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CIAO DATE: 11/00

Implementing Stronger European Air Pollution Policies: Will high hopes in Brussels and Geneva be dashed in London?

Jørgen Wettestad

International Studies Association
41st Annual Convention
Los Angeles, CA
March 14-18, 2000


1. Introduction.

The politics of European air pollution control is changing (Wettestad, forthcoming 2000). Within the context of what may loosely be referred to as “the European air pollution regime”, with the Convention on Long-Range Transboundary Air Pollution (CLRTAP) and the EU as main components, there is a substantial recent increase in regulatory “strength”, “robustness” and “institutional coherence». One of the most important challenges for this “new” European air pollution regime is successful implementation of the substantially strengthened commitments . What are the chances then for such implementation success? And what are the main determining factors? This paper makes a first and very tentative effort to address these important questions.

Let us substantiate the various aspects in this picture a little bit. First, as to increasing regime strength: According to the recently adopted CLRTAP Gothenburg Protocol, by 2010, Europe’s sulphur dioxide emissions should be cut by 63%, its NOx emissions by 41%, its VOC emissions by 40% and its ammonia emissions by 40%; all compared to their 1990 levels. 2 Moreover, a draft EU National Emission Ceilings (NEC) Directive was launched in June 1999, targeting the same substances as the CLRTAP Protocol. If the Directive is adopted in its present form, with overall lower emission ceilings than in the CLRTAP Protocol, even further emission reductions can be envisaged. 3 Compared to the initial CLRTAP and EU commitments adopted in the 1980s, with for instance the 1988 CLRTAP NOx Protocol aiming for emissions stabilisation, this is a significant change. 4 Second, compared with the “flat rate” and “single substance” approach utilised in the CLRTAP protocols in the 1980s, a much more sophisticated approach is utilised in the recent CLRTAP and EU policy developments. Several substances and effects are entered into an ambitious modelling exercise, ending up in a complex web of differing national emission ceilings. 5 If we accept that this complex exercise means much more cost-effective and easily defendable policies than in the past, then it is quite likely that overall regime “robustness” is also increasing. Third, the «institutional coherence» of the European air pollution regime is increasing, in the form of an increasing and constructive EU-CLRTAP interplay. This interplay has not least been witnessed in the similar multi-pollutant approach utilised and similar substances addressed in the CLRTAP Gothenburg Protocol and the EU NEC Directive proposal. Leaving the two latter developments aside, it is the increase in “strength” that is the main point of departure for this paper. As substantial cuts in emissions will be required of many countries and hence the potential environmental improvement will be significant - and as it has generally been suggested that stronger commitments will easily be followed by weaker implementation (cf. Downs, Rocke and Barsoom 1996) - the topic of this paper is of considerable practical political and theoretical interest.

With regard to the four main substances focused in recent EU and CLRTAP policy-making (i.e. S O2, NOx, VOCs, NH3), there are certain key countries in terms of size of emissions and contributions to transboundary effects &-; and hence also a number of countries whose performance matters only marginally. Take S O2, NOx and VOC emissions 6 : according to ECE/CLRTAP (1999), with regard to S O2 emissions, the six largest European emitters in 1995 were Poland, the UK, Germany, Spain, Bulgaria, and Italy. 7 With regard to NOx, the top five 1995 emitters were the UK, Germany, Italy, France and Spain. 8 Regarding VOC emissions, the top five on which data existed in 1995/96 were as follows: France, Italy, the UK, Germany, and Spain. 9 Looking at these various groups, certain KKCs (“key key countries”) stand out, first and foremost the UK, Germany, Italy and France . Is there then one TKCC ( the key key country)? Norwegians and Swedes would probably point at the British, given the “vulnerable, net-importer not least from the UK” position of the Scandinavians. The UK is a generally interesting country, being a big emitter, and with its past “dirty man of Europe” image and record of international stubbornness (e.g. Rose 1990). This is then the background for the question posed in the title of this paper: will the high hopes of emissions reductions in Brussels/EU and Geneva/CLRTAP be “dashed” in London? 10 In addition to the UK, the two other KKCs France and Germany are singled out for closer scrutiny in this paper. In order to understand countries’ past level of compliance, three main analytical perspectives have been suggested: 1) “basic interests”, related to the relationship between abatement costs and damage costs; 2) “domestic politics”, bringing in not least the distribution of costs and benefits; and 3) “learning” and policy diffusion (Underdal 1998). As we in this context will use these perspectives to look forward, the perspectives need to be complemented by a “baseline” perspective, summing up important achievements and failures so far of the countries in question . What can we say, then, about past achievements and the prospects ahead of the three KKCs singled out? This exercise will only be very, very tentative and superficial in this paper. It will hopefully form the background for a broader and much more deep-diving future project.

