Preliminary Environmental Report

1. Basis and Purpose

This report was prepared by an expert group based on:

• open data from raids by the Special Environmental Commission (December 2025);
• estimates of waste oil generation in Uzbekistan (~250,000 t/year);
• international reference emission factors (EPA, IPCC, Japanese methodology for waste oil);
• international damage cost estimates (market CO₂ price, SCC, EPA rates for PM/NOx/SO₂).

Purpose: to provide an order-of-magnitude damage estimate where official calculations are absent, and to propose short-term solutions.

2. Initial Balance Hypothesis (Working Assumption)

3. Emission Calculation from Burning 125,000 t of Oil

4. Damage Assessment (International Rates)

4.1. Burning

4.2. Discharge of 75,000 t to Soil/Water

There are no direct international "tariffs." The lower bound based on soil treatment cost (~$1/t) is ~$75,000, but this does not account for groundwater migration or health impacts. A realistic range cannot be determined without monitoring data.

4.3. Unaccounted 50,000 t

Not assessed. Conservatively, this could be attributed to burning or discharge, increasing the total by 20–40%.

5. Summary Conclusion on Damage

6. Short-Term Solutions

6.1. Conversion to Biodiesel with Pre-Treatment

Waste oil, after pre-treatment (filtration, removal of water and mechanical impurities, neutralization), can be processed into biodiesel. This:

• reduces burning and discharge volumes;
• creates a local energy carrier;
• does not require imported catalysts for simple schemes.

6.2. Mini-Plant Deployment Scheme

6.3. Environmental Effect

Processing ~25,000 t/year of waste oil instead of burning/discharging:

• reduces PM/PM-10, NOx, SO₂, and CO₂ emissions from burning;
• prevents ~25,000 t of oil from entering soil and water;
• reduces pressure on groundwater in areas of mass burning (Kibray, Zangiota, Bektemir).

7. Brief Calculation for All of Uzbekistan

7.1. Initial Data (Same Hypothesis)

The calculation fully coincides with Section 3, since 125,000 t is already the national estimate of the burning stream.

7.2. Emissions and Damage from Burning (National Scale)

7.3. Discharge of 75,000 t

Without groundwater monitoring data, this cannot be determined. The lower bound based on soil treatment cost (~$1/t) gives only ~$75,000, which is clearly underestimated.

7.4. Comparison with the Mini-Plant Solution

The scheme of 72 plants × 1 t/day = ~25,200 t/year processes:

• ~20% of the burning stream (125,000 t);
• ~34% of the discharge stream (75,000 t);
• ~10% of total generation (250,000 t).

To cover at least half of the burning stream, ~170 plants would be required, and even more with discharge included.

7.5. National Conclusion (Brief)

The theoretical damage from burning at the national scale is from ~$150M to ~$1.2B. Discharge to soil/water is not assessed due to lack of data. The 72 mini-plant scheme covers no more than 10% of total oil generation. Real reduction of damage requires expanding the collection network, field emission measurements, and phased scaling of processing.

8. Recommendations for Companies (Short-Term, 0–12 Months)

1. Greenhouse farms and boiler houses: install particulate/gas filters on existing boilers; stop burning waste oil, tires, bitumen, and fuel oil; conclude contracts for waste oil removal with licensed collectors.
2. Collectors and processors: organize oil collection points in each district; implement pre-treatment of oil before biodiesel conversion; launch pilot mini-plants (1 t/day) in 2–3 districts to refine the scheme.
3. Service and transport companies: hand over waste oil only under contract, with transfer acts; maintain records of oil generation and transfer.
4. Investors and mini-plant operators: replicate modular plants according to the 12 regions × 6 plants scheme; ensure pre-treatment of feedstock for stable biodiesel yield.

9. Limitations and Caveats

1. This calculation is not official and cannot be used for legal claims.
2. Emission factors are taken from international reference books, not from measurements on Uzbek boilers.
3. The 50/30/20 balance hypothesis is an estimate.
4. Damage from discharge to groundwater is not calculated due to lack of monitoring data.
5. The 72 plants × 1 t/day scheme is illustrative; actual productivity depends on collection logistics and feedstock quality.
6. Exchange rate for conversion to UZS: 1 USD = 12,014.37 UZS (Central Bank of Uzbekistan, 14.11.2026).

10. Next Steps (Internal)

1. Request actual collection volumes from Uz-Prista Recycling for 2020–2025 to verify the balance.
2. Initiate field measurements of emissions from greenhouse boilers (PM, NOx, SO₂, Pb).
3. Conduct soil and groundwater sampling in areas of mass burning.
4. Launch a pilot mini-plant (1 t/day) and measure actual biodiesel yield after pre-treatment.
5. After obtaining data, recalculate the report using national methodologies.

11. Official Inspections & Media Coverage (Context)

The following official inspections and media reports illustrate the regulatory context and enforcement actions related to environmental violations in Uzbekistan (2026).