Sunday 18 November 2012

The application of the Polluters Pay Principle in establishing civil liability for environmental damage.


This paper is a study on the Polluters Pay Principle and its application to environmental law and civil liability. Consideration is given to how the principle is understood with relevance to environmental law and how it may be implemented in accordance to its interpretation.
Specific attention is given to the application of this principle from EU and UK perspective, however, it would not be possible without a detailed analysis on the conception from its legal, historical as well as international importance. 

Introduction

“If anyone intentionally spoils the water of another .... let him not only pay damages, but purify the stream or cistern which contains the water....”[1]
The essence of the above quote has been replicated by the proponents of the Polluters-Pay Principle; Stewart Bell describes it as a principle where the responsibility for the production of goods and items, that may result in environmental damage such as pollution, or be the cause of such harm, as well as taking the steps in the prevention of such harm, then the cost of this should be on the producer.[2] Such costs include environmental cost as well as that direct cost to people and property; this also covers not only remedying damage but also cost incurred in avoiding pollution.[3] Legal commentators have often argued that there is no agreed definition to this principle, nor any precisely defined scope for its implementation and this is due to the lack of international treaty on its application.[4] Regional organisation like the EU and OECD, and national authorities, apply it for their own purposes and subject it to various considerations with overriding need in favouring depressed economic areas with assistance.[5] The interpretation of the principle to particular cases and situation remain open as Philippe Sands points out ... “in relation to the nature and extent of costs included and the circumstances in which the principle will, perhaps exceptionally, not apply.”[6] The polluter-pays principle has practical implications in regards to environmentally damaging activities in particular those of liability and “the use of economic instruments, and the application of rules relating to completion and subsidy.” [7]



[1] The Dialogue of Plato: The Laws, vol. 4, book 8, section 485(e), translated by Jowett B, (Oxford:             Clarendon Press: 4th ed. 1953)
[2] Bell S, McGillivary Environmental Law (Oxford: Oxford University Press: 2008 7th ed.) p.244
[3] Ibid.
[4] Mc Loughlin, Bellinger Environmental Pollution Control (London: Graham & Trotman/ Martinus Nijhoff:         1996) p145.
[5] ibid.
[6] Philippe Sands Principles of International Environmental Law (Cambridge:Cambridge University  Press:2003 2nd ed.) p.280
[7] Ibid.

The principle in essence is an economic policy for allocating the costs on public authorities responsible for the environmental pollution or damage done by them; moreover, the principle also has the scope for the development of international and national law on liability for damage.[1] It is often argued that pollution is often an externality that imposes a social cost, there is no reflection in its entirety in the private cost of the polluter, and hence, exceeding more pollution than what is economically optimal. It is argued that the Polluters Pay Principle is an attempt to make polluters bear the “real” social cost bringing pollution to the optimal point.[2] The rationale behind the economic approach to the Polluters Pay Principle is the “prices of goods (depending on the quality and/or quantity of environmental resources) reflect, more closely, their relative scarcity and that economic agents concerned react accordingly”. [3]
The aim of this paper is to consider the civil liability of the principle to environmental damage, as opposed to direct regulation and economic incentives. Environmental liability in the context of national and international liability laws are based on strict liability under which, the injurer is liable irrespective of the presence or absence of fault or negligence, only harm must be demonstrated. Furthermore, economic analysis of strict liability demonstrates efficiency since the injurer internalises the harm ensuring that the due level of care is taken, though it should be noted that strict liability is reserved usually for cases involving hazardous activity, whilst negligence, which may be also considered efficient because the injurer can be induced to take exactly the specified amount of care and this amount can be set efficiently.[4] Nevertheless, it should be noted that negligence is the dominant rule in tortuous liability.



[1] Birnie P, Boyle A, Redgwell C International Law & the Environment (Oxford: Oxford University  Press: 2009 3rd ed.) p 322
[2] Førsund R. Finn., “The Polluter Pays Principle and Transitional Period Measures in a Dynamic Setting”;  The Swedish Journal of Economics, Vol. 77, No. 1, Public Finance:Allocation and Distribution, (March1975), pp. 56-68;  http://www.jstor.org/stable/3439327
     [3] OECD: “On guiding principles concerning international economic aspects of environmental  
policies”, C(72) 128, 1972, Paris, France. Also see, OECD: “The polluter pays principle.
Note on the implementation of polluter pays principle”, 1974, Paris, France.
     [4] Shavell Steven, Liability for Accidents, National Bureau of Economic Research Working  
Paper  No.11781,  November 2005, Cambridge, MA USA, http://www.nber.org/papers/w11781


The proponents of the strict liability rule also focus on “cost internalisation” that is social cost of an activity is charged to the polluter and this is parallel with the Polluters Pay Principle.[1] The rationale for strict liability being better for harm is that of economics and this is because it is unilateral where the injurer can take due care to prevent such harm. This is seen in environmental pollution and degradation and consequently, there is convergence towards using strict liability in cases environmental pollution and degradation.[2] Nevertheless, what this paper considers is the application of the polluters pay principle in establishing civil liability for environmental damage. 



