25. 4. 85 Official Journal of the European Communities NoC 104/7 
'The reasoned application must be submitted by the 
employer, together with the opinion of the workers' 
representatives after they have been informed and 
consulted, to the responsible authority. . .' (rest 
unchanged). 
The Committee further proposes that a new paragraph 
Article 4 (5) be added, as follows: 
'The enterprises or sectors concerned would of course 
continue to operate during the procedure for assessment 
of the exemption application by the authorities, when the 
1. On 27 October 1983 the ESC, acting under its urgency 
procedure, welcomed the Commission's proposal to set up a 
network of posts to monitor forest health (opinion on the 
proposal to provide forests in the Community with increased 
protection against fire and acid rain. 
2. Following a study group visit to Stuttgart, 
Freudenstadt and Marseilles in March 1984, the Committee 
issued an additional opinion on 4 July 1984 on the protection 
of forests against fire and acid rain. This opinion firmly 
supported the Commission's proposals, while making a few 
additional suggestions. National efforts to combat forest 
fires should be backed by the Community. The same applies 
to national efforts to combat acid rain. 
3. Air pollution is causing more and more damage to 
forests. In some regions of the northern hemisphere visible 
(») OJNoC248,17. 9. 1984,p. 1 andOJNoC358,31. 12. 1983, 
p. 50. application is for exemption from a process which was 
operational before the date of the proscription.' 
2.6. Article 5 
It should be noted that workers' access to the documents 
which are the subject of notification must form part of the 
consultation and opinion procedure referred to in point 2.5 
above. 
2.7. The substance benzidine and its salts should be 
included in the Annex to the Directive. 
forest damage has been on the increase since the beginning of 
the 1980s. According to research in Germany growth was 
affected for many years prior to this. The first to suffer were 
the coniferous forests; now it is the turn of the deciduous 
forests. 
4. Forest dieback is an indication that the ecosystem is 
being overloaded. Trees are dying at an alarming rate despite 
highly developed forest management in central Europe and 
regulations and forestry measures in most Member States to 
curb harmful practices and prevent overcropping. Methods 
for investigating the damage are still in their infancy. They 
have developed along different lines. The Federal Republic of 
Germany has been monitoring the damage the longest. Other 
EEC countries are only just beginning to develop a 
monitoring system. The Committee therefore regrets that the 
proposed Regulation of 14 June 1983 has not yet been 
adopted. Done at Brussels, 27 February 1985. 
The Chairman 
of the Economic and Social Committee 
Gerd MUHR 
Second additional opinion on the proposal for a Council Regulation establishing a Community 
scheme to provide forests in the Community with increased protection against fire and acid 
rain (*) 
(85/C 104/06) 
On 4 July 1984 the Economic and Social Committee decided, in accordance with Article 20 (3) of its 
Rules of Procedure, to draw up a second additional opinion on the proposal for a Council Regulation 
establishing a Community scheme to provide forests in the Community with increased protection 
against fire and acid rain. 
The Section for Protection of the Environment, Public Health and Consumer Affairs, which was 
responsible for preparing the Committee's work on the subject, adopted its opinion on 4 February 
1985 in the light of the report by Mr Schnieders. 
At its 224th plenary session (meeting of 27 February 1985) the Economic and Social Committee 
adopted the following opinion by 71 votes to 10 with seven abstentions: 
No C 104/8 Official Journal of the European Communities 25. 4. 85 
In this connection the Committee would refer to its opinions 
of 27 October 1983 and 4 July 1984. It stresses the urgent 
need for a rapid improvement in monitoring methods and the 
application of the same monitoring methods in all Member 
States. 
5. There are a number of indications, however, that 
atmospheric pollution is detrimental to the health of forests. 
