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Possible Control of EU Priority Substances in Danish Waters

14 Conclusion

• 14.1 The need for further national regulation
  • 14.1.1 EQS compliance
  • 14.1.2 Cessation/phase-out of discharges, emissions and losses
  • 14.1.3 Losses of priority substances from contaminated sites
  • 14.1.4 Certain priority hazardous substances in biota
  • 14.1.5 Other pollutants
• 14.2 Progressive reduction and cessation/phase-out measures
• 14.3 Overall economic assessment
  • 14.3.1 Substance-specific assessments
  • 14.3.2 Assessment of common measures for all substances
  • 14.3.3 Conclusion on economic consequences

14.1 The need for further national regulation

Firstly, the need for further national regulation of a priority substance depends on whether the concentration of the substance in discharges into surface waters and into the aquatic environment itself exceeds the EQS or not. Secondly, there may a need for further national regulation aiming at cessationg/phase out of priority hazardous substances. The extent of necessary measures depends on the scenario considered (briefly summarised, for a full description see Section 3.3):

(1) Scenario A/C representing the situation with the current, official proposal for the Daughter Directive, which only esta blishes specific requirements to compliance with the proposed EQS values while possible measures aimed at progressive reduction and cessation/phase-out must be based on WFD requirements. In the assessment this scenario is considered almost identical to not having a Daughter Directive but only the requirements of the existing WFD (Scenario A), or

(2) Scenario B representing the 2005 draft proposal for the Daughter Directive in which, additionally to the A/C scenario, binding requirements to measures to achieve progressive reduction or cessation/phas out were included with a 20-year time limit for implementation.

It should be noted that the reduction target of aiming at cessation/phase-out and progressive reduction in Scenario A/C is an obligation according to the existing WFD. Hence, estimated costs related to this reduction target are not a consequence of the final Daugher Directive proposal.

Therefore, in the following, the EQS issue and the effort to ceasing/phasing out PHS are described separately.

Further, a number of other, minor issues are dealt with in separate sub-sections.

14.1.1 EQS compliance

In Table 14-1 the AA-EQS and MAC-EQS (where applicable) values of the eight selected PS are compared to data from monitoring of the levels of the substances in sewage effluent and in stormwater from separate systems respectively, in order to calculate the initial reduction necessary to lower the effluent concentrations to the EQS value. With regard to the 23 priority substances that were not selected for this study it is the assessment that they, at the national level, already comply with the proposed EQS values.

For sewage effluent two sets of data are available, the average concentration in the effluent and the 95 % percentile concentration. Compliance with the AA-EQS is assumed when less than 10 times initial dilution of the 95 % percentile data is required to reach the AA-EQS value.

For stormwater, Table 14-1 is based on average data from measurements of concentrations in the first 5 mm of six rain events at each of two locations in suburban Copenhagen. These are compared with the MAC-EQS. The initial dilution, after which compliance with the MAC-EQS must be obtained, may in some parts of eastern Denmark be considerably lower than the factor 10 applied to sewage effluent, especially during the summer period.

Table 14-1

Required initial dilution of priority substances in sewage effluent and stormwater (separate system) to comply with the most rigorous AA-EQS and MAC-EQS value, respectively (in the cases where the values differ). All EQS values and concentrations are in μg/l.

N.A. = "not applicable" (as stated in the directive proposal).
*   Nonylphenol "potential" i.e. NP + NPE1-2EO

As can be seen from the table, with regard to sewage effluent none of the priority substances require an initial dilution of more than 10 times (standard initial dilution factor applied in the environmental regulation of wastewater discharges in Denmark), even for the 95 % percentile of the discharges, in order to comply with the AA-EQS.

The stormwater effluents generally require very little initial dilution to comply with the MAC-EQS. The maximum reduction required is a factor 2.9 for nonylphenol while cadmium only requires a factor 1.6. Further, it is believed that PAH will also require reduction in stormwater prior to discharge but an exact reduction factor cannot be defined at present.

In a national perspective the majority of stormwater discharges are considered to comply with the MAC-EQS. However, in some parts, mainly the eastern, of the country there may problems in the summer season (at median minimum of dry weather flow) in obtaining even a dilution factor of about 3 as required for nonylphenol. As this situation may represent as much as 40 % of the volume of separate stormwater discharges, the likely non-compliance with the MAC-EQS should not be overlooked and has therefore been assessed economically under measures for stormwater (relevant for all three scenarios).

