[pic] | COMMISSION OF THE EUROPEAN COMMUNITIES |

Brussels, 22.9.2006

SEC(2006)620

COMMISSION STAFF WORKING DOCUMENT

Document accompanying the COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Thematic Strategy for Soil Protection IMPACT ASSESSMENT OF THE THEMATIC STRATEGY ON SOIL PROTECTION {COM(2006)231 final}{SEC(2006)1165}

TABLE OF CONTENTS

1. Procedural issues and consultation of interested parties 5

1.1. Policy background 5

1.2. Consultation 6

1.3. Expertise 8

2. Extent and costs of soil degradation in the EU 9

2.1. Erosion 10

2.1.1. Qualitative analysis 10

2.1.2. Quantitative analysis 12

2.2. Decline of soil organic matter (SOM) 12

2.2.1. Qualitative analysis 12

2.2.2. Quantitative analysis 15

2.3. Compaction 16

2.3.1. Qualitative analysis 16

2.3.2. Quantitative analysis 18

2.4. Salinisation 19

2.4.1. Qualitative analysis 19

2.4.2. Quantitative analysis 20

2.5. Landslides 21

2.5.1. Qualitative analysis 21

2.5.2. Quantitative analysis 22

2.6. Contamination 23

2.6.1. Qualitative analysis 23

2.6.2. Quantitative analysis 26

2.7. Sealing 27

2.7.1. Qualitative analysis 27

2.7.2. Quantitative analysis 28

2.8. Biodiversity 28

2.8.1. Qualitative analysis 28

2.8.2. Quantitative analysis 29

2.9. Conclusions 30

3. Existing policy framework for the protection of soil 31

3.1. Member States level 31

3.2. Conventions and protocols 31

3.3. EU level 32

3.3.1. Links to objectives from other environmental legislation 32

3.3.2. Links to other Community policies 34

3.4. Soil legislation of important trading partners 35

3.5. Current use of market based instruments 35

3.6. Conclusions 36

4. Objectives of the strategy 37

4.1. The general objectives 37

4.2. Specific objectives 37

4.3. Link to other policies and previously established objectives 37

5. Need for EU action 38

6. Policy options to reach the objectives of the strategy 40

6.1. Possible options 40

6.2. Which options have been rejected at an early stage? 41

6.3. Which policy option has been considered? 41

6.4. Description of the option chosen 42

7. Qualitative and quantitative analysis of impacts of obligations specified in the Soil Framework Directive 44

7.1. Introduction 44

7.2. Establishment of risk areas and programmes of measures for erosion, SOM decline, salinisation, compaction and landslides 45

7.2.1. Costs of options considered for risk area identification 45

7.2.2. The option chosen 48

7.2.3. Benefits of identifying risk areas 48

7.2.4. Establishing a Programme of Measures 49

7.3. Establishment of an inventory of contaminated sites and of a National Remediation Strategy 49

7.3.1. The inventory of contaminated sites 49

7.3.2. Establishing a National Remediation Strategy 54

7.4. The establishment of a soil status report 54

7.4.1. Qualitative analysis of environmental, social and economical impacts of establishing a soil status report 56

7.4.2. Quantitative analysis and monetisation on the impacts of a soil status report 56

7.5. Impact of a mechanism to fund the remediation of orphan sites 58

7.5.1. Qualitative analysis of environmental, social and economical impacts 58

7.5.2. Qualitative analysis of establishing a mechanism to fund the remediation of orphan sites 58

7.6. Limitation of sealing by giving priority to the rehabilitation of brownfield sites and the use of soil saving construction techniques 59

7.7. Awareness raising 59

7.8. Summary of impacts of obligations specified in the Soil Framework Directive 60

8. Qualitative assessment of the impacts of possible measures to be taken by Member States 60

8.1. General qualitative impacts of measures against erosion, organic matter decline, salinisation, compaction and landslides 62

8.2. General qualitative impacts of the management of contaminated sites 67

9. Monitoring and evaluation 69

9.1. Core indicators of progress to meet the objectives 69

9.2. Monitoring and evaluation 69

ANNEXES:

Annex 1: Scenarios to illustrate possible implementation of the Soil Framework Directive

Annex 2: Results of the Internet Consultation

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES

Policy background

The 6th Community Environment Action Programme[1] requires the development of a Thematic Strategy on soil protection “addressing the prevention of, inter alia , pollution, erosion, desertification, land degradation, land-take and hydrological risks taking into account regional diversity, including specificities of mountain and arid areas”[2].

Consequently and as a first step, the Commission presented its approach to soil protection in a Communication “Towards a Thematic Strategy on soil protection”[3]. The main threats to soil described were erosion, decline in organic matter and biodiversity, contamination, sealing, compaction, salinisation, landslides and flooding[4]. The Commission stressed the importance of integrating soil aspects into other policies, but also indicated the need for legislation focussing exclusively on soil.

This Communication was the subject of favourable conclusions by the other European Institutions which recognised that soil has a major role with respect to long term European sustainability.

The European Parliament stated in particular “the urgent need to regulate its (soil) use and assess and mitigate the impact of external actions”, and generally supported the approach of the Commission, including the necessity for Community action and some legislative proposals[5].

The Council welcomed the Communication as it “provides a comprehensive overview of the elements and factors related to soil threats, as well as of existing Community policies relevant for soil protection, and establishes the basis for the identification of the future Community actions for its protection” and underlined that “the proper functioning of the single market may require also a common approach to soil policy, in so far as its protection and remediation at all relevant levels may also affect competitiveness”[6].

The Economic and Social Committee especially emphasised the need for objectives to be set for European soils, the need for an assessment of the threats in the different regions, the importance of building any new data collection and monitoring systems on already ongoing activities, and the need to address the issue of private ownership of soil[7].

The Committee of the Regions emphasised the need for a vision on the sustainability of European soils as well as for the establishment of targets and local risk-orientated and cost-effective programmes of protection[8].

Consultation

In developing the strategy, the Commission has broadly consulted stakeholders and the public:

In February 2003 the Commission organised an open stakeholder meeting to launch a wide public consultation and to call for volunteers to participate in a set of Working Groups that would assist the Commission in the development of soil policy.

In May 2003, on the basis of candidacies received, the Commission established a wide platform of more than 400 members, composed of five Working Groups and an Advisory Forum with a steering role. The members of these groups were experts from public administrations, agricultural, industrial, environmental and consumer organisations, science and research institutes, the European Environment Agency, the Join Research Centre and other Commission services, as well as many other associations which had European coverage and an interest in soil. The Working Groups, on the basis of mandates prepared by the Commission, addressed the following issues:

- Monitoring of soil,

- Erosion,

- Decline of organic matter and biodiversity,

- Contamination,

- Research, sealing and cross-cutting issues.

Throughout the process a continuous information exchange with other stakeholders not participating in the groups was also carried out.

An electronic mailbox for receiving public questions and feedback on soil was created as well as a comprehensive public electronic library and information repository, called CIRCA[9], to allow stakeholders within and outside the platform to transmit input and follow the progress of the work.

In June 2004, the Working Groups finished their extensive reports which included information on the state of soils in Europe, the pressures, the driving forces for soil degradation and a set of recommendations addressed to the Commission for the development of an EU soil policy. These reports have been published by the OPOCE[10], and are also available without charge on the Internet[11].

In parallel to the external consultation, the Environment Directorate-General of the Commission, by means of an ad-hoc Inter-service Working Group, worked closely with other Directorates-General (such as those for Enterprise, Agriculture and Rural Development, Regional Policy, Development, Transport and Energy) on the development of a soil policy at EU level.

In November 2004, the Dutch Presidency of the Council held a conference gathering Member States and participants to the stakeholder process who expressed strong support for a framework approach based on EU action[12].

In June 2005, the Environment Directorate-General presented an outline of a proposal for a Soil Thematic Strategy to the Member States. A Common Implementation Strategy to accompany the implementation process was seen as very beneficial.

In August/September 2005, for a period of eight weeks, the Commission carried out an Internet consultation aimed at citizens, soil experts and organisations to elicit opinions on specific measures being considered for inclusion in the strategy. This consultation was done by means of two questionnaires (one for citizens and one for experts and organisations) available in seven languages (EN, FR, DE, ES, IT, NL, PL). The minimum standards for consultation were respected during the consultation process and the Commission does not claim that the group of respondent is a statistically representative sample for the EU.

The results of these questionnaires are presented hereafter.

The consultation drew replies from 1,206 citizens, 377 soil experts and 287 organisations from 25 countries.

The majority (91%) of participating European citizens expressed the view that preventing and mitigating soil degradation in Europe is important or very important, favoured (74.6%) that action be taken under the form of a framework adopted at EU level and concrete measures at national or local level (16.4% advocated taking all measures at EU level), supported the identification of risk areas (87.8%) and the obligation to adopt measures in those areas (96.5%) and ranked the possible measures in order of priority. As regards the different measures proposed to deal with soil contamination, the endorsement of the responding citizens (that fully agree or rather agree) ranged between 95.3% and 98.9%.

Most soil experts and organisations which replied also believed that preventing and mitigating soil degradation in Europe is important or very important (90.2%); they clearly preferred (87.8%) that a framework be developed at EU level and measures established at national/local level. For the measures proposed, only few participants (0.9-3%, depending on the threat) flagged that these could have high negative economic or social impacts on their activities. As regards the different measures proposed to deal with soil contamination, the endorsement of soil experts and organisations (that fully agree or rather agree) ranged between 81.3% and 98.8%.