The pollutants (CH; S02; CO; C02; NOx; photo-oxidants) 
are the result of combustion processes, many of which have 
not been yet been analyzed. In addition, sufficient research 
has still not carried out into the conversion and dispersion of 
substances in the atmosphere. The 'tall stacks policy' means 
that they are transported long distances into clean air 
regions. Annual NOx emissions are estimated at 12,2 million 
tonnes for the European OECD countries, annual S02 
emissions at 58 million tonnes for Europe, including the 
European part of the Soviet Union. 
6. It is still not possible to explain the links between cause 
and effect, nor to identify the toxic atmospheric pollutant(s) 
responsible for forests dying; neither is it possible to establish 
the exact role of other factors such as monoculture and 
altitude. The present state of knowledge does not allow 
scientific proof of these causal links for the following 
reasons: 
(a) the forest is a complex ecosystem and a large number of 
factors (soil, water, vegetation, soil quality and 
weather) can affect the progress of the damage; 
(b) the damage appears primarily in older trees, though 
increasingly in younger trees too; 
Federal Ministry for Agriculture: 1984 survey of forest damage 
Species of tree 
Spruce 
Pine 
Fir 
Beech 
Oak 
Other species 
Total Degree 0 
no signs 
of damage 
1983 1984 Degree 1 
slightly 
damaged 
1983 1984 Degree 2 
' moderate 
damage 
1983 1984 Degrees 3 
and 4 
very sick 
and dead 
1983 1984 Total 
degrees 
1+2+3+4 
1983 1984 
as % of area covered by species 
59 
56 
25 
74 
85 
83 
66 49 
41 
13 
50 
57 
69 
50 30 
32 
27 
22 
13 
9 
25 31 
38 
29 
39 
35 
24 
33 10 
10 
41 
4 
2 
8 
9 19 
20 
45 
11 
9 
7 
16 1,1 
1,4 
7,8 
0,4 
0,2 
0,4 
1,0 1,6 
1,3 
12,8 
0,8 
0,4 
1,0 
1,5 41 
44 
75 
26 
15 
17 
34 51 
59 
87 
50 
43 
31 
50 
Survey: Forest damage 1983 and 1984 by species and degree of damage. 
In the Federal Republic the annual damage is put at DM 1 400 million. (c) frequently atmospheric pollutants do not act directly as 
S02, NOx, etc. or at the source of emission, but are 
converted into other substances by insolation and other 
meteorological factors. 
However, it has not been possible in all cases to establish a 
link between the intensity of air pollution and the occurrence 
of damage to trees. The Committee therefore supports all the 
research work proposed by the Commission, and calls for a 
special scientific investigation into trees which are most 
exposed to air pollution, particularly from exhaust gases, 
such as trees in an urban environment or in high pollution 
areas. 
7. At the end of the 1984 Munich conference of 
environment ministers all the participating countries 
recognized air pollution as the crucial cause of damage 
although the chain of cause and effect is not yet fully 
understood; nor is it possible to determine which type of 
pollution is harmful (e.g. S02, lead, NOx, or others). 
8. Despite inadequate and as yet varying procedures for 
recording the damage, it would appear that in 1982 between 
3 and 8 % of the total forest area of the Member States was 
already affected. In Eastern Europe damage ranged from 
7 % (Poland) to 12 % (GDR). 
In 1983 the survey and assessment method was improved and 
standardized in the Federal Republic of Germany. The 
results obtained by this method show that damage is 
considerably more widespread than hitherto assumed and is 
increasing rapidly as regards both species of tree and degree 
of damage (table). The total proportion of trees affected rose 
from 34 % in 1983 to 50 % in 1984. 
25. 4. 85 Official Journal of the European Communities No C 104/9 
9. In view of these developments the Committee strongly 
urges that all practicable measures be taken as soon as 
possible to combat air pollution. There is no time to waste. 
Waiting for research findings on the precise chain of cause 
and effect only prevents effective measures from being taken. 
Delays run the risk of irreversible damage occurring to the 
forest ecosystem. In the Committee's view it is essential that 
an EEC programme be drawn up as soon as possible for a 
gradual reduction in the major atmospheric pollutants, with 
priority being given to those pollution factors which are 
supposed to be the most harmful. 
