28. 1. 85 Official Journal of the European Communities No C 25/33 
3,2. Re Article 1 (11) — amendment of Article 11 (2) 
of Directive 77/93/EEC. 
The Committee would refer in this connection to the 
comments in point 2.2.9. 3.3. Re Article 1 (14) — amendment of Article 11 (3), 
second subparagraph, of Directive 77/93/EEC. 
The Committee would refer to the comments made 
in point 2.2.8. 
Done at Brussels, 21 November 1984. 
The Chairman 
of the Economic and Social Committee 
Gerd MUHR 
Opinion on the proposal for a Council Directive on the limitation of emissions of 
pollutants into the air from large combustion plants (*) 
(85/C 25/14) 
On 11 January 1984 the Council decided to consult the Economic and Social Commit­
tee, under Article 100 of the Treaty establishing the European Economic Community, 
on the abovementioned proposal. 
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 30 October 1984, in the light of the Report by Mr Vercellino. 
At its 221st plenary session (meeting of 21 November 1984) the Economic and Social 
Committee adopted the following opinion by a majority, with five abstentions: 
1. Introduction 
1.1. The Committee regards as very positive the 
Commission's decision to draw up a Directive to 
limit and reduce, through effective, homogeneous 
measures at Community level, emissions of pollu­
tants into the air from large combustion plants. It 
endorses the basic content and aims of the Direc­
tive; it would point out that the question is a very 
important one, involving extremely diverse interests 
and posing considerable problems because of the 
types and number of existing plants, differences in 
local conditions and conditions within enterprises, 
the need for coordination with the other Directives 
on air pollution and more general measures to pro­
tect the environment. Aware of this, the Committee, 
after carefully studying the draft Directive, decided 
to make a series of comments and proposals — gen­
eral and specific — on its content and on the possi-
(') OJ No C 49, 21. 2. 1984, p. 1. bilities of applying it in the various Member States 
and sectors. 
1.2. The problems relate above all to: other emis­
sion sources (other types of plant, motor vehicles, 
domestic sources etc.) acidification processes (acid 
rain and depositions, SO2, NOx, dusts, etc.); Com­
munity-level and national energy policies; the rela­
tionship between the costs of, and the benefits 
resulting from, anti-pollution measures; the level 
and growth of information and research on actual 
and potential damage to persons and things; the 
application and dissemination of methods and tech­
nology currently available or being developed; the 
imperative need for intensive and more rapid devel­
opment of research in this field. 
1.3. The Committee has devoted much discussion 
to these problems and their implications, not only 
for human beings and the environment — highly rel­
evant to the aims in view — but also for production 
and employment, for the economic and social 
groups concerned and for the population in gen­
eral. 
No C 25/34 Official Journal of the European Communities 28. 1. 85 
1.4. Part of the report has been devoted to a de­
tailed, fully documented study of these matters, 
which were discussed — together with more specific 
aspects — in a meeting of experts and during two 
fact-finding visits: one to the Centre for Prevention 
of Air and Water Pollution (Antwerp, Belgium), and 
the other to the flue-gas desulphurization plant at­
tached to Mannheim power station (GKM) (Federal 
Republic of Germany). 
1.5. The main guiding principle was that, while it is 
right to avoid excessive costs which do not lead to 
an appropriate reduction of air pollution, one 
should on no account lose sight of the fact that sig­
nificant costs are already borne by the whole of 
society as a result of the damage caused by the 
absence or inadequacy of protective measures. 
2. General comments 
2.1. Selection of Community standards and instru­
ments 
2.1.1. The problems raised by the Directive give 
rise to some preliminary remarks on the type of 
standards and instruments which should be adopted 
at Community level to ensure protection of the envi­
ronment and reduction or prevention of air pollu­
tion. 
