Committee Reports > List of Committees > Joint > 1985 > Committee on the Secondary Legislation of the European Communities (4th Committee) > Report No. 25 - Acid Rain

FOURTH JOINT COMMITTEE
on the
SECONDARY LEGISLATION
of the
EUROPEAN COMMUNITIES

REPORT NO. 25

ACID RAIN

A. INTRODUCTION

1.The Joint Committee in its third Report entitled Air Pollution, Conservation and Protection ⁽¹⁾ of the Environment dealt, inter alia, with the problem of acid rain. This Report elicited a response from concerned bodies and, in view of this and the growing public debate in relation to the phenomenon of acid rain, it was decided to examine the problem specifically in conjunction with current Community legislation and proposals in this area.

Acknowledgements

2.This Report was prepared for the Joint Committee by its Sub-Committee on Social, Environmental and Miscellaneous Matters under the Chairmanship of Senator Mary Robinson. The Joint Committee is indebted to Senator Robinson and her colleagues for their work.

3.The Joint Committee also wishes to express its thanks to the various individuals and groups who made written and/or oral submissions namely:

Help Organise Peaceful Energy (HOPE)

An Foras Forbartha (AFF)

Electricity Supply Board (ESB)

National Board for Science and Technology (NBST)

Ms. Karin Dubsky, Irish Air Group

Dr. David Jeffrey, Environment Services Unit, Trinity College.

Professor Tom Raftery, MEP.

An Taisce.

Dr. rer. nat. Ulrich Kleeberg, Gottfried Bischoff GmbH & Co. KG, Essen, West Germany.

Dr. Jas Fenger, Director, Danish Air Pollution Laboratory, Copenhagen.

4.Written memoranda were received from the Departments of the Environment, Fisheries and Forestry, Energy and Industry, Trade, Commerce and Tourism. Representatives from the Departments of the Environment, Fisheries and Forestry and Industry, Trade, Commerce and Tourism also had discussions with members of the Sub-Committee. The Joint Committee is grateful for the help and assistance received.

The Department of Energy declined to send representatives to a meeting of the Sub-Committee. The Joint Committee wishes to express its regret at this development in view of the long-standing mutual working arrangement the Joint Committee has fostered with Government Departments.

Orders of Reference

5.Several witnesses who appeared before the Sub-Committee referred to a House of Commons Environment Committee Report on Acid Rain.⁽¹⁾ The Commons Committee is enjoined to examine the expenditure, administration and policy of the Department of the Environment and associated public bodies.

The Orders of Reference of the Oireachtas Joint Committee on the Secondary Legislation of the European Communities enjoin it to examine Community acts and proposals. It is from this perspective and within this framework that this Report has been prepared.

Community Measures

6.In examining the problem of acid rain the following Community measures and documents were taken into consideration:-

Council Directive 80/779/EEC of 15 July 1980 on air quality limit values and guide values for sulphur dioxide and suspended particulates.⁽²⁾

Council Directive 84/360/EEC of 28 June 1984 on the combating of air pollution from industrial plants.⁽¹⁾

Amended proposal for a Council Directive on the limitation of emissions of pollutants into the air from large combustion plants.⁽²⁾

Proposal for a Council Regulation establishing s Community scheme to provide forests in the Community with increased protection against fire and atmospheric pollution.⁽³⁾

Visit to Moneypoint

7.Members of the Joint Committee visited the ESB Generating Station at Moneypoint on Friday, 8 November 1985 to conduct an on-the-spot assessment of the operation of the plant and the Board’s facilities for the prevention and monitoring of atmospheric pollution in connection with the preparation of this Report. The Joint Committee is grateful to the ESB for its co-operation and assistance on that occasion.

B. THE EUROPEAN PROBLEM

Definition

8.Acid rain is a global term which refers to all forms of precipitation (hail, snow, mist etc) which have an acidity significantly above normal levels due to the effects of various atmospheric pollutants. It also refers to these pollutants when they are deposited in dry form and to their particulate derivatives, eg sulphate.

The description “acid rain” was first used in 1872 by the English chemist, Robert Smith, in reference to the sooty skies over Manchester. The term was revived in 1967 by the Swedish soil scientist Svante Oden who warned against man’s “chemical war” on nature. The term acid rain has also gained currency because of its graphic and emotive connotations. The terms “acid deposition” and “acid precipitation” are considered more scientifically accurate.

9.Acidity is measured on a pH scale. A pH value of 7.0 is neutral. Higher pH values indicate alkalinity and lower pH values, acidity. The pH of “normal” rainwater is around 5.5 but this may be lowered significantly as a result of contamination of air.

Causes of Acid Rain

10.Acid rain is mainly caused by emissions of sulphur dioxide

(SO₂) and nitrogen oxides (NO_x). These are produced by the burning of fossil fuels especially coal and oil, in power stations, industrial plant, motor vehicles and domestic heating appliances. These constituents react with moisture to produce, in effect, a dilute solution of sulphuric and nitric acids which may have severe effects on the environment receiving such rainfall.

Sources of Emissions

11.The compounds giving rise to acid rain originate in man’s activities with a very high percentage of the SO₂ coming from large combustion installations, such as smelters, oil and coal-fired electricity generating stations, auto-motor vehicles and oil and gas refineries. In the case of NO_x about half the emissions in Europe are anthropogenic (manmade) with vehicle sources and stationary sources (major industries, again including power stations) contributing about equal amounts.

Transboundary Problems

12.Depending upon prevailing wind patterns, geographical location, degree of industrialisation, and so on, some countries are net importers of air pollutants, and others net exporters. The Scandinavian countries are net importers, for example, while Great Britain, Germany, France and Italy are net exporters of sulphur dioxide.

13.Transboundary pollution has been exacerbated by the use of tall chimney stacks at power stations. These make for a considerable degree of dispersion and dilution in the atmosphere, eliminating to a very great extent the local acute effects. However, this can be at the expense of the wider environment. It may serve to transfer the ultimate effects to areas perhaps hundreds of miles away. Emissions may not be effectively dispersed and may thus be brought away by prevailing winds to other countries which receive the consequent acid rainfall.

14.The idea of transboundary air pollution over great distances did not gain general acceptance until the mid 1970s when it was proved scientifically that emissions from central Europe and Britain were significantly affecting acid deposition in Scandinavia. Norway, one of the hardest hit areas, receives a high percentage of its acid rain from Great Britain and Germany.⁽¹⁾

Effects in European Countries

15.The impact of acid rain on natural and built environments has been devastating:

Lakes:- Only a small proportion of acid rain falls directly into streams, lakes or rivers. Most of it enters watercourses via the soil. The buffering (neutralising) capacity of the soil is, therefore, crucial in determining the degree of damage.

In Scandinavia fish-kills in rivers and lakes have raised public awareness of environmental issues.

Trees:- Damage to forestry is perhaps the most dramatic consequence of acid rain. Millions of acres of trees mainly in Central Europe, have been devastated and further damage is expected. In West Germany there has been widespread concern over forest damage on an extensive scale.