10. There is also a danger that air pollution will affect the 
whole of living nature. For some years already an 
acidification of lakes has been observed in the Scandinavian 
countries. Harmful effects on the soil have recently been 
demonstrated. A deterioration in drinking water and damage 
to buildings on a catastrophic scale in some areas should be 
noted in addition to the risks and damage to human 
health. 
Research must be stepped up in the following areas: 
(a) atmospheric chemistry; 
(b) combustion processes and the products released; 
(c) their effects on ecosystems. 
Furthermore, all research projects in the EEC must be 
coordinated. The proposed Directive (COM(83) 375 final) 
provides for the monitoring of forest health and the 
development of preventive measures. While this action is to 
be welcomed, it can do no more than provide an assessment 
of damage which has already occurred. 
11. When weighing all the costs of keeping the 
atmosphere clean against the potential damage, it should be 
borne in mind that every delay could multiply the damage 
over the coming years. 
(a) Every means of combating air pollution should 
automatically be used and given every support. 
(b) The forestry measures frequently proposed are at best 
able to effect some improvement in small, confined 
areas, but are not suitable as a universal remedy for 
forest damage. An improvement will only be brought 
about by a substantial reduction in air pollution. 
(c) The introduction of emission controls will increase 
industry's costs. The EEC must therefore ensure that 
avoidable distortions of competition do not occur. This 
should not debar individual Member States from 
applying stricter measures. 
(d) Atmospheric currents carry pollutants over frontiers. 
Therefore the Community must try to persuade its 
neighbours to combat air pollution in their countries too as a matter of the highest priority. If necessary the 
Commission must use trade policy as a lever to prompt 
firm action in these countries. 
12. The Committee once again stresses that it would be 
irresponsible of the Member States to delay resolute joint 
action. The Directives already adopted should be reviewed to 
see whether their limits can be reduced and their deadlines 
brought forward. This applies to the following Community 
legislation: 
— Council Decision 81/462/EEC of 11 June 1981 on the 
conclusion of an agreement on long-range transboundary 
air pollution (Official Journal of 27 June 1981), 
— Council Directive 80/779/EEC of 15 August 1980 on air 
quality limit values and guide values for suplhur dioxide 
and suspended particulates (Official Journal of 30 August 
1980), 
— Directive 75/716/EEC laying down the maximum 
sulphur content of light fuel oil and diesel oil. These are 
much too high and not in line with current technology. 
A reduction to 0,15 % by weight is required. 
13. The Committee has issued opinions on the following 
Directives proposed by the Commission: 
(a) proposal for a Council Directive on the combating of air 
pollution from industrial plants (*); 
(b) proposal for a Council Directive on the limitation of 
emissions of pollutants into the air from large 
combustion plants (2); 
(c) proposal for Directives on the lead and benzene content 
of petrol and on measures to prevent air pollution from 
motor vehicle emissions (3). 
The Committee would refer to its opinions on these subjects 
(23 November 1983, 21 November 1984 and 
22 November 1984 (4) and calls on the Council of Ministers 
to adopt these Directives as quickly as possible, taking into 
consideration the ESC's views. The Committee would point 
to the success of the measures already taken by some 
countries to combat air pollution. 
14. The Committee proposes that the Commission 
should study the effects of the following measures and should 
quickly take the most appropriate measures, taking into 
account all the interests at stake: 
(») OJNoC 139, 27. 5. 1983, p. 5. 
(2) OJ No C 49, 21. 2. 1984, p. 1. 
(3) OJ No C 178, 6. 7. 1984, p. 5. 
(«) OJ No C 23, 30. 1. 1984, p. 25 and OJ No C 25, 28. 1. 1985, 
pp. 33 and 46. 
