Published: 13/12/2024
Policy Brief (Options for Reducing Winter Air Pollution)
Prepared by: B. Oyuntugs, Doctoral Candidate, Public Administration, MUST; MSc in Security and Environmental Management, UK; Certified Environmental Auditor and Senior Implementer, Australia, Canada, Singapore, India
December 13, 2024 – Ulaanbaatar, Mongolia
CURRENT STATUS OF WINTER AIR POLLUTION IN MONGOLIA
1.1. Problem
As of January 2024, Mongolia ranked 145th globally in the Environmental Performance Index (EPI) with a score of 48.2. As of December 12 of the same year, the daily Air Quality Index (AQI) ranged from 78 during the day to 152 during peak stove usage hours, fluctuating throughout the day, making Ulaanbaatar the “city with the most polluted air in the world” [1]. This level is 27 times higher than the standard set by the World Health Organization (WHO).
1.2. Cause
Households and industries use coal and fuel that emit high levels of greenhouse gases. Heat loss from poorly insulated buildings increases the demand for thermal energy.
Main air pollutants include particulate matter (PM), carbon monoxide (CO), sulfur dioxide (SO₂), nitrogen dioxide (NO₂), and ozone (O₃) [2]. The AQI categories are as follows:
| AQI Score | Interpretation |
|---|---|
| 0–50 | Normal |
| 51–100 | Harmful to some individuals |
| 101–150 | Harmful to vulnerable groups |
| 151–200 | Harmful to all; severe risk for vulnerable groups |
| 201–300 | Disaster level; severe risk for all |
| 301–500 | Severe harm to everyone |
An AQI of 152 indicates that every resident in a polluted city is at health risk, with pregnant women, infants, and the elderly facing serious dangers.
As of September 2023 (excluding thermal power plants), 55.6% of air pollution comes from ger districts and 28.9% from vehicles. Including power plants, the breakdown is:
- Thermal power plants: 44.2%
- Ger districts: 31%
- Vehicles: 16.1%
- Other sources: 8.7%
Notably:
- Particulate matter: 52.3% from vehicles
- NO₂: 63.2% from vehicles
- CO: 64.1% from ger districts
- SO₂: 71.7% from ger districts
According to the UNDP’s report “Air Pollution and Future Opportunities in Mongolia”, there are:
- 194,900 household stoves under 10kW
- 2,830 steam boilers between 11–100kW
- 320 industrial boilers over 101kW [4]
This confirms that coal, as used in Mongolia, is the main source of pollution. Despite paying seven times more per unit of heat than others, 38% of ger households fall under the poverty line and spend 17.5% of their annual income on fuel [5]. From 2008 to 2018, Mongolia spent MNT 147.5 billion in foreign aid to fight pollution with little success.
1.3. Consequences
According to WHO, the global average death rate due to indoor and outdoor air pollution is 92 per 100,000 people. In Mongolia, it’s 132 per 100,000 [6]. A UNDP-EU funded study reported:
- 7,139 annual deaths
- Economic loss of MNT 4.8 trillion [7]
Air pollution causes or contributes to:
- Acute lower respiratory infections
- Chronic obstructive pulmonary disease (COPD)
- Ischemic heart disease
- Lung cancer
- Stroke
- Type 2 diabetes
53% of respiratory illnesses, 40% of lung cancers, and 24% of children’s respiratory illnesses are linked to air pollution [8]. 844,646 people (53% of Ulaanbaatar’s population) live in the most polluted areas.
ANALYSIS OF CAUSES AND IMPACTS
A matrix analysis shows the most significant impacts come from coal smoke in ger districts and chemical emissions:
Table: Matrix of Health Impacts by Pollution Source
| Impact Areas | I. Ger Districts’ Coal Smoke | II. Industrial Coal Smoke | III. Vehicle Emissions | IV. Chemical Emissions |
|---|---|---|---|---|
| Lung disease (cold, flu, pneumonia, bronchitis, COPD, cancer) | 3 | 3 | 2 | 3 |
| Maternal, fetal, and infant health (miscarriages, preterm birth, defects, stillbirth) | 3 | 2 | 3 | 2 |
| Other illnesses (cardiovascular, hypertension, heart attack) | 2 | 2 | 2 | 3 |
| Total | 8 | 7 | 7 | 8 |
Legend:
- 1: Low Risk
- 2: Medium Risk
- 3: High Risk
GOVERNMENT MEASURES AGAINST WINTER AIR POLLUTION
Measures Taken So Far
International recommendations include: distributing improved fuel and stoves, improving insulation, accelerating ger area redevelopment, and promoting apartment housing. Mongolia has banned raw coal in ger areas and supplied improved fuel.
