Review of the National Air Pollution Control Programme – Portugal · 2020-06-12 · Review of the National Air Pollution Control Programme – Portugal | 5 Ricardo Confidential

Review of the National Air Pollution Control Programme – Portugal ___________________________________________________ Final Report for European Commission – DG Environment Specific contract 070201/2018/791186/SER/ENV.C.3

ED 11495 | Issue Number 4 | Date 06/03/2020

Review of the National Air Pollution Control Programme – Portugal | i

Ricardo Confidential Ref: Ricardo/ED11495/Issue Number 4

Ricardo Energy & Environment

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Author:

Hetty Menadue, Natalia Anderson

Approved By:

Ben Grebot

Date:

06 March 2020

Ricardo Energy & Environment reference:

Ref: ED11495 - Issue Number 4

Review of the National Air Pollution Control Programme – Portugal | ii



Table of contents

1 Introduction ................................................................................................................ 4

Review of the National Air Pollution Control Programmes ................................................ 4

Methodology ...................................................................................................................... 5

NAPCP submission documents ........................................................................................ 6

2 Projected compliance with NECD emission reduction commitments .................... 8

Margin of compliance ........................................................................................................ 8

Projected compliance and consistency with projections submitted under Article 10(2) .... 9

3 Findings of the in-depth NAPCP review ................................................................. 13

NAPCP overview (M) ...................................................................................................... 13

Executive summary (O) ................................................................................................... 13

The national air quality and pollution policy framework (M, O) ....................................... 14

Progress made by current PaMs in reducing emissions and the degree of compliance with

national and EU obligations, compared to 2005 (M, O) .............................................................. 14

Projected situation assuming no change in currently adopted PaMs (M, O) .................. 17

Policy options considered to comply with emission reduction commitments for 2020 and

2030, intermediate emission levels for 2025 and stakeholder consultation (M, O) .................... 17

The policies selected for adoption by sector including timetable for adoption,

implementation and review and responsible competent authority (M, O) .................................. 17

Projected combined impacts of PaMs on emission reductions, air quality and the

environment and associated uncertainties (where applicable) (M, O) ....................................... 17

4 Conclusions and recommendations ....................................................................... 18

Conclusions ..................................................................................................................... 18

Recommendations .......................................................................................................... 18

Appendices

Appendix 1 Completeness assessment

Appendix 2 Assessment of the risk of non-compliance

Review of the National Air Pollution Control Programme – Portugal | iii



Abbreviations

BaP Benzo(a)pyrene

BAT Best Available Technique

BC Black Carbon

EEA European Environment Agency

EU European Union

GHG Greenhouse Gas

kt Kilo tonne

NAPCP National Air Pollution Control Programme

NECD National Emission reduction Commitments Directive (Directive (EU) 2016/2284)

NECP National Energy and Climate Plans

NH3 Ammonia

NMVOC Non-Methane Volatile Organic Compounds

NO2 Nitrogen dioxide

NOx Nitrogen oxides

O3 Ozone

PaMs Policies and Measures

PM10 Particulate matter 10 micrometres or less in diameter

PM2.5 Particulate matter 2.5 micrometres or less in diameter

RAG Red; Amber; Green [rating]

SO2 Sulphur dioxide

WAM With Additional Measures

WHO World Health Organisation

WM With Measures

Review of the National Air Pollution Control Programme – Portugal | 4



1 Introduction

Review of the National Air Pollution Control Programmes

1.1.1 This report

The following report presents the results of the review of the National Air Pollution Control Programme

(NAPCP) submitted to the European Commission by Portugal on 1 April 2019.

EU Member States are required to prepare and report their NAPCP according to the minimum content

and common format (Commission Implementing Decision (EU) 2018/1522)1 stipulated by Article 6 of

the Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants2,

hereafter referred to as the Directive or the NECD3. The NAPCP should demonstrate compliance with

the Member State’s respective emission reduction commitments and set out how compliance will be

achieved.

This review has been undertaken alongside a review of national air pollutant emission projections

developed and reported by Member States under Article 10(2) of the NECD. These reviews have been

commissioned by the European Commission as Service Request 2 under the Framework Contract No

ENV.C.3/FRA/2017/0012 (specific contract 070201/2018/791186/SER/ENV.C.3).

The review of the first NAPCPs and of the air pollution projections with regards to their fulfilment of the

requirements of the NECD will both contribute to the Commission’s reporting on the implementation of

the NECD required under Article 11 of the NECD.

This report feeds into the horizontal review report under the same contract, which presents conclusions

and recommendations from the review at the EU-level. The horizontal report also contains, for each

Member State, an assessment of its risk of non-compliance with its emission reduction commitments,

based on a cross-analysis of the information provided in the NAPCPs and projection submissions under

Article 10(2) of the NECD. This risk assessment is also presented in Appendix 2 to the present report,

while details on the methodology for that risk assessment are found in the horizontal report.

1.1.2 Objectives of the NAPCP review

The purpose of the following report is to determine Member State compliance with the requirements of

the NECD. The scope of the NAPCP review includes:

• The use of the NAPCP common format.

• NAPCP compliance with the minimum content requirements of the Directive (mandatory content

(M)).

• The extent to which the optional content requirements (O) of the Directive are reported and what

added value this brings to the quality of the NAPCP.

• Consistency between the NAPCP and the information in the air pollutant emission projections

that were due to be submitted by Member States by 15 March 2019.

• The extent to which Member States are reliant on additional PaMs (as included in the ‘With

Additional Measures’ (WAM) scenario) to achieve compliance.

1 Commission Implementing Decision (EU) 2018/1522 of 11 October 2018 laying down a common format for national air pollution control

programmes under Directive (EU) 2016/2284 of the European Parliament and of the Council on the reduction of national emissions of certain

atmospheric pollutants, OJ L 256, 12.10.2018, p. 87.

