National Emission Ceiling (NEC) Directive

An Open letter

To:  EU Ministers for a strong National Emission Ceiling (NEC) Directive

Dear Ministers,

Subject: Public Health recommendations for strong National Emission Ceiling (NEC) Directive

We, the undersigned 17 health organisations, representing thousands of health professionals and affected European citizens, are writing to you ahead of the 16th December meeting where you will discuss the revision of the National Emission Ceilings (NEC) Directive to urge you to support saving the lives of tens of thousands of Europeans lost each year.

We urge you to:

1. Keep methane and mercury among the pollutants covered by the targets, based on the strong scientific evidence of their contribution to air pollution and health impacts;

2. Include legally binding targets for all pollutants for Member States to be met by 2025, targets supported by the European Parliament, and give priority to early action to significantly decrease air pollution

3. Support greater emission reduction commitments (ERCs) going beyond the 52% reduction in health impact by 2030 as proposed by the European Commission. This is especially important for ammonia as cutting its emissions would reduce Particulate matter (PM) levels and exposure and therefore improve people’s health;

4. Reject unnecessary flexibilities which could in-fact dilute the ambitious content of the Directive, such as the adjustment of emission inventories, adjustment of emission factors and three-year averaging in case of dry summers or cold winters.

According to the World Health Organization (WHO), exposure to air pollutants, including fine particulate matter, is a leading risk factor for non-communicable diseases in adults, including ischemic heart disease, stroke, chronic obstructive pulmonary disease (COPD), asthma and cancer.

WHO evidence also underline that children’s healthy development is particularly under threat from air pollution.¹ It poses a considerable health threat not only to current but also future generations.² New studies are emerging which indicate the role of ambient air pollution in the development of other chronic conditions such as diabetes, liver disease, mental health, obesity³ and childhood leukaemia⁴.

Air pollution has a gender dimension too because of physiological differences between women and men leading to differing pollutant health effects. PM associated Cardiovascular Disease (CVD) risks are statistically significantly higher among women with diabetes⁵.

The public health context in terms of protecting EU citizens’ health and reducing the chronic disease burden and its associated costs to healthcare systems is a vital consideration in this debate. The European Environment Agency (EEA)
estimated in its recent report that long-term exposure to PM2.5 caused 403,000 premature deaths in the EU-28 in 2012.⁶

In addition, the health related economic costs are enormous, and amount to as much as €940 billion for the year 2010 alone.⁷ The Directive you are discussing will make an important contribution to reaching air quality as recommended by the WHO.

We urge you not to weaken it to protect interests or groups, but instead strengthen the Commission proposal.

For the contested points of the Directive on the agriculture sector, the NEC proposal could affect mainly large industrial farms, as the Directive offers flexibility to Member States to decide which farms they want to address and therefore small farms can be excluded. There are also transition mechanisms with funding support envisaged.

Nothing is of more importance as a European issue than the air we breathe. As air pollution does not recognise borders, the EU must – and has the power – to act to protect the health of its citizens, halt premature deaths and keep health
systems sustainable.

We hope we can count on your support and strong political leadership for this vitally important public health issue.

Yours Sincerely,

Comité Développement Durable Santé,

Council of Occupational Therapists,

European Academy of Allergy and ClinicalImmunology,

European COPD Coalition,

European Federation of Allergy and Airways Diseases Patients’ Association,

European Hematology Association,

European Heart Network,

European Institute of Women’s Health,

European Public Health Alliance,

European Respiratory Society,

France Nature Environnement,

Health and Environment Alliance,

Health Equalities Group,

Initiativ Liewensufank,

Malta Health Network,

No Pain Foundation,

Royal College of Physicians

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