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European Commission DG Environment

National Emission Ceilings Directive Review

Task 3 - Summary

Final Report

May 2005

Entec UK Limited

Certificate No. FS 13881

Report for Michel Sponar DG ENV-C.1 European Commission Avenue de Beaulieu 5 6/103B-1160 Brussels Belgium

Main Contributors Katherine Wilson Ben Grebot Andriana Stavrakaki Alistair Ritchie Alun McIntyre

Issued by …………………………………………………………

Katherine Wilson

Approved by ………………………………………………………… Alistair Ritchie

Entec UK Limited Windsor House Gadbrook Business Centre Gadbrook Road Northwich Cheshire CW9 7TN England Tel: +44 (0) 1606 354800 Fax: +44 (0) 1606 354810

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h:\projects\em-260\13000 projects\13636 ec necd review\reports sent to ec\05 amended final report (20th may 05)\task 3\13636 amended final report - task 3 (summary)_05156.doc

European Commission DG Environment

National Emission Ceilings Directive Review

Task 3 - Summary

Final Report

May 2005

Entec UK Limited

Certificate No. EMS 69090

In accordance with an environmentally responsible approach, this document is printed on recycled paper produced from 100% post-consumer waste, or on ECF (elemental chlorine free) paper

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Executive Summary

Entec UK has undertaken a project for the European Commission (Contract No. 070402/2004/383810/MAR/C1) to support the review of Directive 2001/81/EC, referred to as the National Emission Ceilings Directive (NECD). This report serves as the final report for the additional analysis conducted under Task 3 of the contract: provision of the first draft of the NEC review report and recommendations for further legislation, and for the thematic strategy. This report should be read alongside the ‘first draft review report’, which is the main output under Task 3.

Under this project, Entec has produced a first draft of the review report as required by the NECD. As agreed with the Commission, the requirements outlined in Article 10, paragraph 5 (a) and (b)1 of the Directive are not to be included within the scope of the work. Given the range of additional projects commissioned by the EC as well as the UN ECE, in addition to EEA reports and national programmes, this task has been mainly to gather and summarise the relevant information sources that contribute to the review of the Directive. Work undertaken within Tasks 1 and 2 also contribute to the review report. The review report has been submitted to the Commission separately.

The text of the NECD details the requirements of the review report under Articles 9, 10 and 12. A review of the data sources has not identified any significant data gaps, beyond those outlined in the Technical Annex of the Tender Specification. These are:

“a review of the limitations of the regional scope of the NEC Directive as defined in article 2 for what concerns Spain, France and Portugal”; and

“measures to ensure compliance with the ceilings”.

This report presents the supporting analysis conducted by Entec to fill these data gaps for the purposes of inclusion in the review report.

Drafting the review report The following tables identify the requirements of Articles 9, 10 and 12 in the Directive and indicate the sections of the Review Report under which these requirements are fulfilled.

1 Relating to modifications of the national ceilings and/or for modifications to interim environmental objectives as well as possible further emission reductions with the aim of meeting, preferably by 2020, the long-term objectives of the Directive.

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Table A Location of response to specific elements detailed in Article 9, paragraph (1)

Requirement Section of the review report

progress on implementation of the national emission ceilings laid down in Annex I 3. BAU emissions projections

extent to which the interim environmental objectives set out in Article 5 are likely to be met by 2010 and on the extent to which the long-term objectives set out in Article 1 could be met by 2020

4. Consequences for IEOs / LTOs

economic assessment, including cost-effectiveness, benefits, an assessment of marginal costs and benefits and the socioeconomic impact of the implementation of the national emission ceilings on particular Member States and sectors

5. Meeting the NECs

limitations of the scope of this Directive as defined in Article 2 6. Meeting IEOs / LTOs – protecting human health and the environment

an evaluation of the extent to which further emission reductions might be necessary in order to meet the interim environmental objectives set out in Article 5


Table B Location of response to specific elements detailed in Article 9, paragraph (1) (a)-(n)


(a) any new Community legislation which may have been adopted setting emission limits and product standards for relevant sources of emissions;

2. Policy drivers affecting NEC sources

(b) developments of best available techniques in the framework of the exchange of information under Article 16 of Directive 96/61/EC;


(c) emission reduction objectives for 2008 for emissions of sulphur dioxide and nitrogen oxides from existing large combustion plants, reported by Member States pursuant to Directive 2001/80/EC of the European Parliament and of the Council of 23 October 2001 on the limitation of emissions of certain pollutants into the air from large combustion plants;


(d) emission reductions and reduction commitments by third countries, with particular focus on measures to be taken in the accession candidate countries, and the possibility for further emission reductions in regions in the vicinity of the Community;


(e) any new Community legislation and any international regulations concerning ship and aircraft emissions;


(f) the development of transport and any further action to control transport emissions; 2. Policy drivers affecting NEC sources

(g) developments in the field of agriculture, new livestock projections and improvements in emission reduction methods in the agricultural sector;


(h) any major changes in the energy supply market within a Member State and new forecasts reflecting the actions taken by Member States to comply with their international obligations in relation to climate change;


(i) assessment of the current and projected exceedences of critical loads and the WHO's guideline values for ground-level ozone;


(j) the possibility of identification of a proposed interim objective for reducing soil eutrophication;

Not to be included within this project, as identified in the Technical Annex.

(k) New technical and scientific data including an assessment of the uncertainties in:

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(i) national emission inventories; 3. BAU emissions projections

(ii) input reference data; 4. Consequences for IEOs / LTOs

(iii) knowledge of the transboundary transport and deposition of pollutants; 4. Consequences for IEOs / LTOs

(iv) critical loads and levels; 4. Consequences for IEOs / LTOs

(v) the model used; 4. Consequences for IEOs / LTOs

and an assessment of the resulting uncertainty in the national emission ceilings required to meet the interim environmental objectives mentioned in Article 5.


