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Transboundary air pollution
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Transboundary air pollution
- Calls for concerted action

Text from pamphlet published jointly in November 1999 by Swedish NGO Secretariat on Acid Rain, European Environmental Bureau (EEB), European Federation for Transport and Environment (T&E).



Introduction
The innovative strategies employed by the Convention on Long-Range Transboundary Air Pollution have brought forth smart solutions which have saved, and continue to save, several billion euros every year – on account both of their cost-efficiency and avoidance of damage that air pollution would otherwise have caused.

The combination of the new multi-effect protocol and already existing and proposed legislation is expected to result in considerable environmental improvements. The new protocol, however, provides only a first step. In the absence of further measures, by 2010 millions of European citizens will still be exposed to harmful concentrations of ground-level ozone, and large areas of sensitive ecosystems will still be receiving acidifying and eutrophying deposits in excess of the critical loads.

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Innovative protocol but sluggish signatories
The new multi-effect protocol to the Convention on Long-Range Transboundary Air Pollution (CLRTAP) certainly represents an advance. Thanks to extensive, skilfully prepared work it became possible to attain something that had seemed almost utopian when preparations for the protocol started in the summer of 1994: to work out an agreement involving environmental quality targets to combat several different kinds of environmental effect - ground-level ozone, acidification, and eutrophication - and including requirements for reducing emissions of four pollutants (sulphur dioxide, nitrogen oxides, ammonia, and volatile organic compounds).

After five years of data gathering, analyses, meetings of experts, and negotiations, a plan of action emerged. Its environmental aims - the so-called interim environmental quality targets - were clearly expressed. All the countries have had a hand in setting these targets, which were based on a thoroughgoing analysis of cost-effectiveness, spreading commitments so as to attain the aims at the lowest possible cost. On top of all this, an analysis of the economic benefits was made, showing that the overall gain would be most likely to exceed the outlay five times over.

It is all the more deplorable to have to recognize that most of the participating countries are unwilling to take the necessary steps to cut down emissions even to the extent required to meet the modest targets set by themselves as late as in January 1999. At the final meeting for negotiation in September 1999, several countries laid claim to national ceilings for emissions that were higher, in some cases much higher, than those in the plan. Some figures were even higher than they would be as a result of current legislation and the country’s existing commitments. Still more astonishing, perhaps, was the fact that not even those countries that are normally in the forefront in these matters were prepared to give full backing to the proposed ceilings.

The reasons for this seemingly strange behaviour are many. Some countries are using the Convention as a means of demonstrating their opposition to some proposed EU legislation. Some, too, have given way to powerful lobbying by industry against stricter environmental requirements. Some consider that they have already done more than others, and so do not want to do anything further until the others have caught up with them.

A further reason, unfortunately all too common, is that many countries have simply not done their homework (although they do not care to admit it). They have not dug up the necessary information and analyzed what they actually could do. Consequently they have failed to gain popular support for any more advanced measures

In conclusion, the multi-effect protocol is a step in the right direction – but it is far from enough to achieve the reductions in emissions necessary to protect human health and the environment.

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Why international agreements?
Environmental demands are ever more frequently met with the excuse that "we as a country cannot proceed alone," followed by others such as "it would impair our international competitiveness," or "it would be pointless, since anything we could do would have so little effect on the general situation." The final escape is usually "the problem can only be solved by international agreement."

The Convention on Long-Range Transboundary Air Pollution (CLRTAP) came about precisely to overcome this reluctance. Under it, too, many countries have made great efforts to reach concrete proposals for internationally agreed measures. Although they fail to have global application, for the participating countries these measures nevertheless involve the greater part of the "international competition" (the CLRTAP is supported by more than forty countries in Europe and North America).

