Comments on the EU Commission Zero Pollution Action Plan

The Stockholm University Baltic Sea Centre welcomes the EU Commission Zero Pollution Action Plan, ZPAP, which was launched today. We support the aim of the plan to increase efforts to combat negative effects on the environmental and human health from pollution of air, water and soil. We agree with the statement that the economic case for acting on pollution is clear and the benefits for society far outweigh the costs, just as the costs of inaction hugely outweigh the costs of action.

Text: Gun Rudquist, Head of policy, and Marie Löf, Researcher

Regarding soils and eutrophication

Seas and coastal areas are negatively affected by excess nutrients, resulting in e.g. increased algal blooms, regime shifts and lower fish productivity. It also has negative social and health impacts. Eutrophication is a priority area in marine environmental work but more can be done to mitigate these negative effects. We would like to underline the importance of minimizing diffuse pollution of nutrients such as nitrogen and phosphorus from all sources and their transport to fresh-and marine waters. 

In ZPAP the objectives and actions suggested in the Farm to Fork strategy are included. The BSC support these, but in order to promote soil and water health the following should be included.

It is the necessary to improve the eco-efficiency of the plant nutrient cycles, as concluded in the UNEP report Our Nutrient World. Agriculture is the single largest source of new nutrients to the Baltic Sea (see here). Most of mineral fertiliser and livestock feed which is imported to the catchment area is transformed into manure; however, the nutrients in manure are often not used efficiently in crop production, increasing the risk of losses to the waters. These nutrient losses can be reduced by improving manure management and substituting imported mineral fertilisers with manure, as well as by reducing the import of livestock feed and the number of animals in regions with high livestock. More information on farm structure can be found here

Whether or not reduced consumption of animal products leads to less eutrophication of waters depends on which animal products, how and where they are produced and the alternative production/action at farm level. For a full fact sheet read here.

Good soil structure is crucial for minimising surface run off of phosphorus. 

Legacy of phosphorus in the soils is a major source for external input to water. For instance, in the Baltic Sea region, research shows that almost half of the phosphorus currently entering the Baltic Sea could derive from a pool of accumulated phosphorus on land (McCrackin et al. 2018). The role of legacy P and the properties, fate and management of soil nutrient inventories have to be considered in a future soil strategy. 

Reduction of nutrient sources from soils can have clear advantages for water quality, but there are trade-offs to be considered. For example, nitrogen additions have the potential to reduce carbon dioxide emissions and increase carbon storage (Janssens et al., 2010). Therefore, the cycling of carbon and nutrients should be monitored and considered together for effective soil management.

Soil carbon stabilization (and associated nutrient retention) can be promoted by improving soil structure (e.g., no tillage) and increasing the diversity of residue inputs to soil (e.g., crop rotations, diversified agriculture, cover crops) (Lehmann et al., 2020).

Regarding chemicals pollution and the need for better regulation

We welcome that the EU policy on the environment shall be based on the precautionary principle and on the principles that preventive action should be taken, that environmental damage should as a priority be rectified at source and on the polluter pays principle.

In the ZPAP, there are six specific zero pollution targets for 2030, where EU should reduce:

  1. by more than 55% the health impacts (premature deaths) of air pollution;
  2. by 30% the share of people chronically disturbed by transport noise; 
  3. by 25% the EU ecosystems where air pollution threatens biodiversity;
  4. by 50% nutrient losses, the use and risk of chemical pesticides, the use of the more hazardous ones, and the sale of antimicrobials for farmed animals and in aquaculture;
  5. by 50% plastic litter at sea and by 30% microplastics released into the environment;
  6. significantly total waste generation and by 50% residual municipal waste. 

Even though measures against other substances will be addressed in the chemicals strategy for sustainability, such as phasing out the most harmful chemicals, like endocrine disruptors and persistent substances, a clearly defined pollution target in the ZPAP for harmful chemicals would have improved efforts in this area and the chances of achieving a non-toxic environment.

The ZPAP states that implementing the zero pollution ambition in production and consumption means that chemicals, materials and products have to be as safe and sustainable as possible by design and during their life cycle, leading to non-toxic material cycles. This is true, but in this context we want to stress the need for transparency. Full transparency on chemicals should be the general rule for the whole chain of events from generation of information, via reporting of data, to hazard and risk assessments. The current developments in the food law is very welcome and should be expanded to all chemicals. In a system where manufacturers are responsible for assessing their own products sufficient resources to control the quality of this work must be secured. The overall aim must be full legal compliance.

The Commission states in the ZPAP that ’pollution does not stop at borders’, and that the EU will scale up international partnerships and action in and with third countries. Here it is also key that companies in Member States do not produce and export hazardous, and potentially banned, chemicals to countries outside the union.

IN ZPAP, the forthcoming review of the Urban Waste Water Treatment Directive, UWWTD, is mentioned as tool for improving human health and well-being. We agree with the Commission that this is important, the UWWTD needs to be part of the solution to fulfil and reach the targets under both the WFD and the MSFD. UWWTPs can be important entry routes for some priority substances and river basin specific pollutants. These links need to be better addressed in a revised UWWTD by introducing requirements on wastewater quality with respect to micropollutants in addition to nutrients and organic matter. This is important not only to protect human health and well-being, but also for biodiversity, thus parameters relevant for the protection of the environment should also be included. In the UWWTD, criteria should be developed for minimum chemical wastewater quality that address micropollutants and their mixtures. A clear connection should be established between UWWTD and the Water Framework Directive and the Marine Strategy Framework Directive (WFD and MSFD) ensuring that the UWWTD functions as a means of also achieving good chemical/ecological/environmental status of surface waters with regard to CECs and other micropollutants. The connection should allow for flexibility in the definition of good status as science and policy progress.

When reviewing the Marine Strategy Framework Directive by 2023, we would like to stress the following points:

  1. Regarding chemical pollution, the MSFD and its POMs would benefit from including more of a source to sea perspective, and a closer connection to the WFD. It is understandable to avoid duplication of measures under various legislation and action programmes under the WFD. The risk with this reasoning, however, is that measures in the water authorities' action programmes have only an inland and coastal perspective, and not also a marine perspective. Since most of the chemical pollutants present in the sea come from activities on land or coast, this means that action on land is most important and that no measures may be needed at all in the marine environment action programme. It is also the case that even for those substances that have sea-based sources, land-based inputs are often dominant. This means that sea-based sources receive unjustifiably high focus as the action programme has to be filled with some measures, i.e. it leads to inefficient actions being prioritised.
  2. The indicators for hazardous substances do not cover all problems related to chemical pollution in the sea, i.e. substances covered by the indicators do not represent the wider chemical pollution in the sea and the possible combination effects. Therefore, there is a need to further build up knowledge and develop indicators. Action programmes could for example include knowledge-building measures such as various types of screening activities to identify new environmental toxins, with a specific focus on high-risk chemicals, substances of very high concern, SVHCs (e.g. very persistent and very bioaccumulative chemicals, vPvB; chemcals that are carcinogenic, mutagenic or toxic for reproduction, CMR; endocrine-disrupting chemicals, EDCs)
  3. In the context of the Zero Pollution Action Plan and MSFD, monitoring should be better designed to enable evaluation of effectiveness of specific measures and temporal trends in emissions of hazardous substances and environmental levels. Currently compiled data under e.g. MSFD, WFD, IED/E-PRTR etc are not appropriate for this evaluation due to differences in monitoring and reporting approaches between nations and also over time. 

Further, it is important to include underwater noise and its effects on marine mammals, birds, fish and other aquatic organisms that are affected by noise from shipping, boat traffic, military, dredging etc.