original dutch can be found here:
Critical comments on the Dutch approach to the nitrogen crisis and suggestions for solutions. Concept.
Prof. Dr. Han Lindeboom
with contributions from Prof Dr Johan Sanders, Dr Marc Jacobs, Prof Dr Ronald Meester,
Mr Willem Bruil and Dr Jaap Hanekamp
Part 2 at Lindeboom, Sanders ea “How do we get out of the nitrogen impasse in the Netherlands?”
With New information about Shortcomings of the RIVM model
Ammonia from the North Sea
may differ NH3
Nature and now what?
More of this
and less of that
Chapter Chapter Chapter Chapter Chapter
2 What goes wrong with the RIVM nitrogen model or, how models to live their own life
3 Comments from Jaap Hanekamp’s blog posts
4 Nitrogen crisis -legal aspects
5 Agriculture will only become future-proof through the drastically improve nitrogen efficiency
6 Nature requires customization, not nitrogen standards
Appendix 1 Speech by the Prime Minister of Tessel 24
Appendix 2 Ammonia from sea, latest developments 25
Appendix 3 A solution for the nitrogen problem in coastal fisheries? 30
Appendix 4 Adjusting diet and other techniques to reduce NH3 emissions 33
Appendix 5 Towards a local, integrated area-oriented nature approach in the Netherlands 35 Appendix 6 Confidential investigation TNO makes mincemeat of RIVM model 39
Prayer for serenity by Reinhold Niebuhr
‘Give me the serenity to accept what I cannot change the courage to change what I can change
and the wisdom to tell the difference’
For more information: firstname.lastname@example.org
Critical comments on the Dutch approach to the nitrogen crisis and suggestions for solutions.
Part 2 at Lindeboom, Sanders ea “How do we get out of the nitrogen impasse in the Netherlands?”
Version 1 Draft
Prof. Dr. Han Lindeboom
With contributions from Prof Dr Johan Sanders, Dr Marc Jacobs, Prof Dr Ronald Meester, Mr Willem Bruil and Dr Jaap Hanekamp1 .
In addition to our previous report ‘How do we get out of the nitrogen impasse in the Netherlands’, we have collected new information in this report that can contribute to a solution.
Summary of new findings.
In Chapter 2 on the RIVM nitrogen model, it follows from quotations from a forthcoming book by Marc Jacobs and Ronald Meester on the use of models for policy that so many comments are
made, including identified uncertainties and improper model use, that OPS (the RIVM model) and
the Aerius Calculator should never have been used for policy. In view of the enormous consequences for an entire Dutch profession, a revision of the current policy is recommended.
In Chapter 3, with comments from Jaap Hanekamp’s blog posts, the conclusions follow:
KDW are not decision-making tools. They are numbers of a strongly reductionist
nature that suggest an ecological precision that does not exist. KDW is subject to numerous uncertainties and ambiguities that make the current use in policy (and AERIUS) questionable from a scientific point of view.
In Chapter 4, Willem Bruil indicates that two legal instruments are available to start immediately with the restoration of Natura 2000 areas: the management plans of art. 2.3 Nature Conservation and Land Development Act of the Rural Areas Development Act (WILG). These instruments also make it possible to link up very well with the initiatives that were or are already underway throughout the country. Trust between parties can be restored.
In Chapter 5 Johan Sanders provides an addition on how to make agriculture future-proof
in terms of efficient nitrogen use and associated lower emissions.
Chapter 6 describes how we can better use existing and desired natural values for policy and management per Natura 2000 area and not nitrogen deposition values.
The appendices provide a lot of additional information to further substantiate the discussions and conclusions.
With both notes we hope to have made a total package to get out of the crisis.
Only through an integrated approach in which we fully include all aspects of the nitrogen cycles and processes can we get out of the nitrogen crisis and ensure healthy nature, sufficient food for everyone and a varied landscape.
And thanks to Carla Soesbergen Kuipers and Drs Luit Buurma for many inspiring discussions 3
Chapter 1 Introduction
Partly due to a quicksand-based approach to the nitrogen crisis in which the current nature quality of Natura 2000 areas, but nitrogen depositions calculated using a complex model, are the leading parameter for measures and the fact that people are too little open to alternatives and innovations is the current crisis arise. In doing so, little account is taken of the social consequences for an entire industry and our food production and the layout of our landscape are unnecessarily seriously endangered. In this memorandum we make critical comments on both the basis and the implementation of the Dutch approach and we make suggestions on how this can be done differently with less social impact, better results for nature and at lower costs.
Numbers, models, interpretations
Questions are regularly asked about RIVM modelling. The Hordijk Committee may have been
too optimistic about the application of the RIVM model. This has been criticized by Marc Jacobs and Ronald Meester, who are writing a book about this (see Chapter 2) and by Jaap Hanekamp, former member of the Hordijk Committee, who has written blogs (see Chapter 3). Both come to the conclusion that OPS (the RIVM model) and the Aerius Calculator should never have been used for policy. And TNO recently made mincemeat of the RIVM model in confidential research (Appendix 8)
Nitrogen Cycle (See also pages 8-16 Note 1)
Mixing up NH3 and NOX is not scientifically justified with regard to the effects on individual Natura 2000 areas. NH3 and NOX behave differently in the atmosphere as well as in the ecosystem. For example, in the calculations by the Ministry of Finance about the nitrogen space that would be created for agriculture if stopping the use of fossil fuels, which means that NOX production disappears (which is correct; if we get rid of combustion engines, we also get rid of NOx emissions) no account is taken of the fact that the sources are concentrated in completely different areas in the Netherlands and therefore have effects on other Natura 2000 areas. This also raises major questions about the exchange of NH3 and NOx sources, for example at Schiphol, which wants to buy out farmers (NH3) in order to be allowed to emit more NOx themselves. The effects of this cannot be predicted.
Depositions and problems
Research into the nitrogen cycle in a penguin colony (pages 9-10, note 1) and
observations in nature reserves in the Netherlands shows that the process of deposition has a
completely different spatial pattern than RIVM and the government assume. There are major
differences between NH3 and NOx and between dry and wet deposition, which lead to hotspots for effects. NH3 provides effects through wet deposition up to 150-200 m downwind of the source. NOx and
drifting NH3 cause effects in places where the air is in relief, such as
wooded banks, forest edges, structures, etc. There is much that can be improved through
targeted observations and customization on the right scale. Certainly if one also looks for hotspots of
good nature and expands them locally as much as possible. Of course there is also a variable nitrogen blanket over the Netherlands, but a generic approach will not yield much in view of the effect and
location of hotspots.
Ammonia from sea, latest developments (see also Appendix 2 in Note 1)
There is a new letter from the Minister of N&S (see Appendix 3) stating that it has become clear that the influence
of ammonia from the sea on the dunes area is less certain than previously thought. In an added footnote, RIVM indicates that it is currently working on 3 different studies. Two to see if salt crystals or atmospheric conditions in the dunes are interfering with the measurements and one to see if the birds in the dunes could be the cause. But these studies will either indicate that the methods are no good or solve nothing, and birds can definitely never poop that much. The nitrogen gains for agriculture, construction and nature in and near those areas have been calculated for 30 Natura 2000 areas and it is proposed that the benefit of the doubt should no longer be given to RIVM but to society. For Texel, with a high contribution of ammonia from the sea, according to the RIVM, there are indications that the conclusions that nature is dying due to nitrogen are incorrect.
Many nitrogen-averse plants are found. This also provides nitrogen space for coastal fisheries, which are already having a hard time without unnecessary nitrogen requirements (see appendix 4).
Nature requires customization, not nitrogen standards. (Chapter 6)
Dutch nature is not natural, but man-made and that requires maintenance.
In addition to nitrogen, also look at other causes of (undesirable) nature development, such as water management (desiccation/wetting), layout, grazing, maintenance, pesticides, other use. And don’t forget the cats and dogs. Climate change also plays a role. We can also focus more on vulnerable species such as (for Texel) sundew, various types of orchids, parnassia, rosary, dog violet and dune violet. By making an inventory of where these species still occur, you can take very specific measures to maintain or even expand those species there.
All this calls for a rethink in the approach to the nitrogen problem. In view of the problems in agriculture, fishing and construction, it is high time to start immediately. Don’t strive for unattainable ideals in a crowded Netherlands, but come up with a realistic approach that uses opportunities where they really lie. In order to set up a nationally uniform set of instruments, it is proposed to take the star system that we have already introduced in our earlier memorandum and possibly try it out in a few test areas.
