Commission Staff Working Document: Impact Assessment Accompanying the documents Communication from the Commission to the Council, the European Parliament, the European Economic and Social Committee and he Committee of the Regions a Clean Air Programme for Europe, Proposal for a Directive of the European Parliament and of the Council on the limitation of emissions of certain pollutants into the air from medium combustion plants, Proposal for a Directive of the European Parliament and of the Council on the reduction of national emissions of certain atmospheric pollutants and amending Directive 2003/35/EC, Proposal for a Council Decision on the acceptance of the Amendment to the 1999 Protocol to the 1979 Convention on Long-Range Transboundary Air Pollution to Abate Acidification, Eutrophication and Ground-level Ozone
Inhoudsopgave van deze pagina:
COUNCIL OF Brussels, 23 December 2013 THE EUROPEAN UNION (OR. en)
18167/13 ADD 3
ENV 1235 ENER 600 IND 388 TRANS 693 ENT 356 SAN 555 PARLNAT 325 CODEC 3086
COVER NOTE
From: Secretary-General of the European Commission, signed by Mr Jordi AYET PUIGARNAU, Director
date of receipt: 20 December 2013
To: Mr Uwe CORSEPIUS, Secretary-General of the Council of the European
Union
No. Cion doc.: SWD(2013) 531 final PART 2/4
Subject: Commission Staff Working Document: Impact Assessment Accompanying the documents Communication from the Commission to the Council, the
European Parliament, the European Economic and Social Committee and he
Committee of the Regions a Clean Air Programme for Europe, Proposal for
a Directive of the European Parliament and of the Council on the limitation
of emissions of certain pollutants into the air from medium combustion
plants, Proposal for a Directive of the European Parliament and of the
Council on the reduction of national emissions of certain atmospheric
pollutants and amending Directive 2003/35/EC i, Proposal for a Council
Decision on the acceptance of the Amendment to the 1999 Protocol to the
1979 Convention on Long-Range Transboundary Air Pollution to Abate
Acidification, Eutrophication and Ground-level Ozone
Delegations will find attached document SWD(2013) 531 final PART 2/4.
Encl.: SWD(2013) 531 final PART 2/4
18167/13 ADD 3 CM/ach
DG E 1A EN
EUROPEAN COMMISSION
Brussels, 18.12.2013 SWD(2013) 531 final
PART 2/4
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT
Accompanying the documents
Communication from the Commission to the Council, the European Parliament, the European Economic and Social Committee and he Committee of the Regions a Clean
Air Programme for Europe
Proposal for a Directive of the European Parliament and of the Council on the limitation
of emissions of certain pollutants into the air from medium combustion plants
Proposal for a Directive of the European Parliament and of the Council on the reduction
of national emissions of certain atmospheric pollutants and amending Directive
2003/35/EC
Proposal for a Council Decision on the acceptance of the Amendment to the 1999 Protocol to the 1979 Convention on Long-Range Transboundary Air Pollution to Abate
Acidification, Eutrophication and Ground-level Ozone
{COM(2013) 917 final i} {COM(2013) 918 final i} {COM(2013) 919 final i} {COM(2013) 920 final i} {SWD(2013) 532 final}
EN EN
3. T HE T HEMATIC S TRATEGY ON A IR P OLLUTION
3.1. Objectives, scope and approach
The environmental and socioeconomic scope of the TSAP 2005 is Box A.4.1: Summary of the environmental and sociosummarized
in Box A.4.1. economic scope and context of the TSAP
It incorporates the above mentioned Multi-sectoral Multi-pollutant Multi-effect
multi-effect, multi-pollutant and Agriculture PM HEALTH EU Treaty / 6th Environmental Action Plan multi-sectoral methodology SO
Energy 2
developed at the international level. NH Acidification Biodiversity 3
Transport ammonia
The analysis underpinning the 2005 EU 2020 CO Eutrophication
TSAP was based on a previous Industry NO x Ozone
generation of the same suite of Waste NMVOC
models used for the current Non-methane volatile Global organic carbons Warming
assessment. 168 The objective of the CH 4 Other methane ENVIRONMENT
analysis was to identify to what Other Other
extent cost-effective progress could Cost-effectiveness Science-based
be made by 2020 towards the 6EAP objectives of no significant impact on human health or the environment from air pollution, focusing on five major impacts of air pollution: health impacts of particulate matter; health impacts of ground-level ozone; plant impacts of ozone; ecosystem impacts of acidification; and ecosystem impacts of eutrophication.
Impacts were calculated based on spatial modelling of pollution concentrations and depositions taking into account meteorological and topographic conditions that were characteristic for the respective regions in the EU. For ecosystem impacts, the depositions are compared with ‘critical loads’ calculated for each ecosystem type, which are deposition rates beyond which the ecosystem suffers damage, to determine the ecosystem area affected. For human health, the concentrations were combined with population data to determine exposure to those concentrations, and those were in turn combined with concentration-response functions established by the WHO based on a thorough scientific review, and baseline health impact data for the endpoints in question, to estimate the resulting years of life lost, or premature deaths.
Based on this assessment, the 2005 TSAP set out interim objectives for headline health and environmental indicators (Table 1) and accompanying pollutant emission reduction objectives (Table 2) for 2020 that would be required to meet those impact objectives. 169
168 See Annex 2 of SEC(2005)1133 for detail
169 One technical point is that the 2005 TSAP interim objectives for 2020 were formulated in terms of percentage reduction compared to 2000 as the base year, and for the EU25 rather than the current EU28. The present review is based on assessments for EU28 based on an updated energy baseline and with 2005
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Table 1: TSAP Health & Environmental Targets (target year 2020)
2020 "Interim Targets" Headline Health and Environmental Impacts
%Δ vs 2000 %Δ vs 2005
Loss of life expectancy due to PM exposure 47% 40%
Acute mortalities due to ozone exposure 10% 0%
Excess acid deposition in forest areas 74% 67%
Excess acid deposition in fresh surface water areas 39% 32%
Areas or ecosystems exposed to eutrophication 170 31% 29%
Forest Area exceeded by ozone (M Km 2 ) 171 15% 12%
Table 2: TSAP Emission Reduction Targets (indicative for target year 2020)
Headline Emission Reduction Targets 2020 "Interim Targets" %Δ vs 2000 %Δ vs 2005
Primary Particulate Matter (PM2.5) 59% 52% Nitrogen Oxides (NOx) 60% 56% Sulphur Oxides (SOx) 82% 76% Non-Methane Volatile Organic Compounds (NMVOC) 51% 38% Ammonia (NH3) 27% 24%
The TSAP objectives were politically endorsed by Council and EP conclusions but have no formal
legal status. 172
3.2. Monitoring, Reporting and Evaluation
Progress towards the TSAP objectives is monitored through several indicators, most directly through trends in air pollutant emissions based on national emission inventories established by the Member States according to the requirements of the NECD (referring to the guidelines adopted by the
CLRTAP-EMEP) and collated by the EEA. 173
Impacts on health, acidification and eutrophication are calculated regularly and published on the occasion of comprehensive reviews conducted by the European Commission and the EEA or the CLRTAP. 174 The effectiveness of the TSAP has also been tracked through the EEA’s annual report on Air Quality in Europe which collates monitored air quality data reported through EIONET in
chosen as the base year (because emission inventory data are of better quality). Hence, the tables include a column with the equivalent TSAP objectives for 2020 presented on the revised basis.
170 The figure in the original strategy is 43%, but based on updated scientific methodology the 2005 emission
reductions correspond to a reduction in impact of only 31%.
171 Rebased as percentage reduction in ozone flux, where the latter is defined as phytotoxic ozone dose (mmol/m2) over a threshold of 1 nmol/m2/s.
172 Council Conclusions on TSAP, 9 March 2006, available on:
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2012:225:0011:0019:EN:PDF.
173 See http://www.eea.europa.eu/data-and-maps/indicators for air pollution related indicators and assesments. 174 See for example the CLRTAP co-ordination centre for effects annual status reports; 2012 report available
on http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2012:225:0011:0019:EN:PDF.
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accordance with the implementing decisions adopted under the Ambient Air Quality Directives (See section 4). 175
The TSAP was furthermore evaluated in the review of the 6EAP with regard to the breadth and
quality of its analysis. 176 The review process builds on these monitoring and evaluation mechanisms
and included extensive further consultation of stakeholders.
3.3. Relevance
The analysis under the current review of EU air policy has confirmed that the overall scope, objectives, parameters and sources identified in the TSAP remain relevant and appropriate to address the main air pollution challenges in the EU. The main impacts focused on in 2005 remain the key air quality impacts today. Successive reviews of the science underlying the problems have confirmed
that the pollutants addressed are indeed the main problem drivers. 177 A review of evidence has
confirmed that particulate matter and ozone are the two substances for which the evidence of health impacts in the EU is strongest. 178 For ecosystem impacts, while acidification has reduced dramatically, eutrophication remains substantial. 179 The modelling framework was further developed and updated in the period 2006-2013, with in-depth stakeholder consultation. 180 It was concluded that
the approach to identify pollution reduction objectives, sources and legislative instruments remains valid.
Stakeholders have stressed the importance of maintaining, and where possible extending, the interrelation between air quality and climate change policy analysis. 181 Likewise, the inter-relation between the AAQD and the NECD could be strengthened. 182 A number of tasks related to climate
change and its effect on air pollution also require consideration on broader spatial scales whilst at the same time there is increasing need for more detailed information on pollution levels within Member
175 See most recent report, Air Quality in Europe – 2012 report, p34 for current emissions and historical
trends; report available on http://www.eea.europa.eu/publications/air-quality-in-europe-2012. The EEA’s annual report on implementation of the NECD provides more detail on four of the five main TSAP pollutants (the exception being PM2.5, which is not currently regulated under the NECD). Latest report available on http://www.eea.europa.eu/highlights/publications/evaluation-progress-nec-2012.
176 See ‘Final report for the assessment of the 6 th environment action programme, DG ENV.1/SER/2009/0044,
chapter 3.3 and Annex A, in particular p80 ff. For stakeholder consultation, see Chapters 1-2 and Annexes E-G. Report available on: http://www.ecologic.eu/files/attachments/Projects/2010/ecologic_6eap_report.pdf .
177 For an in-depth assessment of eutrophication and its underlying causes see the European Nitrogen Assessment: Sources, Effects and Policy Perspectives, Sutton, M A et al, Cambridge University Press 2011; for an in-depth assessment of the health impacts of air pollution and their underlying causes see the Review of Evidence on the Health Aspects of Air Pollution, WHO/Europe 2013 (see above or Annex 1 for ref.)
178 WHO Review of Evidence on Health Aspects of Air Pollution, 2013. Available on http://www.euro.who.int/en/what-we-do/health-topics/environment-and-health/airquality/publications/2013/review-of-evidence-on-health-aspects-of-air-pollution-revihaap-project-final-
technical-report.
179 Report ‘Factors determining recent changes of emissions of air pollutants in Europe, ENV.C.3/SER/2011/0009 TSAP report #2.
180 In the context of the EC4MACs project, a preparatory project under the LIFE programme. See
http://www.ec4macs.eu/.
181 See ‘Survey of view of stakeholders, experts and citizens on the review of EU Air Policy. Part II: Detailed results’, pp17-19 points 2 to 4. Available on http://ec.europa.eu/environment/air/review_air_policy.htm.
182 See report from Member State Expert Group meeting on Air Quality review (2012)
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States' territories that require assessments with finer spatial resolution. 183 It was noted that EU provisions for monitoring ecosystems were lacking (See section 5 on NECD below. Finally, it has been suggested that in addition to the coverage of "traditional" sectors such as energy, industry, and transport, increasing attention should go to agriculture and maritime emissions as well as emissions
from small and medium scale combustion. 184
3.4. Effectiveness
As shown in Figure 1 below, substantial reductions have been achieved between 1990 and 2010 for the main air pollutants tracked by the TSAP.
Figure 1: EU air pollutant emissions 1990-2010 (EEA, 2012)
In consequence the EU's huge acid rain (acidification) problem is set to be broadly solved 185 , the impact of lead from vehicle fuels has been eliminated, and the ambient air health risk from other heavy metals and carbon monoxide has been greatly reduced. The health impacts of particulate matter, the main cause of death from air pollution, have been reduced by around 20% between 2000 and 2010 . Figure 2 shows the comparative success in eliminating acidification versus the large outstanding eutrophication problem.
183 See reports from EMEP Steering Body and EMEP website.
184 See ‘Survey of view of stakeholders, experts and citizens on the review of EU Air Policy. Part II:
Detailed results’, pp19-20, point 5.
185 The emission reductions are due to EU legislation on sulphur emissions from large combustion plants (LCPs), and to the low sulphur road transport fuel requirements that also enabled the use of catalytic converters from Euro 4 onwards.
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Figure 2: EU ecosystems at risk of acidification and eutrophication
The present review has also developed updated projections related to the air pollutant emissions and air quality impacts for the period up to 2030 assuming no changes to current policy (see Annex 5).
Despite the progress made in addressing air pollution, several of the 2005 TSAP objectives will not be met - the health and environmental impacts of air pollution in the EU remain large.
As shown in Table 3, projected emission reductions without further measures will fall short of the 2020 TSAP targets for all main pollutants, most importantly for PM2.5 and ammonia (NH 3 ) and to a lesser extent for NOx and NMVOC. 186 The reasons for this shortfall are further discussed in the section relating to the NECD and source controls.
Table 3: Distance to TSAP Emission Reduction Targets for 2020 (latest projections)
%Δ vs 2005 %Δ vs 2005 Headline Emission Reduction Targets for 2020
TSAP 2005 Projected 187
Primary Particulate Matter (PM 2.5 ) 52% 24%
Nitrogen Oxides (NOx) 56% 51%
Sulphur Oxides (SOx) 76% 65%
Non-Methane Volatile Organic Compounds (NMVOC) 38% 34%
Ammonia (NH3) 24% 15%
As a consequence of failing to achieve the emission reduction targets, there is also under-achievement of the TSAP's headline health and environmental targets for reduction of PM2.5 mortality,
eutrophication and forest acidification (Table 4). 188 However, the target for fresh water acidification
186 Emission projections carried out in the context of this review are documented in Annex 5.
187 Projected emission reductions by 2020 compared to 2005 are calculated based on data presented in Annex 5.
188 The first column gives the scale of the impact in 2000, the second the projected impact in 2020 on a
business as usual scenario (baseline), and the third, the projection for 2020 on the basis of the maximum technically feasible reduction of air pollution (MTFR). Note that the impacts reported in this table are smaller than in chapter 3 of this impact assessment. This is because advancements in atmospheric dispersion modelling and ecosystem impact assessment have led to the upward revision of the magnitude of impacts. In % reduction terms, however conclusions have not substantially changed.
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will be met, as well as the ozone mortality target (the latter represented a 10% reduction compared to 2000).
Table 4: Distance to TSAP Health & Environmental Targets (latest projections)
%Δ vs 2005 %Δ vs 2005 Headline Health and Environmental Impacts for 2020
TSAP 2005 Projected 189
Loss of life expectancy due to PM exposure (M) 40% 26%
Acute mortalities due to ozone exposure (M) 0% 13%
Excess acid deposition in forest areas (M Km 2 ) 67% 64%
Excess acid deposition in fresh surface water areas (M Km 2 ) 32% n.a.
Areas or ecosystems exposed to eutrophication (M Km 2 ) 29% 17%
2
Ozone flux (Forests (mmol/m above effects threshold)) 12% 13%
The updated human health impacts in the EU due to PM and ozone air pollution in 2010 are presented in Table 39. 190 The associated external costs and costs of implementation are discussed in the following section on efficiency. Air pollution remains the number one environmental cause of death in the EU, responsible for an estimated 406 000 premature deaths or ten times more than fatalities due to road traffic accidents. 191 In addition to premature mortality there are also substantial quality-of-life (well-being and morbidity) impacts, ranging from asthma to exacerbation of cardiovascular symptoms, which result in restricted activity days with associated productivity losses.
Table 5: Health Impacts in the EU Due to PM and Ozone Air Pollution in 2010 (EU28)
Acute Mortality (All ages) Premature deaths O3 26,525 Chronic Mortality (All ages) * Life years lost PM 4,030,653 Chronic Mortality (30yr +) * Premature deaths PM 379,420 Infant Mortality (0-1yr) Premature deaths PM 1,829
Chronic Bronchitis (27yr +) Cases PM 316,685
Bronchitis in children (6 to 12 years) Cases PM 6,231,812
Respiratory Hospital Admissions (All ages) Cases PM 142,243 Respiratory hospital admissions (>64) Cases O3 19,117 Cardiovascular Hospital Admissions (>18 years) Cases PM 108,989 Cardiovascular Hospital Admissions (>64) Cases O3 86,279
Restricted Activity Days (all ages) Days PM 436,351,761 Asthma symptom days (children 5-19yr) Days PM 11,290,673 Lost working days (15-64 years) Days PM 121,378,612 Minor Restricted Activity Days (MRADs all ages) Days O3 108,845,140 Notes: * These rows represent alternative measures of the same effect on mortality, and hence are not additive..
189 n.a. indicates that calculations are not available at this stage.
190 Source: EMRC 2013.
191 EUROSTAT statistics report the number of traffic fatalities in the range of 35,000 in the year 2010 across the EU 27.
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3.5. Efficiency
Promoting cost-effective air pollution abatement actions
One of the principal aims of the TSAP was to promote cost-effective air pollution abatement actions in the EU and internalise externalities through the adherence to the polluter pays principal and optimal market based solutions.
As is set out in section 6 on EU source controls, the main focus of current air pollution policies has been on the major polluters. External costs associated with air pollution in the EU remains, however, very large. Table 40 below builds on table 39 above and shows the external costs associated with the main health impacts in the EU due to air pollution.
Table 6: External Costs Associated with Main Health Impacts in the EU Due to Air Pollution in 2010
Impact €M/year
Acute Mortality (All ages) Premature deaths O3 1,531 – 3,679 Chronic Mortality (All ages) LYL median VOLY * Life years lost PM 232,569 – 559,052 Chronic Mortality (30yr +) deaths median VSL * Premature deaths PM 413,567 – 842,312 Infant Mortality (0-1yr) median VSL Premature deaths PM 2,990 – 6.090
Chronic Bronchitis (27yr +) Cases PM 19,001 Bronchitis in children (6 to 12 years) Cases PM 3,664
Respiratory Hospital Admissions (All ages) Cases PM 316 Respiratory hospital admissions (>64) Cases O3 42 Cardiac Hospital Admissions (>18 years) Cases PM 242 Cardiovascular hospital admissions (>64) Cases O3 192
Restricted Activity Days (all ages) Days PM 40,144 Asthma symptom days (children 5-19yr) Days PM 474 Lost working days (15-64 years) Days PM 15,779 Minor Restricted Activity Days (MRADs all ages) Days O3 4,571
Core median VOLY 327,691 Core mean VOLY 657,913
Core median VSL 505,120 Core mean VSL 937,434
Notes: * These rows represent alternative measures of the same effect on mortality, and hence are not additive.
