After attending the public hearing on Air Pollution Policy Effectiveness held between December 2024 and February 2025 in Mongolia, I’ve reflected on some key insights.
Logical Fallacy Between “Accountability” and “Accuracy of Information” in Air Pollution Hearings and Solution Proposals
1️⃣ 👉 Demanding Accountability from Those Responsible and Proposing Future Accountability Measures
When there is a risk of punishment, ultimate accountability often remains unclear, leading to concealment and secrecy. During the hearing, data was vague, conclusions and critiques were ambiguous, and there was no clear “truth” regarding who was harmed by the statistics. This clearly demonstrates the issue.
(Source: ISO Standards, Section 5.3 – Allocation of Roles, Responsibilities, and Authorities)
2️⃣ 👉 Prioritizing Systemic Integrity Over Fear-Based Punishment
When integrity and availability of information—two of the three core pillars of information security—are compromised, the first priority should be ensuring access to complete and accurate data rather than threatening punishment.
Some systems adopt a “forgiveness phase” to encourage transparency, recognizing that decisions cannot be made correctly without accurate data.
(Source: International Management Standards: ISO 9001, ISO 45001, ISO 14001, Section 7.4 – Information, Section 7.5 – Documentation Systems; ISO/IEC 27001, Section 6 – Information Integrity, Availability, and Security Risk Management)
3️⃣ 👉 Accountability Must Be Properly Structured
International management standards categorize accountability into different types, each with clearly defined roles. This is structured through the RACI Matrix (Responsible, Accountable, Control, Inform).
- R – Responsibility: The person who performs the task.
- A – Accountability: The ultimate decision-maker and leader.
- C – Control: Oversight and regulation.
- I – Inform: Communication and transparency.
3.1 ☝️ The Ultimate Accountable Party (A – Accountability)
The final decision-maker is responsible for policy direction, ensuring no unauthorized interventions disrupt or distort the process. This person has approval authority, assigns roles, oversees audits, and manages appointments/dismissals.
- While tasks can be delegated to organizations or employees, the accountable party must ensure they have the necessary training, resources, and authority.
- If underqualified personnel are assigned, proper training and expert guidance must be provided.
👉 In the case of air pollution, the Prime Minister should be the ultimate accountable authority.
(Source: ISO Management Standards, Section 5.1 – Leadership and Commitment, Section 7.1 – Resources, Section 5.3 – Roles, Responsibilities, and Authorities)
3.2 ☝️ The Responsible Party (R – Responsibility)
The responsible party executes tasks and manages resources, ensuring completion and reporting. For example, in home insulation:
- B develops insulation material standards,
- C conducts material analysis,
- D certifies compliance through product audits,
- E grants usage approvals,
- F monitors implementation, etc.
(Source: ISO Management Standards, Section 5.3 – Allocation of Responsibilities)
3.3 ☝️ Oversight and Control (C – Control)
Regulatory bodies must be independent, professional auditing organizations; otherwise, oversight functions fail. Standards such as ISO 17065, ISO 17029, and ISO 17021 ensure proper auditing structures.
(Source: ISO 17065 – Product and Process Auditing, ISO 17021 – Management System Auditing, ISO 17029 – Information Verification and Validation Standards)
📌 Common mistake observed in hearings: A single expert was tasked with oversight instead of assembling a proper auditing team, violating ISO 19011 guidelines for audits.
(Source: ISO 19011 – Guidelines for Management System Audits)
📌 Oversight should be divided into levels:
- Strategic policy oversight,
- Tactical decision verification,
- Operational process monitoring,
- Independent auditing,
- Executive review and management decisions.
(Source: ISO 9001, Sections 8.1, 8.5-8.7, 9.1-9.3)
3.4 ☝️ Transparency and Public Information (I – Inform)
Defining who, how frequently, and through which platforms information should be shared is critical.
- The lack of accessible, real-time data creates public confusion and decision-making uncertainty.
- A centralized information platform could compile reports, allow expert and citizen input, and facilitate public engagement.
📌 Example from the UK: Citizens have access to an open forum to discuss, observe, and provide feedback on decisions, reducing stress and increasing participation.
📌 Solution Proposal:
- Assign national TV and radio scheduled reporting duties on air pollution progress.
- Centralize data from various sources into a single online platform accessible to all.
- Enable public input and feedback mechanisms.
📌 Information should be communicated in three directions:
- Top-down (Government → Public)
- Bottom-up (Public → Government)
- Horizontal (Inter-agency cooperation)
👉 Conclusion:
If clear accountability structures are established, decision-making can become more transparent, solutions can be tested and refined in real-time, and policies can be adapted efficiently.
📌 The root issue: Fear-based secrecy.
- Information concealment, fear of punishment, and personal risk aversion are obstructing transparency.
- Making data open, accurate, and accessible will expose corruption, favoritism, and misuse of power, ultimately eliminating systemic failures.
- Law enforcement should focus on corruption, while solution-oriented teams should stay focused on pollution reduction efforts.
(Photo credit: https://mongolianeconomy.mn/en/any-results)
