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Ahead of the 15 July vote in the Environment, Public Health and Food Safety (ENVI) Committee on the revised National Emission Ceilings (NEC) Directive report, more than 60 health, environmental and animal welfare organisations signed a letter containing recommendations to MEPs for ambitious EU action that will benefit people’s health, the environment and the economy.

Dear Members of the Environment, Public Health and Food Safety (ENVI) Committee,

On 15 July 2015, you will vote on Julie Girling’s report concerning the revised National Emission Ceilings (NEC) Directive. On behalf of a coalition of over sixty health, environmental and animal welfare organisations, we urge you to stand for ambitious EU action that will benefit people’s health, environment and the economy.

Every year, over 400,000 Europeans die prematurely because of air pollution. Bad air quality causes severe illnesses such as cardiovascular and respiratory disease, aggravation of asthma and chronic obstructive pulmonary disease (COPD), harms to children’s healthy development and is a risk factor for diabetes. The health-related economic costs of air pollution are enormous, amounting to between €330 billion and €940 billion for the EU in the year 2010 alone. [[European Commission’s Impact Assessment, page 43]] This is equivalent to between 3 and 9% of the EU’s GDP. Air pollution also impacts Europe’s nature and biodiversity, agricultural yields and natural vegetation. Crop yield losses due to air pollution are estimated at €3 billion per year in 2010. [[European Commission’s Impact Assessment, pages 14 and 19]]

More ambition is necessary, possible and cost-effective. The Commission’s proposal to revise the National Emission Ceilings (NEC) Directive is very welcome but is far from sufficient to solve Europe’s air quality problems. The European Parliament’s impact assessment shows that the new EU climate and energy policy agreed by the Council in October would lead to significant air quality improvements for costs that are lower than in the initial Commission proposal. [[Complementary Impact Assessment on interactions between EU air quality policy and climate and energy policy, November 2014. See EU and country by country comparisons by using the Air-o-Meter.]]

We therefore call upon you to support:

BINDING & AMBITIOUS EMISSION REDUCTION COMMITMENTS FOR 2025

Given the scale of damages caused by air pollution in the EU, the binding 2030 targets are clearly too far away in the future. Legally binding 2025 emission reduction commitments (ERCs) would save 42,865 additional European lives per year compared to the Commission proposal. See more comparisons here.

AMBITIOUS EMISSION REDUCTION COMMITMENTS FOR 2030

Over 260,000 premature deaths would still occur in 2030 even after implementation of the Commission’s proposal. Bigger emission reductions would lead to fewer damages and further socio-economic benefits. The 2030 emission reduction commitments (ERCs) would save 19,824 lives of Europeans per year compared to the Commission proposal. See more comparisons here.

AMMONIA EMISSION REDUCTION COMMITMENTS

Ammonia emissions impact Europe’s biodiversity as well as health through the formation of particle matter (PM). During days of high air pollution levels, over 50% of PM concentrations can be due to ammonia emitted outside cities, mostly by farms and by manure application and handling practices. [See for instance French study showing that 51% of PM2.5 concentrations during the March 2014 pollution peak in Paris came from ammonium nitrates from agriculture (CNRS, 2014). Available here: http://www2.cnrs.fr/presse/communique/3481.htm]] Solutions to reduce ammonia emissions at farm level are well known and cost-effective. See [here how ammonia emissions affect human health.

METHANE EMISSION REDUCTION COMMITMENTS

In addition to being a powerful greenhouse gas, methane contributes to the formation of ground level ozone which has a severe impact on human health and vegetation. Methane reductions under the NEC Directive would therefore be a necessary and complementary tool to EU climate policies. Agriculture is the largest source of human-related methane emissions (45%). Emissions come from cattle, sheep and other ruminants as part of their normal digestive process and from manure decomposition (particularly from industrial lagoons as opposed to field deposited). See here how methane emissions affect human health.

MERCURY EMISSION REDUCTION COMMITMENTS

Given the transboundary nature of mercury emissions and their significant adverse impacts on human health, the inclusion of mercury emission reduction commitments in the NEC Directive as proposed by the ITRE Committee would be an effective way of protecting human health from a dangerous exposure to mercury. This would be consistent with the recent adoption of the Minamata Convention, which is a legally-binding treaty to cut mercury emissions. The main source of EU mercury emissions in the air is coal-burning.

DELETION OF FLEXIBILITIES

While some degree of flexibility is necessary in a Directive which sets objectives over a very long time scale, this needs to be limited to ensure the Directive enforceable and does not risk losing the necessary health and environmental protections.

EFFECTIVE NATIONAL AIR POLLUTION CONTROL PROGRAMMES (NAPCPS)

Member States should design appropriate, effective and timely measures at national level to improve air quality throughout their territory.

ACCESS TO JUSTICE AND PUBLIC PARTICIPATION & INFORMATION

The Directive should facilitate access to environmental information on air pollution and the impact it has on health and the environment; the participation of the public in the formulation of national programmes to reduce emissions of air pollution; and access to justice where laws regulating air pollution are broken.

Thank you in advance for your support.

Yours sincerely,

Jeremy Wates

Secretary General
European Environmental Bureau (EEB)

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