The next section of this paper will sum up some “baseline” information about past achievements of the KKCs singled out. Section three will form the main part of the paper, discussing the three perspectives of interests, politics, and learning. Section four will sum up some main impressions.


2. “The implementation baseline”: what has been achieved so far?

In this context, we will limit the discussion to achievements within CLRTAP. Luckily, we can build upon a quite recently published overview of compliance and achievements so far (ECE/CLRTAP 1999). Before we zoom in on the KKCs, a few words about the overall achievements and compliance in relation to the past SO 2, NOx and VOC commitments. First, sulphur dioxide has the longest and most “advanced” regulatory history (with the first protocol in 1985 calling for 30% emissions reductions and the second protocol in 1994 introducing the critical loads concept and related, differentiated targets), and achievements here are impressive. 11 In relation to the 1980 baseline, European SO 2 emissions had been reduced by 60% by 1997. Second, the main NOx commitment was established in 1988, calling for a stabilisation of emissions by 1994, with 1987 as baseline. In addition, twelve countries adopted a declaration calling for 30% reductions by 1998. Overall, as signalled by lower ambitions, NOx achievements are less impressive. Between 1987 and 1994, NOx emissions fell by around 10%. Third, the 1991 VOC Protocol overall called for 30% reductions by 1999, with 1988 as the main baseline. Measuring performance here is complicated by lacking baseline and emissions data, but available data indicate around 20% reductions between 1988 and 1997. In sum, the overall CLRTAP compliance picture looks pretty good, but in terms of reduction achievements, the SO 2 record is far more impressive than the NOx and VOC record. 12

Let us then sum up some main compliance achievements by 1996/97 of the three KKCs. 13 Turning first to France, its sulphur record is very good (66% reductions); NOx record unimpressive (rough stabilisation); and VOC record unknown (no figures submitted for the base year – but in the period 1990-97 VOC emissions actually increased!). Germany’s sulphur record is also good (50% reductions); NOx record good (22-23% reductions); and VOC record fair (20% reductions). Although the UK did not sign the 1985 SO 2 Protocol, sulphur emissions had been reduced by 60% by 1996; NOx emissions had been reduced by 20%, and the VOC record is similar to Germany, i.e. 20% reductions. Overall, although VOC developments are less impressive, in terms of compliance, the KKCs have done pretty good. On the one hand, this generally bides well for the future. On the other hand, the recently adopted commitments are generally far more ambitious than in the past. Moreover, having reduced quite a lot already means that achieving further, substantial reductions may become increasingly expensive. With this ambiguous tentative conclusion as a backdrop, let us turn to the main forward-looking exercise.


3. The three determining factors: interests, politics, and learning. A first, exploratory discussion.

3.1. «Calculating interests»: a rare case of benefits clearly exceeding costs?

This fundamental perspective zooms in on the governments’ calculation of the benefits and costs related to compliance. 14 An important aspect of such benefits and costs is simply the domestic monetary dimension of these concepts. Hence, in the context of environmental policy, a main proposition related to this perspective can be formulated as follows: a party will comply if, and only as long as, its expected marginal abatement costs are lower than expected marginal damage costs. 15 But as pinpointed by Underdal (1998), costs and benefits also have more international and political dimensions. Being caught cheating may represent a substantial cost for certain governments and, conversely, being a «best in class» and «vanguard implementor» may include technology development and export possibilities, and represent substantial reputation benefits. Hence, the proposition above may be restated in the following manner: an actor will comply if, and only as long as, expected marginal abatement costs minus any implementation benefits are lower than expected marginal damage costs plus any sanction costs incurred by defecting. 16

