Europaudvalget 2022
KOM (2022) 0542
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EUROPEAN
COMMISSION
Brussels, 26.10.2022
SWD(2022) 545 final
PART 2/4
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT REPORT
Accompanying the document
Proposal for a Directive of the European Parliament and of the Council
on ambient air quality and cleaner air for Europe (recast)
{COM(2022) 542 final} - {SEC(2022) 542 final} - {SWD(2022) 345 final} -
{SWD(2022) 542 final}
EN
EN
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1
1
T
ABLE OF
C
ONTENTS
TABLE OF CONTENTS .....................................................................................................................73
ANNEX 1: PROCEDURAL INFORMATION .............................................................................................75
1.
2.
3.
LEAD DG, DECIDE PLANNING/CWP REFERENCES ...................................................................75
CONSULTATION OF THE REGULATORY SCRUTINY BOARD (RSB) .....................................79
EVIDENCE, SOURCES AND QUALITY .........................................................................................80
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) .................................................84
1.
AIM OF THE CONSULTATION .......................................................................................................84
1.1
1.2
2
Consultation strategy ................................................................................................................84
Consultation activities ..............................................................................................................85
SUMMARY OF CONSULTATION ACTIVITIES ............................................................................85
2.1
2.2
2.3
Open public consultation ..........................................................................................................85
Targeted stakeholder consultation ............................................................................................87
Stakeholder meetings ...............................................................................................................91
Feedback by stakeholder groups – Policy Area 1.....................................................................94
Feedback by stakeholder groups – Policy Area 2.....................................................................97
Feedback by stakeholder groups – Policy Area 3.....................................................................99
3
RESULTS OF THE STAKEHOLDER FEEDBACK ..........................................................................94
3.1
3.2
3.3
4
OTHER CONSULTATION ACTIVITIES ........................................................................................100
4.1
4.2
4.3
4.4
Ad-hoc contributions ..............................................................................................................100
Third EU Clean Air Forum ....................................................................................................101
Inception Impact Assessment .................................................................................................101
Fit for Future Platform opinion on the ambient air quality legislation ...................................102
5
USE OF STAKEHOLDER FEEDBACK ..........................................................................................103
ANNEX 3: WHO IS AFFECTED AND HOW? .........................................................................................104
1.
2.
3.
PRACTICAL IMPLICATIONS OF THE INITIATIVE ...................................................................104
SUMMARY OF COSTS AND BENEFITS ......................................................................................107
RELEVANT SUSTAINABLE DEVELOPMENT GOALS ..............................................................116
ANNEX 4: ANALYTICAL METHODS ....................................................................................................117
1.
2.
OVERVIEW ......................................................................................................................................117
QUANTITATIVE MODELLING OF AIR POLLUTANT STANDARDS ......................................118
2.1
2.2
2.3
2.4
2.5
3.
Introduction of the modelling framework ..............................................................................118
Application of GAINS ...........................................................................................................120
Concentration modelling methodology ..................................................................................121
Assessment of health impacts.................................................................................................122
Monetisation of health and non-health impacts ......................................................................124
SHORTCOMINGS OF THE MODELLING APPROACH AND SOURCES OF
UNCERTAINTY ...............................................................................................................................126
73
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ANNEX 5: BASELINE, MAXIMUM TECHNICALLY FEASIBLE REDUCTION AND POLICY
SCENARIOS – MODELLING RESULTS........................................................................................127
1.
2.
3.
DESCRIPTION OF THE BASELINE SCENARIO ..........................................................................127
AIR POLLUTANT EMISSIONS: BASELINE DEVELOPMENT AND SCOPE FOR MTFR
REDUCTIONS ..................................................................................................................................128
AIR POLLUTANT CONCENTRATION PROJECTIONS ..............................................................135
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A
NNEX
1: P
ROCEDURAL INFORMATION
1. L
EAD
DG, D
ECIDE
P
LANNING
/CWP
REFERENCES
The revision of the Ambient Air Quality Directives is led by the Directorate General for
Environment. It was included as items PLAN/2020/8962 and PLAN/2020/8636 in the
Agenda Planning.
This impact assessment started in December 2020.
An Interservice Group to steer the evaluation was set up in June 2020 with representatives
from the Secretariat-General (SG); Legal Service (SJ); Directorates-General for Budget
(BUDG); Economic and Financial Affairs (ECFIN); Internal Market, Industry,
Entrepreneurship and SMEs (GROW); Defence Industry and Space (DEFIS); Competition
(COMP); Employment, Social Affairs and Inclusion (EMPL); Agriculture and Rural
Development (AGRI); Mobility and Transports (MOVE); Energy (ENER); Environment
(ENV); Climate Action (CLIMA); Research and Innovation (RTD); Joint Research Centre
(JRC); Maritime Affairs and Fisheries (MARE); Regional and Urban Policy (REGIO);
Structural Reform Support (REFORM); Taxation and Customs Union (TAXUD); Health and
Food Safety (SANTE) and Neighbourthood and Enlargement Negotiations (NEAR).
The Interservice Group met eight times during the impact assessment process.
Timeline
5 Mar 2020
(Other)
Conclusions of the Council of the European Union
on
Improvement of air quality
1
1
st
ISG meeting:
discussion of overall process, draft roadmap and
draft terms of reference for the support study
Launch of the service request for “Strengthening of air quality
monitoring modelling and plans under the Ambient Air Quality
Directives”
to the contractors under the Framework Contract
ENV.C.3/FRA/2017/0012 (Ares(2020)4231895) (closing date to
submit offers: 14 Sep 2020)
Ambient Air Quality Expert Group
meeting with a session
dedicated on the follow-up to the Fitness check of the Ambient Air
Quality Directives
26 Jun 2020
(COM)
12 Aug 2020
(Other)
7 Oct 2020
(MS)
1
Council (2020),
Council conclusions 6650/20
(accessed: 10.06.2022)
75
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27 Oct 2020
(Other)
Signature of contract for “Strengthening of air quality
monitoring modelling and plans under the Ambient Air Quality
Directives”
with the consortium led by Ricardo
2
nd
ISG meeting:
discussion of draft inception impact assessment
and draft consultation strategy; planned work under the contract to
support strengthening of air quality monitoring, modelling and
plans
Publication of the
Inception impact assessment
2
on the Better
Regulation Portal (feedback period closing date: 14 Jan 2020)
3
rd
ISG meeting:
discussion on the framing of the underpinning
study for the impact assessment
Launch of the targeted expert survey under the contract for
“Strengthening of air quality monitoring modelling and plans
under the Ambient Air Quality Directives”
(feedback period
closing date: 22 February 2021)
Launch of the service request for “Study to support the impact
assessment for the revision of the EU Ambient Air Quality
Directives”
(‘the support study’)
3
to the contractors under the
Framework
Contract
ENV.F.1/FRA/2019/0001
(Ares(2021)1395608) (closing date to submit offers: 22 March
2021)
European Parliament resolution
on the implementation of the
Ambient Air Quality Directives: Directive 2004/107/EC and
Directive 2008/50/EC
4
Ambient Air Quality Expert Group
meeting with a dedicated
session on the revision of the Ambient Air Quality Directives
Signature of contract for “Study to support the impact
assessment for the revision of the EU Ambient Air Quality
Directives”
with the consortium led by Trinomics
Publication of the EU Action Plan: 'Towards Zero Pollution for
Air, Water and Soil'
(COM(2021)400)
13 Nov 2020
(COM)
17 Dec 2020
(EXT)
19 Jan 2021
(COM)
1 Feb 2021
(EXT)
22 Feb 2021
(Other)
25 Mar 2021
(Other)
22 Apr 2021
(MS)
29 Apr 2021
(Other)
12 May 2021
(Other)
2
3
4
COM (2022),
Have your say - Air quality - revision of EU rules
(accessed: 10.06.2022)
Contract no. 09029901/2021/848269/SFRA/ENV.C.3, implementing Framework Contract no.
ENV.F.l/FRA/2019/0001
European Parliament (2021),
resolution of 25 March 2021 on the implementation of the Ambient Air Quality
Directives
(accessed: 10.06.2022)
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20 May 2021
(COM)
4
th
ISG meeting:
presentation and discussion of inter-institutional
developments relevant for the revision of the Ambient Air Quality
Directives and of the planned and ongoing work to support the
impact assessment
EU Green Week 2021
session on
“Upgrading the ambition of
EU Air Quality legislation”
5
Upstream meeting with the
Regulatory Scrutiny Board
First
stakeholder meeting
on ‘Air quality – revision of EU rules’
Launch of the
open public consultation
6
on ‘Air quality – revision
of EU rules’ (feedback period closing date: 16 Dec 2021)
Publication of the
2021 World Health Organization: WHO
Global Air Quality Guidelines
7
5
th
ISG meeting:
update on stakeholder consultation and on the
preparatory work to support the impact assessment
Ambient Air Quality Expert Group
meeting with a dedicated
session on updates on the revision of the Ambient Air Quality
Directives
Launch of the service request for “Systematic assessment of
monitoring of other air pollutants not covered under Directives
2004/107/EC and 2008/50/EC (with a focus on ultrafine
particles, black carbon and ammonia)”
to the contractors under
the
Framework
Contract
ENV.C.3/FRA/2017/0012
(Ares(2020)6691085) (closing date to submit offers: 30 Nov 2021)
Third Clean Air Forum
8
in Madrid, Spain with two dedicated
sessions on: “Revision of the Ambient Air Quality Directives” and
“Access to justice and the right to clean air”
European Parliament exchange of views on new WHO Global
Air Quality Guidelines
(ENVI Committee)
Launch of the
targeted stakeholder survey part 1
(feedback
period closing date: 11 Feb 2022)
2 June 2021
(Other)
10 Jun 2021
23 Sep 2021
23 Sep 2021
(COM)
(EXT)
(EXT)
23 Sep 2021
(EXT)
30 Sep 2021
(COM)
19 Oct 2021
(MS)
29 Oct 2021
(Other)
18-19 Nov 2021
(Other)
29 Nov 2021
(Other)
13 Dec 2021
(EXT)
5
6
7
8
COM (2021),
Upgrading the ambition of EU Air Quality legislation
(accessed: 10.06.2022)
COM (2021),
public consultation on Air quality- revision of EU rules
(accessed: 10.06.2022)
WHO (2021),
WHO global air quality guidelines
(accessed: 10.06.2022)
COM (2021),
EU third Clean Air Forum
(accessed: 10.06.2022)
77
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23 Dec 2021
(Other)
Signature of the contract for “Systematic assessment of
monitoring of other air pollutants not covered under Directives
2004/107/EC and 2008/50/EC
(with a focus on ultrafine particles,
black carbon and ammonia)” with the consortium led by IIASA
Launch of the
targeted stakeholder survey part 2
(feedback
period closing date: 11 Feb 2022)
6
th
ISG meeting:
update on progress in the stakeholder consultation
process, discussion of first results of analysis for the impact
assessment and the list of potential interventions to be considered
for the revision of the Ambient Air Quality Directives
Second
stakeholder meeting
on ‘Air quality – revision of EU
rules’
Ambient Air Quality Expert Group
meeting with a dedicated
session on the latest updates on the revision of the Ambient Air
Quality Directives
7
th
ISG meeting:
update on the progress in finalising the impact
assessment support study and the policy options to be considered
for the revision of the Ambient Air Quality Directives.
8
th
ISG meeting:
update on the progress in finalising the impact
assessment staff working document and the preferred policy options
for the revision of the Ambient Air Quality Directives.
Meeting with the
Regulatory Scrutiny Board
Opinion
of the Regulatory Scrutiny Board
Finalisation of the support study
Launch of the
Inter-service consultation
on the final Staff
Working Document
13 Jan 2022
(Other)
27 Jan 2022
(COM)
4 Apr 2022
(EXT)
5 Apr 2022
(MS)
5 May 2022
(COM)
7 Jun 2022
(COM)
19 Jul 2022
22 Jul 2022
24 Oct 2022
30 Sep 2022
(COM)
(COM)
(COM)
(COM)
LEGEND
(COM)
(MS)
(EXT)
(Other)
Interservice Group or Regulatory Scrutiny Board
Member States input via Ambient Air Quality Expert Group
(External) stakeholder input (including stakeholder consultation)
Other key events or input
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2. C
ONSULTATION OF THE
R
EGULATORY
S
CRUTINY
B
OARD
(RSB)
An upstream meeting with the RSB took place on 10 June 2021.
After final discussion with the ISSG, a draft of the impact assessment was submitted to the
RSB on 20 June 2022 and discussed at a meeting with the RSB on 19 July 2022.
In relation to this impact assessment, the Regulatory Scrutiny Board (RSB) delivered a
positive opinion with reservations on 22 July 2022. The following table provides information
on how the comments made have been addressed in this Staff Working Document:
Follow-up to recommendations of the Regulatory Scrutiny Board
Topic of RSB
comment
RSB recommendation
Improvement made
Corresponding
section(s) of the
SWD
Section 5.1
Section 6.1
(1) Interaction
with other
initiatives
Include projected quantified impact of
proposed revision of the Industrial
Emissions Directive (IED) in the baseline.
Potential effects of the revised IED have
been tested through sensitivity analysis
representing in a broad manner the
implementation of the revised IED. This
additional analysis indicates that the results
are rather stable compared to the baseline
without the additional reductions resulting
from the IED.
A clarification is provided that the
upcoming proposal is included in the
modelling.
Clarify whether upcoming proposal for
Euro 7 road vehicle emission standard is
included in the modelling.
Section 5.1
Make qualitative references to other
Potential co-benefits of the Nature
legislation expected to deliver co-benefits, Restoration Law and the REPowerEU
notably the Nature Restoration Law.
package are analysed qualitatively.
Clarify whether the level of air pollutant
emission reduction forecast under the
baseline is likely to be underestimated or
not.
Additional sensitivity analyses on several
elements examine this question, including
quantitative analysis of the impact of the
revised Industrial Emissions Directive
(IED), of correcting for ‘border cell effects’,
and of different health impact assumptions.
Section 5.1
Section 7
Section 5.1
Section 8.2
(2)
Presentation Provide a clear balanced, and open
of policy
presentation of the options, in particular
options
regarding the WHO alignment choices and
their different technical feasibility.
The presentation of policy options has
been improved and enhanced, including by
adding a summary comparison table
presenting key figures on achievability of
different WHO alignment choices,
indicating where flexibility elements may
Present upfront all option design
be needed, and adapting the description
parameters (e.g. review clause,
exemptions, inclusion of flexibility elements for more clarity and openness.
given geo-political challenges) and justify if
these are not integrated for all alignment
options
Consider an explicit staged policy option
consisting of a long-term political alignment
commitment, concrete short-term
measures (perspective 2030) and a regular
review mechanism.
An explicit staged policy option has been
included, which features measures for the
2030 perspective, a long-term alignment
commitment, and a regular review
mechanism.
Section 8.1
Section 8.1
(3)
Justifying the Reflect better the feasibility concerns of the The presentation of policy options has
chosen
been improved and enhanced, including by
preferred
adding a summary comparison table
Section 8.1
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option
preferred option.
presenting key figures on achievability of
different WHO alignment choices,
Section 2.1
(4)
Drivers of the Clarify why the existing air quality plans
A clarification on the reasons for ineffective
identified
are not effective, and whether this is due to air quality plans has been added.
problems
a lack of enforcement, financing or
monitoring.
Set out clearly the current set-up of
monitoring stations and sampling points
and be transparent about the extent to
which existing air quality data is reliable
and of comparable quality across the EU.
A clarification on the reliability and
comparability of air quality data has been
added.
Section 2.1
3. E
VIDENCE
,
SOURCES AND QUALITY
Support study
To support the analysis of different policy options, the European Commission awarded a
specific support contract to external consultants on “Study to support the impact assessment
for the revision of the EU Ambient Air Quality Directives”. The consortium comprised
Trinomics (consortium lead), in collaboration with Ricardo, VITO, IIASA and MET Norway.
Two further support contracts provided input on specific aspects related to the revision of the
Ambient Air Quality Directives:
Support contract on “Strengthening of air quality monitoring, modelling and plans
under the Ambient Air Quality Directives”. The consortium comprised Ricardo
(consortium lead), NILU, VITO and Trinomics.
Support contract on “Systematic assessment of monitoring of other air pollutants not
covered under Directives 2004/107/EC and 2008/50/EC (with a focus on ultrafine
particles, black carbon and ammonia)”. The consortium comprised IIASA
(consortium lead), Umweltbundesamt, EMISIA and RIVM.
Consultation strategy
Guided by the consultation strategy,
9
a broad range of stakeholders was consulted for the
revision of the Ambient Air Quality Directives, including:
Public authorities
– i.e. EU Member States and their public authorities, at different
governance levels (national, regional, local) and other institutions;
9
COM (2021)
AAQDs revision - consultation strategy - final
(accessed: 04.08.2022)
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Civil society & NGOs
– i.e. non-governmental organisations (NGOs) and civil society
representatives;
Industry & businesses
– i.e. private economic sector operators such as business
associations, organisations, trade unions, companies;
Academia
&
research
– i.e. research community, academia, medical professionals, and
patient organisations;
EU citizens
– i.e. citizens not directly affiliated with the above stakeholder groups, but
with a keen interest in the topic of air pollution.
Consultation activities included an open public consultation, a targeted stakeholder survey,
stakeholder meetings, interviews and further outreach, such as through the third EU Clean
Air Forum. Stakeholders also provided ad hoc contributions. A detailed overview is presented
in Annex 2.
Bespoke modelling
Quantitative modelling has been conducted, focusing in particular on the impacts of different
air quality standards, with a state-of-the-art modelling framework including: the
Greenhouse
gas – Air pollution Interactions and Synergies
(GAINS) model and MET Norway’s chemical
transport model (EMEP CTM) with the uEMEP downscaling extension for fine resolution.
