The European Union’s Acidification Strategy (II)

As outlined in the previous article, a properly-designed EU Acidification Strategy should not be restricted only to a consideration of the available emission control options and the associated costs to fully achieve environmental targets over the next 10 to 15 years. Imprecisions of modelling, inaccurate predictions of energy consumption and energy mixes, diminishing returns when approaching the 100 per cent ecosystem protection level and limited financial resources suggest a step-wise approach where additional legislation is only decided and implemented once the actual improvement of the environment over the next years deviates from the path of ultimately meeting the environmental targets by 2010. The most positive feature of the Acidification Strategy is its objective to assign overall reduction goals to individual countries. This approach would ensure that countries are not being restricted from designing a legislative package of measures which is most cost-effective for their specific national situations. To this end it is confusing that the Commission is currently planning for a series of additional directives which attempt to enact EU-wide legislation on the very same pollutants addressed by the Acidification Strategy. The diagram below shows some of this overlapping legislation in the context of the ‘umbrella legislation’ of the Acidification Strategy and the Air Quality Framework Directive. While the need for the harmonization of vehicle emission standards and transport fuel quality is justified, uniform legislation on emissions from stationary sources is counterproductive to the principles of the Acidification Strategy which leaves maximum flexibility to Member States to decide on their most cost-effective control strategies in line with the subsidiarity principle.