Supporting the Fitness Check of the EU Ambient Air Quality ... FC AAQD - Appendix J - C… · The ‘Plovdiv Agglomeration’ air quality zone covers two municipalities, which need

Directorate-General for Environment

Written by Adriana R. Ilisescu

September 2019

Supporting the Fitness Check of the EU Ambient Air Quality Directives

(2008/50/EC, 2004/107/EC)

Final Report

Appendix J: Case Studies

EUROPEAN COMMISSION, DG ENVIRONMENT

SUPPORTING THE FITNESS CHECK OF THE EU AMBIENT AIR QUALITY DIRECTIVES

(2008/50/EC, 2004/107/EC)

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APPENDIX J CASE STUDIES

• Case study Report – Bulgaria

• Case study Report – Germany

• Case study Report – Ireland

• Case study Report – Italy

• Case study Report – Slovakia

• Case study Report – Spain

• Case study Report – Sweden



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Written Mariya Gancheva March 2019

CASE STUDY REPORT

BULGARIA

Supporting the Fitness Check of the EU

Ambient Air Quality Directives

(2008/50/EC, 2004/107/EC)



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Contents

1 Introduction 4

2 Background and context 5

2.1 Bulgaria and air quality zone characteristics 5

2.2 Air quality monitoring and air quality 7

2.3 Allocation of responsibility 13

2.4 Legal and policy framework and air quality measures 14

2.5 Information to the public 16

2.6 Use of EU funding for air quality improvements 17

3 Findings 18

3.1 Relevance of the AAQ Directives 18

3.2 Implementation successes 19

3.3 Implementation challenges 21

3.4 Factors underlying compliance and effectiveness of the AAQ

Directives 25

3.5 Costs and benefits of the AAQ Directives 28

4 Conclusions 32

4.1 Identified problems and potential for improving the

implementation of the Directives 32

4.2 Assessment of the AAQ Directives 33



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Appendices

Appendix A References

Appendix B Interviews

Appendix C Pilot interview guide

Appendix D Areas of air quality management

Appendix E Pollutant concentration data for Bulgaria, 2013-17



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1 INTRODUCTION

This report summarises the findings and conclusions of the case study for Bulgaria. The case

study had a focus on air quality zone Plovdiv Agglomeration.

The report is one of seven case studies carried out for the Fitness Check of the EU Ambient Air

Quality Directives. Its main purpose is to examine, in more detail, the situation regarding the

experience and lessons learnt in the implementation of the air quality legislation. The case studies

provide a basis for a more detailed examination of the questions of the fitness check and include

a review of implementation and integration successes and problems, the costs of implementation

and of non-implementation of the legislation and the administrative burden of implementation

and opportunities for improving implementation without compromising the integrity of the pur-

pose of the Directives. As such, the case study complements the information gathered through

other sources, such as desk review, targeted questionnaire, open public consultation, interviews,

focus groups and stakeholder workshops.

The Member States for detailed case studies have been selected to cover a range of geographies,

governance structures and sizes. This has led to the selection of the following seven case study

Member States: Slovakia, Germany, Spain, Sweden, Ireland, Bulgaria and Italy.

The case study report is structured in four chapters, namely:

• Chapter 1 – Introduction

• Chapter 2 – Background and context, presents general information about the context of

the case study

• Chapter 3 – Findings, presents detailed findings regarding the relevance of the AAQ Direc-

tives, the implementation successes and problems, the factors underlying compliance with

the Directives, the costs and benefits.

• Chapter 4 – Conclusions, presents a summary of the main findings.

The case study findings rely on extensive desk research and a series of interviews that took place

over the period October and November 2018. An overview of the interviews carried out is provided

in Appendix A.

The case study has been shared with the interviewed stakeholders in January 2019 for validation

of findings and correction of factual mistakes. Feedback received from the stakeholders was inte-

grated in the case study report.



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2 BACKGROUND AND CONTEXT

The present chapter contains general information about the air quality framework in Bulgaria.

2.1 Bulgaria and air quality zone characteristics

2.1.1 Scope of the case study

The case study covers the entire territory of Bulgaria and focuses in particular on the Plovdiv

Agglomeration. As shown in Error! Reference source not found. below, for the purpose of

assessing air quality the territory of Bulgaria is divided into six zones of which three agglomera-

tions (Capital, Plovdiv and Varna).

Figure 2-1 Air quality zones for NO₂ and PM10, 2014

Source: European Commission, DG Environment, Atlas of air quality zones and monitoring stations (2013 &

2014), Bulgaria.

The air quality zones correspond to the so-called ‘areas for air quality assessment and manage-

ment’ defined in the national legislation transposing the Ambient Air Quality Directives (AAQDs)1.

These areas are identified by the Minister of Environment and Water and are updated every five

years unless significant changes in the activities causing changes of the concentration levels of

1 Ordinance N12 of 15 July 2010 concerning norms for sulphur dioxide, nitrogen dioxide, particulate matter,

lead, benzene, carbon monoxide and ozone in ambient air.

Ordinance N11 of 14.05.2007 concerning norms for arsenic, cadmium, nickel and polycyclic aromatic hydro-

carbons in ambient air

Ordinance N7 of 3 May 1999 concerning assessment and management of air quality.



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the pollutants are observed. The areas are identified based on assessments and according to any

exceedances of the assessment thresholds defined in the national legislation. The 2013 Order2

issued by the Ministry of Environment and Water (MOEW) has divided the territory of the country

in six ‘areas for air quality assessment and management’ that cover all 28 provinces of the coun-

try. The division of these areas was based on the existing administrative and territorial organisa-

tion of the country and on a preliminary assessment of the air pollution in each municipality.

According to the list of beneficiaries eligible for support under the Operational Programme (OP)

Environment 2014-2020 for development or update of the municipal air quality plans, 28 munic-

ipalities have problems in meeting the AAQD standards and need to prepare air quality plans3.

The information about the air quality zone coverage and the pollutants monitored is summarised

in Appendix D.

2.1.2 Characteristics of air quality zone

The ‘Plovdiv Agglomeration’ air quality zone covers two municipalities, which need to prepare air

quality plans – Plovdiv and Asenovgrad. Together the two municipalities host about 7% of the

population in the country. Furthermore, the Plovdiv Municipality is the most densely populated

area in the country. It is over three times more densely populated than the capital city of Sofia

with an estimated people density of 3,358 in 20164.

The Plovdiv and the Asenovgrad municipalities form an important economic centre and contribute

significantly to the economy of the Plovdiv Province. The main economic sectors in Plovdiv are

manufacturing (primarily metal products, food, machinery and equipment), services (primarily

business services such as IT and wholesale trade but also public and commercial services) and

construction. In 2015, the output of the local non-financial sector was EUR 7.3 billion with an

added value of EUR 2.2 billion5. Leading economic sectors in Asenovgrad are commerce, metal-

lurgy and manufacturing of metal goods, transport and logistics6.

Both municipalities have specific local climatic and geomorphological characteristics that affect air

quality. This is especially relevant for Plovdiv where the geomorphology of the city creates condi-

tions for holding atmospheric masses and forming a specific atmospheric stratification, which

impede the dispersion of air pollution7.

The detailed characteristics of Bulgaria and the Plovdiv Agglomeration are presented in Text box

2-1 below.

2 Order 969 of 21.12.2013, Ministry of Environment and Water and Executive Environment Agency,

http://eea.government.bg/bg/legislation/air/zapoved_96921.12.2013.pdf. 3 Operation Programme Environment 2014-2020, Ongoing calls, BG16M1OP002-5.002, http://ope.moew.gov-

ernment.bg/bg/notice/noticedetail/from/noticecurrent/id/77/typeId/1. 4 National Statistical Institute, 2016, Cities and Their Urbanised Areas in the Republic of Bulgaria 2010-2016,

http://www.nsi.bg/sites/default/files/files/publications/URBAN2016_ENG.pdf. 5 Investment Destination Plovdiv, Local Economy website, http://invest.plovdiv.bg/en/content/local-econ-

omy/. 6 Asenovgrad Municipality, General Economic characteristics website, https://www.assenovgrad.com/ob-

jects.php?cid=46. 7 Plovdiv Municipality, 2011, Update of the programme for improving air quality on the territory of the Plovdiv

Municipality 2003-2010 and preparation of Action plan for the period 2011-2013, http://www.plovdiv.bg/wp-

content/uploads/okolna-sreda/normativni-dokumenti/Plovdiv_Programa_KAV_2011-

2013_Plan%20za%20deistvie.pdf.

http://eea.government.bg/bg/legislation/air/zapoved_96921.12.2013.pdf

http://ope.moew.government.bg/bg/notice/noticedetail/from/noticecurrent/id/77/typeId/1




http://www.nsi.bg/sites/default/files/files/publications/URBAN2016_ENG.pdf

http://invest.plovdiv.bg/en/content/local-economy/




https://www.assenovgrad.com/objects.php?cid=46




http://www.plovdiv.bg/wp-content/uploads/okolna-sreda/normativni-dokumenti/Plovdiv_Programa_KAV_2011-2013_Plan%20za%20deistvie.pdf





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Text box 2-1 Bulgaria and the Plovdiv Agglomeration

Bulgaria

GDP per capita in PPS (2016) 49

GDP per capita growth (% 2008-2016) 18%

Population (1 January 2017) 7.1 million

Governance structure Unitary

Zones defined as agglomerations (%) 50%

Plovdiv Agglomeration

Number of inhabitants (2016) Plovdiv Municipality: 342,525

Asenovgrad Municipality: 61,993

Area: 1,390 km2

Characteristics of the Plovdiv Agglomeration:

The city of Plovdiv is the second largest city after the capital and the administrative centre of the Plovdiv

Municipality and the Plovdiv Province. It is located in the Southern part of Bulgaria, on the banks of the

Maritsa river and in the Upper Thracian Plain. It is in a transitional continental climate zone but its micro-

climate is affected by the seven city hills (ranging 176-286 m in altitude) and the mountains surrounding

the Plovdiv plateau in every direction. The latter creates conditions for holding atmospheric masses and

forming a specific atmospheric stratification that impede the dispersion of air pollution.

Asenovgrad, which is located 19km south of Plovdiv in the steps of the Rhodope Mountains, is the second

biggest city in the Plovdiv Province and the administrative centre of the Asenovgrad Municipality. The area

of the municipality varies as is partly a plateau (210-230 m in altitude) and partly semi-mountainous (240-

400 m in altitude).

Sources: Eurostat, GDP per capita in Purchasing Power Standards (PPS) expressed in relation to the European

Union (EU28) average set to equal 100; Eurostat, Real GDP per capita, growth rate and totals; Eurostat,

Population on 1 January; Eionet data. National Statistical Institute, 2016, Cities and Their Urbanised Areas in

the Republic of Bulgaria 2010-2016, and air quality plans of the Plovdiv and Asenovgrad municipalities.

2.2 Air quality monitoring and air quality

The following section presents briefly the arrangements for air quality monitoring and provides a

short overview of air quality problems and achievements in Bulgaria. 4.2.5Appendix E includes an

overview of the reported exceedances in the European Environment Agency's (EEA) database.

2.2.1 Air quality monitoring

Bulgaria has fulfilled its obligations concerning the number of monitoring stations and the param-

eters monitored. The national monitoring system for air quality is part of the national monitoring

system of the environment of MOEW. It consists of 48 monitoring stations: 30 fixed automated

measuring stations (AMS); 4 AMS for air quality monitoring in forest ecosystems; 5 Differential



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Optical Absorption Spectroscopy (DOAS) systems; and 9 stations for manual sampling and con-

sequent laboratory analysis. In addition, the system has 6 mobile automated stations (MAS) dis-

tributed proportionally in the regional laboratories in Sofia, Plovdiv, Pleven, Stara Zagora, Varna

and Ruse in order to cover the territory of the whole country and provide additional monitoring

(e.g. in areas without any or sufficient number of stations, in cases of emergency or after requests

by public and municipal organisations). The MAS operate according to an agreed yearly schedule

prepared by the Regional Inspectorates for Environment and Water (RIEWs) and the Executive

Environment Agency (ExEA) and approved by MOEW and monitoring points selected within the

municipalities where air quality plans are prepared to help track the implementation of these

plans8.

The national monitoring system for air quality controls the concentrations of the following pollu-

tants: particulate matter (PM10 and PM2.5), sulphur dioxide (SO2), nitrogen dioxide (NO2) and

nitrogen oxides (NOx), carbon monoxide (CO), ozone (O3), benzene (C6H6), lead (Pb), cadmium

(Cd), nickel (Ni), arsenic (As), polycyclic aromatic hydrocarbons (PAHs) as well as other pollutants

in specific areas. All AMS and DOAS stations work uninterruptedly and provide real time data to

the regional dispatch points and regional databases of the RIEWs and the central dispatch point

and national database managed by the ExEA. The stations for manual sampling take samples 4

times a day, 5 days a week with the exception of PM10 for which the sampling is every 24 hours9.

The monitoring system within the Plovdiv Agglomeration covers three monitoring stations. In the

Plovdiv Municipality there are two AMS that together monitor O3, NO, NO2, SO2, CO, PM10, PM2.5,

C6H6, Cd, C8H10 (xylene), C7H8 (toluene) and C20H12 (benzo[a]pyrene or BaP)10. In the Asenovgrad

Municipality there is only one monitoring station for manual sampling, which monitors PM10, Pb

and Cd11.

In addition to the two AMS on its territory, the Plovdiv Municipality has installed one automated

meteorological monitoring station that complements the AMS for air quality monitoring. Together

all these stations form the ‘system for air quality monitoring on the territory of the Plovdiv Mu-

nicipality’ managed together by the Municipality, the local RIEW and the National Institute for

Meteorology and Hydrology (NIMH)12. The system has been operational since 2004 and provides

monitoring, real time dispersion modelling, analysis of the emission sectors contribution, and

dispersion modelling of an accidentally released passive substance13.

2.2.2 Air quality in Bulgaria

Despite a decrease in emissions of some pollutants since 1990 (notably sulphur oxides, nitrogen

oxides, non-methane volatile organic compounds (NMVOCs) and ammonia), emissions from other

pollutants have increased (e.g. PM2.5)14 and the air quality in Bulgaria remains a concern. This

has resulted in exceedances of the EU limit values for some pollutants, although the number of

8 Executive Environment Agency, Technical condition of the National automated system for air quality control

in the first six months of 2018 website (http://eea.government.bg/bg/nsmos/spravki/2018/air2) and infor-

mation provided during the stakeholder interview. 9 Ibid. 10 Plovdiv Municipality, 2018, Programme for improving air quality on the territory of the Plovdiv Municipality

for the period 2018-2023. 11 Asenovgrad Municipality, 2016, Programme (corrected and expanded) for decreasing the levels of pollution

with particulate matter (PM10) and cadmium (Cd) and reaching the established standards in ambient air, with

Action plan 2016-2019. 12 Plovdiv Municipality, Local system for air quality website. 13 Atanassov, D. et al. 2013, Air Quality Management System of the City of Plovdiv – Annual Analysis for 2013. 14 Ministry of Environment and Water and Executive Environment Agency, 2018, National report on the state

and protection of the environment.

http://eea.government.bg/bg/nsmos/spravki/2018/air2




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exceedances is generally decreasing. More specifically, the country persistently breached the limit

values for PM10 and the limit value for SO2 in one zone, which resulted in infringement procedures

by the European Commission. In addition, the limit values for PM2.5 were exceeded in four air

quality zones although the values became binding only in 2015. At the same time the long-term

objectives for O3 concentrations were not met in several air quality zones15.

The following table provides a summary of the emissions of air pollutants over the evaluation

period (2008-2018) based on the national reports on the state of the environment.

Table 2-1 Emissions of air pollutants in Bulgaria over the evaluation period

Pollutant 2008 2009 2010 2011 2012 2013 2014 2015 2016

PM10 (1000 t/y) 59 45 41 45 44 42 46 50 48

PM2.5 (1000 t/y) - - - - - - 34 29 32

3232 SO2 (1000 t/y) 735 657 387 515 329 194 189 142 105

NO2 (1000 t/y) 194 165 116 138 127 124 134 132 126

CO (1000 t/y) 445 475 321 370 446 346 318 314 271

NMVOC (1000 t/y) 309 332 280 283 279 277 287 282 273

Pb (t/y) 323 291 107 120 117 76 198 81 67

Cd (t/y) 4 3 2 2 2 1 2 1 2

PAH (t/y) 19 88 64 30 32 30 28 27 17

Source: Ministry of Environment and Water and Executive Environment Agency, National reports on the state

and protection of the environment 2008-2018.

The main sources of pollutants are coal-fired thermal power plants (TPPs) for SO2 emissions, road

transport for NO2 emissions and domestic heating for PM emissions. Agriculture is the main source

of ammonia emissions while natural sources contribute to the largest part of NMVOC emissions16.

The underlying factors determining the main air pollution source, which is by far domestic heating,

are of socio-economic nature and often stem from the energy poverty of numerous households17.

The following table summarises the shares of each source in the emissions of the main air pollu-

tants for 2016 (although the exact values differ, the same trends are observed over the entire

evaluation period).

15 European Commission, 2017, The EU Environmental Implementation Review, Country Report – Bulgaria,

SWD (2017) 35 final. 16 Ministry of Environment and Water and Executive Environment Agency, 2018, National report on the state

and protection of the environment, http://eea.government.bg/bg/soer/2016/soer-bg-2016.pdf. 17 EUROSAI, 2019, Joint report on air quality, https://english.rekenkamer.nl/publications/re-

ports/2019/01/30/joint-report-air-quality.

http://eea.government.bg/bg/soer/2016/soer-bg-2016.pdf


https://english.rekenkamer.nl/publications/reports/2019/01/30/joint-report-air-quality






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Table 2-2 Contribution of the main sources to air pollutant emissions (share of emissions in 2016)

Source SO2 NO₂ PM10 PM2.5 NMVOC

TPPs 55% 22% 2% - -

Road transport - 34% 7% 8% 4%

Domestic heating 7% - 56% 82% 8%

Agriculture - - - - 4%

Source: Ministry of Environment and Water and Executive Environment Agency, 2018, National report on the

state and protection of the environment.

A significant part of the urban population in Bulgaria remains exposed to air pollution above the

EU standards. The table below shows the percentage of urban population exposed to concentra-

tions above EU standards.

Table 2-3 Percentage of urban population in Bulgaria exposed to concentrations above EU standards

P

o

l

l

u

t

a

n

t

Measure 2011 2012 2013 2014 2015 2016

P

M

2

.

5

Annual mean 92.4 92.2 78.1 78.1 25.7 0.0

P

M

1

0

Percentile 90.41 100.0 97.2 90.9 96.7 77.8 86.8

O

3

Percentile 93.15 2.1 46.3 0.0 0.0 0.0 0.0

N

O

₂

Annual mean 16.6 1.3 0.5 0.0 0.2 7.1

B

a

P

Annual mean - 36.5 34.2 25.4 34.7 -

Source: European Environment Agency, Bulgaria – air pollution country fact sheet 2017 and 2018.

2.2.3 Compliance with EU ambient air quality standards

In 2016 (the latest year for which national and EEA data is available), Bulgaria exceeded the limit

values for concentrations of PM10, PM2.5, BaP and SO2. The concentrations of PM10 exceeded the

annual limit values in 11 stations, while the Average Exposure Indicator (AEI) for PM2.5 was above

the exposure concentration obligation for Bulgaria (25g/m3). The annual mean concentration of

BaP exceeded 1ng/m3 in seven stations, while the hourly and daily limit values for SO2 were

breeched in one station18.

The latest National Report on the State and Protection of the Environment19 reports that the

overall trend is for the emissions of key pollutants to decrease, namely in the period 1990-2016

the emissions of SO2, NO2, NMVOC, and ammonia have decreased. Nevertheless, the emissions

of PM2.5 and PM10 remain problematic. The report summarises the state of air quality in Bulgaria

for 2016 as follows:

18 European Environment Agency, 2018, Air quality in Europe — 2018 report, https://www.eea.eu-

ropa.eu/publications/air-quality-in-europe-2018. 19 Ministry of Environment and Water and Executive Environment Agency, 2018, National report on the state

and protection of the environment, http://eea.government.bg/bg/soer/2016/soer-bg-2016.pdf.

https://www.eea.europa.eu/publications/air-quality-in-europe-2018







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Non-compliance with the EU standards

• PM10: Pollution with PM10 continues to be one of the main problems for air quality, it is caused

primarily by domestic heating with solid fuels in the winter period (October-March) and road

transport. In 2016, exceedances of the average daily limit were observed in all air quality

zones. The most exceedances were registered in an AMS in the North air quality zone. Nev-

ertheless, in many cities the average annual concentrations and the number of exceedances

of the limit values decreased in the period 2012-2016.

• PM2.5: Pollution with PM2.5 is another problematic area, the main sources of PM2.5 emissions

are transport, domestic heating and industry. In 2016, the average annual limit was ex-

ceeded by only two air quality zones, namely Plovdiv and South-West. However, average

exposure of the population (i.e. the AEI) decreased since 2015.

• BaP: The target average annual value was exceeded in 10 of the 15 stations monitoring the

parameter. Furthermore, the decreasing trend observed over 2012-2015 was not kept and

emission increased in 2016.

• O3: In 2016, the short-term target value was exceeded for over 25 days only in three back-

ground stations.

• SO2: Even though the overall emissions have decreased and this is not a problematic pollu-

tant at the national level, exceedances persist in the South-East air quality zone. The main

sources of SO2 in this area are the TPPs of the Maritsa-East complex.

• NO2: None of the stations registered exceedances of the average hourly limit and exceed-

ances of the average annual limit were registered only for three AMS.

Compliance with the EU standards

• Cd: No exceedances of the target average annual limit achieved that should be achieved in

2013 and maintained further on.

• Pb: No exceedances of the average annual limit value in 2016.

• Ni: No exceedances of the target average annual limit in 2016.

• As: No exceedances of the target average annual limit in 2016.

• CO: No exceedances of the target average annual limit in 2016.

• C6H6: No exceedances of the target average annual limit in 2016.

The report notes that the percentage of the population exposed to pollution with PM10 and BaP

above the EU standards remains high, while the proportion of the population living with high

levels of PM2.5 decreased significantly since 2015 and no population is exposed to O3 emissions

above the standards.



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Table 2-4 Percentage of the population affected by concentrations of PM10, O3, NO2, PM2.5, BaP and SO2

above the EU standards (2016)

Air quality zone PM10 PM2.5 O3 NO₂ SO2 BaP

Sofia 100 0 0 0 0 100

Plovdiv 100 100 0 3.6 0 100

Varna 50 0 0 50 0 0

North 87.2 0 0 22.7 0 100

South-West 100 100 0 0 40.7 100

South-East 69.5 0 0 0 0 26.4

Total for the country 87.2 18 0 9.7 2.8 75.1

Source: Ministry of Environment and Water and Executive Environment Agency, 2018, National report on the

state and protection of the environment.

Compliance in the Plovdiv Agglomeration

The problematic pollutants in the Plovdiv Municipality are PM10, PM2.5, NO2 and BaP. Estimations

suggest that the population exposed to concentrations above the limit values in the Plovdiv Mu-

nicipality were around 15% for PM2.5 and all of the population for BaP in 201120. Despite overall

reductions in the annual concentrations of these pollutants since 2010, exceedances of the limit

values still persist. Data for 2016 shows: 196 exceedances of the average daily limit value for

PM10 in the two monitoring stations of the municipality; 11 exceedances of the average daily limit

for NO2 in only one of the monitoring stations, which is below the 18 exceedances allowed per

year; exceedances of the average annual concentrations of PM2.5 and the average annual target

value for BaP. The main sources of the emissions are domestic heating with burning of solid fuels

and transport, followed by industry and construction. Therefore, higher emissions and more fre-

quent exceedances of the limit values are registered in the cold period of the year (usually Octo-

ber-March). In addition, the unique micro-climate conditions in Plovdiv (in particular the high

number of days within a year without wind and/or rain, with temperature inversions and fogs)

exacerbate the concentration of pollutants in the air21.

Nevertheless, concentrations of PM10 and NO2 are problematic in other European cities too. A

study22 of the urban air quality in 10 European cities shows that over the period 2013-2017 the

annual average concentrations of PM10 exceeded the EU limit in Plovdiv, but this was the case for

another city as well (Milan). In the same period, the annual average NO2 concentrations in Plovdiv

decreased and complied with the EU limit values.

20 Plovdiv Municipality, Programme for reaching the standards of particulate matter smaller than 2.5 micrones

(PM2.5) and polycyclic aromatic hydrocarbons (PAHs) in the ambient air on the territory of the Plovdiv Munic-

ipality with Action plan for the period 2013-2015, http://www.plovdiv.bg/wp-content/uploads/okolna-

sreda/Program_AQ_PM2,5&PAH_Pd_2013_2015.Plovdiv.pdf. 21 Plovdiv Municipality, 2018, Programme for improving air quality on the territory of the Plovdiv Municipality

for the period 2018-2023. 22 European Environment Agency, 2018, Europe's urban air quality — re-assessing implementation chal-

lenges in cities, https://www.eea.europa.eu/publications/europes-urban-air-quality.

http://www.plovdiv.bg/wp-content/uploads/okolna-sreda/Program_AQ_PM2,5&PAH_Pd_2013_2015.Plovdiv.pdf



https://www.eea.europa.eu/publications/europes-urban-air-quality




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In the Asenovgrad Municipality, problematic are the concentrations of PM10 and Cd. In 2014, the

population exposed to concentrations of PM10 above the limit values was 3,500 people or around

7% of the total population. While the average annual concentration of both pollutants have de-

creased since 2011, exceedances of the limit values still occur. Data for 2015 shows: 98 exceed-

ances of the average daily limit value for PM10 and exceedance of the target annual concentration

for Cd. The main sources of emissions are domestic heating with burning of solid fuels, transport

and industry. Notably, a significant source of Cd emissions in the area is the production of non-

ferrous metals. Similarly to Plovdiv, the exceedances are more predominant in winter, while the

climatic conditions exacerbate the situation23.

Enforcement and infringement cases

In June 2015 the European Commission referred Bulgaria to the European Court of Justice over

the continued breech of PM10 emissions limits, noting ‘non-compliance with the annual and/or

daily limit values for PM10 in all the country's 6 zones and agglomerations other than in Varna,

which complied with the annual limit value once – in 2009’24. In 2017, the European Court of

Justice issued a judgement against Bulgaria confirming the Commission’s view that persistent

exceedances necessitate more effective measures25. In November 2018, the European Commis-

sion expressed concern that the country is showing only limited progress in adopting measures

to remedy the situation and urged Bulgaria to fully comply with the Court’s ruling. At the same

time, the European Commission also sent a letter of formal notice calling Bulgaria to bring the

national legislation fully in line with the AAQDs (specifically Directive 2008/50/EC) concerning the

provisions to keep periods of exceedance of permitted values as short as possible26.

2.3 Allocation of responsibility

The responsibility to develop overall policies for air quality and the environment in general is held

by the MOEW. The main responsibility for monitoring of ambient air quality lies with the MOEW,

the ExEA and the RIEWs. The MOEW defines the number and type of monitoring stations, the

pollutants, methods and sampling of the national monitoring system for air quality. The day-to-

day management of the system is delegated to the RIEWs and the ExEA which collect regional

and national real time air quality data respectively27.

In areas where the emissions of pollutants exceed the limit values, the mayors and the munici-

pality councils develop and adopt programmes for reducing the levels of the pollutants and

meeting the standards (i.e. air quality plans) in the municipalities affected. These programmes

are consulted with the relevant RIEWs and when necessary they can be ‘complex programmes’

to cover multiple pollutants28. In addition, the MOEW has developed instructions on e.g. how the

23 Asenovgrad Municipality, 2016, Programme (corrected and expanded) for decreasing the levels of pollution


Action plan 2016-2019, https://www.assenovgrad.com/userfiles/file/docs3/Pg-A-grad%203.pdf. 24 European Commission, 2015, Commission refers BELGIUM and BULGARIA to Court and gives Sweden a

final warning over poor air quality, press release IP-15-5197, http://europa.eu/rapid/press-release_IP-15-

5197_en.htm. 25 Judgment of the Court of Justice of 5 April 2017 in C-488/15, Commission v Bulgaria, http://curia.eu-

ropa.eu/juris/liste.jsf?num=C-488/15. 26 European Commission, 2018, November infringements package: key decisions, European Commission –

Fact Sheet, 8 November 2018, http://europa.eu/rapid/press-release_MEMO-18-6247_en.htm. 27 Executive Environment Agency, Monitoring of air, noise and radiology website, http://eea.govern-

ment.bg/bg/nsmos/air. 28 Plovdiv Municipality, 2018, Programme for improving air quality on the territory of the Plovdiv Municipality

for the period 2018-2023.

https://www.assenovgrad.com/userfiles/file/docs3/Pg-A-grad%203.pdf

http://europa.eu/rapid/press-release_IP-15-5197_en.htm


http://curia.europa.eu/juris/liste.jsf?num=C-488/15




http://europa.eu/rapid/press-release_MEMO-18-6247_en.htm

http://eea.government.bg/bg/nsmos/air






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municipal air quality plans should be prepared and how the public should be informed when the

alarm thresholds are breeched together with more methodological guidelines on e.g. how the air

quality plans should be developed and how local SO2, PM10, Pb and NO2 emissions could be as-

sessed and managed29.

According to the instructions for development of air quality plans, municipalities establish ‘Pro-

gramme Councils’ consisting of representatives from the RIEWs, Ministry of Interior, Health In-

spectorates, civil protection and other relevant institutions. The councils coordinate the prepara-

tion of the air quality plans, their adoption, implementation and monitoring. Interested parties

can share their concerns or suggestions with the Programme Councils during the preparation

process or comment on the draft air quality plans when those are shared on the municipal web-

sites30.

2.4 Legal and policy framework and air quality measures

Legal framework

Directive 2008/50/EC was transposed in the national legislation through the ‘Ordinance N12 of 15

July 2010 concerning norms for sulphur dioxide, nitrogen dioxide, particulate matter, lead, ben-

zene, carbon monoxide and ozone in ambient air’ (hereafter ‘Ordinance 12’)31 in force from 31

July 2010 and later amended in June 2017. Directive 2004/107/EC was transposed with ‘Ordi-

nance N11 of 14.05.2007 concerning norms for arsenic, cadmium, nickel and polycyclic aromatic

hydrocarbons in ambient air’ (hereafter ‘Ordinance 11’) in force from 27 May 2007 and later

amended in March 2017. In addition, ‘Ordinance N7 concerning assessment and management of

air quality’ defines the conditions and processes for air quality assessment and management,

while the overall priorities, principles and responsibilities for air quality are defined in the Air

Quality Act32. The Air Quality Act was amended in January 2019 to clarify the transposition of the

provisions to keep periods of exceedance of permitted values as short as possible and to respond

to the Commission’s letter of formal notice from November 2018.

Strategic framework

Bulgaria did not have a dedicated air quality strategy in the evaluation period (2008-2018). The

most recent strategic document defining priorities and targets for air quality in that period is the

2007 ‘National Programme for reducing the overall annual emissions of sulphur dioxide, nitrogen

oxides, volatile organic compounds and ammonia in ambient air’33. This strategy defined 2010

targets for meeting the objectives of the now repealed National Emission Ceilings (NEC) Directive

29 Instructions and guidance documents are available on the website of the MOEW, ‘Air quality – normative

acts’ webpage, https://www.moew.government.bg/bg/vuzduh/kachestvo-na-atmosferniya-vuzduh/norma-

tivni-aktove/. 30 Instruction for developing programs to reduce emissions and achieve the established limits of harmful

substances in the areas for air quality assessment and management where there is exceedance of the estab-

lished limits, established with Order 996/20.12.2001 and available on the MOEW website,

https://www.moew.government.bg/bg/vuzduh/kachestvo-na-atmosferniya-vuzduh/normativni-aktove/. 31 Weblinks to the national legislation mentioned can be found in Appendix A. 32 Executive Environment Agency, Legislation concerning ambient air quality website, http://eea.govern-

ment.bg/bg/legislation/air. 33 Ministry of Environment and Water, 2007, National Programme for reducing the overall annual emissions

of sulphur dioxide, nitrogen oxides, volatile organic compounds and ammonia in ambient air,

https://www.moew.government.bg/static/media/ups/tiny/filebase/Air/Strategicheski_dikumenti/Na-

tional_Programm_decr_annual_em_SO2_NOx_NH3_VOC.pdf.

https://www.moew.government.bg/bg/vuzduh/kachestvo-na-atmosferniya-vuzduh/normativni-aktove/





http://eea.government.bg/bg/legislation/air




https://www.moew.government.bg/static/media/ups/tiny/filebase/Air/Strategicheski_dikumenti/National_Programm_decr_annual_em_SO2_NOx_NH3_VOC.pdf






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2001/81/EC and defined measures to adopt relevant legislation, control the technical functionality

of the vehicle fleet and develop strategies on renewable energy and energy efficiency.

Nevertheless, a national air quality programme was developed in 2018 by experts from the World

Bank and its draft was shared for a one-month public consultation in November 201834. The MOEW

clarified that the programme is nearly finished and its adoption is expected in the near future35.

The programme’s horizon is 2024 and its focus is on the sectors that contribute the most to the

high emissions of the most problematic air pollutants – domestic heating and transport. As the

responsibilities to implement specific measures lie with the municipalities where air quality prob-

lems are identified, the national programme does not change the obligations and responsibilities

of the municipalities but aims to support them. It identifies sectors where the municipalities can-

not act and where solutions at the national level are required e.g. for minimum requirements of

the quality of the fuels sold on the market or more stringent requirements for the technical checks

of vehicles. While the development of a national programme is considered a step in the right

direction, some stakeholders have questioned its focus on only the municipalities that currently

do not meet the AAQD standards (see section 2.1) instead of the whole country36 and the lack of

consideration of measures related to other sectors in which local authorities lack competences to

act such as regulation of industrial installations37.

Air quality measures: air quality plans and action plans

Since 2011, the Plovdiv Municipality has developed and implemented two separate air quality

plans or ‘programmes’ with integrated action plans to target specific pollutants: a programme to

reduce the levels of PM10 and NO2 (2011-2013)38 and a programme to reduce the levels of PM2.5

and BaP (2013-2015)39. Overall, the air quality plans contributed to meeting the objectives for

some pollutants, while improving the performance concerning others. For instance, the first air

quality plan resulted in fulfilment of the objectives concerning SO2 and Cd emissions through

measures targeting the industry and these emissions have not been problematic since. However,

the emissions of other pollutants, such as PM10, PM2.5, BaP and NO2, remain a concern despite the

various measures the Municipality planned and implemented over the years.

The measures included targeting emissions of the domestic heating sector (e.g. information cam-

paigns, facilitation of gasification of the households, social schemes for purchasing better quality

fuels), the transport sector (e.g. renewal of the vehicle fleet of the public transport, development

of the trolley bus system, improvement of the road infrastructure) and industry. Overall, all

measures contributed to decreasing or at least limiting these emissions but were not sufficient to

34 Council of Ministers, Portal for Public Consultations, Draft National Programme for Improving the Air Quality

(2018-2024) website, http://www.strategy.bg/PublicConsultations/View.aspx?lang=bg-BG&Id=3846. 35 At the time of the interview, MOEW explained that a stakeholder workshop will be held in the last week of

September 2018 to present the draft programme. Then it will be reviewed by the Council of Ministers and

depending on the feedback of other ministries it will be adopted. 36 Feedback provided by the EAP. 37 Za Zemiata and Greenpeace Bulgaria, 2018, Position concerning the Draft National Programme for Improv-

ing the Air Quality (2018-2024), http://archive.zazemiata.org/v1/fileadmin/content/energy/docs/stanov-

ishte-NPKAV-ZaZemiata-GreenpeaceBG.pdf. 38 Plovdiv Municipality, 2011, Update of the programme for improving air quality on the territory of the Plovdiv

Municipality 2003-2010 and preparation of Action plan for the period 2011-2013, http://www.plovdiv.bg/wp-

content/uploads/okolna-sreda/normativni-dokumenti/Plovdiv_Programa_KAV_2011-

2013_Plan%20za%20deistvie.pdf. 39 Plovdiv Municipality, Programme for reaching the standards of particulate matter smaller than 2.5 micrones

(PM2.5) and polycyclical aromatic hydrocarbons (PAHs) in the ambient air on the territory of the Plovdiv

Municipality with Action plan for the period 2013-2015, http://www.plovdiv.bg/wp-content/uploads/okolna-

sreda/Program_AQ_PM2,5&PAH_Pd_2013_2015.Plovdiv.pdf.

http://www.strategy.bg/PublicConsultations/View.aspx?lang=bg-BG&Id=3846

http://archive.zazemiata.org/v1/fileadmin/content/energy/docs/stanovishte-NPKAV-ZaZemiata-GreenpeaceBG.pdf











(2008/50/EC, 2004/107/EC)

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make the municipality permanently fulfil its objectives and meet the required limit values40. There-

fore, in July 2018, the Municipality published an updated air quality plan or ‘programme’ that

covers all four pollutants for which exceedances of the limit values persist – PM10, PM2.5, BaP and

NO2 and outlined further measures to address these exceedances (often by prolonging the imple-

mentation of measures undertaken in the previous plans)41.

The measures that have been implemented in the period 2013-2017 and are planned for contin-

ued implementation include measures in two key areas42:

• Domestic heating:

- Ban on marketing, sale and distribution of bituminous coal for household heating/cook-

ing;

- Fuel conversion in domestic heating;

- Promoting substitution of old, dirty stoves and boilers with clean models;

- Energy-efficient buildings with insulation;

- Use of renewable energy sources.

• Road transport:

- Low-emission zone;

- Promoting cycling;

- Managing traffic flow by reduced speed limits and congestion charges.

The notable successes and air quality good practices implemented in Plovdiv include modernisa-

tion of the bus fleet of the public transport, installation of air filters on chimneys and extension

of the cycling lanes43.

The Asenovgrad Municiaplity has published only one air quality plan with an integrated action plan

to target PM10 and Cd emissions in the period 2016-201944.

2.5 Information to the public

According to Art. 20 of the Air Quality Act45, the air quality is monitored with the national system

for monitoring and control of the environment of the MOEW, local authorities can install additional

monitoring stations if they wish to do so. The information from the national and any local moni-

toring systems is public property and is published in the official bulletins of MOEW or its related

institutions free of charge (Art. 23). Consequently, the ExEA publishes a daily bulletin46 on the air

quality in the country on its website. The bulletin shows only the registered exceedances of the

limit values of given pollutants (namely SO2, NO2, PM10, CO and O3) and the stations where they

40 Based on the information provided in the air quality plans (see the previous two footnotes). 41 Plovdiv Municipality, 2018, Programme for improving air quality on the territory of the Plovdiv Municipality

for the period 2018-2023. 42 European Environment Agency, 2018, Europe's urban air quality — re-assessing implementation chal-

lenges in cities, https://www.eea.europa.eu/publications/europes-urban-air-quality. 43 EUROSAI, 2019, Joint report on air quality, https://english.rekenkamer.nl/publications/re-

ports/2019/01/30/joint-report-air-quality. 44 Asenovgrad Municipality, 2016, Programme (corrected and expanded) for decreasing the levels of pollution


Action plan 2016-2019, https://www.assenovgrad.com/userfiles/file/docs3/Pg-A-grad%203.pdf. 45 Air Quality Act, latest amendment from 03.02.2017, available for download from the MOEW website,

https://www.moew.government.bg/bg/vuzduh/zakonodatelstvo/zakoni/. 46 Executive Environment Agency, Daily Bulletin on air quality in the country website, http://eea.govern-

ment.bg/airq/bulletin.jsp.








https://www.moew.government.bg/bg/vuzduh/zakonodatelstvo/zakoni/


http://eea.government.bg/airq/bulletin.jsp






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occurred based on real time data. The information is published for the preceding day and infor-

mation about other days can be found through a menu searching the archive. In addition, the

ExEA publishes quarterly bulletins47 on the air quality in the country based on real time data that

has been verified. These quarterly bulletins contain information about SO2, NO2, PM10, PM2.5, O3,

CO and C6H6 levels. Summary results, trend assessments for all pollutants and analyses of air

quality are published in the annual National Reports on the State and Protection of the Environ-

ment.

Furthermore, MOEW has defined alert thresholds for the concentrations of SO2, NO2 and O3 for

which the public should be informed. If these levels are exceeded48, the RIEWs inform local au-

thorities, the media and stakeholders about the time and duration of the exceedance, the prog-

nosis concerning the expected change of the pollution levels, underlying causes, the areas af-

fected, the sensitive population groups and preventive measures that should be taken49. The ExEA

also manages a common SMS alarm system that connects the ExEA, MOEW, RIEWs and the mu-

nicipalities and automatically informs them of any exceedance of the alert thresholds50.

In addition to the information provided by the ExEA, some municipalities have installed infor-

mation boards that provide real time data about some parameters using the data from the AMS

system. The Plovdiv Municipality has an information board installed in front of the municipality

building that provides daily information about the air and meteorological conditions in the city51.

Moreover, the website of the Municipality publishes user-friendly information about the levels of

NO2, SO2, PM10, benzene and O3 for each of the two AMS in its territory based on the real time

data received. The levels of each pollutant are denoted with a simple traffic-light system that

distinguishes between good, acceptable, bad and very bad levels, indicates which parts of the

population might be sensitive and provides simple tips for action52. In addition, non-interactive

graphics in image format show the hourly concentrations of the main pollutants over a 24-hour

period53. Nevertheless, the website cautions that the information is based only on preliminary

hourly values that are also subject to verification by the ExEA in its quarterly bulletins.

2.6 Use of EU funding for air quality improvements

Bulgaria did not specifically target air quality with its OP Environment implementing the EU Co-

hesion Policy Funds in the period 2007-2013 but measures related to e.g. transport were sup-

ported with other OPs. Nevertheless, in OP Environment for the period 2014-202054, air quality is

a designated priority axis with the specific objective of ‘Reducing ambient air pollution by lowering

the quantities of PM10 and NOx’ and a budget of EUR 50 million. More specifically, the OP will

47 Executive Environment Agency, Quarterly Bulletin on the state of the environment website, http://eea.gov-

ernment.bg/bg/dokladi/threemonth/threemonth.02_2018/index. 48 The alert thresholds are: 500 µg/m3 (SO2), 400 µg/m3 (NO2) and 240 µg/m3 (O3, average hourly value)

measured in three consecutive hours at monitoring stations that are representative of the air quality in a

region or agglomeration. 49 Regional Inspectorate for Environment and Water – Plovdiv, Informing the public in case of exceedance of

the alert thresholds website, http://plovdiv.riosv.com/main.php?module=info&object=info&ac-

tion=view&inf_id=31. 50 Interview with ExEA. 51 Plovdiv Municipality, Local system for air quality website. 52 Plovdiv Municipality, Monitoring of the Environment, Air Quality website, http://ecomonitoring.plov-

div.bg/plovdiv/air_quality.jsp. 53 Plovdiv Municipality, Monitoring of the Environment, Real Time Parameters website, http://ecomonitor-

ing.plovdiv.bg/plovdiv/air_params.jsp. 54 Operational Programme Environment 2014 – 2020, CCI: 2014BG16M1OP002, http://ope.moew.govern-

ment.bg/files/useruploads/files/ope_2014-2020_amendment_en_july2017.pdf.

http://eea.government.bg/bg/dokladi/threemonth/threemonth.02_2018/index




http://plovdiv.riosv.com/main.php?module=info&object=info&action=view&inf_id=31




http://ecomonitoring.plovdiv.bg/plovdiv/air_quality.jsp




http://ecomonitoring.plovdiv.bg/plovdiv/air_params.jsp




http://ope.moew.government.bg/files/useruploads/files/ope_2014-2020_amendment_en_july2017.pdf






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March 2019 18

target pollution from domestic heating and transport and foresees the support of three types of

measures:

• Air quality plans: review and analysis of the municipal plans on ambient air quality and sup-

port for their preparation/revision, implementation and control;

• Measures addressing pollution from domestic heating: replacement of domestic combustion

installations/boilers on solid fuel, installation of PM filters on individual domestic combustion

installations, alternative heating;

• Measures addressing pollution from public transport: reducing the use of conventional fuel in

public transport, replacement of the public transport vehicles exhaust systems (retrofitting)

and supplementary measures.



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March 2019 19

3 FINDINGS

Chapter 3 presents detailed findings regarding the experience and lessons learnt in the imple-

mentation of the AAQDs in Bulgaria and the Plovdiv Agglomeration in particular. Specifically, the

chapter focuses on the challenges and successes encountered in the implementation of the Direc-

tives. Additionally, the relevance of the AAQDs, and their air quality standards, has been explored.

Finally, the chapter identifies the factors underlying compliance with and effectiveness of the

AAQDs and provides an overview of the costs and benefits associated with the implementation of

the Directives.

The findings presented in this chapter rely primarily on input provided by stakeholders interviewed

in the context of the case study. These were supplemented as relevant by additional desk re-

search. An overview of the interviews carried out is provided in Appendix B.

3.1 Relevance of the AAQ Directives

The desk research carried out for this case study found that air quality remains an issue in Bulgaria

primarily due to exceedances of the EU standards for PM10 and PM2.5. The country struggles also

with the BaP, NO2 and SO2 concentrations but to a lesser extent as these emissions are exceeded

only in some air quality zones. These findings were confirmed by all stakeholders interviewed who

stressed that PM pollution remains problematic in the whole country and even more so in the big

cities.

The findings of the 2017 Special Eurobarometer study55 show that air quality is a concern for

Bulgarian citizens. 59% of the respondents thought that air quality in Bulgaria deteriorated over

the last 10 years, 27% thought it stayed the same and only 5% considered that it improved. The

proportion of the respondents that considered the air quality in Bulgaria improved over the last

10 years is one of the smallest in the EU.

While the objective of controlling pollutant emissions promoted by the AAQDs is highly relevant

for Bulgaria, the relevance of the particular standards has been questioned. The MOEW is con-

cerned that the standards set at the EU level do not take into account either the specific climate

and meteorological conditions of each country, nor its economic or social situation. This results in

imposing standards that are difficult to attain in some areas due to specific local meteorological

conditions or economic and social constraints that make some measures unfeasible or ineffective.

In the Plovdiv Agglomeration in particular, the impact of the local meteorological and geomorpho-

logical conditions in retaining air pollution has been pointed out as a particular challenge in the

municipal air quality plans. A 2013 analysis of the city’s air quality monitoring and management

system found that the ‘potential of the atmosphere to disperse the discharged pollutants in the

region of Plovdiv turns to be too low. Prevailing part of AQ standard violations for PM10 happened

in condition of calm weather […] and in stable stratification […]’56.

55 European Commission, 2017, Special Eurobarometer 468, Summary, Attitudes of European citizens towards

the environment, http://ec.europa.eu/commfrontoffice/publicopinion/index.cfm/Survey/getSurveyDetail/in-

struments/SPECIAL/surveyKy/2156. 56 Atanassov, D. et al. 2013, Air Quality Management System of the City of Plovdiv – Annual Analysis for 2013,

https://www.researchgate.net/publication/280484828

http://ec.europa.eu/commfrontoffice/publicopinion/index.cfm/Survey/getSurveyDetail/instruments/SPECIAL/surveyKy/2156







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3.2 Implementation successes

The implementation and integration successes can be summarised as:

• Successful coordination with some sectoral policies;

• Continued support from the European Structural and Investment Finds (ESIF) over two pro-

gramming periods;

• Development and completion of the air quality monitoring system.

3.2.1 Successful coordination between air quality objectives and some sectoral policies

Air quality objectives have been successfully coordinated with some sectoral policies. In the en-

vironmental field, the targeted actions taken to improve waste management, including develop-

ment of anaerobic digestion plants and better management of landfills (including through projects

financed with OP Environment in the period 2007-2013) have contributed to a reduction of the

greenhouse gas (GHG) emissions and thus to improvement of the air quality57.

Actions have been coordinated also with the Ministry of Labour and Social Policy, particularly in

relation to the social help provided for purchase of heating fuel and the broader issue of energy

poverty and its links to air quality. In the past, the social ministry challenged proposals for limiting

the provision of social help to exclude the purchasing of fuel. This was justified by the fact that

the share of population receiving such social help is small and consequently the effect of a meas-

ure limiting the purchasing of fuel with social help will be small, while exacerbating the energy

poverty of the most vulnerable. Under a new approach the quality of the solid fuels sold on the

market will be controlled at the national level ensuring that the social help can be spent on higher

quality fuels. This measure, which entered into force in January 2019, is considered as more

suitable and has the support of the social ministry58.

In the transport sector, the Ministry of Transport is expected to strengthen the mandatory annual

technical checks for vehicles and introduce stickers for different emission levels in order to help

distinguish the vehicles and facilitate the implementation of low emission zones in the municipal-

ities. In addition, some changes to the tax policy are also planned. The calculation of the vehicle

tax will be based on two components – the value of the vehicle and an environmental component

based on the vehicle’s emission certificate. It is expected that the environmental component will

lead to gradual decommissioning of the oldest vehicles59.

3.2.2 Continued support from the European Structural and Investment Funds

The main EU source of financing for air quality is the European Structural and Investment Funds

(ESIF). Even though air quality was not directly targeted in the 2007-2013 programming period,

various of the measures funded indirectly contributed to improving air quality e.g. waste man-

agement investments, public transport investments (notably for the expansion of the metro sys-

tem in Sofia) and investments for improving the road infrastructure60. As discussed in section 2.6,

in the current programming period OP Environment has a dedicated priority axis on air quality

that will support a variety of actions.

To date the focus of the calls launched under OP Environment 2014-2020 has been on the update

of the municipal air quality plans: one part of the municipalities that need to prepare such plans

57 Interview with EAP. 58 Interview with MOEW. 59 Ibid. 60 Interviews with MOEW and EAP.



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could apply for funding until January 2017, while the remaining part have time to prepare them

until January 2019. In addition, several other cross-cutting measures such as capacity building

and monitoring system improvements have been supported. Specific measures for air quality

improvement have not been financed by September 2018 although the 2018 indicative work pro-

gramme of the OP includes the procedure ‘Measures for improvement of the ambient air quality’61

suggesting that such measures might be supported in the future. By September 2018, OP Envi-

ronment has financed the following air quality measures62:

• Creating an information system for reporting of air quality data as part of the National System

for monitoring air quality in real time with beneficiary the ExEA;

• Development or update of municipal air quality plans for 11 municipalities, including

Asenovgrad and Plovdiv;

• Preparation of a plan for assessing OP "Environment 2014-2020" and activities under Ex-

ante conditionalities No 7 and under Priority Axis 5 "Improving air quality” and Technical

assistance for the implementation of measures to improve air quality (both operations under

the priority axis on technical assistance with beneficiary the MOEW).

3.2.3 Development of the air quality monitoring system

Bulgaria has fulfilled its obligations concerning the number of monitoring stations and the param-

eters monitored. The national monitoring system for air quality has been developed further and

since 2017 transmits real time data to the EEA. It is also used to provide information to the public

concerning any exceedances of the limit values or the alert thresholds. Although the maintenance

can be challenging due to the limited administrative capacity of the ExEA as mentioned in the

previous section, the development of the monitoring system continues and further improvements

are foreseen. For instance, with a recently launched public tender (with funds from the MOEW)

the agency plans to develop the software so that real time data about main air pollutants can be

published on its website allowing the public to track air quality in real time. The tender is expected

to start soon and to be completed in six months in the beginning of 201963.

However, one of the stakeholders stressed that the number of PM2.5 monitoring stations, which is

in line with the requirements of the AAQDs, is very low and insufficient in some areas requiring

stronger and clearer provisions concerning the minimum number of monitoring devices in a given

territory to ensure a denser and more complete monitoring64. Another stakeholder pointed out

that having monitoring stations also in smaller towns or villages can help provide a clearer picture

of the air quality status in the whole country65. Nevertheless, MOEW pointed out that any revisions

to the requirements for the number of monitoring stations, including at the EU level, need to be

backed by relevant assessments of the costs and benefits associated. Nonetheless, all stakehold-

ers interviewed were unanimous that monitoring is the most objective and reliable source about

air quality and the development of the national monitoring system is a considerable accomplish-

ment and a major improvement since the introduction of the AAQDs.

61 Operational Programme Environment 2014-2020, Indicative Annual Work Programme for 2018,

http://ope.moew.government.bg/files/useruploads/files/igrp_ope_2018-en_mc-17.05.2018.pdf. 62 Operational Programme Environment 2014-2020, List Of Operations for Priority Axis 5 Improvement Of

Ambient Air Quality and Priority Axis 6 Technical Assistance. 63 Interview with ExEA. 64 Interview with Za Zemiata. 65 Feedback provided by EAP.

http://ope.moew.government.bg/files/useruploads/files/igrp_ope_2018-en_mc-17.05.2018.pdf



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3.3 Implementation challenges

The key implementation challenges can be summarised as follows:

• Insufficient administrative capacity and financial resources at different levels of governance;

• Insufficient coordination with some sectoral policies, most notably the climate and energy

policies;

• Local conditions;

• Data limitations and insufficient methodological guidance for the preparation of the air quality

plans;

• Uncertainties in the AAQDs.

3.3.1 Insufficient administrative capacity and financial resources

A significant implementation challenge is the insufficient administrative capacity at the different

levels of governance. This is most prominent at the municipal level as all stakeholders agree most

municipalities do not have sufficient in-house capacity for air quality management. Most often the

municipal air quality plans and action plans are prepared by external consultants but their imple-

mentation and assessment must be followed up by the municipalities. Often the municipal admin-

istrations do not have sufficient internal capacity to do this due to human resource, financial or

even expertise constraints (e.g. smaller municipalities might have only one environmental expert

and they might not necessarily be specialised in air quality). Strengthening the in-house capacities

of municipalities to deal with air quality policies is necessary66.

The insufficient administrative capacity of municipalities also limits the use of some EU or EIB

financial instruments with complex application rules and procedures or co-financing requirements.

The use of EU funds such as Interreg, LIFE+ and the Urban Innovation Action tend to help only

larger municipalities that have or can afford the necessary capacity for obtaining and managing

the financing67. Moreover, a recent audit of air quality policy in Bulgaria concluded that munici-

palities do not actively seek and benefit from additional opportunities for funding air quality pro-

jects apart from the municipal budgets68.

Although to a lesser extent, insufficient administrative capacity is an issue also for the ExEA that

is responsible for air quality monitoring. The service and maintenance of the AMS and of the

system for real time data transmission are outsourced as the agency has problems to attract and

retain internal experts with relevant knowledge, mainly due to financial constraints. Consequently,

these services are procured through public tenders, which according to the legislation are

launched every year with budget provided by MOEW. However, this creates risks of delays (e.g.

due to delayed provision of the funds, slow tendering procedures) that can be critical and result

in delays or even gaps in the air quality monitoring69.

Another significant constraint at all levels of governance is the lack of sufficient financial resources

for the different aspects of air quality management. At the national level a considerable cost is

the national monitoring system, which is expensive, and the financing is limited (see section 3.5.1

for details). At the local level, municipalities struggle with the financing of the measures for air

quality improvement. Significant resources from the EU funds are earmarked for supporting air

66 Interviews with EAP, Za Zemiata and NAMRB. 67 Interviews with MOEW and Za Zemiata. 68 EUROSAI, 2019, Joint report on air quality. 69 Interview with ExEA.



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March 2019 23

quality in the current programming period in order to remedy this (for details see section 3.2.2),

even if these resources cannot cover all financial needs70.

3.3.2 Insufficient coordination with climate and energy policies and some environmental policies

The coordination, including integration or mainstreaming of air quality objectives in some sectoral

policies, is insufficient. Some stakeholders pointed out that neither at the national level (e.g. in

strategic documents) nor at the municipal level (e.g. in the air quality plans) is there consistent

coordination between the air quality objectives and climate and energy strategies for reducing

GHG emissions and improving energy efficiency. Coordination particularly with energy efficiency

policies is crucial as more efficient homes can reduce the energy consumption of households and

contribute to decreasing the emissions from solid fuels burnt for heating. Furthermore, some

opportunities to develop biomass and biogas in the context of the 2020 renewable energy target

have been missed as no clear links are established between the climate action policies and air

quality objectives71.

According to one of the stakeholders interviewed, the newest approved Best Available Techniques

(BAT) Reference Documents (BREFs) e.g. concerning combustion (LCP BAT 2017) and burning of

waste, are not necessarily applied. Instead, industrial emitters such as coal-fired power plants

apply for derogations (for some pollutants) and renewal of their integrated permits without any

references or commitments to apply the newest BREFs72. Nevertheless, MOEW stressed that pos-

sible trade-offs and risks from the introduction of the latest BREFs exist and should be carefully

considered – if these requirements are costly to the operators, there is a risk that the costs are

transferred to consumers through higher electricity prices creating a further risk of fuel switch

away from power and towards cheaper solid fuels for heating73.

Links between air quality objectives and the IED and the NEC Directive are also missing. More

specifically, the delay in the transposition of the NEC Directive lead to uncertainties concerning

the updated air quality plans (especially for PM2.5 emissions) and its long-term requirements were

not taken into account in the national air quality programme that was developed recently (see

section 2.4) resulting in missed opportunities for policy coordination74.

3.3.3 Local conditions

Specific local characteristics also pose challenges to the implementation of the AAQDs. An im-

portant factor is the social aspect attached to one of the main sources of PM emissions, namely

domestic heating. A large part of the population in the country lives below the poverty line and

relies on domestic heating with solid fuels, including social schemes that help households purchase

coal or firewood each season75. Until recently the quality of those fuels was not regulated (see

section 3.2.1).

In addition, the meteorological particularities and geographical features in some areas such as

Plovdiv exacerbate the non-compliance with the air quality standards and pose a challenge to the

implementation of the AAQDs. Therefore, to comply with the standards, some municipalities need

70 Interviews with MOEW and NAMRB. 71 Interview with EAP. 72 Interview with Za Zemiata. 73 Feedback provided by MOEW. 74 Interview with Za Zemiata. 75 Interview with MOEW.



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to adopt more ambitious targets and take more stringent measures, which is not always techni-

cally, financially76 and/or politically77 feasible.

At the moment the potential of local conditions to affect the implementation and compliance with

the standards is not sufficiently reflected in the AAQDs78.

3.3.4 Data limitations and insufficient methodological guidance

Another challenge for the preparation of the air quality plans, which according to some of the

interviewees hinders implementation, is the limited availability of easily accessible, free-of-charge

data in a suitable format for emissions and dispersion modelling and development of projections.

More specifically, some of the necessary data is either paid (e.g. some meteorological and climate

datasets provided by NIMH), or incomplete and covering a short period of time. Comprehensive

datasets are usually available only for purchase, which represents a significant expense for most

municipalities and when their financial resources are limited, some municipalities do not invest in

comprehensive data inputs for their air quality plans. In addition, other organisations such as

independent research organisations or NGOs cannot prepare independent studies either as the

costs for obtaining data are too high or because the information from the national monitoring

system is not available in an easy-to-use format. In particular, some stakeholders pointed out

that the data provided through the national monitoring system of the ExEA (and some municipal-

ities like Plovdiv) is not readily available in a machine-readable format, while in some cases au-

thorities refuse to provide hourly PM data, which resulted in several court proceedings79.

Even though the national legislation defines the air quality data and its format that should be

available for all stakeholders and the research carried out in this case study indicates data is

publicly available (see section 2.5), one of the stakeholders interviewed suggested that the AAQDs

could be more specific about the minimum types of data necessary for air quality management

that should be freely available in appropriate machine-readable format in order to strengthen the

implementation of the Directives and facilitate the development of independent air quality anal-

yses80.

Furthermore, one of the stakeholders pointed out that municipalities can also benefit from more

methodological guidance concerning the assessment of air quality that informs their air quality

plans. In particular, days with exceedances should consider both the ambient air temperature and

the wind speed as exceedances are lower in months with warm days. Therefore, when considering

trends and the effectiveness of local measures, there is a need to assess the impact of high/low

winter temperatures and compare similar months or winters. In addition, there is a need for

guidance on how to model different land sources in dispersion modelling and which are the most

suitable tools to use. There is currently no clear or consistent approach to modelling the dispersion

of emissions from land sources and municipalities take different approaches81. As stated in section

2.3, several methodological guidance is already available on the MOEW website.

Despite continued progress with developing emission inventories and modelling for air quality

management, better tools are needed especially for forecasting peak concentrations (e.g. for NO2

76 Feedback provided by MOEW. 77 Feedback provided by Za Zemiata. 78 Interview with MOEW. 79 Interviews with EAP and Za Zemiata. 80 Interview with Za Zemiata. 81 Feedback provided by EAP.



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in cities). This is a common challenge among multiple European cities82. Furthermore, the lack of

sufficient data can limit the monitoring of progress towards the air quality objectives. An audit of

the air quality policy in Bulgaria found that there are gaps in the planning and reporting of the

implementation of air quality measures. Evaluation of progress towards objectives tends to con-

sider only summarised results and does not take into account the contribution of individual

measures separately83.

3.3.5 Uncertainties in the AAQDs

According to some of the stakeholders interviewed, the AAQDs are not specific enough on a num-

ber of important issues, which could result in different interpretations and implementation in the

Member States84. These statements are reflected in the following.

One such aspect is public participation. The involvement of different stakeholders in the air quality

management process in Bulgaria can be improved. Some of the interviewees found the opportu-

nities, given to stakeholders to consult and provide feedback on the draft national air quality

programme that was recently developed, were insufficient and lacked public debates85. However,

the preparation of the national programme is not a requirement of the AAQDs and its draft was

subject to a public consultation like other similar documents (see section 2.4).

Some interviewees also considered that the opportunities provided by the law to stakeholders to

provide feedback on the draft municipal air quality plans (currently through ‘programme councils’

at the municipal level) are insufficient and can be improved further. This is partly due to the fact

that public participation in the preparation of those plans is regulated by an old Ordinance from

1999 that does not reflect the needs of the more current legislation. According to this Ordinance

the public and any relevant stakeholders only need to be informed, there are no provisions about

their involvement in the decision-making process. However, the AAQDs are not very specific about

public participation in the decision-making process either, which in turn hinders the improvement

of the provisions for stakeholder involvement at the Member State level86.

Another important aspect where the AAQDs are unclear is access to justice. In Bulgaria, the mu-

nicipal air quality plans cannot be challenged in court at the moment. While a possible remedy

could be class actions in civil courts, administrative courts are of the opinion that these plans are

internal administrative documents and thus cannot be challenged as judged in several recent

cases87. Nonetheless, the AAQDs are not sufficiently clear about the access to justice requirements

either, which leads Member State courts to refrain from action according to stakeholders88.

In addition, the AAQDs are not specific enough about the mechanisms that can be used for achiev-

ing the air quality standards. For instance, one stakeholder stressed that sanctions should be

defined for all stages of the AAQDs implementation in order to facilitate and clarify the use of

82 European Environment Agency, 2018, Europe's urban air quality — re-assessing implementation chal-

lenges in cities, link. 83 EUROSAI, 2019, Joint report on air quality, link. 84 Interviews with EAP and Za Zemiata. 85 Feedback provided by EAP. 86 Interviews with EAP and Za Zemiata. 87 Administrative Court Sofia city ruling 6541/25.09.2017 court case 7190/2017; Supreme administrative

court ruling 13138/01.11.2017 court case 12064/2017; Supreme administrative court ruling 890/23.01.2018

court case 14145/2017; Plovdiv Administrative Court rulings 1972/05.10.2018 court case 3006/2018 and

1996/10.10.2018 court case 3070/2018; Supreme Administrative Court judgement 16049/20.12.2018 court

case 14184/2018. 88 Interview with Za Zemiata.






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sanctions at the national or local level89. Ambiguities and uncertainties also stem from the defini-

tion of Art. 23 of Directive 2008/50/EC as it is not clear what is meant by ‘as short as possible’.

According to one of the interviewed stakeholders, this resulted in non-consideration of the urgency

aspect in the air quality plans of the municipalities in Bulgaria until recently when an amendment

to the Air Quality Act was made to remedy this and address the 2017 judgement of the European

Court of Justice (see section 2.2.3 concerning the legal action against Bulgaria and section 2.4 for

the amendments). However, as this amendment was adopted only recently, and its effects are

unknown yet, the plans adopted so far do not include measures that can lead to results and

compliance in a short period of time and the authorities tend not to consider the urgency of

addressing any exceedances90.

Another gap according to one of the stakeholders is the lack of an average daily limit value for

PM2.5 concentrations91, however other stakeholders did not mention this, while MOEW pointed out

that there is a need to ensure compliance with current standards everywhere in the EU before

more ambitious targets are set.

3.4 Factors underlying compliance and effectiveness of the AAQ Directives

The following section provides an overview of the factors underlying and hindering compliance

with and effectiveness of the AAQDs in Bulgaria and the Plovdiv Agglomeration. Unless specified

otherwise, the factors apply to the entire Bulgarian territory, including the Plovdiv Agglomeration.

3.4.1 Factors hindering compliance and effectiveness

Mismatch of the responsibilities and competences at different governance levels

While policies in most sectors, including the environment, are set at the national level, the imple-

mentation of specific air quality measures to address certain pollutants is a responsibility of the

municipalities in which exceedances are observed. This has proven problematic for addressing

emissions from certain sectors such as domestic heating from households and transport. In these

sectors, the municipalities either do not have sufficient competences to intervene or their actions

are ineffective without measures at the national level.

The main source of PM emissions is the domestic heating sector. However, without policies or

measures at the national level to control the quality of the solid fuels or heating appliances, the

measures municipalities take are ineffective as households can still procure low-quality fuels or

burners. Therefore, the stakeholders stressed the need for establishing minimum quality stand-

ards/requirements for the firewood and solid fuels sold on the market as well as eco-design stand-

ards for the heating equipment at the national level. This will enable municipalities to take more

stringent measures or impose sanctions at the local level, if necessary92. MOEW clarified that

requirements for the quality of the solid fuels sold on the market have been prepared and entered

into force in 2019. Moreover, according to news coverage about the draft national air quality

programme introduction of eco-design requirements for the heating appliances is recommended

by 2020 together with complementary measures at the municipal level to provide alternative

89 Ibid. 90 Ibid. 91 Ibid. 92 Interviews with EAP, Za Zemiata, NAMRB and MOEW.



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heating (e.g. gasification, city heating networks) or replacement of the old burners with more

efficient alternatives93.

Although NO2 concentrations are not a problem at the national level, they remain high in big cities

and primarily result from the transport sector. While municipalities can establish low emissions

zones on their territories, they cannot control the quality of the private vehicles in circulation. A

particular problem in Bulgaria is the circulation of old diesel vehicles, sometimes even without

diesel catalysts or filters, which often come from other European countries where more stringent

emission requirements made these vehicles become non-compliant on the local markets. There-

fore, more stringent control at the national level is needed to control what vehicles are imported

and to ensure no vehicles circulate without filters. MOEW clarified that the Ministry of Transport

is working on measures for improving the technical checks and updating the tax policies to facili-

tate the decommissioning of the most polluting vehicles. At the same time, introduction of stickers

denoting the emission category of each vehicle is expected to help municipalities implement low

emission zones on their territories94. Furthermore, one stakeholder suggested that EU-level or

national guidelines on what constitutes a ‘low emission zone’ might be useful for improving the

implementation of such measures95.

Addressing emissions from the public transport is within the competences of the municipalities as

they often own the lines and the fleet. In the case of Plovdiv, the lines of the public transport are

tendered through a concession to privately owned operators and the city does not directly own or

manage the bus fleet. Therefore, the city can control the quality of the vehicles and their emissions

only through the tendering requirements96.

Emissions from industrial sources are limited and the most significant problem is the SO2 emis-

sions from several TPPs in one municipality of the South-East air quality zone. Nevertheless, this

is another area in which municipalities have limited possibilities to act. Permits for industrial in-

stallations are issued by the RIEWs or ExEA and the municipalities do not have jurisdiction to

control the emissions of such installations or to impose sanctions. Better coordination between air

quality and IED policies may help clarify the role and jurisdiction of local authorities on this issue97.

In the case of the TPPs in the South-East air quality zone, MOEW clarified that these installations

are important for the energy security of the country and any decision that concerns them requires

coordination with various institutions. Therefore, the emission control measures are decided at

the national level and implemented for all four installations. Furthermore, there is a project for a

system of preventive measures to be implemented when bad meteorological conditions are fore-

casted for the area. This measure is expected to help manage the emissions from these installa-

tions98.

Gaps in the overall allocation of responsibilities combined with deficiencies in communication

across the different governance levels were found to hinder the effectiveness of air quality policies

in Bulgaria. Another potential gap identified by the same audit is the lack of sanctions imposed

on municipalities for failing to fulfil their obligations for air quality management99.

93 Filipova, I. 2018, Bulgaria now has a programme for reduction of particulate matter in the ambient air, 30

Sep 2018 published in Capital Newspaper, https://www.capital.bg/politika_i_ikonomika/bul-

garia/2018/09/30/3318430_bulgariia_veche_ima_programa_za_namaliavane_na_finite/. 94 Interviews with NAMRB and MOEW. 95 Feedback provided by EAP. 96 Interview with NAMRB. 97 Interview with Za Zemiata. 98 Interview with MOEW. 99 EUROSAI, 2019, Joint report on air quality.

https://www.capital.bg/politika_i_ikonomika/bulgaria/2018/09/30/3318430_bulgariia_veche_ima_programa_za_namaliavane_na_finite/






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Insufficient coordination of air quality policy with sectoral policies at different levels of governance

The coordination and integration of air quality objectives with sectoral policies at the local level is

low and often missing. For example, only 25 Bulgarian municipalities (around 10% of all munici-

palities) have signed the Covenant of Mayors and prepared Sustainable Energy Action Plans

(SEAPs). Of those, only two have signed also the Mayors Adapt initiative and are expected to

prepare Sustainable Energy and Climate Action Plans (SECAPs). Even though some of these mu-

nicipalities also have air quality problems, links between the SEAPs/SECAPs and the municipal air

quality plans are hardly found. In addition, the municipalities rarely update their SEAPs and thus

do not take advantage of the available guidance on how to integrate different policy concerns in

their SEAPs. There are even fewer municipalities with Sustainable Urban Management Plans

(SUMPs) and it is unclear if air quality is integrated in those plans. It is also unclear whether the

air quality plans are integrated or linked with municipal/urban/regional level planning e.g. in the

area of land use and spatial planning100.

Despite successes in some areas (see section 3.2.1) coordination of air quality policy with other

sectoral policy requires further improvement also at the national level. An important gap in the

period before 2019 was the lack of a national air quality strategy101 that could have defined na-

tional objectives or promoted coordinated policies across sectors.

Lack of ambition in some air quality plans

Some of the stakeholders interviewed questioned the ambition of some municipal air quality plans

and the overall focus on the strictness of the EU standards instead of on the effectiveness of the

local measures. In particular, they criticised the lack of clear objectives or more stringent targets

in some cases e.g. where the local conditions hinder the dispersion of air pollutants as in the case

of Plovdiv, as well as the lack of specific actions to address the insufficient effectiveness of the

measures implemented so far. This was attributed to several of the cross-cutting implementation

challenges102:

• Insufficient internal capacity to prepare air quality plans (e.g. some municipal administrations

lack the expertise to identify air quality needs and appropriate measures) and consequent

over-reliance on external expertise. It is also critical that municipalities have sufficient ca-

pacity to implement the plans later on;

• Insufficient integration between policies - measures to improve the energy efficiency of build-

ings are not consistently considered;

• Incomplete data for the inventory and modelling of the emissions and pollution sources in

some cases - this reduces the quality of the air quality plans as there is insufficient data to

develop high quality scenarios and projections or to quantitatively justify the targets and

links between measures and emission sources;

• Insufficient public participation and possibility for independent verification of the analyses in

the plans, which if facilitated, can support municipalities in their efforts to prepare and im-

plement air quality plans.

Gaps in the information provided to the public

100 Interviews with EAP and Za Zemiata. 101 EUROSAI, 2019, Joint report on air quality. 102 Interviews with EAP and Za Zemiata.



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At the moment of writing this case study, the information available daily on the website of the

ExEA does not provide real time data and does not cover all parameters monitored (e.g. infor-

mation about PM2.5 emissions is not published in the ExEA daily bulletins). Real time data is pro-

vided directly only to RIEWs and the municipalities or consultants working on their behalf to de-

velop air quality plans. Instead, the focus of the daily information accessible to the public is on

reporting any exceedances and not all real time data from the monitoring system. Some of the

stakeholders pointed out that as the exceedances data published in the ExEA daily bulletins is

easily available only for 24 hours, this hinders the easy review of historical data for independent

research and dispersion modelling103. Nevertheless, the ExEA clarified that an ongoing tendering

procedure aims to develop the software of the monitoring system in order to allow the provision

of real time data for the main parameters to the public.

Improved awareness about air quality issues is important especially for the acceptance of policies

and the success of air quality measures104. A recent audit concluded that the awareness of Bul-

garian citizens on air quality issues, including health risks but also benefits from different policies

and measures, can be improved through more centralised efforts to improve awareness105.

3.4.2 Factors underlying compliance and effectiveness

Improved regulation at the national level

In order to support municipalities in their actions to improve air quality, national policy makers

have taken or are currently working on a series of measures that aim to provide some common

regulation of the pollutant emissions at the national level. One of the most important develop-

ments is the introduction of minimum requirements for the solid fuels sold on the market in the

Air Quality Act. In addition, as mentioned in section Error! Reference source not found., the

Ministry of Transport is also working on several measures that aim to regulate the emissions from

the transport sector, while MOEW is in the process of finalising a national air quality programme.

Citizen initiatives

Some municipalities complement the air quality data published by the ExEA with provision of

information at the local level e.g. through their websites or information boards. Furthermore, the

limitations in the officially published data has led to some citizen-led initiatives. For example, Za

Zemiata NGO runs a website106 that informs about air pollution in general and advises the public

what to do in the case of pollution peaks. In Sofia, a citizen initiative invested in low-budget

sensors, installing more than 100 PM sensors in the city, in order to provide information about

concentrations and collect data building a historical database that allows trend analyses and can

complement official analyses107. In Plovdiv, the Energy Agency Plovdiv operates an independent

mobile laboratory for measuring and testing emission concentrations from point source polluters,

which covers PM10, PM2.5 and NOx for the moment. However, there is little interest in independent

monitoring and the mobile laboratories are not often used so far108.

103 Interviews with EAP and Za Zemiata. 104 European Environment Agency, 2018, Europe's urban air quality — re-assessing implementation chal-

lenges in cities, https://www.eea.europa.eu/publications/europes-urban-air-quality. 105 EUROSAI, 2019, Joint report on air quality, https://english.rekenkamer.nl/publications/re-

ports/2019/01/30/joint-report-air-quality. 106 www.smog.zazemiata.org 107 Interview with Za Zemiata. 108 Interview with EAP.







http://www.smog.zazemiata.org/



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3.5 Costs and benefits of the AAQ Directives

3.5.1 Costs of implementation

Currently there is no national analysis of the costs of AAQDs implementation. Nevertheless, some

of the available information can provide an indication:

• Monitoring: Although the total cost for the development of the national air quality monitoring

system is not available, there are some indications about its maintenance cost. According to

the ExEA, the annual cost for the entire national system for monitoring of the environment

(including air quality, water, noise, radiation etc.) is around BGN 3.7 million or EUR 1.9

million109. It is not clear if the cost specifically for air quality monitoring can be separated

from the overall monitoring costs, the ExEA was not able to provide data specifically for the

air quality monitoring. The recently completed project on the upgrade of the real time re-

porting system, supported by OP Environment is worth approximately EUR 357,909110.

• Air quality plans: The total budget of the call launched for the development and update of

the municipal air quality plans of the 28 non-compliant municipalities is around EUR 1.5

million suggesting an average budget of approximately EUR 0.05 million per plan111. The total

budget of the procedures financed under this call so far in 11 municipalities is around EUR

777,502, of which the procedures for the air quality plans in Plovdiv is EUR 47,830 and in

Asenovgrad EUR 74,370112. The funds spent so far suggest an average budget of around EUR

0.07 million per air quality plan.

• Measures: A review of the actual allocations for the programming period 2007-2013 of three

OPs (Environment, Good Governance and Transport and Infrastructure) indicated that at the

end of the funding period around EUR 156.8 million were allocated to air quality projects113.

Information provided by the interviewees indicates that these were mainly measures for im-

proving the public transport in different areas.

• Measures in the Plovdiv Agglomeration: Some information about the cost of air quality

measures implemented in the Plovdiv and Asenovgrad municipalities is available in the plans

themselves but it is not provided consistently. The available information is summarised in

the following table.

Table 3-1 Costs of the air quality measures taken in the Plovdiv agglomeration

Plovdiv Municipality Asenovgrad Municipal-

ity

Period 2011 2014 2011-2015

Cost EUR 9.4 million from munici-

pal budget

EUR 11.9 million from munici-

pal budget

EUR 3.5 million from

municipal budget

109 All estimates are converted using the fixed ECB exchange rate of EUR 1= BGN 1.9558. 110 Operational Programme Environment 2014-2020, List Of Operations for Priority Axis 5 Improvement of

Ambient Air Quality, http://ope.moew.government.bg/files/useruploads/files/list_of_operations_air_en.pdf. 111 Operation Programme Environment 2014-2020, Ongoing calls, BG16M1OP002-5.002,

http://ope.moew.government.bg/bg/notice/noticedetail/from/noticecurrent/id/77/typeId/1. 112 Operational Programme Environment 2014-2020, List Of Operations for Priority Axis 5 Improvement of

Ambient Air Quality, http://ope.moew.government.bg/files/useruploads/files/list_of_operations_air_en.pdf. 113 COWI and Milieu, 2017, Integration of environmental concerns in Cohesion Policy Funds (ERDF, ESF, CF).

http://ope.moew.government.bg/files/useruploads/files/list_of_operations_air_en.pdf





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Plovdiv Municipality Asenovgrad Municipal-

ity

Examples of

measures

Regulation of the traffic; road

infrastructure renovation;

improvement of the street

cleaning; greening of public

spaces; preparation of an ac-

tion plan for stimulating the

use of new heating technolo-

gies and renewable energy

Road infrastructure mainte-

nance/renovation; street

cleaning; greening of public

spaces

Street cleaning and road

maintenance; mainte-

nance of public green

spaces; renovation of

public buildings

Sources: Air quality plans of the Plovdiv and Asenovgrad municipalities.

3.5.2 Costs of non-implementation

There is currently no national analysis of the costs of non-implementation of the AAQDs either.

According to the 2013 Commission Impact Assessment, the health-related external costs from air

pollution in Bulgaria, including the intrinsic value of living a full health life and the direct costs to

the economy, are estimated at more than EUR 3 billion per year (income adjusted, 2010). The

direct economic costs relate to 2 million workdays lost each year due to sickness related to air

pollution, which are associated to annual costs (income adjusted, 2010) of EUR 121 million costs

to employers, over EUR 11 million for healthcare and EUR 58 million for agriculture (crop

losses)114. Furthermore, the EEA estimated that for 2015 around 14,200 premature deaths were

attributable to fine PM concentrations, 640 to NO2 concentrations and 350 to ozone concentra-

tion115.

More specifically, the total costs (both health and non-health related) of road traffic related air

pollution in 2016 was estimated at EUR 612 - 778 million. The majority of these costs stem from

diesel vehicle transport. The specific health costs of diesel vehicle air pollution were estimated at

EUR 389 – 459 million, considerably higher than the health costs associated with petrol vehicles

(EUR 184 – 266 million)116.

3.5.3 Benefits of the AAQ Directives

Currently, there is no national analysis of the valorised benefits from implementation of the

AAQDs. Nevertheless, a number of benefits were identified.

First and foremost, all stakeholders interviewed agree that the AAQDs have been drivers of change

and actions at the national and local levels that have resulted in decreasing emissions of all pol-

lutants. Particularly important is the reduction of the PM10 emissions in some municipalities and

an overall reduction of the SO2 emissions. These significant improvements might not have taken

place without the binding element of the Directives. In addition, the AAQDs have contributed to

making air quality a more prominent issue fostering the development of air quality plans, provision

of information to the public and uptake of citizen initiatives.

There was no systematic data about air quality before the introduction of the European legislation

and an important change brought by the AAQDs is the development of a national monitoring

114 Impact Assessment for the European Commission Integrated Clean Air Package (2013) cited in SWD(2017)

35 final. 115 European Environment Agency, 2018, Air quality in Europe — 2018 report. 116 CE Delft, 2018, Health impacts and costs of diesel emissions in the EU.



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system with improvements in the equipment and data used. The main change since the imple-

mentation of the AAQDs in Bulgaria is the monitoring of PM2.5 and PM10, which were previously

not monitored (instead, only the general PM/dust level was monitored)117.

Another important transformation facilitated by the Directives and stakeholder activism is the

abolishment of naphtha (crude oil) as a widespread fuel in industrial installations and public build-

ings and the replacement of the combustion facilities with capacities to burn other fuels118.

Air quality standards before 2008

Before the transposition of Directive 2008/50/EC, air quality was regulated according to legislation

transposing earlier European air quality legislation (e.g. Directive 96/62/ЕС, Directive 99/30/ЕС,

Directive 2000/69/EC, Directive 2002/3/ЕС and Directive 2004/107/ЕС)119. While the introduction

of Ordinance 12 made no changes to the limit values of most pollutants, it made the requirements

for PM concentrations less precise compared to the pre-2008 requirements as summarised in the

following table. Before the transposition of the AAQD the legislation defined additional more am-

bitious PM10 limit values to be attained in a second period of implementation and a daily ‘action

level’ for PM2.5. For pollutants regulated by Directive 2004/107/EC the limit values are transposed

by Ordinance 11 (for details see section 2.4).

Table 3-2 Changes introduced in national legislation as result of the AAQD (Directive 2008/50/EC)

Pollutant Situation prior to the AAQDs Changes introduced by the AAQD to

the legislation

SO2, NO2, Pb Defined in Ordinance 9 of 1999120 No changes

C6H6, CO Defined in Ordinance 1 of 2004121 No changes

O3 Defined in Ordinance 4 of 2004122 No changes

PM10 Defined in Ordinance 9 of 1999;

Prior to 2008 the limit values were defined in

two stages:

Stage I to fulfil by 31.12.2008:

• Average daily limit 50 μg/m3, not to be

exceeded more than 35 times per year

• Average annual limit 40 μg/m3

Stage II to fulfil by 01.01.2010:

• Average daily limit 50 μg/m3 not to be ex-

ceeded more than 7 times per year


Ordinance 12 defines only the Stage I

limit values, there is no longer a refer-

ence to the Stage II limit values.

PM2.5 Defined in Ordinance 9 of 1999;

Prior to 2008 ‘action levels’ were defined as:

Ordinance 12 defines the limit values in

two stages:

117 Interviews with MOEW and ExEA. 118 Interview with EAP. 119 Information provided by MOEW. 120 Ordinance N9 of 3 May 1999 concerning norms for sulphur dioxide, nitrous oxide, particulate matter and

lead in ambient air, available at http://www.econ.bg/. 121 Ordinance N1 of 16 January 2004 concerning norms for benzene and carbon monoxide in ambient air,

available at http://www.econ.bg/. 122 Ordinance N4 of 5 July 2004 concerning norms for ozone in ambient air, available at http://www.econ.bg/.

http://www.econ.bg/

http://www.econ.bg/

http://www.econ.bg/



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Pollutant Situation prior to the AAQDs Changes introduced by the AAQD to

the legislation

• Average daily level 40 μg/m3, not to be

exceeded more than 14 times per year

• Average annual level 20 μg/m3

Stage I to fulfil by 01.01.2015:


Stage II to fulfil by 01.01.2020:


An average daily level or limit value is

no longer defined.

Sources: Own analysis based on national legislation.



(2008/50/EC, 2004/107/EC)

March 2019 34

4 CONCLUSIONS

Chapter Error! Reference source not found. presents the summary of the main findings of the

case study regarding the main implementation challenges and the potential for improving the

implementation of the Directives in Bulgaria. Finally, a summary of the evaluation of the AAQDs

is presented.

