The Situation

  • For more than two decades, both in the context of the UN-ECE LRTAP convention and the European Union, air policy has largely been developed using an ‘effects based’ approach
  • Examples of these are the Oslo Protocol, the Gothenburg Protocol, the CAFÉ programme and resulting Thematic Strategy on Air Pollution (TSAP) and, more recently, the EU revised TSAP and associated Air Policy Package.
  • In each case, the approach has been based on identifying the optimal level of burden on each country to enable the policy ambition to be achieved. In other words, the emissions reduction required in each country to achieve a set of environmental improvements at the lowest cost burden.
  • While instruments like the Gothenburg Protocol and the parallel EU Nation Emission Ceilings Directive (NECD) set individual country emission ceilings on a cost-effectiveness basis, the implementation of measures, at least in the case of industrial installations, is realised through ‘local permitting’ under the Industrial Emissions Directive ().
  • This poses the key question as to how the cost-effectiveness principles used to allocate the ceilings can be preserved and systematically applied in the local permitting process?
  • Unless vertical alignment from TSAP to NECD to local permitting is achieved, the principle of cost-effectiveness used in designing these overarching legislative instruments will not be realised in practise

Vertical Alignment - ‘Treaty > TSAP > Permit’

Vertical alignment is essential to ensure the realisation of proportionality and cost-effectiveness principles

i-PASS Diagram Legislation


The i-PASS concept is designed to align the local permitting process with the ‘proportionality principle’. It does this by ensuring that every national industry spends the same amount of money on a given unit of impact reduction. This cost varies between countries and industries and is akin to the "polluter pays" principle. This ensures no unfair burden on countries and industries where the emissions have little impact on the environmental targets compared to those that do - the principle of proportionality.

Technology Approach

In the technology driven approach each country pays the same Euros per tonne (€/t) of emission reduction. This is illustrated below where a common 5,000€ per tonne abatement cost for each EU Member State is used as a surrogate for a common EU-Wide BAT AEL.

Tech Approach - Common BAT AEL
Technology Approach €/t Abatement Costs

Effects Approach

The effects driven approach requires local determination of a countries position in the BAT AEL range. Given the different impact potential of each pollutant in each country the €/t spend on abatement costs varies widely. The equivalent national spend for a 5,000€ per tonne abatement cost is shown below.

Effects Approach - MS BAT AEL
Effects Approach €/t Abatement Costs

In the technology driven approach each country also pays the same Euros per unit of impact reduction. This is illustrated below using a common 20,000€ per tonne abatement cost for each year of life gained.

Tech Approach - YOLG
Technology Approach € per Year of Life Gained

The effects driven approach takes into account the potencies of the emissions of each pollutant in each country. Given the different impact potentials the € per Year of Life Gained cost varies widely. This again highlights how far from the principle of proportionality incorrect application of emission abatement measures can drive a country.

Effects Approach - YOLG
Effects Approach € per Year of Life Gained

The Burden on Industry

The above examples help to highlight how important vertical alignment of policy to permitting and adherance to the principle of proportionality are. Ultimately it will be industry who are asked to pay these costs and it is vital that each industry pays a fair and proportional share of the impact reduction expense.

This is where the i-PASS toolkit is used to determine, for a specific industrial installation the most cost-effective emissions limits required in any permit granted. The toolkit takes into account local and trans-boundary effects, emissions abatements systems all ready in place at the installation and the impacts of each pollutant on the environment and human health.

For a more technical discussion of the i-PASS concept please read the Aligning the Local Air Permitting Process with the TSAP and NECD white paper.

thumbnail of Aligning-the-Local-Air-Permitting-Process-with-the-TSAP-and-NECD
Aligning the Local Air Permitting Process with the TSAP and NECD