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RIVM: nitrogen problem requires excess policy
According to the RIVM, an excessive focus on environmental policy to achieve low critical deposition values (KDWs - calculated with via the Aerius program) requires an excess of national policy. The cabinet wants to focus heavily on lower deposition and spatial measures in rural areas.
The warning against an excessive use of KDWs comes from a group of scientists from RIVM and PBL. It is in a response to the official steering group surrounding the study Nitrogen Room for the Future. This study was compiled by ABD Topconsult and aims to be an important basis for new policy. The study recommends that by 2050 all Natura 2000 areas have a deposition of nitrogen and ammonia that is below the CDW, with the intermediate target of a deposition of twice the CDW for vulnerable nature areas. The documents were published after a WOB request. RIVM: "In our view, the generic and priority pursuit of the realization of the KDWs will overshot to national policy." According to the RIVM, the intermediate goal will also be legally contestable.
In the coming years, the new cabinet wants to many tens of billions set aside for the purchase of agricultural companies and the depreciation of agricultural land. KDWs differ per type of nature reserve and are expressed in mill (calculated) deposition per hectare. One kilogram of deposition represents 70,14 mol.
Struggling between officials and scientists
The preparation of the report was accompanied by various quarrels between officials from LNV (particularly the Directorate of Nature) and the Interior, and scientists from RIVM, the Netherlands Environmental Assessment Agency, TNO, Wageningen UR and Wageningen Economic Research (the Netherlands Environmental Assessment Agency). former LEI). The usefulness and value of the nitrogen figures and calculations are especially discussed.
It is not so much a question of whether the ministries want too much or too weak a policy, but the desire of the civil servants to reason towards a specific goal. "What we find striking, and in some ways inconvenient, is that there are a number of selective references to PBL publications to support your problem definition — or so it seems," said one commenter. Elsewhere it is stated that "The PBL maintains that we view the problem differently and that we also arrive at other possible solution routes from that point than this draft text sets out."
Numbers go against 'intuition'
On the other hand, a senior LNV official complains that it is difficult for him to work with RIVM figures:. He would like to demonstrate that buffer zones around nature reserves work and that buying out agricultural companies is an effective method in this respect: "I am currently working on the document, but I am running into the usefulness of the RIVM calculation exercise. It's very counter to my intuition." TNO and PBL also indicate that the damage to nature caused by nitrogen and ammonia is substantial, but that the social damage caused by nitrogen (NOx, partly from agriculture) is much greater. That is also not reflected in the report of the ABD.
Uncertainty in Aerius greater than outcome calculation
Criticism of the foundation under all calculations, calculation model Aerius, certainly does not get any further. In a contribution, which seems to come from Leiden University, it is stated: "You keep counting with Aerius,
without first solving the shortcomings of this model. The uncertainty in the model is many times greater than the outcome of the calculations. Each annual new version of Aerius leads to relatively large shifts in outcomes. The justification for the changes goes little further than 'improved and updated' (black box).
According to 'Impact Analysis Update AERIUS Calculator 2020' (RIVM of 15 October 2020), the average nitrogen deposition in the Netherlands between 2019 and 2020 has decreased by about 150 mol/ha/year. Where does this big difference of 150 moles come from? The distribution model has been adjusted, emission factors have been changed, changes have been made to the habitat map, sources have been changed. And the deposition effect of each component has relatively large uncertainties."
Klaas van der Horst
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