Public consultation on the EU Action Plan “Towards a Zero Pollution Ambition for air, water and soil”
Technology Industries of Finland’s comments on the EU Action Plan “Towards a Zero Pollution Ambition for air, water and soil”. Technology Industries of Finland supports the plan to further reduce pollution, which contributes to better protection of people and ecosystems. To achieve this goal, the review of environmental legislation should ensure that it results in a coherent, modern, science-based and efficiently implemented set of rules to support the industrial transition.
In accordance with the principles of better regulation, comprehensive impact assessments based on high-quality data must be carried out before any new legislative work is planned. The focus of the action plan should therefore be on streamlining and harmonizing legislation and eliminating overlapping requirements. In addition, in cooperation with all actors, attention should be paid to more effective and harmonized implementation.
All the planned requirements should be based on financial and technological feasibility principle. It is not reasonable to literally target to zero pollution – the costs of lowering emission levels will eventually be strongly disproportionate compared to the benefits. The future action plan should therefore balance the ambition with both technical feasibility and economic viability of the envisaged measures by setting an appropriate framework to remain sustainable not only environmentally but also socially and economically. The choice of suitable technology should also be given to the industry and not determined by legislation.
Moreover, a risk-based approach should be introduced to evaluate the environmental and health effects of materials, especially when it comes to e.g. metallic alloys. The environmental and health effects should be properly and sufficiently managed towards tolerable risk levels, and not towards ‘zero’ level. Any proposed action in terms of risk minimisation should be based on what is reasonably practicable.
It is important to address the pollution that has the heaviest impacts on humans and ecosystems. The action plan should also ensure that targeted actions do not tackle those who already significantly contributed to lower emission levels. For example, no additional regulation of combustion plants is needed. It should also be noted that electrification of the industry contributes to the reduction of air pollutant emissions as well as the reduction of other pollutants on industrial sites.
Ms. Tiina Fiskaali, Advisor