The European Environmental Bureau (EEB)

The European Federation for Transport and Environment (T&E)

The Swedish NGO Secretariat on Acid Rain


Ozone and acidification

Brief comments to the proposal by the European Commission for a Directive on national emission ceilings and a Directive on ozone in ambient air (2000-03-01).

The damage to human health and the environment caused by ozone-forming and acidifying air pollutants constitutes one of the most serious environmental problems in Europe, and urgent action is necessary in order to reduce the emissions. In this context, we welcome the two new proposed directives by the European Commission. Although, both proposals provides steps in the right direction, they are far from enough to achieve the long-term objectives of the EUís Fifth Environmental Action Programme.

The proposal for a directive on National Emission Ceilings (NECs).

The proposed directive on national emission ceilings for the four harmful air pollutants - sulphur dioxide (SO2), nitrogen oxides (NOx), volatile organic compounds (VOCs), and ammonia (NH3) - has the potential to bring about obvious environmental and health benefits. However, it is both necessary and cost-effective to significantly raise the level of ambition as compared to the Commissionís proposal. There are several reasons for this:

- The environmental objectives will not be fulfilled

The objective of the Communityís environmental policy is to protect peopleís health and the environment. The long-term environmental quality targets in relation to air pollution, as given in the Fifth Environmental Action Programme, are that all people should be effectively protected from recognized health risks from air pollution, and that critical loads for acidification should not be exceeded anywhere.

The combination of the proposed NEC-directive and other already existing and proposed directives is expected to deliver significant environmental improvements in the coming decade. The proposed NEC-directive provides however only a first step towards the attainment of the long-term environmental quality targets. Even after full implementation of all current legislation as well as the emission reductions expected to result from the NEC-directive, by 2010 millions of persons living in most EU-countries will still be exposed to ozone concentrations exceeding the World Health Organizationís guideline for protecting human health. Similarly, several million hectares of sensitive ecosystems will still be receiving acidifying deposits in excess of the critical loads.

- The costs are significantly overestimated

The incremental cost of the NEC-directive has been estimated to amount to up to euro 7.5 billion per year in 2010. While this figure may appear high, if spread over the population, it represents an additional annual cost of euro 20 per person. Moreover, it is obvious that this figure is an overestimate. The cost estimates assume the application of technical abatement measures only. No account has been taken of structural measures, such as switching fuels from coal to gas, increasing energy efficiency, greater use of alternative energy sources and changes in the transportation and agricultural sectors. Such measures could reduce emissions at much lower cost as compared to relying solely on technical "end-of-pipe" solutions. Moreover, the performance of the technical abatement measures was based on the current state, i.e. technical development and improvement have not been accounted for.

Even more important is the fact that the underlying energy scenario is assuming a 20 per cent increase in energy use between 1990 and 2010, and an accompanying 9 per cent increase in emissions of the major greenhouse gas carbon dioxide (CO2). This is contradictory to the Communityís and the member statesí international commitment to reduce greenhouse gas emissions. It should be noted that measures aimed at reducing CO2-emissions will in general also reduce emissions of SO2 and NOx. According to the Commissionís own analysis, the use of an alternative energy scenario that would roughly meet the EUís Kyoto Protocol commitment would approximately halve the estimated costs for the NEC-directive.

- Vital benefits are at stake

The NEC-directive is vital to achieve the very significant benefits that are necessary both for health and the environment. While only some of these benefits can be estimated in monetary terms, the quantifiable gains have been estimated to euro 32 billion per year, i.e. up to four times higher than the (over)estimated costs. Among the gains not included in these figures are less acidification of soil and waters, less eutrophication, fewer effects on biological diversity, less long-term effect on forest productivity, and less damage to the cultural heritage.

The proposal for a directive on ozone in ambient air

Elevated levels of ground-level ozone remains a serious problem, causing damage to human health as well as to crops and natural vegetation over large parts of Europe. The Commissionís proposal for a new daughter directive on ozone is welcome, especially since it combines long-term objectives with a hot-spot management of ozone.

- The ozone standards should be based on the work of the World Health Organisation

The Fifth Environmental Action Programme states that "all people should be effectively protected against recognized health risks from air pollution" and requires that "WHO values (should) become mandatory at EC level". The WHO air quality guideline for ozone is 120 micrograms/m3 (8-hour value), and this value is also used by the Commission. There are however proposals put forward by industry to instead use 160 micrograms/m3 as the target value. This is obviously unacceptable, both because it is not linked to the WHO guideline, and since it would hide the fact that the ozone concentration has to be further lowered.

- The selection of the target value and the number of "allowed exceedance days"

Since this long-term target value of 120 micrograms/m3 cannot be easily reached within the next few years over large parts of the EU, the Commission proposes - as an interim target - to allow up to 20 days of exceedance of the target value by 2010. As described above, it is both necessary and cost-effective to significantly raise the level of ambition of the national emissions ceilings directive. If doing so, the level of ambition of the ozone directive could also be raised, and the number of "allowed exceedance days" be reduced. Moreover, while we agree in general to the approach of setting interim targets, such should be complemented by specified dates by which the long-term objective (in this case the WHO guideline) has to be reached.