[1] Bergkamp Lucas, “Liability and Environment Private and Public Law Aspects of Civi liability for Environmental Harm in an International Context”, Draft 10, April 2001
   http://papers.ssrn.com/paper.taf?abstract_id=266365
[2] Shruti Rajagonpalan The Polluter Does Not Pay Model for Environmental Protection in India   www.emle.org  

1.1 ENVIRONMENT
If the environment is recognised as a representation of “the living space, the quality of life and the very health of human beings, including generations unborn.”[1]Or simply understanding it to mean complex interrelationship between climatic, biotic and edaphic factors that “act upon an organism or an ecological community and ultimately determine its form or survival; the aggregate of social or cultural conditions that influence the life of an individual or a community.”[2]Then it is at least apparent that even without a clear authoritative definition[3] of the term, the environment and the symbiotic relationship with human beings are “at the centre of concerns for sustainable development.”[4]Nature, ecosystem, natural resources, wildlife and so on are thus of concern to International law makers primarily for the value to humanity.
The environment is a fragile eco-system that sustains life in the elemental description (and the emotive empathise) from providing the air that every living creature breathes, to the “clean” water that is drunk, to the water that is used for agriculture amongst other things, which produces for food that is consumed by all living creatures. It is part of the cycle of life that is dependent on each other and requires protection.[5] The natural resources that the earth contains has been exploited at an unprecedented rate since the industrial revolution,[6] with the growth in population and urbanisation, the advancement in both transportation, and agricultural production as a consequence, has led to the increase demand in energy consumptions.




[1]  Nuclear Weapons Advisory Opinion, ICJ Reports (1996) 241-2, para29.
      [2]  Webster’s New World Dictionary (3rd edn, Cleveland,1988) 454
[3] Environmental Protection Act 1990 section 1, legally defines the Environment as “All or any of the  following media, namely air, water, land and air includes air within buildings or any other natural or man-made structure above and below ground”.
[5] Environmental protection is essentially anthropocentric: the key drive for the right to a clean environment   emanates from Principle 1, of the 1992 Rio Declaration which states “Human Beings are the centre of   concerns for sustainable” The preamble to the 1972 Stockholm Declaration stated “Man is both creature 
 and moulder of his environment, which gives him physical sustenance and affords him the opportunity for
intellectual, spiritual, moral and social growth”.
      [6]  David Taylor Mastering Economic and Social History (Macmillan: 1988) Chap 3.


Such progress comes at a cost to the environment and to the limited natural resources that are not sustainable at the current rate of consumption, and this is not just stating the obvious such as “peak oil”[1] where dwindling oil supply meets expediential demand for energy, but over fishing and climate change has been highlighted in recent years as a major cause for concern. The cost of maintaining a better quality of life and living standards in a free market economy such as those in North America and Western Europe, or the aspiration to achieve those goals as an economy in the developing nations of the African, Asian and Latin American continents has put more strain on the resources and often at the expense of nature and the environment, on factor that all this has in common to the detriment of the environment is pollution.
   1.2 POLLUTION
      Martin Holdgate[2] states what he refers to as a restricted but an evolved definition of pollution:
“The introduction by man into the environment of substance or energy liable to cause hazards to human health, harm to living resources and ecological systems, damage to structures or amenity, or interference with legitimate uses of the environment”[3]
       From the above, it can be construed that it is exploitation and the demand for energy and substances associated with energy production that are the main culprits that cause pollution; and it is man who is the creature of this source or sources removing the natural input of this substance, thus “pollution is an increment added by man to biogeochemical cycles.”[4]



      [1]  Deffeyes K. Beyond Oil: A view from Hubbert’s Peak (New York: Hill and Wang 2005)
[2]  Martin W. Holdgate A Perspective of Environmental Pollution (Cambridge: Cambridge University Press:  1979 First edition) p.17
[3]  According to Holdgate this definition closely follows the wording used in Article II of the Paris   Convention on the Prevention of Marine Pollution from Land-Based Sources, which according to him has  
similar terminology to that of documents of the United Nations Conference on the Human Environment  
(The Stockholm Conference) and the United Nations Environment Programme (UNEP)
[4] Martin W. Holdgate A Perspective of Environmental Pollution (Cambridge: Cambridge University Press:    
1979 First edition) p.17