However:
- Power plants and factories still burn coal.
- Improved fuel hasn’t significantly reduced pollution.
- Energy and heating sources remain unregulated.
Effectiveness Analysis of Measures
Table: Evaluation of Five Current Government Measures
| Policy Measure | Impact | I. Improved Fuel | II. Improved Stoves | III. Coal Ban | IV. Better Insulation | V. Housing Projects |
|---|---|---|---|---|---|---|
| Reduced Pollution | 1 | 1 | 2 | 2 | ||
| Reduced serious harm to vulnerable groups | 1 | 1 | 1 | 1 | ||
| Reduced overall health impacts | 1 | 1 | 1 | 1 | ||
| Addressed root causes (heat source) | 1 | 1 | 1 | 1 | ||
| Total Score | 1 | 1 | 1 | 1 |
Legend:
- 1: No results
- 2: Some results
- 3: Significant results
These 5 measures have been ineffective. Citizens criticize them as short-sighted, lacking long-term strategic planning.
FUTURE POLICY FRAMEWORK
Stakeholders
Government: Capital city authorities, districts, ministries, customs, land offices, registration offices, Parliament
Private Sector: Construction, infrastructure, transport, factories, logistics, landscaping
Citizens: Ger and apartment residents, Homeowners Associations
Strategic Goal
Establish a framework to reduce winter air pollution through a 15-year policy cycle, progressing through 5 stages (3-year intervals).
Implementation Plan
Years 2025–2040 (Cycle 1):
- Develop a legal framework for greenhouse gas (GHG) regulation
- Improve reporting from major enterprises; train and involve small and medium enterprises
- Upgrade ger infrastructure, promote independent heating systems
- Plan green zones and offset markets
- Educate public and conduct Scope 1 emissions inventory
Years 2040–2055 (Cycle 2):
- Expand to SMEs and rural areas
- Pilot eco-villages
- Implement Scope 1 emissions reporting and legal enforcement
- Strengthen Scope 2 supplier emissions policies
Years 2055–2070 (Cycle 3):
- Scope 3 emissions tracking
- Make GHG reduction mandatory for all
- Green certification for imports
Years 2070–2085 (Cycle 4):
- Focus on summer pollution and allergens
- Eco-label requirement for 50% of imports
Years 2085–2100 (Cycle 5):
- 100% eco-label requirement for imports
- Full seasonal air quality regulation
IMPLEMENTATION STRATEGY
Involve all stakeholders, including public and private sectors. Note: 70% of Mongolia’s spending comes from government procurement, with only 30% from private sector [9].
Air pollution mitigation is tied to greenhouse gas emissions accounting (ISO 14064 series):
- Scope 1: Direct emissions
- Scope 2: Supplier emissions
- Scope 3: Customer emissions
Organizations like SBTi (Science Based Targets initiative) audit and verify GHG reduction commitments, ensuring accurate public data and avoiding false claims.
POLICY OPTIONS: CAUSE-RANKED SOLUTIONS
Root Cause Overview
According to previous studies, pollution is primarily caused by GHG emissions.
| Source | Estimated Share |
|---|---|
| Industrial emissions | Unknown (not measured) |
| Household smoke (ger districts) | 56% |
| Vehicle emissions | 29% |
Despite their impact, industrial emissions have not been quantitatively assessed. Developed nations strictly apply ISO 14064 and legally require corporate GHG inventories, a step not yet taken in Mongolia.
