Council of the
European Union
Brussels, 4 March 2015
(OR. en)
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2013/0443 (COD)
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From:
To:
General Secretariat of the Council
Delegations
No. Cion doc.:
18167/13 ENV 1235 ENER 600 IND 388 TRANS 693 ENT 356 SAN 555
PARLNAT 325 CODEC 3086 - COM(2013) 920 final
Subject:
Proposal for a Directive of the European Parliament and of the Council on
the reduction of national emissions of certain atmospheric pollutants and
amending Directive 2003/35/EC
-
Comments from delegations
Delegations will find in the Annex comments from Croatia on the International Institute for Applied
Systems Analysis (IIASA) TSAP reports nº 16A and 16B on "Adjusted historic emission data,
projections, and optimized emission reduction targets for 2030", presented at the Working Party on
the Environment (WPE) meeting on 27 January 2015.
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Croatia finds as very useful the bilateral consultation during IIASA exercise that was held during
2014 in order to narrow the differences between emissions in the GAINS and national system. In
the exchange of information the key differences were recognised and both sides strived to improve
its calculation. The TSAP#16 Report provides a step of improvement, but there are still some issues
opened for Croatia.
We think that more time is needed for analysis of projection data and implication of this projections
and ceilings to the national economy and development. In our opinion, the agreed Gothenburg
protocol revised reduction targets are already challenging and setting of reduction targets for 2030
is considered as premature. Nevertheless, Croatia supports very early consideration and analysis of
options, exchange of information and views about them.
In our view, the non-GHG emission reduction pathway up to 2030 substantially depends on the
climate-energy framework for 2030, both on the EU and national level. We have started to prepare
(to be adopted during 2015) the Low-carbon Development Strategy in parallel with our Programme
for emission reduction of certain air pollutants which will define actions for the path to meet the
new Gothenburg protocol revised reduction targets.
In our opinion, the uncertainty of results is significant, related not only to the emission part but also
to the critical threshold data. Croatia would like to understand more the influence of critical
threshold data uncertainties since we have no capacity to follow the new development in modelling
and mapping and were unfortunately not able to respond to the last CCE ‘call for data’.
We would like to emphasise that socio-economic implications of the emission reduction in
agriculture sector for us are very high. The farm structure in Croatia contains an extremely large
number of small family agricultural holdings, which are on the edge of economic viability. Rural
areas in Croatia are suffering from emigration and ageing. In this context, reduction of NH3 will be
a very challenging issue, taking into account our current level of agriculture performances and
compliance status of Croatia regarding that pollutant. Reoptimised calculation in the TSAP#16
Report led to an increase of the NH3 emission target for +1%. Although the bilateral consultation
resulted in considerable narrowing of the NH3 emission in 2005, the difference is still 5%.
The reoptimised reduction target for NMVOC emissions has also increased, from 48% to 50%.
Additionally, it can be noted that the national total of NMVOC emissions is underestimated because
the national inventory, for now, does not include the calculation of NMVOC emissions from
manure management. In 2014 the NMVOC emission factors for agriculture were defined and
included in the guidebook. The inclusion of missing NMVOC emissions will certainly lead to an
increase in the national NMVOC total. Accordingly, these emission factors have not yet been
included in the GAINS model, although this source will be a new key source in NMVOC emission
when implemented. Therefore, in the NEC negotiations Croatia has to consider, with caution, how
to include these emissions in the whole trend and how it will affect the proposed emission ceiling.
We believe that the feasibility of reduction measures for VOC emissions in agriculture is
questionable and still not documented.
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Croatia has no data on agriculture waste burning on open land, and this difference has been
recognised in the bilateral consultation and left open.
Finally, there is a trend in using more wooden fuel in Croatia, while only small part of households
use pellets, which will, most likely, lead to an increase of PM2.5 emission from the household
sector.
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