This modelling assesses a number of effects, in particular: air pollutant emissions,
concentrations, ecosystem impacts, feasibility to attain particular air quality targets as well as
respective measures and their costs. A detailed overview of the modelling framework is
included in Annex 4.
Evidence from air quality monitoring and reporting
Under the two Ambient Air Quality Directives, Member States make available the
information they use for reporting and reciprocal exchange of information via and air quality
data repository (http://www.eionet.europa.eu/aqportal), including:
monitoring and assessment regimes, including assessment methods:
http://aidec.apps.eea.europa.eu
and
http://aided.apps.eea.europa.eu
attainment of environmental objectives, including information on exceedance situations:
http://aideg.apps.eea.europa.eu
air quality plans and programmes, as well as air quality measures:
http://aideh.apps.eea.europa.eu
and
http://aidek.apps.eea.europa.eu
information on source apportionment in zones and agglomerations:
http://aidei.apps.eea.europa.eu
information on air data and aggregated validated assessment data as summarised in the
annual air quality reports published by the European Environment Agency
online EEA indicators, such as:
o
Exceedance of air quality standards in urban areas:
https://www.eea.europa.eu/ims/exceedance-of-air-quality-standards
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Evidence from selected studies and policy documents
COM(2005)446. ‘Thematic Strategy on air pollution’
COM(2013)918. ‘A Clean Air Programme for Europe’, including, in particular:
SWD(2013)531. ‘Clean Air Programme for Europe Impact Assessment’
COM(2017)312. ‘Actions to Streamline Environmental Reporting’
COM(2018)446. ‘The First Clean Air Outlook’
COM(2018)330. ‘A Europe that protects: Clean air for all’
COM(2019)149. ‘Environmental Implementation Review 2019’
SWD(2019)427. ‘Fitness Check of the Ambient Air Quality Directives’
COM(2021)3. ‘The Second Clean Air Outlook’
EEA Annual Air Quality Reports and briefings published from 2011 to 2022, including
o
o
o
o
o
https://www.eea.europa.eu/publications/status-of-air-quality-in-Europe-2022
https://www.eea.europa.eu/publications/air-quality-in-europe-2021
https://www.eea.europa.eu/publications/air-quality-in-europe-2020-report
https://www.eea.europa.eu/publications/air-quality-in-europe-2019
https://www.eea.europa.eu/publications/air-quality-in-europe-2018
EEA Briefing 9/2018. ‘Improving Europe’s air quality — measures reported by countries’
EEA Report 11/2014. ‘Effects of air pollution on European ecosystems’
EEA Report 6/2018. ‘European Union emission inventory report 1990-2016’
EEA Report 22/2018. ‘Unequal exposure and unequal impacts’
EEA Report 24/2018. ‘Europe’s urban air quality’
EEA Briefing 19/2021. ‘Managing air quality in Europe’
ETC/ACC Technical paper 2010/1. ‘The state of the air quality in 2008’
ETC/ACM Technical paper 2011/20. ‘Co-benefits of climate and air pollution
regulations’
European Commission (2013). Flash Eurobarometer 360: ‘Attitudes of Europeans
towards air quality’
European Commission (2017). Special Eurobarometer 468: ‘Attitudes of European
citizens towards the environment’
European Commission (2019). Special Eurobarometer 497: ‘Attitudes of Europeans
towards Air Quality’
European Court of Auditors Special Report 05/2018 on Renewable Energy
European Court of Auditors Special Report 23/2018 on Air Pollution
European Parliament (2017). ‘Report on the inquiry into emission measurements in the
automotive sector’
82
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European Parliament (2019). ‘Sampling points for air quality: Representativeness and
comparability of measurements in accordance with Directive 2008/50/EC on ambient air
quality and cleaner air in Europe’ (study requested by the ENVI Committee)
EUROSAI (2019). ‘Joint report on air quality by the European Organisation of Supreme
Audit Institutions’
IIASA (2014). ‘Complementary Impact Assessment on interactions between EU air
quality policy and climate and energy policy’
IIASA (2017). ‘Costs, benefits and economic impacts of the EU Clean Air Strategy and
their implications on innovation and competitiveness’
IIASA (2018). ‘Progress towards the achievement of the EU’s air quality and emissions
objectives’
JRC (2013). ‘Assessment on siting criteria, classification and representativeness of air
quality monitoring stations’
JRC (2017). ‘Urban PM
2.5
Atlas: Air Quality in European Cities’
JRC (2017). ‘Global Energy and Climate Outlook 2017: How climate policies improve
air quality’
JRC (2019). ‘Urban NO
2
Atlas’
JRC (2021). ‘Urban PM
2.5
Atlas: Air Quality in European Cities’
Nationale Akademie der Wissenschaften Leopoldina (2019). ‘Saubere Luft.
Stickstoffoxide und Feinstaub in der Atemluft: Grundlagen und Empfehlungen’
OECD (2016). ‘The Economic Consequences of Outdoor Air Pollution’
OECD (2020). ‘The economic cost of air pollution – Evidence from Europe’
World Health Organization (2006). ‘Air quality guidelines – global update 2005’
World Health Organization (2013). ‘Review of evidence on health aspects of air
pollution’
World Health Organization (2021). ‘WHO global air quality guidelines: particulate matter
(PM
2.5
and PM
10
), ozone, nitrogen dioxide, sulfur dioxide and carbon monoxide.’
Additional sources of evidence, including relevant academic literature and scientific articles,
reports and conference papers, online and data sources, as well as further policy documents
and guidelines, are listed in the respective Annex 4, and also in the support study informing
this impact assessment or cited as footnotes where referred to.
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A
NNEX
2: S
TAKEHOLDER CONSULTATION
(S
YNOPSIS REPORT
)
1. A
IM OF THE CONSULTATION
This annex summarises the results of the stakeholder consultation activities
undertaken as part of the revision of the Ambient Air Quality Directives. The
stakeholder consultation aimed to collect supporting information, data and knowledge
in order to provide input for the different policy options for the revision of the
Ambient Air Quality Directives, with a view to fill any potential information/data
gaps and gather views of stakeholders on the different policy options and the
feasibility of their implementation. The thorough stakeholder consultation ensures that
the view from different stakeholder groups are duly represented and considered in the
impact assessment.
1.1
Consultation strategy
10
The consultation focused on gathering stakeholders’ responses on the following:
extent and feasibility of a closer alignment of EU air quality standards with the latest
recommendations of the World Health Organization
(policy area 1);
ways to improve legislative provisions and their coherence, including in relation to
penalties, public information and air quality assessments
(policy area 2);
ways of strengthening of air quality monitoring, modelling and air quality plans
(policy
area 3).
A broad range of stakeholders was consulted for the revision of the Ambient Air Quality
Directives, including:
Public authorities
– i.e. EU Member States and their public authorities, at different
governance levels (national, regional, local) and other institutions;
Civil society & NGOs
– i.e. non-governmental organisations (NGOs) and civil society
representatives;
Industry & businesses
– i.e. private economic sector operators such as business
associations, organisations, trade unions, companies;
Academia
&
research
– i.e. research community, academia, medical professionals, and
patient organisations;
EU citizens
– i.e. citizens not directly affiliated with the above stakeholder groups, but
with a keen interest in the topic of air pollution.
10
COM (2021)
AAQDs revision - consultation strategy - final
(accessed: 04.08.2022)
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1.2
Consultation activities
As outlined in the
consultation strategy,
the following activities were applied as
complementary activities that formed the core of the stakeholder consultation:
Open public consultation
allowing the interested public and stakeholders to express
their views
(see section 2.1);
Targeted stakeholder consultation
addressing selected stakeholders in all Member
States and at EU level via a targeted survey
and
interviews
(see section 2.2);
Stakeholder meetings
aimed at assisting in the identification and confirmation of the
policy measures and at receiving feedback that would support its completion (see
section
2.3).
Table A2.1: Stakeholder groups
Stakeholder groups
Consultation activity
Open public
consultation
(2.1)
X
X
X
X
X
Targeted survey
(2.2)
X
X
X
X
Interviews
(2.2)
X
X
X
Stakeholder
meetings
(2.3)
X
X
X
X
X
See section
Public authorities
Civil society & NGOs
Industry & businesses
Academia & research
EU citizens
2
2.1
S
UMMARY OF CONSULTATION ACTIVITIES
Open public consultation
11
The open public consultation ran for 12 weeks, from 23 September 2021 to 16 December
2021.
12
The online questionnaire contained 13 introductory and 31 specific questions and was
hosted on the EU Survey tool. The questionnaire aimed to confirm the issues identified for
the impact assessment and gather initial views on the ambition level and potential impacts of
certain options for the revision of the Ambient Air Quality Directives.
A total of 934 responses were received, and 116 position papers were submitted. In the
general part of the questionnaire, respondents could choose whether they wished to respond
further to a targeted section. The targeted section received a total of 555 responses. On
average, open questions received 124 individual responses, with a minimum of 11 and a
maximum of 406 individual responses. 23 Member States were represented in the responses.
11
12
COM (2021),
OPC- Factual summary report - final
(accessed: 04.08.2022)
COM (2021),
Have your say portal
(accessed: 04.08.2022)
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2636043_0015.png
The stakeholder types of respondents, their country of origin and other information about
their profile was collected for the analysis. The distribution of stakeholder groups and
countries is presented below in Box A2.1.
Box A2.1: Open public consultation – Stakeholders per group and country
Stakeholder per stakeholder group (descending):
EU citizens (=615), Civil society & NGOs (=106), Industry & businesses (=103), Public authorities
(=53), Academia & research (=25) + Others (=32).
Stakeholder per country (descending):
DE (=225), IT (=191), FR (=78), PL (=69), BE (=67), RO (=56), ES (=48), SE (=38), AT (=22), NL
(=21), BG (=13), PT (=12), IE (=9), CZ (=8), LI (=7), DK (=7), SI (=6), SK (=6), HU (=6), EL (=5),
FI (=4), LU (=3), ES (=2) + 32 EEA and non-EU countries and international organisations.
On policy area 1,
stakeholder feedback pointed to a desire to opt for a high level of
ambition. 72% (n=673) of all respondents expressed a preference to align with WHO Air
Quality Guidelines. In particular, a large majority of
civil society & NGOs
(93%, n=98) and
EU citizens
(79%, n=485) indicated that EU air quality standards should be fully aligned with
the latest WHO recommendations. This view was only shared by a minority of
public
authorities
(36%, n=19), with a majority of
public authorities
(62%, n=32) here calling for
partial alignment. Furthermore,
civil society & NGOs, academia & research
and
EU citizens
were largely in favour of meeting the current EU air quality standards as soon possible, while
public authorities
and
industry & business
representatives were less in favour of meeting
current EU air quality standards as soon as possible. Nevertheless, there was a general
agreement across the stakeholder groups that meeting current air quality standards is the most
feasible and the most important policy measure. Regarding the extent of applicability of air
quality standards,
civil society & NGOs
and
EU citizens
thought these should apply
everywhere while some
public authorities
were also of the opinion that these should apply
only at selected locations.
On policy area 2,
the majority of
civil society & NGOs
and
EU citizens
were of the opinion
that legislative changes in regards to air quality should include a provision ensuring access to
justice for citizens as well as a provision ensuring compensation for health damage caused by
air pollution. To expand requirements for action by national / regional / local authorities in
case of exceedances as deemed as highly important by 65% (n=607) of respondents.
Regarding the availability of information on air quality,
public authorities
and
industry &
businesses
felt the most informed while
civil society & NGOs
thought there was a room for
improvement. In addition, this measure was thought to be highly feasible to implement by
58 % (n=541) of respondents. In general, regarding the feasibility and importance of new
policy measures, there was quite a divide between the stakeholder groups, though there was a
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2636043_0016.png
general agreement that making it easier for EU air quality standards to update to scientific
progress would be an important measure.
On policy area 3,
regarding monitoring the majority of
civil society & NGOs, academia &
research
and
EU citizen
representatives were of the opinion that there is a need for additional
monitoring everywhere, while there was a lesser support for this additional monitoring from
public authorities
and an even lesser support from
industry & business
representatives. To
establish more detailed rules on the location of sampling points was seen to be highly
important by 60% (n= 560) of respondents as well as the expansion of monitoring
requirements to a broader set of harmful air pollutants (60%, n=560). There was a general
agreement across most of the stakeholder groups that the clarity of air quality plans needs to
be improved, especially when addressing specific sources and origins of air pollution.
Additionally, regarding the clarity of air quality plans,
public authorities
believed that
responsibility across different tiers of governance and stakeholders need to better clarified.
Addressing specifically the proposed policy measures, the option considered most important
and feasible across all stakeholder group was to establish more detailed rules on the location
of sampling points.
2.2
Targeted stakeholder consultation
Targeted survey
The targeted survey was published on EU survey in two parts
(i.e. part 1 on policy area 1 on
13 December 2021, and part 2 on policy area 2 and 3 on 13 January 2022),
both with a
deadline for contributions by 11 February 2022.
The targeted survey was seeking in-depth views by organisations with an interest in, or
working with EU rules on air quality. Therefore, the survey was specifically disseminated to
targeted stakeholders, including competent authorities at different levels, private sector
organisations, academics and civil society organisations. The targeted survey was distributed
to a large network of relevant stakeholders to reach a great number of interested stakeholder
in all EU Member States and all targeted stakeholder groups.
Part one of the targeted stakeholder survey received in total 139 replies representing 24
Member States. Part two of the survey received 93 replies representing 22 Member States.
The number per stakeholder group and Member State for part one (i.e. policy area 1) and for
part two (i.e. policy area 2 and 3) is listed in the boxes (A2.2 and A2.3) below.
Box A2.2: Targeted survey part 1 - Stakeholders per group and country
Stakeholder per stakeholder group (descending):
Public authorities (=53), Academia & research (=42), Industry & businesses (=26), Civil society &
NGOs (=12) + Others (=6).
Stakeholder per country (descending):
DE (=23), BE (=17), IT (=17), ES (=13), SE (=7), RO (=7), AT (=4), FR (=4), HU (=4), NL (=4) PL
(=4), CZ (=3), DK (=3), FI (=3), EL (=3), HR (=3), IE (=3), PT (=3), LU (=2), LV (=2), SI (=2), CY
(=2), SK (=1), EE (=1) + 3 EEA and non-EU countries.
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2636043_0017.png
On
policy area 1,
the majority of stakeholders saw difficulties to reach the recommended
PM
2.5
annual and peak concentrations by the WHO Air Quality Guidelines in the foreseeable
future, while
civil society & NGO
representatives were the most optimistic and
public
authorities
and
research & academia
the least optimistic. A majority was in favour of stricter
PM
2.5
annual limit values (60%, n=83) and short-term limit values (62%, n=86) that apply in
all the territory and not at selected locations only
(policy measure O1 and O2).
For PM
10
a
relative majority (44%, n= 61 for annual and 48%, n= 66 for daily) of stakeholders saw the
recommended PM
10
levels by the WHO Air Quality Guidelines as feasible with significant
additional effort, while
civil society & NGOs
were generally more optimistic. In addition, a
relative majority of stakeholders (37%, n=51) were in favour of more stringent PM
10
EU
standards (especially on a long-term basis) and introducing an average exposure indicator
target for short and long-term PM
10
concentrations at a regional level
(policy measure P1 to
P3).
For NO
2
, 38% (n=53) of the stakeholders saw the recommended annual levels by the WHO
Air Quality Guidelines as feasible but only with significant effort and for the NO
2
hourly
concentrations which mirror the current EU standard a small relative majority of 31% (n=43)
saw it feasible but only with some additional effort
(policy measure Q2).
A majority of 66%
(n=93) of respondents were in favour of more stringent EU standards of the NO
2
annual mean
in a short-term timeframe
(policy measure Q1).
Also a relative majority indicated a full
alignment with the WHO recommendation for a long-term standard (37%, n=51)). Again
public authorities, civil society & NGOs
and
academia & research
were the most ambitious
stakeholders, whereas
industry & business
voted for less ambitious levels. As for PM
2.5
and
PM
10
, stakeholders are of the opinion that an average exposure indicator target at a more
regional level would be appropriate. However, a low response rate for the question on NO
2
average exposure indicates a low level of certainty across all stakeholder groups
(policy
measure Q3).
On ozone (O
3
) a relative majority (38%, n=53) of stakeholders sees the 2021
WHO recommendations for annual ozone levels as feasible without additional effort.
Public
authorities
and
research & academia
were the most optimistic stakeholder groups. A relative
majority (26%, n=37) replied for being in favour of an ozone limit value, while 21% (n=28)
replied for a target value. A relative majority of the stakeholders (31%, n=43) regarded the
recommended ozone peak concentrations by the WHO as being feasible. However, for the
short to medium term, 41% (n=57) of the respondents were in favour for the ozone short-term
concentration that mirrors the current EU target value and only 43% (n=59) agreed to a full
alignment with the WHO recommendation for long-term
(policy measure R1 to R3).
Box A2.3: Targeted survey part 2 - Stakeholders per group and country
Stakeholder per stakeholder group (descending):
Public authorities (=42), Academia & research (=22), Industry & businesses (=14), Civil society &
NGOs (=12) + Others (=3).
Stakeholder per country (descending):
BE (=15), DE (=15), ES (=10), IT (=8), SE (=8), FR (=4), FI (=4), RO (=4), PT (=3), AT (=2), CZ
(=2), EL (=2), IE (=2), HR (=2), HU (=2), PL (=2), DK (=1), SI (=1), SK (=1), LV (=1), EE (=1), NL
(=1) + 3 EEA and non-EU countries.
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On
policy area 2,
83% (n=10) of the stakeholder group
civil society & NGOs
were strongly
in favour of adjusting EU air quality standards upon publication of new scientific evidence
while the other stakeholder groups and in particular
industry & businesses
but also
public
authorities
were less supportive of this policy measure
(policy measure A1).
However, the
policy measure to adjust EU air quality standards based on technical progress didn’t find full
support across all stakeholder groups
(policy measure A2).
