4.3.2022
EN
Official Journal of the European Union
C 105/145
3.2.
The EESC supports the Commission’s plan and its flagship initiatives to address the various types of pollution in a holistic way and to comply with the commitments of the Paris Agreement and the SDGs.
For it to be a truly ambitious plan, the targets must be fully in line with the recommendations of the WHO.
3.3.
The EESC endorses the approach of strengthening existing legislation in different areas and adjusting it where it has not been successfully implemented, for example with regard to water and air quality.
We reiterate that EU environmental policy reveals that poor, fragmented and uneven implementation of the EU environmental legislation is a serious problem in many EU Member States (4).
Moreover, there is no lack of knowledge about what needs to be done.
What is lacking is the implementation of well-known measures, often decided upon long ago, as well as political will (5).
3.4.
The EESC urges the Commission to start collecting data so that it can make legislative proposals soon in areas where they are lacking, such as light and vibration pollution.
3.5.
The extent to which the targets have been met will be assessed on the basis of the monitoring and outlook findings for 2024.
This will open the debate evaluating the level of ambition and, if necessary, revising objectives and legislation more thoroughly.
The EESC fears that this process will be too long given the short amount of time left to achieve the 2030 targets, and believes that they should be made more ambitious from the outset, that is to say now.
3.6.
The air pollution targets set for 2030 are based on reference years from too long ago.
The reference years are different for the different targets because they are based on different data and legislation.
While long periods of cumulative data clearly make it easier to make projections, the EESC believes that the start of the time period used to assess progress towards targets should be aligned for all the targets in order to obtain a realistic picture of the degree of compliance.
3.7.
The right enabling framework must help businesses and SMEs to implement pollution control legislation while keeping administrative burdens to a minimum.
There is also a need for a harmonised international regulatory framework, as EU pollution does not stop at borders.
3.8.
The EESC believes that cooperation between sectors is essential to bring about the transition.
It therefore welcomes the establishment of the Zero Pollution Stakeholder Platform and would like to collaborate through the European Circular Economy Stakeholder Platform and other means.
It also recommends establishing close cooperation with third countries and spaces for cooperation between civil society in the different regions, as pollution has no borders.
4.
Specific comments 4.1.
EU support for innovation, investment and research on new equipment and technologies is important for all businesses and to create new quality jobs.
However, investment is needed in nature and biodiversity (ecosystem restoration and regenerative agriculture); prosperity (sustainable infrastructure and renewable/energy transitions, buildings and green/public mobility); and people (education and bridging the digital divide/R & D, tax reforms to create fairer and more equitable opportunities in education, health and the environment).
4.2.
The EESC regrets that, in the zero pollution hierarchy, remedying and offsetting pollution-related damage is given less consideration.
The polluter pays principle has not proved to be very effective, as shown by the high number of contaminated sites that still exist in the EU.
Measures need to be defined for when polluters cannot be identified or cannot offset the damage.
4.3.
With regard to air pollution, the EESC draws the Commission’s attention to particulate matter (PM), which is linked to millions of premature deaths worldwide.
A standardised metric for assessing the toxicological effects of PM on human health should be established based not just on mass concentration but on size and chemical composition as well.
When assessing sources of PM, their oxidative potential and ultrafine particles are important, as how dangerous they are depends on that, and they should be included in legislation and PM pollution monitoring.
(4) (5)
OJ C 110, 22.3.2019, p. 33.
OJ C 123, 9.4.2021, p. 76.