6 16. It claims that sulphur dioxide (SO2)1 and nitrogen oxide (NOX)2 emissions factors – the mass of pollutant (kg) emitted per unit of energy produced – is increasing for most lignite-fired power plants, a particularly worrying situation in Megalopolis, which represents about 7% of national installed capacity but 57% of the electricity sector’s SO2 emissions and which only has one desulphurisation unit. 17. The MFHR also maintains that the Government has failed to supply clear data on air quality in the two regions where lignite is used for electricity generation. For example, the state does not appear to have collected any data before 2003 on longterm exposure to NOx or short-term exposure to PM10s, SO2 or NOx in the Ptolemaida region. In Megalopolis, the first measurements of TSP pollution were taken in 1996 and of PM10s in 2003. The state does not appear to have collected any data in this region on short-term exposure to SO2 (and none on long-term exposure to SO2 between 1970 and 1996) or on long-term exposure to NOx before 2003. ii. Effects of pollution on health 18. The MFHR claims that a link has been established in the aforementioned studies between environmental exposure to air pollution and an abnormally high prevalence of respiratory diseases, particularly rhinitis, atrophic rhinitis, chronic bronchitis and chronic obstructive pulmonary disease (COPD) among residents and non-residents of the lignite mining areas of western Macedonia. For example, the prevalence rate for rhinitis in these areas was apparently comparable to those recorded in highly polluted urban areas. These studies also show that the aforementioned conditions could also be precursors of other cardiovascular and respiratory diseases, including asthma and lung cancer. The studies also reveal a mortality rate from cardiovascular diseases in Megalopolis above the national average, a significant and rapid rise in mortality due to cardiovascular conditions in Kozani and, in Komanos, a statistical correlation between monthly male mortality rates and monthly average particle concentrations. iii. Acts and omissions of the state Lignite mining: 19. Because of its direct impact on air quality, which is the main subject of the complaint, the MFHR is particularly concerned about the use of conveyor belts and other transport activities without adequately covering and humidifying dust, resulting in avoidable dispersion of particulate matter. More specifically, it states that the conveyor belts at the Aghios Dimitrios power station remained uncovered for a period of ten years and are still only partially covered, even though they are located close to a village of 1 300 inhabitants (Klitos) in a region where the state itself has 1 Sulphur dioxide (SO2) is a colourless, acrid smelling gas. It stems mainly from the combustion of coal and/or heating oil with a substantial sulphur content. On combustion, these sulphuric impurities are oxidised to form sulphur dioxide. This gaseous pollutant is emitted by fixed sources (such as thermal power stations, industrial ovens and urban heating systems) using fossil fuels or by many smaller sources (diesel vehicles). 2 Nitric oxide (NO) and nitrogen dioxide (NO2) are gases. combustion processes (in industry and road transport). These gases are the products of oxygen (O2) and nitrogen (N2) in the air combining under the effect of high temperatures during combustion. Nitrogen undergoes an oxidisation process which depends on combustion temperature. The quantity of nitric oxide (NO) generated increases with combustion temperature. On contact with ambient air, NO is fairly rapidly oxidised into NO 2. Concentrations of NO are greater than those of NO2 when one is close to the emission source.