4.1 Identified problems and potential for improving the implementation of

the Directives

The case study identified a number of challenges in the implementation of the AAQDs in Bulgaria.

While some of the challenges are related to gaps in the country’s implementation, others can be

linked to the set-up of the Directives themselves – either gaps or uncertainties in the AAQDs’

provisions (see section 3.3.5), or a lack of consideration of each country’s specific conditions (see

Section 3.3.3). Therefore, the opportunities for improvement are mainly linked to further clarifi-

cations at the EU level.

The implementation of the AAQDs can be improved by EU-level clarifications, including through

implementation guidelines, concerning:

• The kind of sanctions that can be imposed at the different stages of implementation;

• The daily limit values for PM2.5 e.g. to provide guidelines or suggestions how to consider those

but not to introduce new limit values until current requirements are met;

• The minimum number of monitoring stations to ensure more complete and adequate moni-

toring in some areas e.g. big cities or small towns, based on appropriate assessment of the

costs and benefits associated with a higher number of monitoring stations;

• Access to justice in order to specify whether the air quality plans can be challenged in court

and under what conditions:

• The minimum types of data, which is necessary for the analysis of emissions and the prepa-

ration of the air quality plans and which should be available free-of-charge and accessible for

all stakeholders (in a machine-readable format), as a way to stimulate independent research

that can complement official analyses and reporting.

Another aspect for improving the Directives is the establishment of standards that take into ac-

count the specific climatic, economic and social conditions in the Member States. According to

some stakeholders, the current standards appear to consider only the climate and the conditions

in Western Europe and do not take into account the specific conditions in other parts of the con-

tinent. This leads to adoption of standards that make sense for some countries but not for others

e.g. due to a different economic and social context.

The stakeholders pointed out that existing provisions should not be removed but rather clarified

or made more specific, while future amendments or a potential introduction of more stringent

standards should take into account and be based on the different conditions and resources of each

Member State.



(2008/50/EC, 2004/107/EC)

March 2019 35

4.2 Assessment of the AAQ Directives

The following section presents a summary of the findings of the case study in relation to the

relevance, effectiveness, efficiency, coherence and added value of the AAQDs.

4.2.1 Relevance

Despite continuing improvement in the air quality in Bulgaria, the issue remains a concern for

citizens as outlined in section 0. Overall, the AAQDs remain relevant for improving air quality in

Bulgaria as:

• Their objectives address the needs at the national level – before the introduction of the Di-

rectives there was no consistent monitoring of air quality, provision of information to the

public or planning of mitigation actions (see section 3.5.3). Therefore, the AAQDs ensure that

air quality is targeted at the national level.

• They target pollutants relevant at the national level – despite improvements over time ex-

ceedances of the limit values for PM10, PM2.5, NO2 and in one area – SO2 emissions - persist

(see section 2.2). Thanks to the AAQDs measures are continuously taken to improve perfor-

mance concerning these emissions. However, the EU-wide limit values do not sufficiently

reflect specific local climate, economic or social conditions (see section 3.1).

• The rules for monitoring and assessment are acceptable – before the introduction of the

AAQDs Bulgaria lacked an air quality monitoring system. Even though the maintenance of

the system is costly and more monitoring stations can be installed in the larger cities, the

completion and operation of the monitoring systems is one of the main positive changes

brought by the Directives (see section 3.2.3).

4.2.2 Effectiveness

The challenges with the implementation and compliance with the air quality standards can be

attributed to a number of factors: insufficient administrative capacity at the different levels of

governance coupled with insufficient financial resources to finance different measures; insufficient

integration of air quality objectives in sectoral policies; mismatch of the responsibilities and com-

petences for air quality management at the different governance levels; local conditions that

hinder compliance with the standards; and uncertainties in the AAQDs. Nevertheless, implemen-

tation and compliance with the Directives is ensured by improving regulation at the national level;

successful coordination with some sectoral policies; support from the ESIF; and development of

the national air quality monitoring system together with an uptake of citizen initiatives. More

specifically:

• Monitoring and assessment of air quality function well – the air quality monitoring system,

whose development was fostered by the AAQDs, was completed and it now regularly provides

information about the pollutants monitored in line with the requirements of the EU legislation.

Monitoring data is used by the ExEA to inform the public and by municipal authorities to

prepare air quality plans and track their implementation (see sections 2.2). Even though

some municipalities include also modelling in their plans, this remains a limited practice due

to data availability and financial constraints. Therefore, some stakeholders call for defining

at the EU level the minimum types of data that should be available free-of-charge for all

stakeholders. In addition, the actual monitoring and assessment tasks tend to be outsourced

as public authorities such as the ExEA and the municipalities have limited resources to carry



(2008/50/EC, 2004/107/EC)

March 2019 36

out these tasks in-house. Strengthening the in-house expertise of public authorities concern-

ing the monitoring and assessment of air quality can be targeted at the national level (see

section 3.3.1).

• Compliance with some of the standards remains problematic - although compliance has im-

proved over time, exceedances of the limit values for PM10, PM2.5, NO2 and in one air quality

zone – SO2 emissions – persist. This is primarily due to emissions from the domestic heating

sector for PM, road transport for NOx and TPPs for SOx as confirmed by the national reports

on the state of the environment and the stakeholders interviewed. Furthermore, insufficient

integration of air quality objectives in certain policy areas, most notably climate and energy

policies, limit the effectiveness of some measures to improve compliance with the pollutant

limit values. In some areas such as the Plovdiv agglomeration non-compliance is exacerbated

also by the local climate conditions. Further clarifications or guidelines about the implemen-

tation of the AAQDs can improve compliance at the national level. EU-level clarifications are

needed concerning the types of sanctions that can be imposed to improve compliance, the

minimum number of monitoring stations and the possibilities of access to justice concerning

air quality plans (see sections 2.2 and 3.3.5).

• Air quality information is regularly provided to the public - the ExEA publishes daily updates

about any exceedances of the limit values for the preceding day as well as quarterly bulletins

and yearly reports about the air quality. Even though some stakeholders criticise the lack of

real time data and the format in which the ExEA publishes the daily data, the Agency plans

to further develop the monitoring system to allow the provision of real time data for the main

parameters on its website. In addition, some municipalities including Plovdiv provide real

time data about the air quality in their territory on information boards while citizen-led initi-

atives for providing air quality information have also emerged. Information about breaching

the alert thresholds is also provided regularly thanks to automated updates by the ExEA and

information provided by the RIEWs to local authorities and the media (see sections 2.5 and

3.2.3). As Bulgaria previously had no air quality monitoring or information system, the pro-

vision of information to the public was largely promoted by the AAQDs.

• Air quality plans and measures have been implemented but with varying degree of success

– the number of municipalities non-compliant with the EU standards and thus required to

prepare air quality plans has decreased. However, some municipalities such as Plovdiv or

Sofia continue to exceed the limit values and have to prepare air quality plans. In Plovdiv for

instance, the implementation of the air quality plans has led to improvements and compliance

for some pollutants (e.g. SO2) but the measures implemented have not been sufficient to

ensure compliance for other pollutants (e.g. PM10, PM2.5 and NO2). Some of the main reasons

behind this are the local meteorological conditions and inconsistencies of the policies at the

national level e.g. until recently there were no requirements for the solid fuels used for do-

mestic heating (see sections 0 and 3.3.2).

4.2.3 Efficiency

There is no analysis of the costs and benefits linked to the AAQDs at the national level. Indications

about the cost of monitoring and preparation of air quality plans can be obtained from the budgets

of ESIF calls, while indications about the cost of non-implementation are available in EU reports.

Nevertheless, comprehensive data about the costs of implementation and non-implementation or

benefits is not available.

Based on the available information (see section 3.5.1 for details) the costs of AAQDs implemen-

tation in Bulgaria are in the range of:



(2008/50/EC, 2004/107/EC)

March 2019 37

• Costs of monitoring, reporting and assessment – the annual cost of the air quality monitoring

system is nearly EUR 1.9 million, which is the annual cost for the entire national system for

monitoring of the environment (however it is not clear if the costs per area of environment

can be separated). Data about the costs associated with reporting and assessment are not

available.

• Costs of implementation – the average budget of an air quality plan is around EUR 0.05 –

0.07 million based on the ESIF financing made available for update of the air quality plans in

28 non-compliant municipalities. The latest plans prepared for the municipalities in the Plov-

div agglomeration cost around EUR 47,830 (Plovdiv) and EUR 74,370 (Asenovgrad). The cost

of measures implemented in Plovdiv cost around EUR 21.3 million from the municipal budget

in the period 2011-2014, while in Asenovgrad around EUR 3.5 million from the municipal

budget was spent on air quality measures between 2011 and 2014.

4.2.4 Coherence

The coordination between air quality objectives and sectoral policies is inconsistent. While there

has been successful integration between ESIF spending in different sectors (including waste man-

agement and transport), social and transport policies, links between air quality and climate and

energy policies are missing both at the national level and in the municipal air quality plans. Driven

by the need to comply with the EU standards, an environmental component was introduced in the

calculation of the vehicle taxes, while the EU categories for different emissions levels can now be

used by municipalities to control circulation of vehicles on their territories (see section 3.2.1).

Moreover, air is a separate priority axis in the latest OP Environment, therefore the ESIF will

support the update of air quality plans as well as the implementation of specific air quality

measures in the period 2014-2020. In the previous funding period ESIF investments in waste

management likely contributed to improved air quality (see section 2.6 and 3.2.2). Nonetheless,

the coordination of municipal air quality plans and other local policies is limited and according to

some of the stakeholders interviewed it is generally missing (see section 3.4.1).

4.2.5 EU added value

The overall contribution of the Directives on air quality policy in Bulgaria has been mixed. The

implementation of the Directives, and particularly their binding nature on the standards, have

contributed to improving air quality in Bulgaria, developing a system and monitoring concentra-

tions (some of which were not monitored before), informing the public and fostering citizen action.

The transposition of Directive 2008/50/EC resulted also in the repeal of previous air quality leg-

islation that defined more ambitious limit values for PM concentrations (two-stage limit values for

PM10 and an average daily value for PM2.5). Nevertheless, Bulgaria was not required to make this

repeal because the AAQ Directives allow Member States to have more stringent environmental

standards.



(2008/50/EC, 2004/107/EC)

March 2019 38

APPENDIX A REFERENCES

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(2008/50/EC, 2004/107/EC)

March 2019 39

Za Zemiata and Greenpeace Bulgaria, 2018, Position concerning the Draft National Programme

for Improving the Air Quality (2018-2024), http://archive.zazemiata.org/v1/fileadmin/con-

tent/energy/docs/stanovishte-NPKAV-ZaZemiata-GreenpeaceBG.pdf

National legislation, programmes and air quality plans:

Asenovgrad Municipality, 2016, Programme (corrected and expanded) for decreasing the levels

of pollution with particulate matter (PM10) and cadmium (Cd) and reaching the established

standards in ambient air, with Action plan 2016-2019, https://www.as-

senovgrad.com/userfiles/file/docs3/Pg-A-grad%203.pdf

Air Quality Act, available at: https://www.moew.government.bg/bg/vuzduh/zakonodatelstvo/za-

koni/

Instruction for developing programs to reduce emissions and achieve the established limits of

harmful substances in the areas for air quality assessment and management where there is ex-

ceedance of the established limits, established with Order 996/20.12.2001,

https://www.moew.government.bg/bg/vuzduh/kachestvo-na-atmosferniya-vuzduh/normativni-

aktove/

Ministry of Environment and Water, 2007, National Programme for reducing the overall annual

emissions of sulphur dioxide, nitrogen oxides, volatile organic compounds and ammonia in am-

bient air, https://www.moew.government.bg/static/media/ups/tiny/filebase/Air/Strate-

gicheski_dikumenti/National_Programm_decr_annual_em_SO2_NOx_NH3_VOC.pdf

Operational Programme Environment 2014 – 2020, CCI: 2014BG16M1OP002,

http://ope.moew.government.bg/files/useruploads/files/ope_2014-2020_amend-

ment_en_july2017.pdf

Operational Programme Environment 2014-2020, Indicative Annual Work Programme for 2018,


Operational Programme Environment 2014-2020, List Of Operations, Priority Axis 5 Improve-

ment Of Ambient Air Quality, http://ope.moew.govern-

ment.bg/files/useruploads/files/list_of_operations_air_en.pdf

Operational Programme Environment 2014-2020, List Of Operations, Priority Axis 6 Technical

Assistance, http://ope.moew.government.bg/files/useruploads/files/list_of_operations_tech-

nical_en.pdf

Order 969 of 21.12.2013, Ministry of Environment and Water and Executive Environment

Agency, http://eea.government.bg/bg/legislation/air/zapoved_96921.12.2013.pdf

Ordinance N12 of 15 July 2010 concerning norms for sulphur dioxide, nitrogen dioxide, particu-

late matter, lead, benzene, carbon monoxide and ozone in ambient air, https://www.moew.gov-

ernment.bg/static/media/ups/tiny/file/Air/Naredbi_KAV/Naredba_12_Normi_KAV.pdf

Ordinance N11 of 14.05.2007 concerning norms for arsenic, cadmium, nickel and polycyclic aro-

matic hydrocarbons in ambient air, http://eea.government.bg/bg/legisla-

tion/air/Naredba11_tejki_metali_V_2007.pdf




























http://ope.moew.government.bg/files/useruploads/files/list_of_operations_technical_en.pdf






https://www.moew.government.bg/static/media/ups/tiny/file/Air/Naredbi_KAV/Naredba_12_Normi_KAV.pdf




http://eea.government.bg/bg/legislation/air/Naredba11_tejki_metali_V_2007.pdf






(2008/50/EC, 2004/107/EC)

March 2019 40

Ordinance N7 concerning assessment and management of air quality, http://eea.govern-

ment.bg/bg/legislation/air/N7_OUKAV.pdf

Plovdiv Municipality, 2018, Programme for improving air quality on the territory of the Plovdiv

Municipality for the period 2018-2023, available at: http://www.plovdiv.bg/item/ecology/docu-

ments/%D0%BF%D0%BB%D0%B0%D0%BD%D0%BE%D0%B2%D0%B5-%D0%B8-

%D0%BF%D1%80%D0%BE%D0%B3%D1%80%D0%B0%D0%BC%D0%B8/

Plovdiv Municipality, Programme for reaching the standards of particulate matter smaller than

2.5 micrones (PM2.5) and polycyclical aromatic hydrocarbons (PAHs) in the ambient air on the

territory of the Plovdiv Municipality with Action plan for the period 2013-2015,

http://www.plovdiv.bg/wp-content/uploads/okolna-sreda/Pro-

gram_AQ_PM2,5&PAH_Pd_2013_2015.Plovdiv.pdf

Plovdiv Municipality, 2011, Update of the programme for improving air quality on the territory of

the Plovdiv Municipality 2003-2010 and preparation of Action plan for the period 2011-2013,

http://www.plovdiv.bg/wp-content/uploads/okolna-sreda/normativni-dokumenti/Plovdiv_Pro-

grama_KAV_2011-2013_Plan%20za%20deistvie.pdf

Pre-2008 legislation (Ordinance N9 of 3 May 1999 concerning norms for sulphur dioxide, nitrous

oxide, particulate matter and lead in ambient air; Ordinance N1 of 16 January 2004 concerning

norms for benzene and carbon monoxide in ambient air; and Ordinance N4 of 5 July 2004 con-

cerning norms for ozone in ambient air) were accessed through the website:

http://www.econ.bg/

Databases and websites:

Asenovgrad Municipality, General Economic Characteristics: https://www.assenovgrad.com/ob-

jects.php?cid=46

Council of Ministers, Portal for Public Consultations, Draft National Programme for Improving the

Air Quality (2018-2024): http://www.strategy.bg/PublicConsultations/View.aspx?lang=bg-

BG&Id=3846

CURIA, C-488/15 - Commission v Bulgaria, http://curia.europa.eu/juris/liste.jsf?num=C-488/15

Eionet, Common Data Repository (CDR), (B) Information on zones and agglomerations (Article

6), Bulgaria - 2016 resubmission: http://cdr.eionet.europa.eu/Converters/run_conver-

sion?file=bg/eu/aqd/b/envwdfera/BG_aq_zone_2014.dbf&conv=dbf_as_html&source=local

European Commission, 2018, November infringements package: key decisions, European Com-

mission – Fact Sheet, 8 November 2018: http://europa.eu/rapid/press-release_MEMO-18-

6247_en.htm

European Commission, 2015, Commission refers BELGIUM and BULGARIA to Court and gives

Sweden a final warning over poor air quality, press release: http://europa.eu/rapid/press-re-

lease_IP-15-5197_en.htm

European Environment Agency, 2018, Bulgaria – air pollution country fact sheet 2018: 2018,

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

http://eea.government.bg/bg/legislation/air/N7_OUKAV.pdf




http://www.plovdiv.bg/item/ecology/documents/%D0%BF%D0%BB%D0%B0%D0%BD%D0%BE%D0%B2%D0%B5-%D0%B8-%D0%BF%D1%80%D0%BE%D0%B3%D1%80%D0%B0%D0%BC%D0%B8/













http://www.econ.bg/








http://cdr.eionet.europa.eu/Converters/run_conversion?file=bg/eu/aqd/b/envwdfera/BG_aq_zone_2014.dbf&conv=dbf_as_html&source=local














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March 2019 41

European Environment Agency, Bulgaria – air pollution country fact sheet 2017:


Eurostat, GDP per capita in Purchasing Power Standards (PPS) expressed in relation to the Euro-

pean Union (EU28) average set to equal 100: http://ec.europa.eu/eurostat/tgm/ta-

ble.do?tab=table&init=1&language=en&pcode=tec00114&plugin=1

Eurostat, Population on 1 January: http://ec.europa.eu/eurostat/tgm/table.do?tab=ta-

ble&init=1&language=en&pcode=tps00001&plugin=1

Eurostat, Real GDP per capita, growth rate and totals: http://ec.europa.eu/eurostat/tgm/ta-

ble.do?tab=table&init=1&language=en&pcode=tsdec100&plugin=1

Executive Environment Agency, Daily Bulletin on air quality in the country: http://eea.govern-

ment.bg/airq/bulletin.jsp

Executive Environment Agency, Legislation concerning ambient air quality: http://eea.govern-

ment.bg/bg/legislation/air

Executive Environment Agency, Monitoring of air, noise and radiology: http://eea.govern-

ment.bg/bg/nsmos/air

Executive Environment Agency, Quarterly Bulletin on the state of the environment:


Executive Environment Agency, National reports on the state and protection of the environ-

ment: http://eea.government.bg/bg/soer/soer-arhiv

Executive Environment Agency, Technical condition of the National automated system for air

quality control in the first six months of 2018: http://eea.govern-

ment.bg/bg/nsmos/spravki/2018/air2

Filipova, I. 2018, Bulgaria now has a programme for reduction of particulate matter in the ambi-

ent air, 30 Sep 2018 published in Capital Newspaper: https://www.capital.bg/poli-

tika_i_ikonomika/bulgaria/2018/09/30/3318430_bulgariia_veche_ima_programa_za_nama-

liavane_na_finite/

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omy/

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na-atmosferniya-vuzduh/normativni-aktove/

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ment/update of the municipal programmes for air quality: http://ope.moew.govern-

ment.bg/bg/notice/noticedetail/from/noticecurrent/id/77/typeId/1

Plovdiv Municipality, Local system for air quality: http://www.plovdiv.bg/item/ecol-

ogy/%d0%b2%d1%8a%d0%b7%d0%b4%d1%83%d1%85/%d0%bc%d0%b5%d1%81%d1%8

2%d0%bd%d0%b0-%d1%81%d0%b8%d1%81%d1%82%d0%b5%d0%bc%d0%b0-

%d0%b7%d0%b0-%d0%ba%d0%b0%d0%b2/


http://ec.europa.eu/eurostat/tgm/table.do?tab=table&init=1&language=en&pcode=tec00114&plugin=1




http://ec.europa.eu/eurostat/tgm/table.do?tab=table&init=1&language=en&pcode=tps00001&plugin=1




http://ec.europa.eu/eurostat/tgm/table.do?tab=table&init=1&language=en&pcode=tsdec100&plugin=1


















http://eea.government.bg/bg/soer/soer-arhiv

http://eea.government.bg/bg/soer/soer-arhiv























http://www.plovdiv.bg/item/ecology/%d0%b2%d1%8a%d0%b7%d0%b4%d1%83%d1%85/%d0%bc%d0%b5%d1%81%d1%82%d0%bd%d0%b0-%d1%81%d0%b8%d1%81%d1%82%d0%b5%d0%bc%d0%b0-%d0%b7%d0%b0-%d0%ba%d0%b0%d0%b2/










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March 2019 42

Plovdiv Municipality, Monitoring of the Environment, Air Quality: http://ecomonitoring.plov-

div.bg/plovdiv/air_quality.jsp

Plovdiv Municipality, Monitoring of the Environment, Real Time Parameters: http://ecomonitor-

ing.plovdiv.bg/plovdiv/air_params.jsp

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ceedance of the alert thresholds: http://plovdiv.riosv.com/main.php?module=info&ob-

ject=info&action=view&inf_id=31















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APPENDIX B INTERVIEWS

Organisation Date of the interview Notes

Energy Agency Plovdiv 4 September 2018 Telephone in-

terview

Za Zemiata 5 September 2018 Telephone in-

terview

Executive Environment Agency (ExEA) 19 September 2018 Telephone in-

terview

National Association of the Municipalities in Republic of

Bulgaria (NAMRB)

19 September 2018 Telephone in-

terview

Ministry of Environment and Water (MOEW) 25 September 2018 Telephone in-

terview

Bulgarian Association of the Municipal Environmental Ex-

perts (BAMEE)

28 September 2018 Written feed-

back



(2008/50/EC, 2004/107/EC)

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APPENDIX C PILOT INTERVIEW GUIDE

General questions

• What challenges have been encountered when implementing the AAQ Directives?

• How have these challenges been overcome? What has proved to work well and what turned

out to work less well? Are there any relevant lessons learned that other Member States could

learn from?

• Where do you see the greatest potential to improve further the implementation of the Direc-

tives?

• Have any specific initiatives/measures been introduced to support the implementation of the

AAQ Directives in the Member State (e.g. national guidance, arrangements for information

exchange, etc.)?

• What systems are in place to provide information to the public on air quality, exceedances

and alerts, and the implementation of plans and measures?

Specific questions:

The table below outlines the specific themes discussed during the interviews.



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Evaluation question Questions

RELEVANCE

(1) How relevant are the goals and objectives of

the AAQ Directives to the needs of citizens; do the

AAQ Directives still address the most relevant pol-

lutants and set relevant standards and obligations

to protect human health and the environment; and

are the AAQ Directives sufficiently adapted or

adaptable to evolving technical and scientific pro-

gress?

To what extent do the goals of the Directives corre-

spond to the needs of the citizens (in your coun-

try)?

Which of the Directives' requirements are in your

opinion the most important in relation to the citi-

zens' needs?

To what extent have the goals of the Directives

been integrated in the strategic documents (on en-

vironmental protection) in your country?

(2) How far are the Directives aligned with key EU

priorities? Which elements in the Directives are es-

sential to deliver on these priorities, have elements

become redundant?

EFFECTIVENESS

(3) What factors have contributed to meeting the

objectives of the AAQD or to failing to meet these

objectives, in terms of: 1) defining common meth-

ods to monitor and assess air quality; 2) assessing

ambient air quality in order to monitor trends; 3)

establishing standards of air quality to achieve

across the EU; 4) ensuring that information on air

quality is made public; 5) maintaining good air

quality, improving it where it is not good; to what

level can these factors be attributed to provisions

of the AAQ Directives?

What are the main factors that contribute to com-

pliance with/effective implementation of the air

quality Directives; hereunder:

• air quality standards

• reporting requirements

• requirements regarding the establishment and

implementation of air quality plans and pro-

grammes

• requirements regarding provision of infor-

mation to public?

• requirements regarding monitoring stations?

What are the main barriers (at national/regional/lo-

cal) level preventing effective implementation of

the air quality Directives? Please consider each of

the items listed above separately.

What would it take to overcome the barriers?

EFFICIENCY

(4) What are the costs and benefits (monetary and

non-monetary) associated with implementation of

the AAQ Directives in the Member States, and in

the EU; have the benefits (improved air quality)

been achieved in a cost-effective manner and to

what extent have costs been equitably distributed

across different sectors?

What are the costs of implementation of the AAQ

Directives?

What is the cost of implementation (monitoring, re-

porting, and planning) for different levels of gov-

ernment, including the use of external expertise

on, per year (in FTE)?

What is the cost of implementation for different

sectors of the industry per year (capital and oper-

ating costs of equipment in EUR)?

What specific factors contribute to the efficiency/in-

efficiency of the implementation of the AAQ Direc-

tives?

(5) Where there are significant cost differences be-

tween Member States and/or between different

sectors and/or as regards costs to stakeholders (in-

cluding social costs as a consequences of poor im-

plementation), what is causing them; and are the

costs of compliance proportionate to the benefits

brought by the directives?



(2008/50/EC, 2004/107/EC)

March 2019 46


(6) How efficient are monitoring, reporting and as-

sessment regimes, what are the administrative

costs to the Member States and to the Commission;

taking account of the objectives and benefits of the

directives is there evidence that they have caused

unnecessary or excessive administrative burden?

What are the costs of non-implementation of the

Directives (e.g. environmental and health costs,

uncertainty and market distortion, litigation costs

for Member States)?

What are benefits associated with the implementa-

tion of the Directives in the Member State/air qual-

ity zone (e.g. health and environmental benefits,

economic benefits, eco-innovation, etc.)?

(7) Has the implementation of the AAQ Directives

supported or hampered EU competitiveness in the

global economy; has the implementation of the

AAQ Directives improved or been detrimental to

economic, social and environmental sustainability?

COHERENCE

(8) To what extent do the AAQ Directives comple-

ment or interact with other environmental policies

that affect air quality, or that are affected by it, at

EU level and at Member State level (such as the

NEC Directive and IED Directive as well as the EU

climate legislation and policy; and how do these

policies and legislation support or hamper the im-

plementation of the EU air quality legislation?

How and to what extent is the implementation of

the AAQ Directives coordinated with the implemen-

tation of other EU instruments in the environmental

and climate domain (e.g. the National Emissions’

Ceiling Directive, the Industrial Emissions’ Di-

rective, Large Combustion Plants Directive, etc.)?


ment or interact with sectoral policies that affect air

quality, or that are affected by it, at EU level and at

Member State level (such as energy, transport, ag-

riculture, cohesion, fiscal policies); and how do

these policies support or hamper the implementa-

tion of the EU air quality legislation?


AAQ Directives coordinated with other relevant leg-

islation and policy (e.g. in the area of energy,

transport and agriculture)?

Are air quality plans coordinated with planning ini-

tiatives promoted by EU sectoral legislation (e.g.

Sustainable Urban Mobility Plans, TEN-T invest-

ments)?

Are air quality plans coordinated with national

emission reduction plans and measures under the

NEC Directive?

Are air quality plans coordinated with climate

change mitigation policies and plans (for GHG

emission reductions)?

To what extent are air quality plans integrated or

linked with municipal/urban/regional level planning

e.g. in the area of land use and spatial planning,

energy management, transportation and climate?

To what extent are EU funds used to finance

measures (e.g. abatement programmes) to main-

tain good air quality/improve air quality?

ADDED VALUE

(10) To which degree have the AAQ Directives, in-

cluding common EU air quality standards and com-

parable air quality assessment, management and

information approaches enabled Member States

and their competent authorities to take successful

Have AAQ Directives triggered transformational

changes that have enabled the achievement of air

quality objectives?



(2008/50/EC, 2004/107/EC)

March 2019 47


action to improve beyond what would have been

possible without EU action?

Have AAQ Directives contributed to improvements

in monitoring?


in public information and public participation?

What are the wider economic, social and environ-

mental impacts of the Directives in the Member

State/air quality zone?

(11) What has been the EU added value of the AAQ

Directives, do the Directives and their means of im-

plementation create synergies or overlaps with

other Community objectives, and how has the dis-

tribution of responsibilities between EU, Member

State, regional and local levels impacted on air

quality management?

How is the implementation of the AAQ Directives

coordinated in the Member State (division of re-

sponsibilities, coordination across different activi-

ties)?

To what extent is the implementation of AAQ Direc-

tives coordinated in the region (to address trans-

boundary pollution)?



(2008/50/EC, 2004/107/EC)

March 2019 48

APPENDIX D AREAS OF AIR QUALITY MANAGEMENT

Table 4-1 Air quality zones and the municipalities they cover

Agglomera-

tion/Zone

Provinces cov-

ered (MOEW Or-

der 2013)

Municipalities

that need air

quality plans

(2018)

Pollutants (Eio-

net 2014)

Area (km²)

(Eionet 2014)

Popu-

lation

(Eio-

net

2014)

Plovdiv Part of Plovdiv: mu-

nicipalities of

Asenovgrad, Plov-

div and Rodopi

Asenovgrad and

Plovdiv

C6H6; CO; NO2;

O3; PM10; PM2.5;

SO2; BaP; Cd; Pb

1,390

506,91

3

Sofia

Part of Sofia: larger

Capital Municipality

Sofia C6H6; CO; NO2;

O3; PM10; PM2.5;

SO2; As; BaP; Cd;

Ni; Pb

1,350 1,249,6

65

Varna Part of Varna:

Varna, Devnya and

Beloslav

Varna and Devnya

C6H6; CO; NO2;

O3; PM10; PM2.5;

SO2; As; BaP; Ni

504 397,25

5

North

Vratsa, Vidin, Mon-

tana, Ruse, Veliko

Tarnovo, Gabrovo,

Lovech Pleven, Do-

brich, Targovishte,

Shumen, Silistra,

Razgrad, part of

Varna

Vratsa, Vidin,

Montana, Ruse,

Veliko Tarnovo,

Pleven, Lovech,

Dobrich, Gorna

Oryahovitsa, and

Shumen

C6H6; CO; NO2;

O3; PM10; PM2.5;

SO2; BaP; Ni

48,023 2,258,5

23

South-East

Burgas, Pazardzhik,

Yambol, Sliven,

Stara Zagora,

Haskovo, part of

Plovdiv

Burgas, Nesebar,

Pazardzhik,

Galabovo, Sliven,

Stara Zagora, Di-

mitrovgrad and

Haskovo

C6H6; CO; NO2;

O3; PM10; PM2.5;

SO2; As; BaP; Cd;

Ni; Pb

34,330 1,731,2

38

South-West

Blagoevgrad,

Kyustendil, Pernik,

Smolyan, Kardzhali,

part of Sofia

Pirdop,

Blagoevgrad, Per-

nik, Smolyan and

Kardzhali

C6H6; CO; NO2;

NOx; O3; PM10;

PM2.5; SO2; As;

BaP; Cd; Ni; Pb

25,315 1,102,0

83

Sources: Order 969 of 21.12.2013, Ministry of Environment and Water and Executive Environment Agency.

Operational Programme Environment 2014-2020, Ongoing calls, BG16M1OP002-5.002. Eionet, Common Data

Repository (CDR), (B) Information on zones and agglomerations (Article 6), Bulgaria - 2016 resubmission.



(2008/50/EC, 2004/107/EC)

March 2019 49

APPENDIX E POLLUTANT CONCENTRATION DATA FOR BULGARIA, 2013-17

Table 4-2 Highest pollutant concentrations in exceedance of EU air quality objectives for protection of health in Bulgaria in 2013-2017 - extract from reporting (Dataflow

G).

Pollutant Averaging period Objective type and value Date for achieving objec-

tive

Parameter shown 2013 2014 2015 2016 2017

PM10 Calendar year LV: 40 μg/m3 1 January 2005 Annual mean, μg/m3 62 64 69 61 55

1 day LV: 50 μg/m³ not to be ex-

ceeded on more than 35 days

per year

1 January 2005 Days above 173 171 188 168 127

NO₂ Calendar year LV: 40 μg/m³ 1 January 2010 Annual mean, μg/m3 52 - 42 50 43

1 hour LV: 200 μg/m3 not to be ex-

ceeded on more than 18 hours

per year

1 January 2010 Hours above - - - - 33

SO₂ 1 day LV: 125 μg/m3 not to be ex-


per year




per year

1 January 2005 Hours above 57 83 118 85 117

CO Maximum daily 8-hour

mean

LV: 10mg/m3 1 January 2005 Days above - - - - -

C6H6 Calendar year LV: 5 μg/m3 1 January 2010 Annual mean, μg/m3 - - - - -

Pb Calendar year LV: 0.5 μg/m³ (measured as

content in PM10)

1 January 2005 Annual mean, μg/m3 1 - - - -

O3 Maximum daily eight-hour

mean

TV: 120 μg/m³ not to be ex-


per calendar year averaged

over three years

1 January 2010 Days above - 43 30 30 51



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March 2019 50


tive

Parameter shown 2013 2014 2015 2016 2017

Maximum daily eight-hour

mean within a calendar

year

LTO: 120 μg/m³ Not defined Days above 114 81 37 30 38

PM2.5 Calendar year LV: 25 μg/m³ 1 January 2015 (target value

until 1 January 2010)

Annual mean, μg/m3 35 30 35 26 27

(calculated as Average Ex-

posure Indicator, assessed

as a 3-year running an-

nual mean)

ECO: 20 μg/m3 2015 AEI, μg/m3 40 24 27 24 24

As Calendar year TV: 6 ng/m³ (measured as

content in PM10)

31 December 2012 Annual mean, ng/m3 - - - - -

Cd Calendar year TV: 5 ng/m³ (measured as

content in PM10)

31 December 2012 Annual mean, ng/m3 32 19 11 - -

Ni Calendar year TV: 20 ng/m³ (measured as

content in PM10)


BaP Calendar year TV: 1 ng/m³ (measured as con-

tent in PM10)

31 December 2012 Annual mean, ng/m3 3 3 4 4 3

Source: COWI calculations based on Member State reporting, data flow G. Downloaded in November 2018.

Note: LV: limit value; TV: target value; LTO: Long term objective; ECO: exposure concentration obligation; The values show the maximum exceedance reported in the Member State (if no

exceedances are reported in any of the zones of the Member State, the table shows "-")

Legend: "NA": not available in data flow G, "-": no reported exceedances

[Written by Douglas R. Clark] [March – 2019]

CASE STUDY REPORT

GERMANY



(2008/50/EC, 2004/107/EC)


SUPPORTING THE FITNESS CHECK OF THE EU AMBIENT AIR QUALITY

DIRECTIVES (2008/50/EC, 2004/107/EC)

Written by Douglas Clark March – 2019

EUR [number] EN

Contents

1 Introduction 4

2 Case study background 5

2.1 Geand air quality zone characteristics 5





2.6 Use of EU funding to fund air quality improvements 21

3 Findings 22




3.4 Factors underlying compliance with and effectiveness of the

AAQ Directives 27


4 Conclusions 30





SUPPORTING THE FITNESS CHECK OF THE EU AMBIENT AIR QUALITY

DIRECTIVES (2008/50/EC, 2004/107/EC)

March 2019 3

Appendices




Appendix D Federal Immission Control Regulations (BImSchV)

Appendix E Pollutant concentration data for Germany, 2013-17

Appendix F EU ERDF and LIFE projects

EUROPEAN COMMISSION, DG ENVIRONMENT SUPPORTING THE FITNESS CHECK OF THE EU AMBIENT AIR QUALITY DIRECTIVES

(2008/50/EC, 2004/107/EC)

March 2019 4

1 INTRODUCTION

This report summarises the findings and conclusions of the case study for Germany. The case

study had a focus on Berlin Agglomeration.

















the case study






over the period September, October and November 2018. An overview of the interviews carried

out is provided in Appendix A.





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March 2019 5

2 CASE STUDY BACKGROUND

Chapter 1 provides general information about Germany and the city-state Berlin. The purpose of

this chapter is to set a background for the more detailed findings presented in Chapter 1. The

chapter relies primarily on desk research. The findings from desk research are supplemented by

interviews.

2.1 Germany and air quality zone characteristics

2.1.1 Scope and focus of the case study

The case study covers the entire territory of Germany and focuses in particular on the Berlin

agglomeration.

2.1.2 Characteristic of air quality zones

In Germany, the 16 states are responsible to establish air quality zones and agglomerations. Air

quality zones and agglomerations were first established in 2002. Before 2008, the zones were

revised almost every year based on the exceedances. This led to an annually changing framework

for air quality management that was difficult to follow. Beginning in 2008, the procedure was

changed, and now for all pollutants the zones and agglomerations are stable.

As shown in Figure 2-1 below, Germany was divided into 89 zones for assessment of NO2 in 2014.

The number in 2017 was 87. In 2017, there were 86 zones for PM10, and 79 zones for PM2.5. The

zones for NO2 and PM10 include 36 agglomerations. The boundaries of air quality zones follow

administrative division boundaries.

Figure 2-1 Air quality zones for NO₂, 2014. Source: European Commission, DG Environment, Atlas of air

quality zones and monitoring stations (2013 & 2014), Germany.


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March 2019 6

The whole city-state Berlin, one of the 16 German states, is one of the 36 agglomerations in

Germany. Berlin is situated in north-eastern Germany, surrounded by the state of Brandenburg.

The population of Berlin is 3.7 million (2017), and the area is 892 km2.

Berlin is bounded on the southwest by Potsdam, the largest city in Brandenburg. Potsdam is a

separate agglomeration for air quality assessment.

Figure 2-2 Berlin agglomeration monitoring stations for NO₂ and PM10, 2014. Source: European Com-

mission, DG Environment, Atlas of air quality zones and monitoring stations (2013 & 2014),

Germany.

2.1.3 Geomorphology

Germany reaches from the outer ranges of the Alps northward across the Central German Uplands

and then across the sandy, rolling plains of the North German Plain. Germany's central and south-

ern regions have forested hills and mountains cut through by the Danube, Main, and Rhine river

valleys. In the north, the landscape flattens out to a wide plain that stretches to the North Sea.

There are forested hills in the urbanized west of Germany, and agricultural plains in the east.

The detailed characteristics of Germany and of the Berlin agglomeration are presented in the text-

box below.


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March 2019 7

Text box 2-1 Germany and the Berlin agglomeration.

Germany


GDP per capita growth (% 2008-2017) 11.5 %


Governance structure Federal, 16 States (Länder)


Berlin agglomeration

Number of inhabitants: 3.7 million

Area: 891.7 km2

Characteristics of the Berlin agglomeration:

Berlin straddles the river Spree in an area of low-lying marshy woodlands with a mainly flat topography.

Source: Eurostat tec00114, GDP per capita in Purchasing Power Standards (PPS) expressed in relation to the

European Union (EU28) average set to equal 100; Eurostat tec00115, Real GDP per capita, growth rate and

totals, sum of annual growth rates 2009 to 2017; Eurostat tps00001, Population on 1 January; Eionet data

and the report Air Quality in Germany, 2017.


This section summarises the air quality monitoring networks in Germany and provides a short

overview of air quality achievements in Germany. Detailed information regarding the exceedances

reported in the EEA database is presented in Appendix D to this report.

2.2.1 Air quality assessment

The 16 States are responsible for the assessment of air quality. Air quality is measured at over

650 monitoring stations throughout Germany, by the individual States and by the German Envi-

ronment Agency (Umweltbundesamt, UBA).


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March 2019 8

UBA operates a national network of seven regional background stations, to monitor background

and transboundary pollutant levels. These stations are operated as part of international pro-

grammes, including EMEP.

Each of the 16 Federal States operates air quality monitoring networks in their area and make

current air quality data available on the websites of the responsible state offices1. State monitoring

data is also transmitted to the national air quality database at UBA, where it is accessible on UBA’s

national air quality information service2. UBA transmits data to the EEA e-Reporting system for

the AAQD and Decision 2011/850/EU reporting obligations.

NO₂, PM10, PM2.5, ozone, SO₂ and CO are measured directly in the monitoring stations and real-

time data is retrieved and checked. There is a continuous data flow from the measuring stations

to UBA.

Both gravimetric and automatic equivalent methods are used to measure PM10 and PM2.5. Some

States only send the laboratory-based gravimetric PM measurements for the official reporting to

the EEA as they only consider the reference method to be compliant with the legislative require-

ments. Gravimetric PM samples are further analysed for metals.

In addition to continuous automatic monitoring using reference and equivalent methods, many of

the States collect fixed measurements using passive sampling with 100% time coverage, primarily

for NO₂.

The Berlin air quality monitoring network (BLUME) has operated since 1975. It now includes 16

fixed stations with continuous automatic measurements with a different number of instruments

for NOx/NO₂ (16 sites), PM10 (11), ozone (7), benzene (3), SO₂ (2) and CO (2). There are six

traffic stations on busy roads, five inner-city urban background stations (residential and commer-

cial areas) and five suburban background stations. PM2.5 is measured gravimetrically at one traffic

and three urban background stations. Benzo(a)pyrene and heavy metals in PM10 are measured at

two and four of the stations, respectively. There is also one meteorological station and one mobile

station - the “measurement bus”. Data from the automatic stations is available on Berlin’s online

air quality information service3.

The Berlin monitoring network also includes up to 30 small and low-cost roadside sampling devices

for black carbon (EC/OC) in operation since 1997. Passive samplers for NO₂ are also used at these

30 sites, using a two-week sampling period throughout the year. Due to the delay for laboratory

processing, most of these data are only published in annual reports. Given the growing public

interest in NO₂ measurements, Berlin has now started publishing the bi-weekly averages of the

passive samplers as well. Since 2017, two automatic aethalometer instruments are in operation,

measuring especially the contribution from wood burning to PM10.

2.2.2 Air quality in Germany

The following summary of air quality statistics for 2017 in Germany is based on a preliminary

analysis by the German Environment Agency (Umweltbundesamt, 2018). The summary includes

PM10, PM2.5, NO₂ and ozone.

1 https://www.umweltbundesamt.de/themen/luft/messenbeobachtenueberwachen/luftmessnetze-der-bun-

deslaender

2 https://www.umweltbundesamt.de/en/data/current-concentrations-of-air-pollutants-in-germany

3 https://luftdaten.berlin.de/lqi

https://www.umweltbundesamt.de/themen/luft/messenbeobachtenueberwachen/luftmessnetze-der-bundeslaender




https://www.umweltbundesamt.de/en/data/current-concentrations-of-air-pollutants-in-germany

https://www.umweltbundesamt.de/en/data/current-concentrations-of-air-pollutants-in-germany

https://luftdaten.berlin.de/lqi

https://luftdaten.berlin.de/lqi


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March 2019 9

Air quality

In 2017, the level of PM10 particulate matter in Germany was lower compared to 2005–2016

(Figure 2-3). The EU 24-hour PM10 limit value was only exceeded at one station in Stuttgart. The

WHO 24-hour guideline for PM10 was exceeded at 87 percent of all air monitoring stations. The

EU annual limit value for PM10 (40 μg/m³) was not exceeded in Germany in 2017, although 21

percent of the stations exceeded the WHO annual guideline for PM10 (20 ug/m³).

Figure 2-3 Percentage of stations exceeding the 24-hour PM10 limit value in Germany, 2005-2017.

Source: Umweltbundesamt (2018).

For PM2.5, the EU annual limit value was not exceeded at any monitoring station in Germany in

2017. The Average Exposure Indicator (AEI) for PM2.5 in 2017 (average of 2015, 2016, 2017) was

12.6 μg/m³ (preliminary), which is already below Germany’s 15% national reduction target for

AEI by 2020 of 13.9 ug/m³.

The EU annual limit value for NO₂ was exceeded at an estimated 46 % of urban traffic monitoring

stations in Germany in 2017 (preliminary, Figure 2-4). The EU annual limit value for NO₂ is the

same as the WHO guideline value. The EU one-hour limit value for NO₂ (200 μg/m³ up to 18 times

per year) was not exceeded at any station in Germany for the first time in 2017. In previous

years, there have been several exceedances at urban traffic stations.

The measured annual average concentrations of NO₂ in Germany declined until the end of the

1990’s4. Since the year 2000 only a small downward trend is detectable. In 2017 the air in German

cities was still highly polluted with NO₂4.

4 Schneider et al. (2018). Quantifizierung von umweltbedingten Krankheitslasten aufgrund der Stickstoffdi-

oxid-Exposition in Deutschland https://www.umweltbundesamt.de/sites/default/files/medien/421/publikati-

onen/abschlussbericht_no2_krankheitslast_final_2018_03_05.pdf

https://www.umweltbundesamt.de/sites/default/files/medien/421/publikationen/abschlussbericht_no2_krankheitslast_final_2018_03_05.pdf





(2008/50/EC, 2004/107/EC)

March 2019 10

Figure 2-4 Percentage of air quality monitoring stations exceeding the annual limit value for NO₂ in

Germany, 2010-2017

Source: Umweltbundesamt (2018).

In comparison with the last 20 years, ozone concentrations were quite low in Germany in 2017.

The 8-hour target value for ozone (120 ug/m³ up to 25 day, 3-year average) was exceeded at 17

percent of the monitoring stations in Germany – mostly at rural background stations (Figure 2-5).

The alert threshold for ozone (240 ug/m³) was not exceeded, but the information threshold (180

ug/m³) was exceeded on seven days. The long-term objective for 8-hour ozone concentration

(120 ug/m³) was exceeded at 95 percent of the stations in Germany.


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March 2019 11

Figure 2-5 Percentage of air monitoring stations exceeding the 8-hour limit value for ozone in Germany,

3-year averages, 2008-2017.

Source: Umweltbundesamt (2018). Air Quality 2017 – Preliminary Evaluation. [166]

Compliance performance

A summary of maximum pollutant concentrations in exceedance of the AAQD standards is pro-

vided in Appendix D for the years 2013 to 2017, for each of the 12 pollutants included in the

AAQD. These values are obtained through processing of EEA data flow G data.

In 2017, there were exceedances in Germany of the limit values for NO₂ (annual), PM10, (24-

hour), O3 (8-hour target and long-term objective), and Ni (target). There were no exceedances

of the other pollutants. 2017 is the first year that no exceedances occurred in Germany for the 1-

hour NO₂ limit value.

In 2013, there were exceedances for NO₂, PM10, O3, C6H6, Cd and Ni. The PAH target value has

been exceeded in two of the past five years: 2015 and 2016.

Exposure and health impact

The percentage of urban population exposed to concentrations of PM10 above the 24-hour limit

value has declined from nearly 9 % in 2010 to 0.1 % in 2016 (Table 2-1). The percentage is zero

for PM2.5, since 2012. There is considerable variation and no clear trend in exposure to ozone

concentrations above the target value. There is also no clear trend in urban exposure to NO₂

concentrations above the annual limit value in the years 2010 to 2016, remaining in the range

5.1 to 6.9 %.


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March 2019 12

Table 2-1 Percentage of urban population in Germany exposed to concentrations above EU standards.

Pollu-

tant

Measure 2010 2011 2012 2013 2014 2015 2016 2017

PM2.5 Annual mean na na 0.0 0.0 0.0 0.0 0.0 na

PM10 Percentile

90.41asdfasd

sdaxxx90.41

90.41

8.6 8.4 0.5 0.5 0.8 0.3 0.1 na

O3 Percentile

93.15

11.5 1.3 3.1 4.0 3.6 37.0 2.7 na

NO₂ Annual mean 5.9 5.6 5.8 6.9 6.8 5.2 5.1 na

Source: European Environment Agency, Air pollution fact sheet 2014 – Germany (for 2010, 2011 values), and

2018 (for 2012-2016 values). na = not available.

EEA estimates of premature deaths attributable to PM2.5, NO₂ and O3 exposure in Germany are

available for three years, 2013 to 2015 (Table 2-2). Only the estimates for PM2.5 show decline

over these three years.

Table 2-2 Premature deaths attributable to PM2.5, NO₂ and O3 exposure in Germany.

Pollutant Measure 2010 2011 2012 2013 2014 2015 2016 2017

PM2.5 Annual mean 73 400 66 080 62 300 na na

PM10 Percentile

90.41

na na

O3 Percentile

93.15

2 500 2 220 3 000 na na

NO₂ Annual mean 10 610 12 860 13 100 na na

Source: European Environment Agency, Air quality in Europe – 2016 report (for 2013 values), 2017 report

(for 2014 values), 2018 report (for 2015 values).

In the Commission’s 2013 Impact Assessment, it has been estimated that the health-related ex-

ternal costs from air pollution in Germany are above EUR 58 billion/year (income adjusted, 2010),

which include not only the intrinsic value of living a fully healthy life but also direct costs to the

economy. These direct economic costs relate to 27 million workdays lost each year due to sickness

related to air pollution, with associated costs for employers of EUR 3,500 million/year (income

adjusted, 2010), for healthcare of above EUR 240 – 466 million/year (income adjusted, 2010),

and for agriculture (crop losses) of EUR 715 million/year (2010).5

5 EC. (2013). SWD(2013)531 - Commission Staff Working Document, Impact Assessment, Clean Air Pro-

gramme for Europe (p. 352). Retrieved from http://ec.europa.eu/environment/archives/air/pdf/Impact_as-

sessment_en.pdf [248], as cited in: EC DG ENV. (2017). SWD(2017) 38: EU Environmental Implementation

Review Country Report - Germany. Commission Staff Working Document (Commission Staff Working Docu-

ment). Brussels, Belgium: European Commission Directorate-General Environment. Retrieved from

http://ec.europa.eu/environment/eir/pdf/report_de_en.pdf

http://ec.europa.eu/environment/archives/air/pdf/Impact_assessment_en.pdf







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A recent study of the costs of health impacts from road transport emissions (CE Delft, 20186)

found that total health and non-health costs to be € 12,4 billion in 2016, based on COPERT emis-

sion factors, and € 19.3 billion (55 % more) using TRUE-initiative real-world driving emission

factors (Figure 2-6). The shares of total road-transport costs in Germany due to diesel vehicles in

2016 are 82 % and 75 % in these two cases.

Figure 2-6 Costs of air pollution from road transport in Germany in 2016, based on COPERT emission

factors and TRUE-initiative real driving emission factors.

Source: CE Delft, 2018.

The CE Delft study also calculates health and non-health costs due to road transport in 2030, for

a business as usual (BAU) scenario assuming existing policies, and low- and high-ambition sce-

narios of additional measures (faster uptake of zero-emission vehicles, bans of pre-Euro 6 vehi-

cles, fuel taxes, road charging). The costs are much lower in 2030. With COPERT emission factors,

the three scenarios total costs are BAU: € 3.4 billion, LOW: € 2.6 billion, and HIGH: € 1.8 billion,

corresponding to reductions from 2016 of 73 %, 79 % and 86 % respectively (Figure 2-7). With

TRUE-initiative real-driving emission factors, the costs in Germany in 2030 are about 70 % higher

than with COPERT emission factors, while the relative reductions from 2016 are similar.

6 [468] https://www.cedelft.eu/en/publications/download/2631

https://www.cedelft.eu/en/publications/download/2631


(2008/50/EC, 2004/107/EC)

March 2019 14

Figure 2-7 Costs of air pollution from road transport in Germany in 2030, for three scenarios, based on

COPERT emission factors and TRUE-initiative real driving emission factors.

Source: CE Delft, 2018.

2.2.3 Air quality in Berlin

An overview of the current air quality status in Berlin is given in Table 2-3. NO₂ remains a serious

problem, PM10 is coming under control and ozone exceedances are diminishing somewhat. There

are no longer exceedances of PM2.5, SO₂, benzene or PAH. CO and heavy metals have never been

a problem in Berlin.

Table 2-3 Main sources of air pollution and status of compliance in Berlin. Source: Lutz, 2018.

Pollutant Main sources Status and main measures

PM10 Long-range transport, traffic, resi-

dential heating

Largely solved, shrinking local con-

tribution

Switch to clean fuel & control tech-

nology

PM2.5 Long-range transport, traffic Problem solved, at least in relation

to the limit value

NO2 Road traffic (Diesel) Serious problem, national court

verdicts & law suit filed by EU, Die-

sel bans impending, needs cleaner

Diesel vehicles and less traffic

Ozone long-range transport, traffic Diminishing problem, to be solved

at national & EU level

SO2 Power plants, industry, domestic

heating

Problem solved 20 years ago

switch to clean fuel & control tech-

nology

CO, heavy metals Traffic, heavy industries Never a problem

Benzene Traffic Problem solved 10 years ago,

cleaner fuel & vehicle technology


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March 2019 15

Pollutant Main sources Status and main measures

PAH traffic, domestic heating Problem solved 5 years ago

switch to clean fuel & control tech-

nology

Emissions and source apportionment

At roadside stations in Berlin, about 62 % of the PM10 comes from the regional background and

26 % due to traffic, making it difficult to control PM10 with only local measures (Figure 2-1). For

NO₂ at roadside stations, only about 15 % is due to the regional background, while 75 % comes

from traffic, primarily diesel vehicles.

Figure 2-8 Source contributions a) to PM10 at different monitoring sites based on receptor modelling

(van Pinxteren et al., 2017) , b) to roadside PM10 and c) to roadside NO₂, both based on

dispersion modelling (SenUVK, 2018) (figure from Lutz, 2018).

Source: Lutz (2018).

Air quality

For PM10, exceedance of the short-term limit value has been a problem, with the city going in and

out of compliance from year to year, due to the high percentile statistic for 24-hour values (50

µg/m³, 35 days per year), primarily due to year to year meteorological variability (Figure 2-9).

But at least since 2016 the short-term limit value has been met.


(2008/50/EC, 2004/107/EC)

March 2019 16

Figure 2-9 Trend of annual average PM10 concentrations (lines), and maximum number of days over the

24-hour limit value (bars) in Berlin, 1998-2016.

Source: Lutz (2018).

The levels of NO₂ at monitoring sites in Berlin have not shown a clear trend over the last 20 years,

except a slight downward trend the last few years (Figure 2-10) contrary to traffic changes, which

show a decline of car traffic volume by 15% since 2002.

Figure 2-10 Trend of annual average NO₂ concentration in Berlin, by site type, 1999 to 2017. The solid

curve is the relative traffic volume.

Source: Lutz, 2018.

0

10

20

30

40

50

60

70

80

90

100

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

nitro

ge

n d

ioxid

e (

NO

2)

µg

/m³

Traffic increment

traffic sites

urban background sites

city periphery

limit value for NO2


(2008/50/EC, 2004/107/EC)

March 2019 17


Article 3 of the AAQ Directive requires Member States to designate – at the appropriate levels -

the competent authorities and bodies responsible for the assessment of ambient air quality and

the implementation of other obligations laid down by the AAQ Directive. In Germany, the Federal

Ministry for Environment, Nature Conservation and Nuclear Safety is the national authority re-

sponsible for the transposition of the AAQ Directive into national law, while most of its implemen-

tation like assessment of air quality and establishment of air quality plans, lies in the responsibility

of the Federal States. The day-to-day monitoring of air quality and modelling has also been del-

egated to the Federal States. The Federal States (German Länder) are responsible for ambient air

quality monitoring, assessment, as well as for air quality plans. The German Environment Agency

(Umweltbundesamt, UBA) manages the reporting on AQ and AQ plans to the European Commis-

sion and oversees rural background AQ measurements. It assists the Federal Environmental Min-

istry in developing national programmes. For harmonization of the quality programmes, two na-

tional reference laboratories are notified (UBA and the State Environment Agency of North Rhine

Westphalia (LANUV NRW)).


Legal framework

The legal framework for air quality in Germany is mainly governed by the Act on the Prevention

of Harmful Effects on the Environment Caused by Air Pollution, Noise, Vibration and Similar Phe-

nomena, for short: Federal Immission Control Act (BImSchG)7 and its implementing ordinances

and administrative regulations – the Federal Immission Control Regulations (BImSchV). A list of

the BImSchV regulations is provided in Appendix C, and key regulations are described below.

There are also provisions on air quality control at the Federal State level.

In Germany, the federal level has the legislative authority regarding the AAQD and the States

implement this legislation in their territory. The federal level cannot interfere with State imple-

mentation and enforcement, but the Federal Government exchanges information with the States

through the Federal-State Pollution Control Working Group.

Strategic framework

The German government bases air pollution control on four strategies8:

• laying down environmental quality standard

• emission reduction requirements according to the best available technology

• product regulations

• laying down national emission ceilings.

The ambient air limit values are stipulated in the AAQD and are transposed into German law.

Major legislation for air quality include:

• Federal Immission Control Act and implementing ordinances

Air quality control in Germany is mainly governed by the Act on the Prevention of Harmful

Effects on the Environment Caused by Air Pollution, Noise, Vibration and Similar Phenomena,

7 BImSchG – English translation: https://www.bmu.de/filead-

min/Daten_BMU/Download_PDF/Luft/bimschg_en_bf.pdf

8 https://www.bmu.de/en/topics/air-mobility-noise/air-pollution-control/general-information/

https://www.bmu.de/fileadmin/Daten_BMU/Download_PDF/Luft/bimschg_en_bf.pdf




https://www.bmu.de/en/topics/air-mobility-noise/air-pollution-control/general-information/

https://www.bmu.de/en/topics/air-mobility-noise/air-pollution-control/general-information/


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March 2019 18

short Federal Immission Control Act (BImSchG) and its implementing ordinances and admin-

istrative regulations. For example, the AAQD is implemented in national law by the 39. BIm-

SchV. In addition, there are also provisions on air quality control at Länder level.

• Technical Instructions on Air Quality Control (TA Luft)

The Technical Instruction on Air Quality Control (TA Luft) lays down procedures for authorities

to examine applications for new industrial installations or extensions of existing installations

with respect to their impact on air quality and deposition of air pollutants. In addition, it lays

down emissions limit values for relevant air pollutants from installations. Existing installations

must also be upgraded to the best available technology.

• Amendment to Ordinance on Small Combustion Installations (1. BImSchV)

The amendment to the Ordinance on Small Combustion Installations (1. BImSchV), which

entered into force in March 2010, was an important step towards reducing particulate matter

emissions from small combustion installations such as stoves and tiled stoves. The amended

requirements for new installations and the modernisation of existing installations contribute

a noticeable average reduction in particulate matter emissions of five to ten percent in the

residential areas concerned.

• Implementation of the Industrial Emissions Directive (IED)

A large share of the emissions reduction necessary to meet NEC targets will be achieved

through the IED implementation.

• Transboundary air pollution control policy

A significant share of the pollution load is transported from and to neighbouring countries.

The transboundary air pollution control policy is thus of strategic importance for air quality

in Germany, in particular for the northeast of the country, where Berlin is only 80 km from

the border to Poland. Germany participates actively in the constructive dialogue on air pol-

lution control measures at both European and international level, including the Convention

on Long-range Transboundary Air Pollution (CLRTAP) and Gothenburg Protocol. Encouraged

by the AAQD, bilateral meetings have taken place between Germany and Poland since 2006

dealing with transboundary transport of PM10 pollution and how to tackle it.


UBA maintains a list of local air quality plans (LRP) in Germany9. These plans need to be drawn

up by the Federal States or the authorities designated by them, in some cases city authorities or

regional governments in larger Federal States, like Bavaria and North Rhine-Westphalia. There

are 158 cities listed with links to air quality plans and links to LEZ information for 76 of the cities.

There are both air quality plans and combined air quality and short-term action plans.

Some of the larger cities have separate plans for city districts. There are 86 cities whose current

plans are the first version, 52 in 1st update, 14 2nd update and 2 in 3rd update. Munich’s air quality

plan is in its 6th revision, with the 7th update in preparation. 15 other cities have revisions in

9 UBA - Air quality plans in Germany http://gis.uba.de/website/umweltzonen/lrp_en.php

http://gis.uba.de/website/umweltzonen/lrp_en.php

http://gis.uba.de/website/umweltzonen/lrp_en.php


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March 2019 19

preparation. About 88 % of the cities have plans covering both PM10 and NO₂, while 9 % have

plans for NO₂ only, and 3 % PM10 only.

Berlin’s current air quality plan (for 2011-2017) was published in 201410, preceded by the first

version pursuant to the AAQD, covering the period 2005-2010.

The third revision of Berlin’s air quality plan is under development, to cover years 2018-202511.

An online public consultation survey was carried out in December 2018 and a draft AQ plan is

expected to be published for public comment and hearing by March 2019. The new AQ plan will

benefit from transportation measures included in the Berlin Mobility Act of 5 July 201812. It is a

novelty in Germany and will help to avoid court ordered driving bans by shifting car traffic to

cleaner modes of transport. These measures include incentive programs for taxis and e-mobility

- to quickly eliminate many high-mileage diesel taxis and replace them with green alternatives,

public transport, the promotion of cycling, the electrification of car-sharing offers and the demand

for a nationwide funding program for electro mobility13.

Legal actions

Public frustration with the ineffectiveness of air quality plans to reduce exceedances has led to

citizens seeking legal action to force cities to take effective measures. However, the AAQD does

not expressly grant rights to citizens or organisations to seek legal action to improve air quality,

so this had to be tested in the courts.

A landmark legal action known as “Janecek” was brought by a resident of a highly polluted road

in Munich in 2008. With support from the German NGO DUH (Deutsche Umwelthilfe), the action

passed through all the German courts until it reached the European Court of Justice (ECJ), which

confirmed the legally enforceable right to clean air on 25 July 2008 (Janecek case)14.

With the ruling of the Federal Administrative Court (BVerwG) in Leipzig of 5 September 2013

regarding a legal action brought by the DUH against the State of Hesse on account of the exceed-

ance of air quality limits in Darmstadt, the right of environmental associations to sue was signifi-

cantly strengthened. This ruling enables environmental and consumer protection organisations to

legally pursue compliance with air quality limits throughout the entire city.

The Administrative Court of Wiesbaden stated in its judgement of 30 June 2015 that financial or

economic aspects are not a valid excuse to refrain from taking measures to ensure that the limit

values are complied with. Air quality plans must, therefore, include all measures that are appro-

priate to comply with the limit values as soon as possible. These legal cases have paved the way

for numerous legal actions against German cities, to require effective air quality plans to be pre-

pared and implemented.

10 Berlin Senate, 2014. Air Quality Plan for Berlin 2011-2017 http://www.berlin.de/senuvk/umwelt/luftquali-

taet/de/luftreinhalteplan/download/lrp_150310_en.pdf

11 Berlin Senate – Update air pollution control plan https://www.berlin.de/senuvk/umwelt/luft/luftreinhal-

tung/luftreinhalteplan_2025/index_en.shtml

12 Berlin Mobility Act of 5 July 2018 https://www.berlin.de/senuvk/verkehr/mobilitaetsgesetz/in-

dex_en.shtml

13 Press release – Package of measures adopted to improve air quality and avoid driving bans, 18-01-2018

https://www.berlin.de/rbmskzl/aktuelles/pressemitteilungen/2018/pressemitteilung.666959.php

14http://curia.europa.eu/juris/liste.jsf?language=en&num=C-237/07

http://www.berlin.de/senuvk/umwelt/luftqualitaet/de/luftreinhalteplan/download/lrp_150310_en.pdf




https://www.berlin.de/senuvk/umwelt/luft/luftreinhaltung/luftreinhalteplan_2025/index_en.shtml




https://www.berlin.de/senuvk/verkehr/mobilitaetsgesetz/index_en.shtml




https://www.berlin.de/rbmskzl/aktuelles/pressemitteilungen/2018/pressemitteilung.666959.php

http://curia.europa.eu/juris/liste.jsf?language=en&num=C-237/07


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March 2019 20

Courts ordered the governments of Dusseldorf, Munich and Stuttgart, respectively to put re-

strictions on diesel vehicles in place. However, the cities argued that local authorities did not have

the power to restrict diesel vehicles, a major source of NO₂. BVerwG ruled 27 February 2018 that

cities are obliged to introduce diesel restrictions immediately to protect people’s health.

This ruling prompted DUH and the international NGO ClientEarth to take legal actions against 11

more German cities starting in March 2018. Deutsche Umwelthilfe (DUH) presently has legal ac-

tions in progress in 28 German cities, supported by ClientEarth.

Infringement cases

The persistent breaches of air quality requirements (for PM10 and NO₂) are being followed up by

the European Commission through infringement procedures.

The Commission issued a Formal Notice to Germany in January 2009 for failure to respect the 24-

hour limit value for PM10 to be met in 2005 (under the former AAQD 1999/30/EC). A Reasoned

Opinion was issued in September 2010, an additional formal notice in April 2013, and an additional

Reasoned Opinion in November 201415. The two zones concerned by the additional Reasoned

Opinion are Stuttgart and Leipzig. The infringement procedure is still active, 14 years after the

PM10 limit value was to have been met.

In May 2018, the Commission referred Germany to the European Court of Justice for failing to

address repeated breaches of the NO₂ annual limit value and for failing to take appropriate

measures to keep exceedance periods as short as possible16. A Letter of Formal Notice was issued

in June 2015 and a Reasoned Opinion in May 2017. The referral comes after eight consecutive

years of exceedance – in 28 zones including Berlin – of the NO₂ limit value to be met in 2010.


Pursuant to Article 26 of the AAQ Directive, Member States shall ensure that the public is ade-

quately informed, in good time, about ambient air quality and other issues specified in the above

cited Article.

In Germany, each of the 16 Federal States provides online and published air quality information.

At the Federal level, the UBA website provides information about air quality, pollutants and their

sources17. UBA has an interactive map and data service, which presents information about current

and historical air quality levels in Germany. Air quality measurement data from each monitoring

station can be downloaded in excel format. The exceedances of limit values are available for each

monitoring station in a table format and information on exceedances noted for each year at each

measurement station. The UBA website also offers articles and publications on air quality including

its annual report on air quality based on preliminary data18. Information on health effects of pol-

lutants is also available19 in both German and English language.

15 http://europa.eu/rapid/press-release_MEMO-14-2130_EN.htm

16 http://europa.eu/rapid/press-release_IP-18-3450_EN.htm

17 https://www.umweltbundesamt.de/themen/luft

18 https://www.umweltbundesamt.de/sites/default/files/medien/421/publika-

tionen/180213_uba_hg_luftqualitaet_engl_bf.pdf

19 https://www.umweltbundesamt.de/themen/luft/wirkungen-von-luftschadstoffen/wirkungen-auf-die-ge-

sundheit#textpart-1

http://europa.eu/rapid/press-release_MEMO-14-2130_EN.htm

http://europa.eu/rapid/press-release_IP-18-3450_EN.htm

https://www.umweltbundesamt.de/themen/luft

https://www.umweltbundesamt.de/sites/default/files/medien/421/publikationen/180213_uba_hg_luftqualitaet_engl_bf.pdf




https://www.umweltbundesamt.de/themen/luft/wirkungen-von-luftschadstoffen/wirkungen-auf-die-gesundheit#textpart-1





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2.6 Use of EU funding to fund air quality improvements

There are six ERDF programmes related to air quality in Germany in the 2014-2020 period, total-

ling € 92.3 million, listed in 0. Four of the programmes are classified as air quality measures (€

37.0 million, 40 %) and two are in the integrated pollution prevention and control (IPPC) category

(€ 55.3 million, 60 %).

Interviewees20 inform that Berlin would have liked to use EU structural funds (ERDF), e.g. for

buses, but the current funding criteria were too restrictive and were coupled with the social status

of city districts. The received material needs to be used within the government area receiving the

funds, which would forbid bus routes crossing district boundaries. Berlin was divided into rich

and poor areas, with only the poor areas being eligible for funding. For bus companies also

working outside of these poor urban areas, this funding could not be used. Interviewees high-

lighted similar barriers for construction machines and marine vessels. The current ERDF funding

criteria were thus not flexible enough to be used for air quality, because Berlin's busses, marine

vessels and mobile machinery are operating in the whole city.

0 also provides a list of 30 LIFE projects based in Germany since 1993. Four of these projects

have been financed since 2008, including a legal action programme run by Deutsche Umwelthilfe

(DUH), a clean heat project, a clean air project, and an experimental industrial air pollution control

project.

20 See Appendix B for list of interviews.


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March 2019 22

3 FINDINGS

This chapter presents detailed findings regarding the experience and lessons learnt in the imple-

mentation of the AAQDs in Germany and the Berlin agglomeration. This chapter focuses on the

challenges and successes encountered in the implementation of the Directives. Additionally, the

relevance of the AAQDs, and their air quality standards, has been explored. Finally, the chapter

identifies the factors underlying compliance with and effectiveness of the AAQDs and provides an

overview of the costs and benefits associated with the implementation of the Directives.


in the context of the case study. These were, as relevant, supplemented by additional desk re-



Air quality continues to be a source of concern to citizens in the Germany. The 2016 Environmental

Implementation Review21 indicated that air quality in Germany continues to be a cause for con-

cern. EEA estimates that in 2015 about 62,300 premature deaths were attributable to PM2.5 con-

centrations, 13,100 to NO₂ concentrations and 3,000 to ozone concentration (Table 2-2). For 2013

to 2015, the numbers of premature deaths due to NO₂ and ozone do not appear to be declining.

Furthermore, findings of 2017 Special Eurobarometer confirm that air quality is a concern to

German citizens.

The consultation carried out in the context of the case study (for an overview of the interviews

carried out see Appendix B) showed that the objectives of the AAQDs are relevant in relation to

the citizens' needs. In the following, more detailed stakeholder views on relevance and air quality

plans are listed as expressed during interviews:

The stakeholder interviews identified the following opinions on relevance of the AAQD in Germany:

Pollutants: SO₂ levels have improved and are below the LAT, so there is no longer a requirement

for measurement of SO₂. CO is also not significant.

Other pollutants: EC and UFP would be useful, but there is not enough data available to set a

standard. In particular with regard to UFP monitoring data - including cohort studies on health

impacts - is needed to enable health impact assessments before a limit value could be established.

Standards: Binding EU air quality standards are important. There would have been much less

ambition to improve air quality in Germany without them.

The health impact from PM10 is 4-5 times higher than for NO₂, but only Stuttgart has exceedances

for PM10, while nearly half of roadside monitoring stations in Germany have exceedances for NO₂.

Years of lost life (YLL) for PM2.5 is five times higher than for NO₂, and YLL for ozone is only 25 %

of the YLL for NO₂. Yet there are no exceedances for PM2.5.

This suggests that the current focus on NO₂ in air quality plans is disproportionate with the impact,

compared to the impact of PM2.5 and to a lesser extent with PM10. That is because the NO₂ annual

limit value is equal to the WHO guideline, while the PM2.5 annual limit value is 2.5 times higher

than the WHO guideline.

21 http://ec.europa.eu/environment/eir/pdf/report_de_en.pdf



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March 2019 23

The use of high-percentile short-term limit values makes them unstable from year to year. For

example, the PM10 24-hour limit value allowing 35 days of exceedance (90.41,4-percentile). It is

not helpful if the zone flips in and out of compliance from year to year.

When there are both short-term (hourly, daily) and long-term (annual) LV for a pollutant (PM10,

NO₂), one of them will be the driver – the one that is most difficult to comply with. It is preferred

to have the long-term LV as the driver, because long-term measures are easier to include in an

AQ plan.

The O3 target value is a 3-year average, which helps to even out the wide year to year variations.

However, target values, such as for O3, are not effective, because they do not put pressure on

policy makers. There is no threat of infringement, and court challenges are difficult.

The AEI percentage reduction target for PM2.5 is in the right direction, like in NEC – a relative

rather than absolute reduction. Another advantage of the AEI is its definition based on spatially-

averaged urban background measurements representative for the exposure of the majority of the

urban population, which could be a useful supplement to the current hot-spot-driven approach,

but should be by zone rather than national.

Modelling: Modelling can give a complete spatial distribution of concentrations, which should be

used for compliance assessment much stronger that currently required.

AQ plans: Stakeholders find that the requirement to prepare air quality plans is important.

Reference methods: The NO₂ reference method does not work for low background concentrations

– it needs to be adopted to new technology.

There is a need for real-time measurements of PM10 and PM2.5, but the reference methods for PM

are based on gravimetric sampling which requires laboratory work. Many city networks use non-

reference methods which provide hourly data. If reference method and equivalent method instru-

ments are operated at the same station, the results of the reference method are used for compli-

ance checking. Nonetheless, data for both methods are often submitted to EEA or the Commission

for compliance checking, if the equivalent methods have undergone a proof of equivalence ac-

cording to the AAQD requirements.

Zones: The use of air quality zones makes it easier to structure AQ plans, but it took time to

develop common understanding of zones. The background for use of zones is lacking. The first

zones were defined in 2003, and the zones were changed every year after that, depending on the

exceedances measured, making it difficult for people to know which zone was for which pollutant.

Both authority and NGO stakeholders expressed that having one exceedance make the whole

zone in exceedance is too simplistic. Maps showing zones as either in or not in compliance (i.e.

“red” zones) does not reflect the actual size of the problem. The AAQD’s “hotspot” approach does

not reflect exposure, because most people do not spend as much time in hotspots compared to

background areas. This suggests that the obligation to prioritise measures to comply with limit

values at hotspots takes focus and resources away from reduction of the background levels where

exposure – and resulting health impact – is greatest. The AAQD does not distinguish levels of

exposure for exceedances nor for the measures needed to comply with the limit values.

Public access to justice: An NGO felt that the AAQD does not fully implement the Aarhus Conven-

tion provisions, in particular regarding the public’s right to judicial or administrative recourse

when provisions of the AAQD are not fulfilled by the competent authorities. National courts and


(2008/50/EC, 2004/107/EC)

March 2019 24

the ECJ have now established these rights, but a more explicit granting of public rights in the

AAQD may have been more efficient means to achieve the present state of enforcement.


The present section highlights the key implementation successes of the AAQ Directives in Ger-

many. The main implementation successes include:

• Monitoring systems are well developed

• Data processing and transmission from State to UBA and from UBA to EEA is working well.

• Quality systems are well established throughout the networks and harmonized by the Na-

tional Reference Laboratory (NRL) linked to AQUILA (European network of NRL).

Air quality management in Berlin is administered by the same department as traffic planning,

noise management and climate policy. This greatly facilitates the incorporation of air quality con-

siderations into traffic planning and management. Successful pilot projects have helped to clarify

the relationship between traffic measures and the resulting air quality impacts and improvements.

This close linkage has contributed to the incorporation of air quality considerations in the recently

passed mobility law and the sustainable urban mobility plan (SUMP) in Berlin. It is also an im-

portant factor to facilitate the development of the revised air quality plan for Berlin, due to be

released by March 2019 for public hearing.


3.3.1 Air quality plans and measures

Responsibility for development of air quality plans lies with the States, and the federal government

may not interfere in the States’ implementation and enforcement of air quality obligations. How-

ever, the federal government retains the authority to make legislation governing air quality and

air pollution control regulations often following EU legislation, e.g. product standards or BAT.

Interviewees inform that this results in situations where cities do not have the legal authority to

sufficiently regulate the emission sources contributing to exceedances.

For example, the federal government defines the use vehicle stickers for LEZ (35. BImSchV), but

has not authorized the next logical level of vehicle restriction - a “blue sticker” requiring compli-

ance with EURO 6 for diesel vehicles and offering exemptions for older Diesel vehicles retrofitted

with an efficient type-approved SCR-system. Unable to progress to a next logical step in LEZ

restrictions, court decisions are now requiring cities to adopt bans of diesel passenger cars, with-

out being able to identify easily non-compliant vehicles. Interviewees thus refer to that this makes

enforcement rather difficult and ineffective.

In the following, more detailed stakeholder views on implementation challenges are listed as ex-

pressed during interviews:

Sector authorities, both at state and federal level, are not always cooperative (agriculture, traffic,

energy) and not aware of the binding air quality limit values that the state and city environmental

authorities are obligated to comply with. Air quality is not their responsibility, and there is no

obligation to integrate air quality in their planning at the national level. Interviewees thus express

that in case of budget constraints, air quality is not a priority. To make the plans work, other

sectors thus need to be convinced to put the necessary measures and legislation in place. In

Berlin, air quality is incorporated in the list of objectives of the SUMP, which enhances cross-

sectoral cooperation.


(2008/50/EC, 2004/107/EC)

March 2019 25

There is no means to obligate individual enterprises to be responsible for a share of the reductions

needed to comply with LV – to invest in additional emission reduction measures for further miti-

gations, beyond what is required by IED and BAT conclusions in their permits.

Some interviewees also pointed to that even though local governments can influence local mobil-

ity, they cannot influence the EURO emission standards of the vehicles. The Federal Government

has not promoted tighter vehicle emission standards and until very recently failed to come forward

with the regulations to allow hardware-retrofit of Diesel vehicles with NOx-catalysts (SCR). There

is a clear perception that the Federal Government did not see the difficulties cities were encoun-

tering.

When infringements arise, the States meet with the Federal Government but this was felt a being

too late in the process.

3.3.2 Legal status of air quality plans

Article 23 of Directive 2008/50/EC provides that in zones and agglomerations where the levels of

pollutants in ambient air exceed any limit value or target value (plus any relevant margin of

tolerance) Member States "shall ensure that air quality plans are established for those zones and

agglomerations in order to achieve the related limit value or target value specified in Annexes XI

and XIV". The provision does not specify the legal status of the air quality plans and nor does it

address the issue of access to legal recourse against potentially insufficient air quality plans.

3.3.3 Tackling regional sources

The new NEC Directive introduces an obligation to report on the progress of implementation of

measures [NEC Annex III, Part I, 1(iii)], which will ensure that information is available and up-

dated on the status of measures. The AAQD does not have such an obligation to report on the

progress of implementation of AQ plans. The EOI Decision only requires Member States to provide

a reference to where the public can have access to regularly updated information about AQ plans

and on the implementation of the AQ plans (2011/850/EC Article 13 1(b)), but no requirement

on the content of the updated information, or how often it shall be updated. The lack of obligatory

progress reporting can make it difficult for citizens to monitor the progress of AQ plans.

There is no means in Germany for local authorities to require the Federal Government to take

action on pollution sources that are outside the local jurisdiction, such as when the regional back-

ground is a large part of the pollutant levels where exceedances occur (PM10). The Federal Gov-

ernment is not obligated to reduce background concentrations beyond what is obtained by the

NEC commitments.

3.3.4 Agriculture and NH₃

Agriculture, responsible for 95 % of the German NH3 emissions, is the last sector to get any

requirements for emission reductions. There is considerable room for improvement in terms of

reduction of national NH3 emissions. One interviewee points to that it is very difficult to make

changes in agriculture, because the agriculture lobby is even bigger than the car industry lobby.

One example mentioned by an NGO was that in Lower Saxony/Hannover, reduction of regional

NH₃ emissions from agriculture could have been a component of the AQ plans to address former

PM exceedances, but this cannot be dealt with on a local level. The State environment ministers

meet twice a year with the Federal environment minister. While this issue has been discussed and

the need to reduce NH₃ has been raised, progress has been blocked by the agriculture ministries

on federal and State level. NGOs indicate that CAP reform has not focused on NH₃ reductions.

This suggests that the significance of NH₃ for particulate matter concentrations in ambient air is


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not widely appreciated. One interviewee mentioned that NGOs and the public have not really

taken an interest in NH₃. NGOs seem rather to be interested in diesel cars because it is easier to

get the public interested in the impact of diesel cars. There is no real NGO campaign on nitrates

in agriculture – only in water.

3.3.5 Use of modelling and indicative measurements

There are huge differences between the States on the use of modelling. Early AQ plans used

extrapolation of emission reductions and air quality levels for their projection, which is no longer

sufficient considering current modelling capabilities. For projecting vehicle emissions, cities used

the only available emission factors (Handbook of Emission Factors, HBEFa) which some years

back were outdated in terms of reflecting real-world driving emissions, resulting in overestimation

of the emission reductions due to changes in the vehicle park. Timely updates of the HBEFa based

on the latest knowledge on real driving emissions has made the picture more accurate over the

last three years.

The requirement to report the impact of AQ plans on exposure of the population implies the use

of a model, but interviewees point to that some States have used simplistic methods based only

on air quality monitoring stations, to estimate the population exposed to level above the limit

values.

In Germany, passive sampler data is accepted by UBA only when equivalence to the reference

method has been proven and regular calibration takes place also. QA/QC programmes carried out

by the German Länder networks, an inter-laboratory comparison carried out by the NRL LANUV

as well as equivalence reports showed that passive sampler data could meet the required data

quality objectives of the AAQD. UBA maintains that indicative measurements, i.e. data not cov-

ering the necessary time required for fixed measurements, are to be kept separate from official

data used for compliance testing. At the same time, short measurement campaigns carried out

by some NGOs cannot be used for compliance checking. Siting criteria is another issue that has

to be addressed in this context, and DUH has been able to present passive sampler data for use

in court cases. The NGOs interviewed find the passive sampler data gives good results.

3.3.6 Information to the public

The UBA and Berlin air quality information systems are generally considered to be good by stake-

holders, but the interviewed stakeholders indicate that there is considerable variation in quality

and ease of accessibility of information services among the States. There is a lack of harmonised

requirements and best practices for information services and data access which could help to

improve the quality of public air quality information services.

In the following, more detailed stakeholder views on available information to the public are listed

as expressed during interviews:

It is possible to download air quality data, but each State has its own system for this. The UBA

site is found by interviewees to be good, but download to Excel format appears to be the only

choice. Berlin, for example, offers access to and download of all its monitoring and modelling data

via the Environment Atlas22.

22 https://www.stadtentwicklung.berlin.de/umwelt/umweltatlas/edinh_03.htm

https://www.stadtentwicklung.berlin.de/umwelt/umweltatlas/edinh_03.htm


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The States cooperate through round tables, where they get together to agree on procedures. One

NGO indicates that the technology for providing information services and data is in many cases

not up to date with current information technology.

Many States have indicative measurements (i.e. for periods not representing a full calendar year),

e.g. from passive samplers, however it is reported during interviews that this data is often hard

to find, since for example for NO2, this data is only used for compliance checking with the yearly

limit value and therefore often only published on a yearly basis, as UBA is downplaying of the

value of indicative measurements in not accepting them for compliance checking.

3.3.7 Challenges in ensuring public awareness

Some stakeholders point to that it is difficult to communicate the concept of cost-effectiveness

regarding air quality improvement measures. The NGOs interviewed concur that quantification of

health impacts, such as years of lost life would be useful, and the use of monetary value of these

impacts would be even better, for communication of cost efficiency of air quality measures. All

the interviewed stakeholders agreed that the presentation of health impact based on premature

deaths and years of lost life is problematic in Germany. There is no common language for this

type of attribution. For example, a recent UBA study of the health impact of NO₂, expressed in

terms of YLL, was severely criticised, and the results were discounted. There is likewise no tradi-

tion for CBA based on monetary valuation of premature deaths or YLL. Interviewees find that the

lack of quantification of costs and benefits prevents this valuable tool from being used in plan and

policy development, and communication of cost efficiency of proposed and implemented

measures.

3.4 Factors underlying compliance with and effectiveness of the AAQ

Directives


with and effectiveness of the AAQ Directives in Germany, and Berlin. The factors have been iden-

tified through stakeholder consultation conducted in the context of the case study. The views have

been correlated with information gathered through desk research.


• Standard methods and criteria for measurements

• Harmonized quality standards in the networks (due to inter-laboratory comparisons of NRL,

role of AQUILA)


• Lack of coordination between local, regional and federal authorities on measures due to sep-

aration of legal authority.

• It is not possible for an AQ plan to impose additional pollution reduction requirements on

individual sources (power plants, industries) beyond the requirements in their environmental

permits (based on IED and BAT conclusions)

• Delegation of full responsibility for air quality planning to States, while authority to regulate

key regional emission sources remains at the federal or even European level.

• Lack of motivation among source sector ministries (transport, energy, industry) to incorpo-

rate air quality needs in their policies and measures.


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There are currently no economic analyses of the costs of implementation of the AAQ Directives in

Germany. UBA and Berlin indicated that there should be some data on costs of monitoring, but

none was received in the course of this study.


There is currently no national analysis of the costs of non-implementation of the AAQ Directives.

The case study identified a number of benefits stemming from the implementation of the AAQ

Directives. These benefits cannot be quantified, as there are currently no quantitative assess-

ments of benefits the AAQ Directives in Germany, but can be described in qualitative terms.