A comprehensive report on the statistical analysis of all questions and how the feedback has been taken into account is published on the internet[13] and attached to this report as Annex 2.

Expertise

This impact assessment is based mainly but not exclusively on the following information:

- Reports from the Working Groups[14] set up to assist the Commission.

- A study commissioned by the Environment Directorate-General and carried out by Ecologic and BRGM to assess the economic impacts of soil degradation[15].

- A study commissioned by the Environment Directorate-General and carried out by TAUW and LEI on economic, environmental and social impacts of different measures to prevent soil degradation[16].

In addition, support has also been sought/obtained from other sources, such as:

1. INSEA[17], an ongoing research project funded by the European Commission (under the Scientific support to policies in 6th Framework-programme), which provided a model to quantify the environmental and economic effects of measures to be taken in arable farming against erosion and loss of organic matter.

2. Several EEA reports (references given when they are quoted).

3. A Report on Soil Resources of Europe[18] has formed the basis for an internal Commission Working Document “Status of soil data in EU 25 – soil maps, soil monitoring, soil data bases” to assess the extent of already existing information on soils in EU 25.

4. Preliminary results of a study commissioned by the Environment Directorate-General on market based instruments for soil protection, by the Institute for Environmental Studies[19].

5. A report on common criteria to identify risk areas for erosion, organic matter decline, compaction, salinisation and landslides from the Joint Research Centre in Ispra and the European Soil Bureau Network[20].

EXTENT AND COSTS OF SOIL DEGRADATION IN THE EU

The following sections present the soil threats that have been considered in the strategy. Findings are based on a literature review covering 60 studies, and five case studies analysed more in detail.

It should be borne in mind that the effects of degradation on the non-use values attached to soil (e.g. the patrimonial value of preserving soil for future generations) could not be monetised for any of the threats.

The analysis presented in this chapter focuses on the total cost of soil degradation. Nevertheless, it should be borne in mind, that Member States are currently taking some measures under existing national or Community legislation, to either prevent soil degradation or to mitigate its effects. The present assessment could not take into account the contribution of measures already in place for the following reasons:

- there is no sufficient information on where and what specific measures are taken;

- there are no ex-post evaluations of these measures which would allow an assessment of their efficiency to combat soil degradation;

- some measures have been adopted too recently (cross-compliance) or not yet (Water Framework Directive).

Therefore this analysis does not represent the real current baseline.

On-site and off-site cost entries which are marked with ** could be quantified and were included in the calculation of the total costs for degradation.

Erosion

Qualitative analysis

Erosion is a natural process, which can however be significantly accelerated by human activities. It is known to be a serious problem throughout Europe, especially in the Mediterranean zone, but snowmelt erosion happens in Scandinavian countries and wind erosion is common in Central and Western Europe.

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Soil erosion is increasing in Europe[21]. As precise estimates are not possible due to the lack of comparable data, it is difficult to assess the total area of the EU affected by erosion. The EEA estimated 115 million ha, or 12% of Europe’s total land area, to be affected by water erosion, and that 42 million ha are affected by wind erosion, of which 2% severely affected[22].

Due to the difficulty to assess the affected area, erosion risk has been proposed as an indicator of actual erosion, which can be assessed on the basis of predictive models such as PESERA[23]. This model covers most of the EU25, except Sweden, Finland, Malta and Cyprus, where Corinne Land cover data is not available.

PESERA predicts that overall 3.4% of the area of the 21 Member States covered (1.6 million hectares) is at risk from erosion of more than 10 tonnes per hectare and year, 18% (54 million ha) are at risk of losing soil above 1 tonne per hectare, and 25% of the area (corresponding to 75.5 million hectares) is at risk to lose more than 0.5 t of soil per hectare and year. The Mediterranean region is the most affected, but there is clear evidence that also other parts of EU25 suffer significant soil erosion. For some weather events, the losses can be much more significant: for instance, in a rainstorm in the South of Spain, 20 tonnes of soil can be washed off just one hectare in a few hours.

It is worth noting that as natural soil formation is extremely slow, losses over 1[24] or 2 [25] tons/ha/year are therefore considered irreversible.

The consequences of erosion for soil fertility and soil ecosystems are significant, as soil is practically a non-renewable resource due to the fact that soil formation is extremely slow.

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The following costs resulting from these impacts have to be considered:

On-site costs (costs basically borne by the owner or the user of the land)

- Yield losses due to eroded fertile land**

- On-site costs due to impact on tourism

Off-site costs (costs borne by third parties and society, such as public administration, private sectors, tax payers and society as a whole)

- Costs of sediment removal, treatment and disposal**

- Costs due to infrastructure (roads, dams and water supply) and property damage caused by sediments run off and flooding**

- Costs due to necessary treatment of water (surface, groundwater)**

- Costs due to damage to recreational functions**

- Economic effects due to erosion-induced income losses

- Costs due to increased sediment load for surface waters (e.g. negative effects on aquatic species, difficulties for navigation)

- Costs of healthcare caused by higher exposure to dust and soil particles in the air

Quantitative analysis

Table 1 provides an overview of the sum of the types of costs that could be quantified (marked with **), derived from a review of exiting literature and test cases in the study of Ecologic. Comprehensive and comparable information on the extent of erosion needed for the quantitative analysis was only available for 13 countries (equivalent to a surface area of about 150 million ha).

Table 1 : Estimated total annual cost of soil erosion (million € 2003)

On-site costs | Off-site costs | Total estimate |

Lower bound | 40 | 680 | 720 |

Intermediate | 588 | 6,676 | 7,264 |

Upper bound | 860 | 13,139 | 13,999 |

Note: These estimates are taken from the Ecologic study and relate to the surface affected by erosion in 13 countries and to five land use categories covering a surface area of 150 million ha

In recent years, a number of studies (including some from the FAO) have also tried to assess the costs of erosion, all leading to the same conclusion: off-site costs are much higher than the on-site costs.

Another important remark is that if long term effects (20 years) of soil erosion are taken into account, the estimated on-site costs listed in Table 1, i.e. around €800 million would become €3.25 billion[26].

Decline of soil organic matter (SOM)

Qualitative analysis

SOM, the organic fraction of soil (not including undecayed plant and animal residues), plays a very important role not only for soil fertility, but also for soil structure, buffering and water retention capacity and is crucial for soil biodiversity (see section 2.10). Therefore, in this Impact Assessment only the stable fraction of soil organic matter, the fraction that can be transformed into humus, is referred to. Humus means soil organic matter, exclusive of the partial decomposition products of undecayed plant and animal residues, and the soil biomass; its structure is amorphous, specific weight is low and surface area high. The principal constituents are derivatives of lignins, proteins and cellulose combined with inorganic soil constituents. Humus possesses colloidal characteristics which give it the ability to improve soil properties such as structure and porosity, sorption capacity (water, plant nutrients), protection against erosion, buffering capacity and protection of plants from drastic changes in pH, and store for micro-organisms.

SOM plays a major role in the carbon cycle of the soil. Indeed, soil is at the same time an emitter of greenhouse gases and also a major store of carbon. The global soil carbon pool contains 1,500 gigatons (Gt) of soil organic and inorganic carbon. Furthermore, carbon sequestration in agricultural soils achieved by some land management practices has a potential to contribute to climate change mitigation. Some sources estimate this to be around 2 Gt of carbon annually[27]. As a part of the Climate Change Programme, the potential of soils for carbon sequestration was estimated to be equivalent to 1.5-1.7% of the EU’s anthropogenic CO2 emissions during the first commitment period of the Kyoto protocol.

At the same time, climate change will likely increase the risk of threats due to more extreme weather events such as floods and heavy rainfall as well as increased temperature. This has severe consequences for soil biodiversity as well as for suitability and possibility to produce certain crops.

[pic]Around 45% of soils in Europe have a low or very low organic matter content (meaning 0-2% organic carbon) and 45% have a medium content (meaning 2-6% organic carbon)[28]. Besides climatic reasons, unsustainable practices of human activities are the most relevant driving forces.

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Comprehensive and comparable data for EU25 on SOM content is not available, but models exist to estimate it. Such estimations reveal that the problem of soils with very low and low SOM exists in particular in the Southern countries, where 74% of the soil has less than 3.4% organic matter, but also in parts of France, the United Kingdom, Germany and Sweden.

Consequences of decline of SOM for soil fertility and soil ecosystems are significant.

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As a decline in SOM increases erosion, all costs listed in the respective chapter are equally relevant here, but will not be repeated. The following list is limited to the costs directly resulting from a decline of SOM. The following costs have then to be considered for a decline of SOM:

On-site costs (costs basically borne by the owner or the user of the land)

- Yield losses due to reduced soil fertility**

Off-site costs (costs borne by third parties and society, such as public administration, private sectors, tax payers and society as a whole)

- Costs related to an increased release of greenhouse gases from soil**

- Costs due to loss of biodiversity and biological activity in soil (affecting fertility, nutrient cycles and genetic resources)

Quantitative analysis

As stated earlier, any assessment of SOM loss on a European level is severely limited by the lack of data and of a clear categorisation for different types of organic matter. While some data exists on the organic matter content of soils, there is no consistent Europe-wide data on the organic matter losses . Indeed, the impact of organic matter loss on the productivity of soils is much less researched than in the case of erosion.

Annual on-site costs (mainly due to lower soil productivity) of SOM decline have been estimated to be around €2 billion[29].