In chapter 5 Johan Sanders proposes to apply 9 different methods to reduce NH3 production per farm. These include increasing the share of essential amino acids
for pigs and poultry and resistant protein in cattle feed, collecting beet leaves, increasing field yield of grass by mixed cultivation with leguminous plants, acidifying manure, refining grass, collecting urine and faeces separately, etc (see also pages 42-48 first note).
In Chapter 4, Willem Bruil indicates that two legal instruments are available to start immediately with the restoration of Natura 2000 areas: the management plans of art. 2.3 Nature Conservation and Land Development Act of the Rural Areas Development Act (WILG). These instruments also make it possible to link up very well with the initiatives that were or are already underway throughout the country. Trust between parties can be restored. A point of attention is, of course, the granting of permits for
projects that have to be realized due to an ‘imperative reason of overriding public interest’. The Habitats Directive (Article 6, paragraphs 3 and 4) offers an opening for this.
There are rumors that there are hidden agendas under the current measures. For example,
vegan utopians would disproportionately influence government policy. Critical scientists are silenced or banned from speaking. New information is ignored or minimized. This deserves further attention. The Netherlands has a dysfunctional government structure and culture that makes policy processes inefficient, lasts until St Juttemis and costs unnecessary money. The discussion about farmers focuses entirely on nitrogen, but you hardly hear that driving away 6,000 to 15,000 (and more) farmers will lead to major destruction of our food production, and who is going to maintain the landscape when the farmers are gone. I asked that up to 75% of the livestock (including sheep!) on Texel should be removed where possible. Will the parks service do that? ….. So no.
It can be different and it must be different. For an alternative approach, see the speech of the Prime Minister of the Free Republic of Tessel in Appendix 1 on page 24.
And as my grandma used to say, “Can’t-is in the graveyard and won’t-is next to it.”
What is going wrong with the RIVM nitrogen model or how models are going to
lead their own lives. (Han Lindeboom)
Inspired by and supplemented with citations from the forthcoming book From Earthquake to Zoonoses – a critical discussion of the use of models for policy by Marc Jacobs and Ronald Meester (winter 2023, Walburg Pers)
The developments in society in recent years were special in many respects. I (HL) had the opportunity to read a few chapters from Marc and Ronald’s manuscript in the making. One of the first observations they make is that the major social themes (nitrogen, allowances, COVID-19, climate, earthquakes, and the financial crisis) all have to do with mathematical models and their far-reaching influence on policy-making.
In the first chapter, philosopher of science and historian Daan Wegener
about which Marc and Ronald have the following to say: “Mathematical models function as a kind of mediators between theory and reality. Wegener mainly thinks of physics, in which he sees models as instruments to make natural laws meaningful. That’s an interesting point of view, but applied to things other than physics, it falls short. After all, mathematical models in the nitrogen dossier form the theory themselves. The model was the theory, there was no natural law involved. If the models are the mediators between reality and ourselves, it is very questionable to what extent reality can be unraveled through us”.
We cannot generally solve the practical and detailed problems that arise
with modeling, but we may be able to ensure that the model takes on the role it should have: as something to our advantage. Marc and Ronald explicitly describe that a model is now used as a final judgment, but is actually a starting point for a conversation: “The model can only be a coherent whole composed by people, and its use can therefore never be routine. The model is the beginning, not the end, and insists on exegesis.”
The authors have the following to say about the role of models and numbers:
“We understand that numbers can create a certain semblance of objectivity, and that many people assume that what is formulated mathematically must be true. In fact, we
can say that Dutch politics has largely surrendered itself to the models and the model makers. But the problem is not in the mathematics itself, which is often not even very deep. The problem lies in the interaction between reality and ourselves, and the mediating role that the models play in this. Once a model has been formulated mathematically, the manipulations and calculations within that model are usually not so controversial, but their interpretation is. A model is not an independent entity, but connected to the maker and the user”.
Question marks about the RIVM nitrogen model.
Marc and Ronald also write specifically about the nitrogen model OPS and the complexity of the modelling. In fact, it is so complex that the uncertainty makes any form of policy making impossible: “Modelling nitrogen deposition, with all its complexity, is of course not easy. For example, there is uncertainty in emissions, atmospheric transport (nitrogen from point A to point B), dry and wet deposition and long-distance transport. Ultimately, depending on the specific nitrogen compound, this leads to an uncertainty of 20-30% on a national scale in the calculation of the total annual average deposition. For the local scale (individual ecosystems), the reported uncertainty is between 50% and 95%. The Hordijk Committee attributes the great uncertainty in part to the way in which data is collected.”
With such uncertainty, it is almost impossible to determine policy, regardless
of where that uncertainty comes from. Marc and Ronald write the following about this:
”At the time of the final report of the advisory board, the uncertainty margins were
around 30% on a national scale and between 50% and 95% on a local scale. We
pointed out earlier that such margins are not so easy to interpret, but whoever has calculated these numbers, it is clear that all outcomes are extremely uncertain. If you compare the resolution of the nitrogen map to the resolution and the level of the model, you can see that the OPS model can never meet the demand. The nitrogen policy requires that it is possible to accurately determine per hectare what the nitrogen deposition is and where it comes from by modeling how and where the estimated emission has ended up. So it is quite possible that the basis for expropriating land and people to promote nitrogen reduction is very narrow.”
There is a lot to like about the OPS model itself, but the part that should raise
most eyebrows is the way in which client and contractor are connected. As with corona, RIVM is also responsible for nitrogen modelling. Marc and Ronald write about this explicitly, but it is actually the Hordijk Committee that gives the most complete description. The authors write the following about this: “The advisory board is of the opinion that transparency, (scientific) support and the governance structure surrounding the instruments must be improved. After all, a governance structure must be used for the Emission Registration, for AERIUS and for the modelling/ measurements in which commissioning and execution are separated”. These recommendations are repeated in their final report: “The advisory board has noted that improvements are possible in the governance of the measurement and calculation system.
It is important to have a clear separation of responsibilities between the client and the contractor. Unambiguous management, guaranteeing scientific independence and a system of quality assurance are important aspects.”
A last detail that deserves to be mentioned is how heavy
the partial models interact to create an alternative reality. In the case of the OPS model, the modeling for emission, deposition and airflow interacts making it almost impossible to verify predictions. Marc and Ronald write the following about this: “Each cause is given a number, an ecological footprint. To do this for a farm, for example
In order to be able to determine, an inventory of all parts of that farm is first made.
For example, the type and number of animals kept, the number of square meters
and the layout of the stables and the equipment used are registered. Each component is then looked up in an emission values catalog so that the total emissions can be modelled. The emissions from each farm, and therefore from each vehicle or activity, are an estimate with a limited shelf life. Subsequently, the modeled emissions must be checked against the observed or modeled deposition values. This is done by means of the transport model, which technically calculates whether the prediction of the direction and amount of transport corresponds to the modeled measurement. Because multiple factors can influence one measurement area, it is the task of the model to find out who contributed what.
The theoretical contribution is also compared with the theoretical source”. End quotes from Marc and Ronald
The report “Not taken out of thin air ” of the Advisory Board for Measuring and Calculating Nitrogen (Hordijk Committee) of 5 March 2020 states: “The advisory board concludes that the data, methods and models that are used, also in an international perspective, are are of sufficient to good quality and are therefore suitable for measuring and calculating the concentration and deposition of nitrogen compounds. The advisory board also determined that improvements to the entire system are needed, but as far as is known, no significant improvements have been made since that time.” It now follows from the above quotes from Marc and Ronald that there are so many comments, including the identified uncertainties and improper use of the model, that OPS (the RIVM model) and the Aerius Calculator should never have been used for policy. In view of the enormous consequences for an entire Dutch profession , a revision of the current policy is recommended.
Comments from the blog posts of Jaap Hanekamp.
Over the past year and a half, Jaap Hanekamp, former member of the Advisory Board for Measuring and Calculating Nitrogen, has published a number of blog posts. Jaap is critical of the main conclusions of the report of the Hordijk Committee: Not taken out of thin air.