A number of provisions of the AAQ Directives have been identified as key, in delivering air quality

improvements. These include, more generally, the establishment of a harmonised approach

throughout the EU towards monitoring, assessment and management of air quality. The following

provisions of the AAQ Directive were cited as those most important: 1) the setting of legally

binding air quality standards; 2) harmonised standards and methods for monitoring and assess-

ment, including AQ modelling 3) the obligation to prepare air quality plans with measures that

remove exceedances as quickly as possible, and 4) the obligation to provide information on air

quality to the public.

Maintaining/improving air quality, positive impacts on the eco-system and improvements to citi-

zens' health

Legal challenges to cities’ air quality plans have resulted in court rulings so that cities must revise

the plans and include effective measures to reduce exceedances, and even to impose specific

measures avoided by cities, such as diesel bans, to comply with limit values as quickly as possible.

The threat of court imposed diesel bans is a major impetus for cities to rapidly revise air quality

plans with comprehensive green mobility and residential heating measures that will be effective

to achieve the limit values as quickly as possible. For example, Berlin has adopted a new mobility

act and is currently preparing a comprehensive air quality plan revision, with the express intention

to avoid a diesel ban as much as possible. The attainment of the NO₂ limit value, which has long

been elusive in many cities, will significantly lower the burden on health in heavy-traffic central

city areas.

Establishment of common methods and criteria for monitoring

Common methods have enabled Germany to establish comparable air quality monitoring in the

16 States. Inter-laboratory comparisons at the NRL and the work of AQUILA have helped to har-

monize quality standards. Without the common standards, each State would have their own style

of siting monitoring stations, and different and incompatible measurement methods.

Increased visibility of the issue and interest in solving the problem of air pollution

Interviewees have also noted that the court cases in Germany have received a lot of media at-

tention, and public interest. The Volkswagen emissions scandal, widely known as ‘Dieselgate’

(illegal manipulation of emission control devices by car manufacturers) has also focused attention

on the primary cause of NO₂ exceedances at roadside monitoring stations, and interviewees state

that it has become easier for the public to understand the problem with diesel vehicles. Remarks


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are also made that on the other hand, there is little public awareness, interest and understanding

in the contribution of agricultural NH₃ to PM2.5 levels, so there is little public or NGO pressure to

address the NH₃ emission issue in agricultural policy making. This is even more the case as current

not very ambitious PM2.5 standards are not breached.

Clear effort from the industry to reduce emissions

Industry is meeting the emission requirements in the IED and BAT conclusions, in their environ-

mental permits.

Legal actions

Landmark court decisions in Germany, both in German courts and ECJ, establish precedence for

citizens’ legal right to court actions in other Member States, and precedence for judges decisions

in other Member States.


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4 CONCLUSIONS

Chapter 4 presents the summary of the main findings of the case study regarding the main im-

plementation challenges, the potential for improving the implementation of the Directives in Ger-

many, and the aspects of the AAQD that may have contributed to the present situation in Ger-

many. Finally, a summary of the evaluation of the AAQD is presented.


the Directives

The case study identified the following challenges in the implementation of the AAQ Directives.

Responsibility for air quality plans has been given to the 16 States in Germany. Cities have had

difficulty to implement effective AQ plans because they do not have legal authority over many of

the sources – for example power plants, industry, inland shipping and ports, which require federal

or EU action to regulate. Several of the NGO and authority stakeholders pointed out that the

federal sectoral authorities do not have an obligation or interest to incorporate air quality issues

into their planning and policy implementation. There is not a mechanism or legal authority to

require cooperation of the source sectors with local AQ plans. In addition, the vehicle and non-

road machinery emission standards are established at the EU level, which local authorities have

no influence over.

There is no mechanism to require individual sources (power plants, industries) to adopt additional

air pollution control measures beyond the requirements of their permits (IED, BAT conclusions).

The federal environment ministry has legislative authority over the LEZ system in Germany, and

has not extended the LEZ system with a “blue sticker” that would enable cities to require only

EURO 6 or diesel vehicles with low real driving emissions in urban areas where the NO₂ limit value

is persistently exceeded. A regional authority pointed out that the Federal Transport Ministry has

until recently refused to come forward with technical regulations to allow retrofit of in-use Diesel

vehicles to curb NOx-emissions. The result is that courts are now ordering bans of diesel vehicles

including Euro 5 in LEZ areas, which is effective in reducing NO₂ levels as quickly as possible, but

not necessarily cost-effective.

Berlin is found to have made frequent use of environmental procurement criteria to impose strict

emission requirements on construction machines used for city projects and suppliers of goods and

services to the city, that it otherwise does not have authority to impose.




4.2.1 Relevance

Air quality objectives

The findings of the case study indicate that the objectives of AAQDs are relevant to the needs of

citizens in Germany as air quality continues to pose a concern to the health of German citizens

and the environment.


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Pollutants

SO₂ concentrations in Germany are below the LAT, which removes the obligation to measure them

at fixed sampling points. However, SO₂ levels are still above the WHO guideline. CO is below the

WHO guideline and thus not a problem.23 The other pollutants remain relevant.

There was monitoring of BC/OC/EC and UFP (particle number) before the AAQD, but measuring

of smaller particles was partly stopped in order to focus on PM10. Berlin has continued to measure

UFP and BC. UFP/BC directly reflects local combustion emissions, especially traffic and wood com-

bustion, making it a very responsive indicator for local measures in AQ plans.

Monitoring and assessment methods

Legally binding LV and the obligation to prepare AQ plans are essential for effective air quality

management. Without the LV and planning obligation, the court cases would not be possible.

Both national and regional authorities noted that the definition of compliance testing in the AAQD

is not clear regarding the use of equivalent methods, indicative measurements and modelling for

legally-binding compliance testing. The authorities reported that some authorities interpret the

AAQD to mean that only measurements based on reference methods and meeting all data quality

objectives and siting criteria may be used for formal compliance testing. As a consequence, this

results in useful measurements and modelling results not being contributed to EEA databases,

and thus not available for public information and research. Although requested, there is no obli-

gation to include these measurements and modelling results in submissions to the EC and EEA.

This leaves it to local authority discretion whether to report supplementary data that might indi-

cate additional areas of exceedance. In Germany, the data reported to EEA is limited to the data

provided by the networks of the Länder and UBA. Data from other sources such as measurement

campaigns are not included.

A regional authority expressed that the reference method for NO₂ is not sufficiently sensitive for

low regional background concentrations and needs to be updated with technological advances.

The reference methods for PM10 and PM2.5 do not permit real-time measurements, which are

needed for information to the public during smog episodes. Equivalent methods are used to pro-

vide hourly data.

For equivalent methods, a guide (guide to the demonstration of equivalence of ambient air mon-

itoring methods (GDE)) was issued by an EC working group and revised in 2010. For PM10 and

PM2.5, a CEN standard (DIN EN 16450) exists.

A regional authority expressed that the requirements for demonstration of equivalence to the

reference methods are found to be very complex, and difficult to comply with, causing consider-

able administrative and technical burden for the introduction of new methods. At the same time,

it assures that e.g. air quality plans are based on reliable data that is quality assured and traceable

to European standards.

4.2.2 Effectiveness

Most of the stakeholders noted that the problem is that politicians refuse to act unless there is a

binding obligation in the legislation, backed by potential enforcement action.

23 As referred to also in table 2-3 (Lutz, 2018)


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Monitoring and assessment of air quality

Monitoring is in general found to function well in Germany. Interviewees report that at the time

where zones were first established, the background for using zones was unclear, and frequent

changes in zones were made in the years that followed. The zone definitions are now stable. 10

years ago, it was agreed not to use modelling for assessment of compliance, which has then

indirectly hampered the development and use of modelling for planning and exposure assessment

in Germany. In addition to the official data of the State networks, indicative measurements are

carried out by NGO’s and others with different systems and at different quality levels. NGOs in-

terviewed find these data very useful, while state and federal environment authorities interviewed

are concerned that indicative measurements generally do not meet the quality, calibration and

time coverage requirements needed to be used for compliance testing.

The methodology for assessment of population exposed to pollutant levels exceeding the limit

values is reported to vary considerably from State to State, with the simplest methods potentially

leading to significant underestimation of exposed population. There is no binding guidance on the

approach to use.

Monitoring in Berlin functions well in general and is supplemented by both indicative measure-

ments and modelling. While indicative measurements have not yet been part of the official com-

pliance monitoring to the EU, these data and model results are being used as a driver for measures

to meet the NO2 limit value and to monitor the impact of measures. Having air quality, noise and

traffic management in the same department has facilitated coordination of the measurements and

assessment in these areas, and for planning of measures.

Compliance with standards

Compliance with the NO₂ annual limit value is a wide-spread persistent problem at urban traffic

locations in Germany, including Berlin. The primary reason is the real driving emission of NOX and

NO₂ is much higher than the EURO standards specify.

Exceedance of the 24-hour PM10 limit value has been a serious problem, but few PM10 exceedances

remain. The high percentile definition of the 24-hour PM10 limit value (50 µg/m³ not to be ex-

ceeded more than 35 days) is sensitive to year to year variations in meteorology and, in the past,

has resulted in monitoring stations flipping in and out of compliance from year to year.

There are no exceedances of the EU annual limit value for PM2.5. However, smog episodes in cities

like Stuttgart indicate that a short-term limit value and alert threshold is needed for PM2.5. Without

a standardised alert threshold for PM2.5, each city defines its own threshold. Interviewees have

reported that this is confusing for residents and visitors.

Public information

Public information systems for air quality are working well but could be modernised in some

States. There is a lack of harmonised standards and requirements for information services that

would help to raise the quality in States where the AQ information systems are less sophisticated.

NGOs have pointed out that the AAQD does not fully implement the Aarhus Convention.

Measures and air quality plans

There are 158 cities with air quality plans in Germany. Compliance with the 24-hour PM10 limit

value has been achieved except for one zone, while exceedances of the NO₂ annual limit value


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remain, due primarily to the increase of the diesel share of passenger cars, and real-world driving

emissions that substantially exceed the EURO emission limit specifications.

Initial AQ plans did not have effective measures, or the measures were not implemented. Stake-

holders reported a number of reasons for this, e.g. due to lack of ambition, lack of legal authority,

lack of influence in other sectors, lack of appropriate modelling. There was a lack of analysis of

source apportionment to establish a clear connection between sources and ambient concentra-

tions, although Berlin conducted two source apportionment studies on PM10 (2002) and PM2.5

(2007), which laid the ground for the LEZ scheme enforced 2008. Also, according to stakeholders,

the first plans in some States did not assess the effect of existing measures. As a consequence,

the use of extrapolation of air quality trends based on expected emission reductions was unreal-

istic and overestimated the benefit of proposed measures.

Low emission zones (LEZ) were first implemented to control PM10. LEZ have been an important

measure to reduce PM10-pollution, especially since they accelerated the renewal of the vehicle

fleet. Their impact on UFP- and BC-pollution was even higher than their impact on PM10. The Berlin

LEZ resulted in 7-10% reduction of PM10, equivalent to about 10 excess days of the 24-hour 50

µg/m³ threshold. EC/OC dropped by 50%, largely because about a quarter of the Diesel fleet had

diesel particulate filters (DPF) retrofitted. Existing LEZ without a blue sticker are not an appropri-

ate measure to reduce NO2.

The findings of the case study indicate effectiveness of the AAQDs in maintaining air quality where

it is good and improving it in other cases.

4.2.3 Efficiency

No economic analyses of the costs of implementation of the AAQ Directives in Germany were

obtained from the desk research or interviews.

4.2.4 Coherence

Interviewees pointed to that climate plans do not address synergies with AQ and AQ plans do not

address the synergies with climate. This results in the costs of these policies being over-estimated.

When synergies are included, the implementation costs are lower. As example, interviewees men-

tioned amongst others transport measures to improve air quality, such as improvements to bicycle

infrastructure, urban rail systems, parking fees, obviously also have climate benefits.

Cities are also required to prepare Sustainable Urban Mobility Plans (SUMP), which deal exten-

sively with traffic and therefore have substantial synergies with both air quality and climate. How-

ever, the general point was also made by a stakeholder that having to prepare separate AQ plans,

climate plans and SUMPs, with so much overlap, is an unnecessary administrative burden. These

plans should be fully integrated to be more efficient and also to produce better results in all three

sectors – air quality, climate and mobility. Berlin has an advantage in this regard – seldom seen

in cities – that these three sectors are in the same administrative unit, which has facilitated the

inclusion of AQ objectives in the SUMP and in return, the AQ plan of Berlin integrated several

mobility-related measures stipulated by the SUMP.


The AAQD reference methods, data quality objectives and siting criteria help to harmonize AQ

monitoring.

Without the AAQD, it is the general assessment among the interviewed stakeholders that:


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1 Germany would not have had similar types of limit values. TA Luft would not go so far, and

it only regulates industrial emissions, but not products, traffic, etc.;

2 The local level would not have been involved to make AQ plans. There would not be the local

understanding of where AQ problems come from, and what can be done;

3 Germany would not have had monitoring networks and comparable data, and would not have

all the data in one place to create harmonised maps of AQ for Germany, for reports and

public information;

4 The level of ambition for air quality would be lower. If it were up to the German government,

objectives on AQ might have been weakened in the past years.

The AAQD created a level playing field for air quality management which has been important for

EU negotiations on air quality objectives.

Error! Reference source not found. summarises the air quality standards in place in Germany

prior to the 2004 and 2008 AAQD, and the changes introduced in 2004 or 2008 by the AAQD.

Table 4-1 Changes introduced in national legislation as a result of the AAQD

Pollutant Situation prior to AAQD Changes introduced

(2004 or 2008) by

AAQDs to the legislation

NO₂ NO₂ limits transposed from 1999/30/EC No change

PM10 PM10 limits transposed from 1999/30/EC No change

PM2.5 PM2.5 monitoring obligation transposed

from 1999/30/EC

PM2.5 target, limit value,

AEI and AEI reduction

target transposed from

2008/50/EC.

O3 O3 target and long-term objectives trans-

posed from 2002/3/EC

No change

SO₂ PM10 limits transposed from 1999/30/EC No change

Pb CO limits transposed from 1999/30/EC No change

CO CO limits transposed from 2000/69/EC No change

C6H6 C6H6 limit transposed from 2000/69/EC No change

As, Cd, Ni No information provided As, Cd, Ni targets trans-

posed from

2004/107/EC

PAH No information provided PAH limit transposed

from 2004/107/EC

Access to justice


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Landmark court decisions in Germany, both in German courts and ECJ, establish precedence for

citizens’ legal right to court actions in other Member States, and precedence for judges’ decisions

in other Member States. The legally binding air quality standards and obligation to prepare AQ

plans to address exceedances as quickly as possible have been essential to enable these legal

actions.

The legal right to court action had been narrowly defined in Germany to apply only to citizens

directly affected by air quality exceedances – i.e. only those living on a polluted street. Court

decisions in Germany extended these legal rights to citizen groups and NGOs, with city-wide

coverage. This was a major breakthrough that has enabled NGOs to begin legal actions against

many cities in Germany. This creates legal precedence that is of benefit to NGOs in other member

states.

Access to information on air quality

All 16 German States and the German environment agency (UBA) have air quality information

systems which fulfil the basic requirements of the AAQD for public information on air quality. The

available information and user-friendliness varies considerably from State to State, according to

NGOs, and the Berlin air quality information system is viewed to be the best by the stakeholders

interviewed. Without the AAQD, it is unlikely that air quality data and information would be avail-

able to the extent it is today. The lack of specific requirements and best practices for information

services has contributed to the variable quality of the State air quality information services. NGOs

remark that air quality information services have not kept up with changes in information tech-

nology. For example, the facilities provided to download data providing only text or spreadsheet

export, but not more modern methods that would facilitate automatic retrieval by data analysis

systems and apps. There is no provision in the AAQD regarding adaptation of public information

services to changing technology as there is for measurement methods.


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(2008/50/EC, 2004/107/EC)

March 2019 37

European Commission (2017). SWD(2017) 38: The EU Environmental Implementation Review

Country Report- Germany. Brussels, 3.2.2017. http://ec.europa.eu/environment/eir/pdf/re-

port_de_en.pdf.

European Commission (2017). COM(2017) 63: Common Challenges and how to combine efforts

to deliver better results. Brussels, 3.2.2017. https://eur-lex.europa.eu/legal-con-

tent/EN/ALL/?uri=COM:2017:63:FIN.

EC. (2018). Air quality: Commission takes action to protect citizens from air pollution - Press re-

lease. Retrieved 15 November 2018, from http://europa.eu/rapid/press-release_IP-18-

3450_EN.htm

European Environmental Agency. (2014). Air pollution fact sheet 2014 - Germany (Air pollution

fact sheet). Copenhagen: European Environment Agency (EEA). https://www.eea.eu-

ropa.eu/themes/air/air-pollution-country-fact-sheets-2014/germany-air-pollutant-emissions-

country-factsheet/view

EEA. (2016). Air Quality in Europe - 2016 Report. European Environment Agency (EEA). Re-

trieved from http://www.eea.europa.eu/publications/air-quality-in-europe-2016/at_down-

load/file

European Environmental Agency. (2017). Air Quality in Europe – 2017 Report.

https://www.eea.europa.eu/publications/air-quality-in-europe-2017 [1]

European Environmental Agency. (2018). Air Quality in Europe – 2018 Report:

https://www.eea.europa.eu/publications/air-quality-in-europe-2018 [450]

European Environmental Agency. (2018). Germany – air pollution country fact sheet 2018.

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

Lutz, M. (2018). Caso 3. La experiencia de Berlín. Éxitos y oportunidades de veinte años de ges-

tión de la calidad del aire [Case Study 3. The experience of Berlin. Successes and Challenges of

Twenty Years Air Quality Management]. In X. Querol (Ed.), La calidad del aire en las ciudades.

Un reto mundial [Air quality in cities. A global challenge] (pp. 201–226). Madrid, Spain: Funda-

ción gas Natural fenosa. Retrieved from http://www.fundacionnaturgy.org/wp-content/up-

loads/2018/06/calidad-del-aire-reto-mundial.pdf

Mwaniki, G., & Ehsani, V. (2015). Germany Air Quality Policies (Working Paper) (p. 4). Re-

trieved from https://wedocs.unep.org/bitstream/handle/20.500.11822/17201/Germany.pdf?se-

quence=1&isAllowed=y

Schneider, A., Cyrys, J., Breitner, S., Kraus, U., Peters, A., Diegmann, V., & Neunhäuserer, L.

(2018). Quantifizierung von umweltbedingten Krankheitslasten aufgrund der Stickstoffdioxid-

Exposition in Deutschland. Abschlussbericht [Quantification of environmental burden of disease

due to nitrogen dioxide exposure in Germany. Final report, revised version] (Umwelt & Gesund-

heit No. 01/2018) (p. 170). Dessau-Roßlau, Germany: Helmholtz Zentrum München, Neuher-

berg; IVU Umwelt GmbH, Freiburg; for German Environment Agency (UBA). Retrieved from

https://www.umweltbundesamt.de/sites/default/files/medien/421/publikationen/abschlussber-

icht_no2_krankheitslast_final_2018_03_05.pdf





https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=COM:2017:63:FIN







https://www.eea.europa.eu/themes/air/air-pollution-country-fact-sheets-2014/germany-air-pollutant-emissions-country-factsheet/view





http://www.eea.europa.eu/publications/air-quality-in-europe-2016/at_download/file






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

http://www.fundacionnaturgy.org/wp-content/uploads/2018/06/calidad-del-aire-reto-mundial.pdf




https://wedocs.unep.org/bitstream/handle/20.500.11822/17201/Germany.pdf?sequence=1&isAllowed=y









(2008/50/EC, 2004/107/EC)

March 2019 38

SenUVK, 2018. Modellrechnungen für den Berliner Luftreinhalteplan 2018-2025 [Model calculati-

ons underpinning the air quality plan for Berlin 2018-2025]. IVU Umwelt GmbH for Senate De-

partment for Environment, Transport and Climate protection (SenUVK), 2017, in preparation.

[as cited by Lutz, 2018]

van Pinxteren, D., Mothes, F., Spindler, G., Fomba, K. W., & Herrmann, H. (2017). Auswertung

der gravimetrischen PM10- Messungen in Sachsen, Brandenburg, Mecklenburg-Vorpommern

und Berlin zur Identifikation des Anteils verschiedener Quellen an der Feinstaubbelastung an-

hand der Inhaltsstoffe und anhand von Rezeptormodellierungen (PM-OST) [Evaluation of gra-

vimetric PM10 measurements in Saxony, Brandenburg, Mecklenburg-Vorpommerania and Berlin

to identify the share of different sources of the PM10 pollution based on the composition and on

receptor modelling]. Abschlussbericht 30.11.2017 (p. 153). Leipzig: Leibniz-Institut für Tropo-

sphärenforschung (TROPOS) Abteilung Chemie der Atmosphäre (ACD), for Senatsverwaltung

für Stadtentwicklung und Umwelt. Retrieved from https://www.berlin.de/senuvk/um-

welt/luftqualitaet/de/luftreinhalteplan_projekte/download/PM-OST%20Abschlussbericht.pdf

https://www.berlin.de/senuvk/umwelt/luftqualitaet/de/luftreinhalteplan_projekte/download/PM-OST%20Abschlussbericht.pdf





(2008/50/EC, 2004/107/EC)

March 2019 39


Organisation Date of the interview

German Environment Agency (Umweltbundesamt, UBA) 3 Sep 2018, Berlin

Deutsche Umwelthilfe (DUH) 3 Sep 2018, Berlin

(jointly with BUND)

Bund für Umwelt und Naturschutz Deutschland e.V. (BUND)

/ Friends of the Earth – Germany (FoE-DE)

3 Sep 2018, Berlin

(jointly with DUH)

Berlin Senate Department for the Environment, Transport

and Climate Protection (SenUVK)

4 Sep 2018, Berlin

North Rhine-Westphalia - State Office for Nature, Environ-

ment and Consumer Protection (LANUV)

6 Sep 2018, telephone interview

NABU (Nature And Biodiversity Conservation Union) 25 Sep 2018, telephone interview


(2008/50/EC, 2004/107/EC)

March 2019 40


General questions




learn from?


tives?



exchange, etc.)?



Specific questions



RELEVANCE








gress?



try)?



zens' needs?







become redundant?


(2008/50/EC, 2004/107/EC)

March 2019 41


EFFECTIVENESS



















grammes


mation to public?







EFFICIENCY









Directives?










tives?




for Member States)?























COHERENCE










(2008/50/EC, 2004/107/EC)

March 2019 42






















ments)?



NEC Directive?











ADDED VALUE










quality objectives?


in monitoring?












quality management?




ties)?





(2008/50/EC, 2004/107/EC)

March 2019 43

APPENDIX D FEDERAL IMMISSION CONTROL REGULATIONS

(BIMSCHV)

The Federal Immission Control Regulations (BImSchV) are statutory ordinances of the Federal

Republic of Germany, which serve primarily to protect against harmful environmental effects

caused by air pollution and noise. They are issued by the Federal Environment Ministry on the

basis of the Federal Immission Control Act.

In addition to the fundamental requirements of the law, these regulations regulate the numerous

details that are essential for practical application, especially of a technical nature and administra-

tive execution.

Wikipedia list, google translate - https://de.wikipedia.org/wiki/Bundes-Immissionsschutzver-

ordnung.

For most recent version of the German legislation, see https://www.bmu.de/service/gesetze-

verordnungen/

Table 4-2 Federal Immission Control Regulations (BImSchV)

1. BImSchV Ordinance on small and medium-sized combustion plants

2. BImSchV Ordinance on the Emission Control of Volatile Halogenated Organic Compounds

3. BImSchV Ordinance on the sulfur content of certain liquid fuels, repealed with the entry into

force of 10. BImSchV

4. BImSchV Ordinance on Installations Subject to Licensing

5. BImSchV Ordinance on Immissionsschutz- und Störfallbeauftragte

6. BImSchV Ordinance on the Expertise and Reliability of Immission Control Officers, repealed

(Content integrated in §§ 7 to 10 of 5. BImSchV)

7. BImSchV Ordinance on the ejection limitation of wood dust

8. BImSchV Lawn Mower Noise Ordinance, repealed with the entry into force of 32. BImSchV

9. BImSchV Ordinance on the Approval Procedure

10. BImSchV Ordinance on the Quality and Quality of Fuels

11. BImSchV Regulation on Emission Declarations

12. BImSchV accident regulation

13. BImSchV Ordinance on Large Combustion, Gas Turbine and Internal Combustion Engines

14. BImSchV Ordinance on National Defense Installations

15. BImSchV Construction Machinery Noise Ordinance, repealed with the entry into force of the

32nd BImSchV

16. BImSchV Traffic Noise Ordinance

https://de.wikipedia.org/wiki/Bundes-Immissionsschutzverordnung




https://www.bmu.de/service/gesetze-verordnungen/

https://www.bmu.de/service/gesetze-verordnungen/

https://de.wikipedia.org/wiki/Verordnung_%C3%BCber_kleine_und_mittlere_Feuerungsanlagen

https://de.wikipedia.org/wiki/Verordnung_zur_Emissionsbegrenzung_von_leichtfl%C3%BCchtigen_halogenierten_organischen_Verbindungen

https://de.wikipedia.org/wiki/Verordnung_%C3%BCber_den_Schwefelgehalt_bestimmter_fl%C3%BCssiger_Kraft-_oder_Brennstoffe

https://de.wikipedia.org/wiki/Verordnung_%C3%BCber_genehmigungsbed%C3%BCrftige_Anlagen

https://de.wikipedia.org/wiki/Verordnung_%C3%BCber_Immissionsschutz-_und_St%C3%B6rfallbeauftragte

https://de.wikipedia.org/wiki/Verordnung_%C3%BCber_die_Fachkunde_und_Zuverl%C3%A4ssigkeit_der_Immissionsschutzbeauftragten

https://de.wikipedia.org/wiki/Verordnung_zur_Auswurfbegrenzung_von_Holzstaub

https://de.wikipedia.org/wiki/Verordnung_%C3%BCber_das_Genehmigungsverfahren

https://de.wikipedia.org/wiki/Verordnung_%C3%BCber_die_Beschaffenheit_und_die_Auszeichnung_der_Qualit%C3%A4ten_von_Kraft-_und_Brennstoffen

https://de.wikipedia.org/wiki/Emissionserkl%C3%A4rung

https://de.wikipedia.org/wiki/St%C3%B6rfall-Verordnung

https://de.wikipedia.org/wiki/Verordnung_%C3%BCber_Gro%C3%9Ffeuerungs-,_Gasturbinen-_und_Verbrennungsmotoranlagen

https://de.wikipedia.org/wiki/Liste_von_Baumaschinen_und_Bauger%C3%A4ten

https://de.wikipedia.org/wiki/Verkehrsl%C3%A4rmschutzverordnung


(2008/50/EC, 2004/107/EC)

March 2019 44

17. BImSchV Ordinance on Incineration and Co-Incineration of Waste ( Thermal Utilization )

18. BImSchV Sports Facilities Noise Ordinance

19. BImSchV Ordinance on Chlorine and Bromine Compounds as a fuel additive, repealed with

the entry into force of the 10th BImSchV

20. BImSchV Ordinance on the limitation of emissions of volatile organic compounds during

transfer and storage of petrol, fuel mixtures or petrol

21. BImSchV Ordinance on the limitation of hydrocarbon emissions in the refueling of motor

vehicles

22. BImSchV Ordinance on Immission Values for Air Pollutants, repealed with the entry into force

of 39. BImSchV (certain contents taken over there)

23. BImSchV Regulation on the determination of concentration values, repealed

24. BImSchV traffic routes - sound insulation regulation

25. BImSchV Ordinance on the limitation of emissions from the titanium dioxide industry

26. BImSchV Ordinance on Electromagnetic Fields

27. BImSchV Ordinance on cremation plants

28. BImSchV Regulation on emission limit values for internal combustion engines

29. BImSchV Schedule of charges for type testing of internal combustion engines

30. BImSchV Ordinance on Facilities for the Biological Treatment of Waste

31. BImSchV Ordinance on the limitation of emissions of volatile organic compounds when using

organic solvents in certain installations

32. BImSchV Equipment and Machine Noise Ordinance

33. BImSchV Ordinance to Reduce Summer Smog, Acidification and Nutrient Inputs, repealed

with the entry into force of 39. BImSchV (certain contents taken over there)

34. BImSchV Ordinance on Noise Mapping

35. BImSchV Ordinance on the Marking of Motor Vehicles with Low Pollution Contribution

36. BImSchV Ordinance on the Implementation of the Biofuel Quota Regulations

37. BImSchV Regulation on the allocation of electricity-based fuels and co-processed biogenic

oils to the greenhouse gas quota

38. BImSchV ew regulation with the regulation laying down further provisions on greenhouse

gas reduction for fuels; before: Quota allocation of certain biogenic oils (repealed)

39. BImSchV Ordinance on Air Quality Standards and Emission Ceilings

https://de.wikipedia.org/wiki/M%C3%BCllverbrennung

https://de.wikipedia.org/wiki/Sportanlagenl%C3%A4rmschutzverordnung

https://de.wikipedia.org/wiki/Chlor

https://de.wikipedia.org/wiki/Brom

https://de.wikipedia.org/wiki/Verordnung_zur_Begrenzung_der_Emissionen_fl%C3%BCchtiger_organischer_Verbindungen_beim_Umf%C3%BCllen_und_Lagern_von_Ottokraftstoffen,_Kraftstoffgemischen_oder_Rohbenzin

https://de.wikipedia.org/wiki/Verordnung_zur_Begrenzung_der_Emissionen_fl%C3%BCchtiger_organischer_Verbindungen_beim_Umf%C3%BCllen_und_Lagern_von_Ottokraftstoffen,_Kraftstoffgemischen_oder_Rohbenzin

https://de.wikipedia.org/wiki/Verordnung_zur_Begrenzung_der_Kohlenwasserstoffemissionen_bei_der_Betankung_von_Kraftfahrzeugen

https://de.wikipedia.org/wiki/Verordnung_zur_Begrenzung_der_Kohlenwasserstoffemissionen_bei_der_Betankung_von_Kraftfahrzeugen

https://de.wikipedia.org/wiki/Verordnung_%C3%BCber_Immissionswerte_f%C3%BCr_Schadstoffe_in_der_Luft

https://de.wikipedia.org/wiki/Verkehrsweg

https://de.wikipedia.org/wiki/Titan(IV)-oxid

https://de.wikipedia.org/wiki/Verordnung_%C3%BCber_elektromagnetische_Felder

https://de.wikipedia.org/wiki/Verordnung_%C3%BCber_Anlagen_zur_Feuerbestattung

https://de.wikipedia.org/wiki/Verbrennungsmotor

https://de.wikipedia.org/wiki/L%C3%B6sungsmittel

https://de.wikipedia.org/wiki/Ger%C3%A4te-_und_Maschinenl%C3%A4rmschutzverordnung

https://de.wikipedia.org/wiki/Ger%C3%A4te-_und_Maschinenl%C3%A4rmschutzverordnung

https://de.wikipedia.org/wiki/Sommersmog

https://de.wikipedia.org/wiki/N%C3%A4hrstoff

https://de.wikipedia.org/wiki/Verordnung_%C3%BCber_die_L%C3%A4rmkartierung

https://de.wikipedia.org/wiki/Verordnung_zur_Kennzeichnung_der_Kraftfahrzeuge_mit_geringem_Beitrag_zur_Schadstoffbelastung

https://de.wikipedia.org/wiki/Verordnung_zur_Durchf%C3%BChrung_der_Regelungen_der_Biokraftstoffquote

https://de.wikipedia.org/wiki/Verordnung_zur_Anrechnung_von_strombasierten_Kraftstoffen_und_mitverarbeiteten_biogenen_%C3%96len_auf_die_Treibhausgasquote

https://de.wikipedia.org/wiki/Verordnung_zur_Anrechnung_von_strombasierten_Kraftstoffen_und_mitverarbeiteten_biogenen_%C3%96len_auf_die_Treibhausgasquote

https://de.wikipedia.org/wiki/Verordnung_zur_Festlegung_weiterer_Bestimmungen_zur_Treibhausgasminderung_bei_Kraftstoffen



https://de.wikipedia.org/wiki/Verordnung_%C3%BCber_Luftqualit%C3%A4tsstandards_und_Emissionsh%C3%B6chstmengen


(2008/50/EC, 2004/107/EC)

March 2019 45

40. BImSchV open

41. BImSchV Announcement Ordinance

42. BImSchV Ordinance on evaporative cooling systems, cooling towers and wet scrubbers

43. BImSchV Ordinance on national obligations to reduce emissions of certain air pollutants

44. BImSchV Ordinance on medium combustion, gas turbine and combustion engine systems

https://de.wikipedia.org/wiki/Verordnung_%C3%BCber_Verdunstungsk%C3%BChlanlagen,_K%C3%BChlt%C3%BCrme_und_Nassabscheider

https://de.wikipedia.org/wiki/Verordnung_%C3%BCber_nationale_Verpflichtungen_zur_Reduktion_der_Emissionen_bestimmter_Luftschadstoffe

EUROPEAN COMMISSION, DG ENVIRONMENT SUPPORTING THE FITNESS CHECK OF THE EU AMBIENT AIR QUALITY DIRECTIVES (2008/50/EC, 2004/107/EC)

March 2019 46

APPENDIX E POLLUTANT CONCENTRATION DATA FOR GERMANY, 2013-17

Table E-1 Highest pollutant concentrations in exceedance of EU air quality objectives for protection of health in Germany in 2013-2017 - extract from reporting

(Dataflow G).

Pollutant Averaging period Objective type and value Date for achieving

objective

Parameter shown 2013 2014 2015 2016 2017

PM10 Calendar year LV: 40 μg/m3 1 January 2005 Annual mean, μg/m3 - - - - -



per year


NO₂ Calendar year LV: 40 μg/m³ 1 January 2010 Annual mean, μg/m3 89 89 87 82 78



per year

1 January 2010 Hours above 63 36 61 35 -


ceeded on more than 3 days per

year

1 January 2005 Days above - - - - -



per year

1 January 2005 Hours above - - - - -

CO Maximum daily

8-hour mean

LV: 10 mg/m3 1 January 2005 Days above - - 1 - -

C6H6 Calendar year LV: 5 μg/m3 1 January 2010 Annual mean, μg/m3 7 - - - -


content in PM10)

1 January 2005 Annual mean, μg/m3 - - - - -

O3 Maximum daily

eight-hour mean



per calendar year averaged over

three years



March 2019 47

Pollutant Averaging period Objective type and value Date for achieving

objective

Parameter shown 2013 2014 2015 2016 2017

Maximum daily

eight-hour mean

within a calendar

year

LTO: 120 μg/m³ Not defined Days above 46 52 58 55 50

PM2.5 Calendar year LV: 25 μg/m³ 1 January 2015 (tar-

get value until 1 Jan-

uary 2010)

Annual mean, μg/m3 - - - - -

(calculated as

Average Expo-

sure Indicator,

assessed as a 3-

year running an-

nual mean)

ECO: 20 μg/m3 2015 AEI, μg/m3 NA NA NA NA NA

As Calendar year TV: 6 ng/m³ (measured as con-

tent in PM10)


Cd Calendar year TV: 5 ng/m³ (measured as con-

tent in PM10)

31 December 2012 Annual mean, ng/m3 6 - - - -


content in PM10)

31 December 2012 Annual mean, ng/m3 22 - - - 31

PAH Calendar year TV: 1 ng/m³ (expressed as BaP,

measured as content in PM10)

31 December 2012 Annual mean, ng/m3 - - 2 2 -


Note: LV: limit value; TV: target value; LTO: Long term objective; ECO: exposure concentration obligation; The values show the maximum exceedance reported in the Member State (if no

exceedances are reported in any of the zones of the Member State, the table shows "-")

Legend: "NA": not available in data flow G, "-": no reported exceedances.


March 2019 48

APPENDIX F EU ERDF AND LIFE PROJECTS

Table F-1 EU ERDF 2014-2020 programmes in Germany.

sd Title PA_Title IF_txt EUR

2014DE16RFOP003 OP Berlin ERDF 2014-2020 Sustainable urban develop-

ment

Air quality measures 500.000

2014DE16RFOP004 OP Brandenburg ERDF 2014-

2020

Integrated development of

urban and rural areas

Air quality measures 12.000.000

2014DE16RFOP008 OP Mecklenburg-Vorpommern

ERDF 2014-2020

Promoting integrated sustain-

able


2014DE16RFOP009 OP Nordrhein-Westfalen

ERDF 2014-2020

Sustainable urban and local

development / prevention

Integrated pollution preven-

tion and control (IPPC)

53.040.166

2014DE16RFOP012 OP Sachsen ERDF 2014-2020 Sustainable urban develop-

ment


2014DE16RFOP014 OP Schleswig-Holstein ERDF

2014-2020

Change of the energy system

- building environmentally

sound economic and infra-

structure

Integrated pollution preven-

tion and control (IPPC)

2.300.000

Total 92.318.166


March 2019 49

Table F-2 LIFE projects in Germany under Air & Noise theme, 1993-2015.

Project Title Project Nr Project Website Year of Finance Type Of Beneficiary Themes Keywords

LIFE Legal Actions -

Legal Actions on

Clean Air

LIFE15

GIE/DE/000795

http://www.right-to-

clean-air.eu

2015 NGO-Foundation Air & Noise ~ Air pol-

lutants / Information

- Governance ~

Awareness raising -

Information /

air quality manage-

ment / environmental

training / human ex-

posure to pollutants /

public awareness

campaign / public

health / urban area /

LIFE - CLEAN HEAT -

CLEAN HEAT: Reduc-

ing particulate matter

caused by wood burn-

ing

LIFE14

GIE/DE/000490

http://www.clean-

heat.eu



- Governance ~

Awareness raising -

Information /

air pollution / envi-

ronmental impact of

energy / pollution

control / public

awareness campaign /

CA - CLEAN AIR LIFE11

ENV/DE/000495

http://www.cleanair-

europe.org



- Governance ~ Im-

proved legislative

compliance and en-

forcement /

air pollution / envi-

ronmental impact of

transport / infor-

mation system / pub-

lic health /

Waste air treatment -

Novel purification

technique for the

treatment of waste

air in the manufactur-

ing process of para-

formaldehyde

LIFE11

ENV/DE/001073

http://granuform-pro-

jekt.de

2011 SME Small and me-

dium sized enterprise

Air & Noise ~ Air pol-

lutants / Industry-

Production ~ Chemi-

cals /

air pollution / chemi-

cal industry / odour

nuisance / public

health /

ZEM/SHIPS -

Zero.Emission.Ships

LIFE06

ENV/D/000465

http://www.zem-

ships.eu/en/in-

dex.php

2006 Regional authority Air & Noise ~ Air pol-

lutants / Climate

change Mitigation ~

Renewable energies /

atmospheric pollution

/ climate change miti-

gation / emission re-

duction / energy sup-

http://www.right-to-clean-air.eu/

http://www.right-to-clean-air.eu/

http://www.clean-heat.eu/

http://www.clean-heat.eu/

http://www.cleanair-europe.org/

http://www.cleanair-europe.org/

http://granuform-projekt.de/




http://www.zemships.eu/en/index.php







March 2019 50


Climate change Miti-

gation ~ GHG re-

duction in non EU ETS

sectors / Services

& Commerce ~

Transportation - Sto-

rage /

ply / harbour / navi-

gation / renewable

energy /

PARFUM - Particu-

lates, Freight and

heavy duty vehicles

in Urban Environ-

ments

LIFE06

ENV/D/000477

http://www.parfum-

life.eu

2006 Local authority Air & Noise ~ Air

quality monitoring /

Land-use &

Planning ~ Transport

planning - Traffic

monitoring /

air quality manage-

ment / integrated

management / public

transport / traffic

emission / urban area

/

Sludge Redox -

Transfer of the or-

ganic constituents of

sewage sludge into a

soluble form for an

efficient production of

biogas

LIFE05

ENV/D/000193

http://www.cur-

renta.de/in-

dex.php?page_id=16

2

2005 International enter-

prise

Air & Noise ~ Air


Energy ~ Supply /

Waste ~ Hazardous

waste /

hazardous waste / in-

dustrial waste / sew-

age sludge / use of

waste as energy

source /

HVD - Hydro-Mechan-

ical Descaling Process

based on High-Pres-

sure Vacuum Tech-

nology Using Scales

as Abrasive Blast Me-

dium

LIFE05

ENV/D/000207



Air & Noise ~ Air


Environmental man-

agement ~ Cleaner

technologies / Indus-

try-Production ~

Metal industry /

clean technology / in-

dustrial process / iron

and steel industry /

Odour scrubber -

Demonstration of a

closed circuit system

resulting in a sub-

LIFE04

ENV/DE/000051

http://www.car-

gill.de/deu/loca-

tions/mainz-eupro-

jekt.shtml


prise

Air & Noise ~ Air


Energy ~ Savings /

air pollution / edible

fat / emission re-

duction / odour nui-

sance /

http://www.parfum-life.eu/

http://www.parfum-life.eu/

http://www.currenta.de/index.php?page_id=162







http://www.cargill.de/deu/locations/mainz-euprojekt.shtml









March 2019 51


stantial odour emis-

sion reduction and

energy saving during

oilseed pressing

UFIPOLNET - Ultrafine

particle size distribu-

tions in air pollution

monitoring networks

LIFE04

ENV/DE/000054

http://www.um-

welt.sachsen.de/um-

welt/en/4890.htm

2004 Regional authority Air & Noise ~ Air


Land-use &

Planning ~ Transport

planning - Traffic

monitoring / Risk

management ~ Hu-

man health protection

/

air pollution / air


DAMIVOC - Develop-

ment of an Aerospace

Minimized VOC Exte-

rior System

LIFE03

ENV/D/000044


prise


lutants / Industry-

Production ~ Engines

- Machinery - Vehicles

/


/ coating / emission

reduction / volatile

organic compound /

NT-Plasma - Im-

proved application of

catalytic supported

low temperature

plasma plants for

waste air purification

LIFE02

ENV/D/000406

http://www.doerken-

life.de




lutants / Industry-

Production ~ Building

/

greenhouse gas /

treatment of gases /

LISA - LISA (Low Iso-

cyanate Solventfree

Adhesives) Procedure

for the development

and production of sol-

ventless adhesives

with extremely low

LIFE99

ENV/D/000408


prise


lutants / Industry-

Production ~ Chemi-

cals /

alternative material /

packaging / pollutant

elimination / solvent /

http://www.umwelt.sachsen.de/umwelt/en/4890.htm






http://www.doerken-life.de/

http://www.doerken-life.de/


March 2019 52


contents of mono-

meric isocyanates

Sustainable painting

technique - Demon-

stration of the tech-

nical and economical

feasibility of an inno-

vative painting tech-

nology for small plas-

tic components by

means of high-speed

rotation for the re-

duction of paint con-

sumption and solvent

emissions

LIFE99

ENV/D/000434


prise


lutants / Industry-

Production ~ Chemi-

cals / Waste ~ Waste

reduction - Raw ma-

terial saving /

emission reduction /

paint / plastic / sol-

vent / waste reduc-

tion /

Odour reduction - Re-

duction of the odour

emission in the feed

mill Oldenburg

LIFE99

ENV/D/000442

1999 Public enterprise Air & Noise ~ Air pol-

lutants / Environ-

mental management

~ Cleaner technolo-

gies / Industry-Pro-

duction ~ Agriculture

- Forestry /

animal foodstuff /


odour nuisance /

Dry stage fiber glue -

Development and

testing of an innova-

tive test plant for an

environment-freindly

and energy-saving

glue blending of dried

fibers for the produc-

tion of MDF boards in

the wood industry.

LIFE99

ENV/D/000443


prise


lutants / Industry-

Production ~ Chemi-

cals /


energy saving / vola-

tile organic compound

/ wood product /


March 2019 53


EuroBionet - Euro-

pean network for the

assessment of air

quality by the use of

bioindicator plants

LIFE99

ENV/D/000453

http://www.eurobio-

net.com,.

http://www.uni-ho-

henheim.de/eurobio-

net/report_eng.html

1999 University Air & Noise ~ Air


Risk management ~

Human health protec-

tion /


/ environmental as-

sessment / indicator /

urban area /

Reduction of energy

consumption and air

pollution by means of

absorptionchillers

powered by uncondi-

tioned heat-fluxes

LIFE98

ENV/D/000504

1998


lutants / Energy ~

Savings / Industry-

Production ~ Agricul-

ture - Forestry /

air pollution / energy

saving /

Clean Air System De-

velopment and test of

an innovative and

mobile testing plant

for non-polluting dry-

ing of wet flakes of

the wood material in-

dustry

LIFE98

ENV/D/000522

1998


lutants / Industry-

Production ~ Wood -

Furniture /

air pollution / clean

technology / emission

reduction / wood

product /

Waste site emission

reduction - The de-

crease of the emis-

sion potential of a

housing development

deposing area

through controlled

optimization of de-

posing area gas pro-

duction by a con-

tinously working wa-

tering device.

LIFE98

ENV/D/000524

http://www.emsland.

de/pages/abfall.htm,

, http://www.abfall-

wirtschaft-

emsland.de/




lutants / Waste ~

End-of-pipe treat-

ment - Landfilling /


landfill / treatment of

gases /

http://www.eurobionet.com/




http://www.uni-hohenheim.de/eurobionet/report_eng.html






http://www.emsland.de/pages/abfall.htm

http://www.emsland.de/pages/abfall.htm

http://www.abfallwirtschaft-emsland.de/






March 2019 54


Demonstration pro-

ject 'flameless non-

catalytic oxidation of

hazardous gases from

waste disposal sites'

LIFE97

ENV/D/000457

1997 Regional authority Air & Noise ~ Air pol-

lutants / Waste ~

End-of-pipe treat-

ment - Landfilling /

end-of-pipe technol-

ogy / energy saving /

flue gas / greenhouse

gas / hazardous sub-

stance / landfill / pol-

lutant elimination /

technology transfer /

Reduce VOC using

acid esters - Reduc-

tion of VOC emissions

by using fatty acid

esters for metal

cleaning processes

LIFE97

ENV/D/000465

http://www.rrz.uni-

hamburg.de/koopera-

tionsstelle-hh/in-

dex.html

1997 Research institution Air & Noise ~ Air pol-

lutants / Industry-

Production ~ Metal

industry /



metal products indus-

try / vegetable oil /

volatile organic com-

pound /

Demonstration plant

of an individual

chamber pressure

regulation to avoid

emissions of coke ov-

ens.

LIFE97

ENV/D/000473

1997


lutants / Industry-

Production ~ Metal

industry /


iron and steel indus-

try /

Lacqueur membrane

separation - Using a

membrane separation

process for the depig-

mentation of water

lacquer

LIFE96

ENV/D/000003


prise


lutants / Environ-

mental management

~ Cleaner technolo-

gies / Industry-Pro-

duction ~ Chemicals /

clean technology /

paint / volatile or-

ganic compound /

Replacing organic

solvents with water-

paint technology for

coating casting arti-

cles (gears)

LIFE95

ENV/D/000020

1995


lutants / Industry-

Production ~ Chemi-

cals /


coating / solvent /

http://www.rrz.uni-hamburg.de/kooperationsstelle-hh/index.html








March 2019 55


Qualification of meas-

uring techniques for

process-integrated

emission control

LIFE95

ENV/D/000030

1995


lutants /

air pollution / hazard-

ous substance / pollu-

tion control / volatile

organic compound /

Curing of solvent free

printing inks with low

energy electrons

LIFE94

ENV/D/000052

1994


lutants / Industry-

Production ~ Paper -

Pulp - Printing /

coating / pollutant

elimination / printing

industry / solvent /

XHC-free coating pre-

cleaning - XHC-free

precleaning for envi-

ronmentally conscious

coating processes: a

solution for job-coat-

ers

LIFE94

ENV/D/000240

1994


lutants / Industry-

Production ~ Chemi-

cals /

cleansing product /

coating / ozone layer

depletion / pollutant

elimination /

Non-emission demon-

stration plant for

coating steel parts

with a sintered layer

of zinc/aluminium

LIFE94

ENV/D/000502

1994


lutants / Industry-

Production ~ Metal

industry /

coating / iron and

steel industry / pollu-

tant elimination /

Recovery of valuable

substances from re-

fuse-incinerator flue

gases.

LIFE93

ENV/D/000064

1993


lutants /

flue gas / incineration

of waste / treatment

of gases /

Written by Tanzir Chowdhury March 2019

CASE STUDY REPORT

IRELAND



(2008/50/EC, 2004/107/EC)


SUPPORTING THE FITNESS CHECK OF THE EU AMBIENT AIR QUALITY DIRECTIVES (2008/50/EC, 2004/107/EC)

March 2019 2

Contents

1 Introduction 4


2.1 Ireland and air quality zone characteristics 5






3 Findings 19




3.4 Factors underlying compliance and effectiveness of the AAQ

Directives 25


4 Conclusions 28






March 2019 3

Appendices

Appendix A Interviews

Appendix B Pilot interview guide

Appendix C EU funded projects



March 2019 4

1 INTRODUCTION

This report summarises the findings and conclusions of the case study for Ireland. The case

study had a focus on information provision to the public.

















the case study

• Chapter 3 – Findings, presents detailed findings regarding the relevance of the AAQ Di-

rectives, the implementation successes and problems, the factors underlying compliance

with the Directives, the costs and benefits.




in Appendix A.






March 2019 5


This chapter provides general information about the air quality framework and air quality status

in Ireland. The purpose of this chapter is to set a background for the more detailed findings

presented in chapter 3. The chapter relies primarily on desk research.

2.1 Ireland and air quality zone characteristics

The case study covers the implementation of the AAQ Directives in the entire Republic of Ireland.

As shown in Figure below, Ireland has four national air quality zones. Zone A is centred on Dublin,

Ireland’s largest urban area while Zone B is centred on Cork. Zone C accounts for other remaining

large urban areas, while Zone D, the largest, covers rural parts of the country.

Figure 2-1 Air quality zones for NOx and PM10, 2014 (EPA, 2017)

As Dublin and Cork are Ireland’s two most populous areas, they are designated as separate zones

during, though the zones have been realigned in 2013. For the purpose of the AAQ Directives,

Ireland is split into the following zones1: Zone A is the largest, consisting of the city of Dublin and

three counties (Dún-Laoghaire-Rathdown, South Dublin and Fingal). The population stands at

1,195,789, and the zone encompasses the majority of Ireland’s manufacturing industry.

Zone B consists of the city and county of Cork. The population is considerably less, with 220,298

residents. 2 Zone C accounts for the remainder of Ireland’s cities and large towns, with popula-

tions starting from around 1,500 to 100,0002. The total population of this zone is 722,657. Zone

D covers the majority of Ireland’s land area, and a population of 2,449,508. This rural zone is

characterised by a low population density. Key relevant characteristics of Ireland are presented

below.

1 Environmental Protection Agency, ‘Air Quality Zones Realignment’. 2 European Environment Agency, ‘AQ Zones’.



March 2019 6

Text box 2-1 – Key relevant characteristics of Ireland

Ireland

GDP per capita in PPS (100=EU28 avg)

(2017)

1843

GDP per capita growth

(% 2008-2017)

21.354

GDP per capita (EUR) 56,4005

Population (1 January 2018) 4,838,2596

Governance structure Parliamentary democracy with 31 local authorities

Zones defined as agglomerations (%) 50

Area: 70,280 km2

Characteristics of Ireland:

Ireland has a maritime climate, characterised by warmer winters and cooler summers than continental

climates of mainland Europe. The country has a low population density of 70 people per km2, with few large

cities and large expanses of rural land. The rural land is predominantly used for agriculture, with forests

and national parks as the remainder. There are mountainous regions across the country. For implementation

of the AAQ Directives, Ireland has been divided into four zones of which two are agglomerations.

Source: Eurostat, GDP per capita in Purchasing Power Standards (PPS) expressed in relation to the European


Population on 1 January.


The following section presents briefly the arrangements made in Ireland for air quality monitoring

and overview of the status of air quality in the country.


At the national level, Ireland’s Environmental Protection Agency (EPA) takes responsibility for the

protection and improvement of the environment. Air quality monitoring falls under the remit of

the EPA, who coordinates and manages the monitoring of concentrations of pollutants across the

country.

3 Eurostat (2018) GDP per capita, consumption per capita and price level indices - Statistics Explained, ac-

cessed 14 December 2018, https://ec.europa.eu/eurostat/statistics-explained/in-

dex.php/GDP_per_capita,_consumption_per_capita_and_price_level_indices 4 The World Bank (2018) GDP (current US$) | Data, accessed 14 December 2018,

https://data.worldbank.org/indicator/NY.GDP.MKTP.CD?end=2017&locations=IE&start=2008 5 Eurostat (2018) Real GDP per capita, accessed 14 December 2018, https://ec.europa.eu/eurostat/tgm/ta-

ble.do?tab=table&init=1&language=en&pcode=sdg_08_10&plugin=1 6 Eurostat (2018) Populations by country (January 1st), accessed 14 December 2018, at: https://ec.eu-

ropa.eu/eurostat/tgm/table.do?tab=table&init=1&language=en&pcode=tps00001&plugin=1

https://ec.europa.eu/eurostat/statistics-explained/index.php/GDP_per_capita,_consumption_per_capita_and_price_level_indices




https://data.worldbank.org/indicator/NY.GDP.MKTP.CD?end=2017&locations=IE&start=2008

https://ec.europa.eu/eurostat/tgm/table.do?tab=table&init=1&language=en&pcode=sdg_08_10&plugin=1




https://ec.europa.eu/eurostat/tgm/table.do?tab=table&init=1&language=en&pcode=tps00001&plugin=1






March 2019 7

The EPA’s work is guided by the national ambient air quality monitoring programme (AAMP),

which has a statutory footing. Alongside the AAMP, the national clean air strategy (NCAS) is being

developed, which will eventually encompass the AAMP as a national strategy, linked with policy.7

The NCAS will be Ireland’s first clean air strategy, the aim of which is to provide the framework

for cross-government policies and actions. In this respect, the focus on action to address poor air

quality will be higher in the NCAS than in the AAMP, which is intended as an information gathering

mechanism to improve monitoring and inform policy. Until the NCAS is released, the AAMP guides

national policy for air quality in Ireland. The AAMP covers five objectives8:

• Provide enhanced real-time air quality information to the public across Ireland

• To provide air quality forecasting and modelling

• Place monitoring on a statutory footing

• Progress citizen engagement

• Increase source apportionment resources

At present, all of the EPA’s air quality monitoring is undertaken through a network of stations,

which includes station coordinated by partnerships with local authorities and third-party organi-

sations. The 2008 Directive has guided the current network’s formation and operation, and as the

new National Ambient Air Quality Monitoring Programme (AAMP) network expands, the Clean Air

for Europe (CAFE) network increases its resolution in urban and rural areas. The EPA is planning

to make the network fully autonomous and add 38 additional stations to the current 29. The AAMP

began in 2017 and will run until 2022, by which point Ireland should have a high-resolution real-

time national perspective on air quality. The development of the current network is indicated in

the two figures below.

7 Department for Communications Climate Action and Environment, ‘National Clean Air Strategy’. 8 Environmental Protection Agency, ‘National Ambient Air Quality Monitoring Programme 2017-2022’.



March 2019 8

Figure 1 - 2 Clean Air for Europe Air Monitoring Network 2016 (EPA, 2017)

Ireland’s pre-2017 network of monitoring sites, while meeting the requirements of EU Directives,

as shown in Figure 1, left large rural and urban areas without any assessment. Certain larger

urban areas (such as Cork) did not have high densities of monitoring stations. Efforts under the

AAMP intend to increase the number of monitoring stations, as shown in Figure 2- 2.



March 2019 9

Figure 2- 2 - Proposed air quality monitoring network under the AAMP (EPA, 2017)

The EPA’s CAFE stations monitor Ozone, CO, NOx, SO2, PM2.5, PM10, Benzene (C6H6), Lead (Pb)

and PAH (Polycyclic Aromatic Hydrocarbons)9. The stations are able to provide real-time data for

most of these pollutants, which are published online. Results are summarised in annual EPA pub-

lications of air quality for Ireland, which provide trend analysis for pollutants.

2.2.2 Air quality in Ireland

Ireland’s air quality is determined by a range of human and natural factors. The country’s pre-

vailing weather patterns bring relatively clean Atlantic air from the south-west, which generally

prevents the build-up of pollution10. Ireland also has a low population density, and few large urban

areas, which generally prevents concentrations of pollutants forming which exceed EU limits. Ac-

cording to the most recent European Environment Agency Country Factsheet on Ireland11 none of

Ireland’s urban monitoring stations recorded pollutant concentrations above the EU’s limit values

from 2012 - 2016.

9 Environmental Protection Agency, ‘Air Quality: What We Monitor’. 10 Department for Communication, Climate Action and Environment, ‘Air Quality Overview’. 11 Ireland – air pollution country fact sheet 2018, accessed 19 December 2018, https://www.eea.eu-

ropa.eu/themes/air/country-fact-sheets/ireland



March 2019 10

It is difficult to ascribe any change in air quality in Ireland directly to the impacts of the AAQ

Directives however, in interview, the Irish EPA noted the AAQ Directives have primarily been used

to improve the assessment of air quality in regional areas (Zones C and D) where monitoring

infrastructure was lacking prior to the implementation of the Directives. They note that the Direc-

tives provided the impetus to assess air quality in these regions and act where it needs improving.

The Department of Communications, Climate Action & Environment (DCCAE) noted in interview

that this impetus for improvement of monitoring is key as, without it, it is not possible to identify

areas, which need to be targeted. So far, no breaches of limit values have been recorded in Zones

C and D.12 As depicted in Figure 1 and Figure 2- 2 Ireland is planning to significantly expand its

rural monitoring network as part of its 2017 – 2022 Ambient Air Quality Monitoring Programme

to provide a more spatially extensive and accurate view of exceedances occurring in areas cur-

rently underserved by monitoring.

In 2009, in response to exceedances NO2, the four local authorities in Dublin produced a regional

air quality management plan for the 2009-2012 period to bring NO2 back within EU limit values.

The plan implemented a range of measures including;

• Regional planning guidance for the greater Dublin Area to reduce emissions;

• a Dublin Bike Rental Scheme; and

• a Dublin HGV Management Strategy.

Since 2009, no exceedances of the EU limit value for NO2 have been recorded. This is covered in

more detail in Section 2.4.

Data published by the EPA shows pollutant concentrations in relation to EU limit values. These

are discussed together below.

Although changes in weather patterns can cause accumulations, in 2017 no monitoring stations

in Ireland recorded any exceedance of any EU legislative limit values for protecting human health

and vegetation13.

However, WHO air quality guidelines were exceeded at particular monitoring sites for PM10 and

PM2.5, Ozone and NO2. PM10 24-hour guidelines were exceeded at 11 monitoring sites. PM2.5 24-

hour guidelines were exceeded at nine monitoring sites, and the annual monitoring guideline

exceeded at 1 monitoring site13. European Environment Agency (EEA) reference level14 for PAH

wes breached at four monitoring sites. Ireland was closest to breaching EU limit values for the

concentration of NO2 in urban areas, a trend that is attributed to the level of vehicle use.

Since 2010, concentrations of NO2 recorded at monitoring stations in Ireland have been consist-

ently under the EU annual limit value (Figure 2-3), though it is noted by the EPA that increases

in traffic and unfavourable weather patterns could expose certain areas to build ups.

12 Environmental Protection Agency (2018) Air Quality In Ireland 2017, Wexford, Ireland, 2018,

http://www.epa.ie/pubs/reports/air/quality/Air%20Quality%20In%20Ireland%202017.pdf 13 Environmental Protection Agency, ‘Air Quality In Ireland 2017.Pdf’. 14 The EEA estimated reference levels for pollutants for which the WHO did not establish air quality guidelines.

http://www.epa.ie/pubs/reports/air/quality/Air%20Quality%20In%20Ireland%202017.pdf



March 2019 11

Figure 2-3 - Trend in NO2 concentrations for zones in Ireland 2007-2017

Source: EPA, 2017

Particulate matter can be differentiated according to particle diameter, the two main categories

are 10 micrometres and 2.5 micrometres. PM10 concentrations are contributed to by the burning

of fuels, engine combustion, dust and pollen. PM2.5 concentrations, the finer particles, are primar-

ily from residential solid fuel combustion. As Figure and Figure 2-4 below indicate, concentrations

of PM2.5 are more frequently exceeding WHO air quality guidelines, and in previous years have

come closer to breaching EU annual limit values than PM10.

Ireland was noted by the EEA’s 2018 Air Quality in Europe report15 as being one of only four EU

countries that has not recorded any exceedance the long-term WHO air quality guidelines for

PM10, emphasising the quality of its air in the context of the EU. However, there were breaches of

PM2.5.

Figure 2-5 - Annual mean PM10 concentrations 2007 – 2017 (EPA, 2017)

15 European Environment Agency, ‘Air Quality in Europe — 2018 Report’.



March 2019 12

Figure 2-4- Annual mean PM2.5 concentrations 2009 – 2017 (EPA, 2017)

Polycyclic aromatic hydrocarbons (PAH) are chemical compounds, primarily emitted from the com-

bustion of solid fuels (predominantly for residential heating) and incomplete combustion of fuels

from vehicles. PAH frequently pollute water, as precipitation can wash the particles from the at-

mosphere into surface waters where they are retained. Although monitoring across Ireland shows

that concentrations are primarily below EU annual limit values, in previous years they have been

far higher than EEA air quality reference levels, as can be seen in Figure 2-5.

Figure 2-5 - Annual mean PAH concentrations 2009 – 2017 (EPA, 2017)

Ozone (O3) is formed as a secondary pollutant from chemical reaction between NOx, CO and

volatile organic compounds. Concentrations are higher in rural areas, as in urban areas O3 reacts

with traffic-related pollutants, reducing concentrations. Across Ireland, O3 monitoring in 2017

showed that no sites recorded an exceedance of EU annual limits, though nine sites recorded

breaches of the WHO guideline values, these were primarily rural monitoring sites. Figure 2-6



March 2019 13

shows a number of rural monitoring sites, of which Galway is records the highest concentration

of O3.

Figure 2-6 - Ozone monitoring at rural stations in Ireland 2007 – 2017

Source: EPA, 2017


The governance structure for air quality in Ireland is a network of key actors from the local to the

national level. Across these partnerships, there are defined roles and responsibilities for the man-

agement and coordination of monitoring, data collection, communications and reporting. These

roles are outlined below.

National Government

The Irish Government is developing a National Clean Air Strategy which will provide a framework

for creating, integrating and promoting air quality policies. The Government, through the Depart-

ment of Communications, Climate Action and Environment, has provided funding to upgrade the

monitoring network through the ambient air quality monitoring programme - AAMP.

The Environmental Protection Agency (EPA) is broadly responsible for improving and protecting

the environment for the people of Ireland. It operates independently under the Department of

Communications, Climate Action & Environment - DCCAE and is responsible for national environ-

mental enforcement and regulation.

With regards to AAQ Directives, the EPA is the national competent authority for the implementa-

tion of the 2008 Directive. The EPA is also the National Reference Laboratory meaning it ensures

all instrumentation is compliant with the directives, that third party operators are compliant and

that it meets strict sampling and reporting requirements. Additionally, the EPA regulates the coun-

try’s greenhouse gas emissions, including the implementation of the Emissions Trading Directive

and preparation of Ireland’s greenhouse gas inventories and projections. Under the Environmental



March 2019 14

Protection Agency Act 1992, the EPA is also responsible for the Industrial Emissions Directive

(IED) licensing of large or complex industries with significant polluting potential.

The EPA thus has a number of statutory roles including:16

• Leading the coordination and management of all air quality monitoring activities in Ireland.

There is a total of 31 monitoring stations throughout the country which monitor air quality

under the 2004 and 2008 directive. Although, the EPA is planning to expand this network to

80 stations.17

• Operation of the national ambient air quality monitoring programme (AMMP).

• Together with Met Éireann – the national meteorological service and Teagasc – the Agricul-

ture and Food Development Authority, the EPA manages the national element of the Coop-

erative Programme for Monitoring and Evaluation of the Long-range Transmission of Air

Pollutants in Europe (EMEP). This involves a network of EMEP monitoring sites across the

country.

• Responsible for gathering, analysing and disseminating air quality data.

• Providing technical support and guidance to stakeholders, third parties and local authorities

involved in air quality monitoring. A key aspect of this is hosting forums, workshops and

annual conferences as well as engaging with partners to trial appropriate technologies.

• Reviews the performance of local authorities in relation to enforcing clean air legislation.

• Disseminating information to the public. This includes pollution exceedance alerts.

County and City Management Association (CCMA)

The CCMA represents local government. Its members are Chief Executives of the county and city

councils. The body works in partnership with key stakeholders, such as the EPA, to develop and

implement effective legislation. Moreover, the CCMA was a key partner in developing the AMMP

and ran a programme of engagement with local authorities to encourage involvement in the net-

work.

Local Authorities and City Councils

Under the Air Pollution Act 1987 (as amended), local authorities hold primary responsibility for

addressing local air pollution. Further division of responsibilities between the EPA, local authorities

and city councils is flexible and depends upon the site and what air pollutant is being monitored,

as well as local capacity/resources. Local authorities support local monitoring stations and provide

data to the EPA national network. They play a role in assessing compliance with the relevant

legislation, dealing with complaints regarding air pollution, licensing certain categories of industry,

enforcing the ban on certain solid fuels and supporting research and education regarding air pol-

lution. Local Authorities can also enforce penalties if the Act is infringed. In addition, local author-

ities can designate special control areas in order to prevent or limit air pollution.

City councils such as Dublin City Council and Cork City Council, conduct monitoring on behalf of

local authorities within their jurisdiction.

16 EPA (2017) National Ambient Air Quality Monitoring Programme 2017-2022, November

2017,https://static.rasset.ie/documents/news/2017/11/epa-air-quality-programme-2017-22.pdf 17 DCCAE (2017) Clean Air Strategy Public Consultation

https://static.rasset.ie/documents/news/2017/11/epa-air-quality-programme-2017-22.pdf



March 2019 15

Met Éireann

Met Éireann is the national meteorological service in Ireland. It is responsible for coordinating air

quality data collection from a number of sites, and can issue warnings and forecasts for certain

atmospheric conditions, such as ground-level ozone.


There is a variety of European and Irish legislation settting standards to reduce emissions from a

range of sources, and to limit the exposure to pollution in ambient air. EU legislation has been

transposed into national law, or complimented where appropriate, such as regarding residential

solid fuel use, which is the primary source of fine particulate matter air pollution in Ireland but

for which there is no current EU legislation.

Key legislation

The AAQ Directives have been transposed into Irish legislation. Directive 2008/50/EC was trans-

posed into Irish legislation by the Air Quality Standards Regulations 2011 (S.I. No. 180 of

2011).18Directive 2004/107/EC was transposed into Irish legislation by the Arsenic, Cadmium,

Mercury, Nickel and Polycyclic Aromatic Hydrocarbons in Ambient Air Regulations 2009 (S.I. No.

58 of 2009).19

The Air Pollution Act (APA), 1987, and the Environmental protection Agency Act, 1992 are the

main national legislative provisions addressing air pollution in Ireland. The Act defines air pollution

and devolves the power to ensure compliance to the EPA and local authorities. It introduces the

regulation of emissions from a variety of industrial sources, for which enforcement powers also lie

with the EPA and local authorities. Although the APA was amended in 2015, the Act has not sig-

nificantly changed since its introduction, other than the revision downwards of air quality limits20.

A number of key aspects are outlined below:

• Owners of certain industrial plants must obtain a license to operate from the relevant local

authority or the EPA.

• Persons guilty of offence can be fined or imprisoned at the discretion of the national court

or the local authority in question.

• The Act enables the Minister for Environment to regulate fuel quality. This has been applied

to regulating the marketing, sale, distribution and use of bituminous ‘smoky’ coal as well as

setting a maximum limit on the Sulphur content of solid fuels. This has been key for tack-

ling ‘smog’ especially in larger cities.

• Local authorities have the power to take immediate steps, to declare special control zones

and to make Air Quality Management Plans and Standards to prevent air pollution and to

preserve or improve air quality.

18 Government of Ireland (2011) Air Quality Standards Regulations 2011 19 Government of Ireland (2009) S.I. No. 58/2009 - Arsenic, Cadmium, Mercury, Nickel and Polycyclic Aro-

matic Hydrocarbons In Ambient Air Regulations 2009, accessed 19 December 2018, http://www.irishstatute-

book.ie/eli/2009/si/58/made/en/print 20 DCCAE (2017) Clean Air Strategy Public Consultation

http://www.irishstatutebook.ie/eli/2009/si/58/made/en/print






March 2019 16

Strategic frameworks

As previously outlined, the national government is developing the National Clean Air Strategy

(NCAS). This will set specific air quality goals and targets for the country. The plans highlight that

the NCAS will maximise synergies with the national mitigation plan (NMP), as designed under the

Climate Action and Low Carbon Development Act 2015. The NMP is intended to be a cross-gov-

ernment approach to tackling greenhouse gas emissions by tracking measures currently underway

and identifying new measures.

Furthermore, in 2017 the EPA completed consultation on the new AMMP, proposed under Section

65 of the EPA Act. The programme seeks to improve its capacity and ability to provide more

comprehensive, localised air quality information focusing on:

• Enhancing the provision of real-time air quality information.

• Strengthening air quality forecasting and modelling.

• Increasing the statutory weight of ambient air monitoring, with an aim to ensure the commit-ment and alignment of resources nationwide.

• Improving citizen engagement and access to health advice linked to air quality information.

• Expanding the network of air monitoring stations.

• Increasing source apportionment targets.21

The AMMP provides a roadmap for the development of ambient air quality monitoring from 2017-

2022.

Air quality management plans

Under Section 46 of the 1987 Air Pollution Act, local authorities can devise air quality management

plans for specific areas, updating them at least every five years.22 Two or more authorities are

also able to create a joint plan. Different air quality standards can apply to different areas, time

periods or circumstances, as well as to particular pollutants.

For instance, the four local authorities in Dublin produced a regional air quality management plan

for the 2009-2012 period. The primary objective of the plan was to preserve good air quality in

the region, with particular attention to the risk faced by the most vulnerable members of the

population.23

The plan focuses on specific local conditions, particularly regarding nitrogen dioxide levels. It

outlines the underlying factors which influence the pollutant concentration and identifies multifac-

eted interventions. Ultimately, traffic emissions were identified as the primary cause of the high

nitrogen dioxide levels experienced in Dublin. Thus, the plan centres on urban planning and

transport measures to reduce these emissions. The strategies include:24

21 EPA (2017) National Ambient Air Quality Monitoring Programme 2017-2022, November 2017,

https://static.rasset.ie/documents/news/2017/11/epa-air-quality-programme-2017-22.pdf 22 Government of Ireland (1987) Air Pollution Act, 1987, accessed 12 December 2018, http://www.irishstat-

utebook.ie/eli/1987/act/6/enacted/en/print%23partv 23 Dublin City Council (2016) Dublin Regional Air Quality Management Plan 2009-2012, February 2016,

http://www.dublincity.ie/sites/default/files/content/WaterWasteEnvironment/AirQualityMonitoringandNoise-

Control/Documents/Dublin_Regional_Air_Quality_Management__Plan_2009_2012.pdf 24 Dublin City Council (2009) Air Quality Management Plan for Improvement in levels of Nitrogen Dioxide in

ambient Air Quality

https://static.rasset.ie/documents/news/2017/11/epa-air-quality-programme-2017-22.pdf

http://www.irishstatutebook.ie/eli/1987/act/6/enacted/en/print%23partv




http://www.dublincity.ie/sites/default/files/content/WaterWasteEnvironment/AirQualityMonitoringandNoiseControl/Documents/Dublin_Regional_Air_Quality_Management__Plan_2009_2012.pdf






March 2019 17

• Regional planning guidance for the greater Dublin area – This emphasizes compact

urban form, mixed use development and investment in high quality public transport in order

to reduce car usage, congestion and pollution. The transport measures centre on enhancing

rail, light rail and bus infrastructure and initiatives such as Smarter Travel Initiatives, Bike to

Work scheme, Personal Travel Plans, and Dublin Bikes. Moreover, local authorities are re-

quired to implement the Dublin Transportation Initiative plan for a network of cycle ways,

Park and Ride Facilities and Quality Bus Corridors.

• The Dublin bike rental scheme - This was launched in 2009 and enables Dublin City Coun-

cil to fund the provision of public cycling amenities. Around 450 bikes and 40 stations have

been provided, and to date, 2.6 million bicycle journeys have been taken on the scheme.

There are plans to expand the scheme.

• Dublin HGV Management Strategy - This involves a ban on 5+ axle vehicles during 07:00-

19:00 seven days a week from designated areas within Dublin City and Dun Laoghaire

Rathdown. The HGV Strategy has resulted in dramatic reductions of 5+ axle vehicles of be-

tween 80 - 94% on different routes within the cordon area.

• Local authorities continue to provide a complaint service for citizens with regards to air qual-

ity, as well as educational programmes.

• Strengthening evidence-based decision-making through the improvement of information

sharing on air quality.

It is noted that levels of nitrogen dioxide in Dublin were above the limit value in 2009, but there

have been no exceedances since.25


Pursuant to Article 26 of the Directive 2008/50/EC, Member States shall ensure that the public is

adequately, and in good time, informed about ambient air quality and other issues specified in

the above cited Article. Section 18 of the Air Quality Standards Regulations 2011 outlines the

action which the EPA must take with regards to alert thresholds. Where exceedance occurs, the

EPA is required to make information available to prescribed bodies and the public, through means

such as radio, television, newspapers or the internet.26 Section 21(6) further requires local au-

thorities to freely provide the results of investigations and information regarding air pollution

action plans to the public as well as health care bodies, environmental organisations and so forth.

There are a number of ways in which information dissemination is being addressed. These include;

• the Air Quality Index for Health (AQIH), including colour coded maps of the index across Ire-land;

• real time monitoring data;

• annual AQ reports, including trend analyses for key pollutants and breaches of limits where these have occurred NO2, O3 and PM10;

• historic AQ data from monitoring stations; and

• information web-developers can access for 3rd party reporting solutions.

25 Irish Environmental Protection Agency (EPA) (2018) Air Quality in Ireland 2017, 2018,

http://www.epa.ie/pubs/reports/air/quality/epaairqualityreport2017.html 26 Government of Ireland (2011) S.I. No. 180/2011 - Air Quality Standards Regulations 2011, accessed 12

December 2018, http://www.irishstatutebook.ie/eli/2011/si/180/made/en/print

http://www.epa.ie/pubs/reports/air/quality/epaairqualityreport2017.html





March 2019 18


The EPA’s Environmental Research programme is the primary funding mechanism for air quality

research and projects in Ireland. Through the programme’s Climate theme, over 50 air quality

related projects have been funded since 2007, with a budget of over €11 million.27 The appendix

to the case study report summarises ongoing EPA funded air quality projects. Furthermore, the

EPA funds scientific projects through a variety of national and international partnerships, such as

with the Science Foundation Ireland and Irish Research Council Science Foundation Ireland (SFI).

The EPA’s Research Programme 2014-2020 for instance, funded a project on Irish Nationwide

Health and Air Quality Linkage, at University College Cork.28

Furthermore, in April 2018 the EPA launched its annual Research Call, making available up to

€9.5m for research projects across three key areas: Water Climate and Air, and Environmental

Sustainability. The funding, managed by the EPA and provided by DCCAE, will support the imple-

mentation of environmental policies, including the Clean Air Strategy. The EPA Research Pro-

gramme has allocated €2.8m for Climate research, which is further structured into four thematic

areas, 29 including one on “Air Science”. Successful projects will begin by April 2019, and thus

named air quality research projects are currently unavailable.

The EPA also has key linkages with the European Commission Horizon 2020 programme which

funds research. One such example is the iSCAPE project, coordinated by Trinity College Dublin. It

aims to advance and integrate the control of carbon emissions and air quality in European cities

through developing remediation strategies, policy interventions and behavioural change initia-

tives. The project is also looking to deploy a network of air quality and meteorological sensors to

monitor impacts.30 31

The EU LIFE Programme provides further funding, for which the DCCAE is Ireland’s application

administrator. For 2014-2020, the LIFE budget was €3.4567 billion (€2.5925 billion for Environ-

ment, €864.2m for Climate Action).32 Air Quality and Emissions form a Thematic Priority for fund-

ing under the Environment Sub-programme. Thematic areas included:

• Nature and Biodiversity;

• Water, including the marine environment;

• Waste;

• Resource Efficiency, including soil and forests and green and circular economy;

• Environment and Health, including chemicals and noise;

• Air Quality and Emissions, including the urban environment; and

• Information and Governance

27 Department of Communications, Climate Action and Environment (2017) Cleaning Our Air: Public Consul-

tation to inform the development of a National Clean Air Strategy 28 Environmental Protection Agency (EPA) (2018) EPA Research Awards 2017, accessed 17 December 2018,

http://www.epa.ie/researchandeducation/research/epafunding/researchawards/ 29 EPA (2018) EPA Research – Climate Research Call 2018 Technical Description 30 Environmental Protection Agency (EPA) (2018) International Linkages, accessed 17 December 2018,

http://www.epa.ie/researchandeducation/research/internationallinkages/%23.VpfPN7Gvncs 31 Trinity College Dublin (2018) iSCAPE : Improving the Smart Control of Air Pollution in Europe, accessed 17

December 2018, https://www.tcd.ie/civileng/research/environment/air/iscape.php 32 Thighearnáin, S.N. (2014) LIFE Programme 2014-2020: Opportunities for Environment & Climate Action

Projects

http://www.epa.ie/researchandeducation/research/epafunding/researchawards/

http://www.epa.ie/researchandeducation/research/internationallinkages/%23.VpfPN7Gvncs

https://www.tcd.ie/civileng/research/environment/air/iscape.php



March 2019 19

It is unclear what portion of funds goes directly to Air Quality and Emissions in relation to the

other thematic priorities listed.



March 2019 20

3 FINDINGS


mentation of the AAQDs in Ireland. Specifically, the chapter focuses on the challenges and suc-

cesses encountered in the implementation of the Directives. Additionally, the relevance of the

AAQDs, and their air quality standards, has been explored. Finally, the chapter identifies the

factors underlying compliance with and effectiveness of the AAQDs and provides an overview of

the costs and benefits associated with the implementation of the Directives.


Ireland’s air quality is generally considered as good, with recorded concentrations of all relevant

pollutants at monitoring points within the limit values of the AAQ Directives in 2017. Despite this,

both the EPA and DCCAE commented in interview that limit values are one of the most important

requirements of Directive in relation to the needs of Irish citizens but highlighted the importance

of the levels at which limits are set. In their response to the targeted questionnaire, the EPA

scored the relevance of the AAQ Directives in addressing the current needs of Irish citizens as

three out of five. They noted that limit values for NO2, ozone and PAH are still very relevant, due

to their near alignment with WHO air quality guidelines. For PM2.5 and PM10, they also highlighted

the discrepancies between EU limit values and WHO guideline values suggesting they are there-

fore less relevant as Irish authorities now refer to the WHO Air Quality Guideline values due to

their stringency. Ireland is below the lower assessment threshold for PM2.5 though exceeds WHO

guidelines. The EPA commented in their questionnaire response that they would welcome the

adoption of stricter standards across Europe for these pollutants, and that limit values should

decrease over time.

With regards to the relevance of pollutants included, it was suggested by the EPA in their ques-

tionnaire response that the AAQDs should be expanded to include PM1, which would hold greater

relevance for Ireland. Support for inclusion of PM1 was also given by DCCAE in interview. The EPA

also noted that academic research has suggested that Ammonia and Black Carbon should also be

included.

In terms of redundancy of pollutants, the EPA and Dublin City Council noted that SO2 is not par-

ticularly relevant to Ireland as there is not a large amount of industry and so concentrations are

relatively low. The EPA additionally suggested that CO might not be relevant due to low concen-

trations.

Despite Ireland’s lower levels of air pollution relative to EU limit values, WHO air quality guidelines

were exceeded at monitoring sites for O3 and NO2, and both the EPA and DCCAE noted in interview

that there is scope for improvement, which the AAQ Directives promote, given that there is no

safe level of exposure to pollutants such as particulate matter. Ireland is subjected to considerable

economic and life quality burdens as a result of air pollution. The health-related costs of air pol-

lution are estimated at EUR 2 billion per year with 382 000 work days lost due to air pollution-

related sickness, costing employers EUR 65 million per year.33 Alongside the economic impact, it

is estimated that air pollution in Ireland results in approximately 1,200 premature deaths per

year.34

33 European Commission (2017) EU Environmental Implementation Report - Ireland, accessed 12 December

2018, http://ec.europa.eu/environment/eir/pdf/report_ie_en.pdf 34 http://www.epa.ie/irelandsenvironment/air/

http://ec.europa.eu/environment/eir/pdf/report_ie_en.pdf

http://ec.europa.eu/environment/eir/pdf/report_ie_en.pdf

http://www.epa.ie/irelandsenvironment/air/

http://www.epa.ie/irelandsenvironment/air/



March 2019 21

All interview respondents reported that the AAQ Directives’ goals and objectives will be incorpo-

rated into Ireland’s first National Clean Air Strategy, which is currently under development, and

are also incorporated within all air quality plans as well as local strategies such as transport poli-

cies. The EPA also noted the AAQ Directives have been relevant as they drive the need for im-

provement of air quality in Ireland, and have led to the development of the National Strategy.

The EPA further noted in their response to the targeted questionnaire that while large urban areas

such as Dublin were relatively well served in terms of monitoring, the introduction of the AAQ

Directives was the impetus to assess air quality in more rural locations.

Despite the considerable health impacts associated with air pollution in Ireland, the Eurobarome-

ter data (Figure 3-1) shows that Irish citizens hold the most positive perceptions of air quality of

the EU28. Only 17% believe that air quality has deteriorated in the last 10 years, while 33%

suggest it has improved, the highest proportion in the EU.

Figure 3-1 Results of the 2012 study into Attitudes of Europeans towards Air Quality for Ireland

Source: Eurobarometer 2012 - Attitudes of Europeans towards Air Quality 35


Key implementation successes can be summarised as follows:

• Good information provision

• Good collaborative working

• Development of National Ambient Air Quality Monitoring Programme 2017-22

• Development of first National Clean Air Strategy

• Development of local plans

3.2.1 Good information provision to the public on the state of air quality

The EPA makes available to Irish Citizens information on air quality via a range of media. The

details and strengths of these are covered in more detail below.

Air Quality Index for Health (AQIH)

Developed by the EPA, the AQIH uses numbers from one to 10 to indicate the current air quality

in a particular region and whether it has health implications, both for adults and children. One to

ten correspond with good to very poor. The AQIH is calculated every hour. Readings are displayed

35 Public Opinion - European Commission, accessed 19 December 2018, http://ec.europa.eu/commfrontof-

fice/publicopinion/index.cfm

0% 20% 40% 60% 80% 100%

Ireland

EU28

Do you think that, over the last 10 years, the air quality in Ireland has...?

Don't know Deteriorated Stayed the same Improved

http://ec.europa.eu/commfrontoffice/publicopinion/index.cfm






March 2019 22

on an interactive colour-coded map and on Twitter. Using the index involves identifying the ap-

propriate AQIH region, of which there are six, and reading the health advice for the current AQIH

for the selected region. The AQIH is based on data from air quality monitoring stations.36 With

the planned expansions to the monitoring network, the EPA aims to generate a more localised,

and thus improved, dataset.

Furthermore, the AQIH can be used by health professionals to advise patients who are sensitive

to air pollution. The health advice provided is based on WHO guidelines and is categorised ac-

cording to two groups: the general population and those at risk from air pollution.

Periodic Air Quality bulletins and reports

As Ireland’s air quality monitoring network increases its coverage, localised high-resolution data

will increasingly be available. The EPA collates the data into annual reports on air quality, which

contain trend analyses for NOx, O3, PM10 and PM2.5, PAH and other trace pollutants. The reports

contextualise Ireland’s situation in relation to EU limit values (annual and hourly) and the more

stringent WHO guidelines. Data will often be displayed for the previous 10 years, showing trends

for different pollutants. The reports include discussions on sources of different pollutants, and

make some points on how these could be addressed.