For nonylphenol, the 5.7 μg/L value in stormwater (constituting the basis of the above reduction factor 3) can be regarded a conservative, but not unrealistic value representing the average of a wide range of situations including long periods of dry weather prior to the rain event sampled (i.e. with significant build-up of pollutant levels). Other, later data indicate that the average concentration in stormwater may now be somewhat lower. An in-depth analysis of the issue is therefore recommended prior to initiating implementation of the proposed technical measures for stormwater.

Finally, it should be noted that for a number of the priority substances the official Daughter Directive proposal has not defined any MAC-EQS value but only stated such a value to be "not applicable". This prevents an evaluation of these substances with regard to stormwater as the MAC value would be the relevant evaluation basis. Presumably, the PAH levels require reduction prior to discharge but it is not possible to state a exact reduction factor as currently no MAC-EQS has been established for PAH.

14.1.2 Cessation/phase-out of discharges, emissions and losses

Priority hazardous substances (PHS) require regulation to ensure cessation or phasing out of discharges, emissions and losses irrespective of whether the substances comply with the EQS or not. Therefore, the PHSs among the PSs included in this study will require further national action as discharges, emissions and losses of these substances still occur. Scenario B implies an obligation to reach the target within a time frame of 20 years while in Scenario A a time frame is not specified, and the obligation is limited to considering all technical reduction options (though this will not necessarily result in reaching the target).

The PHSs among the PSs in this study are:

• Cadmium
• Mercury
• Nonylphenol
• PAH (including anthracene)
• TBT

With the exception of nonylphenol (and maybe PAH) in stormwater there generally already appears to be compliance with the proposed AA- and MAC-EQS and the need for national measures to ensure progressive reduction of pollution in Scenario A/C is therefore confined to the stormwater issue. Please note that the objective of aiming at progressive reduction of priority substances in Scenario A/C is a requirement according to the existing WFD, not the final Daughter Directive proposal. In Scenario B (referring to the 2005 draft Daughter Directive), however, there is an obligation to continue progressive reduction in a cost-effective manner of emissions, discharges and losses even beyond the EQS compliance level. Proposed measures are briefly summarised in Section 14.2.

It should also be noted that the objective of aiming at cessation/phasing-out of priority hazardous substances in Scenario A/C is a requirement according to the existing WFD, not the final Daughter Directive proposal.

With regard to the 23 priority pollutants not selected for this study, the following are classified as PHS:

• Pentabromodiphenylether (PeBDE)
• Chloroalkanes, C10-C13
• Endosulfan
• Hexachlorobenzene
• Hexachlorobutadiene
• Hexachlorocyclohexane
• Pentachlorobenzene

As far as the five latter PHS are concerned, the conclusion from the screening assessment remains unchanged, i.e. the substances were either not used in Denmark at all or they were phased out years ago, i.e. it is not relevant to initiate further regulatory measures aiming at ceasing or phasing out discharges or emissions of these substances.

For PeBDE it is concluded that the necessary national phase-out measures have been taken already (recently) while for chloroalkanes common action at EU-level is needed for a measure to become effective. The current use of chloroalkanes in Denmark is, however, believed to be very limited and with only little impact on the quality of surface waters.

14.1.3 Losses of priority substances from contaminated sites

This report mainly deals with the discharges and emissions of priority substances from society today. However, losses of certain substances from contaminated sites to the aquatic environment may occur though the extent of such a potential problem is believed to be quite limited from a national perspective It has not been possible to gather specific information about this issue within the framework of this study and, therefore, a specific study on losses from contaminated sites has been initiated and will be reported separately.

14.1.4 Certain priority hazardous substances in biota

The maximum allowable concentrations in edible biota( fish, shellfish etc.) are set in the final proposal for Daughter Directive (Scenario C) for the substances hexachlorobenzene (HCB), hexachlorobutadiene (HCBD) and methyl-mercury.

While it is assessed that the concentrations of HCB and HCBD in biota comply with the limit value, the concentrations of mercury in fish (of which 90 % is assessed to be due to methyl-mercury) in many places exceed the acceptable level. Hence, action is required but as the contamination leading to the too high levels is widespread and diffuse such action must be aimed at the sources of contamination. A number of such actions are proposed for mercury in relation to the general cessation/phase-out requirement for this metal.

14.1.5 Other pollutants

The final proposal for the Daughter Directive (Scenario C) also establishes EQS values for a number of other, non-priority pollutants: DDT, aldrin, dieldrin, endrin, isodrin, carbon tetrachloride, tetrachloroethylene and trichloroethylene.