See also: https://jaaphanekamp.com/blog/politics/science/media/2022-06-17-magie deception-contempt-en-macht-het-stikstofbeleid-in-vier-termen/
Below are some notable excerpts from this and other blog posts.
Blog post ‘Nature and nitrogen-lake about critical deposition’
He writes about the KDW for Habitat type H4030, heath: KDW for heath has no visible
substantive scientific development history and is nevertheless used as a critical cut-off point in
Aerius without transparent substantiation.
In combination with the large nitrogen uncertainty at the hectare level, the KDW does not provide
any actual insight into the functional and measurable level of protection of habitats such as heathland.
“Even with the full realization that heathland areas have an important natural value, the motto ‘first culture and then nature’ should still be an important guideline for the current management of the ‘heathland’ cultural landscape.
Blog post ‘Mistakes of justice in the uncertain nitrogen landscape’
Sometimes you shouldn’t ask judges for anything. Simply because they don’t understand the issue being presented to them.
Sometimes the result of lawsuits entered into is ignorant case law. This is often related to a specific problem.
Judges often overestimate their understanding of the scientific world and the resulting
knowledge, which implicitly or explicitly plays a central role in the relevant cases.
Scientific research should, according to the judge,
-firstly, to provide certainty with regard to ammonia emissions and depositions – i.e. precision about (i) ammonia sources, their locations and emission quantities; (ii) ammonia deposition on nature reserves.
-and secondly, to provide certainty about the conservation of the intended natural features in relation to the nitrogen deposition that can be determined with certainty – ie precision about (ii) CDW; (ii) their significance for the effects on nature.
According to the judge, scientific research ultimately seems to offer too little certainty, because: (i) nitrogen emissions are uncertain; (ii) nitrogen deposition is uncertain; (iii)
nature effects of nitrogen deposition are uncertain. The judge therefore concludes that…
“… it is insufficiently certain that the emissions of the company in the licensed situation
will not already increase and the license has not been based on an appropriate assessment, which assesses what the actual emission will be, to which deposition that emission will lead and what the consequences of that deposition will be in light of the conservation objectives of the Natura 2000 sites concerned.”
Hilarious actually, at least if the nitrogen tragedy isn’t such a … well … tragedy.
The irony aside, what is crystal clear in this verdict is the judge’s utterly confused perspective on what scientific research should deliver and what in fact is (and can be) delivered.
The contradiction that the judge embraces coûte que coûte is the demand for certainty that science in principle can never provide. In other words, the judge here wears the ideology of scientism, the curse of our time.
I’ll just give a definition for the sake of completeness (and note it, dear reader, because this ideology is everywhere, unfortunately):
Scientism is the fallacy that science can fathom the operation and structure of
reality in its entirety and with precision – I’ll just call it a crossroads: KDW and the state of ‘nature’ – so that action perspectives can be successfully realized on the basis of that knowledge.
One thing is already clear: it is indefensible to use the KDW in law, regulations and
court decisions as conservation referees.
If we want to raise the quality of legislation and regulations for the benefit of Dutch nature, we will have to do a lot more work than allocate KDW to habitats in nature reserves.
Blog post ‘The (un)critical discourse on critical deposition’
The Dutch perspective on H4030 is simplistic and nothing but an expression of nitrogen tunnel vision (emphasis added):
Farming, farming, and more farming threatens H4030; i.e. agricultural nitrogen deposition (mainly ammonia). At least, that’s what ‘the Netherlands’ reports to the European Commission.
Blog post ‘The PBL and Nitrogen – Critical Depreciation of Deposition’
Nitrogen therefore plays a misplaced ‘leading role’ in the Dutch assessment of
nature quality, and that is exactly what the PBL is now saying!
In this policy brief, the PBL shows that the tension between goals, strategy and consequences will be less great if area-specific nature quality is not the focus of
nitrogen but area-specific nature quality. To do this in a legally tenable and manageable way in the short term, a substantial strengthening of the area-specific ecological data collection, analysis and scientific judgment is required. That is what the Habitats Directive requires. For nitrogen measures, the short-term priority can be placed around areas where
the trend in nature quality is negative and the exceedance of the KDWs is large. It is important to choose nitrogen source measures in such a way that they do not hinder the chosen climate goals and strategy in agriculture, but rather reinforce them.”
Since the late 1980s, tens of millions of euros have been spent on WUR, RIVM and other institutes to fill a hangar with research reports that only a few read.
Blog post ‘Nitrogen like old wine in even older bottles.’
Nevertheless, all this has led to the software package (with accompanying hardware) AERIUS and a few dozen Critical Deposition Values (KDW). Together, both are considered and used as a kind of natural thermostat .
Just say a ‘nitrogen state’.
In other words: more nitrogen deposition results in a higher ‘nitrogen state’ and therefore less
nature quality; less nitrogen deposition results in a lower nitrogen state and therefore more nature quality.
Even the PBL no longer believes this; and that’s saying something.
We have therefore identified four points of criticism here, which are discussed in depth in our large article and which the minister, of course, leaves entirely unaddressed.
Why still ask questions to a minister if her answers always fall back on literature that
demonstrably falls short? Here are our four criticisms:
1. KDW contain very large and undisputed uncertainties; 2. the commonly used KDW definition lacks scientific
3. Far too few ‘real world’ experiments have been conducted on a large scale; 4. the overused ‘expert judgement’ is scientifically inimitable.
So no, the scientific research cherished by the minister has not provided a definitive answer on these and other points on the relationship between nitrogen and nature quality as reduced in the numerical KDW.
Again: KDW are therefore not a decision-making tool. They are numbers of a strongly reductionist nature that suggest an ecological precision that does not exist.
This blog post ‘The House of Representatives and KDW – a small analysis’ is also worth reading:
The conclusions from this:
First conclusion: KDW are incorrectly implemented, without a social and economic risk-
analytical context, as bare standards for nitrogen-emitting activities (nitrogen = NOx and ammonia, among others).
Second conclusion: KDW do not come “from science”. It is human work that is often incomplete, lacks precision or even incorrectly presents conclusions based on misunderstood statistics. As far as expert estimates are concerned, KDW suggest far too much certainty that does not exist.
Third conclusion: KDW is subject to numerous uncertainties and ambiguities that make the current use in policy (and AERIUS) questionable from a scientific point of view.
Nitrogen crises – legal aspects
Willem Bruil Augustus 2022
This is a short piece on the legal aspects of the nitrogen crisis. For more detailed information, reference is made to the following documents:
– Solving the acute nitrogen crisis, NJB 15 November 2019, p. 2955 ecu
– Stikstofcrises, TvAR 2022, p. 183 ev
– Another milestone in the nitrogen approach, TvAR (June 2022, forthcoming)
In these documents I have shown that the response of many – starting with the
Remkes Committee – to the Council of State’s decision on the Programmatic
Approach to Nitrogen (May 2019) was completely wrong: the Council of State did not rule that the nitrogen deposition on Natura 2000 areas had to be reduced , but only that the PAS (which allowed an increase in deposition) was in conflict with the Habitats Directive and therefore had to be removed. So we could have returned to the working method before the PAS, but that did not happen. Whether that is due to incompetence
or political expediency can be left open. It may be the case that the nitrogen deposition
in Natura 2000 areas is too high – there is then a question of overload – and that it is therefore desirable to reduce it, but the aforementioned statement does not change that. Moreover, the Habitats Directive itself does not explicitly force a reduction in nitrogen levels, but only draws attention to the objective (favorable conservation status) and furthermore asks for ‘the necessary conservation measures’ without attaching a deadline. The Habitats Directive does not talk about nitrogen, critical deposition values and the like. With regard to the term: it is of course never possible to undo something that has been built up in 100 years (the overload) in a few years. No one is asking that either, only the Dutch legislator.
The policy so far
If the analysis of the problem – the crisis – is already so flawed, then of course no
good solutions can be expected. Both sides are stuck in generalities. The government says ‘we cannot do otherwise’ and ‘the KDW must be met’, the farmers say that they are being killed. This is not how people come together, not even through mediation. The instruments that have been or are being deployed are doomed to failure. Virtually nothing has been achieved in more than three years, not in terms of reducing the nitrogen load, but also not in terms of getting construction projects going or, for example, a solution for the PAS detectors. Expropriation is being considered for the future.
