Stichting Stikkstofclaim (SSC) has summoned Minister Christianne van der Wal to suspend the Aerius permit model as long as it cannot be substantiated that projects will have significant consequences for nature areas due to nitrogen deposition. The foundation gives the minister until 31 December 2022. If she does not do so, SSC will institute summary proceedings.
SSC makes the summons in particular on behalf of a PAS reporter who has been imposed a penalty due to unlawful government action and through no fault of his own, so it is stated.
In support of this, the SSC refers, among other things, to a confidential memorandum from TNO on 26 April of this year, which states that Aerius can only reproduce a reasonably reliable calculation at a limit between 1 and 10 mol/ha/year, while there is now a limit is set at 0,005 mol.
SSC then cites four more arguments. For example, there is the report of the Hordijk committee, 'Measuring more, measuring more robustly'. In it, the committee states that the Aerius model is not suitable for licensing purposes.
RIVM also considers Aerius unsuitable
As a third argument, SSC cites the technical briefing of the RIVM, which was held before the permanent parliamentary committee on Agriculture on 3 November. There, RIVM also concludes that the Aerius model is not suitable for licensing. As a fourth argument, SSC refers to answers to parliamentary questions of 6 September 2021. There, the minister indicates that deposition beyond 1 kilometer from the source can no longer be traced back to the same source. And this observation is at odds with the current calculation distance that the Aerius model calculates with, namely 25 kilometers.
Finally, SSC refers to a judgment of the Court of Justice of the EU of 10 November this year. This judgment states that an appropriate assessment for a project must remove any reasonable scientific doubt about the consequences of the project in question. In view of the above, this is not the case with the Aerius model.
Effect of combustion processes underestimated
In addition, the publication of an international study in the scientific journal Nature notes that ammonia concentrations in the air consist for a much larger proportion of emissions from combustion processes than is currently included in the validation of the Aerius model. As a result, the results of an Aerius calculation have become even more unreliable.
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