DDT and the "drins" have all been phased out in Denmark many years ago while the use of carbon tetrachloride is insignificant. There is still some use of tetrachloroethylene and trichloroethylene but monitoring data show that the concentrations in wastewater effluents are below the EQS.

14.2 Progressive reduction and cessation/phase-out measures

Table 14-2 gives an overview of the specific measures proposed for inclusion in a possible future national programme for progressive reduction and/or cessation of the discharges, emissions and losses of priority substances and priority hazardous substances into the aquatic environment.

Different sets of measures are proposed for Scenarios A/C and Scenario B respectively as "progressive reduction" in Scenario A/C only entails measures if the EQSs are not complied with while in Scenario B the progressive reduction must continue independent of EQS compliance. Further, the requirements to cessation/phase-out measures are stricter in Scenario B than in Scenario A/C.

Please note that in Scenario A/C the objective of aiming at progressive reduction of priority substances and cessation/phasing out of priority hazardous substances is a requirement according to the existing WFD, not the final Daughter Directive proposal.

In addition to the substance-specific measures it has been demonstrated for the majority of the eight selected priority substances that the main release into surface waters in Denmark (i.e. as total amounts) originates from the content of the substances in stormwater discharges. Only mercury and nickel are predominantly discharged with sewage effluent.

Table 14-2

Overview of national measures proposed for progressive reduction of priority substances and/or cessation/phasing out of priority hazardous substances.

1   As part of common action against several substances in critical areas (40 % of volume).
2   As part of common action against several substances (85 % of volume).

With a few exceptions, the biggest fraction of the most critical environmental pollutants in stormwater is associated with the suspended solids. Hence, a common technological measure such as storage with sedimentation and treatment of outlet that would reduce the concentration in the discharge of all substances with this feature could be implemented at least on the outfalls from separate stormwater systems in areas with little dilution potential, and high population density and contamination levels.

The results for Scenarios A and C are presented together above. Scenario C represents the final proposal for the Directive put forward in July 2006. In effect, this scenario corresponds to Scenario A, i.e. the situation without an agreement on a Daughter Directive (i.e. only the WFD).

The final proposal (Scenario C) does have a deadline in 2025 with regard to the Commission's evaluation of the Member States' fulfilment of the obligation to initiate the necessary measures with the aim of ensuring progressive reduction of the PS and cessation/phase-out of the PHS. This deadline is, however, not interpreted by DEPA to have any influence on the timeframe for the implementation of the Directive compared to the described Scenario A.

Regarding the environmental quality targets (the EQS), the proposed Daughter Directive, Scenario C, is in line with Scenario B where targets are set at Community level. DEPA assumes that in practice the difference between national Danish target levels (Scenario A) and Community target levels will be insignificant. All three scenarios are therefore the same with regard to the quality targets.

Table 14-3 below presents the main types of measures that can be used to initiate the actions required to meet the Directive requirements to priority substances and the priority hazardous substances. Distinction is made between national and Community level type of measures. Basically, bans and use restriction types of measures (including substitution) can only be implemented nationally if Community level action has been agreed on in EU.

Table 14-3 National or community level implementation of proposed technical measures

14.3 Overall economic assessment

14.3.1 Substance-specific assessments

Substance-specific economic assessments have been made of four of the substances: cadmium, mercury, nonylphenol, and TBT. The need for action and technical possibilities of substitution of the use of nickel were identified (progressive reduction in Scenario B), but the economic data was insufficient to make a substance- specific economic assessment of nickel within the scope of this study. For the remaining three substances - DEHP, lead and PAH - the technical assessment did not identify a clear need for action neither in Scenario A/C nor in Scenario B.

Several relevant technical possibilities for substitution of cadmium in products were identified. Elimination of zinc-based sacrificial anodes was identified as a realistic technical measure. This can be achieved by substituting zinc anodes with anodes made of aluminium or indium. This is technically possible, and it will imply little or no loss of quality or functionality of the anodes. Further, in the large ship market aluminium anodes dominate. The possibility of substituting anodes on smaller ships was therefore investigated.

