The European Commission needs to enter the ‘digital decade’: it’s about time that it creates a monitoring and benchmarking tool to enable tracking progress towards the delivery on the EU Green Deal objectives, writes Christian Schaible.

How does decision makers’ mantra of “entering the digital age” and “artificial intelligence” fit in with the lamentable reality of lack of access to basic environmental performance information on EU’s biggest industrial activities?  

In its State of the Union Speech, European Commission President Von der Leyen declared that the EU will enter the “digital decade”, stressed the importance of “evidence-based” decision-making, insisting on the role of “smart technologies like artificial intelligence”, “digital technologies to build a healthier, greener society”, and ‘free flow of (industrial) data’. Most importantly, she highlighted that “industrial data will quadruple in next 5 years […] and is worth its weight in gold when it comes to developing new products and services.” Yet, she also concluded that “in reality 80% of industrial data is collected and never used. This is pure waste”.

We could not agree more although we would have welcomed an acknowledgement that badly designed reporting tools and mechanisms, resulting from the European Commission’s short-sightedness, are largely the root problem. The EU’s Green Deal and related policies contain various forward-looking objectives, e.g. climate-neutrality, a toxic-free environment and zero pollution, all connected to the Sustainable Development Goals (SDGs). Where are then the tools that will enable all stakeholders to track progress and benchmark economic actors, including the member states’ decision makers, against those objectives?  

The industry wants to achieve carbon neutral production and member states have embraced the Sustainable Development Goals (SDGs), but the EU has not yet figured out how to make available basic, public, environmental databases – including carbon-footprint ones – that would enable all actors to share knowledge on this transition path. 

What is the ‘digital age’ good for if it does not serve a large set of wider public purposes, in particular benchmarking and compliance promotion vis à vis the set SDGs? 

How do we measure success, identify hot spots for action, share data on efforts in pollution prevention and compliance, in order to progress towards those targets?  

The Pollutant Release and Transfer Registers (PRTRs) could provide an answer

The PRTRs are a tool that seeks to live up to the intentions of the Aarhus Convention, striving for more transparency, accountability, public participation and access to justice on environmental matters. The current tool is based on UNECE Kiev Protocol dating back to 2003.

The current E-PRT Regulation is one of the bad examples of EU policy needing to catch up with the digital age and make it work for us, instead of against us. Reporting requirements and environmental performance data, except for resource consumption, are already generated but not made best use of for benchmarking and compliance promotion. 

There is a considerable reporting and monitoring deficit on the largest EU industrial activities, as highlighted by the ‘Burning: the evidence’ report published by the EEB in 2017. Due to inertia at the EU (and most member states) level, the EEB has therefore decided to build its own database on large combustion plants. It was a huge struggle to collate basic information such as permit conditions or monitoring data by approaching one by one the competent authorities of the member states. The E-PRTR and IED reporting tools failed to do that job for us.  

However, good examples exist and have been highlighted by the EEB -notably in section 6 of the EU Green Deal and Industrial activities briefing

Since 2015, the EEB has been asking for a re-opening of the E-PRTR, to make it fit for various purposes, in particular performance benchmarking and compliance promotion. Better late than never, the European Commission has finally put the EU-PRTR for review, sharing its findings on the inception impact assessment open for public consultation up to 26/10/2020. The EEB’s submission focuses on the following points.

1. The E-PRTR needs a fundamental overhaul as to serve multiple objectives, in particular benchmarking and compliance promotion, in order ensure preventative action

Currently, information is limited to a reduced number of pollutant emissions and not inputs (resources, use of chemicals), and is already outdated when reported, or provided out of context. A centralised, single access point with useful search filters is missing.  

In addition, information fails to assess impacts or threats to health and environmental protection, as well as to assess compliance with permit conditions or performance vis à vis Best Available Techniques (BAT) of pollution prevention and reduction standards.  

SDGs also apply to government actors, but progress tracking and reporting via the PRTR is currently absent. 

2. Reporting should change focus in terms of intended output or service provided by a given industrial activity. 

The ratio of ‘environmental impact of industrial activity’ versus ‘public good/service provided’ needs to be considered to allow for a more holistic comparison of the options and solutions. 

3. We need production inputs and impacts on outposts from products (i.e. ‘diffuse’ emissions) to enable a benchmarking of industrial activities. 

Currently, only the Norwegian PRTR is pro-actively publishing production output and diffuse emissions from products in a centralised database.

In general, hardly any input-relevant information (e.g. qualitative and quantitative information on resources) is available. 

4. Real-time environmental performance information must be disclosed and used more effectively. 

This could for instance include informing BAT standards, a compliance assessment against environmental quality standards, and permit conditions and review status.

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