11.  Requirements as to the State of the Environment



In Chapters 5-10 I reviewed environmental requirements to industry, to special plants and facilities, to agriculture, to consumers, to the manufacturers and users of chemicals, and to polluters causing site contamination. These are requirements directed at the individual polluters, and if they are not complied with, there are means of forcing them through (see Chapter 13).

In the present chapter I will review requirements and lines of reasoning that are based on the state of the environment; these are directed at the authorities rather than at the polluters, and will only gain significance for polluters if the authorities implement them in the form of environmental requirements of the type discussed in Chapters 5-10.

11.1. Strategic considerations

There is something principally correct about basing strategy on the state of the environment: If the latter is unsatisfactory, then one has to define what is satisfactory. On the other hand, if the state of the environment is satisfactory, then one does not need to exert oneself in trying to improve it.

This line of reasoning has previously played a major role in Danish environmental administration. In the 1970s it was believed in Denmark that the sea was a "robust recipient" able to absorb considerable amounts of organic matter and nutrients. It was thought that the Swedes unnecessarily wasted money when they introduced biological treatment of urban sewage discharged to the sea. It was believed that meticulous recipient quality planning would enable definition of how much could be discharged such that neither too little nor too much was invested in treatment facilities.

Within 10-12 years, however, it became apparent that the sea was not as robust as believed. The consequence was that a new line of reasoning took over, as exemplified by the 1987 Action Plan on the Aquatic Environment: This was to treat the sewage as effectively as possible, and then see if that helped. In other words: No more sewage was to be discharged into the surroundings than absolutely necessary.

Development has been similar with respect to air pollution. In this case it has always been clear that the problems in Denmark were minor compared with, for example, Germany. As a consequence, endeavours on this front were moderate for many years, typically being characterized by the tall smokestack solution. However, acidification of Swedish lakes sparked off the first economically hard-hitting requirements on air pollution abatement measures in 1984. With time, the attitude in this area has also developed to one that emissions to the environment must not be greater than necessary. It is on this line of reasoning that the 1990 Guidelines on Industrial Air Pollution Control are based.

Nevertheless, the course of events so far does not preclude the possibility that the pendulum can once again swing in the direction of planning based on recipient quality. Thus if after implementation of all the treatment measures demanded by the Action Plan on the Aquatic Environment in 1995 it transpires that pollution of watercourses, lakes and the sea is still excessive, then it will be necessary to implement further measures (perhaps further treatment) in order to approach the target, i.e. an aquatic environment of an acceptable standard1.

In any event, it will be necessary to face the fact that it is man who defines what is acceptable. In only few places will it be possible to attain completely unpolluted conditions. However, whether the water should be clean enough for salmonids, or for cyprinids, or for some other organism, is a decision taken by man.