The financial cost of substituting cadmium in sacrificial zinc anodes is estimated to be low or even result in a slight welfare-economic and financial gain in both Scenario A and B. This is a tentative, preliminary estimate. Alternative anodes with aluminium for larger ships already dominate the market, and there is no difference in quality or functionality. The price is slightly lower than that of traditional zinc anodes. In the short term, substitution of zinc anodes still used on smaller ships would impose an investment cost on producersand lead to a slightly higher cost to consumers. However, the long-term cost would probably be 0 or even a slight financial and welfare-economic benefit. Public expenditure is probably needed to overcome barriers preventing the change-over of production

An alternative measure would be to replace old gutters and downpipes in zinc with high content of cadmium (i.e. from before approx. 1980). This is a possible phase-out measure in Scenario B. The potential cost was estimated to be quite high as the financial cost of Scenario B would be between DKK 0.4 and 2.9 billion compared to Scenario A standing at between DKK 0.2 and 1.4 billion. The corresponding welfare-economic costs are DKK 1.0-6.6 billion in Scenario B and DKK 0.6-4.2 billion in Scenario A. The outcome of this investment would be a strong reduction (> 90 %) of the yearly release of cadmium to wastewater (estimated to be 120-480 kg/year) in the years following the investment /2/.

For mercury, an economic assessment was made of the two most realistic technical possibilities, which are mandatory use of mercury filters at dental clinics and national collection/ replacement or labelling of mercury equipment in use. Today, it is estimated that around 80 % of all dentists in Denmark use mercury filters though data are uncertain. If the last 20 % were forced to use filters, it is assessed that around 40-200 kg of mercury could be collected each year. The cost of such a measure, gradually executed with a deadline in 2035 (Scenario A) is estimated to be approx. DKK 7 million in terms of financial costs (to the dentists) or DKK 17 million in terms of welfare-economic costs to society. Shortening the deadline to 2025, as proposed in Scenario B, implies higher costs as the financial cost would stand at DKK 10 million DKK and the welfare-economic cost would stand at DKK 23 million. A gradual implementation of the proposed technical measures aimed at ceasing/phasing out mercury emissions and discharges will (irrespective of the deadline) at the same time fulfil the progressive reduction obligations in Scenario B.

A rough estimation of the cost of a campaign to improve national collection of mercury equipment in use is also given. Based on Swedish experiences  the extra economic cost of such a campaign initiated in 2020 (Scenario B) instead of 2030 (Scenario A) is estimated to be approximately DKK 9-10 million in terms of financial costs as the cost of the two scenarios are DKK 9-12 and DK 17-21 million respectively. The welfare-economic estimates stand at DKK 35-44 and DKK 26-33 million for Scenario B and A, and the difference is thus DKK 7-9 million. For that sum of money, an estimated emission of 40-90 kg mercury per year (and perhaps more) could be eliminated.

If the total Danish consumption of NP/NPE in various products of 90 tonnes a year is to be substituted, it would imply a cost to Danish industry and consumers. In order to assess this cost properly, a number of detailed cost-benefit comparisons for specific product types should be made in order to consider the relative cost of relevant substitutions. As an indication of the proportion of the possible cost, a Canadian study estimated that the price of the alternative substances are 20-40 % higher than NP/NPE, but with some variations. The price estimates illustrate the magnitude of the direct financial cost, but not the welfare-economic cost to society. In this case, we do not have current data on the proportion of the substance found in products produced in Denmark and in imported goods. The cost of replacement with alternative substances will be borne by the manufacturing industry, but given the available data, it is not possible to estimate the proportion of costs to be borne specifically by the Danish manufacturing sector. Finally, it remains to be seen how much of the cost that will be passed on to the consumers or to downstream manufactures using the products as input factors. Since the annual 90 tonnes illustrate the total Danish consumption of NP/NPE in various products, it can be assumed that most of the cost will accrue nationally. An illustrative calculation in this report shows that the earlier the deadline is for total substitution, the higher will the cost be: There is not assessed to be any cost associated with Scenario A. In Scenario B, the cost would be DKK 2.5 to 4.3 million, also in welfare-economic terms.

The cost in Scenario B of dredging remaining TBT contaminated sediments and dispose of the sediments on land in 2025 (as a means of eliminating unacceptable “losses" to the marine aquatic environment) was calculated. This results in a total welfare-economic cost of between DKK 11-39 and DKK 27-98 million DKK in net present value depending on whether the low estimate of 100,000 m³ or the high estimate of 250,000 m³ is used. The corresponding financial cost is estimated to be between DKK 5-16 and DKK 11-40 million in net present value. There is no cost associated with Scenario A/C.