For the off-site effects of SOM loss, there is evidence that the climate change impact of carbon released from soils is substantial. It has been estimated the annual costs for society derived from the carbon released annually from soils due to the decline of SOM to be between €1.4 and 3.6 billion[30]. From other sources, a result on the same range could be found at least to be € 3.1 billion[31] annually.

The total annual costs of non action for SOM decline have thus been estimated to be between €3.4-5.6 billion.

Compaction

Qualitative analysis

Compaction, an increase in bulk density and a decrease in soil porosity, is a problem mainly of the subsoil (see Figure 1).

Figure 1 : Illustrative soil profile[32]

Estimates of areas at risk of soil compaction vary. While they all demonstrate the importance of soil compaction, enough data was not available on the actual occurrence of compaction, but data was available on the susceptibility of soils to compaction. Some authors classify around 36% of European subsoils as having high or very high susceptibility to compaction[33]. Other sources speak of 32% of soils being highly vulnerable and 18% moderately affected[34], and again other sources estimate 33 million hectares being affected in total, meaning 4% of the European land[35].

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The problem is likely to have increased, due to a rise in the use of high-axle loads, which are a consequence of larger machine power and intensified production[36].

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The following costs have to be considered for soil compaction:

On-site costs (costs basically borne by the owner or the user of the land)

- Yield losses due to reduced soil fertility and increased vulnerability of crops to diseases as a consequence of worsened growing conditions

Off-site costs (costs borne by third parties and society, such as public administration, private sectors, tax payers and society as a whole)

- Costs due to reduced water infiltration into the soil

- Costs due to increased leaching of soil nitrogen

- Costs linked to increased emissions of greenhouse gases due to poor aeration of soil

Quantitative analysis

No quantitative estimates of the total costs could be produced. Indeed, economic information on the impacts of compaction is very limited.

As regards on site costs, it has been estimated that surface soil compaction may cause yield reductions of up to 13%, whereas subsoil compaction, as a rough indication[37], may reduce agricultural yields by 35% or more in extreme dry or wet periods.

On the other hand the off-site costs of compaction could not be estimated at this stage.

Salinisation

Salinisation, the accumulation in soils of soluble salts mainly of sodium, magnesium, and calcium, can occur naturally in low, poorly drained areas in hot and dry climates, where surface water collects and evaporates, but can be exacerbated by human activities, in particular due to inadequate irrigation of agricultural land.

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Qualitative analysis

Salinisation affects around 3.8 million ha in Europe[38]. Most affected are Campania in Italy, the Ebro Valley in Spain, and the Great Alföld in Hungary, but also areas in Greece, Portugal, France, Slovakia and Austria[39].

The consequences of salinisation for current and future land use are significant.

[pic]The following costs have to be considered:

On-site costs (costs basically borne by the owner or the user of the land)

- Yield losses due to reduce soil fertility**

Off-site costs (costs borne by third parties and society, such as public administration, private sectors, tax payers and society as a whole)

- Costs due to damage to transport infrastructure (roads and bridges) from shallow saline groundwater**

- Costs due to damage to water supply infrastructure**

- Environmental costs, including impacts on native vegetation, riparian ecosystems and wetlands**

- Costs due to negative effects on tourism

Quantitative analysis

Data on the economic impact of salinisation is limited. The assessment of the total costs of salinisation had to be based on the three countries for which some information exists: Spain, Hungary and Bulgaria. Table 2 shows the yearly costs which have been obtained based on the following assumptions.

For the on-site costs, the extrapolation mainly considers the impacts due to reduced agricultural productivity.

For the off-site costs in the absence of European estimates, impacts were estimated for these three countries taking into account an Australian study, which estimated off-site costs to be approximately €10/ha.

Table 2 : Yearly cost of salinisation in selected countries (million €) (LB: lower bound; UB: upper bound)

Spain | Hungary | Bulgaria |

LB | UB | LB | UB | LB | UB |

On-site costs | Agricultural yield losses | 42.71 | 137.64 | 70.16 | 133.91 | 1.08 | 5.38 |

Off-site costs | Infrastructure damage | 12.08 | 18.23 | 1.32 |

Environmental damage | 4.83 | 7.29 | 0.53 |

Total | 59.62 | 154.55 | 95.68 | 159.43 | 2.93 | 7.23 |

The total costs, regarding salinisation for these three countries have been estimated to be between €158 and 321 million per year[40].

Extrapolation at EU level was not considered possible. In absence of more detailed information at the appropriate geographical scale, any up scaling of data would be misleading.

Landslides

Qualitative analysis

Landslides are natural phenomena, which can be exacerbated by human activity or, on the contrary, by lack of human activity. Landslides often occur more frequently in areas with highly erodible soils, clayey sub-soil, steep slopes, intense and abundant precipitation and land abandonment such as the Alpine and the Mediterranean regions.

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There is no sufficient data on the total affected area in the EU. In Italy, more than 50% of the territory has been classified as having a high or very high hydro-geological risk, affecting 60% of the population, i.e. 34 million inhabitants. More than 15% of the territory and 26% of the population are subjected to a very high risk[41],[42] and eight major landslides have been document by the International Disaster Database. The threat of landslides is increasing due to population growth, summer and winter tourism, intensive land use and climate change.

Consequences of landslides

- Loss of human lives and well-being

- Damage to property and infrastructure

- Indirect negative effects on economic activities due to interruption of f.i. transport routes

- Loss of fertile soil

- Contamination of soil due to damage to infrastructure such as pipelines and storage facilities

- Potential contamination of surface waters with associated off-site costs as described already under erosion

The following costs have to be considered:

On-site costs (costs basically borne by the owner or the user of the land)

- The loss of topsoil, leading to a loss of productive soil and hence a decrease in crop yield

- Damage to on-site infrastructures

Off-site costs (costs borne by third parties and society, such as public administration, private sectors, tax payers and society as a whole)

- Impact on human lives and well-being

- Damage to property and infrastructure

- Indirect negative effects on economic activities due to interruption of f.i. transport routes

- Ruptures of underground pipelines, dislocation of storage tanks, release of chemicals stored at ground level and contamination of surface waters with associated off-site costs as described already under erosion

Quantitative analysis

The International Disaster Database of the Université Catholique de Louvain contains twelve cases of major landslides for EU25, two thirds of which are from Italy. Table 3 below presents the quantified evidence on the incidence and costs of landslides that could be inferred from that database.

Table 3: Incidences and costs of landslides in Europe

No. of events | Casualties (total) (av/event) | Affected people (total) (av/event) | Cost € (total) (av/event) |

Austria | 2 | 43 | 22 | - | - | - | - |

Italy | 8 | 1,387 | 173 | 10,100 | 1,263 | 1,200,000,000 | 600,000,000* |

Sweden | 1 | 13 | 13 | 50 | 50 | 11,000,000 | 11,000,000 |

UK | 1 | 140 | 140 | - | - | - | - |

Sum | 12 | 1,583 | 132 | 10,150 | 846 | 1,211,000,000 | 403,666,667** |

Source: EM-DAT: The OFDA/CRED International Disaster Database www.em-dat.net – Université Catholique de Louvain, Brussels, Belgium. * Average based on two out of eight cases, for which there is quantified economic data. ** The average figure (average per event) is based on the three cases of landslides where quantitative data on economic impacts was available (Valtelina/Italy, July 1987, €500 M damage; Ancona/Italy, December 1982, €700 M damage; Gothenburg/Sweden, December 1977, €11 M damage). |

The extrapolation of the costs of landslides is not possible in the same way as for other soil threats, which occur continuously and are more widely-spread. Table 3 demonstrates however the wide range of costs for landslides to be between €11 to 600 million per event[43]. Italy is the country for which more data is available. According to the Italian Civil Protection Department, landslides cost between €1 to 2 billion per year to the Italian economy and have resulted in 5,939 deaths during the last century[44]. In a single Italian region (Emilia Romagna), up to 3,300 km of roads and railways are subject to active landslides[45].

There is evidence that the off-site social costs constitute the biggest share of the total damage.

With the available data, no extrapolation to EU level was considered possible.

Contamination

Qualitative analysis

More than two hundred years of industrialisation have left their trace on the status of soil. Europe has a problem of historical contamination of soil due to the use and presence of dangerous substances in many production processes. Moreover, soil contamination is still currently being produced by inadequate practices and accidents.

Soil contamination is a widely spread problem across all Europe. Most experts acknowledge that the data available are insufficient for assessing certain parameters, such as the total surface area contaminated per class of contaminant, the percentage of population exposed to the contamination, the environmental damage caused by contaminated sites, etc. This is partly because the data collected by each Member State are not comparable.

Available information indicates that the extent of contaminated sites across Europe is enormous and there is a very unequal progress among Member States in addressing the issue, some being very advanced in the identification of the extent and localisation of the problem, some others only at very preliminary phases.

The effects of soil contamination are very diverse and far reaching in their consequences. Once contaminated, soil functions may be impaired and human and ecological health and food quality may also be prejudiced. The consequences can be suffered where the contamination occurs but are mostly suffered also in a large surrounding area, including agricultural land, dwellings and/or nature reserves[46].

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The costs of contamination depend on the type of contaminant, the spatial extent of the pollution and its intensity, the natural characteristics of the contaminated site and the socio-economic characteristics of the surrounding area. However, while such factors have been addressed in local case studies, the calculation of a Europe-wide figure on contamination is impeded by the fact that much of the data is either unavailable or not comparable.