In Sweden forest growth has declined measurably in recent decades. Visible scars have been observed on leaf surfaces of plants exposed to acid rain.

However, in this connection the Joint Committee draws particular attention to the views it expresses in paragraph 77 of this Report.

Agricultural Crops:- Dry deposition of SO₂ and NO_x, particularly in combination with ozone would have an adverse effect on crop growth. In the USA the Environmental Protection Agency (EPA) found acid rain damage in apples tomatoes, beet, carrots, mustard, greens and brocolli.

Wildlife:- Wildlife is threatened as habitats change and acid - sensitive species give way to acid - tolerant ones.

Human Health:- Acid rain represents a direct threat to health via the contamination of drinking water, and a direct threat, particularly in the form of dry deposition, to populations living close to emission sources and absorbing the pollutants by inhalation.

Manmade Structures:- Extensive damage to historic buildings, statues and monuments throughout the northern hemisphere is being caused by acid rain. Limestone, marble, some sandstones and certain kinds of slate are particularly vulnerable to acid rain.

It is estimated that acids have aged the Acropolis in Athens more in the past few decades than in the previous 2000 years. Steel and other metals also corrode more quickly when exposed to acid rain. The US Council on Environmental Qaulity estimates that over £1.5 billion worth of structural damage from acid rain is caused each year in the US.

International Developments

16.The Convention on Transboundary Air Pollution (LRTAP) was formulated under the auspices of the UNECE ⁽¹⁾ and signed in Geneva by 33 countries in November, 1979. The Convention came into force in March 1983 when it had been ratified by 24 countries. Within this framework, specific recommendations will issue by 1987. At the present time, it contains no call for specific reductions in known pollutants, and is therefore relatively ineffective. It is however the only multilateral agreement on air pollution that exists.

30% Club - Protocol on the Reduction of Sulphur Emissions

17.Recognising the need for more drastic measures to curb acid rain the Nordic countries put forward a proposal at an EEC meeting in June 1983 calling on all parties to the Convention to “implement a 30% reduction of national sulphur emissions or their transboundary fluxes by 1993-1995, using 1980 emission levels as a basis for calculation of reductions”. Twenty-one of the contracting parties to the Convention on Transboundary Air Pollution have signed the Protocol. The UK, Ireland, Spain, Portugal and Greece are the only EEC countries not to have joined the 30% Club. (See Appendix 4).

C. IRELAND - CURRENT EVIDENCE AND RESEARCH⁽¹⁾

National Emissions

18.Irish emissions of atmospheric pollutants have increased substantially since the 1950s. A table setting out the SO₂ emissions in the ten-year period between 1972 and 1982 is reproduced in Appendix 1. The levels of SO₂ and NO_x emissions peaked in 1979 but have declined very substantially since then, particularly in the case of SO₂, with the introduction of natural gas for electricity generation. In 1980, total emissions of SO₂ were 217,000 tonnes of which 98,000 tonnes were attributable to large combustion plants. According to the Department of the Environment, in 1984 the figures were 123,000 tonnes and 44,000 tonnes, respectively.

19.Ireland’s total emissions of air pollutants are, in fact, very low and our contribution to transboundary air pollution and to acid deposition is negligible. Total emissions of SO₂ by all Member States in 1982 were an estimated 14,753,000 tonnes. Irish emissions comprised 1.1% of this figure. However, HOPE maintain that, when emissions of SO₂ per capita and per unit of GDP are considered, it can be said that for every man, woman and child in this country, almost as much SO₂ is being emitted as for each of the inhabitants of the most polluting countries. An Foras Forbartha, on the other hand, consider that what is important is the magnitude of emissions in relation to the area of this country.

20.Even with relatively low growth in energy demand emissions of SO₂ from power stations and other large combustion plant in Ireland will increase in the next ten years. Of major significance in this increase is the fact that, in line with EC energy policy, natural gas will no longer be used extensively by the ESB but, instead, by household, commercial and industrial users. The anticipated new pattern of natural gas usage will continue to effect a significant reduction in overall national emissions of SO₂ and, at local level, will be more beneficial in improving the environmental situation. However, as power stations change to the use of fuels such as coal and oil, increases in SO₂ emissions from this sector will ensue.

In relation to natural gas allocation the Minister for Energy replied as follows to a Parliamentary Question ⁽¹⁾ in the Dail:-

“An examination of the long-term development of the gas industry, including the optimum allocation of the balance of the Kinsale Head reserves, is currently underway. Pending completion of this examination, I am not in a position to comment on future gas allocations to the Electricity Supply Board”.

Deposition

21.Ireland is less polluted by acid rain than most other European countries. The prevailing south-westerly winds protect Ireland from the bulk of transboundary pollution imported from the UK and the Continent and Irish emissions of acidifying pollutants per kilometre² are considerably less than those of most of our European neighbours. However, there has been a steady increase in the acidity of Irish rainfall since 1960.

Monitoring by Meteorological Service

22.For over 25 years the Meteorological Service Network has operated a regular monthly programme of sampling and analysis of rainfall. While the network and procedures were not specifically optimised for the assessment of acid rain, the considerable volume of pH data accumulated has indicated an overall trend towards increased acidity, despite considerable variations in rainfall acidity levels.

Indeed, because of the extreme westerly location (in European terms) of the principal site, Valentia station, and because the prevailing winds are from the west or south-west, the data gathered there should reflect a European “zero-effect” baseline and, as such, be of wide international interest. Reflecting this, the Meteorological Service, in conjunction with the Department of the Environment, has designated the station as a participating one in the Environmental Monitoring and Evaluation Programme (EMEP) of the United Nations Economic Commission for Europe (UNECE) for which a range of daily rainfall, dry deposition and air analyses are carried out.

Research by An Foras Forbartha

23.In 1982, as part of its increasing activities in the field of air pollution studies, An Foras Forbartha (AFF), with partial funding from the EEC and as a contribution, in conjunction with Trinity College, Dublin to the EEC Environmental Research Programme, commenced a study in which extensive and specific rainfall analyses would be carried out at a range of stations in the Dublin region. The project is entitled “Distant and Local Pollution Effects on Rain Chemistry and Leaf Yeasts” and was originally scheduled to terminate on 30 November, 1984. However, it will now run until May, 1986.

24.The Dublin region was chosen as the most potentially suitable in the country in that it could be expected to pick up any deposition arising from large Irish emitters to the west or south-west, such as power stations, and because it was felt that deposition from emissions in the UK and even Europe might be picked up.

In this research programme stations for the collection of daily samples of total (wet and dry) deposition were established at the following locations:

Glencree, County Wicklow

Casement Aerodrome, Baldonnell, County Dublin

Trinity College, Dublin

Kinsealy, County Dublin

Dublin Airport, Collinstown, County Dublin.

25.An important aspect of this study is that samples are taken so that wet days and dry days may be studied separately. Daily samples of wet deposition are necessary to relate the rainfall constituent concentrations or the quantity of such deposition to wind direction. This is not possible for samples taken over a longer span because of the factor of wind variability in direction.