There is no explanation for this. It is a mystery to me how people think they are
going to expropriate (object, foundation, new destination, compensation, etc.). Actually
all the figures that have been devised can be missed: they will not work or turn out to be in violation of the Habitats Directive. This piece would be much too long if all legal mistakes – for example the nitrogen registration system – had to be described.
What should happen?
We (government, conservationists and farmers) should focus on the Natura 2000 areas. After all, that’s what started it. So we really have to go back to what matters: a good conservation status for all Natura 2000 areas.
An end goal – for example the KDW – does not have to be cast in concrete, as
long as we are finally going in the right direction. Two instruments are available: the management plans of art. 2.3 Nature Conservation and Land Development Act of the Rural Areas Development Act (WILG):
– A management plan already exists for all Natura 2000 areas. This has been prepared by GS and can also be changed by GS. A draft plan goes through a neat public preparation procedure, with views and an opportunity to appeal. The management plan contains the measures necessary for the conservation objective and the intended results. The administrative bodies that have agreed ensure the implementation of the measures. There is no limit to what measures these can be. The elimination of nitrogen sources can therefore also fall under this. The management plan will therefore also be able to include measures for nitrogen reduction, not only for livestock farms, but also for other sources (traffic, industry, recreation, etc.).
Subsidies can be made available for implementation. The advantage of working
with a management plan is that it is an existing figure, does not conflict with the
Habitats Directive, is concrete, focuses specifically on the locally applicable
conservation objectives and offers the possibility for local/regional involvement.
Any drastic measures can be substantiated immediately and are therefore also acceptable.
– In fact, every Natura 2000 site should be accompanied by a
layout plan (art. 17 WILG). A development plan can provide the basis for measures and facilities (this is not really necessary because the management plan already provides a basis for this), but it can also bring changes in
ownership and use of land, above all through reparcelling. For example,
intensive farmers could be relocated and extensive farmers could end up in the fringe zones of the Natura 2000 areas. A development plan also offers a basis for expropriation, which can always come in handy. A zoning plan is then not necessary. Land development is now an instrument forgotten by the provinces; that can and should be done differently.
These instruments also make it possible to link up very well with the initiatives that
were or are already underway throughout the country. Trust between parties can be restored.
One point for attention is, of course, the granting of permits for projects that have to be realized for ‘imperative reasons of overriding public interest’. The Habitats Directive (Article 6, paragraphs 3 and 4) offers an opening for this. The Council of State has made external netting/compensation much more difficult. Including conservation measures in management plans (which are then no longer available for netting) would also be a solution for this, which is more promising than distributing depositions from a nitrogen registration system.
What are the conditions?
The state must be prepared to abandon general policy. Van der Wal’s nitrogen plan can be withdrawn, Article 1.12a of the Nature Conservation Act can be removed. Money must become available or remain available for the conservation measures.
The provinces will have to work on the management plans (most of which are now undergoing a review procedure) and in particular the nitrogen paragraphs therein. Provinces will also have to draw up land use plans. That can run in parallel. Provinces must avoid getting caught up in endless ‘regional processes’. Nature conservation organizations should not want to rigorously adhere to advocated nature target types or nitrogen targets. The conservation objectives per area are also leading for them. Of course, this also applies to farmers and their organisations. Heels in the sand, delaying tactics, sowing doubts, it all has to disappear. While it will take time – and more time than the government now thinks – there are limits to delaying measures. A perspective for, say, twenty years would not be such a bad idea. By that time, all conservation objectives should be marked with a green check mark or it should be established that this is objectively impossible. Motto: we must not further ruin nature but improve it slowly and steadily.
Addition by Willem Bruil An
important problem now is that systems are (rightly) criticized and then also brushed aside as unusable, but it is not clear how it should be done.
Does this mean that nitrogen deposition is no longer relevant at all? That will not be the intention. It is one of the factors to consider. But we must have an idea of the effects of projects (such as expanding livestock farms) on Natura 2000 areas.
If the KDW has to go and Aerius is no good, how should it be?
It is not all that complicated for lawyers:
• We start with the Habitats Directive: “For any plan or project that is not directly related
or necessary for the management of the site, but may have a significant impact on such a site individually or in combination with other plans or projects, an appropriate assessment of the implications for the site shall be made, taking into account the conservation objectives of that area. Having regard to the conclusions of the assessment of the impact on the site and subject to the
provided for in paragraph 4, the competent national authorities shall only authorize such a plan or project after having ascertained that it will not adversely affect the integrity of the site concerned and after having provided consultations where appropriate.
• Decisions of administrative bodies are then submitted to the court. That can
don’t say ‘I don’t know either, so I won’t say anything about it’; the judge has to make a decision: the decision is right or it is not.
• Subsequently, ‘certainties’ provided by non-lawyers are relied upon: increasing the nitrogen tax is harmful and must therefore be rejected. With Aerius you can calculate what the nitrogen deposition is, given a certain emission, and whether there is an increase. If that is the case, no permit may be issued and a permit that has been issued will be destroyed.
• The Habitats Directive therefore requires certainty, but it goes without saying that this is never
can be absolute certainty. Think of it as an increased duty of motivation (think of the appropriate assessment). And if you continue to doubt, the precautionary principle (if in doubt abstain) also applies. So you cannot harm nature with a lie. None of this has anything to do with scientism, just with a significant barrier to damage to nature.
• We don’t need to spend so many words on the KDW, it has no absolute value (although I think it is a nice concept: the limit above which there is a risk that the quality of the habitat is significantly affected by the acidifying and/or eutrophying influence of atmospheric nitrogen deposition See Overview of critical deposition values for nitrogen, Alterra report 2397 (2012) applied to habitat types and habitats of Natura 2000. I sometimes asked in Brabant whether the KDW for the Groote Peel (400 Mol) was correct. actual deposition (calculated) was 4,000 Mol.
So they replied: if the KDW were 2000 Mol, we would still be faced with a major task. [HL supplement: The KDW is the result of international research and as a result of tests with different nitrogen loads, also in combination with field observations. Within the test design and scale limitations of the tests, the value will be correct with a reasonable margin of error. Where it probably goes wrong is that the actual load in nature cannot be calculated due to the very complex deposition processes]
I hope this makes it clear that you do need standards and methods for decision-making and judicial assessment thereof. If you put them all aside, there’s nothing left to do. Even if you start working for each nature reserve, as I propose, you still have to devise ‘appropriate measures’, which also include nitrogen sources.
And then you have to a) know whether nitrogen is harmful b) know whether a certain emission leads to a certain deposition, but also: what does the overload mean for the conservation goals?
Or do you meanwhile say: forget all that nitrogen?
If I look at it that way, I say: do not take KDW as an absolute starting point for goal achievement and/or provide a better substantiation; Keep Aerius until we have a better system, better substantiate RAV emission factors (or measuring emissions is also better for innovations).
Agriculture will only become future-proof by drastically improving nitrogen efficiency
We can easily support the Cabinet’s goal of achieving 39,000 tons of nitrogen emission reductions by 2034. We must achieve this goal by achieving the same agricultural yields
as now, with much less nitrogen from fertilizers and imported animal feed, both in livestock farming and in arable farming. With 24 kg of nitrogen input per person per year, Dutch agriculture is doing a lot better than the agricultural average in Europe, which needs 36 kg of nitrogen to be able to produce the protein in our food per person. The planetary limit for nitrogen use on our Earth has been calculated at 90 million tons of fertilizer nitrogen per year for the entire planet and currently more than 7.5 billion people. If we were to distribute that large amount of nitrogen equally among all people, only 12 kg would be available
39,000 tons less ammonia emissions per year through efficiency improvements brings us to about 15 kg nitrogen per person, a long way in the direction necessary for a sustainable planet.
If we were to achieve the same 39,000 tons of nitrogen reduction just by reducing livestock, we would be stuck with the 24 kg of nitrogen we have today – we spend a lot of money buying out farmers – and we have made no progress towards a future-proof Agriculture.
The Cabinet has opted to enforce this goal through legal means and is thus digging itself further and further into an insoluble tangle of spaghetti. We want to preserve Nature, but are turning to a calculation method based on nitrogen, while for decades we have stated to each other that nitrogen is not easy to quantify. Moreover, it uses models that – at best – do not exactly describe the reality of nitrogen deposition, whereby it must also be stated that these
deposition has been defined in a very specific way with regard to the
quantitative determination conditions of the ammonia. Many individual or affiliated farmers will file lawsuits against the Government, losing a lot of time and money. Together we have been putting off the manure surplus for 40 years. Farmers could also have become active sooner, but are not motivated by a barely enforcing government and other incentives. ‘Why should I as a farmer invest and solve the problems of my neighbors without being rewarded’?
