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6 November 2005 | Printer friendly

EU Thematic Strategy on Air Pollution: all smoke and mirrors

SOURCE: EEB Metamorphosis Newsletter

Air pollution is one of the major environmental problems facing the European Union today. Much has been done to tackle the problem but a lot more needs to come.

Current pollution levels cause some 370,000 premature deaths per year as well as about 100,000 serious hospital admissions - and affects millions of people who suffer from respiratory illnesses. Furthermore thousands of square kilometres of forest area are damaged by acid deposition (“acid rain”) and biodiversity is threatened in over 60% of Europe’s ecosystems because of excess nitrogen deposition.

The main sectors contributing to air pollution are industry, transport and agriculture.

In response to this challenge, the Thematic Strategy on Air Pollution set out to define the EU’s medium-term policy goals in the field of air pollution, to map out an integrated way of getting there and provide the tools to meet these goals. However, the final Strategy falls short of its ambitions. It defines reduction steps that are watered down, far too small, and most crucially lack the proper legislative instruments to achieve the Strategy’s goals.

On 21 September the European Commission adopted the Thematic Strategy on Air Pollution - a long-term plan on how to reduce air pollution in the EU in the next 15 years. The Strategy is accompanied by a directive proposal on air quality, which will revise existing air quality legislation and combine several directives into one. This is the first of the seven Thematic Strategies that the EU executive is obliged to develop for the most persisting environmental problems in the European Union.

The Thematic Strategy on Air Pollution sets the goals for further reduction of the five most serious air pollutants, which are responsible for health and ecosystem damage in the EU. According to the Strategy, by 2020 emissions of sulphur dioxide would need to decrease by 82%, nitrogen oxide emissions by 60%, volatile organic compounds by 51%, ammonia by 27% and fine particulate matter(2) by 59%, compared to their levels in the year 2000.

It does not aim far enough

In principle the approach chosen in the Thematic Strategy on Air Pollution is a good one. The analysis has been undertaken with a view to achieving clearly defined goals for environment and health. From this starting point it establishes which further reduction measures are necessary. The Commission’s analysis shows that there is a clear need for further air pollution legislation in order to meet the health and environmental objectives of the Community.

This is the case even though pollutant concentrations will further decline due to the implementation of existing legislation - because without additional measures, health and environmental damage caused by air pollution will still be unacceptably high. With the environmental aim in mind the Strategy should then establish what other sectors should do in order “to strengthen a coherent and integrated policy on air pollution”(3). This is the idea of integrating environmental concerns into other policy areas, something the EEB has always called for.

In theory these two elements - starting with the environmental goal in mind and integrating environmental policy concerns into other areas - are positive. However, in practice the Strategy does not go far enough in either of these areas.

The reduction goals defined in the Strategy are clearly not ambitious enough to meet its objectives. The objectives for the Air Strategy have been defined in the Sixth Environment Action Programme(4). This programme aims at "contributing to a high level of quality of life and social well-being for citizens by providing an environment where the level of pollution does not give rise to harmful effect on human health and the environment" (Art. 2.2). More specifically for air pollution policies, the objectives are "achieving levels of air quality that do not give rise to significant negative impacts on and risks to human health and the environment" (Art 7.1) "with a view to reach the long-term objective of no-exceedance of critical loads and levels" (Art 7.2.(f)). This means achieving levels of air quality which protect people’s health - as well as ecosystems - from air pollution. The current proposal would still result in roughly 230,000 premature deaths due to air pollution, 63,000 square kilometres of forest with excess acidification, and 416,000 where the critical loads for eutrophication are exceeded.

The combined reduction package chosen by the Commission is between the medium and low ambition levels, which had been considered in the background studies. The decision to opt for such a low ambition level has been primarily motivated by cutting costs. However calculations show that even for the most ambitious scenario considered in the background analysis (Scenario C), benefits would still exceed costs by a factor of up to 10.