The actual effect of the CLRTAP and its resulting protocols is not that easy to determine. So far only the first protocols, i.e. those of 1985 for sulphur, 1988 for nitrogen oxides (NOx), and 1991 for volatile organic compounds (VOCs) have run their course. The final years for attainment of the agreed targets were 1993, 1994, and 1999, respectively. According to available emission statistics, all countries that signed the 1985 protocol achieved the target of at least a 30 per cent reduction in their emissions of sulphur. It may however be of interest to note that of the twenty-one original signatories, more than half had actually reached that target already in 1985, the year of the signing of the protocol. In effect, most European countries – including those who did not explicitly support the 1985 protocol – have achieved emission reductions well beyond the 30-per-cent target. Some countries, such as Austria, Finland, the former West Germany, Norway, Sweden, and Switzerland reduced their emissions by 70-85 per cent, while a few countries (Greece and Portugal) actually increased their emissions. The overall result was that between 1980 and 1993, total European emissions of sulphur fell by more than 45 per cent.

Turning to the 1988 protocol on NOx, the 25 signatory countries committed themselves only to a freeze in their emissions, i.e. to restrict their emissions to below the 1987 levels after 1994. The most recent statistics available indicate that five signatory countries - Belgium, France, Greece, Ireland, and Spain - did not manage to fulfil even this modest commitment. (Some of these countries have however failed to submit emission data for the base year or the target year, and Belgium has not yet ratified the protocol.) Total European NOx-emissions fell by more than 10 per cent over the time period in question.

According to the 1991 VOC protocol most of the 23 signatory countries are to reduce their emissions of volatile organic compounds by at least 30 per cent by 1999 (from what they were in 1988 or any other year between 1984 and 1990). Since emission data for the target year is not available, the countries’ performance in relation to this protocol cannot yet be evaluated. Between 1988 and 1997, European emissions of VOCs have come down by nearly 20 per cent

But there is more to international agreements than the obligations provided in convention and protocol texts. One additional major advantage is the activities created by the process of arriving at such agreements. In general it is thought desirable to get as many countries as possible involved. Active participation in the working out of an agreement means that even countries that are relatively uninterested are forced to produce information on emissions, depositions, and effects – the data that will show both the need to reduce emissions and indicate, to some extent, how a reduction can be brought about. This is one reason why the countries that feel a special involvement want to get the uninterested ones and the laggards to join in.

But the uninterested and the laggards themselves have an interest both in being able to participate in the negotiating process and to eventually sign the agreement. It is naturally easier for governments to face environmentalist opinion, both at national and international level, if they can show that theirs is among the countries that have signed the latest international agreement. Moreover, by participating in its development they have better opportunities to both delay its conclusion and get its requirements watered down.

The very process of negotiation brings an added value in that it hastens the production of new data, both because the negotiations require it and because there is often a deadline for conclusion of the agreement. It is also important for the formation of opinion. No matter whether the agreement can be regarded as "good enough" from an environmental point of view, there is always pressure from public opinion, as expressed through environmental groups, to get a protocol signed and respected.

In the historical context, therefore, the process of arriving at agreements may be considered as having contributed considerably to the protection of the environment. It has caused a lot of data to be produced which otherwise would have been difficult if not impossible to come by. It has moreover promoted the exchanges of knowledge and experience – thus in turn influencing the decisions of various countries with regard to measures for curbing emissions.

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Shortcomings
The new multi-effect protocol provides only a first step towards attaining 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 new protocol, by 2010 millions of people living in most European countries will still be exposed to ozone concentrations exceeding the World Health Organization’s guideline for protecting human health. Similarly, several million hectares of sensitive ecosystems will still be receiving acidifying and eutrophying deposits in excess of the critical loads.

The current methodology, i.e. the one used for the multi-effects protocol, is a great step forward, but there are still some areas of concern. The first one involves the estimates of the costs and the potential for emission reductions.

- These estimates have been based on a reduction of the emissions solely through the application of technical "end-of-pipe" measures – thus ignoring the fact that a lot of non-technical methods are possible and often relatively inexpensive. Among them are so-called structural changes (such as switching fuels from coal to gas or biofuels, improving energy efficiency, and early decommissioning of old, inefficient, and polluting plants).