2.1.2. It can be said that, now that nearly ten years 
have passed since the start of the first Community 
environment programme setting out the main aims 
and guidelines, a significant qualitative leap has 
been made with the drawing-up of a number of 
Directives and the launching in 1984 of the third 
programme, with more precise aims and more elab­
orate guidelines. This programme, of which the pre­
sent draft Directive forms part, is based on two fun­
damental principles, from which it would be dange­
rous to depart — that of taking structural measures 
which should fit in with economic and social deci­
sions, and that of taking action to prevent and avoid 
damage to human beings, the atmosphere, water 
resources, the soil, buildings and fauna, not only 
because prevention is better than cure, but also be­
cause it is usually less expensive or can become so. 
2.1.3. The weakest point in Community measures 
to date is certainly the gulf between the stated aims 
of the Directives and their implementation. This is 
largely due to the difficulties encountered in at­
tempting to define uniform, rigorous emission limit 
values for all the countries and plants concerned. 2.1.4. It would thus be reasonable to say that too 
many differences in implementation and too many 
exemptions from the limits and deadlines laid down 
do not contribute to uniform environmental policies 
and effective Community measures or to achieving 
satisfactory results at the national level. Perhaps, 
because of the interests and stakes involved, envi­
ronmental policy is one of the sectors of Community 
activity which require more effective and binding 
standards and instruments and more homogeneous 
measures and results in order to make up for lost 
time by exploiting the most advanced innovations 
and techniques quickly and on a larger scale. 
2.1.5. Indeed, the lack of coordination between 
Community standards and national legislation con­
tributes to inadequate or partial implementation of 
the agreed standards or to the adoption of local 
measures which continue to create risks and inequal­
ities, as well as distortions of competition. 
2.1.6. Moreover, experience has shown that 
whether a more binding or a less binding Commun­
ity instrument, applicable to various situations, is 
selected is by no means a matter of minor impor­
tance. In this context the Economic and Social 
Committee, at its July 1984 session, reaffirmed the 
need to adopt a Regulation instead of a Directive — 
which was regarded as insufficiently binding — to 
combat and prevent pollution and disasters caused 
by oil spills at sea. This stance does not conflict with 
the need for flexibility in implementation — particu­
larly in the early stages — of the provisions of both 
regulations and directives. 
2.2. Scope and features of the new Directive 
2.2.1. This Directive is of special importance pre­
cisely because it deals with combustion plants, 
which (a) are to be found almost everywhere, (b) are 
of different sizes and ages and (c) include many 
power stations. These plants, although they are often 
thought to be easier to monitor, pose many difficult 
problems, because they cause not only local but also 
more remote pollution. Their emissions combine 
with other substances, thereby making the measure­
ment of the resulting pollution, and consequent 
measures, more complicated. 
2.2.2. The new Directive is also important because 
of its possible economic and social implications. In­
deed, if careful account is not taken of its possible 
effects, it may influence the cost of ernergy and of 
28. 1. 85 Official Journal of the European Communities No C 25/35 
products with a high energy content, thereby affect­
ing competitiveness on world markets and employ­
ment opportunities. The Committee therefore re­
commends that the Commission and the Council 
redouble their efforts to control pollution and air 
quality, coordinating them with those of third coun­
tries and the initiatives of the UN, the 30 % Club 
and the Munich Conference. 
2.2.3. For these and other reasons, the Committee 
would draw the attention of the Commission and the 
Council to the objective difficulties to be overcome 
and to certain general and specific aspects of an 
organizational, technical, socio-economic and fi­
nancial nature about which it is gravely concerned. 
2.2.4. It is particularly anxious to do this since 
there is a danger that differing views or a lack of 
clarity on these problems and on ways of solving 
them may delay adoption and implementation of 
the Directive, making it difficult to achieve its aim. 
2.3. Integrated implementation of this and the other 
Directives on pollution 
2.3.1. The Committee recommends firstly that the 
Commission, prior to the final drafting process, 
should make a detailed examination of the Direc­
tives in this field already issued or in preparation, 
with a view to better synchronization and integra­
tion of the various measures and aims, cost/benefit 
calculations, experience acquired and results 
achieved; the Member States should be invited to do 
the same. Since this could be achieved with only a 
few working meetings on the basis of documents, 
calculations and data already available, a review of 
this kind should not in any way delay or weaken the 
Directive, but if anything help to speed up its adop­
tion and make it more effective. 