2 Directive (EU) 2016/2284 of 14 December 2016 on the reduction of national emissions of certain atmospheric pollutants, amending Directive

2003/35/EC and repealing Directive 2001/81/EC, OJ L 344, 17.12.2016, p.1.

3 Directive (EU) 2016/2284 repeals and replaces the previous National Emission Ceilings Directive (2001/81/EC) and is generally referred to as the

new NECD or simply the NECD.




• The extent to which the evidence provided on selected PaMs is robust and the level of confidence

it provides that Member States will achieve their 2020 and 2030 emission reduction commitments.

• The extent to which additional PaMs are put forward in view of wider air quality objectives as

set out in Article 1(2) of the NECD (referring to the objectives of the Ambient Air Quality Directives,

the Union’s long-term objective of achieving levels of air quality in line with the air quality guidelines

of the World Health Organisation (WHO), the Union’s biodiversity and ecosystem objectives

and coherence with climate and energy policy priorities).

• The degree of coherence with other plans and programmes in other policy areas,

predominantly the National Energy and Climate Plans (NECP).

Methodology

The key components of the review process are outlined in Figure 1-1. A comprehensive description of

the process, methodology and checks followed are detailed in accompanying review guidelines which

were provided to the NAPCP reviewers responsible for conducting this report.

Figure 1-1 Overview of the NAPCP review methodology

A central review team was used to conduct the initial screening checks. The purpose of the initial

screening was to document Member State submissions in one central data log. For example, the

information recorded includes the date, language and length of the NAPCP submission; accompanying

annexes are similarly reviewed and logged and links to external websites are checked. The initial

checks also record if the Member State uses the NAPCP common format.

The completeness assessment and in-depth review checks are structured according to the section

headings of the NAPCP common format. Together, the review findings inform the extent to which the

NAPCP is compliant with the minimum content requirements, the extent to which evidence is robust

and the level of confidence that the Member State will achieve its commitments.

NAPCP completeness is rated according to a RAG rating (Red, Amber, Green rating as described in

Appendix 1) while the in-depth checks involve a series of questions with pre-defined responses to be

chosen from, designed to systematically determine the robustness and reliability of the evidence

submitted.




NAPCP submission documents

An overview of the Member State’s NAPCP is presented in the table below. This information was

gathered as part of the NAPCP initial screening, as outlined in the methodology.

Table 1-1 Overview of the Member State NAPCP submission documents

Initial screening check Response Additional comment

Was the NAPCP submitted by

1 April 2019?

Yes A complete and final version of the initial NAPCP

was submitted on 1 April 2019.

Was the common format used? Yes Portugal has followed the common format in full.

What is the length of the

NAPCP?

28 pages

What language is the NAPCP

reported in?

Portuguese

What language is the

supporting documentation

reported in?

N/A No supporting documentation was reported.

How many external documents

are referenced or provided in

the NAPCP?

10 Among the external documents referenced in the

NAPCP, the National Air Strategy 2020 is the

most significant as it forms the basis from which

the initial NAPCP was formed. The strategy is in

Portuguese and was published in 2015 and later

adopted in legislation in 2016.

Is it possible to identify the

required information in the

external documents (i.e. is the

page and chapter reference

provided)?

Partially The external documents referenced in the initial

NAPCP do not always include page and chapter

references.

Can all external documents be

accessed?

Yes External documents are referenced in the initial

NAPCP and working links are provided to access

them.

Completeness assessment

A completeness assessment was conducted to identify gaps in reporting according to the minimum

content requirements of the common format (Commission Implementing Decision (EU) 2018/1522).

The completeness assessment also reviewed the extent of reporting of optional content by the Member

State. The results show several gaps in Member State reporting, as presented in Appendix 1 of this

report. To summarise, the minimum content is reported for:

• Policy priorities for emission reductions and other relevant policy priorities and the responsible

authorities involved (sections 2.3.1 and 2.3.2 of the NAPCP). However, this is done with insufficient

detail and more related to the instruments than to the policy priorities per se.

• Progress made by current PaMs in reducing emissions (section 2.4.1 of the NAPCP) and improving

air quality (2.4.2 of the NAPCP). Although for the latter, Portugal provides an overview of

improvements to air quality.




• NAPCP projections to show projected emissions and emission reductions with existing measures

and their projected impact on improving air quality (2.5.1 of the NAPCP).

Portugal does not report:

• External weblinks to the NAPCP and the consultation activities undertaken.

• Transboundary impacts, which are likely to be relevant owing to the shared border with Spain.

• Additional PaMs considered and those PaMs selected for adoption, even though the emissions

reduction commitments are not reached with current PaMs. The PaMs reported via the EEA PaM-

tool have been found in the review as existing ones, and not additional PaMs. This conclusion is

justified in section 3.4.1 of this report.

• NAPCP projections to show projected emission reductions with additional measures.

Portugal has reported some of the optional content from the NAPCP common format:

• An executive summary (section 2.2 of the NAPCP).

• The responsible authorities for source sectors (section 2.3.2 of the NAPCP).

• Graphics to portray current progress achieved and projected impact on air quality improvements

(sections 2.4.1 and 2.4.2 of the NAPCP).




2 Projected compliance with NECD emission

reduction commitments

Margin of compliance

There are several different metrics that can be used to show the “margin of compliance” i.e. the margin

by which compliance with the NECD emission reduction commitments is achieved or missed.

The following two approaches have been used in the overall assessment of NAPCPs and projections

to calculate the margin of compliance:

1. Calculating the difference between an emission reduction commitment and the

projected emission reductions (difference expressed in percentage points) – this

approach is presented in the NAPCP review reports and follows the same approach as required

in the NAPCP format. The emission reduction commitments specified in Annex II of the NECD

are defined as percentage reductions on the 2005 emissions. Projected emissions of pollutants

in 2020 and 2030 are compared to the 2005 emissions to calculate the projected emission

reductions. These projected reductions are then divided by the 2005 emissions to obtain the

projected reductions as a percentage of the 2005 emissions. These percentage reductions are

then compared to the legally binding percentage reduction, with the difference between them

representing the compliance margin expressed as percentage points. As such, negative

percentage points indicate that the emission reduction commitment will not be met.