The EPA also publish air quality bulletins, which include information on any breaches of pollutant

limits at each monitoring station. Stations are described as being urban, suburban, or rural and

levels of traffic are indicated. The number of breaches is displayed for each station, as well as the

EU stipulation for the allowed number of breaches. The EPA only publish bulletins for NO2, O3 and

PM10.

Citizen engagement and citizen science (CE&CS)

The EPA reports that as part of the 2017 – 2022 AAMP it is increasing its activities in relation to

public engagement and education. In particular, through collaboration with partners in education.

For example, AMMP aims to grow CE&CS resources, develop more CE&CS programmes and build

on previous successful partnerships with the National College of Art and Design and INTEL in order

to trial new technologies. In addition, the EPA reported in interview that it already uses social

media (Twitter) to interact with and engage citizens.

Historic Air Quality data from monitoring stations

For Ireland’s monitoring network, historic data can be accessed for all of the pollutants the mon-

itoring station measures, from the date the measurements began. This is made available in

datasheets per pollutant, that each cover three months. The datasets are broken down into daily

concentrations. Data is made available through the EPA’s Secure Archive for Environmental Re-

search Data (SAFER-Data) portal.

36 Environmental Protection Agency (EPA) (2018) What is the Air Quality Index for Health?, accessed 12

December 2018, http://www.epa.ie/air/quality/index/

http://www.epa.ie/air/quality/index/



March 2019 23

Information web-developers can access for 3rd party reporting solutions

Developers are able to access data in a JSON format, which is a dynamically generated feed of

the Air Quality Index for Health. This JSON feed can be freely used, and integrated into applica-

tions or software (with recognitions that the EPA is the source). The feed is re-calculated on an

hourly basis.

This data feeds into publicly accessible apps such as BreezoMeter,37 which formats the data into

clear indicators for people to use in a similar fashion to weather forecasts. A number of websites

also use the JSON feed combined with weather data to forecast air quality for several days in

advance. Although the forecasting is not provided by the EPA, making data available in a format

which allows third parties to provide forecasting services is an important step on from relying on

point-in-time data. Through the use of forecasts, those who are particularly vulnerable to air

pollution (possibly due to age or illness) are able to plan several days in advance, thus avoiding

areas with severe forecasts.

Real-time localised Particulate Matter Monitoring data

In interview, the EPA reported that the number of sites that are capable of monitoring and pub-

lishing real-time PM data was increased during 2017 and that the 2017-2022 AAMP will provide

real-time PM measurements at all but one station.

3.2.2 Good collaborative working

Interviewees all reported a strong and productive culture in Ireland of collaborative partnership

working on air quality between Irish Authorities and institutions at multiple levels. At an interna-

tional level, DCCAE reported in interview that Ireland has dialogues with neighbouring countries

on air quality and attend meetings organised by the European Commission regarding broader air

quality work including Long-range Transboundary Air Pollution (LRTAP) and the EPA reported that

they have good links with other relevant national authorities through the European Monitoring

and Evaluation Programme (EMEP) network. Additionally, Dublin City Council is a part of EEA’s

Air Implementation Pilot.

At a national level, the EPA and DCCAE reported in interview that working in partnership functions

well in Ireland, with the two organisations working together extensively to develop national-level

strategy, conduct stakeholder consultation and keep the public informed of policy changes and

progress on implementation. The EPA also works with Met Éireann and academic institutions on

modelling and research. Additionally, DCCAE and the EPA are collaborating with other government

departments to ensure an integrated approach is taken to air quality improvement through avoid-

ing conflicts between department priorities in the development of the NCAS. This is in part facili-

tated by DCCAE’s National Air Pollution Control Programme which exists to foster coordination

between NEC Directive, the AAQ Directives and climate change policies.

At a sub-national level, the EPA reported that development of the 2017-2022 National AAMP has

involved all local authorities and DCCAE working together. Dublin City Council reported in inter-

view that they have provided detailed input through the public consultation on the AAMP, and are

having ongoing discussions with EPA and DCCAE.

On a more routine basis, the EPA and Dublin City Council reported in interview that LAs across

Ireland and the EPA collaborate extensively to establish monitoring networks locally, develop

37 https://breezometer.com/

https://breezometer.com/



March 2019 24

plans to tackle local Air Quality problems, and execute these plans. This work is substantially co-

ordinated by the NIECE network - Ireland’s Network for Enforcement and Compliance. This in-

volved collaborating through asset sharing, supporting on location selection, and two-way data

sharing according to Dublin City Council. Local authorities, including Dublin City Council, are also

engaging in collaborative research activities with their local research institutions.

3.2.3 Development of National Ambient Air Monitoring Programme 2017-22

As mentioned in section 2.4, the EPA has recently completed consultation on a new Ambient Air

Monitoring Programme which sets a roadmap for improvement of the assessment of air quality

from 2017 – 2022. It will expand the network of monitoring stations which is intended to provide

the capacity for real-time air quality information to inform forecasting and modelling which will

supplement monitoring for assessment of air quality. DCCAE commented in interview that the

development of modelling capacity is intended to increase the spatial resolution of assessment,

in order to provide more accurate information on exposure.

Additionally, the EPA commented in interview that the new programme also aims to improve

citizen engagement, in part through access to health advice linked to air quality information.

3.2.4 Development of first National Clean Air Strategy

As mentioned in section 2.4, the Department of Communications, Climate Action and Environment

is currently leading development Ireland’s first National Clean Air Strategy (NCAS). The DCCAE

reported in interview that this plan will incorporate AAQ Directives’ goals and objectives alongside

other sectoral policies related to air quality, including;

• industrial emissions;

• domestic emissions;

• transport; and

• agriculture.

As part of developing this plan, DCCAE are coordinating with other departments within Irish gov-

ernment to ensure an integrated approach is taken to air quality improvement. Detail on exactly

how policies will be coordinated to integrate well with other government priorities was not avail-

able as the NCAS has yet to be completed.

3.2.5 Development of Local plans

As detailed in Section 2.4, the four local authorities in Dublin produced a joint regional air quality

management plan for the 2009-2012 period after NO2 breached EU limit values in 2009. The plan

contained a number of measures to redress NO2 exceedances including;

• Regional planning guidance for the greater Dublin area; which cover public transport plan-

ning as well as built environment guidance to reduce concentrations and exposure;

• The Dublin bike rental scheme, which funds the provision of public cycling amenities;

• The Dublin HGV management strategy; which bans 5+ axle vehicle in areas vulnerable to

air pollution.

Since 2009 have been no exceedances of EU limit values for NO2 have been detected in Zone A,

though in 2016 they were close to the limit value and so Dublin City Council has continued to take

mitigation action, including promotion of public transport, active travel (bicycle schemes), and

introduction of some traffic-calming measures.



March 2019 25


Key implementation challenges can be summarised as follows:

• Limited resource availability for developing monitoring network

• Challenges related to selection of monitoring sites

• Conflict with climate policies

3.3.1 Limited resource availability for developing monitoring network

The DCCAE reported in interview that the development of Ireland’s monitoring networks for as-

sessment has been costly to set up, and funding issues was highlighted by all interviewees as a

barrier to effective implementation. Both the EPA and Dublin City Council noted that the Irish

economy was in recession at the time of implementation of the Directives, and so national funds

were limited between 2008 and 2011. Dublin City Council highlighted that Dublin has only recently

recovered from the financial crisis. DCCAE reported in interview that this lack of national funds

has been exacerbated by difficulty accessing EU funds experienced by Irish authorities. DCCAE

attributed this to a knowledge gap as to what finances are available and how to effectively apply

for them. The EPA also noted in interview that there is variation across Member States in their

proficiency in securing EU funds and suggested that EU guidelines to access funds would be helpful

for those Member States who are typically less successful in securing funds.

3.3.2 Challenges related to selection of monitoring sites

All interview respondents noted that a particular challenge is the selection of monitoring locations

to ensure accurate information is gathered representative of, inter alia, the highest levels of ex-

posure as required by the AAQ Directives. The DCCAE and Dublin City Council, in interview, and

the EPA, in their targeted questionnaire response, noted that while the Directives provide very

good documentation describing methods for monitoring and the number of sampling points re-

quired, further and more prescriptive guidance is desired on the siting of monitoring stations to

eliminate remaining ambiguity. In particular they noted criteria for classifying traffic environments

such as junctions. The DCCAE suggested in interview that such guidance from EU would increase

consistency in monitoring across different regions in the country.

Related to this, Dublin City Council in their targeted questionnaire response highlighted a concern

that there may not be sufficient spatial resolution in monitoring to identify exposure above limit

values, suggesting that hotspots could go unidentified and population exposure not accurately

quantified. They also expressed a desire that detailed guidance be provided even on such param-

eters as the height that monitoring equipment is installed at, providing the example that equip-

ment 1 meter above the ground may not accurately capture the concentration of the pollutant

microenvironment for vulnerable receptors such as children in buggies/pushchairs.

3.3.3 Conflict with climate policies

The DCCAE suggested in interview that there is currently uncertainty as to the degree to which

some climate change policies interact with, and potentially counteract, air quality policy. An ex-

ample which Irish authorities have identified is that policies on renewable heating which encour-

age use of biomass solid fuels are considered favourable from a carbon emissions-reduction per-

spective but burning of these fuels is associated with higher particulate matter emissions. DCCAE

has indicated that to mitigate the growth of residential biomass heaters, the forthcoming Support

Scheme for Renewable Heat (SSRH) will only apply to commercial operators and not to residential

operators. The EPA reported that this is recognised in Ireland. The EPA highlight that this potential

challenge should be addressed in the National Clean Air Strategy being developed, which is set to

identify the key conflicts between the AAQ Directives’ and Climate Change objectives.



March 2019 26



with and effectiveness of the AAQ Directives in Ireland. The factors have been identified through

stakeholder consultation conducted in the context of the case study.


Public and political attention to air quality problems

The EPA reported in interview that public and political attention to air quality problems has been

a key factor underling compliance with the AAQ Directives. The DCCAE also commented in inter-

view that the framing of air quality as a public health issue has meant that there has been signif-

icant pressure on public authorities to improve it. This was corroborated by Dublin City Council

who said that health considerations and advocacy for public health improvements have been a

key factor contributing to compliance. The EPA commented in interview their Open Data/Reporting

Policy which includes publication of the Air Quality Index for Health has helped to drive public

interest.

Improvements in AQ Assessment

Ireland has recently approved a new Ambient Air Monitoring Programme which sets a roadmap

for improvement of the assessment of air quality from 2017 – 2022. The EPA commented in

interview that it sees effective monitoring as key to effective implementation of the Directives

overall, noting that it is essential for identification of areas need to be targeted for air quality

improvement and see it as the main transformational change that the Directives have brought

about which has facilitating the achievement of air quality objectives. DCCAE also noted in inter-

view that it is supportive of the development of modelling capacity with the aim of increasing the

spatial resolution of assessment in order to provide more accurate information on exposures.

Introduction of measures to tackle local AQ problems

DCCAE noted that actions taken at a local level, spurred by additional requirements for air quality

improvements applied by the AAQ Directives, have been crucial in achieving the goals of the AAQ

Directives to improve air quality where it is not good. Dublin City Council in interview highlighted

their work over the last decade, including integrating air quality objectives within city master

plans for land use planning and housing development such that residential areas are sited away

from polluted locations. They also highlighted public transport as an area in which significant

progress has been made including on low emission bus fleets, the main government bus supplier

having shifted toward low-emission non-diesel vehicles.


Limited resource

As was discussed in section 3.3, the impact of the 2008 financial crisis which left Ireland’s econ-

omy in recession, on the availability of national funds was a significant hindrance to implementa-

tion of the Directives, in particular with regards to expanding the Irish monitoring network. This

economic downturn also resulted in resulted in a number of major strategic transport projects

being postponed in Dublin. On top of this, a lack of knowledge of the funding mechanisms avail-

able to support implementation of the directives, and a lack of expertise in compiling successful

grant applications, has further constrained resources available for implementation.



March 2019 27

Changing public behaviour

Dublin City Council reported in interview that a key barrier hindering effective implementation, in

particular improving air quality where it is not good, is difficulty in engaging the public in behaviour

change required. In particular they highlighted a resistance towards shifting from personal

transport to public transport and active travel, which Dublin City Council has spent the last decade

trying to reverse through encouraging use of active travel, car sharing, public transport and

through active travel and public transport infrastructure. Both the EPA and Dublin City Council

noted in interview that behind this problem of engagement is a lack of understanding of what

citizens want/need in order to encourage behaviour change. The EPA recommended that further

use of social media and awareness campaigns such as were run successfully around 30 years ago

around the time of Ireland’s smoky coal ban would be a start to facilitating greater public engage-

ment.



The EPA and Dublin City Council provided estimates of the costs of AAQ Directive implementation.

The EPA stated in their response to the targeted questionnaire that the above costs represent the

total cost of implementation of the AAQ Directives. 3-1 details the cost data provided.

Table 3-1 Costs of implementation of the AAQ Directives, as reported by the Irish EPA and Dublin City Council

Cost item Cost Cost incurred by

EPA Annual capital replacement cost €380,000 p.a. EPA

EPA Annual staff cost for AAQ Directives €493,000 p.a. EPA

Staff are involved in the other public sector-run

portion of the monitoring network

2 FTEs p.a. Not stated

EPA Annual current cost (excluding staff) €458,735 p.a. EPA

Dublin City Council monitoring infrastructure capi-

tal cost

€160,000 Dublin City Council

Dublin City Council monitoring infrastructure oper-

ating cost

€15,000 p.a. Dublin City Council

Costs of time spent by the relevant persons in-

volved in making measurements, calculations, pre-

dictions or estimations in Dublin

€300,000 p.a. Dublin City Council



March 2019 28

The sum of annual costs reported by the EPA and Dublin City Council is €1,806,735.

In addition, Dublin City Council reported that the total capital cost of additional monitoring infra-

structure required in order to meet the requirements of the Directives since 2008 in Dublin is

€160,000.

Dublin City Council reported in interview that Dublin’s air quality monitoring network was devel-

oped gradually started before the AAQ Directives, and the EPA noted in their targeted question-

naire response that major urban areas such as Dublin were well served by Local Authorities car-

rying out monitoring prior to the Directives. As a result, additional costs incurred as a result of

the implementation of the 2008 AAQD were reduced. The total capital cost of the monitoring

infrastructure in Dublin, including that not required by the AAQ Directives, was estimated by

Dublin City Council in their targeted questionnaire response at €400,000 with an operating cost

€40,000 per year. The EPA did not provide cost estimates for all monitoring infrastructure includ-

ing that not required by the AAQ Directives.


Ireland does not have an implementation gap in terms of exceedances or the sufficiency of its

monitoring network.


Currently, there is no national analysis of the valorised health benefits from implementation of

the AAQDs.

An important benefit of the AAQ Directives, as noted by the EPA in their response to the targeted

questionnaire, that they have driven the assessment of air quality in areas of the country where

there was no monitoring prior to the implementation of the Directives. While large urban areas

such as Dublin were relatively well served in terms of monitoring, the introduction of the AAQ

Directives was the impetus to assess air quality in the regions. This has facilitated the design of

policy which takes into account the varying needs and vulnerabilities of rural and urban popula-

tions.

Another important benefit of the Directives, noted by the EPA in their response to the targeted

questionnaire, is that they have focused the attention of the public and policy makers on air

quality issues, and their causes, in particular related to health. The EPA note that without the

Directives there would be much less public interest in air quality in Ireland and much less demand

to maintain it or improve it.



March 2019 29

4 CONCLUSIONS

The present chapter outlines the summary of the main findings of the case study regarding the

main implementation challenges the potential for improving the implementation of the Directives

in Ireland. Finally, a summary of the evaluation of the AAQDs is presented.


the Directives

The case study identified the following challenges in the implementation of the AAQ Directives:

• Limited resource availability for developing monitoring network, in particular difficulty ex-

pressed by Irish authorities regarding accessing the funding sources available particularly

regarding how best to apply for them;

• Challenges related to selection of monitoring sites, noting that more prescriptive guidance

and oversight is desirable to reduce ambiguity but that existing knowledge sharing platforms;

• Conflict with climate policies, noting that there is uncertainty as to the full range of conflicts

but that action has been taken on some conflicts related to climate change policies targeting

renewable heating.



relevance, effectiveness, efficiency, coherence and EU added value of the AAQDs.

4.2.1 Relevance

A Despite Ireland’s good performance relative to EU limit values, WHO air quality guidelines were

exceeded at monitoring sites for O3 and NO2, with national authorities perceiving scope for im-

provement and desiring a move to stricter and more challenging targets, given the considerable

economic and life quality burdens that result from air pollution in Ireland. Additionally, air quality

is a concern to Irish citizens, with 17% believing it has deteriorated over the last decade, though

this is the lowest of any EU Member State.

Regarding the relevance of air quality standards and limit values, it was suggested that the AAQDs

should be expanded to include PM1, which would hold greater relevance for Ireland and that SO2

is not particularly relevant to Ireland as there is not a large amount of industry and so concen-

trations are relatively low.

Overall, although some pollutants and limit values are seen as less relevant to Ireland, the ob-

jectives and aims of the Directives are still relevant to the needs of Irish citizens.

4.2.2 Effectiveness

The findings of the case study indicate effectiveness of the AAQDs in maintaining and improving

air quality in Ireland. According to the most recent European Environment Agency Country Fact-

sheet on Ireland38 none of Ireland’s urban population was exposed to pollutant concentrations

above the EU’s limit values from 2014 – 2016 for NO2, O3, BaP or particulate matter. Ireland’s

38 Ireland – air pollution country fact sheet 2018, accessed 19 December 2018, https://www.eea.eu-

ropa.eu/themes/air/country-fact-sheets/ireland



March 2019 30

authorities now refer in reports such as annual air quality reports to WHO guidelines for most

pollutants as these are more relevant to concentration levels in Ireland.

The findings indicate that the factors underlying compliance with the AAQDs in Ireland include:

1) public and political attention to air quality problems in particular driven by attention to health

impacts and a desire to protect and improve public health, 2) improvements in AQ Assessment in

particular in Zones 3 and 4, which have allowed air quality policies to be effectively implemented

alongside potential conflicting policies and 3) introduction of measures to tackle local AQ problems

including integrating air quality considerations into broader planning policies and reducing emis-

sion from local transport. In contrast, the case study identified two key factors hindering compli-

ance, including: 1) difficulty changing public behaviour in particular related to home heating fuel

choices as well as update of public transport and active travel and 2) lack of resources and staff,

in particular driven by difficulty accessing EU funding streams.

4.2.3 Efficiency

There are currently no economic analyses of the costs of implementation of the AAQDs in Ireland,

however, Dublin City Council were able to provide an estimate that €160,000 of capital cost has

been incurred for monitoring infrastructure required for compliance with the AAQ Directives, and

that this has created an additional €15,000 of operating costs per year for the monitoring infra-

structure in Dublin.

Given the lack of sufficient cost data, a more detailed assessment of efficiency cannot be under-

taken at this time.

4.2.4 Coherence

The AAQ Directives have prompted the roll out of monitoring infrastructure into urban areas other

than Dublin and in rural areas which will be expanded with the implementation of the new 2017

– 2022 AAMP to develop a comprehensive national system employing common methods for as-

sessing air quality.

The case study has highlighted a strong and productive culture of collaborative partnership work-

ing on air quality between Irish Authorities and institutions at an international, national and sub-

national level. This has facilitated the integration of air quality objectives into a broad range of

linked policy areas including urban planning and climate change, suggesting that the AAQ Direc-

tives have been cohesive with other areas of policy.


As outlined above, the EPA, in their response to the targeted questionnaire, noted that the role

that the AAQ Directives have had in driving the assessment of air quality in areas of the country

where there was no monitoring prior to the implementation of the Directives is seen as a key part

of their added value. This has facilitated the design of policy which takes into account the varying

needs and vulnerabilities of rural and urban populations.

Another important benefit of the Directives, noted by the EPA in their response to the targeted

questionnaire, is that they have focused the attention of the public and policy makers on air

quality issues, and their causes, in particular related to health. The EPA note that without the

Directives there would be much less public interest in air quality in Ireland and much less demand

to maintain it or improve it.



March 2019 31



March 2019 32

APPENDIX A INTERVIEWS


Department of Communications, Climate Action & Environment 26/11/2018

Department of Communications, Climate Action & Environment 26/11/2018

Dublin City Council 27/11/2018

Dublin City Council 27/11/2018

Environment Protection Agency, Ireland 29/11/2018



March 2019 33

APPENDIX B PILOT INTERVIEW GUIDE

General questions




learn from?


tives?



exchange, etc.)?



Specific questions



RELEVANCE

(1) How relevant are the goals and objectives of the

AAQ Directives to the needs of citizens; do the AAQ

Directives still address the most relevant pollutants

and set relevant standards and obligations to protect

human health and the environment; and are the AAQ

Directives sufficiently adapted or adaptable to evolv-

ing technical and scientific progress?


spond to the needs of the citizens (in your country)?



zens' needs?

To what extent have the goals of the Directives been

integrated in the strategic documents (on environ-

mental protection) in your country?




become redundant?

EFFECTIVENESS



March 2019 34


(3) What factors have contributed to meeting the ob-

jectives of the AAQD or to failing to meet these ob-

jectives, in terms of: 1) defining common methods

to monitor and assess air quality; 2) assessing am-

bient air quality in order to monitor trends; 3) estab-

lishing standards of air quality to achieve across the

EU; 4) ensuring that information on air quality is

made public; 5) maintaining good air quality, im-

proving it where it is not good; to what level can

these factors be attributed to provisions of the AAQ

Directives?

What are the main factors that contribute to compli-

ance with/effective implementation of the air quality

Directives; hereunder:





grammes


mation to public?



cal) level preventing effective implementation of the

air quality Directives? Please consider each of the

items listed above separately.


EFFICIENCY



the AAQ Directives in the Member States, and in the

EU; have the benefits (improved air quality) been

achieved in a cost-effective manner and to what ex-

tent have costs been equitably distributed across dif-

ferent sectors?


Directives?


porting, and planning) for different levels of govern-

ment, including the use of external expertise on, per

year (in FTE)?

What is the cost of implementation for different sec-

tors of the industry per year (capital and operating

costs of equipment in EUR)?



tives?

What are the costs of non-implementation of the Di-

rectives (e.g. environmental and health costs, un-

certainty and market distortion, litigation costs for

Member States)?


tion of the Directives in the Member State/air quality

zone (e.g. health and environmental benefits, eco-

nomic benefits, eco-innovation, etc.)?


tween Member States and/or between different sec-

tors and/or as regards costs to stakeholders (includ-

ing social costs as a consequences of poor imple-

mentation), what is causing them; and are the costs

of compliance proportionate to the benefits brought

by the directives?


sessment regimes, what are the administrative costs

to the Member States and to the Commission; taking

account of the objectives and benefits of the direc-

tives is there evidence that they have caused unnec-

essary or excessive administrative burden?



global economy; has the implementation of the AAQ

Directives improved or been detrimental to eco-

nomic, social and environmental sustainability?

COHERENCE



March 2019 35





EU level and at Member State level (such as the NEC

Directive and IED Directive as well as the EU climate

legislation and policy; and how do these policies and

legislation support or hamper the implementation of

the EU air quality legislation?

How and to what extent is the implementation of the

AAQ Directives coordinated with the implementation

of other EU instruments in the environmental and

climate domain (e.g. the National Emissions’ Ceiling

Directive, the Industrial Emissions’ Directive, Large

Combustion Plants Directive, etc.)?





riculture, cohesion, fiscal policies); and how do these

policies support or hamper the implementation of

the EU air quality legislation?





Are air quality plans coordinated with planning initi-

atives promoted by EU sectoral legislation (e.g. Sus-

tainable Urban Mobility Plans, TEN-T investments)?

Are air quality plans coordinated with national emis-

sion reduction plans and measures under the NEC

Directive?


change mitigation policies and plans (for GHG emis-

sion reductions)?



e.g. in the area of land use and spatial planning, en-

ergy management, transportation and climate?




ADDED VALUE



parable air quality assessment, management and in-

formation approaches enabled Member States and

their competent authorities to take successful action

to improve beyond what would have been possible

without EU action?



quality objectives?


in monitoring?








plementation create synergies or overlaps with other

Community objectives, and how has the distribution

of responsibilities between EU, Member State, re-

gional and local levels impacted on air quality man-

agement?

How is the implementation of the AAQ Directives co-

ordinated in the Member State (division of responsi-

bilities, coordination across different activities)?






March 2019 36

APPENDIX C EU FUNDED PROJECTS

Project Number

Project Title Organisation

2013‐EH‐FS‐7

Development of a spatially‐ and temporally‐re-

solved emission inventory for Ireland

University of Dublin, Trinity Col-lege (TCD)

2013‐CCRP‐FS.15

CRiMsON (Consolidation of IRelands Green-house Gas and Transboundary MOnitoring Network)

National University of Ire-land Galway (NUIG

2013‐EH‐MS‐14

Assessment of the impact of ammonia emis-sions from intensive agriculture installa-

tions on SACs and SPAs

University College Dublin (UCD)

2013‐EH‐MS‐15

Source Apportionment of Particulate Matter in Ru-

ral and Urban Residential Areas (SAPPHIRE)

University College Cork (UCC)

CCRP‐09‐FS‐4‐2

Research support for integrated atmospheric stud-ies at Mace Head

National University of Ire-land Galway (NUIG)

2011‐CCRP‐MS‐4.5

Emission Factors for Domestic Solid‐Fuel Appli-ances (EFDOSOF)

University College Dublin (UCD)

2012‐CCRP‐MS.7

Critical Loads and Dynamic Soil‐Vegetation Modelling Trent University

2012‐EH‐FS‐6

Air quality modelling University of Dublin, Trin-

ity College (TCD)

2013‐CCRP‐MS.14

Integrated Modelling Project ‐GAINS Ireland APEnvEcon

2014‐CCRP‐MS.19

On‐Line BioAerosol Sampling (OLBAS) University College Cork (UCC)

2015‐CCRP‐MS.26

National mapping of GHG and non‐GHG emissions sources

Aarhus University

2015‐CCRP‐FS.24

Exploiting the vast remote sensing capabili-

ties at Mace Head to understand Irish air quality

National University of Ire-

land Galway (NUIG)

2015‐CCRP‐MS.29

Particulate Matter from Diesel Vehicles: Emis-

sion and Exposure in Ireland.

University of Dublin, Trin-

ity College (TCD)

2016‐CCRP‐

MS.31

AEROSOURCE National University of Ire-

land Galway (NUIG)

Written by Tony Zamparutti March 2019

CASE STUDY REPORT

ITALY



(2008/50/EC, 2004/107/EC)



(2008/50/EC, 2004/107/EC)

March 2019 2

Contents

1 Introduction 4


2.1 Italy and air quality zone characteristics 5






3 Detailed findings 20





AAQ Directives 30


4 Conclusions 36






(2008/50/EC, 2004/107/EC)

March 2019 3

Appendices




Appendix D Pollutant concentration data for Italy, 2013-17



(2008/50/EC, 2004/107/EC)

March 2019 4

1 INTRODUCTION

This report summarises the findings and conclusions of the case study for Italy. The case study

had a focus on the Sicily region.






and of non-implementation of the legislation and the administrative burden of implementation and

opportunities for improving implementation without compromising the integrity of the purpose of

the Directives. As such, the case study complements the information gathered through other

sources, such as desk review, targeted questionnaire, open public consultation, interviews, focus

groups and stakeholder workshops.







the case study







in Appendix A.






(2008/50/EC, 2004/107/EC)

March 2019 5


The present chapter contains general information about the air quality framework in Italy.

2.1 Italy and air quality zone characteristics


The case study covers the entire territory of

Italy and focuses in particular on the Sicily

region.

Italy’s territory is divided into 21 agglomer-

ations and 81 zones1 for the purpose of as-

sessing air quality for PM10 and NO₂.

Italy’s regions (plus the two autonomous

provinces) play a key role in implementing

the AAQD: according to national legislation,

they are responsible for the assessment of

air quality and the implementation of air

quality measures (see section 2.3 below for

further information on responsibilities). The

agglomerations and zones are identified

within Italy’s regions and autonomous prov-

inces and do not cross their boundaries.

Sicily is one of Italy’s 20 regions. Its popu-

lation is 5.1 million (Eurostat data for

2017). Sicily contains three agglomerations

and two zones for the purposes of the AAQD

for PM10 and NO2 (see Figure 2-2 below;

please note that the figure also presents

the Calabria region, which is not a focus

here). Please also see Text box 2-1 below

for details on Sicily.

1 Data (reference year 2017) sent by ISPRA.


Source: ISPRA, Analisi dei trend dei principali inquinanti

atmosferici in Italia (2008-2017), Rapporti 203/2018,

published February 2019

Notes: dark lines represent regional boundaries, light

lines represent zone/agglomeration boundaries



(2008/50/EC, 2004/107/EC)

March 2019 6

Figure 2-2 Air quality zones for Sicily (and Calabria), NO2 and PM10


2014): Italy.

Note: the map covers both the Sicily and the Calabria regions.

2.1.2 Geomorphology

Italy’s complex geomorphology encompasses two major mountain ranges, the Alps and the Ap-

ennines and two large islands (Sardinia and Sicily). Approximately 35% of Italy’s land area is

mountainous, over 600m above sea level; a similar share is hilly (up to 600m)2. Settlements are

found mainly in the plains, in valleys and along the coastline.

In northern Italy, the Po Valley, in particular its large alluvial plain, is largely surrounded by

mountains, which together with frequent temperature inversions trap air pollution. The Po Valley

is the site of intensive agricultural, industrial and economic activities, as well as extensive urban

sprawl. All these factors exacerbate air quality problems3. In other parts of Italy as well, major

urban areas such as Florence and Naples have sprawled across plains and are at least partially

surrounded by mountains. During summer across nearly all of Italy, high temperatures which

enhance the rate of ozone formation are often associated with slow-moving, high-pressure

weather systems, leading to major episodes of high ozone concentrations.

The Sicily region has one major island whose interior is hilly and mountainous. Most of the region’s

urban areas are found on the coast, including Palermo in the north, Trapani on the west coast,

Agrigento on the south and Syracuse, Catania and Messina on the east coast. The region also

2 Nicolini G. et al, The Italian mountains, Unasylva (Vol. 53 no. 1, 2002 International Year of Mountains) FAO, available at: http://www.fao.org/docrep/004/Y3549E/y3549e16.htm 3 Masetta M. et al, Urbanization Affects Air and Water in Italy's Po Plain, EOS Earth and Space Science

News, 23 October 2015. Available at: https://eos.org/project-updates/urbanization-affects-air-and-water-

in-italys-po-plain

NASA, Smog or Fog? Actually, a Bit of Both, NASA Earth Observatory, 2014. Available at: https://earthob-servatory.nasa.gov/images/84701/smog-or-fog-actually-a-bit-of-both

http://www.fao.org/docrep/004/Y3549E/y3549e16.htm

https://eos.org/project-updates/urbanization-affects-air-and-water-in-italys-po-plain




https://earthobservatory.nasa.gov/images/84701/smog-or-fog-actually-a-bit-of-both






(2008/50/EC, 2004/107/EC)

March 2019 7

includes several minor islands, including the Aegadian Islands to the west of the main island, the

Aeolian Islands to the north, and Pantelleria and Lampedusa to the south.

The detailed characteristics of Italy and of the Sicily region are presented in the text box below.

Text box 2-1 Italy and the Sicily region

Italy

GDP per capita in PPS (100=EU28 avg) (2017) 96

GDP per capita growth

(% 2008-2016)

-6.4%


Governance structure Unitary / regionalised4


Sicily region

Number of inhabitants: 5 056 641 (Sicily region)

GDP per capita in PPS (100=EU28 avg) (2017) 60

Area: 25 833 km² (Sicily region)

Characteristics of the Sicily region:

For implementation of the AAQD, Sicily has been divided into three agglomerations and two zones.

The agglomeration of Palermo (IT1911) contains the city of Palermo and surrounding municipalities. Its

total population (2016) is 811,121. Road traffic is a key source of air pollution emissions. Among other

sources is Palermo’s port.

The agglomeration of Catania (IT1912) contains this city and 10 surrounding municipalities. Its total pop-

ulation (2016) is 497,303. As in Palermo, road traffic is a key source of air pollution emissions. Other

sources include particulates from Etna, the volcano.

The agglomeration of Messina (IT1913) contains the territory of this city, with a total population (2016)

of 252,503.

The industrial areas zone (IT1914) zone contains 31 municipalities characterised by high levels of in-

dustry. The municipalities are found across 7 non-contiguous groups. The main industrial facilities are

mainly large plants and include refineries, power stations and cement kilns.

The other zone (IT1915) contains the remaining regional territory.



Population on 1 January; ARPA Sicilia, Relazione annuale sullo stato della qualità dell’aria nella Regione Sicil-

iana anno 2017 (Annual report on the state of air quality in the Sicily Region, 2017), June 2018; ARPA Sicilia,

Piano Regionale di Tutela della Qualità dell’Aria (Regional plan for the protection of air quality), July 2018

4 For further details see: Committee of the Regions, at: https://portal.cor.europa.eu/divisionpowers/coun-tries/MembersLP/Italy/Pages/default.aspx

https://portal.cor.europa.eu/divisionpowers/countries/MembersLP/Italy/Pages/default.aspx






(2008/50/EC, 2004/107/EC)

March 2019 8


The following section presents briefly the arrangements made in Italy for air quality monitoring

and provides a short overview of air quality achievements in Italy, including the most recent

annual monitoring results published at national level. Further information regarding air quality, as

reported in the EEA database5, is presented in Appendix D to this report.


Italy’s regions and autonomous provinces are responsible for monitoring; their environment agen-

cies lead this work. At national level, ISPRA – Italy’s national Institute for Environmental Protection

and Research (ISPRA, Istituto Superiore per la Protezione e la Ricerca Ambientale) – within the

framework of the recently established National Environmental Protection System (see section 2.3

below), provides technical guidance and coordinates the work of the regional environmental au-

thorities (ARPAs).

Monitoring stations in cities are operated by several types of entities, including the regional envi-

ronment agencies, municipal governments and, in major industrial areas, the operators of large

industrial facilities, which operate some stations for the purposes of monitoring under the AAQD6.

This reflects the system that grew up in previous decades, where municipalities had a leading role

in monitoring air quality. In recent years, based on national guidance, the regions have worked

to address gaps in the monitoring networks, establish common methods across monitoring sta-

tions operated by different entities and ensure that the stations are linked into a network.

Sicily reported a total of 47 monitoring stations in 2013 and 2014, according to the European

Commission’s Atlas. From 2015 on, however, the regional environment agency (ARPA) has used

a more limited number – 35 stations – for its air quality network for data reported to the EU level,

according to an interview with an ARPA official. One key reason is that some existing stations

established by lower authorities (provinces and municipalities) on the basis of old legislation were

assessed as redundant for the needs of Italy’s current requirements and those of the AAQD (Italian

Legislative Decree 155/2010, transposing Directive 2008/50/EC). At the same time, new stations

and capacity to monitor additional pollutants have been needed. The existing monitoring network,

for example, contained a high number of stations in traffic areas and an insufficient number of

urban and suburban background stations7.

To address these issues, ARPA together with the regional government prepared a programme to

improve the region’s air quality network. The upgrade is to be carried out via a Project to improve

the regional air quality monitoring network and its relative evaluation programme8. The project,

developed in 2014, foresees a total of 54 stations in the regional network. Of these, 38 were in

place in 2015; however, 3 of the 38 were not operating9. Of the 35 stations in operation, the

regional environment agency managed 8 stations, local governments operated 24 and a power

5 http://cdr.eionet.europa.eu/it/eu/aqd 6 Industrial facilities also monitor their emissions as per requirements under the EU Industrial Emissions Di-

rective and national or regional legislation. 7 ARPA Sicilia, Piano Regionale di Tutela della Qualità dell’Aria (Regional plan for the protection of air

quality), July 2018 8 Regione Sicilia e ARPA Sicilia, 2014, Project to improve the regional air quality monitoring network and its

relative evaluation programme at: http://pti.regione.sicilia.it/portal/pls/portal/docs/27562382.PDF. 9 Arpa Sicilia, Annuario 2015, Qualita’ dell’aria, at:

http://pti.regione.sicilia.it/portal/pls/portal/docs/27562382.PDF http://www.arpa.sicilia.it/wp-con-tent/uploads/2017/01/capitolo-02-Qualita-dellaria.pdf

http://cdr.eionet.europa.eu/it/eu/aqd

http://pti.regione.sicilia.it/portal/pls/portal/docs/27562382.PDF



http://www.arpa.sicilia.it/wp-content/uploads/2017/01/capitolo-02-Qualita-dellaria.pdf






(2008/50/EC, 2004/107/EC)

March 2019 9

company operated 3 stations (these three, however, did not transmit data directly to the regional

network).

The project calls for: the establishment of new stations, including two for regional background

monitoring; the update of existing stations to monitor additional pollutants; the repositioning of a

few stations to better meet requirements (i.e. those set in national Legislative Decree 155/2010,

transposing Directive 2008/50/EC); the modernisation of the system to acquire and transmit data

from the monitoring stations, linking them in a common network10.

The project is to be co-funded by Sicily’s Operational Programme. It was launched in June 2017

and should have been completed in 2018. As of late 2018, however, funding for the project had

not yet been released (see also section 3.2.1). A representative of ARPA explained that the con-

tract needed to be revised – as preliminary work showed that the conditions of some stations

were not as good as expected – and as a result in 2018 the project was at a temporary standstill

(see also section 2.3); the representative expected that the issues would be resolved in the first

quarter of 2019, in which case the improvements to the regional network would be completed by

2019.

The table below compares the monitoring stations in place in 2013/14 (according to information

reported to the European Commission) with the stations planned under the project and thus shows

the intended changes in the monitoring network. As noted, however, the project was at a tempo-

rary standstill in 2018: as a result, these changes had not yet been undertaken.

Table 2-1 Sicily’s monitoring network: stations reported in 2013/14 vs. planned network improvements

Agglomeration or zone Monitoring stations:

2013 / 14 *

Planned changes:

total stations **

Palermo (IT1911) 9 7

Catania (IT1912) 5 5

Messina (IT1913) 0 2

Industrial zone (IT1914) 26 31

Other zone (IT1915) 7 9

Total 47 54

Sources: European Commission, DG Environment, Atlas of air quality zones and monitoring stations (2013 &

2014): Italy; ARPA Sicilia, Piano Regionale di Tutela della Qualità dell’Aria (Regional plan for the protection of

air quality), July 2018

Notes: * As explained in the text, not all stations reported for 2013/14 were used for the regional monitor-

ing network and for reporting air quality monitoring results to the EU.

** Includes stations that will be upgraded and new stations.

2.2.2 Air quality in Italy

Many agglomerations and zones in Italy, in particular urban areas in northern Italy (i.e. in the Po

Valley), see exceedances of EU target values and limit values for air pollutants.

10 ARPA Sicilia, Piano Regionale di Tutela della Qualità dell’Aria (Regional plan for the protection of air quality), July 2018



(2008/50/EC, 2004/107/EC)

March 2019 10

According to EEA data11, the limit value (days of exceedance in a calendar year) for PM10 was

exceeded in 31 zones and agglomerations: mainly in the Po valley, though also around several

zones and agglomerations in central and southern Italy. The annual limit value for PM2.5 was

exceeded in 13 zones and agglomerations in 2017, all in the Po Valley. The annual limit value for

NO2 was exceeded in 25 zones and agglomerations in 2017, mainly in the Po Valley but also in

major urban areas in central and southern Italy including Florence, Rome and Naples.

The daily target value for ozone was exceeded in 50 zones and agglomerations in 201712, and the

long-term objective for ozone was exceeded in 58 zones and agglomerations that year. These

exceedances occur throughout Italy.

The target value for BaP was exceeded in 19 zones and agglomerations, including major urban

areas in the Po Valley, as well as some mountain areas in northern and central Italy. EEA data

does not indicate exceedances for other pollutants in 2017.

ISPRA reports that pollutant concentrations have fallen slowly over the past decade13: nationwide,

PM10 levels fell an average of 16% from 2007 to 2015, and NO2 levels fell 19% over the same

period; PM2.5 levels fell 5% from 2009 to 2015.

Despite some improvements, data show that a high share of Italy’s population is still exposed to

air quality above limit values. In 2013, according to the European Commission’s Environmental

Implementation Review of Italy14, over 60% of Italy's urban population lived in areas exposed to

PM10 concentrations over the daily limit value, compared to an EU average of 16%. This proportion

decreased in 2016, when 44% of Italy's urban population lived in areas exposed to PM10 concen-

trations over the daily limit value15.

ISPRA reports16 that critical loads for eutrophication depositions were exceeded across the Po

Valley, and northern Italy also has locations with high levels of Cadmium deposition on cropland.

Ozone pollution can also affect rural areas: a study of urban areas in southern Europe, including

two in Italy, noted that high levels of sunshine contribute to the formation of ozone; frequent sea-

land breezes transport ozone from urban areas to inland regions17.

While ambient levels of pollutants have fallen slowly, emissions of air pollutants have fallen sig-

nificantly in Italy since 1990. ISPRA reports emissions of SOx have fallen over 90% from that year

to 2015 and those for NOx, over 60%. Emissions of VOCs fell by over 50%. Emissions of Benzene

fell by over 90%, in particular due to changes in vehicle fuels. Emissions on ammonia, however,

have fallen more slowly, by about 20% from 1990 to 2015.

11 European Air Quality Portal, Attainment Tables (accessed January 2019) at: http://eeadmz1-cws-wp-

air.azurewebsites.net/products/attainment-viewers/attainment-tables-v2/ 12 Data for O3 and other pollutants downloaded from the European Air Quality Portal, Attainment Tables (ac-

cessed January 2019) at: http://eeadmz1-cws-wp-air.azurewebsites.net/products/attainment-viewers/at-

tainment-tables-v2/ 13 ISPRA and SNPA, Dati sull’ambiente: annuario dei dati ambientali 2017, December 2017 http://annuario.isprambiente.it/ 14 European Commission, The EU Environmental Implementation Review Country Report – ITALY, SWD(2017) 47 final, February 2017. Available at: http://ec.europa.eu/environment/eir/pdf/report_it_en.pdf 15 EEA, Italy – air pollution country fact sheet 2018. 16 ISPRA, Qualità dell’ambiente urbano – XIII Rapporto, 2017. Available at: http://www.isprambi-

ente.gov.it/it/pubblicazioni/stato-dellambiente/xiii-rapporto-qualita-dell2019ambiente-urbano-edizione-2017 17 ETC/ACM, Ozone in southern Europe - Assessment and effectiveness of measures, ETC/ACM Technical Pa-

per 2017/3; and EEA, Air quality in Europe – 2018 report, EEA Report No. 12/2018. Available at: https://www.eea.europa.eu/publications/air-quality-in-europe-2018

http://eeadmz1-cws-wp-air.azurewebsites.net/products/attainment-viewers/attainment-tables-v2/






http://annuario.isprambiente.it/

http://ec.europa.eu/environment/eir/pdf/report_it_en.pdf

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2.2.3 Air quality in Sicily

In its most recent report on the urban environment18, ISPRA indicated that NO2 limit values had

been exceeded in 2016 in two agglomerations in Sicily, Catania and Palermo. Daily limit values

for PM10 were exceeded in 2016 in Palermo. The long-term objective for ozone was exceeded at

monitoring stations in three Sicilian cities: Catania; and Enna and Trapani, both in the other zone

(IT1915).

According to EEA data19, the annual mean limit value for NO2 was exceeded in three Sicilian zones

and agglomerations in 2017: Catania, Palermo and the industrial areas. The long-term objective

for ozone was exceeded in three zones and agglomerations: Catania, industrial areas and the

‘other’ zone. The target value for ozone was exceeded in the Messina agglomeration and the

industrial areas zone.

In Sicily’s 2018 air quality plan, the Regional Environment Agency presents the contribution of

main emissions sources for the region as a whole and for two agglomerations and one zone, the

industrial areas20.

Across the whole regional territory, traffic is the source of 55% of NOx emissions and 10% of PM10

and PM2.5 emissions. Agriculture is the source of 82% of ammonia emissions. Other and natural

sources bring about 60% of PM10 and PM2.5 emissions: these include forest fires, Etna and, to a

lesser extent, dust from the Sahara.

In the Palermo agglomeration (ITI1911), road transport is the source of about 75% of NOx emis-

sions, about 45% of VOCs and about 25% of PM10 and PM2.5 emissions (ARPA, based on 2012

data): ARPA estimates that about 80% of road transport emissions come from diesel vehicles.

Non-industrial combustion (mainly boilers) is the source of about 60% of PM10 and PM2.5 emis-

sions: here, a key source is household wood combustion, which is the largest single source of

PM10 and PM2.5 emissions. The category of other mobile sources and machinery is the source of

about 70% of SOx emissions: this category includes Palermo’s sea port, and ships at the port are

a key source of SOx emissions.

In the Catania agglomeration (ITI1912), as in Palermo, road transport is the main source of NOX

emissions in the agglomeration, over 60% (2012 data), and contributes between 17% of PM10

and 16% of PM2.5 emissions. As in Palermo, diesel vehicles are the main sources of PM10 and PM2.5

emissions. An assessment of vehicle types in the agglomeration has shown that heavy vehicles

(greater than 3.5 tonnes, including buses) are the source of about 50% of vehicle emissions of

NOx and about 40% of vehicle emissions of PM10 and PM2.5. Non-industrial combustion, mainly

boilers, is the source of just over 40% of PM10 and PM2.5 emissions. Other and natural sources

bring over 30% of PM10 and PM2.5 emissions: these include fires, in particular forest fires, and

Etna, the volcano.

In the industrial areas zone (IT1914) taken as a whole, industrial processes are the source of over

60% of NOx emissions and over 90% of SOx emissions, as well as over 35% of PM10 and PM2.5

emissions.

18 ISPRA, Qualità dell’ambiente urbano – XIII Rapporto, 2017. Available at: http://www.ispram-biente.gov.it/it/pubblicazioni/stato-dellambiente/xiii-rapporto-qualita-dell2019ambiente-urbano-edizione-

2017 19 Data downloaded from the European Air Quality Portal, Attainment Tables (accessed January 2019) at: http://eeadmz1-cws-wp-air.azurewebsites.net/products/attainment-viewers/attainment-tables-v2/ 20 ARPA Sicilia, Piano Regionale di Tutela della Qualità dell’Aria (Regional plan for the protection of air quality), July 2018









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Emissions of several air pollutants in Sicily declined in the period from 2005 to 2012, according to

data from the regional environment agency: SOx emissions by 70%, NOx emissions by 26%,

VOCs by 23% and PM2.5 by 7%. Emissions of ammonia, however, increased by 20% over this

period.


Over the evaluation period, the Commission undertook several infringement procedures against

Italy concerning air quality21. Five of these procedures have been closed. These covered: moni-

toring of PM in Civitavecchia (closed in 2009); air quality assessment and management in Messina

(closed in 2009); sulphur oxide exceedances (closed in 2009); designation of air quality zones

(closed in 2010); PM10 exceedances (closed in 2013) and monitoring and related issues (closed in

2017).

At the time of writing, two infringement procedures remained open. In 2017, the European Com-

mission issued a reasoned opinion to Italy for failing to address air pollution limits for nitrogen

dioxide (NO2) in 12 air quality zones, including Rome, Milan and Turin22. The same year, the

Commission issued a reasoned opinion concerning exceedance of PM10 limit values, as daily limit

values were exceeded in 30 air quality zones and annual limit values in 9 zones23. The Commission

followed this reasoned opinion in May 2018 by referring Italy and other Member States to court

against for PM10 exceedances24.


Pursuant to Article 3 of the AAQ Directive, Member States shall designate – at the appropriate

levels - the competent authorities and bodies responsible for the assessment of ambient air quality

and the implementation of other obligations laid down by the AAQ Directive.

National level

In Italy, the national Ministry of Environment, Land and Sea is the lead authority for air quality

policy, coordinating the work of other bodies.

ISPRA, the national Institute for Environmental Protection and Research, is a technical body with

roles for coordination, research and monitoring. ISPRA compiles air quality data, prepares guid-

ance on monitoring and on air quality plans.

ENEA, the National Agency for new technologies, energy and sustainable economic development,

supports the Ministry, notably on air quality modelling.

Regional level

Italy’s regions (specifically, 19 regions and 2 autonomous provinces) are responsible for monitor-

ing air quality and for preparing air quality plans. Each region has an environment agency (ARPA,

21 European Commission, Infringement decisions, web page, at: http://ec.europa.eu/atwork/applying-eu-

law/infringements-proceedings/infringement_decisions/?lang_code=en 22 European Commission, Press release: Commission warns Germany, France, Spain, Italy and the United

Kingdom of continued air pollution breaches, 15 February 2017, at: http://europa.eu/rapid/press-re-lease_IP-17-238_EN.htm 23 European Commission, Press Release: Air quality: Commission urges Italy to take action against small

particulate matter (PM10) to safeguard public health, 27 April 2017, at: http://europa.eu/rapid/press-re-

lease_IP-17-1046_en.htm 24 European Commission, Press Release: Air quality: Commission takes action to protect citizens from air pollution, Brussels, 17 May 2018, at: http://europa.eu/rapid/press-release_IP-18-3450_en.htm

http://ec.europa.eu/atwork/applying-eu-law/infringements-proceedings/infringement_decisions/?lang_code=en













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Agenzia regionale per l’ambiente) that operates, and coordinates monitoring networks, ensure

quality and collects and publishes regional air quality data

ISPRA and the ARPAs work together in the National system for environmental protection (SNPA,

Sistema nazionale della protezione dell’ambiente), established in 2016 to ensure coordination and

cooperation, including on air quality monitoring and planning.

Local level

Each region (or autonomous province) works with local government bodies – including municipal-

ities, metropolitan areas and provinces – on monitoring and on the implementation of measures

for air quality, such as traffic restrictions.


Legal framework

The Ambient Air Quality Directives (2008/50/EC and 2004/107/EC) were transposed in Italy by

Legislative Decree 13 August 2010, n. 155. This Legislative Decree constitutes the main national

legal text on air quality, repealing the previous legislation (Legislative Decree 311/99, Ministerial

Decree 60/2002, Legislative Decree no.183 / 2004, D.Lgs.152 / 2007, Ministerial Decree

261/2002).

According to national air quality legislation, the regions and the autonomous provinces are re-

sponsible for the assessment of air quality and the implementation of air quality measures. To

coordinate the activities of the regions and the autonomous provinces, an institutional coordina-

tion body was created according to Article 20 of Legislative Decree 155/2010, hereinafter the Art.

20 Coordination Body. Its members include the national ministries of the environment and health,

the regions and the autonomous provinces, the Union of Italian Provinces (UPI), the National

Association of Italian Municipalities (ANCI) and national technical agencies and institutes with

competences in environmental matters (ISPRA, ENEA, CNR25). In the context of this coordination,

common guidelines are identified, and tools are developed that help the regions tackle air pollution

in compliance with the European rules.

Strategic framework

In December 2017, Italy’s previous government approved a National Sustainable Development

Strategy to implement the UN 2030 Agenda for Sustainable Development and the 17 Sustainable

Development Goals26. Italy’s national strategy includes among its targets, to reduce negative

environmental impacts in cities by 2030, with particular attention to air quality as well as solid

waste management. The Strategy also calls for improving knowledge on the qualitative and quan-

titative status of natural, cultural and landscape resources, including air27.

25 The Superior Public Health Institute (ISS) is involved in the activities of Art. 20 Coordination Body ad hoc

under request of the Ministry of Health. 26 Ministero dell’Ambiente e della Tutela del Territorio e del Mare, Sviluppo sostenibile e rapport interna-

zionali (web pages): http://www.minambiente.it/pagina/sviluppo-sostenibile-e-rapporti-internazionali; http://www.minambiente.it/pagina/la-strategia-nazionale-lo-sviluppo-sostenibile 27 Ministero dell’Ambiente e della Tutela del Territorio e del Mare, Strategia Nazionale di Sviluppo

Sostenibile, 2017.Available at: http://www.minambiente.it/sites/default/files/archivio_immagini/Galletti/Comunicati/snsvs_ottobre2017.pdf

http://www.minambiente.it/pagina/sviluppo-sostenibile-e-rapporti-internazionali


http://www.minambiente.it/pagina/la-strategia-nazionale-lo-sviluppo-sostenibile

http://www.minambiente.it/sites/default/files/archivio_immagini/Galletti/Comunicati/snsvs_ottobre2017.pdf




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Air quality plans

Legislative Decree 155/2010, (Article 9.1) states that regions and autonomous provinces should

prepare a plan for air quality if the levels of one or more pollutants among the regulated ones

(sulphur dioxide, nitrogen dioxide, benzene, carbon monoxide, lead, PM10 and PM2.5 particulate

matter) exceed the corresponding limit value or target value. (The 2010 Decree updates a provi-

sion in place in 1999.)

The main steps for these plans – as per Legislative Decree 155/2010 – are programming, evalu-

ation, implementation and monitoring. Their preparation involves various public and private enti-

ties and includes: the analysis of the regulatory framework, the characteristics of the territory,

the sources of emissions of pollutants in air (inventories of emissions), climatic and meteorological

conditions typical of the territory, assessment of air quality, definition of modelling of emission

scenarios and air quality, and finally the identification and implementation of rehabilitation

measures.

In accordance with Legislative Decree 155/2010 (article 19.3) – and to implement Commission

Decision 2011/850/EC (Art. 13) – the regions and the autonomous provinces must transmit the

information relative to the air quality plans to the Ministry of the Environment and to ISPRA within

18 months of the year in which the exceedances were registered. Until 31 December 2013, this

information was sent according to the procedures established by Decision 2004/224 / EC, i.e. by

completing a questionnaire; while, since January 2014, the new reporting requirements estab-

lished by Decision 2011/850 / EU must be followed.

In 2016, Italy reported28 information regarding the plans prepared in 2012 by the following re-

gions: the two autonomous provinces (Trento and Bolzano); and the regions of Emilia-Romagna,

Lombardia, Puglia, Valle d'Aosta, Veneto, Umbria, Liguria, Piemonte, Toscana. According to

ISPRA29, by February 2019, all the remaining regions have also prepared air quality plans, except

for Molise (for which the new plan is in the process of approval) and Basilicata; in addition, some

regions have updated previous plans.

While the main planning responsibility is with the regions, at national level, the Ministry of Envi-

ronment prepared a planning document in 2014 which summarises information regarding the

trends of NO2 concentrations detected, the pressures and the rehabilitation measures adopted

both at national and regional level30.

The regions of the Po Valley share common air quality problems (see section 2.2). In 2013, the

national government and the regions and autonomous provinces in the Po Valley signed an agree-

ment for coordinated and joint measures to address air quality. An updated agreement was signed

in 2017. In 2018, the national government signed further agreements with the Lazio (November)

and Umbria regions (December), and other agreements are under development with Campania,

Sicily and Tuscany regions.

28 EIONET, CDR, Information on air quality plans (Article 13), at: http://cdr.eionet.eu-ropa.eu/it/eu/aqd/h/envv2e5mw/ 29 Information provided by a representative of ISPRA via email. 30 National planning document, at: http://www.minambiente.it/pagina/gestione-della-qualita-dellaria

http://cdr.eionet.europa.eu/it/eu/aqd/h/envv2e5mw/




http://www.minambiente.it/pagina/gestione-della-qualita-dellaria



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In Sicily, the regional government approved the air quality plan in July 2018 with Resolution no.

268 of 18/07/201831. The plan was prepared by the regional environment agency: this is a de-

parture from the normal practice, as the regional agencies do not have a policy-making or planning

role; in Sicily’s case, after years of inaction32, the regional government’s minister33 for environ-

ment named the director of the regional environment agency as emergency commissioner respon-

sible for preparing the plan, in the place of the regional government’s Department of the Environ-

ment. The plan prepared by the agency was adopted in July 2018 (see section 3.2.1 below for

further information on air quality management in Sicily).

The plan is based on modelling of three scenarios to 2027: current regional trends; (implementa-

tion of) the 2013 National Energy Strategy and related regional plans; implementation of the air

quality plan’s measures.

Sicily’s air quality plan identifies 25 measures to be undertaken. It notes that the implementation

of these measures will require decisions and actions to be taken by regional and local authorities.

Among the measures to reduce emissions are the following34:

• M1. Reduction of traffic volumes in Palermo, Catania, Messina and Syracuse: 40% reduction

by 2022 and 60% reduction by 2027 (interventions to be undertaken by the municipal gov-

ernments)

• M2. Application of lower emissions limits in the integrated permits of refineries, chemical and

cement plants (action to be taken by national and/or regional authorities)

• M3. Actions to attach ships berthed in the ports of Palermo, Catania and Augusta to the

electricity network (to be undertaken by the regional government)

• M5. Reduce the extent of forest fires (to max. 2000 ha/year by 2027) (regional government)

• M7. Raise awareness for the uptake of actions to replace traditional heating with advanced

systems (increase of advanced systems of 5% in 2022 and 10% in 2027) (regional govern-

ment)

• M8. Providing resources to take back old commercial vehicles from small and micro enter-

prises (Euro 0 to 3 diesel and Euro 1 and 1 petrol vehicles) (regional government)

• M13. Increase of urban green areas by 20% (municipalities).

While the plan sets specific targets to be achieve, it provides only qualitative indications of the

cost of some measures. Due to time and resource restrictions, only a limited consultation was

carried out of the draft plan. Its measures, however, call for a range of entities, including various

departments of the regional government, municipalities and the port authorities to take action.

The plan includes a link to the implementation of Sustainable Urban Mobility Plans, but these have

not yet been put in place in Sicily.

31 ARPA Sicilia, Approvato il piano regionale di tutela della qualità dell’aria (press release), July 2018: https://www.arpa.sicilia.it/news/approvato-il-piano-regionale-di-tutela-della-qualita-dellaria/ 32 ARPA Sicilia, Decree of the Director General, at: http://www.arpa.sicilia.it/wp-content/up-

loads/2016/01/2016-01-26-ddg-37-affidamento-servizi-supporto-redazione-piano-qualit---aria.pdf . 33 i.e. the assessore 34 ARPA Sicilia, Piano Regionale di Tutela della Qualità dell’Aria (Regional plan for the protection of air quality), July 2018

https://www.arpa.sicilia.it/news/approvato-il-piano-regionale-di-tutela-della-qualita-dellaria/

http://www.arpa.sicilia.it/wp-content/uploads/2016/01/2016-01-26-ddg-37-affidamento-servizi-supporto-redazione-piano-qualit---aria.pdf






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Pursuant to Article 26 of the AAQ Directive, Member States shall ensure that the public is – ade-

quately and in good time - informed about ambient air quality and other issues specified in the

above cited Article. In Italy, Article 18 of Decree 155/2010 specifies the measures to be imple-

mented to ensure information to the public about air quality.

Public information about air quality is publicly available on several levels. First, each region has a

dedicated section on its website about air quality levels in real time and several have forecast

tools (48-72 hours forecast), as seen in the box below. To meet the obligations of the Directive,

regions have developed modelling tools for forecasting and evaluation phase, although some re-

gions still struggle with the provision of real-time data (see the box below).

Text-box 2-1 Comparison of air quality information provided to the public across three regions

While all of Italy’s regional environment agencies provide information to the public on air quality levels, the

presentation, extent and timeliness of information varies.

Eight regional environmental agencies provide forecasts (48-72 hours):

• Valle d’Aosta: link

• Veneto: link

• Friuli Venezia Giulia: link

• Lombardia: link

• Emilia Romagna: link

• Umbria: link

• Lazio: link

• Basilicata: link

Example of differences of information provided for three regions:

• In Lombardy, the environment agency’s web site provides a map-based display of air quality, with

forecasts provided for the coming 48 hours (the example below shows the forecast for PM10 on

15/11/2018, provided on 13/11/2018).

• In Emilia-Romagna, the environment agency provides tables showing air quality in major cities up

to the current day, with forecasts provided for the coming 48 hours.

• In Sicily, the environment agency’s web site presents tables showing air quality in major cities;

however, a check in November 2018 found that most data was at least 30 days old. In March

2019, monitoring data for the previous day was found for some but not all stations35.

35 http://www.arpa.sicilia.it/storage/#titoloinizio

http://www.arpa.vda.it/it/aria/la-qualit%C3%A0-dell-aria/le-previsioni-della-qualit%C3%A0-dell-aria

http://www.arpa.veneto.it/inquinanti/mappe_previsione_PM10.php

http://www.arpaweb.fvg.it/fcm/gmapsfc.asp

http://www.arpalombardia.it/Pages/Aria/Qualita-aria.aspx#/topPagina

https://www.arpae.it/mappa_qa.asp?idlivello=134&tema=valutazioni&inq=pm10

https://www.arpa.umbria.it/monitoraggi/aria/prev-PM10.aspx

http://www.arpalazio.net/main/aria/sci/previsioni/pm10.php?region=RMC

http://www.arpab.it/aria/prev-dust.asp?pag=0

http://www.arpa.sicilia.it/storage/#titoloinizio

http://www.arpa.sicilia.it/storage/#titoloinizio



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Figure 2-3 Example of the forecast for PM10 (daily average) available on the Lombardia ARPA website

Sources: Lombardy: http://www.arpalombardia.it/sites/qaria/_layouts/15/qaria/imodelli.aspx

Emilia-Romagna: https://www.arpae.it/index.asp?idlivello=134

Sicily: https://www.arpa.sicilia.it/storage/index.php?dt=5/10/2018#titoloinizio

Almost all of Italy’s regions transmit data for publication at EU level on EEA’s air quality maps36,

based on a review of the EEA interactive map in November 2018; at the time, based on the EEA

interactive map as well as interviews at national and regional levels, Sicily was among the few

regions that did not do so. According to interviewees at both national and regional level, it was

expected that data will be transmitted to EEA once the project upgrading the region’s monitor-

ing systems is in place.

In addition to web-based data presentations, information is consolidated on regional sites in an-

nual reports. On the basis of data transmitted by the regions, ISPRA develops at national level,

the main indicators on air quality37 and publishes each year the Report on the Quality of the Ur-

ban Environment (analysis of 120 urban areas) which includes a specific chapter on air quality38.

36 EEA: https://www.eea.europa.eu/themes/air/air-quality-index/index; and https://www.eea.eu-ropa.eu/data-and-maps/explore-interactive-maps/up-to-date-air-quality-data 37 http://annuario.isprambiente.it/ 38 http://www.areeurbane.isprambiente.it/it/pubblicazioni

http://www.arpalombardia.it/sites/qaria/_layouts/15/qaria/imodelli.aspx

https://www.arpa.sicilia.it/storage/index.php?dt=5/10/2018#titoloinizio

https://www.eea.europa.eu/themes/air/air-quality-index/index

https://www.eea.europa.eu/themes/air/air-quality-index/index

https://www.eea.europa.eu/data-and-maps/explore-interactive-maps/up-to-date-air-quality-data





http://www.areeurbane.isprambiente.it/it/pubblicazioni



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In addition, regional data are analysed and elaborated for the publication of technical reports,

(e.g. air quality and the transport sector39).

According the representatives of ISPRA and the Ministry of the Environment, by late 2018 nearly

all regions complied with the Directive’s obligations regarding information to the public. As de-

scribed above and in other sections, Sicily is one of the regions that has not yet fulfilled these

obligations.


EU Structural and Investment Funds have been used in Italy to finance air quality interventions.

In the 2007-2013 programming period, the direct investments under ERDF for air quality (Priority

code 47) in Italy were EUR 25.4 million: the Operational Programmes of four regions – Tuscany,

Sicily, Campania and Calabria region – contained investments under this code40. In particular,

these regions used EU funds to finance improvement of their air quality monitoring networks41. In

addition, EUR 43 million EUR were allocated to integrated prevention and pollution control invest-

ments (Priority code 48), which could include actions to reduce air pollution: The Operational

Programmes of five regions – Umbria, Sicily, Puglia, Campania and Calabria – made these alloca-

tions.

In the 2014-2020 programming period the use of EU funds for air quality investments fell consid-

erably, as none of the regions allocated ERDF resources for investments under the intervention

code 83 (Air Quality measures). A total of EUR 30.7 million (less than three-quarters of the amount

in the previous period) was allocated to IPPC intervention code investments: allocations were

made in the regional OPs for Basilicata, Calabria, Campania and Puglia42.

In addition to the allocations for the priority themes directly related to air quality, Italy’s Opera-

tional Programmes made allocations for renewable energy, energy efficiency and sustainable

transport: investments in these areas can have positive impacts on air quality. For example, sev-

eral regions are currently using EU funds to promote a renewal of public transport systems to

ensure and maintain good air quality levels. ERDF funds are used to support the preparation and

the implementation of Sustainable urban mobility plans43.

The regional Rural Development Programmes (RDPs), co-financed by the European Agricultural

Fund for Rural Development (EAFRD), supports measures that reduce agricultural emissions of air

pollutants44. The RDPs are identified as a key source of funding for agriculture measures in, for

example, the 2013 and 2018 air quality plans for Lombardy and the Sicily. Data on the overall EU

resources allocated air pollution in Italy are not available, however45.

39 http://www.isprambiente.gov.it/it/pubblicazioni/rapporti/trasporti-strumenti-europei-e-nazionali-per-il-risanamento-della-qualita-dellaria 40 Data source: data on final spending from ERDF and CG for the period 2007-2013 obtained from DG Re-

gional and Urban Policy in September 2018 41 Database of projects available at: https://opencoesione.gov.it/it/progetti/?q=&selected_fac-ets=ciclo_programmazione:1&selected_facets=tema:05&selected_facets=is_pubblicato:true 42 Data source: data on final spending from ERDF and CG for the period 2007-2013 obtained from DG Re-gional and Urban Policy in September 2018 43 For example, the Emilia Romagna region has prioritised ERDF funds to this aims. 44 Regulation (EU) No 1305/2013 of the European Parliament and of the Council of 17 December 2013 on

support for rural development by the European Agricultural Fund for Rural Development (EAFRD) and re-pealing Council Regulation (EC) No 1698/2005, https://eur-lex.europa.eu/legal-con-

tent/EN/TXT/?uri=celex%3A32013R1305 45 Air quality Plans for Lombardy and Sicily.

http://www.isprambiente.gov.it/it/pubblicazioni/rapporti/trasporti-strumenti-europei-e-nazionali-per-il-risanamento-della-qualita-dellaria

http://www.isprambiente.gov.it/it/pubblicazioni/rapporti/trasporti-strumenti-europei-e-nazionali-per-il-risanamento-della-qualita-dellaria

https://opencoesione.gov.it/it/progetti/?q=&selected_facets=ciclo_programmazione:1&selected_facets=tema:05&selected_facets=is_pubblicato:true




https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32013R1305






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March 2019 19

The EU LIFE Programme has also supported air quality actions. As an example, the PREPAIR

Project (Po Regions Engaged to Policies of AIR)46, currently underway, supports the implementa-

tion of measures foreseen in regional plans in the Po Valley and in the Po Valley agreement, to

strengthen the sustainability and durability of results: the project’s geographical coverage is the

Po Valley with the regions and cities that mainly influence air quality in the basin. Its actions are

also extended to Slovenia in order to assess and reduce pollutants transportation across the Adri-

atic Sea. The project will last for 7 years (from 2017 to 2024). The total budget is EUR 16.8 million,

of which EU co-financing totals EUR 10.0 million. The recently completed OPERA project (see

section 3.4.3 below), also financed by LIFE, developed a modelling tool to estimate costs and

benefits of air quality measures47: this tool, RIAT+, will be used in the PREPAIR project to estimate

the results of ongoing air quality plans in the Po basin.

In Sicily, structural funds in the 2007-2013 programming period were used for the design and

implementation of interventions aimed at improving the air quality monitoring system, including

the purchase of stationary equipment (7 projects planned for total amount of EUR 10.8 million),

new mobile laboratories and related technical assistance service and maintenance (1.9 million

EUR)48. However, the financing of these projects has been blocked due to administrative issues

(see section 3.2.1 below), causing substantial delays in the development of Sicily’s monitoring

network.

The preparation of the air quality plan was a precondition for the utilisation of structural and

investment funds for the period 2014-2020. As noted above, Sicily’s plan was adopted in August

2018. The funds will be used for investments in several areas49, including the upgrade of the air

quality monitoring network.

46 http://www.lifeprepair.eu/index.php/project/?lang=en 47 http://www.operatool.eu/html/eng/index.html 48 http://www.ignaziocorrao.it/wp-content/uploads/2016/10/fondi-europei.pdf 49 Sicily OP 2014-2020

http://www.lifeprepair.eu/index.php/project/?lang=en

http://www.operatool.eu/html/eng/index.html

http://www.ignaziocorrao.it/wp-content/uploads/2016/10/fondi-europei.pdf



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3 FINDINGS


mentation of the AAQDs in Italy and in the Sicily region. Specifically, the chapter focuses on the

challenges and successes encountered in the implementation of the Directives. Additionally, the

relevance of the AAQDs, and their air quality standards, has been explored. Finally, the chapter

identifies the factors underlying compliance with and effectiveness of the AAQDs and provides an

overview of the costs and benefits associated with the implementation of the Directives.


in the context of the case study. These were, as relevant, supplemented by additional desk re-



The European Commission’s 2017 Environmental Implementation Review of Italy states that ‘air

quality in Italy continues to give cause for concern’, citing the exceedance of limit values for

several pollutants and the high share of the urban population exposed to PM10 levels above the

daily limit values. The Review calls on Italy to continue reducing air pollutant emissions in order

to achieve compliance with air quality limit values and reduce impacts on health, environment and

economy50.

A majority of Italian citizens responding to the 2017 Special Eurobarometer survey on environ-

ment perceived that air quality had deteriorated in the past 10 years (61% of respondents); the

second-largest group (31%) perceived that air quality stayed the same51. (As noted in section 2.2

above, air quality in Italy as a whole has improved slightly in recent years.) When asked in the

Eurobarometer survey at which level (of government) the issue of air pollution can be best ad-

dressed, the largest share of respondents in Italy (43%) nominated the EU level; the second-

largest share (38%) the national level; and the third (13%), the regional or local level52.

In the Open Public Consultation, 5 of the 8 respondents from Italy perceived that air pollution, to

a very large extent, poses a concern for public health; a further 2 indicated that it does to a large

extent. In addition, 5 of the 8 respondents indicated that air pollution, to a very large extent,

poses a concern for the environment and a further 3 indicated that it does so to a large extent.

One response to the evidence-gathering a questionnaire was received from Italy. The respondent,

at an academic institution, cited the high level of premature deaths due to air pollution in Italy

estimated in the EEA’s reports on air quality.

In Sicily as well, ongoing air quality issues indicate that the AAQD remain relevant. The regional

air quality plan proposes additional pollutant limits to address concerns in the region’s industrial

areas, however, including hourly limits for benzene and hydrocarbons as well as limits for odours:

it was felt that the provisions of the AAQD did not fully address the concerns of citizens near these

industrial areas.

50 European Commission, The EU Environmental Implementation Review Country Report – ITALY,

SWD(2017) 47 final, February 2017. 51 European Commission, Special Eurobarometer 468: Attitudes of European citizens towards the environ-

ment (Survey conducted by TNS political & social), October 2017. 52 Based on detailed statistics available at: EU Open Data Portal, Special Eurobarometer 468: Attitudes of European citizens towards the environment, released 2017.



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The present section highlights the key implementation successes of AAQDs in Italy.

These include the recent improvements in monitoring and reporting systems across most of It-

aly’s regions and improvement in regional/local cooperation.

3.2.1 Improvements in monitoring and reporting across most of Italy’s regions

Before Directive 2008/50/EC was adopted, Italy had a large monitoring network which, how-

ever, needed substantial improvements to comply with the directive’s requirements once it en-

tered into force. Italy had many monitoring stations – over 800, more than required by the Di-

rective – but regional networks were fragmented and typically included stations managed by dif-

ferent entities, such as local governments as well as the regions themselves: there were issues

in terms of lack of common methods as well as communication of data. In general, the regional

networks were focused on air quality in high-traffic areas and not on average population expo-

sure.

To comply with the Directive’s requirements, Italy started an ambitious reorganisation of the

monitoring network. The Art. 20 Coordination Body developed national guidelines. Based on

these, the regions prepared programmes to update their monitoring networks: these were then

sent to the Ministry of Environment to be evaluated with the support of ISPRA and ENEA.

The reorganisation process started in 2008 and more than 10 years later the upgrade of the re-

gional networks is almost complete. One factor that slowed down the work to rationalise moni-

toring networks, according to an interviewee, was the strong public opposition: citizens and en-

vironmental NGOs did not understand the reasons for closing or moving stations that were con-

sidered not necessary for assessing exposure of the population to air pollution and reacted with

protests, warnings and legal actions.

The regions where a relatively strong network was already in place upgraded their networks

more quickly, introducing monitoring for additional pollutants; other regions, mainly in the

south of Italy, faced greater efforts to upgrade their networks because they had to fill gaps in

stations and in many cases establish new stations. Among the last regions, in Campania, for ex-

ample, opened new stations in 2016. As noted in section 3.2.1, however, as of late 2018 the

upgrade of monitoring stations and the monitoring network in Sicily still needed to be com-

pleted, as the contract for this work needed to be review (as noted above, if the update to the

contract is in place in early 2019, the upgrade of Sicily’s monitoring network should be com-

pleted by the end of 2019).

Legislative decree 250/2012 defines reporting mechanisms. At present there is no decree that

transposes implementing decision 2011/850/EU, although all activities put in place by Art. 20

Coordination Body contribute to its implementation. Reporting is challenging for Italy because it

is managed at the regional level, so there were 21 systems (19 regions, 2 autonomous prov-

inces) that had to be adapted to the new obligations and it was a very complex process from an

IT point of view. Regions report via ARPA and communicate data to the Ministry through ISPRA,

which is the national collector. While reporting of the consolidated data has not been problem-

atic, the transmission of the updated data and real time data to the EU level started only in

March 2018. An external company was subcontracted to handle this problem and ISPRA put a

lot of effort in collecting, checking quality and sorting data from each region and send it to EEA.

Up to late 2018, only 3 or 4 regions (including Sicily) had not yet provided data streams to be

reported in near real time to EEA.



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3.2.2 Strengthening cooperation: actions at national level and in the Po Valley

Coordination between the Ministry and the regions is complex but has improved significantly

over the years, according to an interviewee. In 2003 the Ministry organised the first coordina-

tion meeting with all regional authorities which was then formalised with the creation of Art. 20

Coordination Body. The members of Art. 20 Coordination Body meet regularly several times a

year. Since the first meeting, important progress has been made, according to the interviewee,

and the competent authorities have learned to dialogue, initially on a technical level, then on a

strategic level. Over time, they have dealt with several issues: initially the activity was focused

on the homogenization of the instruments (zoning, preparation of the monitoring network). The

Art. 20 Coordination Body has first provided regions with technical guidelines and tools for the

implementation of the directive, such as modelling tools to gather information on emission sce-

narios; cooperation then moved to a more strategic phase which consisted in the agreement

and identification of appropriate measures, through the air quality plans; more recently its focus

has been on better reporting.

The establishment of the National System for Environmental Protection (SNPA) in 2016 (under

Law 132 of 28 June 2016) has further advanced cooperation on air quality as well as other envi-

ronmental themes. The SNPA, which started its activities in January 2017, was created to en-

sure common approaches and effective actions for environmental monitoring, to support envi-

ronmental and health prevention policies and to protect public health.

The SNPA brings together ISPRA and the regional ARPAs into one single body to coordinate en-

vironmental monitoring and assessment, related research activities and technical support activi-

ties for administrations responsible for the collection, organization and dissemination of environ-

mental data. Under the coordination of ISPRA and through the organisation of regular meetings,

the ARPAs work on the basis of common standards, (called ‘essential levels of technical environ-

mental performance’ - LEPTAs) throughout the territory53.

In the Po Valley district, an extended area facing serious air quality issues (see section 2.2

above), cooperation between the regions took a step forward with the signature of an agree-

ment in 2013, bringing together the regions as well as several national ministries; the agree-

ment was updated in 2017 (see Text box 3-1).

53 http://www.isprambiente.gov.it/files/snpa/NasceilSNPA.pdf

http://www.isprambiente.gov.it/files/snpa/NasceilSNPA.pdf

http://www.isprambiente.gov.it/files/snpa/NasceilSNPA.pdf



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Text box 3-1 The Po Valley Agreement and its update

The 2013 Action Plan was signed by five national ministries and by six regions and the two autonomous

provinces in the Po Valley. The agreement had great political relevance and marked a milestone in cross-

sectoral cooperation for air quality management in Italy as it was the first time that all relevant ministries

sat at the same table54.

The Agreement indicated that national ministries would take a range of strategic measures including the

following:

• Ministry of Environment, Land Sea: set levels for dust and nitrogen oxide emissions under inte-

grated industrial permits below BREF levels where technically feasible (for facilities under its

competence)

• Ministry of Economic Development: plan a fund for energy efficiency in buildings and update

provisions on biomass combustion

• Ministry of Transport and Infrastructure: promotion of electric vehicles

• Ministry of Agricultural, Food and Forestry Policies: guidelines to address manure management

and promote agricultural practices that reduce air emissions

Among the actions undertaken by the regions and autonomous provinces were the following:

• Strengthen enforcement of uncontrolled burning of waste and agricultural residue

• Implement more stringent integrated industrial permits (for facilities under their competence)

• Cooperate on public awareness activities

The 2017 Action Plan was signed by the Ministry of Environment and by four regions. This second agree-

ment did not involve sectoral ministries. A representative for the Ministry of Environment explained that

the agreement, unlike the one from 2013, had more technical relevance, focusing on the commitment of

the regions for the identification and implementation of concrete measures in their air quality plans,

including:

• Common requirements to ban diesel and commercial vehicles at lower Euro standards in winter

months (see section 3.2.1 above)

• Promotion of non-biomass renewable energy in zones that where PM10 and Benzo(a)pyrene limit

values are exceeded, and a ban on using ESIF funding for biomass in these areas

• Introduce more stringent standards for household biomass burners

Among the actions for the Ministry of Environment were:

• Discuss updating vehicle taxation with the Ministry of Economy and Finance

• Discuss updating vehicle speed limits with the Ministry of Infrastructure and Transport

• Coordinate with the Ministry of Agricultural, Food and Forestry Policies on the use of EU funding

Following the example of the regions of the Po Valley, the Ministry of Environment has signed

agreements with other regions: Lazio in November 2018 and Umbria in December 2018, and soon

in 2019 will follow the agreements with Toscana, Campania e Liguria.

3.2.3 Improvements in regional/local cooperation via the air quality plans

The process of preparing air quality plans has strengthened cooperation between regions, which

are responsible for the preparation and adoption of the plans (see section 2.4 above), and the

municipalities in their territories.

Before implementation of Directive 2008/50/EC and the preparation and adoption of regional air

quality plans, in general regional and municipal levels did not always have a structured approach

to addressing air quality issues: municipalities often carried out actions under their own initiative,

including ad hoc measures to address high pollution periods – for example, partial traffic block

54 Interview with a representative of the Ministry of Environment.



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limitations and bans on household biomass combustion. Their effectiveness was limited, in partic-

ular in the Po Valley, where neighbouring cities might undertake different approaches. The adop-

tion of regional air quality plans and the development of greater coordination, also at national

level, introduced common measures and coordination mechanisms to address high pollution

events at regional level and also at interregional level in the Po Valley.

The development of Sustainable Urban Mobility Plans (SUMPs) in Italian cities may further

strengthen regional and local cooperation, as these plans should refer to the regional air quality

plans: as noted above (see section 3.2.1), the mobility plans for Milan and Ferrara indeed refer-

ence the regional air quality plans (this has not been the case for SUMPs in Sicily, as the regional

air quality plan has only recently been approved).


The following section presents the main AAQD implementation challenges.

Each of the challenges, the factors driving them and the extent to what these challenges can be

linked to the provisions of the AAQDs is presented below.

3.3.1 Ongoing exceedances of limit values and issues related to air emissions from traffic and from heating

According to several interviewees, compliance with air quality standards has been the most diffi-

cult obligation for Italy to fulfil, despite some improvements in air quality over the years have

been observed. This is a problem in particular in the Po Valley (especially for PM10, PM2.5 and NO2

as well as ozone), due to its geography and the concentration of population and economic activity

(see section 2.2), but also other parts of Italy, especially in urban areas, including Palermo and

other zones and agglomerations in Sicily which saw exceedances of NO2 in 2017 (Palermo also

saw exceedances of PM10 in 2016). Exceedances of the daily target value for ozone are seen in

more than half of Italy’s zones and agglomerations.

ISPRA has observed a decreasing trend in PM10, PM2.5 and NO2 concentrations over the last 10

years, but exceedances of limit values continue. A representative from the Ministry of the Envi-

ronment noted that PM10 is very complex pollutant: only in the last 10 years it was recognised by

policy makers that several sources need to be addressed in tackling PM10 levels. The interviewee

also explained that it has been difficult for policy makers to identify the right measures, as the

reduction of emissions necessary to comply with the PM10 limit values in the timeframe foreseen

by the Directive 2008/40/EC would have required stringent actions that risked being unsustainable

on social and economic levels, for example with severe restrictions on the movement of goods

and citizens.

Levels of NO2 remain a problem in Italy due to the high number of diesel vehicles. It also plays a

major role in the atmospheric reactions that produce ground-level ozone. Since nitrogen dioxide

is a traffic-related pollutant, emissions are generally highest in urban rather than rural areas.

However, nitrogen dioxide, together with benzo(a)pyrene (BaP), is also found in areas away from

traffic and industrial plants due to biomass combustion.

Emissions from traffic are one of the main sources of air pollution in Italy, mainly due to emissions

from diesel vehicles (in particular for PM10 and NO2). Emissions from biomass consumption also

contribute to continuous exceedances of limit values in Italy, including those for particulates (PM10

and PM2.5) and BaP. In Sicily, as noted above (see section 2.2), road transport is a leading source

of air pollution and household biomass combustion is also a key source, including in agglomera-

tions such as Palermo.



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Over the years, the Italian government planned various measures to reduce these two pollution

sources, but not enough resources were available to make the measures effective, according to

interviews carried out. More details are given in the following paragraphs.

Emissions from traffic

The Ministry for Environment has provided incentives for the replacement of older, more polluting

vehicles, but an interviewee from the Ministry acknowledged that this funding has not proved to

be sufficient: EUR 200 million have been allocated for the replacement of 10-15,000 old diesel

(Euro 0-3) vehicles with new, less polluting vehicles; overall, however, this represents a small

share of the total number of vehicles circulating in Italy (45 million, among which diesel vehicles

increased from 4 to 16 million in recent years). The interviewee also stressed that, especially for

NO2, the measures adopted at Community level have also been ineffective as it has been only

recently recognised that diesel vehicles Euro 3 have not performed up to the desired levels and

this has greatly influenced the process of reaching the limit values.

The interviewee also acknowledged that, while the incentives helped to raise citizens’ awareness

about the problem, they did not make a large contribution in terms of air quality improvements,

according to interviewees. Many urban areas in the north, such as Turin, Milan and Bologna, offer

efficient tram, metro and train public transport systems that have been built over many years.

However, these cities also attract commuters from neighbouring municipalities (in the case of

Milan, some come from more than 80km distance) which are less served by public transport;

moreover, Italy has seen a significant urban sprawl over many decades (as noted in section 2.1).

Consequently, an important share of mobility is still undertaken by private cars. Southern urban

areas, Rome included, moreover have historically had a less developed public transport system.

In general, a 2013 OECD report55 concluded that, while there had been progress in prior years in

developing integrated urban transport systems in Italy, ‘in most Italian cities and metropolitan

areas local public transport systems remain insufficiently developed (in terms of infrastructure

and service quality) to provide an alternative to the use of private vehicles’. (A major national

program for the improvement of sustainable public transport is being implemented from 2018 to

2033, aiming to address these gaps.)

