978–1997 13 ng/J heat input
1978–Mar 2005
Mar 2005–May 2011 6.4 ng/J heat input
Commenced reconstruction: Mar 2005–May Or: 13 ng/J input and 99.9% reduction
2011
Modified: Mar 2005–May 2011 6.4 ng/J heat input
Or: 13 ng/J input and 99.8% reduction
Construction or reconstruction after: 3 May 2011
12 ng/J net output
Modified after: 3 May 2011 6.4 ng/J heat input
Or: 13 ng/J input and 99.8% reduction
121
Cambodia34
Particulates
mg/Nm3 400 50
Dry, 00c, 1atm, 6% O2
China35
Pollutant Application Emission limit value Location of monitoring and emission
control
Particulate, mg/m3 all 30 stack and flue

Pollutant Application Emission limit value Location of monitoring and emission
control
Particulate, mg/m3 all 20 Stack and flue
India36
(A) Emission limits for particulate matter (PM) from thermal power plants
Plant size, MW Emission limit, mg/Nm3
<210 350
≥210 150
34
Source: WG member.
35
36
122
(B) National Ambient Air Quality Standards
Time Concentration in ambient air Measurement method
weighted Industrial, residential, Ecologically sensitive
Pollutant
average rural, and other areas area (notified by
central government)
Annual 60 60 gravimetric TEOM beta
PM10, μg/m3
24 hours 100 100 attenuation
Annual 40 40 gravimetric TEOM beta
PM2.5, μg/m3
24 hours 60 60 attenuation
Indonesia37

Parameter
A B
Total Particulate 150 100
Opacity 20% 20%
A. For CPP that have been operated before 1 December 2008.

B. For CPP that have been operated after 1 December 2008.
Notes:
c. All parameters corrected by O2 : 7 %
d. For CPP with CEMS installed, the imposition of emission quality standard is for 95 % of normal
37
Source: WG Member.
123
Lao PDR38
Average Time Unit: mg/m3
Pollutant Hours Method of Measurement
1 month 1 year
1 hr 8 hr 24 hr
Total
Suspended - - 0.33 - 0.10 gravimetric
Particulate
gravimetric or beta ray or
taper element oscillating
PM10 .05 - 0.12 - 0
microbalance or
dichotomous

Power Plant Generating Electricity From: ppm mg/m3
Particulate Substances
1. Coal - 120
Malaysia39
Myanmar40
Air Emission Level
Pollutant Unit Guideline value
3
PM10 mg/Nm 30-50
equivalent.
38
Source: WG Member.
39
Source: WG Member.
40
Source: WG Member.
124
Philippines41
National Emission Standards for Particulate Matter for Stationary Sources (DENR
Emission source
Fuel burning equipment
Other stationary
Urban and industrial
Other area sources
area
Emission limit, mg/m3 150 200 200
Singapore42
Environmental Protection and Management (Air Impurities) Regulations (effective 1
January 2001, as revised in 2002 and 2008)
any trade, industry, process, 100
fuel burning equipment or
Particulate matter
industrial plant (except for any
cold blast foundry cupolas)
where there is more than one flue, duct or chimney in any scheduled premises, the total
mass of the particulate emissions from all such flues, ducts, or chimneys divided by the
total volume of such emissions shall not exceed 100 mg/m3 and the particulate emissions
from each of such flue, duct or chimney shall not exceed 200 mg/m 3 at any point of time.
Thailand43
(1) Emission standards from coal-fired power plants
Pollutant Power plant size Unit Emission standard
<50 MW mg/m3 80
Particulate
>50 MW mg/m3 80
Gazette, Vol.127 Part 7, 15 January B.E.2553 (2010).
41
42
43
Source: WG Member.
125
(B) Power Plant (31 January 1996–15 January 2010)
Pollutant Unit Emission standard
Particulate mg/m3 120
Gazette, Vol.113 Part 9, page 220, 30 January (1996).