Figure 2-1 The margin of compliance

Example

A Member State emitted 500 kt of a pollutant in 2005 and had a 20% emission reduction commitment

for 2020. If the 2020 projected emission is 360 kt, the projected emission reduction is 140 kt. This

equates to 28% of 2005 emissions. The projected margin of compliance is 8 percentage points. This

is illustrated in the figure below.

200

250

300

350

400

450

500

550

2005 2010 2015 2020

Emission reduction commitment

(% of 2005 emission)

Compliance margin

Compliance threshold




2. Calculating the difference between projected emissions and the compliance threshold

(expressed as a percentage of the compliance threshold) – this approach is presented in

the projections review reports and follows the same approach as used in the context of

emissions inventories.

Given that each emission reduction commitment specified in Annex II of the NECD is defined as a

percentage reduction on the 2005 emissions, these two values can be combined to express a

“compliance threshold” i.e. the maximum emission that can be emitted by a Member State from 2020

and 2030 onwards, and still be compliant with the emission reduction commitment for a pollutant.

Projected emissions (under the WM and WAM scenarios) can be compared to the compliance

threshold, and the compliance margin expressed as a percentage of the compliance threshold.

Example

A Member State emitted 500 kt of a pollutant in 2005 and had a 20% emission reduction commitment

for 2020. The maximum the Member State can emit in 2020 to achieve its 2020 emission reduction

commitment (the “compliance threshold”) is 400 kt. If the 2020 projected emission is 360 kt, the

commitment will be met by 40 kt and the projected margin of compliance is 10% of the compliance

threshold.

Mathematically these two approaches are different as they use different reference points. However,

they yield the same conclusions concerning compliance or non-compliance with the NECD

reduction commitments. The largest numerical differences between the two approaches occur when

there are significant differences between the 2005 emissions and the projected emissions for 2020 or

2030 (this is in particular the case for SO2).

The percentage point approach is used in the review of the NAPCP to understand the margin of

compliance between the projected emission reductions presented in the NAPCP and the legally binding

percentage emission reduction commitments (see Section 2.2 of this report).

The results of the projections review and of the assessment of the NAPCPs are brought together in the

risk assessment for individual Member States (see Appendix 2 of this report), using the margin of

compliance expressed as a percentage of the compliance threshold based on projections submitted

under Article 10(2). The methodology for assessing the risk of non-compliance is explained in the

accompanying horizontal review report.

Projected compliance and consistency with projections

submitted under Article 10(2)

• Under the WM projections of the NAPCP, all 2020-2029 commitments are projected to be

achieved. The national emission reduction commitments for SO2, NMVOC and PM2.5 for 2030

onwards are projected to be missed.

• Portugal does not provide projections under a WAM scenario.

The projections presented in this section are derived from the information reported by the Member State

in their NAPCP. Portugal included 2017 projections in the NAPCP and did not specify the year of the

historical inventory data used to underpin the projections. The projections included in the NAPCP are

different to those reported under Article 10(2) on 5 July 2019. The differences affect the projected

compliance with the NECD national emission reduction commitments for 2030 onwards only and are

described at the end of this section.

Figure 2-2 presents the emission projections reported in the NAPCP. The emission reductions needed

for 2025 are interpolated according to the 2020-29 and 2030 onwards commitments set out in the




NECD. Additional information is included to demonstrate the extent to which the projections meet the

Member State commitments (shown, for each of the pollutants, as the difference expressed in

percentage points between the projected emission reduction described in the NAPCP and the legal

commitment). The percentage points do not represent the extent to which total emissions projected (kt)

compare to the emission reduction commitment (in terms of kt of emissions).

Under the WM scenario, progress towards the 2020-29 emission reduction commitments is as

follows:

• SO2 – The projections of SO2 emissions under the WM scenario show that Portugal can comply

with the 2020-29 reduction commitments specified in the NECD with existing measures. In 2020,

compliance with the emissions reduction commitments is projected to be achieved with a margin of

15 percentage points.

• NOx– The projections of NOx emissions under the WM scenario show that Portugal can comply with

the 2020-29 reduction commitments specified in the NECD with existing measures. In 2020,



• NMVOC – The projections of NMVOC emissions under the WM scenario show that Portugal can

comply with the 2020-29 reduction commitments specified in the NECD with existing measures. In

2020, compliance with the emissions reduction commitments is projected to be achieved with a

margin of 9 percentage points.

• NH3 – The projections of NH3 emissions under the WM scenario show that Portugal can comply




• PM2.5 – The projections of PM2.5 emissions under the WM scenario show that Portugal can comply




Under the WM scenario, progress towards the 2030 onwards commitments is as follows:

• SO2 – The projections of SO2 emissions under the WM scenario show that Portugal cannot comply

with the 2030 onwards reduction commitments specified in the NECD with existing measures. In

2030, compliance with the emissions reduction commitments is projected to be missed with a

margin of 5 percentage points in 2030.

• NOx – The projections of NOx emissions under the WM scenario show that Portugal can comply

with the 2030 onwards reduction commitments specified in the NECD with existing measures.

However, compliance with the emissions reduction commitments is projected to be achieved with

a margin of 1 percentage point.

• NMVOC – The projections of NMVOC emissions under the WM scenario show that Portugal cannot

comply with the 2030 onwards reduction commitments specified in the NECD with existing

measures. In 2030, compliance with the emission reduction commitments is projected to be missed

with a margin of 11 percentage points.

• NH3 – The projections of NH3 emissions under the WM scenario show that Portugal can comply

with the 2030 onwards reduction commitments specified in the NECD with existing measures. In

2030, compliance with the emissions reduction commitments is projected to be achieved with a

margin of 17 percentage points.