Traffic restrictions are put in place during periods of high pollution levels, and these can be effec-

tive in the short term, especially for particulate concentrations, although they also often face

citizens’ resistance56. Since October 2018, new permanent traffic restrictions are being established

in the regions participating in the new Po Basin Action Plan57: Emilia-Romagna, Lombardia, Pie-

monte and Veneto. The plan calls on the regions to ban, in towns and cities, the circulation of

vehicles that do not meet specific levels of European standards on weekdays in the winter: from

October through March, diesel automobiles with Euro 3 certification or lower are banned from 8.30

to 18.30; in 2020, this will be extended to Euro 4 diesel vehicles and in 2025, to Euro 5 vehicles58.

To be effective, such measures must be integrated in regional air quality plans and implemented

in concert by municipal administrations via implementing decisions. Despite the common approach

55 OECD, Environmental Performance Reviews: Italy, 2013. Available at: http://www.oecd.org/environ-

ment/country-reviews/find-a-review.htm 56 Interviewee 57 2017, Nuovo accordo per la qualità dell’aria nel bacino padano, available here: http://www.arpa.veneto.it/temi-ambientali/aria/file-e-allegati/pm10-2017_informazione-al-

pubblico/DGR%20836_2017.pdf 58

https://motori.ilmattino.it/ecologia/nord_italia_stop_vecchi_diesel_primo_ottobre_fermi_1_1_mln_di_auto_emilia_divieto_fino_euro_4-4007784.html

http://www.oecd.org/environment/country-reviews/find-a-review.htm




http://www.arpa.veneto.it/temi-ambientali/aria/file-e-allegati/pm10-2017_informazione-al-pubblico/DGR%20836_2017.pdf

http://www.arpa.veneto.it/temi-ambientali/aria/file-e-allegati/pm10-2017_informazione-al-pubblico/DGR%20836_2017.pdf





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agreed at the Po basin inter-regional level, different regions and different municipalities may follow

different approaches in terms of which types of vehicle are restricted, the schedules and the ex-

emptions: in the Emilia-Romagna Region, for example, the restrictions applied to Euro 4 diesel

automobiles started from October 2018. When this region’s restrictions were first put in place,

according to interviewees, information was not available on a common inter-regional platform,

and many citizens were reportedly not aware of them59.

In addition, several Italian cities have put in place low emission zones that ban the use of high

polluting motor vehicles at all times. In Milan, the low emission zone system has several areas:

for the city centre, pre-Euro 4 diesel automobiles are prohibited, and all other vehicles must pay

a congestion charge (EUR 5 per day). As a result of these measures, traffic in the centre has fallen

about 30%; moreover, the use of bicycles, including public and private bike-sharing schemes, has

increased.60

Emissions from biomass

Emissions from biomass combustion, notably in household stoves, also contribute to continuous

exceedances of limit values in Italy. Biomass combustion is a source of particulates, VOCs, CO

and PAHs such as Benzo(a)pyrene61. An EU LIFE project found that biomass consumption contrib-

uted to high levels of particulates in Florence and Milan (the two cities studied in Italy): notably,

biomass combustion contributed about one-quarter of PM2.5 in Milan, the second source after traf-

fic62. As noted in section 2.2, household wood combustion is a key source of air pollutants in

Palermo, Sicily.

A representative from the Ministry of Environment noted that many citizens and even the local

administrators are not aware of this problem. A recent trend has seen citizens moving from gas

heating system to biomass combustion systems, possibly also as it is a more climate friendly

option, but not aware of the fact that this causes higher emissions of PM10 and PM2.5.

To tackle this problem Italy has introduced a classification system for wood stoves, anticipating

the implementation of the requirements of the Ecodesign Directive63. Since 2016 the national

government has offered incentives and tax reductions for the purchase of certified wood stoves64.

Moreover, Ministerial Decree 186/201765 establishes requirements, procedures and responsibili-

ties for issuing environmental certifications for heat generators fed with firewood, charcoal and

another combustible biomass. It also identifies the reference emissions performance for five qual-

ity classes, the related test methods and the checks to be carried out for the purpose of issuing

the environmental certification, as well as specific requirements relating to the indications to be

provided regarding the correct methods of installation and management of heat generators that

have obtained environmental certification. As of early 2019, six regions already prohibited the

59

https://motori.ilmattino.it/ecologia/nord_italia_stop_vecchi_diesel_primo_ottobre_fermi_1_1_mln_di_auto_emilia_divieto_fino_euro_4-4007784.html 60 EEA, Europe's urban air quality — re-assessing implementation challenges in cities, EEA Report No.

24/2018 61 ISPRA, Qualità dell’ambiente urbano, XII Rapporto, Focus su inquinamento atmosferico nelle aree urbane ed effetti sulla salute, December 2016. 62 Querol, X., et al, Biomass burning in southern Europe, AIRUSE (LIFE 11 ENV/ES/584) Report no. 8, De-cember 2016. Available at: http://airuse.eu/wp-content/uploads/2013/11/R08_AIRUSE-Biomass-Burning-

SE-ATH-TR.pdf 63 Ministerial Decree 28/12, in force since 2016, offers incentives and tax detractions to substitute wood

stoves with certified ones, at: https://www.mise.gov.it/images/stories/norma-tiva/DM_Conto_Termico_28_dic_2012.pdf

65 Ministerial Decree 186/2017: http://www.gazzettaufficiale.it/eli/id/2017/12/18/17G00200/sg



http://airuse.eu/wp-content/uploads/2013/11/R08_AIRUSE-Biomass-Burning-SE-ATH-TR.pdf



https://www.mise.gov.it/images/stories/normativa/DM_Conto_Termico_28_dic_2012.pdf




http://www.gazzettaufficiale.it/eli/id/2017/12/18/17G00200/sg



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installation of stoves below class 3 (i.e. the most polluting classes) and two further regions were

expected to soon follow66. The Ministry of Environment moreover reached an agreement in June

2018 with the industry association for biomass to raise awareness and promote good practices in

the use of biomass energy and to support the association’s voluntary certification for low-emission

combustion equipment67.

Some local actions plan to go further: for example, the city of Milan, where biomass combustion

is the source of about one-quarter of PM10 emissions, plans to ban residential stoves that do not

meet eco-design requirements and raise public awareness of the correct use of stoves68.

3.3.2 Difficulties establishing shared solutions with sectoral authorities

According to one interviewee, at the beginning of implementation of Directive 2008/50/EC, the

national Ministry of Environment experienced difficulties in terms of the involvement of sectoral

authorities, i.e. Ministry of Transport, Ministry of Energy and Ministry of Agriculture. Initially it

was challenging to gather all these sectoral authorities in coordination meetings. Particularly dif-

ficult was the integration of air quality measures with the climate and transport policy measures:

for some time diesel vehicles were incentivised to act against climate change and their adverse

effect on air quality was not considered. At a strategic level, air quality plans were not coordinated

with other sectoral plans.

Intersectoral cooperation on air quality has improved over the evaluation period, according to an

interviewee: one notable step was that key ministries participated in the development of the first

Po Basin Action Plan in 2013. As a result, in particular of this agreement, according to an inter-

viewee at national level, intersectoral dialogue has improved at national level and consequentially,

also coherence between sectoral plans.

A related issue, noted above in terms of the challenge of ongoing exceedances, is the extensive

use of automobiles for private transport, including daily commuting: the limited efficiency of public

transport in many parts of Italy contributes to the high use of private automobiles. A 2013 OECD

report69 noted that local and regional governments faced financial constraints for public transport

investments. The Italian government has provided financing for public transport and continues to

do so, for example with the national programme initiated in 2018 for the replacement of older

buses with low-emissions models (see section 3.4); however, interviews noted that this financing

has been and remains insufficient to make fast improvements in air quality.

Many Italian urban areas are preparing Sustainable Urban Mobility Plans (SUMPs), which are pro-

moted by the EU’s 2013 Urban Mobility Package: these plans should strengthen coordination at

local level on mobility and air pollution in coming years; indeed, a review of the SUMPs for Ferrara

and Milan found that they referred to air quality goals (see the box below for further details).

66 Interview with a representative of the Ministry of the Environment. 67 Ministero dell’ambiente e della tutela del territorio e del mare and Associazione Italiana Energie Agro-

forestali (AIEL), Protocollo di Intesa per la promozione di azioni e di iniziative finalizzate alla riduzione delle emissioni degli impianti termici alimentati a biomasse legnose, available at: http://www.minambi-

ente.it/sites/default/files/archivio/allegati/inquinamento_atmosferico/Protocollo_Intesa_MATTM_AIEL.pdf 68 EEA, Europe's urban air quality — re-assessing implementation challenges in cities, EEA Report No.

24/2018 69 OECD, Environmental Performance Reviews: Italy, 2013. Available at: http://www.oecd.org/environ-ment/country-reviews/find-a-review.htm

http://www.minambiente.it/sites/default/files/archivio/allegati/inquinamento_atmosferico/Protocollo_Intesa_MATTM_AIEL.pdf










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Text box 3-2 SUMPs in Italy

SUMPs in Italy

As part of the first agreement with the Po Valley, a working group was set up which coordinated the

update of the guidelines for the preparation of the SUMPs. Subsequently in May 2016, the Ministry of

Transport set up a working group aimed at the preparation of guidelines that would be applicable to whole

territory and with Decree 397/2017 set up a technical group with the task of monitoring the state of

implementation of the guidelines.

As of October 2018, 35 Italian cities had recently approved or adopted SUMPs, while 72 cities had plans

in preparation70. These plans are strategic documents that ‘orient mobility in a sustainable direction over

a medium-long time horizon (10 year)’, according to the SUMP for the city of Ferrara71. As strategic

documents, the SUMPs provide indications that need to be implemented via further decisions. A further

issue is that the SUMPs are typically prepared at municipal level, while large agglomerations cover several

municipalities72. Nonetheless, the SUMP for Milan, prepared by the city government and city transport

company, also considers the surrounding urban area73.

Milan’s 2016 SUMP (amended in 2017) identifies the reduction of air pollution among its goals (along with

reduction of energy efficiency, road accidents and road congestion) and states that its areas of action to

address traffic emissions reflect the Lombardy Region’s 2013 air quality plan. Ferrara’s SUMP also refers

to the regional air quality plan (for Emilia-Romagna) and to EU Directive 2008/50.

In Sicily, six cities and urban areas have approved or adopted SUMPs – Agrigento, Bagheria, Gela, Mar-

sala, Sciacca and Siracusa – and four cities have plans in preparation, including Palermo. The plan for

Agrigento74, for example, was approved in November 2015: this plan does refer to air quality. For the city

of Messina, a SUMP has not yet been approved but a preparatory document75 analyses the city’s air quality

and the role of traffic.

3.3.3 Issues with air quality plans and air quality monitoring in Sicily

Sicily is one of the regions that has lagged in terms of improving its monitoring system. As in

other regions, before implementation of Directive 2008/50, regional air quality monitoring in-

volved stations managed by different entities: the regional environment agency, municipalities

and also private, industrial operators (for monitoring of air quality near major industrial facilities).

There were gaps in terms of monitoring pollutants: for example, no monitoring stations in the

region’s three agglomerations measured PM2.5 levels. These stations were not integrated into a

common network using comparable measuring procedures, according to interviewees. Moreover,

by 2018 the minimum number of stations required by the AAQD was not operational in all zones

or agglomerations: for example, the monitoring station operated by the city of Agrigento had been

closed due to lack of municipal resources for its maintenance.

70 Endurance: Osservatorio PUMS, L’Osservatorio – I PUMS in Italia: stato dell’arte (web page), accessed November 2018. Available at: http://www.osservatoriopums.it/osservatorio/pums 71 Comune di Ferrara, PUMS: Piano Urbano della Mobilità Sostenibile – Linee di Indirizzo, June 2016. Availa-ble at: http://servizi.comune.fe.it/3172/attach/mobilita/docs/pums_ferrara_lineeindirizzo.pdf 72 Eltis: the urban mobility observatory, Italy (web page), accessed November 2018:

http://www.eltis.org/mobility-plans/member-state/italy 73 Comune di Milano and AMAT, Piano Urbano Mobilità Sostenibile Milano – Documento di Piano, November 2016 (Amended June 2017) 74 Comune di Agrigento, Piano Urbano della Mobilità Sostenibile della città di Agrigento e connessa Valuta-zione Ambientale Strategica, November 2015. Available at:

https://www.comune.agrigento.it/download/anno_2016/PUMS_2016_DG_108_16/001%20Relazione%20Generale.pdf 75 Comune di Messina, Linee guida per la “Pianificazione strategica della mobilità urbana finalizzata all’ag-giornamento del Piano Urbano della Mobilità in coerenza con le politiche e pratiche europee (PUMS)”, pre-

pared by Prof. Ing. Domenico Gattuso, March 2018. Available at: https://www.pumsmes-sina.it/2018/04/26/approvato-il-documento-finale-delle-linee-guida-pums/

http://www.osservatoriopums.it/osservatorio/pums

http://servizi.comune.fe.it/3172/attach/mobilita/docs/pums_ferrara_lineeindirizzo.pdf


http://www.eltis.org/mobility-plans/member-state/italy

https://www.comune.agrigento.it/download/anno_2016/PUMS_2016_DG_108_16/001%20Relazione%20Generale.pdf




https://www.pumsmessina.it/2018/04/26/approvato-il-documento-finale-delle-linee-guida-pums/






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In 2014, the region prepared a project76 to update the network, adding new monitoring stations

and increasing the range of pollutants monitored in many existing stations77 (see section 2.2).

The project also will integrate existing and new stations into a fully connected network. Although

the 2018 Air quality plan for Sicily78 states that the project will be completed by the end of 2018,

interviewees said that, in late 2018, it was at a temporary stand-still: although a key contract had

been awarded in 2016 via a public tender79, when works started the contractor found that the

conditions of several existing stations were different from those expected (in particular, conditions

of several stations were poorer than expected); consequently, a variation to the contract was

prepared based on an updated analysis of the stations; the procedures required for the approval

of this variation have delayed implementation of the overall project.

In part to address gaps in monitoring data, in 2018 ARPA has subcontracted a company to esti-

mate via modelling levels of pollutants that were not fully monitored between 2015-201780.

Substantial delays were encountered in Sicily also in the preparation of the regional air quality

plan. The first regional air quality plan was prepared and approved in 200781, but environmental

groups brought the regional government to court for its lack of analysis and it was not imple-

mented82. Subsequently, in 2009, the regional environmental department contracted an external

consultancy company to draw up an air quality plan based on the approach set out in national

Ministerial Decree No. 60 2/4/2002. While the contractor had started the work, in 2010 national

Legislative Decree 155 came into force and the regional government put on hold the preparation

of the plan to focus on the revision of air quality zoning and of the regional monitoring network,

implementing the new approaches set out in the decree83. After five years of inaction regarding

the preparation of an air quality plan, in 2015 the regional minister (assessore) for environment

designated the regional environmental agency (ARPA) as responsible for the preparation of a new

plan, instead of the regional government’s Department of Environment84. The plan was adopted

in August 2018 (see section 2.4).

The 2018 plan identifies the actors that need to implement its measures. These include the re-

gional government, municipal governments and also private actors, in particular the operators of

76 Project for the upgrade of the air quality monitoring network in Sicily, available at: http://pti.regione.sici-

lia.it/portal/pls/portal/docs/27562382.PDF 77 D.D.G. n.449/2014, http://pti.regione.sicilia.it/portal/pls/portal/docs/27562381.PDF 78 Air quality plan for Sicily, available at: https://www.arpa.sicilia.it/wp-content/uploads/2018/07/Piano-Aria_.pdf 79 Open tender for the realization and adaptation of the regional air quality monitoring network of Sicily, available at: https://www.arpa.sicilia.it/bandi/appalto-a-procedura-aperta-per-la-realizzazione-e-

ladeguamento-della-rete-regionale-di-monitoraggio-della-qualita-dellaria-di-arpa-sicilia/ 80 Air quality modelling service for the years 2015-2017 for the implementation of the Infoaria platform,

available at: https://www.arpa.sicilia.it/bandi/servizio-di-applicazione-modellistica-annuale-e-meteo-e-di-qualita-dellaria-per-gli-anni-2015-2016-2017-al-fine-della-implementazione-della-piattaforma-infoaria/ 81 Gazzetta Ufficiale, http://www.gurs.regione.sicilia.it/Gazzette/g07-43/g07-43-p10.html 82 The environmental group Legambiente accused the regional government of directly copying parts of the

2007 plan from an earlier air quality plan of the Veneto Region. This accusation was followed by a judicial investigation against several of the officials responsible for the plan. http://www.inuovives-

pri.it/2017/05/18/possibile-che-in-sicilia-panifici-e-pizzerie-inquinano-di-piu-delle-automobili/ . The events

were presented in the European Parliament in 2009, in a written question from the MEP Giusto Catania to

the Commission: http://www.europarl.europa.eu/sides/getDoc.do?type=WQ&reference=E-2009-0548&language=EN 83 ARPA Sicilia, Decree of the Director General, http://www.arpa.sicilia.it/wp-content/up-loads/2016/01/2016-01-26-ddg-37-affidamento-servizi-supporto-redazione-piano-qualit---aria.pdf and Info

news: http://www.qds.it/28877-dopo-otto-anni-e-ben-tre-governi-via-libera-al-piano-di-tutela-dell-aria.htm. 84 Specifically, the Director of the Agency was designated as responsible for the preparation of the new plan, at: https://www.arpa.sicilia.it/news/attivita-svolta-da-arpa-sicilia-in-merito-alla-qualita-dellaria/;

http://www.arpa.sicilia.it/wp-content/uploads/2016/01/2016-01-26-ddg-37-affidamento-servizi-supporto-redazione-piano-qualit---aria.pdf.






https://www.arpa.sicilia.it/wp-content/uploads/2018/07/Piano-Aria_.pdf

https://www.arpa.sicilia.it/wp-content/uploads/2018/07/Piano-Aria_.pdf

https://www.arpa.sicilia.it/bandi/appalto-a-procedura-aperta-per-la-realizzazione-e-ladeguamento-della-rete-regionale-di-monitoraggio-della-qualita-dellaria-di-arpa-sicilia/

https://www.arpa.sicilia.it/bandi/appalto-a-procedura-aperta-per-la-realizzazione-e-ladeguamento-della-rete-regionale-di-monitoraggio-della-qualita-dellaria-di-arpa-sicilia/

https://www.arpa.sicilia.it/bandi/servizio-di-applicazione-modellistica-annuale-e-meteo-e-di-qualita-dellaria-per-gli-anni-2015-2016-2017-al-fine-della-implementazione-della-piattaforma-infoaria/

https://www.arpa.sicilia.it/bandi/servizio-di-applicazione-modellistica-annuale-e-meteo-e-di-qualita-dellaria-per-gli-anni-2015-2016-2017-al-fine-della-implementazione-della-piattaforma-infoaria/

http://www.gurs.regione.sicilia.it/Gazzette/g07-43/g07-43-p10.html

http://www.inuovivespri.it/2017/05/18/possibile-che-in-sicilia-panifici-e-pizzerie-inquinano-di-piu-delle-automobili/




http://www.europarl.europa.eu/sides/getDoc.do?type=WQ&reference=E-2009-0548&language=EN

http://www.europarl.europa.eu/sides/getDoc.do?type=WQ&reference=E-2009-0548&language=EN





http://www.qds.it/28877-dopo-otto-anni-e-ben-tre-governi-via-libera-al-piano-di-tutela-dell-aria.htm

http://www.qds.it/28877-dopo-otto-anni-e-ben-tre-governi-via-libera-al-piano-di-tutela-dell-aria.htm

https://www.arpa.sicilia.it/news/attivita-svolta-da-arpa-sicilia-in-merito-alla-qualita-dellaria/





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major industrial facilities. The plan indicates the types of costs to be incurred; it does not, how-

ever, provide estimates of the costs of the measures.

The monitoring of the implementation of the Regional Air Quality Plan is responsibility of the

Regional Environmental Department (DRA). As of February 2019, none of the 25 measures had

been initiated except for the update of the Emissions Inventory, for which a Convention was signed

between ARPA Sicily and the DRA, which entrusts ARPA with the updating of the Inventory85.

3.4 Factors underlying compliance with and effectiveness of the AAQ

Directives


with and effectiveness of the AAQ Directives in Italy and the Sicily region. The factors have been

identified through stakeholder consultation conducted in the context of the case study. The views

have been correlated with information gathered through desk research.


The findings of the case study indicate that the main factor underlying compliance with the AAQDs

in Italy consists in the overall coordination and guidance provided at the national level by Art. 20

Coordination Body to the regions.

Greater public and political attention to air quality problems

Italian NGOs have raised air quality issues at both local and national levels: examples at national

level include reports by the groups Greenpeace and Legambiente on air quality problems.

In many cities and regions, in particular in the Po Valley, there has been a long-standing political

attention to air quality issues. As described in section 3.2.2, and as noted by interviewees, during

the evaluation period the national government worked to bring together and improve coordination

among the regions of the Po Valley and to address the persistent air pollution problems found

there (notably via the Po Basin agreements).

It was also noted in interviews that public attention has not always led to changes in personal

behaviour: for example, low-income inhabitants who rely on driving to reach work and other

destinations are reluctant to pay for new vehicles to replace their older, more polluting automo-

biles and, at the same time, many continue to prefer driving to using public transport.

At national level, interviewees said, sector ministries – such as those for economic development

and agriculture – have given greater attention to air quality issues in recent years. This has been

an important change over the evaluation period, and is necessary as policies for transport and

energy are led by other ministries. The Ministry of Environment has also involved some private

actors, notably the industry association for biomass combustion (Associazione italiana energie

agroforestali), in actions to address air quality (as noted above in section 3.2.1).

In Sicily, air quality has not been the leading environmental issue for public and NGO attention,

with waste management issues considered a priority, according to an interviewee at regional level.

Residents near major industrial areas, however, have organised to protest ongoing air quality

85 Correspondence with a representative of ARPA Sicily, who also noted that a group of private companies

affected by one of the measures of the plan appealed to the regional administrative court (TAR Palermo)

against the regional government’s approval of the plan. This legal action could further delay the plan’s im-plementation.



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problems (including issues that extend beyond pollutants in the AAQD to cover those addressed

under the IED as well as odour problems). At political level, attention to air quality has grown in

recent years: the previous regional government in 2016 acted to overcome the delays in planning

by giving shifting the task to prepare the regional air quality plan from the regional government’s

Department of Environment to the regional environment agency; the current government adopted

the plan in August 2018 (see section 3.2.1).

Greater coordination

The monitoring of air quality and the preparation of the air quality plan is responsibility of the

regions, but Art. 20 Coordination Body plays a role both downstream and upstream the process.

Art. 20 Coordination Body prepared several national guidelines to ensure a uniform implementa-

tion of the Directive and to avoid regional fragmentation. The regions prepared regional zoning

plans and monitoring programmes following the national guidelines. National guidelines for the

preparation of air quality plans have also been prepared, supporting the regions in this work and

promoting common approaches.

To ensure homogenous implementation of the rules established by the implementing decree of

the Directive, ISPRA assumed all the data quality control and verification functions which were

previously responsibility of each single ARPA. Specific procedures to guarantee network quality

were also established at national level by Legislative Decree 155/2010 which provided for a revi-

sion of the zoning and a review of the monitoring networks. All ARPAs had to use the same rules

to ensure quality measurement. The zoning review projects are submitted to the approval of the

ministry with the support of ISPRA and ENEA. Art. 20 Coordination Body also developed common

modelling approaches to complement air quality monitoring and promoted their use across the

regions.

ISPRA also participates in the preparation of the regional air quality plans through the SEA proce-

dure: the regions prepare the plans with the support of the ARPA’s technicians; the draft plans

are subject to SEA and examined by the Technical Commission for environmental impact assess-

ment (under the Ministry of Environment), whose work is supported by ISPRA’s technicians.

ISPRA organizes periodic meetings to discuss how to meet quality objectives. Thanks to all these

new arrangements, the ability to respect the Directive’s data quality objectives has certainly im-

proved.

At regional level, as noted above, the air quality plans have strengthened cooperation among

municipalities and the coordination of their responses in periods of poor air quality. The agree-

ments for the Po Valley have improved coordination among regions in Northern Italy.


Lack of resources

A key problem has been the lack of resources. The cost of measures to fully address Italy’s air

quality problems appears to be beyond current means, according to some interviewees at national

level: for example, while the national government has provided incentives to replace older, diesel

vehicles, these can only cover a small share of vehicles in circulation.

In Sicily, for example, the regional environment agency has had difficulty providing sufficient

personnel for its air quality monitoring and assessment tasks, as well as those to transfer air



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quality data to national and EU levels; the agency has also had to devote personnel to the prep-

aration of the regional plan. Cities in the region have reduced their monitoring activities due to

budgetary shortfalls. In late 2018, the regional environment agency did not have in place a con-

tract for the maintenance of its monitoring stations, as this is foreseen after the upgrade project

(which as described has been delayed).

Administrative delays

Interviewees at both national and regional levels have indicated that administrative delays have

slowed Italian action on air quality. In many regions, delays in preparing and awarding public

contracts slowed the process of upgrading monitoring networks and improving monitoring stations

(for example, to expand monitoring of PM2.5).

This has been an issue in particular in Sicily, where administrative issues (noted in section 3.2.1

above) have slowed the preparation of the regional air quality plan, adopted only in 2018, as well

as the upgrade of the monitoring network.



Overall estimates of the cost of implementation of the AAQD have not been found.

Estimates of monitoring costs vary across Italy’s regions. One estimate provided by an interviewee

is that the annual average operating cost for a monitoring station was roughly EUR 20,000 (e.g.

in Emilia Romagna and Lombardia), although the cost reached about EUR 32,000 per station on

average in Tuscany. In Italy there are 250 monitoring stations, implying total operating costs for

monitoring were approximately EUR 5 million a year. Another interviewee suggested that if all

costs are taken into account, including acquisition of instrumentation, management, maintenance

and personnel, the annual average cost for a monitoring network ranges from EUR 2 million in a

medium-sized region to EUR 4 million in a large region. Estimates for modelling costs were not

found, but these would be additional to the monitoring costs.

In Sicily, an interviewee indicated that the project to update the regional monitoring network

would cost an estimated EUR 6 million, including the construction of new stations and improve-

ment of existing stations. It was also estimated that, once the network is completed, the annual

maintenance costs will amount up to EUR 300,000 per year for the regional environment agency

(this figure covers only the agency’s monitoring stations, not all those in the network).

Costs for the implementation of the measures to improve air quality are higher than monitoring

costs, although they are difficult to estimate as they depend on the measures that are financed

by different sources and implemented by a variety of sectors and entities. One interviewee noted

that until recently, relatively few Italian air quality plans have made estimates of the total costs

of their measures.

An example of a plan that provides cost information is the 2018 update of the Lombardy region’s

air quality plan. This update indicates the following costs for its measures over the three-year

period 2018-2020:

• Stationary sources and energy efficiency: EUR 152.69 million

• Road transport and mobility (excluding highways and high-speed rail): EUR 2,420 million



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• Agricultural and forestry activities: EUR 52.30 million

The 2018 updated plan for Lombardy notes that spending in these areas overlaps with sectoral

spending plans, for example for public transport (i.e. some measures are set out under both the

air quality plan and sectoral plans). Moreover, the plan notes that overall government financing

for public transport has declined with the country’s economic difficulties, though the regional gov-

ernment has recently increased its support for this sector.

For many measures, the plan identifies funding sources: for example, Lombardy’s Rural Develop-

ment Programme is identified as a source for most of the agricultural and forestry measures.

The updated regional plan for Lombardy also notes that this region and three neighbouring regions

signed the New Agreement for the Po Basin in 2017, together with the national Ministry of Envi-

ronment, which indicated that national funding of EUR 4 million (to be co-financed by the regions)

would be available for the implementation of measures under the agreement. The Ministry of

Environment has also allocated EUR 4 million for the implementation of the measures identified

by the agreements with Lazio and Umbria regions.

While the Ministry of Environment does not provide funding specifically for air quality, other na-

tional ministries have programmes whose spending is expected to support air quality objectives.

These include the following:

Table 3-1 Programmes to support air quality objectives

Sectoral programme/fund EUR / period Ministries responsible

National strategic fund for sus-

tainable mobility86

3.7 billion from

2016 to 2033

Ministry for Economic Development and Ministry

of Infrastructure and Transport

National energy efficiency fund87 400 million to 2020 Ministry for Economic Development and Ministry

of Environment, Land and Sea

Boiler fund (providing incentives

to buy certified, energy efficient

heating systems)88

900 million / year National energy company (GSE), under the Min-

istry for Economic Development

Fund for the replacement of

public buses89

Over 800,000 for

2014

Ministry of Infrastructure and Transport

Test home-school and home-

work mobility plan90

35 million in 2016 Ministry of Environment, Land and Sea

86 National strategic fund for sustainable mobility: Art. 1(613 and 615) of Law 232/2016,

http://www.gazzettaufficiale.it/eli/id/2016/12/21/16G00242/sg 87 National energy efficiency fund, Art. 15(1) of Legislative Decree 102/2014: https://www.sviluppoeconom-

ico.gov.it/index.php/it/energia/efficienza-energetica/fondo-nazionale-efficienza-energetica 88 Boiler fund, Ministerial Decree 28/12/2012: https://www.gse.it/servizi-per-te/efficienza-energetica/conto-

termico 89 Fund for the replacement of public buses, Art. 54(1) of Law 488/99: http://www.mit.gov.it/norma-

tiva/contributi-per-acquisto-e-sostituzione-di-autobus-destinati-al-tpl 90 Ministerial Decree 208/2016: http://www.pdc.minambiente.it/it/news-ed-eventi/bando-progetti-di-mobil-

ita-sostenibile-casa-scuola-e-casa-lavoro; and http://www.minambiente.it/sites/default/files/archivio/al-legati/mobilita_sostenibile/dm_28_07_2016_208_mobilita_programma_sperimentale.pdf

http://www.gazzettaufficiale.it/eli/id/2016/12/21/16G00242/sg

https://www.sviluppoeconomico.gov.it/index.php/it/energia/efficienza-energetica/fondo-nazionale-efficienza-energetica




https://www.gse.it/servizi-per-te/efficienza-energetica/conto-termico

https://www.gse.it/servizi-per-te/efficienza-energetica/conto-termico

http://www.mit.gov.it/normativa/contributi-per-acquisto-e-sostituzione-di-autobus-destinati-al-tpl




http://www.pdc.minambiente.it/it/news-ed-eventi/bando-progetti-di-mobilita-sostenibile-casa-scuola-e-casa-lavoro




http://www.minambiente.it/sites/default/files/archivio/allegati/mobilita_sostenibile/dm_28_07_2016_208_mobilita_programma_sperimentale.pdf








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Sectoral programme/fund EUR / period Ministries responsible

Marebonus91, to shift goods from

road to sea transport

200 million Ministry of Infrastructure and Transport

Ferrobonus92, to shift goods

from road to rail transport

160 million per year

plus funds of Ligu-

ria, Lombardy and

Piedmont regions

Ministry of Infrastructure and Transport


An analysis of the costs of non-implementation of the AAQ Directives was not found.


Interviewees referred in particular to health benefits stemming from the implementation of the

AAQ Directives.

One interviewee at national level noted that few air quality plans in Italy have been assessed in

terms of their costs and benefits. This was also indicated by an interviewee in an academic insti-

tution.

A ex-post modelling analysis was recently undertaken of Lombardy’s 2013 air quality plan (see

the box below). This assessment found that direct benefits outweighed the costs of the plan, and

it also noted that the plan would have further, indirect benefits, for example for climate change.

91 Art. 1 (647 and 649) Law 208/2015: http://www.mit.gov.it/documentazione/ferrobonus-e-marebonus-

contributi-ed-incentivi-per-lintermodalita 92 Art. 1 (647 and 649) Law 208/2015: http://www.mit.gov.it/documentazione/ferrobonus-e-marebonus-contributi-ed-incentivi-per-lintermodalita

http://www.mit.gov.it/documentazione/ferrobonus-e-marebonus-contributi-ed-incentivi-per-lintermodalita






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Text box 3-3 Cost-benefit analysis of Lombardy’s 2013 air quality plan

An independent cost/benefit analysis was prepared of the Lombardy’s 2013 air quality plan93. The analysis

used a model and software, RIAT+, developed by an EU LIFE project, Opera94.

Lombardy’s 2013 plan (Piano Regionale degli Interventi per la qualità dell’Aria, PRIA) contained 66

measures:

• 26 measures for road transport and mobility

• 27 for stationary sources and energy efficiency

• 13 for agricultural and forestry activities

The model was used to estimate the costs of these measures along with their direct benefits of the plan

(primarily linked to reduce fuel consumption) and their health benefits. The results presented benefits for

the actions specifically in 2020 in terms of four sectors where the plan acted. The study notes that for

transport and heat generation, the estimated direct benefits exceed the costs; for electricity generation,

this is not the case. Notably, for electricity generation were considered to have low health benefits as power

plants in the region already had advanced pollution controls as well as high chimneys dispersing remaining

pollutants.

Table 3-2 Estimated costs and direct benefits of Lombardy’s 2013 air quality plan (in 2015 and 2020)

Measures 2020:

Costs

2020:

Direct benefits

2020: Health

benefits

Private transport 208 966 57

Measures 2020:

Costs

2020:

Direct benefits

2020: Health

benefits

Public transport and other modes 846 1454 <0.1

Electricity generation 2590 2058 <0.1

Heat generation 3781 8688 37

Total 7425 13166 80

The study notes that many measures had objectives in addition to air quality, such as for urban mobility

and for the reduction of greenhouse gas emissions, and their implementation should also lead to benefits

in these areas. The study emphasised that this interaction with other policy objectives shows that ‘Perhaps

there is little use in trying to devise and evaluate a “pure” air quality plan’.

Under the LIFE PREPAIR project95 (see section 2.6), the RIAT+ model mentioned in the box will

be used to estimate the costs and benefits of current regional plans in the Po Valley region.

93 Carnevale, C., et al, Assessing the Economic and Environmental Sustainability of a Regional Air Quality

Plan, sustainability, Vol. 10, 2018, doi:10.3390/su10103568; University of Brescia, Politecnico di Milano,

TerrAria srl, Progetto VALUTA Convenzione ARPAL – POLIMI – UNIBS, 2014 94 ARPA Emilia Romagna et al, Opera: RIAT+. ARPA Emilia Romagna et al, Opera: The project (web page):

http://www.operatool.eu/html/eng/project.html 95 http://www.lifeprepair.eu/?lang=en

http://www.operatool.eu/html/eng/project.html

http://www.lifeprepair.eu/?lang=en



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4 CONCLUSIONS


the Directives


1. Ongoing exceedances of limit values and issues related to air emissions from traffic and from

heating

2. Difficulties in establishing shared solutions with sectoral authorities

3. Delays in implementation of improved monitoring approaches and in the preparation of air

quality plans in some regions (including Sicily)




4.2.1 Relevance

The objectives of AAQDs have been and remain relevant to the needs of citizens in Italy, in par-

ticular as air quality continues to pose a threat to the health of citizens and to the environment.

One issue discussed by interviewees in national government is whether the current limit values

are appropriate or whether more stringent WHO values should be considered. On the one hand,

it was noted that Italy continues to struggle to meet the AAQD requirements and thus it would

not be practical to implement more stringent limit values; on the other hand, it was noted that

the WHO guidelines should be considered for the long-term protection of human health and the

environment. National assessments, such as ISPRA’s annual data report, also provide results in

terms of population exposure to pollutant levels above current WHO guidelines.

According to the 2017 Eurobarometer results (see section 3.1), Italian citizens are concerned

about air quality: about 61% of respondents perceive that air quality has worsened in the past 10

years (see section 3.1), though ISPRA data suggests that across the country as a whole there has

been a slight improvement. Moreover, 43% of Eurobarometer respondents indicated that air qual-

ity should be addressed at EU level, though a nearly similar share, 38%, cited the national level.

4.2.2 Effectiveness

The information gathered shows that the AAQD have played an important role in strengthening

the monitoring of air quality in Italy: while some regions already had extensive air quality mon-

itoring, the AAQD’s requirements prompted the national and regional governments to upgrade

monitoring stations and integrate into an integrated network with common quality control ap-

proaches. The AAQD also prompted the use of modelling to address gaps. For regions with less

advanced systems such as Sicily, the AAQD should have an even stronger impact – though as

described in the previous sections, delays in implementation continued in Sicily in 2018.

Already before the AAQD, Italy carried out regular air quality assessments at national level and

in many regions. The AAQD strengthened the information base for these assessments and their

implementation has ensured that all regions prepare annual assessments.



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Implementation of the AAQD has also led to improvements in public information on air quality

levels, in particular the presentation of map data and air quality projects in some regions, as seen

in the example of Lombardy presented in section 2.5 above.

The Directives moreover prompted improvements in actions to address air quality problems, no-

tably via the preparation of air quality plans to address air quality issues. Italy’s implementation

of the Directives has included requirements that all regions prepare such air quality plans, the

development of common guidelines for the plans and the preparation of inter-regional agreements

for the Po Valley.

Little information was found, however, on the implementation of these plans and their actual

results: for example, ex-post evaluations have not been found.

In terms of results, in fact, many zones continue to exceed the AAQD limit values. As indicated,

air quality overall has improved in Italy but only slowly.

4.2.3 Efficiency

There is limited information on the costs of measures in air quality plans: for example, the plans

for the Lombardy region indicate costs of many but not all measures; for the 2018 air quality plan

for Sicily, costs have been estimated. As noted, ex-post evaluations of the regional plans have

not been identified, nor information on the actual costs incurred for their implementation.

4.2.4 Coherence

Over the evaluation period, several national policies have incorporated air quality as a goal. Here,

the AAQD appear to have played an important role in spurring cooperation.

As noted above, the AAQD have strengthened the integration of monitoring stations into regional

networks and the linking of regional networks into a national system with common methods.

The development of regional air quality plans, following AAQD requirements, has spurred coordi-

nation with mobility plans, rural development programmes and energy efficiency initiatives. The

plans have also strengthened coordination between regional and municipal levels and among mu-

nicipal governments.

Italy has used EU funding to address air quality. Notably, a current project under the LIFE Pro-

gramme, PREPAIR, is supporting the implementation and coordination of air quality plans in the

Po Valley; this and a previous project has supported modelling of the costs and benefits of air

quality plans. In addition, air quality plans have been linked to actions under the Rural Develop-

ment Programmes financed by EAFRD. It is not clear if there has been a strong link to ERDF

funding, which in fact is used to address air pollution in the 2014-2020 programming period.

EU policy also promotes the development of Sustainable Urban Mobility Plans (SUMPs). By late

2018, 35 Italian cities had approved or adopted such plans and a further 70 had plans in prepa-

ration. Many SUMPs reviewed, such as those for Ferrara and Milan, refer to the objectives of

regional air quality plans.

Several interviewees raised concerns, however, about a lack of coherence with EU policies for fuel

taxation, which allow lower taxation of diesel fuel, and for renewable energy, as the latter have

promoted biomass combustion.



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Before the evaluation period, Italy had in place pollution concentrations limits for all the pollutants

regulated by the AAQD, with one exception: Directive 2008/50/EC introduced target and limit

values for PM2.5. National Decree 155/2010, transposing the Directive, aligned these limits to

those of the AAQD.

Air quality monitoring and assessment has been in place for a long period. The AAQD have estab-

lished a common European approach; moreover, the Directives have prompted Italy to establish

national guidelines and QA, ensuring greater harmony across the country.

Information on air quality was provided in many but not all urban areas in Italy before the AAQD;

the Directives ensured a minimum common level of access (though full implementation of the

monitoring and reporting requirements has not yet been achieved in Sicily).

In addition, the AAQD established requirements for air quality plans and prompted the develop-

ment of national guidelines for these plans. Here too, the Directives prompted a more uniform

approach across the country for a problem that had been tackled on a more piecemeal and less

coordinated basis.

A review of selected case law96 in Italy has not found evidence that the AAQD has changed access

to justice, however. The largest share of air pollution case law focuses on emissions rather than

air quality. Case law concerning air quality often involves local restrictions on traffic and the ex-

amples reviewed do not contain direct references to EU legislation.

The requirements of the AAQD are seen, however, as having a catalytic effect in Sicily: without

EU legislation, all the interviewees felt that actions to improve monitoring systems and develop

an air quality plan would not have been taken.

96 As found on the Lexambiente.it web site



(2008/50/EC, 2004/107/EC)

March 2019 39


ARPA Sicilia, Relazione annuale sullo stato della qualità dell’aria nella Regione Siciliana anno

2017 (Annual report on the state of air quality in the Sicily Region, 2017), June 2018

ARPA Sicilia, Approvato il piano regionale di tutela della qualità dell’aria (press release), July

2018: https://www.arpa.sicilia.it/news/approvato-il-piano-regionale-di-tutela-della-qualita-

dellaria/

ARPA Sicilia, Piano Regionale di Tutela della Qualità dell’Aria (Regional plan for the protection of

air quality), July 2018

Carnevale, C., et al, Assessing the Economic and Environmental Sustainability of a Regional Air

Quality Plan, sustainability, Vol. 10, 2018, doi:10.3390/su10103568

Comune di Agrigento, Piano Urbano della Mobilità Sostenibile della città di Agrigento e connessa

Valutazione Ambientale Strategica, November 2015. Available at:

https://www.comune.agrigento.it/download/anno_2016/PUMS_2016_DG_108_16/001%20Relaz

ione%20Generale.pdf

Comune di Ferrara, PUMS: Piano Urbano della Mobilità Sostenibile – Linee di Indirizzo, June

2016. Available at:


Comune di Messina, Linee guida per la “Pianificazione strategica della mobilità urbana finalizzata

all’aggiornamento del Piano Urbano della Mobilità in coerenza con le politiche e pratiche europee

(PUMS)”, prepared by Prof. Ing. Domenico Gattuso, March 2018. Available at:

https://www.pumsmessina.it/2018/04/26/approvato-il-documento-finale-delle-linee-guida-

pums/

Comune di Milano and AMAT, Piano Urbano Mobilità Sostenibile Milano – Documento di Piano,

November 2016 (Amended June 2017)

EEA, Air quality in Europe – 2018 report, EEA Report No. 12/2018. Available at:


Eltis: the urban mobility observatory, Italy (web page), accessed November 2018:


Endurance: Osservatorio PUMS, L’Osservatorio – I PUMS in Italia: stato dell’arte (web page),

accessed November 2018. Available at: http://www.osservatoriopums.it/osservatorio/pums

European Commission, Infringement decisions, web page: http://ec.europa.eu/atwork/applying-

eu-law/infringements-proceedings/infringement_decisions/?lang_code=en

European Commission, Press release: Commission warns Germany, France, Spain, Italy and the

United Kingdom of continued air pollution breaches, 15 February 2017,


European Commission, Press Release: Air quality: Commission urges Italy to take action against

small particulate matter (PM10) to safeguard public health, 27 April 2017,











http://www.osservatoriopums.it/osservatorio/pums







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March 2019 40

European Commission, Special Eurobarometer 468: Attitudes of European citizens towards the

environment (Survey conducted by TNS political & social), October 2017. Available at:

http://ec.europa.eu/commfrontoffice/publicopinion/index.cfm/ResultDoc/download/DocumentKy

/81259

EU Open Data Portal, Special Eurobarometer 468: Attitudes of European citizens towards the

environment, released 2017. Available at:

https://data.europa.eu/euodp/data/dataset/S2156_88_1_468_ENG


(2013 & 2014): Italy

European Commission, DG Environment, The EU Environmental Implementation Review Country

Report – ITALY, SWD(2017) 47 final, February 2017. Available at:


European Commission, Eurostat, GDP and Population data: accessed October and November

2018

ISPRA, Qualità dell’ambiente urbano, XII Rapporto, Focus su inquinamento atmosferico nelle

aree urbane ed effetti sulla salute, December 2016

ISPRA, Qualità dell’ambiente urbano – XIII Rapporto (Quality of the urban environment – 12th

Report), 2017. Available at: http://www.isprambiente.gov.it/it/pubblicazioni/stato-

dellambiente/xiii-rapporto-qualita-dellambiente-urbano-edizione-2017

ISPRA and SNPA, Dati sull’ambiente: annuario dei dati ambientali 2017 (Environmental data:

2017 annual report of environmental data), December 2017 (http://annuario.isprambiente.it/)

Ministry of Environment, Land and Sea, Sviluppo sostenibile e rapport internazionali (web

pages): http://www.minambiente.it/pagina/sviluppo-sostenibile-e-rapporti-internazionali;


Ministero dell’Ambiente e della Tutela del Territorio e del Mare, Strategia Nazionale di Sviluppo

Sostenibile, 2017.Available at:

http://www.minambiente.it/sites/default/files/archivio_immagini/Galletti/Comunicati/snsvs_otto

bre2017.pdf

Ministero dell’ambiente e della tutela del territorio e del mare and Associazione Italiana Energie

Agroforestali (AIEL), Protocollo di Intesa per la promozione di azioni e di iniziative finalizzate alla

riduzione delle emissioni degli impianti termici alimentati a biomasse legnose, available at:

http://www.minambiente.it/sites/default/files/archivio/allegati/inquinamento_atmosferico/Protoc

ollo_Intesa_MATTM_AIEL.pdf

OECD, Environmental Performance Reviews: Italy, 2013. Available at:


Querol, X., et al, Biomass burning in southern Europe, AIRUSE (LIFE 11 ENV/ES/584) Report no.

8, December 2016. Available at: http://airuse.eu/wp-content/uploads/2013/11/R08_AIRUSE-

Biomass-Burning-SE-ATH-TR.pdf

Regional air quality web pages:



https://data.europa.eu/euodp/data/dataset/S2156_88_1_468_ENG


http://www.isprambiente.gov.it/it/pubblicazioni/stato-dellambiente/xiii-rapporto-qualita-dellambiente-urbano-edizione-2017

http://www.isprambiente.gov.it/it/pubblicazioni/stato-dellambiente/xiii-rapporto-qualita-dellambiente-urbano-edizione-2017













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• Lombardy: http://www.arpalombardia.it/sites/qaria/_layouts/15/qaria/imodelli.aspx

• Emilia-Romagna: https://www.arpae.it/dettaglio_generale.asp?id=2921&idlivello=1637

• Sicily: https://www.arpa.sicilia.it/storage/index.php?dt=5/10/2018#titoloinizio

Carnevale, C., et al, Assessing the Economic and Environmental Sustainability of a Regional Air

Quality Plan, sustainability, Vol. 10, 2018, doi:10.3390/su10103568; University of Brescia,

Politecnico di Milano, TerrAria srl, Progetto VALUTA Convenzione ARPAL – POLIMI – UNIBS, 2014

http://www.arpalombardia.it/sites/qaria/_layouts/15/qaria/imodelli.aspx

https://www.arpae.it/dettaglio_generale.asp?id=2921&idlivello=1637

https://www.arpa.sicilia.it/storage/index.php?dt=5/10/2018#titoloinizio



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Organisation Name and position Date of the interview

National Ministry of Environment,

Land and Sea

Fabio Romeo 19/09/2018

Greenpeace Italia Andrea Boraschi 04/10/2018

ISPRA (national Institute for Environ-

mental Protection and Research)

Giorgio Cattani 05/10/2018

ARPA (Regional Environment Agency)

Sicilia

Ana Abita 09/10/2018

Regional assembly, Sicily Giampiero Trizzino 09/10/2018



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March 2019 43


General questions




learn from?


tives?



exchange, etc.)?



Specific questions




(2008/50/EC, 2004/107/EC)

March 2019 44


RELEVANCE








gress?



try)?



zens' needs?







become redundant?

EFFECTIVENESS



















grammes


mation to public?







EFFICIENCY









Directives?










tives?




for Member States)?














(2008/50/EC, 2004/107/EC)

March 2019 45













COHERENCE





























ments)?



NEC Directive?











ADDED VALUE










quality objectives?


in monitoring?








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March 2019 46








quality management?




ties)?






March 2019 47

APPENDIX D POLLUTANT CONCENTRATION DATA FOR ITALY, 2013-17

Table 4-1 Highest pollutant concentrations in exceedance of EU air quality objectives for protection of health in Italy in 2013-2017 - extract from reporting (Data-

flow G).


tive

Parameter shown 2013 2014 2015 2016 2017

PM10 Calendar year LV: 40 μg/m3 1 January 2005 Annual mean, μg/m3 NA NA 56 45 49


ceeded on more than 35

days per year

1 January 2005 Days above NA NA 126 89 118

NO₂ Calendar year LV: 40 μg/m³ 1 January 2010 Annual mean, μg/m3 NA NA 75 70 80



hours per year

1 January 2010 Hours above NA NA 57 28 25



per year

1 January 2005 Days above NA NA - - -



hours per year

1 January 2005 Hours above NA NA - - -


mean

LV: 10mg/m3 1 January 2005 Days above NA NA - - -

C6H6 Calendar year LV: 5 μg/m3 1 January 2010 Annual mean, μg/m3 NA NA - - -


content in PM10)

1 January 2005 Annual mean, μg/m3 NA NA - - -

O3 Maximum daily eight-

hour mean




over three years

1 January 2010 Days above NA NA 139 170 109



March 2019 48


tive

Parameter shown 2013 2014 2015 2016 2017

Maximum daily eight-

hour mean within a cal-

endar year

LTO: 120 μg/m³ Not defined Days above NA NA 97 144 117

PM2.5 Calendar year LV: 25 μg/m³ 1 January 2015 (target

value until 1 January 2010)

Annual mean, μg/m3 NA NA 33 36 34

(calculated as Average

Exposure Indicator, as-

sessed as a 3-year run-

ning annual mean)


As Calendar year TV: 6 ng/m³ (measured as

content in PM10)

31 December 2012 Annual mean, ng/m3 NA NA - - 8

Cd Calendar year TV: 5 ng/m³ (measured as

content in PM10)

31 December 2012 Annual mean, ng/m3 NA NA - 5 6


content in PM10)

31 December 2012 Annual mean, ng/m3 NA NA - 21 -

BaP Calendar year TV: 1 ng/m³ (measured as

content in PM10)

31 December 2012 Annual mean, ng/m3 NA NA 3 4 2


Note: LV: limit value; TV: target value; LTO: Long term objective; ECO: exposure concentration obligation; The values show the maximum exceedance reported in the

Member State (if no exceedances are reported in any of the zones of the Member State, the table shows "-")

Legend: "NA": not available in data flow G, "-": no reported exceedance

Written by Sandra Fisker March 2019

CASE STUDY REPORT

SLOVAKIA



(2008/50/EC, 2004/107/EC)



(2008/50/EC, 2004/107/EC)

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Contents

1 Introduction 4


2.1 Italy and air quality zone characteristics 5











AAQ Directives 23


4 Conclusions 29






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Appendices




Appendix D Areas of air quality management

Appendix E Extract from reporting (Dataflow G)



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1 INTRODUCTION

This report summarises the findings and conclusions of the case study for Slovakia. The case

study had a focus on Košice region.

















the case study







in Appendix A.






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Chapter 1 provides general information about Slovakia and the Košice region.

2.1 Italy and air quality zone characteristics

2.1.1 The scope and focus of the case study

The case study covers the entire territory of Slovakia and focuses in particular on the Košice region

and the Košice agglomeration.

As shown in in the figure below, the territory of the Slovak Republic is divided into 8 zones and 2

agglomerations (Bratislava and Košice) for the purpose of assessing air quality. The air quality

zones correspond to administrative divisions of Slovakia.



2014), Slovakia.

As shown in the figure above, the Košice region is one of eight Slovak administrative regions. The

region is located in the south-eastern Slovakia and the entire region (including the Košice agglom-

eration) has the population of nearly 800,000 inhabitants (approximately 14.7% of the total pop-

ulation of Slovakia).1 About one third of the region’s population lives in the agglomeration of

Košice. The region is the centre of heavy industry (in particular non-ferrous and ferrous metal-

lurgy) and is characterised by relatively high concentrations of PM10 and BaP in the ambient air.

1 https://web.vucke.sk/files/dokumenty/pub/regionalny_rozvoj/phsr/2015/prilohy/priloha_1_podrobna_ana-lyza_kosickeho_kraja.pdf



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Figure 2-2 Košický kraj

Source: Source: European Commission, DG Environment, Atlas of air quality zones and monitoring stations

(2013 & 2014), Slovakia.

In addition to defining zones and agglomerations as required in the AAQDs, Slovakia’s Act on Air

Protection, Article 9(3) provides for defining smaller areas of air quality management (i.e. an

agglomeration or an air quality zone zone) that meet specific air quality criteria: exceedance of

the "(1) the limit value of one substance or more pollutants increased by the tolerance limit, (2)

the limit value of one substance or more pollutants, if no tolerance limit is determined, (3) the

target value for ozone, particles PM2,5,arsenic, cadmium, nickel, or benzo(a)pyrene".2 The areas

of air quality management are identified by the Slovak Hydrometeorological Institute (SHMI)

based on an evaluation of air quality for the previous calendar year.3 In 2016, 12 areas of air

quality management have been identified within the Slovak territory, out of these two were located

in the Košice region/agglomeration (the territory of cities Košice, Bočiar, Haniska, Sokoľany and

Velka Ida and the territory of city Krompachy). Appendix D provides an overview of the areas of

air quality management as defined in 2016.

Pursuant to Article 11 of the Act on Air Protection, the district office in the seat of the region is

required to elaborate air quality plans or integrated air quality plans for each area of air quality

management within its competence (see below) with the view of achieving good air quality. As

such, the areas of air quality management correspond to some extent the areas specified in Article

23 of Directive 2008/50/EC (i.e. areas for which air quality plans should be drafted), but, in addi-

tion to the pollutants covered by the Directive 2008/50/EC, cover also pollutants for which target

values have been set by the Directive 2004/107/EC.

2.1.2 Geomorphology

The Slovak territory has a complex geomorphology. There are many hills, but also many low-lying

areas, such as valleys, with bad dispersion conditions. Under certain weather conditions, pollu-

tants can become trapped in such areas. Similarly, from a geomorphologic point of view, the

2 See Article 9(2) of the Act on air protection. The Law on air protection continues to refer to target value,

rather than a limit value for PM2.5 3 Art. 9 (3) of the Act No 137/2010 Coll. on Air protection.



(2008/50/EC, 2004/107/EC)

March 2019 7

territory of Eastern Slovakia is rugged and varied. Mountainous areas, as well as lowland areas

are situated within this region. Western and Eastern Carpathians meet here.4

The detailed characteristics of Slovakia and of the Košice region/agglomeration are presented in

the text-box below.

Text box 2-1 Slovakia and the Košice region

Slovakia


GDP per capita growth (% 2008-2016) 16%

Population (1 January 2017) 5,4 million

Governance structure Unitary


Košice region & Košice agglomeration

Number of inhabitants: 558 962 (Košice region)

239 141 (Košice agglomeration)

Area: 6 511 km² (Košice region)

244 km² (Košice agglomeration)

Characteristics of the Košice region:

The section below provides a short summary of the main characteristics of the region, focusing on the towns

of Krompachy, Strážske and Veľká Ida.

Krompachy

4 http://www.arr.sk/file/projekty_file99.pdf



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Slovakia

The town Krompachy is located in a valley system with good local air circulation. The southern part of the

town lies in the Slovinka River valley surrounding by hills with an elevation of 350 m. The northern part of

the city is placed in the valley of the Hornád River with an east-west orientation determining airflow. The

main source of air pollution in Krompachy is ferrous metal plant Kovohuty ((PM, SO₂ and CO)5 ) and local

heating systems as well.

Strážske

The town Strážske is located to the east of Vihorlat hills in the northern part of the Eastern Slovak lowland

in so called Brekov Gate area – with the orographically increased air flow, mainly from the north. The local

chemical industry in the town represents the main source of air pollution (SO₂, NOX, PM, CO).

Veľká Ida

The town is located at the border line of the Košice Basin and the Moldava Lowland. The area is surrounded

by the Abov hills in the south, by the Slovak Kras from the west and the Slovak Rudohorie from the north.

Towards the west lies the valley of the Hornad River. The main air pollution (PM, SO₂, NOX and CO) source

is the nearby ferrous metallurgy complex and large dumps from extracted ores.

Characteristics of the Košice agglomeration:

The city of Košice spreads out in the valley of Hornád River and the surrounding area. The composition of

the mountains surrounding the city affects the climatic conditions of the area. The main share of air pollution

in the area comes from heavy industry, in particular engineering, non-ferrous and ferrous metallurgy, as

well as limestone processing. Energy sources, including the city heating plants and local boiler houses emit

less amounts of pollutants (PM10 and PM2.5, SO₂, NOX, VOC and benzo(a)pyrene).



Population on 1 January; Eionet data and the report Air pollution in the Slovak republic, 2016.


The following section presents briefly the arrangements made in Slovakia for air quality monitoring

and provides a short overview of air quality achievements in Slovakia, focusing in particular on

the period 2014-2016. Detailed information regarding the exceedances reported in the EEA data-

base6 is presented in Appendix E to this report.


The national air pollution monitoring network in Slovakia is maintained by the Slovak Hydrome-

teorological Institute (SHMI). Air quality monitoring has a long history in Slovakia. The SHMI has

been monitoring the level of air pollution since 1971, when the first two manual stations were put

into operation. Over the next years, the measurements were gradually extended to the most

polluted cities and industrial areas.

At the end of 2007, the monitoring network consisted of 34 monitoring stations.7 As of 2016 the

network included 38 monitoring stations, 4 of them are rural stations belonging to the EMEP mon-

itoring network. Out of the 38 monitoring stations, 8 are placed in the Košice region.8 In addition

to the national network, the largest emission sources are obliged to build, operate and measure

air pollution resulting from these sources. These monitoring stations are operated independently

from the SHMI.

5 http://www.shmu.sk/File/oko/rocenky/Air_pollution_in_the_SR_2016.pdf 6 http://cdr.eionet.europa.eu/sk/eu/aqd/ and http://www.shmu.sk/File/oko/hodnotenie/2016_Hod-notenie_KO_v_SR.pdf 7 http://www.shmu.sk/File/oko/hodnotenie/2007_Hodnotenie_KO_v_SR.pdf 8 http://europa.eu/rapid/press-release_MEMO-17-3494_en.htm

http://cdr.eionet.europa.eu/sk/eu/aqd/

http://cdr.eionet.europa.eu/sk/eu/aqd/

http://www.shmu.sk/File/oko/hodnotenie/2007_Hodnotenie_KO_v_SR.pdf




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The shortcomings in the Slovakian monitoring network in terms of number and type of sampling

points are currently subject to infringement proceedings.9 The conclusions of the Clean Air Dia-

logue between Slovakia and the European Commission indicate that Slovakia is committed to

upgrade its monitoring network by the end of 2019. The conclusions further specify that this

upgrade will include "improvements in the inventories of air pollutant emissions, air quality mod-

elling as well as more and better quality fixed air quality measurements"10 and the addition of 14

new sampling points to the monitoring network.11

2.2.2 Air quality in Slovakia

Particulate matter concentrations in the ambient air continue to be the greatest challenge for air

quality and health in Slovakia. Domestic solid fuel combustion is the main source of particulate

matter emissions. Overall, industry, domestic heating, road traffic, together with long range

transport are among the main pollution sources.12

Figure 2-3 Emissions of particulate matter in 2016

Source: Air pollution in the Slovak republic, 2016.

In 2004 there were 17 air quality management areas (i.e. areas in which a limit or target value

for one or more pollutants has been exceeded, see above) while, in 2016 there were only 12.

Moreover, the total area of air quality management has, according to the information provided by

the MoE decreased by 52%, and the number of inhabitants living in these areas by 54%.13

As far as emissions of various pollutants are concerned, a reduction was reported as between

1990 and 2015. However, the speed of this reduction after 2000 slowed down significantly. In

2015 a reduction of NOX and CO emissions has been reported compared to 2014. In contrast, for

other pollutants annual increases were recorded. This is the case especially for particulate matter

PM2.5 and PM10 (slight increase) and for SO₂ (large increase).14

9 http://europa.eu/rapid/press-release_MEMO-17-3494_EN.htm 10 Conclusions of the Clean Air Dialogue between Slovakia and the European Commission, taking place in Bratislava on 24 -25 April 018 11 Ibid. 12 OECD, Environmental Performance Reviews, Slovak Republic, 2011. 13 Ministry of Environment, Additional information on progress made in Air Quality in Slovakia. Published by

the EEB. 14 State of Environment Report (2016), http://enviroportal.sk/spravy/detail/6961.


http://enviroportal.sk/spravy/detail/6961



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Figure 2-4 Emissions of basic pollutants in the Slovak republic within 2009-2016

Source: Slovak Hydrometeorological institute, Air pollution in the Slovak republic 2016.


In 2014 exceedances of standards set for the protection of human health were reported as to

NO₂, O3, PM10, PM2.5 and SO2 and of standards set for the protection of vegetation as regards O3.15

As for PM10 in 2014 the limit value for human health protection for 24-hour concentration was

exceeded at 10 monitoring stations (Bratislava – Trnavské Mýto, Košice – Štefánikova, Banská

Bystrica – Štefánikovo náb., Jelšava – Jesenského, Veľká Ida – Letná, Krompachy – SNP, Prešov

– arm. gen. Ľ. Svobodu, Trenčín – Hasičská, Ružomberok – Riadok a Žilina – Obežná).

In 2015 exceedances of standards set for the protection of human health were reported for NO₂,

O3, PM2.5 and PM10 and of standards set for the protection of vegetation as regards NOX as NO₂

and O3. As for PM10 exceedances were recorded at 5 monitoring stations (Bratislava - Trnavské

Mýto, Banská Bystrica - Štefánikovo náb., Jelšava Jesenského, Veľká Ida - Letná, Trenčín -

Hasičská).

In 2016 the Slovak authorities have communicated exceedances above EU air quality standards

of PM10 in one quality zone, located in the Košice region. Furthermore, the target values and long-

term objectives regarding ozone concentrations were exceeded in Bratislava. Finally, the target

values for BaP have been exceeded in one air quality zone, located in the Košice region (monitoring

station Veľká Ida).16

In 2017, the PM10 the limit value for human health protection for 24-hour concentration was again

exceeded at all 10 monitoring stations, and also in Riadok a Žilina for the annual limit value. The

target values and long-term objectives regarding ozone concentrations were like in the previous

15 Attainments of (air quality) environmental objectives reported by countries (data flow G) https://www.eea.europa.eu/data-and-maps/data/aqereporting-8. 16 Ibid.

https://www.eea.europa.eu/data-and-maps/data/aqereporting-8



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year exceeded in Bratislava. For PM2.5 exceedances were experienced in Banská Bystrica and Ri-

adok a Žilina. Finally, exceedances for BaP were found in Bratislava.

The breaches of air quality requirements regarding PM10 were being followed up by the European

Commission through infringement procedures.17 As of May 2018 the European Commission in-

formed that the measures being put in place or planned in Slovakia, as communicated to the

Commission, "appear to be able to appropriately tackle the identified gaps, if correctly imple-

mented. For this reason, the Commission will continue to closely monitor the implementation of

these measures as well as their effectiveness in redressing the situation as soon as possible."18

Clean air dialogue

In April 2018, the Commission held a "Clean Air Dialogue" with Slovakia to promote actions to

improve air quality and contribute to Slovakia's compliance with EU air quality rules. The dialogue

focused on the main challenges Slovakia faces –emissions from the burning of solid fuel in homes,

emissions from agriculture, transport and industry. In addition, the need for robust air quality

monitoring and air pollution data, and integrated policy making across levels of governance were

also discussed.19




and the implementation of other obligations laid down by the AAQ Directive. In the Slovak Repub-

lic, the allocation of responsibilities is prescribed in Article 22 of the Act on Air protection. Specif-

ically, the air quality protection authorities in Slovakia include the Ministry of Environment, the

Slovak Environmental Inspectorate, district offices in the seat of the region, district offices and

municipalities (see below).

The main responsibility for ambient air quality, including the transposition and implementation of

the AAQ lies with the Ministry of Environment as the central authority. The day-to-day monitoring

of air quality and modelling has been delegated to the Slovak Hydrometeorological Institute

(SHMI).

The SHMI is a state-subsidised organisation operating under the Slovak Ministry of Environment.

The SHMI's activities include monitoring of quantitative and qualitative parameters of the air in

Slovak territory, collecting, verifying, interpreting and archiving data and information on the con-

dition and regime of air, describing developments in the atmosphere, issuing forecasts, warnings

and other information regarding the atmosphere.20

District offices in the seat of the region elaborate, among other things, air quality plans and short-

term action plans.21 The district offices in the seat of the region have responsibility for ensuring

air quality not only in its own district, but in all districts within the region. The district offices fall

under the responsibility of the Ministry of Internal Affairs, but the Ministry of Environment is re-

sponsible for the methodological management.

17 http://europa.eu/rapid/press-release_IP-18-348_en.htm. 18 http://europa.eu/rapid/press-release_IP-18-3450_en.htm 19 lhttps://ec.europa.eu/info/news/clean-air-dialogue-between-commission-and-slovakia-promotes-actions-

cleaner-air-2018-apr-26_en 20 http://www.shmu.sk/en/?page=1793 21 See Article 25 of the Act on Air protection.


http://www.shmu.sk/en/?page=1793



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Text box 2-2 District office in Košice

The district office in Košice is responsible for air quality management in the entire Košice region (consisting

of 8 districts). The district office elaborates air quality plans, short term action plans, is responsible for

informing the public and fulfils other obligations as laid down in Article 25 of the Act on air protection. In

addition, the district office drafts and publishes reports on air quality in the region.

Source: Interview, district office in the seat of the Košice region; and Act on air protection.

The Slovak Environmental Agency is responsible for the coordination of reporting to the EU in the

areas of environment. The monitoring information is supplied by the SHMI.


Legal framework

The Ambient Air Quality Directives (2008/50/EC and 2004/107/EC) were transposed in the Act No

137/2010 Coll. on Air protection and a number of implementing regulations of the Ministry of

Environment.22

Strategic framework

The principles and priorities in air quality are laid down in a number of strategic instruments,

including the 1993 National Environmental Policy (1993)23 and the National Strategy for Sustain-

able Development of the Slovak Republic (2001).24

In 2012, the Slovak Government issued a Policy Statement for the period 2012-2016.25 The state-

ment foresees, among other things, the introduction of measures to reduce emissions from in-

dustry, energy and mobile sources.

As mentioned above, particulate matter is the main challenge for air quality in Slovakia. The

exceedances of the limit values for PM10 triggered the adoption of a strategy dedicated specifically

to tackling PM10 emissions. The strategy was prepared in cooperation between a number of dif-

ferent actors, including civil society organisations and published in 2013.26 The strategy outlined

a number of strategic priorities and specific measures to be implemented to tackle PM10 pollution.

These include:

• Measures in monitoring and identification of sources of pollution;

• Local heating;

• Transport;

• Soil;

• Information to public;

• Legislative action.

While the strategy provided a variety of measures, it did not include an implementation framework

– an action plan, interim targets, budget and institutional responsibilities. The MoE and the civil

22 http://www.minzp.sk/sekcie/temy-oblasti/ovzdusie/ochrana-ovzdusia/pravne-predpisy/ 23 http://www.minzp.sk/dokumenty/strategicke-dokumenty/strategia-zasady-priority-statnej-environmen-

talnej-politiky.html 24 https://www.thegef.org/sites/default/files/ncsa-documents/Slovakia_NSSD_Final.pdf 25 http://www.vlada.gov.sk/data/files/2008_programove-vyhlasenie-vlady.pdf 26 http://www.enviroportal.sk/uploads/files/ovzdusie/Strategia-pre-redukciu-PM-10-1.pdf

http://www.minzp.sk/sekcie/temy-oblasti/ovzdusie/ochrana-ovzdusia/pravne-predpisy/

http://www.minzp.sk/dokumenty/strategicke-dokumenty/strategia-zasady-priority-statnej-environmentalnej-politiky.html




https://www.thegef.org/sites/default/files/ncsa-documents/Slovakia_NSSD_Final.pdf

http://www.vlada.gov.sk/data/files/2008_programove-vyhlasenie-vlady.pdf



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society association CEPTA pointed to that the lack of such a framework was a major reason for

why the vast majority of measures foreseen in the strategy remain unimplemented.

The Slovak Republic is currently preparing a new air quality strategy (The Strategy for the Im-

provement of Air Quality in Slovakia) to be published in the late spring 2019.27 In contrast to the

2013 PM10 strategy, the measures proposed in the new strategy will be accompanied by a set of

indicators. The selection of measures will be informed by an economic analysis and an analysis of

how each of the measures will contribute to the reduction of the concentration of different pollu-

tants. The cost-effectiveness assessment underpinning the strategy is being prepared in cooper-

ation with the World Bank.

Finally, the National Air Pollution Control Programme will provide measures to reduce national

emissions so as to comply with the requirements (national emission ceilings) as per the revised

NEC Directive.28 The programme is expected to set coordinated directions for policies and actions

on air quality, renewable energy, energy renovation and eradication of energy poverty.29 The

Programme is planned to be approved by the government and shared with the EU Commission in

2019.

There is also a number of other measures that address the issue of air quality – e.g. measures

related to mobility (e.g. subsidy for electromobiles, development of cyclotourism, scrapping of

cars), biomass boilers, renewable energy, insulation of buildings. In other words, there is a num-

ber of measures which do not focus directly on air quality, but which nonetheless contribute to

the achievement of the air quality objectives. For example, air protection is indirectly supported

within the national project Green Households. The primary objective of the project is to increase

the share of renewable energy sources used in households. The contribution provided so far is

over EUR 35 million and for 2018 the planned budget is EUR 45 million.30


Air quality plans provide long-term measures to improve air quality. With the exception of Brati-

slava (2016) and Nitra (2014), the latest versions of air quality plans are from 2013. The latest

amendment of the Act on air protection (November 2017) introduced the obligation to review air

quality plans every three years and, if necessary, to take further measures to improve air quality.

In the Košice region, three air quality plans were adopted and published for: (1) Košice, Bočiar,

Haniska, Sokoľany and Velka Ida; (2) Krompachy and (3) Strážske.31 As indicated above, all three

plans were adopted in 2013. The district office in the Košice region indicates that an update of the

plans is foreseen in the foreseeable future to accommodate, among other things, most recent

monitoring and modelling data.

A number of short-term action plans has been adopted to tackle short-term exceedances of PM10

in the Košice region: action plans (for (1) Košice, Bočiar, Haniska, Sokoľany and Velka Ida; (2)

Krompachy and (3) Strážske).32 Similarly as for the Air quality plans, an update of these Action

Plans is foreseen.

27 More information on http://www.minzp.sk/strategia-ochrany-ovzdusia.html 28 http://www.minzp.sk/strategia-ochrany-ovzdusia.html 29 http://www.minzp.sk/files/oblasti/ovzdusie/conclusions-clean-air-dialogue-between-sk-ec-final.pdf 30 Additional information on progress made in Air Quality in Slovakia. 31 http://enviroportal.sk/ovzdusie/zlepsenie-kvality-ovzdusia 32 http://enviroportal.sk/ovzdusie/akcne-plany-na-zabezpecenie-kvality-ovzdusia

http://www.minzp.sk/strategia-ochrany-ovzdusia.html

http://enviroportal.sk/ovzdusie/zlepsenie-kvality-ovzdusia



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Pursuant to Article 26 of the AAQ Directive, Member States shall ensure that the public is – ade-

quately and in good time - informed about ambient air quality and other issues specified in the

above cited Article. In Slovakia Article 13 of the Act No 137/2010 Coll. on Air protection specifies

the measures to be implemented to ensure information to the public about air quality.

Pursuant to Articles 13(1) and 13(3) information about air quality is being published on the web-

site of the Slovak Hydrometeorological Institute (http://www.shmu.sk/sk/?page=991.) and the

websites of the district offices at the seat of the different regions. The information published in-

cludes near-real-time concentrations (most recent hourly and daily values), annuals report on air

quality and air quality assessments.33

Text box 2-3 Information to the public

The SHMI provides up-to-date information about the pollution (hourly, daily concentrations of different pol-

lutants). Every year a report on the Air pollution in the Slovak Republic is being published. This includes

information on the share of different pollution sources. These reports have been published also prior to the

implementation of the AAQ. The reports are also available on the websites of the district offices in the seat

of the region. In addition, articles providing updates on specific situations (e.g. New Year) are being pub-

lished.

The district office processes the information and puts it on its website (every week). Moreover, the district

office publishes warnings regarding exceedances. These warnings are accompanied by recommendations to

the citizens.

Source: Interview with the SHMI, district office in the seat of the Košice region; and desk review.


EU Structural funds are used and have been very helpful in Slovakia. For example, in the 2007-

2013 programming period, the direct environmental investments (allocation in EUR) from cohe-

sion policy resources for Slovakia was EUR 1,82 billion. This corresponds to approximately 19%

of the total allocation.34 Out of these, EUR 107 million (ca. 6% of the environmental investments)

have been used to finance air quality improvements. For the 2014-2020 programming period the

allocation to air quality is somewhat higher (ca. EUR 215 million) and correspond approximately

to 9.5% of the direct environmental investments (of EUR 2.25 billion).35

33 http://www.shmu.sk/sk/?page=997 34 Ex post evaluation of Cohesion Policy programmes

2007-2013, focusing on the European Regional Development Fund (ERDF) and the Cohesion Fund (CF),

2016. 35 COWI, Milieu, Integration of environmental concerns in Cohesion Policy Funds (ERDF, ESF, CF), Results, evolution and trends through three programming periods, 2017.

http://www.shmu.sk/sk/?page=991





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Figure 2-5 Allocations (EU amount in EUR million) for air quality under ERDF and CF by Member State

across the three financing periods

Source: COWI, Milieu, Integration of environmental concerns in Cohesion Policy Funds (ERDF, ESF, CF), Re-

sults, evolution and trends through three programming periods, 2017, based on (2000-2006, 2007-2013,

2014-2020) DG Regional and Urban Policy (2016) for 2000-2006; DG Regional and Urban Policy (2016) for

2007-2013; InfoRegio, ESIF categorisation (2016) for 2014-2020.

In the programming period 2007-2013 within the Operational Programme (OP) Environment air

protection has been addressed through Priority Axis 3 – air protection and minimisation of adverse

impacts of climate change. In the following programming period (2014-2020) air quality is ad-

dressed in the OP on the Quality of Environment under the Priority Axis 1 – sustainable use of

natural resources through the development of environmental infrastructure. Specific objective

1.4.1. includes the objective of reducing air pollution and improving its quality. The supported

activities include: 1) technological and technical measures to reduce air emissions from air pollu-

tion sources, in particular with the view of meeting the NEC and the AAQ Directives requirements;

2) improvements of air monitoring; and 3) greater awareness of air protection.

The SHMI informed that EU funding has been, among other things, used on investments in the

monitoring network (i.e. modernisation of the existing monitoring stations and establishment of

additional monitoring stations), upgrade of hardware and software solutions and to address large

sources of pollution.

Moreover, under the 7th call, 10 contracts were awarded to provide a non-repayable financial

contribution in the total amount of approximately EUR 64.2 million (out of which EUR 35.3 million

from the Cohesion Fund). In 8 cases the funding was provided to U.S. Steel Košice, in one case

to Žilinská teplárenská a.s. and in one case to Schüle Slovakia s.r.o. Finally, in the framework of

the 14th call, 8 contracts were concluded to provide non-repayable contribution in the total

amount of EUR 80.2 million (out of which EUR 68.1 million from the Cohesion Fund). In 7 cases

to U.S. Steel Košice and in on ecase to KOSIT a.s.). U.S. Steel Košice, which is a large integrated

steel producer in the Košice region, specified that EU resources have been used to finance tech-

nological improvements allowing further reduction of emissions (i.e. emissions further below the

limits provided in the applicable BAT conclusions).



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3 FINDINGS

This chapter presents detailed findings regarding the experience and lessons learnt in the imple-

mentation of the AAQDs in Slovakia and the Košice region in particular. Specifically, the chapter

focuses on the challenges and successes encountered in the implementation of the Directives.

Additionally, the relevance of the AAQDs, and their air quality standards, has been explored.

Finally, the chapter identifies the factors underlying compliance with and effectiveness of the

AAQDs and provides an overview of the costs and benefits associated with the implementation of

the Directives.


in the context of the case study. These were supplemented by additional desk research. An over-

view of the interviews carried out is provided in Appendix B.


Firstly, the case study explored the extent to what the AAQ Directives, and the air quality stand-

ards set within, correspond to citizens' needs.

The 1st Environmental Implementation Review indicated that air quality in Slovakia continues to

give cause for concern. For example, for 2014 the EEA estimated 5160 premature deaths due to

PM2.536 and 4344 premature deaths due to O3 pollution.37

Similarly, the findings of 2017 Special Eurobarometer confirm that air quality is a concern to

Slovak citizens. 43 % of respondents to the Eurobarometer considered that air quality in Slovakia

has remained the same over the last 10 years, while the same amount of respondents though it

has deteriorated. In contrast, only 5% of respondents were of the opinion that air quality in Slo-

vakia has improved.

The consultation carried out in the context of the case study (for an overview of the interviews

carried out see Appendix B) showed that the objectives of the AAQDs are relevant in relation to

the citizens' needs. The stakeholder consultation furthermore indicated that, while all the objec-

tives are relevant, obtaining information on ambient air quality in order to help combat air pollu-

tion and nuisance and to monitor long-term trends and improvements, and ensuring that infor-

mation on ambient air quality is made available to public are particularly important.

The objective of promoting increased cooperation between the Member States in reducing air

pollution was also mentioned as an important objective, however, the civil society association

CEPTA suggested that this objective is less important from the citizens' perspective. It was put

forward that citizens need to be able to see concrete results (i.e. improvements to their sur-

rounded air quality) and, as such, air quality measures that can be directly linked to such results

are those most relevant for citizens.

As far as the air quality standards laid down by the AAQ Directives are concerned, CEPTA sug-

gested that the standards do not reflect the needs of the citizens. The main argument for this

assertion was that the standards set by the Directive do not correspond to the guideline values

recommended by the WHO (the WHO AQG). It was highlighted that the WHO AQG are based on

scientific analyses and not on a political compromise and, as such, are better suited for the pro-

tection of human health. It was put forward that while the current standards laid down in the

AAQDs may contribute to a decrease of the concentrations of different pollutants, the problem

36 Counterfactual concentration of 0 μg/m. 37 EEA, Air Quality Report 2017.



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(=negative health effects) remains largely unsolved as concentrations are still high. CEPTA also

suggested that measures that are being implemented now in Slovakia, but also throughout the

Europe, seek to achieve no exceedance of the current standards. It was put forward that had

more ambitious standards been set, the measures to reach such more ambitious standards would

also be more ambitious in terms of reducing the existing pollutant concentrations.

This view regarding the air quality standards has not been fully shared by the Ministry of Environ-

ment (MoE) and the SHMI. Specifically, while the MoE and the SHMI agreed on that the protection

of the health of the citizens is the main goal of the AAQ Directives (and of the Slovak legislation

that transposes the Directive), they stressed the need to look at what is possible to achieve -

technically and practically. For example, in Slovakia, background concentrations of number of

pollutants are high38 and some of the pollution comes from sources abroad. Accordingly, in the

view of the MoE and SHMI, the setting of more ambitious standards may not necessarily be the

way forward.


The present section focuses on implementation successes. These include the recent revision of

the Slovak smog warning system and improvements in cooperation between sectors.

3.2.1 Smog warning system

Recently, Slovakia has revised its warning system for smog situations enabling the public and, in

particular, vulnerable groups of the public, to become aware of possible longer lasting pollutant

exposures. The revision came into force as of 1 December 2017.

The information and alert thresholds for the activation of the smog warning system have now

been harmonised with the Czech Republic and, as far as PM10 is concerned, are stricter compared

to some of Slovakia's neighbours (e.g. in Poland the information threshold for PM10 is 200 µg/m³

and the alert threshold is 300 µg/m³ while in Slovakia the thresholds are 100 and 150 µg/m³

respectively).39 . Furthermore, prior to the revision of the system the main focus of the system

was on the pollutants regulated in Annex XVI to the Directive, but with the revision the provisions

regarding information on PM10 exposures have been strengthened. The revised system is per-

ceived by the stakeholders – the MoE, SHMI and CEPTA – as a major improvement to the availa-

bility of information to public.

The success of the revised system is related in particular to the variety of channels used to com-

municate the relevant information to the public so as to ensure that the information reaches those

affected. Moreover, the harmonisation of the thresholds with the neighbouring Czech Republic is

a good step forward since, as the MoE has informed, there was a degree of confusion among the

general population, in particular the part living close to Slovakia's borders, about the safe levels

of pollution.

The (revised) smog warning system is described below.

A "smog situation" is defined as a situation when the air pollution by PM10, SO₂, NO₂ or O3 exceeds

the information or the alert threshold laid down in the Order 244/2016 Coll. The smog situation

38 For example, the background concentration of sulphur dioxide recalculated in sulphur was 0.27 μg.m3 on

the Chopok station and 0.49 μg.m on the Starina station, in 2016. Background level of concentrations of

oxides of nitrogen, recalculated in nitrogen (presented 072 μg.m3 on the Chopok station and 1.33 μg.m3 on

the Starina station, in 2016, http://www.shmu.sk/File/oko/rocenky/Air_pollution_in_the_SR_2016.pdf. 39 Levegö Munkacsoport, Air Pollution Emergency Schemes (Smog Alerts) in Europe, 2017.

http://www.shmu.sk/File/oko/rocenky/Air_pollution_in_the_SR_2016.pdf




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can thus be of two degrees of severity: a smog situation (information threshold exceeded) or a

severe smog situation (alert threshold exceeded).

Table 3-1 Information and alert thresholds

Pollutant Information threshold in µg/m³ Alert threshold in µg/m³

PM10 1001) 1501)

SO₂ - 5002)

NO₂ - 4002)

O3 1803) 2404)

Source: Order 244/2016 Coll. on air quality.

Notes: 1) As an average over 12 consecutive hours.

2) As an hourly average over 3 consecutive hours at locations representing air quality over an area of minimum

100 km² or for an entire zone or agglomeration, whichever is smaller.

3) As an hourly average.

4) As an hourly average over 3 consecutive hours.

If the information threshold is exceeded, the SHMI informs the population of the smog situation.

The information threshold reflects the level beyond which there is a risk to human health from

brief exposure for particularly sensitive sections of the population. In case of exceedance of the

alert threshold the SHMI informs the population that there is a case of serious smog situation.

The alert threshold reflects a level beyond which there is a risk to human health from brief expo-

sure for the general population.

At the same time the SHMI informed the relevant district office, municipality, the Slovak Environ-

mental Protection Agency and the media. The municipality is required to inform the public without

delay and, at the latest, within 6 hours from the time it had been informed by the SHMI. The

municipality is obliged to use all communication channels available, including its information

board, local radio and website. Public media are obliged to inform the public within 2 hours from

the time it had been informed by the SHMI. If the smog situation continues an update of the

situation must be provided at least two times a day. If the smog situation concerns a zone or an

agglomeration close to a state border, the MoE must inform the neighbouring Member State as

well.

3.2.2 Coordination between sectors

As mentioned in section 2.3, the Slovak republic is currently preparing a new air quality strategy

(The Strategy for the Improvement of Air Quality in Slovakia).40 Other sectors are actively involved

in the preparation in the strategy and it is envisaged that they will be also involved in the imple-

mentation of the strategy. Sixteen working groups have been established to elaborate the strategy

to discuss different air quality issues (e.g. industrial emissions, transport, agriculture, etc.), in-

cluding representatives of various sectors. While the preparation of the 2013 PM10 strategy also

included extensive consultation, the different sectors were less involved.

The active involvement of other sectors in the preparation of the strategy is likely to have a

positive impact on increasing the ownership of the various sectors of the measures proposed and

has therefore a potential to increase the likelihood of the measures being brought to life. So far,

the MoE highlighted, as a particular success, of the work that there is now a constructive dialogue

40 More information on http://www.minzp.sk/strategia-ochrany-ovzdusia.html



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with other ministries and an agreement between the ministries that initiatives that worsen air

quality should not be set as a priority.



Unless provided otherwise, the challenges apply to the entire Slovak territory, including the Košice

region. Furthermore, the section provides an assessment of the extent to what these challenges

can be linked to the way the AAQ Directives have been designed or the specific requirements of

the Directives.

