The European Union’s Acidification Strategy (I)
At the Environment Council in December 1995, the Commission was requested to develop a proposal, by the beginning of 1997, for a Community strategy to combat acidification. Following the Fifth Environmental Action Programme, the Council confirmed the political long-term goal of ‘no exceeding ever of critical loads and levels’.(1) The Commission’s study (conducted by IIASA, the International Institute for Applied Systems Analysis) showed that even with the most ambitious abatement programmes for reducing acidifying pollutants (SO2, NOx and NH3), the ultimate target of never exceeding critical loads could not be achieved by 2010. In line with the Environmental Council’s decision, the Commission therefore followed the ‘gap-closure’ approach which aims at reducing (by a certain percentage in each of the EMEP grid cells in the EU) the difference between the level of ecosystem protection in 1990 and the 100 per cent ecosystem protection by the year 2010. The Commission feels that the most appropriate interim target is a 50 per cent gap closure. In CONCAWE’s opinion, the basic approach of emission reductions by cost-effective measures and comparing the resulting control costs with the achieved benefits (in this case environmental benefits resulting from an improved protection of ecosystems) is valid. However, we believe that the Commission should avoid following a purely ‘mechanistic’ application of this concept without considering some additional criteria. Although these are not readily quantifiable, they are nonetheless important and need to be taken into account more on the basis of common sense considerations rather than strict scientific proof. These criteria relate to aspects such as: what society can afford in terms of control costs, limitations of financial resources and the associated need to prioritize funding among all of the perceived environmental problems;inaccurate forecasts of energy consumption and energy mixes; andthe diminishing returns in terms of environmental benefits since costs increase exponentially when approaching stringent control levels, etc.Although CONCAWE’s considerations refer, in this case, specifically to the draft Acidification Strategy, they apply in principle to any legislative proposal aiming at a reduction of emissions to cure environmental problems. In the following, the relevance of these criteria is further illustrated. Any emission abatement strategy needs to characterize both the current and the desired future status of the environmental compartment(s) under consideration. In the case of acidification, it is essential to establish emission inventories of the acidifying pollutants in individual countries. Inaccuracies experienced in determining not only future but also current inventories (for example, serious doubts have been expressed about present NH3 emission estimates) and with other input data in the modelling can lead to significant deviations between predicted and future real situations. The risk of ‘overshooting’ environmental targets is particularly high when the limits reach very low levels. The DG-XI study has shown that already-agreed but not yet implemented emission reduction measures, incurring costs of about 40 000 million ECU per year (REF 2010), will increase the Community area protected from non-sustainable acidification from 76 per cent in 1990 to 94 per cent in 2010. This alone would already be an impressive achievement and the question is how much more money should be spent to go further, keeping in mind that even the most ambitious emission reduction programmes will not achieve a 100 per cent protection within the foreseeable future. DG-XI has suggested the ’50 per cent gap closure’ which, according to the principles of diminishing returns, will result in incremental costs of 7–8000 million ECU per year with an increase of the protected area from 94 to 97 per cent.