Proposing a Hypothesis
As mentioned in the previous section, the current solutions implemented by the government are not yielding effective results. Therefore, it is hypothesized that by incorporating neglected or overlooked issues into short-, medium-, and long-term policy solutions and implementing the following measures comprehensively, effective outcomes can be achieved. These issues, though not included in prior solutions, are topics of importance globally. These include:
| № | Stakeholder | % of Emission Contribution | Policy Solution | Feasibility of Implementation |
|---|---|---|---|---|
| 1 | Power Plants | High | Conduct greenhouse gas (GHG) inventory to determine actual emission figures | Require GHG inventories from district and khoroo governors, environmental officers, and local businesses. Consolidate and analyze the collected data. |
| 2 | Industries | High | Same as above | Same as above |
| 3 | Heat Sources | Low | Utilize solar and wind energy sources. Support decentralized, independent local supply systems rather than relying on a few centralized plants. | Fully grant rights to private entities to produce renewable energy and allow the government to purchase it. Establish independent distribution networks in ger districts and industrial zones. |
| 4 | Green Infrastructure | Low | Green spaces and artificial lakes absorb air pollution; therefore, establish more and allocate land for them. | Allocate sufficient space for green projects based on GHG inventory results and invest in these projects. |
| 5 | Change in Procurement Standards | High | Change the procurement criteria of public and private entities | Amend procurement laws to prioritize low or zero GHG emissions rather than lowest price. Mandate large enterprises like Oyu Tolgoi and Erdenet Mining Corporation to revise procurement standards and report emissions from their operations and suppliers. |
| 6 | Land & Property Licensing Criteria | High | Deny permits and certificates to buildings and industries using coal. Require old buildings to transition to new technologies; revoke licenses if not complied within the transition period. | Provide a “green lane” for renewable energy projects and enforce exit policies for coal-based projects. |
| 7 | Education | Medium | Raise awareness and introduce scientific methodologies at all levels | Create and disseminate information on emission reduction and sequestration methods. Establish advisory and auditing entities for households and organizations. Mandate media outlets to produce and allocate content quotas. |
| 8 | Financing | High | Create and operate a carbon offset trading market. Amend environmental compensation laws. | Replace pollution-related taxes with offset payments. Direct funds to green-performing entities such as tree planting, artificial water bodies, renewable energy, and filtration systems. Offer green loans. |
| 9 | Incentives | High | Provide incentives to organizations with verified reports | Grant certificates to organizations meeting GHG reduction targets based on third-party audits. Make these certificates valid for public and private procurement criteria. Offer tax deductions and subsidies for investments in green transition. For example, reimburse households installing solar panels and purchase the generated power. |
Policy Options
The speed, impact, financial burden on citizens, and potential tax revenue generation depend on whether the government chooses coercive policies or market-based incentive approaches. Broader impacts may also affect economic stability, domestic and international trade, investment environments, and social stability—requiring careful evaluation.
The policy transition can be formulated and compared as follows:
| № | Coercive Policy (Option 1) | Soft Transition (Option 2) | Hybrid Transition (Option 3) |
|---|---|---|---|
| 1 | Legislate mandates, centralize authority | Pilot incentive systems, trust organizations | Combine laws, standards, and public-private partnerships |
| 2 | Mandate GHG inventories via local governors and conduct inspections | Introduce methodologies, leave implementation voluntary, praise socially responsible organizations | Require inventories, but gradually phase mandates for financially capable entities |
| 3 | Invest in large-scale projects (e.g., nuclear or gas power plants) | Promote renewable energy via tax breaks and simplified permits | Support local independent stations; allow private sector to handle supply |
| 4 | Mandate zero or offset emissions in all public and private procurement | Recommend including emissions in criteria | Mandate stricter rules for high-pollution sectors, relaxed for SMEs |
| 5 | Require zero-emission operations for licenses, mandate tech upgrades in 3 years | Require self-reported GHG data, no strict reduction targets | Require third-party verified reports, mandate either reduction or offsets |
| 6 | Mandate education/media to teach GHG reduction methods; monitor outcomes | Call for voluntary participation; offer free media coverage for private efforts | Enable private training/advisory firms, offer tax breaks, contract-based funding |
| 7 | Fund green projects and issue subsidies; allocate foreign aid | Provide tax breaks only | Use carbon offset markets to channel private financing |
Impact Assessment of Policy Options
To choose the optimal approach, an impact assessment was done for each policy option. Here are the key findings:
- Option 1 (Coercive): Highly enforceable but may centralize authority too much, causing inefficiencies, bureaucracy, or public resistance.