To establish short-term EU air
quality standards for additional air pollutants found no majority as respondents of the
different stakeholder groups answered with great variety (i.e.
civil society & NGOs
and
research & academia
largely in favour of this policy measure
(B1)
while
industry &
businesses
and
public authorities
were less ambitious). With a relative majority (32%, n=30)
of all replies, all stakeholders were largely in favour of the expansion of the exposure
reduction target
(B3),
with
public authorities
the most supportive of this policy measure. The
regular update of air quality plans was also supported by a relative majority of stakeholders
(41%, n=38) while
industry & business
were the only stakeholder group being less supportive
of this policy measure
(C5).
A policy measure that received minor support across most stakeholder groups (besides
civil
society & NGOs)
was the further specification of the obligation to take measures to keep the
exceedance period as short as possible with almost half of the respondents (45%, n=18)
among
public authorities
that didn’t support this policy measure
(C2). Public authorities
with
a majority (50%, n=21) of replies among
public authorities
respondents replied that they are
not or largely not in favour of harmonising air quality plans
(policy measure D2),
while they
were more supportive (38%, n=16) of establishing a requirement for Member States to
involve specific actors in the air quality plan development
(policy measure D1).
This policy
measure also found support across the other stakeholder groups. Regarding the policy
measures about transboundary air pollution, a large relative majority (48%, n=45 for policy
measure M1 and 36%, n=34 for policy measure M2) of all replies and across all stakeholder
groups are in favour to use an agreed methodology when assessing transboundary air
pollution and when it comes to cooperation and joint action on transboundary air pollution
(noting that the response rate from
industry & business
was very low for those interventions).
Policy measures regarding additional enforcement tools
(policy measures E1 to E4)
in case of
non-compliance had a very low response rate (27%, n= 44). The policy measure E2 on a
specific provision that guarantees a right to compensation for damage and health found no
support among
public authorities
while
civil society & NGOs
where largely supportive. Least
support in this policy area was the introduction of an “access to justice” provision which was
only largely supported by
civil society & NGOs (policy measure E4).
Policy measures
regarding public air quality information was supported across all stakeholder categories with
only minor reservations in regards to the regular up-to-date information from
industry &
business
representatives
(policy measure F1).
A relative majority (40, n=38) of replies was in
favour of requiring Member States to use harmonised air quality indices while comments
from
public authorities
requested that this would be preferred as an additional index to the
national index
(policy measure F4).
On
policy area
3, the mandatory use of modelling as part of air quality assessment did not
find large support, and comments made by stakeholders point to the current large uncertainty
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of harmonised model criteria
(policy measure G2).
To allow the use of indicative
measurements to substitute fixed measurements as part of the air quality assessment was with
a relative majority (43%, n=40) of all replies not supported among all stakeholder groups
(policy measure G1),
whereas the highest support (21%, n=12) was found in the stakeholder
group of
public authorities.
More supported was the policy measure
H2
that considers
sampling points for PM
2.5
and PM
10
independently, especially among
public authorities,
research & academia
and
civil society & NGOs.
The change of minimum number of
sampling points was more favoured by
civil society & NGOs
(42%, n=5) and
academia &
research
(41%, n=9) and by
public authorities
(14%, n=6) and found no support among
industry & businesses (policy measure H1).
To specify that sampling points with
exceedances of limit values should be maintained
(policy measure I1)
found large support
across the different stakeholder groups (noting that
industry & businesses
only had one
reply). This result is similar to the policy measure that foresees the establishment of a
protocol when a sampling point has to be relocated.
Public authorities
(43%, n=18) and
academia & research
(50%, n=11) were fully or largely agreeing to this policy measure
(I3).
To include a requirement to monitor long-term trends if the fixed sampling point is
discontinued with other techniques, such as indicative measurements, found less support, and
stakeholders pointed to the uncertainty that occurs when different monitoring techniques are
used for one measurement
(policy measure I2).
For the policy measure to further clarify
macro-siting criteria for sampling points, a larger number of respondents (31%, n=29) was
fully or more in favour, whereas a relative majority (44%, n=41) did not answer to this
question. Also
public authorities
were more in favour (43%, n=18) of these policy measure,
however a large number of respondents (31%, n=13) from
public authorities
did not reply
(policy measure J1).
For the policy measure to further clarify micro-siting criteria the same
number of respondents from
public authorities
(n=13) either fully and to a large extend in
favour of this policy measure or was to some extend or not at all supporting this policy
measure as some indicated that current rules suffice, while
NGOs & civil society
were more
supportive of this measure
(policy measure J2).
On the data quality requirements for
sampling points to be further defined, a relative majority of replies to this policy measure
(30%, n=27) were in favour, and
academia & research
and
public authorities’
respondents
were the largest supporters
(policy measure K1).
The mandatory up-to-date information on
pollutant concentration was only to some extent or not at all supported across the stakeholder
groups (29%, n=27). Various comments from
public authorities’
stakeholders pointed out
that up-to-date data would be important but it needs to be quality assured to present correct
data information
(policy measure K2).
The introduction of standardized “modelling quality
objectives” were supported largely (38%, n=26) with
public authorities
and
academia &
research
being the greatest supporters of this policy measure
(K3).
To measure additional
emerging air pollutants and to set a minimum number of sampling points for those was
supported by a clear relative majority (43%, n=40 and 39%, n=37) from all stakeholders
except from
industry & business (policy measure L2).
Similar support found the policy
measure N1 on refining the minimum information to be included in an air quality plan (43%,
n=40) across all stakeholders groups.
Interviews
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2636043_0020.png
Targeted interviews were conducted to complement the other consultation activities, in
particular with representatives of regional and national
public authorities, civil society &
NGOs
and
academia & research.
The interviews were conducted in April 2022 after the
targeted stakeholder survey was closed and evaluated. A list of questions was sent to the
stakeholders ahead of the interviews, which were then discussed during the meeting. The
interviews focused on remaining gaps for policy area 2, notably on the feasibility, means of
implementation and impacts of the various options considered. The main purpose of the
interviews was to fill those information gaps identified from the evaluation of the targeted
stakeholder survey. See Table A2.2.
Table A2.1: Interviews
Organisation name
ARPA Lombardia
AirClim
University of Helsinki
SenUVK (Senate Department for the Environment, Mobility,
Consumer and Climate Protection, Berlin)
Department of Air Protection and Urban Policy, Ministry of Climate
and Environment*
Country
Italy
Sweden (EU scope)
Finland
Germany
Poland
Stakeholder type
Public authority (regional)
Civil society & NGO
Academia & research
Public authority (regional)
Public authority (national)
2.3
Stakeholder meetings
First stakeholder meeting
The first stakeholder meeting took place on the 23 September 2021 and was attended by a
total of 345 participants, either onsite or online according to COVID-19 restrictions at the
time.
A total of 315 stakeholders from 27 Member States participated in the meeting, without
considering the consultants contributing to the revision of the Ambient Air Quality Directives
and EU officials involved. The aim of the first stakeholder meeting was to confirm the
shortcomings identified and gather initial views on the ambition level from all stakeholder
groups.
13
All relevant stakeholder groups as set out in the consultation strategy were
represented during the stakeholder meeting. The stakeholder groups and the country is
indicated below in box A2.4.
13
COM (2021),
First stakeholder meeting summary report- final
(accessed: 04.08.2022)
91
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2636043_0021.png
Box A2.4: First stakeholder meeting - Stakeholders per group and country
Stakeholder per stakeholder group (descending):
Public authorities (=201), Industry & businesses (=40), Civil society & NGOs (=34), Academia &
research (=30) + Others (=10).
Stakeholder per country (descending):
DE (=34), ES (=32), FR (=27), IT (=23), SE (=13), BE (=11), PT (=11), HU (=10), SK (=6), DK (=5),
FI (=5), IE (=5), LV (=5), PL (=5), AT (=4), BG (=4), HR (=4), MT (=4), NL (=4), EL (=3), LU (=3),
RO (=3), CY (=2), CZ (=2), EE (=2), SI (=2), LT (=1) + EEA and non- EU countries and
international organisations.
On policy area 1,
the majority of
civil society & NGOs
argued strongly for full alignment of
EU air quality standards with the WHO Air Quality Guidelines levels by 2030, whereas
several
public authorities
commented on the need to consider the measurability and
acceptability of future measures needed to attain a closer alignment.
Industry & business
stakeholders also cautioned that uncertainties related to technical feasibility, local issues,
biogenic emissions and measurements remained. Stakeholders also stressed the need to look
at additional pollutants, a more regular review of air quality standards, requested a location
based limit value, argued for a regional exposure reduction target, and pointed to
measurement uncertainties of air pollutants.
On policy area 2,
the different stakeholder groups, supported in general the proposed
elements to be tackled and possible policy measures presented. The raised topics and
discussions focused on adding an explicit mechanism for adjusting air quality standards to
technical and scientific progress, on expansion of actions required to address exceedance,
specifying provisions to guide the development of air quality plans and on governance, and
expanding the provision of information requirements. The importance of access to
information was underlined by stakeholders, which is deemed crucial for the protection of
public health and also directly connected to other provisions, for example, on access to
justice. Stakeholders also agreed that the revision should also ensure that especially
vulnerable groups have access to information.
On policy area 3,
the use of models to supplement assessment methods was welcomed,
though it was noted this should not be at the expense of a reduced monitoring network. The
importance of clear meta-data to describe a site to enable cross-city comparison was noted.
Civil society & NGOs
and
public authorities
advocated an increase in the number of PM
2.5
monitoring stations, and more broadly set clearer requirements for the proportion between
different types of monitoring stations, which would entail abandoning the PM
2.5
/PM
10
ratio.
Concerns were expressed by several public authorities (both national and regional level) with
regards to stability and sensitivity issues, hence participants noted that single sensors should
not be used for compliance purposes and that uncertainties must be communicated
transparently if such data is used.
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Second stakeholder meeting
The second stakeholder meeting took place on the 4 April 2022 and was attended by a total of
285 participants, either onsite or online according to COVID-19 restrictions at the time.
A total of 257 stakeholders participated in the meeting, without considering the consultants
contributing to the revision of the Ambient Air Quality Directives and EU officials involved.
Stakeholders from 23 Member States were present at the meeting. The aim of the second
stakeholder meeting was to collect feedback from stakeholders that would assist the
Commission in its completion of the Impact Assessment. All relevant stakeholder groups as
set out in the consultation strategy were represented during the stakeholder meeting.
14
The
division of stakeholders per groups and per country is indicated below in Box A2.5.
Box A2.5: Second stakeholder meeting - Stakeholders per group and country
Stakeholder per stakeholder group (descending):
Public authorities (=135), Industry & businesses (=56), Civil society & NGOs (=26), Academia &
research (=23) + Others (=17).
Stakeholder per country (descending):
DE (=42), ES (=37), IT (=20), FR (=20), SE (=16), BE (=10), NL (=7), HU (=7), RO (=6), AT (=6),
PL (=5), FI (=5), DK (=4), SK (=2), MT (=2), HR (=2), LU (=1), LT (=1), LV (=1), IE (=1), EE (=1),
CZ (=1), BG (=1) + EEA and non- EU countries and international organisations.
On policy area 1,
public authorities
and
civil society & NGO
representatives expressed their
preference for binding air pollutant standards. Several NGOs reiterated their preference for
full alignment with the WHO Air Quality Guidelines levels by 2030 while one
public
authorities
also expressed the same view. It was also raised by
civil society & NGO
representatives that they would be interested to see analysis of the percentiles for daily
exceedances. Especially regarding NO
2
, one NGO stressed the future focus should be on
daily limit values.
Civil society & NGOs
also expressed opinions on the relative effectiveness
of target or limit values. It was pointed out that in certain Member States target values do not
provide an effective incentive and as such the revised air quality rules should turn to limit
values. Stakeholders from all stakeholder groups expressed their views regarding the
definition of ‘short’ and ‘long’ term standards. Generally,
civil society & NGO
representatives were of the opinion that 2030 should already be considered as a ‘long term’
timeframe, while
public authorities
were more reserved and stated that 2040 might also be an
appropriate long-term target.
Industry & business
pointed out that the transition in their sector
would take time, and there is a need for the long-term targets to reflect that and align with
sector plans and roadmaps. As such,
industry & business
expressed their preference for 2050
to be considered as the long-term target.
On policy area 2,
representatives of
public authorities
stressed the importance of
transboundary cooperation, which they proposed should be addressed by harmonisation of
14
COM (2022),
Second stakeholder meeting briefing paper
(accessed: 04.08.2022)
93
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rules on air quality plans. This suggestion was also supported by certain
civil society & NGO
representatives. Furthermore on air quality plans it was suggested that their drafting starts
with emission factors and should include absolute numbers.
Civil society & NGO
representatives also touched upon the topic of improvement of public information. They
discussed that there is a need to harmonise the available information as well as to provide a
link between the information provided and the health impacts of air pollution (e.g. by relying
on colour coding of different health impacts). Linking health impacts with air quality will
allow citizens to make more informed decisions. Making informed decisions can further be
supported by providing citizens with real-life data, namely allowing citizens to limit their
exposure levels. The list of pollutants on which real-life data are provided should be
expanded and include pollen, for example. Furthermore, the topic of access to justice was
also touched upon, namely that both the provisions on access to justice and on public
information remain the largest gaps in the current Ambient Air Quality Directives. One
attendee from
research & academia
stressed that penalties have to be more drastic in order to
encourage Member States to take action. However, at the same it was highlighted that any
legal action will be difficult if one relies on target values rather than limit values.
On policy area 3,
public authorities’
representatives highlighted the importance with regards
to sampling points of Annex III to Directive 2008/50/EC. One attendee from
civil society &
NGO
pointed out that there can be issues with accuracy of modelling, due to the availability
of data. As such, one has to approach modelling with caution. It is thus important to use data
that is fit for purpose and regularly updated emission inventories.
Civil society & NGOs
also
highlighted that clarification on the procedures for moving monitoring sites was crucial, as
there are contentious cases where public authorities have shifted sites. One participant
highlighted that there is a need for good real-time monitoring to be in place, ideally
composed of several solutions (e.g. satellite and ground monitoring). Representatives of
academia & research
highlighted the need for monitoring requirements for ammonia, which
are currently not present despite the potential severe impacts on biodiversity and ecosystems.
This would also be beneficial for coherence with the NEC Directive. It was also pointed out
that there is a need for monitoring both in urban and in rural areas, and for sampling points in
residential areas, as wood burning still takes place and is subsidised in some Member States.
3
3.1
RESULTS OF THE STAKEHOLDER FEEDBACK
Feedback by stakeholder groups – Policy Area 1
Representatives from
public authorities
largely consider it is “not feasible, for the
foreseeable future” that the recommended levels from the WHO Air Quality Guidelines for
PM
2.5
of 5 µg/m³ annually
(incl. 36 out of 53 replies to the survey)
or that the daily levels of
15 µg/m³
(incl. 25 out of 53 replies to the survey)
are achievable. Further some
representatives think that the PM
2.5
annual level should be set on 10 µg/m³
(incl. 17 out of 53
replies to the survey)
while more representatives favour an annual level of 15 µg/m³ for PM
2.5
(incl. 19 out of 53 replies to the survey).
For the average exposure indicator target, respondents from public authorities have no
preferred approach but differ strongly. On PM
10
levels, the representatives largely think the
WHO recommended levels are not feasible in the foreseeable future
(incl. 22 out of 53 replies
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2636043_0024.png
to the survey)
and there representatives are mostly favouring 20 µg/m³ or 30 µg/m³ for a
PM
10
annual level. The majority within this group is in favour of an average exposure
indicator target of PM
10
of an “ECO
15
at national level” for both short and long-term. For
NO
2
levels, public authorities think that 30 µg/m³ is the most feasible option and that the
WHO recommended levels are only feasible with significant effort. The large majority is in
favour that the NO
2
levels and also PM
2.5
and PM
10
levels should apply in all territory, and is
in favour that the type of standard should be a limit value. For ozone levels the
representatives think that the most recent WHO recommendation is feasible, without
additional effort and the majority is in favour for a level of 100 µg/m³
(incl. 13 out of 53
replies to the survey).
For all heavy metals this stakeholder group thinks that the most recent
WHO recommendations are feasible without additional effort. For benzo(a)pyrene,
stakeholders don’t think that the WHO recommendations are feasible for the foreseeable
future.
Representatives from
civil society & NGOs
largely think that the WHO recommended levels
for PM
2.5
are feasible with some additional effort
(incl. 10 out of 12 replies to the survey).
The representatives’ opinion on the levels are divided with around half favouring a PM
2.5
level of 5 µg/m³ and the other half favouring a PM
2.5
level of 10 µg/m³
(incl. 6 out of 12
replies for to the survey for each value).
This stakeholder group thinks that PM
2.5
levels
should apply in all territory and a large majority is in favour to set a limit value as the type of
standard. The representatives have the same opinion concerning the PM
2.5
short-term
standards; around half of the stakeholder group is in favour of a short-term PM
2.5
level of
15 µg/m³ and the other half favours 25 µg/m³
(incl. 6 out of 12 replies for to the survey for
each value).
The respondents didn’t express many opinions about the favoured approach on
the PM
2.5
average exposure indicator target.
Concerning PM
10
levels, respondents from civil society & NGOs expressed that the WHO
recommendations are feasible, with some additional effort
(incl. 11 out of 12 replies to the
survey)
and a majority is in favour of a PM
10
annual level of 20 µg/m³. For the PM
10
short-
term concentrations, the majority is in favour for a level of 50 µg/m³ for short to medium
term and for 45 µg/m³ in the long-term. Regarding NO
2
annual levels around half of this
stakeholder group is in favour of a NO
2
level of 10 µg/m³ and the other half is favour of a
NO
2
level of 20 µg/m³. Similar to PM
2.5
and PM
10
the representatives think that the levels
should apply in all territory and limit values is the preferred type of standard. For ozone
levels the representatives believe that the WHO recommended levels are feasible, with some
additional effort
(incl. 11 out of 12 replies to the survey)
and are equally in favour of an
ozone level of 60 µg/m³ or 70 µg/m³
(incl. 6 out of 12 replies to the survey for each option).