2.3.2. Further possible calculations and checks 
could be carried out early enough to set deadlines 
for national plans in good time on the basis of the 
various situations, the technology available, and the 
measures and contributions of public and private-
sector organizations. 
2.4. Coordination of the Directive with energy poli­
cies 
2.4.1. The Committee feels that the Commission 
has undoubtedly geared the Directive to the energy policies of the Community and the Member States, 
and urges it to make further efforts to ensure that 
there are no negative repercussions on the energy 
choices made by the Community and the Member 
States, on the exploitation of the fuels available in 
Europe, on technological innovation or on competi­
tiveness in the European and international markets. 
2.4.2. In particular, the Community must encou­
rage a switch from fuels such as oil and gas to 
locally produced fuels. 
2.5. Dissemination of information and of technology 
2.5.1. In the Committee's view the delays in tack­
ling air pollution are due above all to lack of data, 
to inadequate clarity and to inadequate dissemina­
tion of information and appropriate methods. 
2.5.2. Concerned at this state of affairs, the Com­
mittee strongly urges the Commission, the Council 
and the Member States to take the necessary steps — 
in the context of this and other Directives — to 
improve the provision of information and the ex­
change of experience and of technological and cal­
culation methods already in use or being developed, 
and to ensure wider knowledge of positive results 
and of the errors and distortions to be avoided. 
2.5.3. The Committee particularly recommends 
that dissemination of information among as wide a 
section of the public as possible be encouraged, in 
order to make the public aware of these problems 
and involve it in efforts to solve them. 
2.6. The main aims of the Directive 
2.6.1. The Committee supports the Commission 
proposal that reports on the implementation of the 
Directive be submitted in good time at regular inter­
vals, but these reports should not be weighed down 
or delayed by the inclusion of local details which are 
not strictly necessary. Further efforts should be 
made to define better the emission limits, the types 
and age of plants, and the pace at which measures 
should be implemented in the different countries to 
achieve the same final or interim results — using dif­
ferent methods, but without encouraging recourse to 
exemptions. 
No C 25/36 Official Journal of the European Communities 28. 1. 85 
2.6.2. This presupposes that, while efforts are made 
in the coming months to adopt and implement as 
soon as possible a Directive laying down a uniform 
Community policy in this area, care will have to be 
taken to ensure that the same targets and objectives 
are set and respected by all. To this end it is reason­
able to allow changes only in programme timetables 
to take account of special situations and difficulties. 
This will also be conducive to alignment and help to 
perfect or enrich available methods and technolo­
gies, thereby bringing costs down. 
2.6.3. The Committee takes the view that, with this 
approach — at once Community-oriented and plu­
ralist — the basic aim cannot be other than that pro­
posed by the Commission — to reduce or prevent 
pollution from large combustion plants, by effec­
tively controlling and reducing acidification pro­
cesses and their depositions, as well as emissions of 
pollutants — especially SO2, NOx, and dusts which 
often have a high heavy-metal content. 
2.6.4. The seriousness of the situation and the 
stakes involved should not be minimized, but should 
be appreciated as fully, rationally and objectively as 
possible, without prophesying ecological or eco­
nomic doom. 
2.6.5. By the same token, we in Europe cannot 
underrate the significance of the fact that a United 
States Congress report, made public on 22 June 
1984, considers, on the basis of its own assessments, 
that 50000 deaths in 1983 were due to acidification 
processes (deaths from chronic asthma, broncho­
pulmonary complications and tumours). Indeed, if 
the European situation does not appear to be so ser­
ious as yet, this is due above all to the inadequacy of 
the data and the relatively few measures considered 
necessary. 
2.7. Research, new technologies, cost/benefit analy­
sis 
2.7.1. With regard to research and technological 
innovations, the Committee suggests that the Com­
mission make a more detailed study of other pollu­
tion causes and sources and of the most suitable 
methods for limiting emissions; this study should 
embrace sources such as dusts, hydrocarbons, motor 
vehicles, etc. 
