Greater efforts to improve EU air quality needed

The proposal for a new EU air quality standard is an important step closer to the WHO's guidelines, but there are still health and economic gains in lowering the acceptable levels even further.

On 26 October the European Commission presented its proposal for amending the Ambient Air Quality Directive (AAQD). As can be seen in the table, the annual limit values are stricter than the current directive for NO₂, PM₂.₅ and PM₁₀ but still not in line with WHO Air Quality Guidelines. New short-term (24-hour) limit values have been introduced for NO₂, CO and PM₂.₅. One comment on the proposal from health organisations was a wish for closer alignment with WHO Air Quality Guidelines to protect the health of EU citizens.

Prof. Zorana Jovanovic Andersen, Chair of the Environment and Health Committee of European Respiratory Society (ERS), said: “The burden of disease from air pollution exposure remains unacceptably high in Europe. We need greater efforts to reduce air pollution exposure with a more ambitious path to achieving full alignment with WHO Air Quality Guidelines everywhere in Europe.”

According to the impact assessment the benefits of achieving limit values in line with current WHO guidelines greatly surpassed the costs (by a ratio of between 6:1 and 18:1). The net benefits amount to more than 38 billion euro, and the corresponding mitigation costs are estimated at EUR 7 billion in 2030. The impact assessment also investigates the social impact. It highlights that air pollution is our largest environmental health threat today, and often has disproportionate impact on member states or individuals with poorer economies, and thus on health costs. The abatement strategy of excluding polluting vehicles from city centres might impact on those with less opportunity to own a cleaner car. On the other hand, many do not have the means to own a car at all and only suffer from bad air.

The analysis showed that 71% of sampling points would need additional efforts at local level to meet limit values in line with WHO Air Quality Guidelines. The Impact Assessment include mainly Technical Measures and many of the indicative measures listed in the proposal are not evaluated, such as Low Emission Zones. Limit values exclude natural sources, and maps are thus included both with and without natural sources to allow for comparison of attainability.In addition to limit values, there are target values for ozone and average exposure reduction obligations for PM₂.₅ and NO₂. For ozone, instead of a limit value there are still only target values proposed. The long-term annual daily 8-hour maximum target value is based on calendar year and not peak season, as recommended by WHO. The target value proposed for ozone further includes a clause about disproportionate costs. By comparison, limit values for ozone are part of the US National Ambient Air Quality Standards.

The Average Exposure Indicator (AEI) is used to examine whether the average exposure reduction obligation is met. The AEI proposed is given as a 3-calendar-year running annual mean urban background concentration averaged over all sampling points at regional (NUTS 1) level, and natural sources are deductible. The AEI should not exceed a level that is 25% lower than its value 10 years previously, until WHO Air Quality Guidelines are reached (5 µg/m3 for PM₂.₅ and 10 µg/m3 for NO₂). Concern was raised from environmental and health NGOs that the exposure reduction obligation approach might increase social inequalities regarding air pollution exposures. As housing in air pollution hotspot areas tends to be cheaper, it is often inhabited by people with lower economic means. Hotspot areas are not covered in AEI, as urban background stations do not cover hotspots, leaving the most vulnerable unprotected. Furthermore, it might be less effective for equal rights to clean air across the EU and fails to show us a clear path to achieving WHO alignment across all member states. Moreover, Average Exposure Reduction Obligations might make public communication and access to justice more complicated, they stressed. By using a mean of all urban background stations in a large regional area, accountability for action might be hard to follow.

The proposal also contains other changes apart from level adjustments. The Commission considers that the collected and reported air quality data is robust and of satisfactory quality. Further policy action to be designed and implemented. There have, however, been some concerns about the comparability of monitoring data from member states due to the location of monitoring stations. It is already stated that air pollution should be monitored in areas where the highest concentrations of air pollutants occur and in other areas that are representative of the exposure of the general population. The definition of the criteria for these areas could be clarified to reduce dependency on the competence of the handling authorities. The new proposal suggests that models, indicative measurements, and documentation on how the selection was made should play a bigger role. Given the technical improvements to air quality models since the last proposal, new possibilities have opened up. Models are now suggested for evaluating air quality plans and to indicate levels where there are no measurements. New supersites (monitoring stations with more measurement equipments) have also been suggested to cover emerging pollutants, such as ultrafine particles, ammonia and black carbon.

Another important shortcoming in the current directive is public information. Results from Eurobarometer surveys indicate that most citizens do not feel well informed about air quality in their countries. The quality of information for the public has been of mixed quality but is now detailed in Annex IX. Member states should in the proposal establish an air quality index that provides hourly air quality updates for the most harmful air pollutants. Alert thresholds for sulphur dioxide, nitrogen dioxide, particulate matter (PM₁₀ and PM₂.₅) and ozone, and an information threshold for ozone, should be set to trigger the dissemination of information to the public on the risks of exposure. Up-to-date information on concentrations of all regulated pollutants in ambient air, as well as air quality plans and short-term action plans, should also be readily available to the public. The new proposal includes forecasted air quality, which will hopefully enable the public to make informed decisions on protecting their health and allow policy action. Forecast exceedances should, under the new proposal, be accompanied by major source contribution and recommendations to reduce these exposures and emissions.

Another important aspect is of course what to do if levels of air pollutants exceed the limit values. According to the new proposal, air quality plans should also be prepared ahead of 2030 if there is a risk that member states will not attain the limit values or ozone target value. Currently, the Air Quality Plans have, unfortunately, in some cases become a delaying game in which inadequate measures have been presented time and time again. The relatively low cost for action (which leads to benefits) as compared to the cost of inaction (which leads to harmful impacts from air pollution) on citizens’ health, the economy and society has been presented in many studies by the International Institute for Applied Systems Analysis (IIASA). The new proposal sets clearer guidelines for the Air Quality Plans, including an indicative list of measures and clearly defined and documented responsibility roles, to keep exceedances as short as possible, and to update plans if they are not effective enough. ClientEarth head of clean air Ugo Taddei indicate a weakness of the proposal: The existing rules in the current AAQD state that when exceedances of legal limits occur after the deadline, competent authorities must adopt air quality plans setting out “appropriate measures, so that the exceedance period can be kept as short as possible”. This requirement has allowed citizens, NGOs, and the EU Commission to bring enforcement actions. The proposal suggests amending the requirement and specifying that those air quality plans must “keep the exceedance period as short as possible, and in any case no longer than 3 years from the end of the calendar year in which the first exceedance was reported.” However, the only consequence for missing this three-year deadline in the proposal is the requirement to update the air quality plan.

The new proposal also expands postponement attainment from NO₂ to PM₂.₅ (while excluding benzene). The conditions for this postponement have also been specified. Site-specific dispersion characteristics, orographic boundary conditions (hills and mountains), adverse climatic conditions or transboundary contributions can allow for postponement of attaining limit values for up to 5 years if an Air Quality Plan is prepared according to the requirements and the Commission is notified. The Commission will assess if postponement conditions are satisfied, which might take nine months. If objections are raised, new or amended air quality plans can be sent in. Lastly, a regular review mechanism is introduced to assess whether the directive needs to be revised to ensure alignment with WHO Air Quality Guidelines by the year 2050 at the latest, based on the latest scientific understanding. Health organisations point out that latest scientific evidence is already available and limit values should align with WHO Air Quality Guidelines by 2030 the latest.

Ebba Malmqvist

The proposal can be found here:


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