The different cost categories were estimated as follows:

On-site costs (costs borne by the owner or the user of the land)

- Costs of monitoring measures and impact assessment studies that must be carried out in order to assess the extent of contamination and the risk of further contamination of other environmental media (water, air) **

- Costs of exposure protection measures for workers operating on a contaminated industrial site

- Costs due to land property depreciation if land use restrictions are applied thus representing a loss of economic value of the industrial asset

Off-site costs (costs borne by third parties and society, such as public administration, private sectors, tax payers and society as a whole)

These costs are highly site-specific but generally consist of:

- Costs of increased health care needs for people affected by contamination, which include the treatment of patients and the monitoring of their health during long periods to detect the effects of exposure to soil contamination**

- Costs of treatment of surface water, groundwater or drinking water contaminated through the soil**

- Costs for insurance companies

- Costs of dredging and disposing of contaminated sediments down stream borne by water supply companies or public administrations

- Costs for the depreciation of surrounding land**

- Costs for increased food safety controls borne by public administrations to detect contaminated food

Table 4 gives an overview on total costs of soil contamination, derived from the study of Ecologic.

Quantitative analysis

Table 4 : Estimated total annual cost caused by soil contamination for EU25 (€ M, 2003)

On-site costs | Off-site costs | Total |

Lower bound estimate | 96 | 2,283 | 2,379 |

Intermediate estimate | 192 | 17,126 | 17,318 |

Upper bound estimate | 289 | 207,615 | 207,904 |

Estimates for on-site costs are based on a comparison of information from different sources and data available for the case of the MetalEurop site in France. The off-site costs estimates are largely based on available information for the MetalEurop site in France. This is due to the lack of quantified data on off-site costs as regards in particular healthcare costs of neighbouring populations.

These estimates, and in particular the big difference between the lower and the upper bound, show how difficult it is to quantify the costs due to soil contamination and show the disparity between test cases. In order to use a prudent estimate and to the inaccuracy of data, it was considered to be more sound to use the intermediate value of €17.3 billion per year all through out the report.

Sealing

Qualitative analysis

On average the sealed area, the area of the soil surface covered with an impermeable material, is around 9% of the total area in Member States[47]. In many European countries the built-up area increased by 25 to 75% in the period 1950-1980. During 1990-2000 the sealed area in EU15 increased by 6%[48], and the demand for both new construction due to increased urban sprawl and better transport infrastructures continues to rise[49].

[pic]

Soil sealing through urbanisation dominates in the more densely populated regions and major industrial areas of Western Europe, in particular Belgium, Denmark and the Netherlands, where 16-20% of the surface is built up. Sealing results in the creation of a horizontal barrier between the soil, air and the water and thus has several severe consequences.

[pic]

The following costs have to be considered:

On-site costs (costs basically borne by the owner or the user of the land)

- Opportunity costs due to restrictions on land use

Off-site costs (costs borne by third parties and society, such as public administration, private sectors, tax payers and society as a whole)

- Cost linked to runoff water from housing and traffic areas, which is normally unfiltered and potentially contaminated with harmful chemicals

- Costs due to fragmentation of habitats and disruption of migration corridors for wildlife

- Costs due to impacts on landscape and amenity values

- Costs on biodiversity

Insufficient data relative to soil-sealing costs is available to provide an assessment of the impacts of soil sealing in economic terms.

Quantitative analysis

There was no sufficient information to estimate the costs derived from sealing of soil. Thus no quantitative assessment could be done.

Biodiversity

Qualitative analysis

Soil biodiversity means not only the diversity of genes, species, ecosystems and functions, but also the metabolic capacity of the ecosystem[50].

Insufficient data exist on the status of soil biodiversity in Europe, as the biological quality of soil cannot easily be predicted. Although research on soil biodiversity has been carried out in European countries, it is still impossible to reliably quantify the richness, range and different roles played by microbial species.

Soil biodiversity is affected by all the threats listed above, and therefore all driving forces mentioned apply (equally) to the loss of soil biodiversity, changes in land use (agricultural and forestry practices) and soil contamination being the most prominent.

[pic]

SOM and soil biodiversity decline are closely related and the costs listed above for SOM decline (see section 2.1.4) equally arise for the loss of soil biodiversity. The following additional costs would need to be considered:

On-site costs (costs basically borne by the owner or the user of the land)

- Yield losses due to reduce soil fertility

Off-site costs (costs borne by third parties and society, such as public administration, private sectors, tax payers and society as a whole)

- Costs linked to the loss of ecosystem functions and reduced capacity to sequester carbon (see also section 4.1.4 under organic matter decline)

- Costs related to impacts on landscape and amenity values

- Costs related to changes in genetic resources

Quantitative analysis

There was no sufficient information to estimate the costs derived from sealing of soil. Thus no quantitative assessment could be done. Furthermore, the loss of soil biodiversity is not fully understood from a natural science perspective. Therefore, no quantification of these impacts and costs can be given in this report.

Conclusions

Though difficult to estimate, several studies demonstrate significant annual costs of soil degradation in the ranges of:

- erosion: €0.7 – 14.0 billion[51],

- organic matter decline: €3.4 – 5.6 billion,

- compaction: no estimate possible,

- salinisation: €158 – 321 million[52],

- landslides: up to €1.2 billion per event,

- contamination: €2.4 – 17.3 billion[53],

- sealing: no estimate possible,

- biodiversity decline: no estimate possible.

No assessments of costs to society of compaction, soil sealing and biodiversity decline are currently available. The total costs of degradation that could be assessed for erosion, organic matter decline, salinisation, landslides and contamination, on the basis of available data, would be up to €38 billion[54] annually for EU25. These estimates are necessarily wide ranging due to the lack of sufficient empirical quantitative and qualitative data.

It must be highlighted that these costs of soil degradation do not take into account the effect of standards adopted in January 2005 under cross-compliance nor the effect of other measures recently taken by Member States. For erosion and organic matter decline, they have been produced by estimating the costs of the degradation per hectare and multiplying by the most recent estimate of the number of hectares at risk of suffering these threats. The available estimates of the extent of the hectares at risk might not take into account possible improvements yielded by recent measures. Nevertheless, as changes in soil are very slow, it is likely that the current estimate of the extent of the problem is an appropriate reference.

Evidence shows that the majority of the costs are borne by society in the form of damage to infrastructures due to sediment run off, increased health-care needs for people affected by contamination, treatment of water contaminated through the soil, disposal of sediments, depreciation of land surrounding contaminated sites, increased food safety controls, and also costs related to the ecosystem functions of soil. Although many of these costs could not be monetised, they can be assumed to be very high. Therefore, the real costs for soil degradation are likely to exceed the estimates given above.

EXISTING POLICY FRAMEWORK FOR THE PROTECTION OF SOIL

Member States level

Specific legislation on soil as an environmental media exists only in few Member States (f.i. the Netherlands, Germany, some Austrian regions).

Most Member States have included some soil protection aspects in general environmental or agriculture legislation, thereby addressing the issue in a fragmented way and not comprehensively addressing all threats to soil as identified in the Communication COM(2002) 179.

Specific legislation on soil contamination exists in less than a dozen Member States, though other countries have some soil contamination provisions embedded in other legislation concerning, for instance, waste or pollution prevention. It appears that obligations and legislative acts differ significantly in approach and level of detail.

Different action plans have been established, such as in England (soil strategy), France (action plan on soil management), and Slovenia (National Environmental Action Programme).

Some Southern (Greece, Italy, Portugal and Spain) and some Eastern Member States, being affected areas, have adopted or are in the process of adopting Regional Action Programmes and National Action Programmes under the United Nation Convention to Combat Desertification (UNCCD).

Conventions and protocols

The 1972 Council of Europe’s Soil Charter, revised in 2003, called on States to promote a soil conservation policy, and the World Soil Charter (FAO 1982) and the World Soils Policy (UNEP 1982) sought to encourage international co-operation in the rational use of soil resources. As a result of the Earth Summit in Rio de Janeiro in 1992 and the Johannesburg World Summit on Sustainable Development, several conventions with consequences for soil protection were launched.

The 1992 UN Framework Convention on Climate Change (UNFCCC) recognises the role and importance of terrestrial ecosystems as sinks of greenhouse gases and that land degradation problems and changes in land use can exacerbate the emission of gases to the atmosphere. The 1997 Kyoto Protocol promotes sustainable development and calls on each party to implement policies and measures to protect and enhance sinks and reservoirs of greenhouse gases, e.g. soils.

Soil biodiversity issues are addressed by the 1992 Convention on Biological Diversity (CBD), aiming to conserve biological diversity, encouraging the sustainable use of its components, and sharing the benefits arising out of the utilisation of genetic resources. Fundamental to the CBD is the concern that biological diversity is being significantly reduced by human activities, including soil and land management.

The 1994 UN Convention to Combat Desertification (UNCCD) aims to prevent and reduce land degradation, rehabilitate partly degraded land and reclaim desertified land through effective actions supported by international co-operation and agreements.

In 1999, following a joint initiative of the Commission and some Member States (Bonn Memorandum on Soil Protection Policies in Europe, 1998), the European Soil Forum (ESF) was created, bringing together EU, EFTA and Accession Countries as well as the Commission and the EEA. Its role was to provide a better understanding of soil protection issues and to promote the exchange of information. It aimed to bring the discussion on soil protection from the scientific and technical level to the administrative and policy area thus contributing to the elaboration of the Commission’s Communication COM(2002) 179.

The 2001 Stockholm Convention on persistent organic pollutants (POPs), requires that the Parties endeavour to develop appropriate strategies for identifying sites contaminated by POPs.