The ambition for heavy metals in regards of concentration levels are mostly quite low i.e.
with the majority being in favour of a level for arsenic of 6 µg/m³.
A large majority of representatives from
industry & business
put forward that air quality
standards for PM
2.5
annual should be regulated by the EU. However, a majority also thinks
that PM
2.5
short-term concentrations should not be regulated by EU standards. This
15
ECO=Exposure concentration obligation
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stakeholder group finds that the recommended PM
2.5
annual levels by the WHO are feasible,
but only with significant effort and a large majority
(incl. 16 out of 26 replies to the survey)
think that the PM
2.5
level should be set at 25 µg/m³. Only one representative of this group
expressed the opinion that PM
2.5
level should be lower than 5 µg/m³ and another one
expressed that the level should be set at 5 µg/m³. A majority of this stakeholder group is
largely in favour of applying the PM
2.5
annual levels at selected stations only
(incl. 12 out of
26 replies to the survey),
while only a minority is in favour of applying the levels in all
territory. For the PM
2.5
short-term levels the majority of this group thinks that the
recommended levels by the WHO are not feasible, for the foreseeable future and are also
largely in favour to not set a standard at all
(incl. 14 out of 26 replies to the survey).
However,
asking the representatives what type of standard should apply only a minority repeated that
no standard should be set while a majority expressed that they favour a limit value.
Most respondents from industry & business indicated that an “ECO at a more regional level”
for both, short term and long term should be set
(incl. 14 (short) and 16 (long) out of 26
replies to the survey).
On PM
10
levels, the majority in this group thinks that the WHO
recommended levels are feasible, but only with significant effort and opinions were
expressed that the PM
10
annual level should be set at 30 µg/m³ and only applies at selected
locations
(incl. 12 out of 26 replies to the survey).
For PM
10
peak concentrations the majority
of representatives is in favour of a level of 50 µg/m³, which corresponds to the current EU
standard, but find that the standard should apply at selected locations only. Industry &
business stakeholders are largely agreeing for PM
10
on a “national emission ceiling at more
regional level” for the average exposure indicator target for short and for long-term. For NO
2
annual levels this stakeholder group largely expressed the view that the WHO recommended
levels are not feasible, for the foreseeable future
(incl. 17 out of 26 replies to the survey)
and
some expressed their opinion of being in favour of a NO
2
annual level of 30 µg/m³. Some
stakeholders expressed their opinion that the NO
2
annual level should only apply at selected
stations. Stakeholders also expressed that they are against an EU standard for NO
2
short-term
concentrations
(incl. 13 out of 26 replies to the survey).
Stakeholders think that a NO
2
short-
term level of 200 µg/m³ should apply i.e. which means no change to the current EU standard.
The representatives of
academia & research
largely believe that the recommended WHO
levels for PM
2.5
are not feasible, for the foreseeable future and are in favour of PM
2.5
annual
levels of 10 µg/m³ or 15 µg/m³. This stakeholder group is largely in favour of applying the
levels in all territory and set a limit value as the type of standard for PM
2.5
. For the PM
2.5
short-term concentrations the stakeholder group largely favours a PM
2.5
short-term level of
25 µg/m³ for short-term and 15µg/m³ for long-term
(incl. 16 out of 42 replies to the survey).
On the average exposure indicator target, the opinions differ in this stakeholder group and
also many didn’t express their opinion at all
(incl. 24 out of 42 representatives didn’t reply to
the survey on this matter).
For PM
10
annual values for short to medium term, a large share of
representatives is in favour of 20 µg/m³, while many expressed of being in favour of
30 µg/m³ for PM
10
levels. For long-term levels (with a view on year 2050), a large majority is
in favour of 15 µg/m³. For long-term PM
10
short-term concentrations this stakeholder group
is the most ambitions with a large majority for a PM
10
level of 45 µg/m³ and to a lesser
extend for less than 45 µg/m³. The recommended NO
2
levels recommended by the WHO are
seen as feasible by the majority of this group
(21 out of 42 replies to the survey),
but only
with significant effort. The majority thinks that a NO
2
annual level of 30 µg/m³ for short-term
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2636043_0026.png
and 10 µg/m³ for long-term should be put forward. Representatives of this stakeholder group
think that NO
2
levels should apply in all territory and the type of standard should be a limit
value. For ozone the opinions of short term ozone levels differ strongly, while for the long-
term levels a clear majority is in favour of ozone levels of 60 µg/m³. For heavy metals, this
stakeholder group is in general more ambitious than other stakeholder groups in regards of air
pollutant levels.
Representatives of
EU citizens
thought the most important option was to ensure achievement
of the existing EU air quality standards. Regarding feasibility, EU citizens thought the most
feasible option was to establish legally enforceable limit values for all air pollutants, while
the least feasible option was to mandate that all air quality standards are met, either in general
or everywhere. Representatives made some remarks, respectively on the need to act to protect
human and environmental health, and the need to try to minimise economic impacts. Several
EU citizens made comments linked to revising the Ambient Air Quality Directives, namely:
the need to clearly assign responsibilities, setting targets for additional pollutants (indoor air
quality, pollen), prioritising locations where people spend most of their time, strengthening
monitoring in residential areas and strengthening enforcement to ensure compliance with
standards. Finally, some stakeholders advocated for the ban of wood burning in residential
areas.
3.2
Feedback by stakeholder groups – Policy Area 2
Representatives of
public authorities
expressed largely positive feedback and a majority was
in favour on policy measures regarding the periodically update of a list containing air
pollutant of emerging concern, the establishment of additional short-term EU standards i.e.
for PM
2.5
, the expansion of exposure reduction targets, an agreed methodology for
transboundary air pollution and the obligation for Member States to provide specific health
information to the public. Across all intervention areas
16
different levels of ambition and
opinions were expressed by this stakeholder group, besides on topics that touch upon
intervention area E, where only a minority from public authorities expressed their opinions
(incl. 29 out of 43 no replies to the survey).
In addition, the feedback that was received on
those topics was mostly negative. Other policy measures that found only little consent among
the public authorities were the introduction of a mechanism to adjust air quality standards
based on technical progress, the obligation to introduce short-term action plans for each
pollutant and the requirement for Member States to harmonise air quality plans.
Representatives from
civil society & NGOs
were more in favour of policy measures in area
M and E and lesser to measures in area A and B. Representatives in particular expressed
stronger opinions for topics related to intervention area A, B and F and to a lesser extent on
topics that touch upon the other intervention areas. The large majority of this stakeholder
group favoured the introduction of a mechanism to adjust EU air quality standards based on
scientific advice. In comparison, no representative expressed to be largely in favour to adjust
the EU air quality standards based on technical progress. Other policy measures that found
16
For a complete overview of all intervention areas, see Annex 6 to the SWD.
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high support among the stakeholder representatives touch on the following interventions:
establishing short–term EU air quality for example for PM
2.5
, establish additional limit values
for additional air pollutants, the introduction of an short-term action plan for each pollutant,
the regular update of air quality plans, both policy measures regarding transboundary air
pollution, the introduction of an explicit “access to justice” provision and the requirement to
ensure more regular up-to-date data reporting. The policy measures that are included in
intervention area A found in general the least support among the civil society & NGO
representatives, i.e. the provision for Member States to adopt more stringent standards
(2 out
of 12 replies to the survey being in favour).
Representatives from
industry & businesses
favoured to a large extend the policy measure
that introduces a mechanism to adjust EU air quality standards based on scientific advice
(incl. 8 out of 14 replies to the survey).
This stakeholder group expressed largely opinions in
relation to topics that touch upon intervention area A and B, while other policy measures
didn’t receive many (different) opinions. Only three policy measures (B1, B2 and D1) found
some support expressed by the representatives from industry & businesses while other policy
measures didn’t found strong support during the consultation period. This stakeholder group
in particular not in favour of the establishment of short-term air quality standards such as for
PM
2.5
. In addition, A1, A4 and B4 were the interventions where a large majority of
representatives expressed not being in favour of those policy measures.
Representatives from
academia & research
expressed in general higher support for policy
measures that touch upon intervention areas C and M and didn’t express strong support on
policy measures that are included in intervention area E. Across all policy measures that were
discussed, this stakeholder group expressed strong opinions for all policy measures except for
those in area E
(incl. 18 out of 22 no replies to the survey).
A large majority of respondents
are in favour to the periodically update of list for emerging air pollutants to ensure
monitoring of those
(13 out of 22 replies to the survey).
Also policy measures regarding
transboundary air pollution found among this stakeholder group large support
(incl. 13 for
M1 and 14 for M2 out of 22 replies to the survey).
Defining alert thresholds and information
thresholds for all air pollutants to alert the public was the policy measure that found least
support in this stakeholder group.
The representatives of
EU citizens
thought all policy measures related to policy area 2 that
were presented were almost equally important. They expressed a similar view regarding
feasibility, citizens thought that all the measures presented were almost equally feasible (i.e.
adjust EU air quality standards to the evolving technical and scientific progress, further
define the different types of air quality standards and the actions their exceedances would
trigger’ etc.). Respondents from EU citizens pointed out that better information (on air
pollution in certain areas, on effects of air pollution and on what citizens can do to reduce
pollution in their cities) is needed. Other measures EU citizens focused on: legally binding
EU standards; extending the scope of air quality standards and monitoring to cover other
pollutants harmful to health (e.g. mercury, black carbon, ultrafine particles and ammonia, and
indoor air pollution) and restricting the right of corporations and individuals to make profits
by conducting activities that curtail the right of current and future generations to a healthy,
sustainable and naturally biodiverse environment. With regards to measures supporting
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implementation, this stakeholder group also supported improvements to the current provision
on penalties.
3.3
Feedback by stakeholder groups – Policy Area 3
Representatives of
public authorities
were largely in favour of the policy measure that
foresees the introduction of standardised modelling quality objectives
(incl. 19 out of 43
replies to the survey).
Other policy measures that found strong support among the public
authorities were the policy measure that requires monitoring long-term trend via indicative
measurements or modelling, the measure on establishing a protocol if a sampling point needs
to be relocated and the requirement to measure continuously certain emerging air pollutants.
The policy measure that refines the minimum information for air quality plans has received as
well largely positive feedback and was well discussed among this stakeholder group. The
policy measure that found least support by this stakeholder group was, the simplification of
the definitions of monitoring stations and/or sampling points with a majority not favouring
this measure and a change of the minimum number of sampling points per air quality zone.
Representatives of
civil society & NGOs
were largely in favour of the policy measure that
foresees the expansion of list of required and/or recommended volatile organic compounds
(incl. 7 out of 12 replies to the survey)
and the requirement of a regular review of the
assessment regime following clear criteria
(incl. 6 out of 12 replies to the survey).
In general,
this stakeholder group was more supportive across all policy measures and the majority of
policy measures received positive feedback and that support. However, policy measures
related to policy area 3 were the least discussed or raised by this stakeholder group. Similarly,
policy measures in relation to intervention area K were hardly discussed by representatives.
The policy measure that allows to use of indicative measurement to substitute fixed
monitoring as part of the assessment was the measure that found the least support among the
stakeholder group
(incl. 7 out of 12 replies not favouring this measure in the survey).
Representatives from
industry & businesses
didn’t strongly discuss or support policy
measures that are included in policy area 3. In the targeted survey, no policy measures was
replied to with “fully” agree by this stakeholder group and in general this policy area had a
low response rate in particular for intervention area G, H, I and J with up to 13 “no reply” or
“no opinion” from out of 14 total replies. Representatives of this group did express being in
favour to a large extent of the policy measure defining further data requirements for sampling
points used for air quality data assessment. The least supported policy measure was a
mandatory provision for up-to-date information on the pollutant concentration for certain air
pollutants for a minimum number of sampling points per air quality zone
(incl. 6 out of 14
replies to the survey).
Representatives from
academia & research
were largely in favour of the policy measure
regarding the requirement of monitoring stations that measure continuously certain emerging
air pollutants at “supersites”
(incl. 16 out of 22 replies to the survey)
followed by the
introduction of standardised modelling quality objectives as a control mechanism
(incl. 14
out of 22 replies to the survey).
The policy measures that were least supported by
representatives of this stakeholder group are: the policy measure which allows the use of
indicative measurements to substitute fixed monitoring in some specified cases and the policy
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2636043_0029.png
measure on simplifying the definitions type of monitoring stations and/or sampling point
locations
(incl. both 13 out of 22 replies to the survey).
The stakeholder group was in general
strongly engaging in this policy area and raised and discussed many policy measures.
Representatives of
EU citizens
think that the policy measures under this policy area are all
almost equally important and regarding feasibility, EU citizens think that all measures are
roughly equally feasible. A general support for improved monitoring and specifically in
relation to ultrafine particles and hydrogen sulphide (in areas with industrial pollution) was
expressed. Additionally, the harmonising of monitored data was also strongly supported. This
stakeholder group also pointed out that for air quality plans a more stringent framework
should be put forward setting out clear requirements and timelines in order to maximise their
effectiveness.
4
4.1
OTHER CONSULTATION ACTIVITIES
Ad-hoc contributions
In total 30 ad-hoc contributions (i.e. position papers, scientific studies and other documents)
from 25 different stakeholders
17
were received throughout the duration of the revision period.
Ad-hoc contributions were evaluated and analysed which policy area and policy option the
ad-hoc contribution was targeting and took the information into account for the Impact
Assessment and legislative proposal. The following table A2.3 lists the organisation names
and further details from the received ad-hoc contributions.
Table A2.3: Ad-hoc contributions
Organisation name
WKO Austrian Federal Economic Chamber
Flanders Environment Agency
Bavarian State Parliament
Deutsche Umwelthilfe e.V.
Hamburg city
Ministry of Transport, Baden-Wuerttemberg
German Federal Environment Agency (UBA)
Ministry of Environment
Finnish Atmosphere and Climate Competence Center
Finnish Meteorological Institute
University of Finland
Po valley regions (Lombardia, Emilia-Romagna, Piemonte, Veneto)
Environment & Resources Authority - Malta
Dutch municipalities (Beverwijk, Heemskerk, Velsen)
Dutch Ministry of Infrastructure and Water Management
Province of Utrecht
Polish NGOs*
Swedish Environmental Protection Agency
Organisation name
Ministry of Climate and Environment/ Norwegian Environment Agency
Organisation name
Member State
Austria
Belgium
Germany
Germany
Germany
Germany
Germany
Estonia
Finland
Finland
Finland
Italy
Malta
Netherlands
Netherlands
Netherlands
Poland
Sweden
Country
Norway
International
Stakeholder type
Industry & business
Public authority
Public authority
Civil society & NGO
Public authority
Public authority
Public authority
Public authority
Academia & research
Public authority
Academia & research
Public authority
Public authority
Public authority
Public authority
Public authority
Civil society & NGO
Public authority
Stakeholder type
Public authority
Stakeholder type
17
Two each from: Federal Environment Agency (UBA Germany), Ministry of Transport, Baden-
Wuerttemberg (Germany), Po valley regions (Italy) and three from Client Earth.
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2636043_0030.png
Table A2.3: Ad-hoc contributions
Organisation name
AQUILA
ClientEarth
ERS and ISEE
Eurocities
FAIRMODE
HEAL and other civil society organisations
Member State
Europe
Europe
Europe
Europe
Europe
Europe
Stakeholder type
Academia & research
Civil society & NGO
Academia & research
Public authority
Academia & research
Civil society & NGO
*Polish Smog Alert, Frank Bold Foundation, European Clean Air Centre, Electric Vehilces Promotion Foundation, Health and
Environment Alliance, Client Earth, Towarzystwo na Rzecz Ziemi, Polski Klub Ekologiczny Okręg Pomorski, Stowarzyszenie
Ekologiczne EKO-UNIA, Fundacja na rzecz Efektywnego Wykorzystania Energii, Stowarzyszenie Partnerstwo dla
Bezpieczeństwa Ruchu Drogowego, Rodzice dla Klimatu, Polski Klub Ekologiczny Okręg Mazowiecki, Koalicja Klimatyczna
4.2
Third EU Clean Air Forum
The
Third EU Clean Air Forum
took place on 18 and 19 November 2022 in Madrid with the
possibility to actively engage also via a smartphone application or watch the event online per
web-stream.
18
Around 200 participants were present in the venue in Madrid and more than
500 participants attended the event online across the EU and other non-EU countries.
Stakeholder groups present at the event were mainly public authorities, environmental and
non-governmental organisations, business associations and organisations, research and
academia institutions and citizens. During the week of the event, the hashtag “#CleanAirEU”
reached close to 27 million accounts on the social networking applications
twitter.com
and
instagram.com
globally.
High-level interventions and panel discussions with a wide range of stakeholders groups
reflected on air quality issues and solutions, expressing further scope to improve the current
legislation. The event focused in two sessions in particular on the “Revision of the Ambient
Air Quality Directives” and “Access to justice and the right to clean air”.
4.3
Inception Impact Assessment
The inception impact assessment was published on 17 December 2020 with a feedback
period until 14 January 2021. Stakeholders were invited to provide feedback on the proposed
inception impact assessment as outlined in the roadmap that was made public on the EU
Have-Your-Say-Portal.
19
A total of 63 stakeholders from 12 Member States provided
feedback on the inception impact assessment as indicated in box A2.6.
Box A2.6: Inception impact assessment - Stakeholders per group and country
Stakeholder per stakeholder group (descending):
Industry & businesses (=25), Civil society & NGOs (=24), EU citizens (=7), Public authorities (=4),
Academia & research (=2) + Others (=1).
18
19
COM (2021),
Third Clean Air Forum Events page
(accessed: 04.08.2022)
COM (2021),
Have your say portal
(accessed: 04.08.2022)
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2636043_0031.png
Stakeholder per country (descending):
BE (=19), DE (=12), FR (=8), ES (=5), PL (=3), NL (=3), IT (=3), DK (=2), AT (=2), SE (=1), SI
(=1), EL (=1) + EEA and non-EU countries.