Implementation challenges identified in the case study have been grouped into the following four

categories:

1 Challenges in developing, implementing and enforcing effective air quality measures and en-

suring integration of air quality in local planning and decision making;

2 Challenges in tackling small sources of pollution;

3 Challenges in ensuring compliance with the AAQ monitoring requirements of the AAQ;

4 Challenges in ensuring public awareness, in particular about the surrounding air quality,

health effects of poor air quality and sources of air pollution.

Each of the challenges and the factors driving them and the extent to what these challenges can

be linked to the provisions of the AAQDs is presented below.

3.3.1 Developing, implementing and enforcing effective air quality measures and ensuring integration of air quality in local planning and decision making

With the exception of the interviewed industry representative, who did not experience any partic-

ular challenge in this respect, all stakeholders interviewed in the context of the case study sug-

gested that developing, implementing and enforcing effective measures to address air pollution is

a great challenge for Slovakia and its different regions/air quality zones, including the Košice

region. Stakeholders suggested that the consequence of this is that most measures implemented

are very simple and lack quantified targets to assess the implementation progress and, as such,

do not necessarily make a major difference in improving air quality.

The primary responsibility for air quality lies with the Ministry of Environment. The problem –

pollution sources – is however divided between different sectors. These include the Ministry of

Economy (for industry), the Ministry of Transport, the Ministry of Finance, the Ministry of Transport

and Construction. The Ministry of Environment and the civil society association CEPTA point out

that each of these Ministries/sectors has its own priorities and the protection of air quality is not

necessarily on top of the list. Moreover, the Ministry of Environment does not have the compe-

tences to ensure that air quality measures (e.g. such as those laid down in the 2013 PM10 strategy)

are brought into life by the other sectors. This is supported by findings in the recent report on air

quality by EUROSAI, where it was indicated the need of better information flow between relevant

ministries and the government, more precisely about the status of air quality in Slovakia. The

report highlighted that the interdepartmental cooperation on the air quality management system

is insufficient and dependent on the human resources' capacity. In the same time, the coordination

of health and economic policies with an air quality policy has not yet been effective enough and

has not taken place at the required level.41

41 Joint report on air quality, Eurosai, 2019, available at: https://english.rekenkamer.nl/publications/re-ports/2019/01/30/joint-report-air-quality



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As for regions and municipalities, the Košice district office suggested that the current allocation of

responsibilities, conflicting priorities and a (lack of) coordination are also an issue. As mentioned

above, district offices in the seat of Slovak regions are responsible for elaborating air quality plans.

The district offices lack competences to ensure that the measures laid down in such plans (e.g.

establishment of low emission zones) are implemented on the ground. This is because such

measures cannot be enforced against other municipalities within the region, the state or against

private actors. For example, district offices do not have competences to inspect and to intervene

in the activities of industrial enterprises, nor in relation to transport (e.g. to regulate traffic).

Accordingly, ensuring that air quality concerns are integrated into local planning and decision

making, in particular in relation to transport (e.g. integration of low emission zones in transport

and urban planning) is a challenge. The challenge is also connected with a lack of resources. For

example, CEPTA pointed out that municipalities typically do not have the financial resources in

their budget necessary to finance more ambitious air quality improvements and are not sufficiently

motivated to implement such improvements.

Developing measures that are effective in addressing air pollution is a challenge in itself. For

example, the Košice district office indicated that it struggles when defining measures to be in-

cluded in the air quality plans. More specifically, the Košice district office and CEPTA noted that

emission inventories and projections do not always provide a sufficient basis for drafting effective

measures.42 It was also pointed out by the Košice district office that while the office is sometimes

informed about what has been implemented at the local level and what is being planned for the

future. Finally, the Košice district office highlighted that it is not sufficiently involved in the differ-

ent structures at the local, national and EU levels. For example, the district office is not involved

in different working groups or coordination meetings in which the MoE participates. This limits the

opportunities for the district offices to benefit from the information that is being shared there (e.g.

regarding air quality measures implemented in other regions, but also in other Member States).

The process of developing air quality plans and short-term action plans is described in the text

box below.

Text box 3-1 Development of air quality plans and short-term action plans (Košice region)

When developing an air quality plan, the district office approaches other relevant organisations. This in-

cludes e.g. other district offices in the region, Regional Public Health Office in Košice, the Slovak Road

Administration, and the National Motorway Company. These organisations suggest various measures to be

implemented. The district office uses these suggestions as a basis for the elaboration of the air quality plan,

adds additional measures (where relevant) and finalises the plan.

Moreover, the district office in Košice cooperates with other district offices in the region and the SHMI in

determining who the largest polluters in the region are. These polluters are included in the air quality plans

with specific measures.

As far as short-term action plans are concerned the polluters identified are required to report on the

measures they envisage to introduce. Typically, this includes simple measures such as sprinkling of roads,

but also a temporary boiler shut-down.

Source: Interview, Košice district office.

The implementation challenge described above is driven by a number of factors – mainly at the

Member State level. As elaborated on below, a number of these factors can nonetheless be linked

to the specific provisions of the AAQDs.

42 For example, the Košice district office mentioned that while BaP, which is a particular issue in the Košice

region, is being measured, there is still a lack of information about the sources. As such, it is difficult to de-velop effective measures to tackle the problem.



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First of all, the way responsibilities in air quality management are allocated between different

actors may pose challenges in the implementation of the Directives in itself. This challenge is

further amplified by the – in some areas – limited coordination between the different actors in

Slovakia. Having regarding to the principle of subsidiarity, Directive 2008/50/EC does not specify

the way responsibilities in air quality monitoring, assessment and management should be allo-

cated within the Member States. Article 3 of Directive 2008/50/EC nonetheless lays down the

obligation for Member State authorities to "designate at appropriate levels the competent author-

ities and bodies responsible for the following: (a) assessment of ambient air quality; (b) approval

of measurement systems (methods, equipment, networks and laboratories); (c) ensuring the ac-

curacy of measurements; (d) analysis of assessment methods; (e) coordination on their territory

if Community-wide quality assurance programmes are being organised by the Commission; and

(f) cooperation with the other Member States and the Commission. The provision refers mainly to

tasks related to air quality monitoring and assessment, but not specifically to the management of

air quality. The provision of the AAQ Directive could potentially be strengthened in this respect so

as to include air quality management related tasks as well.

Since there are no performance indicators implemented in Slovakia, the government should es-

tablish and further adopt binding indicators for measuring the effectiveness and efficiency of

measures for combating air pollution. This would need to be supported by regular evaluation of

these indicators and further propositions of actions for improving air quality in Slovakia.43

Secondly, the implementation challenge is driven by the (lack of) legal status of the adopted air

quality plans. Article 23 of Directive 2008/50/EC provides that in zones and agglomerations where

the levels of pollutants in ambient air exceed any limit value or target value (plus any relevant

margin of tolerance) Member States "shall ensure that air quality plans are established for those

zones and agglomerations in order to achieve the related limit value or target value specified in

Annexes XI and XIV". The provision does not specify the legal status of the air quality plans and

nor does it address the issue of access to legal recourse against potentially insufficient air quality

plans. There is thus a room for improvement in this respect.

Text box 3-2 Legal recourse against adopted air quality plans

In 2017 a group of citizens in Bratislava together with the NGOs CEPTA, ClientEarth and Cyklokoalícia

brought a claim against the Slovak government for insufficient protection of air quality in Bratislava to the

district court in Bratislava. The claim suggest that the air quality plan for Bratislava is insufficient, lack

concrete measures and targets and is not compliant with the Slovak, as well as European legislation. The

district office in Bratislava that has drafted the plan argued that, pursuant to the current laws, it is not

competent to require other subjects to implement measures to improve air quality and to enforce such

measures/impose sanctions in case of non-compliance. The district office further argued that the public was

consulted and had the opportunity to comment on the proposed air quality plan.44

Finally, the third major factor driving the challenge is the lack of information, including information

about the measures being implemented and best practices to tackle air pollution. This factor is to

some extent linked to the problem of coordination, as described above. At the same time, the

findings of the case study indicate that there is a need for additional guidance and knowledge

sharing (at EU level).

Section A of Annex XI to the Directive provides an overview of the elements to be included in an

air quality plan, but, at least in Slovakia, more detailed guidance on how to elaborate air quality

plans is missing. This can be provided at national level and some work – in connection with the

43 Joint report on air quality, EUROSAI, 2019, available at: https://english.rekenkamer.nl/publications/re-

ports/2019/01/30/joint-report-air-quality 44 No decision has been published on the matter so far.







(2008/50/EC, 2004/107/EC)

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preparation of the new Slovak Air Quality Strategy – is already ongoing.45 At the same time there

would, however, appear to be a clear benefit from EU level guidance, e.g. as regards the lessons

learned and best practices in air quality plan development and implementation in other Member

States.

3.3.2 Tackling small sources of pollution

The majority of stakeholders interviewed suggest that large polluters 46 are subject to strict con-

trol, a system of fees and fines, and generally tend to comply with the applicable emission stand-

ards set pursuant to the Industrial Emissions Directive. As such, stakeholders suggest that the

more pressing problem from the Slovak perspective, and in particular the Košice region, are small

sources of pollution: medium/small polluters and in particular individuals/households.

Domestic solid fuel combustion has been identified as one of the major sources of particulate

matter and BaP pollution.47 For example, in 2014 it was estimated that domestic solid fuel com-

bustion constituted approximately 81% of the total PM2.5 emissions 84% of polycyclic aromatic

hydrocarbon emissions.48 The issue is that different types of solid materials (including e.g. waste

and wet wood) are being burned, sub-standard solid fuel stoves and boilers are being used, and

there are currently no means of imposing an effective control over these practices and enforce

any measures (e.g. it is not possible to get access to private properties). The MoE noted that the

issue is difficult to tackle as it relates to the problem of energy poverty, which is prominent in

particular in Roma settlements. The issue is being discussed in the context of the new Air Quality

Strategy, to be published in the late spring 2019. Current measures include information to public

about clean domestic heating and the adverse effects of air pollution caused by domestic solid

fuel combustion.49

The implementation challenge cannot be directly linked to any of the provisions of the AAQ Direc-

tives as it driven in particular by the lack of public awareness about the health impacts of resi-

dential solid fuel combustion and clean operation techniques, and generally, also the issue of

energy poverty.

Nonetheless the tackling of the challenge can benefit from sharing of best practices in addressing

similar issues in other Member States. Additionally, the potential to make full use of EU resources

(e.g. the Operational programmes under the Structural Funds, the European Fund for Strategic

Investments, the Rural Development Programme, etc.) to support transition to cleaner residential

heating technologies could be further explored.

3.3.3 Ensuring compliance with the AAQ monitoring requirements

The MoE and the SHMI suggested that monitoring of air quality and, in this connection, living up

to all the detailed requirements of the AAQDs, is a challenge and is costly for such a small country

with complex geomorphology as Slovakia. For example, the SHMI highlighted that in applying the

45 https://www.enviroportal.sk/clanok/bratislava-program-na-ochranu-ovzdusia-je-v-sulade-so-zakonom-reaguju-uradnici 46 For the purpose of the case study polluters are categorised in line with the Report on air pollution is Slo-

vakia: large (stationary) sources are technological units containing combustion plants having total rated

thermal input more than 50 MW and other technological units with a capacity above the defined limit; me-dium (stationary) sources are technological units containing combustion plants having total rated thermal

input between 0.3 -50 MW and other technological units with a capacity under the defined limit for the large sources but over the defined limit for the medium sources; and small (stationary) sources are domestic

heating equipment for combustion of solid fuels and natural gas with total rated thermal input less than 0.3 MW. http://www.shmu.sk/File/oko/rocenky/Air_pollution_in_the_SR_2016.pdf 47 See, e.g. https://ec.europa.eu/info/news/clean-air-dialogue-between-commission-and-slovakia-pro-

motes-actions-cleaner-air-2018-apr-26_en 48 lhttp://vykurovanie.enviroportal.sk/emisie.aspx 49 http://vykurovanie.enviroportal.sk/

https://www.enviroportal.sk/clanok/bratislava-program-na-ochranu-ovzdusia-je-v-sulade-so-zakonom-reaguju-uradnici

https://www.enviroportal.sk/clanok/bratislava-program-na-ochranu-ovzdusia-je-v-sulade-so-zakonom-reaguju-uradnici

https://ec.europa.eu/info/news/clean-air-dialogue-between-commission-and-slovakia-promotes-actions-cleaner-air-2018-apr-26_en




http://vykurovanie.enviroportal.sk/emisie.aspx

http://vykurovanie.enviroportal.sk/



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criteria for sampling points siting, as laid down by the AAQ Directives, it is difficult to ensure

quality/representativeness of the measurement since, given the complex geomorphology of Slo-

vakia, pollutants tend to become trapped in low lying areas. The SHMI and CEPTA also suggested

that communication and negation with municipalities is an issue. For example, the SHMI may

identify a location for a sampling point that lives up with the requirements of the Directive

2008/50/EC (e.g. regarding the distance from a road), but this location may not be acceptable for

the municipality on whose territory the sampling point is to be placed or the municipality places

various conditions for the establishment of the sampling point. Currently, there is no legal instru-

ment that can be used to make municipalities accept.

As elaborated on above, the challenge is driven by a number of factors, including the geomor-

phology of Slovakia, the allocation of powers within Slovakia in relation to the establishment of

the monitoring network, but can also be linked to the detailed siting criteria laid down by the AAQ

Directives (e.g. regarding distance to roads and ensuring representativeness).

3.3.4 Challenges in ensuring public awareness

CEPTA suggested that – despite recent improvements to the smog warning system (see below) –

ensuring that the Slovak population is sufficiently informed about the surrounding air quality, the

negative (health) effects associated with poor air quality and the sources of air pollution continues

to be a challenge for Slovakia. It was pointed out – and this view was shared by the SHMI – that

currently the information is not particularly user-friendly and citizens need to connect different

pieces of information to get a full picture of how they are being affected.

Article 26 of Directive 2008/50/EC lays down the general provisions regarding ensuring infor-

mation to public. Pursuant to the first paragraph, Member States shall ensure that "the public as

well as appropriate organisations such as environmental organisations, consumer organisations,

organisations representing the interests of sensitive populations, other relevant health-care bod-

ies and the relevant industrial federations are informed, adequately and in good time, of the

following:(a) ambient air quality in accordance with Annex XVI; (b) any postponement decisions

pursuant to Article 22(1); (c) any exemptions pursuant to Article 22(2); (d) air quality plans as

provided for in Article 22(1) and Article 23 and programmes referred to in Article 17(2)." Moreo-

ver, paragraph 2 of the same Article provides the obligation for the Member State to ensure

availability of annual reports for all pollutants covered by the Directive. In terms of adverse effects

of poor air quality Annex XVI paragraph 2 specifies that the information on ambient concentrations

shall "also provide a short assessment in relation to the air quality objectives and appropriate

information regarding effects on health, or, where appropriate, vegetation."

As such, Directive 2008/50/EC already contains requirements to share the information on adverse

health effects of air pollution to public. The implementation of the provision could be further

strengthened by sharing of good practices in the implementation between the Member States.

Alternatively, in addition, the EU air quality index, which provides information on the current air

quality across Europe’s cities and regions, could be potentially expanded with additional infor-

mation.Factors underlying compliance with and effectiveness of the AAQ

Directives


with and effectiveness of the AAQ Directives in Slovakia, and the Košice region. The factors have

been identified through stakeholder consultation conducted in the context of the case study. The

views have been correlated with information gathered through desk research.



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The findings of the case study indicate that main factors underlying compliance with the AAQDs

in Slovakia include: 1) an understanding that there is problem, 2) precise data on the levels of

pollution and sources, 3) responsibility and financial resources and 4) follow-up on cases of non-

compliance.

Understanding that there is a problem

The findings of the case study indicate that an understanding of that there is a problem and why

the problem needs to be solved is crucial for the effective implementation of the AAQDs in Slo-

vakia. For example, CEPTA highlighted that is important that the citizens understand the aims of

the Directive in order for them to create pressure on politicians to take action and, at the same

time, to accept and support the measures that are being implemented. For example, when traffic

restrictions are being introduced, it is important that it is communicated that this is done in the

interest of protecting the citizens' health and not simply "because the EU calls for it".

Data on the levels of pollution and on pollution sources

Moreover, the findings of the case study show that it is important to have precise and up-to-date

information. Information is needed not only to ensure an effective implementation of the Directive

and, specifically, to elaborate effective air quality measures, but also to communicate the problem

to the citizens. Thus, for example, the new Air Quality Strategy will be underpinned by a detailed

analysis of causes of air quality deterioration (and evaluation of sector share of sources for air

pollution.

Responsibility, coordination and financial resources

The findings of the case study show that the effective implementation of the AAQDs requires that

responsibility for the implementation/air quality improvements, action is well-coordinated and fi-

nancial resources allocated: at the level of the Member State, regional and local level. As men-

tioned above, the work on the new Air Quality Strategy is already showing improvements to co-

ordination of sectoral priorities.

Follow-up on cases of non-compliance

Finally, the follow-up by the Commission on cases of non-compliance via infringement has been

identified as an important factor contributing to effectiveness/compliance with the Directives. For

example, the MoE and CEPTA highlighted the positive impact of the infringement proceedings

initiated in 2012 regarding PM10 on taking immediate action (e.g. the elaboration of a dedicated

strategy to tackle the PM10 problem).


On the other hand, the case study identified the following factors hindering compliance 1) lack of

information about the problem; 2) lack of detailed information about the levels of pollution, its

chemical composition, sources and effects; 3) lack of motivation to take action, 5) lack of compe-

tences and insufficient coordination, 6) lack for personnel and 7) insufficient information sharing.

Lack of information about the problem

First of all, the case study identified the lack of information about the problem and, in particularly,

about the effects and causes of air pollution among the citizens as one of the major factors hin-

dering effectiveness of the Directives. For example, CEPTA highlighted that from the citizens'



(2008/50/EC, 2004/107/EC)

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perspective the problem is that – as air pollution is not visible – citizens do not know about the

pollution and about the effects of air pollution (health effects, effects on the quality of life, but

also the expenses for health care) and, as consequence, do not fully mobilise the political will to

introduce more far reaching measures to improve air quality.

Lack of detailed information about the levels of pollution, its chemical composition and sources

As mentioned above, up-to-date information about the scope of the problem and its sources is

crucial to develop effective air quality measures and thereby achieve air quality improvements

called for by the AAQDs. Information on air pollution sources is part of the Annual Reports on Air

Quality in Slovakia. However, CEPTA, but also the SHMI and the Košice district office indicated

that there is a room for further improving the current knowledge about the sources, but also about

economic and health impacts of air pollution. As mentioned above, some activities in this respect

are already on-going as part of the preparation of the new Air Quality Strategy.

Lack of motivation to take action

The findings of the case study suggest that – despite recent improvements – there is still a po-

tential to the lack of motivation to introduce far-reaching actions to improve air quality improve-

ments among the different sectoral and local actors. This is closely linked to the hierarchy of

priorities and to the issue of competences, discussed below.

Lack of competences and insufficient coordination

Furthermore, the findings show that the allocation of responsibilities and the somewhat limited

coordination between different actors constitute a major barrier to the effective implementation

of the AAQDs in Slovakia and in the Košice region. As discussed above, while in principle it may

be possible to elaborate effective measures for the air quality plans, but it is not always possible

to bring such matters to life. For example, it may be known that a city bypass would likely improve

air quality, but in practice it is difficult to get such a bypass built because the district office,

elaborating the measure, does not have the powers necessary to make the development decision.

Lack of personnel

Furthermore, the findings suggest that a sufficient amount of qualified personnel, with a strong

insight into air quality issues, is crucial for the effective implementation of the AAQ Directives. In

this connection the MoE noted that other countries typically have a larger a team of people dedi-

cated to air quality issues (for example, in the Czech Republic the air quality unit at the MoE has

20 full-time employees), in the Slovak republic the number is considerably lower (8 full-time

employees at the MoE). The main reason for this is the lack of financial resources.

Insufficient information sharing

Finally, the findings of the case study suggest that communication and knowledge sharing within

the country, but also with other Member States is important. However, as discussed above, short-

comings have been identified in particular in relation to the sharing of information at the local

level (i.e. between the different district offices, but also between district offices and the MoE

regarding the developments and best practices at EU level).



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Slovakia. A number of rough estimates was gathered via stakeholder consultation.

The MoE estimated that the total costs of implementation of the AAQ Directives are likely in the

tens of millions EUR per year, but a more precise estimate/break-up of the costs could not be

provided. As far as labour costs are concerned, the Air Quality Unit at the Ministry of Environment

consists of 8 FTEs (Full Time Equivalents). The Air Quality Unit is responsible solely for the imple-

mentation of the AAQ Directives, but implementation other EU Directives related to air quality

(including the NEC Directive and the Industrial emissions Directive),50 long-range air pollution and

the protection of ozone layer. In addition, there are 9 FTEs working with air quality issues (i.e.

not exclusively the AAQ Directives) in the regions. In the SHMI there are approximately 27 em-

ployees responsible for monitoring, modelling and reporting.

According to SHMI the costs of operating the current monitoring network, consisting of 38 moni-

toring stations, are in the order of magnitude 1 to 1.2 million EUR per year. As mentioned above,

air quality in Slovakia has been monitored also in the years prior to the introduction of Directive

2008/50/EC and its predecessor. The findings of the case study nonetheless indicate that all the

monitoring stations in the monitoring network are necessary for the fulfilment of the monitoring

requirements of the Directives and even that additional sampling points need to be added to the

network in order to comply with the requirements.

No estimate of total costs incurred by the industry could be provided. U.S. Steel Košice, which is

a large integrated steel producer in the Košice region, informs that air quality improvements are

being financed both from internal budgets and from EU sources.

Text box 3-3 Use of EU funding to fund air quality improvements (U.S. Steel Košice)

As far as EU sources are concerned, U.S. Steel Košice has used approximately in between 2017 and 2020

80 mil EUR on further upgrading its technologies from EU budgets.

There was an ad hoc scheme for the support of the Košice region in which all enterprises in the Košice

region could apply for support. 90% of financing came from EU and 10% from the U.S. Steel's own re-

sources. In addition, from the same operational programme there was in 2016 a call for entire Slovakia.

55% of the resources were received from the fund and 45% from U.S. Steel's own resources. EU funding

has been used to further improve existing technologies and, as such, further reduce emissions of harmful

substances in the surrounding air.

Source: Interview, U.S. Steel Košice.


There is currently no national analysis of the costs of non-implementation of the AAQ Directives.

At EU level it was estimated that the health-related external costs from air pollution in Slovakia

are above EUR 3 billion/year (income adjusted, 2010), which include both the intrinsic value of

living a full health life and the direct costs to the economy. The direct economic costs relate to

1.3 million workdays lost each year due to sickness related to air pollution, with associated costs

50 http://www.minzp.sk/sekcie/temy-oblasti/ovzdusie/ochrana-ovzdusia/pravne-predpisy/pravne-predpisy-

eu/pravne-predpisy-eu-2.html



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for employers of EUR 123 million/year (income adjusted, 2010), for healthcare of above EUR 10

million/year (income adjusted, 2010), and for agriculture (crop losses) of EUR 35 million/year

(2010).51

For 2014, the EEA has estimated the number of premature deaths due to PM2.5 to be 5160 (coun-

terfactual concentration of 0 μg/m) and 4520 (counterfactual concentration of 2.5 μg/m). For NO₂

100 and 1,330 premature deaths were estimated (using the counterfactual concentration of 10

and 20 μg/m). Finally, 4344 premature deaths were estimated due to O3 pollution.52




ments of benefits the AAQ Directives in Slovakia, but can be described in qualitative terms.

A number of provisions of the AAQ Directives have been identified as key, in delivering air quality

improvements. These include, more generally, the establishment of a harmonised approach

throughout the EU towards monitoring, assessment and management of air quality. Overall, the

following provisions of the AAQ Directive were cited as those most important include: 1) the set-

ting of air quality standards; 2) providing information to public and 3) cooperation with the Euro-

pean Commission and between Member States.

The benefits of the AAQ Directives for Slovakia are summarised below.

Maintaining/improving air quality, positive impacts on the eco-system and improvements to citi-

zens' health

All stakeholders interviewed noted that despite the fact that there are new sources of air pollution,

the number of cars has increased, there was an economic crisis, air quality has not gotten worse

and the number of exceedances has decreased over the years. This finding is confirmed through

desk study (see section 2.2 above).

Establishment of common methods and criteria for monitoring

Another benefit of the AAQDs, highlighted in particular by the SHMI, is the possibility to assess

ambient air quality on the basis of common methods and criteria that allow for comparison of

across Member States.

Improved monitoring

Furthermore, another benefit of the AAQDs relates to the shift of focus of monitoring from indus-

trial areas to areas where most population lives. In this connection, the SHMI informed that prior

to the implementation of the AAQ Directives monitoring was concentrated in industrial areas, close

to large pollution sources. Over time, additional monitoring stations were added into the monitor-

ing network. These included stations in areas with a lower concentration of industrial pollution

sources (e.g. urban background monitoring stations).

51 The figures are based on the Impact Assessment for the European Commission Integrated Clean Air Pack-

age (2013), as cited in COM (2017) 63 final. 52 EEA, Air Quality Report 2017.



(2008/50/EC, 2004/107/EC)

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Increased visibility of the issue and interest in solving the problem of air pollution

In particular CEPTA highlighted as an important benefit of the Directives the fact that the problem

of air pollution became more visible. It was noted that the Slovak media had started to be more

interested in the issues and in the solutions. According to the MoE and CEPTA, the infringement

proceedings initiated against the Slovak republic had a major role in this.

Clear effort from the industry to reduce emissions

The findings of the case study also show that there has been a major improvement in the tech-

nologies to reduce emission sin the air. For example, U.S. Steel Košice highlighted that this would

not have happened without the EU air policy (the AAQ Directives, the NECD and other instruments

dealing with industrial emissions, the 2012 Conclusions on BAT,53 etc.).

Establishment of good communication and knowledge sharing in the EU

Communication within the EU, through coordination meetings but also by means of bilateral ex-

changes, was also identified as very important and beneficial in terms of knowledge and best

practice sharing.

Establishment of level playing field for EU industries

Finally, as EU legislation provides the same rules for all companies in the EU it also lays ground

to fair competition on the internal market. This latter point was emphasised in particular by the

industry representative U.S. Steel Košice.

53 Commission Implementing Decision establishing the best available techniques (BAT) conclusions under Directive 2010/75/EU on industrial emissions for iron and steel production.



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4 CONCLUSIONS

This chapter presents the summary of the main findings of the case study regarding the main

implementation challenges the potential for improving the implementation of the Directives in

Slovakia. Finally, a summary of the evaluation of the AAQDs is presented.


the Directives

The case study identified the following challenges in the implementation of the AAQ Directives.

Developing, implementing and enforcing effective air quality measures and ensuring

integration of air quality in local planning and decision-making. As described in section 3.3

this is a complex challenge driven by a number of factors – mainly at the Member State level.

First of all, the way responsibilities in air quality management are allocated between different

actors may pose challenges in the implementation of the Directives in itself (see section 2.3

above). This challenge is further amplified by the – in some areas – limited coordination between

the different actors in Slovakia (see section 3.3 above). Provisions of Directive 2008/50/EC ad-

dressing the allocation of responsibility refer mainly to tasks related to air quality monitoring and

assessment, but not specifically to the management of air quality. The provision of the AAQ Di-

rective could potentially be strengthened in this respect so as to include air quality management

related tasks as well. Furthermore, Article 23 of Directive 2008/50/EC does not specify the legal

status of the air quality plans and nor does it address the issue of access to legal recourse against

potentially insufficient air quality plans. Finally, the third major factor is the lack of information,

including information about the measures being implemented and best practices to tackle air pol-

lution. This driver is to some extent linked to the problem of coordination, as described above. At

the same time, the findings of the case study indicate that there is a need for additional guidance

and knowledge sharing (at EU level), e.g. as regards the lessons learned and best practices in air

quality plan development and implementation in other Member States.

Furthermore, in the recent Joint Report on air quality by EUROSAI was stressed that even if the

number of monitoring stations and their location corresponds with the pre-set criteria, the National

Air Quality Monitoring System is inadequate due to the complexity of the territory of Slovakia and

thus the National Air Quality Monitoring System is not representative of the whole Slovakia.54

Challenges in tackling small sources of pollution. The challenge is driven in particular by the

lack of public awareness about the health impacts of residential solid fuel combustion and clean

operation techniques, and generally, also the issue of energy poverty. As such, the implementa-

tion challenge cannot be directly linked to any of the provisions of the AAQ Directives. Nonetheless

the tackling of the challenge can benefit from sharing of best practices in addressing similar issues

in other Member States. Additionally, the potential to make full use of EU resources to support

transition to cleaner residential heating technologies could be further explored.

Challenges in ensuring compliance with the AAQ monitoring requirements of the AAQ.

The findings of the case study indicate that monitoring of air quality and, in this connection, living

up to all the detailed requirements of the AAQ, is a challenge and is costly for such a small country

with complex geomorphology as Slovakia. The challenge is driven by a number of factors, includ-

ing the allocation of powers within Slovakia in relation to the establishment of the monitoring

54 Joint report on air quality, Eurosai, 2019, available at: https://english.rekenkamer.nl/publications/re-ports/2019/01/30/joint-report-air-quality







(2008/50/EC, 2004/107/EC)

March 2019 30

network, the geomorphology of Slovakia, but can also be linked to the detailed siting criteria laid

down by the AAQ Directives (e.g. regarding distance to roads and ensuring representativeness).

Challenges in ensuring public awareness. Finally, the findings of the case study suggest that

– despite recent improvements to the smog warning system – ensuring that the Slovak population

is sufficiently informed about the surrounding air quality, the negative (health) effects associated

with poor air quality and the sources of air pollution continues to be a challenge for Slovakia. It

was pointed out – and this view was shared by the SHMI – that currently the information is not

particularly user-friendly, and citizens need to connect different pieces of information to get a full

picture of how they are being affected. Directive 2008/50/EC already contains requirements to

share the information on adverse health effects of air pollution to public. The implementation of

the provision could be further strengthened by sharing of good practices in the implementation

between the Member States. Alternatively, the EU air quality index, which provides information

on the current air quality across Europe’s cities and regions, could be potentially expanded with

additional information.




4.2.1 Relevance

The findings of the case study indicate that the objectives of AAQDs are relevant to the needs of

citizens in Slovakia as air quality continues to pose a concern to the health of Slovak citizens and

the environment. The consultation carried out in the context of the case study showed that while

all the objectives of the AAQDs are relevant, obtaining information on ambient air quality in order

to help combat air pollution and nuisance and to monitor long-term trends and improvements,

and ensuring that information on ambient air quality is made available to public are particularly

important. As far as the air quality standards laid down by the AAQDs are concerned, there is

some disagreement between the stakeholders as to whether the existing air quality standards are

too lenient.

4.2.2 Effectiveness

The findings of the case study indicate effectiveness of the AAQDs in maintaining air quality where

it is good and improving it in other cases. For example, while in 2004 there were 17 air quality

management areas (i.e. areas in which a limit or target value for one or more pollutants has been

exceeded, see above) while, in 2016 there were only 12. The findings of the case study indicate

that main factors underlying compliance with the AAQDs in Slovakia include: 1) an understanding

that there is problem, 2) precise data on the levels of pollution and sources, 3) responsibility and

financial resources and 4) follow-up on cases of non-compliance. In contrast, the case study iden-

tified the following factors hindering compliance 1) lack of information about the problem; 2) lack

of detailed information about the levels of pollution, its chemical composition, sources and effects;

3) lack of motivation to take action, 5) lack of competences and insufficient coordination, 6) lack

for personnel and 7) insufficient information sharing.

4.2.3 Efficiency


Slovakia. A number of rough estimates was gathered via stakeholder consultation. For example,

the MoE estimated that the total costs of implementation of the AAQ Directives are likely in the

tens of millions EUR per year. As far as labour costs are concerned, the Air Quality Unit at the

Ministry of Environment consists of eight FTEs (Full Time Equivalents). The Air Quality Unit is



(2008/50/EC, 2004/107/EC)

March 2019 31

responsible solely for the implementation of the AAQ Directives, but implementation other EU

Directives related to air quality. In addition, there are nine FTEs working with air quality issues

(i.e. not exclusively the AAQ Directives) in the regions. In the SHMI, there are approximately 27

employees responsible for monitoring, modelling and reporting. The costs of operating the current

monitoring network, consisting of 38 monitoring stations, are in the order of magnitude 1 to 1.2

million EUR per year.



ments of benefits the AAQ Directives in Slovakia but can be described in qualitative terms. The

identified benefits include: 1) maintaining/improving air quality, 2) establishment of common

methods and criteria for monitoring and improved monitoring, 3) increased visibility of the issue

and interest in solving the problem of air pollution, 4) effort from the industry to reduce emissions,

5) establishment of good communication and 6) knowledge sharing in the EU and 7) establishment

of level playing field for EU industries.

4.2.4 Coherence

The IED and the relevant BAT Conclusions contribute to the fulfilment of the objective of the AAQ

Directive to maintain air quality where it is good and improve it in other cases.

As far as other sectoral policies that affect air quality are concerned, there is a potential for further

improving coordination and, in particular, for ensuring that air quality concerns and efforts are

integrated into local planning.


The monitoring requirements of the AAQ Directives have stimulated a number of improvements

in the monitoring of air quality. While monitoring had taken place already before the introduction

of the AAQ, the added value of the AAQ is in shifting the focus of monitoring to the areas where

most of the population lives, improving the quality of the monitoring data and allowing for a

comparison across the EU. Another major area of EU added value of the Directives lies in increased

visibility of the air quality issue and the awakening of the interest to solve the problem of air

pollution.



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March 2019 32


Act No 137/2010 Coll. on Air protection

Agentúra na podporu regionálneho rozvoja Košice, n. o., Regional Accessibility Study of Eastern Slovakia, http://www.arr.sk/file/projekty_file99.pdf

Enviroportal.sk (Information Portal of the Ministry of Environment): https://www.enviropor-tal.sk/en/about-enviroportal

European Commission, DG Environment, Atlas of air quality zones and monitoring stations (2013 & 2014), Slovakia: http://ec.europa.eu/environment/air/pdf/quality_by_coun-try/SK_AirQualityZones_Current_opt.pdf

European Commission, The EU Environmental Implementation Review: Common Challenges and how to combine efforts to deliver better results, COM (2017) 63 final, 2017: http://ec.eu-ropa.eu/environment/eir/pdf/report_sk_en.pdf.

European Environmental Agency, Air Quality in Europe – 2017 Report: https://www.eea.eu-ropa.eu/publications/air-quality-in-europe-2017

European Commission, The EU Environmental Implementation Review, Country Report Slovakia, SWD(2017) 58 final: http://ec.europa.eu/environment/eir/pdf/report_sk_en.pdf

EUROSAI, Joint report on air quality, Eurosai, 2019: https://english.rekenkamer.nl/publica-tions/reports/2019/01/30/joint-report-air-quality

Levegö Munkacsoport, Air Pollution Emergency Schemes (Smog Alerts) in Europe, 2017: https://www.levego.hu/sites/default/files/smog_emergency_schemes_in_europe_201703.pdf

Ministry of Environment, State of Environment Report (2016), 2017: http://enviropor-tal.sk/spravy/detail/6961 Ministry of Environment, National Environment Policy (1993): http://www.minzp.sk/dokumenty/strategicke-dokumenty/strategia-zasady-priority-statnej-envi-ronmentalnej-politiky.html Ministry of Environment, State of Environment Report (2014), 2015: http://enviroportal.sk/uploads/report/2014-03-1-ovzdusie.pdf Ministry of Environment and the European Commission (2018), Conclusions of the Clean Air Dia-logue between Slovakia and the European Commission, taking place in Bratislava on 24-25 April 2018: http://www.minzp.sk/files/oblasti/ovzdusie/conclusions-clean-air-dialogue-between-sk-ec-fi-nal.pdf Ministry of Environment, Additional information on progress made in Air Quality in Slovakia. OECD, Environmental Performance Reviews, Slovak Republic, 2011: http://www.oecd.org/publi-cations/oecd-environmental-performance-reviews-slovak-republic-2011-9788088833567-sk.htm

Okresní úřad Košice, Information about air quality and about the contribution of different sources to pollution in the Košice region in 2015, 2016: https://www.minv.sk/?starostlivost-o-zivotne-prostredie&subor=276322

Order 244/2016 Coll on air quality

Rosičová, K., Detailed analysis of the Košice region, 2015: https://web.vucke.sk/files/doku-menty/pub/regionalny_rozvoj/phsr/2015/prilohy/priloha_1_podrobna_ana-lyza_kosickeho_kraja.pdf

Slovak Hydromeorological Institute, Air Pollution in the Slovak Republic, 2016: http://www.shmu.sk/File/oko/rocenky/Air_pollution_in_the_SR_2016.pdf

http://www.arr.sk/file/projekty_file99.pdf

https://www.enviroportal.sk/en/about-enviroportal




http://ec.europa.eu/environment/air/pdf/quality_by_country/SK_AirQualityZones_Current_opt.pdf




http://ec.europa.eu/environment/eir/pdf/report_sk_en.pdf









https://www.levego.hu/sites/default/files/smog_emergency_schemes_in_europe_201703.pdf









http://enviroportal.sk/uploads/report/2014-03-1-ovzdusie.pdf

http://www.minzp.sk/files/oblasti/ovzdusie/conclusions-clean-air-dialogue-between-sk-ec-final.pdf




http://www.oecd.org/publications/oecd-environmental-performance-reviews-slovak-republic-2011-9788088833567-sk.htm




https://www.minv.sk/?starostlivost-o-zivotne-prostredie&subor=276322

https://www.minv.sk/?starostlivost-o-zivotne-prostredie&subor=276322

https://web.vucke.sk/files/dokumenty/pub/regionalny_rozvoj/phsr/2015/prilohy/priloha_1_podrobna_analyza_kosickeho_kraja.pdf









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Slovak Hydromeorological Institute, Evaluation of Air Quality, 2016, 2017: http://www.shmu.sk/File/oko/hodnotenie/2016_Hodnotenie_KO_v_SR.pdf

Slovak Government, Policy Statement for the period 2012-2016, 2012: http://www.vlada.gov.sk/data/files/2008_programove-vyhlasenie-vlady.pdf

http://www.shmu.sk/File/oko/hodnotenie/2016_Hodnotenie_KO_v_SR.pdf

http://www.vlada.gov.sk/data/files/2008_programove-vyhlasenie-vlady.pdf



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Ministry of Environment, Climate Change and Air Quality Pro-

tection Section

11 July 2018

Slovak Hydrometeorological Institute, Unit for air quality 11 July 2018

CEPTA - Centre for Sustainable Alternatives, civil society asso-

ciation

10 July 2018

District Office in the seat of the region, Košice region 19 July 2018

U.S. Steel, Košice 17 July 2018



(2008/50/EC, 2004/107/EC)

March 2019 35


General questions




learn from?


tives?



exchange, etc.)?



Specific questions




(2008/50/EC, 2004/107/EC)

March 2019 36


RELEVANCE








gress?



try)?



zens' needs?







become redundant?

EFFECTIVENESS



















grammes


mation to public?







EFFICIENCY









Directives?







ating costs of equipment in EUR)? (5) Where there are significant cost differences be-





(2008/50/EC, 2004/107/EC)

March 2019 37








tives?




for Member States)?
















COHERENCE





























ments)?



NEC Directive?











ADDED VALUE



(2008/50/EC, 2004/107/EC)

March 2019 38











quality objectives?


in monitoring?












quality management?




ties)?






(2008/50/EC, 2004/107/EC)

March 2019 39

APPENDIX D AREAS OF AIR QUALITY MANAGEMENT

Table 4-1 Areas of air quality management (2016)

Agglomera-

tion/Zone

The are of air quality management Pollutant Area (km²) Amount

of inhab-

itants

BRATISLAVA The area of the capital city Bratislava PM10, NO2, BaP 368 425 923

KOŠICE

Košice region

The areas of the city Košice and municipalities

Bočiar, Haniska, Sokoľany, Veľká Ida

PM10, BaP

302

245 873

Banskoby-

strice region

The area of the city Banská Bystrica PM10 103 78 735

The area of the city Jelšava and municipalities

Lubeník, Chyžné, Magnezitovce, Mokrá Lúka,

Revúcka Lehota

PM10, PM2,5

109

6 647

Košice region

The area of the city Krompachy

PM10, PM2,5,

BaP

23

8 848

Prešov region

The area of the city Prešov and municipality

Ľubotice

PM10, NO2

79

92 892

Trenčian re-

gion

The area of the city Prievidza BaP 43 46 830

Municipality Bystričany PM10 38 1 791

The area of the city Trenčín PM10 82 55 593

Trnava region The area of the city Trnava NO2, BaP 72 65 536

Žilina region

The area of the city Ružomberok and munici-

pality Likavka

PM10

145

30 134

The area of the city Žilina PM10 80 81 041

Source: SHMÚ, Hodnotenie kvality ovzdušia v Slovenskej republike (Evaluation of Air Quality), 2016.



(2008/50/EC, 2004/107/EC)

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APPENDIX E EXTRACT FROM REPORTING (DATAFLOW G)

Table E-1 Number of zones with exceedances

2013 2014 2015 2016

NO2 - 1 3 -

PM10 - 1 1 -

SO2 - - - -

C6H6 - - - -

CO - - - -

Pb - - - -

O3 2 1 2 2

Source: Member State reporting, data flow G.

doi:[number]

ISBN [number]

[Cata

logue n

um

ber]

Written by Marta Ballesteros March 2019

CASE STUDY REPORT

SPAIN



(2008/50/EC, 2004/107/EC)



(2008/50/EC, 2004/107/EC)

March 2019 2

Contents

1 Introduction 4


2.1 Member State and air quality zone characteristics 5





2.6 Use of EU funding for air quality improvements 25


3.1 Relevance of the Ambient Air Quality Directives 27

3.2 Implementation and integration successes and challenges 28


Ambient Air Quality Directives 36

3.4 Costs and benefits of the Ambient Air Quality Directives 39

4 Conclusions 43




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March 2019 3

Appendices

Appendix A Interview



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1 INTRODUCTION

This report summarises the findings and conclusions of the case study for Spain. The case study

had a focus on the municipality of Madrid.

















the case study






over the period September, October and November 2018. An overview of the interviews carried

out is provided in Appendix A.






(2008/50/EC, 2004/107/EC)

March 2019 5


This chapter provides general information about Spain and the municipality of Madrid in relation

to air quality and the implementation of the above-mentioned Directives. It relies primarily on

desk research, with the intention of establishing the context for the more detailed findings pre-

sented in Chapter 3. Where necessary, the findings from desk research were supplemented by

interviews.

2.1 Spain and air quality zone characteristics

2.1.1 The scope and focus of the case study

The case study covers the territory of Spain, with a particular focus on the municipality of Madrid.

The responsibility for monitoring and ensuring implementation of the AAQ Directives in Spain rests

with the Sub-Directorate General of Air Quality and Industrial Environment of the Ministry of

Environment (currently the Ministry for Ecological Transition, MITECO), with data provided by the

17 autonomous communities and certain local entities. As required by Article 4 of Directive

2008/50/EC, zones and agglomerations have been established in the territory of Spain in order

to assess air quality and ensure air quality management. Given the division of responsibilities in

Spain, each autonomous community has separated its territory into different zones and agglom-

erations depending on the pollutant (e.g. NO2 and PM10). Figures 2.1 and 2.2 below show some

examples.

Figure 2-1 Air quality zones for NO₂, 2017

Source: MITECO, Report on the Evaluation of Air Quality in Spain, 2017.



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Figure 2-2 Air quality zones for PM10, 2017

Source: MITECO, Report on the Evaluation of Air Quality in Spain, 2017.

Each of the zones has a specific number of measurement stations, which vary depending on the

existing levels, the type of zone and the population. In the whole territory of Spain there are more

than 600 measurement stations1.

The municipality of Madrid is a zone within the Region of Madrid. With three million inhabitants,

Madrid is the most populated city in Spain and one of the most populated capitals in Europe. It

welcomes more than two million visitors every day2. The municipality of Madrid has its own net-

work of air quality sampling points, distinct to that of the Region. This network covers a population

of 3,182,981 inhabitants (6.83% of the Spanish population) and a territory of 604 km (0.12% of

the Spanish territory)3. This network is the basis of the system for monitoring, predicting and

providing information on air quality. It aims to ensure that air quality in the city is controlled in

order to protect public health and minimise risk to the greatest extent possible. The system pro-

vides information on the concentrations of pollutants continuously and in real time.

According to the preamble of the Protocol for action in case of incidences of pollution caused by

NO2 in the Madrid municipality4, the alert threshold for NO2 has never been exceeded in the

municipality of Madrid; however, the hourly limit value (which should not be exceeded for more

than 18 hours per year in any of the stations within the network) has been exceeded on several

occasions and at several of the network’s stations.

1 Ministerio para la Transición Ecológica (MITECO), Redes de vigilancia de calidad del aire (Website of the Ministry of Environment, page on air quality monitoring networks), available at:

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-

del-aire/evaluacion-datos/redes/default.aspx 2 Preamble of the Municipal Ordinance of Sustainable Mobility 2018/45: Ayuntamiento de Madrid, Ordenanza de Movilidad Sostenible, Municipal Ordinance of Sustainable Mobility 2018/45 of 23 October 2018,

https://sede.madrid.es/portal/site/tramites/menuitem.5dd4485239c96e10f7a72106a8a409a0/?vgnex-toid=5ccdb732cef96610VgnVCM2000001f4a900aRCRD&vgnextchan-

nel=6b3d814231ede410VgnVCM1000000b205a0aRCRD&vgnextfmt=default 3 Ministerio para la Transición Ecológica, Evaluación de la calidad del aire en España, 20176, available at:

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/informe-

evaluacioncalidadaireespana2017_tcm30-481655.pdf 4 Ayuntamiento de Madrid, Protocolo de actuación para episodios de contaminación por Dióxido de nitrógeno

en la ciudad de Madrid, 2018, Available at: https://transparencia.madrid.es/UnidadesDescentralizadas/Sos-tenibilidad/CalidadAire/Ficheros/ProtocoloNO2AprobFinal_201809.pdf

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/evaluacion-datos/redes/default.aspx

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/evaluacion-datos/redes/default.aspx

https://sede.madrid.es/portal/site/tramites/menuitem.5dd4485239c96e10f7a72106a8a409a0/?vgnextoid=5ccdb732cef96610VgnVCM2000001f4a900aRCRD&vgnextchannel=6b3d814231ede410VgnVCM1000000b205a0aRCRD&vgnextfmt=default






https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/informeevaluacioncalidadaireespana2017_tcm30-481655.pdf




https://www.madrid.es/UnidadesDescentralizadas/Sostenibilidad/CalidadAire/Ficheros/ProtocoloNO2AprobFinal_201809.pdf








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Figure 2-3 Air quality zone of Madrid (for NO2 and PM10)

2.1.2 Geomorphology

Spain has certain geomorphological specificities which influence its performance on ambient air

quality insofar as particles and O3 are concerned. Spain has always presented high levels of par-

ticles, partly due to its situation close to African air mass which triggers a natural increase of

PM10 and PM2.5. As a result, public authorities began to measure and quantify the levels of parti-

cles by taking into account the contributions to pollutants in ambient air from these natural

sources (African air mass), and to deduct those quantities when assessing compliance with air

quality limit values for particles occurring due to human activity5. Spain’s main sources of parti-

cles from human activity are combustion from non-industrial sources (for PM10 and PM2.5), road

traffic (PM10) and agriculture (PM2.5). PM10 is registered in diverse areas: cities, industrial and

rural zones.

Similar to much of southern Europe, O3 constitutes a widespread general issue in Spain, due to

high levels of solar radiation, which affects the entire country, although with markedly lower

levels in the North. The speed and level of generation of ozone (O3) are magnified by increased

solar radiation, human emissions of precursors and the biological cycle of biogenic emissions of

volatile organic compounds (VOCs). Levels of O3 are higher in spring and summer. They are also

higher at the peripheries of large cities, in rural areas and at weekends, especially on Sundays.

The city of Madrid has a continental Mediterranean climate, characterised by an average tem-

perature (at its hottest) above 22oC, dry and fresh winters (with average temperatures around

8º C) and average minimums between 1.6 and 4.2ºC in the different seasons. The average an-

nual temperature exceeds 14ºC. The summers are very hot, with average highs above 30ºC.

There is little rainfall annually, typically less than 500 mm per year, falling mainly in spring and

5 Ministerio de Agricultura, Alimentación y Medio Ambiente, Procedimiento para la identificación de episodios naturales de PM10 y PM2,5, Y la demostración de causa en lo referente a las superaciones del valor límite

diario de PM10, 2013. Available at: https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/te-

mas/atmosfera-y-calidad-del-aire/metodologiaparaepisodiosnaturales-revabril2013_tcm30-186522.pdf;

Ministerio para la Transición Ecológica, Efectos en la salud y ecosistemas (Website of the Ministry of Envi-

ronment, page on health and ecosystem impacts), available at: https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/salud/

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/metodologiaparaepisodiosnaturales-revabril2013_tcm30-186522.pdf




https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/salud/





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autumn, with a markedly dry period in summer. Snow days are scarce (average of four per

year). Frost is more common in winter and autumn, reaching a very different average according

to the different seasons. This is due to the heat island effect produced by the city itself (i.e. the

high intensity of traffic and heating)6.

The surface of the municipality is characterised by soft forms, in which hills and plains alternate,

with an altitude oscillating between 543 and 846 metres as it is located in a plain. The rock face

gives erosion different characteristics, ranging from the sharper slopes in the north to the milder

forms in the south. From a topographical perspective the Manzanares River fractures the munic-

ipality, with its corresponding alluvial plain and fluvial terraces. The presence of the mountain-

ous relief of the Sierra de Guadarrama, has a very important influence on the climate of Madrid.

It exerts a barrier effect which prevents clouds and humid winds from advancing towards the

interior, making rainfall (and precipitation generally) more scarce in the city7. In addition, build-

ings and pavements modify the relief and influence the climate (together with traffic and heat-

ing), creating the recognised climatic effect of a ‘heat island’, i.e. an abnormal increase in tem-

perature from the outskirts to the centre of the city, caused by the heat given off by urban ac-

tivity. The asphalt accumulates a lot of heat during the day and gives off that heat at night, pre-

venting the city from cooling normally8.

The detailed characteristics of Spain and the municipality of Madrid are presented in the text box

below.

Text box 2-1 Spain and Madrid

Spain

GDP per capita in PPS (EU-28 avg: 100) (2017) 92

GDP per capita growth (% 2008-2016) -2.46%


Governance structure Regionalised9

Zones defined as agglomerations (%) Information not found/not available

Autonomous community of Madrid

Number of inhabitants: 6,507,184

GDP per capita in PPS (EU-28 avg: 100) (2017) 125

Area: 8,028 km²

Characteristics of the Madrid region:

The autonomous community of Madrid is divided into six zones for air quality monitoring. One such zone is

the municipality of Madrid, which has its own monitoring network independent from that of the autonomous

7 Ayuntamiento de Madrid, Plan de Calidad del Aire y Cambio Climático de la Ciudad de Madrid, 2017. Avai-

lable at: https://www.madrid.es/UnidadesDescentralizadas/UDCMedios/noticias/2017/03Marzo/13Lunes/No-tasdePrensa/Plan%20Calidad%20Aire/ficheros/PlanACalidadAire2017.pdf 8 Ayuntamiento de Madrid, Plan de Calidad del Aire y Cambio Climático de la Ciudad de Madrid, 2017. Avail-

able at: https://www.madrid.es/UnidadesDescentralizadas/UDCMedios/noticias/2017/03Marzo/13Lunes/No-

tasdePrensa/Plan%20Calidad%20Aire/ficheros/PlanACalidadAire2017.pdf 9 For further details see: Committee of the Regions, https://portal.cor.europa.eu/divisionpowers/coun-tries/MembersLP/Spain/Pages/default.aspx

https://www.madrid.es/UnidadesDescentralizadas/UDCMedios/noticias/2017/03Marzo/13Lunes/NotasdePrensa/Plan%20Calidad%20Aire/ficheros/PlanACalidadAire2017.pdf








https://portal.cor.europa.eu/divisionpowers/countries/MembersLP/Spain/Pages/default.aspx






(2008/50/EC, 2004/107/EC)

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community (as explained further below). Madrid is the most populous city in Spain, with 3,182,981 inhab-

itants in an area of 604 km2.

Source: Eurostat, GDP per capita in Purchasing Power Standards (PPS) expressed in relation to the EU-28 average (set to equal 100); Eurostat, Real GDP per capita, growth rate and totals; Eurostat, Population on 1

January; INE, Statistics on population in Spain.


The following section presents briefly the arrangements made in Spain for air quality monitoring

and provides a short overview of the air quality situation in Spain.


Spain uses different control and monitoring air quality networks, managed by different competent

authorities. All 17 autonomous communities and, specifically, the municipalities of Madrid and

Saragossa, have their own networks to monitor the main pollutants. In addition, there is a national

network (the EMEP/VAG/CAMP network), which monitors the background air quality in remote

rural areas10. Spain has more than 600 fixed measurement stations11.

Each network divides its territory into zones and monitors the concentrations of certain pollutants

in the air. When any of the pollutants is at risk of exceeding one or more alert thresholds, the

network develops a short-term action plan. Networks are also responsible for drafting Air Quality

Plans to keep pollutants below the limit values or target values. Data gathered by the networks

are sent to MITECO, which manages and maintains the Air Quality Database, develops national

plans to improve air quality, compiles annual reports on air quality, and sends data to the Euro-

pean Environmental Agency (EEA)12.

The methodology used to monitor air quality follows the AAQ Directives and is based on the

information collected by each network according to common criteria relating to the size of ag-

glomerations and ecosystems exposed to air pollution13. Based on these data, the competent

administrations divide their territory into zones or agglomerations according to population den-

sity14:

• The zones are portions of territory defined by the competent administration and used for the

evaluation and management of ambient air quality.

• The agglomerations are defined as extended urban areas of population with more than

250,000 inhabitants or, where the population is equal to or less than 250,000 inhabitants,

with a population density per km2 that, according to the competent administration, justifies

the evaluation and control of ambient air quality.

The autonomous communities and local entities define their corresponding zones and agglomer-

ations based on homogenous criteria for emissions and concentrations of pollutants. The zoning

10 Ministerio para la Transición Ecológica, Evaluacion de la calidad del aire in España, año 2017 https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/informe-

evaluacioncalidadaireespana2017_tcm30-481655.pdf 11 Ministerio para la Transición Ecológica, Redes de vigilancia de calidad del aire (Website of the Ministry of

Environment, page on air quality monitoring networks), available at: https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/evaluacion-datos/redes/ 12 Ministerio para la Transición Ecológica, Evaluacion de la calidad del aire in España, año 2017.

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/in-

formeevaluacioncalidadaireespana2017_tcm30-481655.pdf 13 Ibid 14 Ibid





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of the Spanish territory depends on the pollutant, thus each pollutant has its own zoning map.

The zoning is carried out as follows:

• For all of the pollutants evaluated (except for ozone), zoning is carried out in accordance with

the upper and lower assessment thresholds as established in Annex II of Royal Decree

102/2011, of 28 January, which transposes both Directives 2004/107/EC and 2008/50/EC.

These thresholds are set to guarantee the equivalence of the evaluation of ambient air qual-

ity, regardless of the territorial scope considered.

• For O3, zoning is carried out in relation to the long-term objective value also established by

Royal Decree 102/2011 of 28 January

Values in the Royal Decree are the same as those in the Directives it transposes.

The zoning may undergo modifications over time depending on the evolution of legislation on the

levels of pollutants. Ambient air quality is evaluated using the information provided by the differ-

ent air quality networks, in line with the following criteria:

• Evaluation for all pollutants, with the exception of O3

Measurements of these pollutants are first carried out in the ambient air, in fixed places in those

zones and agglomerations where the levels exceed the upper evaluation thresholds. Fixed meas-

urements may be complemented with modelling or indicative measurements to obtain adequate

information on the spatial distribution of ambient air quality.

In those areas and agglomerations where the level of pollutants is below the lower evaluation

threshold, modelling techniques for the evaluation of the ambient air quality can be used without

the need to carry out fixed measurements.

• O3 evaluation:

In the case of O3, it is mandatory to carry out continuous fixed measurements in areas and ag-

glomerations in which O3 concentrations exceeded a long-term objective during any of the previ-

ous five years.

Where data are available for a period of less than five years, the competent authorities complete

the data with short-term measurement campaigns in the periods and places where the probability

of observing high levels of contamination is high, in accordance with the results obtained from

emissions inventories and modelling.

In the remaining zones and agglomerations, continuous fixed measurements can be supple-

mented with information from modelling and/or indicative measurements.

• Determination of the classification of the area with respect to the legislated values:

The classification of an area with respect to the legislated values for all pollutants is determined

by the situation of the worst station or the highest levels of a model.

Monitoring stations for air pollution can be classified according to the type of area in which they

are located (i.e. urban, suburban and rural) or according to the typology of the main emissions

source, which determines predominant pollutants (e.g. traffic, industrial or background).



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The municipality of Madrid has in place the so-called Integral System of Air Quality, which

provides information on the level of air pollution in its territory at any time. The system is com-

posed by three sub-systems (for monitoring, prediction and information)15:

• Monitoring system: composed by 24 automatic remote stations that measure the levels of

pollutants (gases and particles). There are three types of stations: background urban sta-

tions, traffic stations and sub-urban stations (depending on the location). The system also

disposes of monitoring mobile units for specific measuring campaigns.

• Prediction system: it provides information on the evolution of the levels of air quality and

generates a hourly prediction of the concentrations of nitrogen, ozone and particles PM10 for

the next 24 hours.

• Information system: provides information on air quality to the public.

2.2.2 Air quality in Spain

The data provided below (for the period 2005-2016) were included within the report on the Na-

tional Plan for Air Quality 2017-2019 (Plan Aire II)16 and can also be found in the latest national

report on air quality with data from 201717. It shows an improvement of the situation on SO2. Of

all pollutants, three (NO2, PM10 and O3) have exceeded the established legal value in all years

during the period 2005-2016, and in 2017. In other cases, the exceedance of the value occurred

at a particular point in time (see Figure 2-4).

Figure 2-4 Exceedances of legal values in Spain (2005-2016)

Source: MITECO, Plan Nacional de Calidad del AIRE 2017-2019 (Plan Aire II).

15 Ayuntamiento de Madrid, Plan de Calidad del Aire y Cambio Climático de la Ciudad de Madrid, 2017. Avai-lable at: https://www.madrid.es/UnidadesDescentralizadas/UDCMedios/noticias/2017/03Marzo/13Lunes/No-

tasdePrensa/Plan%20Calidad%20Aire/ficheros/PlanACalidadAire2017.pdf 16 Ministerio para la Transición Ecológica, Plan Nacional de Calidad del AIRE 2017-2019 (Plan Aire II), 2017.

Available at: https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-

aire/planaire2017-2019_tcm30-436347.pdf 17 Ministerio para la Transición Ecológica, Evaluación de la calidad del aire en España: Año 2017, Available

at: https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/in-formeevaluacioncalidadaireespana2017_tcm30-481655.pdf





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Further, the analysis of the period 2012-2016 shows that the average concentrations of the pol-

lutants in question (SO2, NO2, PM10, PM2,5, O3) decreased between 2012 and 2014, increased in

2015 and decreased again in 201618.

According to the 2017 Evaluation Report on Air Quality in Spain (published in September 2018),

the 2017 results are worse than those of 2016, as the number of air quality zones exceeding the

legislated values for NO2 and PM10 increased19. For NO2, the number of urban agglomerations that

exceeded the legislated values increased. More specifically, in 2017, the hourly limit value was

exceeded in the same area of Madrid as it was in the previous year. In addition, exceedances

occurred in large cities such as Madrid and surroundings, Barcelona and surroundings, Granada

and its metropolitan area, and Bilbao and its surroundings, largely due to traffic emissions20.

Per pollutant, the evolution of NO2 in the period 2005-2016 shows a continuous decrease in all

type of stations (traffic, urban and rural) with a small rise in each in 2015. NOx is known to be

the sum of NO+NO2. The main source of this pollutant is transport, which represents more than

50% of the total NOx emissions. The levels of NO2 have continuously decreased since 2005, with

a small rise in 2015.

In 2017, the hourly limit value of NO2 was exceeded only in Madrid (similar to previous years),

while the NO2 annual limit value was exceeded in seven zones (compared to six in 2016): Bajo

Nervión (Basque Country), Barcelona and Vallès-Baix Llobregat (Catalonia), Corredor del Henares

and Urbana Sur (in the community of Madrid), Granada and its metropolitan area (in Andalusia),

and in the municipality of Madrid.

Figure 2-5 Annual mean NO2 level, 2005-2016, by type of station and area


A similar trend of decrease is evident for levels of SO2 in the period 2005-2016. In 2015, the

main source of such emissions was energy production, followed by industrial processes using

combustion. Between 2011 and 2017, limit values were not exceeded in any zone. The exceeding

18 Ministerio para la Transición Ecológica, Plan Nacional de Calidad del AIRE 2017-2019 (Plan Aire II), 2017.

available at: https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/planaire2017-2019_tcm30-436347.pdf 19 Ministerio para la Transición Ecológica, La calidad del aire en España en 2017 baja levemente con res-

pecto al año anterior (webpage). Available at: https://www.miteco.gob.es/es/prensa/ultimas-noticias/La-

calidad-del-aire-en-Espa%C3%B1a-en-2017-baja-levemente-con-respecto-al-a%C3%B1o-anterior/tcm:30-

481677 20 Idem.



https://www.miteco.gob.es/es/prensa/ultimas-noticias/La-calidad-del-aire-en-Espa%C3%B1a-en-2017-baja-levemente-con-respecto-al-a%C3%B1o-anterior/tcm:30-481677






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emissions before 2012 came mainly from industrial stations in rural areas. However, this is no

longer a problem. The link with the Industrial Emissions Directive has been positive and the best

available techniques references (BREF) are ambitious. It is worth noting the particular problem in

Asturias, where a station has been placed inside an industrial facility and the problems of exceed-

ances of the SO2 limit values continued for 10 years. The Directive does not permit a station to

be moved for three years from the time a limit value has been exceeded. Having explained this

case to the Commission, however, Spain is set to move the station21.

Figure 2-6 Annual mean of SO2 level 2005-2016, by type of station and area


Levels of PM10 have progressively decreased since 2005. However, the situation changed in 2014,

which noted an increase until 2016, at which time values were again similar to those of 2013 (the

minimum in the period). The sources of emissions chiefly related to combustion in non-industrial

sectors (especially residential combustion), as well as agriculture and the cattle industry. The

daily and annual values of PM10 exceeded the limits in 19 zones at some point during the period

2012-2016.

In 2017, the PM10 daily limit value (excluding particles of natural origin) was exceeded in five

zones, while the annual limit value was exceeded in one single zone. This evidences an increase

in the number of areas exceeding the daily limit value, which has gone from three areas in 2016

to five in 2017: Granada and the Metropolitan Area, Malaga and Costa del Sol, Villanueva del

Arzobispo, Avilés, and Plana de Vic. The PM10 annual limit value evaluation data indicate that

the situation remains similar to previous years with Avilés as the single zone which continues to

show exceedances22.

It is worth mentioning the case of Villanueva del Arzobispo, which, according to the information

collected within the framework of this project, is an area with industrial production (Jaen, olive

groves) where biomass is regularly burned. Although the problem of emissions from industrial

activity was solved by changing the means of energy production and the use of filters for smoke

21 Information from the interview with the Ministry of Environment, 24 September 2018. 22 Ministerio para la Transición Ecológica, La calidad del aire en España en 2017 baja levemente con res-


calidad-del-aire-en-Espa%C3%B1a-en-2017-baja-levemente-con-respecto-al-a%C3%B1o-anterior/tcm:30-481677









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treatment, the boom in domestic biomass burning has created a new, more complex problem.

The lack of prioritisation of gas distribution at local level saw gas arrive to the village of Villanueva

del Arzobispo only in 2018. Up until now, the use of biomass has been promoted without ensuring

the use of certified efficient stoves or boilers, resulting in air quality problems. The Ministry of

Industry has now approved subsidies to support behavioural change in homes23.

Figure 2-7 Annual mean of PM10 level 2005-2016, by type of station and area


The general levels of PM2.5 have been also reduced, despite some increases in 2011, 2012 and

2015. The biggest source of pollution was combustion in non-industrial sectors, at more than 60%

of the total. The number of areas exceeding the limit was considerably reduced in 2016.The limit

value of PM2.5 (which entered into force in 2015) was exceeded that year (before it was a target

value but was not exceeded) but the situation reverted to normal in 2016. In 2017, the annual

limit value had good results after applying the new methodology (excluding particles of natural

origin). The objective is to reduce this particle by 15% by 2020, compared to the value in 2010.

However, in 2017 the results were slightly worse than the previous year (9.9% reduction in 2017,

compared to 12.1% in 2016).

23 Information from the interview with the Ministry of Environment, 24 September 2018.



(2008/50/EC, 2004/107/EC)

March 2019 15

Figure 2-8 Annual mean of PM2.5, 2008-2016, by type of station and area


O3 values were reduced in rural stations, reaching the minimum in 2016, but increased continu-

ously in traffic and urban stations (despite a decrease in 2016). O3 is a secondary pollutant formed

through photochemical reactions from precursor gases. The speed and level of formation of O3 is

influenced by solar radiation, making it a widespread general issue in Spain. In 2015, the main

sources of emissions were related to the use of solvents and agriculture.

In 2017, of Spain’s 126 zones measuring this pollutant, 36 zones (Southern part of the pen-

insula) reported values higher than the target value, 78 showed values between the target

value and the long-term target, while 12 reported values below the long-term target.

The annual reports prepared by the Ministry also contain information on the levels of other pollu-

tants: benzo(a)pyrene (B(a)P), carbon monoxide (CO), lead (Pb), benzene (C6H6), arsenic (As),

cadmium (Cd) and nickel (Ni). Target or limit values of these pollutants were not exceeded in any

zone in 2017. Royal Decree 102/2011 also requires all agglomerations of more than 500,000

inhabitants to ensure measuring ammonia (NH3), despite not been covered by the Ambient Air

Quality Directives.



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March 2019 16

Figure 2-9 Annual mean of the 93.2 percentiles of O3, by type of station and area


2.2.3 Air quality in Madrid

The data trend for NOx by activity sector since 1999 shows that road transport has the biggest

impact on NOx emissions. However, emissions have diminished from 19,226 tonnes in 1999 to

7,012 tonnes in 201424.

Statistics on SO2 emissions show a general drop for all activity sectors, largely caused by a re-

duction in the sulphur content of fuels and the reduction in the consumption of coal and fuel oil.

Again, the sharpest decline occurred in the road transport sector (down from 1,136 tonnes in

1999 to 14 tonnes per year between 2012 and 2014).

A drop is also evident in non-methane volatile organic compounds (NMVOC) during the period

1999-2014. These are found in solvents and other products, as well as emissions from nature.

Road transport emissions of carbon monoxide (CO) represent more than half of CO emissions.

They have dropped very significantly, from 90,200 tonnes in 1999 to 6,234 tonnes in 2014. A

similar trend is found when analysing the levels of particles (PM10 and PM2.5), with road transport

again the primary source, responsible for 61.3% and 55% of the totals, respectively.

The 2017 national report on air quality25 includes a section on the municipality of Madrid, which

shows that the hourly and annual limit values for NO2 and the target value for O3 were exceeded,

being the only zone with exceedances in the terms of the hourly limit value for NO2 and therefore

on the three values at the same time. Road transport is the main cause of the NO2 levels. During

the period analysed in the report (2011-2017), there were constant breaches of the limit values

for NO2 and the target value of O3.

24 Ayuntamiento de Madrid, Plan de Calidad del Aire y Cambio Climático de la Ciudad de Madrid, 2017. Avail-able at: https://www.madrid.es/UnidadesDescentralizadas/UDCMedios/noticias/2017/03Marzo/13Lunes/No-

tasdePrensa/Plan%20Calidad%20Aire/ficheros/PlanACalidadAire2017.pdf 25 Information from the interview with the Madrid municipality, 21 September 2018 and with the Ministry of

Environment, 24 September 2018. And Ministerio para la Transición Ecológica, Evaluación de la calidad del

aire en España: Año 2017, Available at: https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/te-mas/atmosfera-y-calidad-del-aire/informeevaluacioncalidadaireespana2017_tcm30-481655.pdf











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The municipality of Madrid also publishes annual reports. The latest from 201726, shows that

values for SO2 were very low in all stations. The same was true of PM10 and PM2.5, whose limit

values were kept below those set out in the AAQ Directives. However, some stations exceeded

the guide value established by the World Health Organization (WHO).

Clean air dialogue

In October 2018, the Commission held a Clean Air Dialogue with Spain27, at which it was concluded

that good governance including better coordination among the different administrations and

different ministries is essential to improve the clean air policy.. The Commission urged

Spain to implement measures to ensure better coordination and thereby improve policies and

maximise benefits. In addition, the involvement of the stakeholders concerned and transparency

are key to ensure effective implementation of mitigation measures and public acceptance. Addi-

tional actions to comply with NO2 limit values such as those demonstrated in other Member States,

should be considered in Spain, e.g. access restrictions for transport, fiscal incentives to promote

cleaner cars, or incentives to promote public transportation and non-motorized transport oppor-

tunities. The current imbalance in taxation between petrol and diesel is not justified from an

environmental perspective28.

Further action is needed in order to meet PM10 limit values and achieve the reduction commit-

ments for PM2.5 in all Spanish regions. Such actions could include: establishing requirements on

the quality of solid fuels used in households; further incentives to accelerate scrapping of sub-

standard solid fuel stoves and boilers and promoting systematic transfer to cleaner heating

sources; continuous awareness-raising among the public of the health impact of residential solid

fuel combustion and operation techniques in private households; and activities on energy effi-

ciency. A ban on open field burning of agricultural waste was also raised, together with the pro-

motion of policies on energy renovation of buildings. Due to the cross-cutting nature of air quality,

efforts in this area can be included in both climate and energy-related policies29.

Finally, the dialogue highlighted the need to reduce NH3 emissions, for which agricultural activity

is the key source. Experiences from other Member States could be applied in Spain. O3 values are

also an important issue in Spain and some effort has already been expended in improving

knowledge to create more targeted policy responses.


Pursuant to Article 3 of the AAQ Directives, Member States shall designate – at the appropriate


and the implementation of other obligations laid down by the AAQ Directives.

In Spain, Article 5 of Law 34/2007 of 15 November on air quality and the protection of the at-

mosphere makes a list of the competences attributed to the administrations of the state, the

26 Madrid, Dirección General de Sostenibilidad y Control Ambiental, Calidad del Aire 2017, available at:

http://www.mambiente.munimadrid.es/opencms/export/sites/default/calaire/Anexos/Memorias/Memo-ria2017.pdf 27 European Commission and Ministerio para la Transición Ecológica, Conclusions of the Clean Air Dialogue between Spain and the European Commission, taking place in Madrid on 8-9 October 2018, October 2018.

Available at: http://ec.europa.eu/environment/air/pdf/shared conclusions from clean air dialogue w Spain.pdf 28 European Commission and Ministerio para la Transición Ecológica, Conclusions of the Clean Air Dialogue

between Spain the European Commission taking place in Madrid on 8 – 9 October 2018, October 2018.

Available at: http://ec.europa.eu/environment/air/pdf/shared conclusions from clean air dialogue w

Spain.pdf 29 Ibid

http://www.mambiente.munimadrid.es/opencms/export/sites/default/calaire/Anexos/Memorias/Memoria2017.pdf




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autonomous communities and local entities. Article 3 of Royal Decree 102/2011 on the improve-

ment of air quality further specifies the responsibilities of different institutions. According to these

provisions, the administration of the state (generally MITECO through its Directorate-General on

Environmental Quality and Evaluation), alone or with the participation of the autonomous com-

munities, is charged with, among other tasks: defining and establishing the air quality objectives,

the alert and information thresholds and the emission limit values; defining the minimum require-

ments for stations, networks, methods and other systems; defining methodologies; preparing

plans and programmes; preparing and periodically updating the Spanish emissions inventories;

and coordinating the Spanish system of information, monitoring and prevention of air pollution.

The State Meteorological Agency (attached to the Ministry of Environment) is responsible for the

management of the EMEP/VAG/CAMP network of air pollution and for implementing a quality con-

trol and quality assurance system for guaranteeing the results of the network.

The National Centre for Environmental Health of the Carlos III Health Institute, under the Ministry

of Economy, Industry and Competitiveness, acts as a national reference laboratory.

The autonomous communities – and local entities where appropriate – are competent to assess

air quality, establish stricter air quality targets and limit values than those established by the

state, adopt air quality improvement plans and programmes, adopt control and inspection

measures, and impose sanctions. To discharge these responsibilities they need to: designate

competent bodies, laboratories, institutes and technical-scientific bodies responsible for the ap-

plication of the standards on ambient air quality; delimit and classify zones and agglomerations;

compile data on their territories; adopt measures to ensure that concentrations of regulated pol-

lutants do not exceed the air quality objectives and to reduce them if necessary, including by

taking emergency measures; and approve the measurement systems, consisting of methods,

equipment, networks and stations.

In the case of the region of Madrid, two administrative entities are competent for these functions,

the autonomous community, through its Department of Air Quality within the Ministry of Environ-

ment of the Region, and the municipality of Madrid, which has its own control and monitoring air

quality network, separate to that of the autonomous community. Article 6 of the Autonomous

Statute of the Community of Madrid states that Madrid will have its own special regime due to its

position as capital of the state.

Within the municipality of Madrid, the Department of Environment and Mobility is responsible for

ambient air quality. The municipality has in place the so-called Integral System of Air Quality,

which allows it to know the level of air pollution in its territory at any given time. The system

comprises three sub-systems (for monitoring, prediction and information)30. They lead to im-

portant measures such as the development of a map of the monitoring network which provides

information on the concentration levels per station, date and time31.


Legal framework

The legal framework for air quality in Spain is composed of Law 34/2007 of 15 November on air

quality and the protection of the atmosphere, and Royal Decree 102/2011 on the improvement

30 Ayuntamiento de Madrid, Plan de Calidad del Aire y Cambio Climático de la Ciudad de Madrid, 2017. Avail-

able at: https://www.madrid.es/UnidadesDescentralizadas/UDCMedios/noticias/2017/03Marzo/13Lunes/No-tasdePrensa/Plan%20Calidad%20Aire/ficheros/PlanACalidadAire2017.pdf, p. 37 31 Idem







(2008/50/EC, 2004/107/EC)

March 2019 19

of air quality. In addition, Articles 99 and 100 of Law 2/2011 of Sustainable Economy establish

the principles and objectives of a policy on sustainable mobility.

Law 34/2007 provides the legal basis for the prevention, monitoring and reduction of air pollution

in Spain. Its ultimate goal is to achieve optimal levels of air quality to prevent or reduce the

potential negative effects of air pollution on human health, the environment and other goods of

any nature. Through the Law, the Central government exercises its competence to define and

establish air quality objectives and the minimum requirements of air quality assessment systems,

and it also serves as a regulatory framework for the preparation of national, regional and local

plans for the improvement of air quality. It sets out a system for the management and evaluation

of air quality based on air quality objectives and the zoned territory, prevention and control of

emissions, planning and public participation, incentives, inspections and monitoring through net-

works of monitoring stations, and an enforcement policy with infringement and sanctions.

Royal Decree 102/2011 transposes the AAQ Directives (2008/50/EC and 2004/107/EC). It was

amended by Royal Decree 678/2014 to update the carbon sulphide quality objectives, and again

by Royal Decree 39/2017 to transpose Directive 2015/1480 into Spanish law, which establishes

standards for reference methods, data validation and location of measurement points for the

evaluation of ambient air quality, and incorporating the new requirements for exchange of infor-

mation set out in Decision 2011/850/EU.

At a municipal level, the Madrid government updated the regulatory framework from 200532 and

adopted a new Municipal Ordinance for Sustainable Mobility33 in 2018. The main objective of this

Ordinance is to regulate certain activities to ensure the protection of human health through the

substantial improvement of air quality. Together with Law 34/2007, the Royal Decree provides

the legal framework to develop Plan A for Air Quality and Climate Change, published in the official

journal of 26 September 201734. It also aims to influence environmental sustainability through

the promotion of public transport and the use of collective public transport, pedestrian and cyclist

mobility, the development of electric mobility, less polluting mobility and shared-use vehicles,

and to better rationalise the different uses of urban public roads and spaces, including parking

space both on the surface and in municipal car parks. It introduces the use of an environmental

classification for cars, developed by the State General Directorate of Traffic as a tool to manage

sustainable mobility based on environmental criteria and promoting the use of less polluting cars.

The new Ordinance thus introduces measures that were not in place previously, such as the gen-

eral obligation for cars and motorbikes to circulate at 30 km/h maximum unless the streets have

several lanes in each direction (e.g. in large avenues) or multiple lanes in a single direction. The

cycle lanes in the main avenues remain as before, i.e. lanes marked horizontally with bicycle

symbols and limited to 30 km/h.

The new Ordinance only allows scooters without engines on footpaths provided that they do not

exceed 50hm/h (those with engines are forbidden on footpaths in all cases). It also introduces a

32 Ayuntamiento de Madrid Municipal Ordinance for mobility in Madrid of 2005 (ANM 2005/48), available at: https://www.madrid.es/UnidadesDescentralizadas/UDCMovilidadTrans-

portes/SER/Ficheros%20nuevo%20SER%202014/Ordenanza%20de%20Movilidad.pdf 33 Ayuntamiento de Madrid, Ordenanza de Movilidad Sostenible, Municipal Ordinance of Sustainable Mobility

2018/45 of 23 October 2018, https://sede.madrid.es/portal/site/tramites/menui-tem.5dd4485239c96e10f7a72106a8a409a0/?vgnextoid=5ccdb732cef96610VgnVCM2000001f4a900aR-

CRD&vgnextchannel=6b3d814231ede410VgnVCM1000000b205a0aRCRD&vgnextfmt=default 34 Ayuntamiento de Madrid, BOAM 7999 26 September 2017, available at: Error! Hyperlink reference not

valid.https://sede.madrid.es/portal/site/tramites/menuitem.b4c91589e7f6a5d829da39e5a8a409a0/?vgnext

oid=02c9dee6398be510VgnVCM1000001d4a900aRCRD&vgnextchan-nel=257865dd72ede410VgnVCM1000000b205a0aRCRD&vgnextfmt=default

https://www.madrid.es/UnidadesDescentralizadas/UDCMovilidadTransportes/SER/Ficheros%20nuevo%20SER%202014/Ordenanza%20de%20Movilidad.pdf










https://sede.madrid.es/portal/site/tramites/menuitem.b4c91589e7f6a5d829da39e5a8a409a0/?vgnextoid=02c9dee6398be510VgnVCM1000001d4a900aRCRD&vgnextchannel=257865dd72ede410VgnVCM1000000b205a0aRCRD&vgnextfmt=default








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March 2019 20

minimum age of 15 years to drive an electric scooter. Those aged under 16 must also wear a

helmet. Scooters are forbidden in bus lanes and in specific sections of the M30 avenue.

With the new Ordinance, all cars and motorcycles accessing the city of Madrid (including those

coming from other municipalities and regions) must carry the environmental distinctions of the

Directorate-General of Traffic (DGT). The badge excludes the most polluting, those registered

before the year 2000 or diesel engines prior to 2006. The City Council intends to use the label to

apply its new protocol against pollution.

Motorbikes will continue to be able to park on footpaths if they leave a space of three meters,

with some exceptions: in the centre, they cannot park where there is a parking belt on the road

and must instead go to areas reserved for motorbikes. The City Council is seeking to extend this

restriction throughout the city.

The Ordinance also creates the so-called ‘Madrid Central’ area (see below for further explanation).

The Madrid municipality’s Protocol for action in the case of instances of NO2 pollution was adopted

by agreement on 10 December 2018 (Decree 428 of 11 December). It contains extraordinary and

temporary measures of total or partial restriction of traffic, prohibition on parking and limitation

of speed within the municipal area of Madrid, once proper signs are set35. It follows the Protocol

adopted by the Agreement of 21 January 2016.

On the other hand, Decree 140/2017 of November 21 of the Governing Council approved the

Framework Protocol for action during instances of high pollution by nitrogen dioxide (NO2) in the

Community of Madrid, in other words at regional level. It determines that ‘the municipalities in

their protocols may establish the concentrations of NO2 and define the levels of action, but in no

case can these concentrations be higher than those established by the Community in this Proto-

col’. It requires the local action protocols, as well as that approved by the Madrid municipality, to

be framed within the framework of regional planning [...], with local action to be adjusted to the

principles of mutual information, cooperation and collaboration.

Strategic framework

The state has also the competence to develop national plans to improve air quality for those

pollutants with similar behaviours regarding sources, dispersion or levels in several zones or ag-

glomerations.

The government thus approved Plan AIRE 2013-2016, which was a reference framework for

the improvement of air quality in Spain. It established specific measures and coordination with

other sectoral and regional plans, which it tried to complement. The Plan included horizontal

measures related to awareness-raising; provision of information to citizens, administration, re-

search and taxation; and sectoral measures targeting industry, construction, transport, agricul-

ture and livestock, or the residential, commercial and institutional sectors.

One of the main purposes of the AIRE Plan was to make information about air quality more ac-

cessible, transparent and easy to understand. In addition, the AIRE Plan contemplated some

measures to reduce emissions where the state assumes direct competence, such as in ports,

airports and roads, where significant emissions are generated.

35 Ayuntamiento de Madrid, Protocolo de actuación para episodios de contaminación por Dióxido de nitró-

geno en la ciudad de Madrid, 2018, Available at: https://transparencia.madrid.es/UnidadesDescentraliza-das/Sostenibilidad/CalidadAire/Ficheros/ProtocoloNO2AprobFinal_201809.pdf









(2008/50/EC, 2004/107/EC)

March 2019 21

Finally, it included measures to research the situations of more widespread air pollution, such as

the high formation of O3 in periods of greater solar radiation, or the high concentration of particles

in the air. Also important were efforts to improve pollution prediction models, which allow episodes

of pollution to be anticipated with sufficient time to adopt measures and thus improve the effec-

tiveness of the information offered to citizens.

The Plan was updated in 2017 - Plan AIRE 2017-2019 (Plan AIRE II) - which added particles

PM2,5 to the list of parameters included in the previous Plan (SO2, NO2, particle PM10 and O3). The

objective of the Plan remains unchanged, i.e. to implement a series of measures at state level to

improve ambient air quality. The general objectives are: to ensure compliance with legislation on

air quality; to implement measures to reduce the levels of emission into the atmosphere of the

most relevant pollutants; to promote available information on air quality and raise awareness; to

implement measures to ensure compliance with the emission reduction commitments; and to

reinforce actions for the control of registered tropospheric ozone values, given the generalised

exceeding of the objective value for the protection of health in a large part of the country.

The current Plan comprises a total of 52 measures in the areas of information, taxation, improve-

ments in mobility, research, agriculture and livestock, residential sector, industrial sector, road,

air and rail transport and ports.

Infringement procedures

In 2015, the Commission initiated an infringement procedure against Spain for non-compliance

with the NO2 standards of the AAQ Directives. The reasoned opinion was published by the Com-

mission in early 2017 and triggered the adoption of stronger measures in Spain to ensure com-

pliance with the AAQ Directives. One of the regions involved in the infringement (for its failure to

respect air quality limit values for NO2) was Madrid. After the adoption of the reasoned opinion,

on 12 May 2017, Madrid issued a report analysing the situation and proposing measures to comply

with the limit values established in the AAQ Directives for NO2 and PM10 and PM2.5. This report

was followed by regular updates and the adoption of specific measures.