Under the Alpine Convention aiming at protecting the Alpine region, the Protocol on Soil Protection seeks to preserve the ecological functions of soil, prevent soil degradation and ensure a rational use of soil in that region. It includes a series of principles and measures pertaining in particular to contamination, erosion and soil sealing.

EU level

Soil has not, to date, been subject to a specific protection policy at EU level. However, several Community policies, such as on environment, agriculture and rural development, transport, regional development contain provisions or objectives related and contributing to soil protection.

Links to objectives from other environmental legislation

Community water legislation aims to secure good quantitative, qualitative and ecological quality of all water (Water Framework Directive[55]), to avoid contamination of waters with nitrates from agricultural sources (Nitrates Directive[56]), to ensure ground water quality[57] and to prevent floods[58]. This is done by, for instance reducing direct and indirect inputs of pollutants, including sources on or in the soil, and measures to prevent floods. Eroded, contaminated, sealed or excessively fertilised soil contributes to surface or groundwater quality deterioration and flooding. Hence preventive and remedial actions to combat soil degradation will lead to improved water quality and less flood events.

Less soil contamination as a result of the remediation of contaminated sites and actions against diffuse pollution will contribute to the objectives of the Community air legislation aiming to maintain ambient-air quality where it is good and improve it in other cases. On the other hand, reduced air emissions imply less atmospheric deposition of dangerous substances into the soil, hence less soil contamination.

Soil protection objectives are present in the Waste Framework Directive[59], which requires that waste is to be disposed of without endangering, inter alia , the soil, and other specific waste legislation[60]. For example, the Sewage Sludge Directive[61] regulates the use of sewage sludge in agriculture in such a way as to prevent harmful effects on soil. The recently adopted Directive on the management of waste from extractive industries[62] requires the drawing up of inventories of closed waste facilities, six years from the entry into force of the Directive. The general soil protection objective of the Waste Framework Directive can be coupled with the objective to promote the recycling of waste in the context of the Thematic Strategy on prevention and recycling of waste [63].

In chemicals legislation, in particular under the Directives on Authorisation of Plant Protection Products[64] and on Biocidal products[65], the work on the upcoming proposal for a Thematic Strategy on the sustainable use of pesticides [66] as well as the REACH proposal[67] recognise the importance of soil protection.

Biodiversity will generally benefit from all actions proposed for the different threats. Improved soil biodiversity will contribute to achieve the objectives to halt the decline of biodiversity by 2010 as laid down in the Communities Sustainable Development Strategy[68], the need to integrate biodiversity into soil policy[69] and support the Habitats Directive[70], aiming directly at preserving i.a. a number of terrestrial habitats that depend on specific soil characteristics, such as dunes, peat lands, calcareous grasslands and wet meadows.

The expansion of cities into the surrounding rural areas, known as urban sprawl, is an important concern of the Community policy on the urban environment and relates to the Thematic Strategy on the urban environment [71]. Activities aiming at limiting urban sprawl and ensuring the rational use of the land will contribute to reduce soil sealing.

Natural resources include both the raw materials necessary for most human activities often extracted from soil, and the different environmental media, such as air, water and soil, which sustain life. Careful management of the use of these resources is a basis for sustainable development as described in the Thematic Strategy on the sustainable use of natural resources [72].

Links to other Community policies

In the 2003 Common Agriculture Policy reform[73] obligatory provisions were introduced for farmers receiving direct payments to respect specific statutory management requirements and maintain land in Good Agricultural and Environmental Condition (cross compliance). Member States are required to define such (GAEC) at national or regional level, including for soil erosion, soil organic matter and soil structure through the establishment of standards. These standards concern minimum soil cover, minimum land management reflecting site specific conditions, the retention of terraces, standards for crop rotations where applicable, arable stubble management and appropriate machinery use. Furthermore, Member States are required to define a minimum level of land management with regard to livestocking rates and/or appropriate regimes, the protection of permanent pasture and the retention of landscape features.

These cross compliance standards should ensure a minimum level of soil protection for agricultural land receiving direct payments under the first pillar of CAP with respect to erosion, organic matter and compaction. However, in non-agricultural land, in agricultural areas where a higher risk of soil degradation occurs or where agricultural activities take place which are not subject to direct payments or certain rural development payments, additional measures provided for under this strategy will be necessary to reach its objectives. As regards rural development, some Member States have used, in the current programming period, i.a. the agri-environmental measures to combat various soil threats. They will have this possibility again in the next programming period (2007-2013). In addition, the baseline for most of the measures of Axis 2 of the new Rural Development Regulation will be cross-compliance at the minimum.

Structural fund programmes have as a general and compulsory objective to contribute to sustainable development, and many measures in these programmes contribute directly or indirectly to the protection of soil. Examples are erosion and flood prevention, rehabilitation of derelict and polluted land and measures for sustainable tourism and leisure. Identification of risks areas for the different soil threats, an inventory for contaminated sites and mechanisms to finance the remediation of “orphan sites” will be valuable to make funding more efficient.

Soil legislation of important trading partners

Several important trading partners of the EU, such as Australia, Brazil, Canada and the United States, have addressed soil protection in different, although quite substantial ways:

- Soil erosion and desertification have also been recognised as important issues in Brazil, where i.a. public authorities are obliged to fight against soil erosion and to assure and monitor rational use of soils. A map with areas at risk of desertification has also been developed. In the United States, a Soil Conservation Act was agreed already in 1935, and the Soil Conservation Service, predecessor to the Natural Resources Conservation Service, began working already in 1933 with farmers to prevent erosion.

- Salinisation has been identified as one of the most significant environmental problems in Australia, where it has been addressed via a National Action Plan endorsed in 2002. Its objective is to prevent, stabilise and reverse trends in dryland salinity and to improve water quality.

- Regarding contamination, Australia has drafted guidelines on prevention, management and remediation at national level, while management of contaminated sites is carried out at regional level. In Brazil, regulations have been developed, addressing i.a. the remediation of contaminated sites and emphasising the polluter pays principle. In the United States, the Comprehensive Environmental Response, Compensation, and Liability Act, commonly known as Superfund, created in 1980, provides i.a. for liability of persons responsible for releases of hazardous waste and established a tax on the chemical and petroleum industries. The money is used for cleaning up abandoned or uncontrolled hazardous waste sites. Canada addresses soil contamination by its Environmental Protection Act.

In addition to the legislation listed above, many non-EU countries are also parties to the international conventions and protocols mentioned in this impact assessment and are consequently implementing the different obligations therein.

Current use of market based instruments

The Commission investigated the current use of market based instruments (MBIs) to protect soils in the EU and elsewhere[74]. Indeed in some environmental areas, MBIs have shown to be a valuable alternative to regulation and have a large potential for cost-effective environmental improvement. The results show that, at present, the use of these instruments is largely confined to erosion and contamination with the dominant instrument-type being subsidies. Examples of other MBIs, such as taxes, charges and tradable permits, are few and there is very limited information on the cost-effectiveness of the instruments. With the present data and knowledge gaps, the Commission considers that the introduction of such instruments at the European level is not appropriate at this stage. However, the Commission encourages the Member States to make use of such instruments in the implementation of the strategy.

Conclusions

Different Community policies contribute to soil protection, particularly environment (e.g. air and water) and agricultural (agri-environment and cross-compliance) policy. For instance, land management practices such as organic and integrated farming or extensive agricultural practices in mountain areas can maintain and enhance organic matter in the soil and prevent landslides respectively.

Achieving the objectives of the Water Framework Directive will entail changes in practices in soil management and the protection of some soils, but only where soil degradation hinders water quality. It addresses soil as far as it is a pressure to water but does not provide a protective regime for soil in all circumstances, does not cover all threats to soil thus does not ensure a sustainable use of soil as an essentially non renewable resource in Europe.

Though significant benefits can be expected from linking the direct payments to farmers to the application of some soil-friendly agricultural practices, these measures are not obligatory everywhere, they are just a precondition to receive payments for the farmers who are under the payment regimes (not all markets are under these regimes). Some farmers do not receive payments hence are not bound to adopt these soil-friendly practices. Cross-compliance will only contribute to the soil preservation in a partial way.

These provisions in favour of soil protection are spread across many areas and, to the extent that they often aim to safeguard other environmental media, do not constitute a coherent soil protection policy. This means that even if exploited to the full, existing policies are far from covering all soils and all soil threats identified.

There are different approaches to soil protection in the Member States and the level of progress in soil protection varies enormously between the Member States. Some being fairly advanced, some being at early stages.

The major conclusion therefore is that given that soil degradation continues (and even accelerates at some point) the existing policy framework does not guarantee the high level of protection to soil and the environment that the European Union has committed itself to achieve; it is simply not enough.

OBJECTIVES OF THE STRATEGY

Soil performs many functions and services vital to human activities and ecosystems survival. Indeed, soil provides us with food, biomass and raw materials. It serves as a platform for human activities, landscape and heritage, while it has also a role as a habitat and gene pool. It performs the storage, filtration and transformation of energy and many substances including water, nutrients and carbon, and constitutes the major carbon store in the world.

The general objectives

The variety of functions, the difficulty to define soil quality standards due to the variability and complexity of soils, the specific features of soils and the range of degradation processes to which they are subject, require a comprehensive approach to soil protection based on the general objective of preservation of soil functions rather than soil quality standards. Consequently, the guiding principles for the protection of soil within this common objective are:

6. Preventing further soil degradation and preserving its functions:

7. when soil is used and its functions are exploited, action has to be taken on soil use and management patterns, and

8. when soil acts as a sink/receptor of the effects of human activities or environmental phenomena, action has to be taken at source.

