Cases / Oil, gas and coal operations · Mongolia · 2008–2024
Ulaanbaatar winter air pollution: stove programmes, the 2019 raw-coal ban and subsidised briquettes
Nature's voice · report
My winter air in Ulaanbaatar carried around 62 percent of its PM10 and 65 percent of its PM2.5 from coal-burning stoves in approximately 175,000 households, according to the World Bank.
Did nature suffer? Yes. Harm is on record. Disputed
Recorded
- At my worst recorded levels PM10 was more than 10 times the standard and PM2.5 was 25 times the standard, according to the IEG. World Bank Independent Evaluation Group
- My average winter PM2.5 in 2019–2020 was 51% lower than in 2016–2017, 46% lower than in 2017–2018 and 40% lower than in 2018–2019, according to the ADB. ADB
- The World Bank's completion report gives an average decrease of 3.6 percent in my PM emissions from 2012 to 2019. World Bank
- Subsidised stoves emitted 65% less PM2.5 and 16% less CO than traditional stoves; ambient sampling ran from 22 January to 22 April 2013, and the MCC modelled 30% lower ambient PM2.5 than a counterfactual of all-traditional stoves. Millennium Challenge Corporation
What the record lacks: 3 none on record · 1 not disclosed · 1 not measured · 3 disputed · 1 unclear See the gaps
Accounts of the harm differ
How much did Ulaanbaatar's air improve?
- International bodies ADB: Average winter ambient PM2.5 in 2019–2020 was 51% lower than 2016–2017, 46% lower than 2017–2018 and 40% lower than 2018–2019. ADB
- International bodies World Bank Implementation Completion and Results Report: PM emissions exhibited an average decrease of 3.6 percent from 2012 to 2019 (cited for the stove component). World Bank
Donor and state programmes in Ulaanbaatar's ger districts since 2008 paid for stove subsidies, loans and, from May 2019, a household raw-coal ban with subsidised briquettes made by a state-owned producer. The Auditor General sent findings on the producer's financing to prosecutors in April 2024.
51%Fall in average winter PM2.5, 2019–2020 vs 2016–2017
ADB figure for average winter ambient PM2.5. The World Bank's completion report gives an average decrease in PM emissions of 3.6 percent from 2012 to 2019 (different period and measure).
ADB figure for average winter ambient PM2.5. The World Bank's completion report gives an average decrease in PM emissions of 3.6 percent from 2012 to 2019 (different period and measure).
Status As of April 2024: the Auditor General referred three issues on Tavantolgoi Tulsh to prosecutors; charges: None on record.
What?
Donor and state programmes in Ulaanbaatar paid for stove subsidies, policy loans, a 2019 household raw-coal ban and subsidised briquettes; the briquette producer was financed with MNT 1.1 trillion from a state miner and the Auditor General referred issues to prosecutors in April 2024. ikon.mn
Where?
Ulaanbaatar, especially the ger districts (about 47.92 N, 106.92 E); briquette plant of Tavantolgoi Tulsh LLC in Ulaanbaatar. World Bank
When?
MCC compact 2008–2013; UBCAP 3 April 2012 to 31 December 2023; ADB loans March 2018 and 5 December 2019; raw coal ban 15 May 2019; discount rise 13 December 2020; Auditor General's letter 3 April 2024. World Bank Independent Evaluation Group
Who?
Gained
- 40,813 households — Received clean stoves under UBCAP in 2013 to 2015 World Bank Independent Evaluation Group
- Tavantolgoi Tulsh LLC — MNT 1.1 trillion of repayable financing in 2019 to 2023 for air-pollution reduction and briquette quality ikon.mn
- Mongolia's government budget — The Clean Air Fund collected 30 billion togrog a year and was reported to be used to fill the budget deficit AKIpress
Lost
- Households using the refined briquettes — The IEG found the briquettes incompatible with clean stoves and shortening stove lifespan World Bank Independent Evaluation Group
Harmed
- Ulaanbaatar's winter air — Coal stoves contributed around 62 percent of PM10 and 65 percent of PM2.5; worst recorded levels were over 10 times the PM10 standard and 25 times the PM2.5 standard World Bank
- Residents' health — ADB cited a 2019 UNDP study of US$486 million a year welfare costs and US$58 million lost productivity, together 5.6% of GDP ADB
Why?