(l) whether there is a need to avoid excessive costs for any individual Member State; 5. Meeting the NECs

(m) a comparison of model calculations with observations of acidification, eutrophication and ground-level ozone with a view to improving models;


(n) the possible use, where appropriate, of relevant economic instruments. 5. Meeting the NECs

Table C Location of response to specific elements detailed in Article 10


evaluation will be carried out of the indicative emission ceilings for the Community as a whole set out in Annex II… with the aim of attaining the interim environmental objectives set out in Article 5, for the Community as a whole by 2010


investigation of the estimated costs and benefits of national emission ceilings, computed with state-of-the-art models and making use of the best available data

5. Meeting the NECs

with the aim of avoiding distortion of competition, and taking into account the balance between benefits and costs of action …examine further the need to develop harmonised Community measures, for the most relevant economic sectors and products contributing to acidification, eutrophication and formation of ground-level ozone

6. Meeting IEOs / LTOs – protecting human health and the environment

measures to ensure compliance with the ceilings 6. Meeting IEOs / LTOs – protecting human health and the environment

Table D Location of response to specific elements detailed in Article 12


extent to which emissions from international maritime traffic contribute to acidification, eutrophication and the formation of ground-level ozone within the Community


extent to which emissions from aircraft beyond the landing and take-off cycle contribute to acidification, eutrophication and the formation of ground-level ozone within the Community


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specify a programme of actions which could be taken at international and Community level as appropriate to reduce emissions from the sector concerned


Additional Analysis

Limitations of regional scope for what concerns Spain, France and Portugal The current NECD does not apply to the Spanish Canary Islands, French overseas departments (Guadeloupe, Martinique, French Guiana and La Réunion) or the Portuguese Islands of Madeira and the Azores.

The information collated demonstrates that available information on emissions varies across the remote regions. As such, the capacity for building emission inventories would have to be improved to be equivalent to those submitted by Member States under the requirements of the NECD.

The distance at which the remote regions are located from Europe, coupled with the apparent relatively low emissions of NECD pollutants, indicates that these areas do not have a significant impact on acidification, eutrophication and ground level ozone in Europe.

Furthermore, emissions from the remote regions are already controlled by a number of EU directives. The benefits arising from potential additional emission reductions by including these areas within the NECD are therefore expected to be relatively limited.

It is also possible that, given the special status afforded by the European Union to these regions2 and their geographical location beside emerging regional and sub-regional blocs, the imposition of additional emission reduction requirements may create local market distortions for the outermost regions, depending on which other countries they mainly trade with.

Nevertheless, as indicated by the EC3, it will be important to consider the environmental impacts of emissions on the geographical regions in which these areas are located, in view of their natural fragility and also because the environment is the essential physical basis for tourism, which constitutes one of the pillars for the development of the outermost regions. However, as the objectives of the NECD are to reduce transboundary pollution, these issues may be best dealt with outside of the structure of the NECD, in collaboration with France, Spain and Portugal or through regional agreements within their localities.

Such considerations should be incorporated within a sustainable development strategy, managing emission reductions where necessary, but taking account of the socio-economic circumstances of the regions. A first step would be to encourage the development of NECD consistent emission inventories. These emissions could then be reviewed to determine their

2 which have previously been the subject of measures designed to reduce the costs for energy production and transport to avoid hampering their competitiveness

3 European Commission (EC) (2000) COMMISSION REPORT ON THE MEASURES TO IMPLEMENT ARTICLE 299(2) THE OUTERMOST REGIONS OF THE EUROPEAN UNION Brussels, 14.3.2000 COM(2000) 147 final.

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significance, in relative terms, to the rest of the EU25. The impact of their emissions could then be compared with the cost-effectiveness of abatement.

Potential measures to ensure compliance with the ceilings Within this report, consideration has been given to potential administrative and policy measures to facilitate the implementation of the NECD and achieve compliance with the ceilings. These include:

• monitoring progress: improving consistency with other Member States and other submissions; development of indicators; Commission report and inventories each year;

• reporting requirements: potential submission with other inventories;

• tools for knowledge exchange: database of policies and measures; annual workshops;

• setting ceilings; and

• the use of economic instruments.

Recommendations The recommendations of this task are presented in the separate summary report, which combines the summaries and recommendations of all three tasks together.

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Contents

1 Introduction 1

1.1 This Report 1 1.2 Task 3 Scope and Objectives 1 1.3 Structure of the Report 1

2 Drafting the NEC review report 3

2.1 Introduction 3 2.2 Contents of the review report 3 2.2.1 Structure of the report 3 2.2.2 Information sources 5 2.2.3 Signposting to potential updates 6

3 Additional Analysis 7

3.1 Introduction 7 3.2 Limitations of regional scope for what concerns Spain,

France and Portugal 7 3.2.1 Overview - the ‘Remote Regions’ 7 3.2.2 France 8 3.2.3 Portugal 12 3.2.4 Spain 13 3.2.5 Summary 14 3.3 Potential measures to ensure compliance with the ceilings 15 3.3.1 Monitoring progress 15 3.3.2 Reporting requirements 17 3.3.3 Tools for knowledge exchange 18 3.3.4 Setting ceilings 18 3.3.5 The use of economic instruments 19

4 References 20

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Table 1 Location of response to specific elements detailed in Article 9, paragraph (1) 3 Table 2 Location of response to specific elements detailed in Article 9, paragraph (1) (a)-(n) 4 Table 3 Location of response to specific elements detailed in Article 10 5 Table 4 Location of response to specific elements detailed in Article 12 5 Table 5 Contact made with other EC contractors 6 Table 6 Socio-economic characteristics of the remote regions (EC, 2004) 7 Table 7 Sectoral breakdown of air emissions in the French overseas departments in 1998

(CITEPA, 2000) 10 Table 8 Atmospheric emissions in the French overseas departments in 1998 (CITEPA, 2000)1 11 Figure 1 Locations of the French Overseas Departments 9 Figure 2 Locations of Madeira and Azores 12 Figure 3 Locations of the Canary Islands 14

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1 Introduction

1.1 This Report Entec UK has undertaken a project for the European Commission (Contract No. 070402/2004/383810/MAR/C1) to support the review of Directive 2001/81/EC, referred to as the National Emission Ceilings Directive (NECD). This report serves as the draft final report for the additional analysis conducted under Task 3 of the contract: provision of the first draft of the NEC review report and recommendations for further legislation, and for the thematic strategy. This report should be read alongside the draft final ‘review report’, which is the main output under Task 3.

