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C 64/36 EN Official Journal of the European Communities 27.2.


Opinion of the Committee of the Regions on:

— the ‘Communication from the Commission to the Council and the European Parliament
on a Community strategy to combat acidification’,
— the ‘Proposal for a Council Directive relating to the sulphur content of certain liquid
fuels’, and
— the ‘Proposal for a Council Decision on the conclusion by the European Community of
the Protocol to the 1979 Convention on long-range trans-boundary air pollution on
further reductions of sulphur emissions’

(98/C 64/05)


having regard to the Communication to the Council and the European Parliament on a
Community strategy to combat acidification (COM(97) 88 final);
having regard to the proposal for a Council Directive relating to a reduction of the sulphur
content of certain liquid fuels and amending Directive 93/12/EEC (1);
having regard to the proposal for a Council Decision on the conclusion by the European
Community of the Protocol to the 1979 Convention on long-range transboundary air pollution
on further reductions of sulphur emissions (2);
having regard to the decision by the European Commission of 20 May 1997 to consult the
Economic and Social Committee on this subject;
having regard to its decision on 11 June 1997, pursuant to the third paragraph of Article 198c
of the Treaty establishing the European Community to issue an opinion and to direct
Commission 5 — Land-use Planning, Environment and Energy, to undertake the preparatory
having regard to the draft opinion adopted by Commission 5 on 3 July 1997 (CdR 174/97 rev.)
(rapporteur: Mr McKenna),
adopted the following opinion at its 20th plenary session on 19 and 20 November 1997
(meeting of 19 November).

1. Introduction 1.2. While progress is being achieved in reducing the

emissions of these pollutants, the rate of achievement is
1.1. The deposition of atmospheric emissions of considered to be too slow. The proposed strategy
acidifying substances and their reaction products leads therefore, revises current and planned legislation in an
to changes in the chemical composition, or acidification attempt to achieve the long-term goals of not exceeding
of soil and surface water which have significant biologi- ever the critical loads and levels of acidifying substances,
cal effects on both aquatic and terrestrial ecosystems, as set out in the fifth environmental action programme.
create human health risks and accelerate the deterio- The strategy thus aims to impose an interim target of
ration of the materials used in buildings and monuments. 50 % gap closure by the year 2010 between the level of
The primary air pollutants contributing to acidification ecosystem protection in 1990 and the ultimate target of
are: 100 % ecosystem protection. The strategy outlines the
following measures:
— sulphur dioxide (SO2);
— nitrogen oxide (NOx);
— a proposal for national emission ceilings;
— ammonia (NH3).
These pollutants can be carried by wind for thousands — ratification of the 1994 CLRTAP sulphur protocol;
of kilometres before being deposited in the environment
as sulphuric acid and nitric acid. Therefore, in order to
reduce acidification in one country it is necessary to — a proposal for the revision of the directive on the
reduce emissions in many of the countries across the EU sulphur content of certain liquid fuels;
and beyond.

(1) OJ C 190, 21.6.1997, p. 9. — action related to the LCP and IPPC directives:
(2) OJ C 190, 21.6.1997, p. 13. controlling emissions from stationary sources;
27.2.98 EN Official Journal of the European Communities C 64/37

— action related to emissions from shipping; 2.2. In developing a strategy to combat tropospheric
ozone pollution during the course of 1998 to complement
— action related to countries in central and eastern the proposed strategy, the Committee of the Regions
Europe; would welcome the opportunity to be consulted prior
to its finalization so that its comments are taken into
consideration rather than just noted. This is vital for the
— action related to the CLRTAP; reasons given above and the consequences this strategy
would have for the economic and social development of
— possible action to reduce emissions of ammonia; specific regions of the Community.

— economic instruments;

— possible further action related to emissions from

transport; 3. The strategy

— actions to promote energy efficiency and energy

3.1. The Committee of the Regions believes that the
ultimate target of no exceedence of critical loads, as
1.3. These proposed measures will lead to further outlined in the Fifth Environmental Action Programme
emission reductions as compared to those expected to and endorsed by the European Council decision in De-
result from current legislation and commitments, which cember 1995, must still remain. The development of an
are estimated to reduce Community-wide emissions of acidification strategy to establish realistic and coherent
SO2, NOx and NH3 by 66, 48 and 15 % respectively targets which will focus preventative actions and maxim-
between 1990 and 2010. ize their impact is very desirable and one which the
COR welcomes.