Household coal burning for heating in the ger districts; the 2019 ban replaced raw coal with refined briquettes whose subsidised price was meant to encourage the switch. World Bank
How?
Stove subsidies and loans from donors, a government ban and discount, and repayable financing from state-owned Erdenes Tavan Tolgoi to the briquette producer. ikon.mn
6 of 6 questions answered from the record
What happened
The record, in order.
The World Bank reported that coal-burning stoves in “approximately 175,000 households” in Ulaanbaatar contributed “around 62 percent of PM10 and 65 percent of PM2.5 concentrations”. The World Bank's Independent Evaluation Group (IEG) recorded worst levels of more than 10 times the PM10 standard and 25 times the PM2.5 standard.
Several programmes followed. The US Millennium Challenge Corporation (MCC) Mongolia Compact (US$268.9 million, 2008 to 2013) subsidised energy-efficient stoves from 2011 to 2013. The World Bank approved the Ulaanbaatar Clean Air Project (UBCAP) on 3 April 2012 and closed it on 31 December 2023: 40,813 households received clean stoves in 2013 to 2015 against a target of 36,000, and 1,500 kindergartens received HEPA filters, while the target for electric thermal storage heaters was cut from 5,000 to 340 households. In 2015 the government replaced the subsidised clean-stove model with a commercial one. The ADB made policy-based loans of US$130 million (March 2018) and US$160 million (5 December 2019). A National Program for Reducing Air and Environmental Pollution set a target of an 80% reduction by 2025 (March 2017).
On 15 May 2019 Ulaanbaatar banned raw coal for households and small businesses and introduced refined briquettes. The Ministry of Energy procured 80,000 tons of semi-coke briquettes for ger households. According to the IEG, the briquettes “were not compatible with the clean stoves developed by the Project, and which had high caloric value, thus shortening the lifespan of the stoves”. On 13 December 2020 the government covered household utility bills until 1 July 2021 and raised the refined coal discount from 50% to 75%; the IEG found that this discount created “disincentives to use clean stoves”.
The briquette producer, Tavantolgoi Tulsh LLC, is state-owned. The National Audit Office's 2023 financial audit of Erdenes-Tavantolgoi JSC recorded receivables of MNT 2.8 trillion, of which 38.4% related to MNT 1.1 trillion of repayable financing given to Tavantolgoi Tulsh LLC in 2019 to 2023 for air-pollution reduction and briquette quality. On 3 April 2024 the Auditor General sent three issues on Tavantolgoi Tulsh “with supporting evidence” to the General Prosecutor's Office in letter No. 907.
In 2016 AKIpress, citing Bloomberg Quint, reported that the Clean Air Fund, financed by charges on car owners and coal users, was being used to fill the budget deficit. Measured outcomes differ by source: the ADB reported winter PM2.5 in 2019–2020 51% below 2016–2017, while the World Bank's completion report gave an average decrease in PM emissions of 3.6 percent from 2012 to 2019.
- 2008MCC Mongolia Compact begins (to 2013); stove subsidies 2011-2013
- 2012World Bank approves Ulaanbaatar Clean Air Project (3 April)
- 2015Government replaces the subsidised clean-stove model with a commercial one
- 2016Reported use of the Clean Air Fund for the budget deficit (29 November)
- 2017National Program for Reducing Air and Environmental Pollution (March)
- 2018ADB phase 1 policy-based loan, US$130 million (March)
- 2019Raw coal ban for households and small businesses (15 May); ADB phase 2 loan, US$160 million (5 December)
- 2020Government covers utility bills and raises the refined coal discount from 50% to 75% (13 December)
- 2023UBCAP closes (31 December); 2019-2023 financing of Tavantolgoi Tulsh totals MNT 1.1 trillion
- 2024Auditor General's letter No. 907 to the General Prosecutor's Office (3 April)
What was said
Claims, in the words of those who made them.