The implementation costs of existing policy are given per sector in Table 41. Note that these are the costs for reducing pollution from a situation of no pollution mitigation at all, to the current pollution level. The pollution which would result from today's activity levels if there were no policy at all would be extremely high. The concentrations in such circumstances would be at least an order of magnitude higher than current concentrations, and although impacts are not linear over the whole concentration range, the impacts would also be several multiples of the current impacts.
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Table 41: Pollution control costs for the baseline up to 2020 (EU28, M€)
2010 2015 2020 Power generation 12700 12093 10711 Domestic sector 7476 9115 9629 Industrial combustion 2435 2468 2521 Industrial processes 4760 4983 5029 Fuel extraction 976 907 770 Solvent use 1638 1964 2140 Road transport 26022 34357 42023 Non-road mobile sources 1892 4320 6975 Waste treatment 0 1 1 Agriculture 1750 1775 1786 Total 59650 71983 81584
It can be seen that even on the most conservative valuation, the benefits of implementation of current policy hugely outweigh the costs. Despite the very substantial progress, the remaining impacts in 2010 still place a huge burden on society.
Enhancing the overall coherence of the principle TSAP instruments
Another principal efficiency related aim of the TSAP was to enhance the overall coherence of the main instruments put in place to achieve the TSAP objectives including the balance between Member State and EU action.
Whilst detailed comments are provided in the below sections relating to the respective instruments, the following areas for reinforcement of the strategy (and its underlying analysis) have been identified based on the public consultation for the TSAP review:
• A reinforced analysis of the impact of emission reductions (from source controls and national emission ceilings) on compliance with the AAQD air quality standards (it is now possible for the first time to model this at EU scale); 192
• the interaction with other policies, in particular with the forthcoming climate and energy package; 193
• the robustness of the proposed policy with respect to variations in the underlying analytical assumptions; 194
• alternative instruments to those brought forward in 2005 (e.g. fiscal instruments); 195
192 See next section for rationale; See also TSAP report #9, ‘Modelling compliance with NO2 and PM10 air quality limit values in the GAINS model’, IIASA 2013. This and all other reports referred to here are available on http://ec.europa.eu/environment/air/review_air_policy.htm , unless otherwise specified.
193 TSAP report #1, ‘Future emissions of air pollutants in Europe – Current legislation baseline and the scope for further reductions’, IIASA 2012, section on decarbonisation scenario impacts, pp43-48.
194 For an ex post analysis of the robustness of the assumptions made in the 2005 TSAP, see TSAP report #2
‘Factors determining recent changes of emissions of air pollutants in Europe’, IIASA 2012. For an assessment of the achievability of prospective future targets on alternative assumptions, see TSAP report # 10, ‘Policy Scenarios for the revision of the Thematic Strategy on Air Pollution’ IIASA 2013 section 4.2 pp16-19.
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• how action at Member State level can be supported and reinforced at EU level; 196
• additional flexibilities in instruments compared with those assessed in 2005. 197
3.6. Relation of the TSAP analysis to emission ceilings and ambient air quality targets
The TSAP modelling delivered as one of its direct outputs emission reduction objectives for SO 2 , NOx, NMVOCs, ammonia and PM 2.5 not only for the EU as a whole but for individual Member States. These reductions took account of the transboundary impacts of the pollution concerned by determining the optimum spatial and sectoral profile of pollution reductions across Europe, so as to meet the desired health and environmental objectives. Thus the outcome of the modelling translated naturally into national emission ceilings for the various pollutants. The NECD had been adopted in 2001, and while it addressed human health impacts from ozone exposure, its main focus was on ecosystem impacts. The level of the ceilings set did not correspond to those required to meeting the 2005 TSAP objectives, and importantly, the Directive did not include a ceiling for PM 2.5 . The TSAP proposed that these points be rectified by a revision of the Directive.
However, the relation of the TSAP and its associated modelling to the ambient air quality standards adopted was less direct. Those standards had been adopted based on scientific advice from the WHO, and on an assessment of the current levels of concentration and achievability of reduced levels. 198 The TSAP analysis was not optimised to achieve compliance with the air quality limit values, but rather to maximise the reduction in air pollution impacts across Europe. Nor was it possible to determine in detail the impacts of achieving the impact reduction objectives on compliance with the air quality standards, as the resolution of the model grid was too coarse (at 50x50km). The TSAP thus did not propose any adjustment to the limit values already adopted under framework and daughter directives on air quality, but did allow an extension of the timescale for meeting these values based on evidence that Member States had taken all possible action and still certain limit values were unlikely to be reached by the required deadlines.
4. T HE A MBIENT A IR Q UALITY D IRECTIVES
4.1. Objectives, scope and approach
Legislation on ambient air quality stems principally from the Air Quality Framework Directive 1996/62/EC i. That Directive set out a framework for the establishment of ambient air quality standards and for air quality assessment, public information, and management with the aim of establishing a uniform minimum level of protection for human health and the environment. It also listed a set of key pollutants which had been identified as posing the most significant threats to human
195 JRC-IPTS 2013. Market based instruments to reduce air emissions from household heating appliances: Analysis of scrappage policy scenarios. To be published.
196 Addressed in: EEA Air Implementation Pilot ‘Lessons learned from the implementation of air quality
legislation at urban level’, EEA report No 7/2013, available on http://www.eea.europa.eu/publications/airimplementation-pilot-2013 ; ‘Review of the Air Quality Directive and the 4 th Daughter Directive, Service request no 6 under FW contract ENV.C.3/FRA/2009.0008. Final report 2012; ‘Final report of the PM Workshop Brussels 18-19 June 2012’ (service request 7 under FW contract ENV.C.3/FRA/2009/0008; ‘Services to assess the reasons for non-compliance with the ozone target value set by Directive 2008/50 i, and potential for air quality improvements in relation to ozone pollution’, Ecorys 2013.
197 The main two issues are offsetting for shipping NOx emissions and joint implementation for methane.
198 See Directive 1996/62/EC i Annex 2, and Commission proposal for 1999/30 (COM(1997)500 final i.
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health and the environment. Standards for these pollutants were initially set in four subsequent ‘daughter’ Directives that were governed by the Framework Directive.
For SO 2 , NO 2 , PM 10 , lead, benzene and carbon monoxide the standards were set as limit values, to be achieved everywhere; while standards for ozone were set as target values, in recognition of the difficulty in ensuring that the required concentration is met given the complex atmospheric chemistry
involved in ozone production. The 4 th Daughter Directive, 2004/107, covering heavy metals and
polyaromatic hydrocarbons (PAHs), also established target values, on the basis that the desired concentrations of ambient air concentrations of arsenic, cadmium, nickel and polycyclic aromatic hydrocarbons (i.e. concentrations which would not pose a significant risk to human health) could not
be achieved in a cost-effective manner in specific areas. 199 The implementation of target values does not require that measures entailing disproportionate costs be taken; 200 for an ambient air quality limit
value, on the other hand, the obligation is binding as to the concentration to be achieved and Member States are obliged to put in place the necessary plans and programmes to reach compliance.
The 2005 TSAP was accompanied by a legislative proposal for amending the Ambient Air Quality Directives –eventually adopted as Directive 2008/50/EC i. It significantly streamlined the legislation by merging the Air Quality Framework Directive and its first three daughter directives. It also included new flexibilities by introducing the possibility of time extensions for the PM 10 , benzene, and NO 2 limit values originally established in 1999. New air quality standards were introduced for particulate matter (PM 2.5 ), based on the increasing evidence that health effects were dominated by long-term exposure to this pollutant. Finally, it called for further streamlining the existing implementing acts and further adapt them to reduce the administrative burden through making better use of electronic and automated data collection and processing technology. The latter consolidation was completed in 2011 through the adoption of the Commission Decision 2011/850 i/EU, consolidating and amending three implementing acts.
A particular innovation of Directive 2008/50/EC i was to include a different kind of regulatory parameter for PM 2.5 in addition to the traditional ambient concentration: an average exposure indicator (AEI) designed to reflect the population exposure to PM 2.5 in an individual Member State, and with
two related objectives. 201 The rationale was that there was no identifiable threshold below which PM 2,5 would not pose a risk, and so a mechanism was needed to prompt a general reduction of concentrations in the urban background to ensure that large sections of the population benefit from improved air quality. This would supplement the PM 2.5 limit value, the role of which is to ensure a
minimum degree of health protection everywhere. 202
Since the recent consolidation, ambient air quality standards are contained in the Directive 2008/50/EC i and 2004/107/EC.
4.2. Monitoring, reporting and evaluation
The implementation of the ambient air quality standards is monitored according to specific provisions established in the relevant Directives and including provisions on zoning, the determination of the required assessment regime, criteria for location of sampling points (macro-scale and micro-scale
199 See Directive 2004/107/EC i recital 3.
200 Ibid., recital 5.
201 A national exposure reduction target to be met by 2020 and an exposure concentration obligation to be met by 2015. See Annex IX of Directive 2008/50 i.
202 Directive 2008/50/EC i recital 11.
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siting), data quality objectives, reference methods for the assessment of concentration of pollutants, and the conditions under which modelling could be used in combination with fixed measurements. 203
Data collection, quality assurance, and reporting of the resulting data is managed by the European Environment Agency (EEA). The EEA provides annually a consolidated report on implementation of
the Directive. 204 Detailed data sets are maintained and publically available in the EEA's Airbase. 205
It is noted that under the provisions of the new Decision 2011/850 i/EU a transition to electronic reporting compatible with the INSPIRE Directive will take place in 2014, allowing for further streamlined reporting and evaluation as well as enhanced public access to relevant air quality information. 206
4.3. Relevance
The main issue of relevance for the Ambient Air Quality Directives is whether the pollutants regulated are indeed those of principal health concern, and whether the controls are set at the correct level. As part of the 2013 air policy review, the Commission asked WHO to carry out a review of the health effects of air pollution according to a series of questions identified in consultation with
stakeholders. 207 Among the key questions were:
whether any developments in evidence would justify modifications to the emphasis on the main pollutants currently regulated (PM 10 and PM 2.5 , NO 2 and ozone), including:
o whether any fractions of particulate matter should be regulated in preference to particulate mass;
o whether new evidence affected the assumptions regarding a no-effect threshold for any pollutant;
o whether the health evidence related to NO 2 indicated that it impacted directly on human health, or was a marker for some other component of air pollution.
• whether any parameters could be consolidated or deleted from the regulatory framework, or whether any should be added;
• which metrics, health outcomes and concentration-response functions could be used to assess the health impacts of PM, ozone and NO 2 .
These questions covered all the main issues raised by stakeholders in the first public consultation. 208 The question of the independent health impacts of NO
2 was particularly important given (a) the widespread non-compliance with the NO 2 limit value and (b) the fact that while vehicle related PM pollution has been decreasing (due e.g. to implementation of the diesel particle filter), NO 2 concentrations have been stable and often above the EU AQ limit value, and in several places increasing levels.
203 See e.g. Directive 2008/50/EC i annexes I-VI.
204 The most recent being report No 4/2012, ‘Air Quality in Europe – 2012 report’; see above for availability. 205 See http://www.eea.europa.eu/themes/air/air-quality/map/airbase.
206 Directive 2007/2/EC i establishing an infrastructure for spatial information in the European Community.
207 WHO, ‘Review of the impacts on health of air pollution’, 2013. http://www.euro.who.int/en/what-wedo/health-topics/environment-and-health/air-quality/publications/2013/review-of-evidence-on-health-
aspects-of-air-pollution-revihaap-project-final-technical-report
208 See report ‘Survey of views of stakeholders, experts and citizens on the review of the EU Air Policy Part II: Detailed results.’ In particular pp35-40.
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The main conclusions from the WHO analysis are as follows:
• While there is some evidence linking particular sub-components of PM 2.5 with specific health impacts (for instance the sub-components related to primary combustion), the balance of evidence favours retaining PM 2.5 mass as the target for policy measures; 209
• Evidence still supports the absence of a threshold for PM 2.5 . 210 For ozone the evidence is inconclusive, but any threshold, if it exists, is likely to lie below 90 µg/m3. 211 (The EU target
value is 120µg/m3.) Since 2005 there is new evidence indicating potential severe health impacts (premature mortality) of chronic exposure to ozone.
• Evidence indicates that there are independent effects of NO 2 on short-term health outcomes; the evidence for independent long-term effects is less clear-cut but still suggestive of a causal relationship.
• There are independent rationales for each of the current PM limit values. 212 In addition there is a
potential rationale for a limit value on short-term average concentrations (as well as the current
annual average). 213
• Specifications on the metrics and concentration-response functions appropriate for health impact assessment were provided in this and the follow-up project (HRAPIE), and used in the ex-ante impact assessment for the new Strategy. 214 The recommendation was that air pollution health impact assessments should focus on chronic PM 2.5 exposure and acute ozone exposure, as in 2005, but that sensitivity analysis on chronic ozone impacts and chronic NO 2 impacts would also be warranted.
• While the parameters of the current legislation are all separately justified based on the health evidence, there is evidence indicating the need to revise WHO guidelines for PM, ozone (longterm exposure), NO 2 and SO 215 2 .
With regard to the level at which the EU limit and target values are set, with the exception of the NO 2 annual limit value these are less strict than the current WHO guidelines, and no values have been tightened since they were originally established. The WHO advised in particular that the levels at
which the PM limit values are set are not sufficient to adequately protect human health. 216 Thus, even
full compliance with the existing Ambient Air Quality Directive would be insufficient to protect human health: very substantial health impacts would remain.
The review also examined the levels at which controls are set for the substances regulated in the AAQD in the EU's main trading partners and the WHO guidelines. Appendix 2 sets out the levels established in the EU as compared with the WHO guidelines and the limit values in the USA, Japan, Switzerland, China, Korea, and India. The limit values set are broadly comparable to those of the EU even in emerging economies. For the health problem of most concern (PM 2.5 ), the USA limit value is substantially tighter than the EU limit (at 12 µg/m 3 3 , as compared with 25µg/m in the EU). For the pollutants for which compliance in the EU is most difficult, the following observations are made:
• NO 2 annual average: the limit in the USA is substantially higher (100µg/m 3 as compared with EU’s 40µg/m 3 ), but China and India are the same and Switzerland is tighter (30µg/m 3 ).
209 WHO REVIHAAP report pp10-12, 182-183.
210 Ibid., pp38, 182-183.
211 Ibid., p59.
212 Ibid., p35.
213 Ibid., p32.
214 Ibid., pp41, 62, 117.
215 Ibid., ppp182-186.
216 Ibid., p83.
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• PM 10 daily average: this is difficult to compare given the crucial role of the number of allowed exceptions. USA looks less stringent (at 150µg/m3 as compared with the EU’s 50µg/m3), but (a) the USA strictly regulates the PM 2.5 sub-fraction of PM 10 and (b) it allows only one day’s exceedence a year as opposed to the EU’s 35 days.
4.4. Effectiveness
The effectiveness of the AAQDs in achieving their objectives has been assessed in terms of the extent of compliance with the limit values set.
Figure 3 presents the summary compliance picture in graphical form. It shows the percentage of monitoring stations in exceedance of the limit or target values (left), and the percentage of the EU population potentially exposed to concentrations above those values (right).
Figure 3: The 2010 AAQD Compliance and Population Exposure Picture (EEA)
Widespread compliance with the limit values for benzene, lead, CO, and SO 2 in the Directive has been achieved (Figure 4).
Figure 4: Status of compliance in 2010 with EU legally binding air quality standards for Benzene, Lead, CO, and SO 2 (clock wise from upper left onwards); EEA 2012
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In addition, the non-binding target values for heavy metals (arsenic, cadmium, nickel) are also broadly complied with (Figure 5).
Figure 5: Level of compliance with non-binding target values for heavy metals (arsenic, cadmium, and nickel) in the EU
These successes have been mainly attributed to effective EU –level source controls including fuel quality measures (requiring the placing on the market of low-sulphur and unleaded fuels throughout the EU) and measures addressing large point sources such as the Large Combustion Plants Directive, the Waste Incineration Directive, and the Integrated Pollution Prevent and Control Directive, all now consolidated in the new Industrial Emissions Directive.
As shown in Error! Reference source not found., there remains however widespread noncompliance with the PM 10 and the NO 2 limit values despite the time extensions provided in the Directive 2008/50/EC i. 217 There is also widespread exceedance of the target value for benzo(a)pyrene (BaP, the marker for polyaromatic hydrocarbons), and the target value for ozone.
217 For PM
10 the daily limit value is the most demanding to meet; for PM 2.5 the the annual average limit value is the most demanding to meet.
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Figure 6: Exceedance of EU air quality standards in 2010 for PM 10 , NO 2 , Ozone, and BaP
(clockwise from upper right) in 2010 (EEA)
Dots represent individual monitoring stations; green dots indicate compliance with the standards, red dots exceedance.
For PM 10 , infringement procedures have currently been launched against 17 MS. For NO 2 , 18 MSs have requested time extensions up to 2015 in accordance with the time extension provisions in the Directive; taking into account the Commission's decisions on these requests, 18 MSs are currently in non-compliance with the NO 2 limit values. The enforcement options related to BaP and ozone are currently limited.
With respect to the new PM 2.5 standards introduced in 2008, the limit value of 25µg/m 3 for 2015 is likely to be broadly complied with. 218 That standard is, however, less stringent than the PM 10 daily limit value. Projections show that the Directive's indicative limit value for PM 2.5 of 20µg/m 3 by 2020 is also likely to be broadly complied with, except in specific circumstances.
218 In 2011, 17 MSs are already in compliance with the limit value, with a further 4 within the so-called margin of tolerance (indicating a sound trajectory towards compliance).
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With regard to the PM 2.5 average exposure reduction objectives introduced in 2008, the first legal milestone is achieving the exposure concentration obligation of 20µg/m 3 in 2015 at the latest. Member States were asked to share their
experiences with implementing the exposure Figure 1: Projected compliance with PM
reduction obligations, but there is little 2.5 limit values (2015 and 2020) assuming
practical experience at this stage given that no change to current policies
the first substantive obligation is for 2015, and it is too early to assess the effectiveness of the concept in delivering health impact
reductions. 219
Pollutant specific causes of non-compliance and outlook for improvements
Particulate Matter
The causes of non-compliance vary significantly depending on the pollutant and the national or local circumstances. The following is an assessment by pollutant of the main reasons for non-compliance.
