The "Regulations for the Establishment and Management of Air Pollution Control Units and Personnel" were promulgated and implemented on August 6, 2019, in accordance with the amendments to the Air Pollution Control Act. Since then, practical operations can be further refined, addressing issues such as (1) incomplete alignment of responsibilities of personnel with the newly revised Air Pollution Control Act and its subsidiary laws; (2) administrative procedures that do not substantively impact air pollution-related activities, with penalties being disproportionately heavy and not adhering to the principle of proportionality; (3) differences in training qualifications and courses for personnel, with no differentiation in practical work; (4) vague definitions of terms such as concurrent, full-time, and specialized positions, lacking clear practical criteria for determination; (5) some public and private places that should apply for permits or undergo regular inspections not requiring responsible personnel according to the law, and so on.
In summary, to enhance the management system of responsible personnel, this project has conducted a current situation inventory to understand the current manpower allocation. Through regulatory comparative analysis, questionnaire surveys, and interviews with air pollution control personnel, insights into the practical operational status have been gained. Based on the information collected and consolidated, a draft amendment to the management regulations that can address current obstacles has been proposed. In addition to regulatory adjustments, simultaneous reviews and improvements of training courses for responsible personnel and the qualification management of inspectors for permits for fixed pollution sources are underway. The proposed amendment and adjustment plans will be consulted, discussed, and negotiated with experts, stakeholders, local authorities, and relevant agencies to gather opinions on the amendments and explore the feasibility and appropriateness of related institutional research directions. Additionally, through the planning and development of the Fixed Pollution Source Air Pollutant Emission Testing Operation Platform, it will support the effective and smooth implementation of the pollution source management system.