I advocate a pragmatic approach in which reduction targets are agreed with farmers per area that can be achieved with government support to reduce nitrogen emissions for 5 years by improving nitrogen efficiency. If this does not succeed, the agreement includes the reduction of livestock or arable products.
Below is a non-exhaustive list of previously published technological measures. More
than half of these technologies have already been tested in the Netherlands or abroad. The others on this list will need a few more years of government support to remove the risks for farmers. Wageningen UR certainly did not approve all these technologies, often because there was no company willing to pay for such Wageningen approval through research. Over the past ten years, the government has only come up with money if there is a company that is willing
to pay 50% of the research costs. This was referred to as ‘market forces’ as a successor to research carried out on a sectoral basis via, for example, the Main Product Boards. It is apparently not sufficient for broad acceptance of the technology in the Netherlands that the technology is already widely used or has been tested abroad.
By investing 100 million € in 3-5 years, for example, you can keep the risks for a
group of pioneers very low and, if successful, you can put much larger groups on the road to future-proof agriculture for much less money per ton of reduced N. revenue model shows measurably lower emissions per product produced, which is better suited to a fair distribution of nitrogen planetary limit value among all world citizens. As far as I am concerned, we also make it clear that with these measures we are also taking a major step forward in the field of CO2 emission reduction in one effort. We would almost forget that because of the Corona and the Nitrogen concerns.
Below is a non-exhaustive list of technological measures. In bold are the technologies that are now marketable. The other technologies require modest support to be introduced. In addition, there are several other technologies in the pipeline that may require even more time, but which could certainly have made their contribution before 2034. In September 2022, a report by Wageningen Environmental Research (Options to improve the protein use efficiency in the Dutch agriculture sector, JP Lesschen and JPM Sanders) will be published, stating a reduction of 70,000 tons of nitrogen fertilizer use and 110,000 tons less nitrogen by 2040. described in animal feed. Emission reductions are stated in brackets that are not additional because you can only remove the nitrogen from manure once.
1. Increasing the proportion of essential amino acids in pig and poultry feed reduces the amount of nitrogen entering the manure and thus the emissions during manure storage and during field application in the following season. The reduction in emissions will amount to 2000 to 5000 tons of NH3 as a result of this measure. This measure, applied to cattle, would also be successful.
2. Increasing the proportion of resistant protein in cattle feed contributes to increase of nitrogen efficiency and thus a reduction of N in the manure and thus
losses during storage and application. The expected NH3 emission reduction is 5250 tons.
3. Collection of beet leaves and use as animal feed immediately or after processing using, for example, Grassa technology. The reduction potential is 1000-
4200 ton NH3.
4. Increasing field yield in grass through mixed cultivation with
legumes. As a result, the nitrogen dose goes down considerably
and the protein content goes up. This has already been demonstrated
in Ireland. Less/no fertilizers and more legumes increase the conversion
efficiency to vegetable protein and thus reduce the loss of NH3 and NOx to the
atmosphere and NO3 to the soil. The potential saving amounts to approximately 6400 tons of NH3.
5. Acidification of manure produces less ammonia emissions and at the same time less methane emissions. In Denmark this is a standard technique and in the
Netherlands it will certainly be effective in open cow sheds where no air washing is possible. The expected savings are 15 – 20,000 tons of NH3.
6. Another technology that may be useful and the PAS
The problem is reduced by stripping ammonia from manure digestates
developed by Byosis. That company is now one of the best of its kind in the world. This can lead to 1700 tons of NH3 reduction immediately and 10 000 tons
of N if sufficient manure fermentation is available.
7. Refining grass as developed by Grassa BV leads to approximately 50%
increase in nitrogen efficiency and thus more than 30% less nitrogen and
phosphate in the manure. If this technology were to be applied to 50% of the Dutch
pastures, this would mean 10,000 tons less N emissions. We then need to import
900,000 tons less soy meal, leaving about 62,500 tons of N and 20,000 tons of phosphate in South America.
8. Separate collection of urine and faeces in the stable prevents micro
Organisms present in large numbers in the faeces convert the urea from the urine into ammonia. Urea is not volatile and ammonia is at least above pH 7. An unsolved question is how the urea that has to be stored in winter behaves. (6000 tons N)
9. Spread fertilizer diluted with water (5 000 tons N)
Chapter 6. Nature requires customization, not nitrogen standards From Trouw 15 June 2022:
De Groote Peel nature reserve on the border of North Brabant and Limburg. Nitrogen emissions must be reduced by 70 to 80 percent. PHOTO ANP
Not beautiful nature, but achieving unrealistic nitrogen standards is the goal. An approach based on nature is more effective, says Han Lindeboom.
The Netherlands has more than 160 Natura 2000 areas, 75 percent of which must meet statutory nitrogen standards. Even if all livestock farmers disappear from the Netherlands, we will not succeed. What are we doing?
The nitrogen policy is based on a value that must be achieved. But isn’t it better to start from nature that is already there? Can’t we better look at the real situation in the field and improve nature on the spot?
There is still a lot of beautiful nature in the Netherlands and if you look for a
while, the rare nitrogen-averse plants can still be found in many places, and you will not find displacement species everywhere. An example: the minister for nitrogen and nature, Christianne van der Wal, was standing in the Kampina nature reserve in Brabant near a moorland overgrown with pipe straws, looking at ‘the great damage to nature’. But when I went cycling there later, I found a moorland a kilometer away where maintenance had clearly been done, with few straws. We on Texel have known for centuries how to deal with heaths with pipe straws: let sheep graze. I saw the same on the Veluwe.
On Texel, in the areas where according to the standard too much nitrogen precipitates, I can still find sundews and sensitive orchids in various places. And if you pay close attention, you will also see that the so-called overgrown nitrogen-loving plants, such as nettles, blackberries and grasses, often grow in specific places, namely on hotspots of nitrogen deposition such as forest edges and wooded banks. It is important to pay more attention to the details.
Lessons from the wilderness
During my PhD research on the microbiology and chemistry of the nitrogen cycle on the uninhabited Marion Island, more than 1700 km southeast of South Africa, I learned a lot about the effects of nitrogen on nature.
In a penguin colony with half a million penguins, 430 kg of ammonia (NH3) is released into the air every day, about 60 kg of which rains down next to the colony. This has resulted in a very rich grass growth up to 500 meters away, which in 6000 years has formed a six meter thick layer of peat on the leeward side of the colony. One km away from the colony, the vegetation is almost the same as elsewhere on the island. This is an indication of how far these large NH3 sources have a significant impact on their environment. The nitrogen lesson from the wilderness is: big effect, short distance, downwind. And the result can last for thousands of years.
What does this teach us for the situation in the Netherlands? Our goal is no longer beautiful
nature, but the reduction of emissions from agriculture to unreal proportions. It is right that we also want places in the Netherlands where nitrogen-averse plants and sensitive animals grow well, but does that have to be done everywhere in pre-designated places?
Dutch nature is not natural, but man-made and that requires maintenance. Now we look at the location of natural areas and nitrogen-emitting human activities, and then the latter have to adapt for something that we want to have in those natural areas by all means.
But couldn’t we better look where in the Netherlands those nitrogen-averse plants still grow and then take good care of them or even expand them. We also have to recognize that nature with a relatively large amount of nitrogen is sometimes quite beautiful, even if it does not meet legal standards.
But not everywhere. Nitrogen emissions in the Netherlands are too high and must be addressed. But our kind of nature requires customization for every square kilometre. In addition to nitrogen, also look at other causes of (undesirable) nature development, such as water management (desiccation/wetting), layout, grazing, maintenance,
pesticides, other uses. And don’t forget the cats and dogs. Climate change also plays a role.
We can also focus more on vulnerable species such as (for Texel) sundew, various types of orchids, parnassia, rosary, dog violet and dune violet.
By making an inventory of where these species still occur, you can take very specific measures to
maintain or even expand those species there. It is also possible to map where we find the crowding species of purple twigs, common blackberries, large stinging nettles and dune reeds. We may be able to manage those areas specifically or even actively use them for nitrogen removal.