Concentrated local pollution sources for PM are a problem mainly in large urban centres which are often densely populated, making the resulting health impacts particularly significant. 220 In most locations currently in exceedance of the PM standards, high PM concentrations are the compound effect of different sources that include traffic (notably older diesel vehicles, both heavy- and lightduty), domestic heating, industrial sources, power production and background concentrations including also secondary aerosols, i.e. emissions of PM precursors including SO 2 , NO x , VOCs and NH 3 . 221
Projections of the compliance picture assuming no changes to the current policy framework developed in Annex 5 show that by 2020, reductions delivered by implementation of current legislation will
bring most stations situated in these "normal" areas into compliance. 222 For instance, the continued
penetration of Euro 5 light duty vehicles and Euro VI heavy duty vehicles into the fleet will progressively reduce (primary) particulate matter in line with the stricter emission introduced by those Euro standards. Further PM emission reductions can also be expected in the period up to 2020 from robust pollution controls on other relevant sources such as industrial installations and the energy sector that have been regulated the recently revised Industrial Emissions Directive, including the
219 th See report, ‘Review of the Air Quality Directive and the 4 Daughter Directive’, RICARDO-AEA 2012, section 4.4.3 p64.
220 E.g. some of the main population centres in Europe remain in non-compliance: Milan, Madrid, Barcelona,
London and others.
221 See EMEP country reports, ‘Transboundary air pollution by main pollutants (S, N, O3) and PM in 2010’ showing the extent of transboundary contributions to concentrations of those pollutants in all CLRTAP parties (including all Member States). All reports are available on:
http://www.emep.int/mscw/mscw_publications.html ; see for instance p19 of the Belgium country report for 2010 for the transboundary contribution to PM2.5 in BE (around 80%). BE report available on http://www.emep.int/publ/reports/2012/Country_Reports/report_BE.pdf.
222 See Annex 5, section 5 for detail.
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revision of the associated Best Available Technology Reference Documents and conclusions. As a consequence, implementation of current legislation will resolve most of the current compliance problems by 2020. (See also Annex 5).
However, this positive trend will not solve all non-compliance. Specific localised problems will remain related to special "worst case" circumstances that are particularly challenging to address at the local level. To identify the drivers responsible, the remaining areas of non-compliance were identified from the compliance modelling, and the reasons for non-compliance isolated, as follows.
Those are characterised by either (a) specific domestic solid fuel combustion issues, or (b) particularly concentrated local pollution sources, often combined with a particular topography.
• Domestic (household) solid fuel combustion has historically been a major driver of PM pollution in many Member States (for instance it caused the great London smog). Most Member States have restricted solid fuel use in response, but there are areas (notably the border region of PL, SK, CZ, and BG) where it remains the major pollution source. The required action has not been taken by the Member States in these regions mainly because the areas in question are often relatively poor, and the socio-economic impact of implementing the required restrictions is a deterrent.
Pioneering initiatives have however been launched in a few locations, for instance Krakow. 223
The problem is not only continuing coal use, but also increase in biomass use, driven partly by renewables policy and (more recently) by the economic crisis which has caused some people to turn to wood burning and other forms of highly polluting and inefficient heating solutions. While action on the marketing and use of solid fuel combustion appliances will have an impact on the problem over time, the replacement rate of solid fuel installations is slow (and possibly even slower in low-income households), and open fireplaces will never be covered. Consequently,
existing instruments such as the Ecodesign Directive, 224 which apply only to new products and do
not affect existing installations, will not be sufficient; different approaches better adapted to specific local circumstances will be required.
• The problem is compounded in certain locations by a topography which limits effective dispersion of pollution, a factor that was explicitly recognised in Directive 2008/50/EC i, which allowed time-bound flexibilities to deal with site specific dispersion characteristics. To reach compliance in such 'difficult' locations requires more comprehensive action than elsewhere on the relevant local pollution sources, to ensure that the economic benefits of the concentrated economic activity are not compromised by adverse health impacts. 225
Further reductions in PM concentrations in the EU, beyond those required to achieve compliance with current air quality standards, will require reductions in background concentrations. This requires coordinated national and/or transboundary action on primary PM and on precursors. The lack of a primary PM 2.5 ceiling in the NECD, and of new stricter ceilings for PM precursors resulted in inadequate reductions in this regard. Also, the AAQD provisions on transboundary pollution problems
(Art 25) are rarely used, and when used, ineffective. 226
Nitrogen Dioxide (NO 2 )
Type-approval emission requirements for motor vehicles have been tightened significantly through the introduction and subsequent revision of Euro standards. Figure 8 shows, however, that while
226 Few cases are known; DE made contacts with PL, and PL and CZ have had some contacts.
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vehicles in general have delivered substantial emission reductions across the range of regulated pollutants, this is not true of NO x emissions from diesel engines (especially light-duty vehicles).
Figure 8: Euro Emission standards and real world emissions for gasoline and diesel vehicles (ICCT, 2012)
NO x emissions of gasoline cars in the EU have decreased significantly since 2000, from about 0.2 grams per kilometer (g/km) to 0.05 g/km. This corresponds quite well with the Euro emission limits, which were adapted from 0.15 g/km to 0.06 g/km in the same time period. The Euro emission limits regulate how much specific pollutants, such as NO x , may be emitted by a car when it is tested under laboratory conditions and using a specific driving cycle. In the case of gasoline vehicles, the NO x emissions measured in the laboratory are fairly well in line with the level of emissions measured onroad, i.e., when driving the car under real-world conditions on a real road. This, however, is not the case for diesel cars. Diesel vehicles in the EU are allowed a much higher NOx emission level than gasoline cars. In 2000, when the Euro 3 standard was introduced, the allowed level was 0.5 g/km, more than twice as much as for gasoline vehicles. Yet, as vehicle tests show, even back then the real on-road emission levels were closer to 1.0 g/km, i.e., much more than actually allowed by the standard. Still, the vehicles received their type-approval and could be sold, as the Euro emission standards have to be met under laboratory conditions only. Over time, emission limits got stricter, and the current Euro 5 emission standard sets a limit of 0.18 g/km for NO x diesel emissions. This is still more than three times as high as for gasoline vehicles, but of course much lower than back in 2000. However, research suggests that the on-road emissions did not really change at all during the last decade. The values measured are in the range of 0.8 g/km, only 20% lower than in 2000 and more than four times higher than allowed by the Euro 5 emission limit. 227
227 See for example the study carried out on on-road emission data from a by King’s College London and the University of Leeds for the UK government. In total, emissions data from more than 80,000 vehicles were
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The problem is due in part to the poor representativeness of the standardised test cycle used for type approval in the EU 228 and weaknesses of in-service conformity testing. Under the current regime an engine type has to meet the type-approval requirements when tested according to the test cycle, but under normal driving conditions the real emissions can be much higher.
Figure 9 shows that while the NOx emission limit values for diesel passenger cars have been tightened by approximately a factor of 4 from 1993 to 2009 (Euro 1 to Euro 5), the estimated average NOx emissions in real driving conditions have slightly increased. As a side-effect of engine technology developments, the share of direct NO 2 emissions in the NOx mixture has increased at the same time, posing additional challenges for the attainment of the NO 2 air quality standards.
Figure 9: type approval (left) and real-world emissions (right) from diesel light duty vehicles across Euro standards (source: COPERT analysis and IIASA 229 )
While this has been observed for several years, many Member States continue to promote the sale and use of diesel vehicles compared to gasoline and other cleaner fuel vehicles. The consequences of the less than hoped for effects of the vehicle standards relating to diesel passenger cars and light-duty vehicles have been exacerbated by national taxation policies favouring diesels and increasing traffic volumes in urban areas (see also governance issues) 230 .
analyzed, and the authors conclude: “In the case of light duty diesel vehicles it is found that NO x emissions have changed little over 20 years or so over a period when the proportion of directly emitted NO 2 has increased substantially”.
228 The New European Driving Cycle (NEDC).
229 https://circabc.europa.eu/sd/d/2f169597-2413-44e2-a42c-35bbbde6c315/TSAP-TRANSPORT-v2-
20121128.pdf
230 See also OECD, 2013
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Figure 10: Fuel tax rate comparisons in the EU and CH in 2002 and 2012 (OECD,
2012)
Sustained high levels of NO x emissions and NO 2 concentrations are particularly related to these emissions and the associated AAQD and NECD compliance issues.
Ground-level ozone
For ground-level ozone, there has been significant reduction in ozone precursor emissions since 1990, and this has been mirrored by a general trend towards lower peak values for severe ozone episodes. 231 However, there is no corresponding downward trend in background concentrations. 232 A significant part of this discrepancy is likely to be due to hemispheric transport of ozone which is substantially influenced by methane emissions across the northern hemisphere (methane has a long atmospheric
lifetime and influences ozone concentrations at substantial distances from the point of emission). 233
Poly-Aromatic Hydrocarbons and BaP
For BaP the exceedance is largely due to domestic biomass combustion and thus is linked to the drivers of PM exceedances. 234
231 See ‘Services to assess the reasons for non-compliance with the ozone target values set by Directive
2008/50’, Ecorys 2013, pp15-19. See also the EEA’s annual ozone report on
http://www.eea.europa.eu/publications/air-pollution-by-ozone-across-EU-2012.
232 Ibid.
233 EEA report 4/2012, ‘Air Quality in Europe – 2012 report’, p11.
234 Ibid p14 and Chapter 8.
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4.5. Efficiency
In addition to the above pollutant- specific drivers of non-compliance, several governance related problems that affected the efficiency of the AAQD emerged from the review.
The AAQD works through the development of action plans at local and regional level designed to
achieve compliance with the concentration limits by the relevant deadlines. 235 This reflects the
"subsidiarity" principle, i.e. that action should be left to the Member States where it is most costeffective do so.
In practice, many Member States have relied substantially on EU source control measures whilst evidence from the time extension notification 236 process under the AAQD 2008/50/EC shows that authorities often acted late in relation to the lead time necessary to bring air pollution down in "local" hotspots, with many plans and programmes developed only as the compliance deadlines approached and not fully implemented in practice. 237 In many cases responsibility for meeting ambient air quality standards rests at regional and/or local level, but the financial and other tools to meet those responsibilities are often lacking.
Late or insufficient action often relates to the fact that local action was not sufficiently supported by action in surrounding zones or at the national level, or in some cases between Member States to
address transboundary pollution. 238
Part of the problem is also related to the lack of the assessment and management capacity to develop, implement and monitor plans. For instance, local authorities have been unable to design effective air quality plans because no adequate inventories of the contributing local sources have ever been developed. In some cases, capacity has been further reduced in the wake of the economic crisis,
including at the national level. 239
The efficiency of the Directive 2008/50/EC i in driving local action has nevertheless improved over time, as effort on enforcement at EU level has intensified. As a result, good practices have been emerging (see also section 7).
5. T HE N ATIONAL E MISSION C EILINGS D IRECTIVE
5.1. Objectives, scope and approach
The National Emission Ceilings Directive 2001/81/EC i aims at controlling transboundary fluxes of air pollution for the purpose of meeting in a cost-effective way, air pollution impact objectives for
235 For more detail see EEA report 7/2013, ‘Air Implementation Pilot’, p37.
236 The possibility under Directive 2008/50/EC i (Article 22) for Member States to notify a postponement of the
attainment deadlines for particulate matter (PM10), nitrogen dioxide and benzene, under certain conditions and subject to approval by the Commission.
237 Internal assessment based on analysis of Time Extension Notifications.
239 From exchange of views with national and local competent authorities.
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acidification, eutrophication and the health and environmental impacts of ozone. It does so by setting ceilings on total national emissions of four pollutants (SO 2 , NO x , non-methane VOCs and NH 3 ) which are to be complied with by 2010 and thereafter.
The NECD covers all emission sources on the territory that constitute the national totals. They include all land-based sources and inland waterway and national maritime navigation, but the large emissions
associated with international maritime traffic are excluded. 240 Aviation emissions are included only
for the relatively minor shares associated with the take-off and landing phases, while the larger emissions occurring during cruise are excluded.
The 2005 TSAP announced a revision of the NECD to set new ceilings for 2020 in line with the objectives set in the Strategy for those pollutants already regulated, plus primary particulate matter (PM 2.5 ) which is not regulated in Directive 2001/81/EC i. The proposal for revision was finalised by the Commission services in 2008, but not adopted by the College.
5.2. Monitoring and Evaluation
The Directive requires Member States to calculate and report emission inventories and projected emissions for 2010 according to the methodologies specified under the LRTAP Convention. Reports were to include emission projections for 2010 including information to enable a quantitative understanding of the key socioeconomic assumptions used in their preparation.
The EEA annually establishes compiled emission inventories and projections on the basis of information reported by Member States. The information is publicly disseminated on the EEA’s website both as data files, core environmental indicators and in online data viewers. 241 In addition, the EEA annually publishes technical reports including its assessment of the progress being made towards
the implementation of the NEC Directive. 242
5.3. Relevance
A review of evidence has confirmed the continued importance of ozone impacts, and ecosystem impacts from eutrophication and acidification, among the problems caused by air pollution, 243 and as commented above for the TSAP, successive reviews of the science underlying those problems have
confirmed that the pollutants addressed in the NECD are indeed main problem drivers. 244 The
approach of the NECD, to cap transboundary flows of air pollution by setting national ceilings, remains relevant to address the continuing evidence that very substantial proportions of pollution
240 To be precise, they are excluded from the emission ceilings, although not from the obligation to establish inventories.
241 http://www.eea.europa.eu/data-and-maps/data/data-viewers/emissions-nec-directive-viewer and
http://www.eea.europa.eu/data-and-maps/indicators/#c5=agriculture&c7=all&c0=10&b_start=0.
242 See 2012 report on http://www.eea.europa.eu/publications/nec-directive-status-report
243 WHO Review of Evidence on Health Aspects of Air Pollution, 2013. Available on
http://www.euro.who.int/en/what-we-do/health-topics/environment-and-health/airquality/publications/2013/review-of-evidence-on-health-aspects-of-air-pollution-revihaap-project-final- technical-report.
244 For an in-depth assessment of eutrophication and its underlying causes see the European Nitrogen
Assessment: Sources, Effects and Policy Perspectives, Sutton, M A et al, Cambridge University Press 2011; for an in-depth assessment of the health impacts of air pollution and their underlying causes see the Review of Evidence on the Health Aspects of Air Pollution, WHO/Europe 2013 (see above or Annex 1 for ref.)
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concentrations in many Member States are due to transboundary pollution 245 , and to bring down the background concentrations that affect the prospects of achieving the ambient air quality standards. 246
However, the 2001 NECD does not explicitly address the health impacts of particulate matter, which was identified by the 2005 TSAP as the major health problem from air pollution in the EU (and
confirmed as such by the current analysis). 247 While all pollutants regulated under the NECD are PM
precursors, and so NECD reductions will influence PM concentration levels, the level of the ceilings in question was not determined on the basis of the required reductions in PM. Furthermore, the NECD includes no emission ceiling for primary particles. Such a ceiling was scheduled for introduction in the 2008 revision, along with tightening of the other ceilings for 2020.
A further issue is whether and how to regulate air pollutants which are also Short-Lived Climate
Pollutants (black carbon and methane) under the NECD. For technical reasons 248 a separate ceiling
for black carbon is currently not appropriate, but special attention to measures to limit black carbon emissions when designing national programmes for PM2.5 compliance, as agreed in the amended Gothenburg Protocol, would be sensible. Hemispheric methane emissions are a determining factor for
background ozone concentrations, in addition to their climate forcing role. 249
Thus there is a need to amend the NECD for the purpose of transposing the international obligations agreed under the Gothenburg Protocol of the LRTAP Convention, and also a case for considering an additional ceiling related to methane.
5.4. Effectiveness
The emissions ceilings have broadly been attained. Member States (EU27) reported for 2010 emissions breaches for in total 17 of the 108 ceilings, and the EU-wide emission ceilings (a combination of all Member States ceilings) were reached, except for a relatively limited exceedence of the NOx ceiling. Green bars and negative figures signify overachievement of the emission reduction objective; orange bars and positive figures signify exceedances.
245 See EMEP country reports, ‘Transboundary air pollution by main pollutants (S, N, O3) and PM in 2010’
showing the extent of transboundary contributions to concentrations of those pollutants in all CLRTAP parties (including all Member States). All reports are available on http://www.emep.int/mscw/mscw_publications.html ; see for instance p19 of the Belgium country report for 2010 for the transboundary contribution to PM2.5 in BE (around 80%). BE report available on http://www.emep.int/publ/reports/2012/Country_Reports/report_BE.pdf .. For stakeholder comments on the importance of regulating transboundary pollution, see ‘Survey of views of stakeholders, experts and citizens on the review of the EU Air Policy: Part II’, p63.
246 See for instance report on ‘PM Workshop Brussels 18-19 June 2012’, pp 5-6, 9,
247 See section 3.2.1 of the main Impact Assessment.
248 The need to introduce an inventory methodology. See report, 'Services to support the update of the EMEP EEA Emission Inventory Guidebook, in particular on methodologies for black carbon emissions', Ecorys 2013.[to appear on the EEA website within short]
249 For the impact of hemispheric methane emissions on ozone concentrations, see the Executive Summary of
the LRTAP Task Force on Hemispheric Transport of Air Pollution (HTAP) 2010, p3 point 10 (report available on http://www.htap.org/ ). For the impact of methane on climate forcing, see the UNEP Synthesis Report, ‘Near-term climate protection and clean air benefits: actions for controlling short lived climate forcers’, UNEP 2011, Chapter 2 p3. Report available on http://www.unep.org/publications/ebooks/slcf/.
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Figure 11: NECD Compliance Picture Related to 2010 Member State Obligations (EEA, 2012)
The extent to which action was driven specifically by the NECD varies by pollutant. This discussed in the section below dealing with source control measures.
The non-compliance issue is much smaller than for the AAQD. It relates mainly to the NOx ceilings,
where nine Member States reported 2010 emissions that were above the ceilings. 250 In most cases, the
less than expected emission reductions of the Euro standards for diesel vehicle NOx emissions have contributed to this situation. 251 The Commission launched a contract to identify the reasons for noncompliance with the ceilings. It concluded that for the vast majority of non-compliance cases, compliance could be achieved in a reasonable timescale with the appropriate effort from the Member
States. 252
The main message from the stakeholder consultation was that the NEC Directive is an effective instrument to bring down transboundary emissions, especially if the ceilings are supported by source legislation at European level, where cost-effective, and by identifying those national source controls
which should contribute substantially towards achievement of the ceilings. 253
As well as the NECD annual status report, the EEA produced a review of the overall achievements of
the NECD in 2012 (the emissions data for the compliance year 2010 was available). 254 In performing
an assessment of the progress made by the Directive in reducing harm caused by air pollution, the
250 In 2011 only 8 MSs are in breach, and the number of ceilings breached is lower than in 2010 (down to 11, from 17). See EEA 2012 report, op. cit.
