Ten one-liners for air policy

In politics, one-liners are in vogue because they bring the message back to the core. Nuances do not come across in a debate. The same seems to apply to air pollution policy. The multitude of information seems to paralyse policy, and not only in the Netherlands. So here are ten ‘one-liners’ for boosting air pollution policy, in the spirit of the Ten Commandments.

One-liners linger. Air pollution is complex and, especially for EU countries, taking measures is not easy. The ten crisp conclusions in the form of one-liners partly rest on experience gained in negotiations in the EU and the UN, and partly on literature.

1. Air pollution is still a problem
Since the eighties, emissions into the air in Europe have been reduced considerably and air quality has profited^1,2. Yet in many parts of Europe, concentration and deposition levels exceed standards and sustainable levels. The Netherlands is a ‘hot spot’ for many forms of air pollution with a relatively high load of acid and nitrogen, but also high levels of ozone, particulate matter, nitrogen oxides, heavy metals and persistent organic substances³. The Netherlands struggles to meet air quality standards for nitrogen dioxide and particulate matter. The country has taken many measures and has one of the lowest emissions per GDP or per capita. However, the Netherlands still has the highest emissions per km².

2. Air pollution policy in EU countries comes from  Brussels
EU member states have transferred much of their environmental policy-making to the EU, estimations are 80%. The European Commission prepares legislation and monitors the implementation by the member states. The Netherlands mainly implements EU regulations. This is reflected by the decline in the number of civil servants at the Ministry of Environment. Twenty years ago, 1250 employees worked there, now around 150.

3. EU standards are national standards
Air quality must meet certain requirements, for example the fine dust concentration must not exceed 40 micrograms/m³ (PM₁₀, yearly average). This standard has been prepared by the European Commission and the member states. EU countries have subsequently accepted this standard at an Environmental Council meeting. By accepting the same air quality standards, all EU countries created a level playing field for health and nature. You can also have a level playing field for industry with equal emission requirements. When the latter conflicts with an air quality standard a country should apply stricter emission requirements. A concentration requirement supersedes an emission standard.

4. Benefits of air measures are greater than the costs
Two cost–benefit analyses (CBAs) were carried out for the Gothenburg Protocol, which was completely revised in May, one for all countries4 and one for the Netherlands5. Without exception, CBAs show that the benefits of further measures to reduce air pollution are many times greater than the costs. Not so strange, because fewer hospitalisations and a longer life (productivity and paying taxes) are substantial benefits. Nature (biodiversity) also benefits from measures. Unfortunately, it is not easy to substantiate this in monetary terms. Benefits are thus usually underestimated. The costs tend to be lower than first calculated.

5. International emission   reduction measures are cheaper than local measures
When concentrations exceed air quality standards, additional measures should be taken. For nitrogen dioxide and particulate matter many EU countries face this problem. The Netherlands has chosen to take action through the National Air Quality Collaboration Programme (NSL). The NSL consists of mostly local measures to reduce concentrations in certain streets. These are expensive source-oriented measures (e.g. cleaner buses, soot filters on diesel cars) and effect-oriented measures (e.g. one-way traffic in streets). The costs of NSL are estimated at 1.5 to 2 billion euro over nine years. In general, it is much more effective and cheaper to reduce emissions at the European scale^5,6,7. Moreover, in contrast to local measures the costs of internationally agreed lower emission limits are borne by the target groups (industry, traffic etc.) and not governments.

6. Environmental costs are offset by other competitive factors
The Netherlands Environmental Assessment Agency (MNP) has investigated8 whether environmental rules cause companies to leave the country. MNP concluded that the costs of environmental regulation represent only a small part of the total production costs and they are less important than other competitive factors such as favourable geographical location and the presence of trained personnel.

Yet you see large Dutch farms in Eastern Europe and elsewhere. Apparently, the more strict requirements on environment and animal welfare in the Netherlands impose more weight than logistical and other advantages. This is not good for the environment and the Dutch economy.

The exodus of intensive livestock farming from the Netherlands shows that equal international standards are important.
The overall conclusion of one-liners 4, 5 and 6 is: Far-reaching international measures are a top priority.

7. Integration of air and  climate policy is inevitable
The Gothenburg Protocol (UN/ECE Convention on Long-range Transboundary Air Pollution (CLRTAP)) and the EU National Emission Ceilings Directive save billions through an integrated approach to air pollution compared to a uniform reduction approach per substance. Air pollution and greenhouse gases both originate from the burning of fossil fuels and agriculture. Also, various effects are correlated. Ozone is the third most important greenhouse gas after carbon dioxide and methane⁹. Also, black carbon is an important greenhouse gas. Integration is more efficient and cheaper, and it creates opportunities. For developing countries, improved air quality can be a profitable and attractive side effect of climate change mitigation. In 2050 air pollution will be the main cause of premature deaths, causing 3.6 million early deaths per year worldwide, especially in Asia¹⁰. In a workable future, negotiators for climate change would define the reduction targets and regionally these goals are the basis for formulating measures for air pollution.