1.2 Task 3 Scope and Objectives Under this project, Entec has produced a first draft of the review report as required by the NECD. As agreed with the Commission, the requirements outlined in Article 10, paragraph 5 (a) and (b)4 of the Directive are not to be included within the scope of the work. Given the range of additional projects commissioned by the EC as well as the UN ECE, in addition to EEA reports and national programmes, this task has been mainly to gather and summarise the relevant information sources that contribute to the review of the Directive. Work undertaken within Tasks 1 and 2 also contributes to the review report. This report has been submitted to the Commission separately.

The text of the NECD details the requirements of the review report under Articles 9, 10 and 12. A review of the data sources has not identified any significant data gaps, beyond those outlined in the Technical Annex of the Tender Specification. These are:

• “a review of the limitations of the regional scope of the NEC Directive as defined in article 2 for what concerns Spain, France and Portugal”; and

• “measures to ensure compliance with the ceilings”.

This report presents the supporting analysis conducted by Entec to fill these data gaps for the purposes of inclusion in the review report.

1.3 Structure of the Report The structure of this report is as follows:

• Section 2 summarises the mechanism for drafting the NEC review report;

4 Relating to modifications of the national ceilings and/or for modifications to interim environmental objectives as well as possible further emission reductions with the aim of meeting, preferably by 2020, the long-term objectives of the Directive.

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• Section 3 describes the ‘additional analysis’ required to fill the data gaps within the review report; and

• Section 4 lists the references.

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2 Drafting the NEC review report

2.1 Introduction This section presents the approach to the drafting of the NEC review report. The review report has been submitted as a separate report.

2.2 Contents of the review report

2.2.1 Structure of the report The various requirements of the review report are set out in the Directive under articles 9, 10 and 12. The report is structured as follows:

− Section 1 introduces the report;

− Section 2 provides background on the policy drivers affecting NEC pollutant sources;

− Section 3 presents the ‘business as usual’ (BAU) emissions projections for Member States;

− Section 4 demonstrates the consequences of these emissions on human health and the environment, by comparing modelled outputs with the interim environmental objectives (IEOs) and long term objectives (LTOs);

− Section 5 goes on to discuss how the NECs can be met in a cost-effective manner and issues surrounding the associated marginal costs and benefits;

− Section 6 discusses wider issues of whether meeting NECs will achieve the IEOs and LTOs and thereby protect human health and the environment; and

− Section 7 lists the references.

The following tables identify the requirements of Articles 9, 10 and 12 in the Directive and indicate the sections of the report under which these requirements are fulfilled.

Table 1 Location of response to specific elements detailed in Article 9, paragraph (1)


progress on implementation of the national emission ceilings laid down in Annex I 3. BAU emissions projections

extent to which the interim environmental objectives set out in Article 5 are likely to be met by 2010 and on the extent to which the long-term objectives set out in Article 1 could be met by 2020


economic assessment, including cost-effectiveness, benefits, an assessment of marginal costs and benefits and the socioeconomic impact of the implementation of the national emission ceilings on particular Member States and sectors

5. Meeting the NECs

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limitations of the scope of this Directive as defined in Article 2 6. Meeting IEOs / LTOs – protecting human health and the environment

an evaluation of the extent to which further emission reductions might be necessary in order to meet the interim environmental objectives set out in Article 5


Table 2 Location of response to specific elements detailed in Article 9, paragraph (1) (a)-(n)


(a) any new Community legislation which may have been adopted setting emission limits and product standards for relevant sources of emissions;


(b) developments of best available techniques in the framework of the exchange of information under Article 16 of Directive 96/61/EC;


(c) emission reduction objectives for 2008 for emissions of sulphur dioxide and nitrogen oxides from existing large combustion plants, reported by Member States pursuant to Directive 2001/80/EC of the European Parliament and of the Council of 23 October 2001 on the limitation of emissions of certain pollutants into the air from large combustion plants;


(d) emission reductions and reduction commitments by third countries, with particular focus on measures to be taken in the accession candidate countries, and the possibility for further emission reductions in regions in the vicinity of the Community;


(e) any new Community legislation and any international regulations concerning ship and aircraft emissions;


(f) the development of transport and any further action to control transport emissions; 2. Policy drivers affecting NEC sources

(g) developments in the field of agriculture, new livestock projections and improvements in emission reduction methods in the agricultural sector;


(h) any major changes in the energy supply market within a Member State and new forecasts reflecting the actions taken by Member States to comply with their international obligations in relation to climate change;


(i) assessment of the current and projected exceedences of critical loads and the WHO's guideline values for ground-level ozone;


(j) the possibility of identification of a proposed interim objective for reducing soil eutrophication;

Not to be included within this project, as identified in the Technical Annex.

(k) New technical and scientific data including an assessment of the uncertainties in:

(i) national emission inventories; 3. BAU emissions projections

(ii) input reference data; 4. Consequences for IEOs / LTOs

(iii) knowledge of the transboundary transport and deposition of pollutants; 4. Consequences for IEOs / LTOs

(iv) critical loads and levels; 4. Consequences for IEOs / LTOs

(v) the model used; 4. Consequences for IEOs / LTOs

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and an assessment of the resulting uncertainty in the national emission ceilings required to meet the interim environmental objectives mentioned in Article 5.