251 Ref to IIASA report indicating how compliance with NEC ceilings depends on Euro emissions.
252 Specific contract, ‘Services to assess the reasons for non-compliance with the emissions ceilings set in the National Emissions Ceilings Directive’. Final report pending; will be published on the review website http://ec.europa.eu/environment/air/review_air_policy.htm.
253 See ‘Survey of views of stakeholders, experts and citizens on the review of the EU air policy Part II’, p80 point 3.
254 See EEA report No 14/2012, ‘Evaluation of progress under the EU National Emission Ceilings Directive’, available on http://www.eea.europa.eu/publications/evaluation-progress-nec-2012.
125
EEA took account of advances in scientific knowledge since the Directive’s adoption in 2001, such as updates in emission inventories, improvements in dispersion modeling (including a finer resolution), and refinements of the critical load thresholds needed to protect ecosystems from harm. 255 It did so by employing two approaches in assessing the progress achieved toward meeting the interim environmental objectives: one assuming the science available at the time of adoption; the other using current science. The report concluded that in some cases the emission reductions achieved under the NECD have been insufficient to reach the Directive's environmental objectives, because the reductions estimated on the basis of the science of 1999 underestimated the reductions that were
actually needed. 256 However, the NECD had been broadly successful in its own terms, in that the
reductions and objectives agreed in 2001 had been broadly achieved in practice.
5.5. Efficiency
The NECD requires that Member States draw up and implement national programmes to meet the emission ceilings, which should be revised if projections show that the ceilings are unlikely to be met. An ex-post review of the efficiency of the national programmes 257 showed that:
• the programme design was often suboptimal and in some cases the national measures were inadequate to meet the ceilings.
• the structure and organisation for the preparation of programs varied across the Member States although the Commission services had prepared recommendations and guidance for that purpose 258 and did often not secure public participation in the process nor a commitment of the national governments to implement the proposed measures.
• the reporting from the Member States on their programs was incoherent and did not allow an effective review of the programs at the EU level to secure that the environmental and health objectives were met by the target year 2010. 259
With regard to the assessment framework, the inventories used for assessing compliance were highlighted as an issue. Reporting obligations are inconsistent with international requirements, but also the quality of the inventories requires improvement.
Two key reasons for the quality issues are:
Limited inventory review process and resources allocated. The effort on inventory review for the NECD has been limited and depends on the reviews by the LRTAP Convention. Resources are limited also because there are no provisions in the NECD for a detailed in depth inventory review. Nor are there provisions for following through adverse findings by Commission (and EEA). Active engagement with Member States would be needed to develop solutions based on training, capacity building, technical assistance programmes etc. Finally, there is no possibility to sanction incompleteness such as a provision authorising the Commission/EEA to complete any missing submissions for particular sectors or regions. (Such a provision has proven in the context of greenhouse gas reporting to offer a strong incentive for Member States to provide their own data.)
255 Ibid., pp5-6 and Chapter 2.
256 Ibid., pp7-10..
257 Report, ‘National Emission Ceilings Directive Review Task 1: In-depth analysis of the NEC national programmes’, Entec UK, 2005. Available at:
http://ec.europa.eu/environment/air/pollutants/pdf/final_report.pdf.
258 See http://ec.europa.eu/environment/air/pdf/recs_national_programmes.pdf
259 See summary report of above Task 1 (and the other review tasks): ‘National Emission Ceilings Directive Review: Project Summary and Conclusions’, Entec 2005, pp6-7. Available at:
http://ec.europa.eu/environment/air/pollutants/pdf/recs.pdf.
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• Limited guidance for developing local emission inventories. The Air Implementation Pilot 260 demonstrated the need for guidance to address the present situation where local emission inventories are developed independently from national emission inventories. The lack of detailed local emission inventories has caused delays in developing appropriate air pollution management programmes (e.g. for measures reducing pollution from domestic heating) whilst hampering comparison and exchange of good practice across local authorities.
The second point on the assessment regime is that there is currently no legal basis requiring systematic monitoring in the EU of the ecosystem impacts of air pollution. Again this is inconsistent with international obligations, and it compromises the prospects for any review of the environmental effectiveness of EU and international policy.
6. EU S OURCE C ONTROL M EASURES
6.1. Objectives, scope and approach
As stated above, the principle of the AAQDs and NECD is that while the EU should set the standards and ceilings, Member States are best placed to determine the pollution reduction measures needed to achieve them. However, source control measures at EU level are an essential reinforcement to the ceilings and standards in two respects. First, emissions from products placed on the common EU market contribute substantially to air pollution problems and these must be regulated at EU level (e.g. light- and heavy-duty road transport, non-road mobile machinery, etc). Second, for a range of other pollution sources the co-legislators have determined also that control of emissions at source at EU level is appropriate (for instance the Directives recently consolidated into the Industrial Emissions Directive 2010/75 i/EU). There is now a substantial acquis of source control legislation in the fields of transport, energy, industrial emissions and (to a much lesser extent) agriculture. A (non-exhaustive) list of relevant source controls is provided in Appendix 5.
The approach taken in this review was to assess the effectiveness of the source legislation in controlling emissions relevant to the achievement of the air policy objectives, and in particular to assess progress against the proposals of the 2005 TSAP regarding source legislation (see next section). A detailed review of the success of each instrument in its own terms is beyond the scope of this exercise: source policies normally have objectives which go beyond the reduction of air pollution and a comprehensive review would normally be carried out when the source policy itself was reviewed. 261
Although we have assessed the financial impact by sector of implementation of the acquis, both historically and projected to 2030 (see Table 41 below), we have not assessed the cumulative impact on particular sectors of the air quality policy in combination with other environmental policies. That is also beyond the scope of this exercise, and would normally be taken up in ‘fitness check’ exercises for individual sectors.
With regard to source controls, the 2005 TSAP proposed:
• for industrial installations, to examine options to streamline existing legislation. This resulted in the Industrial Emissions Directive (IED) adopted in 2010 which consolidated seven Directives;
260 Reference: http://www.eea.europa.eu/publications/air-implementation-pilot-2013
261 See for instance the Impact Assessment accompanying the proposal for an Industrial Emissions Directive, SEC(2007)1679.
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• for smaller combustion plants, to examine a lower threshold (below 50 MW thermal input) for combustion installations under the IPPC directive, harmonisation of technical standards for domestic heating and fuels (Ecodesign Directive), and energy efficiency for buildings (Energy Performance of Buildings Directive and the Energy Efficiency Directive);
• for transport, additional pollution controls for car and truck emissions (Euro 5 and Euro VI), and a range of transport initiatives which were later reflected in the 2011 Transport White Paper (proposals on infrastructure charging, guidance on externalities charging, green procurement, etc.);
• for VOC management for petrol stations, so-called Stage II petrol vapour recovery controls (Directive 2009/126/EC i);
• for international shipping, a request for a mandate to negotiate tighter shipping fuel and emission standards at the IMO / MARPOL level, which resulted in the recent revision of the Sulphur Content of Fuel Directive (Directive 2012/33 i/EU);
• for energy, no measures were proposed beyond already planned Commission initiatives (indicative Renewable Energy targets and minimum targets for the share of biofuels);
• for agriculture, an integrated approach to nitrogen management, which has so far not been adopted; the potential positive impacts from the 2003 CAP reform and the Rural Development Regulation 2007-13 were also highlighted;
• for EU funding, promotion of the available possibilities in the Cohesion Policy 2007-13, principally measures to support sustainable transport and energy; and
• international initiatives within the UNECE LRTAP Convention on hemispheric transport of air pollution which culminated in the revision of the Gothenburg Protocol in May 2012.
6.2. Monitoring, reporting and evaluation
Monitoring, reporting, and evaluation provisions for EU source controls are defined and carried out in accordance with the provisions applying to the individual instruments. In addition, however, periodic assessments are undertaken by the EEA which also maintains a set of sustainability indicators tracking the contribution of key sectors such as transport and energy to air pollution in the EU.
6.3. Relevance
As an indicator of the extent to which source legislation has contributed towards the total emission reductions required by air policy, Table 7 below summarizes the contribution of EU versus national
source legislation towards compliance with the NECD ceilings for the four regulated pollutants. 262
Table 7: EU versus National actions driving compliance with the NECD
Pollutant Main drivers of action
SO 2 Action was driven mainly by emission control measures for large combustion plans, mainly in the Large Combustion Plants Directive 2001/80/EC i (LCPD), the application of Best Available Techniques (BAT) in accordance with the
IPPC Directive 2008/1/EC i, the Sulphur Content of Liquid Fuels Directive 99/32/EC i and the Fuel Quality Directive 98/70/EC i.
NO x Action was driven in roughly equal proportions by:
262 Assessment by DG ENV based on the EEA SOER 2010 Air Thematic report pp31-37 (available on
http://www.eea.europa.eu/soer/europe/air-pollution ) and the EEA report 14/2012 on evaluation of progress under the NECD ( http://www.eea.europa.eu/publications/evaluation-progress-nec-2012 ). See also the two reports 'Review and evaluation of national programmes 2002' (Entec UK 2005), and, 'Review and evaluation of national programmes 2006', AEA Energy and Environment, 2008). Available on http://ec.europa.eu/environment/air/pollutants/rev_nec_dir.htm.
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-
-the LCPD and the IPPC Directive
-
-the Euro vehicle standards
-
-national and local action in NECD national programmes
NMVOCs Action was driven largely by the Solvents Directive 1999/13/EC i, the Paints Directive 2004/42/EC i and the Petrol Vapour Recovery I (94/63/EC), and the IPPC Directive, and by EU and national labelling schemes to reduce VOC content in household products. At the national level, action on limiting use of solvents for in small and medium size enterprises was particularly important.
NH 3 The IPPC (for large scale pigs and poultry farms) and the Nitrates Directive (indirect effects e.g. due to thresholds for manure spreading) plus
complementary national action going beyond the minimum requirement of the IED (scope and manure management), in particular aiming at meeting the NECD NH 3 ceilings.
The principal industrial, agro-industrial and power sector emissions contributing to air quality are
regulated through the IPPC Directive 2008/1/EC i 263 and the accompanying "sectoral" directives. From January 2014, these directives 264 will be replaced by the Industrial Emissions Directive 2010/75 i/EU
(IED), which will tighten the requirements to apply Best Available Techniques (BAT) and set more stringent emission limits for large combustion plants.
Emissions from small (< 1 MW) and medium (1-50 MW) combustion plants have so far not been regulated at EU level. Plants under 1 MW capacity can only realistically be controlled through product legislation, which strongly motivates measures at EU level. The forthcoming Ecodesign measures on central heaters (up to 400 kW, including gas and oil boilers, the so-called Lot1), solid fuel central heaters (up to 1 MW, fueled by biomass or coal, Lot 15) and local room heaters (up to 50 kW, including appliances fired by gas, oil, biomass and coal, Lot 20) will partially cover this category. These Ecodesign measures do not address industrial or agricultural applications of such capacity, and it is not yet clear what a possible future Ecodesign measure for industrial ovens and furnaces (Lot 4) would cover. Moreover, Ecodesign requirements only apply to new installations placed on the market and do not cover existing installations so it will in general take about an average appliance lifetime of 15 years before more or less the whole stock complies through replacement. In any case there is a remaining gap in legislative coverage at EU level between 1 and 50 MW capacity, with significant potential for cost-effective emission reduction. An analysis was done on the potential contribution of Ecodesign measures to reduction of air pollution and the conclusions thereof are integrated into the main impact assessment. 265
For road transport the main pollutant emissions relevant for air quality are in principle controlled by
the EU legislation. 266 For Non-Road Mobile Machinery (NRMM) Directive the priority pollutants
263 Codified version; originally 96/61/EC.
264 With the exception of the Large Combustion Plants Directive, which is repealed from January 2016.
265 TSAP report #5, ‘Emissions from households and other small combustion sources and their reduction potential’, IIASA 2012.
266 Regulation 715/2007/EC i for light passenger and commercial vehicles; and Regulation 595/2009/EC i for heavy duty vehicles.
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are addressed but there are gaps in the scope of the legislation which are being addressed in the current revision. 267 For inland waterway transport, the principal air emissions are not effectively taken into account by the NRMM Directive. The directive still allows for high PM and NO x emissions, the impact of which is worsened by the long life span of the engines (up to 40 years). These ships are often navigating in near-urban areas and close to highly trafficked roads, adding to road pollution. The same reasoning holds for diesel trains, railcars and locomotives.
For international shipping, regulation proceeds through emission controls agreed at IMO which are then implemented at EU level. EU legislation to date has focused on implementing the internationally agreed provisions on sulphur content of liquid fuels; but IMO provisions on emissions of nitrogen
oxides and particulate matter are also important and have not been addressed in the EU. 268
Ammonia emissions decreased by less than 10% from 2000-2010 and are projected to remain at today's levels to 2020 and beyond. Agriculture is responsible for 90% of the burden and is the primary
driver of eutrophication in Europe. 269 There is little EU source control of agricultural air emissions.
The IED covers 20% of pig production, 60% of poultry and excludes cattle and other animals. The Nitrates Directive covers pollution to air only indirectly. Moreover, there is large variation in Member State controls, ranging from practically nothing to extensive national regulation. There is a large untapped potential to achieve significant and cost-effective emission reductions (around 30% for 2025), and many of the measures bring benefits to farmers, as they improve overall nitrogen efficiency and creates a playing level field for actors in agriculture. Many will also have climate cobenefits,
by reducing nitrous oxide emissions (N 2 O), a powerful greenhouse gas. 270
6.4. Effectiveness
For large industrial installations, which still account for a considerable share of total emissions, the IPPC Directive and in particular the "sectoral" directives on large combustion plants, waste incineration and VOC emissions due to solvents use have successfully reduced emissions from the
main polluting industries. 271 The implementation of the IED, in particular for large combustion plants,
will contribute substantially to further reductions.
For road transport, Euro 5 (passenger cars and light duty vehicles) and Euro VI (heavy duty vehicles) emission requirements were implemented as scheduled in the type approval legislation for motor vehicles, with the European Parliament adding Euro 6 and VI in negotiations. The Euro standards have proved successful in reducing real-world emissions of particulate matter from road transport in line with the legislation. For petrol vehicles the same is true for NO x emissions, but for diesel vehicles, real-world NO x emissions are substantially higher than the limit values specified in the type
267 See website on review of Directive 97/68/EC i on http://ec.europa.eu/enterprise/sectors/mechanical/nonroad-mobile-machinery/publications-studies/index_en.htm
268 See report, ‘Specific evaluation of emissions from shipping including assessment for the establishment of
possible new emission control areas in European Seas’, VITO 2013, pp5-7.
269 TSAP report #3, ‘Emissions from agriculture and their control potentials’, Chapter 5 pp31-34.
270 Ibid., pp24-26.
271 See impact assessment for proposal for an Industrial Emissions Directive, SEC(2007)1679 (op. cit.).
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approval legislation. 272 As indicated in the previous sections, this is a major factor contributing to non-compliance with the NO 2 ambient air quality limit value and the NO x national emission ceiling.
Directive 1999/32/EC i on Sulphur Content of Fuels has reduced emissions of sulphur from shipping as expected. The recent modification by Directive 2012/33 i/EU fulfils a TSAP commitment and will
substantially further reduce the levels of secondary PM in the EU. 273
The existing EU source legislation on air pollution emissions from agriculture is very limited in scope. While the NECD ceiling on ammonia has been reached for most Member States, and work has been done to implement the IPPC and the Nitrates Directives, these instruments have been weak to provide significant emission reductions from agriculture as a whole. Emissions of ammonia from agriculture have decreased by about 30 % from 1990 (and by 11% from 1999 to 2009), but this is less an effect of environmental policy measures than of structural changes in the sector, in particular a reduction in livestock numbers (especially cattle). To some extent it is also an effect of changes in the management of organic manures and from the decreased use of nitrogen mineral fertilisers, but it is unclear to what extent these changes have been policy-driven.
The 2008 climate and energy package was brought forward and agreed after the TSAP, but contributes substantially to air pollution reduction. The exception is the use of biomass in small and medium combustion installations, where the potential negative impact on air quality may be substantial and careful management will be needed.
Other relevant source measures outlined in the TSAP were either not proposed (integrated nitrogen management), rejected by Council (reduction of the IED threshold to 20 MW for combustion plants) or are yet to be fully implemented (Stage II vapour recovery).
Reasons for failure
The main areas of failure that are relevant for the achievement of the air quality objectives are the failure to control real world emissions from passenger cars and light duty diesels; the lack of effective regulation of ammonia emissions from agriculture; and the failure to control combustion from installations below 50MW th capacity . 274 The reasons for each of these failures are considered in turn below.
(i) Real world emissions from diesel vehicles
As discussed already above, the main reason for failure of the Euro standards to control real world emissions of NO x from diesels is the test cycle for both type approval and in service compliance, which does not reflect emissions in normal driving conditions. 275 This problem has been addressed
https://circabc.europa.eu/sd/d/2f169597-2413-44e2-a42c-35bbbde6c315/TSAP-TRANSPORT-v2-
20121128.pdf . See the impact assessment for the review of Directive 1999/32/EC i, SEC(2011)919, pp6-7.
274 IIASA 2013 demonstrates that these are the most significant impacts on outstanding air pollution problems.
275 https://circabc.europa.eu/sd/d/2f169597-2413-44e2-a42c-35bbbde6c315/TSAP-TRANSPORT-v2-
20121128.pdf
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for new heavy duty vehicles, but tackling it for diesel passenger cars and light duty vehicles in the implementation of Euro 6 is a major outstanding issue for the transport sector. Where feasible, retrofit of vehicles already placed on the market should be considered. (This is mainly applicable to municipal vehicles and transport vehicles, such as captive fleets, which make intra-urban trips. For all
these vehicles, deployment of cleaner alternative fuels is also to be considered.) 276
(ii) Lack of effective regulation of ammonia emissions from agriculture
The initiative on integrated nitrogen management proposed in the TSAP has not yet materialised, in particular due to uncertainties as to how such an initiative would impacts on the implementation of existing legislation such as the Nitrates Directive, and the time and effort needed to agree to a regulatory approach to integrated nitrogen management at EU level. As to the reasons for the lack of effective EU control of agriculture emissions to date, the main ones have been identified as follows:
• A relatively low priority has historically been given to NH 3 compared with other air pollutants. Policy has historically been driven mainly by health concerns and has focused on pollutants posing a more immediate threat (in particular SO 2 and NO x ). As these emissions have drastically reduced, the relative importance of ammonia emissions has increased both in terms of contributing to increased levels of PM2.5 and for eutrophication, the major outstanding ecosystem issue.
• The Gothenburg Protocol and the 2010 NECD ceilings are, therefore, not particularly challenging. Most MS are well below the ceilings, even without putting additional measures in place.