26.Samples have been taken and analysed since early 1984, the parameters comprising rainfall volume, pH, conductivity, sulphate, nitrate, ammonia and sodium. The last-mentioned is used as an indicator of wind-borne sea spray and enables appropriate corrections to be made to other key determinations to eliminate errors on that account. In addition, for much of the experimental period a rainfall recorder has been used to monitor the time, duration and quantity of wet deposition at the Glencree site. This situation was considered the primary one, being located in an upland granitic area with potential for the assessment of the effects of acid rain, as discussed further below.

The Findings to Date

27.The data from the research programme - covering the period from March 1983 to October/November 1984 - show the following:

(i)clear evidence of acid rain has been gathered - the data for the Glencree site, in particular, confirm this.

(ii)on over four per cent of the total number of wet days (ignoring wind direction) the Glencree rainfall pH levels were 4.0 or less.

(iii)when only those wet days when the wind came from the NE-SE quadrant of the compass are taken into account the percentage figure mentioned in (ii) above rises to over thirty.

(iv)the highest deposition rates for sulphate and nitrate, derived respectively from SO₂ and NOx, at Glencree can be correlated clearly with wind direction, revealing that rates are greatest when winds are from the NE-SE quadrant.

(v)the seasonal variations in the levels of sulphate, nitrate and acidity at Glencree show that in winter, when westerly winds prevail, values are very much below those recorded for late Spring/early Summer when easterly winds are prevalent.

The results suggest strongly the presence of transfrontier air pollution and they show that an incipient problem exists on the eastern seaboard. However, An Foras Forbartha warn that these results are not definitive and must be regarded primarily as an initial batch of data which will serve, inter alia, as the foundation on which future work programmes will be built.

Research on Lakes

28.A study complementary to that described above has been under way since early 1984, and is scheduled to run for two years, again as part of the EEC Environmental Research Programme. The project is entitled “Precipitation Characteristics and the Chemistry and Biology of Poorly-Buffered Irish Lakes - A Western European Baseline for ‘Acid Rain’ Impact Assessment” and the aim of it is to establish a well-defined baseline for those lakes susceptible to damage from acid deposition (soft, poorly-buffered waters on granite) by means of extensive physical, chemical and biological studies on lake and rain waters in two areas.

29.Two lakes (Loughs Maumwee and Nahasleam) near Maam Cross in County Galway and two in County Wicklow (the Upper Lake at Glendalough and Lower Lough Bray) have been selected for the study on the rationale that the former pair, because of their location, should be unaffected by acid rain while the latter could show some effects (particularly in view of early findings from the first-described project). To ensure as much integration of effort as possible a common schedule of analyses is carried out in both studies with data being pooled where appropriate in order to eliminate duplication.

Research on Damage to Buildings

30.In like manner rainfall data from the central Trinity College Station will be used in a third study now under way. This research, on the effects of acid rain on buildings, is being undertaken by workers at TCD and the findings should be of considerable interest. The European Commission is providing £80,000 for this multi-disciplinary research project to investigate the effects of acid precipitation on historic buildings and monuments in Dublin. Most of the buildings to be included in the study are located in a relatively small area of the city adjacent to Trinity College, where transportation, space heating and power generating systems have been polluting the local atmosphere for some years.

31.The resources and individuals engaged on this project will take the form of a unique combination of organisations involved with building maintenance, repair and conservation - the Director of Buildings, TCD, Environmental and Materials Sciences Unit, TCD, School of Architecture and Building Technology Laboratory, UCD, and a Senior Architect from the Office of Public Works. This multi-disciplinary approach to the project represents a major innovation in this field of research.

32.Finally, as part of the extension of the original project, other workers at TCD hope to supplement the measurements made by AFF by carrying out, as resources permit, additional chemical determinations on soil and air in order to maximise the benefits from the study.

33.By late 1986, therefore, Ireland should have available reports on acid rain occurrence at the five-station Dublin network over a period of some 2½ years, on the characteristics of lakes which are susceptible to damage from acid deposition, and on the effects of rain on buildings in Dublin. While some of these will be of more than local interest - in the case of the lakes study, for example, the baseline is intended as a European one against which the status of lakes in other countries which already experience acid rain problems may be gauged - their main value will be in providing the first substantial bank of information on a range of acid rain related topics in Ireland.

Future Activities

34.While it is very probable that in future, extensions of the above studies and/or completely new projects will be planned, An Foras Forbartha consider that specific proposals must be made now for the ongoing monitoring of acid rain (locally, generally and transfrontier) in the Dublin area, in particular, in order to ensure continuity of information on a long-term basis. Specifically, AFF told the Joint Committee that it intends to maintain the principal station in Glencree as one at which present and additional analyses will be carried out. Although under present studies daily data will be obtained from Glencree for at least the next 15 months, studies are now on hand to determine the implications of setting up a permanent site to EMEP standards at which an extended range of sampling and analysis will be carried out, including the periodic monitoring of SO₂ and NOx in air.

35.By virtue of its work undertaken at the request of the Minister for the Environment AFF has established the capability to carry out all relevant rainwater analyses as well, of course, as the determination of the primary air pollutants (black smoke, SO₂ and NOx), so that relatively little capital costs are foreseen apart from the purchase of the instrumentation and equipment needed for the discrete sampling of wet (as distinct from total) deposition. The relative proximity of the Glencree site to the analytical laboratories of AFF (these are at Kill-of-the-Grange, Dun Laoghaire) would mean correspondingly small increases would be required in running expenditure.

36.Although these data have shown clearly that the extent and frequency of acid rain events on the eastern seaboard is discernible, the AFF feel that there is a definite need for both continuing and additional data, the latter to cover measurements in air as well as rainfall. The systematic, ongoing collection of such data seems practicable at moderate levels of both capital and running expenditure.

Research on Forestry

37.The Forest and Wildlife Service (FWS) have informed the Joint Committee that there is no evidence of any forestry related problems connected with acid rain in Ireland. As in Britain, it is not possible to be certain that damage has not occurred in the past or may occur in the future. Because of this uncertainty and the disagreement among European scientists on the precise cause(s) of forest decline in countries such as Germany and Switzerland, FWS is maintaining close links with the various international bodies concerned with continuing research and debate on the subject. The FWS is represented on EEC Technical Committees and Working Parties dealing with acid rain and part of its research programme is aimed at achieving a better understanding of the overall phenomenon. While the information at present available to the FWS does not suggest that acid rain is likely to pose a threat either in the short or medium term (say 50 years) to Irish forests the conditions in Ireland are such that they provide baseline data based on a relatively clean environment for the study of acid depositions, their significance, and the interactions between forests and rainwater chemistry. The forest decline in Central Europe is so little understood that there is an urgent need for close collaboration between scientists to arrive at a clearer understanding of the problem.