On policy area 1,
the expressed ambition in the replies were predominantly for a high
ambition level, calling for closer or full alignment of EU standards with the WHO
recommendations.
On policy area 2,
addressing the enforcement and governance shortcomings, the ambition
levels expressed in writing were outbalanced. Stakeholders had strong opinions of ambitions
varying from the opinion that the Ambient Air Quality Directives do not need to be revised at
all to the opinion that compensations for citizens who have to live surrounded by high air
pollution needs to be granted.
On policy area 3,
respondents addressed to a lesser extent issues in regards to this policy
area. Topics that were raised by respondents with asking for high ambition was the need for
more precise criteria for air quality monitoring and to consider a cooperation across different
government levels when implementing air quality measures.
4.4
Fit for Future Platform opinion on the ambient air quality legislation
The Fit for Future Platform is a high-level expert group that helps the European Commission
in its efforts to simplify EU laws and to reduce related unnecessary costs, so as to deliver
maximum benefits to citizens and businesses, in particular small and medium-sized
enterprises. On 12 November 2021 the platform adopted its opinion to the “Ambient air
quality legislation”
20
, which included the following suggestions (references
in brackets refer
to where these suggestions have been addressed in this impact assessment):
Review air quality standards to reflect latest scientific evidence and supplement limit
values with regional exposure reduction targets (addressed in
problem area I);
Ensure coherence of action between different levels of governance to improvement the
effectiveness of air quality measures and the implementation of the Ambient Air Quality
Directives (addressed
in problem area II);
Improve monitoring networks to diminish discrepancies and enhance comparability
across Member States; improve design of air quality plans and promote local/regional
level action
(addressed in problem area III);
Monitoring of pollutants not currently covered by the Ambient Air Quality Directives
such as Ultrafine Particles (PM
0.1
), black carbon and other components of PM, metals,
and ammonia
(addressed in problem area II);
20
COM (2022),
Fit for Future Platform
Opinion reference: 2021/SBGR1/04 (accessed: 04.08.2022)
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2636043_0032.png
Simplify the legislative framework by bringing together directives 2008/50/EC and
2004/107/EC in a single directive
(addressed as part of section 8.3 on administrative
costs and REFIT);
Ensure coherence with EU legislation, including urban and road transport, renewable
energy and agricultural policies
(addressed throughout this impact assessment, including
modelling efforts and Annex 8);
Address emission sources such as tyre and brake wear, non-exhaust traffic related
particles, heavy goods vehicle refrigeration units, heating and power emissions,
agriculture and wood burning
(not directly addressed in this impact assessment, as they
are covered under relevant EU legislation.)
21
5
USE OF STAKEHOLDER FEEDBACK
All of the stakeholder feedback as outlined under the sections here above was part of an
extensive data collection process. The different consultation streams highlighted in this
annex, as well as the modelling of scenarios for evidence gathering were combined in order
to provide input for the impact assessment. The consultation activities aimed at informing the
Ambient Air Quality Directives revision process, either by collecting evidence or by
gathering the views of a broad array of stakeholders. The information gathered during the
open public consultation (section 2.1) contributed to building the problem definition, and to
designing potential (regulatory and non-regulatory) measures, including by seeking to
understand the importance and feasibility of several potential measures according to different
stakeholder groups. The targeted stakeholder survey (section 2.2) built on the results of the
open public consultation and asked more specialised questions on the design, feasibility and
potential impacts of different measures, which contributed to the assessment of these
measures. The inputs gathered during the stakeholder meetings (section 2.3) also informed
the revision process, by giving participants the opportunity to comment on the presentations
given on the preliminary results of the project. Lastly the interviews were undertaken to fill in
the knowledge gaps identified after the analysis of preceded consultation activities (section
2.2).
The data was examined to underpin the assessment of impacts of different policy options and
the feasibility of their implementation. Data was analysed to identify contradictory or
supportive statements and evidence to reach to conclusions for each of the stakeholder groups
individually. In this context, all widely supported views are entirely considered in the final
report, with less widely supported views identified as such.
21
Including Directives
2010/75/EU
(on industrial emissions),
2009/125/EC
(on eco-design), as well as EC
Regulations
443/2009
and
510/2011
(on emission standards for vehicles), Regulations
(EU) 2016/427, (EU)
2016/646,
and
(EU) 2017/1154
(on real driving emissions), Directive
(EU)2016/2284
on the reduction of
national emissions of certain atmospheric pollutants, as well as relevant published or upcoming proposals,
such as on the revision of the Industrial Emissions Directive, and on Euro 7 standards for road vehicles.
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A
NNEX
3: W
HO IS AFFECTED AND HOW
?
1. P
RACTICAL IMPLICATIONS OF THE INITIATIVE
This annex sets out the practical implications of the preferred policy package for the various
types of stakeholders concerned. It describes the possible implications for public authorities
or businesses of complying with the air quality standards and other measures set out in the
revised legislation and indicates the likely costs to be incurred in meeting those, or, where
quantitative information is not available, the nature and magnitude of such costs. It also
presents the implications for the citizens.
Public authorities / Administrations
Increasing the stringency of standards can be expected to lead to an increase in the number of
sites and zones in exceedance in the short term. As such, competent authorities will be
required to develop and implement new or revise existing
air quality plans
in order to put in
place a strategy to meet new standards. These plans will also require ongoing review and
management. Hence, increasing standards will overall imply an increase in the competent
authorities’ administrative burden. The degree to which this would affect each Member State
would vary, provided that some would be closer to meeting new revised standards, while
other would be further away from them. For those standards which could drive a large
number of new exceedances with even a small change (e.g. PM
2.5
, PM
10
, NO
2
and ozone),
administrative costs are likely to be high. Where there is broad compliance with existing and
proposed standards (e.g. SO
2
, CO, benzene, etc.), it could be assumed that administrative
costs would at most be low.
Other sources of potentially high costs include the build-up of air quality
modelling capacity
where this is not developed yet as well as the
installation of new monitoring stations,
especially those for ensuring the additional monitoring of pollutants of emerging concern.
The need to address poor air quality in hot spots requires
action at local level
in particular,
some of which might be of non-technical nature and which would in any case differ
considerably across municipalities and are therefore challenging to estimate.
Preferred policy options
addressing governance and enforcement shortcomings
will entail
costs in relation to changing the way the Ambient Air Quality Directives are implemented
(rather than them resulting from administrative burden of specific policy options suggested).
Increasing the stringency of the existing policy framework will significantly increase the
costs for those administrations currently in breach of the provisions of the Directives.
Conversely, administrations currently compliant with the Ambient Air Quality Directives will
have very limited additional costs other than those related to transition to the new regime.
Overall, total administrative costs are estimated to range from 75 to 106 million Euro per year
in 2030, with
costs in the preferred scenario estimated at 78 million Euro.
These are costs
that fall on public authorities. Some of the adjustment costs (see next sub-section) may fall on
public authorities (such as through procuring materials and infrastructure, building
ownership, changing vehicle fleets), but these have not been estimated separately here.
104
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Businesses and the economy at large
Businesses
and more generally employers will benefit from the reduction of negative health
and (though less significant) non-health impacts associated with poor air quality. The
improvement of air quality expected to follow from adopting the preferred policy package
will have positive knock-on effects on the
productivity
of the EU workforce, both through
reduced mortality and reduced morbidity (the latter causing absence through illness,
including of dependent children, or lower productivity at work). The analysis has
demonstrated that with a 10 μg/m
3
headline limit value for PM
2.5
as part of the preferred
package,
monetised benefits from reduced costs of health impact
are estimated to be 40 or
119 billion EUR (2015 prices) in 2030, depending on the valuation approach chosen.
22
In
either way, these represent a close to 30% decrease in costs compared to the baseline in 2030.
Material and ecosystem impacts
are typically much smaller than health impacts. Benefits
from reduced material damage are projected to amount to almost 200 million EUR in 2030 in
the 10 μg/m
3
scenario compared to the baseline; benefits from reduced crop damage to
254 million EUR, benefits from reduced forest damage to 287 million EUR, benefits from
reduced ecosystem impacts between 706 (low estimate) and 2 117 (high estimate) million
EUR (all 2015 prices).
At the same time, stricter air quality standards require
investments
such as installation of
abatement measures that come at a cost. The costs increase with the stringency of the new
standard. For the 10 µg/m
3
standard,
mitigation (or adjustment) costs
beyond the baseline
amount to around
5.6 billion EUR.
Industry bears most of the costs, followed by agriculture.
These two together bear above two thirds of the total costs. There are
no direct
administrative costs
falling on businesses.
Taking these two sides of the equation together, the
macroeconomic modelling
undertaken
shows that the market
benefits
of improved air quality
outweigh the costs
of abatement
measures and other investments needed to meet stricter EU air quality standards. The key
insight is that all scenarios, including the preferred one,
improve aggregate economic
outcomes
in the EU compared to a situation of unchanged policy, when productivity gains of
clean air are accounted for (the positive impact on the gross domestic product, GDP, and
private consumption increases with the stringency of the scenario). With the exception of
livestock-based agriculture, which sees a small percentage reduction,
all sectors raise output
compared to the baseline. Results further indicate
enhanced competitiveness
of the EU
economy as indicated by an improved trade balanced and higher exports, again with
productivity gains from clean air factored in.
22
In line with the second Clean Air Outlook, results are presented for different approaches to monetising
impacts: a ‘VSL’ or value of statistical life approach, which monetises the number of deaths (yielding the
119 €bn), and a VOLY or value of statistical life year approach (40 €bn), which instead monetises life years
lost.
105
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Citizens and consumers
Citizens will enjoy
health benefits
from improved air quality. The benefits increase, as
expected, with the ambition of the scenario. For PM
2.5
, premature death in the EU-27 caused
by the exposure to air pollution at levels above the WHO guidelines reduces by around 50%
under the 10 μg scenario compared to the baseline in 2030. In the same scenario, the
additional reduction for NO
2
compared to the baseline is 16%. Citizens will further enjoy
benefits from reduced morbidity. A 10 μg headline limit value is projected to reduce the
number of yearly cases of a range of health outcomes caused by the exposure to air pollution
at levels above the WHO guidelines by around 50% in 2030 compared to the baseline.
23
Citizens residing in
hot spots
areas are particularly vulnerable as a result of high exposure to
air pollution and can thus be expected to benefit most from stricter air quality standards. Also
citizens with existing medical conditions and citizens in
sensitive groups
may be at higher
risk due to exposure and will therefore have more to gain on average from improved air
quality. The analysis undertaken shows little distributional differences across scenarios. In
other words, impacts on different age groups remain consistent across scenarios. Citizens
vulnerable due to their lower
socio-economic status
(based on household income,
unemployment rate and lack of higher education) have been shown to be disproportionately
affected by poor air quality and will likewise benefit more on average from reduced air
quality.
24
As with the analysis for sensitive groups, impacts on socio-economic groups remain
consistent across scenarios, with the effects varying by pollutant and socio-economic group.
To meet the targets associated with the preferred package, some of the
overall adjustment
costs
will be borne by households by switching to lower polluting devices such as for
domestic heating. Some change in behaviour would likely be triggered by national or local
strategies to abate pollutant emissions (such as a switch to cleaner modes of transport,
including public transport). The extent of the costs borne by households for such measures
will depend ultimately also on public policy choices made in Member States as regards
financial and investment support mechanisms. There are
no direct administrative costs
falling on citizens.
The
macroeconomic modelling
undertaken shows that on an aggregate level, private
consumption increases compared to the baseline in 2030 across scenarios, including the
preferred one, when productivity gains from clean air are factored in. When taking into
account further market and also non-market effects (avoided health care costs, years of life
lost, loss of utility due to sicknesses etc.), which could not be taken into account in the
macroeconomic modelling undertaken but is addressed separately, the overall benefit would
become even larger.
23
24
These include infant mortality, (chronic) bronchitis in children (in adults), cardiovascular as well as
respiratory hospital admissions, restricted activity days, lost working days, stroke, lung cancer and asthma
in children.
EEA (2019),
EEA Report No 22/2018
(accessed: 10.06.2022)
106
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An
increased stringency of the legislative framework,
as per the preferred policy options
addressing governance and enforcement shortcomings will ensure higher compliance with the
set objectives, and thus translate into environmental, social, and economic benefits for the
wider public.
Other
The preferred policy package will
improve
air quality assessments done through monitoring
and modelling, as well as
data availability
on air quality. This will be helpful for
researchers
that work on air quality monitoring and modelling, as well as for
civil society
organisations
that work on improving air quality through awareness raising campaigns and
other actions.
2. S
UMMARY OF COSTS AND BENEFITS
Table A3.1 - (I) Overview of Benefits (total for all provisions) compared to the baseline – Preferred
Option
Description
Amount
Beneficiaries
Direct benefits
Reduced health
impacts
40 or 119 billion EUR
(2015 prices) in 2030,
depending on the valuation approach chosen.
25
These represent a close to 30% decrease in costs
compared to the baseline in 2030.
Direct health benefits
reduced public costs
health care spending;
businesses
from
productivity / reduced
days.
for citizens;
due to less
benefits for
increased
lost working
Reduced material
damage
196 million EUR
(2015 prices) in 2030
Beneficiaries depend on ownership
of buildings, including of historic
ones, and on who incurs their
running costs.
Increased crop yields benefit the
agricultural sector and possibly
consumers if productivity gains are
passed on through lower prices.
In the case of productive forests,
increased productivity of forests
benefits forest owners/managers and
possibly consumers if productivity
gains are passed on through lower
prices for wood-based products.
Reduced crop
damage
254 million EUR
(2015 prices) in 2030
Reduced forest
damage
287 million EUR
(2015 prices) in 2030
Reduced ecosystem
impacts
Between
706
(low
estimate)
and
2 117
(high Benefits for biodiversity, benefits for
estimate)
million EUR
(2015 prices) in 2030
those sectors relying on ecosystem
services.
Indirect benefits / co-benefits for other policies
25
See previous section.
107
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This part of the table summarises the likely indirect benefits of more ambitious clean air policy including the
co-benefits for other EU policy objectives. This is done in a qualitative way, as the quantification undertaken
here has focused on estimating the direct benefits, indirect ones being much more uncertain.
Climate
Generally, more action will be needed to clean Society at large will benefit
energy supply and mobility to attain limit
values. A move to clean, renewable energy
sources and propulsion systems will reduce air
pollutants and greenhouse gas emissions in
parallel. Stricter air quality standards bring co-
benefits in the form of reduction of black carbon
(BC), a short-lived climate forcer (SLCF),
mostly achieved in residential heating sector,
introducing cleaner burning technology, and
effective enforcement of ban of field burning of
agricultural residues.
Noise
As above, a move to cleaner modes of transport
will trigger co-benefits for noise (electric power
trains being significantly less noisy than internal
combustion engines, and soft transport modes
being less noisy than motorised ones).
Those currently most affected by
noise pollution notably from road
transport, i.e. those living along busy
roads.
Indoor air quality
Indoor air quality depends to a large extent on
As for direct health impacts.
the quality of ambient (outdoor) air and would
therefore improve with stricter air quality
standards.
Poor air quality disproportionally affects citizens Groups of society of lower socio-
of lower socio-economic status, as well as those economic status, vulnerable groups.
with pre-existing conditions and children.
26
Consequently, introducing stricter air quality
standards can be expected to have indirect
redistributional effects in benefitting these
groups most.
European citizens care strongly about air
As for direct health impacts.
quality.
27
/
28
Besides the quantified health
impacts of clean air, indirect benefits are likely
to accrue from citizens awareness of breathing
cleaner air and living in a more healthy
environment.
Equality
Quality of life
Administrative cost savings related to the ‘one in, one out’ approach
The Ambient Air Quality Directives
do not impose any direct administrative costs on consumers and
businesses
(while these do bear important adjustment costs, i.e. due to measures needed to achieve EU air
quality standards), therefore the one-in-one-out approach is not applicable (as explained in the main report
section 8.4).
II. Overview of administrative costs and the one-in-one-out scheme – Preferred option
26
27
28
EEA (2019),
EEA Report No 22/2018
(accessed: 10.06.2022)
Special Eurobarometer 497
(accessed: 10.06.2022)
COM (2021),
Open Public Consultation on “Air quality – revision of EU rules”
(accessed: 10.06.2022)
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The following provides an overview of the costs of the different policy options that form part
of the preferred package. As presented in Section 6 of the main report, a 10 µg/m
3
target for
annual mean PM
2.5
(policy-option I-2) amounts to
adjustment or mitigation costs of
5.6 billion Euro per year in 2030,
with the most impacted sectors being industry,
households and livestock.
To assess the potential administrative burden placed on different actors, the EU’s Better
Regulation Toolbox Standard Cost Model (SCM)
29
was used. The SCM uses information on:
number of activities required, with the time required per activity and the cost per unit of time
spent. The aim is to estimate additional costs (or cost reductions) of new policy options
compared to the baseline scenario.
The following tables provides an overview of administrative costs related to monitoring,
assessment, implementation and enforcement. The
total administrative costs are estimated
to range from 75 to 106 million Euro per year in 2030,
increasing with the stringency of
the scenario, with costs in the preferred scenario estimated at 78 million Euro per year.
Administrative costs estimates include:
costs for all policy options and their individual measures included in the set of preferred
policy options that are not linked to the level of ambition of revised EU air quality
standards, which add up to about
75 million Euro
per year – this includes approximately
4.8 million Euro
per year related to better implementation and communication (see Table
A3.1), and a further
70.3 million Euro
per year related to improved monitoring and
assessment (see Table A3.2);
costs linked to the development of air quality plans, which depend on the number of
exceedances above EU air quality standards to be expected in the target year 2030. This
component hence depends on the level of ambition assumed via policy options I-1, I-2 or
I-3, which adds up to
between 1 and 31 million Euro
per year. Table A3.3 provides an
overview of costs related to exceedances per pollutant – based on assumption of residual
exceedances based on the modelling that underpins this impact assessment.