• PM2.5 – The projections of PM2.5 emissions under the WM scenario show that Portugal cannot

comply with the 2030 onwards reduction commitments specified in the NECD with existing

measures. In 2030, compliance with the emission reduction commitment is projected to be missed

by 10 percentage points.




The differences between the projections reported via the NAPCP and those submitted on 5 July 2019

under Article 10(2) affect projected compliance for SO2. Under the Article 10(2) projections, the SO2

2030 onwards commitment is projected to be achieved but is projected to be missed according to the

NAPCP projections. The NAPCP projections are projecting greater emission reductions in 2020 for NOx,

NH3 and PM2.5, and in 2030 for NH3 and PM2.5 compared to those submitted under Article 10(2). The

NAPCP projections are projecting greater emissions in 2030 compared to those submitted under Article

10(2) for NMVOC (in 2020 and 2030) and NOx in 2030. However, in the cases of NOx, NMVOC, NH3

and PM2.5, the differences between the two sets of projections do not affect the conclusions on projected

compliance for these pollutants.

The differences between the projections in the NAPCP and those reported under Article 10(2) occur

primarily as a result of the different historical inventory data used to underpin the projections.

Furthermore, the NAPCP review finds that the baseline emissions reported for the year 2005 in the

NAPCP incorrectly include emissions from NFR sectors 3B and 3D for the national totals for NOx and

NMVOC. In accordance with Article 4 of the NECD, emissions of NOx and NMVOC from activities falling

under the 2014 NFR categories 3B (manure management) and 3D (agricultural soils) are not accounted

for the purpose of complying with national emission reduction commitments.

Figure 2-2 Projected attainment of emission reduction commitments (WM scenario used in the NAPCP)

Note: The extent to which the projections meet the Member State commitments is shown, for each of the pollutants,

as the difference expressed in percentage points between the projected emission reduction described in the

NAPCP and the legal commitment. A negative number indicates that the emission reduction commitment is

projected to be missed.

Despite the emission projections under the WM scenario showing that Portugal is not projected to meet

its 2030 onwards commitments for most pollutants, projections under a WAM scenario are not reported

in the NAPCP nor under Article 10(2).

In a letter accompanying the NAPCP submission, Portugal explains that the NAPCP is derived from the

National Air Strategy 2020 which was published in 2015 and later adopted in legislation in 2016 in

response to the reporting requirements established by the NECD. It further explains that the NAPCP




does not reflect the additional measures which will be included in the NECP and 2050 Carbon Neutral

Plan, but which were only defined in draft at the time of the submission of the NAPCP.

Further analysis related to the risk of non-compliance, taking into account the information provided in

both the NAPCP and the projections submissions, is presented in Appendix 2.




3 Findings of the in-depth NAPCP review

NAPCP overview (M)

• The initial NAPCP was submitted in keeping with the deadline of 1 April 2019.

• The common format was used.

• The external weblink provided for consultation activities is out of date for the 2019 NAPCP

submission.

The NAPCP adheres to the common format specified by the Commission Implementing Decision (EU)

2018/1522, pursuant to Article 6 of the NECD. The NAPCP is made up of one main report (28 pages).

It is accompanied by a one-page letter to explain why the initial NAPCP does not include projections

under a WAM scenario. The complete submission was made on 1 April 2019. PaMs were submitted via

the EEA PaM-tool on 1 April 2019.

Of the 10 external links provided in the NAPCP, all are in working order. References to supporting

documents are partially complete with, however, chapter and pages numbers not included. External

documents referenced are publicly available. All references are relevant and provide further context for

the NAPCP.

The title and responsible authority for the development of the Portuguese NAPCP (Portuguese

Environment Agency) is reported in accordance with section 2.1.1 of the common format.

An external weblink is reported for the consultation activities undertaken for a previous national

emission reduction programme, titled the National Air Strategy 2020 which was published in 2015 and

later adopted in legislation in 20164. As such, the NAPCP review finds that the consultation activities

are out of date for the 2019 NAPCP submission.

The transboundary impact of air pollution is not outlined in the NAPCP and there is no evidence of a

transboundary consultation having been conducted.

Executive summary (O)

The executive summary (five pages long) is in accordance with the structure established by the common

format except that no projections are included under a WAM scenario. The executive summary only

provides an overview of the projected emissions (kt) for NECD pollutants for the year 2030 (i.e.

overlooking how the projected emissions compare with the emission reduction commitments for 2020-

29 and 2030 onwards).

The content of the executive summary is not fully consistent with the main body of the NAPCP regarding

information on existing PaMs. It is also reported in the executive summary that the (existing) PaMs

reported in the NAPCP are in line with those in the NECP and the National Action Plan for Energy

Efficiency which is not reported in the main body of the NAPCP.

4 Portugese Environment Agency: Estratégia Nacional Para o Ar 2020 (ENAR) [National Strategy for Air 2020].

https://www.apambiente.pt/index.php?ref=16&subref=82&sub2ref=1174 [last accessed: 19/07/2019]

https://www.apambiente.pt/index.php?ref=16&subref=82&sub2ref=1174




The national air quality and pollution policy framework (M, O)

• Air quality policy priorities are described for NO2 and PM10.

• The National Programme for Climate Change forms part of the national low carbon roadmap for

low carbon trajectories up to 2050 and provides a framework for air pollutant emission reductions

and relevant sectors (including agriculture, industry and transport).

The key air quality pollutants are described in accordance with the air quality plans which have been

developed under the legal framework of the Ambient Air Quality Directives and the related EU limit and

target values. Air quality plans are described in the NAPCP for NO2 and PM10. The information reported

is aligned with the EEA Member State fact sheet5 for Portugal. The air quality priorities described do

not include references to the WHO guidelines.

Portugal sets out the policy priorities for climate change as established by the National Programme for

Climate Change which forms part of the national low carbon roadmap for low carbon trajectories up to

2050, highlighting the overlap between the measures included in the programme with the NAPCP. The

draft National Energy and Climate Plan (NECP) for Portugal builds on the roadmap and provides the

policy framework for 2021-2030 but at the time of the initial NAPCP, Portugal reports that the NECP

was still in draft format.