Air quality plans

Royal Decree 102/2011 states the need to approve action plans in those zones or agglomerations

exceeding the regulated levels of pollutants in the air. Several autonomous communities and local

entities subsequently approved air quality plans. The website of the Ministry includes the list of

plans at local and regional level approved in 2016 in those areas were limits were exceeded36.

A total of 54 air quality plans were approved across almost all of the autonomous communities:

Andalusia (15 plans), Aragon (two plans: one approved by the Community and one by the Munic-

ipality of Saragossa), Asturias (three plans), Balearic Islands (one plan), Basque Country (nine

plans), Canary Islands (two plans), Cantabria (one plan), Castilla La Mancha (two plans), Castilla

y Leon (three plans), Catalonia (two plans), Galicia (one plan), La Rioja (one plan), Madrid (nine

plans: seven approved by the Community and two by the municipality of Madrid), Murcia (one

plan) and Valencia (three plans).

The 2017 Annual Report on Air Quality in Spain includes a short-term action plan to reduce the

levels of C6H6 in Trubia (Asturias).

36 Available at: MITECO, Planes de mejora de la calidad del aire (web page), https://www.mi-

teco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/planes-mejora/

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/planes-mejora/







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In its 2017 report, the NGO ‘Ecologistas en acción’37 states that there are several plans on air

quality or short-term action but that a series of flaws have been identified in those plans, namely:

they do not have an execution timeline; they do not establish reduction objectives nor quantitative

indicators to evaluate them; there is no budget assigned to the measures (nor they are not suf-

ficiently broken down); most of the measures only focus on providing information to the public or

raising awareness, which, while necessary, is not enough; some measures included were already

approved in the past and are already in place (therefore, nothing new is approved); some so-

called plans are really guidance or studies and not plans in the sense required by the legislation;

and there is sometimes no monitoring procedure in place. For the short-term plans in particular,

the NGO highlighted several areas where these plans should have been approved but were not.

In the autonomous community of Madrid, the administration approved seven plans and the mu-

nicipality of Madrid approved two, the plan 2011-2015 and the last one, the so-called Plan A. Plan

A was adopted on 21 September 2017 and published in the Official Journal on 26 September

201738. The main objective is to ensure that the limit values established by the legislation on air

quality at national and EU level for NO2, and the WHO guide values for PM10 and PM2.5 are complied

with as soon as possible and, in any case, by 2020. To this end it has ringfenced EUR 543.9 million

from the municipality budget. Plan A has 30 specific measures designed to reduce air pollution or

emissions causing climate change. Among those measures are:

• Madrid Central Low Emissions Zone – this aims to develop a closed perimeter in the Centre

of Madrid with limited access to traffic and increased pedestrian zone. The aim is to promote

a low emissions mobility which prioritises pedestrians, cyclists and public transport and limits

traffic and parking to residents. Cameras will be used to enforce the system, using vehicle

registration plates. It is further developed by the Sustainable Mobility Ordinance, published

on 23 October 201839 .

• The infrastructure measures target the main urban axes by promoting the use of public

transport through the design of specific access roads reserved for public transport driving

from the suburbs to Madrid. Several roads are planned but only one is fully working and set

up to date. The establishment of this infrastructure supporting public transport is the com-

petence of the Autonomous Community, highlighting some tensions between governments

at local and regional level.

• Madrid has created tax incentives for less polluting cars including taxes for circulation and

for parking.

• Car parking is regulated using air quality criteria. This includes parking restrictions based on

pollution levels, regulated through the use of car traffic cards that have been developed

taking into account of cars’ environmental performance. Electric cars benefit from an exemp-

tion to parking tax. The objective is to reduce diesel cars in the short-term and thereby

reduce the exceedance of limit values of NO2.

37 Ecologistas en Acción, La calidad del aire en el Estado español durante 2017, June 2018. Available at:

https://www.ecologistasenaccion.org/wp-content/uploads/2018/06/informe-calidad-aire-2017.pdf 38 Ayuntamiento de Madrid, BOAM 7999 26 September 2017, available at: Error! Hyperlink reference not

valid.https://sede.madrid.es/portal/site/tramites/menuitem.b4c91589e7f6a5d829da39e5a8a409a0/?vgnextoid=02c9dee6398be510VgnVCM1000001d4a900aRCRD&vgnextchan-

nel=257865dd72ede410VgnVCM1000000b205a0aRCRD&vgnextfmt=default 39 Ayuntamiento de Madrid, Ordenanza de Movilidad Sostenible, Municipal Ordinance of Sustainable Mobility

2018/45 of 23 October 2018, https://sede.madrid.es/portal/site/tramites/menui-

tem.5dd4485239c96e10f7a72106a8a409a0/?vgnextoid=5ccdb732cef96610VgnVCM2000001f4a900aR-CRD&vgnextchannel=6b3d814231ede410VgnVCM1000000b205a0aRCRD&vgnextfmt=default

https://www.ecologistasenaccion.org/wp-content/uploads/2018/06/informe-calidad-aire-2017.pdf














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• The short-term plan has been adopted as a Protocol to Plan A to reduce the risk, duration or

severity of the NO2 exceedance. Under the Protocol, information on exceedance of alert

thresholds or critical levels, as well as on the measures to be adopted, is systematically

shared with the public through the web, app “Aire de Madrid”, twitter, sms, visual panels on

the roads, access roads to Madrid, bus canopies or stations, and main streets. Some of the

measures require cars to be banned to ensure traffic reduction or speed limits.

Plan A also includes measures to promote renewable energy and energy efficiency through tax

incentives for buildings. There is a specific measure to improve the management of the waste

treatment plant in Valdemingómez to reduce emissions. The plant operates as an incinerator and

landfill, but the treatment of composting has been improved to include a separated collection for

organic waste. It also uses methane gas as part of its improved energy-use system.


Pursuant to Article 26 of the AAQ Directive, Member States shall ensure that the public are –

adequately and in good time - informed about ambient air quality and other issues specified. In

Spain, Article 8 of Law 34/2007 and Article 28 of Royal Decree 102/2011 oblige public admin-

istrations to take any necessary measures to guarantee the provision of information to the public

regarding air quality, the environmental indicators developed by the Ministry, and plans and pro-

grammes for the protection of the atmosphere40.

According to the legislation, information must be provided in a clear and comprehensive way

through easily accessible means, including the Internet. The following information must be pro-

vided in all cases:

• The situation of air quality in relation to the current quality objectives for each pollutant,

together with periodic information on background contamination (rural background pollution

shall be updated every month). This includes periodic information on:

- Concentrations in the ambient air of SO2, NO2 and NOx, particles, Pb, C6H6, CO,

ozone, As, Cd, mercury (Hg), Ni, B(a)p, and other aromatic hydrocarbon polycyclic

substances, including, at least, enzo (a) anthracene, benzo (b) fluoranthene, benzo (j)

fluoranthene, benzo (k) fluoranthene, indene (1,2,3-cd) pyrene and dibenzo (a, h) an-

thracene.

- The information on concentrations of SO2, NO2, particulates, PM10 at least, O3 and CO

in the ambient air shall be updated, at least every day, and, where feasible, every

hour.

- Information on concentrations of Pb and C6H6 shall be updated at least once a quar-

ter and, where feasible, once a month.

- Deposit levels of As, Cd, Hg, Ni, B(a)p, and other polycyclic aromatic hydrocarbons, at

least, enzo (a) anthracene, benzo (b) fluoranthene, benzo (j) fluoranthene, benzo (k)

fluoranthene, indene (1,2,3-cd) pyrene and dibenzo (a, h) anthracene.

40 The plans at national and regional level are available at: MITECO, https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/planes-mejora/





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- All of this information is provided at the website of the Ministry, which is available at:

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-cal-

idad-del-aire/calidad-del-aire/visor/

• In cases where discounts are established for certain pollutants (due to emissions from natural

sources) for the calculation of non-compliance with quality objectives, the methodology fol-

lowed and the justification for the application of such discounts shall be adequately reported.

The website of the Ministry includes a page on natural sources, with links to the methodology

(procedure for the identification of natural episodes of PM10 and PM2.5) and a list of yearly

reports on natural episodes. This is available at: https://www.miteco.gob.es/es/calidad-y-

evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/evaluacion-da-

tos/fuentes-naturales/

• The information on air quality that Spain sends annually to the European Commission in

compliance with the obligations set out in the Community regulations on air quality. The

website of the Ministry includes a page with links to this information:

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-

del-aire/calidad-del-aire/evaluacion-datos/datos/

• Studies on air quality and health

All publications are available at: https://www.miteco.gob.es/es/calidad-y-evaluacion-ambi-

ental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/documentacion-oficial/ and gen-

eral information per pollutant is provided at: https://www.miteco.gob.es/es/calidad-y-eval-

uacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/salud/

• Autonomous communities are obliged to provide periodic information on the levels of pollu-

tion, specifically when air quality objectives are exceeded. The list of networks of the different

autonomous communities are available at: https://www.miteco.gob.es/es/calidad-y-evalu-

acion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/evaluacion-da-

tos/redes/

The Royal Decree also states that in all cases the public shall be informed when concentrations

exceed air quality objectives, including limit values, target values, alert thresholds, infor-

mation thresholds and long-term objectives, their causes and the affected area. Specific infor-

mation must be provided when alert and information thresholds are exceeded (see Article 28(4)

Royal Decree). That information will also include a brief evaluation in relation to air quality objec-

tives, as well as adequate information on the impact on health and, where appropriate, vegeta-

tion. Finally, a description of the methodology followed in the sampling and analysis will also be

provided.

The criteria for evaluation of air quality are available at the website of the Ministry:

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-

aire/Cap3_Criterios%20evaluacion_tcm30-186479.pdf

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/visor/




https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/evaluacion-datos/fuentes-naturales/





https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/evaluacion-datos/datos/

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/evaluacion-datos/datos/

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/documentacion-oficial/
















https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/Cap3_Criterios%20evaluacion_tcm30-186479.pdf

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/Cap3_Criterios%20evaluacion_tcm30-186479.pdf



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Public administrations must also provide the public with annual reports on all pollutants. On its

website, the Ministry includes the list of annual reports and historic data41. It is also obliged to

approve a National Index of Air Quality, which is not yet available42.

At municipal level, in Madrid, Plan A establishes the development of awareness-raising and

communication actions across the various action lines of the Plan, with the aim of raising

awareness of the need to change citizens’ behaviours so that they can contribute to improving air

quality and fighting climate change in the city.

In addition, Annex II to the Madrid municipality’s Protocol for emergency action in case of in-

stances of pollution by NO2, adopted by agreement on 10 December 2018, establishes the specific

information measures to be activated from the moment any of the alert scenarios of NO2 concen-

trations exceedance are reached or anticipated43. It provides the framework for the short-term

plan to be implemented in exceptional circumstances and establishes the information to be ad-

dressed to the population, with simultaneous notice to political leaders, municipal departments

and organisations working in health and the environment. Information will include the forecast

pollution value that can be reached or the value reached, the time and place at which the levels

were registered and a forecast of their evolution. Likewise, information should include the traffic

restrictions and public transport promotion measures envisaged, as well as the estimated time

for their implementation, in accordance with the levels of pollution that are registered or that are

expected to be registered, based on the weather forecast. The Protocol highlights the need to

take the greatest efforts to adequately inform the public through widely spread media (press,

radio, television) and social networks. Other communication resources will also be used, such as

the website of the municipality and traffic information panels.

In addition, the Alert System on Environmental Health will be activated in order to ensure maxi-

mum reach of the health recommendations to the population, including information on health

protection and minimising environmental exposure.

All information on air quality from the municipality of Madrid is available from a dedicated website,

which has an associated smartphone app with updated information on air quality. The website

(and the app) are available at: http://www.mambiente.madrid.es/opencms/opencms/calaire

2.6 Use of EU funding for air quality improvements

Spain does not typically use EU Structural funds to promote compliance with the AAQ Directives.

According to the interviews carried out within the framework of this project44, this is more due to

the lack of knowledge and awareness of the available funding possibilities among those responsi-

ble for air quality in the relevant abovementioned bodies.

41 Available at: MITECO, https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/evaluacion-datos/datos/historico_calidad_aire.aspx 42 EFE, Teresa Ribera anuncia la creación de un Índice Nacional de Calidad del Aire, 15 October 2018. Avai-lable at: https://www.efe.com/efe/espana/sociedad/teresa-ribera-anuncia-la-creacion-de-un-indice-nacio-

nal-calidad-del-aire/10004-3780639 43 Ayuntamiento de Madrid, Protocolo de actuación para episodios de contaminación por Dióxido de nitró-

geno en la ciudad de Madrid, 2018, Available at: https://transparencia.madrid.es/UnidadesDescentraliza-

das/Sostenibilidad/CalidadAire/Ficheros/ProtocoloNO2AprobFinal_201809.pdf 44 Ministry of Environment on 24 September

http://www.mambiente.madrid.es/opencms/opencms/calaire

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/evaluacion-datos/datos/historico_calidad_aire.aspx

https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/evaluacion-datos/datos/historico_calidad_aire.aspx

https://www.efe.com/efe/espana/sociedad/teresa-ribera-anuncia-la-creacion-de-un-indice-nacional-calidad-del-aire/10004-3780639












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The promotion of air quality is indirectly referenced within some of the objectives included in the

Operational Programmes (OPs). For instance, the National OP of the European Regional Devel-

opment Fund (ERDF)45 includes as a priority and specific objective, ‘actions to improve the envi-

ronment in cities’, which includes the improvement of air quality among the results expected to

be obtained. One of the indicators to measure the results achieved will be the number of days per

year when limits on air quality are exceeded. Among the examples of actions to be taken, it

includes the design and implementation of plans to improve urban air quality, provided that they

imply investments, such as the implementation of measuring stations for air quality indicators in

cities. The total budget foreseen is EUR 24,880,555.

The OP for Madrid46 includes some priorities and specific objectives from which measures to

improve air quality could be derived. This is the case for two investment priorities: 4c, support

for energy efficiency, smart energy management and the use of renewable energy in public infra-

structures, including public buildings, and in housing; and 4e, promotion of carbon reduction

strategies for all types of territories, especially urban areas, including the promotion of sustainable

multimodal urban mobility and adaptation measures with mitigation effects. These investment

priorities contain the following specific objectives: to improve energy efficiency and reduce CO2

emissions in buildings and public infrastructures and services; to increase the use of renewable

energies for the production of electricity and thermal uses in buildings and public infrastructures,

in particular favouring small-scale generation in points close to consumption; and the promotion

of sustainable urban mobility through a clean urban transport, collective transport, urban-rural

connection, road network improvements, cycling, pedestrian transport, electric mobility and the

development of clean energy supply systems.

The OPs of Andalusia (EUR 5,304,756), Ceuta (EUR 240,000) and Extremadura (EUR

4,020,000) also include the possibility to develop projects on air quality.

In practice, the only project identified in the national and Madrid ERDP OPs directly related to

air quality policy is the update and improvement of the air quality monitoring system of the In-

stituto Universitario de Medio Ambiente (IUMA) of the University of A Coruña for an amount of

EUR 147,525.47

45 Ministerio de Hacienda y Administraciones Públicas, PROGRAMA OPERATIVO EN EL MARCO DEL OBJETIVO

DE INVERSIÓN EN CRECIMIENTO Y EMPLEO, Available at: http://www.idae.es/uploads/documentos/docu-mentos_PO_CrecimientoSostenible_FEDER_2014-2020_cb50c638.pdf 46 Ministerio de Hacienda, Programas Operativos Plurirregionales (web page). Available at:

http://www.dgfc.sepg.hacienda.gob.es/sitios/dgfc/es-

ES/ipr/fcp1420/p/Prog_Op_Plurirregionales/Paginas/inicio.aspx 47 Ministerio de Hacienda, Lista de Operaciones FEDER 2014- 2020 (web page). Available at: http://www.dgfc.sepg.hacienda.gob.es/sitios/dgfc/es-ES/loFEDER1420/Paginas/inicio.aspx

Ministerio%20de%20Hacienda%20y%20Administraciones%20Públicas,%20PROGRAMA%20OPERATIVO%20EN%20EL%20MARCO%20DEL%20OBJETIVO%20DE%20INVERSIÓN%20EN%20CRECIMIENTO%20Y%20EMPLEO,%20Available%20at:%20http:/www.idae.es/uploads/documentos/documentos_PO_CrecimientoSostenible_FEDER_2014-2020_cb50c638.pdf





http://www.dgfc.sepg.hacienda.gob.es/sitios/dgfc/es-ES/ipr/fcp1420/p/Prog_Op_Plurirregionales/Paginas/inicio.aspx

http://www.dgfc.sepg.hacienda.gob.es/sitios/dgfc/es-ES/ipr/fcp1420/p/Prog_Op_Plurirregionales/Paginas/inicio.aspx

http://www.dgfc.sepg.hacienda.gob.es/sitios/dgfc/es-ES/loFEDER1420/Paginas/inicio.aspx



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3 FINDINGS

Chapter 3 presents detailed findings on the experiences and lessons learned in the implementation

of the AAQ Directives in Spain, and in the municipality of Madrid in particular. More specifically,

the chapter focuses on the challenges and successes encountered in the implementation of the

Directives, and explores the relevance of the AAQ Directives and their air quality standards. Fi-

nally, the chapter identifies the factors underlying compliance with and effectiveness of the AAQ

Directives and provides an overview of the costs and benefits associated with their implementa-

tion.

The findings presented in this chapter rely primarily on input from the stakeholders interviewed

in the context of the case study. These were supplemented by additional desk research, as ap-

propriate. An overview of the interviews carried out is provided in Appendix B.

3.1 Relevance of the Ambient Air Quality Directives

Firstly, the case study explored the extent to which the AAQ Directives, and the air quality stand-

ards set therein, correspond to citizens' needs.

The 1st Environmental Implementation Review adopted by the Commission in April 2017 indicated

that air quality in Spain continues to give cause for concern48. For example, for 2013, the EEA

estimated that about 23,940 premature deaths in Spain were attributable to fine particulate

matter concentrations, 1,760 to O3 concentrations, and over 4,280 to NO2 concentrations49. The

persistent breaches of air quality requirements (for PM10 and NO2), which have severe negative

effects on health and the environment, are being followed up by the European Commission

through infringement procedures against Spain (among other Member States). The aim is to put

adequate measures in place to bring all zones into compliance. The main suggestions in the report

include:

• Reduce NH3 emissions to comply with currently applicable national emissions ceilings, for

example by introducing or expanding the use of low emission agricultural techniques.

• Reduce NOx emissions to comply with currently applicable national emissions ceilings and/or

to reduce NO2 (and O3 concentrations), inter alia, by reducing transport-related emissions -

in particular in urban areas.

• To reduce PM10 emissions and concentrations, including by reducing emissions relating to

energy and heat generation using solid fuels, transport and agriculture.

The targeted consultation carried out as part of the case study showed that while the objectives

of the AAQ Directives are considered relevant in relation to citizens’ needs, stakeholders inter-

viewed find that the scientific evidence behind the WHO recommendations to ensure human health

requires the limit levels of the AAQ Directives to be increased to similarly ambitious levels. This

perspective was shared by all stakeholders in both the public sector and environmental and health

NGOs50. For an overview of the interviews carried out, see Appendix A.

The stakeholders from the public authorities interviewed within the framework of this project,

stressed that scientific information on the impact of other pollutants, such as O3 or B(a)P, on the

48 EU Environmental Implementation Review, Country Report: Spain, SWD (2017) 42 final, available at:

http://ec.europa.eu/environment/eir/pdf/report_es_en.pdf 49 EEA, Air quality in Europe — 2017 report, 2017. Available at: https://www.eea.europa.eu/publica-

tions/air-quality-in-europe-2017 50 Targeted questionnaire from the Spanish Ministry and Spanish environmental NGOs.

http://ec.europa.eu/environment/eir/pdf/report_es_en.pdf







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March 2019 28

environment and human health point to the need to review the Directives’ target levels and de-

velop emissions level targets. They also recognised the scientific evidence with respect to addi-

tional pollutants that have important impacts on the environment and human health but which

are not reflected in the current AAQ Directives, such as tare black carbon and ultrafine particu-

lates51. The targeted stakeholder consultation also highlighted greater citizens’ awareness of the

impact of poor air quality on public health, and the consequent demand for the authorities to take

action to ensure appropriate levels of air quality, including more stringent limit values.

The NGOs stated their belief that, without the AAQ Directives, no measures on air quality would

have been taken in Spain. The Directives are necessary but currently insufficient to ensure the

protection of air quality and human health. Some pointed to causes such as: the differentiation

between pollutants with target values and limit values when their toxicity is similar; the estab-

lishment of more relaxed legal standards than those recommended by the WHO and, therefore,

below a sufficient level to protect human health; insufficiency of fixed measures to assess air

quality (for instance, stations are not well located); lack of reference methods for the modelling

of pollutant concentrations; insufficiency of air quality plans in order to meet legal standards (late

development, lack of proper monitoring and lack of coercive measures for enforcement); lack of

efficient short-term plans; inefficiency in public information; and lack of coherence of sectoral

policies (agriculture, energy, etc.).

One health NGO stated that some pollutants should be added, for instance, pesticides (glyphosate,

phosphorates, piretines and organoclorades) or mercury. They also highlighted the need to start

measuring air quality inside domestic homes. Waste management should also be improved in

order to control pollutant emissions.

In addition, the findings of the 2017 Special Eurobarometer52 confirmed that air quality is a con-

cern for Spanish citizens, with 68% of respondents stating that air quality in the country has

deteriorated in the last 10 years. This represents the second highest rate in the EU (behind Cypriot

respondents). 23% considered air quality to have remained the same, while 4% felt that it has

improved.

According to the Spanish Organisation of Consumers and Users (OCU), 81% of the Spaniards

consider that a measure banning or reducing the use of the most polluting cars should be adopted

and 77% thinks that cars should be banned on days of pollution exceedance; 70% of drivers

would reduce the use of the car if the public transport would improve and 60% of the Spanish

citizens would support higher taxes for more polluting cars53.


The present section highlights the key implementation successes of AAQDs in Spain generally,

and specifically in Madrid. They were identified through desk research and stakeholder interviews.

The section also provides an assessment of the extent to which these challenges can be linked to

the design of the AAQ Directives or, indeed, to their specific requirements.

51 Information from the interview with the Spanish Ministry on 24/09/2018. 52 European Commission, Special Eurobarometer 468: Attitudes of European citizens towards the environ-

ment, November 2017. Available at: http://ec.europa.eu/commfrontoffice/publicopinion/index.cfm/Result-

Doc/download/DocumentKy/81259 53 europa press, El 81% de los españoles cree que se debería prohibir la circulación de vehículos muy conta-

minantes, 23 May 2018. Available at: https://www.europapress.es/motor/coches-00640/noticia-81-es-panoles-cree-deberia-prohibir-circulacion-vehiculos-muy-contaminantes-20180523114000.html





https://www.europapress.es/motor/coches-00640/noticia-81-espanoles-cree-deberia-prohibir-circulacion-vehiculos-muy-contaminantes-20180523114000.html






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This section focuses on measures adopted in Spain, and sometimes specifically by the Madrid

municipality, showing some implementation success.

3.2.1 Strategic planning as a reaction to enforcement of the AAQ Directives at EU level

The enforcement of the AAQ Directives by the European Commission has been instrumental in

ensuring that Spain takes action on air quality and, in particular, Madrid’s adoption of measures

to tackle air pollution. While slow, it has been a key element in improving ambient air quality.

At present, there are infringement procedures open against Spain for breaches of NO2 and PM10

limit values in several cities, e.g. Barcelona and Madrid for NO254. PM pollution is also an issue in

Catalonia, Asturias and Andalusia. However, the problem has been recognised and efforts are

underway to address it, through, for example, the national plan for air quality (Plan AIRE II) and

the local plan for Madrid (Plan A).

Plan AIRE II

At national level, the government approved the so-called Plan Aire II for the period 2017-2019 as

a continuation of the first Plan 2013-2016. The objectives of Plan II are:

• Ensure compliance with legislation on air quality in all areas: national, European and inter-

national.

• Implement general measures that help to reduce the levels of emissions into the atmosphere

of the most relevant pollutants with the greatest impact on health and ecosystems, especially

in the areas most affected by pollution.

• Promote the information available on air quality and thus promote awareness among citizens.

• Implement measures to ensure compliance with the emissions reduction commitments es-

tablished by Directive (EU) 2016/2284.

• Reinforce the actions for the control of registered tropospheric O3 values, given the general-

ised exceedances of the objective value for the protection of health in a large part of the

country.

Plan A

Madrid has adopted Plan A (the air quality and climate change plan for the city of Madrid) that

includes short-term and long-term measures (as required under Articles 23 and 24 of Directive

2008/50/EC) to reduce emissions and comply with the AAQ Directives and climate change objec-

tives. Madrid submits regular reports to the Commission on its progress on the implementation

of the Directives, including an annual report and monthly reports where progress on Plan A is

described.

Plan A’s specific objectives are to:

• Comply with European and national legislation on air quality.

54 European Commission, Air quality: Commission takes action to protect citizens from air pollution (press release), 27 May 2018. Available at: http://europa.eu/rapid/press-release_IP-18-3450_en.htm





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• Achieve levels of air quality for particles in suspension that are in line with WHO guide values.

• Achieve, by 2030, a reduction of more than 40% of the total GHG emissions of the munici-

pality of Madrid compared to 1990, contributing to the objectives of the Paris Agreement and

the EU Climate Agenda and online as the new Alliance of Mayors for Climate and Energy.

• Fulfil the commitment to reduce by 50% the GHG emissions caused by urban mobility in

2030, compared to 2012.

• Develop a strategy of adaptation to the effects of climate change, reducing urban vulnerabil-

ity to the risks associated with global warming.

In order to reach these objectives, Plan A promotes a series of measures organised in four blocks:

sustainable mobility; urban regeneration; climate change adaptation; and citizen awareness. En-

forcement measures are applied, including police controls (at the level of individual cars) where

limitations on the use of cars or speed limits are set. Currently, the controls are manual but will

be automated through the use of a reader mounted on the windshield of the car.

While Spain has a National Air Quality Plan, only a third of the measures have been implemented

and there are no performance indicators for measuring policy effectiveness55.

3.2.2 Central Area Zero Emissions

There are 30 measures included in Plan A, one of which is the so-called ‘central area zero emis-

sions’ (Área Central Cero Emisiones), aimed at reducing the negative effects of road transport in

the centre of the city and incentivising collective transport and non-engine related vehicles. Pre-

viously, the city had the so-called Residential Priority Areas model, which restricted access to

vehicles belonging to non-residents. However, these areas were conceived as isolated areas

whereas the new model intends to give continuity to the restricted areas by establishing a larger

area to optimise the positive effects produced in those areas. The delimitation of the area was

carried out taking into account several elements, such as the road network, promoting sustainable

modes (more cycling routes, increase pedestrian areas, modal interchange, taxi stops, optimisa-

tion of urban distribution of goods), improving the parking slot system (dynamic information sys-

tem for parking, etc.), and establishing access criteria. Cameras are used to enforce the system

on the basis of car registration plates.

During the development of Plan A, the municipality of Madrid carried out a process of consultation

and participation.

According to one NGO interviewed, this measure generated a lot of controversy. While the Madrid

Federation of Consumers and Users supports the plan, which it considers absolutely critical to

reduce pollution in Madrid56 other sectors announced their intention to file complaints in court57.

The municipality postponed its implementation in order to gain more support and undertook a PR

and information campaign throughout Madrid. At the Time of writing, the measure was being

55 Joint report on air quality by Court of Auditors, Eurosai, 2019, p. 40 and 41 at: https://www.euro-sai.org/en/databases/audits/Joint-Report-Air-Quality/ 56 Confederación de Consumidores y Usuarios de Madrid, CECUMadrid considera absolutamente necesario el Plan Madrid Central contra la contaminación (press release), 27 November 2018, available at; http://ce-

cumadrid.org/images/13_-_Madrid_Central.pdf 57 The Madrid autonomous community and the Conservative Party filed a case before the High Court of Jus-

tice of Madrid (Tribunal Superior de Justicia de Madrid) against the measure, based on the following argu-

ments: interference with the competence of the Community in the area of transport and environment; the

lack of prior consultation involving the Madrid autonomous community (such as on the development of the

economic and regulatory impact assessments); and the lack of public information and public hearing for this specific measure.

https://www.eurosai.org/en/databases/audits/Joint-Report-Air-Quality/




http://cecumadrid.org/images/13_-_Madrid_Central.pdf






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implemented. Effectiveness of the measure has been analysed through the publication of the

impact assessment: the data on traffic reduction and emissions in December 2017 (when the

measure was provisionally implemented and tested) was the lowest since 2000. Records in Madrid

fell, compared to values recorded in 2010 and 201558. However, the regional authority claims that

Madrid Central will not be effective because it does not involve the most polluted areas of the city,

nor does it include measures to allow effective application of the project (for instance, priority

access of inter-city buses to the main access points of the city or the establishment of dissuasive

car parks)59.

With respect to the implementation of the Plan, the participatory approach sets the basis for the

effectiveness of the measure. There is a Commission for Air Quality and a Technical Platform60,

which are consultation bodies whose aims are:

to participate in monitoring the implementation

of the Plan and the accomplishment of its ob-

jectives; to establish periodic coordination

mechanisms; and to collaborate on the revi-

sions foreseen in Plan A. The Commission and

the Platform are composed of representatives

competent in different areas (environment, air

quality, trade, tax, etc.) from the municipality,

the region of Madrid, the state and environ-

mental and neighbourhood associations. Rep-

resentatives from interested groups are also

expected to participate in the meetings on the

implementation of Plan A, such as university

experts, SMEs, citizens’ associations, etc.

In order to monitor the implementation of the

Plan, different impact indicators have been de-

veloped, associated with specific objectives of the Plan, as well as process indicators per measure,

for each of the four blocks into which the Plan is divided.

Revisions are planned in 2020 and 2025, based on annual reports, input from the participative

process, international agreements, new scientific and technological studies and the incorporation

of the new legislative framework.

3.2.3 Ensuring public awareness

Most of the stakeholders interviewed confirmed that the AAQ Directives promoted the use of

information and public awareness measures on air quality in Spain in general and Madrid in par-

ticular.

During the development of Plan A, the municipality of Madrid carried out a consultation process

promoting participation in the decision-making process on the measures constituting the plan.

58 Evaluación del efecto del plan de calidad del aire y cambio climático de la ciudad de Madrid, September

2017 59 For example: eldiario.es, La Comunidad cumple su amenaza de llevar Madrid Central a los tribunales y

argumenta que afecta a sus competencias, 27 November 2018. Available at: https://www.eldiario.es/ma-drid/Comunidad-Madrid-Central-tramitacion-competencias_0_838166707.html 60 Ayuntamiento de Madrid, Decreto de 6 de julio de 2017 de la Alcaldesa por el que se crea la Comisión de

Calidad del Aire de la Ciudad de Madrid y se regula su composición y funcionamiento. Available at:

https://sede.madrid.es/portal/site/tramites/menuitem.b4c91589e7f6a5d829da39e5a8a409a0/?vgnex-

toid=a120bfe0d2c1d510VgnVCM1000001d4a900aRCRD&vgnextchan-nel=257865dd72ede410VgnVCM1000000b205a0aRCRD&vgnextfmt=default

https://www.eldiario.es/madrid/Comunidad-Madrid-Central-tramitacion-competencias_0_838166707.html




https://sede.madrid.es/portal/site/tramites/menuitem.b4c91589e7f6a5d829da39e5a8a409a0/?vgnextoid=a120bfe0d2c1d510VgnVCM1000001d4a900aRCRD&vgnextchannel=257865dd72ede410VgnVCM1000000b205a0aRCRD&vgnextfmt=default








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That process was divided into different phases. In Phase 1, a technical team from city hall pre-

pared a draft containing the general lines of the plan. In Phase 2, the strategic lines of the Plan

were presented at a conference attended by political parties, media, the autonomous community

of Madrid, the Ministry of Environment, environmental NGOs, neighbourhood associations and

others.

In Phase 3, the municipality opened different channels through which citizens could express their

opinions and establish a formal dialogue (called Diálogo con los barrios): a questionnaire hosted

on a website61, a campaign on social networks and digital media, and campaigns in the different

District Municipal Boards (Juntas Municipales de Distrito). In this phase, the technical team of the

municipality also planned a three-month series of meetings with the main social and economic

agents in order to explain the plan and obtain input on possible improvements. In Phase 4, after

all input was received, a document was developed and proposed publicly before being submitted

for initial approval to the Governing Board of the city. Phase 5 was a process of public information

in order to collect further input. The final text was then approved and published62.

The public consultation on the measures of Plan A generated public awareness. In particular, the

PR campaign on measure 1 of Plan A is another example of activities aiming to raise public aware-

ness of the issue and the need to adopt specific measures.

In addition, the Protocol for alert thresholds exceedance in place both in the municipality and the

autonomous community requires the authorities to broadly disclose information to the public on

the pollutants whose levels exceed those recommended63.

At national level, one of the 52 measures intended to be applied within Plan AIRE II is to provide

information to the general public on air quality, which includes the development of clear indicators

of air quality and easy access to them. Plan AIRE II also includes the development of a framework

action protocol for episodes of high pollution, with the aim of offering a homogenous framework

in each of the territories in which there is a need for one.

However, one of the main challenges recognised by cities like Madrid for the implementation of

air quality measures include how to effectively communicate air quality issues to the public64.


Several implementation challenges were identified in the course of the case study:

3.3.1 Non-compliance with limit values

Spain does not comply with the limit values set by the AAQ Directives in relation to PM10 and NO2

in some air quality zones. The infringement procedure opened against Spain on breaches of the

NO2 limit value includes the cities of Barcelona and Madrid. The breaches of implementation of

the AAQ Directives by Spain are longstanding. As early as 2002 the Commission had announced

that a case against Spain was to be referred to the Court of Justice of the European Union (CJEU)

for failure to transpose into national law the new air quality limits on SO2, NO2, particulates and

61 Decide Madrid, Borrador de Plan de Calidad de Aire y Cambio Climático (web page), available at: https://decide.madrid.es/proceso/plan-calidad-aire 62 Ayuntamiento de Madrid, Plan de Calidad del Aire y Cambio Climático de la Ciudad de Madrid, 2017. Avail-able at: https://www.madrid.es/UnidadesDescentralizadas/UDCMedios/noticias/2017/03Marzo/13Lunes/No-

tasdePrensa/Plan%20Calidad%20Aire/ficheros/PlanACalidadAire2017.pdf 63 http://www.mambiente.munimadrid.es/opencms/opencms/calaire/ServCiudadanos/ProtocolosInfo.html

and http://gestiona.madrid.org/azul_internet/html/web/AlertasActivasAccion.icm?ESTADO_MENU=10 64 EEA, Europe's urban air quality — re-assessing implementation challenges in cities, EEA Report No 24/2018, 2019. Available at: https://www.eea.europa.eu/publications/europes-urban-air-quality

https://decide.madrid.es/proceso/plan-calidad-aire





http://www.mambiente.munimadrid.es/opencms/opencms/calaire/ServCiudadanos/ProtocolosInfo.html

http://gestiona.madrid.org/azul_internet/html/web/AlertasActivasAccion.icm?ESTADO_MENU=10





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Pb. In 1999, the Framework Air Quality Directive 1999/30/EC65 set limit values for several air

pollutants which needed to be transposed into national law by 19 July 200166.

In relation to Directive 2008/50/EC, the Commission initiated infringement procedures for lack of

compliance with limit values for NO2 and PM10 that became binding in 2010 and 2005 respectively.

Spain, according to some stakeholders, did not take any measures to ensure that the NO2 limit

values would be respected by 201067.

The latest national report on air quality with data from 201768 (published in September 2018)

evidences that of all pollutants, three (NO2, PM10 and O3) have exceeded established legal limit

or target values in all years during the period 2005-2016, and in 2017 in some air quality zones.

According to the 2017 Evaluation Report on Air Quality in Spain, the 2017 results are worse than

those of 2016, as the number of air quality zones exceeding the legislated values for NO2 and

PM10 increased69. For NO2, the number of air quality zones that exceeded the legislated values

increased. More specifically, in 2017, the hourly limit value was exceeded in the same area of

Madrid as it was in the previous year. In addition for the annual limit value, exceedances occurred

in large cities such as Madrid and surroundings, Barcelona and surroundings, Granada and its

metropolitan area, and Bilbao and its surroundings, largely due to traffic emissions70.

Infringement procedures started in 2010 (e.g. for failing to comply with PM10 limit values). In

2013, a new infringement procedure was opened for exceeding PM10 limit values in 3 regions (for

daily limit) and in one region (for an annual mean), with the reasoned opinion sent in 2014 to-

gether with an additional letter of formal notice. The National Plan for 2013-2016 was adopted in

response to these breaches. Another infringement procedure was initiated with a letter of formal

notice in June 2015 for failure to comply with the NO2 limit values. The reasoned opinion followed

in February 201771.

In January 2018, Commissioner Vella announced that Spain would be subject to legal action be-

fore the CJEU if adequate, effective and timely measures were not taken72. The case was put on

hold given the specific measures adopted73 or proposed. However, the need to implement the

Madrid Protocol for pollution peaks on a regular basis (particularly to establish the procedure for

action in case of instances of NO2 pollution) when it is meant to be a short-term plan to be

implemented in exceptional circumstances, seems to evidence the existence of a structural prob-

lem.

65 Directive 1999/30/EC of 22 April 1999 relating to limit values for sulfur dioxide, nitrogen dioxide and ox-

ides of nitrogen, particulate matter and lead in ambient air. Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A31999L0030 66 European Commission, Air Quality: Commission pursues infringement proceedings against six Member States (press release), http://europa.eu/rapid/press-release_IP-02-1013_en.htm 67 Interview with NGOs on 21 September 2018 68 Ministerio para la Transición Ecológica, Evaluación de la calidad del aire en España: Año 2017, Available

at: https://www.miteco.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/in-

formeevaluacioncalidadaireespana2017_tcm30-481655.pdf 69 Ministerio para la Transición Ecológica, La calidad del aire en España en 2017 baja levemente con res-pecto al año anterior (webpage). Available at: https://www.miteco.gob.es/es/prensa/ultimas-noticias/La-

calidad-del-aire-en-Espa%C3%B1a-en-2017-baja-levemente-con-respecto-al-a%C3%B1o-anterior/tcm:30-481677 70 Idem. 71 European Commission, Infringement decisions, web page, at: http://ec.europa.eu/atwork/applying-eu-

law/infringements-proceedings/infringement_decisions/?lang_code=en; and https://legal.cleanair-eu-

rope.org/legal/eu/infringement-procedure/ 72 http://europa.eu/rapid/press-release_IP-18-348_en.htm 73 http://europa.eu/rapid/press-release_MEMO-18-3446_en.htm and http://europa.eu/rapid/press-re-lease_IP-18-3450_en.htm and http://europa.eu/rapid/press-release_MEMO-18-6247_en.htm

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A31999L0030















https://legal.cleanair-europe.org/legal/eu/infringement-procedure/















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3.3.2 Lack of policy consistency

Spain has one of the largest diesel fleets in Europe, having promoted these types of cars for years

with fiscal and consumer benefits. Similarly to other countries, Spain has provided incentives to

consumers for buying cars, including diesel cars on a continued basis, e.g. the Plan RENOVE (later

re-named PIVE)74.

The Central Government is working on a new plan which imposes an increased tax on diesel, with

likely impacts on emissions reduction. The increase in the amount of tax collected from the addi-

tional diesel tax is expected to be about EUR 670 million, 30% of which will be dedicated to

promoting cleaner mobility75.

The Government introduced its Plan MOVEA (targeting companies buying electric cars) and Plan

MOVALT (incentivising alternative energy vehicles (i.e. electric, natural gas), both of which were

implemented in 2017/2018. The new plan MOVES on sustainable mobility aims at incentivising

the purchase of alternative cars and infrastructure for charging electric cars and has a total budget

of 45 million. The legal basis of this programme is established under Royal Decree 72/2019 of 17

February implementing Directive 2014/94/EU under the clean Mobility package76.

According to the survey by the Organisation of Consumers and Users (OCU) 96% of the Spanish

request measures to improve the public transport in general with specific reinforcement on days

of high pollution and 81% of the Spanish support measures forbidding or reducing the use of

polluting cars. Furthermore, 60% supports higher taxes for polluting cars. The OCU therefore

advocates for higher taxes for higher polluters, irrespective of the type of fuel77.

Some stakeholders argue that promoting energy alternative cars (including electric versus diesel)

implies promoting the use of cars in any case which is not consistent with a traffic reduction

policy78.

The Madrid municipality has referred to the need for stricter standards for car emissions, and

considered that while most cities have traffic problems and the car industry has the potential to

develop cleaner technologies more quickly, the EU has not adopted the necessary legislation. The

Euro 6 Regulation on pollutant emissions from passenger cars is expected to improve the situation

but the Commission Regulation (EU) 2016/646 set the real driving emissions test limits on the

basis of the limits defined for the Euro 6 standard to which it applied correction coefficients in

order to take account of statistical and technical uncertainties of the laboratory tests79. Alongside

the cities of Paris and Brussels, Madrid reacted against these measures to the CJEU because it

considered that the Commission did not have the competence to adopt the relevant correction

factors which rendered the Euro 6 emission limits less strict. In a first instance judgment, the

General Court of the EU ruled that the provision prescribing the coefficient factor is invalid as its

adoption is an infringement of Regulation No 71/2007 establishing emission limits for NO2. Appeal

proceedings against this judgment are currently pending 80.

74 http://www.planrenove.info/ 75 http://www.expansion.com/empresas/motor/2018/10/15/5bc48a8f468aebe1498b45cb.html 76 https://www.miteco.gob.es/es/prensa/ultimas-noticias/el-gobierno-aprueba-la-distribuci%C3%B3n-terri-torial-del-programa-moves-para-favorecer-la-movilidad-sostenible/tcm:30-487788 and

https://www.boe.es/boe/dias/2019/02/16/pdfs/BOE-A-2019-2148.pdf 77 https://www.ocu.org/organizacion/prensa/notas-de-prensa/2018/movilidad230518 78 Interview E-NGO 21 September 2018 79 Commission Regulation (EU) 2016/646 amending Regulation (EC) No 692/2008 as regards emissions

from light passenger and commercial vehicles (Euro 6) 80 See pending cases (status as of 29 August 2019), Germany - Ville de Paris and Others v Commission (C-177/19 P), Hungary - Ville de Paris and Others v Commission (C-178/19 P) and Commission v Ville de Paris

http://www.planrenove.info/

http://www.expansion.com/empresas/motor/2018/10/15/5bc48a8f468aebe1498b45cb.html

https://www.miteco.gob.es/es/prensa/ultimas-noticias/el-gobierno-aprueba-la-distribuci%C3%B3n-territorial-del-programa-moves-para-favorecer-la-movilidad-sostenible/tcm:30-487788




https://www.boe.es/boe/dias/2019/02/16/pdfs/BOE-A-2019-2148.pdf

https://www.ocu.org/organizacion/prensa/notas-de-prensa/2018/movilidad230518



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3.3.3 Coordination between administrations

The main problem underlying Madrid’s lack of compliance with the AAQ Directives’ NO2 limit values

is the traffic. In Spain, the use of cars has been greatly promoted for many reasons: lack of

awareness; low fuel prices; and strategic interest of the sector in Spain, as a car manufacturing

country with a strong lobbying sector81. Some measures to reduce traffic in Madrid need coordi-

nated action between the municipality and the regional government but they are not taken82. Cars

driving into Madrid from areas outside the municipality create 40% of Madrid’s traffic, pointing to

the need for regional measures. Access to the city is through state-owned roads which do not

always have priority bus lanes to avoid traffic jams. The number of buses linking the areas outside

Madrid and the municipality do not operate with sufficient regularity to promote the use of public

transport. Some of the entry roads have been improved and have even became paying highways

but the problem of access to the city remains. Traffic jams affect the capacity to predict the time

that it takes to arrive to Madrid by public transport, making it an unattractive alternative to pri-

vately owned vehicles83.

As noted earlier, there is a coordination issue between the Madrid local government (municipality)

and the regional government of Madrid (province) due to political and technical considerations.

The municipality of Madrid complains that the region of Madrid does not support its compliance

efforts.

The Clean Air Dialogue with Spain84concluded that improving coordination between the various

levels and types of public administrations competent is important to ensure the implementation

of the AAQ Directives in Madrid. Furthermore, the EEA report acknowledges that one of the main

challenges faced by cities on their implementation of the air quality measures are related to the

lack of coherent governance across the different administrative levels85 .

The national Ministry for the Environment is responsible for coordinating the autonomous com-

munities and the municipalities. In 2011 it established a coordination group to share lessons on

the implementation of air quality measures. The Ministry organises regular meetings and thematic

workshops, such as a workshop with network managers or on low cost microsensors. For example,

the establishment of a national air quality index - in line with the European index - is currently

being debated.

3.3.4 Ineffective and insufficient measures

Spain is taking measures to respond to the infringement procedures, as follows:

• Spain has developed a categorisation of cars based on environmental criteria, which is the

basis for defining efficient cars and applying traffic reduction measures or car incentive

measures. This categorisation has its origin in the National Plan for Air Quality and Protection

of the Atmosphere 2013-2016 (Air Plan), which states that the main source of PM10 and NO2

is traffic and proposes the classification of vehicles according to their levels of emissions and

environmental impacts86. The purpose of this classification of cars is to positively discriminate

and Others (C-179/19 P). Cases T-339/16 Ville de Paris v Commission, T-352/16 Ville de Bruxelles v Com-

mission, T391/16 Ville de Madrid v Commission; https://curia.europa.eu/jcms/upload/docs/applica-

tion/pdf/2018-12/cp180198en.pdf. 81 Interview ministry representative 82 Interview Madrid municipality 83 Interview stakeholders 84 European Commission and Ministerio para la Transición Ecológica, Conclusions of the Clean Air Dialogue


http://ec.europa.eu/environment/air/pdf/shared conclusions from clean air dialogue w Spain.pdf 85 Europe's urban air quality — re-assessing implementation challenges in cities, EEA Report No 24/2018,

2019. 86 page 12 of the Air Plan.

https://curia.europa.eu/jcms/upload/docs/application/pdf/2018-12/cp180198en.pdf








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in favour of those vehicles that are most respectful of the environment and to be an effective

instrument in the service of municipal policies, i.e. restricting traffic during high pollution

episodes, and promoting new technologies through benefits. The system is implemented

through car cards or badges whose display in Madrid remains voluntary up to 24 April 2019

when it will become mandatory.

• While car badges/cards are designated according to their environmental impact, for some

stakeholders the categorisation is not strict enough to ensure an appropriate impact on air

quality87. There are four environmental distinctions defined on the basis of the cars’ environ-

mental impacts, covering 50% of the most efficient fleet. The categories are: Zero emissions

(blue colour – covers electric and hybrids cars); Eco (blue and green colour, includes hybrids

and gas); C (green colour, includes petrol and diesel cars) B (yellow colour, covers gasoil

and diesel cars). According to some stakeholders88, the green label provides a confusing

perception of an ‘environmentally friendly’ car when, in reality, it includes new diesel cars.

• While the implementation of the Madrid municipality’s Protocol for action in case of instances

of pollution by NO2 (pollution peaks) is necessary, the impact of measures during adverse

weather conditions seems to be very low, according to the NGOs interviewed89. They consider

these measures to be effective only if they are applied preventatively.

The Protocol requires information to be disseminated when instances of pollution happen. How-

ever, the effectiveness of the information measures is not clear as the 2017 Eurobarometer points

out that, of all Europeans, the Spanish show the highest numbers reporting being poorly informed

about air quality. They are above average in considering air quality a major problem.

The Clean Air Dialogue with Spain90 held in October 2018, concluded that additional measures in

relation to PM10 and PM2.5 should be considered, such as establishing requirements on the quality

of solid fuels used in households; further incentives to accelerate scrapping of sub-standard solid

fuel stoves and boilers and promoting systematic transfer to cleaner heating sources; continuous

awareness-raising among the public of the health impact of residential solid fuel combustion and

operation techniques in private households; and activities on energy efficiency. A ban on open field

burning of agricultural waste was also raised, together with the promotion of policies on energy

renovation of buildings.

Furthermore, the 2016 evaluation of the National Plan showed that it had not achieved its objec-

tive91.

3.4 Factors underlying compliance with and effectiveness of the Ambient

Air Quality Directives

The following section provides an overview of the factors promoting and hindering compliance

with and effectiveness of the AAQ Directives in Spain in general, and Madrid in particular. The

87 Interview of Environmental NGO 21 September 2018 88 Interview of Environmental NGO 21 September 2018 89 Interview 21 September 2018. 90 European Commission and Ministerio para la Transición Ecológica, Conclusions of the Clean Air Dialogue


http://ec.europa.eu/environment/air/pdf/shared conclusions from clean air dialogue w Spain.pdf 91 Joint report on air quality by Court of Auditors, Eurosai, 2019, p. 40 and 41 at: https://www.euro-sai.org/en/databases/audits/Joint-Report-Air-Quality/









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factors were identified through stakeholder consultations conducted in the context of this case

study. The views expressed correlated with the information gathered through desk research.


The case study shows that the main factors promoting compliance with the AAQ Directives in

Spain include: 1) an understanding that there is a problem; 2) harmonised methods and regular

data on the levels of pollution and sources; 3) Coordination; and 4) effective enforcement at EU

level in cases of non-compliance.

Understanding that there is a problem

The Competent authorities in Spain recognise the air quality issues in relation to certain pollutants

such as NO2, O3, NOX and PM10 and are willing to deal with it. The findings of the case study

indicate that the Madrid authorities understand that effective solutions need to be implemented,

even if they are controversial. As mentioned above, the measures of Plan A were preceded by

broad public consultation which resulted in a public recognition of the importance of air pollution

and the need to act. Furthermore, the constructive answer to EU level enforcement actions lies

on the understanding that there is a need for urgent and effective measures. Madrid reports

regularly to the Commission on its progress in implementing the Directives, through an annual

report and monthly reports.

However, more could be done to educate citizens on the aims of the Directive and the measures

taken to ensure air quality. Some measures are still unpopular and difficult to enact or implement.

There is little pressure in Spain from NGOs or citizens in general requesting politicians to take

action and, at the same time, little acceptance or support for the measures proposed or imple-

mented.

Harmonised monitoring and measuring methods and regular data on the levels of pollution and

on pollution sources

The authorities interviewed consider the Directives to have promoted a harmonised method for

collecting data and measuring limit values and a process for monitoring some key pollution ele-

ments in all EU Member States. This has triggered a wealth of precise and up-to-date information

on specific pollutants per zone, or per agglomeration, which allows the necessary measures to be

adopted to ensure environmental and human health protection. As the information is harmonised,

it can be compared both between regions within Spain but also between countries or villages with

similar circumstances in different Member States. Lessons can be learned from the effectiveness

of certain actions taken in different countries, such as closing access to traffic in central areas in

large cities.

However, no systematic data on the impacts on heath from air pollution is collected, other than

premature deaths, nor are any data systematically collected on the health incidence of the

measures92.

Coordination

While the competence for air quality rests at regional and local level, the Spanish Ministry has a

coordination role that facilitates the effective implementation of the AAQ Directives. The local

authorities interviewed within the framework of this project recognised the critical coordination

92 Interview Health NGO on 24 September 2018 and European Court of Auditors, Special Report – Air pollu-tion: Our health still insufficiently protected, 2018.



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role of the Ministry is certain respects. For example, the national air quality index to inform the

public is not yet harmonized, with each region applying its own. The Ministry is proposing to

harmonise it with the European index. Additional activities beyond the requirements of the AAQ

Directives are carried out by the Ministry which coordinates measures to gather data on other

pollutants such as NH3 or black carbon. The Madrid municipality has carried out some research

on monitoring black carbon within the working group coordinated by the Ministry.

Enforcement

It is broadly recognized that without the enforcement actions at EU level, the implementation of

the Ambient Air Quality Directives in Spain would be much less advanced93.

The Commission has initiated infringement procedures against Spain (in relation to specific air

quality zones) since 2010 for failing to comply with PM10 or NO2 limit values. In 2013, a new

infringement procedure was opened for exceeding PM10 limit values, with the reasoned opinion

sent in 2014 together with an additional letter of formal notice. The Plan for 2013-2016 was

adopted in response to these breaches. Another infringement procedure was initiated with a letter

of formal notice in June 2015 for failure to comply with the NO2 limit values. The reasoned opinion

followed in February 201794. The Madrid Plan A was adopted in September 2017. In 2018, the

European Commission announced that it was taking legal action before the CJEU but the case was

put on hold following Spain’s commitment to adopt the necessary effective measures and to pro-

vide regular information to the Commission on the progress of the measures.

However, all stakeholders identified a need for quicker and more systematic enforcement

measures at EU level95.


The implementation challenge described above is driven by a number of factors, which are some-

times linked to the specific provisions of the AAQ Directives.

Insufficient coordination at local level

The allocation of responsibilities at local and regional level in air quality management may itself

pose challenges to the implementation of the Directives. This challenge is further amplified by the

limited coordination between the different authorities’ levels in Spain. Under the principle of sub-

sidiarity, Directive 2008/50/EC does not specify how responsibilities in air quality monitoring,

assessment and management should be allocated within the Member States. Article 3 of Directive

2008/50/EC nevertheless lays down the obligation for Member State authorities to ‘designate at

appropriate levels the competent authorities and bodies responsible for the following: (a) assess-

ment of ambient air quality; (b) approval of measurement systems (methods, equipment, net-

works and laboratories); (c) ensuring the accuracy of measurements; (d) analysis of assessment

methods; (e) coordination on their territory if Community-wide quality assurance programmes

are being organised by the Commission; and (f) cooperation with the other Member States and

the Commission’. The provision refers mainly to tasks relating to air quality monitoring and as-

sessment rather than to the management of air quality specifically.

93 All stakeholder interviews 21-24 September 2018 94 European Commission, Infringement decisions, web page, at: http://ec.europa.eu/atwork/applying-eu-

law/infringements-proceedings/infringement_decisions/?lang_code=en; https://legal.cleanair-europe.org/le-gal/eu/infringement-procedure/ 95 Special Report - Air pollution: Our health still insufficiently protected, European Court of Auditors, 2018, p. 30 at: https://www.eca.europa.eu/Lists/ECADocuments/SR18_23/SR_AIR_QUALITY_EN.pdf








https://www.eca.europa.eu/Lists/ECADocuments/SR18_23/SR_AIR_QUALITY_EN.pdf




(2008/50/EC, 2004/107/EC)

March 2019 39

As discussed above, particular shortcomings have been identified in relation to the adoption of

the necessary measures to reduce pollution. There is a strong lack of information sharing at the

different levels of responsibility - in relation to the measures needed or planned, their develop-

ment and examples of best practices. This lack of coordination evidences the need to improve the

communication and knowledge sharing between authorities within the country, which the Ministry

is trying to promote. However, political considerations may jeopardize the adoption of the neces-

sary measures.

Lack of motivation to take action

The findings of the case study suggest that, despite recent improvements, there has been a per-

sistent lack of motivation and a certain negligence in taking action to ensure timely compliance

with the requirements of the AAQ Directives. The absence of public awareness did not help to put

pressure on the authorities to take action. This is closely linked to the hierarchy of priorities and

the problem of competences and lack of coordination, as discussed above.

The fact is that while Spain has a National Air Quality Plan, only a third of the measures have

been implemented and there are no performance indicators for measuring policy effectiveness96.

The 2016 evaluation of the National Plan showed that it had not achieved its objective97.

Some of the implementation problems in Spain stem from difficulties in understanding the man-

datory nature of some of the Directives’ provisions that require action prior to the deadlines. Limit

values announced since 1999, which came into force in 2010, continue to be exceeded in 2017.

Spain considered the earlier version of the Directive to represent recommendations up to the

deadline – thus it did not set out a plan to ensure compliance with the limit values. Furthermore,

there seems to be the understanding that target values are not mandatory.

This situation evidences the need for quicker and more systematic enforcement measures at EU

level98. The deterrent effect of a quicker and more systematic EU enforcement policy would act

as a stronger motivating element to take the necessary action on air quality in Spain.

3.5 Costs and benefits of the Ambient Air Quality Directives


As yet, there is no economic analysis of the implementation costs of the AAQ Directives in Spain.

A number of rough estimates were gathered during the interviews with stakeholders for this study.

96 Joint report on air quality by Court of Auditors, Eurosai, 2019, p. 40 and 41 at: https://www.euro-

sai.org/en/databases/audits/Joint-Report-Air-Quality/ 97 Idem, p. 47 98 Special Report - Air pollution: Our health still insufficiently protected, European Court of Auditors, 2018, p. 30 at: https://www.eca.europa.eu/Lists/ECADocuments/SR18_23/SR_AIR_QUALITY_EN.pdf








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Table 3-1 Information gathered and sent by the Ministry on 15 November 2018

Network maintenance costs (EUR)

Main-

tenance per sta-

tion

Main-

tenance all sta-

tions

Analysis Other ex-

penses

Adminis-

trative expenses

TOTAL/

year

Acquisition

of new Equipment

No. of

sta-tions

Red

emep/vag/camp

681,919 465,000 1,146,919 125,417

(2017) – 406,735

(2015)

13

Andalucía 15,000-20,000

estación/ año

1,000,000 1,500,000 200,000 2,700,000 VARIABLE

Castilla y león. Ayto.

Valladolid

68,894 344,471 344,471 5

Castilla y

león

26,621 612,300 612,300 23

Comunidad

valenciana

38,675 688,690 717,386 66,915 74,000 1,546,991 VARIABLE 74

Navarra 123,000 53,420 70,000 3,600 250,020

Com. Madrid

24,300 583,200 100,000 100,000 211,200 24

La rioja 13,950 69,750 33,200 146,950 44,000 5

Baleares 69,666 100,000 25,000 5,000 150,000 418,000 100,000 6

Cantabria 300,000

País vasco 1,000,000

Extrema-dura

46,758 220,000 110,000 44,071 374,071 8

Ayto. Za-ragoza

283,140 7

Asturias 18,400 290,000 20,000 70,000 80,000 25

Castilla-la

mancha

115,633 309,980

Galicia 529,958 337,739 867,697

In addition, the municipality of Madrid provided the following information during the interview:

• Renewal of measuring equipment and maintenance of the network, which includes the value

of the contract with the company (tendered). At the moment there are 10 people working on

it. The estimated cost is about EUR 600,000. Each station has its own measuring equipment

but the cost is not known.

• Plan A implementation: EUR 600,000.



(2008/50/EC, 2004/107/EC)

March 2019 41

• There are specific measures triggered by the peak pollution protocol, including the improve-

ment of the transport public service, which are not estimated as they are part of the normal

municipal budget.

• There is no estimate of the benefits regarding the improvement of air quality and the impact

on public health of measures adopted in Madrid. A project will be launched in 2019 to obtain

data on this issue.

• Contracts with laboratories: EUR 30,000 per year.

• Staff in the municipality: EUR 300,000 (four staff and two support staff).


One study by CE Delft provides some estimates on the health impacts and costs of diesel emis-

sions in the EU in 2016, including Spain.

• Estimates vary depending on several factors. According to this study, the total cost of road

traffic-related air pollution in 2016 (both health and non-health related) in Spain is between

EUR 3,916 million and EUR 4,836 million (depending on whether it is based on COPERT

emissions factors or on TRUE emission factors). Between 80-85% of emissions has its origin

in diesel. Estimates of the total health-related air pollution costs borne by governments and

compulsory health insurance varies from EUR 2,634 million to EUR 3,204 million.



Directives. Without quantitative assessments of the benefits of the AAQ Directives in Spain, these

can only be described in qualitative terms.

A number of provisions in the AAQ Directives have been identified as key in delivering air quality

improvements. These include the establishment of a harmonised approach to monitoring, assess-

ment and management of air quality throughout the EU. Overall, the following provisions of the

AAQ Directive were cited as being the most important: 1) the setting of air quality standards; 2)

providing information to the public and 3) cooperation with the European Commission and be-

tween Member States.

All stakeholders interviewed (institutions and NGOs) consider the AAQ Directives to have had a

positive impact on air quality in Spain, stating that, without the Directives, efforts would have

been considerably less.

The Ministry made special mention of the positive impact of promoting the monitoring and as-

sessment of air quality in a harmonised way, ensuring the comparability of data. It pointed out

that while air quality networks have existed for more than 20 years the main focus was controlling

air quality problems due to traffic. There is now more social pressure and demand with respect to

the issue.

According to a health NGO, the Spanish law and the implementing Royal Decree are complemen-

tary and establish an effective system to identify pollution problems. They could be used to include

additional pollutants and ensure consistency with chemicals legislation.



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The municipality of Madrid clarified that while the impact of the Plan A measures on the air quality

has been assessed, there is no estimate of the benefits of the implementation of the Directives

through the Plan Air or other measures with respect to the impact on health. A research project

to obtain these data is planned for 2019.



(2008/50/EC, 2004/107/EC)

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4 CONCLUSIONS

Chapter 4 presents a summary of the main findings of the case study with respect to the main

implementation challenges, the potential for improving the implementation of the Directives in

Spain, and the aspects of the AAQ Directives that may have contributed to the present situation

in Spain. Finally, a summary of the evaluation of the AAQ Directives is presented.

Identified problems and potential for improving the implementation of the Directives


Limits and pollutants

There was general agreement among the stakeholders that the Directives could be stricter on

the limits for certain pollutants which are not yet in line with WHO standards. The distinction

made between pollutants with target values and limit values was also criticised. Those criticisms

were based on the existing scientific evidence on the impact on human health and the environ-

ment of the pollutants, which evidence is reflected, for instance, in the WHO recommendations.

Other pollutants, similarly harmful to human health, could also be included, such as black car-

bon, ultrafine particulates or Hg, among others. It was also noted that the Directives are rigid

and not sufficiently flexible to be adapted to advances in science.

Measuring limit values

The authorities interviewed believed that the Directives promote a harmonised method for col-

lecting data and measuring emissions levels, as well as a process for monitoring them in all EU

Member States. According to a recent study, practices on air quality management and in partic-

ular, the use of assessment tools and methods, have improved increasing understanding of the

sources of air pollution99.

However, NGOs remarked on the insufficiency of fixed measurement to assess air quality and,

more specifically, criticised the location criteria of measuring points and the imbalance between

the number of types of stations (e.g. between traffic and urban points). The lack of reference

methods for the modelling of pollutant concentrations and the admission of measuring methods

other than the reference methods was also criticised. It should be note, however, that the Direc-

tives allow for using other methods if their equivalence has been demonstrated. In addition, NGOs

criticised that no regular data are collected on the impact of emissions on health, nor are any data

systematically collected on health incidence of the measures.

Exceedance of limits & EU enforcement

In practice, Spain does not comply in certain air quality zones with the limit values set by the

AAQ Directives in relation to NO2 and PM10. Of all pollutants, three (NO2, PM10 and O3) have

exceeded the established limit or target value in all years during the period 2005-2016, and in

2017. According to the 2017 Evaluation Report on Air Quality in Spain (published in September

2018), the 2017 results are worse than those of 2016, as the number of air quality zones ex-

ceeding the legislated values for NO2 and PM10 increased100. For NO2, the number of urban ag-

glomerations that exceeded the legislated values increased. More specifically in 2017, both the

NO2 annual mean and the hourly limit value was exceeded in Madrid, as it was in the previous

99 EEA, Europe's urban air quality — re-assessing implementation challenges in cities, EEA Report 24/2018,

2019. Available at: https://www.eea.europa.eu/publications/europes-urban-air-quality 100 Ministerio para la Transición Ecológica, La calidad del aire en España en 2017 baja levemente con res-


calidad-del-aire-en-Espa%C3%B1a-en-2017-baja-levemente-con-respecto-al-a%C3%B1o-anterior/tcm:30-481677








(2008/50/EC, 2004/107/EC)

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year. In addition, exceedances of NO2 annual limit value occurred in other large cities such as

Barcelona and surroundings, Granada and its metropolitan area, and Bilbao and its surround-

ings, largely due to traffic emissions101.

The Commission has initiated infringement procedures against Spain since 2010 (e.g. for failing

to comply with PM10 limit values). In 2013, a new infringement procedure was opened for exceed-

ing PM10 limit values, with the reasoned opinion sent in 2014 together with an additional letter of

formal notice. The Plan for 2011-2015 was adopted in response to these breaches. Another in-

fringement procedure was initiated with a letter of formal notice in June 2015 for failure to comply

with the NO2 limit values. The reasoned opinion followed in February 2017102. In 2018, the Euro-

pean Commission announced that it was taking legal action before the CJEU but the case was put

on hold following Spain’s adoption of specific measures that could be effective. In the meantime,

Spain committed to adopt the necessary measures and to provide regular information to the

Commission on the progress of the measures.

As stated by the European Court of Auditors the lengthy enforcement procedure has not ensured

compliance with the Directive103. Quicker and more systematic enforcement measures at EU level

are needed to ensure their deterrent effect.

Planning

Spain has developed Air Quality Plans at national, regional and local level in order to promote the

full implementation of the AAQ Directives. However, as evidenced by the EU infringement proce-

dures and stakeholder reports, their implementation remains to be a challenge104. Additional ac-

tions to comply with NO2 limit values such as those demonstrated in other Member States, could

be usefully implemented in Madrid, i.e. access restrictions for transport, fiscal incentives to pro-

mote cleaner cars, or incentives to promote public transportation and non-motorized transport

opportunities. The current imbalance in taxation between petrol and diesel is not justified105.

While Spain has a National Air Quality Plan, only a third of the measures have been implemented

and there are no performance indicators for measuring policy effectiveness106. The 2016 evalua-

tion of the National Plan showed that it had not achieved its objective107.

Concrete measures on energy efficiency (e.g. in buildings), measures promoting renewable en-

ergy, taxes targeting diesel or measures modifying the car environmental labels have been iden-

tified as still required to be implemented108.

Other measures suggested as a result of the Clean Air Dialogue which have not been implemented

yet are: establishing requirements on the quality of solid fuels used in households; further incen-

tives to accelerate scrapping of sub-standard solid fuel stoves and boilers and promoting system-

atic transfer to cleaner heating sources; continuous awareness-raising among the public of the

health impact of residential solid fuel combustion and operation techniques in private households;

101 Idem. 102 C:\Users\mb\Downloads\EU-infringements_2017.pdf and https://legal.cleanair-europe.org/legal/eu/in-

fringement-procedure/ 103 Special Report - Air pollution: Our health still insufficiently protected, European Court of Auditors, 2018,

p. 30 at: https://www.eca.europa.eu/Lists/ECADocuments/SR18_23/SR_AIR_QUALITY_EN.pdf 104 Ecologistas en acción, 2017 report on air quality in Spain, p. 61 105 European Commission and Ministerio para la Transición Ecológica, Conclusions of the Clean Air Dialogue between Spain the European Commission taking place in Madrid on 8 – 9 October 2018 at: http://ec.eu-

ropa.eu/environment/air/pdf/shared conclusions from clean air dialogue w Spain.pdf 106 Joint report on air quality by Court of Auditors, Eurosai, 2019, p. 40 and 41 at: https://www.euro-

sai.org/en/databases/audits/Joint-Report-Air-Quality/ 107 Idem, p. 47 108 Ibid, p. 62
















(2008/50/EC, 2004/107/EC)

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and activities on energy efficiency. A ban on open field burning of agricultural waste was also

raised, together with the promotion of policies on energy renovation of buildings. Due to the

cross-cutting nature of air quality, efforts in this area can be included in both climate and energy-

related policies109.

At a municipal level, the measures of the Madrid Plan A aim at improving ambient air quality and

complying with the limit values established for NO2, WHO guide values for PM10 and target values

for O3.

The insufficiency of the air quality plans to meet legal standards was noted by NGOs, in particular

their late development, lack of proper monitoring and lack of coercive measures for enforcement.

In addition, the lack of short-term plans is deemed an issue of concern110.

Coherence and sectoral policies

While coherence with other environmental measures such as those related to the IED is en-

sured, there is a lack of coherence with other sectoral policies. For instance, Spain is still incen-

tivising the acquisition of diesel cars until 2020. Further the modification of the standards on

NO2 emission limit under the Euro 6 Regulation (EC) No 715/2007 through the Regulation EU

2016/646 were identified. Alongside the cities of Paris and Brussels, Madrid reacted against

these measures to the CJEU because it considered that the Commission did not have the com-

petence to adopt the relevant correction factors since it considered that this rendered the Euro 6

emission limits less strict. In a first instance judgment, the General Court of the EU ruled that

the provision prescribing the coefficient factor is invalid as its adoption is an infringement of

Regulation No 71/2007 establishing emission limits for NO2111. Appeal proceedings against this

judgment are currently pending112.

Coordination

The lack of coordination between competent administration levels in Madrid hinders compliance

with the AAQ Directives’ targets and limit values. This is an issue, for instance, in the policy to

reduce the presence of cars in Madrid, where regional policies from the autonomous community

are necessary in order to successfully apply the measures intended by the municipality of Madrid.

This lack of coordination also translates into a lack of communication and knowledge sharing

within the country. The Clean Air Dialogue held in October 2018 concluded that better coordination

among the different administrations and different ministries is essential to improve the clean air

policy. This will also maximise the co-benefits of action in other areas including transport, energy,

climate change and agriculture113.

109 European Commission and Ministerio para la Transición Ecológica, Conclusions of the Clean Air Dialogue between Spain the European Commission taking place in Madrid on 8 – 9 October 2018 at: http://ec.eu-

ropa.eu/environment/air/pdf/shared conclusions from clean air dialogue w Spain.pdf 110 Interviews NGO 21/09/2018 and Ecologistas en acción, 2017 report on air quality in Spain, p. 40 at:

https://www.ecologistasenaccion.org/?p=13106 and https://www.ecologistasenaccion.org/wp-content/up-loads/2018/06/informe-calidad-aire-2017.pdf 111 Cases T-339/16 Ville de Paris v Commission, T-352/16 Ville de Bruxelles v Commission, T391/16 Ville de

Madrid v Commission at: https://curia.europa.eu/jcms/upload/docs/application/pdf/2018-

12/cp180198en.pdf 112 See pending cases (status as of 29 August 2019), Germany - Ville de Paris and Others v Commission (C-

177/19 P), Hungary - Ville de Paris and Others v Commission (C-178/19 P) and Commission v Ville de Paris

and Others (C-179/19 P). 113 European Commission and Ministerio para la Transición Ecológica, Conclusions of the Clean Air Dialogue

between Spain the European Commission taking place in Madrid on 8 – 9 October 2018 at: http://ec.eu-ropa.eu/environment/air/pdf/shared conclusions from clean air dialogue w Spain.pdf





https://www.ecologistasenaccion.org/?p=13106

https://www.ecologistasenaccion.org/?p=13106













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March 2019 46

Public awareness

Traditionally, there has been a lack of awareness among citizens, which translated into a lack of

pressure for public administration to comply with the objectives of the Directive. However, in

recent years, public awareness of the issue has increased in Spain. The implementation of the

Directives triggered the adoption of important measures such as the development of a map of

the monitoring network which provides information on the concentration levels per station, date

and time114.

• For some NGOs, this is not enough. The Eurobarometer points out, for instance, that among

all Europeans, the Spanish report the highest numbers of citizens feeling that they are not

properly informed about air quality. This is confirmed by the report stating that one the main

challenges recognised by cities like Madrid on their implementation of air quality measures

is how to effectively communicate air quality issues to the public115.



relevance, effectiveness, efficiency, coherence and added value of the AAQ Directives.

4.1.1 Relevance

The findings of the case study indicate that the objectives of the AAQ Directives are relevant to

the needs of citizens in Spain. All stakeholders consulted agreed on the need to retain the objec-

tives of the Directive. However, there is also a general opinion that the Directives should be

stricter, with new pollutants added and stronger limits imposed in some cases.

4.1.2 Effectiveness

The Directives have provided an incentive to establish policies to control air quality in Spain.

According to some NGOs, without the Directives, measures would have been much slower to

develop. It has also fostered increasing social pressure to solve the problem, e.g. Plan A of the

municipality of Madrid. However, Spain still does not comply with the limits of NO2 and PM10 in

some zones; this lack of implementation affects the effectiveness of the Directives. The lack of

coordination between public authorities also hinders the effectiveness of the application of the

Directives.

4.1.3 Efficiency

As yet there is no economic analysis of the implementation costs of the AAQ Directives in Spain.

A number of rough estimates were gathered via the interviews with stakeholders in the context

of this study. These estimates relate to the network maintenance costs per autonomous commu-

nity. With data from 10 of the 17 autonomous communities and the national network, the reported

costs exceed EUR 9 million per year. The municipality of Madrid also provided some data, for

instance, the cost of implementing Plan A (EUR 544,000).


Directives. Without any quantitative assessments of the benefits of the AAQ Directives in Spain,

these can be described solely in qualitative terms. Identified benefits include: 1) the establishment

114 Ayuntamiento de Madrid, Plan de Calidad del Aire y Cambio Climático de la Ciudad de Madrid, 2017.

Available at: https://www.madrid.es/UnidadesDescentralizadas/UDCMedios/no-

ticias/2017/03Marzo/13Lunes/NotasdePrensa/Plan%20Calidad%20Aire/ficheros/PlanACalidadAire2017.pdf,

p. 37 115 EEA, Europe's urban air quality — re-assessing implementation challenges in cities, EEA Report 24/2018, 2019. Available at: https://www.eea.europa.eu/publications/europes-urban-air-quality








(2008/50/EC, 2004/107/EC)

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of a harmonised approach to monitoring, assessment and management of air quality throughout

the EU; 2) positive impact on the improvement of air quality in Spain; 3) promoting the monitoring

and assessment of air quality in a harmonised way; and 4) increased public awareness.

4.1.4 Coherence

In Spain there is a high level of coordination and consistency between the air quality policy and

the Industrial Emissions Directive including the relevant best available techniques (BAT) conclu-

sions. They contribute to the fulfilment of the objective of the AAQ Directive to maintain air quality

where it is good and improve it in other cases.

At national level, there is a lack of coherence and coordination with other public policies. For

instance, the incentives for diesel cars by the state, or the lack of coordination to implement

policies between the autonomous community and the municipality of Madrid, which hinder the

effectiveness of policies applied.

The Madrid municipality identified a problem of coherence between the European air quality re-

quirements and emission standards for vehicles. Under the Regulation EU 2016/646 the European

Commission proposed an amendment to the new Euro 6 Regulation regarding the cars’ NO2 emis-

sion limit which would affect compliance with ambient air quality limit values or targets116. It

applied correction coefficients in order to take account of, statistical and technical uncertainties

of the laboratory tests. Alongside the cities of Paris and Brussels, Madrid reacted against these

measures to the CJEU because it considered that the Commission did not have the competence

to adopt the relevant correction factors since it considered that this rendered the Euro 6 emission

limits less strict. In a first instance judgment, the General Court of the EU ruled that the provision

prescribing the coefficient factor is invalid as its adoption is an infringement of Regulation No

71/2007 establishing emission limits for NO2117. Appeal proceedings against this judgment are

currently pending118.


The monitoring requirements of the AAQ Directives have stimulated a number of improvements

in the monitoring of air quality. While monitoring took place before the introduction of the AAQ

Directives, the added value of the Directives comes from the shift in focus of monitoring to the

areas where most of the population lives, improvements in the quality of the monitoring data,

and harmonised data collection allowing for comparisons across the EU.

The enforcement actions at EU level to ensure implementation of the AAQ Directives are perceived

as an EU added value inherent in the functioning of the EU system. According to some stakehold-

ers, efforts would have been considerably less in Spain had the Directives not come into force and

the Commission not monitored its implementation.

Another major area of EU added value of the Directives lies in the increased visibility of the air

quality issue and the awakening of public and political interest to solve the problem.

116 Commission Regulation (EU) 2016/646 amending Regulation (EC) No 692/2008 as regards emissions from light passenger and commercial vehicles (Euro 6): https://eur-lex.europa.eu/legal-con-

tent/EN/TXT/?uri=CELEX%3A32016R0646 117 Cases T-339/16 Ville de Paris v Commission, T-352/16 Ville de Bruxelles v Commission, T391/16 Ville de

Madrid v Commission at: https://curia.europa.eu/jcms/upload/docs/application/pdf/2018-

12/cp180198en.pdf 118 See pending cases (status as of 29 August 2019), Germany - Ville de Paris and Others v Commission (C-

177/19 P), Hungary - Ville de Paris and Others v Commission (C-178/19 P) and Commission v Ville de Paris and Others (C-179/19 P). https://curia.europa.eu

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016R0646






https://curia.europa.eu/



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APPENDIX A INTERVIEWS

Organisation Name and position Date of the interview

Madrid municipality 21/09/2018

Madrid municipality 21/09/2018

Ministry of Environment 24/09/2018

Ecologistas en accion 21/09/2018

Fundación Alborada 24/09/2018

doi:[number]

ISBN [number]

[Cata

logue n

um

ber]

Written by Adriana R. Ilisescu March 2019

CASE STUDY REPORT

SWEDEN



(2008/50/EC, 2004/107/EC)



(2008/50/EC, 2004/107/EC)

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Contents

1 Introduction 4


2.1 Sweden and air quality zone characteristics 5






3 Findings 23




3.4 Factors underlying compliance and effectiveness of the AAQ Directives 29


4 Conclusions 37






(2008/50/EC, 2004/107/EC)

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Appendices




Appendix D Use of EU funds

Appendix E Pollutant concentration data for Sweden, 2013-17



(2008/50/EC, 2004/107/EC)

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1 INTRODUCTION

This report summarises the findings and conclusions of the case study for Sweden. The case

study had a focus on rural environment and ecosystem impacts.

















the case study







in Appendix A.






(2008/50/EC, 2004/107/EC)

March 2019 5


The present chapter contains general information about the air quality framework in Sweden.

2.1 Sweden and air quality zone characteristics


The case study covers the entire territory of Sweden and the implementation of the AAQDs. In

addition, the case study will present findings related to the effects of AAQDs on air quality and

the implications it had on rural environment and ecosystem impacts.

As shown in the figure below, the territory of Sweden is divided into 6 zones and 3 agglomerations

(Stockholm, Malmo, and Goteborg).

Figure 2-1 Air quality zones for AAQ Directives


2014), Sweden.

The table below presents an overview of the different zones and counties / municipalities that are

included, type of zone and the number of inhabitants and area.



(2008/50/EC, 2004/107/EC)

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Table 2-1 Overview of air quality zones in Sweden

Zone Zone name Counties / municipalities Type of

zone

Number of in-

habitants in

2017 (million

inhabitants)

Area (km2)

SE0001 North Swe-

den

Norrbotten (BD), Västerbotten

(AC), Västernorrland (Y), Jämtland

(Z), Dalarna (W), Gävleborg (X)

Other

(Non-ag-

glom.)

1.47 290,647

SE0002 Middle

Sweden

Värmland (S), Örebro County (T),

Västmanland (U), Uppsala (C),

Stockholm County except Zone 4

(AB),

Södermanland (D), Östergötland

Other

(Non-ag-

glom.)

2.28 69,344

SE0003 Southern

Sweden

Västra Götaland except zone 5 (O),

Jönköping (F), Kalmar (H), Gotland

(I) Kronoberg (G), Halland (N), Ble-

kinge (K), Skane except zone 6 (M)

Other

(Non-ag-

glom.)

2.99 81,762

SE0004 Stock-

holm's ur-

ban area

The municipalities Botkyrka, Dan-

deryd, Ekerö, Haninge, Huddinge,

Järfälla, Lidingö, Nacka, Salem, Sol-

lentuna, Solna, Stockholm,

Sundbyberg, Täby, Tyresö, Up-

plands Väsby, Vallentuna, Vaxholm,

Österåker

Semi-ur-

ban area

(Agglom.)

1.99 2,755

SE0005 Gothen-

burg urban

area

The municipalities of Ale, Gothen-

burg, Härryda, Kungälv, Lerum,

Mölndal, Partille, Öckerö.

Semi-ur-

ban area

(Agglom.)

0.82 2,002

SE0006 Malmo ur-

ban area

The municipalities Burlöv, Lomma,

Lund, Malmö, Staffanstorp, Vel-

linge.

Semi-ur-

ban area

(Agglom.)

0.56 925

Total

10.12 447,435

Source: Swedish EPA, Sweden's air quality zones, http://www.naturvardsverket.se/Sa-mar-

miljon/Klimat-och-luft/Statistik-om-luft/

2.1.2 Characteristics of air quality zones

Sweden is an elongated country with geographically diverse climate. This has an impact on the

air pollution levels in several manners. In general, there is a north-south gradient in terms of

pollution levels for background concentrations, with increased air quality in the northern parts of

Sweden and decreased air quality in the southern parts. However, local variations can occur be-

cause of local emissions. The southern part of Sweden is located in the closer proximity of major

pollution sources and densely populated parts of Europe and is affected by long-range trans-

boundary air pollution happening in other countries.



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March 2019 7

Local climate and meteorological conditions are important and have an effect on the inter-annual

variability in atmospheric composition and emission levels. For example, low temperatures can

lead to increased air pollution levels because of general emissions from the increasing use of fuels

in households for heating. This also has applicability for vehicles, as emissions increase in seasons

with cold climate. Furthermore, the level of precipitation / rainfall also has an effect on the levels

of air pollution in Sweden, in particular when it comes to particles and water-soluble air pollutants,

such as sulphur dioxide.

The speed and direction of the wind has an important impact on the dispersion and concentration

of air pollutants. In Sweden, western and southwest winds are commonly occurring which have a

positive effect on air quality. Nevertheless, Sweden does get affected by transboundary pollution

from other neighbouring countries.

Variations in topography also have an effect. Many communities in Sweden are located along

watercourses or valleys or in the proximity of the sea and lakes, which can cause issues in terms

of air pollution because of mixing of air due to ground inversion.

Text box 2-1 Sweden

Sweden


GDP per capita growth (% 2006-

2017)

23.8

Population (1 January 2018) 10,120,242

Governance structure Unitary and decentralised

Zones defined as agglomera-

tions (%)

50%

Area: 447,435 km2

Characteristics of Sweden:

For the implementation of the AAQDs, Sweden is divided into 6 air quality zones, 3 of which are agglomera-

tions.

Sweden has a varied topography and climate, which have an impact on the concentrations and dispersion of

air pollution in different regions.

The main causes of air pollution in Sweden are NO₂ and PM10. The main sources of pollutants are traffic,

international shipping, and industry.



Population on 1 January; EEA Air Quality e-Reporting.

2.1.3 Ecosystem effects and rural environment

Despite the fact that the impacts of air pollutants on ecosystems and biodiversity in Sweden have

decreased in the past few decades, they continue to constitute an important source of concern.

In the 1970s, acidification as a consequence of air pollution constituted an important issue in

Sweden and measures have been taken since to tackle the root causes of acidification. In the

1980s, concerns grew related to forest damage, eutrophication and stratospheric ozone layer

depletion. During the 1990s, heavy metals and persistent organic pollutants became a growing



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March 2019 8

source of concern and in later years, increased emphasis was put on health issues (particulate

matter) and the effects of air pollution on climate change. Compared to the 1980s and 1990s,

some improvements were registered at pan-European level and in Sweden in terms of reductions

of eutrophying and acidifying emissions to the air. In recent years, concentrations of NOx and SO₂

in Sweden have been reduced but there are still exceedances of critical loads across ecosystems.

Some emissions, in particular ammonia (NH₃) and nitrogen dioxide (NO2) emitted from the agri-

culture and transport sectors, will remain an important source of concern when it comes to eu-

trophication cause by air pollution.

The ecosystem area at risk of eutrophication due to airborne nitrogen deposition has decreased.

It is further expected to decrease up to 19% by 2020 compared to 30% in 2010.1


The following section presents briefly the arrangements in Sweden in terms of air quality moni-

toring and presents information regarding exceedances reported.


Air quality monitoring set-up

At national level, the Swedish Environmental Protection Agency (EPA) is responsible for monitor-

ing concentrations of pollutants in air in rural background areas on a national level. The EPA is

also responsible for transferring to the EU monitoring data. Furthermore, the EPA ensures the

availability of information to the public. The data collected by the Swedish EPA is hosted by the

Swedish Meteorological and Hydrological Institute (SMHI).

