New Directions: Comments on "The European Air Quality Framework Directive and Atmospheric Mercury: the Wrong Tool for the Job"

In their recent New Directions article Lee et al.(Atmospheric Environment 35, 5855–5857, 2001) propose the "deposition target loading formulated along the critical loads effects-based approach" as the parameter to be regulated by the future European Directive, considering as they do the Air Quality Daughter Directive an inappropriate tool, in fact rather a "blunt instrument" for limiting the impact on human health and the environment of this highly toxic contaminant. The Working Group (WG) that prepared the Position Paper on Mercury (PP) has extensively discussed during its meetings whether to employ the deposition approach and considered it as not presently applicable on the basis of our current knowledge of different aspects of the biogeochemical cycle of mercury in the environment. Instead, the WG proposed an action plan starting with monitoring of emissions, ambient air concentrations and deposition as well as assessment of potential for emission reductions in the Member States. Here, we briefly outline the thoughts that have inspired the recommendations that the WG forwarded to the European Commission.