(l) whether there is a need to avoid excessive costs for any individual Member State; 5. Meeting the NECs

(m) a comparison of model calculations with observations of acidification, eutrophication and ground-level ozone with a view to improving models;


(n) the possible use, where appropriate, of relevant economic instruments. 5. Meeting the NECs

Table 3 Location of response to specific elements detailed in Article 10


evaluation will be carried out of the indicative emission ceilings for the Community as a whole set out in Annex II… with the aim of attaining the interim environmental objectives set out in Article 5, for the Community as a whole by 2010


investigation of the estimated costs and benefits of national emission ceilings, computed with state-of-the-art models and making use of the best available data

5. Meeting the NECs

with the aim of avoiding distortion of competition, and taking into account the balance between benefits and costs of action …examine further the need to develop harmonised Community measures, for the most relevant economic sectors and products contributing to acidification, eutrophication and formation of ground-level ozone


measures to ensure compliance with the ceilings 6. Meeting IEOs / LTOs – protecting human health and the environment

Table 4 Location of response to specific elements detailed in Article 12


extent to which emissions from international maritime traffic contribute to acidification, eutrophication and the formation of ground-level ozone within the Community


extent to which emissions from aircraft beyond the landing and take-off cycle contribute to acidification, eutrophication and the formation of ground-level ozone within the Community


specify a programme of actions which could be taken at international and Community level as appropriate to reduce emissions from the sector concerned


2.2.2 Information sources The data sources required to complete this task include outputs from other EC contracts, information from Task 1 of this project and from wider literature reviews.

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As agreed at the project kick-off meeting, Entec has been liaising between contractors in order to obtain the most up-to-date information (Table 5). The ongoing nature of the CAFE work has meant that some results have not been available for inclusion within this report, e.g. the AEA T cost benefit analysis.

Table 5 Contact made with other EC contractors

Organisation EC project Notes

IIASA Ongoing RAINS web data and CAFE baseline

Information has been obtained from the organisation’s website

EMEP Supporting modelling under CAFE

Information has been obtained from the organisation’s website

AEA Technology Ex-post Evaluation of Short-term and Local Measures in the CAFE Context

Entec has been provided with the final report

AEA Technology Cost Benefit Analysis of the CAFE programme

Entec has been provided with a final methodology report. Whilst it is understood that baseline analyses were due to be completed in January, this information had not been received prior to submission of this report.

Clean Air Policy, Milieu Consortium

Comparison of EU and US approaches towards acidification, eutrophication and ground level ozone

Entec has been provided with the final reports and the accompanying case studies.

IFARE Emerging technologies Entec has been provided with a copy of the final report.

2.2.3 Signposting to potential updates Given the ongoing nature of work conducted under the CAFE programme, the draft review report has included notes to indicate where further information is expected. These notes are entered in the review report in green italics.

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3 Additional Analysis

3.1 Introduction Additional analysis has been required under Task 3, beyond that which is covered by existing contracts and studies, in order to fulfil the requirements of the directive. These ‘data gaps’ were identified by the EC within the Technical Annex and are as follows:

• “a review of the limitations of the regional scope of the NEC Directive as defined in Article 2 for what concerns Spain, France and Portugal” (Article 9, Paragraph 1 of the NEC Directive); and

• “measures to ensure compliance with the ceilings” (Article 10, Paragraph 5 (c) of the NEC Directive)

The findings of our analysis for these ‘data gaps’ is described in the following sections.

3.2 Limitations of regional scope for what concerns Spain, France and Portugal

3.2.1 Overview - the ‘Remote Regions’ The current NECD does not apply to the Spanish Canary Islands, French overseas departments (Guadeloupe, Martinique, French Guiana and La Réunion) or the Portuguese Islands of Madeira and the Azores. Article 299(2) of the Treaty of Amsterdam constituted the legal basis for the concept of these ‘most remote regions’:

“…taking account of the structural social and economic situation of the French overseas departments, the Azores, Madeira and the Canary Islands, which is compounded by their remoteness, insularity, small size, difficult topography and climate, economic dependence on a few products, the permanence and combination of which severely restrain their development, the Council, acting by a qualified majority on a proposal from the Commission and after consulting the European Parliament, shall adopt specific measures aimed, in particular, at laying down the conditions of application of the present Treaty to those regions, including common policies.”

Table 6 Socio-economic characteristics of the remote regions (EC, 2004)

Azores Canary Islands Guadeloupe French

Guiana Madeira Martinique Réunion

Location Atlantic Ocean

Atlantic Ocean

Caribbean Sea

South America

Atlantic Ocean

Caribbean Sea

Indian Ocean

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Azores Canary Islands Guadeloupe French

Guiana Madeira Martinique Réunion

Surface area 2 333 km² 7 447 km² 1 710 km² 84 000 km² 795 km² 1 080 km² 2 510 km²

Population 237 900 1 715 700 425 700 161 100 244 800 383 300 715 900

Per capita GDP index (Note 1)

52 78 58 54 74 67 50

Unemployment (Note 2) 2,5 % 11,1 % 26,0 % 24,4 % 2,5 % 22,9% 29,3%

Notes:

1. 2000, in standard of purchasing power (EUR-15 = 100)

2. 2002

In general, other European environmental directives would apply in the ‘remote regions’, although for some directives, ‘special provisions’ apply in these areas, allowing less stringent requirements in certain specified situations. Directives with special provisions for these areas include:

• large combustion plant (LCPD 2001/80/EC)5;

• the sulphur content of liquid fuels (SCLFD 1999/32/EC)6; and

• directives relating to the quality of petrol and diesel fuels (2003/17/EC)7.

The following sections investigate the available emissions data and potential for emission reductions of NECD pollutants within each of the remote regions.

3.2.2 France The French overseas departments are integral parts of the French Republic. Guadeloupe and Martinique are both located in the Caribbean. French Guiana is located in the North East of South America between Brazil and Surinam. La Réunion is located in the Indian Ocean, to the east of Madagascar and has the highest population of all the French overseas departments and territories (Figure 1).

5 Directive 2001/80/EC of the European Parliament and of the Council of 23 October 2001 on the limitation of emissions of certain pollutants into the air from large combustion plants – special provisions are listed for the ‘outermost’ regions.