38.The FWS is co-operating with the Macaulay Institute, Aberdeen, Scotland, in an EEC funded project, part of which is concerned with making comparisons between rainfall acidity in Scotland and Ireland and the degree to which rainwater chemistry, including its acidity, is altered as it penetrates the forest canopy. This study site is located at Avondhu Forest, County Cork and it is intended to set up another observation station with the same objective in Glenamoy Forest, County Mayo. This will facilitate the collection of data not only on the effects of forest canopies on rainwater acidity, but will also include studies of the changes that occur in soil water chemistry after normal forest operations such as clearfelling. It is hoped to obtain some further funding for these studies from EEC sources through the new Programme on Environmental Protection (1986-1990).

39.The FWS is also monitoring water acidity and nutrient concentration on a regular basis in an important fishery area in Connemara (Invermore Fishery) in order to ascertain if afforestation in the catchment has any significant effect on water chemistry.

40.FWS consider that it would be premature to comment on the results of any of these studies so far. However, rainfall acidity at the north Cork site is less than in Scotland and there is no evidence so far of acidity increasing as the water penetrates the forest canopy. Seldom is the rainfall actually “acid”. There is no evidence so far to suggest that afforestation has produced any significant changes in the water acidity of the Invermore Fishery.

41.FWS is represented on an EEC Concerted Action Committee on the ecological effects of air pollution and acid depositions. The Committee, which was set up in 1984 under EEC Directorate - General XII, Science, Research and Development (Environmental Protection and Climatology), aims to co-ordinate and evaluate existing research in this field and to initiate new research.

FWS is also represented on a Working Party set up by the Committee to examine air pollution effects on the forest ecosystem, in particular.

D. COMMUNITY MEASURES

Proposal for a Council Regulation establishing a Community scheme to provide forests in the Community with increased Protection against fire and atmospheric pollution⁽¹⁾

42.The Forest and Wildlife Service was represented at the Working Party discussions in Brussels on this draft Regulation. The Working Party has completed its examination of the draft Regulation but was unable to reach complete agreement. The draft will now be considered by the Committee of Permanent Representatives of the EEC. (Coreper)

43.One of the measures proposed under the Draft Regulation (under atmospheric pollution) is the setting up of a forest health observation network in the Member States. FWS has taken part in discussions at EEC level on the approach to be adopted when setting up this network. Broadly, the object is to monitor, on an annual basis, the appearance, nutrient status and vigour of representative tall forest crops and relate these to regional rainfall chemistry. Data from each Member State will be co-ordinated by the EEC Commission.

44.Setting up of these monitoring stations in Ireland (as in other Member States) will proceed if/when the draft Regulation is agreed.

Council Directive 80/779/EEC of 15 July 1980 on air quality limit values and guide values for sulphur dioxide and suspended particulates⁽¹⁾

45.Pursuant to Article 15, Member States had to bring into force the necessary laws, regulations and administrative provisions within 24 months of the notification, ie 18 July 1982. The Department of the Environment considered that the objectives of the Directive were already covered by existing regulations and that no further statutory rules were required. However, the Commission delivered a reasoned opinion under Article 169 of the Treaty of Rome on 27 February, 1985. The Department replied on 22 April, 1985.

46.Throughout the Member States the implementation of this directive has been beset with major difficulties and in the First Annual Report from the Commission to the Council⁽²⁾ on its implementation it states that “progress made so far is anything but satisfactory”.

Council Directive 84/360/EEC of 28 June, 1984 on the combating of air pollution from industrial plant ⁽¹⁾

47.This Directive comes into effect on 1 July, 1987. It requires that prior authorisation be given to the operation of certain industrial plant and to the major alteration of such plant. In effect, the Directive requires that those industries and power plants most likely to give rise to air pollution must be licenced.

48.According to the Department of Industry, Trade, Commerce and Tourism this Directive should not present any difficulties for Irish industry; those industries already existing here in the categories covered are already meeting the most stringent international emission standards.

49.The Department of the Environment have informed the Joint Committee that the legislative framework for implementation of the Directive is to be provided in an Air Pollution Bill. Work is proceeding at present on the drafting and it is hoped to present the Bill to Dail Eireann in the near future.

50.It is envisaged that the Bill will provide for a licensing system, to be operated by local authorities, which will apply to new plant of the kind to which the Directive relates and which can be extended, as necessary, to existing plant. It is expected that the Bill will also provide for procedures regarding applications for licences, granting of licences, appeals, review, duration of licence etc.

Proposal for a Council Directive on the limitation of emissions of pollutants into the air from large combustion plants ⁽¹⁾

51.The Commission’s original proposals have been amended following debate on the proposal in the European Parliament on 15 November, 1984.

52.The draft Directive covers both new and existing combustion plant with a rated thermal output equal to or greater than 50MW. It is designed substantially to reduce emissions of sulphur dioxide (SO₂), oxides of nitrogen (NO_x) and dust from such installations.

53.The following requirements would apply if the Directive were adopted in its present form:-

(a)New plant authorised after a specific date (probably one year after adoption of the Directive) would have to observe Community emission limit values specified in the Directive for SO₂ and NO_x and dust. The values are stated by the Commission to be based on the best available technology for the types of fuel and methods of combustion involved. In the case of SO₂ emissions, for example, modern flue gas desulphurisation (FGD) equipment would be needed in large plants if the values were to be attained.

(b)Member States would have to draw up programmes to achieve the following reductions in total emissions from both new and existing plant by the end of 1995, taking 1980 as a base:

-60% in the case of SO₂;

-40% in the case of NO_x;

-40% in the case of dust.

54.The Industrial Plant Directive discussed already, which will become operative in mid-1987, will require the introduction of an authorisation system for air emissions from industrial plant, including power stations in excess of 50MW (thermal). In the case of new plant (ie neither built nor authorised before 1 July, 1987), the authorisation must involve the application of the best available technology, provided that this does not entail excessive costs. Controls are required to be applied to existing plant on a gradual basis, taking account of factors such as the technical characteristics of the plant, of utilisation and remaining life span, the nature and volume of polluting emissions from it and cost considerations. Provision for implementation of this Directive will be made in the Air Pollution Bill referred to already.

55.The Directive provides for the fixing by the Council, acting unanimously, of Community emission limit values based on the best available technology not involving excessive costs and taking account of the nature, quantities and harmfulness of the emissions concerned. It was envisaged when the Directive was being adopted that action would be taken at Community level only if this was considered essential on scientific grounds and that account would be taken of the provisions of the industrial plants Directive with respect to existing plant in drawing up any proposals for Community emission standards. It was also argued that any new proposals should take account of differing environmental conditions, the extent to which transboundary air pollution may be involved, the special problems of existing plant and the desirability of achieving balanced development.

56.The direct impact of the proposed Directive on large combustion plant in Ireland would be felt mainly by the ESB, most of whose existing power stations exceed the 50MW (thermal) threshold, and the Board would have to reduce its emissions drastically if the proposals were to be given effect, In addition, any new ESB plant would have to comply with the proposed Community emission limit values. New industrial concerns with combustion plant in excess of 50MW would also have to meet the emission limit values and there would be widespread knock-on effects for industry as a whole, and throughout the economy, because of the impact on the ESB.