The policy framework for relevant sectoral policies is reported but the corresponding priorities have not

been stated. For industry, Portugal refers to the national implementation of the EU environmental

acquis. For agriculture and transport, key policy strategies are described for the respective sectors up

to 2020. In all sectors, the policy framework mentioned dates back to several years.

The relevant authorities are reported in the NAPCP in accordance with the minimum content

requirements of section 2.3.2 of the common format. National government ministries are responsible

for policy making and policy implementation with different government departments involved according

to the source sector. Local authorities are involved with implementation. Regional authorities are

responsible for reporting and monitoring. The centralised governance system will facilitate coordination

between sectors and consistency in implementation across the country. The role of local authorities

concerning air pollution matters and the built environment is unclear according to the information

reported. Enforcement roles are not defined in the NAPCP.

Progress made by current PaMs in reducing emissions and

the degree of compliance with national and EU obligations,

compared to 2005 (M, O)

3.4.1 Progress made by current PaMs in reducing emissions

• By pollutant, key emitting sectors are: SO2 (energy), NOx (road transport), NMVOC (transport

and product use), NH3 (agriculture) and PM2.5 (from household combustion).

• Current PaMs and implementation of relevant EU legislation are summarised for agriculture,

energy supply, manufacturing industries and road transport.

The review of the NAPCP finds that the information reported via the EEA PaM-tool covers existing

PaMs only. As a result, the information reported by Portugal via the EEA PaM-tool (with respect to

section 2.6 of the NAPCP common format) has been incorporated within the review of current PaMs

and is presented below. This decision was taken in view of the following factors:

5 Air pollution country fact sheets 2018: https://www.eea.europa.eu/themes/air/country-fact-sheets [last accessed: 14/06/2019]

https://www.eea.europa.eu/themes/air/country-fact-sheets




• The NAPCP is based on the National Air Strategy 2020 (ENAR 2020) for which a consultation was

conducted, and a plan was adopted by legislation in 2016. According to the information reported

via the EEA PaM-tool, implementation of PaMs either started or was due to start between 2005 and

2020 and that all these PaMs were adopted between 2012 and 2019.6

• None of the PaMs are included in any of the projections scenarios according to the information

reported via the EEA PaM-tool7. As such, there is insufficient information to conclude which PaMs

are additional.

• In section 2.4.1 of the NAPCP, current PaMs and existing EU legislation are described at individual

level by sector for energy (supply); manufacturing industries; and transport (road). The degree of

detail is limited and the information presented in the NAPCP only reproduces the content of the

already published Informative Inventory Report.

Emission reductions are described for between 1990 and 2017. Charts are used to illustrate how the

total emissions compare to the national emission reduction commitments; they are accompanied by a

qualitative description of the key emitting sectors during this period, covering:

• Energy industry (SO2, NOx)

• Road transport (NOx, NMVOC)

• Industrial processes and product use (NMVOC)

• Agriculture (NH3)

• Combustion by household combustion (PM2.5)

Information reported via the EEA PaM-tool on existing PaMs is presented in the tables below. Where

described, the PaMs involve information campaigns and campaigns that either drive behavioural shift

or rely on voluntary uptake. Quantified emission reductions are not reported – neither at the individual

or package level. Based on the PaM descriptions, the NAPCP review finds that it is likely that emission

reductions are not expected as a result of the PaMs alone which is why their estimated impact cannot

be quantified.

Agriculture (one individual PaM)

Incentive to reduce the use of nitrogen fertilisers

Energy (two individual PaMs)

Increasing energy efficiency to reduce emissions of air pollutants

Replacement of fireplaces by heat recovery technologies

Transport (eight individual PaMs)

Development and implementation of mobility plans.

Promotion of Eco-driving

6 A definition of implemented and adopted PaMs is provided in the NAPCP guidance (European Commission 2019/C77/01). The definition is in

accordance with paragraph 11, chapter 8 of the EMEP/EEA Guidebook (UNFCCC 2016) and states that existing PaMs are where an official

government decision has been made and there is a clear commitment to proceed with implementation.

7 For each PaM reported via the EEA PaM-tool, Member States are required to specify which projections scenario the PaM is included in. The

majority of PaMs are expected to be categorised as ‘with additional measures’, however Member States have the option to report ‘with measures’

and ‘not included’.




Transport (eight individual PaMs)

Promotion of electric mobility

Promotion of the network development for alternative fuel stations

Program to support the reduction of public transport tariffs

Reduction of the average age of heavy passenger fleet of public passenger transport.

Decarbonisation of the fleet of taxis

Creation of Low Emission Zones in medium and large cities

Promotion of the use of in urban and suburban public transport (modal shift)

Horizontal (one individual PaM)

Clean air media campaign

Portugal reported that the mandatory measures relating to agriculture as listed in Annex III, Part 2 to

the NECD were adopted in national legislation in 2018 but that the measures are still being developed.

The following has been adopted by national legislation:

• A national advisory code of good agricultural practice to control NH3 emissions is adopted in

national legislation.

• The use of ammonium carbonate fertilisers is prohibited by national legislation.

• Measures to reduce NH3 emissions from livestock manure is mentioned as already being adopted

in national legislation while also requiring further development.

Small farms are exempt from the above.

In the case of the optional measures listed, Portugal has not established a national nitrogen budget,

nor a national advisory code of good agricultural practices for the proper management of harvest

residue nor prohibition of open field burning.

3.4.2 Progress made by current PaMs in improving air quality

National compliance with EU standards under the Ambient Air Quality Directive is reported for the year

2017. Exceedances are reported for NO2 and O3.

Evolution achieved is illustrated for NO2 in relation to specific air quality zones between 2016 and 2017.

For PM10, a static overview is shown for 2017 by air quality zone; while for O3, evolution at national level

is shown for between 1995 and 2017. Histograms are included in the NAPCP to show the number of

compliant air quality zones for these pollutants.