All this calls for a rethink in the approach to the nitrogen problem. In view of the problems in agriculture, fishing and construction, it is high time to start immediately. Don’t strive for unattainable ideals in a crowded Netherlands, but come up with a realistic approach that uses opportunities where they really lie.
Han J. Lindeboom Emeritus Professor of Marine Ecology Wageningen University
Speech by Prime Minister of Tessel, 8 July 2022.
Result of a playful farmer’s action with a serious undertone
Victory begins on Texel, but that sounds very presumptuous, so: The solution begins on Tessel.
Reasonableness must return to the debate and polarization must go out the window. We are going to innovate instead of remediate
We are going to use the correct numbers: no exceedance of KDWs on Tessel and therefore room for farmers, fishermen and construction.
Common sense takes precedence over models. Models are a means of nurturing common sense.
From a legal point of view, we assume that the RvS has not ruled on lowering nitrogen levels but on not raising them. Appropriate assessments open the build.
There is certainly a nitrogen problem, but locally and not spread across the whole country. We
pay attention to the hotspots of nitrogen deposition. Customization for agriculture AND nature.
We give farmers space where possible and remove the paradoxes from the regulations. Dutch farmers and knowledge are desperately needed to produce enough protein.
We start from the beautiful nature on Tessel.
We start from actual nature in the field and not from theoretical nitrogen numbers We are introducing a star system for Natural Areas (rural).
We change protein composition in food for animals AND humans
Together with at least 8 other measures, this reduces NH3 by 30 – 40%
In the long term (2050) a halving of nitrogen required per person from 24 to 12 kg/pp/yr.
We start from the behavior of the nitrogen compounds NH3 and NOx, it is complex and you cannot just add them up or cancel them out.
We integrate the measures for air, water and climate from the start
Only through an integrated approach can we do justice to the various aspects of the nitrogen problem, healthy nature, sufficient food for everyone and a varied landscape.
The solution begins on Tessel
Ammonia from the North Sea, latest developments
For introduction and explanation of problem see pages 17-24 Note 1.
The Minister of N&S has now written a letter to the House of Representatives on 19 July 2022:
The President of the House of Representatives of the States General Princess Irenestraat 6 2595 BD THE HAGUE
Date July 19, 2022
Reaction to committee letter regarding memorandum ‘Major inaccuracy in nitrogen model of the
RIVM construction, farmers and fishermen in the coastal area suffer’ Dear President,
In the procedural meeting of May 18, 2022, the standing committee for Agriculture, Nature and Environment Food Quality decided to receive a response from me to the letter that had been received with the subject “Offer memorandum ‘Major inaccuracy in RIVM’s nitrogen model: construction, farmers and fishermen in the coastal area suffer’”. I am responding to this request with this response letter.
In the dune areas there is a difference between the calculated and measured concentrations of ammonia.
A higher ammonia concentration is consistently measured in the dune area than calculated.
According to research by the RIVM in 2014, this so-called ‘dune hole’ could largely be explained by ammonia emissions from the sea.1 New insights have shown that the influence of ammonia from the sea on the dune areas is less certain than previously thought. It is therefore unclear what exactly is the cause of the dune hole.
Further research is currently being conducted by RIVM to explain the difference between the calculated ammonia concentration and the measured values of ammonia in dune areas. This investigation started in April 2021.
In the news item of 17 May 2022, RIVM shared the latest state of affairs regarding this research on their website.2 This indicates that three possible causes of the dune hole are currently being assumed. These are causes that can be traced back to: the
measurements, missing emissions, or the models. It may be a combination of these causes.
Since the research focuses on these three possible causes and is therefore associated with measurements, which may require multi-year measurement results to be able to draw conclusions
there is a chance that the study will not be completed this year. RIVM has indicated that it will share a new state of affairs in the autumn of 2022.
Consultations have now taken place with the author of the study referred to
in the note. RIVM has promised to include the findings in the ongoing investigation.
Pending the conclusions from the ongoing research, the measured value of ammonia in the dune areas is assumed to be correct. There is sufficient scientific certainty for this. It
means that the calculated value is corrected based on measurement results. Until the ongoing research
warrants a review, the difference between the measured and the
calculated value included in the measurement correction.
The measurement correction is already included in the background maps of the total (national) deposition and
stays unchanged. The aforementioned consideration therefore has no consequences for the current policy or the granting of permission.
Concerns about the reduction target for coastal areas
I realize that there are concerns about the guiding reduction targets for nitrogen emissions in, among other things, the Wadden
area, also in relation to the measurement and calculations of ammonia in dune areas. I would like to emphasize that the reduction targets on
national scale and may therefore be less appropriate locally. That is why these objectives are guiding in nature. In the coming
period there will be room to adjust the objectives where appropriate on the basis of local circumstances, new information and insights. It does apply, however, that the achievement of the objectives of the integrated approach must be achieved nationally. The further determination of the objectives and their interpretation will be worked out in more detail in the area programmes.
A better explanation of the origin of deposition in those areas, where the measurement correction is a significant part of the total deposition in some places, could possibly support the
further defining the objectives and measures of the integrated approach. Partly for this reason, I value careful research to explain the difference between the calculated and measured concentrations of ammonia.
Christianne van der Wal-Zeggelink Minister for Nature and Nitrogen
The footnote of the RIVM belonging to the letter from the minister
Review ammonia in the coastal region: no consequences of nitrogen tasking coastal provinces With new scientific knowledge and current measurement data, RIVM is constantly working on improving calculation models. In case of differences between the field measurements and the model calculations, RIVM is looking for possible explanations. RIVM then processes these statements in the models. There is also a difference between the calculated and measured concentrations of ammonia on the Dutch coast. New, current insights have cast doubt on the cause of this so-called ‘dune hole’. From an earlier study (2014), ammonia emissions from the sea still seemed to be the main reason for this gap. New studies show that the amount of ammonia from the sea may be lower than thought. RIVM is investigating this further and expects the results later this year. Below is an update on that research.
Nitrogen load in coastal nature reserves does not change
The provinces will make area plans in the near future, such as for the areas along the coast. However, the investigation into the cause of the dune hole has no consequences for the absolute deposition contributions of the various sectors. It may follow from further research that the coastal provinces have a (slightly) larger deposition target, but these changes are so small that the general picture of the nitrogen load of the nature reserves is the same. In any case, the total nitrogen target for all provinces will remain large.
Sea produces ammonia, but the question is how much exactly
In 2014, RIVM, together with WURWageningen University & Research and TNO, among others, investigated what causes the ‘dune hole’. In that study, ammonia from the sea turned out to be the most important explanation. It is known, among other things, that rotting processes in sea foam cause
for ammonia emissions. In addition, higher ammonia concentrations were measured directly
along the sea than a few hundred meters inland. Since then, calculations of nitrogen precipitation
in the dune area have taken into account both onshore sources and ammonia emissions from the
sea. Due to new scientific insights, there is now doubt about the amount of ammonia that comes from the sea.
One or combination of explanations?
During the additional investigation, RIVM will look at the possible causes and
consequences of this. Possible causes of the dune hole can be traced back to: the
measurements, missing emissions or the models. It may also be a combination of these causes. The observed difference is then not entirely caused by one of the individual points (measurements, emissions or model), but by a combination of causes. What are possible explanations?
1. The measurements are locally too high due to the influence of salt particles
Salt particles in the measuring tubes can influence the ammonia measurement. These
(especially ammonium nitrate) particles are formed in the air and can adhere to the measuring tubes. However, under the influence of temperature changes, these particles can disintegrate again, producing ammonia. This ammonia can then be captured in the measuring tube, causing the ammonia measurement to be unjustifiably higher. In the Zwanenwater nature reserve near Callantsoog, research has been conducted into this over the past year. Further research should show whether the influence of the salt particles also plays a role in other (coastal) areas. If this applies to all coastal areas, a correction to these measurements could have consequences for the height of the deposition. In that case, the calculated deposition would be overestimated.
2. Local ammonia sources are missing from the emission estimates
There may be sources of ammonia near the measurements or close to the coast, such as local (water) bird colonies. These have not yet been included in the current emission estimates of ammonia from the Emission Registration. However, because the deposition calculations are corrected based on the measurements (the measurement correction), this has no influence on the deposition figures.