- Option 2 (Voluntary): Gentle approach but may result in low participation and weak implementation.
- Option 3 (Hybrid): Balanced, phased transition that considers financial capacity and ensures gradual compliance while maintaining flexibility.
The hybrid approach is mostly rated with positive outcomes, combining the strengths of both coercive enforcement and voluntary incentive systems, thereby fostering greater participation and sustainable change.
Choose the Correct Option
An analysis of the consequences and impacts of the three policy alternatives illustrated in the previous chapter shows that transitioning from a greenhouse gas-emitting heat supply system to a pollution-free one using a “hybrid” approach is necessary.
The following actions are effective:
Choose the Correct Option
An analysis of the consequences and impacts of the three policy alternatives illustrated in the previous chapter shows that transitioning from a greenhouse gas-emitting heat supply system to a pollution-free one using a “hybrid” approach is necessary.
The following actions are effective:
Table: Using a Hybrid Transition Policy (Option No.3)
| № | Option | Consequence | Impact |
|---|---|---|---|
| 1 | Combine laws, regulations, standards; use a public-private partnership system | A mixed system based on standards with public-private partnership will ensure good participation | Positive |
| 2 | Require reporting, but phase in transition responsibilities starting with financially capable organizations | Gradual requirements based on sector and financial capacity allow phased implementation, public awareness and training can match the pace | Positive |
| 3 | Transition from centralized power stations to support for local sub-stations; allow private sector implementation of independent supply networks; allocate land and use polluter funds as investment | If financial and legal issues are resolved, many private energy companies can emerge, build and operate renewable or restored energy stations in approved areas; risks include increased consumer costs and inequality in access for low-income citizens | Positive, Negative |
| 4 | Require public and private procurement to use only non-emitting or offset goods/services; require compliance reports | Strong effect as all entities focus on compliance; needs enforcement mechanism, penalties for violations | Positive |
| 5 | Include self-reported emissions inventory and reduction targets in land, property, and operational permit criteria | Allows learning and practice in reporting without strict reduction quotas, likely leading to accurate data | Positive |
| 6 | Use public media freely for awareness campaigns; teach GHG inventory and reduction methods in media, education, and training institutions | Encourages private sector participation; requires expert knowledge; risks confusion if different methodologies are used | Positive |
| 7 | Support environmentally friendly and emission-reducing projects through carbon offset markets | Solves financing issues; high implementation potential via private sector | Positive |
Implementation Plan
Example Criteria Over the First 15-Year Policy Cycle to Reduce GHG Emissions and Improve Air Quality
| Period | Stakeholders | Policy Requirement | Outcome |
|---|---|---|---|
| First 3 years (2025–2027) | City and provincial administrations, district and local councils, regional representatives | Conduct GHG emission inventories for public/private enterprises, apartment associations, and households; compile unified database | Complete emission inventory by location; prepare for coal ban by 2027; require new buildings to prove air pollution mitigation |
| Ministry of Environment | Ban coal burning in Ulaanbaatar from 2027; target a coal-free city by 2030 | ||
| Construction & mining companies | Require GHG emission and sequestration reports for licenses and state approvals | ||
| Second 3 years (2028–2030) | City, province, local authorities | Allocate and clear land for afforestation, artificial lakes; report on sequestration | Support clean energy and public heating projects; provide tax incentives based on sequestration; restrict land rights if no sequestration |
| Energy authorities, renewable projects | Support solar panel supply to homes; promote electric heating | ||
| Companies, experts, financiers | Support innovative heating projects; introduce filtration technology | ||
| Citizens, apartment associations | Plant trees; reduce coal/fuel use; use renewables; insulate homes | ||
| Land & property registration offices | Require GHG emission and sequestration reports for land/property transactions | ||
| Local administrations | Aggregate and report household and enterprise emissions | ||
| Third 3 years (2031–2033) | Large (70%), medium (30%) private sector, 10% government agencies | Submit reports showing 20% emission reduction/sequestration based on ISO 14064-1 Scope 1 | 70% of Ulaanbaatar’s high emitters standardize reporting; implement community heating projects; give procurement preference to green-labeled entities |
| Construction, mining, int’l orgs | Launch district-level heating projects for ger areas; finalize past redevelopment projects | ||
| Local governments | Map and evaluate areas for heating/water connection | ||
| Green-labeled companies | Gain priority in government and corporate tenders | ||
| Fourth 3 years (2034–2036) | 100% of large, 50% of medium enterprises, 20% of government agencies | Submit reports showing 50% emission reduction/sequestration, ISO 14064-1 Scope 1 | Track effectiveness by number of ISO-certified or green-labeled entities; improve Ulaanbaatar’s air quality by 50% |
| 10% of ger households | Connected to electricity, solar or public heating | ||
| Fifth 3 years (2037–2039) | 100% of large & medium, 50% of government agencies | Large firms reduce or sequester 80%, medium 50%, based on ISO 14064-1 Scope 1 | |
| 30% of small/micro businesses | Report 20% emission reduction/sequestration | ||
| 20% of ger households | Connected to electricity, solar or public heating |
Second 15-Year Cycle (2040–2055)
- 50% of ger households connected to clean energy.