Costs for consumers and businesses are represented jointly as there are no direct regulatory
requirements for businesses stemming from the Ambient Air Quality Directives. This also
means that there are
no direct administrative costs to be borne by business or citizens.
This means there is no need to look at potential off-setting measures as part of the
Commission’s commitment to the
‘one-in-one-out’
scheme, and therefore the tables below
do not contain the part of the template reserved for “costs related to the ‘one in, one out’
approach”.
Hence, most costs for consumer and businesses are
indirect costs
that cannot always be
broken down into who will bear what share. The costs most clearly attributable are
direct
29
COM (2022),
Tool #60 - the standard cost model for estimating administrative costs
(accessed: 10.06.2022)
109
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administrative and enforcement costs
falling on the competent authorities in Member States.
Table A3.2 – (II.1) Overview of costs – Assessment of administrative costs and burden for specific policy
measures preferred policy options (note that one-off costs have been annualized assuming a period of 20 years
and a discount rate of 3%)
30
For public authorities
(€)
One-off
A1:
Introduce review
triggered by scientific
progress
A2: Introduce review
triggered by technical
progress
A3:
Introduce option to
notify stricter standards
A4:
Introduce a list of
priority pollutants
B1:
Introduce additional
short-term standards
B2:
Introduce additional
alert/information
thresholds
B3:
Revise definition of
average exposure
standards
B4:
Introduce guidance on
addressing
exceedances
B5:
Introduce limit values
for additional air
pollutants
C1:
Revise obligations
triggered by
exceedances
C2:
Revise/clarify definition
of ‘as short as possible’
C3:
Revise short-term
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
Low
For consumers
& business (€)
One-off
-
Total administrative
costs (€)
Recurrent
Low
Recurrent
-
Low
Low
Low
-
-
Not part of preferred
option
Low
Low
-
-
Low
Low
Low
-
-
Not part of preferred
option
Low
Low
-
-
Low
Low
Low
-
-
Low
Low
Low
-
-
Low
Low
Low
-
-
Low
Low
Low
-
-
Low
600k
Low
-
-
600 000
600k
Low
-
-
600 000
30k
Low
-
-
30 000
30
This and following tables categorise costs as follows: ‘low’ means costs of <100k, ‘medium’ 100k to 1
million, high >1 million EUR.
110
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Table A3.2 – (II.1) Overview of costs – Assessment of administrative costs and burden for specific policy
measures preferred policy options (note that one-off costs have been annualized assuming a period of 20 years
and a discount rate of 3%)
30
For public authorities
(€)
One-off
action plans & air
quality plans
C4:
Introduce additional
short-term action plans
C5:
Introduce requirement
to update air quality
plans
D1:
Revise requirements to
involve stakeholders
D2:
Introduce a ‘one zone,
one plan’ requirement
E1:
Introduce minimum
levels for financial
penalties
E2:
Introduce right to health
damage compensation
E3:
Introduce a fund to be
fed by penalties paid
E4:
Introduce an explicit
‘access to justice’
clause
F1:
Revise provisions
related to up-to-date
data
F2:
Introduce requirement
to provide AQ health
data
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
For consumers
& business (€)
One-off
Recurrent
Total administrative
costs (€)
Recurrent
50k
Low
-
-
50 000
Low
2400k
-
-
2 400 000
320k
Low
-
-
320 000
600k
Low
-
-
Not part of preferred
option
Low
Low
-
-
Low
Low
Low
-
-
Low
Low
Low
-
-
Not part of preferred
option
Low
Low
-
-
Low
140k
640k
-
-
780 000
Low
Low
-
-
Low
F3:
Direct
Introduce use of specific
administrative and
communication
enforcement costs
channels
F4:
Introduce requirements
for harmonised AQ
index
Direct
administrative and
enforcement costs
60k
1280k
-
-
Not part of preferred
option
10k
Low
-
-
10 000
SUB-TOTAL
4 790 000
111
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Table A3.3 – (II.2) Overview of costs – Assessment of administrative costs and burden for specific policy
measures preferred policy options (note that one-off costs have been annualized assuming a period of 20 years
and a discount rate of 3%)
31
For public authorities
(€)
One-off
G1:
Revise rules related to
indicative sampling
points
G2:
Introduce requirements
for AQ modelling
G3:
Revise rules for regular
review of AQ
assessment
H1:
Revise minimum
number of sampling
points
H2:
Simplify combined
PM
10
/PM
2.5
monitoring
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
1 070k
For consumers
& business (€)
One-off
-
Total administrative
costs (€)
Recurrent
Low
Recurrent
-
1 070 000
320k
2 230k
-
-
2 550 000
Low
Low
-
-
Not part of preferred option
540k
2 100k
-
-
2 640 000
230k
2 780k
-
-
3 010 000
H3:
Direct
Simplify the definitions
administrative and
of sampling points types enforcement costs
I1:
Introduce obligations to
maintain sampling
points
I2:
Introduce obligations to
monitor long-term
trends
I3:
Introduce a protocol for
relocated sampling
points
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
200k
Low
-
-
Not part of preferred option
Low
Low
-
-
Low
Low
Low
-
-
Not part of preferred option
50k
Low
-
-
50 000
J1:
Direct
Revise macro-scale
administrative and
siting of sampling points enforcement costs
J2:
Direct
Revise micro-scale
administrative and
siting of sampling points enforcement costs
J3:
Introduce obligation for
spatial
Direct
administrative and
enforcement costs
150k
Low
-
-
150 000
150k
Low
-
-
150 000
370k
2 230k
-
-
2 600 000
31
This and following tables categorise costs as follows: ‘low’ means costs of <100k, ‘medium’ 100k to 1
million, high >1 million EUR.
112
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Table A3.3 – (II.2) Overview of costs – Assessment of administrative costs and burden for specific policy
measures preferred policy options (note that one-off costs have been annualized assuming a period of 20 years
and a discount rate of 3%)
31
representativeness
K1:
Revise AQ monitoring
data quality objectives
K2:
Introduce up-to-date
data at all sampling
points
K3:
Introduce AQ modelling
data quality objectives
K4:
Revise approach to AQ
assessment uncertainty
L1:
Introduce concept of
monitoring at ‘super-
sites’
L2:
Introduce obligations to
monitor more pollutants
L3:
Revise list of VOC to
monitor
M1:
Introduce methodology
to assess
transboundary
M2:
Revise obligations for
transboundary
cooperation
M3:
Revise the information
in air quality plans
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
Direct
administrative and
enforcement costs
100k
Low
-
-
100 000
140k
640k
-
-
780 000
20k
Low
-
-
20 000
100k
Low
-
-
100 000
1 080k
5 400k
-
-
6 480 000
4 390k
45 000k
-
-
49 390 000
1 690k
25 310k
-
-
Not part of preferred option
600k
Low
-
-
600 000
Low
Low
-
-
Low
600k
Low
-
-
600 000
SUB-TOTAL
70 290 000
Table A3.4 – (II.3) Overview of costs – Assessment of administrative costs and burden for specific policy
measures preferred policy options (note that one-off costs have been annualized assuming a period of 20 years
and a discount rate of 3%)
32
For public authorities (€)
For consumers
& business (€)
Total administrative costs
(€)
32
This and following tables categorise costs as follows: ‘low’ means costs of <100k, ‘medium’ 100k to 1
million, high >1 million EUR.
113
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Table A3.4 – (II.3) Overview of costs – Assessment of administrative costs and burden for specific policy
measures preferred policy options (note that one-off costs have been annualized assuming a period of 20 years
and a discount rate of 3%)
32
One-off
O1:
Revise standards
for annual PM
2.5
O2:
Introduce
standards for
daily PM
2.5
O3:
Revise average
exposure
standards for
PM
2.5
P1:
Revise standards
for annual PM
10
P2:
Revise standards
for daily PM
10
P3:
Introduce average
exposure
standards for
PM
10
Q1:
Revise standards
for annual NO
2
Q2:
Revise/introduce
standards for
hourly/daily NO
2
Q3:
Introduce average
exposure
standards for NO
2
R1:
Introduce
standards for
peak-season O
3
R2:
Revise standards
for 8-hour O
3
R3:
Introduce average
exposure
standards for O
3
S1:
Revise standards
for annual SO
2
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Recurrent
One-off
Recurrent
High
(I-1)
6870k
Central
(I-2)
200k
Low
(I-3)
10k
200k
-
-
-
200k
-
-
-
6870k
200k
10k
240k
-
-
-
340k
240k
140k
200k
-
-
-
760k
200k
20k
200k
-
-
-
760k
200k
20k
240k
-
-
-
340k
240k
150k
80k
-
-
-
5 540k
80k
50k
80k
-
-
-
5 540k
80k
50k
240k
-
-
-
340k
240k
135k
Low
-
-
-
Low
Low
Low
Low
-
-
-
Low
Low
Low
240k
-
-
-
340k
240k
135k
Low
-
-
-
Low
Low
Low
114
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Table A3.4 – (II.3) Overview of costs – Assessment of administrative costs and burden for specific policy
measures preferred policy options (note that one-off costs have been annualized assuming a period of 20 years
and a discount rate of 3%)
32
S2:
Revise standards
for daily/hourly
SO
2
T1:
Revise standards
for daily/8-hour
CO
U1:
Revise standards
for annual
benzene
V1:
Revise standards
for annual
benzo(a)pyrene
W1:
Revise standards
for annual lead
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Low
-
-
-
Low
Low
Low
Low
-
-
-
Low
Low
Low
Low
-
-
-
Low
Low
Low
1 210k
-
-
-
3 350k
1 210k
390k
Low
-
-
-
Low
Low
Low
Direct
X1:
administrative and
Revise standards
enforcement
for annual arsenic
costs
Y1:
Revise standards
for annual
cadmium
Z1:
Revise standards
for annual nickel
Ø
1:
Introduce
standards for
additional air
pollutants
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Direct
administrative and
enforcement
costs
Low
-
-
-
Low
Low
Low
Low
-
-
-
Low
Low
Low
Low
-
-
-
Low
Low
Low
Low
Low
-
-
Not part of preferred option
SUB-TOTAL
31 050k
3 130k
1 110k
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3. R
ELEVANT SUSTAINABLE DEVELOPMENT GOALS
Table A3.5 – (III) Overview of relevant Sustainable Development Goals (SDG) – Preferred Option(s)
Relevant SDG
Expected progress towards the Goal
Comments
SDG 3 – Establish
Good Health and
Well-Being
A more effective Ambient Air Quality
Note specifically the direct
Directive would lead to better health outcomes, contribution to the 2030 goal target for
and thereby directly contribute to SDG 3.
this SDG to “substantially reduce the
number of deaths and illnesses from
hazardous chemicals and air, water and
soil pollution and contamination”
More ambitious air quality standards will
require investing in clean energy, which will
contribute to SDG 7.
Note specifically the contribution to
the 2030 goal targets for this SDG to
improve energy efficiency and
increase the share of renewable and
clean energy
SDG 7 – Grow
Affordable and
Clean Energy
SDG 10 Reduce
Inequality
While more ambitious air quality standards will Note that this is an indirect
not reduce income inequality, they can address contribution
consequences of these inequalities, namely
ensuring cleaner air in particular for
socioeconomically disadvantaged and
vulnerable groups, who often live in more
polluted areas.
More ambitious air quality standards will
Note specifically the 2030 goal targets
require investment in attractive, affordable,
for this SDG to
clean public transport and infrastructure for safe
reduce the adverse per capita
walking and cycling; in upgrading the energy
environmental impact of cities,
efficiency of buildings, implementing
including by paying special
renewable heating and cooling, and in
attention to air quality and
improvements to urban planning. All of these
municipal and other waste
measures contribute to SDG 11.
management
provide access to safe, affordable,
accessible and sustainable transport
systems for all, improving road
safety, notably by expanding public
transport
Measures needed to attain more ambitious air
quality standards have important co-benefits for
climate action, e.g. implementing non-
combustion renewable energy and improving
energy efficiency.
Note in particular the goal target for
this SDG to integrate climate change
measures into national policies,
strategies and planning
SDG 11 – Mobilize
Sustainable Cities
and Communities
SDG 13 – Organize
Climate Action
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A
NNEX
4: A
NALYTICAL METHODS
1. O
VERVIEW
A range of interventions (or policy measures) have been defined to revise various elements of
the Ambient Air Quality Directives. Each intervention would have a number of associated
impacts, with the exact impacts, their size and significance depending on each individual
intervention. Based on the Better Regulation Guidelines,
33
these interventions have been
compared on the basis of how they address the objectives considering their effectiveness,
efficiency and coherence.
Twelve indicators (see Table A4.1) have been defined to capture and present the key
economic, environmental, and social impacts associated with the interventions being
considered. All interventions have been appraised against this set of indicators, to ensure
consistency in the analysis and presentation of results.
Table A4.1
- Twelve indicators used as basis for in-depth assessment
Broad impact
category
Air
pollutant
concentrations
Environmental
impacts
Indicator
Concentration levels of air pollutants, at (a) background locations, and (b) ‘hot-
spot’ (incl. both traffic and industry-related) locations, and their development over
time.
Health impacts of air pollution, for example the health impacts resulting from
exposure to particulate matter (PM
2.5
and/or PM
10
), nitrogen dioxide and ozone.
Ecosystem impacts of air pollution, including acidification, eutrophication, ozone
damage to vegetation and agricultural yields.
Links between air pollution and climate change, including increased ozone levels
due to global warming, and co-benefits or trade-offs between climate and air
pollution abatement measures.
Cost to society due to air pollution, including health and healthcare impacts and
costs, lost working days, crop and animal value loss, losses to other assets and
other costs avoided by taking action to reduce air pollution.
Measures needed to meet EU air quality standards - and their costs, including
costs for key economic sectors, and regional differences across the EU of the
costs and benefits of the air pollution abatement measures.
Positive and negative impacts on the EU’s international competitiveness, including
tapping into innovation potential for clean air technologies.
Effects of air pollution on sensitive population groups, including children, pregnant
women, elderly citizens and those suffering from pre-existing conditions.
Societal impacts of air pollution and societal impacts of air pollution abatement
measures, including resulting inequalities (i.e. who is most affected, who bears the
costs).
Effects of measures to address air pollution on employment.
Synergies with other goals of the EU Zero Pollution Action Plan on air, water and
soil. This includes premature death reduction (indicator 2) and ecosystem impact
(indicator 3) goals. It additionally reflects the synergic role of indoor air pollution
(notably in terms of exposure and health impacts) or co-benefits in reducing noise
pollution. Also considers synergies with climate action.
Administrative burden of air quality management, in particular as relates to air
quality assessment regimes (including monitoring, modelling, and reporting of
related data)
Indicator
#
1
2
3
4
Economic
impacts
5
6
7
8
9
Social impacts
Synergies
10
11
Administrative
burden
12
33
SWD(2021) 305 final
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Across each of these specific indicators, available evidence on the effectiveness, efficiency
and coherence of the interventions has been collated, assessed and, where possible, quantified
in comparison to the baseline. Where quantification was not possible, impacts were assessed
in a qualitative way, clearly indicating the type of the most important impacts and their likely
magnitude.
To support the assessment of impacts, three main sources of evidence were used: quantitative
modelling, in particular focusing on the impacts of different air quality standards, detailed
literature review and extensive stakeholder engagement. The remainder of this Annex focuses
on presenting in further detail the approach taken to the quantitative modelling.
2.
Q
UANTITATIVE MODELLING OF AIR POLLUTANT STANDARDS
This section contains a general introduction to the modelling framework deployed in the
support study for this impact assessment and a description of the most important elements of
relevance for the assessment of policy options. More detailed descriptions including data
sources for various underlying assumptions used in the modelling can be found in the
annexes to the support study.
2.1
Introduction of the modelling framework
Quantitative modelling has been conducted with a state-of-the-art modelling framework,
including: the
Greenhouse gas – Air pollution Interactions and Synergies
(GAINS) model
and MET Norway’s chemical transport model (EMEP CTM) with the uEMEP downscaling
extension for fine resolution. This modelling assesses a number of effects, in particular: air
pollutant emissions, concentrations, health and ecosystem impacts, feasibility to attain
particular air quality targets as well as respective measures and their costs.
The
GAINS integrated assessment model,
developed at the International Institute for
Applied Systems Analysis (IIASA), addresses air pollution impacts on human health from
fine particulate matter (PM
2.5
) and ground level ozone (O
3
), vegetation damage caused by
ground level ozone, the acidification of terrestrial and aquatic ecosystems and excess nitrogen
deposition on soils. GAINS brings together data on economic development and structure,
control potential and costs of emission sources, the formation and dispersion in the
atmosphere of - as well as the inter-relations between - pollutants such as sulphur dioxide
(SO
2
), nitrogen-oxides (NO
x
), particulate matter (PM), non-methane volatile organic
compounds (NMVOCs) and ammonia (NH
3
). GAINS assesses more than 1 000 emission
control measures for all EU Member States, computes the atmospheric dispersion of
pollutants and analyses the costs and environmental impacts of pollution control strategies. In
its optimisation mode, GAINS identifies the cost-effective emission control strategies that
can be used to inform policy processes and international negotiations on mitigation of
atmospheric air pollutants.
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The
EMEP CTM
is a state of the art atmospheric chemistry transport model, and includes a
recently developed novel, but well documented,
34
/
35
/
36
uEMEP downscaling module that
allows the estimation of ambient air pollution concentrations down to a grid resolution of
approximately 250x250 m
2
for the whole of Europe. Downscaling is carried out where
suitable high resolution emissions proxies are available. This includes the emissions from
traffic, shipping, stationary combustion, off road combustion and aviation.