Turning first to the more domestic monetary aspects, consultant reports produced during the EU and CLRTAP policy-making processes give us important inputs for discussing these important issues. Within CLRTAP, specific figures were put on the table in the beginning of 1999. At this stage, it had principally been agreed to base the CLRTAP multi-pollutant protocol on a “medium” ambitious emissions reductions scenario. 17 The total costs in 2010 for Europe under this scenario was put at 9.7 billion ECU, with the EU countries accounting for two-thirds of the costs. Total benefits were more uncertain, with a low estimate at 35 billion and a high estimate at 56 billion ECU. 18 Still, these figures indicated that overall benefits would outweigh costs by a clear margin . This must at least be characterised as interesting, although such figures invite a number of critical questions. Moreover, the impression of overall benefits clearly exceeding costs was strengthened when the draft EU NEC Directive was put forward in June, 1999. 19

However, more country-specific information presented in the EU context connection was more disturbing, not least within a KKC perspective. According to EU Commission official Gammeltoft, “meeting these national ceilings <in the draft EU Directive> will cost little in Finland, but the costs will be higher <elsewhere>, especially in the United Kingdom, France, Belgium, and some parts of southern Europe”. 20 With regard to the UK situation, the Commission estimated in June that annual costs for the UK would be 1350 million ECU; 18% of the EC total. Towards the end of 1999, the British Department of Environment (DETR) disputed this figure, but not in the direction that one would easily anticipate. In fact, the DETR believed that these cost figures were “likely to be significant overestimates”. 21 Instead, the DETR put the overall annual costs around 900 million ECUs; most of these for VOC controls. Moreover, DETR stated that the cost of meeting the CLRTAP ceilings would be “considerably lower”. 22 However, on the other hand, the DETR also fundamentally doubted if the Commission’s claim that benefits would exceed costs was right and based on sound valuation methods. 23 What about Germany, then? This central country was not mentioned in the statement from the Commission official cited above. However, in a table indicating the total implementation costs for each of the EU countries, Germany comes out clearly at the top, with 2146 million Euro per year. This is almost twice as much as the number two on the list, the UK. 24 Moreover, reported German “backtracking” in the concluding negotiations on the CLRTAP multi-pollutant protocol may indicate that the costs of coming reductions worry German decision-makers. 25 Turning very briefly to France, the Commission June exercise referred to above explicitly identified France as one of the high cost countries. Total annual costs of 916 million euro were indicated. 26 However: for all three countries, we must keep in mind that these costs are related to the attainment of the emission ceilings in the draft EU NEC directive, which is far from adopted. As indicated by British decision-makers, meeting the CLRTAP targets will be less costly. This also follows from the simple fact that the CLRTAP targets in many cases are quite close to what the Institute for Applied Systems Analysis (IIASA) has calculated as the “reference” scenario – in other words, what the countries will probably do anyway, due to other commitments and likely developments in energy use etc. 27 Tentatively summing up, this highly incomplete and tentative exercise indicates that, in the case of the KKCs, CLRTAP abatement costs will not necessarily be all that much. However, if the EU NEC Directive is adopted close to its present form, then the cost factor will become much more important.

Is it then possible to say anything more specific about damage costs in the KKCs? As indicated above, the UK authorities generally doubted that the overall cost-benefit ratio was as positive as depicted by the Commission, or even if it was positive at all. As this was partly due to a more principal scepticism about valuation methods, it does not necessarily mean that the UK authorities see the more specific UK cost-benefit scenario as skewed in favour of costs. Taking into account other recent information about the development of the British air pollution conditions and effects, there are reasons to assume that perceived damage costs are on the increase in the UK. For instance, a UK workshop on eutrophication and acidification held in December 1998 concluded that conditions throughout the country were more serious than perceived earlier. 28 Turning to Germany, the outside impression is that concern over air pollution has decreased somewhat compared to the 1980s heyday, but that remains to be further substantiated. Given Germany’s comparatively highest abatement costs, it is more open if damage costs will weigh as heavily as earlier in the German cost-benefit assessment. 29 My knowledge about the French situation is even more rudimentary than in the case of Germany. France has never experienced a “Waldsterben” uproar and the impression is that concern over air pollution (effects) has never been very high on the French agenda (Skea and Du Monteuil, forthcoming). Given uncertain French costs (but substantial in the EU context), my guess would be that the French cost-benefit assessment will easily be skewed in the favour of abatement costs.