     

It follows a pathway[1] which can have an effect on a range of receptors[2]and thus is judged by its impact on social values as well as environmental components; it is a pollutant by definition if the effects of substance that causes damage to structures or amenity, or interference with legitimate uses of the environment. By identifying and understanding the science, the legal issues, political agendas, economical benefits and long term detriments, as well as the social aspect of the problem perhaps a communal recourse can be addressed, thus striving for common goods based on common principles?
        Principles amongst others provide a moral reasoning to ensure that such fragile ecosystem is given the protection it needs. If that was not the driving force than perhaps out necessity or public health at a national level[3] or trans-boundary harm at a regional level triggering international precedent which bring states together to address a “harm” such as the Trail Smelter arbitration[4] where there is an obligation on States not to cause cross-boundary environmental damage, an obligation repeated in many international instruments and is customary international law.[5]As society evolves it does come together to strive for a better expectation and often these are translated into rules and principles, at least for this author in the normative sense society knows or recognises what it should do and should not when it comes to the environment.
       It is beyond the remit of this paper to provide an in-depth perspective on the science, biodiversity and other methodologies to illustrate the damage done by pollution; nor can the historical or social-political evolution can be covered at length to do justice in presenting a narrative, that humanity at large, has awakened to the fact that the earth we live in is “fragile”, with delicate eco-system that needs to be protected and preserved. It is not just a national or a regional concern but a global necessity.



[1] Air, Water and Soil
[2] People, infrastructure and property (by air) the ecosystem by water and animals and plants (by soil)
[3] Historically the “industrial revolution” changed the social structure in Britain, a shift from an agricultural  
society to a concentrated urbanisation of factories, be they the cotton industries of Yorkshire, or the steel  industries of Sheffield or even the coal mines of the “black country” outbreak of diseases was rampant and in  some cases horrific. In the UK, public health legislation were introduced, thus, the use of private law remedies  
to protect private property impacted by the pollution arising from industrial activity.
[4] 33AJIL (1939) 182 and 35 AJIL (1941) 684
[5] Dixon & McCorquodale Cases & Material on International Law (Oxford: Oxford University Press: 4th    
ed) p467


It is no longer a mere normative  concept; humanity is facing an “ecological bankruptcy”[1] which was reported as a “spasm” that the planet has not seen in “65 million years, since the dinosaurs disappeared.”[2]
         Humanity thus has an obligation as a trustee to protect the environment for the future, it has the responsibility to ensure mechanism and procedures are in place for negotiating the necessary rules and standards to protect the environment. A duty in providing common standards and practices, for the functioning of regulatory structures for environmental management; establishing empowerment to manage and sanctions activities with values, policies, standards, licences and incentives. Providing administrative, civil and criminal sanctions for non-compliance with the rule of law, which needs to be global in its application as environmental law is a concern for all humanity. Whatever the reason we may rationalise be it aesthetic or scientific, intrinsic or economic this has to be based on principles that can be acceptable by all and agreed upon as a common good to serve as the foundation for soft law. The first step towards accepting principles as a general anthropocentric value and perhaps then developed as an institutional principle which can be governed in uniform by treaties and convention and implemented within national legislature.
 1.3 SOFT LAW
         There is wide academic literature on this concept and much like “regulation”[3] there is “no rigorous and widely accepted definition of soft law”,[4] however, it has been stated that “[s]oft law consists of written instruments that spell out rules of conduct that are not intended to be legally binding,”[5]they are not subject to law of treaties but more as an “international instrument other than a treaty containing principles, norms, standards or statement of expected behaviour”.[6]It is by its nature the articulation of a “norm” in a non-binding written form.



[1] Mary Christina Wood “You Cant Negotiate with a Beetle”:Environmental Law for a New Ecological Age  (2010) 50 Nat. Resources J. 167-539
[2] ibid at 178
[3] Barton B Regulating Energy and Natural Resources (Oxford:Oxford University Press:2006) Chap 2
[4] Sheldon D International Law and “Relative Normativity” in International Law, M.D. Evans (2003) p166
[5] Harris  D Cases and Materials on International Law (Sweet & Maxwell: 2004 6th ed) p62
[6] See above. Sheldon

1.4 PRINCIPLES
      There is much debate on the nature and conceptualisation of principles, for the purpose of this paper the focus will be centred on the general notion in considering if principles can be binding rules or as having a non-binding normative purpose for international environmental law.
“Principles, even if they are part of law, are norms of a general nature, which give guidance to state behaviours, but are not directly applicable; the violation of such principles cannot be pursued in international courts unless they are made operational by means of more concrete norms.”[1]
       However, as we will discuss later that it is a particular principle that derives the establishment of civil liability, and in some jurisdictions implemented rigorously be that as an economic instrument or simply a permitting regime regulated by the respective  government.