1.4. The Commission considers that the interim

environmental target of 50 % gap closure represents a
good balance between ecosystem protection and a global
3.2. However, the COR also recognizes the improve-
least cost solution for the whole Community. It considers
that this target should be achieved by 2010 and that a ments which have been achieved thus far in reducing
review process will be undertaken in the year 2004. the level of emissions of pollutants that contribute to
acidification. While these do not match the targets set
out, they must be viewed as a significant achievement
on which to build future action.

2. The role of the Committee of the Regions

3.3. The Committee of the Regions recognizes that

2.1. While acidification is a transboundary phenom- the introduction of this strategy has multiple effects, not
enon, requiring cohesive international and Community least in terms of the interlinkages between existing and
action, it is nonetheless appropriate that the Committee proposed directives and the measures outlined in the
of the Regions comments on any proposal to combat strategy. With the proposed strategy establishing clear
acidification as it also requires coordinated action at priorities the COR considers it vital that the current
national, regional and local levels. Already local and directives should be reviewed and up-dated in light of
regional authorities are involved in environmental moni- these priorities, to avoid overlap and/or a shortfall in
toring, imposing economic instruments to combat pol- the provision of directives addressing the contributing
lution and have the mandate to influence investment in factors to the problem of acidification.
order to achieve reductions in emissions. Local and
regional authorities are often the competent authorities
for developing local emission plans, imposing local fuel
standards and providing fiscal incentives for low sulphur
fuels. 3.4. The Committee of the Regions considers that
the target of a 50 % gap closure in the level of ecosystem
protection to be a realistic objective, but one which will
The Committee of the Regions therefore welcomes the impose a significant imbalance in the cost-benefits for
establishment of a strategy to combat acidification some regions. While the COR underlines that the
which will provide a context within which existing primary objective of the strategy is to improve the
directives will apply, a clear framework for the develop- protection of ecosystems against acidification, it would
ment of future policy instruments and their implemen- nevertheless endorse a flexible approach in implementing
tation and enable a complementarity of actions taken the strategy to enable some regions, where the emission
by national, regional and local authorities. targets are ambitious, to adjust more gradually.
C 64/38 EN Official Journal of the European Communities 27.2.98

3.5. Welcomes the commitment to review progress and voluntary agreements which would allow a broad
of the strategy in light of the fact that emissions from approach as to how targets may be achieved.
countries in central and eastern Europe and Russia will
probably decrease over the life of the proposed strategy
and the development of new technologies and tougher
legislation in some Member States will facilitate the However, while the measures proposed by the Com-
achievement of more ambitious, but realistic, targets in mission relate directly to fuel quality standards and
some regions. emission standards for vehicles and the strategy does
make brief reference to possible further action in respect
of transport, the Committee of the Regions is concerned
that the Commission makes no mention of the means of
3.6. The Committee of the Regions does however dealing with traffic growth.
question the methodology and the underlying assump-
tions used in developing the strategy. This is based on a
general cost-benefit analysis and does not sufficiently
consider the implications for individual regions in
implementing the strategy. The COR considers that the
cost-effectiveness is not significant enough for the level
4.2. National emission ceilings
of environmental protection achievable.

In order for the strategy to remain cost-effective, it is

essential that the individual measures proposed are 4.2.1. The Committee of the Regions supports the
responsive to the regional patterns of ecosystem sensi- use of national emission ceilings as the basis for an
tivity, emissions and acid deposition but also on the acidification policy. This will allow a degree of flexibility
ability of regions to meet the targets set out. as to how targets should be achieved in the most
cost-effective manner. However, the underlying problem
with the proposed ceilings is that they are based on
ambitious medium-term objectives which will place
additional burdens on regions already endeavouring
4. The proposed measures to lower the level of emissions in line with current
Community directives.