No C 104/10 Official Journal of the European Communities 25. 4. 85 
— incentives (e.g. tax treatment fiscal) to encourage the use 
of less powerful, lighter cars which consume less fuel and 
so produce less exhaust gases, 
— incentives (e. g. tax treatment; to encourage the 
immediate use of motor fuels that contain no lead already 
exist on the market (LPG and diesel fuel) and do not 
require engine modifications, 
— reduction in motor vehicle fuel consumption via 
measures to ensure a smoother flow of traffic 
(synchronization of traffic lights, public works), 
— reduction in fuel consumption by reducing the speed of 
vehicles and an investigation into whether motor vehicles 
should be treated any differently from any other modes of 
transport, 
— reduction of air pollution from aircraft, ships, 
construction plant, etc., 
— reduction in the consumption of motor vehicle fuel, by 
vigorously promoting public transport, 
— strict control over the incineration of household 
refuse, 
— promotion of the use of the least polluting domestic 
heating fuels, 
— as strict as possible a limitation of waste emitted into the 
atmosphere from factories and power stations, 
— revitalization of the energy conservation policy, 
including the consumption of electricity (high and low 
voltage), insulation, use of waste heat, etc., 
— support for non-polluting, alternative energy projects, 
— more pedestrian zones in heavily congested town 
centres. 
15. Even if all measures to prevent air pollution are 
introduced immediately, the damage cannot be expected to 
diminish in the near future. The effects of air pollution will 
continue to be felt for some time. Hence, the quantities of 
wood felled must be expected increasingly to exceed normal. 
For this transitional period (estimated at 10 to 15 years), 
measures are necessary: 
(a) Timber marketing 
— forecasts and constant monitoring of quantities 
felled, 
— foreign trade measures, in particular to curb 
dumping and low-price imports, — measures to prevent a falling-off in the qualify of 
wood, in particular preservation or other treatment 
of wood felled on account of forest damage. 
(b) Revenue problems 
For some years already forest damage has resulted in 
heavy losses, estimated at up to 40 % and more in 
extreme cases, for land and forest owners in some 
regions. The loss is total in regions where the forest is 
dying. This is threatening the livelihood of many small 
and medium-sized forest owners who derive their 
income primarily from forestry. The Committee calls 
upon the Commission to investigate the loss in income 
for the owners of forests and wage-earners caused 
by: 
— forest fires, 
— diseases in trees, 
— acid rain, 
— storms. 
On the basis of this investigation the Commission could 
subsequently put forward appropriate proposals for 
compensation in the case of exceptional losses. 
16. In regions where forest damage is destroying a forest 
economy, the Community should concern itself with the 
potential impact on employment in forestry and the timber 
processing industry. 
17. In conclusion the Committee would point out that: 
(a) forest damage can only be combatted by a package of 
many measures which must be taken in the foreseeable 
future; 
(b) measures to control air pollution must as far as possible 
be introduced throughout the Community. 
Negotiations must also be held with non-member 
countries to ensure that appropriate controls are 
introduced there too; 
(c) if forest damage is not combatted effectively, a 
deterioration in our living conditions is inevitable. The 
forest stores and filters water; it prevents erosion and 
acts as a sight and noise screen; it balances climatic 
extremes. The forest acts as a 'green lung', producing 
oxygen and filtering the air. It is a feature of the 
landscape and provides a home for numerous plants and 
animals. 
Member States should ensure that adequate funds are 
allocated to the reduction of forest damage and the 
long-term conservation of the natural resources of the 
European Community. 
Done at Brussels, 27 February 1985. 
The Chairman 
of the Economic and Social Committee 
Gerd MUHR 
25. 4. 85 Official Journal of the European Communities NoC 104/11 
APPENDIX 
to the opinion of the Economic and Social Committee 
A. Rejected amendment 
The following amendments, tabled in accordance with the Rules of Procedure, were rejected by the Committee 
during plenary session discussions: 
Point 5 should read: 
'All the available information points to air pollution as one of the primary causes of forest dieback' 
Reason 
Even if air pollution has a certain effect, especially in the Federal Republic, it seems that there are other primary 
causes, such as climate, of forest dieback. Further investigations must be undertaken before too large funds are 
spent on filtering smoke. 