       [1] Winfred Lang (1999) UN-Principles and International Environmental Law p159 downloaded from www.mpil.de/shared/data/pdf/pdfmpunyb/lang_3.pdf  (Also available from heineonline)

2.1 GLOBAL ENVIRONMENTAL LAW
      In its constitutional role international law provides the procedures and mechanism for negotiating the necessary rules and standards, settling disputes, and supervising the implementation and compliance with treaties and customary rules to facilitate and promote cooperation between states, international organisations, and non-governmental organisation; thus constitutes the process of international environmental governance, international lawmaking and regulations and in few areas international trusteeship.[1]Ultimately, the concern is with regulating environmental problems by providing standards and practices for mitigation or prevention of pollution, highlighting conservation by promoting the importance and the sustainable exploitation of natural resources and biodiversity.
       In many cases some international environmental agreements serves the purpose in harmonising national laws, this is done globally or regionally. For example, treaties on civil liability for nuclear accidents or oil-pollution damage at sea replicate the provisions of these treaties and will essentially be the same in each state party. It is the litigants who have suffered loss in large-scale international accidents who will have access to justice. However, lack of uniformity can cause regulatory conflict and this is because states may have the same goal but differ considerably in the methods and implementation as well as the standards and timetables they set.
2.2 INTERNATIONAL LAW
       International law offers many vehicles for the necessary developments, custom, treaty, soft law, general principles, and framework agreement and so on, this can be utilised in a variety of ways to develop and revise the law to meet new environmental concerns. Furthermore, the availability of scientific information and its reliability along with social, economic, and political implications are factors that affect the speed with which progress is determined by governments to weigh against environmental demand. 



[1] Birnie P, Boyle A, Redgwell C Iternational Law & the Environment (Oxford: Oxford University 
Press: 2009 3rd ed.) Chap 1

Thus it is at this stage that the discourse of this paper will focus on the UN context and the “important role of legislative declarations as they may be precursors to and guide a later treaty-making process and are designed to influence the conduct of states directly.”[1]An expectation of such declarations which according to Szasz, “may catalyze the creation of customary law by expressing in normative terms certain principles whose general acceptance is already in the air.” [2]



[1] See above Lang p158.
[2] P. Szasz International Norm-making in: E. Brown-Weiss, Environmental Change and International Law,  
1992, 68.

2.3 UN-PRINCIPLES
         There are wide ranging legal literature on international law and normative principles which are available, not to mention the extensive treaties and conventions, as well as the functionality of the UN. Though it is beyond the scope of this section to show an exact link to the origin of environmental law or to provide a narrative let alone a descriptive or a historical analysis of the UN and it’s role; a linkage was important to demonstrate how principles developed or agreed upon at the international stage can filter down to the regional or national level, often enforced by regulatory or other legal or economic means. Yet having said that it should be pointed out that it does not always happen according to plan, this is because in many instances it can get disregarded or not applied at all. The best example is how an oil disaster in the Gulf of Mexico[1] can ensure billions of dollars of compensation for some, whilst others have nothing more than “bad press”.[2]The main difference in the application of these principles and norms is the strength in the rule of law and a stable democratic system.



[1] This is in reference to BP operated oil platform disaster in the Maconda oil field in the Gulf of Mexico.
[2] This is in reference to the Niger Delta, where I have had personal experience in witnessing the damage  
done to the environment. Though blame can be pointed out in so many factors, the fact remains the
ecological damage is horrendous. 

           However, it must be said that one major factor that has enabled the development of international law and in particularly environmental law would be largely due to global  trade.[1]It is from this perspective that this paper will develop its analysis on the polluters pay principle and its application by focusing mainly within the European and UK angle.



[1] Lyster R, Bradbrook A  Energy Law and the Environment (Cambridge University Press:2006) p35.