4.1. General comments In addition, the calculation of national emissions will

be particularly sensitive, given the high percentages of
SO2 and NOx emissions from one country which are in
fact deposited in other countries. Accordingly, it will
4.1.1. The Committee of the Regions supports the be most important to have an effective means of
broad range of measures which the Commission pro- Community-wide compliance.
poses in this strategy and underlines the complementary
and mutually reinforcing nature of these measures in
achieving the targets set out.
4.2.2. The COR concurs with the procedure to set
these national ceilings after the elaboration of the ozone
4.1.2. In particular the COR welcomes the inclusion strategy and a refinement of the scientific analysis used,
of measures to combat the level of emissions of ammonia, as not to do so could undermine the measures which are
something which is not addressed comprehensively in currently being implemented in Member States to reduce
current EU legislation. However, the COR agrees with the contributing pollutants to acidification.
the Commission’s proposal that measures relating to
environmental objectives in the field of agriculture may
best be achieved in a revised common agricultural policy
and at a time when preventative measures are more fully 4.2.3. The use of national emission ceilings also
developed. enables competent authorities (national, regional or
local) to design economic instruments that will go
beyond common minimum environmental requirements.
4.1.3. The Committee of the Regions also considers The Committee of the Regions underlines the obligations
it appropriate that a strategy such as this should outline under the Treaty to implement the polluter-pays prin-
new approaches and more proactive ‘soft’ measures to ciple and the prevention principle and the necessity
deal with the problem of acidification. Highlighting new of integrating environmental requirements into fiscal
approaches and best practices would help encourage policy. Such instruments would have the value added
Member States, at appropriate levels, to initiate a range benefit for meeting the national ceilings and lever further
of economic measures, such as the bubble principle and emission reductions through structural change in sectors
key indicators, information and consumer campaigns such as energy use and agriculture.
27.2.98 EN Official Journal of the European Communities C 64/39

4.3. Ratification of the 1994 CLRTAP Sulphur Pro- at present in the Member States. It is for this reason that
tocol it welcomes the flexible approach which the Commission
proposes in outlining a general limit value for heavy fuel
oils of 1 % by weight and higher limits of up to 2,5 %
4.3.1. The Committee of the Regions supports the by weight where environmental objectives are not
proposal by the Commission that the Community should compromised.
ratify the 1994 Sulphur Protocol to the 1979 Convention
on Long-Range Transboundary Air Pollution
(CLRTAP). This would underline its commitment to
4.4.3. Similarly, for the use of gas oils the Committee
reducing emissions.
of the Regions endorses the Commission’s proposal not
to impose a sulphur limit of 0,1 % across the Community,
At the same time, however, consideration must be given but instead to maintain the current standard of 0,2 % as
to the implications which action to reduce emissions a minimum standard. The COR would underline that
must have for the coal-mining regions of the Member this does not prevent Member States from imposing
States. more stringent measures than those outlined in the
strategy. It thus encourages Member States to do so,
given that the motivation for these measures is an
4.3.2. The Committee of the Regions would also urge environmental one.
that all Member States would sign the 1994 Sulphur
Protocol and ratify it to enable it to come into force.
Ratification of this protocol would demonstrate the
political will of Member States on this issue to non-EU It is for the purposes of the need for flexibility that the
countries that currently contribute to acid deposition COR welcomes the introduction of these actions in the
within the EU. form of a directive rather than a regulation, imposing a
strict community-wide standard.