• More generally, ammonia emissions have been given low priority in the context of EU's general environmental legal framework, where the focus with regard to agriculture has been on water protection (e.g. through the Nitrates Directive and the Water Framework Directive), pesticide use, and biodiversity protection (land management). While these environmental problems remain very challenging, the ecosystem impacts of air pollution are increasingly significant.
• The CAP framework did not list ammonia among the core measures eligible for support, nor subject to cross-compliance requirements. Instead, priority was given to other agri-environmental issues, such as water protection or biodiversity. This has been mitigated recently by the addition of ammonia to the focus areas of the Rural Development Programme in the recent CAP agreement.
Thus until now, there has been very little interest in developing EU source legislation to address ammonia emissions, the problem being largely left to Member States to regulate, with the consequent implications for the conditions of competition in the sector. In the air policy review, calls have been made from many stakeholders to regulate ammonia emissions at EU level to support the achievement of the ammonia reduction commitments in the NECD. 277
(iii) Failure to control combustion from installations below 50MW
The proposed extension of the IED scope by lowering the combustion threshold down to 20MW was rejected in co-decision, mainly because of concerns regarding the administrative burden of imposing the IED permitting regime in that capacity range.
276 th See, ‘Review of the Air Quality Directive and the 4 Daughter Directive’, op. cit. pp56-57.
277 See, ‘Report on the consultation of options for revision of the EU Thematic Strategy on Air Pollution and related policies’, op. cit., p61.
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6.5. Efficiency
Table 8 below summarizes the estimated implementation costs related to current EU air pollution control measures. It shows the extent to which EU air pollution controls have focused primarily on large sources, notably road transport and industrial emissions including energy production in large combustion installation. It also shows that existing legislation is still set to yield further reductions (and therefore also costs).
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Table 8: Estimated air pollution control costs associated with current legislation (EU28)
2005 2010 2015 2020
Power generation 12496 12700 12093 10711
Domestic combustion 5957 7476 9115 9629
Industrial combustion 2180 2435 2468 2521
Industrial Processes 4471 4760 4983 5029
Fuel extraction 1096 976 907 770
Solvent use 756 1638 1964 2140
Road transport 18663 26022 34357 42023
Non-road machinery 980 1892 4320 6975
Waste 0 0 1 1
Agriculture 1094 1750 1775 1786
Sum 47694 59650 71983 81584
As indicated above, it is beyond the scope of this review to assess the efficiency with which each source control instrument achieves its objectives. However, the following comments can be made.
For industrial emissions, emissions from road transport and emissions from non-road mobile machinery, there is no obviously more efficient way than the chosen source controls to achieve the desired emission reductions. However, for combustion plants below 50MW, it may indeed be possible to regulate with a lighter permitting regime than that of the IED.
For agriculture, an integrated approach to nitrogen management would be the most efficient way to
regulate emissions, 278 but for reasons explained above this option may not currently be practicable.
However, the analysis shows that there is a strong case for more action at both EU and at national level to reduce ammonia and PM emissions from agriculture, advocated also by other emitting sectors on the grounds that the lack of reductions in agriculture is imposing unreasonable constraints on their
emissions. 279
A range of regulatory and non-regulatory policy options have been assessed and the following identified as promising in consultation with stakeholders:
• Implementing measures for the agriculture sector in the NECD;
• Controls on manure management at EU level;
278 See ‘The European Nitrogen Assessment’, op. cit., Chapter 23 (pp541-550).
279 See, ‘Report on the consultation of options for revision of the EU Thematic Strategy on Air Pollution and related policies’, op. cit., p62, comments from power and heating, cement and multi-sector business associations.
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• Measures to reduce use of urea-based fertilisers (perhaps in the context of the on-going review of the EU Fertilisers Regulation);
• Support for national implementation through the EU Rural Development Programs.
For international shipping, other mechanisms than low-sulphur fuel are potentially more cost-effective to reduce SO 2 emissions, and these alternatives (e.g. scrubbers) are enabled in the recent revision (2012/33/EU). Given the IMO legal framework governing emissions from international shipping, there is no obvious alternative for regulation than implementation of agreed IMO positions. However, international shipping emissions could potentially be brought under national emission ceilings, thus making more explicit the choice between regulating land-based or (through IMO) sea-based sources. 280
7. N ATIONAL AND L OCAL S OURCE C ONTROL M EASURES
7.1. Objectives, scope and approach
National and local source controls comprise a large set of measures applied with varying geographical scope ranging from legal instruments to voluntary programs, technical to economic instruments. In principle they cover all measures that Member States can take in areas not regulated at EU level. The range of actions that Member States can undertake is illustrated in the Appendices 4.3 through 4.5.
The terms national and local action are used interchangeably although in practice national measures have most often been related to the implementation of the NECD whilst local measures have been related to the implementation of the AAQD.
National measures triggered by the NECD have focused mostly on SO 2 , NO x , and VOCs (less so on NH 3 due to the relatively generous ceilings). Local action triggered by the AAQD focused on reaching compliance with the legally binding standards for PM and NO 2 in the AAQD.
7.2. Monitoring, Reporting and Evaluation
Several processes have led to enhanced insights on the relevance, effectiveness, efficiency, and coherence of national source controls. These include the monitoring and reporting processes required under the AAQD and NECD, the notifications of derogations/extensions under the AAQD, and the infringement processes.
There are also important lessons learned on the design, implementation, and evaluation of national and local actions from the Air Implementation Pilot, a dedicated urban air quality project conducted
jointly by the EEA, the Commission, and 12 EU cities. 281 . (See appendix 4.6).
It is noted that the Commission does not typically assess the effectiveness of individual measures but rather assesses overall policy packages in terms of the ability to reach the binding standards.
7.3. Relevance
Both the NECD and the AAQD set commonly agreed and effect-based air pollution and ambient air quality standards requiring action at source from the Member States. Whilst a significant portfolio of
280 See discussion in report, ‘Summary report for National Emission Ceilings Review’, op. cit., p12.
281 EEA Report No 7/2013, op. cit.
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EU source measures has been established over time (see above), national and local action continues to be required. Its relevance continues to be related to the principle of subsidiarity and costeffectiveness, i.e. national and local action ensures that EU measures remain proportionate and do not lead to higher costs than required taking into account the different situations in the Member States (and urban areas) across the EU.
7.4. Effectiveness
The review yielded a mixed picture with respect to the effectiveness of national and local measures implemented by the Member States. Whilst Member States have revamped their national and local actions to reduce air pollution in the wake of enforcement procedures, their effectiveness is generally insufficient to enable reaching the EU air quality standards (See section 4).
Among the most successful local actions to address PM and NO 2 are: favouring public transport use whilst upgrading public transport fleets (through retrofitting old diesel vehicles with particulate and/or NO x traps or alternative fuel purchase programmes, increasingly also electric vehicles); establishing access restrictions for the most polluting vehicles (e.g. low emission zones); road pricing and/or parking fee policies reducing traffic and improving traffic flows (thereby improving also the efficiency of catalytic equipment), speed limits on highways passing through high population density areas (also improving the traffic flow), greening taxi fleets, and facilitating cycling and walking. Impacts are increased where modal shifts can reduce short distance trips (representing up to 50% of vehicle use in urban areas), also because the 'light-off' time required for catalytic equipment to reach maximum efficiency is harder to achieve for shorter trips.
Actions have enabled the respective limit values to be met, or the number of zones in exceedance to be reduced, as well as reduction in population exposure. The low emission zone in Berlin, for example, gradually reduced the PM 10 exceedance area from 27% to 7% between 2008 and 2012 whilst reducing the number of citizens exposed to levels exceeding the EU air quality standard from 21% to 5%. Limiting the maximum speed along the A13 beltway in Rotterdam reduced PM 10 emissions in the
area by between 25 and 35% leading to air quality improvements of 4 µg/m 3 at 50m from the
roadside. The contribution of the highway to the city's overall PM 10 pollution was reduced by 34%. NO 2 related emission benefits ranged between 15 and 25% leading to air quality improvements of 5µg/m3 at 50 m from the roadside. The contribution of the highway to the city's overall NO
2 air pollution was reduced by 25%. Other benefits yielded by the measure included a 15% CO 2 emission reduction and a 50% reduction in noise levels. In some cases of advanced air quality management, actions focused on reducing PM and NO 2 emissions from diesel equipment on construction sites and other small and medium scale combustion installations.
National actions influencing air quality both positive and negative include fuel and vehicle taxation and/or subsidies, scrappage schemes, public transport infrastructure projects.
National and local actions have been most successful where they were designed and implemented in a well-researched and integrated manner, i.e. based on robust emission inventories containing relevant information for the area under consideration as well as robust air quality models able to integrate the relevant local and regional dimension as well as the meteorological and topographic information in an appropriate manner.
Effective actions has often been hampered by a lack of political will to establish and/or maintain effective actions which in turn could be linked to the often poor capacity to conduct in-depth ex-ante
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analysis or timely ex-post assessments to help gathering public support. The effectiveness of low emission zones and/or differentiated road pricing systems has been vitiated by the real world emission issue (the lack of reduction in light-duty diesel emissions across successive Euro classes); and by the increasing share of diesel vehicles also promoted through favourable national tax structures. In other cases, traffic related air quality management cases were challenged on the grounds of limiting free movement of goods.
7.5. Main orientations for the future
In addition to the source categories that contribute to the present exceedance situation, a number of issues preventing better compliance have been identified relating to Member State Competent Authorities' technical capacity for assessing and managing air quality as well as general and specific governance issues.
Limited capacity to assess and manage air quality problems and impacts
In general, and with a few notable exceptions, the capacity of competent authorities to assess and manage air quality remains weak and has not been brought to the level required for dealing with the increasingly complex air quality challenges.
Whilst the analysis suggests that there is are no major compliance problems with the minimum criteria set for air quality monitoring and the establishment of national emission inventories as required by the AAQD and NECD, the capacity of competent authorities to use the available information for identifying the major sources contributing to the national and/or local air quality problems and for assessment the cost-effectiveness of abatement strategies and policies is limited, and this has often prevented the development, implementation, and monitoring of cost-effective strategies.
The lack of adequate emission inventories at local level is a particular problem where national emission inventories may not be representative for the local situation. Missing, under- or overestimated emission categories may lead to ill-targeted air pollution policies or prevent the development of cost-effective measures all together. This has been a particular problem, for example, for taking timely action on certain important source categories such as domestic heating.
The lack of adequate air quality modelling (or expert modelling capacity) to assess national air quality and the effectiveness of national and local action is another problem that has been identified. Whilst various forms of air quality models are widely available, there analysis suggested that there is no systematic use made of them (compared for example to the practice in the US). Increased use of dispersion models could help assess the impacts of new sources in the area or the impact of large emission sources outside but upwind of the area. Atmospheric chemistry models can assist in predicting the impacts of air quality management measures taking into account meteorological and topographic conditions. Modelling is typically required also to ensure that trends in "background pollution" are duly taken into account. Many competent authorities have limited or no access to such important contextual information.
The EEA Pilot exercise also suggested that cost-effectiveness data and/or assessment tools are generally lacking at national and/or local level. Hence, local authorities are often forced to invest a considerable amount of time and resources to obtain such information or, where that is not possible, drive forward policies on a limited knowledge base.
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Where competent authorities are well equipped, cost-effectiveness analysis often ignores the transboundary impacts of measures taken (or rejected) at national level.
Governance deficiencies preventing better coherence of air quality and other policies
The technical capacity problems that have contributed to the present state of poor compliance have in many cases been compounded by certain governance deficiencies and poor public information.
As a general principle, Member States' national governments are accountable for the implementation of EU legislation. In the case of the AAQD, national authorities have often delegated substantial responsibilities to regional and local authorities in line with the determination of air quality zones and agglomerations linked to the assessment and management of the respective air pollutants covered by the Directive. Whilst this is compatible with the air quality legislation, this sub-delegation has often taken place without foreseeing adequate dialogue to reconcile air quality issues across zones and agglomerations and between the local and national governments.
In a number of cases, local or competent authorities have been faced with problems that could not be solved adequately without the assistance of the national government. Typical problems have related to managing transport emissions, notably where exceedances were driven by diesel vehicles but national governments maintained tax incentives that promoted these vehicles. Other cases include where local air quality management needs required management of pollution sources outside the boundaries of the local authorities. Governance deficiencies also extended to the Member States' interventions at EU level, where certain authorities of a Member State argued for stricter EU measures whilst others from the same Member State argued the contrary. Better alignment of positions has proven possible after the Commission made Member States aware of the contradicting positions yet in a number of cases, the lack of detailed information referred to above, prevented Member States from taken fully informed positions.
Similar governance issues emerged with respect to the implementation of the NECD. Contrary to the assessment and management of air quality standards, national emission inventories, projections, and plans and programmes related to the national emission ceilings have been (quite logically) managed at the national level. In doing so, however, little account has been taken of the needs at regional and local level, notably where a substantial part of the air quality exceedances are linked to background pollution. Recent initiatives to bring the NECD and AAQD experts closer together at the level of EU expert group meetings have started to enhance the prospect for more coherence between the management of these instruments.
Efforts from competent authorities and policy makers continue to be hampered by a relatively poor understanding of air pollution issues by the general public. Whilst there is generally good access to air quality data and reports, it remains a challenge for citizens and consumers to take informed decisions considering the state of air pollution in their region and/or the environmental performance of products in relation to air pollution.
8. I NTERNATIONAL ACTION TO REDUCE AIR POLLUTION
8.1. Objectives, scope and approach
Pollution sources external to the EU contribute substantially to EU air quality and impacts significantly on human health and the environment. For pollution formed in the atmosphere from
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precursor emissions (such as secondary particulate matter and ground-level ozone) the influence of long range transport becomes crucial. In particular for ozone, background concentrations in the EU are substantially influenced by ozone production and transport in the entire northern hemisphere. Hemispheric methane emissions (an important ozone precursor) are a particular driver of the EU ozone background.
Historically, the principal international instrument is the UN Economic Commission for Europe (UNECE) LRTAP Convention, which covers Europe but also includes North America (the USA and Canada).
The Convention has 51 Parties within the region and it has generated a knowledge base on air pollution, its impacts and effective management which continues to provide a solid basis for air policy in the EU and beyond.
The 1999 'Gothenburg' Protocol to the CLRTAP is the most important instrument from the perspective of EU air quality policy, and has recently been revised (2012). It covers all the main pollutants, and sets the agenda for upcoming air quality issues (for instance on Short- Lived Climate Pollutants such as black carbon).
8.2. Monitoring, Evaluation, and Enforcement Provisions
The LRTAP Convention provides for extensive provisions for monitoring of air quality, emissions and policy implementation.
The European Monitoring and Evaluation Programme (EMEP) has the long term objective to provide the Parties with an objective assessment of air pollution emissions, transmission in the atmosphere and the air pollution concentration and deposition over the entire European part of the UNECE region (except North America). The Parties report their emissions and air quality data to the EMEP centres that annually evaluates and provides reports on emissions, air quality and transboundary fluxes of all pollutants covered by the Convention protocols. 282 It conducts method development for inventories and air quality assessment and provides guidance to Parties including the EU on better methods. EMEP thus provides the backbone for the application of EU legislation through methodologies and standards for inventories, projections and air quality assessments, as well as methods intercomparisons and modelling.
EMEP also plays an increasingly important role in international cooperation beyond the Convention area, in particular in Asia. The EU has therefore jointly with the USA taken the co-lead for the Convention Task Force on Hemispheric Transport of Air Pollution to reinforce the monitoring and evaluation of hemispheric transport of air pollution, including also Short-Lived Climate Pollutants
Work under the Working Group on Effects collects information from the Parties on air pollution effects in order to establish the critical loads and levels for ecosystems, crops, materials and cultural heritage. The collected information under the International Cooperative Programmes is evaluated and annually reported to Parties including the EU 283 . Again the CLRTAP concepts of critical loads and levels are also central in EU legislation and a part of the NECD objectives and the 7 th EAP objectives.
The air pollution health effects are assessed by the joint CLRTAP/WHO Task Force on Health which
282 EMEP main webpage http://www.emep.int/
283 WGE web page http://www.unece.org/env/lrtap/workinggroups/wge/welcome.html
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systematically collects and reviews air pollution health impacts and provides scientific basis for CLRTAP and EU health impact assessments and cost-benefit analyses.
Work under the Working Group on Strategies and Reviews systematically collects information on how Parties have implemented their obligations and the CLRTAP holds now a data basis on the various policies and measures implemented by the Parties to meet their obligations. The 2010 review of policies and measures is currently ongoing and not yet finalised. In addition to the general reviews of policies specific task forces have been reviewing the specific protocols on Heavy Metals and POPs for their effectiveness and sufficiency. The POPs Protocol was revised in 2009 and the Heavy Metals Protocol in 2012.
8.3. Relevance
While the geographical coverage of CLRTAP is appropriate for addressing some European problems (acidification and eutrophication), others such as methane, ozone and particulate matter have a wider geographical perspective, involving emissions from India and China in particular.
Also other international initiatives are worth mentioning in the latter context. The first is the Climate and Clean Air Coalition, which was set up to co-ordinate action of its members on the main Short Lived Climate Pollutants (SLCPs, methane, ozone and black carbon). The second is the Global
Methane Initiative 284 which stimulates international action for methane emission reduction. Finally, the Global Atmospheric Pollution Forum 285 under the auspices of the International Union of Air Pollution and Prevention Associations is raising awareness and advocating action in regions where air pollution management is still weak, such as in South East Asia and Africa.
8.4. Effectiveness
The Gothenburg Protocol
The Gothenburg Protocol presently has 26 Parties, of which 23 are EU or EU Member States. Six EU Member States have not yet ratified. Two more countries have deposited their ratification instrument but their accession needs approval by the current Parties (in December 2013 at the earliest.)
The Protocol played an important role in the pre-accession period for the EU 12, as the obligations in the Protocol largely reflected EU legislation at that time. Whilst the Protocol may have lost some of its added value following EU enlargement (when many CLRTAP Parties joined the EU), it remains an important forum for sharing experience with other Convention Parties, including the Eastern European, Caucasus and Central Asian Countries such as the Russian Federation, Ukraine and Belarus, as well as the US and Canada.
The Protocol was successfully amended in 2012 to strengthen the existing reductions commitments for SO 2 , NO x , NH 3 and VOC and introduce new reduction commitments for PM 2.5 , to be attained from 2020 onwards. The amendment also updated the minimum performance standards for industrial emissions, which are now broadly in line with existing EU legislation. It is also the first Multilateral Environment Agreement to include binding obligations to monitor and abate SLCPs, such as black carbon.