- The figures on emission reduction potentials and abatement costs used in the analysis are restricted to reflect current technology and costs. They take no account of technical developments and improvements that could result in a more efficient removal of the polluting substances, and lower cost. Nor of new techniques that are coming onto the market.

- Finally there is the fact, and perhaps the most significant, that the energy projections that have been used for making the analysis stand in total contradiction to many of the countries’ commitments in the Kyoto protocol to reduce the emissions of the greenhouse gas carbon dioxide. According to an analysis for the European Commission made with the use of more appropriate energy projections, implying fulfilment of the EU commitment under the Kyoto protocol, the cost of meeting the requirements of the recently proposed national emission ceilings directive would be 40 per cent less than supposed.

A second concern is that by using a very coarse mapping of depositions and critical loads, the outcome from the computer model analysis is likely to underestimate the environmental damage, both now and in the future.

Taken together, these shortcomings of the current analysis result in an underestimate of the emission reduction potential, an overestimate of the costs of achieving a certain environmental quality target, and an overestimate of the environmental results of a given emission reduction. As a consequence, decision-makers are led to believe that emissions reductions are both more difficult to achieve and more expensive than is actually the case. They are also given the impression that the environmental problems are smaller and less acute, than is actually the case.

Implementation and reporting is a third area of concern. As described above, many participating countries do not fulfil even the minimum requirements on reporting. This, in turn, makes any efforts to monitor these countries’ compliance with the agreements extremely difficult, sometimes even impossible. The CLRTAP’s implementation committee reported in 1998 that very few parties have been respecting reporting deadlines, and that between 1994 and 1998 only about 70 per cent of the parties submitted reports on strategies and policies. Consequently, countries must improve procedures for reporting. Moreover, in order to ensure overall compliance, the CLRTAP needs to develop more effective means of monitoring and enforcement.

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The next step
Parallel to the CLRTAP negotiations on the multi-effect protocol, the European Commission has developed a proposal for a new directive prescribing national emission ceilings (NECs) for the same four air pollutants as covered by the protocol. The proposal, which was presented in June 1999, is based on the same principles and methodology as the multi-effect protocol. In general the NECs in the Commission’s proposal are stricter than those of the multi-effect protocol. The decision-making process in the EU will probably take some time (usually about two years) before the directive is finally adopted. In any case, by 2003-2005, review and revision are envisaged both for the multi-effect protocol and the EU’s NECs directive. In order to facilitate these processes, preparatory work ought to start right away. Moreover, to ensure widespread support for further emission reductions, public awareness and knowledge of the air pollution problems will have to be improved.

Funding, reporting and implementation
From the above it is obvious that there is a need to further improve and refine the work on emission abatement strategies. To continue the development of such strategies, as well as to ensure effective implementation of existing undertakings, it is crucial that governments provide adequate funding to support the core activities of the CLRTAP. For the same reasons, countries must improve their reporting on emissions, strategies and policies. Eventually, more effective means of enforcing compliance with the basic obligations of the CLRTAP protocols need to be found.

Information
The CLRTAP should develop means to communicate its work and results to individuals, institutions, and organizations which are currently not adequately informed or involved. Promoting a wider awareness and involvement will improve public acceptability, which in turn will help maintain and hopefully also enhance the political momentum.

Review and revision
Preparations for the first review of the new multi-effect protocol should start immediately. Since it is both necessary and cost-effective to significantly raise the level of ambition, emissions must be further reduced - even more so than was indicated in the so-called guiding scenario, the scenario that provided the starting point for the negotiations on the multi-effect protocol. Consequently, any proposals for revision should aim for higher levels of health and environmental protection compared to those used for the guiding scenario.