However, it is unclear how non-EU countries might be

further encouraged to ratify the protocol. It needs to be
borne in mind that there may be a continuing issue for 4.4.4. The COR welcomes the proposal that in
some central and eastern European states over industrial revising the International Maritime Organization’s Con-
and domestic use of lignite or ‘brown coal’. It therefore vention on Maritime Pollution (MARPOL) that ships in
follows that it will be essential to have a realistic process SOx sensitive areas such as the Baltic Sea and parts of
and timetable for achieving the desired reduction in SO2 the North Sea/English Channel be required to use
emissions. bunker fuel with a sulphur content of 1,5 % or less.
However, without unilateral provisions this may prove
difficult to implement. It is vital that Member States
4.3.3. The COR supports the consistent approach have a clear and coherent approach to the revision of
undertaken by the Commission in developing this the MARPOL Convention, later in 1997.
acidification strategy in line with the research and
methodologies used by the UN ECE/CLRTAP. This
will ensure that the strategy supports action taken at an
international level and avoids the danger of Community
actions having a minimal impact.
5. Conclusion
In this regard it welcomes the formation of a steering
group between the Commission and the UN ECE/
CLRTAP to facilitate coordination and would encourage
further consultation on this issue. 5.1. The Commission’s proposed strategy for the
control of acidification is designed to make significant
progress towards the achievement of the objective set
down in the Fifth Environmental Action Programme,
4.4. A revision of the directive on the sulphur content namely that the critical loads for acidification shall not
of certain liquid fuels be exceeded. The development of such a strategy is very
welcome in that it will provide concrete targets for
each Member State to reduce emissions. However, the
4.4.1. The Committee of the Regions considers it Committee of the Regions is concerned that the targets
appropriate that measures to reduce the emissions of set for the reduction of pollutants in comparison
SO2 from the combustion of heavy fuel oils and gas oils to current actions are ambitious and will impose a
should be an integral part of the strategy to combat significant degree of costs for what is essentially a
acidification. low level return in terms of the improvement in
environmental standards. In addition to a uniformly
high level of environmental protection, attention should
4.4.2. The COR recognizes the dependence of certain also be given to abolishing competition distortions by
Member States on heavy fuel oil and the significant establishing various environmental protection con-
variations in the average sulphur content of fuels used ditions.
C 64/40 EN Official Journal of the European Communities 27.2.98

5.2. Despite this the COR considers that the degree implementation of the strategy should consider the
of flexibility built-in to many of the measures is also gradual reduction in the level of flexibility inherent in
important in assisting regions which will have difficulty many of the strategy’s measures.
in reaching targets set. However, a revision of the

Brussels, 19 November 1997.

The Chairman
of the Committee of the Regions

Opinion of the Committee of the Regions on ‘Agenda 2000: the financing of the European
Union after 1999 taking account of enlargement prospects and the challenges of the
21st century’

(98/C 64/06)


having regard to its decision of 11 June 1997, under Article 198c(4) of the Treaty establishing
the European Community, to draw up an opinion on Agenda 2000: the financing of the
European Union after 1999 taking account of enlargement prospects and the challenges of the
21st century and to instruct Commission 1 for Regional Development, Economic Development
and Local and Regional Finances to prepare the Committee’s work on the subject;

having regard to the European Commission document Agenda 2000: For a stronger and wider
Union (COM(97) 2000 final);

having regard to the draft opinion adopted by Commission 1 (CdR 303/97 rev. 2) on 3 October
1997 (rapporteurs: Mr Behrendt and Mrs Nielsen),

at its 20th plenary session of 19 and 20 November 1997 (meeting of 20 November) adopted
the following opinion.

1. Introduction in connection with eastward enlargement, guaranteeing

the EU’s ability to act both internally and externally,
1.1. On 16 July 1997 the European Commission ensuring competitiveness and creating new employment.
published its document entitled Agenda 2000: for a At the same time the document makes it clear that the
stronger and wider union. In so doing the Commission forthcoming decisions on the future financing of the
was complying with the request of the European Council Union require complex analysis in the light of integration
of December 1995 by submitting, immediately after the policy and that the need for adjustments, reforms and
IGC, a single communication on the future financial changes in the EU is not purely the result of enlargement.
framework of Union. This fleshes out the institutional
and treaty framework of the European Union, as
extended by the Intergovernmental Conference. There
2. Financial framework 2000-2006
is a clear connection here with the Amsterdam Treaty
currently awaiting ratification by the Member States.
2.1. The new financial framework proposed by the
1.2. The Committee of the Regions views with interest Commission in Agenda 2000 provides a total of ECU
the Commission document which contains a complex 745,5 billion (funding for commitments at 1997 prices)
analysis of the financing of the tasks facing the Union for the financing of the tasks of the European Union