6 Council Directive 1999/32/EC of 26 April 1999 relating to a reduction in the sulphur content of certain liquid fuels and amending Directive 93/12/EEC.

7 Directive 2003/17/EC of the European Parliament and of the Council of 3 March 2003 amending Directive 98/70/EC relating to the quality of petrol and diesel fuels – special provisions are listed for the ‘outermost’ regions.

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Figure 1 Locations of the French Overseas Departments8

Each department is administered by an appointed representative of the French government, and the level of autonomy is restricted. In general, French regulations apply to these departments. However, the overseas departments have special measures delegated (MEDD, 2005). Atmospheric emissions are controlled by European regulations as described above. The French overseas departments are also under the United Nations framework convention on climate change (UNFCCC) (CITEPA, 2000).

Whilst a number of contacts were attempted including the MEDD, the Directions régionales de l’environnement (DIREN) and the Directions Régionales de l'Industrie, de la Recherche et de l'Environnement (DRIRE) for all four overseas departments, detailed information on potential technical, logistical or economic considerations associated with reducing emissions of NECD pollutants were not received. However, the MEDD (2005) felt that there would be specific technical difficulties with reducing emission if these overseas departments were to be included within the NECD, e.g. involving the improvement of fuel quality.

Atmospheric emissions have been monitored in the overseas departments from 1990, and emission data are available for all four departments until 1998. Maritime and air traffic 8 www.worldatlas.com

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emissions are included in the emission data for distances below 1000 m as ‘other transport’, however, mainly CO2 is measured for that sector (CITEPA, 2000). Table 7 shows the sectoral breakdown of emissions and Table 8 gives the emissions for 1998.

Table 7 Sectoral breakdown of air emissions in the French overseas departments in 1998 (CITEPA, 2000)

Guadeloupe SO2 NOX NMVOC NH3

Electricity production 92% 71%

Agriculture 97%

Road Transport 17% 40%

Martinique SO2 NOX NMVOC NH3

Energy sector 94% 71%

Agriculture 95%

Road Transport 19% 32%

French Guiana SO2 NOX NMVOC NH3


Agriculture 91% 97%

Road Transport 17%

Other Transport 29%

La Réunion SO2 NOX NMVOC NH3


Manufacturing Industry 51%

Agriculture 96%

Road Transport 41%

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Table 8 Atmospheric emissions in the French overseas departments in 1998 (CITEPA, 2000)1

In kt SO2 NOX NMVOC NH3 Comments

Guadeloupe 9.98

(17%)

19.01

(25%)

12.30

(10%)

1.82

(19%)

No heavy industries and no intensive agriculture but high energy consumption that continuously grows

Martinique 8.85

(<20%)

16.39

(22%)

17.04 0.99 Two power stations and an oil refinery, mainly responsible for the high NOX and SO2 emissions

French Guiana 1.99

(3%)

5.39

(<10%)

44.82

(<10%)

0.44

(37%)

94% of the region is covered by forests. Three power stations, mainly responsible for the SO2 emissions. In 1994 a hydroelectric dam was put into service, subsequently decreasing the use of the power stations. Fishing is the second biggest activity.

La Réunion 8.34

(~20%)

13.37

(~20%)

23.84

(~20%)

1.81

(~20%)

No heavy industries. The energy structure of La Réunion is different since 36% of the electricity produced is hydraulic, thus SO2 and NOX emissions are lower than other departments. A quarter of the island is used for agricultural purposes and fishing, although La Réunion is not a highly intensive agricultural department

Total emissions in the French overseas departments

29.16 54.16 98.00 5.06

Total emissions of France2

823 1586 1888 785

% of emissions of the French overseas departments from total emissions in France

3.5% 3.4% 5.2% 0.6%

Notes:

1. Percentage of emissions in each department compared to the total emissions of the overseas departments and territories is shown in brackets

2. Emission data for France (1998) were obtained from CITEPA (2004).

Table 9 gives the emissions per head for France and the French Overseas Departments. It should be noted that the population data is for 2000, whereas emission data is for 1998 (from Table 8). No population data for 1998 was available. As such, this assumes that the populations within France and the Overseas Departments have remained relatively constant over this period, compared to each other.

The table shows that emissions per head vary widely amongst the regions and between different pollutants. For SO2, emissions per head in Guadeloupe and Martinique are over 50% higher than in France, whereas the emissions per head in French Guiana and La Réunion are lower than in France. For NOX, emissions per head in Guadeloupe, Martinique and French Guiana are higher than France, whereas they are lower in La Réunion. Emissions per head of NMVOCs in French Guiana significantly greater than in France and the other Overseas Departments. Emissions of NH3 per head in France are significantly higher than in the Overseas Departments.

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Table 9 Emissions per head for France and the French Overseas Departments

Population (2000)

SO2 per head (kg)1

NOX per head (kg) 1

NMVOC per head (kg) 1

NH3 per head (kg) 1

France 59,329,691 13.9 26.7 31.8 13.2

French Guiana 172,605 11.5 31.2 259.7 2.5

Guadeloupe 426,493 23.4 44.6 28.8 4.3

Martinique 414,516 21.4 39.5 41.1 2.4

La Réunion 720,934 11.6 18.5 33.1 2.5

Notes:

1. Based on emissions data from 1998

3.2.3 Portugal Madeira and Azores are autonomous regions approximately 964km and 1419km respectively from Portugal and are located in the middle of the North Atlantic Ocean (Figure 2).

Figure 2 Locations of Madeira and Azores9

Agriculture and livestock are considered to be the main economic activities in the Azores (IA, 2005). Energy production is mainly from small power stations although geothermic and wind energy is also produced (SRA, 2005).

In Madeira the main economic activity is tourism. Madeira is now developing a significant effort to use renewable energies, which in 2000 represented 7% of the produced primary energy. The recent decision to introduction natural gas in Madeira in place of fossil energy for the electricity production sector, will be an important contribution for reduction the emissions of

9 www.worldatlas.com

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some of NEC pollutants. For the Azores, the NH3 emitted from the livestock sector represents the most important NEC pollutant (IA, 2005).

