The European Union's
Acidification Strategy
(I)

A potentially cost-effective option to reduce
emissions
in accordance with environmental
requirements

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; and

the 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.

Figure 1
Even the most ambitious emission
reduction programmes will not achieve a 100 per cent protection
within the foreseeable future

It appears that a legislative decision on this issue should not be
taken before thoroughly addressing and answering a number of important
questions, for example:

Wouldn’t it be more prudent to follow up real acidification trends
over the next years under the regime of already-agreed measures, rather
than to decide now on further emission reductions? It might well be
that, within the ‘error bands’ of the modelling exercise, the envisaged
target might already be being met without any additional legislation.

If proceeding from a 94 to a 97 per cent protection level, what kind
of sensitive ecosystems are incrementally protected? Are there other,
perhaps local means, to achieve a more cost-effective protection of
these singular ecosystems? For example, sensitive lakes or forest soils
without any buffering capacity could be treated with lime at probably
lower costs.

Is it appropriate to concentrate now on acidification problems only,
when during the next months the Community will embark on additional
programmes on the very same pollutants addressing eutrophication and
ground level ozone problems?

This will definitely change the reduction targets for the individual
pollutants. For example, if considering eutrophication (overfertilizing)
in addition to acidification problems, the reduction burden will change
from SO2 to NO2 and NH3. In this context it should be noted that the
UN-ECE Nitrogen Protocol, presently under debate, addresses all three
problems (acidification, eutrophication and ozone formation) caused by
acidifying pollutants in an integrated way, and involves eastern European
countries together with EU-15 Member States. This global and integrated
European approach would also lead to a more cost-effective solution as
opposed to legislation restricted to the EU-15 only.

CONCAWE feels that all of the above considerations should be taken into
account to strike a reasonable balance between ambitions to implement
environmental legislation of ever-increasing severity and decreasing
marginal benefits, and the costs which society is able and willing to
absorb. Equally the additional costs resulting from other environmental
legislation should be considered in this context.

(1) The critical load/level indicates the
sensitivity of a particular environment by defining how much exposure to
pollution it can tolerate before long-lasting or other significant damage
occurs.