2.4 RIO DECLARATION
          
     The Rio Declaration on Environment and Development (the “Rio Declaration”),[1] in 1992, constitutes “at present the most significant universally endorsed statement of general rights and obligations of states affecting the environment.[2]It has been described as an:

instrument of international jurisprudence [that] articulates policies and prescriptions directed at the achievement of worldwide sustainable development”.[3]

Furthermore, Principle 16 of the Rio Declaration provides that:

“[n]ational authorities should endeavour to promote the internalization of environmental costs and the use of economic instruments, taking into account the approach that the polluter should, in principle, bear the cost of pollution, with due regard to the public interest and without distorting international trade and investment”.[4]

The above statement has been considered as a strong objection by some countries for its further development in international relations as it falls short of the more specific language of EC, OECD, and UNECE.[5] 



[1] Rio Declaration on Environment and Development, United Nations Conference on Environment and Development, U.N. Doc. A/CONF. 151/5/Rev.1 (1992), reprinted in 31 I.L.M. 874, 878 (1992). 
[2] See Birni, Boyle and Redgwell at p.112.
[3] John Batt & David C. Short, The Jurisprudence of the 1992 Rio Declaration on Environment and Development: A Law, Science, and Policy Explication of Certain Aspects of the United Nations Conference on Environment and Development, 8 J. NAT. RESOURCES 8: ENVTL. L. 229, 230 (1993). 
[4] Rio Declaration at 879. 
[5] See Sands at p280. 

It is said that the wording does not intend the principle to be legally binding, [1]and it that the principle is applicable at the domestic level but does not



[1] See Birni, Boyle and Redgwell at p.322.

govern relations or responsibilities between states at the international level;[1] it simply lacks the rule of law. Having said that, it should be noted that the preambles to the 1990 Oil Pollution Preparedness and Response Convention, the 1992 UNECE Convention on the Transboundary Effects of Industrial Accidents and the 2003 Kiev Protocol on Liability for Pollution of Transboundary Waters and Lakes, describe the polluters pay principle, as a “general principle of environmental law.” Moreover, some treaties like the 1992 Paris Convention for the Protection of the Marine Environment of the NE Atlantic,[2] require parties to “apply the polluter pays principle,”[3]
Therefore, it is in treaty law that the polluters pay principle is traced back as instrument in establishing rules on civil liability and compensation for damage resulting from hazardous activities. 



[1] Sands, p 281
[2] Article 2(2)(b)
[3] Ibid. 

3.1 OECD
         It is often quoted in academic literature that the champions of the polluters pay principle, was conceived in the 1972 OECD Council Recommendation on Guiding Principles Concerning the International Economic Aspects of Environmental Policies. This is because it was the first international instrument to refer expressly to the polluters pay principle, by endorsing the principle to allocate costs of pollution prevention and control measures to encourage rational use of environmental resources and avoid distortion in international trade and investment.[1]
“The principle to be used for allocating costs of pollution prevention and control measures to encourage rational use of scarce environmental resources and to avoid distortions in international trade and investment is the so-called ‘Polluter Pays principle’. This principle means that the polluter should bear the expenses of carrying out the above mentioned measures decided by public authorities to ensure that the environment is in an acceptable state. In other words, the cost of these measures should be reflected in the costs of goods and services which cause pollution in production and/or consumption. Such measures should not be accompanied by subsidies that would create significant distortions in international trade and investment”.[2]
            The above definition was limited as meant the polluter should bear the expenses of carrying out the measures deemed necessary by public authorities to protect the environment, yet it did not apply to the costs of environmental damage. This gradual development in the 1974 OECD Council went a bit further by reaffirming that the principle constituted a “fundamental principle” for member countries, by ensuring aid is provided for innovative technologies for the control of pollution and the development of new pollution abatement equipment which was not incompatible with the principle. Moreover, there should be uniformity between the member states in their observance of the principle.[3]



[1] OECD Council Recommendation C(72) 128 (1972), 14 ILM 236 (1975.
[2] Ibid.
[3] OECD Council Recommendation C(74) 223 (1974, paras.I(1), II(3) and III(1), 14 ILM 234 (1975).

In 2001, the OECD Joint Working Party on Agriculture and Environment stated that a new and expanded  form of the polluter pays principle seeks to cover the costs of accident prevention and to “internalise” the environmental costs caused by accidents.
"... the polluter should be held responsible for environmental damage caused and bear the expenses of carrying out pollution prevention measures or paying for damaging the state of the environment where the consumptive or productive activities causing the environmental damage are not covered by property rights."[1]
3.2 EUROPEAN UNION
            The polluters pay principles was introduced into the EC Treaty in 1987, and is enshrined in Article 174(2) of the Treaty Establishing the European Union (the “EC Treaty”), which provides that:

   “Union policy on the environment shall aim at a high level of protection taking into account the diversity of situations in the various regions of the Union. It shall be based on the precautionary principle and on the principles that preventive action should be taken, that environmental damage should as a priority be rectified at source and that the polluter should pay”.[2]
        It must be said that the European Court of Justice and its legislature showed resourcefulness in expanding European Union competence into the environmental arena long before any formal treaty Provision.

the European Court of Justice had placed a liberal interpretation upon Article 100, which granted the European Union competence to enact “harmonising” measures, which directly affected the establishment or functioning of the common market”.[3]


          The Council of Europe’s Convention on Civil Liability for Damage Resulting from Activities Dangerous to the Environment is the only existing scheme for environmental liability that is comprehensive and harmonised in Europe or elsewhere.