3. Current model calculations may not be optimal for coastal areas
Calculating the ammonia concentration and deposition along the coast depends on several aspects that can be a source of uncertainty. For example, there is an ‘erratic’ pattern of water/ land transitions and a complex meteorological situation in the dune areas. The study must
show how sensitive the calculations are to differences in, for example, the aforementioned water/ land transitions and whether this leads to systematic deviations in the calculated deposition.
There are always uncertainties involved in measuring and calculating; we take that into account
Measurements and model calculations by definition have a certain uncertainty. RIVM always reports extensively on this. New scientific knowledge, such as with ammonia from the sea, in combination with the annual updating of local data (such as weather conditions, land use, traffic emission factors) is also included in our models. These models
always reflect the most probable reality. RIVM is constantly working to minimize the uncertainties by means of extra measurements and the further development of models.
The investigation into the possible causes of the observed difference has now been started. It focuses on the influence of salt particles on the measurements, any missing sources and the functioning of the model for the coastal area. We will provide another update in the fall of 2022.
Comments by Han Lindeboom on letter from minister and footnote RIVM
Ammonia from sea was already discussed with RIVM in 2019, which first changed it into ammonia from sea and later into measurement correction. But if indeed no substantial amount of ammonia comes from the sea and this is in fact added to the model and the calculated depositions in Natura 2000 areas, then those depositions are calculated higher than they are in reality. For areas close to the coast, this can amount to more than 25% overestimation of nitrogen depositions. The question then is whether, if you omit the measurement correction, sufficient nitrogen space is created for other users, including coastal fisheries.
The RIVM claims not, although it is now admitted that much less ammonia comes from the sea than has been maintained for a long time. But in the House of Representatives briefing on 25 May, RIVM indicated that it had to conduct another two years of research before it could continue. And they are now going to investigate whether salt crystals on the measuring tube or meteorological conditions along the coast are the cause of incorrect measurements. But if this research yields results, this means that the measurements are wrong and that corrections have to be made for this, and that provides space for the fishermen. The third cause is being investigated whether defecating birds are the unknown source, with which RIVM suggests that the seagulls, terns and cormorants along the coast throw more nitrogen into the air than
the entire Dutch industry combined. lariekoek.
The consequences of omitting the measurement correction for the 30 Natura 2000 areas in which this plays a role are shown on the next page.
A solution for the nitrogen problem in coastal fisheries?
Opinion published in Visserijnieuws of 3 June 2022 Prof. Dr. Han Lindeboom
TEXEL – In nature reserves, too much nitrogen may not be deposited: legal standards have been set for deposition. For shrimp fisheries in Natura 2000 waters, it is therefore a question of whether they will receive a new permit with sufficient fishing hours for the coming years.
As far as the Ministry of Agriculture, Nature and Food Quality is concerned, it is: Meet the dust standards or stop fishing… The fisheries organizations must submit a collective license application before 1 July, including nitrogen calculations
per vessel now and after investments in nitrogen-reducing measures.
Fishermen are then individually allocated a maximum number of ‘nitrogen hours’. Prof. dr. Dr Han Lindeboom, emeritus professor of Marine Ecology at Wageningen University, is closely following the discussion. Lindeboom questions the calculation method of the RIVM and presents a solution to the nitrogen problem. Rapid reduction of nitrogen emissions from coastal fishing is, in his view, unnecessary for nature. “In the nitrogen approach in the Netherlands, it is not the effects on nature that are leading, but rather ramshackle nitrogen accounting and modelling.”
At the moment the fishery is in very difficult weather and one of the reasons is that the shrimp fishery
must meet the nitrogen standard as of 1 January 2023 in accordance with the Aerius program, the tool of the RIVM for calculating nitrogen deposition.
The current permit under the Act of the Nature Conservation Act expires on 1 January 2023. Because significant consequences for Natura 2000 areas due to shrimp fisheries cannot be ruled out, a new permit is required. A nitrogen
calculation is requested with the permit application.
But can significant consequences be ruled out? At the end of 2019 I already found out that there is an inaccuracy in the nitrogen model of the RIVM. Ammonia from the North Sea has been included as a source because there is a difference between measurements and model. But ammonia cannot come from the sea, it is a well rather than a source. That has to do with the ecology, algae absorb ammonia and the acidity (pH) is not high enough.
This was already discussed with the RIVM in 2019, which first changed it to ammonia from the sea and later to measurement correction. But if indeed no substantial amount of ammonia comes from the sea and this is in
fact added to the model and the calculated depositions in Natura 2000 areas, then those depositions are calculated higher than they are in reality. For areas close to the coast, this can amount to more than 25% overestimation of nitrogen depositions. The question then is whether, if you omit the measurement correction, sufficient nitrogen space is created for other users, including coastal fisheries.
The RIVM claims not, although it is now admitted that much less ammonia comes from the sea than has been maintained for a long time. But in the House of Representatives briefing on 25 May, RIVM indicated that it had to conduct another two years of research before it could continue. And they are now going to investigate whether salt crystals on the measuring tube or meteorological conditions along the coast are the cause of incorrect measurements. But if this research yields results, this means that the measurements are wrong and that corrections have to be made for this, and that provides space for the fishermen. The third cause is being investigated whether defecating birds are the unknown source, with which RIVM suggests that the seagulls, terns and cormorants along the coast throw more nitrogen into the air than the entire Dutch industry combined. lariekoek.
Moreover, it is claimed that even if that ammonia does not exist, the Critical Deposition Value
(KDW; the value above which nitrogen becomes harmful to nature) will still be exceeded in the Natura 2000 areas and nothing will change for the fishery. Certainly not after the court’s latest ruling: “every additional molecule in a nature reserve that has already been exceeded is one too many”. But is that true?
It is difficult to find suitable numbers with which to calculate it, but for Texel I gathered them together and the result is the following.
On Texel, two habitat types, gray dunes (lime-poor) and gray dunes (scaling) appear to have the lowest KDW of 714 mol/ha/y. A presentation by the RIVM shows that the deposition on Texel amounts to 849 mol N/ha/y. That is 135 mol above the KDW, and since the limit is above the KDW at a maximum of 70, this is an exceedance that cannot be reached. Issue.
But this is with measurement correction. If the measurement correction is omitted, the deposition is only 631 mol N/ha/y. And that is 83 moles below the KDW, so absolutely no excess. And the same applies to the six other Texel habitat types with CDWs of 1,000, 1,071 and 1,786 respectively, which are also not exceeded by 631 mol. The RIVM claims in a report that it does, but that is because in their model it doubles or even triples the non-existent marine ammonia in forest edges.
For other Natura 2000 areas in the dunes in North Holland I was also able to roughly calculate that omitting the measurement correction means that KDWs are no longer exceeded. This is probably also the case further inland, but it becomes more complicated as the agricultural influence increases. To really find out, an Aerius calculation must be performed without measurement correction. And if we then show that all Natura-2000 areas that are less than 25 km from the fishing areas are under the KDW, the problem for coastal fisheries is solved. There are still a few caveats, such as the fact that ammonia can come from tidal flats in the Wadden Sea for Ameland and Schiermonnikoog, but that can be solved locally.
But this is only a solution if RIVM and the government now admit that there is an error in the calculations. They’ve known this for two and a half years, but they don’t change anything. RIVM states that they are not about that and that this is something for the administrative/political domain, but that they must then have the correct information.
In close consultation with the fisheries foremen Pim Visser and Maarten Drijver, I raised this issue
at an early stage and they have since brought it to the attention of the Ministry on a regular basis. So far in vain.
I do not think it is necessary for nature to reduce nitrogen emissions from coastal fishing now.
In the nitrogen approach in the Netherlands, it is not the effects on nature that are leading,
but rather ramshackle nitrogen accounting and modelling. Moreover, in the future, the fishing industry will also have to drastically reduce CO2 emissions and if this is done around 2030/35, for example with hydrogen engines, the nitrogen problem will also be a thing of the past. Better to do it right the first time.
In the above I have tried to find a solution that can work quickly and is also tenable in court. They remain within the nitrogen limits set.
With a small nitrogen focus group, we also produced a report in which we delve much deeper into the nitrogen problem and make four recommendations for getting out of the nitrogen impasse throughout the Netherlands. In addition to recalculation with the RIVM model, these are: Provide customization on the square kilometer for agriculture AND nature; Change protein composition in food for animals AND humans; Dutch farmers and knowledge are desperately needed to produce enough protein. And as far as I’m concerned, the latter also applies to fishermen.