284 http://www.globalmethane.org/gmi/
285 http://www.sei-international.org/gapforum/
140
Importantly, the 2012 amendment also allows a flexible approach for new Convention Parties to ratify the Protocol, which improves the prospect of ratification by Eastern European, Caucasus and Central Asian countries (including the Russian Federation). This was a main objective for the EU in the negotiations to amend the Protocol. A broadening of the ratification towards the east will not only yield additional environmental benefits for the EU but also (potentially) a significant market extension for green products. 286
The Climate and Clean Air Coalition
The Climate and Clean Air Coalition 287 (CCAC) was formed in 2012 to coordinate and extend action on reducing SLCPs such as black carbon, methane and hydrofluorocarbons (HFCs) largely based on
the conclusion of the UNEP integrated assessment on black carbon and tropospheric ozone 288 . The
CCAC thus aims at supporting fast action to simultaneously improve public health, food and energy security and climate. The focus of the work is to raise awareness of SLCP impacts and mitigation strategies, enhance and develop new national and regional actions, promote best practices and showcase successful efforts, and improve scientific understanding of SLCPs impacts and mitigation strategies. The Coalition has only recently been established, but a number of concrete projects have been initiated, such as action on improving domestic heating and cooking in developing countries, which are beneficial for both indoor and outdoor air quality and climate. The Coalition now comprises 70 countries and organisations, including the European Commission, and is increasing rapidly to become a major player in international action on SLCPs.
8.5. Efficiency
The CLRTAP and in particular the Gothenburg Protocol has been instrumental in the policy development of effective air pollution strategies across Europe. The effects-oriented policy of the Gothenburg Protocol, underpinned by scientific and technical knowledge has been endorsed by the EU and subsequently applied in EU legislation such as the NECD. In particular the scientific work under the European Monitoring and Evaluation Programme (EMEP), including its various science centres and task forces, the Working Group on Effects and the International Cooperative Programmes have provided important cornerstones for the EU in developing and applying a knowledge-based approach for air pollution policy.
The Convention has also provided an important platform to strengthen the wider international coordination on the scientific basis for air pollution and on the exchange of experience and information on best practices. Provided that more countries from Eastern Europe will ratify and implement the amended Protocol, it can potentially deliver significant direct benefits to EU air quality by reducing transboundary air pollution from the East.
9. C OHERENCE OF THE OVERALL FRAMEWORK
The aim of the policy framework is to implement an optimized set of measures to reduce air pollution impacts in the EU. In broad terms, that entails (i) controlling the international impacts of our and our neighbouring states' pollution; (ii) bringing down background and transboundary pollution within the EU, and (iii) stimulating complementary action to deal with the regional and local contribution.
286 I.e. products with lower environmental impact over the lifecycle compared with other similar products.
287 http://www.unep.org/ccac/
288 http://www.unep.org/publications/contents/pub_details_search.asp?ID=6201
141
9.1. International pollution
The international framework in which EU air policy is embedded has the twin aims of reducing EU pollution impacts on air quality in neighbouring countries, and reducing their impact on EU air quality. The need for such co-ordination is still clear and the scale of the required co-ordination depends on the transport scale for the relevant pollutants. For most pollutants, the effective scale is the EU and its neighbours to the east on the Eurasian landmass, which is covered by CLRTAP.
However for ground-level ozone and some aspects of particulate matter, such as black carbon, the relevant scale is the entire northern hemisphere. North America is included in CLRTAP (the USA and Canada) but effective control will involve extending international co-operation to include also
China and India. 289
In terms of the coherence between international action and EU action, there is a particular issue at the moment arising from the recent revision of the Gothenburg Protocol of the CLRTAP, which must be transposed into EU law.
9.2. Background and transboundary pollution within the EU
With regard to background and transboundary pollution within the EU, the main regulatory control mechanism is a ceiling on emissions of the relevant pollutants per Member State. The ceilings allow substantial discretion to Member States on how to achieve the relevant reductions. While this is legitimate on subsidiarity grounds, there are two caveats. The first is that the framework for meeting the required reductions (emission projections combined with national programmes) was not
effectively implemented in practice. 290 If this control mechanism is to be used again, those aspects
must be strengthened and and/or modified in order to ensure better effectiveness.
The second caveat is that effective implementation of emission ceilings has been facilitated by EU action on sources. 291 This is true not only of those source categories which can only be regulated at EU level (products), but also of action on other sources where efficient and cost-effective. An example is the support provided by the Large Combustion Plants Directive to the achievement of the sulphur dioxide emission ceilings.
The combination of EU source legislation with national emission ceilings is thus an effective framework to reduce background and transboundary pollution, so long as the individual pieces of legislation are effective.
9.3. Local pollution
The approach to regulating the local contribution to ambient air quality has been to set ambient air quality standards which apply everywhere in the EU, and to allow discretion to national, regional and local authorities to develop the complementary measures (building on background reductions) needed to meet them.
In principle this is a sensible approach, but problems arise where there is insufficient control of background and transboundary pollution. The obligation to meet the ambient standards remains but
289 See Executive Summary of Assessment Report of CLRTAP Task Force on Hemispheric Transport of Air Pollution, op cit., p5.
290 See evaluation of NECD above, section ‘Efficiency’.
291 See Table 14 above.
142
then local reductions need to carry more of the burden than anticipated. 292 There are also problems where the relevant pollution source is a product. For example, local diesel emissions are the main driver of local NO 2 concentrations; but regulation of emissions is an EU competence, and the taxation policies favouring diesel have often been national. Those tools that are available at the urban level are
then strained to the limit. 293
In addition to this, the compliance approach implemented at national level has often been deficient. As highlighted above for the emission ceilings, so for ambient air quality standards: action plans were often put in place late, without adequate supporting analysis or effective co-ordination.
One further question is whether local action is more effectively driven by ambient air quality standards or by an exposure reduction approach. Both have their merits: the ambient air quality standards ensure a minimum level of air quality for all, while the exposure reduction concept drives reduction even in those areas compliant with limit values, where substantial health problems remain. 294
9.4. Analytical framework for the Thematic Strategy on Air Pollution
The TSAP was designed to set cost-effective objectives for reduction in air pollution impacts on health and the environment, and to marshal the appropriate combination of measures at local, national and regional, and international level to deliver those objectives. The analytical approach has assured substantial coherence between the various legislative instruments, but improvements are possible as outlined in section 3.5.
10. C ONCLUSIONS AND ORIENTATIONS FOR THE REVIEW
10.1. Validity of objectives and scope, and overall coherence
The review has confirmed that the overall structure of air quality policy is logical and coherent. However, a better match must be ensured (in practical implementation) between source controls, ceilings and ambient air quality standards. This is required in particular to ensure that local achievement of ambient air quality standards is not compromised by (a) failure to limit pollution from
significant point sources or from products, 295 or (b) high background concentrations resulting from the
overall (Member State or transboundary) emission burden. The review examined for each individual policy instrument the extent to which its objectives and scope remain valid:
• For the Thematic Strategy, the underlying analytical framework remains valid for the current review, although some improvements are identified. The impacts identified in 2005 remain the priorities today (with the exception of acidification); an updated review should focus on the scope for further reducing these in the period up to 2030 (beyond which the uncertainties in the analysis become large). It should also focus on greater coherence across the range of policy instruments (including untapped synergies between the AAQD and the NECD).
292 See ‘PM workshop Brussels, 18-19 June 2012’, op cit, pp5-6, 9.
293 Ibid.
294 As indicated previously, no more robust conclusion is currently possible on the exposure reduction
approach given that the first compliance deadline is 2015. See, ‘Review of the Air Quality Directive and the 4 th Daughter Directive’, op cit, p64 section 4.4.3.
295 For instance the issue of real-world emissions from light-duty diesel vehicles – see section Error! Reference source not found. for details.
143
• For the Ambient Air Quality Directives, the health relevance of the pollutants and standards of the original policy has been reviewed by WHO, and confirmed, with the caveat that the level at which certain standards are currently set (mainly for PM) provides only incomplete protection for human health. As compared with 2005 there is additional evidence on the chronic impacts of ozone and NO 2 , which reinforces the rationale for the respective standards.
• The scope and objectives of the NEC Directive are out of line with the latest scientific findings and international agreements. The NECD must be adapted to focus better on health by introducing a ceiling for PM 2.5 , and on short-lived climate pollutants (black carbon and methane) in line with the 2012 amendment of the Gothenburg Protocol. Objectives must be extended to 2020 to fulfil the Gothenburg requirements, and strengthened for the period 2025-30 to deliver further reductions in background pollution to enable levels of air quality that are closer to those recommended by the WHO and CLRTAP . 296
• For the EU source controls the scope and objectives also remain broadly valid. Updated emissions data and projections confirm that the sectors driving the relevant pollutant emissions were correctly identified. In the short term, the main priority is the full implementation of the existing legislation and in particular the resolution of the real world emissions issue for light duty diesel vehicles. In the longer term the main gaps relate to combustion from small and medium installations, and ammonia emissions from agriculture.
• The scope, objectives, and coherence of international action under the CLRTAP remain relevant to co-ordinate action in the northern hemisphere on the key air quality drivers. The recently amended Gothenburg Protocol usefully extended the scope to include action on short-lived climate pollutants (notably black carbon), and flexibility has increased thereby also enabling a broader participation. Further action should focus on facilitating ratification by Eastern European, Caucasus and Central Asian Countries, action on short-lived climate pollutants (including also methane, black carbon and ozone) and extended exchange of scientific and technical co-operation with other regional groups notably in Asia and North America.
10.2. Main outstanding problems
Based on the above analysis, the following main outstanding problem relates to the fact that the health and environmental impacts of air pollution in the EU remain large. This conclusion is set out further in Chapter 3.3.1 of the main impact assessment. Two specific problems related to these substantive impacts were identified as follows.
• EU air quality standards are widely exceeded in densely-populated areas
• The EU is not on track to meet its long-term air quality objective
The summary conclusions from the above review related to these specific problems are set out in
Chapter 3.3.2 and 3.3.3 of the main impact assessment.
10.3. Main drivers of the outstanding problems
The review allowed further more to identify the main drivers for the aforementioned problems. They relate partly to the pollution sources themselves, and partly to the failure to manage air quality effectively and efficiently ("governance issues"). The main drivers are summarised in the main body of the impact assessment for each problem in turn as follows.
• Main drivers causing exceedance of EU air quality standards (See Chapter 3.4.1 of the main impact assessment report)
• Diesel emissions drive the NO 2 and NO x compliance problems (See Chapter 3.4.1.1 of the main impact assessment report)
296 Annex 4 section 5.
144
• Small scale combustion and concentrated local pollution drive the worst PM compliance problems (See Chapter 3.4.1.2 of the main impact assessment report
• Poor co-ordination between national and local action, and lack of capacity at regional and local level (See Chapter 3.4.1.3) of the main impact assessment report
• The main drivers preventing the EU to stay on track towards meeting its long-term air quality objective (See Chapter 3.4.2 of the main impact assessment report)
• The remaining health impacts from PM and ozone are driven by emissions from a range of sectors (See Chapter 3.4.2.1 of the main impact assessment report)
• Agricultural ammonia emissions drive the remaining health impacts (See Chapter 3.4.2.2 of the main impact assessment report)
• Sustained background pollution means local action alone cannot effectively reduce impacts (See Chapter 3.4.2.3 of the main impact assessment report)
• There remain gaps in the information base for assessing and managing air pollution (See Chapter 3.4.2.4 of the main impact assessment report)
10.4. Orientations for the review
The conclusions from the review on the outstanding problems and drivers have formed a robust basis for further assessments and defining the policy objectives for the updated EU air quality policy framework (see section 4). As indicated during the review process documented in this annex, the problems identified in the review can be addressed by modification (rather than replacement) of the existing policy framework. The required modifications should take place in a stepwise manner as follows.
Based on experience with the existing policy framework, setting ambitious ambient standards in the absence of measures to control transboundary pollution, and emissions at source, generates large-scale non-compliance. It is thus proposed to move to a staged approach whereby transboundary and source controls are brought forward first, and then once they are implemented, ambient air quality standards (mainly for PM) are reduced building on the resultant reductions in background concentrations delivered.
On that basis, a sensible order for the further policy revision would be first of all i) a revision of the TSAP to set the future EU policy framework to 2030; and ii) a simultaneous revision of the NECD to control transboundary pollution and limit background pollution concentrations. Once these are in place and broad-based compliance with the current standards has been achieved, a revision of the AAQD could be envisaged to bring standards closer to the WHO guideline values and address outstanding issues (such as the appropriate balance between limit values and exposure reduction obligations).
These orientations have been taken into account when designing the policy options for further action as described in the main impact assessment report from Chapter 4 onwards.
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A PPENDIX 4.1 S PECIFIC EVALUATION STUDIES LAUNCHED FOR INDIVIDUAL POLICY
INSTRUMENTS AND THE DETAILED QUESTIONS ADDRESSED
All reports are available at http://ec.europa.eu/environment/air/review_air_policy.htm unless otherwise specified.
1. T HE T HEMATIC S TRATEGY ON A IR P OLLUTION (TSAP)
Data sources:
-
-Quantitative review of experience with implementation of the 2005 TSAP (TSAP report 2 of Service Contract ENV.C.3/SER/2011/0009)
Questions addressed
-
-What underlying factors led to differences in emissions as compared with projections in 2005 TSAP?
-
-What were the substantive impacts on emissions?
-
-How did the implementation cost projections compare with actual experience?
-
-To what extent will the environmental objectives of the TSAP be achieved?
2. T HE A MBIENT A IR Q UALITY D IRECTIVES (AAQD)
Data sources:
-
-Review of the health evidence on the pollutants regulated by the Ambient Air Quality Directive (2 grant agreements with WHO).
-
-EEA report No 4/2012, 'Air Quality in Europe'.
-
-EEA report No 7/2013, Air Implementation Pilot, Final Report
-
-Specific contract on implementation of the Air Quality Directive and the 4th Daughter Directive (ENV.C.3/FRA/2009/0008 Service request 6, final report 10 December 2012)
-
-Workshop on PM (ENV.C.3/FRA/2009/0008 Service request 7, final report October 8 2012)
-
-Modelling compliance with NO2 and PM10 air quality limit values in the GAINS model (ENV.C.3/SER/2011/0009 Report #9)
Questions addressed:
-
-Are the pollutants addressed by the legislation the most relevant for health protection?
-
-Are the levels at which the standards are set appropriate for health protection?
-
-How effective is the management framework of the Directive?
-
-What are the health impacts of the pollutants?
-
-What is the status of air quality in Europe, the trends and the compliance picture?
-
-What are the underlying emission levels and their trends?
-
-What are the main reasons for non-compliance?
146
3. T HE N ATIONAL E MISSION C EILINGS D IRECTIVE (NECD)
Data sources:
-
-EEA report No 14/2012, 'Evaluation of progress under the EU National Emission Ceilings Directive' assessing
-
-Specific contract, 'Services to assess the reasons for non-compliance with the emissions ceilings set in the National Emission Ceilings Directive', (Specific Agreement 5 under Framework Contract ENV.C.3/FRA/2011/08)
Questions addressed:
-
-What are the evolution of emissions, state of compliance and the extent to which the NECD environmental objectives are achieved?
-
-What are the main reasons for non-compliance, (a) based on objective analysis and (b) as identified by the Member State?
-
-When is compliance likely to be achieved?
-
-Will the reasons for non-compliance of the NECD 2010 ceilings affect the ability of a Member State to meet its new 2020 emission reduction commitments under the Gothenburg Protocol?
-
-Recommendations for modification to the management framework of the Directive.
4. S ECTOR POLLUTION CONTROL POLICIES
Data sources:
-
-Future emissions of air pollutants in Europe – current legislation baseline and the scope for further reductions (ENV.C.3/SER/2011/0009 Report #1)
-
-Emissions from agriculture and their control potentials (ENV.C.3/SER/2011/0009 Report #3)
-
-The potential for further controls of emissions from mobile sources in Europe (ENV.C.3/SER/2011/0009 Report #4)
-
-Emissions from households and other small combustion sources and their reduction potential (ENV.C.3/SER/2011/0009 Report #5)
-
-Specific review of emissions from shipping (Special report under ENV.C.3/SER/2011/0009)
Questions addressed:
-
-What are the main emissions from the sector, their sources, and abatement options?
-
-What existing policies and regulations impact on future emissions from the sector?
-
-What are the costs, emission reductions and compliance implications of implementation of current legislation for each sector?
-
-What is the further reduction potential in the sector?
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A PPENDIX 4.2 EU VERSUS INTERNATIONAL AIR QUALITY STANDARDS
International air quality standards for PM10 (µg/m 3 unless otherwise stated)
Statistics EU CH US JP CN KR IN WHO
Ann. av. 40 20 - - 40 I 70 60 70 (IT-1)
100 II 50 (IT-2)
150 III 30 (IT-3) 20 (AQG)
Ann. mean of min. Ann. mean 50 Ann. mean Ann. mean Ann. mean; min. Annual arithmetic
90% of yearly Annual arithmetic 104 meas. p.a. at a mean
measurements mean, averaged over Zone I: residential particular site taken
3 years areas twice a week; 24
(Standard revoked in hourly at uniform Zone II: commercial 2006) interval. areas
Sec. st.1 & Prim. Zone III: industrial st.2 areas
24 hr av. 50 50 150 100 50 I 150 100 150 (IT-1)
Sec. st. 297 150 II 100 (IT-2)
25 III 75 (IT-3)
-
&Prim. st. 298
50 (AQG)
35 d. p.a. admitted 1 d. p.a. admitted 1 d. p.a. admitted, on daily mean daily mean daily mean 24 hrly values shall 3 d. p.a. (99th avg. over 3yrs be complied with percentile)
Zone I: residential 98% of time in a areas year. Zone II: commercial 2% of values may areas exceed limit but not
on 2 consecutive
Zone III: industrial days.
areas
297 Secondary standards provide public welfare protection, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings.
298 Primary standards provide public health protection, including protecting the health of "sensitive" populations such as asthmatics, children, and the elderly.
148
International Air Quality Standards for PM2,5 (µg/m 3 unless otherwise stated)
Statistics EU CH US JP CN KR IN WHO
Annual av. 25 - 12 Secondary st.1 15 40 I - 40 35 (IT-1)
15 Primary st.2 100 II 25 (IT-2)
150 III 15 (IT-3)
10 (AQG)
Annual arithmetic Three year average Annual arithmetic Annual arithmetic Annual arithmetic mean of minimum of the weighted mean; Zone I: mean of minimum mean 90% of annual mean 299 residential areas; II: 104 measurements measurements per commercial areas; p.a. at a particular year < 2015 III: industrial areas site taken twice a week 24 hourly at uniform interval.