Annual mean concentrations are calculated with the EMEP model under different policy
scenarios for the following pollutants and indicators: SO
2
, NO
2
and NO
X
, PM
2.5,
PM
10
,
NMVOC, O
3
, SOMO35, NH
3
, BaP, benzene and carbon monoxide (CO). Downscaling is
applied to a selection of these pollutants (PM
2.5
, PM
10
, NO
2
, BaP, Benzene, CO and ozone)
on annual mean concentrations. BaP is not normally explicitly modelled by the EMEP
modelling suite. However, a BaP emissions inventory is available for present day emissions,
though no scenario trends are available. By applying the same trends used for PM
2.5
emissions to the BaP emissions, BaP can then be modelled explicitly by the EMEP modelling
suite for all scenarios. Heavy metals, regulated under the Ambient Air Quality Directives
cannot be quantitatively assessed with the EMEP CTM modelling suite. Therefore, these
have been considered outside of the integrated modelling system through statistical analysis,
by comparing different concentration thresholds to monitoring data for 2019.
37
The integrated GAINS and EMEP models provide analysis of many of the impacts
considered here. That said, some further calculations and post-processing was required to
bring out further impacts associated with the interventions. This was the case for the
assessment of health, social cost, and impacts on vulnerable groups. This also includes
analysis by linking the GAINS model with the
JRC-GEM-E3 model
to explore macro-
economic, GDP and employment effects. GEM-E3 is an applied general equilibrium model
that covers the interactions between the economy, the energy system and the environment. It
represents the whole economy and the interactions between key actors: firms, households and
governments in the EU and in the rest of the world. Annex 5 (section 7 on macro-economic
impacts) provides some further details on how GAINS results feed into GEM-E3.
All impacts are assessed compared to the baseline, in both a mid-term (2030) and long-term
(2050) time horizon. The overall quantitative modelling flow is summarised in Figure A4.1.
34
35
36
37
Denby, B. R., Gauss, M., Wind, P., Mu, Q., Grøtting Wærsted, E., Fagerli, H., Valdebenito, A., and Klein,
H. (2020): Description of the uEMEP_v5 downscaling approach for the EMEP MSC-W chemistry transport
model, Geosci. Model Dev., 13, 6303–6323,
Description of the uEMEP_v5 downscaling approach for the
EMEP MSC-W chemistry transport model, Geosci. Model Dev., 13, 6303–6323
(accessed: 10.06.2022)
Mu, Q., Denby, B. R., Wærsted, E. G., and Fagerli, H. (2022): Downscaling of air pollutants in Europe using
uEMEP_v6, Geosci. Model Dev., 15, 449–465,
Downscaling of air pollutants in Europe using uEMEP_v6,
Geosci. Model Dev., 15, 449–465
(accessed: 10.06.2022)
Transboundary particulate matter, photo-oxidants, acidifying and eutrophying components.
EMEP Status
Report 2020
(accessed: 10.06.2022)
See annex 4 of the underlying support study for more detail.
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Figure A4.1
– Modelling framework applied to assess the twelve indicators
2.2
Application of GAINS
The policy options defined to address health and environmental outcome shortcomings
(corresponding to policy area 1 in the support study) aim to attain closer alignment of air
quality standards with the recently published WHO Air Quality Guidelines. The underlying
analysis has assessed different
policy scenarios
(in line with the different policy options
presented in this impact assessment) corresponding to different ambition levels. In addition, a
Maximum (technically) Feasible Reductions
(MFR,
or
MTFR) scenario
was generated for
both target years 2030 and 2050, which minimises emissions taking into account all available
technologies irrespective of costs and thus represents the lower limit of emissions achievable
with technical measures only.
The ‘headline indicator’ of the extent of the alignment with the revised WHO Air Quality
Guidelines (and for expressing the level of ambition of different scenarios assessed) is the
annual mean concentration of fine particulate matter (PM
2.5
), as this air pollutant at its current
levels is associated with the most harmful effects on human health. The scenarios are defined
based on assumptions of different PM
2.5
levels as a headline indicator, but will also include
assumptions for each pollutant covered by the current Ambient Air Quality Directives.
Results for the different policy scenarios have been assessed against a
baseline,
which
includes existing and (in line with the Better Regulation guidelines) policies proposed.
Annex 5 describes the baseline assumptions including the policies included.
The emission scenarios have been developed with the optimisation module of the GAINS
model, which has been applied to identify cost-optimal strategies to achieve ambient PM
2.5
concentrations in compliance with ambient air quality standards, where this is technically
feasible through the model optimisation. The GAINS model includes a linearised
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approximation of the EMEP atmospheric model relating emissions of PM precursor
pollutants to ambient concentrations on a (roughly) 7x7 km
2
grid. GAINS can determine the
cost optimal solution to achieve certain targets on ambient air quality. For the present
analysis, the optimisation analysis is constrained to achieve PM
2.5
compliance at this grid
level. In case the model finds no feasible solution for achieving compliance in all grid cells,
the constraints are relaxed to allow for a certain fraction of exceeding areas where additional
local policy measures will be needed to achieve compliance. For such grid cells, the
optimisation requires at least a 90% improvement of ambient PM
2.5
concentrations towards
the concentration levels attained in the maximum feasible reductions (MTFR) case. The cost
optimisation is thus used to suggest the most cost effective national or EU wide emission
control measures to bring ambient concentrations close to the ambient air quality limit values.
Given GAINS contains simplified atmospheric calculations based on a linear approximation
of the EMEP CTM at 7 km resolution, it can only assess compliance at background level. It is
important to note that compliance at hot spots, e.g., in busy street canyons, may require
supplementary local measures (e.g., traffic restrictions, which cannot always be reflected in
the GAINS model). To some degree, the question of compliance at hot spots may be
addressed by adding a margin to the background PM
2.5
concentration levels in the cost
optimisation.
For any of the scenarios, if a feasible solution for attaining PM
2.5
standards at background
level is found, GAINS quantifies the related emissions of, at least, PM
2.5
, SO
2
, NO
X
, NH
3
,
NMVOC, and CO in each Member State and economic sector. These are then fed into the
EMEP CTM and uEMEP downscaling scheme to calculate ambient concentrations of air
pollutants at fine resolution.
While the PM
2.5
objectives are the driving indicator defining the different scenarios, different
ambition levels for PM
2.5
will have implications for the concentration levels of other air
pollutants. Optimising for concentrations of multiple pollutants has not been considered
feasible in the framework of this impact assessment. However, from the high-resolution
calculations of the EMEP CTM, ambient concentrations of all pollutants covered in the
model are estimated for the scenarios optimising around PM
2.5
. This allows quantification of
the range of feasible concentration limits for other pollutants under each scenario.
2.3
Concentration modelling methodology
Concentration modelling of the emission scenarios provided by GAINS is carried out using
the EMEP CTM and uEMEP models. uEMEP calculates only annual mean concentrations.
Exposure calculations using the modelled concentrations are carried out at grid resolution of
approximately 250x250 m
2
, matching the resolution of the available population density data,
and these are used for the health impact assessment. Further to the exposure calculations,
additional calculations at higher resolution, 50x50m2, are carried out to ascertain the impact
of the emission scenarios at measurement station sites across Europe. Changes in
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concentrations at measurement sites are used to assess the possible level of attainment at
these sites, in relation to the currently observed concentrations. All scenario simulations were
using meteorological conditions for 2018.
38
Concentrations at individual stations cannot be expected to be perfectly matched with a
Europe wide modelling approach. However robust statements about the likely distribution of
concentration levels across stations can be made. Although no specific street canyon module
was employed, experience has shown that concentrations generated with uEMEP for PM
2.5
,
PM
10
, NO
X
and NO
2
are comparable to measured roadside concentrations. For this impact
assessment, the downscaling was extended to include O
3
, benzene and CO.
The analysis was limited to annual mean concentrations. For SO
2
and the indicators that
require temporal resolutions higher than annual mean, the EMEP model is used without
downscaling. For the downscaled compounds of NO
2
, PM
2.5
and PM
10
, statistical
relationships based on observed concentrations are used to infer statements about likely
compliance with short-term daily limit values, such as done in previous work for the
Commission on the Thematic Strategy on Air Pollution
39
. No assessment of hourly indicators
is carried out.
Benzo(a)pyrene (BaP) remains a problem in several countries in Europe and is mostly related
to residential sector emissions (wood and coal combustion in stoves and small boilers). While
BaP is not normally explicitly modelled by the tools used for this analysis, the analysis did
include BaP using current day BaP emission inventories and linked them to PM
2.5
emission
scenarios to provide a quantitative assessment of BaP concentrations. This approach assumes
that the ratio of BaP in PM
2.5
will not change for any of the scenarios.
2.4
Assessment of health impacts
The assessment includes premature mortality caused by long-term exposure to particulate
matter (PM) and nitrogen dioxide (NO
2
), mortality caused by ozone (O
3
) peaks, and an
estimate for the morbidity related to long-term and short-term exposure to particulate matter.
The WHO updated its Air Quality Guidelines in 2021. In the process of the update, also the
systematic reviews on the current scientific knowledge concerning the
mortality
related to
exposure to air pollution have been updated, leading in turn to updated concentration
response functions. The latest WHO relationships are deployed in this analysis. The
premature mortality are also estimated per age group (one-year interval). The analysis
combines these estimates with the life expectancy (which can vary across Member States)
from Eurostat, to assess the number of years of life lost (YLL). For future years, the evolution
of the population is considered via the Eurostat projections.
To assess impacts on
morbidity,
the approach taken here is based on that taken in the second
Clean Air Outlook, which in turn based its method on the health pathways and concentration
38
39
In addition, control runs for the 2015 baseline scenario were performed using meteorological data for 2015.
See IIASA,
Thematic Strategy on Air Pollution (TSAP) Reports
(accessed: 15.06.2022)
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response functions (CRF) recommended by the WHO in its Health risks of air pollution in
Europe (HRAPIE) reports.
40
Acknowledging that there have been developments in the
underlying evidence base since HRAPIE, but that the WHO has not undertaken a
comprehensive recent review of morbidity pathways, a targeted review of literature was
undertaken in preparation of the support study to explore whether there are other pathways
for which evidence is stronger. The analysis only considers morbidity pathways associated
with exposure to PM
2.5
.
In summary, this yields a three-tiered health impact assessment:
1.
2.
premature mortality caused by the long-term exposure to air pollution using the
concentration response functions (CRF) recommended by the WHO;
morbidity caused by long-term and short-term exposure based on the HRAPIE
recommendations from 2013 (chronic bronchitis in adults, bronchitis symptoms in
children, cardiovascular hospital admissions, respiratory hospital admissions, infant
mortality, restricted activity days and lost working-days);
morbidity effects beyond HRAPIE, to incorporate new insights that became apparent
after the 2013 HRAPIE study, and to provide a more complete overview of the health
impact due to air pollution. This covers three additional health outcomes in the primary
analysis (asthma in children, lung cancer, stroke (CVA)), and three additional health
effects in sensitivity analysis (COPD
41
, Diabetes Mellitus Type 2 and myocardial
infarction).
3.
For the main scenario analysis, quantification of health impacts for comparing the benefits of
different policy options
is limited to the impact of air pollution concentrations in excess of
the revised WHO Air Quality Guidelines
(from 2021). This approach has been adopted
given that:
The guideline exposure levels have been subject to extensive review work from WHO
and represent an up-to-date overview of scientific knowledge on the subject, including on
levels above which the health impacts are well documented;
There is added uncertainty in the applicability of concentration response functions below
the guideline exposure levels suggested by the WHO (also note that below these levels
the contribution of natural sources of air pollution becomes more significant).
It is acknowledged, however, that this approach likely
underestimates
the total impact of air
pollution on health (and thus also the likely benefits of action to improve air quality). For this
40
41
See WHO (2013),
Health risks of air pollution in Europe – HRAPIE project Recommendations for
concentration–response functions for cost–benefit analysis of particulate matter, ozone and nitrogen dioxide
(accessed: 15.06.2022)
Chronic obstructive pulmonary disease; COPD impacts are not included in the aggregated results for the
valuation of health impacts (as per Annex 5.5) given concerns about the overlap with chronic bronchitis.
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reason, further quantification has been carried out to inform sensitivity runs (results of which
are available in the support study).
This approach of assessing impacts above WHO Air Quality Guidelines levels is consistent
with the approach the EEA adopts in its latest briefings on air quality in Europe
42
. It is also
consistent with the approach followed in the preparation of the forthcoming Third Clean Air
Outlook (publication foreseen for end 2022).
2.5
Monetisation of health and non-health impacts
Calculating the costs to society of air pollution is a means of monetising the effects of air
pollution, such that they can be more readily compared to the costs of mitigation action. To
estimate the costs to society, the health impacts calculated in the previous step (such as
number of deaths and of adverse health outcomes) were combined these with monetary
impact values to capture the impact on: lost utility or welfare, lost labour (or productivity)
and health care costs.
For
human health impacts,
the monetary values applied in the second Clean Air Outlook are
used. The values are based on an extensive literature review of the latest approaches by
organisations such as the OECD. The second Clean Air Outlook involved an extensive
review of the literature available at the time,
43
and concluded in December 2020. Some of the
health outcomes of the third tier go beyond what was covered in the second Clean Air
Outlook. For these, a targeted literature review was undertaken to support the selection of
appropriate monetary impact values for these pathways (available in the underlying support
study). Also in line with the second Clean Air Outlook, results are presented for different
approaches to monetising impacts: a VSL (value of statistical life) approach, which monetises
the number of deaths, and a VOLY (value of statistical life year) approach, which instead
monetises life years lost. For the aggregate assessment, the mortality effects associated with
NO
2
are excluded to avoid the risk of overlap with the mortality effects of PM
2.5
.
Materials damage
has long been associated with emissions of SO
2
and NO
X
. Damage values
per unit emission for SO
2
and NO
x
have been taken from the CASES study (CASES, 2008),
and applied to the emissions changes observed in the integrated modelling.
Air pollution is also associated with a range of
ecosystem impacts.
Several of these impact
pathways (but not all) have been monetised in the literature, most commonly: crop damage,
forest damage and damage to ecosystems. Methods to monetise such effects stem from the
ECLAIRE study
44
and are in line with what was done in the second Clean Air Outlook. For
crops
and forests, impacts from exposure to ozone on yields or productivity were taken into
account.
Forest
damage reflects in addition reductions in carbon sequestration potential. For
42
43
44
EEA (2022),
Europe’s air quality status 2022
(accessed: 10.06.2022)
Available in the
annex
to the support study for the Second Clean Air Outlook report, as well as in the annex
of the support study underlying this impact assessment.
Europa.eu (2015),
Effects of Climate Change on Air Pollution Impacts- final. -nr. 282910
(accessed:
10.06.2022)
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this, two different estimates of carbon mitigation costs were assumed, resulting in a low and
high variant of forest damage (but only after 2030 do the assumptions for Low and High
diverge). Impacts on
ecosystems
tend to be most significant out of the three. The analysis
was limited to terrestrial ecosystems and the focus was on exceedance of the critical load for
nitrogen in Natura 2000 sites, with valuation applied to the area subject to critical loads
exceedance. No account was taken of exceedance of the critical load for acidification,
because the area concerned is far less than that affected by eutrophication and there is
potential for double counting if results for both effects are combined. A
willingness to pay
approach to valuation is adopted consistent with that used for other impacts assessed. A Low
and High estimate is adopted to reflect uncertainty in the underlying valuation techniques.
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3.
S
HORTCOMINGS OF THE MODELLING APPROACH AND SOURCES OF UNCERTAINTY
One of the major uncertainties in air quality modelling remains the correct representation of
emissions, including how they are distributed in space. Modelling quality suffers where
emission inventories (submitted by Member States) are deficient, e.g. because emissions are
underestimated or unknown emission sources are not included. To some extent, these effects
are reflected in the underlying modelling work when running sensitivity analyses with a bias
adjustment. Modelling uncertainties in methodologies also lead to limitations. It is worth noting
the EMEP and uEMEP models have been applied in countries where emissions are better
known. Under these conditions the model performance is much improved.
During the course of the modelling some clear challenges in emissions have been found. These
include:
Separation and spatial distribution of national and international shipping emissions;
Individual industries with large and uncertain emissions that can dominate the exposure in a
whole city;
Incorrect allocation of some residential heating emissions;
Reported non-exhaust emissions that may not be adequately spatially distributed or
quantified.
For the estimation of chronic mortality, the following limitations are observed:
Only the mortality related to long-term exposure to PM, NO
2
and O
3
is considered. Other
pollutants and mortality due to short-term exposure are not considered.
Results for mortality are not corrected for overlaps between the different pollutants. As an
indicative estimate for the order of magnitude of the overlap, HRAPIE suggests an overlap
of 33%.
45
This number is, however, associated with a large uncertainty.
Since the meteorological data is the same for each year under consideration, the impact of
climate change is not considered (also
holds for morbidity estimates).
The uncertainty on the results is larger for the results reported per individual country, than
for EU-27 total estimate (also
holds for morbidity estimates).
For the estimation of morbidity, the following additional limitations are observed:
Only the morbidity related to exposure to particulate matter is considered. Other pollutants
are not considered.
Future projections for the baseline incidence are unavailable for most health outcomes. The
analysis therefore relies on the morbidity rates for the most recent year for the future
baseline morbidity. Impacts due to improvements in health care, more / less healthy
lifestyle etc. are hence not considered.
In general, the uncertainty on the morbidity estimates is larger than the uncertainty on the
mortality estimates, mostly due to more pronounced uncertainty in the input datasets
(concentration response functions, baseline morbidity). When interpreting the results, the
focus should therefore lie on relative differences between scenarios.
45
See WHO (2013),
Health risks of air pollution in Europe – HRAPIE project recommendations for
concentration–response functions for cost–benefit analysis of particulate matter, ozone and nitrogen dioxide
(accessed: 16.06.2022)
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A
NNEX
5: B
ASELINE
, M
AXIMUM
T
ECHNICALLY
F
EASIBLE
R
EDUCTION AND POLICY
S
CENARIOS
–
MODELLING RESULTS
This annex complements the description of baseline development in chapter 5 and of policy
scenario developments in chapter 6 of the main report by providing further detailed results from
the quantitative modelling. This means that modelled results that are already included in the
main report are not repeated here. The underlying support study contains further, more
disaggregated results, including tables with results per Member State.
