1. Some costs of inaction Prof. Mikael Skou Andersen, Aarhus University (DK)

2. Outline of presentation Implications of precautionary principle for socio-economic analysis Lead case: costs of inaction Drinking water nitrate: a case for risk analysis Outlook: green growth and technological innovation

3. Principles of EU environmental policy Precaution Prevention Polluter-pays TFEU art. 191.2 ”Union policy on the environment shall aim at a high level of protection taking into account the diversity of situations in the various regions of the Union It shall be based on the precautionary principle and on the principles that preventive action should be taken, that environmental damage as a priority be rectified at source and that the polluter should pay”

4. Precautionary principle in EU law Commission communication COM (2000)1 on the precautionary principle: ”The precautionary principle applies where scientific evidence is insufficient, inconclusive or uncertain and preliminary scientific evaluation indicates that there are reasonable grounds for concern that the potentially dangerous effects on the environment, human animal or plant health may be inconsistent with the high level of protection chosen by the EU” European Court: Paraquat case (Sweden vs. Commission T-229/04) ‘the existence of solid evidence, which while not resolving scientific uncertainty, may reasonably raise doubts as to the safety of a substance’, when interpreted ‘in combination with the precautionary principle’

5. Weak precautionary principle Rio declaration, principle 15 (1992) ”In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation” Adopted by 172 countries incl. USA ‘cost-effective’ vs. ’lack of scientific certainty’ ?

6. Socio-economic analysis European Union requirements Structural funds WFD art. 4: proportionality clause Revival: regulatory impact analysis Addressing safety, health and environment deregulation agenda: CBA Origin: US flood control act (1936) Addressing floods and economic crisis Roosevelt’s New Deal: ‘orderly process’

7. Will CBA get the answers right ? Costs of measures are usually fairly straight-forward to quantify and monetize Benefits of measures will depend on assessment of the risk in question – do we need ‘proof’ ? Need to quantify relations between cause and effect Need to value and monetize key impacts Critique (Ackerman and Heinzerling, 2005) “If today’s methods of CBA had been applied in the past, would it have given its blessings to the early regulations which now look so successful in retrospect?” No: “The technique would have gotten the answer wrong”

8. Knowledge Lack of knowledge Boundary between our knowledge and lack of knowledge Research and development From: Poul Harremöes

9. research effort is biased towards ‘established’ issues and problems

10. Case of Lead (Pb) Highly Toxic –Acute effects -> Saturnism Accumulates in –bones –brain –Liver Many chronic health impacts –Neurodevelopment (children) –Anemia (Adults) Biomarkers –Pb in blood (short term exp.) –Pb in urine (short term exp.) –Pb in bones (long term exp.)

11. Lead (Pb) accumulation in body Age Dependent Biokinetic Model –ADBM accounts for body burden –Specifies the contribution to Pb blood from inhalation CHILDRENS IQ-LOSS Pb blood / Pb air dependent of age dependent of exposure time Pb air - 1 Pb air - 3 Pb air - 2

12. IMPACT PATHWAY APPROACH Externe (2005) Methodology Local scale (MWCP as emission source) Long term conditions Danish conditions Quantification of Emission Modeling of Increment in Air Concentration Concentration- Response Function Monetary Evaluation of Impacts STEPS Atmospheric model Bio-kinetic model Loss of IQ points IQ loss / Pb blood function Exposed population FOCUS ONMODELS

13. REDUCED LIFETIME EARNINGS Cognitive impairments reduce income by 2-3% per IQ-point lost External costs of lead: €1.5/gram Pb (r=1.4%) Up to 1985: 1 gram of Pb per liter petrol imply annual social costs of 4-6 % of GDP (Schwartz 1993; Grosse et al. 2002; Pizzol et. al., 2010)

14. Implications of lead case No-threshold for impact on childrens IQ has been thoroughly documented Evidence triggered ban after 50 years of controversy Careful inspection of the early OSH evidence presented in 1925 suggests need for ban A CBA-framework extended with risk analysis

15. Drinking water nitrate case WHO guide value of 50 mgNO 3 /liter reflects acute toxicity; no safety factor IARC level 2A: probably carcinogenic to humans via nitrosation – chronic impacts Epidemiological studies suggest carcinogenic impacts >25 mgNO 3 /liter Which number for the benefits of avoided impacts to be used in SEA/CBA ?

16. European Environment Agency

17. 0.01 0.00 0.03 0.02 0.03 0.23 0.08 0.07 0.05 0.48 0.30 0.02 0.03 0.39 0.07 1.34 0.34 0.15 0.05 0.07 0.00 0.03 0.00 0.15 0.02 1.29 with illustrative health-related external costs €/kgN applied (NUTS1 averages; EXIOPOL)

18. Biogas: vehicle for nitrogen and climate innovation

19. Århus 23 November 2009 Pb in products Flow of Metals in waste

20. What role for precautionary principle ? Socio-economic assessment (incl. CBA) is often a mandatory requirement in providing support to decision-makers Careful screening of potential impacts (risk analysis) needs to be an integral part in considering cost-effective measures The precautionary principle places the burden of proof on the proponents of the activities in question, not on socio-economic analysis or the victims of pollution. A high level of protection is emphasised in TFEU.

22. European Environment Agency Reference Andersen MS and Clubb DO, 2013. Understanding and accounting for costs of inaction, Chapter 23 in Late lessons from early warnings: science, precaution, innovation, EEA Report No. 1/2013, Copenhagen: European Environment Agency. http://www.eea.europa.eu/publications/late-lessons-2#! http://www.eea.europa.eu/publications/late-lessons-2#