9. Restoring degraded soils to a level of functionality consistent at least with current and intended use, thus also considering the cost implications of the restoration of soil.

Specific objectives

Most of the soil threats represent risks in specific areas. These are linked to natural conditions (climate, topography, soil type etc.) and to human activities. Identification of different risk areas and contaminated sites within the EU territory will therefore be necessary as a first step, followed by the setting of risk reduction targets and adoption of measures to achieve such targets and the overall general objectives.

For soil sealing, a risk approach is not suitable, as sealing is intentionally caused and normally subject to planning decisions.

Link to other policies and previously established objectives

As described in section 2.3, different policies can contribute to the protection of soils. Reciprocally, as soil interacts with all other media, the achievement of the objectives to protect and restore its functions will undoubtedly allow achieving objectives set out in other Community policies and international agreements, for instance as regards water quality, nature protection or climate change mitigation.

As recognised by the Commission in the Thematic Strategy on the sustainable use of natural resources[75], the sustainable use of resources is hence a key ingredient of long-term prosperity, both within the EU and globally. Indeed, the EU Strategy for Growth and Jobs[76] endorsed by the Spring Summit of 2005 (revised Lisbon strategy) gives high priority to more sustainable use of natural resources. The Thematic Strategy on soil protection is a contribution to that challenge. Moreover, the recently reviewed Sustainable Development Strategy (SDS)[77] has set the objective of safeguarding the earth’s capacity to support life in all its diversity and respect the limits of the planet’s natural resources. As soil is an essentially non-renewable resource of common vital interest throughout the EU, the Thematic Strategy on soil protection will contribute to reaching that objective.

Need for EU action

As mentioned in chapter 1, the 6th Community Environment Action Programme requires the development of a Thematic Strategy on soil protection “addressing the prevention of, inter alia , pollution, erosion, desertification, land degradation, land-take and hydrological risks taking into account regional diversity, including specificities of mountain and arid areas”.

The Institutions have broadly welcomed the analysis and proposals for solution contained in the 2002 Communication launching the debate on soil protection at EU level. In particular, the Council:

- underlined the need for appropriate Community action to protect soil and provide for its sustainable use. It should take already existing Community policies and measures and subsidiarity appropriately into account;

- considered that the proper functioning of the single market may require also a common approach to soil policy, insofar as its protection and remediation at all relevant levels may also affect competitiveness.

- requested the Commission to bring forward the Thematic Strategy for Soil Protection, based on an integrated approach and with a comprehensive and long-term perspective with a view to maintain the vital functions of the soil, which should include where appropriate relevant qualitative and quantitative targets and timetables, general principles for assessing and managing the threats, as well as identify actions for its implementation, including appropriate sustainable use and soil protection measures. It should also consider the possible long distance degradation effects of some human actions including inappropriate soil management, in particular through water and air pollution.

While the request of the Institutions to the Commission to address soil protection at EU level needs to be acknowledged, at the same time the Commission believes that important reasons call for an intervention at EU level, such as:

- Soil degradation affects other environmental areas for which Community legislation exists. Failure to protect soil will undermine sustainability and long-term competitiveness in Europe. Indeed, soil is interlinked with air and water in such a way that it regulates their quality. In addition soil functions enormously contribute to areas such as biodiversity and marine protection, coastal management, and to the mitigation of climate change.

- Distortion of the functioning of the internal market – the wide differences between national soil protection regimes, in particular as regards soil contamination, sometimes impose very different obligations on economic operators, thus creating an unbalanced situation in their fixed costs. The absence of such regimes and the uncertainty as regards the extent of soil degradation can, in some cases, also hinder private investment. The Directive on environmental liability[78] creates a harmonised framework for the liability regime to be applied across Europe when land contamination creates a significant risk to human health. However, it does not apply to historical contamination or damage prior to its entry into force.

- Impacts in other areas – soil degradation has negative impacts on other areas also considered of common interest, such as quality of air and water, biodiversity and climate change.

- Transboundary impacts – soil, though generally immobile, is not completely so and therefore degradation in one Member State or region can have transboundary consequences. Losses of soil organic matter in one Member State impair achievement of the EU’s Kyoto Protocol targets. Dams are blocked and infrastructure is damaged downstream by sediments from massive erosion further upstream in another country. Groundwater in bordering countries is polluted by contaminated sites on the other side of the border. Therefore it is of outmost importance to act at source to prevent damage and subsequent remedial actions, otherwise costs to restore environmental quality may be borne by another Member State.

- Food safety – uptake of contaminants in the soil by food and feed crops and some food producing animals can have an impact on the safety of products which are traded freely within the internal market by increasing their level of dangerous substances and, hence posing a risk to human or animal health. Acting at source and at European level, by preventing soil contamination or reducing its level, will complement the safety controls performed to ensure feed and food safety. Indeed food safety legislation imposes some maximum contents for a limited number of contaminants, and these limit values are established taking into account not only the daily tolerable intake but also the environmental background concentration, in order to realistically ensure food supply. Moreover, food and feed controls are carried out on a limited number of samples chosen at random, hence there is no obligation to check all the food and feed put on the market.

- International dimension – soil degradation is receiving increasing attention in international agreements and charters. By establishing an appropriate and coherent framework which will translate into better knowledge and management of soil, the EU can play a leading role internationally, facilitating the transfer of know-how and technical assistance whilst at the same time ensuring the competitiveness of their economies.

- The Community acquis has not hitherto sufficiently ensured soil protection – although different Community policies can be expected to contribute to soil protection (see section 2.3.3), provisions concerned are fragmented and do not represent a coherent soil protection policy. Hence, soil degradation continues.

In addition, action at EU level will also have an added value by contributing to the protection of the health of European citizens that can be impaired in different ways by soil degradation, for instance because of exposure to soil contaminants by direct ingestion (children in playgrounds) or indirect intake (through contaminated food or drinking water). Equally, casualties may occur in the event of landslides.

The Commission believes that, for all these reasons, there is a need for actions at EU level in order to ensure that the requirement of Art. 174 of the EC Treaty are met, because the objectives of the strategy cannot be sufficiently achieved by the Member States and can therefore be better achieved by the EU.

POLICY OPTIONS TO REACH THE OBJECTIVES OF THE STRATEGY

POSSIBLE OPTIONS

In order to assess which policy option is most appropriate to address the threats to European soils and therefore reach the strategy’s objectives, the following options, from less to more prescriptive, have been considered:

10. Member States are encouraged to take action under a general non-binding EU soil strategy.

11. A strategy containing a flexible Soil Framework Directive, setting common principles and objectives at Community level, leaving the identification of the areas and sites at risk, definition of targets and design of appropriate measures to Member States and regions. This should be complemented by fostering an improved knowledge base, in particular on soil biodiversity, and better awareness of soil issues as well as greater coordination between the various EU and national policies which impact on the soil (improved integration).

12. EU legislation for the different soil threats, setting also all targets and means at EU level. Monitoring, soil threats linked to land management (erosion, decline in organic matter and biodiversity, salinisation, compaction and landslides) and soil contamination being addressed in separate legal initiatives.

Which options have been rejected at an early stage?

Based on the analysis carried out in the previous sections, in particular chapters 2 and 3, and taking into consideration the views received during the stakeholder process, including a public consultation open to citizens, experts and organisations, the Commission is persuaded that options 1 and 3 are not appropriate for achieving the strategy’s objective for the following reasons:

Option 1: Member States are encouraged to take action under a general non-binding EU soil strategy

The option considered was that of non-binding action at EU level, where Member States would be encouraged to take action under a general non-mandatory EU soil strategy. Achieving soil protection requires actions to protect soil on supranational, national, regional and indeed local levels in order to succeed. However, the fragmented approach taken so far and the extent of the problem with the attached significant off-site and transboundary effects and costs to be borne by society demonstrate that the absence of a focused policy approach has not been sufficient in establishing comprehensive mechanisms to address the identified threats. This calls for a comprehensive approach to soil protection.

Option 3: The creation of EU legislation for the different soil threats, setting all objectives, targets and means at EU level

This option has been rejected for the following reasons:

- Soil is very variable regarding its general characteristics, but also with regard to its use in the socio-economic context. This makes is very difficult to establish general EU-wide soil quality standards and measures to address soil threats.

- Historically, some national, regional and local authorities have dealt with soil, generating significant knowledge on where and how to address soil protection in their particular areas. It seems therefore appropriate that full use is made of this experience.

- Detailed and harmonised data and information at Community level on soil degradation is limited.

Which policy option has been considered?

Having examined the different options, the Commission proposes a Framework Directive as the best means of ensuring a comprehensive approach to soil protection whilst fully respecting subsidiarity. Member States will be required to take specific measures to address soil threats, but the Directive will leave to them ample freedom on how to implement this requirement. This means that risk acceptability, the level of ambition regarding the targets to be achieved and the choice of measures to reach those targets are left to Member States.

This option comprises a flexible Soil Framework Directive, setting common principles and objectives at Community level, complemented by fostering an improved knowledge base and better awareness of soil issues as well as greater coordination between the various EU and national policies which impact on the soil (improved integration). The impacts of this option have therefore been thoroughly analysed in this impact assessment.