In both regions, the industrial sector is rather small. Three installations from Madeira and four from the Azores are included within the CO2 European Trading Scheme, all of them belong to the energy production sector.

There are considered to be inherent difficulties associated with reducing emissions of NECD pollutants in Madeira. These problems are mainly financial (SRA, 2005). The power plants are currently known to be relatively high emitters of SO2 and NOX. Technological improvements are required to reduce emissions, but the costs of implementation are considered too great to be economically feasible (SRA, 2005).

In accordance with Air Quality Directives and national legislation, Madeira has a recent air quality network to assess the pollutants regulated by Daughters Directives. The data is reported annually to the European Commission and EEA. Until now the air quality data demonstrate compliance within limit values for almost all the pollutant, exception for particulate matter PM10, which has high concentrations usually during episodes of natural events from Sahara in the north of Africa. In the Azores some indicative measurements campaigns are used for assess air quality in the territory. In the near future an air quality monitoring station will be installed (IA, 2005).

There is currently no information on historical and projected emissions of NECD pollutants from Madeira and the Azores. However the disaggregation of the national emission inventories according to the EMEP grid will be finalized at the end of March. The Instituto do Ambiente estimates that the regional contributions from Madeira and Azores together represent approximately 5% of the total national emissions (IA, 2005).

3.2.4 Spain The Canary Islands are approximately 1350 km from the Iberian Peninsula, close to the Northwest coast of Africa (Figure 3). The Canary Islands are an autonomous community.

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Figure 3 Locations of the Canary Islands10

No emission data for the Canary Islands were available11. Various sources were contacted, such as the Ministerio de Medio Ambiente of Spain and the Direcci�n General de Calidad Ambiental of the Canary Islands.

3.2.5 Summary The information listed above demonstrates that available information on emissions varies across the remote regions. As such, the capacity for building emission inventories would have to be improved to be equivalent to those submitted by Member States under the requirements of the NECD.

The distance at which the remote regions are located from Europe, coupled with the apparent relatively low emissions of NECD pollutants, indicates that these areas do not have a significant impact on acidification, eutrophication and ground level ozone in Europe.

Furthermore, emissions from the remote regions are already controlled by a number of EU directives. The benefits arising from potential additional emission reductions by including these areas within the NECD are therefore expected to be relatively limited.

It is also possible that, given the special status afforded by the European Union to these regions12 and their geographical location beside emerging regional and sub-regional blocs, the imposition of additional emission reduction requirements may create local market distortions for the outermost regions, depending on which other countries they mainly trade with.

Nevertheless, as indicated by the EC (2000), it will be important to consider the environmental impacts of emissions on the geographical regions in which these areas are located, in view of their natural fragility and also because the environment is the essential physical basis for tourism, which constitutes one of the pillars for the development of the outermost regions. However, as the objectives of the NECD are to reduce transboundary pollution, these issues may be best dealt with outside of the structure of the NECD, in collaboration with France, Spain and Portugal or through regional agreements within their localities.

Such considerations should be incorporated within a sustainable development strategy, managing emission reductions where necessary, but taking account of the socio-economic circumstances of the regions. A first step would be to encourage the development of NECD consistent emission inventories. These emissions could then be reviewed to determine their significance, in relative terms, to the rest of the EU25. The impact of their emissions could then be compared with the cost-effectiveness of abatement.

10 www.worldatlas.com

11 Air quality legislation for the Canary Islands can be found at http://www.gobcan.es

12 which have previously been the subject of measures designed to reduce the costs for energy production and transport to avoid hampering their competitiveness

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3.3 Potential measures to ensure compliance with the ceilings

This section considers potential administrative and policy measures to facilitate the implementation of the NECD and achieve compliance with the ceilings. The discussion focuses on:

• monitoring progress;

• reporting requirements;

• tools for knowledge exchange;

• setting ceilings; and

• the use of economic instruments.

3.3.1 Monitoring progress

Improving NEC National Programmes13 Under the current requirements of the NECD, Member States are only required to report information on policies and measures, emission inventories and projections, socio-economic assumptions and any potential changes in the geographical distribution of emissions (Sections 1.5.4, 1.5.5, 1.5.6 and 1.5.8 of guidelines). Entec’s proposed guidelines address these requirements whilst also going beyond the current NECD to improve the consistency of national programmes between Member States and also with reporting under the greenhouse gas Monitoring Mechanism.

The proposed guidelines have been prepared to ensure that all the requirements of the Directive are met by specifically defining the type of information that should be reported and, for policies and measures, providing a format for presenting it. This should ensure that the information submitted by Member States under the NECD will be much more consistent and comparable.

To improve the level of consistency of reporting with greenhouse gas plans and programmes relevant sections of the proposed guidelines have been based on the guidelines for reporting to the UNFCCC (UNFCCC, 2000 & 2003) and the implementing provisions of the Monitoring Mechanism. As such, a number of requirements of the proposed NECD guidelines have been developed in line with reporting under greenhouse gas obligations. Increasing the linkages between NECD and climate change reporting should lead to the promotion and increased consideration of measures that reduce both greenhouse gases and NECD pollutants.

Development of indicators14 A further potential improvement in the reporting guidelines for national programmes under the NECD could be the inclusion of a requirement for Member States to report annually on a series of indicators to monitor progress towards the NECD. The EEA have identified a number of criteria for selecting indicators for monitoring air pollution (EEA, 2004c). Indicators should:

13 Further information can be found in Task 1 of this study.


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• Answer main policy questions and communicate meaningful messages for policy makers and implementers;

• Be comparable between countries; and,

• Be transparent regarding the data used; be informative to a general public; and, provide the best available scientific insights.

The implementing provisions of the greenhouse gas Monitoring Mechanism requires Member States to report annually with their emission inventories on a series of ‘priority’, ‘additional’ and ‘supplementary’ indicators (specified in Annex II of the provisions). Examples of these indicators include: specific CO2 emissions of households (‘priority’), specific CO2 emissions of iron and steel industry (‘additional’) and carbon intensity of transport (‘supplementary’).

