PAS (Programma aanpak stikstof. In English: Program Approach Nitrogen). What now?

Many parties in the construction industry are struggling with the uncertainty that has arisen after the destruction of PAS (Program Approach Nitrogen), as a result of which many projects are now at a standstill. For Yoeri Schenaus, program manager sustainability at Arcadis, a good reason to lock up for a day with colleagues and also ecologists Eric Schouwenberg and Reinoud Kleijberg. Together they explored the solutions.

Because we are now forced to take measures at the source, we are emitting less nitrogen. This will ultimately benefit the achievement of our nature and climate goals and contribute to a healthy living environment. However, this won't solve short term problems. More than 18,000 projects are cancelled or delayed. These include projects that are important for our safety, economy and accessibility. Examples are the flood protection projects, the modification of the Afsluitdijk, the construction of wind farms (at sea), the expansion of the railroads, projects by the Ministry of Defence, housing projects and even the construction of new bicycle parking places at railway stations.

Nature affected by nitrogen

We have a major ecological problem with nitrogen in the Netherlands. The quality of many (protected) Natura 2000 areas is under pressure due to excessive nitrogen emissions ending up in nature. But also fragmentation, desiccation, neglect and climate change are causing the deterioration of our natural environment. For too long we have invested insufficiently in the design, management and quality of the Natura 2000 areas. The PAS included a package of measures to restore this nature.

Many projects are now coming to a standstill and it appears that the combination of too many emissions and too little investment in nature is not legally tenable. Only a small part of the 18,000 projects can appeal to the so-called ADC-test. The ADC-test must show no alternatives with less harmful effects. Subsequently, imperative reasons of overriding public interest must be demonstrated. But there are no hard criteria against which to test this. We expect - like the Remkes Committee - that many of the 'normal' projects that are currently stalled will not pass the ADC test.

Area-based approach

Is demonstrating on ecological grounds that a very small increase in nitrogen - which hardly contributes to the deterioration of nature - is then a solution? A good ecological justification for the exclusion of significant effects is sometimes quite easy to give. The law also offers possibilities, but in reality it is problematic. The results of ecological research are never black and white. And there is an obligation to assess the effects cumulatively (with those of other projects). It is therefore possible to realise a project, but it also provides doubts.


That leaves balancing to give room for new developments that are important for our economy, housing, accessibility and safety. The livestock population accounts for 70 percent of nitrogen emissions (from our own country). According to Remkes, lowering the maximum speed and reducing the number of livestock are unavoidable and he advocates an area-oriented and warm clean-up in order to create nitrogen space for projects. Area-focused, because this is the most effective way to remediate livestock farms with outdated barn systems (that produce many emissions) near Natura 2000 areas. Arcadis sees concrete opportunities for linking projects to agricultural companies that can provide the required nitrogen space. In this model, the projects (partly) finance the transition to other crops, functions (such as solar meadows) and circular agriculture. The nitrogen space that is released in this way then benefits the projects. In this way the projects help the agricultural companies to get new (future) perspectives and they can start working in an area-oriented way!

Do you wish to learn more about eliminating PAS?





8 January 2020



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