So far I have summed up scattered pieces of evidence about important domestic interest-determining factors. However, as can be recalled, this perspective also includes some “international” factors. What can we say about those? First, with regard to “implementation benefits” and technology exports etc., I would be skating on extremely thin ice and have to leave this aspect unspecified for the time being. However, a bit more can be said about the issue of “sanction costs” and “shaming”. Both the EU and CLRTAP have established formal reporting procedures. The CLRTAP multi-pollutant protocol includes a quite long Article 7, spelling out various reporting commitments. Reporting practice has so far been mixed, with especially VOC reporting being inadequate. 30 Within the EU, directives usually require the member states to submit a report to the commission on national legislation, regulations or administrative measures that give formal effect to the directive. Reporting practice can also here be characterised as mixed. 31 Moreover, both institutions have seemingly developed somewhat tougher practices with regard to implementation review in the recent years. Within CLRTAP, although functioning basically in a consensual and non-confrontational way, a specific Implementation Committee was established in 1997. 32 Within the EU, the “implementation gap” has received increasing attention throughout the 1990s. 33 In terms of enforcement, the EU of course has the most “advanced” system, with the possibility of taking cases of non-compliance to the European Court of Justice. In recent years, there has seemingly been an increasing willingness on the part of the Commission to take states to court over lacking environmental policy implementation. 34 Hence, all in all, it is possible to envisage the EU in the future acting as a sort of “compliance cop” for CLRTAP. The crucial question is however: are the commitments in question really “verifiable” enough to form the basis for clear determination of non-compliance and ensuing strong EU (or CLRTAP) action? On one hand, the commitments and emissions ceilings are clearly precise enough to allow the determination of compliance/non-compliance. On the other hand, the emissions figures are clearly the weakest link in the CLRTAP science-politics system. 35 Hence, the crucial question is if this part of the system is robust enough to withstand “creative calculations” if states get into trouble? I know very little about this. If, however, the answer here is no, then it may very well be possible that CLRTAP meetings and the more loose review atmosphere within that regime may be at least an equally strong compliance strengthening mechanism as the formally stronger procedures within the EU.

3.2. Institutions and politics: will not so high total costs fall specifically on powerful actors and “huge benefits” disappear into the air?

This perspective highlights the complexity of democratic decision-making. Interests are not only “calculated”; they are shaped through negotiations and political pressure – within and outside of the government. Although governments may perceive the benefits of compliance as clearly exceeding costs, they may be unable to comply due to societal resistance. Or conversely, they may be pressured to comply, due to the strong political position of “compliance supporters”. Societal resistance may be assumed to be related to the distribution of implementation costs and benefits. A main idea here is that implementation policies which need to hit specific, well-organised and powerful societal groups are much less likely to contribute to governmental compliance than policy situations where compliance can be achieved without the need to take on such societal actors. Hence, two important propositions within this perspective can be formulated in the following manner:

  1. the policy measures that are most easily implemented will be those which offer tangible benefits to some specific sector of the economy or organised segment of society, while costs are widely dispersed (and the other way around);
  2. damage or abatement costs that hit the social “centre” of society will be better articulated and carry more political weight than those that hit the social “periphery” only, and this bias will be stronger the greater the distance in social and political resources between “centre” and “periphery”. 36