Adapt diet and other techniques to reduce NH3 emissions.
This Figure shows how we can move from a nitrogen approach to a nature approach
Towards a local, integrated area-oriented nature approach in the Netherlands. (see also pages 25-33 in Note 1)
It is proposed to list the nature facts for each Nature 2000 area with nitrogen problems by means of a survey or fact-sheet in which all necessary information is brought together • Name of the area, size,
habitat characteristics, conservation objectives • Are the conservation objectives achieved, if not why not? • What are the characteristic types of plants and animals for the area • What are the most important uses in the area • Is the emphasis for the area on ecological or economic nature?
Then the following nature-related aspects are rated with a yes or no • Is half of the area closed
to the public yes no • Are feral cats removed yes no • Are dogs always on a (short) lead,except in small off-leash areas yes no • Are there no mountain bike trails through the area (onlytahleong edge) yes no
• Is there no hunting in at least 50% of the area yes no
• Is there the possibility for a complete food web (including top predators) yes no • Is the water level optimally regulated for nature yes no • Is there sufficient maintenance yes no • Is the area adequately grazed where necessary yes no • Are the agreed management measures sufficiently complied with yes no
And also a number of environment-related aspects that have been or can be adapted • Has
the surrounding agriculture been adapted (increasing biodiversity) yes no • No blowing pesticides used within 1 km of the area yes no • No upwind point sources of ammonia within 500m of the area yes no • Do the physical and chemical soil characteristics meet the preconditions of the habitat types concerned
From this, the number of yes’s is counted.
And follows an approach with gold (and possibly green stars)
Gold stars for ecological nature and green stars for economic nature.
With 14 yes’s an area gets 5 gold stars and with less than 4 yes’s 1 star, etc.
With 14 yes’s an area gets 5 gold stars and with less than 4 yes’s 1 star, etc.
Depending on changes in policy, an area may receive more or fewer stars.
Consideration could also be given to using green stars to indicate the economic value of the area for other users, eg recreation.
Use money for nitrogen approach only for the 4 and 5 gold star areas
The legal regulations are no longer the norm, but the actual quality of nature, which is then clearly defined per area. Customization per area and not national, with the current climate change unattainable, conservation goals or the like.
The local nitrogen deposition processes in nature reserves could be taken more into account.
Research into the nitrogen cycle in a penguin colony (page 9-10 note 1) and observations
in nature reserves in the Netherlands shows that the process of deposition has a different spatial
pattern than the RIVM and the government assume. There are major differences between NH3 and NOx and between dry and wet deposition, which lead to hotspots for effects. NH3 provides effects through wet deposition up to 150-200 m downwind of the source. Around farms with ammonia emissions it is often seen that the grass and weeds on one side of the farm grow better than on the other. NOx and drifting NH3 cause effects in places where the air is in relief, such as wooded banks, forest edges, buildings, etc. There is much that can be improved through targeted observations and customization on the right scale. Certainly if one also looks for hotspots of good nature and expands them locally as much as possible. Of course there is also a variable nitrogen blanket over the Netherlands, but a generic approach will not yield much in view of the effect and location of hotspots.
Conservation goals also raise questions.
For example, these targets were set around 1995, at a time when nitrogen emissions, and therefore nitrogen deposition, were double what they are now. To make changes between then and now attributable to nitrogen is debatable. It is much more complex and will also vary widely locally.
And in a world with climate change, temperature, rainfall, wind, etc. will also be important drivers.
Also for the North Sea, in the KNAW Sounding Board Committee North Sea Consultation (KKN), of which I was a member, we had a discussion about the Good Environmental Status (GMT, type of
marine conservation targets) and whether it can be measured.
The KNAW North Sea Sounding Board came to the conclusion that the GMT, in particular for the
relevant Descriptors Biodiversity, Food webs and Integrity of the seabed 36
insufficiently defined and it cannot be expected that this will be sufficient in the short term.
Therefore, the GMT, in its current form, is not a suitable measure for assessing the (future) status of the North Sea. The Committee recommends assessing the future status of the North Sea much earlier on the permitted uses in the various subareas of the Dutch part of the North Sea and their possible effects.
In addition, the Committee recommends that all stakeholders draw up a list of species, populations and habitat
types from which the developing status of the Dutch North Sea can be read. One could check whether a Commonly Desired Ecological Condition can be defined. The associated parameters can be monitored in a well-balanced monitoring program tailored to the target. The question is whether something like this could also be useful for the situation on land.
It would also be possible to map where nitrogen-averse plants still occur, such as those found on Texel by Kees Bruin
Spotted tar Orchis gossip
And the same with places with nitrogen-loving plants.
Sweet-smelling night orchid
Plantain- fountain herb
It is striking that the vegetations below are often found in wooded banks and forest edges, where it is possible that their dense structure has a reinforcing effect on dry deposition and thus promotes their own growth. This could be taken into account in management.
In the Early Birds of August 7, 2022, a visit was made to the scenic landscape near Winterswijk. It was discussed what should/could be done here in order to achieve a permanently beautiful and multifunctional landscape.
Keywords were: Variation, Landscape restoration, Diversity, Nature inclusive, Greener,
Farmers do not have to stop, Transforming Woodwalls Job rewards for landscape maintenance, Nature transition, Making sustainable ideas politically possible, Turnaround/rethinking Integrated area plan, Herb-rich grassland, and cultural landscape instead of a natural landscape This also deserves local elaboration
A few more useful figures (Note the different scales in the upper figures)
Confidential research TNO makes mincemeat of RIVM model
The Ministry of Agriculture, Nature and Food Quality has received a report from TNO in
which research was conducted into the reliability of the RIVM’s AERIUS calculation tool.
This calculator is used to calculate the so-called Critical Deposition Value (KDW). Nitrogen compounds that are formed in the air, such as ammonia, eventually end up on the ground again. The KDW then indicates whether this deposition is ‘critical’. Above a certain (calculated) value, this deposition is characterized as unacceptable and farmers and cows must disappear to prevent this.
TNO’s research shows two things: the accuracy of the calculated CDW decreases as the
distance from the source decreases, and the accuracy decreases as the number of sources decreases. In other words, a cow’s calculated fart gives a much more accurate critical value at
a distance of 20 meters than at a distance of 20 kilometres. Yet AERIUS also calculates with the impact of that fart 20 kilometers away. The second statement is also clear: it makes quite a difference whether there is 1 fart from 1 cow, or 100 farts from 100 cows.
What TNO subsequently explains in the report is that the proof that that fart still has an
influence at a distance of 20 kilometers is not provided by measurements that confirm
this, but by calculations or measurements in the air or precipitation at a distance of 20 kilometers. This has been the criticism of all parties since the beginning of the ‘nitrogen crisis’: there are hardly any measurements that can confirm the calculated values from AERIUS, the calculated results are blinded by the fact that they cannot be tested.
Source: https://indepen.nl/vertrouwelijk-onderzoek-tno- Makes-hacked-van-rivm-model /
Subsequently, TNO notes that an arithmetical lower limit of 0.005 mol/ha/year has been chosen for software-technical reasons, but there is no scientific substantiation completely. If the lower limit is higher, the software will have to calculate with many more numbers, which would seriously affect the usability of the model. So it is not reality that forms the basis, but the software and hardware limitations.
TNO’s final conclusion is overwhelming: the arithmetic accuracy of AERIUS is just as great as the ‘noise’ that can occur. Simply explained: the cow fart, which according to the model still has an influence at a distance of 20 kilometers, is completely lost in all other factors that would yield the same measurement value.
TNO advice: adopt the limit values from abroad
TNO gives a disguised advice in the (confidential) report: use the limit values for the KDW as they are used abroad, these are many times more realistic. It should also be noted that the KDW limits have been set even stricter by the ministry than AERIUS of the RIVM has already calculated, which means that The Hague lives in a completely paper reality.
It should also be noted that this report also disappeared somewhere in a drawer in The Hague, and that all tricks were used again with the mandatory disclosure:
released in a low resolution and therefore difficult to read and made unsuitable for OCR software, so that the searchability is severely hampered.
For literature, also with this note see Note 1