[1] www.eoearth.org/article/Polluter_pays_principle
[2] Consolidated Versions of the Treaty on European Union and of the Treaty Establishing the European Union, art. 174(2), 2002 O.J. (C 325) 1. 
[3] See Michael Cardwell, The Polluter Pays Principle In European Union Law And Its Impact On United Kingdom Farmers, Oklahoma Law Review, Vol 59:89, 89 at 90.  

Strict liability is  imposed as a common scheme for dangerous activities or dangerous substances on the operator of the activity it concerns. The amount of liability is not limited and thus reflects more of the polluters pay principles and is observed more than any other treaties under which the loss is spread. Injury to persons and property along with impairment of the environment is covered by “damage” as it is defined.[1]  
             However, the polluters pay principle is the responsibility of producers of goods for the costs of preventing or dealing with the outcome of the process that is pollution. Part from cost on people or property as mentioned above the principle also covers costs incurred in avoiding pollution and is not relating to those only on remedying damage.
             As an “economic instrument” the producer will always pass the cost on to the consumer as market forces dictate, this stands as a principle and has no legal force that is defined in statute. The scope on the limits on payments for damage caused has been the cause for frequent disputes. In R v Secretary of State, ex parte Standley and Metson[2] The court ruled:
“it must be understood as requiring the person who causes the pollution, and that person alone, to bear not only the costs of remedying pollution, but also those arising from the implementation of a policy of prevention. It can therefore be applied in different ways. Thus, it may be applied either after the event or preventively before the harm occurs”.



[1] See Birni, Boyle and Redgwell at p 318.
[2] [1999] ECR I-8033




However, the cost will be identified with the polluter, rather than being a general societal cost and, in theory at least, a manufacturer with high pollution costs maybe become less economically competitive than one with lower costs.[1]Apart from eco-tax measures and criminal liability the Directive on civil liability,[2]which creates strict liability, subject to exemptions and legal defences, for environmental damage caused by activities judged to pose a potential or actual risk to humans and the environment, and fault-based liability for damage to natural resources caused by activities which are not inherently dangerous. The opening preamble states the following:



[1] Shaw J, Hunt J & Wallace C Economic and Social Law of the European Union (London NewYork: Palgrave Macmillan: 2007) p 432
[2] European Parliament and Council Directive 2004/35 on environmental damage, OJ 2004 L143/56

fundamental principle of this directive.....[is]...... that an operator whose activity has caused the environmental damage or the imminent threat of such damage is to be held financially liable, in order to induce operators to adopt measures and development practices to minimise the risks of environmental damage so that their exposure to financial liabilities is reduced”.[1]



[1] Ibid. 

3.3 EQUITY AND STRICT
Equity is the name given to the set of legal principles, in jurisdictions following the English common law tradition, which supplement strict rules of law where their application would operate harshly, so as to achieve what is sometimes referred to as "natural justice". It is often confusingly contrasted with "law", which in this context refers to "statutory law" (the laws enacted by a legislature, such as Parliament), and "common law" (the principles established by judges when they decide cases). In modern practice, perhaps the most important distinction between law and equity is the set of remedies each offers. The most common civil remedy a court of law can award is monetary damages. Equity, however, enters injunctions or decrees directing someone either to act or to forbear from acting. The notion of Equity is introduced to the polluters pay principle as a mechanism for prescribing that:

in addition to ... economic efficiency considerations, fundamental fairness and the protection of property also require that polluters pay for or abate their own emissions”.[1]

The contention of these interpretations is that governments should only bear the abatement costs, but the responsibility should be on the specific polluters for abating their contribution to a specific pollution problem. In the finest tradition of the common law scholars have noted, “[L]awyers have interpreted the economic [polluter pays principle] as a requirement that polluters should pay all the social and economic costs of their conduct[2]  this hard approach whereby, for example the Rio Principle 16 is interpreted so that,



[1] Daniel C. Esty, Toward Optimal Environmental Governance, 74 N.Y.U. L. REV. 1495, 1504 (1999). 
[2] Sanford E. Gaines, The Polluter-Pays Principle: From Economic Equity to Environmental Ethos, 26 TEX. INT'L L.J. 463, 480 (1991).  