I am far from being in a position to carry out a systematic discussion of these and a number of other, related “political” propositions in the current paper. 37 Instead, in addition to some general reflections on the institutional capacity for implementation 38 , I will mainly address the following broad, but important, question: Does the current environmental policy-making development and “swing” in the focused countries bide good or bad for future levels of air pollution compliance? Turning first to the UK, my feeling is that the current air pollution political “swing” in this country is positive. Quite recently, a seemingly solid, revised national Air Quality Strategy was launched. 39 This must be seen as part of the government’s response to a deteriorating urban air pollution situation, with traffic going up – like almost everywhere else. 40 My impression is that popular concern over these problems is increasing. Moreover, as discussed under the previous section, British authorities seem quite confident about the implementation possibilities. With regard to SO 2 emissions, fuel switching or further installation of flue gas desulphurisation equipment has been indicated. 41 Moreover, and not least important, given the 1990 baseline, the UK can again benefit from the “dash to gas” process which took place in the first part of the 1990s. 42 Several VOC control measures have also been indicated; among them vapour recovery on offshore installations and further controls in refineries. 43 A more detailed scrutiny would probably dig up a number of questions and discussion points, but the overall picture looks promising.

My knowledge of the German situation is very rudimentary. It can be noted that it has established a sweeping 70% emissions reduction by 2010 (with a 1990 baseline) domestic target for all the four focused substances. 44 Compared with the 1999 CLRTAP commitments for sulphur, this is actually 20% below the German CLRTAP commitment (i.e. 90% reductions). But both for NOx and ammonia, this is more ambitious than the CLRTAP targets (i.e. 60% NOx reductions and “mere” 28% NH3 reductions). This domestic ambitiousness can be counted as a weak, positive “implementation signal”. In terms of the general institutional capacity for implementation, it has been noted that “decision-making authority on issues of air pollution control in Germany is neither highly centralised nor very decentralised. It rests mainly with the federal government, albeit subject to relatively strong influence of the states as exercised mainly through the Bundesrat” (Sprinz and Wahl 2000:148). However, compared to for instance the UK, there is generally a higher chance of a German “implementation gap” between the central government and local authorities. The picture that most easily comes to mind is one of a willing government and stubborn Lander. However, in the global climate change context, the political dynamic has been more the other way around (Hasselmeier and Wettestad 2000). Moreover, the seemingly decreasing governmental concern and “supply” and public “demand” in the climate change context may not bide well for the air pollution context either, especially the climate-related transport/NOx/VOC context (ibid.).

My knowledge of recent French air pollution politics is close to zero. Going back to the French compliance performance so far – very good on sulphur and far more modest with regard to NOx and VOCs - NOx and VOC politics will most probably be the two issues and sectors “to watch”. Glancing through the two chapters and 60 pages on “national strategies and policy measures” in the 1999 ECE/CLRTAP review, there is very little information on France’s current activities and policy plans ahead. For instance, there is much more information on Turkey than on France. This may be a sign that the French government does not give very high priority to this issue area, but that remains to be substantiated further.

3.3. Learning and policy diffusion: will knowledge provided and/or pressure exerted from “epistemic communities” and diffusion of “smart policies” energise the implementation processes?

This perspective sensitises us to the inherently more diffuse processes of social learning and policy diffusion. In a stark version, although costs may exceed benefits, and supporters of compliance may be weak, governments may still comply, due to convincing knowledge provided and/or policy pressure exerted by “epistemic communities - and/or the learning about smart and less costly policies and technologies from other actors/countries. 45 Hence, in relation to the previous, “domestic” perspective, this perspective is more “transnational” by nature. Moreover, it is also clearly less elaborated than the two previous perspectives. 46 Hence, I will be even more brief in the discussion of this perspective than what has been the case in the two previous sections.

Is there an “epistemic community”, including both scientists and policy-makers, in the international air pollution context? 47 I am tempted to say that if there isn’t, then this concept really is in trouble. Due to 1) the long scientific and political history of the acid rain/air pollution issue; 2) the strong emphasis given to scientific cooperation and monitoring within the regime, manifested for instance in the well-functioning EMEP monitoring program (di Primio 1996); and 3) increasingly closer science-politics interface within the CLRTAP regime (Wettestad 2000), then there should be a strong reason to expect that an “epistemic community” exists in this issue area. An implication of this is that there are good reasons to believe that there are groups of quite centrally placed people in all the focused countries which can be expected to voice their concern in a situation where the implementation of the air pollution commitments clearly lags behind. This should be generally good news for the prospects of compliance in general, but it says nothing about the possible more specific impacts in specific countries. My very rough guess here would be that the British part of the transnational “epistemic community” will be most influential (of the three KKCs) on the domestic air pollution scene, given the active role of the British in the scientific work within CLRTAP. The German part will also be quite influential, while the French part will be least influential.

