Sixth Environmental Action Programme
The Royal Society of Edinburgh (RSE) is pleased to respond to the Scottish Executive Environment Group consultation on the Sixth Environmental Action Programme. The RSE is Scotland’s premier Learned Society, comprising Fellows elected on the basis of their distinction, from the full range of academic disciplines, and from industry, commerce and the professions. This response has been compiledby the General Secretary with the assistance of a number of Fellows with substantial experience of environmental issues.
The RSE broadly welcomes the Sixth Environmental Action Programme. The proposals address important issues which require urgent attention on both national and international fronts. The new Programme also takes a new direction by relating environmental problems and their solutions widely to all aspects of Community strategy and by seeking to achieve integration of environment policy with stakeholders, to bring about sustainable development and a better balance of economic, social and environmental objectives.
The cause of environmental enforcement and protection of landscape and biodiversity in the UK as elsewhere in Europe has already been advanced by the work of the Commission and this new Programme should carry this process further if it is effectively implemented. Therefore, it is to be hoped that the UK's negotiating strategy will be generally supportive, seeking mainly to identify the best ways in which the UK can promote the objectives set out.
Key issues in the Programme include the affirmation of climate change as a major theme, and the development of thematic strategies on soil protection and the protection of the marine environment.
The different Articles of the European Commission's Decision are addressed below:
Article 1: Establishment of the Programme
The Society welcomes the 10-year time span of this action programme. For environmental issues, it is important to take both a long-term and a strategic view. The time scale for the programme, however, is a particularly tight one. The final form of the Decision is still negotiable and the development of new measures, let alone their implementation, is some time off. Consequently, a mid term review in 2004 seems too early and should be delayed for at least a year if any meaningful effects of new actions are to be seen. Given the importance of climate change, there would also be merit in a longer-term view encapsulated in the document, perhaps looking at 25, 50 or 100 years hence, as these are often the time scales over which modelling for climate change is based.
Article 2: Overall aim and objectives
The Society believes that the overall aims and objectives of the programme are sensible. It should be noted, however, that it is not clear how far the Community will drive these initiatives and how far national governments will be expected to formulate their own action plans within the framework defined by the Programme. What is clear is that work required to meet the priority areas will vary across the Community, especially given the intended enlargement to include countries with differing problems and attitudes to the environment.
Some of the aims of the Programme in Article 2 are rather vague, for example, 'Achieving better understanding of the threats to human health'. Reference to pesticides is also ambiguous in that paragraph 5 aims to achieve an overall reduction in the use of pesticides while in Article 6, mention is made of their sustainable use.
Article 3: Strategic approaches to meeting environmental objectives
The Programme makes appropriate provision for the achievement of the objectives. However, Member States often lag behind in implementing decisions made at European level.
The 'greening' of land-use planning and activities affecting landscapes and habitats is a key issue, and action by the Programme in the area of planning and the environment will be valuable. This will also be relevant in connection with nature and biodiversity, because of the growing evidence for severely damaging consequences of some changes in the use of land and natural resources in Europe.
Article 4: Priority areas for action on tackling climate change
This Priority Area needs some changes in light of the recent position of the United States. However, the EU should continue to promote ratification of the Kyoto Protocol and take the lead with implementation. The target of an 8% reduction in greenhouse emissions by 2008-12 may be achievable although it is noted that the target only applies to current member states as opposed to a future enlarged community.
With regard to the proposed shift towards low carbon fuels for power generation, it should be recognised that there will be a continuing requirement for fossil fuels for some time to come. There should also be reference to the potential role of nuclear power as a low carbon fuel, which some see as the best hope of meeting the energy and greenhouse gas emission targets. In these contexts, reference to research and development in these areas and on further enhancements of combined heat and power technology, and on sequestration of CO2 below ground, will be particularly important and could enable companies and organisations in the Community to exploit world markets for such technology.
The adoption of emissions trading is controversial as it allows rich countries to continue to pollute the world.
Article 5: Priority areas for action on nature and bio-diversity
The mention of landscape values is welcome since these have often been neglected in the past. The proposal for landscape 'restoration', however, is unattainable even though the intention is good. Natural systems are far too complicated to be ‘restorable’ and the best that can be done is to ameliorate damage and, by responsible actions, assist the attainment of a new (near) steady state. The development of policies to deal with landscape protection, or enhancement, needs to be based on some assessment of landscape quality. However, this is a complex matter and studies to explore more integrated approaches to this matter need to be undertaken.
The Society particularly welcomes the focus on soil protection (or perhaps 'soil sustainability' would be more appropriate). Soil is a vital resource to agriculture and is susceptible to degradation through erosion, with resulting implications for soil biodiversity, archaeological features (e.g. crop marks of archaeological features which are present in the subsoil) and increased sediment and nutrient yield (especially phosphates) to streams. At the present, there are varying attempts in EU countries to develop soil protection strategies and there needs to be better co-ordination to ensure comparability of results. Thus an important objective of a thematic strategy on soil should be the development of frameworks or templates for soil protection strategies.
The focus on soils should also be reflected in the priority area for action on environment and health (Article 6). While Article 6 contains recommendations for achieving levels of water and air quality that do not give rise to significant impacts on either human health or the environment, similar goals could also be sought for soil quality, in terms of the environment and foodstuffs grown in the soil.