A similar set of indicators could be developed for reporting under the NECD which, if prepared and submitted annually with emission inventories, would allow Member States and the Commission to monitor and compare progress towards the NECs.

Review process for the NECD15 The Commission could set up an official NECD Review Process, similar to that in place for the greenhouse gas Monitoring Mechanism. This could include a technical evaluation of national programmes and emission inventories and projections. A specific timetable for review should be established. This would give Member States confidence that their data is being used and could encourage submission of information by the required deadlines. It should also lead to improvements in the accuracy and level of information being submitted, and enable the potential use of data for additional policy development purposes.

Commission report and inventories each year16 The first annual LRTAP/NEC emission inventory review carried out by EMEP and the EEA has already identified the potential to harmonise and/or combine the reporting of emission inventories under the NECD and CLRTAP as some Parties/Member States report the same submission to both. The study recommended that the reporting of emission inventories under the NECD be moved to 15th February each year to coincide with reporting to CLRTAP. Another potential option could be that Member States report their NEC emission inventories to the Commission and EEA as required by the Directive (by December 31st each year). The Commission and/or EEA could then compile a Community report, similar to the process under the Monitoring Mechanism, which could be sent direct to CLRTAP. This would help to reduce the reporting burden on Member States.



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3.3.2 Reporting requirements

Potential submission with other inventories17 The comparison of the NECD national programmes with other national plans and programmes under Task 1 of this study highlighted the linkages and differences between the different submissions. There is a significant overlap of policies and measures reported in NECD national programmes and in plans and programmes reported under the LCPD, Air Quality Framework Directive and under greenhouse gas obligations (to the UNFCCC and the Monitoring Mechanism). In particular, a large proportion of policies and measures reported to reduce greenhouse gas emissions will also reduce emissions of NECD pollutants and vice-versa. The proposed guidelines also highlight how similar the two sets of submissions could be in the future as they have been based on the implementing provisions of the Monitoring Mechanism. The potential for combining reporting under the NECD and the Monitoring Mechanism could be hugely beneficial in reducing the reporting burden on Member States. One complete emission inventory for all pollutants could be submitted each year and national programmes including projections, policies and measures and other relevant information could also be combined. Although there are some clear differences between the two sets of submissions, combining the reporting of greenhouse gases and NECD pollutants could help to improve consistency between submissions and Member States.

Aside from the linkages between reporting under the NECD and to CLRTAP and the Monitoring Mechanism, all of the policies and measures reported in LCPD plans and the majority in air quality plans will also contribute towards a Member State achieving their ceilings under the NECD. Some technical measures in air quality plans, however, are aimed specifically at reducing particulate matter emissions such as particulate traps, for example, and will not reduce emissions of current NECD pollutants. The level of consistency of reporting of policies and measures between NECD national programmes and LCPD and air quality plans varied considerably between Member States. NECD national programmes, unsurprisingly, tended to include European and national level policies and measures such as the LCPD itself without outlining what specific measures would be required at a smaller scale (for example, on a plant-by-plant basis). In contrast, LCPD and air quality plans reported local and plant specific measures that have been, or will be, implemented to comply with the legislation. Although no emission reduction plans were submitted under the Solvent Emissions Directive within the timescales of this study, these plans should contain installation specific measures that have been or will be taken to reduce VOC emissions in accordance with the Directive.

A potential area for further investigation could be whether or not it would be feasible for Member States to report, in one submission, a full complement of policies and measures that have been, or will be, implemented to comply with the requirements of these Directives. This could be reported on a regular basis (for example, biannually) in a standard format such as that proposed in the draft guidelines. This submission would ensure consistency and transparency of reporting between submissions and provide a detailed insight into the level of action of each Member State in each sector. As well as policies and measures reported under the NECD, LCPD, Air Quality Framework and Solvent Emissions Directives, this submission could go even further and be combined with policies and measures reported under greenhouse gas obligations.


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In addition to this, there is also the potential to synchronise and even combine the reporting of emission inventories and projections under the NECD, LCPD and possibly under the Monitoring Mechanism. A combined inventory would have to be sufficiently disaggregated to the level of detail required under the LCPD (for example, ‘new’ and ‘existing’ LCPs) or more detailed emissions for the sector could be provided as an attachment to the core inventory. The achievement of consistency in the sectoral disaggregation of the inventory would have to be investigated further, particularly if greenhouse gases were to be reported as well. Plans and programmes reported under the Air Quality Framework Directive deal with exceedences of ambient air concentration limit values rather than total emissions so this information would still have to be reported separately.

3.3.3 Tools for knowledge exchange

Database of policies and measures The wide range of policies and measures reported in each of the NECD national programmes could provide a useful tool for the next round of reporting for not only the New Member States submitting their first programmes under the NECD but also those that will be on their second round of reporting. Most countries will be aware of the more traditional policies and measures such as ELVs for LCPs, for example, but several, more innovative measures have been described for specific sectors such as the transport sector, for example. A comprehensive list and/or searchable database of all policies and measures reported for each key sector could provide a useful ‘toolkit’ for the next round of reporting so that each country is aware of all of the possibilities for emission reductions before preparing their programme. This type of database could be combined with that on studies and standards, produced by the Milieu Consortium under the contract for the Commission to ‘assess the effectiveness of air quality policies and measures’ (Milieu et al., 2004).

Annual workshops Workshops on policy and measures could be organised on an annual basis by the Commission for Member States to share their experiences. This type of knowledge exchange could be a valuable means of disseminating information on the most effective policy and administrative measures for emission reduction, covering both market-based instruments and more traditional command and control policy measures.

3.3.4 Setting ceilings

Relative targets Task 1 of this study, found that Member States have expressed difficulties in that the current NECD contains absolute ceilings and as such, does not account for adjustments to compensate for changes in methods used to compile emission inventories. For example, the NOX emission factor used to estimate emissions from heavy duty vehicles has increased since the negotiations for the NECD. Member States’ ‘baseline’ emissions have increased accordingly, but the NECs have remained constant. This means that Member States need to make greater absolute reductions than they originally agreed to.