What about the prospects for the diffusion of smart technologies and policies? This is a field I know very little about. However, given the “maturity” of the air pollution control issue, my general hunch would be that main technological and political options are quite well known by now and that radical further progress and breakthroughs in the field of technology are less likely than what was the case for instance in the mid 1980s.


4. Summing up: positive prospects, but much uncertainty.

Based on the reasoning above, I do not think that the “high hopes” in Geneva/CLRTAP and Brussels will be dashed in London. The UK as “the dirty man of Europe” seems to be history. The prospects for German implementation are more uncertain, but my guess is that the Germans will do quite well, but less impressive than in the past. France is even more of an uncertain card here, and unimpressive NOx and VOC performance so far does not bide well. To the extent that these countries really are the “key key countries”, even if there are huge uncertainties to be clarified further, the implementation prospects for the new CLRTAP commitments are overall quite promising. Some would even say that this is a “piece of cake”. However, the closer the adopted version of the EU NEC Directive is to the present draft, the less relevant will the “piece of cake” perspective become.

More specifically, the following table sums up tentative impressions and important areas of uncertainty with regard to implementation prospects:

  The UK Germany France


Substantial possible abatement costs in the EU context, but increasing damage costs. Seemingly relaxed policy-makers

Highest abatement costs and decreasing damage costs? Past leader reputation to up-hold, though.

Substantial abatements costs at least in the EU context and uncertain damage costs.


Increasing concern over air pollution; a National Air Quality Strategy recently published

Decreasing concern over air pollution? More ambitious domestic NOx and NH3 targets than international commitments

Stable, low concern about air pollution? Little information on planned air pollution policies


Influential British part of “epistemic community”??

Quite influential German part of “epistemic community”?

Moderately influential French part of “epistemic community”??



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Note 1: This paper has benefited from the comments of Steinar Andresen, Arild Underdal and Christer Agren. Thanks to Maryanne Rygg for language polishing.  Back.

Note 2: The Protocol was adopted December 1, 1999.  Back.

Note 3: The European Parliament has been carrying out its first debates on the proposal in February-March, as far as I know.  Back.

Note 4: The case of the big emitter and earlier air pollution “laggard” the UK is instructive. In the 1980s, the UK was not willing to sign the sulphur protocol calling for 30% emissions reductions and accepted unenthusiastically a stabilisation of NOx emissions. In comparison, the UK has recently committed itself to reducing sulphur dioxide emissions by 83% and NOx emissions by 56% by 2010, with a 1990 baseline. However, as will be further elaborated later in the paper, the advance of at least central parts of the CLRTAP Protocol in relation to reductions likely to take place due to other international commitments and energy policy developments is less impressive.  Back.

Note 5: See for instance Tuinstra, Hordijk and Ammann (1999).  Back.

Note 6: The following are Central European emitters. Other large emitters are Russia and Ukraine.  Back.

Note 7: Poland (2376 000 tons), the UK (2343 000), Germany (2102 000), Spain (2061 000), Bulgaria (1497 000) and Italy (1322 000).  Back.

Note 8: The UK (2104 000 tons), Germany (1946 000), Italy (1768 000), France (1666 000), and Spain (1223 000).  Back.

Note 9: France (2620 000 tons), Italy (2368 000), the UK (2120 000), Germany (1981 000) and Spain (1120 000).  Back.

Note 10: This title is of course inspired by Pressman and Wildavsky’s classic 1973 implementation study, Implementation: How Great Expectations in Washington are Dashed in Oakland.  Back.

Note 11: For overview discussions of the protocols and the CLRTAP regime, see Wettestad (1991; 1996; 1999); Levy (1993; 1995); and Gehring (1994).  Back.

Note 12: This has of course to do with the SO 2 problem having a longer scientific and regulatory history than the others and also being more of an easily targeted “power stations” problem. See Wettestad (1998).  Back.