At regional level, the county administrative boards monitor concentrations of pollutants in air and

precipitation in rural background areas on a regional level. This monitoring aims to follow up the

Swedish environmental objectives, among others Clean Air, Natural Acidification Only and Zero

Eutrophication (see section 2.4).

Monitoring in cities is the responsibility of local authorities (municipalities). The Swedish Environ-

mental Protection Agency's regulations on air quality control specify how monitoring of air quality

should be carried out (NFS 2016:9). According to section 26 of the Air quality ordinance (SFS

2010:477), each municipality must ensure monitoring of air quality through measurement, model

calculation or objective observations in urban areas. Municipalities are responsible for assessing

the air quality in order to follow up on the air quality standards in urban background areas and in

traffic sites. Municipalities can join forces to set up areas of cooperation. For areas of cooperation

between municipalities, a coordination programme to monitor the air quality standards and quality

control and assurance programme must also be defined jointly.

Overall, the Swedish EPA is responsible for receiving, compiling, making available and storing air

quality data from municipalities. The Swedish EPA also presents the data in annual charts, which

are made publically available.

The delineation of the responsibilities for monitoring different type of pollutants in Sweden is

presented in the table below. Overall, responsibility is split between the municipalities that keep

control of air quality in cities (traffic and urban areas) and the Swedish Environmental Protection

Agency that is responsible for ensuring control of air quality in rural areas (regional background).

1 EEA (2018), Eutrophication of terrestrial ecosystems due to air pollution. Available at https://www.eea.eu-ropa.eu/airs/2018/natural-capital/eutrophication-of-terrestrial-ecosystems#tab-based-on-data.

../../../../../Forms/All%20Documents.aspx?RootFolder=%2Fps%2FA104859%2FDocuments%2FExternals%2FTask%201%20and%205%20%2D%20Deliverables%2F4%2E%20Final%20Deliverables%2FCase%20studies%2FFinal%20country%20reports%20to%20be%20submitted






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March 2019 9

Each municipality must check in urban areas that the levels of NOx, SOx, CO, PM10, PM2.5, Benzene,

BaP, As, Cd, Ni, Pb is within the set limits. On the other hand, the Swedish EPA is responsible for

monitoring pollutants such as PM2.5, nitrogen doxide, sulphur doxide and ground-level ozone.

Table 2-2 Monitoring of air quality in Sweden

Air quality norm Where?* Responsible

Nitrogen dioxide Traffic/Urban areas Municipalities

Nitrogen oxides Regional background (Rural) Environmental Protection

Agency

Sulphur dioxide Traffic/Urban areas Municipalities

Sulphur dioxide Regional background (Rural) Environmental Protection

Agency

Carbon monoxide Traffic/Urban areas Municipalities

Ozone Cities / suburbs / rural areas / regions Environmental Protection

Agency

Benzene Traffic/Urban areas Municipalities

PM10 Traffic/Urban areas Municipalities

PM2.5 Urban areas Municipalities

PM2.5 Exposure reduction / Urban areas Environmental Protection

Agency

BaP Traffic/Urban areas Municipalities

Arsenic Traffic/Urban areas Municipalities

Cadmium Traffic/Urban areas Municipalities

Nickel Traffic/Urban areas Municipalities

Lead Traffic/Urban areas Municipalities

*Measurement in traffic stations can also correspond to other sources such as heating sources or

industries.

Source: Swedish EPA (2016), Air quality Guide

The scope of monitoring, i.e. whether it should be conducted in the form of continuous fixed

measurement, indicative measurement, model calculations or objective estimation as well as the

number of measuring points required is defined in the national legislation. Continuous measure-

ments are done for concentrations above the lower assessment threshold and with a specific

number of inhabitants as indicated below.



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Table 2-3 Assessment procedures

Assessment level Assessment procedure which as a minimum shall

be applied in a municipality or a collaboration area

The concentrations exceed or risk exceeding the en-

vironmental quality standard

Continuous measurements in the exceeding mu-

nicipalities

The concentrations are between the upper assess-

ment threshold (UAT) and the environmental quality

standard

Continuous measurements

(Objective estimation if less than 10,000 inhabit-

ants)

The concentrations are between the lower assess-

ment threshold (LAT) and the upper assessment

threshold (UAT)

Indicative measurements, modelling or objective

estimation are required (applies mostly on

smaller municipalities in northern Sweden) or ob-

jective estimation if less than 10,000 inhabitants.

The concentrations are below the lower assessment

threshold (LAT)

Model calculation or objective estimation

Source: Swedish Environmental Protection Regulations on Assessment of Air Quality

Table 2-4 Sampling locations in a municipality or collaborative area

Number of in-

habitants,

thousands

A. At concentrations above the upper as-

sessment threshold

B. At concentrations between the lower as-

sessment thresholds and the upper as-

sessment threshold

NO, SO,

Pb, CO,

Benzene

PM10 and

PM2.5

As, Cd,

Ni

BaP NO, SO,

Pb, CO,

Benzene

PM10 and

PM2.5

As,

Cd, Ni

BaP

10-249 1 2 1 1 1 1 1 1

250-499 2 3 1 1 1 2 1 1

500-749 2 3 1 1 1 2 1 1

750-999 3 4 2 2 1 2 1 1

1,000-1,499 4 6 2 2 2 3 1 1

1,500-1,999 5 7 2 2 2 3 1 1

2,000-2,499 6 8 2 3 3 4 1 1

2,500-2,999 7 10 2 3 3 4 1 1

3,000-3,500 8 11 2 3 3 6 1 1

The total number of sampling locations for PM10 and PM2.5. If PM10 and PM2.5 are measured at the same sam-

pling location, these shall be counted as two separate sampling locations.

Source: Swedish EPA

The national legislation also stipulates that continuous measurements need to be done, as a basic

rule, by each municipality who exceeds the lower threshold. However, municipalities can form

collaborative areas2 which would then allow them to have sampling points covering more than

one municipality, thus implicitly reducing the number of sampling points in place.

2 Collaborative areas are geographical areas where the assessment of air quality is carried out in collaboration between two or more municipalities.



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March 2019 11

In line with the AAQD, the national legislation stipulates that modelling or indicative measure-

ments can supplement continuous measurements at concentrations above the upper assessment

threshold so that sufficient information is obtained on the spatial distribution of air pollutants.

The measuring methods are defined in cooperation with the Reference Laboratory for Urban Air

Measurement (Reflab) and the Reference Laboratory for modelling, which has been set up as a

result of the implementation of the AAQDs. The Reflab provides on assignment by the Swedish

EPA advice to municipalities on measuring methods and instruments to be used. The Reflab meas-

urements also support the EPA in making recommendations for decisions for approval of measur-

ing methods. In 2016, the Reflab developed a national manual outlining the various procedures

and tasks to be performed as part of the air quality control process in Sweden. The manual for

the harmonisation of quality assurance and quality control for air quality measurement in Sweden3

covers guidance on:

• Choice of location for measurement

• Selection of measuring instruments

• Installation of measuring equipment

• Maintenance and maintenance of measuring equipment, including calibration and service

• Data management, including control of compliance with data quality goals

• Reporting and availability of data

• Training.

Monitoring of air quality pollutants effects on the ecosystem and rural environment has been

defined in line with the NEC Directive and international commitments of Sweden (e.g. the Con-

vention of Long Range Transboundary Air Pollution). The monitoring program is designed to fit

the purpose of the NECD with the main pressure being air pollution. However, the monitoring

system has not changed or been affected by the implementation of the AAQDs.

The monitoring design covers large spatial gradients combined with high intensity monitoring sites

for improved process understanding.

3 Harmonisation of QA / QC for air quality measurement in Sweden. Available at: http://www.aces.su.se/re-flab/kvalitetssakring/harmoniserad-qaqc-manual/.

http://www.aces.su.se/reflab/kvalitetssakring/harmoniserad-qaqc-manual/






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• Terrestrial ecosystems: the monitoring network consists of a combination of sites covering

the spatial gradients of Sweden and a few monitoring locations with high temporal resolution

with measurements in both terrestrial and aquatic environments. Additionally, four inten-

sively monitored Integrated Monitoring sites are included.

• Ozone monitoring network: the monitoring net-

work consist of 10 sites where hourly measure-

ments of O3 and monthly measurements of NO₂

are performed. The monitoring is combined with

modelling to assess the potential effects of ozone

on forests and crops in Sweden.

• Freshwater ecosystems: monitoring of lakes and

streams.

Concentrations in Sweden are well below the critical

levels for NOx and SO₂ and target value for ozone set

out in the AAQDs.

Figure 2-2 Monitoring network for ozone, terrestrial ecosystems, freshwater monitoring

Air quality monitoring effectiveness

Sweden was monitoring air quality even before the implementation of the AAQDs but the added

value of the Directives in terms of air quality is that it ensures more harmonised and standardised

measurements within and across countries. In Sweden, the implementation of the AAQDs also led

to more emphasis on traffic measurements and monitoring of PM10 levels.

Evidence collected in the context of the case study shows that monitoring is compliant with the

AAQ Directives but limited in some cases. The Swedish EPA works actively with municipalities to

improve the effectiveness of the monitoring. In some instances, monitoring could be improved

and the provisions of the AAQD be further strengthened. For example, interviews with the au-

thorities conducted in the context of this case study highlighted that Sweden complies with the

requirements of the sampling points but has a limited amount of sampling points. This is partly a

consequence of the possibility of municipalities to monitor jointly air quality by setting up coop-

erative areas.

In addition, measurement focus is on monitoring particulate matter and NO₂ emissions but to a

lesser extent on other pollutants. For example, the location of monitoring sites for BaP was ques-

tioned by the Swedish EPA interviewees indicating that BaP is a very local problem in areas with

no district heating and substantive log combustion and that sampling and siting point should take

this into consideration. As such, monitoring in traditional stations and in some cities in a few

background stations may not provide a clear idea of the scale of the problem. In rural areas,

where BaP may constitute a problem, monitoring does not take place.



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2.2.2 Air quality in Sweden

Although the emissions of several air pollutants have decreased significantly in Sweden, there are

still some sources of concern for air quality levels in Sweden. Between 1990 and 2014 reductions

in the levels of emissions have been registered in relation to sulphur oxides (-77%), nitrogen

oxides (-51%), ammonia (-5%) and volatile organic compounds (-50%). The reductions regis-

tered ensured that air emissions for these pollutants are within the currently applicable ceilings.4

However, air quality continues to be a source of concern in Sweden in particular in relation to

particulate matter (PM10) and nitrogen dioxide (NO2) concentrations. Local emissions play an im-

portant role in contributing to concentrations of these types of pollutants. Exceedances of air

quality standards related to the annual mean concentration of NO₂ have been registered in two

air quality zones (Gothenburg and Stockholm) and related to the daily concentration of particulate

matter (PM10) in two air quality zones (Stockholm and Middle Sweden). Additionally, ozone con-

centrations have also been an issue in several air quality zones.

Figure 2-3 Pollutant concentrations (2014)

Source: EC (2017), the EU Environmental Implementation Review5

The main sources of air pollution are road traffic, shipping, industry and domestic air pollution.

Local emissions also play an important role in air pollution in Sweden. The location of Sweden in

the close proximity of countries with high emissions also contributes to concentration levels. The

table below provides an overview of the main sources of pollution per type of pollutant.

4 European Commission (2017) The EU Environmental Implementation Review, Country Report – Sweden, SWD (2017) 35 final. Available at: http://ec.europa.eu/environment/eir/pdf/report_se_en.pdf. 5 The graphs show concentrations as measured and reported by the Member States at different locations, specifically they show (a) for PM10 the 90.4 percentile of daily mean concentration, which corresponds to the 36th highest daily mean, (b) for NO₂, the annual mean concentration and (c) for O3, the 93.2 percentile of maximum daily 8-hour mean concentration values, which corresponds to the 26th highest daily maximum. For each pollutant, they depict both the lowest and highest concentration reported, as well as the median values (i.e. note that 50% of the stations report lower concentrations than the respective median value, the other 50% report higher concentrations). The air quality standards as set by EU legislation are marked by the red line.

http://ec.europa.eu/environment/eir/pdf/report_se_en.pdf



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March 2019 14

Figure 2-4 Primary sources of pollutants for various pollutants

Pollutant Sources

PM10 Road traffic when using studded tires

PM2.5 Long-distance transport, small-scale wood burning, electricity and

heat production, industrial emissions, road traffic, shipping

NOx Road traffic, electricity and heat production, industrial emissions,

small-scale wood burning, shipping, long-haul transport

SO₂ Long-distance transport, electricity and heat production, industrial

emissions, shipping

*O3 Long-distance transport, road traffic, smalls-scale wood burning,

households, industrial emissions

CO Road traffic, small-scale wood burning, small work machines, elec-

tricity and gas heat generation, industrial emissions, shipping,

VOC Households, road traffic, small-scale wood burning, small work ma-

chines, industrial emissions, shipping

PAH Small scale word burning, industrial emissions

Metals Metal industrial emissions, long-distance transport

Source: Swedish EPA, Air quality Guide

*O3 is a secondary pollutant, it is not directly emitted from a source but it is created through chemical reac-

tions of other pollutants.

On average, air quality in Sweden is good but there are periods with higher pollution levels. During

spring and winter, NOx and PM levels rise due to increased combustion, tear from transportation

and meteorological conditions. High levels of ozone occur during summer months. Transboundary

air pollutants, especially from forest and agricultural fires play an important role in Sweden's air

quality.6 Sweden has put in place measures to tackle such issues, which are further explained in

section 3.2.


In 2016, Sweden was one of the countries in breach of PM and NO₂ limit values.7 The table below

present exceedances in municipalities in Sweden in 2016.

6UNEP (2015), Sweden Air Quality Policies. Available at http://wedocs.unep.org/xmlui/bitstream/han-dle/20.500.11822/17118/Sweden.pdf?sequence=1&isAllowed=y 7 ECA Report

http://wedocs.unep.org/xmlui/bitstream/handle/20.500.11822/17118/Sweden.pdf?sequence=1&isAllowed=y






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March 2019 15

Table 2-5 Exceedances in municipalities in Sweden 2016 (NO₂, PM10)

Pollutant Environmental Quality Standard

(μg /m3 ), max allowed ex-

ceeded (day, hours)

Municipality Station Exceedance

measured

since the

year

NO₂ Hour> 90 max 175h Gothenburg Gårda 2003

NO₂ Day> 60 max 7 days Gothenburg Gårda 2003

NO₂ Hour> 90 max 175h Gothenburg Haga 2015

NO₂ Day> 60 max 7 days Gothenburg Haga 2015

NO₂ Years> 40 μg / m3 Gothenburg Haga 2016

NO₂ Hour> 90 max 175h Mölndal Göteborgsvägen 2016

NO₂ Day> 60 max 7 days Mölndal Göteborgsvägen 2016

NO₂ Hour> 90 max 175h Sollentuna E4 Häggvik 2016

NO₂ Day> 60 max 7 days Sollentuna E4 Häggvik 2016

NO₂ Hour> 90 max 175h Stockholm Hornsgatan 1999

NO₂ Day> 60 max 7 days Stockholm Hornsgatan 1999

NO₂ Years> 40 μg / m3 Stockholm Hornsgatan 1999

NO₂ Day> 60 max 7 days Stockholm Lille Essingen 2015

NO₂ Day> 60 max 7 days Stockholm Norrlandgatan 2006

NO₂ Hour> 90 max 175h Stockholm Sveavägen 2006

NO₂ Day> 60 max 7 days Stockholm Sveavägen 1999

NO₂ Hour> 90 max 175h Umeå Västra Esplanaden 2006

NO₂ Day> 60 max 7 days Umeå Västra Esplanaden 2006

NO₂ Hour> 90 max 175h Örnsköldsvik Centralesplanaden 2014

NO₂ Day> 60 max 7 days Örnsköldsvik Centralesplanaden 2013

PM10 Day> 50 max 35 days Gotland Norra Hansega-

tan, Visby

2014

Source: Swedish EPA (National Data Host for Air Environment Data). Available at: https://www.natur-

vardsverket.se/Stod-i-miljoarbetet/Vagledningar/Luft-och-klimat/Miljokvalitetsnormer-for-

utomhusluft/Overskridanden-av-miljokvalitetsnormerna-2016/.

Information on pollutant concentrations in Sweden is also provided in more detail in Appendix E

The percentage of the urban population exposed to concentrations above EU standards has de-

creased compared to 2012and findings suggest that the AAQ Directives have contributed to this.

The table below shows the percentage of urban population exposed to concentrations above EU

standards for selected air pollutants.

https://www.naturvardsverket.se/Stod-i-miljoarbetet/Vagledningar/Luft-och-klimat/Miljokvalitetsnormer-for-utomhusluft/Overskridanden-av-miljokvalitetsnormerna-2016/







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Table 2-6 Urban population exposed to concentrations above EU standards (%)

2012 2013 2014 2015 2016

O3 Percentile 93.15 0.0 0.0 0.0 0.0 0.0

PM2.5 Annual mean 0.0 0.0 0.0 0.0 0.0

NO2 Annual mean 0.5 0.4 0.7 0.4 0.3

PM10 Percentile 90.41 0.2 1.2 0.3 0.0 0.0

Source: EEA (2018), Sweden Air Pollution country factsheet 2018. Available: https://www.eea.eu-

ropa.eu/themes/air/country-fact-sheets/sweden




and the implementation of other obligations laid down by the AAQ Directive.

At national level, overall responsibility for supervision and planning of air quality is assumed by

the Swedish Environmental Protection Agency at central level. As presented in section 2.2, the

Swedish EPA is also responsible for overall monitoring of air quality and transmission of data on

air quality to the EU level.

At regional and local level, the control function of air quality in urban areas is decentralised. As

such, municipalities (local authorities) control the air quality standards to ensure that the limit

and target values as per the AAQDs and the national legislation are met. In terms of assessment

regimes, the approach towards the control depends on the amount of population and, whether or

not, the municipality is part of collaborative areas or not. The controls are primarily carried out in

urban and in the most polluted areas.

When an environmental quality standard is exceeded, the municipality concerned informs the

Swedish EPA. The Swedish EPA assesses whether there is a need to establish an air quality plan.

In cases where an action plan is needed, the county administrative board or the municipality (by

delegation) coordinates its drafting and the implementation of the most appropriate and most

cost-effective measures. The affected municipalities and authorities are responsible for sharing

the responsibility for implementing the measures or instruments set out in the action plan.

In addition, in Sweden there are 12 air quality associations formed of counties, regions as well as

companies and government agencies. Several of the associations were set up in the 1980s and

follow counties' borders. Initially, they were set up due to the fact that acidification was a key

issue related to air pollution in Sweden and the associations were tasked to address the issue.

Presently, several of the associations have an important role in monitoring air quality in a regional

background and coordinating urban monitoring. The concrete work of the air quality associations

is to provide inventories of emission sources, measurement of air quality and meteorology, models

for spreading and depositing air pollutants. The difference with the regional and local authorities

is that such associations involve more stakeholders including companies.

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






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March 2019 17


Legal framework

The AAQDs have been implemented in Swedish legislation through the Environmental Code (SFS

1998: 808), the Air Quality Ordinance (SFS 2010:477) and the Swedish Environmental Protection

Agency Regulations on air quality control (NFS 2016:9). An "Air Quality Guide'' (Luftguiden) has

been published by the Swedish Environmental Agency.

The Air Quality Directives have been transposed into national legislation through the Swedish

Environmental Code (1998: 808) which set environmental quality standards 8that are legally bind-

ing. The standards were imposed to remedy the environmental impact of diffuse emission sources,

such as road traffic and agriculture. The Environmental Code is a framework that contains different

instruments to achieve the overall objective of sustainable development. Provisions on environ-

mental standards are mainly contained in chapter 5.

Swedish Air Quality Ordinance9 transposed into national legislation the provisions of the AAQDs

on the limit value. These are presented in the comparative table below.

Figure 2-5 Air quality limits per pollutant

Pollu-

tant

Average WHO

(Guideline

3)

SE Environmental

objective

Ambient air10

EU

Limit / (L)

Target / (T)

SE Environmental qua-

lity standards

Limit / (L)

Target / (T)

NO2 1 hour 200 μg/m3 60 μg/m3

Cannot exceed more

than 175 times /

year

200 μg/m³ (L)

Cannot exceed

more than 18

time/year

90 μg/m³ (L)

Cannot exceed more

than 175 times/year

provided that 200 μg/m³

is not exceeded more

than 18 times / year

Day - - - 60 μg/m³ (L)

Cannot exceed more

than 7 times/year

Year 40 μg/m3 20 μg/m3 40 μg/m³ (L) 40 μg/m³ (L)

NOx re-

gional

back-

ground

Year - 30 μg/m³ (L) 30 μg/m³ (L)

SO2 10 min 500 μg/m3 - - -

1 hour - - 350 μg/m³ (L)

Cannot exceed

more than 24

times / year

200 μg/m³ (L)

Cannot exceed more

than 175 times / year,

provided that 350 μg/m³

is not exceeded more


8 Environmental quality standards specify the level of pollution or disturbance to which the population may be exposed without any risk of significant detriment or to which the environment or nature may be exposed without any risk of substantial detriment. 9 Air Quality Ordinance, SFS 2010:477, 8 June 2010. 10 Kvävedioxid, PM10: Naturvårdsverket rapport 4995, 1999, Institutet för miljömedicin (IMM), Karolinska Institutet, Review of evidence on health aspects of air pollution-REVIHAAP Project, WHO Europe,2013; PM2,5, WHO Air Quality Guidelines Global Update 2005; Ozon Health risks of ozone from LRTAP WHO 2008.



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Pollu-

tant

Average WHO

(Guideline

3)

SE Environmental

objective

Ambient air10

EU

Limit / (L)

Target / (T)

SE Environmental qua-

lity standards

Limit / (L)

Target / (T)

Day 20 μg/m3 - 125 μg/m³ (L)

Cannot exceed

more than 3

times / year

100 μg/m³ (L)

Cannot exceed more

than 3 times / year

SO₂ re-

gional

back-

ground

Interim

Winter

- - 20 μg/m³ (L) 20 μg/m³ (L)

Year - - 20 μg/m³ (L) 20 μg/m³ (L)

PM10 Day 50 μg/m³ 30 μg/m³ (L)

Cannot exceed more


50 μg/m³ (L)

Cannot exceed

more than 35

times / year

50 μg/m³ (L)

Cannot exceed more


Year 20 μg/m³ 15 μg/m³ 40 μg/m³ (L) 40 μg/m³ (L)

PM2.5 Day 25 μg/m3 25 μg/m3 - -

Year 10 μg/m3 10 μg/m3 25 μg/m³ (T)

25 μg/m³ (L)

25 μg/m³ (T)

25 μg/m³ (L)

CO Highest

8h value

10 μg/m³ - 10 μg/m³ (L) 10 μg/m³ (L)

1 hour 30 μg/m³ - - -

30 min 60 μg/m³ - - -

15 min 100 μg/m³ - - -

Benzen Year 1.3 μg/m³

(IMM*)

- 5 μg/m³ (L) 5 μg/m³ (L)

Ozone Highest

8h value

100 μg/m³ 70 μg/m³ 120 μg/m³ (T)

Cannot exceed

more than 25

days / year

120 μg/m³ (T)

Pb Year 0.5 μg/m³ - 0.5 μg/m³ (L) 0.5 μg/m³ (L)

As Year - - 6 μg/m³ (L) 6 μg/m³ (L)

Cd Year 5 μg/m³ - 5 ng/m³ (L) 5 ng/m³ (L)

Ni Year - - 20 ng/m³ (L) 20 ng/m³ (L)

B(a)P Year 0.1 ng/m³

(IMM*)

- 1 ng/m³ (L) 1 ng/m³ (L)

*Institute of Environmental Medicine, Karolinska Institute.



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March 2019 19

Strategic framework

In addition to the strategic legal framework set by the Environmental Code, the Swedish Parlia-

ment adopted an overarching generational goal supported by 16 environmental quality objectives

and a number of milestone targets. These are closely related to the objectives set in the Environ-

mental Code. The 16 environmental objectives are presented in the box below.

Text box 2-2 Sweden's environmental quality objectives

The Swedish Parliament has adopted 16 objectives for environmental quality in Sweden:

1. Reduced climate impact

2. Clean air

3. Natural acidification only

4. A non-toxic environment

5. A protective ozone layer

6. A safe radiation environment

7. Zero eutrophication

8. Flourishing lakes and streams

9. Good-quality groundwater

10. A balanced marine environment, flourishing coastal areas and archipelagos

11. Thriving wetlands

12. Sustainable forests

13. A varied agricultural landscape

14. A magnificent mountain landscape

15. A good built environment

16. A rich diversity of plant and animal life

Several of the environmental objectives relate to the issue of air quality and pollutants, in partic-

ular, the environmental objective of Clean Air, which states that 'the air must be clean enough

not to represent a risk to human health or to animals, plants or cultural assets'.11 As such, the

government gives priority to improving air quality and reducing emissions to ensure a toxic-free

environment, ecosystems and biodiversity.

Furthermore, the environmental quality objective on Natural Acidification Only and Zero Eutroph-

ication are also linked to air quality and deposition. Sweden aims at reducing eutrophication

caused by excessive levels of nitrogen and phosphorus in soil and water generated by emissions

to air from road traffic, industry and international shipping. Similarly, Sweden's objectives also

focus on reducing the acidifying effects of deposition of sulphur dioxide, nitrogen oxides and am-

monia.

Air quality measures: air quality plans and air quality plans12

Drafting Air Quality Plans

If the monitoring of air quality indicates that specific standards are exceeded or at risk of being

exceeded, the municipality is obliged to immediately notify the Swedish EPA. The relevant county

board or municipality (by delegation) will then develop an air quality plan.

The purpose of the Air Quality Plans is to identify the most appropriate and cost-effective

measures to ensure compliance with the air quality standards. The Air Quality Plans normally

11 Swedish EPA, Sweden's Environmental Objectives. Available at: http://www.swedishepa.se/Docu-ments/publikationer6400/978-91-620-8620-6.pdf?pid=6759. 12 Swedish EPA, Action Programmes. Available at: https://www.naturvardsverket.se/Stod-i-miljoar-betet/Vagledningar/Luft-och-klimat/Miljokvalitetsnormer-for-utomhusluft/Atgardsprogram-for-luft/.

http://www.swedishepa.se/Documents/publikationer6400/978-91-620-8620-6.pdf?pid=6759




https://www.naturvardsverket.se/Stod-i-miljoarbetet/Vagledningar/Luft-och-klimat/Miljokvalitetsnormer-for-utomhusluft/Atgardsprogram-for-luft/






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include different authorities to build ownership and ensure their implementation, for example

public authorities in the transport sector, which is a main contributor to exceedances of air quality

standards. Air Quality Planss are reviewed as necessary and at least every six years.

According to Chapter 5 of the Environmental Code and Section 6 of the Air Quality Ordinance

2010: 477, the action programs have to include:

• where the exceedance of an environmental quality standard has occurred

• the type, size, weather conditions and object worthy of the protection of the are concerned

• the type of air pollution and how it has been observed

• the origin of the pollution

• the analysis of the situation which has been made

• improvement measures implemented and their effects

• ongoing improvement measures

• publications and other documents

The Air Quality Ordinance Section 27 also requires that the authorities responsible make publically

available and free of charge to the public the information on the action programme.

Today there are air quality plans for NO₂ and PM10 in 9 municipalities in the country. Work on

developing plans in other municipalities is ongoing. In the case of 4 municipalities, previous air

quality plans were considered to be completed and the environmental quality standards were

assessed to be achieved. These are Gothenburg (PM10, 2012), Norrkoping (PM10, 2015), Helsing-

borg (NO2), Malmo (NO₂, 2017) and Jönköping (PM10, 2019).13

Enforcement of Air Quality Plans

The enforcement of Air Quality Plans is generally an effective manner of tackling exceedances and

ensure that air quality standards are met. However, their effectiveness depends on the extent to

which the measures are actually enforced.

Collaboration between local and national authorities is considered to be key in enforcing air quality

plans. For example, the Gothenburg region had 2 air quality plans for NO₂. The implementation

of the first air quality plan was assessed to be effective only to a limited extent due primarily to

the fact that many of the measures included in the plan required action at Government or national

level (for example, measures to tackle pollution from state roads and ports). However, the support

from the Government level was not strong enough to enable the implementation of some

measures. The implementation of the current air quality plan for NO₂ (2017) is expected to lead

to better results as it contains measures that would require a change in laws or action to be taken

by authorities at national level. The drafting of the air quality plan was done in cooperation with

various authorities including amongst others the County Administrative Board, the Swedish

Transport Administration, the Gothenburg Region Municipal Association, the authority for public

transportation. Such cooperation is important to build ownership and enable measures that ad-

dress the sources of pollutants. For instance, in Gothenburg, pollution from state roads is main

source of concern. As such, the involvement of the Swedish Transport Administration, responsible

for state roads, is essential.

13 See: Action Programmes available at: http://www.naturvardsverket.se/Stod-i-miljoar-betet/Vagledningar/Luft-och-klimat/Miljokvalitetsnormer-for-utomhusluft/Atgardsprogram-for-luft/.

http://www.naturvardsverket.se/Stod-i-miljoarbetet/Vagledningar/Luft-och-klimat/Miljokvalitetsnormer-for-utomhusluft/Atgardsprogram-for-luft/






(2008/50/EC, 2004/107/EC)

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Member States are required (pursuant to Article 26 of the AAQ Directive) to ensure that the public

is informed adequately and in good time about air ambient air quality and other issues specified.

At national level, legal requirements of section 38 of the Swedish Air Quality Ordinance14 specifies

the measures to be implemented to ensure that the public is informed about air quality. As per

section 38, municipalities are required to provide information free of charge, through the Internet

or in other suitable manner on concentrations of NO₂, SO₂, CO, Benzene PM, BaP, As, Cd, Ni, Pb.

Municipalities are required to provide information on any exceedances of the levels of air quality

standards, any exceedances of the alert thresholds with regard to SO₂ and NO₂, information

related to what actions municipalities take with regard to such exceedances and the potential

consequences to health. The legislation requires that the information on exceedances be updated

every day for concentrations of NO₂, SO₂, CO, PM10. The information for BaP, As, Cd, Ni needs to

be updated at least every 12 months. For Benzene and Pb, the legislation requires that the infor-

mation be given in the form of an average for the past 12 months and updated every 3 months.

The Swedish EPA makes available data on air quality measured hour by hour in a large number

of Swedish urban areas for PM10, PM2.5, NOx and ground level ozone. Charts with data on the

measurements for the last 24 hours are made available to the public.15 The Swedish EPA's website

also makes available statistics on the current year for the main pollutants. Data is available and

easily accessible on: Nitrogen dioxide (daily average values), Ground-level ozone (eight-hour av-

erage values), Ground-level ozone (daily maximum eight-hour average values), Particles (PM10)

(daily average values) Particles (PM2.5) (daily average values), black carbon (daily average val-

ues). 16 Charts with data trends for the last 15-20 years are also available on the Swedish EPA's

website.17 Furthermore, the Swedish EPA makes available information on exceedances of limit

values as per the requirements of the national legal framework. Additionally, information on air

quality plans is available both on the Swedish EPA's website and on the municipalities or counties

administrations websites18.

At regional level, some municipalities and cities have considered additional information dissemi-

nation means. For example, Stockholm proposed a mobile app for air quality but in the end de-

cided not to have one. The rationale behind that was that the municipality wanted to have control

of the data due to the fact that such data could be subject to misinterpretation. Another example

is the city of Gothenburg where an app can be downloaded and used by the wider public called

'Air in Gothenburg' - 'Luften i Göteborg'.


According to stakeholders interviewed and desk research, Sweden has made limited use of EU

funding for air quality improvements. For example, research suggests that Sweden has not made

in the programming period 2014-2020 use of ESI funds to support air quality measures.

14 Air Quality Ordinance, SFS 2010:477, 8 June 2010. Available at: http://www.sea.gob.cl/sites/de-fault/files/migration_files/Normas_secundarias/Anexo_documental/Reino_de_Suecia/Aire/SUE-AI-03-SFS477.pdf. 15 See: Air quality in real time and preliminary statistics. Available at: http://www.naturvardsverket.se/real-tidsdataluft. 16 See: Air quality preliminary statistics for the current year. Available at: http://www.naturvardsver-ket.se/realtidsdataluft. 17 See: Air quality statistics quality controlled. Available at: http://www.naturvardsverket.se/luftenisverige 18 See for example: Air quality programs. Available at: http://www.naturvardsverket.se/Stod-i-miljoar-betet/Vagledningar/Luft-och-klimat/Miljokvalitetsnormer-for-utomhusluft/Atgardsprogram-for-luft/.

http://www.sea.gob.cl/sites/default/files/migration_files/Normas_secundarias/Anexo_documental/Reino_de_Suecia/Aire/SUE-AI-03-SFS477.pdf





http://www.naturvardsverket.se/realtidsdataluft








http://www.naturvardsverket.se/luftenisverige







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The LIFE Programme supported air quality actions in Sweden. A list of actions is presented in the

Appendix to the case study. For example, the project CLEANTRUCK - CLEAN and energy efficient

TRUCKs for urban goods distribution had as primary objective to demonstrate the commercial and

technical viability of alternative fuels and new technologies for vehicles for the distribution of

goods. The aim of the project was the overall reduction of GHG emissions but also other forms of

pollution. The innovations introduced by the project were envisaged to achieve annual reductions

of CO₂ emissions by 1,500 tonnes, NOx, pollution by 17 tonnes, noise pollution and the reduction

of generation of the breathable fraction of fine particles (up to 2.5 μm) by 240 kg. 19

The Swedish EPA also indicated that EU funding could be attracted to deal with the issue of wood

burning in households and support the transition to cleaner heating.

19 See: CLEANTRUCK - CLEAN and energy efficient TRUCKs for urban goods distribution. Available at: http://ec.europa.eu/environment/life/project/Projects/index.cfm?fuseac-tion=search.dspPage&n_proj_id=3462.

http://ec.europa.eu/environment/life/project/Projects/index.cfm?fuseaction=search.dspPage&n_proj_id=3462






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3 FINDINGS

This chapter presents detailed findings regarding the implementation of the AAQ Directives in

Sweden. Specifically, the chapter focusses on the challenges and success encountered in the

implementation of the Directives. Additionally, the relevance of the AAQDs, and their air quality

standards, has been explored. Finally, the chapter identifies the factors underlying compliance

with and effectiveness of the AAQDs and provides an overview of the costs and benefits associated

with the implementation of the Directives.


in the context of the case study. These were supplemented as relevant by additional desk re-



Although air pollution in Sweden is comparatively lower than in other EU countries, the AAQDs

are still highly relevant. Stakeholders consider the AAQ Directives to be relevant due to the fact

that they establish a clear legal framework for regulation of air quality, they ensure that monitor-

ing, and assessment of air quality is highly comparable and accurate. Furthermore, the AAQDs

incentivise action if issues are identified. Nevertheless, some stakeholders (i.e. Swedish EPA)

considered that a weakness of the AAQDs is that there is a lot of detail when it comes to publishing

data at EU level.

Eurobarometer data shows that air quality continues to be a source of concern for citizens. As

presented below, 46% of respondents considered the air quality to have stayed the same over

the past 10 years, although improvements in air quality have been registered in Sweden.

Figure 3-1 Do you think that, over the last 10 years, the air quality in (OUR COUNTRY) has…?

Source: Eurobarometer, 2017

Relevance of pollutants and binding targets

Evidence collected for the case study indicates that the pollutants regulated by the AAQDs are

relevant for Sweden. However, Swedish authorities consider that the air quality standards and

limits set by the AAQDs are not sufficiently strict. The limits could be reinforced for example

through the implementation of a binding PM2.5 daily limit value. The Swedish regulatory framework

even goes beyond the requirements of the AAQDs by setting even stricter values for NO₂ (alt-

hough there is a difference in the statistical indicator – number of allowed exceedances) and for



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March 2019 24

SO₂ and O3. Since the standards in Sweden are stricter than the EU limit values, Sweden is having

difficulties in reaching the national standards for these pollutants.

Sweden also has stricter national standards for SO₂ and O3. The standards set by the AAQ Direc-

tives were considered to be relevant by stakeholders consulted and even not going far enough in

setting strict values. Furthermore, enforcement of the air quality limits appears to be an issue as

for example for NO₂, neither the Swedish nor the EU limit value are enforced. Enforcement issues

are also generated by the absence of remedies in case of non-implementation of air quality plans

which is not provided for in the Swedish legislation.

Ozone requirements have been challenging. The provisions in the Directive are quite complicated,

open to interpretation and not well suited for the Swedish conditions (the Directives assumes high

concentrations in cities but many cities in Sweden are sub-urban and substantive pollution comes

from long-range transport of pollutants). As such, sub-urban stations to monitor ozone pollution

would be needed. Sweden has found a pragmatic manner to monitor this as it conducts extensive

modelling which is a good source of information on the levels of pollution from ozone.

Relevance of provisions to draft and implement air quality plans

The provisions requiring authorities to draft and implement air quality plans are also considered

to be relevant but not going far enough. For example, some consulted stakeholders considered

that the AAQ Directives air quality plans could be given legal status to ensure better enforcement.

Relevance of provisions on monitoring air quality

The AAQDs ensure that there is monitoring and assessment that is highly comparable and accu-

rate. However, the requirements of the AAQDs are considered to impose a substantive burden on

the authorities to publish data. Furthermore, monitoring varies across municipalities and regions.

For example, monitoring in large cities is considered a priority whereas sampling points in medium

sized and small cities is limited. This raises the question of whether monitoring requirements meet

the needs of the citizens as they would prefer that monitoring be done as close to their location

as possible for an accurate depiction of pollution levels.


The present section highlights the key implementation successes of AAQDs in Sweden.

3.2.1 Guidance on the implementation of the AAQDs

As previously highlighted, Sweden has developed a comprehensive Guide for air quality – Hand-

book for Environmental Quality Standards for ambient air (version 4, 2019).20 The guide is very

comprehensive (approximately 300 pages) and contains all information on the planning, control

and management of air quality in Sweden, reporting, modelling, publication of information on air

quality. According to stakeholders interviewed (EPA), since the publication of the guide, the Swe-

dish EPA received fewer questions concerning the implementation of the AAQDs.

Furthermore, in the last few years, more practical guides have been drafted by the Swedish EPA

to ensure the implementation of the AAQDs, in particular: a Guide on objective estimation, three

Guides on modelling (on how to model for Air quality plans, reporting for modelling data and on

practical aspects of modelling) and a Guide on quality assurance and quality control (QAQC).

20 Swedish Environmental Protection Agency, Guide for air quality – Handbook for Environmental Quality Standards for ambient air. Available at: http://www.naturvardsverket.se/Documents/publikationer6400/978-91-620-0182-7.pdf?pid=24067.

http://www.naturvardsverket.se/Documents/publikationer6400/978-91-620-0182-7.pdf?pid=24067






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3.2.2 Reference Laboratory for modelling

The Reference Laboratory for Urban Air Measurements is a support function for the municipalities

of Sweden on behalf of the Swedish EPA. The purpose of the Reflab is to serve as a national node

when it comes to questions concerning air quality measurements made in the country. The deci-

sive reason for establishing a reference laboratory for air quality measurements were the require-

ments of the AAQDs. The directive states that each Member State in the EU should have a national

reference laboratory. In Sweden, the requirement was translated into a Reference Laboratory

focussing on measurements and one focussing on modelling. Ensuring the quality of Sweden's air

quality measurements could be done by securing that the methods and instruments that perform

the measurements have sufficient high quality. The Reference Laboratory makes assessments of

the application for approval of measuring instruments. The Swedish EPA uses the assessments as

a basis for deciding which instruments are to be approved for air quality control in Sweden. In

addition to this, Reflab also carries ongoing control of automated instruments that measure par-

ticulate matter (PM10 and PM2.5) in order to verify that they work in the environment and in the

conditions we have in Sweden. The Reflab drafted a Manual for Quality Assurance / Quality Con-

trol.

3.2.3 Dialogue between authorities

Close dialogue between authorities is of great importance for the implementation of the require-

ments of the AAQDs. The EPA arranges meetings with municipalities and air quality associations

on how to improve monitoring. For example, a 2-day seminar for municipalities took place, which

dealt with both basics (for new employees) and the details of monitoring. The seminar was well

received by participants and the EPA plans to hold such seminars regularly. The EPA also gets

invited on an irregular basis to the municipalities, counties and associations for discussions and

clarifications regarding the monitoring.

3.2.4 Availability of information to the public

Public awareness and information has a critical role in addressing air quality pollution. Research

conducted for this case study indicated that the information provided by the Swedish authorities

is easily accessible to the public and of good quality. As presented in section 2.5 of the case study,

the Swedish EPA presents air quality measurements data for various pollutants, information on

exceedances of pollutants as well as the air quality plans adopted. Some of the information on air

quality measurements is presented in real time.

Furthermore, according to the Swedish EPA, 2-3 times a year a newsletter is sent to municipali-

ties, other relevant authorities, air quality associations and some private parties to inform them

of the air quality progress made, news regarding regulations and guidance etc.

3.2.5 Measures to regulate road traffic

Low emissions zones

According to the Traffic Ordinance (1998:1276), municipalities have the right to exclude heavy

trucks and busses that do not comply with emission standards within designated environmental

zones. Low emission zones already exist in eight municipalities. Recently, the Government intro-

duced a new type of low emission zone setting standards for lighter trucks and cars and low

emission zones for purely electric cars, fuel cell cars and gas cars that meet the emission standard

Euro 6.21

21 Government Office of Sweden. Available: http://ec.europa.eu/environment/archives/air/pdf/docu-ments/pos_paper.pdf.

http://ec.europa.eu/environment/archives/air/pdf/documents/pos_paper.pdf






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Table 3-1 Vehicles permitted in various types of low emission zones

Low emission

zones

Light vehicles (cars, light lorries, light buses up to 3.5

tonnes)

Heavy vehicles

Class 1 Vehicles need to comply

with the Euro 5 emission

class and are allowed to

drive in the environmental

zone until the end of 2020

Class 2 As of 1 January 2020:

Cars with compression ignition engines (diesel, hybrid,

electric, plug-in hybrid) in Euro 5 or better

Cars with spark-ignition engines (petrol, hybrid electric,

plug-in hybrid, natural gas, E85) in Euro 5 or better

Electric cars

Fuel cell cars

As of July 2022:

Cars with compression ignition engines (diesel, hybrid,

electric, plug-in hybrid) in Euro 5 or better

Cars with spark-ignition engines (petrol, hybrid electric,

plug-in hybrid, natural gas, E85) in Euro 5 or better

Electric cars

Fuel cell cars

Class 2 does not include

heavy vehicles

Class 3 Electric cars

Fuel cell cars

Cars that run on natural gas Euro 6

Electric vehicles

Fuel cell vehicles

Plug-in hybrid vehicles

Source: Government Office of Sweden. Available: https://www.regeringen.se/pressmeddelan-

den/2018/03/regeringen-ger-besked-om-miljozoner/.

According to stakeholders consulted, although air quality rules on zones are in place, the extent

to which they are used by politicians at local level varies. In some municipalities, it is assessed

that such measures are not needed due to the development of cleaner engine for cars, which will

reduce by default the emission problem from traffic.

The steps taken to reinforce further the implementation of low emission zones is considered to be

a consequence of the AAQDs.

Measures to restrict the use of studded tires

The use of studded tires is considered to contribute to the formation of particles (PM), which has

detrimental health effects. To reduce the use of studded tires, several measures were considered.

Measures related to studded tires are considered to be a consequence of the implementation of

the AAQDs in Sweden.

At national level, the Swedish Transport Authority has implemented changes in the rules for us-

ing studded tires. Since 2010, the season for the use of studded tire has been shortened by 14

days in the spring. Now, in the period 16th April to 30th September, the use of studded tires is

banned unless it is a winter road.

Furthermore, since July 2013 there has also been a limitation imposed on the number of stud-

ded tires that are newly manufactured. The change resulted in an average reduction in the

number of tires in the tires by approximately 15% compared with previously applicable rules.

https://www.regeringen.se/pressmeddelanden/2018/03/regeringen-ger-besked-om-miljozoner/






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Since 2009, some municipalities have decided to ban the use of studded tires for certain roads

(Regulation 2009: 985). The measure is considered to be a result of the implementation of the

AAQDs in Sweden. Such prohibitions have been announced for Hornsgatan, Fleminggatan and

Kungsgatan in Stockholm, Odinsgatan / Friggagatan in Gothenburg and Kungsgatan in Uppsala.

The purpose of the ban is to increase air quality on the specific streets. According to a study

conducted on the implementation of the ban, the findings suggest that the proportion of vehi-

cles with studded tires decreased from 40% to 30% after the implementation of the ban on

Fleminggatan and Kungsgatan. Furthermore, traffic has decreased from 17,900 to 15,600 vehi-

cles per day on Fleminggatan and from 14,800 to 13,700 vehicles per day on Kungsgatan. Cal-

culations have indicated that the concentrations of PM10 on Fleminggatan and Kungsgatan have

decreased by 21% and on Kungsgatan with 17% in January through May 2016. This was a re-

sult of the reduced use of studded tires and reduced traffic.22

In some cities (e.g. Stockholm), information campaigns have been carried out for several years

to make drivers more aware of the consequences of use of studded tires and to discourage their

use. Although the action by itself is not sufficient to meet the environmental standards for parti-

cles, it does positively contribute to raising awareness and influencing the behaviour of drivers.

Reduces speed on some streets

Emissions on roads generally increase with higher speeds. Therefore, by regulating and reducing

the speed on certain streets, the levels of pollution in the air may decrease. This type of action

has been taken amongst others in the cities of Stockholm, Gothenburg, and Uppsala and on the

routes of the national roads E4 and E18. The measure has been implemented by the Swedish

Transport Administration and is considered to have had a positive effect on reducing emissions

levels on state roads.

Dust binding

The Swedish Transport Administration also implemented a number of measures with local and

regional plan for better air quality. A saline solution, CMA – calcium magnesium acetate, is sprayed

onto the roadway to keep it moist, thus preventing dust from being emitted and decreasing the

particulate content (PM10) in the air. Dust binding to reduce particulate levels is one of the

measures that have been implemented in Stockholm, Gothenburg, Jönköping, Norrköping, Upp-

sala and Örnsköldsvik. In Stockholm, an evaluation of the efforts made to reduce PM10 levels

through dust binding indicates that in 2015-2016, the limit value for PM10 was not exceeded for

the 2015–2016 season for the third consecutive year, but the number of days with PM10 levels

over the limit value was higher than in the previous season, which had a record low number of

exceedances.23

22 Michael Norman (2016), Evaluation of a studded tire ban on Kungsgatan and Fleminggatan. Available at http://slb.nu/slb/rapporter/pdf8/slb2016_008.pdf. 23 Mats Gustafsson et al. (2016), Operational measures against PM10 pollution in Stockholm. Available at http://vti.diva-portal.org/smash/get/diva2:1111887/FULLTEXT01.pdf.

http://slb.nu/slb/rapporter/pdf8/slb2016_008.pdf

http://vti.diva-portal.org/smash/get/diva2:1111887/FULLTEXT01.pdf



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Improved weather cleaning after the winter season

An intensified and timely sanding up after the winter season is performed in, among others, Upp-

sala and Stockholm. In the immediate vicinity of sanding, the streets are then cleaned with vac-

uum suction or high-pressure washing to reduce the particulate content (PM10) in the air.



3.3.1 Division of responsibilities

One key implementation challenge is the fact that Sweden has a decentralised system for as-

sessing and managing air quality, which creates issues in terms of delineation of responsibilities

amongst authorities. Although de jure the Swedish Environmental Protection Agency Regulations

on air quality control outlines fairly clearly the distribution of responsibilities, in practice there is

confusion about the division of responsibilities for meeting air quality standards. The Swedish EPA

provides guidance but it is up to municipalities to ensure that the provisions are respected. Nev-

ertheless, municipalities claim to the Government that they do not have the tools needed to com-

ply and that action should be taken at national level. As such, some stakeholders (i.e. Swedish

EPA) suggest that a more centralised approach would improve efficiency of implementation. For

example, more powers to coordinate to the Swedish EPA could also mean that the EPA would be

able to control the exact amount of sampling points and ensure that the data from monitoring is

accurate. Furthermore, in some cases, measures are developed by municipalities without the

actual mandate for implementing them, as they would fall in the remit of responsibility of the

Government.

As per Swedish legislation, municipalities can engage into 'collaborative areas' (or air quality as-

sociations) which are cooperation set-ups between mainly municipalities, but regional governance

and businesses as well. The associations draft the strategies and renew them every year. The

associations are mainly on the level of counties but sometimes they can be larger (e.g. Stockholm)

or even smaller (e.g. Gothenburg). The strategies control the assessment of air quality. If there

is an exceedance, the associations monitor the situation and the municipalities report to the EPA.

However, it is up to the county board or municipality (by delegation) to produce an air quality

plan. In theory, the system is good as it is aimed at improving efficiency. However, in practice,

there may be cases where municipalities assume that the issue is dealt with by the collaboration

area when in reality the issue is not addressed at any level.

3.3.2 Enforcement of air quality plans

Air quality plans are reported to EU by the Swedish EPA. As such, theoretically, the Swedish EPA

should be amongst the stakeholders that are consulted when developing the action plan. The EPA

normally comments on the plans – providing advice on modelling, source apportionment, quanti-

tative information etc. However, in some occasions it was reported that the EPA had not been

involved in the development of air quality plans.

Furthermore, consulted stakeholders reported that sometimes air quality plans included measures

that were not always relevant – e.g. bike lanes in areas not affected by an exceedance. Such

situations are an indication that air quality plans are sometimes used by municipalities to steer

the broader environmental work and not necessarily to address the issue of air pollution, which

also positively contributed to the improvement of air quality. Additionally, in some cases,

measures proposed in the air quality plans fell outside the remit of responsibility of authorities

that were enforcing them, which made their implementation unviable.



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Air quality plans are sometimes perceived more as administrative burdens by the authorities. As

a result, many tend to contain generally acceptable actions and the measures are not always

effective and efficient.

3.3.3 Reporting requirements and human resources

EU reporting are considered to require substantive resources to modernise information exchanges.

Authorities in Sweden consider the reporting requirements arising from the AAQDs as being too

comprehensive and cumbersome. Mandatory data is considered to be not always necessary. As

such, a need for a more flexible system was highlighted by authorities during interviews.

Limited human resources and funds in municipalities to deal with the requirements of the AAQDs

are another challenge. EU reporting requires a lot of resources to modernise the information ex-

change system to meet the reporting requirements. Reporting requirements are considered to be

too comprehensive and in need to be streamlined, which in turn would reduce the amount of

resources necessary.



with and effectiveness of the AAQ Directives in Sweden. The factors have been identified through

stakeholder consultation conducted in the context of the case study. The views have been corre-

lated with information gathered through desk research.


The main factors underlying compliance and effectiveness of AQ measures and of the AAQDs in

Sweden include amongst others.

Consequences of non-compliance

The commitment of Swedish authorities to ensure that air quality standards are respected is also

incentivised by the risk of consequences for not complying with the standards. Pressures from the

public to ensure air quality standards are also considered an important factor underlying compli-

ance and effectiveness. For example, the action taken by the European Commission for exceed-

ances of PM10 led to the introduction of measures to reduce daily exposure. The absence of

enforcement mechanisms in Sweden was considered by stakeholders to have negative conse-

quences on the levels of concentrations of pollutants in the air.

National implementation guidance

One important factor underlying compliance was the production of guidance and standards for

ensuring that air quality standards are met. As presented in section 3.2, the Swedish EPA pro-

duced an Air Quality Manual (which has been recently updated) which contains detailed guid-

ance on the air quality standards, performance of monitoring of air quality pollutants and other

useful information for county administrations, municipalities and other authorities involved in air

quality control.

Furthermore, the existence of a national Reference Laboratory for modelling and the guidance

drafted by it (e.g. the Quality Assurance and Quality Control manual) contributed to a harmo-

nised assessment of air quality levels across Sweden.



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March 2019 30


Insufficient monitoring stations

According to consulted stakeholders, for some types of pollutants, Sweden does not have enough

monitoring stations. For example, some municipalities in the North of Sweden should have stricter

monitoring requirements than they currently have in force for BaP levels due to the wood burning.

Availability of resources and staff

There are certain variations in terms of the level of commitment of municipalities to monitor air

quality standards across Sweden. The variations are also dependent on the level of staffing and

financial resources of the municipalities. In some municipalities and cities, additional resources

would be important to ensure a better enforcement of the rules. For instance in Gothenburg,

interviews with local stakeholders indicated that the air quality plan set in place in 2017 could

have been improved (e.g. with more modelling) provided that more resources would have been

available.



Presently, there are no economic analyses of the costs of implementation of the AAQDs in Sweden.

Furthermore, the decentralised Swedish system makes it very difficult to obtain accurate esti-

mates of costs.

Overall, the Swedish EPA reported that it has a budget for AAQ of 400,000 EUR per year. The

Swedish EPA estimated that approximately 200,000-300,000 of its AAQ budget goes to the im-

plementation of the AAQD per year.

Estimates provided by the Swedish EPA concerning the costs of assessment of ambient air quality

(costs of measurement, calculation, predictions or estimations) as required by the AAQDs is pre-

sented below.



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Table 3-2 Total estimated annual cost for all fixed measurements

NO₂ PM10 PM2.5 CO O3

Total number of fixed AQD measure-

ments

41 41 6 2 27

Total number of fixed EoI measure-

ments that are relevant to include

7 15 2 1 0

Estimated annual cost per fixed meas-

urement site (SEK)

135,000 135,000 135,000 135,000 135,000

Total estimated annual cost for fixed

measurement per pollutant (SEK)

6,480,000 7,560,000 1,080,000 405,000 3,645,000

Total estimated annual cost for all

fixed measurements (SEK)

19,170,000

Total estimated annual cost for all

fixed measurements (EUR)

1,859,490

Source: Estimates provided via email by the Swedish EPA

According to the Swedish EPA, the majority of the requirements related to the number of fixed

measurements were in place even before the 2008 AAQD. This means that the additional costs

incurred as a result of the implementation of the 2008 AAQD were reduced.

The development and approval of the measurement system (e.g. standardised methods, calibrat-

ing equipment, engaging in networks and running laboratories) is primarily by the Reference

Laboratory for Urban Air Measurement commissioned by the Swedish Environmental Protection

Agency. Estimates of the contract of the Reference Laboratory with the Swedish EPA provided by

the Swedish EPA suggest that the costs for relevant activities related to the development and

approval of the measurement system are approximately EUR 1.5 million.

When it comes to estimates of the costs of data analysis and assessment methods, the Swedish

EPA indicated that the national costs, for the Reference Laboratory to check the quality of reported

monitoring data is approximately EUR 50,000 per year. However, data validation and ratification

is the responsibility of the local and regional operators, so significant additional local and regional

costs are not included in the afore-mentioned total.

The amount and scale of air quality modelling carried out in Sweden varies from one year to

another. However, there is no concrete estimate of the total costs for this. The Swedish EPA

conducts national modelling of regional background concentrations of ground-level ozone, nitro-

gen dioxide and sulphur dioxide. The total annual cost for such modelling is estimated by the

Swedish EPA to be approximately EUR 65,000, but it also includes modelling of deposition, which

is not required by the AAQD. Furthermore, modelling is carried out on an urban-scale at a local

and regional level, but no concrete estimates of costs are available.

At regional level, some estimates on costs of monitoring were provided by the Gothenborg County

Administrative Board on the regional monitoring done as part of the “The Swedish Throughfall

Monitoring Network”. The County Administration Board is responsible for four measurement sta-

tions in Västra Götaland: Hensbacka, Stora Ek, Storskogen and Humlered. The cost for these



(2008/50/EC, 2004/107/EC)

March 2019 32

four stations is around EUR 30,000 [300,000 SEK] excl. VAT per year. The costs includes every-

thing from sampling to reporting.24 The County Administration Board also has regional monitoring

of ground level ozone, which is part of a network in the south of Sweden. The part of the costs

for the County Administrative Board of the network is about EUR 6,300 [65,000 SEK] excl. VAT

per year. This includes everything from sampling to reporting.25

According to the Swedish EPA, without the EU legislation in place there would still be monitoring

done in Sweden.


Although Sweden is one of the EU countries with lower background concentrations of air pollutants

in urban areas, health impacts of exposure to ambient air pollution still represent an important

issue, especially since the concentration levels of NO₂, PM10 and PM2.5 exceed the air quality stand-

ards at street level in several urban areas.

The EEA estimates that premature deaths due to air pollution exposure in Sweden are below the

EU average but they still constitute a source of concern. The table below presents the premature

deaths attributable to PM2.5, NO₂ and O3 exposure in Sweden, EU-29 and total EEA-33 in 2015.

Figure 3-2 Premature deaths attributable to air pollutants (2015)

Country Popula-

tion

(x1,000)

Annual

mean

(PM2.5)

Prema-

ture

deaths

(PM2.5)

An-

nual

mean

(NO2)

Prema-

ture

deaths

(NO2)

Somo35

(O3)

Prema-

ture

deaths

(O3)

Sweden 9,747 5.9 3,000 10.8 110 2,080 140

EU-28 506,030 12,9 391,000 18.9 76,000 4,250 16,400

EEA-33 538,278 14.1 422,000 18.8 79,000 4,310 17,700

Source: EEA (2018), Sweden Air pollution Country Factsheet 2018

In the Environmental Implementation Report – Sweden, it was estimated that the health-related

external costs for air pollution in Sweden are above EUR 3 billion/year (income adjusted, 2010),

which include not only the intrinsic value of living a full health life but also direct costs to the

economy. These direct economic costs relate to 803 thousand workdays lost each year due to

sickness related to air pollution, with associated costs for employers of EUR 111 million/year

(income adjusted, 2010), for healthcare of above EUR 11 million/year (income adjusted, 2010),

and for agriculture (crop losses) of EUR 48 million/year (2010).26

In a study conducted by the Swedish Environmental Research Institute and Umeå University es-

timated that every year over 5,000 people die prematurely due to air pollution in Sweden. The

study focussed on the effects of NO₂, PM2.5 and PM10. The study estimated that approximately

3,500 premature deaths per year were caused by exposure to PM2.5 when assuming no division

24 See: http://krondroppsnatet.ivl.se/ 25 See: http://ozonmatnatet.ivl.se/ 26 These figures are based on the Impact Assessment for the European Commission Integrated Clean Air Package (2013)

http://ozonmatnatet.ivl.se/

http://ozonmatnatet.ivl.se/



(2008/50/EC, 2004/107/EC)

March 2019 33

between sources and using an exposure-response coefficient of 6.2 per cent per 10 μg/m3. As-

suming a division between sources, it was estimated that non-local sources caused over 3,000

premature deaths per year (exposure-response coefficient 6.2% per 10 μg/m3), and that resi-

dential wood burning caused over 1,000 premature deaths per year. A higher exposure-response

coefficient of 17% per 10 μg/m3 was used for these primary combustion particles. Additionally,

it was estimated that approximately 1,300 premature deaths per year were caused by locally

generated vehicle exhaust using NO₂ as indicator and approximately 200 premature deaths per

year were caused by road dust. 27

Furthermore, the study estimated that the health effects related to annual mean levels of NO₂ in

2010 were between SEK 7 and 25 billion (cca. EUR 700 million and EUR 2.4 billion), depending

on whether a threshold of 5 μg/m3 was included or not. Furthermore, welfare losses due to expo-

sure to PM pollutants from road dust, residential wood burning and other sources were valued at

SEK 35 billion (cca. EUR 3.3 billion), of which approximately SEK 6.5 billion (cca. EUR 630 million)

were linked to productivity losses, i.e. days when people are limited in their normal activities

causing a loss of work days. The amount of work and study days lost constituted about 0.3% of

the total amount of such days in Sweden in 2010. Using the division between PM sources and

NO2 (with a 5 μg/m3 cut-off) as an indicator of traffic combustion, the total annual socio-economic

cost was estimated to be approximately SEK 42 billion (cca. EUR 4 billion).28

In 2018, the Swedish Environmental Research Institute and Umeå University updated the study

with data for 2015. The findings of the new study indicated that neatly all Swedish population was

exposed to concentrations below the environmental standards, and 97%, 78% and 77% was

exposed to concentrations below the respective specifications of the environmental objective for

NO₂, PM10 and PM2.5. Exposure to high concentrations was found in some polluted central parts of

large cities. In contrast to the results of the 2010 assessment (see above), the findings showed

an increase in mean population exposure to NO₂ and PM and a slight increase in the percentage

of population exposed to concentrations above the objective for NO₂. Particles concentrations

were found to show a decreasing trend in Sweden, resulting in reduced exposure to high PM

concentrations in urban centres.

27 Malin Gustafsson, Bertil Forsberg, Hans Orru, Stefan Åström, Haben Tekie, Karin Sjöberg (2014), Quantifi-cation of population exposure to NO2, PM2.5 and PM10 and estimated health impacts in Sweden 2010. Avail-able at: https://www.ivl.se/download/18.343dc99d14e8bb0f58b76b7/1446478779885/B2197.pdf 28 Ibidem.

https://www.ivl.se/download/18.343dc99d14e8bb0f58b76b7/1446478779885/B2197.pdf




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Table 3-3 Calculated population exposure to NO2 and particles in ambient air in 2005, 2010 and 2015

respectively

2005 2010 2015

Total population 8,899,724 9,546,546 9,839,105

Mean population weighted ex-

posure (µg/m³)

NO₂ 6.3 6.2 6.4

PM10 13.0 12.0 12.5

PM2.5 9.8 8.6 8.3

Percentage of population ex-

posed to concentrations above

the environmental objective

NO₂ (20 µg/m³) 2,3% 2,7% 2,9%

PM10 (15 µg/m³) 38% 25% 22%

PM2.5 (10 µg/m³) 49% 28% 23%

Percentage of population ex-

posed concentrations above the

environmental quality stand-

ards

NO₂ (40 µg/m³) 0% 0% 0%

PM10 (40 µg/m³) 0,4% 0,3% 0,3%

PM2.5 (25 µg/m³) 0% 0,6% 0,6%

Source: Malin Gustafsson et. al (2018), Quantification of population exposure to NO₂, PM2.5 and PM10 and

estimated health impacts. Available at: http://projects.cowiportal.com/ps/A104859/Documents/Exter-

nals/Task%201%20and%205%20-%20Deliverables/4.%20Final%20Deliverables/Case%20studies/Fi-

nal%20country%20reports%20to%20be%20submitted/Case%20Study%20Report_Bulgaria_FINAL.docx.

The findings of the study suggested that the number of premature deaths due to air pollution was

estimated to be higher in 2015 compared to 2010, i.e. 7,600. The increase in comparison to the

2010 estimate is not due to changes in the estimated exposure, but resulting from a revision of

assumed exposure-response relations. If for the 2010, the urban NO₂ contribution to increase

mortality had assumed without any cut-off, the estimates would have been almost the same as

in 2015. The study estimated that approximately 3,600 deaths per year were associated with

exposure to regional background (long-distance transported) concentrations of PM2.5. On average,

each premature death represents over 11 years of life lost. The main sources for mortality were

assumed to be locally emitted particles. Wood burning was estimated to cause more than 900

deaths per year, but the exposure estimate is uncertain.

The study also estimated that the health impacts from exposure to NO2 and PM2.5 could be con-

servatively estimated to cause socio-economic costs of approximately SEK 56 billion (cca. EUR

5,4 billion) in 2015. Just absence from work and studies can be estimated to cause socio-economic

costs of approximately 0.4% of GDP in Sweden.

http://projects.cowiportal.com/ps/A104859/Documents/Externals/Task%201%20and%205%20-%20Deliverables/4.%20Final%20Deliverables/Case%20studies/Final%20country%20reports%20to%20be%20submitted/Case%20Study%20Report_Bulgaria_FINAL.docx








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Table 3-4 Annual socio-economic costs of high long term air pollution levels in Sweden, 2015

Socio-economic cost of

health effect [million

SEK2015/case]

Health effects from an-

thropogenic sources

Socio-economic cost

of health effect [mil-

lion SEK2015]

Total Sweden 55,509

Out of which:

Value of prevented fatality

(VSL*/VPF

5.66 7,412 41,938

RAD (age group 0-14, 65-) 0.001 2,590,006 1,378

RAD (15-64) 0.001 4,509,911 6,678

Chronic Bronchitis 2.20 723 1,589

MI incidence 0.43 774 332

Stroke incidence 2.03 874 1,772

MI illness 1.50 774 1,163

Stroke illness 0.76 874 661

VSL = Value of Statistical Life Source: Malin Gustafsson et. al (2018), Quantification of population exposure to NO₂, PM2.5 and PM10 and estimated health impacts. Available at: http://naturvardsverket.diva-por-tal.org/smash/get/diva2:1242584/FULLTEXT01.pdf.

Another study focussing on the economic benefit of improvements in children's health resulting

from reduction in air pollution calculated the benefit of a reduction in children's exposure of 1

µg/m³ of NO2 in Stockholm and Umeå. The calculation was done for two endpoints, i.e. that

children having wheeze develop asthma and that asthmatic children are admitted to hospital due

to respiratory symptoms. According to the study, a reduction in exposure in the Greater Stock-

holm area would generate a benefit to society of SEK 168 million (cca. EUR 16 million) per year

because of fewer cases of child asthma, and SEK 47,000 (cca. EUR 4,500) due to fewer hospital

admissions (for the price levels in 2000). For Umeå the benefits are smaller, SEK 8 million (cca.

EUR 780,000) and SEK 2,000 (cca. EUR 200) per year.29 Subsequently another report on Air &

Environment pointed out the short and long-term health effects of air quality on children30.


Several types of benefits were reported by stakeholders interviewed arising from the AAQDs im-

plementation, in particular:

As presented above, air quality in Sweden has improved considerably compared to previous dec-

ades and part of this improvement can be assessed to be a result of the enforcement of the AAQDs

but also of stricter measures at national levels. In addition to the AAQDs, other measures taken

by Sweden as a result of both European (e.g. NEC Directive) and international commitments (e.g.

29 Lena Nerhagen, Tom Bellander, Bertil Forsberg (2013), Air pollution and children's health in Sweden. An enquiry into how the economic benefit of improvements in children's health resulting from reductions in air pollution can be assessed. Available at: https://www.naturvardsverket.se/Documents/publika-tioner6400/978-91-620-6585-0.pdf?pid=9678. 30 Swedish EPA (2017), Air and Environment, Children's Health. Available at: https://www.naturvardsver-ket.se/Om-Naturvardsverket/Publikationer/ISBN/1300/978-91-620-1303-5/

http://naturvardsverket.diva-portal.org/smash/get/diva2:1242584/FULLTEXT01.pdf




https://www.naturvardsverket.se/Documents/publikationer6400/978-91-620-6585-0.pdf?pid=9678




https://www.naturvardsverket.se/Om-Naturvardsverket/Publikationer/ISBN/1300/978-91-620-1303-5/






(2008/50/EC, 2004/107/EC)

March 2019 36

CLRTAP) have also contributed to reducing emissions from pollutants, in particular pollutants af-

fecting vegetation and ecosystems (SO2 critical level, NOx critical level, Ozone AOT40). For ex-

amples, Sweden registered improvements in terms of ozone levels as a result of reduced emis-

sions in Europe.

In addition to improving the air quality, the AAQDs requirements were also considered to have

brought positive effects when it comes to political commitment of authorities to improve air qual-

ity. Although there is a general awareness and commitment of the authorities to ensure good air

quality, there are cases where it has been reported that the responsibility was not assumed by

the relevant authorities (for instance, when there was a need to enforce a specific measure). In

this sense, the AAQDs have helped incentivise political action by enabling the public to put pres-

sure on the authorities. Furthermore, general stigma associated with infringement procedures is

taken seriously by Swedish authorities and remedy action is taken to avoid such situations. This

was the case with PM10, where the European Commission took action against Sweden. This was

considered to be an important incentive for political action at national level.

Exceedances on PM10 and NO₂ have led to the implementation of air quality plans and measures

to prevent pollution from traffic. Such measures include a ban on studded tires, shortened sea-

son for studded tires, strengthened requirements for manufacturing studded tires, low emission

zones.

According to consulted stakeholders, the need to set in place measures to mitigate pollution

caused by actions in other sectors has also led to increased cooperation and horizontal action in

Sweden. Although authorities in Sweden collaborated even before in the implementation of air

quality measures (for example, municipalities and public transport authorities), more recently

an increased involvement of the national level can be noted in the implementation of air quality

plans and measures to ensure air quality (see section 3.2). For example, in the implementation

of traffic control measures, the National Transport Administration has become more involved to

enforce measures that would reduce air pollution on state and local roads.

As further presented in section 3.2, desk research and consultation of stakeholders indicates that

the implementation of the AAQDs also meant increased harmonisation of the approaches to mon-

itoring. Sweden also put in place Reference Laboratories for monitoring and modelling of air qual-

ity, which focusses on defining common methods for monitoring, modelling, and established clear

quality control and quality assurance methods and rules outlined in a comprehensive manual.

The AAQDs and the 2011 Implementing Decision have incentivised Sweden to set up a national

system for real time data (see section 2.5). This, in turn, means improved information flow to the

public. Increased flow of information to the public also means that people are more aware of air

quality, which leads to changes in their behaviour.



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4 CONCLUSIONS

The present chapter contains e summary of the main findings of the case study regarding the

main implementation challenges the potential for improving the implementation of the Directives

in Sweden. Finally, a summary of the evaluation of the AAQDs is presented.


the Directives

The case study identified the following challenges in the implementation of the AAQ Directives in

Sweden.

• The need to strengthen the air quality standards, in particular establishing a PM2.5 hourly

limit (see page 23);

• The minimum number of monitoring stations in the AAQ Directive and in Sweden to ensure

more complete and adequate monitoring in some areas e.g. big cities and collaborative areas;

• Legal status of air quality plans in the AAQ Directives and actions for remediation in case of

non-implementation of measures set in the air quality plans;

• Comprehensive requirements for monitoring and the minimum types of data, which is nec-

essary for the analysis of emissions and the preparation of the air quality plans and which

should be available free-of-charge and accessible for all stakeholders (in a machine readable

format).




4.2.1 Relevance

Air quality continues to be a source of concern for citizens, as the Eurobarometer 2017 shows

that 46% of respondents perceive that air quality stayed the same in the past 10 years and 24%

consider it has deteriorated, although data from the Swedish EPA indicates a slight improvement.

The European Commission’s 2017 Environmental Implementation Review of Sweden cites the

exceedances of the limit value of NO₂ and PM10 in several municipalities and calls for additional

action in maintaining a downward emissions trend of air pollutants, reducing NOx emissions to

comply with the currently applicable national emission ceilings and to reduce NO₂ and ozone

concentrations. Furthermore, the review calls for the reduction of PM10 emissions and concentra-

tions by reducing emissions of energy and heat generation using solid fuels.

The air quality standards imposed by Swedish legislation go beyond those imposed by the AAQDs

and interviews with stakeholders on a national level consider that rules that are even more strin-

gent should be put in place. For example, stakeholders interviewed called for the need to set a

daily limit for PM2.5.

Thus, in this context, the objectives of the AAQDs are and remain relevant to respond to the

needs of citizens in Sweden, even if air quality in Sweden is considered to be better than in other

EU countries.



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4.2.2 Effectiveness

The findings of the case study indicate effectiveness of the AAQDs in maintaining and improving

air quality in Sweden. Exceedances are only registered when it comes to two types of pollutants

– PM10 and NO₂ - and air quality plans are put in place as a result of the AAQDs.

The findings indicate that the factors underlying compliance with the AAQDs in Sweden include:

1) the general air quality status in Sweden which is good compared to other countries and be-

low limit and target values and a general awareness and understanding of the problem, 2) na-

tional implementation guidance which is published on the implementation of EU and national

legislation on air quality – for example, a comprehensive Air Quality Manual, 3) the awareness

of authorities of the consequences of non-compliance both in terms of poorer air quality but also

in terms of remediation measures taken by the European Commission. In contrast, the case

study identified a number of factors hindering compliance, including: 1) insufficient monitoring

stations and 2) lack of resources and staff.

4.2.3 Efficiency

There are currently no economic analyses of the costs of implementation of the AAQDs in Sweden.

Furthermore, the decentralised Swedish system makes it very difficult to obtain accurate esti-

mates of costs. However, some estimates have been provided by the authorities.

The Swedish EPA reported that it has a budget for AAQ of 400,000 EUR per year. The Swedish

EPA estimated that approximately 200,000-300,000 of its AAQ budget goes to the implementation

of the AAQD per year.

When it comes to the costs of assessment of ambient air quality (costs of measurement, calcula-

tion, predictions or estimations) it is estimated that the costs of all fixed measurements are ap-

proximately EUR 1.8 million per year. According to the Swedish EPA, the majority of the require-

ments related to the number of fixed measurements were in place even before the 2008 AAQD.

This means that the additional costs incurred as a result of the implementation of the 2008 AAQD

were reduced. The development and approval of the measurement system (e.g. standardised

methods, calibrating equipment, engaging in networks and running laboratories) was estimated

to amount to approximately EUR 1.5 million.

When it comes to estimates of the costs of data analysis and assessment methods, the Swedish

EPA indicated that the national costs, for the Reference Laboratory to check the quality of reported

monitoring data is approximately EUR 50,000 per year. However, data validation and ratification

is the responsibility of the local and regional operators, so significant additional local and regional

costs are not included in the afore-mentioned total.

The amount and scale of national air quality modelling is carried out in Sweden varies from one

year to another so estimates are difficult to obtain. Nonetheless, the total annual cost for such

modelling is roughly estimated to be approximately EUR 65,000, but it also includes modelling of

deposition, which is not required by the AAQD. Furthermore, modelling is carried out on an urban-

scale at a local and regional level, but no concrete estimates of costs are available.

An extensive body of research has been conducted concerning the cost of non-implementation of

the AAQDs in particular concerning the costs on health and social welfare. The findings of a study

indicate that approximately 7,600 premature deaths can be estimated to be due to air pollution

from NO₂, PM10 and PM2.5. The study also estimated that the health impacts from exposure to NO2

and PM2.5 can be conservatively estimated to cause socio-economic costs of approximately SEK



(2008/50/EC, 2004/107/EC)

March 2019 39

56 billion (cca. EUR 5,4 billion) in 2015. Just absence from work and studies can be estimated to

cause socio-economic costs of approximately 0.4% of GDP in Sweden.

The benefits of AAQD include amongst others: 1) maintaining and improving air quality and pos-

itive ecosystem effects, 2) increased political commitment to improve air quality, 3) national and

local measures to control traffic pollution, 4) incentivise cooperation between authorities, 5) es-

tablishment of harmonised approaches to monitoring, 6) availability of information to the public.

4.2.4 Coherence

As noted above, the AAQD have strengthened the integration of monitoring stations into regional

networks and the linking of regional networks into a national system with common methods.

Furthermore, in the context of the implementation of air quality plans, collaboration between

authorities working in different areas – for example, cooperation between municipalities, county

administrative boards, and transport authorities – has been sought in the design of air quality

plan and the implementation of the concrete measures. Given the important contribution of

transport to air pollution, measures to tackle air pollution from such sources are taken at a na-

tional level by the Swedish Transport Administration and on a local level by public transport au-

thorities. However, several interviewees indicated that further coordination and ownership of

measures included in the air quality plans is necessary to ensure the viable implementation of

actions tackling pollution at its source.

Sweden has also used EU funding to address air quality. Notably, the project CLEANTRUCK -

CLEAN and energy efficient TRUCKs for urban goods distribution had as primary objective to

demonstrate the commercial and technical viability of alternative fuels and new technologies for

vehicles for the distribution of goods. The aim of the project was the overall reduction of GHG

emissions but also other forms of pollution.


Although Sweden had in place rules to monitor air quality, the added value of the AAQDs was that

it harmonised the approach to the standards and monitoring across the EU. The monitoring re-

quirements of the AAQ Directives have stimulated a number of improvements in the monitoring

of air quality. While monitoring had taken place already before the introduction of the AAQ, alt-

hough in a smaller scale, the added value of the AAQ is in shifting focus on PM10 and NO₂ con-

centrations and ensuring the harmonisation of measurements and methods for monitoring.



(2008/50/EC, 2004/107/EC)

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(2013 & 2014), Sweden.

Swedish EPA, Sweden's air quality zones. Available at: http://www.naturvardsverket.se/Sa-

mar-miljon/Klimat-och-luft/Statistik-om-luft/

Harmonisation of QA / QC for air quality measurement in Sweden. Available at:

http://www.aces.su.se/reflab/kvalitetssakring/harmoniserad-qaqc-manual/.

Swedish Environmental Protection Agency, Guide for air quality – Handbook for Environmental

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(2014), Quantification of population exposure to NO2, PM2.5 and PM10 and estimated health

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and estimated health impacts. Available at: http://naturvardsverket.diva-por-

tal.org/smash/get/diva2:1242584/FULLTEXT01.pdf.

Lena Nerhagen, Tom Bellander, Bertil Forsberg (2013), Air pollution and children's health in

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ing from reductions in air pollution can be assessed. Available at: https://www.naturvardsver-

ket.se/Documents/publikationer6400/978-91-620-6585-0.pdf?pid=9678.

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vardsverket.se/Om-Naturvardsverket/Publikationer/ISBN/1300/978-91-620-1303-5/

Air Quality Ordinance, SFS 2010:477, 8 June 2010. Available at:

http://www.sea.gob.cl/sites/default/files/migration_files/Normas_secundarias/Anexo_documen-

tal/Reino_de_Suecia/Aire/SUE-AI-03-SFS477.pdf.

Swedish Environmental Protection Agency Regulations on air quality control, NFS 2016:9, 14

December 2016. Available

at:https://www.naturvardsverket.se/Documents/foreskrifter/nfs2016/nfs-2016-9.pdf.

Swedish EPA (2017), Research in support of Air Pollution Policies. Results from the first phase of

the Swedish Clean Air and Climate Research programme. Available

at:https://www.naturvardsverket.se/Documents/publikationer6400/978-91-620-6784-

7.pdf?pid=21182

Norwegian Institute for Air Research (2016), Evaluation of the Swedish national air-monitoring

programme "Programomrade Luft". Available at: http://naturvardsverket.diva-por-

tal.org/smash/get/diva2:1156632/FULLTEXT01.pdf.

http://www.naturvardsverket.se/Sa-mar-miljon/Klimat-och-luft/Statistik-om-luft/

http://www.naturvardsverket.se/Sa-mar-miljon/Klimat-och-luft/Statistik-om-luft/


























https://www.naturvardsverket.se/Documents/foreskrifter/nfs2016/nfs-2016-9.pdf









(2008/50/EC, 2004/107/EC)

March 2019 41



Swedish Environmental Protection Agency 20-09-2018

Swedish Society for Nature Conservation 21-09-2018

AirClim – Air Pollution and Climate Secretariat 19-09-2018

Gothenborg County Administrative Board. 30-11-2018



(2008/50/EC, 2004/107/EC)

March 2019 42


General questions




learn from?


tives?



exchange, etc.)?



Specific questions




(2008/50/EC, 2004/107/EC)

March 2019 43


RELEVANCE








gress?



try)?



zens' needs?







become redundant?

EFFECTIVENESS



















grammes


mation to public?







EFFICIENCY

















(2008/50/EC, 2004/107/EC)

March 2019 44









Directives?


porting, and planning) for different levels of govern-

ment, including the use of external expertise on, per

year (in FTE)?

What is the cost of implementation for different sec-

tors of the industry per year (capital and operating

costs of equipment in EUR)?



tives?

What are the costs of non-implementation of the Di-

rectives (e.g. environmental and health costs, un-

certainty and market distortion, litigation costs for

Member States)?


tion of the Directives in the Member State/air quality

zone (e.g. health and environmental benefits, eco-

nomic benefits, eco-innovation, etc.)?






COHERENCE

















(2008/50/EC, 2004/107/EC)

March 2019 45
















ments)?



NEC Directive?











ADDED VALUE










quality objectives?


in monitoring?












quality management?




ties)?






(2008/50/EC, 2004/107/EC)

March 2019 46

APPENDIX D USE OF EU FUNDS

Project Title Project Project Website Year Of

Finance

Type Of Ben-

eficiary

HYPER BUS - Hyper Bus -

Hybrid and plug-in extended

range bus system

LIFE10

ENV/SE/000041

http://www.hyper-

bus.se/,

2010 Development

agency

GREENCIT - Green citizens of

Europe - Innovative tools

and methods for interactive

and co-creative citizens

LIFE09

ENV/SE/000346

http://www.greenci

t.se/,

2009 Local authority

CLEANTRUCK - CLEAN and

energy efficient TRUCKs for

urban goods distribution

LIFE08

ENV/S/000269

http://www.stock-

holm.se/cleantruck,

2008 Local authority

Biored - Multi-Stage Biologi-

cal Reduction of EDTA in

Pulp Industries

LIFE04

ENV/SE/000765

http://www.nordic-

paper.com ,

http://www.bi-

ored.se/,

2004 International

enterprise

Basta - Phasing Out Very

Dangerous Substances from

the Construction Industry

LIFE03

ENV/S/000594

http://www.bastao

nline.se/,

2003 International

enterprise

Tanwater - Reduction of the

nitrogen discharge from the

leather industry

LIFE03

ENV/S/000595

http://www.tanwat

er.net/,

2003 International

enterprise

New LS Lacquers - Low sol-

vent lacquers based on new

binder combinations

LIFE00

ENV/S/000851

http://www.arbor-

itec.se,

2000 SME Small

and medium

sized enter-

prise

http://www.hyperbus.se/




http://www.greencit.se/

http://www.greencit.se/

http://www.stockholm.se/cleantruck




http://www.bastaonline.se/

http://www.bastaonline.se/

http://www.tanwater.net/

http://www.tanwater.net/

http://www.arboritec.se/






March 2019 47

APPENDIX E POLLUTANT CONCENTRATION DATA FOR SWEDEN, 2013-17

Table 4-1 Highest pollutant concentrations in exceedance of EU air quality objectives for protection of health in Sweden in 2013-2017 - extract from reporting

(Dataflow G).

Pollutant Averaging period Objective type and value Date for achieving objective Parameter shown 2013 2014 2015 2016 2017

PM10 Calendar year LV: 40 μg/m3 1 January 2005 Annual mean, μg/m3 - - - - -



per year

1 January 2005 Days above 56 36 38 - 45

NO₂ Calendar year LV: 40 μg/m³ 1 January 2010 Annual mean, μg/m3 46 41 42 43 -



per year

1 January 2010 Hours above - - - - -



per year

1 January 2005 Days above - - - - -



per year

1 January 2005 Hours above NA NA - - -


mean

LV: 10mg/m3 1 January 2005 Days above - - - 2 2

C6H6 Calendar year LV: 5 μg/m3 1 January 2010 Annual mean, μg/m3 - - - - -


content in PM10)

1 January 2005 Annual mean, μg/m3 - - - - -



March 2019 48

Pollutant Averaging period Objective type and value Date for achieving objective Parameter shown 2013 2014 2015 2016 2017

O3 Maximum daily eight-hour

mean




over three years


Maximum daily eight-hour

mean within a calendar

year

LTO: 120 μg/m³ Not defined Days above - - - - -

PM2.5 Calendar year LV: 25 μg/m³ 1 January 2015 (target value

until 1 January 2010)

Annual mean, μg/m3 - - - - -

(calculated as Average Ex-

posure Indicator, assessed

as a 3-year running annual

mean)


As Calendar year TV: 6 ng/m³ (measured as con-

tent in PM10)


Cd Calendar year TV: 5 ng/m³ (measured as con-

tent in PM10)



content in PM10)


BaP Calendar year TV: 1 ng/m³ (measured as con-

tent in PM10)



Note: LV: limit value; TV: target value; LTO: Long term objective; ECO: exposure concentration obligation; The values show the maximum exceedance reported in the Member State (if

no exceedances are reported in any of the zones of the Member State, the table shows "-") Legend: "NA": not available in data flow G, "-": no reported exceedance