24 hours av. - - 35 35 50 I - 60 75 (IT-1)
Secondary st.1 150 II 50 (IT-2)
-
&Primary st.2 250 III 37,5 (IT-3)
25 (AQG)
Three year average Annual 98th daily mean; Zone I: 24 hly values 3 days per year of the 98th percentile values at residential areas; II: monitored shall be admitted
percentile of daily designated commercial areas; complied with 98% (99th percentile)
means monitoring sites in III: industrial areas of the year; 2% may an area exceed the limit but not on two
consecutive days.
Other Exposure
20 3 calendar year running ann. mean of a set of urban background stations <2015
299 The EPA tightened the constraints on the spatial averaging criteria by further limiting the conditions under which some areas may average measurements from multiple communityoriented
monitors to determine compliance (see 71 FR 61165-61167). [where "Federal register" "Vol. 71" 61164 - follow] In this review, the Staff Paper concluded that it is appropriate to retain a concentration-based form that is defined in terms of a specific percentile of the distribution of 24-hour PM2.5 concentrations at each population oriented monitor within an area,
averaged over 3 years.
149
International Air Quality Standards for NO2 (µg/m 3 unless otherwise stated)
Statistics EU CH US JP CN KR IN WHO
Annual av. 40 30 100 - 40 I 57 40 40 (AQG)
Secondary st.1 40 II {0,03 ppm}
-
&Primary st.2 80 III
Annual arithmetic Annual arithmetic Annual arithmetic Annual arithmetic Annual arithmetic mean of minimum mean mean mean mean of minimum
90% of Zone I: residential 104 measurements measurements per areas per year at a
year Zone II: commercial particular site taken areas twice a week 24
hourly at uniform
Zone III: industrial interval.
areas
hourly av. 200 100 100 - 120 I 188 80 200 (AQG) [or ½ h] Primary st.2 120 II {0,1 ppm}
240 III
18 hours per year 95o Percentile of ½ hourly mean 1 hour means shall admitted hourly values be complied with
per year admitted Zone I: residential 98% of time in a areas year.
Zone II: commercial 2% of the values areas may exceed the limit
but not on two
Zone III: industrial consecutive days.
areas
24 hours av. 80 113 80 I 113
Daily mean Daily mean 80 II {0,06 ppm}
1 day per year {0,06 ppm} 120 III
admitted [within zone 0,04- daily mean
0,06 ppm or below]
150
International Air Quality Standards for Ozone (µg/m3 unless otherwise stated)
Statistics EU CH US JP CN KR IN WHO
1 hours av. - 120 - 120 120 I 200 180 -
{0,06 ppm} 160 II {0,1 ppm}
200 III
1 hours per year 238 For all 1 hour mean 1 hour monitored
admitted (Standard revoked photochemical values shall be
on 2005 in all US oxidants. That are Zone I: residential complied with 98% except 14 areas) oxidizing substances areas of time in a year.
such as ozone and 2% of the values
peroxiacetyl nitrate Zone II: commercial may exceed the limit produced by areas but not on two
photochemical Zone III: industrial consecutive days.
reactions. areas
8 hours daily max 120 - 160 - - 120 100 240 (Hi-L)
{Target Value} {0,075 ppm} {0,06 ppm} 160 (IT-1)
Secondary st.1 100 (AQG)
-
&Primary st.2
25 days per year Three year average 8 hour monitored admitted over 3 of the 4th highest values shall be years daily maximum 8 complied with 98% hourly means of time in a year.
(< 2007-2024) 2% of the values may exceed the limit but not on two consecutive days.
Other AOT40 ½ hourly av.
18K 100
May-Jul sum of 98o Percentile of ½ values of difference hourly values
between max 8h per month admitted
mean and 40 ppb
151
Sources
CH: OIAt of 16/12/1985 (at 15/07/2010) 814.318.142.1;
<http://www.admin.ch/ch/i/rs/c814_318_142_1.html>
JP: Environmental Quality Standards in Japan <http://www.env.go.jp/en/air/aq/aq.html>
CN: National Ambient Air Quality Standards
<http://cleanairinitiative.org/portal/knowledgebase/countries/country_overview/China/Air%20Quality %20and%20Co-Benefits?page=4>
<http://transportpolicy.net/index.php?title=China:_Air_Quality_Standards>
KR: National Ambient Air Quality Standards
<http://www.airkorea.or.kr/airkorea/eng/information/main.jsp?action=standard>
IN: National Ambient Air Quality Standards
<http://cpcb.nic.in/National_Ambient_Air_Quality_Standards.php>
NZ: Resource Management (National Environmental Standards for Air Quality) Regulations
<http://www.mfe.govt.nz/laws/standards/air-quality/index.html>
WHO: Air Quality. Guidelines for Europe (World Health Organization)
<http://www.euro.who.int/__data/assets/pdf_file/0005/74732/E71922.pdf>
US: National Ambient Air Quality Standards (NAAQS) <http://www.epa.gov/air/criteria.html>
152
A PPENDIX 4.3 E XAMPLES OF NATIONAL AND LOCAL AIR QUALITY MANAGEMENT MEASURES
A set of broad categories of measures can be distinguished based on information obtained through the Time Extension Notifications for PM 10 and NO 2 , exchange of information in the context of on-going infringement cases, and various targeted workshops and projects. These categories are shown in Table 44 below. Further details illustrating practical implementation experience is provided in Appendix 4.4 for the case of Dresden. The potential of fiscal measures to promote emission reduction measures is provided in Appendix 4.5. Further information on experience with national and local measures is referred to in Appendix 4.6 summarizing the experience with the Air Implementation Pilot.
Table 44: Example of National and Local Measures by Source (Sub)Category
Emission source / Subcategories Measures / Examples sectors Transport Road Transport / traffic • Road pricing (e.g. London, management Gothenburg)
• Speed-limits (e.g. Rotterdam) • Low Emission Zones (e.g. Berlin) • Parking fees (e.g. Torino) • Car sharing (e.g. Cambio) • Bus or Heavy Occupancy Vehicles
Road Transport / fleet • Green Public Procurement (Ultra management Low emission or alternative fuelled vehicles) • Retrofitting standards (e.g. for buses, municipal service vehicles, trucks,…) Road Transport / inter• Kiss & Ride road and rail modality infrastructure • Pedestrian zones and dedicated bike lanes, … Road Transport / Promoting • Green taxis Public Transport • Green buses (LPG, CNG cars and buses) • … Maritime Transport / • Electricity at berth (Hamburg) Promoting clean Marine Ports • Differentiated fees • Remote sensing of emissions (JRC) • Retrofitting vessels • Discharge services • Alternative fuel infrastructure (Low sulphur fuels, LNG,…) • Clean intermodality Maritime Transport / Fleet • Retrofitting (inland, SSS) management • LNG (SSS, inland) • Scrubbers …
153
Air Transport / Clean Air Ports • Public Transport Access • Differentiated fees
Rail Transport / fleet • Retrofitting (diesel) railcars
management • Electrification • …
Energy Large and medium sized • Permitting (upper range BAT/ combustions installations beyond);
• Promote energy efficiency • Promote RES, • District Heating and Cooling (Torino) • Fuel taxes (Denmark) • Carbon pricing (ETS)
Small combustion installations • Labels and/or standards for clean
wood / biomass stoves (IT, DK) • Fuel switching (Dublin)
• Permitting Industry Iron & Steel • Permitting according to best
Cement Available Technologies or
… beyond (national / local
competence!) • Joint clean air and climate
change pilot projects
Agriculture • Manure management conditions
(BE, NL, DE) • Agriculture burning restrictions • Animal rearing criteria
(CLRTAP) • Fertilizer Management • Food and feeding strategies Economic • Greening vehicle taxation incentives / general (differentiated registration tax,
road tax, fuel tax) • NOx Funds (Norway) • Off-set systems (US) • Tradable permits (NL,
California) Public Information • Promotion campaigns, on-site
training and inspection for energy efficiency and RES
• Awareness and actions at citizen level
Other • Measures funded by the EU
Cohesion Fund.
154
A PPENDIX 4.4: I LLUSTRATING LOCAL ACTION TO REDUCE AIR POLLUTANT --T HE D RESDEN
CASE
This appendix offers further illustration of local measures implemented in the case of Dresden (Germany). Dresden is a town of about 517 000 inhabitants, situated in the river basin of the river Elbe in Eastern Germany. There is a wide mix of industries, but heavy industry is not dominant. It is an important traffic junction. Part of the city is densely built. This results in higher average temperature in these areas, resulting in less heating in winter, but also in less natural ventilation. Dresden has succeeded in reaching the limit values of PM10 and NO2 over the past years. There was no application for a Time Extension Notification (TEN) for PM10, but a TEN for NO2 was granted in 2011. The figure below shows the trends for PM10 and NO2 air quality levels from 2001.
The below paragrahs describe the measures taken in Dresden with respect to emissions from
combustion installations, transport, and other sectors. 300
Combustion installations
Already in the period from 1989 till 2000 Dresden already took many local measures related to emissions from combustion installations that resulted in a decrease of PM emissions from large and small combustion installations by about 99% and 97% respectively. These measures included:
• decommissioning of coal fired district heating plants • fuel switch in district heating plants towards gas • fuel switch in domestic heating installations • modernising domestic heating installations
Whilst this reduction potential of PM emissions is no longer available for Dresden in future, they constitute good examples for other cities that have not yet taken such measures. It is noted that these reductions in Dresden were achieved without a significant increase in the use of renewable energy which could thus remain available options for going further (ground water heat pumps, solar).
Transport
300 Source: Luftreinhalteplan für die Landeshauptstadt Dresden 2011.
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The local emission inventories established by Dresden indicated a significant contribution from transport. For example trucks are responsible for about 74% of NOx and about 60% of PM10 emissions. On that basis, several measures have been implemented to address transport from the period starting from the 1999-2010 onwards. These measures include:
• urban planning measures –including the development of new residential areas close to existing road infrastructure; use of designated areas in the city to avoid residential expansion over a large area, and reconversion and upgrading of derelict areas and brownfields
• infrastructure development measures –such as changing the structure of the main roads from radial to tangential thereby avoiding that traffic first has to go to the city centre before leaving town again for the right direction; construction of bypasses for transit traffic; replacing top layers of roads; improving traffic signs taking into account local and regional traffic flows; improved intermodality (e.g.bus/metro, park and ride, bike and ride, construction of an intermodality logistics centre); expansion of public transport, especially metro and local train; construction of a railway link with the airport; electrification of railway tracks; purchase of cleaner buses; eliminate barriers (e.g. river and railway crossings); and promotion of non-motorised traffic (expansion and upgrading of pedestrian and cycling lanes, elimination of crossings and barriers, better traffic signs)
• traffic management –including improved use of existing infrastructure; preferential road access for public transport; intelligent traffic flow controls with real time information (e.g. green wave); speed limits (e.g. 30 km/h zones), traffic information with details on construction site related barriers , parking options for passenger cars as well as tourist buses, and intermodality options; promotion of car-sharing; traffic control and guidance for trucks; and speed limits on motorways close to town.
• mobility management including better or preferential access for cleaner vehicles; coordination with mobility plans for big employers (e.g. work-related traffic of staff); and combined tickets and e-tickets for public transport
Some results are remarkable: the city managed to increase the share of bicycle use in transport from
9.7% in 2003 to 12.3 % in 2009.
Other measures
Due to the specific nature of the city with its densely built city centre, special attention has been devoted to improve the heat balance and increase natural ventilation and the flow of fresh air from the surrounding area by constructing and expanding city parks and urban green. An analysis of the major fresh air flows from the area surrounding the city was done and based on the findings the following measures were taken:
• shifting the long term urban planning strategy towards a more compact city with concentration of energy efficient "city cells" in an ecological network; liberating environmental corridors; create a mix of functionalities (e.g. living, working, spending free time , sport, tourism); and ensuring ventilation and create/protect city zones with low concentrations of pollutants
• develop environmentally functional spaces and corridors such creating and linking woody areas; establishing green corridors that are wide enough and that integrate private and public green; making sure that corridors are nearby for all citizens; developing green "junctions" ; and making the corridors accessible for pedestrians and cyclists.
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• developing criteria for the compact city's "city cells" to make them fit in the green urban structure by promoting active climatic elements such as vegetation, water works, solar energy, heat pumps, green roofs; promoting natural ventilation; replacing asphalt roads by other surfaces that retain less heat, linking green areas with public spaces such as schools, hospitals
It is furthermore noted that a part of these measures (e.g. speed limits) were coordinated with local noise plans or measures for urban green (parks, green corridors) and urban planning in general.
Although the measures mentioned above were mostly local, some required at least some cooperation or coordination with other levels of government or companies to get the best results.
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A PPENDIX 4.5 M ARKET B ASED I NSTRUMENTS (MBI S ) FOR PROMOTING CLEAN HOUSEHOLD
HEATING APPLIANCES
This appendix contains the summary of a JRC-IPTS study conducted in support of this review to assess the potential for using market based instruments to contribute to reducing the emissions of particulate matter of less than 10 micrometres (PM10) from household heating appliances in the framework of the review of the Thematic Strategy on Air Pollution (TSAP).
The study focused on the assessment of the economic and environmental impacts of possible scrappage policies for promoting the accelerated replacement of existing heating appliances by cleaner ones. Under this policy programmes, households replacing an old appliance by a cleaner one would receive a subsidy from the government. This subsidy would compensate households for the residual value of the appliance scrapped and the opportunity costs of the early investment in a new one.
Two different scenarios have been analysed: 1) a "Scrappage All" scenario where all the different types of conventional appliances that do not incorporate any emission control technology ("noncontrolled" appliances) are replaced, and 2) "Scrappage SHB" scenario where only "non-controlled" firewood and hard coal fired manual single house boilers (SHB) are replaced. It has been assumed that the scrappage programme would be in force for 3 years (between 2018 and 2020). For each of these scenarios, the study further focused on the effects of different levels of replacement of the "noncontrolled" appliances and the size of subsidies relative to the investment costs.
Results for the EU-27 show that a scrappage programme designed to replace all types of "noncontrolled" appliances and with subsidies limited to 20% of the investment costs, could contribute to the reduction of the emissions of PM10 from household heating appliances in 2020 by 18% (-79 kt), with an average annual reduction of 7.4% (-22 kt/year) for the period 2018-2030. This early replacement would increase average annual investment costs of the period 2018-2030 by 11% (+1.5 billion €/year). Total subsidies to compensate households for the early replacement would amount to 9.4 billion € during the period 2018-2020. Health benefits of this policy scenario would total between 0.9 and 2.7 billion €/year. This scheme would increase the Gross Value Added (GVA) by 2.3 billion €/year.
The scrappage mechanism which only targets SHB and with subsidies limited to 20% of the costs could achieve 9% of the reduction resulting from the previous "Scrappage All" scenario, while cutting the abatement costs and subsidies to 3.7% and 4.9% respectively. This mechanism would reduce PM10 emissions in 2020 by -3% (13.3 kt) and the average emissions of the period 2018-2030 by - 0.7% (2.1 kt), the costs would increase by 0.5% (55.6 million €/year). Total subsidies during the period 2018-2020 would sum to 411 million €. Health benefits would range from 147 and 424 million €/year. Around 50% of the investment costs and subsidies, and 61% of the reduction in PM10 emissions would be generated by the accelerated replacement of SHB in Poland. This scrappage mechanism would increase the GVA by 106 million €/year; 42% of the total increase in the GVA would be in Poland, 11% in Germany, 8.5% in Slovenia and 7% in the United Kingdom.
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A PPENDIX 4.6 L ESSONS L EARNED FROM THE "A IR I MPLEMENTATION P ILOT "
The Air Implementation Pilot brought together 12 cities across the European Union and was jointly run by the cities themselves, the European Commission, and the European Environment Agency (EEA). It aimed at better understanding the challenges cities faced in implementing air quality policy, and also encouraged the cities to share their experiences, so they could learn from each other and see what has worked and what has not worked in other cities. The pilot also aimed to develop common proposals to help improve implementation of air policy. The pilot lasted for 15 months, starting in March 2012. It consisted of several workshops held with representatives of the European Commission's Directorate General of Environment; the EEA; the EEA's Topic Centre on Air Pollution and Climate Change Mitigation; and representatives of the cities participating in the pilot. Eight cities originally took part in the pilot: Berlin, Dublin, Madrid, Malmö, Milan, Ploiesti, Prague, and Vienna. Four more cities subsequently joined at the end of 2012: Antwerp, Paris, Plovdiv, and Vilnius. The cities were selected so as to ensure a representative sample of the diversity of Europe's urban areas. The selection aimed at including cities from different parts of Europe, of different population sizes, with different administrative traditions, and with a variety of sources of pollutants. The pilot focused on five 'work streams', where lessons for implementation could most usefully be drawn. The lessons learned and recommendations for further action are provided below.
Local emission inventories
Although 11 of the 12 cities have emission inventories 301 , the pilot uncovered a great variety of methodologies used to compile these inventories. This variety means that the cities' emission inventories are often not comparable with one another, or with the emission inventories of the regions within which they are located. Cities have problems taking into account all sources of pollution, due to the difficulty in finding available data, or because of the difficulty in appropriately quantifying different sources.
The pilot project concluded that better input data and more guidance are needed on inventory methodology.
Modelling and the use of air quality models
For air quality modelling 302 , there was also a great diversity of models used by the cities. Because air
quality models make use of emission inventories, often the shortcomings of these inventories carry over to the modelling activities. Additional issues encountered by the cities related to the other input data used in models, such as meteorological information, and background concentrations of pollutants. Another difficulty when applying models at urban level was how to accurately reflect the specificities of urban topography, such as pollution hot spots on kerbsides. Finally, many city representatives said that the results of their models were often highly complex, and therefore difficult to interpret, consuming a lot of resources and computational time. This complexity also makes the subsequent validation of the results more difficult.
301 Emission inventories are sets of data that show what pollutants are emitted into the air, where, and from which sources.
302 Models are the computer‑based tools that help to understand air pollution processes.
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The pilot project concluded that greater training in modelling was needed, along with improved input data (including meteorological data, background concentrations, and the specificities of each city's topography).
Monitoring networks
On monitoring networks 303 , the pilot project found that most of the cities had the necessary number of
monitoring stations required by the relevant directives. However, the criterion for the macro‑scale siting of ozone stations (their distribution between urban and suburban locations) has not always been met in the cities participating in the Air Implementation Pilot.
The cities' experts therefore recommended addressing this issue of the location of monitoring stations. Some experts also suggested that the air quality directives provide more detailed requirements for measuring stations. These requirements would stipulate the macro-siting (where the stations are located with respect to major pollution sources) and micro-siting (where the stations are sited with respect to their immediate surroundings, such as their height, proximity to the kerb, etc.), as well as the representativeness of the stations (the spatial area over which the value measured at the station can be accepted as meaningful).