“it appears to state an affirmative and original 'strong' form of the Polluter-Pays Principle that directs governments to assure the internalization of environmental costs through the use of economic instruments, not merely to refrain from subsidizing the purchase and use of pollution control equipment by private industry”, is gaining ground[1]
Many of the environmental statute offences are usually the ones of strict liability and that is only actus reus[2]or fault in the form of intention, recklessness or negligence.[3]According to Lord Hoffman in the House of Lords decision in Empress[4]confirmed that the offence is one of strict liability,[5]only does this mean that there is no need for mens rea, but one can be liable for certain deliberate acts of third parties and for certain natural events. However, the problem is often in the difficulty of identifying the “polluter”, including the Contaminated Land Regime in EPA 1990, Pt 2A and under the Agricultural Nitrate Directive 91/676/EEC.
Under Pt 2A, the polluters pay assertion is nothing more than shorthand for complex system of detailed regulatory tests a complex system designed to address the consequences of pollution through economic measures. The polluters pay principles is not concerned with explicit punishment.[6]if that was the case than many polluters under the contaminated land regime would feel hard done by because of retroactive legislation. However, if a contaminated land is identified, then the local authority or the Environmental Agency identifies the “appropriate person” to remediate the land. [7]



[1] See David A. Wirth, The Rio Declaration on Environment and Development: Two Steps Forward and One Back, or Vice Versa?, 29 GA. L. REV. 599, 643 (1995).
[2] In this context, generally an act, e.g. causing trade or sewage effluent to be discharged into controlled waters (the actis reus of the offence in s.85 (3) of the WRA 1991.
[3] Hilson C Regulating Pollution A UK and EC Perspective (Oxford: Hart Publishing: 2000) p134
[4] Empress Car Company Ltd v NRA [1998] 2 WLR 350
[5] Causing offence in section 85 of the Water Resources Act (WRA) 1991
[6] See above Bell & McGillivrary p564
[7] Maria Lee “New” environmental liabilities: the purpose and scope of the contaminated land regime and the Environmental Liability Directive Env. L. Rev 264




3.4 APPLICATION IN PRACTICE.
In this section a brief examination on how the principles are applied in different countries.[1]
a)      USA, favours interpretation of the principle in equity terms, it looks at the allocation of costs between polluters and society at large, and between individual polluters. Certain provisions of the United States’ Clean Air Act 1970 (the “CAA”) and Clean Water Act 1977 (the “CWA”) require polluters to satisfy environmental standards at their own expense; and the Comprehensive  Environmental Response, Compensation and Liability Act of 1980 (“CERCLA”) assigns liability for costs associated with cleaning-up sites contaminated by hazardous wastes. CERCLA is a notable milestone in the development of the polluter pays principle in the United States and commentators have noted that: “the polluter pays principle is one of the central objectives or goals of CERCLA”.[2]
b)      Germany accepted the principle on the basis that the polluter must pay for the reduction of the polluting effects and also for the restitution after damage has been done. However, subsidies were not ruled out as it provides financial aid for investments on environmental protection.
c)      France has put reliance on pollution charges as means of applying the principle.
d)     Netherlands has an approach where the governments considers the discharges in general to be responsible.
e)      Sweden has the costs of administration monitoring and control which are charged on that basis. This include penalties for non-compliance for non-compliance



[1] Mc Loughlin, Bellinger Environmental Pollution Control (London: Graham & Trotman/  Martinus Nijhoff: 1996) p151-152
[2] J. Whitney Pesnell, The Contribution Bar in CERCLA Settlements and Its Effect on the Liability of Nonsettlors, 58 LA. L. REV. 167, 190 (1997).  

CONCLUSION    
Polluters Pay Principle like other principles is essentially a guide to desirable courses of action, and it clear that it has rarely been fully satisfied in either EC or UK environmental legislation.[1]The principles has not been narrowed to a specific law, and it was not meant to be as such, and this is because it is an economic instrument applicable in the accordance to the interpretation of the principle. It is impossible to point to any general pattern of state practice.  It has been left to national rather than international action for its implementation; as a result states have been consistent in their policy in the method of choice of taxation, charges and among other liability laws. The most that can be said is that regions, institutions intergovernmental bodies including courts can and should take account of the principle in the development of environmental law and policy.
The extent to which civil liability makes polluters pay for environmental damage will depend on variety of factors. If it is negligence on which liability is based, this has to be proved but harm which is neither reasonably foreseeable nor avoidable will not be compensated and the victim or the taxpayer, not the polluter, will bear the loss. Strict liability on the other hand is a better approximation of the polluters pay principle, but if limited to amount how one does value what is worth what? There is never an equilibrium in economic value of goods and services as well equity, what is worth one price in one region will always be worth more or less in another. 
In the end what matters is how a regime applies the principle, how it is interpreted and how and who enforces. As an “economic” instrument it becomes a mere permit to a limited controlled pollution. This may not be a bad thing if the principles ensures decisive and controlled regulation at least than the liability can be as it is many western Europe penalties or charges, and in extreme cases criminal.