Description of the option chosen

The different proposed actions within a Soil Framework Directive are:

Risk identification : For erosion, organic matter, salinisation, compaction and landslides, the extent of the areas at risk and the degree of risk for each of these threats need to be identified. This can best be done by the Member States themselves. Nevertheless, in order to ensure a coherent and comparable approach, the identification of risk must be carried out on the basis of common criteria. These criteria include parameters which are known to be driving forces for the different threats. Thus each threat is linked to its own set of criteria for the risk identification. Models can also be used to support risk identification. Member States will be able to build upon existing national inventories and monitoring schemes or Community programs such as CORINE Land Cover, LUCAS or BIOSOIL, but additional activities may be necessary to achieve a representative picture of state, impacts and pressures on soil in order to identify the risk areas. Risk identification implies the establishment of unacceptable levels of occurrence of the threats and acceptable risks may be very different between regions having different soil and climatic conditions.

For contamination, a definition of contaminated sites and a list of potentially soil polluting activities will be established at Community level. These would be the basis for Member States to locate sites which can potentially be contaminated, as a preliminary step to the establishment of an inventory of effectively contaminated sites, constituting the registry of all sites in the national territory for which an investigation has determined there exists a risk for human health or for the environment. This would be complemented by the obligation for landowners or prospective buyers to provide a soil status report for any transaction of land where a potentially contaminating activity has taken or is taking place.

Measures to reduce the risk : Having established the risk areas for erosion, organic matter decline, compaction, salinisation and landslides, Member States would then need to adopt risk reduction targets and programmes of measures to reach those targets. Such programmes may require measures of a compulsory or voluntary nature and cover different sectors such as the construction industry, forestry and agriculture, as appropriate. Programmes can build on standards and measures already identified and implemented in national and Community contexts, such as cross compliance, the codes of Good Farming Practice and Action Programmes under the Nitrate Directive, the future measures under the river basin management plans of the Water Framework Directive and international standards, such as the Pan-European Indicators for Sustainable Forest Management[79]. These programmes may include measures co-financed by the Community, and will strengthen and possibly encompass the efforts currently done by Member States to comply with the obligations under the UN Convention to Combat Desertification.

For local contamination, Member States will have to establish National Remediation Strategies aiming at reducing soil contamination and the risk caused by it. These plans will be based on the inventory of contaminated sites, and on a sound and transparent prioritisation of the sites to be remediated, including timeframes, targets and allocation of resources.

Soil sealing : With regard to soil sealing, a risk approach is not appropriate. Instead, a national or regional approach is proposed, requiring Member States to take the appropriate measures to limit sealing or to mitigate its effects.

Precautionary measures : Soil is, in contrast to air and water, mainly privately owned in the European Union, nevertheless it is a natural resource that has to be protected for future generations to ensure that it is used in a sustainable manner.

Diffuse contamination : In order to make full use of the prevention principle, Member States will be required to take measures to limit the introduction of dangerous substances into the soil, in order to avoid accumulation in soil that would hamper soil functions and create a risk to human health and the environment.

The Commission also proposes the following non-legislative actions, which will not be included into the Soil Framework Directive but will be part of the strategy :

Biodiversity : Measures adopted by Member States to combat the various soil threats will equally contribute to protect and restore soil biodiversity. In addition to this, the Commission proposes to address the existing knowledge gap on soil biodiversity, with a view to take targeted actions if appropriate at a later stage.

Research and awareness raising : There is a need to increase the general knowledge basis and the awareness from the general public, administrations, civil society and economic operators on the importance of soil and soil functions. Mechanisms to improve such knowledge are i.a. research activities, exchange of information and best practices. The Commission therefore proposes that initiatives should be fostered at EU and national level to improve the general knowledge on soil.

Integration : As soil is in many cases the recipient/receptor of the environmental impacts of measures taken in other sectors, the Commission and Member States should continue to “act at source” and do their outmost to integrate soil protection aspects into other policy areas.

QUALITATIVE AND QUANTITATIVE ANALYSIS OF IMPACTS OF OBLIGATIONS SPECIFIED IN THE SOIL FRAMEWORK DIRECTIVE

Introduction

In the proposed Directive, there are a series of specified obligations aimed at a shared objective which is the identification of the location and extent of the problem of soil degradation and the obligation to act upon it. These obligations are:

- Identification of risk areas for erosion, SOM decline, salinisation, compaction and landslides

- Adoption of a programme of measures for these areas

- Development of an inventory of contaminated sites

- Adoption of a National Remediation Strategy.

- Establishment of a Soil Status report

- Development of a mechanism for funding the remediation of ‘orphan sites’.

- Increasing Awareness raising

- Giving priority to the rehabilitation of brownfield sites and the use of soil saving construction techniques

In this chapter, the impacts of these obligations are assessed qualitatively and, when possible, quantitatively.

However, the proposed Directive will finally require Member States to take specific measures to address soil threats, but it leaves to Member States the freedom to implement this requirement. This means that risk acceptability, the level of ambition regarding the targets to be set and the choice of measures to meet these targets are left to Member States. Therefore the impacts of the proposed Directive cannot be assessed to the full extent. Measures taken by Member will be more or less radical depending on their level of ambition and the severity of the soil degradation process. Qualitatively , the environmental, economical or social impacts of possible measures may be similar. On the other hand, quantitatively , the impacts of possible measures vary enormously depending on the approach and measure taken. Therefore it is not possible within the scope of this impact Assessment to assess all the particular impacts of such specific measures. Hence, in chapter 8 only a general qualitative impact assessment of possible measures to combat soil degradation has been provided.

Nevertheless, in order to support and facilitate decision making, the Commission has made an effort by means of different scenarios analysis to attempt to quantify the environmental, economic and social impacts of possible measures. These scenarios are constructed on the basis of expert guess and limited available information from Member States instruments currently in place to address soil degradation. Annex 1 includes this quantification of impacts of the scenarios.

These scenario-generated figures are under no circumstances to be looked at as the real implementation costs of the Soil Framework Directive . They are only presented as an Annex to this Impact Assessment for illustrative purposes.

Establishment of risk areas and programmes of measures for erosion, SOM decline, salinisation, compaction and landslides[80]

Costs of options considered for risk area identification

On the basis of accurate soil data, policy makers are able to establish adequately the risk areas.

Three main options were considered:

13. For the risk area identification, use solely the current monitoring schemes Member States have already undertaken.

14. Fully harmonise risk identification in Member States through a 16x16 km grid for the purpose of both general soil state monitoring using general soil parameters and monitoring of the various soil threats using so called stratified soil parameters. This option is to be regarded as the most ambitious scenario.

15. Use a monitoring approach targeted to the identification of risk areas.

The costs of options 2 and 3 have been compared to the option 1.

Option 1: Current status of risk area identification in Member States

The current soil monitoring activities are considered to be the no-action scenario for this impact assessment[81]. At the moment some countries (33%) already monitor several of the soil parameters considered necessary in this option (as recommended by the Working Group Monitoring[82]), whereas other countries (10%) hardly measure any data at all.

A brief overview of existing soil information in EU25

Soil surveys are well established in all countries in Europe. They have traditionally been developed to support agricultural development and the planning and organisation of crop production as well as for environmental purposes. They include plot level samplings and the production of soil maps at various scales.

Currently, a harmonised soil mapping approach in the scale 1:250,000 is proposed by the European Soil Bureau Network (ESBN). Such mapping is already underway in several European countries on a voluntary basis and at their own cost. The classification system has been agreed to follow WRB[83], and the scale has been clearly defined as well. Therefore, the resulting maps are expected (a) to show strongly reduced border effects, (b) to allow the definition of a harmonised soil map legend, and (c) to gather better harmonized attribute data.

The investigations of the Working Group Monitoring and the EEA show that a large number of plots have been designated to fit monitoring requirements. However, the sampling and analytical schemes differ quite substantially, which restrict their value for Europe-wide assessments.

The need for soil information, e.g. in agriculture, environmental and research policy, is strongly increasing. The demands can only be fulfilled if soil inventory data, and mapping and monitoring data, are readily gathered into soil information systems. This has been recognized by many countries. However, current resources still concentrate on making existing data usable on a digital basis. Until now, the development of a soil information system (maps, plot inventory data including monitoring) is still the exception.

The availability of national evaluations with regard to occurrence and impacts of soil threats varies greatly within EU25. Member States generally have evaluations regarding only a limited amount of soil threats, some even not having any evaluation at all. However, a more intensive evaluation of the existing soil inventory data is still needed to fully explore the information available and that can best be done by Member States.

Costs

This option does not incur in additional costs.

Option 2: Fully harmonising risk identification in Member States through a 16x16 km grid

Option 2 considers a fully harmonised system of monitoring in a 16x16 km[84] grid for inventory data (parameters on general information on soil to be monitored at all grid points) and for stratified parameters (parameters related to the threats to be monitored in points in risk areas only).

Monitoring should be repeated periodically to keep data updated. It has been assumed, based on their variability over time, that the inventory parameters are measured once every 50 years and that the stratified parameters are measured every 10 years.

Costs

The costs per Member State are calculated based on costs for fieldwork, average prices for analyses and tests, and the number of sites. Complex erosion measurements in the field are not considered, since they are performed rarely (use is made of modelling instead), the results vary enormously and they are very expensive and thus would give a distort view on the costs.

The additional costs for this option are the result of the total costs for soil monitoring under such grid minus the expenditure already incurred by Member States for monitoring.

The additional costs of installing a 16x16 km monitoring grid are about €97 million higher than the current expenditures. For a 50 year period for EU25, that represents €2 million annually.

As regards administrative costs linked to the risk area identification (e.g. additional personnel developing or refining the models and carrying out the risk area identification), the Commission has made several attempts to estimate them, but inquiries amongst experts from Member States have not resulted in gathering sufficient data to do so.