57.To effect the level of reduction required by the Directive, it would be necessary to secure the removal of SO₂ from flue gases by the installation of flue gas desulphurisation (FGD) equipment. This is a particularly expensive operation, at either new or existing plant. The use of natural gas which does not contain sulphur, and of coals and oils with low sulphur content would, of course, also help to reduce SO₂ emissions. However, the use of natural gas on a large scale in power stations raises serious issues in relation to the optimum economic use of gas, while coal and oil with low sulphur content can attract a premium price and there can be no guarantee of their continued availability at reasonable cost. In the future, the application of new technologies (eg improved combustion processes) may provide other measures to reduce SO₂ emissions at power stations but these technologies are not, however, yet fully developed and of themselves, would not affect the reductions sought in the draft Directive.

58.The Government have directed that a study be carried out by the ESB of the possible costs involved in reducing future emissions from power plants to the extent necessary to achieve a stabilisation of overall national sulphur emissions at the 1980 level. The results of the study will be assessed in the context of overall ESB plant construction and/or conversion programmes and taking account of the most economic options from an energy strategy point of view. This study is underway.

59.The Directive would also cover Aughinish Alumina which operates a 490MW combustion plant. Adoption of the Directive could necessitate the installation of desulphurisation equipment at considerable cost. Aughinish, which employs 750 people, is already under very severe trading difficulties. Further capital costs of this order of magnitude would completely jeopardise the future of the plant.

Irish Position on draft Directive - Department of the Environment

60.Ireland has entered a general reservation in relation to the proposed Directive for, inter alia, the following reasons:

-application of the limits proposed would be of negligible benefit to either our own national or the wider European environment;

-the substantial extra costs involved in implementing the proposal would have a disproportionate effect on the Irish electricity generating system and the economy, adding to the cost of living and to production costs, affecting competitiveness and probably causing job losses;

-Ireland is opposed to the principle of setting standard Community-wide emission limit values in the absence of satisfactory scientific justification for their introduction:

-the proposal fails to meet specific undertakings given by the commission to the Council in regard to the application of key provisions of the Directive on industrial plants in the drawing up of subsequent proposals for Community instruments on air pollution;

-the proposal takes no account of the differing environmental situations in Member States, nor of the relative contributions of the various regions of the Community to the air pollution problem;

-there is no scientific evidence that Ireland contributes to any significant degree to the pollution of the atmosphere by any of the substances covered by the proposal;

-no account is taken in the proposal of either Irish environmental conditions or the need to increase our level of industrial development and production;

-the proposal does not allow for the necessary adjustments in energy policy and supply, or in the “mix” between oil, gas and coal, and it favours those Member States who have moved, or are moving, towards increased use of nuclear power;

-the choice of 1980 as a base year is disadvantageous in Ireland’s case, having regard to developments in energy supply;

-the proposal cannot override the basic aspirations of the Community and the fundamental provisions of the Treaty of Rome insofar as development of the Common Market and the elimination of unequal conditions of competition are concerned.

Department of Industry Viewpoint

61.It is this Department’s view that Ireland should totally oppose the imposition of the proposals on Irish industry and, if necessary, veto the proposals in the Council. The Department is opposed to the concept of standards for emissions or discharges without reference to the condition and the receptive capacity of the local environment and considers that the adoption of emission standards as proposed would impose undue and unnecessary costs on Irish industry, particularly at a time when industry is striving hard to maintain its competitiveness vis-a-vis other Member States. Since Ireland has a relatively clean environment and since there is no evidence that Ireland contributes to atmospheric pollution, transboundary or otherwise, the Department of Industry, Trade, Commerce and Tourism does not agree that Ireland should have the requirements of the proposed Directive imposed on our industry because industries in other Member States are incurring relatively high costs to alleviate environmental problems which are essentially caused by their own industries. The Department considers that every effort should be made to secure total exemption for Ireland from the provisions of the draft Directive.

The Environmentalist Viewpoint

62.The Irish position outlined above has been criticised by many conservation groups and academics. The views expressed relate in the main to Moneypoint generating station, the question of whether it should be regarded as “old plant” in the context of the draft Directive and whether flue gas desulphurisation equipment should be fitted.

ESB Viewpoint

63.The ESB is very strongly opposed to the proposed Directive. In its view specific stringent emission limitations on a single class of plant will in the case of Ireland quite demonstrably impede the achievement of optimum deployment of resources on solving environmental problems. This size of plant specified in the draft Directive corresponds to a thermal generating station of about 12MW. There are separate requirements in the Directive for new and old plant.

64.For new plant, which for the ESB would be any plant after Moneypoint’s third unit, specific limits for the pollutant concentrations in the stacks are laid down. Operating to these limits would require the fitting of the most expensive sulphur-removing equipment currently available, with very significant costs for satisfaction of NO_x and spm limits in addition.

65.For old plant, which include the first three units of Moneypoint, targets of total emissions in 1995 from large plant are set at 40% for SO₂, 60% for NO_x and 60% for spm of the 1980 emissions of these substances. This approach is supposed to give flexibility in the method of achieving reduction, but in the particular case of the ESB, it gives no such flexibility.

66.The factors causing this situation are a high reliance on imported fossil fuels and the small size of the isolated system. Maximum size of a generator is currently 270MW and will be 300MW by 1995 because of system stability and security considerations. This size limitation effectively precludes the option of developing a nuclear programme. By 1995 the ESB is likely to be more than 80% dependent on imported fossil fuels (currently 21%, 55% in 1980/81), (73% in 1978/79). The base year of 1980 in the proposal does not help. ESB peak emissions of SO₂ occurred in 1978. Because of these factors the proposed Directive could mean 80-90% desulphurisation, applied by retrofit, to all coal and oil plant. The ESB is extremely worried about the implications of all this because of its potential impact on electricity tariffs in Ireland and the lack of any comparable environmental benefit. The impact of electricity tariffs would be very much higher in Ireland than for other countires. As far as environmental benefit is concerned, the sum of the benefits achieved by the proposed measures for Ireland would be lower than for any other country.

Current Position at Community Level

67.There have been exchanges of views about the draft Directive at several meetings of the Environment Council but no significant progress has been made. Ireland has maintained its general reservation on the proposal and so has Greece. Other Member States have overall waiting reservations or have raised specific problems or suggested amendments relating to matters such as the scope of the proposals, the extent of the reductions sought in 1980 emissions, the level of the emission standards to be set, etc.

E. Views of the Joint Committee

Introduction

68.Over a considerable period economic growth has been promoted at the expense of the environment. There has been an inherent rivalry between these two concepts. The lack of specific mention in the Treaty of Rome of the environment reflects the absence of any great concern for conservation in the 1950s.

69.This reprehensible development has posed a serious threat to our physical environment and to public health through the wastage of scarce resources and the creation of nuisance and pollution. There is now, however, evidence that public awareness and appreciation of the complementary role of economic development and the preservation of the environment is mounting. The quality of our environment, in the form of clean air, unpolluted water and recreational outlets, such as forests and woodlands, is now broadly accepted as an important constituent factor in determining our standard of living. This was acknowledged at Community level when the Heads of State and Governments at their Paris Summit in October, 1972 proclaimed the need for a Community environment policy. A first Action Programme, drawn up by the European Commission, was adopted in 1973, followed by a second in 1977. A third programme, to cover the period 1983-86, was approved in February, 1983. Unlike previous Environmental Action Programmes, the Third Programme places emphasis on prevention rather than on the curative treatment of environmental pollution.