Air quality management practices
The pilot project examined trends in concentrations of three air pollutants: nitrogen dioxide, particulate matter and ozone and the effect of measures taken to improve air quality for those pollutants. No clear trend in concentrations of these pollutants could be seen in the monitoring stations considered. Nevertheless, some commonalities did emerge in the management measures taken by the cities. In most of the cities, and in agreement with the main pollutant sources identified, more than the 50 % of the implemented measures are traffic related. Other measures focused on the domestic, commercial and industrial sectors. Another common theme emerged among all the cities: how to define and assess the effects of measures. The cities' experts also expressed a common uncertainty regarding how best to assess the costs and benefits of measures to abate pollution. Again, some of the deficiencies identified in previous work streams have implications that carry over: improvement of inventories and modelling tools, for instance, would better enable cities to assess which of their measures were most effective in improving air quality. Further support was also requested in the form of proposals for new EU legislation. Examples included: standard methodologies to measure emissions from boilers, regulations for domestic stoves, and improved vehicle emissions data to help ascertain the effect of traffic measures on air quality.
Public information.
This work stream focused on how the cities kept their citizens informed about air quality. The pilot project showed that, by and large, air quality information that is required by legislation to be made public is promptly provided by the cities to the public, mostly through dedicated air quality internet sites. In general, the cities underuse mass media, social media websites, and new technologies like smartphone applications. Most of the participating cities lacked feedback on the interest of their citizens in air quality issues. There is thus room for cities to increase the presence of air quality issues
303 These are the networks of sampling stations located across cities that take regular measurements of air quality.
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in the media and for them to develop their smartphone and social media presences. The adoption of a common Europe-wide index for air quality, using the same colour codes to facilitate comprehension, would also help make air quality information comparable across Europe.
Next steps
The Air Implementation Pilot identified a number of challenges which cities face in implementing EU air quality policy that would have to be taken up in the present air quality policy review. This would include further consideration how EU action can best support local, regional and national authorities in addressing them. Options could include:
• financing of improved management and capacity-building through the forthcoming revision of the LIFE regulation (3);
• the development of a broader network of cooperation on the urban air quality challenge across the EU, with regular information exchange, capacity building, and a common database of measures;
• promoting and enabling increased use of other EU funding opportunities, such as the structural funds, particularly to address local drivers of persistent non-compliance with EU air-related legislation.
One possibility that has been discussed is to package all the European measures related to urban air quality in a single programme, which would then be one of the accompanying documents to a revised Thematic Strategy on Air Pollution. For its part, the EEA will continue to support its member countries and the European Commission in their aim to improve the implementation of environmental policy.
ANNEX 5 F UTURE AIR QUALITY PROJECTIONS A SSUMING N O C HANGE IN C URRENT
P OLICIES
1. M ETHODOLOGY FOR PROJECTING FUTURE EMISSIONS AND AIR QUALITY IMPACTS
Projections for future emission scenarios under alternative hypotheses have been prepared using the
GAINS suite of models. This toolbox 304 brings together an ensemble of interlinked models with the
objectives to simulate future emission scenarios and cost-effective emission reduction strategies; this is done following an upstream causal chain that includes standard Commission projections on economic development, energy, transport, agriculture and climate change mitigation policies to estimate emission levels for pollutants, which are subsequently used to determine concentration/ deposition patterns across Europe and finally impacts on human health, ecosystems, agricultural crops and the built environment.
304 See description on the webpage of the EC4MACS Life+ project, which developed the latest update of the GAINS Integrated Assessment Modelling (IAM) toolbox
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2. M AIN ASSUMPTIONS AND RELATED UNCERTAINTIES
Baseline emissions are determined under standard Current Legislation assumptions described in chapter 2 below. Other important assumptions relate to economic growth, national energy balances, and agriculture.
The baseline emission scenario has been developed based on and consistent with the draft 2012-3 EU Reference energy projection coordinated by Commission services ENER, CLIMA and MOVE. For the energy and CO2 reference scenario, the PRIMES energy system model operated by the National Technical University of Athens is used. Energy-related activity data and the evolution of fuel prices are taken from this scenario. It uses macroeconomic assumptions which are based on DG ECFIN/ Economic Policy Committee short and medium term growth projections and on the DG ECFIN/ EPC Ageing Report 2012 for long term GDP growth and population trends. Projections for agricultural activities are those developed with the CAPRI model in the context of the same EU Reference projection.
Despite a doubling in economic activity by 2050, the baseline scenario suggests a stabilisation of energy consumption, as energy efficiency policies will successfully reduce energy demand in households and industry. On a sectorial basis, the rapid penetration of energy efficiency measures maintains constant or slightly decreasing energy consumption despite the assumed sharp increases in production levels and economic wealth.
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Figure A5.1: economic growth (left-hand side) and energy use by sector (right-hand side) in the E previosu PRIMES 2010 reference energy projections.
18 90 PRIMES 2012 Old MS Power PRIMES 2012 New MS Industry
16 80
PRIMES 2010 Old MS Domestic
Transport
14 PRIMES 2010 New MS 70 Feedstocks
12 60 yr yr o/ J/
ur 10 50
E
ion 1000 P
ill 8 40 Tr
6 30
4 20
2 10
0 0
2005 2010 2015 2020 2025 2030 2005 2010 2015 2020 2025 2030
The adopted policies for renewable energy sources are expected to increase biomass use by more than a factor of two thirds in 2030 compared to 2005, and to triple energy from other renewable sources (e.g., wind, solar). In contrast, coal consumption is expected to decline by 40% by 2030, and oil and natural gas consumption is calculated to be 20% lower than in 2005, as shown in the following table.
Table A5.1: energy consumption by source up to 2030, EU 28.
PJ 2005 2010 2015 2020 2025 2030
Coal 13,3 11,8 11,1 9,9 9,0 7,3
Oil 28,6 26,0 24,7 23,1 22,2 21,8
Gas 18,8 18,6 18,2 17,0 17,0 16,6
Nuclear 10,8 9,9 9,6 8,1 7,6 8,4
Biomass 3,6 5,2 5,7 6,3 6,4 6,4
Other Renewables 1,6 2,5 3,8 5,3 6,2 7,0
Total 76,7 74,0 73,1 69,7 68,4 67,5
3. EU POLICIES INCLUDED IN THE CURRENT LEGISLATION (CLE) BASELINE
In addition to the energy, climate and agricultural policies that are assumed in the different energy and agricultural projections, the baseline projections consider a detailed inventory of national emission
control legislation (including the transposition of EU-wide legislation). 305 They assume that these
305 For CO2, regulations are included in the PRIMES calculations as they affect the structure and volumes of
energy consumption. For non-CO2 greenhouse gases and air pollutants, EU and Member States have
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regulations will be fully complied with in all Member States according to the foreseen time schedule. For air pollutants, the baseline assumes the regulations described in the tables below. 306 The baseline assumes full implementation of this legislation according to the foreseen schedule.
Table A5.2: Legislation considered for SO2 emissions
• Directive on Industrial Emissions for large combustion plants (derogations and opt-outs are considered according to the information provided by national experts)
• BAT requirements for industrial processes according to the provisions of the Industrial Emissions directive.
• Directive on the sulphur content in liquid fuels
• Fuel Quality directive 2009/30/EC i on the quality of petrol and diesel fuels, as well as the
implications of the mandatory requirements for renewable fuels/energy in the transport sector
• MARPOL Annex VI revisions from MEPC57 regarding sulphur content of marine fuels
• National legislation and national practices (if stricter)
Derogations under the IPPC, LCP and IED directives granted by national authorities to individual plants are considered to the extent that these have been communicated by national experts to IIASA.
Table A5.3: Legislation considered for NOx emissions
• Directive on Industrial Emissions for large combustion plants (derogations and opt-outs included according to information provided by national experts)
• BAT requirements for industrial processes according to the provisions of the Industrial Emissions directive
• For light duty vehicles: All Euro standards, including adopted Euro-5 and Euro-6, becoming mandatory for all new registrations from 2011 and 2015 onwards, respectively (692/2008/EC), (see also comments below about the assumed implementation schedule of Euro-6).
• For heavy duty vehicles: All Euro standards, including adopted Euro-V and Euro-VI, becoming mandatory for all new registrations from 2009 and 2014 respectively (595/2009/EC).
• For motorcycles and mopeds: All Euro standards for motorcycles and mopeds up to Euro-3, mandatory for all new registrations from 2007 (DIR 2003/77/EC, DIR 2005/30/EC, DIR 2006/27/EC). Proposals for Euro-4/5/6 not yet legislated.
issued a wide body of legislation that limits emissions from specific sources, or have indirect impacts on emissions through affecting activity rates.
306 The analysis does not consider the impacts of other legislation for which the actual impacts on future
activity levels cannot yet be quantified. This includes compliance with the air quality limit values for PM, NO 2 and ozone established by the Air Quality directive, which could require, inter alia, traffic restrictions in urban areas and thereby modifications of the traffic volumes assumed in the baseline projection. For methodological reasons it is also difficult to reflect the impact of some other relevant directives such as the Nitrates Directive.
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• For non-road mobile machinery: All EU emission controls up to Stages IIIA, IIIB and IV, with introduction dates by 2006, 2011, and 2014 (DIR 2004/26/EC). Stage IIIB or higher standards do not apply to inland vessels IIIB, and railcars and locomotives are not subject to Stage IV controls.
• MARPOL Annex VI revisions from MEPC57 regarding emission NOx limit values for ships
• National legislation and national practices (if stricter)
For NO x emissions from transport, all scenarios presented here assume from 2017 onwards real-life
NO x emissions to be 1.5 times higher than the NTE Euro-6 test cycle limit value. This results in about
120 mg NO x /km for real-world driving conditions, compared to the limit value of 80 mg/km. As portable emissions measurement systems (PEMS) will only be introduced gradually, between 2014 and 2017 emission factors of new cars are assumed at 310 mg NO x /km. Also, inland vessels are excluded from Stage IIIB or higher emission controls, and railcars and locomotives not subject to Stage IV controls.
Table A5.4: Legislation considered for PM10/PM2.5 emissions
• Directive on Industrial Emissions for large combustion plants (derogations and opt-outs included according to information provided by national experts)
• BAT requirements for industrial processes according to the provisions of the Industrial Emissions directive
• For light and heavy duty vehicles: Euro standards as for NOx
• For non-road mobile machinery: All EU emission controls up to Stages IIIA, IIIB and IV as for
NOx.
• National legislation and national practices (if stricter)
Table A5.5: Legislation considered for NH3 emissions
• IPPC directive for pigs and poultry production as interpreted in national legislation
• National legislation including elements of EU law, i.e., Nitrates and Water Framework Directives
• Current practice including the Code of Good Agricultural Practice
• For heavy duty vehicles: Euro VI emission limits, becoming mandatory for all new registrations from 2014 (DIR 595/2009/EC).
Table A5.6: Legislation considered for VOC emissions
• Stage I directive (liquid fuel storage and distribution)
• Directive 96/69/EC i (carbon canisters)
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• For mopeds, motorcycles, light and heavy duty vehicles: Euro standards as for NOx, including adopted Euro-5 and Euro-6 for light duty vehicles
• EU emission standards for motorcycles and mopeds up to Euro-3
• On evaporative emissions: Euro standards up to Euro-4 (not changed for Euro-5/6) (DIR 692/2008/EC)
• Fuels directive (RVP of fuels) (EN 228 and EN 590)
• Solvents directive
• Products directive (paints)
• National legislation, e.g., Stage II (gasoline stations)
4. F UTURE AIR POLLUTANT EMISSIONS UNDER THE CURRENT POLICY SCENARIO
On the same time horizon, as a consequence of the structural changes in the energy and transport sectors and the progressing implementation of emission control legislation, SO2 emissions will fall drastically. The largest reductions are foreseen for the power sector, which is projected to cut its emissions by almost 90% in 2050 compared to 2005. NOx emissions may drop by more than 65% in the coming years provided that the EURO 6 emission standards are effectively implemented. Legislation directed at other pollutants reduces PM2,5 emissions by about 40%. In contrast to the other air pollutants, only minor changes are expected for NH3 emissions. VOC emissions will decline by 40% in the EU27, and converge on a per-capita basis across Member States.
More detail is provided below on a pollutant-by-pollutant basis
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4.1. Sulphur dioxide
Progressing implementation of air quality legislation together with the structural changes in the energy system will lead to a sharp decline of SO 2 emissions in the EU; in 2025 total SO 2 emissions would be almost 70% below the 2005 level. Most of these reductions come from the power sector. Full implementation of the available technical emission control measures could bring down SO 2 emissions by up to 80% in 2025 vs 2005.
SO2 emissions 2005 2010 2015 2020 2025 2030
EU28, kilotons CLE MTFR CLE MTFR
Power generation 5445 2739 1375 937 824 608 637 436
Domestic sector 623 624 520 467 399 250 336 213
Industrial combust. 1100 695 640 616 605 362 613 355
Industrial processes 743 626 578 577 570 344 575 345
Fuel extraction 0 0 0 0 0 0 0 0
Solvent use 0 0 0 0 0 0 0 0
Road transport 36 7 6 5 5 5 5 5
Non-road mobile 215 137 109 71 37 29 37 29
Waste treatment 2 2 2 2 2 1 2 1
Agriculture 7 8 8 9 9 0 9 0
Sum 8172 4837 3238 2685 2451 1598 2214 1383
4.2. Nitrogen oxides
Also for NO x emissions, implementation of current legislation will lead to significant declines, and for 2025 a 60% reduction is estimated. These changes emerge from measures in the power sector, and more importantly, from the implementation of the Euro-6 standards for road vehicles. Full implementation of additional measures for stationary sources could bring NO x emissions in 2025 68% down compared to 2005. The sensitivity of these projections towards uncertainties about future reallife emissions from Euro-6 standards as well as the potential for further emission cuts from ‘Super Ultra-Low Emission Vehicles’ (SULEV) is explored in Chapter 5 of the main IA.
NOx emissons 2005 2010 2015 2020 2025 2030
EU28, kilotons CLE MTFR CLE MTFR
Power generation 2879 1908 1513 1172 1055 636 906 517
Domestic sector 632 619 580 532 506 417 471 389
Industrial combust. 1253 913 898 884 901 492 929 503
Industrial processes 213 184 172 174 171 137 172 137
Fuel extraction 0 0 0 0 0 0 0 0
Solvent use 0 0 0 0 0 0 0 0
Road transport 4905 3751 2994 1890 1210 1210 887 887
Non-road mobile 1630 1400 1156 914 748 632 661 513
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Agriculture 16 17 19 21 21 1 21 1
Sum 11538 8799 7338 5591 4617 3526 4051 2947
4.3. Fine particulate matter
Progressing introduction of diesel particle filters will reduce PM2.5 emissions from mobile sources by about two thirds up to 2025; the remaining emissions from this sector will mainly originate from nonexhaust sources. While this trend is relatively certain, total PM2.5 emissions in Europe will critically depend on the development for small stationary sources, i.e., solid fuel use for heating in the domestic sector. The anticipated decline in solid fuel use for heating together with the introduction of newer stoves would reduce emissions from this sector by ~17% in 2025. However, more stringent product standards could cut emissions by up to two thirds.
Overall, total PM2.5 emissions in the EU-28 are expected to decline by 25% in the CLE case, while additional technical measures could cut them by up to 60% compared to 2005.
PM2,5 emissions 2005 2010 2015 2020 2025 2030
EU28, kilotons CLE MTFR CLE MTFR
Power generation 132 92 70 63 60 25 53 21
Domestic sector 573 695 653 597 523 230 465 156
Industrial combust. 85 72 73 75 73 38 76 37
Industrial processes 213 190 196 199 199 138 201 139
Fuel extraction 9 8 8 7 7 7 6 6
Solvent use 0 0 0 0 0 0 0 0
Road transport 270 217 149 115 104 104 102 102
Non-road mobile 123 99 74 53 41 33 35 27
Waste treatment 88 88 89 89 90 64 90 64
Agriculture 155 155 164 171 172 53 172 54
Sum 1647 1616 1477 1370 1269 692 1201 607
4.4. Ammonia
Although NH 3 emissions are subject to targeted controls in the agricultural sector and will be affected as a side impact of emission legislation for road transport (i.e. by improved catalytic converters), only slight changes in total emissions in the EU-28 are expected up to 2030.
Due to the absence of effective wide-spread legislation on the control of NH 3 emissions from the agricultural sector, the baseline shows only little change in NH 3 emissions over time. For 2025, a 5% decline in the EU-28 is estimated. However, EU-wide application of emission control measures that
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Ammonia emissions 2005 2010 2015 2020 2025 2030
EU28, kilotons CLE MTFR CLE MTFR
Power generation 14 22 22 25 24 22 23 20
Domestic sector 19 22 23 22 20 20 19 18
Industrial combust. 4 5 5 5 5 8 6 8
Industrial processes 78 73 74 75 75 28 75 28
Fuel extraction 0 0 0 0 0 0 0 0
Solvent use 0 0 0 0 0 0 0 0
Road transport 128 88 67 54 48 48 46 46
Non-road mobile 2 2 2 2 2 1 2 1
Waste treatment 166 174 174 174 173 173 173 173
Agriculture 3518 3292 3336 3338 3311 2267 3319 2274
Sum 3928 3678 3702 3693 3658 2566 3663 2568
4.5. Volatile organic compounds
The future trend in VOC emissions is strongly determined by measures for mobile sources and by dedicated controls of solvents emissions.
Further implementation of the Euro-standards will eliminate almost all VOC emissions from road vehicles. Legislation on solvents is expected to cut VOC emissions from this sector by about 20% in 2025 relative to 2005. However, there remains significant potential for further reductions for VOC emissions from solvents. Together with additional measures in households, these could cut total VOC emissions in the EU-28 by two thirds, compared to the 37% reduction in the baseline case.
VOC emissions 2005 2010 2015 2020 2025 2030
EU28, kilotons CLE MTFR CLE MTFR
Power generation 176 196 185 181 172 132 162 117
Domestic sector 987 1080 1026 911 813 195 736 156
Industrial combust. 53 56 60 69 77 77 85 85
Industrial processes 943 875 878 884 815 659 819 663
Fuel extraction 538 385 364 332 305 254 289 242
Solvent use 3600 3037 2882 2795 2584 1364 2603 1375
Road transport 2047 1100 593 392 293 293 257 257
Non-road mobile 657 538 414 355 314 259 281 223
Waste treatment 133 120 95 89 86 74 84 74
Agriculture 125 126 137 146 146 0 146 0
Sum 9259 7512 6635 6152 5604 3308 5460 3191
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| 23 dec '13 |
Voorstel voor een richtlijn van het Europees Parlement en de Raad ter vermindering van de nationale emissies van bepaalde luchtverontreinigende stoffen en tot wijziging van Richtlijn 2003/35/EG PROPOSAL |
Secretary-General of the European Commission 18167/13 |