Pollutant Power unit Unit Emission standard
3
Unit 1-3 mg/m 180
NO2 Unit 4-7 mg/m3 180
3
Unit 8-13 mg/m 180
Notification of the Ministry of Science, Technology and Environment No.3, B.E.2544 (2001) 29 January
(2001).

Pollutant Average Emission standard
24 hr Not exceed 0.33 mg/m3
Total Suspended Particulate
PM10
PM2.5
Part 52, 25 May B.E.2538 (1995).
Part 37, 24 March B.E.2553 (2010).
126
Viet Nam
Viet Nam’s standards are based on the size of operation and location of the
facility. The relevant emission standard for a pollutant is calculated using the following
formula:

Existing plants operating before 17 Plants operating since 17 October 2007
Pollutant
October 2007 and valid until 31 and all plants after 1 January 2015
December 2014
Particulate 400 200
matter

P ≤ 300 1.0
300 <P ≤ 1200 0.85
P> 1200 0.7

cities, historic, cultural, or natural heritage 0.6
rural 1.2
rural mountains 1.4
127

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Mitsuru Motokura

Leader of the Working Group

Leader of the Working Group

List of Project Members vi

Chapter 2. Summary of Management System in ASEAN, China and India 9

Chapter 3. Summary of Management System in Selected OECD Countries 25

Chapter 4. Comparison of Management System between Selected ASEAN and 35

Chapter 5. Policy Recommendation 41

Annex 1 Environmental Legislation in Selected Countries 45

MR VORAWUT POONTHARIGPUN: Environmental Scientist, Project Environment Division, Electricity

Figure 1 Share of coal-fired power generation in selected ASEAN 3

AEC ASEAN Economic Community

Country SOx NOx PM

Figure B: Emission standards for new CPPs in selected countries (NOx)

1. Background and objectives of the study

(A) Survey of the Status of Emission Regulations

 Existence or non-existence of regulations (central and/or municipal government)

The following items will be only applied to central government regulations

 Process of regulation development

 Management system of power company (measurement, record, verification, report)

 Management system of regulator (organization, human resources, checking)

 How to enforce (authorization, order, penalty)

 Support for power company (technical guidelines, finance, education)

(B) Comparative Analysis with Developed Country

(C) Derive Policy Recommendations

3. Focus area of fiscal year (FY) 2016 study: survey

(A) Why focus on air pollution from CPP?

Figure 1: Share of coal-fired power generation in selected ASEAN countries

Figure 2: Coal-fired power generation in ASEAN

a) Sulphur dioxide (SOx)

b) Nitrogen dioxide (NOx)

NOx in the atmosphere contributes to nutrient pollution in coastal waters.

c) Particulate matter (PM)

Particulate matter includes:

4. Working Group activities in fiscal year 2016

Summary of Management Systems in ASEAN, China, and India

1. Survey of management systems in ASEAN countries

(A) Legislation (National)

Cambodia 1. Air Pollution Control Act (Ministry of Environment)

China Environmental Protection Law (1989)

India Prevention and Control of Pollution Act, 1981 (amended in 1987)

Environment (Protection) Act (No. 29 of 1986, 23 May 1986, last amended in

The implementation of power plant projects requires clearance from the

Malaysia 1. Environmental Quality Act 1974

2. Environmental Quality (Clean Air) Regulations 2014

Myanmar Environmental Conservation Law 2012

Environmental Conservation Rule 2014

National Environmental Quality (Emission) Guideline (2015)

Environmental Impact Assessment Procedure 2015

DENR Administrative Order No. 2000 - 81, 7 Nov 2000)

Singapore Environment Pollution Control Act (1 Apr 1999)

Environmental Protection and Management Act (1 Jan 2008)

Environmental Protection and Management (Air Impurities) Regulations (1

Thailand Environmental Act

There is no conflict between the two Acts.

Emission standards for thermal power plants were released on 16 November

a. Emission quality standards for business and/or activities of a thermal

b. Additional parameters outside the emission quality standards for business

Malaysia Not available

Myanmar Environmental Conversation Law 2012