The Future of Air Pollution Policy?
Tim Williamson, policy officer for the NSCA outlines the current developments in atmospheric environment policy.Over the past five years, the major preoccupation for the air quality community in the UK, NSCA included, has been the development and implementation of the Local Air Quality Management regime and the tools used in review and assessment. A second strand has been the periodic review of the UK Air Quality Strategy and its associated research findings. Both are clearly ongoing issues, and the latter will remain a periodic debate for the foreseeable future. More recently, the Clean Air For Europe process has been engaging, and mystifying, air pollution policy makers and technical staff alike, and the interactions with climate change have progressively risen up the priority list.
With LAQM now established and stable, at least into the medium term, and CAFE rushing towards its conclusion early next year, we've taken the opportunity to review the current developments in atmospheric environment policy and assess what the future drivers and priorities might be.
Principle EU/International Initiatives
CAFÉ The thematic strategy on air quality will be finalised early in 2005, in order to ensure its adoption by June. The strategy itself will be short (15 pages), but will be accompanied by a series of reports focusing on the outputs of the tree main pillars of the CAFÉ review process - RAINS, TREMOVE and the Cost Benefit Analysis working being led by AEA Technology. It will not address the review of the NECD or the Framework and Daughter Directives, but instead is likely to focus on sector specific issues and "new" pollutants. It is also possible that initial proposals for an "exposure reduction" approach to air quality control will be included.
NECD Review: Alongside the air quality limit values and product emission standards (e.g. the Euro standards for vehicles), the National Emissions Ceilings Directive is one of the main pillars of EU air pollution policy. Its revision was originally to be tied into the CAFÉ process, but delays have meant that it will take place 6-12 months after the thematic strategy is finalised. Currently, the NECD covers SO2, NOx and VOC, although there has been some discussion of including particles.
LCP: the revised Large Combustion Plants Directive has not yet been implemented in the UK (and other member states), but over time it will drive down further NO2 and NOx emissions. Its relevance and ambition levels could, however, be challenged, particularly when the emission limit values it contains are compared to the limits achievable under IPPC (the BREF note on LCPs is close to completion).
Euro Standards: A new Euro V for diesel cars and LDVs is currently being discussed and will be finalised early in 2005 - proposals on the table are likely to force manufacturers to install particle traps, although the standard will not be mandatory until at least 2010. Euro VI for HGVs will be debated towards the end of 2005. It has been suggested that Europe should move towards fuel and technology neutral standards (as is the case in the US), and that these should be technology forcing. Emission standards for CO2 have also been mooted.
Shipping Strategy: Shipping has been identified as a major source of both SO2 and NOx emissions, which will increase in both absolute and relative terms over the next few decades (shipping will make up around 75% of EU SO2 emissions and 66% of NOx within the next decade). Action at the EU level can be taken on fuel quality, but international law prevents requiring modification to the design or construction of foreign flagged vessels (including engine design), other than through the International Maritime Organisation. The Commission is developing a strategy on shipping, and also actively encouraging member states to ratify Annex VI to the MARPOL convention, to create a block EU vote in any amendment discussions (the UK has now ratified).
Emissions Trading: The impact of the EU trading scheme for CO2 emissions has yet to be fully assessed, but the inclusion of aviation is already being discussed, and both the UK and Netherlands have reportedly called for acid gas trading.
Priority Pollutants (all are transboundary)
Possible Future Priority Areas for Air Pollution:
This list does not include climate change emissions directly, but the assumption can safely be made that all policies will now have to be assessed for their effect on climate change.
New Approaches on exposure reduction: the work initiated by NSCA on supplementary approaches to Limit Values (see NSCA Briefing no. 35, November 2003) has gained greater impetus, and the development of workable "exposure reduction" systems is ongoing. The next stage will be to find ways to integrate these with the current regulatory structures.
Current Road Fleets: There are two particular concerns here - how can the turnover rate for new vehicles be increased, so as to introduce higher Euro standards faster into areas of poor air quality, and how can the current fleet, especially large diesel vehicles, be cleaned up. The first would need genuine incentives to buy, and therefore make available, cleaner vehicles, and the second would require a step up in the retrofitting on particle traps for public service and "local use" vehicles. This latter action may have the side effect of increasing direct NO2 emissions, and therefore raising roadside concentrations. Such effects need to be properly researched, quantified and then priorities against particle emission reduction.
Future Road Fleets: Improved Euro standards will help, but by specifying for petrol and diesel engines, they tend to consolidate current technology rather then drive innovation. In the long term, fuel neutral standards will be needed, whereby the ideal tailpipe emission is specified and it is up to the manufacturer how this standard is met. These will also need to include emission limits for CO2.
Shipping: In terms of CO2 emissions, shipping remains an efficient way to move goods around. However, while land based sources rightly come under ever tighter pollution control, shipping emissions are largely unregulated.
Access to Justice: Currently in the UK, judicial review remains the only route for a third party to challenge decisions taken in key areas of environmental law. This generally slow and expensive, and therefore probably in breach of the Aarhus convention on public access to environmental justice. The provision of specialist environmental tribunals is one solution which has been discussed, and which may well be taken further in the next few years.
By Tim Williamson, Policy Officer, NSCA (currently on secondment to DEFRA AEQ Division).
This article is reproduced with the permission of NSCA, and was first published in NSCA Briefing no. 49, January 2005.