70.The Council of Ministers under the programmes have endeavoured to establish the legitimate place of the environment across the range of Community policies. Among the priority measures accepted by the Council are the prevention or reduction of atmospheric pollution; the promotion of clean technologies and the development of cross-frontier and anti-pollution co-operation.

71.In addition the Commission has submitted four draft Articles on the environment to the inter-Governmental Conference charged with drawing up a new treaty on the European Union. (At present environment Directives rely on the general enabling provision, Article 235, of the Treaty of Rome for their legislative authority). The proposed articles are based on the “polluter pays” principle.

72.The Joint Committee welcomes the proposal to give the environment a formal legal status under the proposed new Treaty as it feels that the most effective way to conserve the environment is through co-ordination at European level where an overall view can be taken to ensure equitable and balanced development of Member States’ economies. The environment is a natural asset of the Community that cannot be delineated by national boundaries.

73.The Joint Committee also sees the co-ordinated approach to the environment as essential to defend the Community’s interests at international level.

74.Since it submitted its Third Report (Air Pollution, Conservation and Protection of the Environment) to the Dail and Seanad in March 1984 the Joint Committee has been keeping the question of acid rain under review. It now identifies more clearly the potential threat to public health and the environment from acid rain and other acidic precipitations.

Acid Rain

75.In its further consideration of the acid rain phenomenon the Joint Committee is faced with an array of conflicting scientific opinion about its effects and, indeed, about its very existence in this country. These opinions range from a relatively harmless to a totally destructive impact on the environment.

76.The Joint Committee is satisfied that over the past 25 years there has been a steady increase in the acidity of Irish rainfall and that this trend correlates closely with the trend in national SO₂ emissions.

77.A focus of the acid rain debate is its effect on trees. The malady that has afflicted the forests of central Europe, particularly the Black Forest in South Western Germany and the Vosges in Eastern France, has been identified with air pollution caused by sulphur dioxide (SO₂) and oxides of nitrogen (NO_x) which are the principal ingredients of acid rain. Despite this contention the Joint Committee is at a loss to understand how trees in areas of the Alps, where the limestone soil should neutralise the acids, are affected in the same way. Some scientists are now beginning to discount the acid rain theory and direct their attention to investigating the effect of ozone, drought, species selection and forest management, particularly the policy of successive rotations of conifers. The application of nitrate fertilisers also can increase the acidity of the soil, often to a greater extent than acid rain.

78.While the Joint Committee cannot come up with any plausible explanation for the demise of the forests of central Europe it has little doubt about the effect of acid rain and particularly dry deposition on the physical environment. For example in Dublin it is estimated that recent repairs confined to a very limited area of the Trinity College buildings - the balustrades and the examination hall - cost in excess of £250,000 to arrest acid damage caused by local pollution sources. The Bank of Ireland building recently underwent a very expensive cleaning and restoration job, estimated to cost about £1.2m, to combat the effects of corrosive atmospheric pollution. Restoration work on the Custom House will cost in the region of £2.5m. This gives some idea of the effect on the economy of this problem, not to mention the challenge to our architectural heritage. The problem is so serious in the Netherlands that the Dutch Government has published a detailed brochure dealing with the problems of acidification, as it seems to be generally recognised that once the problem reaches a certain level it is impossible to tackle the pollution at source, as this would involve inordinate expenditure.

79.In the area of human health, the toxic constituents of acid rain that have penetrated the soil to groundwater can be ingested through drinking water. Drinking water could, in these circumstances, be contaminated with heavy metals such as cadmium, zinc, copper, lead and manganese. Dry sulphate deposition can be inhaled, affecting the respiratory system. While there is no toxicological evidence to suggest that the level of these pollutants has reached the danger level, at present, nevertheless, in the Joint Committee’s view, they are an insidious threat to public health that cannot be ignored.

The Joint Committee wishes to emphasise, in particular the importance of regular monitoring of possible crop damage and variations in soil acidity levels attributable to environmental pollution.

Irish Emissions and Contribution to Transboundary Pollution

80.Ireland’s air is considerably cleaner than that of other Member States. Ireland contributes approximately 1.1% of sulphur dioxide emissions to the EEC total. The four major polluters contributing 85% of Community pollution are Germany, France, Italy and the UK. In Ireland’s case only 45% of SO₂ emissions is caused by large combustion plants, whereas in other Member States the proportion is set up to 75%. In these circumstances the Department of Energy consider that the imposition of Community emission limit values, as proposed in the large combustion plants Directive, would be of little or no benefit when applied to Ireland, affecting as it would only 45% of 1% of total EEC emissions.

81.This is one of the principal arguments used to dispute the applicability of the draft Directive on large combustion plants to the Irish context. The fact that overall emissions from large combustion plants in Ireland are substantially lower than in countries which have provided the driving force behind the Directive fails to take account of the whole cost-benefit dimension in pollution control. The Joint Committee agrees with HOPE that inhabitants of a less populated, less industrialised country should be entitled to a proportionately less polluted environment. The transboundary component in Irish emissions should also be considered regardless of how insignificant this may seem.

82.This assimilative capacity of the environment should also be taken into consideration because estimates of the quantities or concentrations of the various pollutants which the environment is presumed to be capable of absorbing without harm can, perhaps, be strongly influenced by those with an interest in disposing of pollutants. The fact that acid rain deposition in Ireland is not at the hazardous level it has reached in some other countries is not a reason for Ireland to forego emission controls until the level of deposition reaches hazardous or potentially hazardous proportions. By this time the damage may well be irreversible.

ESB Generating Station at Moneypoint

83.At the centre of the acid rain debate in Ireland is the new ESB coal-fired generating station at Moneypoint, County Clare, the first unit of which was commissioned in October of this year. (The second and third units will be commissioned in mid-1986 and mid-1987, respectively). When the representative of the ESB appeared before the Joint Committee he argued that Moneypoint did not pose any threat to the domestic environment, and was supported in that contention by a technical expert from An Foras Forbartha. It was contended by the ESB that the tall chimney stacks, standing at 220m high, dispersed any pollutants that remained after subjection of flue gases to electrostatic precipitation and ash-arresting procedures. The ESB also stated that Ireland did not join the league of exporters of acid rain to Scandinavia as there is no evidence of long range damage originating here.

84.Moneypoint was designed without the incorporation of flue-gas desulphurisation emission control (FGD) on the basis of tall stack dispersal, ash arrestors and electrostatic precipitation. The environmental design of Moneypoint was subjected to ecological and agricultural impact studies by An Foras Forbartha and An Foras Taluntais, respectively. However, no adequate analysis of the contribution of emissions from Moneypoint to long range air pollution was included in the AFF study as this study was commissioned solely for planning permission purposes.

