No C 248/14 Official  Journal  of the European  Communities 29.10.  75 
Community  have  as members  of the committee  in 
question.  The  European  Community  shall  not 
exercise  its right  to vote  if its Member  States 
exercise  their  right  to vote'. 3. The  Committee  recommends  that  the  'Draft 
statement  on the internal  procedures  relating  to the 
implementation  of the Convention'  (to be inserted  in 
the Council's  minutes)  should  be published. 
Done  at Brussels,  24 April  1975. 
The Chairman 
of the Economic  arid.  Social  Committee 
Henri  CANONGE 
Opinion  on the proposal  for a Council  Decision  establishing  a common  procedure  for 
the reciprocal  exchange  of information  between  the  surveillance  and  monitoring 
networks  based  on data  relating  to-atmospheric  pollution  by sulphur  compounds  and 
suspended  particulates 
The text  referred  to the  Committee  was  published  in the  Official  Journal  of the 
European  Communities  No  C 11 of 16 January  1975,  page  1. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 3 December  1974,  the  Council  referred  the  abovementioned  proposal  to the 
Economic  and  Social  Committee  under  Article  198  of the  Treaty  establishing  the 
European  Economic  Community. 
B. OPINION  OF THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  drew  up its Opinion  at its 129th  plenary  session, 
held in Brussels  on 23 and 24 April  1975. 
The Opinion  is published  below: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Haying  regard  to Article  198  of the  Treaty 
establishing  the European  Economic  Community; 
Having  regard  to the referral  on 4 December  1974  by 
the Council  of the  European  Communities  of the 
proposal  for  a Council  Decision  establishing  a 
common  procedure  for the reciprocal  exchange  of 
information  between  the surveillance  and  monitoring 
networks,  based  on data  relating  to atmospheric 
pollution  by sulphur  compounds  and  suspended 
particulates; Having  regard  to the decision  taken  by the Chairman 
of the Committee  on 10 December  1974  instructing 
the Section  for Protection  of the Environment,  Public 
Health  and  Consumer  1 Affairs  to draw  up  an 
Opinion  and a report  on the matter; 
Having  regard  to, the Section's  Opinion  of 11 March 
1975  and  the oral  report  made  by the Rapporteur, 
Mr Eboli; 
Having  regard  to the discussions  at the Committee's 
meeting  on 24 April  1975  (129th  plenary  session  of 
23 and 24 April  1975), 
29.10.  75 Official  Journal  of the European  Communities No C 248/15 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
with no votes  against  and 1 abstention: 
The Committee  approves  the proposal,  subject  to the 
following  comments. 
1. General  comments 
1.1. There  is no disputing  the proposal's  value  and 
it is to be hoped  that  the objectives  laid down  will  be 
achieved.  But there  are difficulties  in attaining  these 
goals  at present,  because  of the lack  of completely 
inter  comparable  data.  This  is due to the fact  that  the 
relevant  intercomparison  programmes  have  not  yet 
been  completed. 
1.2. But,  despite  these  difficulties,  this  initiative 
should  be encouraged,  above  all since  it will  make  it 
possible  to obtain  time-base  data  for specific  areas 
(so that  any  methodological  errors  will  be constant) 
plus useful  material  for  a more  effective 
anti-pollution  strategy. 
1.3. On  more  detailed  examination  of the proposal 
the Committee  notes  that  in the  explanatory 
memorandum  (first  paragraph)  reference  is made  to 
'sulphur  compounds'  and  'suspended  particulates'. 
Further  on in the text,  and  in the annexes,  sulphur 
compounds  are equated  with  sulphur  dioxide,  whilst 
in the case  of suspended  particulates,  black  smoke 
forms  a special  category.  Clearly,  the explanation  for 
this is that  sulphur-dioxide  pollution  is the typical 
form  of sulphur-compound  pollution  and  indeed  of 
pollution  in general,  and  that  solid  particulates  in 
suspension  consist  in some  cases  of what  is termed 
black  smoke.  It would  be desirable  to eliminate  the 
apparent  inconsistency  by inserting  '(and  in particular 
SO2)'  and '(consisting  in some  cases  of black  smoke)' 
in the  last  line  of the  first  paragraph  of the 
explanatory  memorandum,  after  'sulphur  com-
pounds'  and 'suspended  particulates'  respectively. 
2. Specific  comments 
The Committee  would  propose  the  following 
amendments. 
2.1. Article  1 
The Committee  proposes  that  the  terms  'sulphur 
compounds'  and  'suspended  particulates'  be clarified in the  same  way  as suggested  in respect  of the 
explanatory  memorandum. 
2.2. Article  2 
The criteria  set out in Annex  1 are not in all cases 
sufficient  to ensure  that  the Member  States  will  make 
selections  that  further  the objectives  of the proposal. 
Although  the nature  of the proposal  requires  that  the 
rules  should  be flexible,  it might  be useful  if the 
Member  States'  selections  were  examined  in advance 
by the Commission,  which  might  have  more  criteria 
at its disposal,  providing  a wider  frame  of reference. 
2.2.1.  The  Committee  therefore  proposes  that 
Article  2 be amended  to read: 
'Following  consultation  with  the  Commission, 
each Member  State  shall,  having  regard  to the 
criteria  set out in Annex  1 to this  Decision,  select 
from  existing  or  planned  sampling  and/or 
monitoring  stations  those  which  are to supply  the 
data for  the  exchange  of information.  It shall 
inform  the Commission  of its selection  by means 
of the form  set out in Annex  2'. 
2.3. Article  3 
In view,  among  other  things,  of the details  required 
in Annex  2 (Section  7), the Committee  proposes  that 
the word  'two'  be omitted  from  the first  line  of the 
first subparagraph  of Article  3 (1).  As regards  the 
second  subparagraph  of Article  3 (1), the Committee 
proposes,  in line  with  the remarks  made  above,  that 
the words  'sulphur  compounds'  be replaced  by 
'sulphur  dioxide'  and  that  the  words  'and  black 
smoke'  be added  after  'suspended  particulates'.  The 
second  subparagraph  of Article  3 (1) would  then 
read: 
'These  daily  averages,  for  sulphur  dioxide, 
suspended  particulates  and  black  smoke,  shall  be 
expressed  in microgrammes  per cubic  metre  of air 
at standard  temperature  and pressure'. 
2.4. Annex  1 
In line  with  its remarks  on Article  2, the Committee 
considers  that  'following  consultation  with  the 
Commission'  should  be inserted  before  the words 
'each  Member  State  shall  specify'  (Section  2). 
Done  at Brussels,  24 April  1975. 
The Chairman 
of the Economic  and  Social  Committee 
Henri  CANONGE