14.3.2 Assessment of common measures for all substances

In a national perspective the majority of stormwater discharges are considered to comply with the MAC-EQS values. However, in some parts of the country, mainly the eastern, there may problems in the summer season (at median minimum of dry weather flow) in obtaining even a dilution factor of about 3 as required for nonylphenol. As this situation may represent as much as 40 % of the of the volume of separate stormwater discharges, the likely non-compliance with the MAC-EQS should not be overlooked and has therefore been assessed economically under common measures for stormwater.

A common measure was proposed to fulfil the obligations of progressive reduction of priority substances and cessation/phasing-out of priority hazardous substances. It should be noted that in Scenario A/C the objective of aiming at progressive reduction of priority substances and cessation/phasing out of priority hazardous substances is a requirement according to the existing WFD, not the final Daughter Directive proposal.

An economic assessment was made of the common measure for all substances. Detention of suspended solids in stormwater runoff was investigated in Chapter 13. A cost assessment was made of the gradual implementation of two types of technology to an end result of 40 % (critical areas where the MAC-EQS requirement cannot be met for an extended period, Scenario A/C) and in the worst-case 85 % (Scenario B) of the volume of all stormwater runoff discharges being treated.

The 85 % scenario corresponds to the total volume of stormwater discharges into freshwater bodies, all of which, when interpreting the obligations in Scenario B in a strict way, must be equipped with detention arrangements before 2025 to ensure cessation/phase-out of the discharges of priority hazardous substances.

The 40 % scenario in Scenario C reflects the fraction of the stormwater volume being discharged into streams where less than 3 times initial dilution (needed for MAC-EQS compliance for the most critical substance, nonylphenol) can be obtained in the summer at median minimum flow. Therefore, the same percentage has been used for illustrating the costs of cessation/phase-out of priority hazardous substances in Scenario A/C. If an in-depth analysis shows that a lower initial dilution requirement can be justified for the most critical substance (currently nonylphenol) with regard to EQS, Scenario A/C should be based on a lower percentage than 40 % of the volume also for cessation/phase-out.

The total welfare-economic cost in the two scenarios is estimated. In the case of retention of sediment in 40 % (Scenario A/C) of all stormwater runoff, the cost of the technology "storage with sedimentation alone" is DKK 2.0 billion for storage chambers with sedimentation and DKK 4.7 billion if treatment of outlet is added (discount rate of 3 % is used).  The majority of the cost can be attributed the cost of investment and the operating and maintenance costs of the technology, which are DKK 1.6 and DKK 4.4 billion respectively.

The total financial cost is DKK 1.2 billion for storage chambers with sedimentation and DKK 2.6 billion if treatment of outlet is added (discount rate of 6 % is used). The cost of investment and the operating and maintenance costs of the technology alone are DKK 1.0 and DKK 2.4 billion respectively.

In the worst case where 85 % of the stormwater runoff must be treated, the cost of the technology "storage with sedimentation alone" with a deadline in 2025 (Scenario B) is DKK 5.6 billion for storage chambers with sedimentation and DKK 13.9 billion if treatment of outlet is added (discount rate of 3 % is used). The bulk of this cost can be attributed to the cost of investment and the operating and maintenance costs of the technology are DKK 4.6 and DKK 12.7 billion respectively.

The total financial cost is DKK 3.7 billion for storage chambers with sedimentation and DKK 7.8 billion if treatment of outlet is added (discount rate of 6 % is used). The cost of investment and the operating and maintenance costs of the technology alone are DKK 3.0 and DKK 7.1 billion respectively.

14.3.3 Conclusion on economic consequences

Recommendations for the most useful measures in regulating PS and PHS should be based on both technical effectiveness and the financial cost to industry and consumers, and the welfare-economic cost to society as a whole. A thorough economic analysis of the various measures would be required to make such a decision. A detailed analysis is beyond the scope of this study but some general conclusions can be drawn.

For the purpose of estimating the total cost of the most cost-effective package of policies to comply with the objectives of Scenario A/C and Scenario B, we first looked at possible substitution of the substances. This option is generally assumed to be the most cost-effective measure (since it is abatement), but this can vary greatly depending on whether there are any known substitutes and on other factors. Also, the degree of substitution needed will have a significant effect on the cost since total substitution as mentioned often will be very expensive due to high costs of replacing the last few percent of the use of a substance. Again, this may vary between substances and their uses. We have attempted to give a rough assessment of the cost of substitution where it was technically assessed to be relevant the prerequisite beingavailability of data on the cost.