[1] See above Bell & McGillivary at p244

BIBLIOGRAPHY

The Dialogue of Plato: The Laws, vol.4, book 8, section 485(e), translated by Jowett B,  
Oxford:  Clarendon Press (4th ed. 1953)
Bell S, McGillivary Environmental Law (Oxford: Oxford University Press: 2008 7th ed.)
Mc Loughlin, Bellinger Environmental Pollution Control (London: Graham & Trotman/  Martinus Nijhoff: 1996)
Philippe Sands Principles of International Environmental Law (Cambridge: Cambridge   University Press: 2003, second edition.)
Birnie P, Boyle A, Redgwell C Iternational Law & the Environment (Oxford: Oxford University  Press: 2009 3rd ed.) p 322
Deffeyes K. Beyond Oil: A view from Hubbert’s Peak (New York: Hill and Wang 2005)Martin W. Holdgate A Perspective of Environmental Pollution (Cambridge: Cambridge     
University Press:1979 First edition)Dixon & McCorquodale Cases & Material on International Law (Oxford: Oxford   
University  Press: 2003 4th edition)
Barton B Regulating Energy and Natural Resources (Oxford:Oxford University  
Press:2006) Chap 3.
Sheldon D International Law and “Relative Normativity” in International Law, M.D. Evans (2003)
Lyster R, Bradbrook A  Energy Law and the Environment (Cambridge University Press:2006)
Shaw J, Hunt J & Wallace C Economic and Social Law of the European Union (London NewYork: Palgrave Macmillan: 2007)
Hilson C Regulating Pollution A UK and EC Perspective (Oxford: Hart Publishing: 2000)

    

ARTICLES



Mary Christina Wood “You Cant Negotiate with a Beetle”: Environmental Law for a New Ecological Age (2010) 50 Nat. Resources J. 167-539 (Heineonline)

Winfred Lang (1999) UN-Principles and International Environmental Law

Førsund R. Finn., “The Polluter Pays Principle and Transitional Period Measures in a Dynamic Setting”; The Swedish Journal of Economics, Vol. 77, No. 1, Public Finance: Allocation and Distribution,(March1975), pp. 56-68; downloaded from JStore at http://www.jstor.org/stable/3439327
OECD: “On guiding principles concerning international economic aspects of environmental   policies”, C(72) 128, 1972, Paris, France. Also see, OECD: “The polluter pays principle. Note on the implementation of polluter pays principle”, 1974, Paris, France.

Shavell Steven, Liability for Accidents, National Bureau of Economic Research Working Paper  No.11781,  November 2005, Cambridge, MA USA, http://www.nber.org/papers/w11781

Bergkamp Lucas, “Liability and Environment Private and Public Law Aspects of Civil liability for Environmental Harm in an International Context”, Draft 10, April 2001

Shruti Rajagonpalan The Polluter Does Not Pay Model for Environmental Protection in India    

John Batt & David C. Short, The Jurisprudence of the 1992 Rio Declaration on Environment and Development: A Law, Science, and Policy Explication of Certain Aspects of the United Nations Conference on Environment and Development, 8 J. NAT. RESOURCES 8: ENVTL. L. 229, 230 (1993). 
Michael Cardwell, The Polluter Pays Principle In European Union Law And Its Impact On United Kingdom Farmers, Oklahoma Law Review, Vol 59:89, 89 at 90. 
Daniel C. Esty, Toward Optimal Environmental Governance, 74 N.Y.U. L. REV. 1495, 1504 (1999). 
Sanford E. Gaines, The Polluter-Pays Principle: From Economic Equity to Environmental Ethos, 26 TEX. INT'L L.J. 463, 480 (1991). 
David A. Wirth, The Rio Declaration on Environment and Development: Two Steps Forward and One Back, or Vice Versa?, 29 GA. L. REV. 599, 643 (1995).
Maria Lee “New” environmental liabilities: the purpose and scope of the contaminated land regime and the Environmental Liability Directive Env. L. Rev 264
J. Whitney Pesnell, The Contribution Bar in CERCLA Settlements and Its Effect on the Liability of Nonsettlors, 58 LA. L. REV. 167, 190 (1997). 

WEBLINKS












No comments:

Post a Comment