85.In the course of the recent visit to Moneypoint members of the Joint Committee were impressed by the keen environmental awareness that exists in the ESB. The sophisticated technology used by the Board to monitor coal - sulphur levels, water, air and soil quality lends support to this view. The Board has established an excellent record going back over 30 years in the field of conservation. The Joint Committee points to the Board’s pumped storage scheme at Turlough Hill, County Wicklow as a model of the harmonious relationship that can be established between the environment and a major engineering development. The range of monitoring stations, particularly the Slieve Bloom station which is strategically located in the plume path of emissions from Moneypoint, set up by the Board to detect and record any environmental threat from Moneypoint emissions is to be commended.⁽¹⁾ The switch from oil to low-sulphur coal is also a positive contribution to reducing atmospheric pollution.

86.The Joint Committee has been assured that results of the Board’s very comprehensive environmental monitoring programme will be made available to the local authority (Clare County Council), and to the national air pollution data bank which is kept by An Foras Forbartha, with no restrictions as regard to availability.

The ESB has also informed the Joint Committee that it would accept as monitors any independent agency considered competent to operate the monitoring system and to analyse the results. The Board’s concern would be that the agency would have the competence and be given resources to carry out the task.

87.Notwithstanding, the Joint Committee, despite all the Board’s assiduous precautions, must express its unease at the volume of SO₂ ⁽¹⁾ that is likely to be discharged into the atmosphere at Moneypoint each year. Even if the Joint Committee were to concede that the Moneypoint Plant does not threaten the domestic environment it feels unable to accept that pollution from Moneypoint, albeit at a very reduced level is not a contributor to acid rain elsewhere on the basis of the principle that whatever goes up must come down somewhere. In the Joint Committee’s view any aggravation of the serious trans boundary acid rain problem would be unacceptable and could point to a low level of environmental awareness among Irish people.

88.While the Moneypoint Station is burning low-sulphur coal (1.65% sulphur content, hopefully reducing to 1%) there is no guarantee of supply as an international shift to this type of coal could cause shortages and price problems.

Unfortunately, the bulk of the natural gas allocation to the ESB will shortly be drawn down. However, the possibility of a further allocation is being kept under review by the Department of Energy.

89.The reluctance of the Board to install FGD emission control must, in the Joint Committee’s view, debilitate its sterling record on the environment. While the Board has made a very cogent case in support of its existing measures to prevent air pollution, the bona fides of which are not challenged, the Joint Committee must entertain the view that the Board’s reluctance to install FGD emission control is heavily influenced by the cost factor. When the Board’s trading mandate, coupled with the serious deficit it is running at present £64m to 31 March, 1985 - is taken into account the Joint Committee can entertain the Board’s apprehensions. The Board’s concern for its customers, particularly industrial users whose cost structures are critically influenced by the energy component, must also strike a sympathetic chord.

90.At this stage the Joint Committee would like to consider the cost factor.

Various estimates in relation to full compliance with the draft Directive on large combustion plants have been put forward. Examples include the following:-

91.The ESB has argued that there are special circumstances peculiar to Ireland which explain the vastly augmented cost of meeting the Directive relative to the average European cost. It cites the small size of generating units and proportionally large plant margins due to the size of the grid, lack of interconnection with the rest of Europe, and heavy reliance on fossil fuels, without the possibility of developing a nuclear programme.

92.It is HOPE’s contention that part of the large disparity in costing is due to the fact that the ESB has chosen to consider an unnecessarily costly strategy for reducing emissions.

93.Spread over a period of ten years, the electricity price increases resulting from applying emission controls could well be less than 1% per year. Between 1979 and 1984 the annual electricity price increases ranged from 5-19.5% with an average of 12.7% per year. On this basis the price increase that would result from FGD emission control would not be significant.

94.It is the view of the Department of Energy that the imposition of large costs on the ESB (and therefore on the electricity consumer) would not in fact contribute to the solution of the problem which the Directive attempts to address ie, the level of pollution within the EEC. The Department is therefore opposed to the Directive in its

95.The Joint Committee is satisfied that no agreed costing of the retrofitting of FGD emission control at Moneypoint has been carried out. The Government has directed that a study be carried out by the ESB of the possible costs involved in reducing future emissions from power plants to stabilise overall national sulphur emissions at the 1980 level. The Joint Committee would prefer, however, that an independent detailed review of costings, together with the implications for electricity costs in Ireland, be undertaken and a full report made publicly available at the earliest opportunity.

Technology has been developed in Germany to combat problems associated with acid rain in the Ruhr Valley and the Joint Committee understands that the cost of FGD emission control equipment is coming down.⁽¹⁾

96.While early estimates of possible increases in electricity charges are a cause for concern the social cost of damage to human health and the environment and other negative externalities must not be lost sight of. For this reason the Joint Committee feels that the ESB should not have to carry the total cost of FGD emission control and that the Exchequer should make a contribution to cushion the effect on consumers, particularly heavy industry.

97.An Taisce has suggested that Moneypoint should be fitted with flue gas desulphurisation equipment of 80% sulphur removal efficiency, at a cost of £80M and invoke the derogation provisions of the proposed Directive in respect of the ESB’s other generating stations. The effect of this, according to An Taisce, would be to reduce SO₂ emission attributable to ESB’s other generating stations. The effect of this, according to An Taisce, would be to reduce SO₂ emission attributable to ESB stations nationally by 50%.

98.The ESB have, however, pointed out that such expenditure would be tackling about 17% of national emissions in 1995, and only those emissions which do not contribute to environmental problems.

99.The facilities of the Shannon estuary, such as deep berth facilities, are ideal for the attraction of industry. This will add further to the problem of pollution and for this reason the Joint Committee feels that the operation of the Tarbert, County Kerry generating station will also have to be carefully examined in the short term.

100.The Shannon estuary also accommodates the Aughinish Alumina plant which exceeds the 50MW rated thermal output threshold laid down in the Directive. This concern, as a large energy consumer, has remonstrated at the existing level of electricity charges. The Joint Committee feels that the application of the Directive to this plant, without subsidisation, could jeopardise its viability. Instances such as this will cause the delicate balance between industrial development and environmental conservation to oscillate and test our commitment to the latter.