- 100% of businesses & agencies offset 100% of emissions, 80% pollutant filtration, use clean heat sources.
- Require eco-labeling for heavy industry and imports.
- Institutionalize ISO 14064 Scope 1 reporting.
Third 15-Year Cycle (2055–2070)
- Expand scope to rural areas.
- 100% of ger households connected to clean energy.
- 100% of businesses & agencies offset 100% emissions and filter 100% of air pollutants.
- Require 50% of imported goods to have eco-labels.
- Institutionalize ISO 14064 Scope 1 reporting nationwide.
Fourth 15-Year Cycle (2070–2085)
- Expand coverage further outside Ulaanbaatar.
- All industries to have eco-certification.
- Summer, spring, and fall air quality improvements begin.
- Implement ISO 14064 Scope 2 (supply chain emissions) reporting.
- Require green space reporting, weed control, and dust management.
Fifth 15-Year Cycle (2085–2100)
- Require all products to be eco-labeled, report GHG emissions post-consumer use.
- Institutionalize ISO 14064 Scope 3 reporting.
- Achieve clean air in all seasons.
- Prevent allergenic weed spread and dust pollution.
3. CONCLUSION
From the impact analysis of policy alternatives, it is clear that Mongolia must transition from a GHG-emitting heat supply system to a “hybrid” approach toward a non-polluting system.
Previous policy decisions had low effectiveness because they neglected root causes. This proposal targets those foundations and offers a practical and impactful solution.
The policy structure will tighten requirements every 3 years and implement 5 stages over 15 years per policy cycle. Thus, a 75-year long-term policy is necessary, including standard-setting, measurement, and adjustments.
Previous policies lacked requirements for public procurement, which accounts for 70% of Mongolia’s purchases. Future success hinges on first regulating public institutions before imposing on the private sector—using a top-down information flow strategy.
The main issue lies in heat supply in ger areas, and this must be addressed simultaneously. Establishing independent heating substations with public-private cooperation and giving citizens choice is vital. Investment in renewable and restored energy is also necessary.
Temporary measures and guidelines will not suffice—permanent structural and legal frameworks are required. Internationally, the “Nuisance Law” prohibits emissions that affect others’ living environments and imposes heavy penalties or even criminal charges.
As discussed in the previous chapter, public policy addressing ongoing, population-wide issues must be long-term and sustainable.
References
[1] https://www.aqi.in/dashboard/mongolia/ulaanbaatar
[2] https://www.aqi.in/dashboard/mongolia/ulaanbaatar
[3] https://mn.usembassy.gov/embassy/ulaanbaatar/aqi/
[4] https://www.undp.org/sites/g/files/zskgke326/files/migration/mn/infographics-mon.pdf
[5] https://www.undp.org/sites/g/files/zskgke326/files/migration/mn/infographics-mon.pdf
[6] https://www.who.int/mongolia/news/detail/28-02-2018-world-health-organization-issues-recommendations-to-tackle-health-impacts-of-air-pollution-in-mongolia
[7] https://gogo.mn/r/qyxq1
[8] https://gogo.mn/r/qyxq1
[9] “FREE MARKET ECOSPHERE: VALUES OF FREEDOM” Economic Forum, 2024.11.27