8. International environmental agreements have to be reformed
The economic crisis is not the main cause of the collapse of international environmental policy-making in recent years. Unpopular measures that deliver in the long-term are not attractive to politicians. Environmental treaties have a negative motivation for they focus on solving problems by (reduction) obligations. A first step to solve a problem usually succeeds because low-hanging fruit is picked. Further action is more difficult. It is of no help that decisions are taken by consensus. Also, the enforcement of agreements is an issue. Non-compliance with obligations rarely leads to sanctions.

This has to be solved, but how? An important improvement would be that the intent of environmental treaties should be positive. Solutions must lead to benefits instead of limitations. An example of a more positive solution for climate change would be to link the credit, energy and climate crises¹¹. End all stimulation of energy use (rebates for large consumer’s tax breaks and subsidies) and billions could be saved and used to finance deficits. This would further stimulate the process of making alternative energy cheaper than fossil energy. This benefits the environment, oil and gas will last longer and we would be less dependent on the Middle East and Russia.

9. Scientific knowledge steers international policy
Since the Treaty of Lisbon (2009), the European Commission speaks for all EU countries during plenary sessions of international environmental meetings. This has its advantages. Obviously, the EU coordinates its inputs with member states. Although the Netherlands is small, the influence of the Netherlands in the EU and at the international environmental conventions is relatively large, because the Netherlands has some excellent environmental institutes. These provide reports of high quality and they are involved in preparatory groups. It is in these groups that decisions are prepared. A move from a PM₁₀ standard (includes all larger particles and sea salt that is considered less harmful) to a standard restricted to smaller particles PM_2.5 or PM₁ (mostly combustion aerosols), can only be achieved when there is consensus among scientists.

10. Influence comes with powerful (political) commitment
Science yes, but essential is a powerful and political input in Brussels. Indeed, the Commission has the right of initiative for legislation. This means that a minister already at the front of the policy process must seek cooperation with colleagues in the Environmental Council to get a subject on the agenda. In the elaboration of policies and measures, the negotiating civil servants must feel supported by the official and political management. At an Environmental Council the minister, who is fully aware of the development on a file, should vigorously promote a desired decision.

Finally
Obviously, nuances and details are sacrificed when you reduce information in the field of air pollution to ten one-liners. I hope that they can guide civil servants and politicians to a successful air pollution policy.

Johan Sliggers

The National Institute for Public Health and the Environment (RIVM) currently employs Johan Sliggers (johan.sliggers@rivm.nl, tel. + 31.30.2743147). He has been head of delegation for the Netherlands from 1998–2010 preparing international agreements in Geneva (CLRTAP) and Brussels (EU) to reduce air pollutant emissions.

References:
1) Sliggers Johan and Kakebeeke (editors), Clearing the air, 25 years of the Convention on LRTP, 2004.
2) Amann M. et al, Environmental Improvements of the 2012 Revision of the Gothenburg Protocol, IIASA, CIAM report 1/2012, version 1.1, September 10, 2012.
3) Sliggers Johan e.a., Convention on Long-range Transboundary Air Pollution, Dutch Hope…. (in Dutch), Milieu no. 3/Dossier, pages 29-33, 2009.
4) Holland M. et al, Cost Benefit Analysis for the Revision of the National Emission Ceilings Directive: Policy Options for revisions to the Gothenburg Protocol to the UNECE CLRTAP, AEA/ ED47788 Final Issue 2, 2011.
5) Smeets W. et al, Costs and benefits for stricter emission ceilings: national evaluation of the Gothenburg Protocol (in Dutch), www.pbl.nl, PBL-publicatienummer 500092002, 2012.
6) Particulate Matter: a closer look, p. 14, Netherlands Environmental Assessment Agency report no. 5000370011, www.rivm.nl, 2012.
7) Amann M. et al, An Updated Set of Scenarios of Cost-effective Emission Reductions for the Revision of the Gothenburg Protocol: Background paper for the 49th Session of the Working Group on Strategies and Review, Geneva, September 12-15, 2011, IIASA, CIAM report 4/2011, Version 1.0, , 2011.
8) Brink. C et al, Environmental policy and competition (in Dutch), MNP rapport 500091002/2007, www.pbl.nl, 2007.
9) IPCC, Fourth assessment report: Summary for Policy makers WG1, p. 4, 2007.
10) Environmental outlook to 2050: The consequences of inaction, 2012.
11) VVM-sectie Lucht en Klimaat, Link Credit, Energy and Climate Crises (in Dutch), Milieu no. 4, p. 21, July 2012.