Benefits outweigh costs
A higher level of ambition is justified not solely for environmental reasons, but also on economic grounds. The incremental cost of attaining the environment quality targets of the so-called guiding scenario has been estimated at up to euro 8.5 billion per year in 2010. While this figure may appear high, if spread over the population it represents an additional annual cost of approximately euro 12 for each European. Moreover, for the reasons given above, it is obvious that this figure is an overestimate.

More far-reaching emission reductions will be 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 incremental gains of the guiding scenario have been estimated at euro 46 billion per year, i.e. more than five 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, reduced risk of effects on forest productivity, and less damage to cultural heritage.

Long-term objective
The policy objective as regards air pollution, as spelled out in inter alia the European Union’s Fifth Environmental Action Programme, is to protect people’s health and the environment. The long-term environmental quality targets in relation to air pollution are that all people should be effectively protected from recognized health risks from air pollution, and that critical loads for acidification and eutrophication should not be exceeded anywhere.

Required emission cuts
In order to eventually attain the ultimate target of no exceedance of the critical loads, it is obvious that further significant reductions in emissions must take place. Scenario analysis done by the CLRTAP’s expert group on integrated assessment modelling has demonstrated that even the application of so-called maximum technically feasible reductions would not be enough. This scenario assumes a reduction in the emissions of sulphur, nitrogen oxides, volatile organic compounds, and ammonia of about 90, 80, 75, and 40 per cent respectively, compared to emissions in 1990. Despite these reductions, the critical loads for acidification and eutrophication would still not be achieved everywhere. Damaging levels of ground-level ozone would also remain.

Taking internationally agreed scientific data on critical loads as a basis, more than twenty European environmental organizations have agreed on the following as objectives with regard to the overall emissions of air pollutants in Europe: At least a 90 per cent reduction in emissions of sulphur dioxide and nitrogen oxides, and at least a 75 per cent reduction in emissions of volatile organic compounds and ammonia. These are minimum demands, but they do not necessarily imply that every country or region must achieve equal reductions. In areas with very high emissions, greater reductions will be necessary, while in some others areas the reductions may be allowed to be lower.

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Some references

First Report of the Implementation Committee (September 1998) UN ECE Report EB.AIR/1998/4. UN ECE, Geneva, Switzerland.

Integrated Assessment Modelling – Progress report by the Chairman of the Task Force (June 1999). UN ECE Report EB.AIR/WG.5/1999/14. UN ECE, Geneva, Switzerland.

Economic phpects of Abatement Strategies – Progress report by the Chairman of the Task Force (June 1999). UN ECE Report EB.AIR/WG.5/1999/15. UN ECE, Geneva, Switzerland.

Limiting Marginal Costs of Emission Reductions (March 1999). By Amann et.al, IIASA, Laxenburg, Austria.

Analysis of the J1 scenario (May 1999). By AEA Technology, Culham, UK.

Acidification & Air Pollution: Still With Us (1997). By Elvingson, P. & Ågren, C. The Swedish NGO Secretariat on Acid Rain, Göteborg, Sweden.

Attacking air pollution – Critical loads, airborne nitrogen, ozone precursors (1995) Report from the fourth international NGO strategy seminar on air pollution. By Elvingson, P. & Ågren, C. The Swedish NGO Secretariat on Acid Rain, Göteborg, Sweden.

EMEP Emission Data – Status Report 1999 (1999) EMEP/MSC-W Report 1/99. By The Meteorological Synthesizing Centre-West, Norwegian Meteorological Institute, Oslo, Norway.

Transboundary Acid Deposition in Europe (1999) EMEP Report 1/99. By The Norwegian Meteorological Institute, Oslo, Norway.

Strategies and Policies for Air Pollution Abatement (1999) Major review prepared under the Convention on Long-Range Transboundary Air Pollution. UN ECE Report EB.AIR/65. UN ECE, Geneva, Switzerland.


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Published November 1999.

 
 
» Introduction

» Innovative protocol but sluggish signatories

» Why international agreements?

» Shortcomings

» The next step

» Some references


 

 

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