“Every year 30 billion togrog ($12 million) is collected from car owners, coal users and others”
“exceeding project targets by over 100% does not necessarily signify optimal performance”
“Air pollution in Ulaanbaatar has improved significantly”
“fueled less often, but with more coal per fueling, resulting in no impacts on overall fuel usage”
“thus making clean stoves unaffordable for many households”
Where accounts differ
Each party's account, side by side, with its source. The record does not settle these points; it shows them.
How much did Ulaanbaatar's air improve?
International bodies
ADB
Average winter ambient PM2.5 in 2019–2020 was 51% lower than 2016–2017, 46% lower than 2017–2018 and 40% lower than 2018–2019.
ADBInternational bodies
World Bank Implementation Completion and Results Report
PM emissions exhibited an average decrease of 3.6 percent from 2012 to 2019 (cited for the stove component).
World BankHow well did the World Bank's clean air project perform?
International bodies
World Bank (completion report self-rating)
Outcome rated Satisfactory.
World Bank Independent Evaluation GroupInternational bodies
World Bank Independent Evaluation Group
Outcome rated Moderately Satisfactory; the 2015 end of subsidies made clean stoves unaffordable for many households and the December 2020 coal discount created disincentives to use clean stoves.
World Bank Independent Evaluation GroupHow it looked
What was shown, beside what was recorded.
Shown
- Air pollution in Ulaanbaatar “has improved significantly”.ADB Country Director (5 December 2019) · ADB
- Winter PM2.5 in 2019–2020 was 51% lower than in 2016–2017.ADB results page · ADB
- Outcome rated “Satisfactory” in the project's own completion report.World Bank ICR self-rating (the IEG rated it “Moderately Satisfactory”) · World Bank Independent Evaluation Group
Recorded
- Stoves in about 175,000 households contributed around 62 percent of PM10 and 65 percent of PM2.5 concentrations.
- MCC evaluation: subsidised stoves emitted 65% less PM2.5 and 16% less CO than traditional stoves; only 4 percent of owners of energy-efficient stoves fuelled consistently with the requirements.
- UBCAP: 40,813 households received clean stoves against a target of 36,000; the planned borrower contribution of US$6.9 million was not made.
- Briquettes were not compatible with the project's clean stoves; the refined coal discount rose from 50% to 75% in December 2020.
- MNT 1.1 trillion of repayable financing to Tavantolgoi Tulsh LLC in 2019–2023; the Auditor General referred three issues to prosecutors on 3 April 2024.
- 2019 UNDP study cited by the ADB: welfare costs of US$486 million a year and lost productivity of US$58 million, together 5.6% of GDP.
- UNICEF Mongolia's representative wrote on 29 December 2023 that flu and pneumonia among children under 5 rise with daily PM2.5 and PM10, and cited a decade-old study attributing about one in 10 deaths in Ulaanbaatar to air pollution.
Who gained
Money that reached nature, beside money that stayed elsewhere.
Reached nature or the ground
Not published
No figure published.
Gained elsewhere
Not totalled
MCC Mongolia Compact$269m
Window: 2008–2013
MCC Energy and Environment Project, at inception (US$40,420,819 disbursed)$47m
Window: 2008–2013
World Bank UBCAP credit (disbursed US$14.1 million)$15m
Window: 2012
World Bank UBCAP additional financing (disbursed US$11.7 million)$12m
Window: 2019
ADB policy-based loan, phase 1$130m
Window: 2018
ADB policy-based loan, phase 2$160m
Window: 2019
Clean Air Fund annual collection (30 billion togrog, per the environment minister)$12m
Window: 2016
As stated in the article; the 2017 allocation was lowered to 5 billion togrog.
Repayable financing from Erdenes Tavan Tolgoi to Tavantolgoi Tulsh (MNT 1.1 trillion)—
Window: 2019–2023
Not converted; repayment date unknown.
Currency: USD · Window: Mixed — see each line. Figures cover different periods and are not compared as a ratio. * Estimate built from cited figures.