We also looked at common substance reduction measures. This may be the only option for some substances for which the main contribution to the aquatic environment comes from diffuse sources to stormwater including atmospheric deposition. From an economic point of view, it may also be the overall most cost-effective measure because of the synergy effect. General reduction measures such as detention of suspended solids in wastewater or stormwater runoff have an effect on all the priority substances at the same time. The effect will vary from substance to substance depending on the inherent properties of the substances, in particular their inclination to sorb to suspended solids. The cost of this sort of measures can therefore not be attributed to one particular substance, but instead gives an idea of the total cost of measures and an estimate of the effect on the individual priority substances.

Abatement measures such as phasing-out the use of a substance or limiting the emissions to the environment are generally recommended as being less costly than clean-up measures. In the case of significant synergies in cleaning up this may, however, not be the case. The cost of substance-specific measures must therefore be considered against the common measures that target all substances. The economic estimates in this analysis are not sufficient to give a clear recommendation on whether abatement or clean-up measures are the most cost-effective. It would, however, appear to be the case given that alternatives appear to be available for most of the substances in question. However, for some substances the only technical option that remains to meet the quality criteria are clean-up measures as the sources losses to the environment originate from uses that are now historical.

It is obvious that the longer the time period that is allowed for a substance to be phased out or cleaned up, the easier and less costly it will be for companies to adapt to consumers and society. This assumes a positive discount rate. Hence, there will be an extra cost of complying with the Daughter Directive in the cases where faster phasing-out of hazardous substances is required than otherwise intended in Danish environmental policy based on the WFD.

A final relevant conclusion regarding the potential economic cost of Scenario A/C and Scenario B is that many of the relevant measures will only be possible and effective if implemented Community-wide. There are two reasons for this; firstly, there are regulatory constraints on bans, environmental taxes, and other measures that counteracting the Common Market. And secondly, the global market for goods means that national agreements may only have limited effects.

In conclusion, from Table 14-3, no purely national options are available with regard to nonylphenol(ethoxylates). For cadmium, both national and Community-wide implementation of measures will be possible. As discussed in Chapter 3.4, initiation of measures at the national level will probably have a lower cost-efficiency than Community-wide initiatives. For mercury, TBT in harbour sediments and general regulation of priority substances in stormwater runoff only national measures are relevant.

Since the analysis does not involve a regulatory impact assessment of the proposed Directive, it is difficult to draw conclusions on the financial costs to the state, industry and consumers. The issue is further complicated by the fact that regulatory impact assessments have yet to be made for the Water Frame Directive in Denmark. The welfare-economic cost to society as a whole has thus been the main focus of this report. However, based on current practices in the Danish environmental policy, the financial cost can be expected to accrue to the different groups as shown in Table 14-4 below.

Table 14-4 Potential distribution of financial cost of proposed measures

* ) Note that consumer financing is not assumed in the calculation of the welfare-economic cost.

For PS/PHS in sewage/wastewater it is assessed that the requirement to comply with the proposed EQS values will not imply additional costs to Denmark as the current levels in the aquatic environment and in wastewater discharges are so low that the EQS values are generally not at risk to be exceeded.

In a national perspective the majority of stormwater discharges are also considered to comply with the MAC-EQS values. However, in some parts of the country, mainly the eastern, there may problems in the summer season (at median minimum of dry weather flow) in obtaining even a dilution factor of about 3 as required for nonylphenol. As this situation may represent as much as 40 % of the volume of separate stormwater discharges, the likely non-compliance with the MAC-EQS should not be overlooked.

The welfare and financial cost of proposed measures to fulfil the obligations of progressive reduction of priority substances and cessation/phasing-out of priority substances is shown in table 14-5. The table corresponds to table 14.2 which summed up the technical assessment. The estimated cost for each potential measure is given in welfare economic terms. It should be noted that in Sceanario A/C the objective of aiming at progressive reduction of priority substances and cessation/phasing out of priority hazardous substances is a requirement according to the existing WFD, not the final Daughter Directive proposal.

Table 14-5 Welfare-economic cost of proposed measures (as in Table 14-2). Financial costs are shown in parenthesis. Net Present Value with a 30-year horizon.

1   As part of common action against several substances in critical areas (40 % of volume).
2   As part of common action against several substances (85 % of volume).

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Version 1.0 August 2007, © Danish Environmental Protection Agency