No PaMs are described in the NAPCP in view of contributing to reducing these exceedances but

weblinks are provided to the relevant air quality plans.

3.4.3 Current transboundary impact of national emission sources

Portugal does not provide information concerning the transboundary impacts of national emission

sources. In view of the shared border with Spain, the NAPCP review finds that a transboundary impact

of national emission sources is likely.




Projected situation assuming no change in currently adopted

PaMs (M, O)

As presented in section 2.2 of this report, all 2020-29 national emission reduction commitments are

projected to be achieved under the WM scenario. For 2030 onwards, national emission reduction

commitments for SO2, NMVOC and PM2.5 are projected to be missed.

The 2017 WM projections used in the NAPCP are not sufficiently up to date to capture all existing PaMs

(adopted by legislation in 2016).

As projections under a WAM scenario are not reported, the NAPCP review considers the extent to

which the emission reduction trajectories under the WM scenario follow a linear trajectory. For SO2,

NMVOC and PM2.5, the emission projections show that emissions are expected to increase between

2020 and 2025 and return to 2020 levels by 2030 (thus following a non-linear emission reduction

trajectory). No explanation is provided by Portugal for this trend.

The projected improvements to air quality are described in qualitative terms only for PM2.5, PM10, NO2

and O3. Compliance with EU air quality standards for PM2.5, PM10 and NO2 is projected but not for O3

owing to projected increases of NMVOC emissions (section 2.5.2.1 of the NAPCP).

Policy options considered to comply with emission reduction

commitments for 2020 and 2030, intermediate emission

levels for 2025 and stakeholder consultation (M, O)

No additional PaMs have been considered.

The policies selected for adoption by sector including

timetable for adoption, implementation and review and

responsible competent authority (M, O)

No additional PaMs have been adopted.

Projected combined impacts of PaMs on emission

reductions, air quality and the environment and associated

uncertainties (where applicable) (M, O)

Portugal has not reported projections under a WAM scenario in its NAPCP. This is despite establishing

that existing measures are insufficient to meet its emission reduction commitments for most pollutants

for 2030 onwards under the NECD. A WAM scenario has not been submitted with the projections

reported under the Article 10 (2).




4 Conclusions and recommendations

Conclusions

The Portuguese NAPCP was submitted on 1 April 2019, meeting the deadline of 1 April 2019. Portugal

has followed the layout of the common format for its NAPCP.

Portugal meets the minimum reporting requirements of the common format except in the following

aspects:

• The consultation activities undertaken are out of date for the 2019 NAPCP submission.

• Transboundary impacts are not assessed, which they are likely to be relevant owing to the shared

border with Spain.

• Additional PaMs considered and selected for adoption have not been reported, even though some

emission reduction commitments are projected to be missed, hence making additional PaMs

necessary. Information reported in the EEA PaM-tool covers existing PaMs only, while this tool

should be used to report additional PaMs.

• Projected emission reductions with additional measures (WAM scenario) are missing.

In the absence of projections under a WAM scenario (which has not been submitted under Article 10(2)

and has not been presented in the NAPCP), the projected evolution towards meeting the NECD

commitments is presented in the NAPCP review according to the projections under the WM scenario

from the NAPCP (Section 2.2), as follows:

• All emissions reduction commitments for 2020-29 are projected to be achieved.

• The national emission reduction commitments for SO2, NMVOC and PM2.5 for 2030 onwards are

projected to be missed.

As such, the lack of information presented in the NAPCP on additional PaMs and on projected emission

reductions under a WAM scenario are considered by the NAPCP review to be significant gaps in

reporting.

Differences between the NAPCP projections and those submitted under Article 10(2) result in different

conclusions on projected compliance with 2030 onwards emission reduction commitment for SO2 (the

commitment is projected to be achieved according to Article 10(2) projections but missed according to

the NAPCP). For other pollutants the inconsistencies impact the projected margins of compliance only.

A positive highlight from the review of the NAPCP for Portugal is that there is a detailed description of

current PaMs together with implemented EU legislation that provides a good basis for understanding

progress achieved to date. However, due to the findings that the projection’s methodologies were found

to require major improvements for all pollutants and commitment years, as well as the lack of additional

PaMs selected for adoption, Portugal is found to be at high risk of not achieving its emission reduction

commitments (see the risk assessment in Appendix 2 to this report).

Recommendations

Recommendations are prioritised according to the following categories:

1. Ensuring compliance – non-compliance with the NECD, where the minimum content is not

reported and/or the Member State does not demonstrate how it may achieve its emission reduction

commitments.

2. Areas for improvement – the NAPCP is reported to be compliant with its emission reduction

commitments and provides the minimum content required by the common format but uncertainties

are identified. Clarification and/ or additional information could improve quality of the NAPCP.




3. Encouragements – where optional reporting could be provided to improve the quality of the

NAPCP and/or where the NAPCP could be closer aligned with the guidance document on

preparation of initial NAPCPs.

Ensuring compliance

• SO2, NMVOC and PM2.5 2030 onwards commitments are projected to be missed. To ensure

compliance, Portugal has to consider and select additional PaMs for adoption and provide emission

projections under a WAM scenario.

• The NAPCP does not provide evidence of consultation activities undertaken to develop the NAPCP.

The external weblinks provided direct to a website hosting the consultation documents for a

previous national emission reduction programme (ENAR 2020) which is considered out of date for

the 2019 NAPCP submission.

• No information is provided to describe the transboundary impacts of national emissions. In view of

the shared border with Spain, it is likely that transboundary impacts are relevant and therefore a

description is required.

• Article 4(2) of the NECD stipulates that the indicative levels of emissions between 2020 and 2030

shall be determined by a linear reduction trajectory. Under the WM scenario, SO2, NMVOC and

PM2.5 emissions are projected to increase between 2020 and 2025 and return to 2020 levels by

2030 (thus following a non-linear emission reduction trajectory). To ensure compliance, Portugal is

required to report the deviation from the linear trajectory for 2025 for these pollutants and explain

why a linear trajectory cannot be followed.

