Higher ambitions needed for NEC

Illustration: © Lars-Erik Håkansson

National emission reduction commitments for 2030 should ensure achievement of the World Health Organization’s recommended air quality levels.

A coalition of environmental groups has summarised their main concerns about the proposed revision of the EU’s National Emissions Ceilings (NEC) directive, and provided inputs to the ongoing decision-making process in the European Parliament and the Council.

Every year, over 400,000 Europeans die prematurely because of air pollution. Poor air quality also makes Europeans sick and significantly reduces their quality of life, in particular in cities. Increased illness, hospital admissions, extra medication and millions of lost working days are very costly for the European Union – the health-related costs of air pollution amounted to €330–940 billion in the year 2010 alone, which is equivalent to between 3 and 9 per cent of the EU’s GDP. This includes €15 billion in direct costs from lost workdays and €4 billion from treatments of chronic bronchitis. Air pollution also causes great harm to Europe’s ecosystems, crop yields, buildings and monuments.

Numerous studies have systematically demonstrated that the benefits of taking action to cut emissions of air pollutants outweigh the costs, in most cases by large margins.

Although environmental groups welcomed the Commission’s proposal from December 2013 to revise the National Emission Ceilings (NEC) Directive, they conclude that its ambition level does not match the scale of Europe’s air quality problems and the benefits at stake. Some of the main points of criticism are that:

• The targets, known as “Emission Reduction Commitments” (ERCs), set for 2020 have been copy-pasted from the 2012 revised Gothenburg Protocol without consideration of the potential for additional health and environmental benefits for the EU of higher ambition levels. These proposed ERCs are expected to be achieved by member states, in many cases by a wide margin, just by implementing existing legislation. In some cases, the proposed ERCs would even result in higher emissions in 2020 than are allowed under the old NEC Directive dating from 2010.
• The Commission’s proposal does not set legally binding reductions for 2025, thus risking the delay of urgently needed action until 2030.
• The proposed ERCs for 2030 are clearly not sufficient to achieve the World Health Organization’s recommended levels of air quality, which are equivalent to the EU’s long-term air quality objective as set out in the 7th Environmental Action Programme. Even after implementing the proposed 2030 ERCs, air pollution would still cause some 260,000 premature deaths every year, i.e. more than half of today’s death toll would still remain. Large areas of sensitive ecosystems would still be exposed to excessive inputs of acidifying and eutrophying air pollutants.

The European Parliament’s Rapporteur, British Conservative MEP Julie Girling, published her draft report in late March, saying that “the NEC Directive is Europe’s overarching framework piece of legislation for air quality, and without effective and implementable source legislation, member states will never meet their emission reduction targets. In other words, a further tightening of air quality standards will be redundant unless we see a clear reduction in pollution from the main sources”.

Her report recommends improvements with regard to some aspects of the Commission’s proposal, in particular the 2025 emission reduction commitments, which she proposes to make mandatory for four out of the six pollutants.

Environmental groups also welcomed her proposals to require member states to monitor the impacts of air pollution; to strengthen the role of both the Commission and the public in scrutinising national air pollution control programmes; to improve coherence between the NEC directive and the ambient air quality directive, as well as with source emission legislation; and to remove the proposed shipping flexibility.

It was noted with criticism, however, that she missed the opportunity to improve the proposal’s ambition level for 2020, 2025 and 2030, especially considering that since the Commission published its proposal nearly one and half years ago, there are new studies and developments that further strengthen the case for more ambitious air pollution reductions.

For example, recent adjustments to national emission inventories and projections by member states show more optimistic developments in air pollutant emissions in comparison with the Commission’s previous calculations (see AN 1/15, p 22). This means that more ambitious ERCs and higher benefits could be achieved for the same initial cost.

Moreover, the European Parliamentary Research Service’s impact assessment report demonstrates that more ambition is possible and can be achieved at the same or lower cost (see AN 4/14, p 18–19). It shows that reduced consumption of polluting fuels under the EU’s new climate and energy policy agreed by the EU Council last October would decrease the need and costs for air pollution controls and make further air quality improvements significantly cheaper.

In light of the significant health, environmental and economic benefits that would result from a more ambitious NEC Directive, the environmental groups call upon the European Parliament and the Council to support:

• Significantly stricter ERCs for 2025 and 2030. The ambition level should ensure the achievement of WHO’s recommended air quality levels by 2030.
• Stricter ERCs for 2020, based on the most recent baseline figures and on a linear pathway towards the achievement of the 2025 and 2030 levels.
• Legally binding ERCs for 2025 for all pollutants covered by the directive.
• Legally binding ERCs for methane and mercury for all three target years, 2020, 2025 and 2030. (Mercury is left out of the Commission’s proposal despite being a toxic and highly transboundary pollutant causing great damage to health and ecosystems.)
• The rejection of flexibilities such as adjustment of emission inventories and offsetting of emissions between land and sea.

On 15 June, environment ministers will discuss the directive in Brussels. A vote in the Parliament’s environment committee is scheduled for 15 July, with a plenary vote in September.

Christer Ågren

Source: “NGO recommendations on the revision of the NEC directive following the publication of the rapporteur’s draft report” (13 April 2015). By the European Environmental Bureau, Transport & Environment, ClientEarth, Health and Environment Alliance and AirClim.