The continued recognition of the importance of biodiversity is welcome as the state of biodiversity, and pressures and trends on it, are important topics in many member states. Statistical and other methods for collecting and integrating data sets need to be addressed at the Community level to ensure that regional-scale analyses can be developed that cross national boundaries.
One important priority action, however, is the problem caused by non-native species, often referred to as 'alien species'. The spread of the rhododendron in the west of Scotland has had a major environmental and economic impact and there are potentially serious problems with the introduction of alien species in ballast water being discharged in coastal waters of Scotland. The International Union for the Conservation of Nature (IUCN) has recognised that the problems of invasive, non-native species, constitute after habitat fragmentation the greatest global cause for the loss of biodiversity. Action on this issue should, therefore, be included within the Programme.
Common Agricultural and Fisheries Policies
Promoting a greater integration of environmental considerations into the Common Agricultural Policy and the Common Fisheries Policy is an essential part of environmental and biodiversity protection. In this context, the gene pool of cultivated vegetables should be considered. The current EU Seeds Directive risks reducing the number of vegetable and fruit cultivars remaining in cultivation in as much as registration of a cultivar under the Directive is costly and there is little incentive to register rarer, less commercial, cultivars.
The document seems relatively weak in relation to the marine environment of the European Union. This contrasts with the detail on strategy for protecting forests (item 6). Early on, the Programme should make the point that where water is referred to, the reference is to both fresh water and seawater. The marine environment is particularly important for Scotland, since if Scotland is defined as lying within the 12-mile limit, about 42% is covered by the sea, 41% is upland in character, and 17% is lowland in character. The extension of Natura 2000 to the marine environment, and the implementation of Integrated Coastal Zone Management, will therefore both be of importance in the Scottish context.
Article 6: Priority areas for action on environment and health
The impact of the proposed EU Chemicals strategy will benefit the general public and the environment. Researchers draw heavily upon the data provided by their chemical suppliers, typically in the form of chemical safety data sheets, in order to perform risk assessments on all experimental procedures carried out within their laboratories. More readily available information on the intrinsic hazards and exposure risks associated with the substances involved in their work allows for a more thorough assessment of the short and long term risks. This, in turn, facilitates the making of an informed decision on the containment measures and working practices required to control them.
Important research areas concerning air pollution and health include the development of a better understanding of pathways for pesticides and other man-made chemicals from the atmosphere to human populations; and understanding the interactions between aerosols and pollutant gases in affecting health (for example how do chemicals attached to aerosols and photochemical ozone interact when inhaled?). It has been suggested that such interactions may be involved in the large increases in such diseases as asthma being reported. Mention could also be made of the need to generate more effective selective pesticides with low mammalian and general toxicity and the role of Genetically Modified Organisms in offering the potential of reduced pesticide application could also be relevant here.
In addition, although mentioned in the Communication, there is no reference in Article 6 of the Decision for ‘reducing the number of people regularly affected by long-term and significant levels of noise’. Consideration should also be given to noise, and light, pollution in terms of their affect on wildlife. Marine mammals, for example, seem to be adversely affected by noise in the marine environment.
Article 7: Priority areas for action on the sustainable use of natural resources and management of wastes
The sustainable use of natural resources and the management of wastes are areas where positive action is critical.
Article 9: Environment policy making based on participation and sound knowledge
This is a topic where the Programme should make sure that the rapid changes in information technology capability are incorporated. For example, public information about environmental issues and hazardous substances is increasingly sought on the Web, but there is often no guarantee of the quality of information. The Community should ensure (through a central site with links to national sites), that the public can gain access to the most reliable up-to-date information effectively. Mechanisms for the transfer of knowledge from the researchers to the policy makers could also be improved.
Financial support for Non-Government Organisations (NGOs) to participate in the dialogue process is another important area. NGOs can be major drivers of public opinion on environmental issues and recognition, and support, of this is essential if the action programme is to achieve its full potential.
In responding to this inquiry the Society would like to draw attention to the following Royal Society of Edinburgh responses which are of relevance to this subject:
People and Nature: A new Approach to SSSI Designations in Scotland (November 1998); National Scenic Areas Review (April 1999);
Study of Environmental Planning (October 1999);
Royal Commission Study of Environmental Planning (July 2000);
A Proposal for a Loch Lomond & the Trossachs National Park (February 2001);
Energy and the Environment (December 1998);
New and Renewable Energy (May 1999);
Energy and Natural Environment: A Way To Go (September 2000);
Fuelling the Future (March 2001);
EU policy on Biodiversity (May 1999);
Protecting and Promoting Scotland's Freshwater Fish and Fisheries (August 2000)
The Assessment of Risk to Biodiversity from GM Crop Management (December 2000);
Management of Waste
Scotland’s National Waste Strategy (July 1999);
Environment and health
The OECD Edinburgh Conference on the Scientific and Health Aspects of Genetically Modified Foods (February 2000);
Long-Term Effects of Chemicals in the Environment (January 2001);
Adventitious Presence of Genetically Modified (GM) Seeds in Seed of Conventional Varieties (April 2001);
The European Commission's Chemicals White Paper (May 2001).