Smoke and mirrors

A consequence of the integrated approach should be that the Strategy would result in emission reductions from all sectors addressed. We welcome that the Strategy explicitly addresses Transport, Agriculture and the Structural Funds as areas of EU policy-making where action is required to reduce air pollution. However, regarding the important agricultural sector the Strategy is much too tame in its wording. The background studies for the preparation of this Strategy clearly show the growing importance of the agricultural sector in causing air pollution - whereas the Strategy only mentions that reductions in air pollution in the agricultural sector from implementing existing EU law “could be insufficient” to meet the objectives of the Strategy. Here concrete proposals for measures to further reduce emissions from the agricultural sector are needed.

Regarding Structural Funds the Strategy is also much too weak, as it only mentions that some elements in the Commission Proposal for the reform of the cohesion policy for 2007- 2013 will help to meet the objectives of this Strategy. It does not address the problem that current Structural Fund projects often support unsustainable investments that further undermine EU environmental policy goals.

The Strategy outlines a number of possible legislative proposals. The most important of these are the review of the National Emission Ceilings Directive (NECD), proposals for further tightening emission limits for new cars (EURO 5) and for heavy duty vehicles (EURO 6), an expansion of the IPPC directive to cover Small Combustion Plants, a directive to reduce VOC emissions from fuel stations, setting NOx emission limit values for ships, and measures to reduce nitrogen use for animal feedstuffs and in fertilizers. While there are concrete dates for EURO 5 (by end-2005) and the NECD review (2006), the Strategy remains vague regarding the other possible directives. It states that new measures “may be envisaged” after being “subject to careful impact assessment”. It is of primary importance that in these areas concrete legislative proposals are rapidly developed - without them the objectives of the Thematic Strategy cannot be realised.

Directive proposals much too weak

The directive for emission limit values for new passenger cars and light duty vehicles (EURO 5) has been delayed for months now. Publishing it at the end of 2005 is much too late. In an internet consultation during the summer, the Commission suggested potential emission limit values for this directive which are far too weak - particularly for nitrogen oxides.

The proposal for a revised air quality directive is the only legislative element that was adopted together with the Strategy. In order to contribute the Strategy’s goals it would need to set an ambitious and legally binding new standard for fine particles (PM2.5)(5). The Commission proposed two elements to regulate PM2.5 in future: concentration cap of 25 ?g/m3 to be met in 2010, and a requirement to reduce population exposure to fine particles by 20% between the years 2010 and 2020. However, this combined suggestion on PM2.5 is a toothless tiger: the concentration cap is legally binding but will not bring any additional improvements, because these levels will be met anyway through existing legislation by 2010. The second element - which could potentially require further reductions - is not legally binding, but only a non-binding target.

To worsen the picture, the Commission opened up the possibility of applying for derogations of up to five years to meet the existing limit values. This possibility is introduced for the limit values on coarse particles (PM10), which entered into force this year as well as for the limit values on NO2 and benzene, which will become legally binding in 2010. Furthermore, by introducing a new paragraph which allows for some discounting of sea salt and desert sand, it effectively weakens the current EU limit value on coarse particles. Paradoxically this is referred to in the Thematic Strategy as “strengthening implementation”. This is a clear euphemism for a directive proposal which might best be summarised as half a step forward, two steps back.

For further information: Kerstin Meyer, EEB Policy Officer Air Pollution, Noise and Urban Environment

(1) Sulphur dioxide (SO2), Nitrogen Oxides (NOx), Ammonia (NH3), volatile organic compounds (VOC) and particulate matter (PM). (2) These are emissions of primary particulate matter - fine particles which are emitted directly. There is also a significant share of fine particles, which is formed indirectly - that is by precursor gases such as SO2, NOx and NH3. In order to reduce particles it is therefore important to reduce all those pollutants. (3) Decision N° 1600/2002/EC of the European Parliament and the Council of 22 July 2002 laying down the Sixth Community Environment Action Programme, Art. 7.2 (f). (4) Decision N° 1600/2002/EC of the European Parliament and the Council of 22 July 2002 laying down the Sixth Community Environment Action Programme. (5) PM is "particulate matter". Particles which pollute ambient air are generally referred to by their size. Dust particles which are 2.5 micrometers in diameter - about 1/30 of a human hair - are called fine particles, or PM2.5. The slightly larger particles are up to ten micrometers in diameter and are called PM10, or coarse particles.

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