2.7.2. Another important recommendation by the 
Committee to the Commission and the Council is 
that more detailed calculations be made — in the 
remaining time available, with the help of the indi­vidual Member States and research centres — on the 
effective ratio of costs to benefits for the measures to 
reduce pollutant emissions laid down in the Direc­
tive. 
2.7.3. The Committee accordingly proposes that 
the Commission and the Council arrange for the 
necessary studies and investigations on the basis of a 
plan with precise deadlines, which would not delay 
but facilitate adoption and implementation of the 
Directive. 
2.7.4. This could be done either by drawing on the 
more advanced calculations and experience already 
available in the Member States, or by applying to 
this specific sector the Community calculations al­
ready made or more general calculations relating to 
measures taken to protect the environment as a 
whole. 
2.7.5. For example, on a more general level, some 
interesting estimates are available both for the costs 
of measures taken and for expenditure entailed by 
damage resulting from failure to act. Indeed, data 
published by the OECD on its member countries 
show that the inflationary effect of environmental 
policies has in general been slight — in the region of 
0,2 to 0,3 %. In the same countries expenditure on 
the environment varies from 1 to 2 % of GDP, while 
annual expenditure to make good the damage to the 
environment is significantly higher — of the order 
of 3 to 5 % of GDP. 
2.8. Cooperation and consultation between the two 
sides of industry and the public authorities 
2.8.1. While it is true, and encouraging, that many 
Community countries have already acknowledged 
the potential of environmental policy for job crea­
tion and taken steps to that end, at this stage the 
practical and operational difficulties in implement­
ing measures at large combustion plants, including 
power stations, in the Member States should not be 
underestimated. 
2.8.2. If sufficient account is to be taken of these 
aspects, there must be more coordination of meas­
ures to limit emissions. Compliance with emission 
limits and the costs involved would depend on how 
the plants are run. Networks should be set up to 
measure and monitor air quality in the areas af­
fected — this action would depend mainly on meas­
ures and financing by the public authorities. 
28. 1. 85 Official Journal of the European Communities No C 25/37 
2.8.3. To this end provisions should also be 
adopted to encourage the development of research 
and new technology in order to facilitate the adapta­
tion of old combustion plants, using public or a 
combination of public and private funds. 
2.8.4. The Committee accordingly recommends 
that the Directive should also strongly stress the 
need for growing, effective cooperation and consul­
tation in this vast sphere of activity and interests 
among the four main parties — plant operators, 
local and national authorities, representatives of 
workers and local communities, and members of 
scientific and technical groups and institutes, who 
are essential partners if a decisive, specialized and 
independent contribution is to be made in this 
area. 
2.8.5. A special effort should also be made in draft­
ing and implementing the Directive to ensure that 
no country, sector or region is placed in a privileged 
or a disadvantaged position. While it is right to lay 
down that each Member State should draw up a 
plan to reduce emissions to the limits set, taking 
account of local circumstances, it would seem that, 
if a proper balance of costs, benefits and conditions 
of competition is to be achieved, the Member States 
with low total emissions and those burning indige­
nous fuels should not be allowed for any reason to 
disregard either the general aim of reducing total 
pollutant emissions or the emission limits for large 
combustion plants. 
3. SPECIFIC COMMENTS 
3.1. Definition of combustion plants 
3.1.1. In order to take more account of the differ­
ent circumstances the Committee suggests that the 
Commission should consider the possibility of dis­
tinguishing not two but three types of plant, amend­
ing Article 2 (definitions 11 and 12) to read: 
New plant: any combustion plant authorized and 
built after 1 January 1985; 
Existing plant: any combustion plant already in ser­
vice the operation or construction of which was 
authorized before 1 January 1985; Plant under construction: any combustion plant 
whose construction was authorized in full or in part 
before 1 January 1985, but which has not yet come 
into service. 