This view is supported by the following statement by Mr M. W. Holdgate, UK Department of Environment, at a 
meeting of the Royal Society (London): 
'Our aim has been to evaluate scientific understanding of the ecological effects of deposited sulphur and nitrogen 
compounds, not to propose governmental or industrial policies. But the continuing evolution of such policies needs 
to be based on the most critical possible evaluation of the scientific facts. Without this, false conclusions could all 
too easily lead to actions wasteful of resources and unhelpful to the environment.' 
Voting: 
For: 28. Against: 31. Abstentions: 23. 
Point 9, second indent: 
Delete 'available' and substitute 'practicable economic'. 
Reason 
This opinion is more likely to be considered by the Environment Council if it makes suggestions which take into 
consideration the overall economic balance and welfare of the Member States. 
Volting: 
For: -. Against: majority. Abstentions: 1. 
B. The following passages of the opinion were deleted as a result of the amendments adopted during the 
discussion 
Point 2: 
In its opinion of 4 July 1984 (CES 654/84) the Committee dealt at length with the damage caused by forest fires 
and approved the Commission proposals. National efforts to combat and prevent fires should be backed by the 
Community. There is no disagreement about methods of fighting forest fires. 
Points 14 to 16: 
14. The Section calls for further Community action in the transport field: 
(a) a new Regulation imposing a speed limit of 100 km / h on motorways and 8 0 km / h on main roads throughout 
the Community; this would also reduce the risk of accidents and conserve energy; 
According to official estimates, which not even the car industry disputes, this alone would reduce NOx 
substantially (15 to 18 % NOx emissions from traffic). 
NoC 104/12 Official Journal of the European Communities 25. 4. 85 
(b) stricter regulations on exhaust gases; 
(c) concessions for vehicles using clean energy, 
(d) promotion of public transport and non-polluting transport systems. 
These measures could bring about a substantial, direct and immediate reduction in emissions. 
15. Reduction of air pollution from aircraft. 
The effects of aircraft exhaust gases on plant life should be examined. Appropriate regulations should be adopted 
to reduce the emission of pollutants. 
16. Besides these direct methods of combating air pollution all other means of indirectly reducing atmospheric 
pollution by energy-saving measures must be implemented. These include, for instance: 
(a) all measures to conserve energy; 
(b) the promotion of energy sources such as bioalcohol, liquid gas, district heating, which cause less air 
pollution; 
(c) incentives for energy conservation, such as insulation, improved combustion techniques, combined 
electricity/heat production; 
(d) a long-term reorientation of housing and town planning policy, with a greater emphasis on reducing the need 
for transport as much as possible. 
Point 17 (a), third indent: 
If necessary, concessions for the transport of wood by rail and road. 
Point 17 (b), last sentence of first paragraph and second paragraph: 
As there is no scientific or legal possibility of determining who is responsible for the air pollution and hence the 
damage, it is necessary to provide statutory arrangements for compensation. 
Tax concessions must be granted for wood used as a result of forest damage. 
First part of second paragraph: 
A considerable part of GNP must be ... . 
Own-initiative opinion on the current situation and medium-term prospects of the Community 
fisheries sector 
(85/C 104/07) 
On 23 October 1984 the Economic and Social Committee, acting under the fourth paragraph of 
Article 20 of its Rules of Procedure, decided to draw up an own-initiative opinion on the current 
situation and medium-term prospects of the Community fisheries sector. 
The Section for Agriculture, which was responsible for preparing the Committee's work on the 
subject, adopted its opinion on 7 February 1985, in the light of the information report by 
Mr Morselli. 
At its 224th plenary session (meeting of 27 February 1985) the Economic and Social Committee 
adopted the following opinion by a large majority, with two votes against and one abstention: