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J. Preparation and Presentation of Reports of
Practical Working Groups
On their return to the main workshop venue each team completed the worksheets
in the EnTA Manual and prepared their presentations.
The first team noted many shortcomings in the current system for the
collection, transport and storage of used lead acid batteries at the plant, and
identified several new technologies that could be employed to improve
environmental performance, both off- and on-site. These options included a
railway system for battery transportation, a well informed system for collection
and transportation, short term fixes to problems plus a "just in time"
approach, and a zero discharge wastewater treatment plant. Each of these options
was subjected to an environmental assessment, resulting in recommendations as to
which options might be considered for adoption by plant management.
The second team considered the environmental benefits that might arise from
the incorporation of the PLACID and/or PLINT processes at the plant, leading to
a recommendation that plant management consider such technological improvements.
Feedback from the group included:
- The goal of the assessment and the goal of the technology are two different
things;
- The preferred option might be different if cost is, or is not, a factor;
- An issue is whether to consider costs implicitly or explicitly; but if there
are serious concerns about the economics of the technology, a return on
investment (ROI) and a cost-benefit analysis should be recommended, over and
above the EnTA;
- EnTA can lead into, and facilitate economic analysis, more detailed
environmental analysis and government policy analysis;
- If economic aspects are integrated into the assessment, questions such as
"can wastes be turned into a by-product?" will more likely be
addressed;
- There is a need to internalise all the environmental costs;
- Government assistance might be required to support a technology, or else it
might fail;
- While it is appropriate for the assessment to focus on the technology, it is
important to realise that the technology will be a success only if it is
supported by an integrated strategy;
- The Manual should include a preface to explain that a technology assessment
decision is not made in a vacuum - while the private sector can make an effort,
the added support of government is often needed; and
- The team recommended a further case study based on PRI, in which the current
technology is compared to the PLACID technology; the technology and the
engineering would have to be on a comparable basis, with the same capacity for
the plant and the same social and other conditions; these would serve as inputs
to the EnTA process.
The third team identified several ways in which the environmental performance
of the existing plant could be improved through the introduction of technologies
that build on the currently employed pyro-metallurgical processes. Thus the
current operation provided the benchmark.
Feedback from the group included the following:
- There is confusion over whether the goals are of, or for, the technology -
this can be clarified by thinking of the goals as the outcomes the technology is
intended to achieve;
- EnTA is not always the end of the assessment - for example, it might
highlight the need for more information, such as the undertaking of an economic
analysis;
- The assessment is subjective, suggesting the need for more information; but
more information may not reduce the subjectivity, or the uncertainties;
- If there are issues of concern, more detailed, rigorous and quantitative
analyses may well be warranted;
- Despite the presence of a number of technical experts in the team, there was
still insufficient information on which to base judgements - this highlights the
need for more consultation, leading to more information being available;
- Step 4 calls for differentiation of subjective judgements, such as
identifying the difference between a slight impact with high level of certainty
and a major impact with a low level of certainty;
- Given that the goal is to optimize the recovery of lead, with maximum
efficiency, the Manual does little to identify the pressures and levers related
to the industry - for example, there is no reflection of the importance of
different price factors, such as the difference in cost between primary and
secondary lead; the cost pressure on the technology to be selected is not
reflected in the assessment tool; and
- EnTA should also consider the impact of trade liberalization - for example,
cheap battery imports increase the pressure on the secondary lead industry.
Following the presentations by the three teams, the resource persons
participating in the workshop provided constructive feedback to the working
groups. The feedback was a mix of additional technical information that the
teams might have included in their assessment, and guidance as to how their
assessment might have been improved by consideration of key information.
The teams were also urged to reflect on the adoption of different approaches and
suggestions, and how a more rigorous assessment might be undertaken outside the
training environment. It was also pointed out that no one person has all the
expertise and knowledge needed in an EnTA - a multidisciplinary team approach
was required to guarantee the best results. The comment was also made that EnTA
does have a role in encouraging the use of environmentally friendly
technologies. It is a tool that helps make decisions at enterprise level, in
consultation with regulators and community representatives. EnTA also
facilitates a comparative analysis.
But with respect to the case study it was pointed out that lead metal prices
are at their lowest ebb, in real terms, since systematic recording of prices
began at the end of the 19th century. As a result, the competitive position of
primary materials, versus recovered materials, has increased. Also,
pyro-metallurgically produced secondary lead products have difficulty competing
on the basis of purity. Overall, certain secondary materials can be at a
competitive disadvantage. Tightening of the environmental requirements can
increase the used battery recovery rates, but it can also reduce profit margins
and discourage investment. Reflecting the costs of environmental damage in the
product costs adds to the problem. So governments have a key role to play, in
that they can encourage implementation of technologies that are drastically cost
cutting. Governments may thus need to assist the private sector. One way would
be to tax the primary material so that secondary lead becomes more cost
competitive. Any action requires development of a plan that is comprehensive and
provides a mix of incentives, restrictions and even penalties.
Thus while EnTA is useful at enterprise level, there is also a need for
national policy analysis to ensure that policy is supportive of achieving the
identified national environmental and other goals. There is also a need to
involve the government in any follow-up activities after the EnTA. In that way
everyone will benefit from the EnTA being undertaken.
However, EnTA is not a "silver bullet" - it is one of many tools.
The workshop is an important opportunity to learn how to improve EnTA as a tool.
As a tool, EnTA makes an assumption - that there is an enlightened government
and industry. EnTA is a "process tool" so some are comfortable with
the process, while others will be uncomfortable. This raises questions as to who
are the target audience for EnTA and does there need to be specialised training
for EnTA - does a company need to hire an EnTA specialist?
The target audience needs to be more clearly identified - different
information is required and expertise needed if the target audience is the
enterprise or the regulator. Another issue is the ideal composition of the
assessment team.
There is a need to clarify the relationship between EIA and EnTA - for
example, in the Philippines the priority for industry and the regulator is the
EIA, so what is the role for EnTA? It is important to recognise that, in
general, the EIA is obligatory while EnTA is voluntary. Perhaps EnTA can best be
used to prevent the enterprise from reaching the stage of doing an EIA on an
unfeasible technology or other proposal.
EnTA needs to be flexible. In this respect an advantage comes from the fact
that the worksheets in the Manual are in electronic form, so they can be
expanded and modified, as the situation requires.
Again in the context of the case study, a challenge for EnTA is that in its
present form it does not give rise to a framework for developing a strategy for
improving the environmental outcomes associated with the activities of the
informal sector, other than emphasising that many of the current practices are
unacceptable.
The field trip was considered to be an excellent opportunity to evaluate a
real world activity, rather than engage in EnTA on a theoretical basis.
K. Preparation of Personal Action Plans
In the concluding stages of the workshop all participants were invited to
prepare and share their personal actions plans for follow-up activities related
to EnTA and the tools and experience they had acquired at the workshop.
They were asked to develop their action plans under two headings:
- Actions that can be undertaken without assistance in addition to that
already available in the course of current employment; and
- Actions that can be undertaken only if additional assistance is available.
Participants were also advised to provide a timetable for the planned
actions.
The resulting personal action plans are presented in Annex 4.
In general, most action plans included aspects of the following:
- EnTA will be further evaluated and applied in the domestic situation, with
different applications and approaches - e.g. treatments, adaptation, innovation;
- Multi-sector training and consultation will be undertaken;
- The policy environment for the implementation of EnTA will be developed in
the home country; and
- The tool will be refined (e.g. improve precision, and include financial and
economic analyses).
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