Intermediate arrangements, which take account of 
individual projects and the progress of building 
work, could apply to the third type of plant. 
3.1.2. The Committee also calls for the other defi­
nitions in Article 2(1 to 10) to be formulated more 
precisely in all the languages of the Member States 
so as to take sufficient account of the different situa­
tions and laws. 
3.2. National programmes 
3.2.1. The Committee proposes that the national 
programmes (Article 3.1) should include, in addition 
to control of emissions, a system for checking air 
quality and a network of acid deposition monitoring 
stations. The results of these activities should be 
communicated to the Commission (Article 9.2). 
3.2.2. The Committee thinks it desirable that the 
national programmes (Article 3.1) should also pro­
vide — as is already the case in some States — for a 
survey of the types of fuel, their quality (calorific 
value, sulphur content) and the quantities con­
sumed, together with forecasts for subsequent years. 
This information should be communicated to the 
Commission (Article 9.2). 
3.2.3. Whilst historical information on sulphur 
dioxide emissions is available for most countries, 
historical information on oxides of nitrogen and 
dust is not. The Committee asks the Commission to 
state clearly how these emissions will be evaluated 
for the base year 1980. 
3.2.4. Although the timescale and deadlines pro­
posed by the Commission already constitute a valid 
basis for a solution, the Committee thinks that an 
attempt could be made to work out a more flexible 
timescale for the reduction, taking account of tech­
nical progress and other factors. For example Arti­
cle 3.2. could provide for a two-stage reduction — 
(a) from 1985 to 1990 and (b) from 1990 to 1995. The 
Committee recommends that the Commission do its 
utmost to reduce the time needed for drawing up 
national programmes to a minimum — if possible to 
one year. 
No C 25/38 Official Journal of the European Communities 28. 1. 85 
3.2.5. The Committee would also ask the Commis­
sion to review the rates of emission reduction 
(Article 3) so as to take more account of the special 
characteristics of certain sectors and plants — e. g. 
traditional power stations and oil refineries — with­
out, however, favouring or discriminating against 
any particular sector. 
3.3. Exemptions (Article 7) 
3.3.1. The Committee does not think there should 
be excessive or general exemptions which might fa­
vour some Member States or discriminate against 
others. It stresses that the Commission should ask 
the Member States to take acount of specific circum­
stances in their national programmes, in order to 
achieve the common aims without creating distor­
tions of treatment or competition between plants, 
Member States or sectors. 
3.4. Emission limit values 
3.4.1. Existing plants 
Since large combustion plants have a long working 
life and problems of air pollution and acidification 
are worsening, the Committee takes the view that the 
Directive would be more effective if it laid down a 
special type of pollutant emission limit for existing 
plants as well. To avoid distortions of competition 
and wait-and-see attitudes which would militate 
against the installation of new, more efficient plants, 
less harmful to the environment, it would be advisa­
ble to set sufficiently reasonable and flexible limit 
values for existing plants, applicable initially only to 
existing plants with a capacity of more than 
100 MW; this could form part of a more general 
technical and economic solution involving gradual 
replacement of old plants with new plants which are 
obliged to comply with the emission limits. 
3.4.2. New plants and timetable 
The Committee takes note of the fact that for new 
plants of between 50 and 100 MW the measures will 
come into force five years later (in 1990). However, 
it thinks that it is necessary also to limit emissions 
from such plants. It therefore recommends that the 
Commission determine suitable solutions and limits 
in line with those suggested in point 3.4.1. Bearing in mind that plants of less than 50 MW also 
contribute to pollution (up to 20 % in some Member 
States), the emission limits laid down in the Direc­
tive should be applied as soon as possible to new 
plants of less than 50 MW. 
3.4.3. Periodic adjustment of the Directive 
It has come to the Committee's notice that some 
plants already respect the limits for SO2, NOx and 
dusts envisaged for the post-1995 period. 