Note 13: The baselines are as set in the protocols: SO 2 1980; NOx 1987; VOC 1988. Note here that we talk about compliance achievements, which say absolutely nothing about the causes of emission reductions.  Back.

Note 14: The perspective builds upon three basic assumptions:1) states are unitary, rational actors; 2) decision-makers evaluate options in terms of costs and benefits to their nation, and only in those terms, and choose whichever option (is believed to) maximize(s) net national gain; 3) states are in full control of “their” societies. See Underdal (1998:7-12).  Back.

Note 15: Ibid.:8.  Back.

Note 16: Ibid.:9. I will here interpret “sanction costs” broadly and include softer “shaming” and reputation effects.  Back.

Note 17: See summary of these developments in Acid News 1999 A: 1, 4-5.  Back.

Note 18: According to Christer Agren, the estimated benefits are clearly underestimated for the simple reason that they only take account of what is judged to be possible to estimate in monetary terms (i..e. primarily health) – thus excluding some of the main objectives of the legislation, i.e. reduced acidification, reduced “damage” to the natural and cultural environment, etc.  Back.

Note 19: See International Environment Reporter, June 23, 1999:518-519.  Back.

Note 20: Ibid.  Back.

Note 21: ENDS Report 299, December 1999:41.  Back.

Note 22: Ibid:42.  Back.

Note 23: Ibid.  Back.

Note 24: International Environment Reporter, op.cit.:519.  Back.

Note 25: These negotiations, and the role of important countries such as Germany, are further discussed in Wettestad (forthcoming 2000).  Back.

Note 26: International Environment Reporter, op.cit.:519.  Back.

Note 27: See ENDS Report 296, September 1999:44-45.  Back.

Note 28: Interviews with CLRTAP negotiators, Autumn 1999.  Back.

Note 29: For an interpretation of the dynamics of German air pollution politics, see Boehmer-Christiansen and Skea (1991); Wettestad (1996); and Sprinz and Wahl (forthcoming).  Back.

Note 30: See Acid News 1999 B:12-13.  Back.

Note 31: See e.g. Jordan (1998).  Back.

Note 32: See Wettestad (1999), Ch.4.  Back.

Note 33: See for instance Jordan (1997, 1998); Knill (1997) and Knill and Lenschow (1997).  Back.

Note 34: See for instance International Environment Reporter, February 3, 1999:96-97.  Back.

Note 35: Interviews with CLRTAP negotiators Autumn 1999.  Back.

Note 36: Underdal, op.cit.:14, 16.  Back.

Note 37: See Underdal, ibid.:12-20, for an overview of such propositions.  Back.

Note 38: In a more deep-diving effort, the OECD Performance Reviews contain useful institutional and political background information. See e.g. the UK report (OECD 1994).  Back.

Note 39: A consultation document was published last year; see DETR (1999). Note, however, that the final strategy was immediately attacked by environmentalists, especially the government’s targets on particles; see Reuter/Planetark, January 20, 2000.  Back.

Note 40: See for instance ENDS Report 272 1997, “Royal Commission warns of looming transport crisis”, pp.11-12.  Back.

Note 41: ENDS Report (1999:42).  Back.

Note 42: See Collier (1997) and Boehmer-Christiansen’s chapter in Hanf and Underdal (forthcoming).  Back.

Note 43: ENDS (1999), op.cit.:42.  Back.

Note 44: ECE/CLRTAP (1999:12).  Back.

Note 45: The classic reference with regard to the concept of “epistemic communities” is of course Haas (1990). I am grateful to Arild Underdal for pointing out to me that such communities may influence policy-making both by the more “passive” production of new knowledge and more “active” knowledge-based policy pressure.  Back.

Note 46: See Underdal (1998:20-23) for an overview of central assumptions and somewhat mixed propositions which can be derived from this perspective.  Back.

Note 47: Peter Haas defines “epistemic communities “ as “transnational networks of knowledge based communities that are both politically empowered through their claims to exercise authoritative knowledge and motivated by shared causal and principled beliefs”.  Back.