102.The area most threatened by air pollution is the Dublin region. In the course of its evidence to the Joint Committee the ESB made the point that a very significant proportion of SO₂ pollution is caused by low level emissions such as domestic fires and motor vehicles. The representative of AFF at the recent Irish Air Group Seminar suggested that it might be a more efficient allocation of resources if any proposed expenditure on Moneypoint were diverted to reducing pollution in Dublin city. The Joint Committee sees merit in these arguments about contends that if the challenge to the environment is to be fought off successfully a co-ordinated approach involving all levels of pollution will have to be undertaken. This list must include all ESB generating stations, industry, motor vehicles and domestic consumers. A programme of this magnitude would need to be co-ordinated at a central government level where resources could be allocated on an equitable and efficient basis to safeguard the environment. The Joint Committee would see, among other things, a scheme of grant-aids for the conversion of domestic heating systems to natural gas and the extension of natural gas supply to industry where possible. Alternatively, industry, particularly heavy industry, should be grant-aided to fit FGD emission control at adequate levels of sulphur removal efficiency. The new comprehensive Air Pollution Bill, at present being drafted will have a central role to play in combating pollution from industrial plants. This framework measure is welcomed by the Joint committee as we do not have any modern air pollution legislation in Ireland. A piecemeal approach to air pollution control could be self-defeating and an unwarranted diversion of scarce resources. On this ground the Joint Committee could not go along with the suggestion of An Taisce. (See para 98)

102.Following the two oil crises in the 1970s there was a significant switch to coal-fired domestic heating appliances, aided by a system of state subvention. This has seriously exacerbated the pollution problem especially in the Dublin area.

103.The number of monitoring stations has been significantly reduced from the 1980 level and this has given rise to a dearth of monitoring data for the west of the city where smoke concentrations are at their worst.

The discontinuance of air quality monitoring in the Dublin area by the ESB earlier this year is the main explanation for the reduction. However, Dublin Corporation who are responsible for the monitoring of air quality in the Dublin area in accordance with Directive 80/779/EEC have informed the Joint Committee that the number of monitoring stations in Dublin now stands at 12 and that this is the level of monitoring recommended by a leading consultancy firm who are also consultants to the EEC Commission in relation to air pollution control.

105.The Joint Committee has not attempted to undertake a scientific evaluation of all the technical evidence which has been presented to it. To do this it would need to engage expert consultancy to arbitrate in a field where many competent and well-meaning professionals are already at work. In the Joint Committee’s view by adding another technical tier to a debate which has already developed an emotional dimension, this could unduly complicate the issue of acid rain and confuse the lay person who will ultimately have to decide between a clean healthy environment and the financial disadvantages this could entail.

106.The Joint Committee hopes that its report will form the basis of a useful debate among elected representatives in the Dail and Seanad and thereby alert the public to the insidious threat to public health and the environment. Arising out of this debate it hopes that the positions of environmentalists and industrialists can be reconciled. The Joint Committee cautions of the danger of a victory for any of the lobbies in this controversy.

F. CONCLUSION

106.Ireland has one of the cleanest atmospheres in the Community and we should seek to defend this extremely fortunate situation. Because of our geographic location and the direction of the prevailing winds our atmosphere is well armed to withstand the normal challenge from pollution. We do, however, have high cloud cover over the Midlands, and West Wicklow where lakes have shown increased acidification. Also, during the early months of the year, we are subject to easterly winds which make us vulnerable to pollution from Europe and particularly from the UK where the Environment Committee of the House of Commons stated in a Report ⁽¹⁾ last year that the UK is the worst polluter of other countries in Western Europe and that 28% of the 5.1 million tons of sulphur dioxide belched from British smokestacks each year are windborne to other countries. At the same time the UK is resisting the adoption of the Commission’s proposal on large combustion plants. Our reluctance could lend implicit support to this attitude.

107.Failure by Ireland to implement the Directive on large combustion plants could leave this country open to infringement proceedings. Divergent national environment policies could create anomalies which would impede the common market for goods and services. The establishment of differing standards prevents the free movement of goods. Varying financial burdens on business distort competition.

108.The Joint Committee feels that Ireland has a duty to the citizens of the Community not to contribute to atmospheric pollution. Countries such as Denmark and Germany are making serious efforts to deal with acid rain. Our best protection against the threat of transboundary pollution from mainland Europe is to comply fully with all the Community measures on air pollution when implemented and to insist that all Member States, particularly the UK, do likewise.

109.The Joint Committee is very concerned that the case for anti-pollution measures is seen mainly in economic terms. Environmental policy has a fundamental importance, independent of the vagaries of the economic climate. It aims to safeguard the potential for future development by preventing the despoilation of natural resources. Sufficient attempts have not been made to heighten public awareness of the problem. Bodies such as the Irish Air Group, HOPE and An Taisce have stepped in to correct the imbalance. The Joint Committee welcomes the setting up earlier this year of the Environment Awareness Bureau (EAB) but warns that, unless it is adequately funded, it cannot be effective.

The Joint Committee feels that the State should rigorously take up the defence of the environment. If the consequences of air pollution can be put across to the general public in a convincing manner the economic cost will at least be tolerated.

Irish SO₂ emissions peaked in 1979 but have since shown a slight decline with a correlative drop in the acidity of rainfall. This is a welcome development which must be maintained through prudent management of the environment. 1987 is designated as the year of the Environment. This opportunity must not be lost to sharpen public awareness of this priceless natural asset that could be permanently sequestered through thoughtlessness or indifference. Modern technology has increased the amount of leisure time available and people are becoming increasingly aware of the advantage of a well conserved natural environment. We do not have a constitutional right to clean air. However, we can insist that legal measures be put in place to protect us from the ill-effects of industrial processes, such as SO₂ and NO_x emissions. We hold the environment in trust for future generations and we should endeavour not to bequeath it to them irreversibly damaged.

Gerard Collins T.D.

Chairman of the Joint Committee

18 December, 1985.

(1) Laid before the Dail and Seanad on March, 1984.

(1) Fourth Report published July, 1984. HMSO HC 446-11, HC 4461-X

(2) O.J. 229, 30 August, 1980, p.30

(1) O.J. L188, 16 July, 1984, p. 20.

(2) COM (85) 47 final.

(3) COM (83) 375 final.

(1) HOPE’s submission to Joint Committee and House of Commons Environment Committee Fourth Report published July, 1984 on Acid Rain HMSO HC 446-11, HC 4461-X

(1) United Nations Economic Commission for Europe

(1) This Part of the Report is generally based on the submission of AFF and FWS to Joint Committee

(1) Dail Debate, 4 December, 1985 Vol. 362 No. 6 Col. 1116

(1) COM (83) 375 final

(1) O J L229 of 30 July, 1984.

(2) COM (85) 368 final.

(1) OJ L188, 16 July, 1984, page 20.

(1) COM (83) 704 final - original proposals COM (85) 47 final - amendments agreed to by the Commission following debate in European Parliament, 15 November, 1984.

(1) See Appendices 2 and 3.

(1) “The Moneypoint plant at full operation will emit 65,000 tons of SO₂ per annum which will more than double the present ESB output and add more than one-third to Ireland’s total SO₂ emissions. Simultaneous operation of Moneypoint and of the oil-fired Tarbert station across the Shannon will emit approximately 80,000 tonnes of SO₂ per annum. Figures calculated by the ESB itself predict an increase in SO₂ emissions from the 1984-85 figures of 51 × 10³ t to 138 × 10³ t in 1988-89.” [Submission by An Taisce to Joint Committee - October, 1985].

*£338M at 1984 prices assuming a 3% growth £472 at 1984 prices assuming a 5% growth

(1) Irish Air Group Conference in Dublin - October, 1985.

(1) Fourth Report, published July, 1984. HMSO HC 446-11, HC 4461 - X.