A group of us put some hard questions to the Netherlands Council of State, asking how they knew there was a nitrogen “crisis.”
Yes, this is about political matters in a far-off land, but it is worth your attention because the same kind of The Science that classifies nitrogen as a “crisis” is being used to say carbon dioxide is a menace.
Essential background: The Model That Dutch Rulers Rely On To Claim There Is A Nitrogen “Crisis” Has No Skill, The Dutch Nitrogen “Crisis” Explained, Dutch Regime To Seize Private Land Because Of Faux Nitrogen Crisis – A Brutal Example Of The Science
The questions are in Dutch at this site. Below, a summary in English, loosely translated, so refer to the original in Dutch if you want to be official.
The “us” is Lucas Bergkamp, Jan Bergstra, Yours Truly, Jaap C. Hanekamp, Ira Helsloot, Ronald W.J. Meester, Quinten Pluymaekers, and Geesje Rotgers.
The RvS [Council of State] ruling states the following about AERIUS:
“In this context, the legislator has considered it important that activities in the construction phase of a project often involve small, temporary nitrogen depositions, which overall make only a limited contribution to the nitrogen problem. As the AERIUS-Calculator program has become increasingly accurate over time…”
Question 1. What source is RvS using to assess model accuracy of AERIUS, with regard to calculated deposition contributions?
It is our strong suspicion no such source exists, especially given our work linked above, which show the model has never been seriously vetted, and that it often performs poorly.
An important conclusion of the Advisory Board for Measuring and Calculating Nitrogen [which is outside RvS and the folks who built AERIUS] concluded “…the reliability of the prediction by using a very low assessment threshold [is] insufficient and this approach leads to false certainty. AERIUS Calculator…calculates small contributions to concentrations and deposition based on emissions from a project. The uncertainty of this extra deposition on Natura 2000 areas is many times higher than the assessment threshold at the spatial scale used (hexagons the size of one hectare)…” This finding contradicts the statement that AERIUS has “become” an “increasingly accurate” computing tool.
Question 2. Which documentation does the Council use to state, contrary to the above conclusion of the scientific Advisory Board, that AERIUS is “becoming more and more accurate”?
Question 3. In the light of the answers to the previous two questions, how does the Council assess the rejection and approval of permits based on AERIUS at the level of hundredths to tenths of a mill per hectare per year?
Yes, really: hundredths of a mil! Scientifically, this is nuts.
The RvS has ruled the following about nitrogen critical loads (NCLs):
“The critical deposition value does not apply as an absolute limit value for determining the favorable conservation status of nitrogen-sensitive habitat types, but the extent and duration of the critical deposition value being exceeded are important indicators for assessing whether the decrease in deposition by the PAS source measures and the effects of the restoration measures in the areas are necessary or not for the preservation and prevention of deterioration of the nitrogen-sensitive natural values.”
Question 4. To which NCL does the RvS refer exactly and what documentation has been used for this? What accuracy does the RvS apply to KDW used under which documentation references?
There is no one “nitrogen critical load”, because they are defined haphazardly, inconsistently, ad hoc, and most of all by—wait for it…wait for it—wee P values. Yes.
RvS often uses the term ‘significant’. Here’s a small anthology:
“…a worsening or significant confounding effect…”
“…for projects with potentially significant negative impacts…”
“…no significant worsening effects…”
“…If significant consequences cannot be excluded…”
“…a habitat is significantly affected by the influence of nitrogen deposition…”
Question 5. It seems to us that the Council of State uses the word ‘significant’ both qualitatively and quantitatively. In the second case, we request the Council to quantify the term ‘significant’, with reference to the documentation used. If the term is to be understood qualitatively, when are changes (“disruptive effect”, “negative consequences”, “worsening effects”) “significant” or not?
In statistics, significance has a definite meaning: wee P-value. And what does a wee P-value mean? Significance. This circularity almost never bothers anybody.
The RvS uses the ‘precautionary principle’ several times, such as:
“The Court has ruled on several occasions that the precautionary principle is the basis of Article 6(3) of the Habitats Directive…As the Court already ruled in the Kokkelvisserij judgment, the competent authority must, on the basis of that appropriate assessment, have obtained the certainty that the activity will not have any harmful consequences for the natural characteristics of the area concerned. This is the case when there is no scientifically reasonable doubt that there are no harmful effects.”
Question 6. We request the Council, with reference to the documentation used, to quantify the term ‘certainty’, in the context of the precautionary principle, in order to understand ecological harmlessness.
The precautionary principle is always a dodge, and it is only ever used to favor Ruler policies. For it can always, but never is, turned around, and we can say that proposed Ruler policies may have unforeseen devastating effects, and therefore should never be implemented.
The RvS answered these! (Right before I posted this.)
The answer is like this: “We the RvS are an agency to answer questions. Answering questions is what we do. We answer questions put to us with answers, in the following way: by answering questions using our procedure. Thank you for your questions, we hope you enjoy your answer, which this response is. The questions you have asked will therefore not be answered substantively.”
The last sentence is an exact quote. Yes, really. Hilarious.
We will follow up.
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