Areas for improvement

• In its process of selecting additional PaMs and presenting a WAM scenario due to the projected

non-compliance in 2030 for SO2, NMVOC and PM2.5, Portugal should also consider and adopt

additional PaMs to address the other pollutants, taking into account the inconsistencies of

projections presented in the NAPCP and the Article 10(2) submission.

• Exceedances of EU air quality standards are reported for NO2 and O3. Current PaMs contributing

to air quality improvements are not reported. It would be useful to include a summary of the PaMs

contributing to air quality improvements to better establish coherence between the NAPCP and air

quality policy priorities. Additional PaMs should also be adopted that would reduce concentrations

of these air pollutants as a co-benefit of reducing air pollutant emissions.

• The policy framework described by Portugal outlines the relevant policies for the sectors defined

by the common format, but it does not describe the relevant policy priorities. To better understand

the relevance of the policies to emission reductions, the corresponding policy priorities should be

reported.

• Current PaMs in the NAPCP are summarised by sector but the descriptions do not cover PaMs

aimed at reducing emissions of PM2.5 or NH3. Information reported by Portugal using the EEA PaM-

tool provides relevant information to address this gap. Portugal should incorporate information

currently reported via the EEA PaM-tool within Section 2.4.1 of the NAPCP instead (the tool is

designed to report on new additional PAMs considered for adoption only – not the current PaMs).

Encouragement

• The information included in the executive summary is different from the main body of the NAPCP.

While the inclusion of an executive summary is optional reporting, where provided, it needs to reflect

accurately the information reported in the main body of the NAPCP.




Appendix 1 Completeness assessment

A completeness assessment was conducted to identify gaps in reporting according the minimum

content requirements of the common format (Commission Implementing Decision (EU) 2018/1522).

The completeness assessment also reviewed the extent of optional reporting by Member States.

For mandatory reporting requirements, the status has been assessed using the traffic light RAG rating

as presented in the table below.

Table A1- 1 Traffic light RAG rating for completeness assessment of mandatory reporting

Red No information provided for mandatory reporting requirement

Amber Evidence is incomplete or unclear to meet reporting requirement

Green Evidence is sufficient to meet reporting requirement

N/A Mandatory reporting requirement not relevant for the given Member State or

mandatory only when available and not available in the given Member State (e.g.

where mandatory reporting requirements apply only where a non-linear emission

reduction trajectory is followed)

Table A1- 2 Completeness assessment of the NAPCP – mandatory content

Reference to the NAPCP common

format

RAG

Rating

Explanation

2.1 Title of the programme contact

information and websites

Green The NAPCP is appropriately introduced.

2.3.1 Policy priorities and their

relationship to priorities set in other

relevant policy areas

Amber All minimum content has been reported;

however policy priorities are not clearly

stated.

2.3.2 Responsibilities attributed to

national, regional and local authorities

Green All minimum content has been reported.

2.4.1 Progress made by current PaMs in

reducing emissions, and the degree of

compliance with national and Union

emission reduction obligations

Green All minimum content has been reported. The

references provided are complete; even

though chapter and page references are not

provided, sufficient detail is reported.


improving air quality, and the degree of

compliance with national and Union air

quality obligations

Amber Portugal provides an overview of

improvements to air quality but does not link

them in detail to existing PaMs. The

references provided are complete but do not

include chapter and page references; this

affects compliance with the reporting

requirement owing to the limited detail

included in the NAPCP.

2.4.3 Where relevant, current

transboundary impact of national emission

sources

Red Portugal does not report the transboundary

impacts of national emission sources. In

view of the shared border with Spain, this is

considered a gap in completeness.





format

RAG

Rating

Explanation

2.5.1 Projected emissions and emission

reductions (WM scenario)

Green All minimum content has been reported.

2.5.2 Projected impact on improving air

quality (WM scenario)

Amber Portugal provides a qualitative description of

the projected improvements to air quality for

the pollutants specified by the common

format only, but no quantitative information.

2.6.1 Details concerning the PaMs

considered in order to comply with the

emission reduction commitments

(reporting at PaM level)

Red No additional PaMs have been considered,

even though the WM scenario does not

present compliance with emission reduction

commitments.

The EEA-PaM tool has been used to report

information concerning existing PaMs, while

the tool is meant for additional PaMs.

2.6.2 Impacts on air quality and the

environment of individual PaMs or

packages of PaMs considered in order to

comply with the emission reduction

commitments

Red No additional PaMs have been considered.

2.6.4 Additional details concerning the

measures from Annex III Part 2 to

Directive (EU) 2016/2284 targeting the

agricultural sector to comply with the


Green No modifications to the measures included in

Annex III, Part 2 to the NECD are reported

by Portugal.

2.7.1 Individual PaMs or package of PaMs

selected for adoption and the competent

authorities responsible

Red No additional PaMs have been selected for

adoption.

2.7.2 Assessment of how selected PaMs

ensure coherence with plans and

programmes set up in other relevant

policy areas

Red No additional PaMs have been selected for

adoption.

2.8.1 Projected attainment of emission

reduction commitments (WAM)

Red Projections under a WAM scenario are not

provided.

2.8.2 Non-linear emission reduction

trajectory

N/A Projections under a WAM scenario are not

provided. Even though there are non-linear

trends in the WM scenario, this is not

explained.

2.8.3 Flexibilities N/A There is no mention of the use of flexibility in

the NAPCP.




The rating used for the completeness assessment of optional reporting by Member States refers to only

two categories, whereby the Member State either reported the information (Green) or it did not (White).

This rating reflects the fact that the reporting is optional and therefore where the information was not

provided, or where it was incomplete or unclear, the assessment should not consider this a gap in

reporting.