As an alternative an emission ceiling could be specified as a percentage reduction in emissions relative to a base year (or period of years), as in commitments under the Climate Change Convention, rather than as absolute tonnage values. This would help “to ensure countries

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deliver on the level of ambition they originally agreed” and “make agreements more robust to technical developments in inventories” (Rea, 2004). However, it is important to consider the reasons for the implementation of the NECs with regard to meeting environmental objectives, which, by their nature are absolute.

Optimal areas With regards to the future potential for the use of economic instruments in meeting the IEOs, the EC has an ongoing contract to investigate the extent to which national ceilings could operate in optimal ‘bubbles’ to control the substances that are covered under the NEC directive with regard to the protection of soils, lakes and vegetation from ground level ozone, acidification and eutrophication.

There is reason to believe that in the case of small Member States, the ‘bubble’ might be too small, whereas in the case of some larger Member States the ‘bubble’ might be too large. The study will then investigate whether the ‘bubbles’ of two or several Member States could be joined for instance in a context of a European wide emissions trading scheme on some of the substances responsible for acidification, eutrophication or ground-level ozone.

Likewise, the RAINS review team suggested that (SERI, 2004: 4) emissions and control measures could be applied with a finer resolution than country specific national boundaries. For large countries a regional approach may be more appropriate from a scientific point of view, since the outcome of a strategy may be quite different depending on where in a Country control measures are implemented.

The ‘optimal areas’ approach would be particularly beneficial if an emission ceiling was to be implemented for particulate matter. This issue is further discussed in Task 2.

3.3.5 The use of economic instruments Information on the potential use of economic instruments is included in the Draft Review Report.

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4 References

Amann, M., Heyes, C. and Schöp, W. (2004b) Uncertainties. The Regional Air Pollution Information and Simulation (RAINS) model Review 2004. February 2004. Available online at: www.iiasa.ac.at/rains/review/. Accessed October 2004.

Centre Interprofessionnel Technique d’Etudes de la Pollution Atmosphérique (CITEPA) (2004) Air emissions in France, Mainland France substances causing acidification, eutrophication and photochemical pollution. Available online at: www.citepa.org. Accessed January 2005.

Centre Interprofessionnel Technique d’Etudes de la Pollution Atmosphérique (CITEPA) (2000) Emissions dans l’air en France outre-mer, substances impliquées dans les phénomènes d’acidification, de photochimie et d’effet de serre. Available online at: www.citepa.org. Accessed January 2005.

Dekker, C. (Dutch Ministry of the Environment) (12th November 2004), “Emissions trading to Control NOx in the Netherlands”, paper presented at Joint CAFE/NEBEI conference, Brussels

ENDS Daily (10th November 2004), “Netherlands Moves Towards NOx Emissions Trading”, Issue 1765

European Commission (EC) (2004) Information published online, after Eurostat, at: http://europa.eu.int/comm/regional_policy/themes/rup_en.htm. Accessed January 2005.

European Commission (EC) (2000) COMMISSION REPORT ON THE MEASURES TO IMPLEMENT ARTICLE 299(2) THE OUTERMOST REGIONS OF THE EUROPEAN UNION Brussels, 14.3.2000 COM(2000) 147 final. Accessible online at: http://europa.eu.int/comm/secretariat_general/sgb/rup/documents/comm2000-147_en.pdf. Accessed January 2005.

European Environment Agency (EEA) (2004a) An initial assessment of Member States' national programmes and projections under the National Emission Ceiling's Directive (2001/81/EC). European Topic Centre on Air and Climate Change (ETC/ACC) Technical Paper 2003/8 for the European Environment Agency, April 2004.

European Environment Agency (EEA) (2004b) Air Pollution in Europe 1990-2000, European Environment Agency, EEA Topic Report 4/2003, 2004.

European Environment Agency (EEA) (2004c) Air Pollution in Europe 1990-2000, European Environment Agency, EEA Topic Report 4/2003, 2004.

Instituto do Ambiente (IA) Personal Communication 27th January 2005

Labandeira, X. (University of Vigo) (12th November 2004), “Regional Air Pollution Taxes in Spain”, paper presented at Joint CAFE/NEBEI conference, Brussels

Ministère de l’écologie et du développement durable (MEDD) Direction de la prévention des pollutions et des risques, France, Personal communication 28th January 2005.

Milieu Ltd., the Danish National Environmental Research Institute and the Center for Clean Air Policy (2004) Assessment of the effectiveness of European air quality policies and legislation.

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Case study 1: Comparison of the EU and US approaches towards acidification, eutrophication and ground level ozone. 4th October 2004.

Millock, K., and Sterner, T. (2004) NOX emissions in France and Sweden. In Harrington, W., Morgenstern., R. D. and Sterner, T. Choosing Environmental Policy: Comparing Instruments and Outcomes in the United States and Europe. Resources for the Future. Washington DC. 283 pp.

Portuguese National Emission Ceilings Programme (Portuguese NEC Programme) Reference Scenario (2002) Background Studies

Rea, J. (2004) Improving air quality- the Policy Challenge to 2020. Workshop on Review and Assessment of European Air Pollution Policies, Gothenburg, Sweden Oct 25-27, 2004.

Secretaria Regional do Ambiente e dos Recursos Naturais of Madeira (SRA) Personal Communication, 18th January 2005

UNFCCC (2003) Review of the implementation of commitments and of other provisions of the convention – UNFCCC guidelines on reporting and review. Conference of the Parties, eighth session, 23 October – 1 November 2002. Published 28 March 2003.

UNFCCC (2000) Review of the implementation of commitments and of other provisions of the convention – UNFCCC guidelines on reporting and review. Conference of the Parties, fifth session, 25 October – 5 November 1999. Published 16 February 2000.

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