Responses on record
- mongolia-national-audit-office (30 August 2024): Auditor General D. Zagjav said in an interview that the audit report contains no conclusion that the decision of the then Prime Minister, now President, was wrong; the referral concerned lower-level management (paraphrase from ikon.mn). · ikon.mn
- adb (5 December 2019): Country Director Pavit Ramachandran said air pollution in Ulaanbaatar had improved significantly. · ADB
- world-bank (2024): Rated the project outcome Satisfactory in its completion report; the IEG rated it Moderately Satisfactory. · World Bank Independent Evaluation Group
In court and with insurers
Every proceeding and every insurer decision on record.
Lawsuits and rulings
- 2024–Outcome not on recordAuditor General referral on Tavantolgoi Tulsh LLC financingGeneral Prosecutor's Office of Mongolia · Administrative · Auditor General (National Audit Office) → Tavantolgoi Tulsh LLC (management)
In letter No. 907 of 3 April 2024 the Auditor General sent three issues on Tavantolgoi Tulsh “with supporting evidence” to the General Prosecutor's Office. The 2023 audit findings included about MNT 4.17 billion spent on a building for a purpose other than intended and a MNT 6.6 billion contract with Hong Kong Hengde for which delivery could not be confirmed. None on record: charges after the referral. ikon.mn
Insurers
No insurer decision on record.
What nature saw
Outcomes measured on the ground, and nature's note.
Nature's report opens this page. Below: further outcomes measured on the ground.
Winter PM2.5, 2019–2020 vs 2016–2017
−51%
Average winter ambient PM2.5 (ADB); 46% below 2017–2018 and 40% below 2018–2019
PM emissions, 2012 to 2019
−3.6%
Average decrease (World Bank completion report)
Share from household coal stoves
62% PM10, 65% PM2.5
About 175,000 households (World Bank)
Worst recorded levels
10× PM10, 25× PM2.5
Multiples of the standard (IEG)
What we don't know
Undisclosed, unproven, untried: recorded as data.
Nature
- Disputed How much did Ulaanbaatar's air improve?
Money
- None on record Repayable financing from Erdenes Tavan Tolgoi to Tavantolgoi Tulsh (MNT 1.1 trillion) — Not converted; repayment date unknown.
Court
- Unclear Auditor General referral on Tavantolgoi Tulsh LLC financing: outcome not on record.
Accounts
- Disputed How well did the World Bank's clean air project perform?
Record
- None on record None on record: charges after the Auditor General's April 2024 referral to the General Prosecutor's Office.
- Not measured Not measured: health effects of the MCC-subsidised stoves; the MCC evaluation states they “were not directly measured” and were modelled only.
- None on record None on record: a borrower contribution to UBCAP; US$6.9 million was planned and the IEG states “there was no Borrower contribution”.
- Not disclosed Not disclosed: repayment date of the MNT 1.1 trillion financing to Tavantolgoi Tulsh LLC (National Audit Office 2023 audit: unknown).
- Disputed Figures differ: the ADB reports a 40–51% reduction in average winter PM2.5 (2019–2020 against earlier winters); the World Bank completion report gives a 3.6 percent average decrease in PM emissions for 2012 to 2019.
Did the harm stop?
The ADB reported lower average winter PM2.5 in 2019–2020 than in the three preceding winters; no later monitoring series is on record.
Who paid?
Donors and the state paid for stoves, loans and briquette discounts: MCC US$268.9 million, World Bank credits US$27.0 million, ADB loans US$290 million, and MNT 1.1 trillion of repayable state-miner financing to the briquette producer.
Sources
Voices on record: — Company or project✓ Government and regulators— Courts✓ Press and investigations— Communities and civil society— Researchers✓ International bodies
Government and regulators
- Closed Compact Report: Mongolia CompactMillennium Challenge Corporation · 2015-10-17
- Evaluation Brief: Better Air Quality with Energy Efficiency in MongoliaMillennium Challenge Corporation · 2014-08
Press and investigations
International bodies
- ICR Review ICRR0024171: MN-Ulaanbaatar Clean Air (P122320)World Bank Independent Evaluation Group · 2024-11-13
- Implementation Completion and Results Report, Ulaanbaatar Clean Air ProjectWorld Bank · 2024-06-18
- We must fight air pollution every dayUNICEF Mongolia · 2023-12-29
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