Table A1- 3 Rating for completeness assessment rating of optional reporting

Green Evidence is sufficient to meet reporting requirement

White No information provided for optional reporting requirement or evidence is

incomplete or unclear to meet optional reporting requirement

Table A1- 4 Completeness assessment of the NAPCP - optional content


format

RAG

Rating

Explanation

2.2 Executive summary Green The NAPCP includes an executive summary

in accordance with the structure established

by the common format. It is however not fully

consistent with the core text.

2.3.1 Policy priorities and their

relationship to priorities set in other

relevant policy areas: Reference to WHO

guideline values

White The NAPCP does not refer to the WHO

guidelines with respect to the air quality

priorities listed.

2.3.2 Responsibilities attributed to

national, regional and local authorities:

Source sectors under the responsibility of

the authority

Green Portugal reports the source sectors under

the responsibility of the authorities listed.


reducing emissions, and the degree of

compliance with national and Union

emission reduction obligations: Provision

of graphics

Green Graphics are included in the NAPCP to

illustrate emission reductions per pollutant.


improving air quality, and the degree of

compliance with national and Union air

quality obligations: Provision of graphics

and progress made in a specific air quality

zone

Green Histograms are included in the NAPCP to

show the number of compliant air quality

zones by pollutant.

2.4.3 Methodologies and data used to

show the current transboundary impact of

national emission sources

White Portugal does not report the transboundary

impacts of national emission sources.

2.5.1 Associated uncertainties of the

projected emissions and emission

reductions (WM scenario)

White Portugal does not outline the associated

uncertainties.





format

RAG

Rating

Explanation

2.5.2 Quantitative data on the projected

impact on improving air quality (WM

scenario)

White No quantitative data are provided for air

quality projections.

2.6.1 Details about additional pollutants

concerning the PaMs considered in order

to comply with the emission reduction

commitments: Reporting of affected

pollutant(s) beyond the scope of the

NECD

White No additional PaMs have been considered.

2.6.3 Estimation of costs and benefits of

the individual PaM or package of PaMs

considered in order to comply with the


White No additional PaMs have been considered.

2.6.4 Additional details concerning the

optional measures from Annex III Part 2 to

Directive (EU) 2016/2284 targeting the

agricultural sector to comply with the


Green Portugal reports that it will not establish a

nitrogen budget but that measures will be

adopted in national legislation to reduce

ammonia emissions from livestock manure.

Portugal reported that the detail for these

measures is still to be determined.

2.7.1 Individual PaMs or package of PaMs

selected for adoption and the competent

authorities responsible: Reporting of

relevant comments arising from the

consultation and provision of interim

targets and indicators

White No additional PaMs have been selected for

adoption.

2.7.2 Explanation of the choice of

selected measures

White No additional PaMs have been selected for

adoption.

2.8.4 Projected improvement in air quality

(WAM)

White Projections under a WAM scenario are not

provided.

2.8.5 Projected impacts on the

environment (WAM)

White Projections under a WAM scenario are not

provided.




Appendix 2 Assessment of the risk of non-compliance The description of the methodology used for this assessment is presented in the Horizontal Report.

In the following tables, the information used in the decision tree process is presented in black font.

Information not used in the decision tree process is presented in grey font and italics.

Where information is required but not reported, the response to the decision tree question is ‘not

reported’ (NR). Where information is not required and not reported, the response to the decision tree

question is ‘not applicable’ (n/a).

Risk of non-compliance with 2020-2029 emission reduction commitments

Decision tree question Relevant

scenario

2020 – 2029

SO2 NOx NMVOC NH3 PM2.5

Can the Member State

achieve the emission

reduction commitments?

(projections submitted

under Article 10(2))

WM Yes Yes Yes Yes Yes

WAM NR NR NR NR NR

Are the projections

submitted under Article

10(2) considered to be of

good quality?

WM No No No No No

Are the NAPCP projections

consistent with the latest

projections submitted under

Article 10(2)?

WM Partially Partially Partially Partially Partially

WAM n/a n/a n/a n/a n/a

Does the NAPCP present

credible additional PaMs

selected for adoption?

WAM n/a n/a n/a n/a n/a

Is the margin of compliance

(percent of the compliance

threshold) likely to ensure

compliance with the

emission reduction

commitments? (projections


10(2))

WM Yes

(54)

No (16) No (8) No (8) Yes

(21)

WAM NR NR NR NR NR

Risk of non-compliance M H H H M

Additional comments on

high risk scores

The review has concluded that Portugal is at a high risk of non-

compliance with the emission reduction commitments for NOx,

NMVOC and NH3 for 2020-2029. This is driven by:

• The projection’s methodologies found to require major

improvements

• Compliance margins are less than 20%




Risk of non-compliance with 2030 emission reduction commitments

Decision tree question Relevant

scenario

2030 onwards

SO2 NOx NMVOC NH3 PM2.5

Can the Member State

achieve the emission

reduction commitments?

(projections submitted

under Article 10(2))

WM Yes Yes No Yes No

WAM NR NR NR NR NR

Are the projections


10(2) considered to be of

good quality?

WM No No No No No

Are the NAPCP projections

consistent with the latest

projections submitted under

Article 10(2)?

WM No Partially Partially Partially Partially

WAM NR NR NR NR NR

Does the NAPCP present

credible additional PaMs

selected for adoption?

WAM No n/a No n/a No

Is the margin of compliance

(percent of the compliance

threshold) likely to ensure

compliance with the

emission reduction

commitments? (projections


10(2))

WM No (10) No (10) No (-6) No (2) No (-25)

WAM NR NR NR NR NR

Risk of non-compliance H H H H H

Additional comments on

high risk scores

The review has concluded that Portugal is at a high risk of non-

compliance with the emission reduction commitments for all

pollutants for 2030 onwards. This is driven by:

• The projection’s methodologies found to require major

improvements

• Portugal projecting non-compliance under WM scenario and

not providing WAM scenario (for NMVOC and PM2.5)

• Margins of compliance are lower than 20% (for SO2, NOx

and NH3).

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