1.
D
ESCRIPTION OF THE BASELINE SCENARIO
The starting point for the quantitative analysis is the
baseline scenario,
which provides a
critical reference point against which to assess changes and impacts of the formulated policy
options. It serves as the counterfactual for examining how the situation is expected to change in
the case of no further changes to the Ambient Air Quality Directives. The baseline is defined
by the current status of implementation of different obligations under the existing EU
Directives relevant for air pollutant releases as well as national legislation, if stricter than the
EU law. This defines the existing political and legal context at the EU and at the national level.
The current status of implementation is well defined in several existing studies, not least the
second Clean Air Outlook. This baseline builds on the backdrop of existing measures and
policies already committed (including some which might require introduction of further
measures in the near term).
In line with the Commission’s Better Regulation guidelines, policy proposals (even though still
subject to modifications in the course of the policy making cycle) form part of the baseline
assumptions. Policies and measures included in the baseline are considered to continue over the
duration of the analysis period. Key
elements of the baseline scenario
that have been updated
since the Second Clean Air Outlook include:
46
The broader EU policy environment and potential changes - including revised European
Commission climate targets and related legislative proposals (Fit for 55) as well as of
preliminary assumptions for the introduction of Euro 7;
Confirmed changes at Member State level (i.e. adopted policies and measures as set out in
National Air Pollution Control Programmes);
Sulphur Emissions Control Area (SECA) in the Mediterranean Sea from 2025;
Assumptions about the development in the non-EU countries, which are of relevance owing
to the impact of transboundary pollution, in particular, new data and projections (energy
and agriculture) for Western Balkan, Ukraine, Moldova, and Georgia from a recently
completed EU funded project.
47
46
47
See Appendix 3 of the support study for a full list of policies included in the baseline.
Extension of the EU Energy and Climate Modelling Capacity to include the Energy Community and its Nine
Contracting Parties (ENER/2020/OP/0005)
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2.
A
IR
POLLUTANT EMISSIONS
:
BASELINE DEVELOPMENT AND SCOPE FOR
REDUCTIONS
MTFR
Considering current economic and environmental policies included in the baseline for the EU-
27 will result in continued decline in emissions of key air pollutants (Figure A5.1). Compared
to 2015, emissions of PM
2.5
, NO
x
, and SO
2
are estimated to drop by 50 to 70%, NMVOC by
25%, while for ammonia (NH
3
) only about 5% reduction is calculated by 2030. The trends are
expected to continue towards 2050 but with much smaller further reductions.
The key drivers of emissions change towards 2030 are different for each pollutant:
for PM
2.5
most of the reduction is due to reduced use of coal and biomass in the
residential sector and transition to cleaner technologies;
for NO
x
recent legislation and fuel trends (less diesel and increase of hybrid and full
electric vehicles) are the key drivers;
for SO
2
, first strong reduction in coal use in power plants and then residential coal use
decline are among major factors;
For NMVOC, reduction in residential heating sector (see PM
2.5
) and transport (see NO
x
)
are key contributors;
For NH
3
, the (limited) decline is mostly driven by structural changes (livestock
numbers), including reduction of mineral nitrogen fertilizer application.
Figure A5.1
– Trends of air pollutant emissions in the EU-27; baseline scenario (GAINS)
For NH
3
, further emission reductions are expected from recently proposed revision of the IED,
including cattle and reducing the farm size threshold for pigs and poultry.
48
While the
modelling baseline used here does not include this proposal (implementation in the GAINS
model is under way within the study supporting the third Clean Air Outlook), the impact
assessment study of the revised IED estimated the potential ammonia reductions at about 155 kt
per year, about 4.4% of total EU ammonia emissions.
48
COM(2022)
156 final/2
(accessed: 04.08.2022)
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To define the scope of the maximum mitigation potential
based on available technologies,
a
maximum technically feasible reduction (MTFR) scenario
for 2030 and 2050 was modelled
in GAINS (Figure A5.2). Key elements to note:
Lifetime of installed capacity is respected, i.e. no premature scrapping of existing
equipment is considered;
No further structural (e.g. fuel switch) or behaviour-driven (e.g. lifestyle choices of
reducing meat/diary intake) measures are considered beyond what is included in the
baseline, neither at the local nor regional level;
Potential local and technological constraints are taken into account to the extent that they
are reflected in the model drawing on previous Member State consultations and technology
information;
Any potential financial constraints are ignored (in other words do not hinder the take-up of
measures).
Figure A5.2
– Scope for further emission mitigation of air pollutant emissions in 2030 and 2050 in the EU-27.
Changes shown relative to 2015 (GAINS model)
Since current legislation is expected to reduce emissions of
SO
2
and
NOx,
further potential is
rather limited and even declines in the long-term owing to the reduced used of fossil fuels
already in the baseline. Remaining limited potential has been identified for industrial process.
For
PM
2.5
, key further mitigation can be achieved in the residential sector and also by enforcing
bans on open burning of various agricultural residues that in spite of existing legislation are still
burned, while there would remain very limited, if any, potential to further reduce emissions
from power or industrial sectors. For
NMVOC,
apart from some potential in residential sector
and agricultural burning, further reductions in solvent use applications were estimated. For
ammonia,
mitigation of emissions from mineral nitrogen fertilizer application and livestock
offer significant reduction potential assuming that measures addressing housing, storage, and
application of manures on land would be introduced in an integrated manner (as proposed in
the revised IED), but for a much larger number of farms than is currently the case as per
baseline assumptions, especially for cattle.
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The mitigation potential shown above (as well as the results that include sectoral breakdown
shown in chapter 6 of the main SWD) vary strongly between Member States depending on
structure of emission sources and local constraints.
49
The following figures (A5.3 to A5.7)
reflect this variation. They present the reduction of emissions of PM
2.5
and its precursors
compared to the baseline
as calculated in the GAINS model for policy and MTFR scenarios,
showing a disaggregated sector/measure resolution and with results per Member State.
Figure A5.3
– Reduction of
PM
2.5
emissions, split by Member State (2030)
49
See main report of the underlying support study for estimates per Member State.
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Figure A5.4
– Reduction of
SO
2
emissions, split by Member State (2030)
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Figure A5.5
– Reduction of
NO
X
emissions, split by Member State (2030)
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Figure A5.6
– Reduction of
NH
3
emissions, split by Member State (2030)
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Figure A5.7
– Reduction of
VOC
emissions, split by Member State (2030)
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3.
A
IR POLLUTANT CONCENTRATION PROJECTIONS
The main report includes detailed results for the baseline and policy scenarios showing the
number of stations with remaining exceedances above different limit values. To complement
these results, this section includes a number of maps that show the geographical distribution of
air pollutant concentrations in the baseline, various optimisation and MTFR scenarios.
The below maps (Figures A5.8) show concentrations of
fine particulate matter (PM
2.5
)
in
2030 indicate that already under baseline assumptions substantial improvements in air quality
over the coming decades can be expected, with most of Europe reaching concentration levels
below 10 μg/m
3
. Areas including parts of Central Europe, the Baltics, Italy and Northern parts
of France move even to concentration levels of below 5 μg/m
3
.
The optimisation scenarios bring further improvements. Significant parts of Europe remain
above 5 μg/m
3
in the OPT-5 scenario (which corresponds to policy option I-1), including
Northern Italy (Figure A5.10), the border region of Czechia, Poland and Slovakia (see also
Figure A5.11), as well as southern regions along the Mediterranean coast of the EU. This
remains the case in the MTFR scenario, which would bring little additional improvements.
Going to 2050 (Figure A5.9), additional areas reach concentration levels below 5 μg/m
3
,
notably most remaining parts of Poland and Hungary, as well as of Belgium and the
Netherlands. Elevated levels of fine particulate matter (PM
2.5
) in Southern Europe are rather
persistent, which is explained by the fact that much of the pollution is due to natural sources,
and Sahara dust and sea spray in particular (which the current Ambient Air Quality Directives
allow to be deducted from air pollution levels reported).
Figure A5.10 highlights the specific dynamics in the Po Valley region in Northern Italy, where
specific meteorological and orographic circumstances lead to reduced dispersion, and elevated
emission levels from residential heating (including biomass burning) as well as agricultural
emissions represent particular challenges. While under the preferred policy option the area
exposed to PM
2.5
concentration levels above 10 µg/m
3
reduces significantly by 2030, some
hotspots would be expected to remain across optimisation scenarios (and significant parts
remain are just below 10 μg/m
3
).
Similarly, for much of Eastern Europe (see for example Figure A5.11), residential heating
(often reliant on fossil fuel combustion) and industry production facilities today lead to
elevated PM
2.5
concentration levels. Under the preferred policy option and based on the
measures taken to address these emissions, the area exposed to PM
2.5
concentration levels
above 10 µg/m
3
reduces almost to zero by 2030.
As regards the concentration levels of
particulate matter (PM
10
)
for the baseline and MTFR,
most areas in the EU reach concentration levels of below 15 µg/m
3
in 2030 already in the
baseline when looking at background concentration levels (Figure A5.12). The remaining areas
above 15 µg/m
3
are along the Mediterranean cost and as such can be explained by pollution
from natural sources.
Zooming in to a finer resolution, however, indicates that local peaks of concentration levels of
particulate matter (PM
10
) can be expected to remain under all scenarios analysed. These can be
linked, for example to constant levels of non-exhaust emissions from transport: Figure A5.13
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illustrate the particular case of Stockholm, where pollution peaks can be seen along the main
road traffic axes.
The baseline assumptions related to improved vehicle emissions standards and increased
electrification of road transport lead to reductions of
nitrogen dioxide (NO
2
)
concentration
levels in urban centres across the EU from 2020 to 2030, with further reductions in the MTFR
and towards 2050 (Figure A5.14). A large area with noticeable improvements in NO
2
concentration levels is the area spanning parts of Belgium and the Netherlands as well as the
Ruhr area in Germany. Zooming into this region (Figure A5.15) shows that areas with an
annual mean concentration of over 20 µg/m
3
are markedly reduced in 2030, already in the
baseline scenario, with remaining areas above 20 µg/m
3
being situated mainly around ports.
Moving from 2020 to 2030 in the baseline already brings marked improvements to
ozone (O
3
)
(26
th
highest maximum 8-hour daily running mean) concentrations levels with large areas
where concentrations levels are reduced to below 100 µg/m
3
, and few remaining areas with
levels above 120 µg/m
3
(in Northern Italy). Further reductions are observed in the MTFR in
2030 and even more pronounced in baseline and MTFR in 2050, when most parts of the EU
have levels of 80 to 100 µg/m
3
, with levels above 100 µg/m
3
remaining primarily in Romania,
Northern Italy, in some parts around the Mediterranean cost as well as parts of North-Western
Europe (Figure A5.16).
Figure A5.17 shows low levels of
sulphur dioxide (SO
2
)
concentrations levels of below
40 µg/m
3
prevailing throughout the EU. This is explained by the strong reduction in coal use in
power plants as well as in residential coal use in line with EU energy and climate policy that
form part of the baseline assumptions.
Carbon monoxide (CO)
concentration levels are below 1 mg/m
3
in most of the EU, with little
changes between baseline and MTFR. Smaller patches are between 1 and 2 mg/m
3
.
Most of the EU has concentration levels for
benzene (C
6
H
6
)
below 0.8 mg/m
3
already in the
baseline in 2020. Parts of Northern Italy show more elevated levels between 0.8 and 3.4 mg/m
3
.
This area is reduced significantly already in the baseline in 2030.
Concentrations levels for
benzo(a)pyrene (BaP)
are above 1 ng/m
3
in significant parts of the
EU in the baseline in 2020, notably in Poland, in Northern Italy and in more localised places in
Southern, Central and Eastern Europe. Already the baseline assumptions reduce these areas in
2030 to a good extent, most notably in Poland. In the MTFR in 2030 and going towards 2050,
there are very limited areas left with concentration levels exceeding (in Poland, Northern Italy
and Greece) 1 ng/m
3
.
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2636043_0066.png
Maps for fine particulate matter - PM
2.5
Figure A5.8
- PM
2.5
concentrations for baseline 2020 and a range of optimised (OPT) scenarios, including MTFR
for
2030.
Calculations are made on the EMEP 0.1
o
grid For details (including on bias correction), please see the
underpinning support study on the revision of the Ambient Air Quality Directives.
Base 2020
Base 2030
OPT-15 2030 (Policy Option I-3)
OPT-10 2030 (Policy Option I-2)
OPT-05 2030 (Policy Option I-1)
MTFR 2030
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Figure A5.9
- PM
2.5
concentrations for baseline 2020 and a range of optimised (OPT) scenarios, including MTFR
for
2050.
Calculations are made on the uEMEP 250 m grid. For details (including on bias correction), please see
the underpinning support study on the revision of the Ambient Air Quality Directives.
Base 2020
Base 2050
OPT-15 2050 (Policy Option I-3a)
OPT-10 2050 (Policy Option I-2a)
OPT-05 2050 (Policy Option I-1a)
MTFR 2050
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Figure A5.10
-
Focus: Region in Northern Italy.
PM
2.5
annual mean concentrations for baseline 2020 and a
range of optimised (OPT) scenarios, including MTFR for 2030. Calculations are made on the uEMEP 250 m grid.
Note the change in colour scale to emphasize concentrations between 5 and 12 µg/m
3
. For details (including on
bias correction), please see the underpinning support study on the revision of the Ambient Air Quality Directives.
Base 2020
Base 2030
OPT-15 2030 (Policy Option I-3)
OPT-10 2030 (Policy Option I-2)
OPT-05 2030 (Policy Option I-1)
MTFR 2030
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Figure A5.11
–
Focus: Region in Central Europe.
PM
2.5
annual mean concentrations for baseline 2020 and a
range of optimised (OPT) scenarios, including MTFR for 2030. Calculations are made on the uEMEP 250 m grid.
Note the change in colour scale to emphasize concentrations between 5 and 12 µg/m
3
. For details (including on
bias correction), please see the underpinning support study on the revision of the Ambient Air Quality Directives.
Base 2020
Base 2030
OPT-15 2030 (Policy Option I-3)
OPT-10 2030 (Policy Option I-2)
OPT-05 2030 (Policy Option I-1)
MTFR 2030
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Maps for particulate matter - PM
10
Figure A5.12 -
PM
10
annual mean concentrations for baseline (Base) and MTFR for 2020, 2030 and 2050.
Calculations are made on the uEMEP 250 m grid. For details (including on bias correction), please see the
underpinning support study on the revision of the Ambient Air Quality Directives.
Base 2020
Base 2030
MTFR 2030
Base 2050
MTFR 2050
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Figure A5.13
–
Focus: Region in Scandinavia.
PM
10
annual mean concentrations for baseline 2020 and a range
of optimised (OPT) scenarios, including MTFR for 2030. Region shown is the city of Stockholm in Sweden.
Calculations are made on the uEMEP 250 m grid. Note the change in colour scale to emphasize concentrations
between 7.5 and 20 µg/m
3
. For details (including on bias correction), please see the underpinning support study on
the revision of the Ambient Air Quality Directives.
Base 2020
Base 2030
OPT-15 2030 (Policy Option I-3)
OPT-10 2030 (Policy Option I-2)
OPT-05 2030 (Policy Option I-1)
MTFR 2030
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Maps for nitrogen dioxide - NO
2
Figure A5.14
- NO
2
concentrations for baseline (Base) and MTFR for 2020, 2030 and 2050. Calculations are
made on the uEMEP 250 m grid. For details (including on bias correction), please see the underpinning support
study on the revision of the Ambient Air Quality Directives.
Base 2020
Base 2030
MTFR 2030
Base 2050
MTFR 2050
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Figure A5.15
–
Focus: Region in North-Western Europe.
NO
2
annual mean concentrations for baseline 2020
and a range of optimised (OPT) scenarios, including MTFR for 2030. Region in North-Western Europe including
Belgium, Germany and The Netherlands. Calculations are made on the uEMEP 250 m grid. Note the change in
colour scale to emphasize concentrations between 10 and 25 µg/m
3
. For details (including on bias correction),
please see the underpinning support study on the revision of the Ambient Air Quality Directives.
Base 2020
Base 2030
OPT-15 2030 (Policy Option I-3)
OPT-10 2030 (Policy Option I-2)
OPT-05 2030 (Policy Option I-1)
MTFR 2030
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Maps for ozone – O
3
Figure A5.16
- O
3
(26th highest maximum 8 hour daily running mean) concentrations for baseline (Base) and
MTFR for 2020, 2030 and 2050. Calculations are made on the EMEP 0.1
o
grid. For details (including on bias
correction), please see the underpinning support study on the revision of the Ambient Air Quality Directives.
Base 2020
Base 2030
MTFR 2030
Base 2050
MTFR 2050
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Maps for sulphur dioxide - SO
2
Figure A5.17
- SO
2
(99th percentile daily mean) concentrations for baseline (Base) and MTFR for 2020, 2030 and
2050. Annual means are calculated and converted to 99th percentiles. Calculations are made on the EMEP 0.1
o
grid. For details (including on bias correction), please see the underpinning support study on the revision of the
Ambient Air Quality Directives.
Base 2020
Base 2030
MTFR 2030
Base 2050
MTFR 2050
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Maps for carbon monoxide - CO
Figure A5.18
- CO (highest maximum 8 hour daily running mean) concentrations for baseline (Base) and MTFR
for 2020, 2030 and 2050. Calculations are made on the EMEP 0.1
o
grid. For details (including on bias correction),
please see the underpinning support study on the revision of the Ambient Air Quality Directives.
Base 2020
Base 2030
MTFR 2030
Base 2050
MTFR 2050
147