In order to take account of technological progress 
and of the problems which combustion plants will 
face in seeking to comply with emission limits, the 
Committee proposes that the Commission examine 
the possibility of a periodic adjustment (perhaps 
every three or five years), in the initial stage between 
1986 and 1995, of the limit values set for 1985 to 
1995 to take account of any new technology which 
becomes available ('state of the art'), and of any 
other changes in the sectors concerned. 
3.4.4. Limit values for SO2 and for fuels 
The Committee points out that, if SO2 limit values 
are expressed in mg/nm3 (see Table 5, page 42 of the 
report) a brown-coal-fired power station will be able 
to emit up to 60 % more than a comparable oil-fired 
power station. It therefore recommends that the 
Commission express the limit values in such a way 
as not to discriminate between fuels. A number of 
proposals are made for guidance on pages 23 and 25 
of the report. 
3.5. Emission measurement methods 
(Articles 13 and 15 and Annex II) 
3.5.1. The Committee urges the Commission to 
propose reference methods for measuring SO2, NOx, 
dusts and other substances, and for calibrating the 
measuring instruments (Article 13). 
3.5.2. The Commission rightly lays down that cal­
culations may be used instead of emission measure­
ment in order to determine the SO2 concentration 
(Annex II 1). In the Committee's view, however, it 
should be made clearer that these calculations (for 
every emission point) must be based on continuous, 
recorded measurements of the fuels used and the 
sulphur which they contain, or on an alternative 
method which is sufficiently representative and 
reliable. 
28. 1. 85 Official Journal of the European Communities No C 25/39 
3.5.3. In such cases, besides the carrying-out of 
checks by means of individual measurements (as 
laid down in Article 15 [2]), the emission limit values could be regarded as having been complied with 
when these weighted calculations indicate that the 
average daily value has not been exceeded. 
Done at Brussels, 21 November 1984. 
The Chairman 
of the Economic and Social Committee 
Gerd MUHR 
Opinion on the Commission's annual economic report 1984/85 
(85/C 25/15) 
On 7 November 1984, the Council, acting in accordance with its Decision No 120/ 
74/EEC of 18 February 1984 on the attainment of a high degree of convergence of 
economic policies of the Member States of the European Economic Community (l), as 
amended by Decision No 787/75/EEC (2), and in particular Article 4 thereof, decided 
to consult the Economic and Social Committee on the Commission's annual economic 
report 1984/85. 
The Section for Economic and Financial Questions, which was responsible for prepar­
ing the Committee's work on the subject, adopted its opinion on 13 November 1984 in 
the light of the report by Mr Pelletier. 
At its 221st plenary session (meeting of 22 November 1984) the Economic and Social 
Committee adopted the following opinion by 57 votes to 46, with 13 abstentions (vote 
recorded): 
1. Introduction 
The Committee welcomes the Commission's deci­
sion to give in its annual economic report 1984/85 a 
clear and frank picture of the Community's econ­
omic problems which are considered by it to be of 
great importance. 
The Committee notes with satisfaction that the 
Commission has adopted in its report several of the 
suggestions made by the Committee in previous 
opinions. The Committee thanks the Commission 
for this. 
After a brief review of the economic problems in 
1984 and the prospects for 1985, the Committee 
intends to comment on some basic proposals con­
tained in the Commission's report and reserves the 
right to deliver a more comprehensive opinion after 
a more thorough examination and discussion of the 
Commission's report. 
(1) OJ No L 63, 5. 3. 1974, p. 16. 
(2) OJ No L 330, 24.12. 1975, p. 52. 2. Commission forecasts of economic trends in 
1984/85 
2.1. The economy in 1984 
As regards developments in 1984 and the outlook 
for 1985, the Commission notes the following: 
The Community's economy is now on a recovery 
course; this recovery is, however, only gradual and 
remains subject to uncertainty and is clearly insuf­
ficient to bring down unemployment significantly. 
The Commission's GDP growth forecast for 1984 
has been revised upwards from the original 1,5 to 
2,2 %. 
At the beginning of 1984, industrial strife in various 
countries of the Community led to a fall-off in 
industrial production. However, since July indus­
trial production has forged ahead and is now stand-