Option 3: Monitoring targeted to the identification of risk areas

Option 3 implies that Member States identify risk areas under common criteria by using as much as possible the data they have already gathered or which they would gather in any case in a no-action scenario. However, in case this is not sufficient to meet the criteria, Member States would have to collect the remaining necessary information.

Costs

From the overview on existing soil information presented above, it was concluded that most of the current soil information cannot be used in an aggregated way in order to establish risk areas. Compared to option 1, additional costs may therefore still be needed to complete/develop an operational soil information system equipped with the necessary methodologies and targeted at the specific aims.

Compared to option 2 (harmonised monitoring in a grid system), an estimate of the savings by using as much as possible already existing soil information is not possible at this stage. A more intensive evaluation of the existing soil inventory data with a view to use them for the risk area identification is still needed and can best be done by Member States or regions themselves. However, the costs for option 3 are likely to be significantly lower than the costs identified for option 2, less than €2 million per year for EU25.

The option chosen

From the overview on existing soil information it can be concluded that although Member States are already monitoring soil for a series of reasons, there is little relation between existing monitoring schemes and identified soil threats. Thus, the existing monitoring schemes are considered unfit to support the objectives of the strategy. Therefore, option 1 was rejected as a policy option. However, information on existing monitoring schemes has been used to define as efficiently as possible options 2 and 3 and to monetise their additional costs.

While the additional costs for full harmonisation (option2) of around €2 million per year for EU25 are not very substantial, such a harmonised monitoring approach would have administrative impacts, as Member States would need to modify their current monitoring systems and might not be able to use already acquired data. Indeed, such a harmonised system would involve the loss of continuity with existing monitoring systems which are very valuable tools to be used in soil protection policy development. The benefits of such a fully harmonised system for the risk identification were not sufficiently clear to justify this approach. Therefore, option 2 was abandoned.

The option chosen therefore is option 3: Monitoring targeted to the identification of risk areas. The additional costs for this option are less than €2 million per year for EU25.

Benefits of identifying risk areas

From a targeted soil monitoring scheme, resulting in risk areas, generally two main benefits would arise:

- It would allow targeting the measures to combat the soil threats where they are needed, hence making an efficient use of resources.

- It would allow controlling the effectiveness of these measures to preserve and improve soil functions.

Expenditures on measures provide more value for money if measures are based on sufficient and effective monitoring.

Establishing a Programme of Measures

Based on the identified risk areas, Member States will establish a Programme of Measures. The costs involved are purely administrative. Despite several attempts, it was not possible to gather information on the administrative costs of adopting a programme of measures for EU 25. Therefore they could not be further monetised.

The implementation of these programmes, once they are adopted, involves taking appropriate measures to meet the level of ambition and targets set therein. As mentioned, above Chapter 8 provides a general qualitative analysis of the impacts of possible measures, while Annex 1 provides a scenario-based quantitative analysis of their impacts.

Establishment of an inventory of contaminated sites and of a National Remediation Strategy

The inventory of contaminated sites

This measure would require Member States to identify and include in an inventory the contaminated sites in their national territory. Table 5 presents the main steps that could be followed to set up such an inventory. The process starts by establishing a definition of contaminated sites and by the identification of the potentially contaminated sites through a list of potentially contaminating activities, followed by a more in depth analysis to assess if contamination really occurs and if there is risk for human health and the environment.

The definition of contaminated sites

Two options for the definition of contaminated sites to address contamination have been considered:

- a definition based purely on the concentration of contaminants in the soil,

- a definition based on risk to human health and the environment.

With regard to the first of these options:

- Advantages: with a definition based on concentration values, the identification of contaminated sites would be more straightforward (analytical analysis and no risk assessment), and more transparent, though the maximum concentration limit values would also be risk based, and there would be no need for a long term monitoring of the evolution of the risk.

- Disadvantages: a definition based on concentration values would imply that the number of sites falling under the scope of this definition could be much higher and the costs of the management of the contaminated sites would also be much higher. Issues could also arise concerning naturally occurring concentrations above limit values.

With regard to the second:

- Advantages: this definition would allow making a prioritisation of the sites based on risk which would allow managing historical contamination without disproportionate costs.

- Disadvantages: a risk based approach requires long term monitoring to survey if the land use and the risk has changed, it also can trigger some public opposition as the notion of risk is perceived sometimes (e.g. by the public and insurance companies) as a softer or subjective approach which entails more uncertainty.

Currently, the majority of the Member States, which have legislation on soil contamination, use a risk based definition where the risk is assessed taking into account the current use of the land. It is proposed to take this second option.

Establishment of a list of soil polluting activities

The list of potentially polluting activities is used as a management tool in order to identify and locate sites where there is a risk that contamination has occurred. Introducing a common and comprehensive list ensures a wider coverage and a systematic and coherent approach and avoids that many contaminated sites may be missed in the inventory because the activity causing them was overlooked.

Some Member States have established at national level a list of potentially polluting activities to address soil contamination. Nevertheless, an analysis of the activities included in some of these national lists[85] revealed that there are large differences between these countries, though some industrial and commercial activities were common to all the lists.

A common list of potentially polluting activities would overcome the differences between Member States and would provide a common approach for the same sector across the EU, thus precluding a distortion of competition.

Establishment of an inventory of contaminated sites

Thirteen Member States have already started to draw up their inventory of contaminated sites, but none has finished yet. The differences in progress between Member States are very significant.

Table 5: Steps to set up an inventory of contaminated sites[86]

Preliminary survey | On the basis of available information, a preliminary survey has the aim of assessing whether potentially polluting activities have taken place and whether contamination can be expected. As a result of the preliminary survey, a site will, in most cases, be classified as potentially (suspected to be) contaminated or not contaminated. |

Preliminary site investigation | Preliminary investigations are carried out to confirm the existence of contamination. In most cases, the results of the preliminary investigation form the basis to definitely classify sites as being contaminated. A variety of issues will influence the results of a preliminary investigation, as for example: sampling patterns, number and type of samples, depth of the boreholes, quantity of the samples, transport and storage of samples, selection of substances to be analysed, treatment of samples. |

Main site investigation | A main site investigation is carried out to determine the need for remediation or other measures to eliminate or reduce exposure to the contaminants. Major goals are: to define the extent of the contaminated area and the degree of contamination; to assess the risks of the involved impacts. |

Remediation activities | This covers the time from the start of taking measures to reduce the environmental impact to the moment that monitoring of environmental media has proven that the agreed remediation targets have been met. |

Costs

The preliminary survey represents the very start of the inventory process. It consists mainly of a desk study on available information, based on which potentially contaminated sites are identified. According to the Soil Framework Directive, this stage will be needed to be carried out within 5 years after its transposition.

For this first phase, the total costs for EU25 could be monetised on the basis of available information from:

- 13 Member States which have already carried out or are currently carrying out such a preliminary survey, and

- the Dutch inventory ‘Landsdekkend Beeld’, which is basically a desk study. Available information was used to carry out an extrapolation for EU25 on the basis of artificial surface.

It is assumed that the 13 Member States mentioned above have already accomplished on average about 25% of the total identification of contaminated sites and that they will in any case carry out this work since they have already started (see Annex 1).

Therefore, expenditure already incurred by these Member States has been subtracted from the total costs. The estimated total additional costs for the preliminary survey are €255 million or €51 million per year for EU25 for the first five years after the transposition of the Soil Framework Directive. Table 6 shows the results.

Table 6: Estimated additional costs to establish a preliminary survey (first five years)

Costs of preliminary survey | €680 million (a) |

Expenses already incurred and identification already carried out by 13 Member States (25% of the total) | €170 million (b) |

Already planned expenditure in Member States is 50% (since 13 Member States will continue) | €255 million (c) |

Additional costs for EU25 (a - b- c) | €255 million or €51 million per year (for five years) |

This first stage, preliminary survey, will be followed by a second stage, the preliminary site investigations to confirm the actual presence or absence of contaminants on the identified potentially contaminated sites.

Based on the outcome of the preliminary site investigation, the sites can be identified where the concentration levels of dangerous substances are such that there may be sufficient reasons to believe that they pose a significant risk to human health or the environment. On these " suspected" sites, as a third stage; full site investigations , will have to be carried out, including a risk assessment, to conclude if there is indeed a serious risk to human health or the environment. If so, then the site will be classified as contaminated sites and introduced in the inventory.

For the second and third stages of the inventory, the estimate of the costs for EU25 ideally should be made by multiplying:

the number of " potentially contaminated sites" x average costs of preliminary site investigation [€1,300 to 4,900, average €3,100]

and by multiplying

the number of " suspected contaminated sites" x average costs for full site investigation (incl. on-site risk assessment) [€5,200 to 19,600, average €12,400].

However, at present the number of potentially contaminated sites, let alone the number of contaminated sites, for EU25 is unknown. Therefore, to illustrate possible costs for site investigations, Annex 1, part 2 provides an estimate of the additional annual costs based on a scenario approach. According to the outcome of this scenario, the annual additional costs for the site investigations may amount up to €240 million for EU25 for the full 25 year period provided for the completion of the inventory. The additional annual costs of the inventory of contaminated sites are summarized in Table 7.

Table 7: Estimated annual additional costs for EU25 to establish a complete inventory of contaminated sites

Costs of preliminary survey | €51 million per year for the first 5 years |

Costs of preliminary and main site investigation | Up to €240 million per year for 25 years |

These estimated costs must be regarded as an upper bound estimate for the following reasons: