EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 21 9.2005 
SEC (2005) 1133 
  
COMMISSION STAFF WORKING PAPER 
Annex to : 
 
 
The Communication on Thematic  Strategy on Air Pollution 
 
and 
  
The Directive on “Ambient Air Quality and Cleaner Air for Europe” 
    
Impact Assessment  
  
 
{COM(2005)446 final} 
{COM(2005)447 final} 
 
EN 2   EN TABLE OF CONTENT 
Summary ........................................................................................................................ ............ 7 
1. Introduction................................................................................................................ 23 
2. What problem does the Thematic Strate gy on Air Pollution set out to tackle? ......... 25 
2.1. The problem of air pollution ...................................................................................... 25 2.2. Trends in air pollution levels up to 2020: the CAFE Baseline .................................. 29 2.3. Quantification and valuation of health impacts of air pollution ................................ 37 2.4. Environmental and non-health impacts...................................................................... 42 3. The long-term objectives............................................................................................ 43 3.1. Current policies will not bring about the long term objective ................................... 43 
3.2. A point of reference – The maximum technically feasibly reduction........................ 43 4. The main policy options cons idered for the strategy ................................................. 46 
4.1. The broad approach for sett ing the interim objectives............................................... 46 
4.2. Final set of policy options.......................................................................................... 52 5. Impact assessment of the options............................................................................... 53 5.1. Impact on pollutant emissions.................................................................................... 53 5.2. Impact on air quality and human health..................................................................... 56 5.3. Direct costs of measures............................................................................................. 58 5.4. Uncertainties ............................................................................................................. . 59 
5.5. Sensitivity analysis..................................................................................................... 6 3 
5.6. Comparing costs and health impacts.......................................................................... 71 5.7. Impact on ecosystems ................................................................................................ 75 5.8. Summary of costs and benefits .................................................................................. 82 5.9. Wider economic and social impacts........................................................................... 83 5.10. Other environmental impacts ..................................................................................... 89 6. Measures and instruments.......................................................................................... 91 6.1. Emission reduction measures for meeti ng the ambition level of the Strategy – 
indicative outcome of RAIN S optimisation process.................................................. 91 
6.2. Measures considered .................................................................................................. 96 6.3. Integration of air quality c oncerns into other sectors............................................... 100 
 
EN 3   EN 6.4. Applying effective policy instruments..................................................................... 102 
7. Impact assessment for Directive on “Ambient Air Quality and Cleaner Air for 
Europe” .................................................................................................................... 103 
7.1. Better regulation: Streamlining cu rrent air quality legislation................................. 103 
7.2. Health advice............................................................................................................ 1 06 
7.3. Reducing exposure to PM 2.5..................................................................................... 109 
7.4. Costs and benefits of th e proposal for regulating PM 2.5.......................................... 113 
8. Monitoring and evaluation ....................................................................................... 118 8.1. Evaluation and review of policies............................................................................ 118 8.2. Consultative arrangements....................................................................................... 118 8.3. Research needs including  financial implications ..................................................... 119 
9. Stakeholder and public consultation ........................................................................ 124 9.1. Public consultation................................................................................................... 124 9.2. Stakeholder consultation .......................................................................................... 125 9.3. Consultation within the Commission....................................................................... 127 10. Commission proposal and grounds .......................................................................... 128 10.1. Selection of the interim objectives for the Thematic Strategy up to 2020............... 128 10.2. Better regulation –– cutting re d tape and streamlining curr ent air quality  legislation
............................................................................................................................... ... 135 
10.3. Proposal for regulating particulat e matter and other air pollution ........................... 136 
Annexes ....................................................................................................................... ........... 138 
 
EN 4   EN  
GLOSSARY AND ABBREVIATIONS  
Acidification Excess acidity from the deposition of ammonia, nitrogen oxides 
and sulphur dioxide can lead to the damage of freshwater and 
terrestrial ecosystems. 
Aerosol A dispersion of solid particulat e matter or droplets in air. 
Air quality limit value A legally binding pollutant concentration in air which may be 
exceeded on a prescribed number of occasions per calendar year 
(c.f. target value,  an air quality objective which is not legally 
binding ). 
Air Quality Proposal Proposed Directive to merge the Air Quality Framework 
Directive, first, second and th ird daughter directives, and the 
Council Decision on the reciproc al exchange of air quality 
monitoring information. 
Ammonia (NH 3) A gas which is emitted mainly from animal wastes and following 
the application of fertilisers. 
Background Urban background represents locati ons in urban areas where the 
level of air pollutants is not mainly influenced by any single 
source, but rather by the integrat ed contribution from all sources 
upwind of this location. The air pollution level in these locations should typically be representative for several km
2. 
Rural background represents lo cations with lower population 
density, far removed from urban and industrial areas and away from local emissions. The air pollution level in these locations 
should typically be representativ e for an area of at least 1000 km
2. 
CAFE Clean Air for Europe programme 
CAFE baseline 
(called also  “Business-as-usual” or “Current Legislation”) The expected evolution in EU- 25 pollutant emissions up to 2020 
assuming that current legislation to reduce air pollution is implemented. The baseline is based upon forecasts of economic growth and changes in energy production, transport and other polluting activities. 
CAIR Clean Air Interstate Rule 
CAP Common Agricultural Policy 
CBA Cost-benefit analysis 
CLTRAP UN ECE Convention on Long Range  Transboundary Air Pollution 
Critical level A pollutant concentration level in air below which significant 
adverse impacts on vegeta tion are not expected. 
Critical load A level of deposition below whic h significant adverse impacts on 
ecosystems are not expected 
EMEP Protocol on long-term financing of the co-operative programme 
for monitoring and evaluation of long-range transmission of air 
 
EN 5   EN pollutants in Europe 
Eutrophication Excess nutrient nitrogen (mainly in the form of ammonia or 
nitrogen oxides) can lead to changes in the composition of ecosystem communities and a loss of biodiversity. 
GEM-E3 General equilibrium macro-economic model – Economy, Energy 
& Environment 
Ground-level ozone (O
3) Ozone formed in the lowermost part of the atmosphere from the 
reaction of nitrogen oxides and volatile organic compounds in the 
presence of sunlight. Ozone is a strongly oxidising gas. 
IA Impact Assessment 
IAM Integrated Assessment Modelling 
IIASA International Institute of Applied Systems Analysis 
IPPC Integrated pollution prevention a nd control (Direc tive 96/61/EC) 
LRS Lower respiratory symptoms 
MRAD Minor restricted activity day 
MTFR Maximum Technically Feasible Reduction 
National emission 
ceiling The maximum amount of a substance expressed in kilotonnes that 
may be emitted by a Member State in a particular calendar year. 
NECD National Emissions Ceiling Directive 
NewExt New Elements for the Assessment of External Costs from Energy 
Technologies 
Nitrogen oxides (NO x) The gases nitric oxide (NO) and nitrogen dioxide (NO 2). NO is 
predominantly formed in high temperature combustion processes and can subsequently be converted to NO
2 in the atmosphere. 
PM 10, PM 2.5 Particulate matter in ambient air with a diameter less than 10 or 
2.5 millionths of a metre respectively. 
PRIMES Energy model 
RAD Restricted activity day 
RAINS Regional Acidification Inform ation Simulation Integrated 
Assessment Model 
SCHER Scientific Committee on Hea lth and Environmental Risks 
SCNR Selective Non-Catalytic Reduction 
Secondary pollutant Secondary pollutants are not emitt ed directly but are formed by 
subsequent chemical processes in the atmosphere. Examples 
include ground-level ozone, and nitrate and sulphate aerosols. 
Strategy Thematic Strategy on Air Pollution 
SOMO35 Sum of daily maximum ozone concen trations above a threshold of 
35 ppb (70 µg/m3) 
 
EN 6   EN Sulphur dioxide (SO 2) Gas formed from the combustion of fuels which contain sulphur. 
Transboundary air 
pollution Pollutants emitted in one country are transported in the 
atmosphere and may contribu te to adverse health and 
environmental impacts in other countries. 
Volatile Organic 
Compounds (VOC) VOC are volatile carbon-based chemical compounds (such as 
solvents or components of paints and varnishes) which are emitted to the atmosphere from natural sources or as a result of human activities. 
VOLY Value of life year 
VSL Value of statistical life 
WGI Working Group on Implementation 
WG PM Working Group on Particulate Matter 
WG TSPA CAFE Working Group on Target Setting and Policy Assessment 
WHO The World Health Organization 
YOLL Years of life lost 
 
EN 7   EN SUMMARY  
PART ONE - IMPACT ASSESSMENT ON THE THEMATIC STRATEGY ON AIR POLLUTION  
The objectives 
The Sixth Environment Action Programme (6 th EAP) is a programme of Community 
action on the environment w ith key objectives covering a period of ten years. The 
priorities of the 6th EAP cover climate ch ange, nature and biodiversity, environment, 
health and quality of life , and natural resources and waste. Within these key 
priorities, the 6th EAP calls for the development of seven thematic strategies including a coherent and integr ated strategy on air pollution. 
The Thematic Strategy on air pollution is to present a coherent a nd integrated policy 
on air pollution which: (1) sets  out priorities for future action; (2) reviews existing 
ambient air quality legislation and the Na tional Emission Ceilings Directive with a 
view to reaching l ong-term environmental objectiv es; and (3) develops better 
systems for gathering information, modelling and forecasting air pollution. 
The 6th EAP establishes the objective of ach ieving levels of air quality that do not 
give rise to significant negative impacts on and risks to human health and the 
environment. This includes no exceedence of critical loads and levels for natural ecosystems (a critical load being a leve l of exposure below which there is not 
expected to be any risk). 
Air pollution is complex. There are local components and transboundary 
contributions to observed effects. Severa l pollutants contribut e to the same or 
multiple effects and pollutants interact. Moreover, there are prominent synergies and tensions between air polluti on and other environmental pr oblems such as climate 
change. These issues must be addressed in a systematic and cross-cutting way so that benefits can be maximised. The Thematic Strategy on air pollution is built upon an 
integrated assessment of different envir onmental and health effects and aims to 
provide the most cost-effective soluti on for the chosen level of objectives. 
The Strategy assesses the prospects for making further progress towards the 
objectives set out in the 6
th EAP. It considers the econom ic, social and environmental 
dimensions in an integrated and balanced manner. 
Development of the Thematic Strategy and Stakeholder Consultation 
In its Communication on the Clean Air For Europe (C AFE) Programme: Towards a 
Thematic Strategy for Air Qualit y the Commission set out its intention to develop the 
Thematic Strategy based upon sound tech nical information. The CAFE Programme 
was set up to develop, collect and validate scientific informati on about air pollution 
with the aim of reviewing current policies and assessing progress towards long-term 
objectives. It established five  working groups to provide assistance and advice (see 
box below). 
There were over one hundred stakeholder meetings during the CAFE programme 
including conferences to disseminate results, to share experiences on the use of different policy instruments (including econom ic instruments), and to discuss issues 
 
EN 8   EN relating to the implementation of current air quality legisl ation. In addition, there was 
a two-month “non-expert” web-based publ ic consultation on the content and 
objectives of the Thematic  Strategy. Of the 11,578 re sponses received, over 10,000 
were from private individuals. Respondents indicated a clear need for better public 
information, a greater desire for protecti on from air pollution and a willingness to 
pay for reduced risks on a par w ith those for drinking water. 
 
As well as the various working groups, the Commission launched several contracts 
for services during the CAFE Programme. The total value of these contracts and 
agreements amounted to several million euros.  The most important of these are listed 
below.  Working Groups under the Clean Air For Europe Programme 
• The CAFE Steering Group; 
• The Target Setting and Policy Assessment Working Group (TSPA); 
• The Technical Advisory Group (TAG); 
• The Working Group on Particulate Matter (WGPM);  
• The Working Group on Implementation (WGI). 
The Steering Group was and continues to be th e main forum for stakeholder participation 
on air pollution issues. Members include repr esentatives of the Member States, several 
industry sectors (energy production, petroleu m, VOC industries, automotive sector and 
general industry), environmental NGOs, EEA countries, the European Environment 
Agency, the Joint Research Centre and the CLRTAP. The Steering Group met fourteen 
times during the four years of the CAFE programme. 
The TSPA included selected experts from th e Member States, i ndustry, NGOs, the 
European Environment Agency and the JRC. Its role was to assist the Commission in managing the technical service contracts that were launched to provide information on the 
development of cost-effective control strate gies and to estimate health benefits. The 
TSPA’s main role was to provide feedback on the environmental targets to be used in 
developing cost-effective control strategi es using the RAINS integrated assessment 
model. The TAG was a forum for different modelling groups to discuss and give advice on technical and scientific issues relating to the analyses undertaken. 
The WGPM was convened to review the latest  health evidence and scientific information 
regarding the effects and presence of particulate matter in ambient air and to make 
recommendations for modifications to existing legislation. The WGPM was led by experts 
from the UK and Germany. The WGI was conve ned by the Commission to gather and 
report on the implementation of existing air quality legislation and to report to the 
Commission on potential modifications and improvements. Its members consisted 
primarily of experts from the Member States. 
 
EN 9   EN  
An overriding principle of the CAFE programme  was to ensure that the analyses were 
conducted on the basis of the best available information. It is for this reason that the 
main analytical tools (the RAINS integrat ed assessment model and the cost-benefit 
methodology) were both subject to independe nt peer-review before being used to 
develop and analyse policy scenarios. In a ddition, the World Hea lth Organisation was 
asked to provide its best information on the impacts of air pollutants on health. 
The problem 
The main sources of air pollution are transport, power generation, industry, 
agriculture, and heating. All these sectors emit a variety of air pollutants - sulphur 
dioxide, nitrogen oxides, ammonia, volatil e organic substances , and particulate 
matter – many of which interact with others to form new pollutants. These are eventually deposited and have a whol e range of effects on human health, 
biodiversity, buildings, crops and forests.  
Air pollution results in  several hundreds of thousands of  premature deaths in Europe 
each year, increased hospital admissions, extra medication, and millions of lost working days. The health costs to th e European Union are huge. While the 
environmental damage through acidification of ecosystems and damage to crops and 
forests is impossible to quantify, it is likely to be substantial as well. The pollutants of most concern for human health are air borne particulates and ozone – indeed no 
safe levels have yet been identified for either. Service contracts launched under the CAFE Programme 
(1) Energy Baseline Scenarios for the Clean Air For Europe Programme (CAFE) –
service contract to verify consistency between air quality and climate change 
policies in the CAFE baseline scenarios,  National Technical University of 
Athens, Contract N° 070501/2004/377552/MAR/C1; 
(2) Baseline Scenarios for the Clean Air For Europe (CAFE) Programme. Service 
contract for the development of the b aseline and policy scenarios and integrated 
assessment modelling framework for the CAFE programme, International 
Institute for Applied Systems Analysis, Contract N° B4-3040/2002/340248/MAR/C1; 
(3) Service Contract for Carrying Out Cost-Benefit Analyses of Air Quality Related 
Issues, in particular in the Clean Air For Europe (CAFE) Programme; AEA 
Technology plc, Contract N° ENV.C.1/SER/2003/0027 ; 
(4) Service Contract for the Review of the RAINS Integrated Assessment Model; 
The Swedish Environmental Research  Institute & AEA Technology plc, 
Contract N° ENV.C1/SER/2003/0079; 
(5) Peer-Review of the Methodology of the Cost-Benefit Analysis of the Clean Air 
For Europe Programme; Alan Krupnick (editor), Bart Ostro and Keith Bull, October 2004, (under contract N° 070501/2004/382805/MAR/C1); 
(6) Systematic Review of Health Aspects of Air Pollution in Europe, European 
Centre for Environment & Health of the World Health Organisation (Bonn), 
Grant agreement 2001/321294. 
(7) Assessment of the effectiveness of Eur opean Air Quality Policies and Measures; 
Millieu Ltd, Contract N° B4-3040/2003/365967/MAR/C1. 
 
EN 10   EN Particulates consist of the “primary” par ticles emitted directly into the atmosphere 
from certain processes and “secondary” particles (or “aeros ol”). The latter are 
emissions of gaseous pollutants,  such as sulphur dioxide (SO 2), nitrogen oxides 
(NO X) and ammonia (NH 3), which are altered through chemical reaction in the 
atmosphere and add to the particulate mass. Particulates in ambient air are classified 
according to size, so PM 10 and PM 2.5 refer to all particles with diameter less than 10 
micrometers (the “coarse” fraction) and 2.5 micrometers (the “fine” fraction) 
respectively. Fine particles tend to originate more from human activities than coarse particles.  
Ozone occurs naturally in th e stratosphere and in the tr oposphere, but is formed by 
very different chemical processes. Ozone in the stratosphere is valuable as it protects 
us from harmful ultraviolet radiation, but  tropospheric ozone near ground level is 
harmful to ecosystems and human health. Ground-level ozone is formed in the atmosphere by reaction between volat ile organic compounds (VOC) and NO
X in the 
presence of sunlight. The VOC  come from petrol stations , car exhausts, and the use 
of solvents and paints. 
In the environment, emissions of SO 2, NO X and NH 3 contribute to the acidification 
of lakes, rivers, forests and other ecosys tems, although it is possible to identify a 
“critical load” below which the ecosystem is not expected to be at risk. But after fauna and flora are lost it may take several decades for an ecosystem to recover, even when acidifying inputs are reduced to su stainable levels. Excess nitrogen from NO
X 
and NH 3 can lead to eutr ophication, while ground-level ozone can damage forests, 
crops and vegetation. Ozone damage is the most serious re gional air pollution 
problem affecting agriculture in Europe . Air pollution also has an impact on 
materials, buildings and cultural heritage.  
The approach 
The present document explains how the Strate gy was build up, the options chosen or 
discarded and the costs and benefits of each  of them. It assesses the impact of the 
Strategy based on the best scientific understanding of emissions, atmospheric 
transport, and the human health and e nvironmental impacts of air pollution. It  
concentrates on the five major impacts of the five major pollutants shown in this 
table. 
Multi-pollutant/multi-effect approach of the Strategy 
 Primary PM SO 2 NO x VOC NH 3 
Health effects :      
- Particulate matter √ √ √ √ √ 
- Ground-level ozone    √ √  
Vegetation effects :      
- Ground-level ozone   √ √  
- Acidification  √ √  √ 
- Eutrophication   √  √ 
 
 
EN 11   EN The method used for the Strategy was first to establish a baseline  showing air 
pollution up to 2020 if no extra measures or additional legislation are implemented.  This was then set against Community long-term objectives of  achieving levels of air 
quality that do not give rise  to significant negative impacts on and risks to human 
health and the environment. This includes no exceedence of cr itical loads and levels 
for natural ecosystems. Then, various scenarios  were examined to close the “gap” 
between the baseline and the achievement of  the long terms objectives. On the basis 
of cost-effectiveness and cost/benefit analysis interim objectives  for the Strategy 
have been set. Peer revi ews and sensitivity analyses were used to minimise 
uncertainties in modelling, assumptions, and assessments of alte rnative strategies. 
The baseline  
The baseline scenario takes account of the effects of emissions control legislation, 
against the background of future economic developmen t. The baseline scenario is 
sometimes called also the “business-as-usual” or “current legislation” scenario. Existing legislation – e.g. on cars, large combustion plants, fuel quality, the VOC 
content of products, emission limits for major pollutants – will deliver reductions in emissions of most air pollutants (SO
2, NO X and VOC) in the 25 Member States of the 
European Union, in a context of econom ic growth. The exception is ammonia 
emissions, although the recent reforms of the Common Agricultural Policy should bring considerable improvements. Emissions of  all particulates should also continue to 
decline, but background concentrations of ozone will increase and are of concern. 
The relationship between the decrease of primary pollutant emissions and the 
improvement of air quality is  not straightforward. Air qual ity is affected not only by 
local emissions, but also by interactions between these pollutants, their long-range 
transport in the atmosphere, natural emi ssions and meteorological  conditions. So the 
picture varies across the EU.  
In the natural environment it is possible to determine “critical loads” for individual 
ecosystems, namely sustainable levels of deposition above  which the ecosystem will 
be at risk of harmful effects. For human h ealth, the situation is more complex as no 
safe levels of exposure have yet been identified for some pollutants, such as 
particulate matter and ground-level ozone.  
The improvements in pollutant emissions, hea lth impacts from air pollution across the 
EU are therefore stil l projected to be considerable  in 2020. The effects on life 
expectancy of exposure to particulates (estimated at over 300 000 premature deaths equivalent a year in 2000) are expected to be  much greater than those associated with 
ozone (some 21 000 premature deaths). Total he alth damage costs – including illness – 
associated with particulate matter and ozone  are estimated to be between €189 billion 
and €609 billion per annum in 2020. 
The options 
Since by 2020 the EU will stil l be a long way from achievi ng the two objec tives of the 
6th EAP with current legislation, further actio n is required. To help  decide on the costs 
and benefits of different levels of acti on, various options were considered with 
reference to a scenario whereby all possible emissions abatement measures are deployed irrespective of cost. This is called the “Maximum Technically Feasible 
 
EN 12   EN Reduction” (MTFR) scenario, but even if the EU undertook all measures available, 
irrespective of costs, there w ould still be significant negative impacts on health and the 
environment.  
So, various options between the baseline and the MTFR scenario were assessed to 
establish interim environment objectives that deliver progress in a balanced and cost-effective way. At the outset, and followi ng discussion and advice from the Working 
Group on Target Setting and Policy Assessmen t, three different levels of ambition
1 
were considered in four areas, combining the health-related PM 2.5 and ozone 
objectives with those of environmental pr otection for acidifica tion and eutrophication 
as shown in the table below 
Scenarios considered in the Thematic Strategy  
 2000 Baseline 
2020 Scenario 
A Scenario 
B Scenario 
C MTFR2 
EU-wide cumulative 
years of life years lost (YOLL, million) 203  137 
(0%)110 
(65%)104 
(80%)101  
(87%) 96 
(100%)
Acidification (country-wise gap closure on cumulative excess deposition)
3 120 30
(0%)15
(55%)11
(75%)10 
(85%) 2
(100%)
Eutrophication (country-wise gap 
closure on cumulative 
excess deposition)
4 422 266 
(0%)173
(55%)138
(75%)120 
(85%) 87
(100%)
Ozone (gap closure on SOMO35)
5 4081 2435 
(0%)2111
(60%)2003
(80%)1949 
(90%) 1895
 (100%)
Impact assessment of the options  
The three scenarios between the baseline  and the maximum technically feasible 
reduction were subjected to a full cost-benef it analysis, together with analysis of 
impacts on competitiveness and employment . The analysis focuses on the most 
significant impacts and the most important distributive effects, and the depth of 
analysis matches the significance of the impacts. 
The reduction in pollutant emissions for each ambition level is not homogeneous 
across pollutants and Member States. For example, it can be seen from the table below that under Scenario B, SO
2 emissions would be reduced by a further 44% from where 
they would be with current legislation in 2020, but NO X emissions by only 272%.  
                                                 
1 The assessment focuses on the range between 50% an d 100% of MTFR, as control costs started to 
increase significantly at about 75% be tween the baseline and MTFR in 2020. 
2 The percentage refers to the difference between  Baseline 2020 and Maximum Technically Feasible 
Reduction (MTFR) 
3 Average accumulated excess acidification equivalents per hectare 
4 Average accumulated excess eutro phication equivalents per hectare 
5 SOMO35 in parts per billion days 
 
EN 13   EN Emission reductions for th e three ambition levels in 2020 (in kilotonnes) 
 Baseline Ambition level in 2020 
 2000 2020 Scenario A Scenario B Scenario C 
SO 2 8735 2805 1704 1567 1462
NOx 11581 5888 4678 4297 4107
VOC 10661 5916 5230 4937 4771NH
3 3824 3686 2860 2598 2477
PM 2.5 1749 964 746 709 683
The direct costs of these measures have b een calculated at between €5.9 billion for 
Scenario A and €14.9 billion for Scenario C. The tables show a preliminary estimate of costs by pollutant and by major source for 2020.  
Abatement costs by pollutant in 2020 (€ million per year) 
Ambition level 
Pollutant Scenario A Scenario B Scenario C MTFR
SO 2 800 1,021 1,477 3,124
NOx 903 2,752 4,255 6,352
NH 3 1,785 3,770 5,410 13,584
Primary PM 2.5 411 695 908 12,335
VOC 157 573 935 2,457PM
2.5 and NOx from road transport 1,868 1,868 1,868 n/a
Total  5,923 10,679 14,852  over 39,720
Abatement costs by sector in 2020 (millions of euros per year) 
0200040006000800010000120001400016000
Scenario A Scenario B Scenario CMillion €/yearAgriculture (animals)
Agriculture (crops)
Small Combustion Plants
Large Combustion Plants (industry)
Large Combustion Plants (power and heat)
Transport
Fuel production and conversion
Other industrial process and waste
 
 
EN 14   EN  
Health benefits  of the different policy options have been assessed using the 
methodology outlined in Section 2.3 and given in detail in the CBA methodology reports. The major monetised benefits of policy options would come from reduced premature deaths and reduced loss of life expectancy. Also benefits from reduced 
morbidity contribute signifi cantly to the overall benefits, although it must be kept in 
mind that the basis of evidence for quantifyi ng the most influential morbidity health 
endpoints is more limited than for mortality. 
A way of defining the optimal ambition leve l would be to compare the cost per life 
year saved against the marginal benefit of  a life year saved. This balance should be 
limited to the costs for reducing PM
2.5 concentration only (therefore excluding 
additional costs linked with acidificati on, eutrophication and ground-level ozone 
targets), with the monetary valuation of both mortality and morbidity effects due to reduced PM
2.5 concentration. The optimum is th e point where marginal costs and 
marginal benefits are equalized. The reason is that at this point the total benefits minus the total costs (i.e. the net benef its) are maximised. Such an analysis was 
carried as part of this impact assessment This happens (see figure) beyond Scenario 
B. It should be noted, though, that with different assumptions of the value of statistical life, a higher amb ition level could be justified. 
For environmental benefits , a comparative analysis was made of the impacts of 
reduced air pollution on ecosystems, usi ng a precise ecosystem-specific deposition 
methodology. For acidification, although impr ovements are expected following the 
present environment policies, but major problems would remain in areas with sensitive ecosystems and high emissions. Regarding eutrophication, the scenarios 
would reduce the area with excess deposition of  nitrogen above the critical load, but 
substantial and severe eutrophication problems would remain in many Member 
States. As there is still no sound basis at present for further quantification impacts 
and valuation of impacts on different type s of ecosystems, omission of monetised 
ecosystem benefits out side of agriculture
6 may trigger a significant bias towards 
underestimation of total benef its and further research will be undertaken. There will 
also be benefits in other environmental areas. There are linkages and overlaps with climate change policy, and air pollution directly aff ects soil and water quality. 
Economic and social impacts 
The macro-economic effects of the options, as estimated using the GEM-E3 general 
equilibrium model,
7 do not appear to be significan t: The costs of meeting Scenarios 
A, B and C were estimated at 0.04%,  0.08% and 0.12% of EU-25 GDP in 2020 
respectively The Strategy has very little impact on overall employment. There are 
some sectoral shifts and some differences  between Member States. However, they 
cancel each other out. There would be a sma ll positive impact to exports. However, 
imports are estimated to grow more, main ly due to the terms of trade effect. 
                                                 
6 Damage to crops (mainly wheat yield loss) from ozone would be reduced by 0.3-0.5 billion euros in 
2020. 
7 The model was developed with the support of the 5th Research Framework Programme and is currently 
being used to develop the modelling capability of the Commission in the IQ-TOOLS project under the 
6th Framework Programme.  
 
EN 15   EN  
Macroeconomic impacts of three scen arios compared to baseline in 2020 
 Scenario A Scenario B Scenario C 
Gross Domestic Product -0.04% -0.08% -0.12%
Employment 0.00% 0.00% 0.00%
Private consumption -0.06% -0.13% -0.20%Investment -0.01% -0.02% -0.03%
Final energy consumption -0.12% -0.24% -0.34%
Exports to rest of the world 0.00% 0.01% 0.02%Imports from rest of the world 0.04% 0.10% 0.15%
Real wage rate -0.04% -0.09% -0.14%
Relative consumer price 0.00% 0.00% 0.00%Real interest rate 0.01% 0.02% 0.03%
Terms of trade 0.04% 0.08% 0.12%
These calculations do not take into accoun t efforts to improve the environment in 
non-EU industrialised and developing countri es and the increased compliance costs 
and the demand for technologies to re duce air pollution. These factors would 
contribute to enhancing the competiti veness aspects for European industry. 
Indeed, other developed countries, such as the USA8 and Japan, have similar or more 
stringent air pollution policies in place. Mo reover, awareness of air pollution issues 
is increasing in developing countries, such as China9 and India, and measures to 
improve environmental performance are being implemented. 
By focusing research and development on the resource-efficient and less polluting 
technologies that other countries will eventually need to adopt, the EU can gain advantages in terms of innovation, bus iness opportunities and export potential. 
Reducing damage to human health and the environment could help improve the EU’s 
competitiveness. 
Conclusion: Proposed inter im objective up to 2020 
All scenarios deliver benefits far in excess of costs.  However, the additional costs 
relative to benefits start to increase steep ly at around the mid ra nge (Scenario A/B).  
Furthermore, the changes in ecosystem improvements between the lower (Scenario A) and mid range scenario (Scenario B), ba lanced against costs, argue in favour of 
choosing a  level between the low and mid range that  delivers the lowest levels of air 
pollution that can be justifie d in terms of benefits a nd costs while preventing undue 
health risks for the population. It should also  be noted that the largest improvements 
are estimated to materialise from moving fr om the baseline to Scenario A. The costs 
of moving from Scenario A to B are estima ted almost to double and increase further 
                                                
 
8 The recent air pollution laws, such as the “Clean Air Interstate Rule”, which are comparable to the 
interim objectives in the Strategy, are estimated to cost for transport and power generation sectors alone 
in the US between $12 and $14 billion per annum. 
9 For instance, practically all newly built and expanded coal-fired units must install flue gas 
desulphurization units to meet new Chinese emission limit values. From 2007 all new cars sold in China must meet “Euro 3” emission limit values and the feas ibility of raising this requirement to “Euro 4” 
from 2010 is being evaluated. In sum, the Chinese policies to reduce SO2 and NOx emissions are 
similar to those of the EU and trailing by about 5 to 10 years. 
 
EN 16   EN by about €4 billion in Scenario  C for relatively small additio nal benefits.  This is why 
the Commission is proposing an ambitious, yet prudent, approach to setting environment and health objectives for 2020 coupl ed with a review in about five years 
from the adoption of the Strategy. The alte rnative environmental interim objectives 
up to 2020 and the proposed Strategy are given in the table below.  
Alternative environmental in terim objectives up to 2020 
 Human health  Natural environment 
Ecosystem area exceeded 
acidification 
(000 km2) Ambition 
level Cost of 
reduction 
(€bn) Life 
Years 
Lost due 
to PM 2.5 
(million) Premature 
deaths due 
to PM 2.5  
and ozone 
(thousands) Range in 
monetised 
health 
benefits10 
(€bn) 
Forests Semi-
natural Fresh-
water Ecosystem 
area 
exceeded 
eutrophicat-
ion  
(000 km2) Forest 
area 
exceeded 
ozone 
(000 km2)
2000  3.62 370 - 243 24 31 733 827 
Baseline 
2020  2.47 293 - 119 8 22 590 764 
Scenario A 5.9 1.97 237 37 – 120  67 4 19 426 699 
Scenario B 10.7 1.87 225 45 – 146  59 3 18 375 671 
Scenario C 14.9 1.81 219 49 – 160  55 3 17 347 652 
MTFR 39.7 1.72 208 56 – 181  36 1 11 193 381 
Strategy 7.1  1.91 230 42 – 135  63 3 19 416 699 
Note: Ecosystem benefits and the damage to materials and buildings have not been monetised but still need to be 
considered. MTFR is the Maximum Feasible Technical Reduction and includes the application of all possible technical abatement measures irrespective of cost. Only costs and benefits of moving beyond the baseline are 
presented. Lower value is based on the median of the value of a life year lost (VOLY) & higher value is based on 
mean value of a statistical life (VSL). Costs and benefits are annual amounts. In addition to the benefits the damage to agricultural crops is around €0.3-0.5 billion lower in 2020 under scenarios A-C. 
This level of ambition will entail improvements by 2020 relative to 2000 of: 
– 47% in life expectancy lost from exposure to particulate matter 
– 10% fewer cases of acute mort ality from exposure to ozone 
– 74% less forest area and 39%  less freshwater area wher e acidification critical 
loads are exceeded 
– 43% less area where critical load s for eutrophication are exceeded 
– 15% less forest area where critical levels are exceeded due to ozone 
                                                 
10 Lower  value is based on the median of the value of a life year lost (VOLY) and higher value is based 
on mean value of a statistical life (VSL). 
 
EN 17   EN Changes in loss of life expectancy in the EU  in 2000 and in the interim objective in 2020 
(Strategy) 
 
  
2000 Strategy in 2020 
Percentage of total ecosystems area receiving ni trogen deposition above the critical loads 
in 2000 and in the proposed interim objective for eutrophication in 2020  
 
 
2000 Strategy in 2020 
 
These improvements will require by 2020 emission reductions in the EU-25 of 82% 
for SO 2, 60% for NOx, 51% for VOCs, 27% for NH 3 and 59% for primary PM 2.5 
relative to emissions in 2000. The follo wing graph illustrates the reduction 
requirements and shows to what extent the reductions are due to current legislation 
being implemented up to 2020. 
 
EN 18   EN Improvement of health & environmen t indicators following the Strategy 
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Health (PM2.5)
Health (ozone)
Forest acidification
Ecosystem acidification
Freshwater acidification
Eutrophication
Forest damage (ozone)Current legislation
Further improvement
 
The level of ambition chosen for this Strategy has been estimated to deliver at least 
€42 billion per annum of benefits in mone tary terms representing between 0.35-1.0% 
of the EU-25 GDP in 2020. These benefits include fewer premature deaths, less 
sickness, fewer hospital admissions, im proved labour productivity etc. Although 
there is no agreed way to monetize ecosystem  benefits, the environmental benefits of 
reduced air pollution will be significant.  In addition, damage to buildings and 
materials will also be reduced. Similarly, fo r agricultural crops the damage would be 
reduced by around €0.3 billion per annum. 
Attainment of these targets is estimated to cost approximately €7.1 billion per annum 
representing about 0.05% of the EU- 25 GDP in 2020, though no net change in 
employment is expected. Production lost through ill health would be reduced. Low income groups generally exposed to the hi ghest levels of air pollution may benefit 
most. 
The chosen level of ambition represents an optimal balance between economic and 
environmental goals, contributing to Li sbon and the Community’s Sustainable 
Development Strategy objectives.   
 
EN 19   EN Measures and instruments 
The impact assessment of the different opti ons is based on the analysis of a set of 
technological measures with the RAINS model. The level of ambition of the 
Strategy, is based on a set of specific measures which woul d need to be undertaken at 
Community and Member State level. Thes e possible measures – in addition to 
current legislation – relative to the main pollutants are outlined below: 
– to reduce SO 2 emissions: the use of low–sulphur heavy fuel oils; flue gas 
desulphurisation; reducing the sulphur content of fuels; 
– to reduce NO x emissions: modifications to dom estic and industrial combustion 
plant including selective catalytic redu ction; bans on open burning of waste;  
– to reduce PM 2.5 emissions: using cyclones and fabric  filter dedusters for boilers in 
the commercial sector and new reside ntial boilers;improvements to diesel 
vehicles; 
– to reduce NH 3 emissions: reducing nitrogen content in animal feed; fertilizer 
substitution; low-emission housing for poultry; more use of low-ammonia 
application measures for pig and cattle manures;. 
– to reduce VOC emissions: control of fugitiv e losses in the chemicals industry and 
in refineries; control of the use of paints and solvents.  
In order to attain th e strategic objectives defined above , current air quality legislation 
will be simplified and other legislation revi sed where appropriate. Further initiatives 
will be taken on new vehicles and, subject to careful impact assessment, new measures may be envisaged for small combustion plants, ships and aircraft 
emissions. Community struct ural funds, internationa l cooperation and improved 
implementation will all form part of the sugge sted policy mix. Finally, it is clear that 
other sectors – like agriculture , energy and transport – will have to be involved with 
some of these measures. Recent reform of the Common Agricultural Policy should 
bring about a reduction in em issions from agricultural sources. In keeping with the 
commitments made in the White Paper on a common transport policy, the Commission will further encourage shifts to wards less polluting modes of transport, 
alternative fuels, reduced congestion and th e internalisation of externalities into 
transport costs. 
 
 
EN 20   EN PART TWO - IMPACT ASSESSMENT OF THE PROPOSED DIRECTIVE ON “AMBIENT AIR 
QUALITY AND CLEANER AIR FOR EUROPE ” 
In order to improve the re gulatory framework on air quality in line with the 
Commission’s Strategic Obj ectives 2005-2009 calling for Better Regulation, it is 
indispensable to modernise and simplify cu rrent air quality legislation – and to 
reduce its volume – in order to improve the competitiveness of the European economy.  
Better regulation – cutting red tape  and streamlining legislation 
Therefore, the Commission proposes to  combine the Framework Directive,
11 the 
First,12 Second13 and Third14 Daughter Directives, and the Exchange of Information 
Decision15 into one Directive on “Ambient Air Quality and Cleaner Air for Europe”. 
This will cut red tape, cl arify and simplify ambiguous pr ovisions, repe al obsolete 
provisions, modernise and reduce repor ting requirements, and introduce new 
provisions on fine particulates . The Fourth Daughter Directive16 will be merged later 
through a simplified “codification” process. While the impacts of this modernisation 
and simplification exercise cannot be quantif ied in monetary terms, it is certain to 
have positive effects on competitiveness by reducing bureaucracy and increasing transparency. 
Addressing specific implementation problems 
It is necessary to address some implementation problems that have occurred with 
current air quality legislation. The Commi ssion proposes to allow Member States to 
request an extension to extend the deadlin e for compliance in affected zones if 
objectively verifiable conditi ons are met, including information on the compliance 
with certain Community legislation contribu ting to improvement of air quality. As a 
quid pro quo the Member State would ha ve to develop and implement an air 
pollution abatement programme to ensure that the limit values are attained upon 
expiry of the extension. It has not been  possible to quantify the impact of this 
proposal, which is a “safety valve” ag ainst unduly high abatement costs in 
exceptional situations.  
Modernising reporting requirements 
It is also necessary to bring the repor ting requirements for air quality into the 21
st 
century by using the internet as the ma in means of delivery and making this 
compatible with INSPIRE.17  
                                                 
11 Council Directive 96/62/EC OJ L 296, 21.11.1996, p. 55 
12 Council Directive 1999/30/EC OJ L 163, 29.6.1999, p.41 
13 Directive 200/69/EC OJ L 313, 13.12.2000, p. 12 
14  Directive 2002/3/EC OJ L 67, 9.3.2002, p.14 
15 Council Decision 97/101/EC O.J. L 35, 5.2.1997, p. 14 
16 Directive 2004/107/EC OJ L 23, 26.1.2005, p. 3 
17 Proposal for a Directive of the Euro pean Parliament and of the Council establishing an infrastructure for 
spatial information in the Community (INSPIR E) COM(2004) 516 final, SEC (2004) 980. 
 
EN 21   EN In the light of recent health evidence, the Commission is proposing the following approach.  
No change in current limit values 
Based on the advice received from the scientific community – WHO ’Systematic 
review on air pollution he alth aspects in Europe’ and the Commissions’ Scientific 
Committee on Health and Envi ronmental Risks – the Commi ssion is not proposing to 
revise the current limit and target values for air pollutants set by European air quality legislation. However, the Commission proposes  to repeal the indicative limit value of 
PM
10 for 2010 and – on the basis of scientif ic advice and health evidence – to start 
regulating fine particulate ma tter below 2.5 microns (called PM 2.5) differently. 
Reducing annual average urban bac kground concentrations of PM 2.5 between 2010 and 2020 
The latest scientific evidence confirms that PM 2.5 is responsible for significant 
negative effects on human health, and thus  leads to substantial loss of life by 
European citizens. Further, there is no identifiable threshold below which particulate matter would not pose a risk to human health. Because of this evid ence, it is vital to 
regulate fine particulate matter differen tly from some other air pollutants. The 
Commission considers that the proposed effective and proportional approach – 
namely reduction of the average annual  urban background concentration of PM
2.5 – 
is justified  
The Commission proposes a two-stage appr oach by first setting a concentration 
reduction target of 20% between 2010 and 2020 for PM 2.5. Based on actually 
monitoring data of 2008-2010 the Commi ssion would secondly propose a legal 
requirement each Member State to reduce average annual urban background concentrations of PM
2.5 by a definited minimum percentage between 2010 and 2020 
possibly calculated for each microgram per cubic metre of PM 2.5 measured in the 
baseline concentration. It  also proposes that average annual urban background 
concentrations be calculated as a three- year running average – starting from the 
period between 2008 and 2010, thus modera ting the impact of meteorological 
variability. The reduction would be based upon the arithmetic (or population 
weighted, if data allows) mean of all measurements of PM 2.5 concentrations made in 
urban background locations in the territory of the individual Member State. The 
reduction requirement is described in detail  in Section 7.4 of the Impact Assessment. 
Benefits and costs of regulating PM 2.5 at EU level 
The benefits of the Commission’s proposal to require a reducti on of the average 
urban background concentration, between 2010 and 2020, between €37 billion and €119 billion per annum in 2020. These are be tween seven and 24 times higher than 
the estimated costs of between  €5 and €8 billion per annum. 
Capping unduly high risk  
The Commission also proposes a “cap” of 25 micrograms per cubic metre expressed 
as an annual average to be attained by 2010. The level of the cap is such as to be 
entirely consistent with the existing limit value for PM
10, so Member States are not 
expected to incur any additional burden. The cap will apply throughout the territory 
of the Member States.  
 
EN 22   EN The main justification for proposing the “ca p” is to ensure that there are no 
unintended consequenc es of reducing PM 2.5 average concentrations. No European 
should be exposed to unduly high levels of PM 2.5 concentrations. 
Follow-up: New proposals to reduce emissions 
Since a large fraction of air pollu tion – including the precursors to PM 2.5 
concentrations – travels very long di stances, the Commission intends to make 
legislative proposals in the near future to reduce the transb oundary component of 
urban background concentration of PM 2.5. These measures include reviewing 
emissions limits for light- and heavy-dut y vehicles (e.g. to go beyond current Euro 
standards) and revision of the National Emission Ceilings for 2015 or 2020 in order 
to reduce urban background concentrations of PM 2.5 consistent with the proposed 
new way of regulating PM 2.5. 
MONITORING , EVALUATION AND CONSULTATION  
The EEA and Eurostat have developed i ndicators to monitor the impacts of air 
emissions on human health and the envi ronment, and there will be long-term 
monitoring under the UNECE Conventi on on Long-range Transboundary Air 
Pollution. Monitoring, modelling, assessm ent and mapping will follow agreed 
methodologies. Since Community air pollution policy is built on robust scientific and 
technical knowledge, continual further resear ch will be needed to refine current and 
future policies and measures. Our understand ing of adverse health  and environmental 
impacts is improving all the time, so it is im portant to keep targ ets and policies under 
review, and to take account of changes in the costs and effectiveness of measures. 
The Commission plans to carry out a first review in about fi ve years from the 
adoption of the Strategy.  
Public consultation has shown that more than half of Europeans are worried about air 
pollution, particularly its impacts on the e nvironment and health. They attach a high 
priority to improving air qua lity and call for a level of environmental ambition 
resembling Scenario C. The international and European levels were seen as the most 
appropriate for taking action. Respondents identified indus trial production and traffic 
most often as the targets for measures. They were also prepared to take individual action themselves and to pa y to improve air quality.  
These results were taken into  account in the Strategy, par ticularly when defining the 
environmental ambition level, when developing the health and environment objectives, and when identifying measures  to simplify legislation and improve 
information to the public. 
In addition to consultation of stakeholde rs and the public, internal consultation 
between the various Commission services  has been a regular feature of the 
preparation of the Strategy.  
 
EN 23   EN 1. INTRODUCTION  
This Impact Assessment (IA) describes th e options considered  in developing the 
Thematic Strategy on Air Pollution (“the Strategy ”) and justifies the choices 
presented in the Strategy and in the Comm ission’s proposal to revise the air quality 
framework directive,18, the first three daughter directives19 and the Council decision 
on the exchange of air quality information20 (“the Air Quality Proposal ”). The  
Strategy is part of the Sixth Co mmunity Environment Action Programme21 
(6th EAP), which sets objectives for action and several thematic strategies to address 
important aspects of the environment. The EAP lays down the objective for the 
Strategy as “achieving levels of air quali ty that do not give rise to significant 
negative impacts on and risks to hu man health and the environment”. 
This assessment follows closely the Impact Assessment Guidelines of the 
Commission22 and considers the economic, social  and environmental dimensions in 
an integrated and balanced manner. The guidelines emphasise the need to concentrate on those impacts that  are likely to be the most significant and/or will lead 
to important distributive effects. The analysis  presented here is consistent with these 
principles and is proportionate to the nature of the proposal 
The problem of air pollution and the trends in emissions and impacts foreseen up to 
2020 are described in Chapter 2. Chapter 3 examines the long-term objectives defined by the 6th EAP, and Chapter 4 desc ribes the process used  for the definition 
of a set of policy options co rresponding to interim levels of ambition for air quality 
by 2020. Chapter 5 provides a detailed asse ssment of the environmental, economic 
and social implications of each level of ambition. Chapter 6 describes the measures 
that would have to be implemented for each level of ambition. The impact assessment for the legislative proposal accompanying the Thematic Strategy (revised 
directives on ambient air quality) is pres ented in Chapter 7. Chapter 8 details the 
monitoring and evaluation implications of  the Thematic Strategy, and Chapter 9 
reports on the stakeholder and public consultation undertaken for the definition and evaluation of the Thematic Strategy. 
The assessment is underpinned by a subs tantial body of knowledge generated by 
Commission service contracts, studies, health advice from the World Health 
Organisation (WHO), advice from Comm ission working groups, and by workshops 
and conferences under the Clean Air for Eu rope (CAFE) Programme. It also builds 
on information provided by Commission RTD projects and assessment programmes 
under the UN ECE Convention on Long Range Transboundary Air Pollution 
(CLRTAP). A comprehensive list and refere nces to these reports and activities is 
given in Annex 1. 
                                                
 
18 Directive 96/62/EC, OJ L 296, 21.11.1996, p. 55. 
19 Directive 99/30/EC, OJ L163, 29.6.1999, p. 41; Directive 2000/69/EC, OJ L 313, 13.12.2000, p. 12; 
Directive 2002/3/EC, OJ L 67, 9.3.2002, p. 14. 
20 Decision 97/101/EC, OJ L 35, 5.2.1997, p. 14. 
21  Decision 1600/2002/EC OJ L242, 10.9.2002, p 1.  
22 See http://europa.eu.int/comm/secr etariat_general/impact/key.htm  
 
EN 24   EN The methodology and the modelling framework us ed in the integrated assessment of 
options presented in the Strategy are descri bed in Annex 2. The main elements were: 
(1) establishment of baseline scenario for ai r pollution up to 2020; (2) anal ysis of the 
“policy gap” between the baseline a nd Community long-term objectives; (3) 
assessment of policy options; and (4) definiti on of interim objectives for the Strategy.  
The assessment uses our best scientific understanding of the emissions, atmospheric 
transport, and human health and environm ental impacts of air pollution. Where there 
is sufficient consensus and robust inform ation a quantitative assessment has been 
provided i.e. for human health impacts.  Many health impacts have also been 
estimated in monetary terms, but this ha s not been possible for the assessment of 
impacts on the natural environment. Becau se of this, an “Extended Cost-Benefit 
Analysis” has been set up, in order to in clude effects that ar e not quantified or 
assessed in monetary terms but are likely to  be important and potentially capable of 
changing the balance of  costs and benefits. 
The methodology used has also been subject to independent scien tific peer reviews.23 
These reviews give details of possible uncer tainties caused by model simplifications, 
assumptions, boundary conditions and inhere nt technical uncertainties. Extensive 
sensitivity analyses24 have also been performed to  assess uncertainties and the 
robustness of the model resu lts, particularly uncertainties in energy demand and 
agricultural production, emissions data and em issions abatement factors, the various 
ambition levels, or target-setting methods. These aspects are described in Annex 2, 
and were thoroughly discussed with contract ors and stakeholders during work on the 
Strategy.25 This process will lead to improvements in the impact assessment 
modelling used for revision of the Na tional Emission Ceilings Directive26 in 2006. 
 
                                                 
23 See http://europa.eu.int/comm/environmen t/air/cafe/activities/rain_model.htm  and 
http://europa.eu.int/comm/environment/air/cafe/activities/krupnick.pdf  
24 i.e. numerous models with different key assumptions in order to estimate to what extent optimised 
strategies are dependent on various input parameters 
25 In particular the Working Group of Target Setting and Policy Assessment as well as the CAFE Steering 
Group. 
26 Directive 2001/81/EC, OJ L 309, 27.11.2001, p. 22. 
 
EN 25   EN 2. WHAT PROBLEM DOES THE THEMATIC STRATEGY ON AIR POLLUTION SET OUT TO 
TACKLE ? 
2.1. The problem of air pollution 
Air pollution is a significant publ ic health concern. It is re sponsible for a significant 
reduction in average life expectancy, seve ral hundred thousand premature deaths, 
thousands of additional hospital admissi ons, increased use of medication and 
millions of days every year where activities are restricted. The pollutants of most concern for human health are ozone and airborne particulate matter.  
There are many sources of air pollution; the main contributing sectors are transport, 
power generation, industry, agri culture, domestic use of pr oducts, and heating. All 
these sectors emit a variety of air pollutants, such as  sulphur dioxide, nitrogen 
oxides, ammonia, volatile organic substances  and particulate matter. Other important 
air pollutants include persistent organic pollutants, heavy metals and polyaromatic 
hydrocarbons. The relationship between the economic sectors, emissions, air 
pollution and the negative effects is schematically outlined in Figure 1. The pollutants of most concern for human hea lth are ozone and airborne particulate 
matter. 
Two environmental problems are worth setting out in more detail.  Particulate matter  (particles in the range PM
10 – PM 2.5) consists both of 
(i) “primary particles”, which are emitted directly into the atmosphere from combustion processes, industrial proce sses and mechanical, like grinding, and 
(ii) emissions of gaseous polluta nts such as sulphur dioxide (SO
2), nitrogen oxides 
(NO x) and ammonia (NH 3), which are altered through chemical reactions in the 
atmosphere, adding to the particulate ma ss, and are referred to as “secondary 
particles” or “secondary aerosol”.27 Varying amounts of water also contribute to the 
aerosol particulate mass. The total atmosphe ric burden of aerosol particulate matter 
depends on the total emissions of primary pa rticles and the contribution of secondary 
particulate matter. The contribution of gase ous pollutants to the fraction of secondary 
inorganic aerosol particulate matter is  well described and validated through 
comparison with monitoring data, whereas th ere is a lack of unde rstanding about the 
formation of secondary organic aerosols particulate matter and also very limited 
monitoring data for model validation. At present the asse ssment of aerosol 
particulate matter with models systemati cally underestimates the contribution of 
secondary aerosols, and the total particulat e matter as the contri bution to secondary 
organic aerosol is not include d. The modelled values of aer osol particulate matter are 
some 20 to 30 percent lower than the observe d values of particulate matter. Part of 
the reason for the difference is that secondary  organic aerosol is not accounted for in 
the model. 
                                                 
27 Particulate matter in ambient air is classifi ed according to its aerod ynamic diameter, so PM 10 and PM 2.5 
refer to all particles with a diameter of less th an 10 micrometer (µm) and 2.5 micrometer (µm) 
respectively. The “fine fraction” (PM 2.5) is more strongly associated wi th anthropogenic activities than 
the “coarse fraction” (particles in the range PM 10 – PM 2.5), which may contain for example wind-blown 
dust and Saharan sand. Secondary aero sol falls into the fine fraction. 
 
EN 26   EN Ozone  occurs naturally in the stratosphere and in the troposphere, but ozone 
concentrations close to ground-level are harmful to ecosystems and human health. 
Ground-level ozone is formed from the comp lex chemical reactions between volatile 
organic compounds (VOC) and NO x in the presence of sunlight.  VOC are emitted 
from many different sources, including petrol  stations, tailpipe emissions from cars, 
and the use of solvents and solvent containi ng products such as pa ints and varnishes. 
Figure 1: The problem of air pollution 
 Transport
AgricultureDomesticPower 
generation
Industry / 
ProcessesSO2
VOCNOxNH3PM
Acid deposition
Eutrophication
Ground level 
ozonePM 
Concentration
Nature / 
Biodiversity
CropsMaterialsHealthSECTORS EMISSIONS AIR QUALITY EFFECTS
Transport
AgricultureDomesticPower 
generation
Industry / 
ProcessesSO2
VOCNOxNH3PM
Acid deposition
Eutrophication
Ground level 
ozonePM 
Concentration
Nature / 
Biodiversity
CropsMaterialsHealthSECTORS EMISSIONS AIR QUALITY EFFECTS
 
Source : RAINS, CBA, based on EEA, Air pollution in Europe 1990-2000, Topic report 4/2003 
2.1.1.  Air pollution impacts 
Air pollution can have a number of impacts:  damage to human health, acidification, 
eutrophication, and damage to other ecosyst ems such as forests. Other impacts have 
been identified and assessed, such as damage  to materials, buildings and cultural 
heritage, as well as wider economic and so cial effects. Chapte r 5 of this report 
provides a more detailed review of thes e impacts and the methodology used for their 
assessment.  
Ozone and airborne particulate matter can affect human health28. They are 
responsible for several hundred thousand pr emature deaths every year. They also 
cause thousands of additional hospital admi ssions and millions of days every year 
where individuals have to restrict their ac tivities. These health impacts are caused by 
both long-term (chronic) and short-term ( acute) exposure, resulting in both mortality 
(death) and morbidity (illness). The “Syste matic Review of Health Aspects of Air 
                                                 
28 Scientific evidence exists also concerning health e ffects caused by nitrates, sulphates and ammonia as 
aerosols. These effects however are significantly smal ler (results of ExternE projects). In addition, for 
the purpose of CAFÉ, those effects are considered th at are explicitly recognized by international bodies 
such as WHO. 
 
EN 27   EN Pollution in Europe” carried out by WHO29 revealed significant impacts of exposure 
to particulate matter and ozone even at lo w concentrations. Indeed, no safe level for 
effects has currently been identifi ed for either of these pollutants.30 
Emissions of SO 2, NO x and NH 3 contribute to the acidification of lakes, rivers, 
forests and other ecosystems , including Natura 2000 sites. 31 Acidification can 
result in the loss of fauna and flora, and ecosystems may take many decades to 
recover after acidifying inputs are reduced to sustainable levels.32 
Eutrophication  can occur when nutrient nitrogen is deposited. This can lead to 
changes in the composition of species in  plant communities and loss of biodiversity. 
Emissions of NO x and NH 3 contribute to nutrien t nitrogen deposition.  
Ground level ozone can also damage forests, crops and vegetation  where a critical 
level of ambient concentration is exceeded.33 Ozone damage is recognised as the 
most serious regional air pollution problem  affecting the agricultural sector in 
Europe. 
Air pollution also has an impact on material and cultural heritage.  The main 
damage was earlier due to high levels of sulphur dioxide, but the increase in vehicle 
emissions created a new multi-pollutant s ituation. A recent EU research project 
MULTI-ASSESS34 developed dose-response functions for corrosion and soiling of 
indicator materials for the multi-pollutant situation involving the effect of both climate and pollution. These have been us ed to propose new quality objectives to 
protect various materials, expressed as " acceptable" concentrati ons of air pollution. 
For SO
2, an "acceptable" level of 10µg/m3 is proposed that pr otects 80% of European 
territory at present HNO 3 levels. Taking an "acceptable" soiling level and intervals 
between cleaning, an acceptable PM 10 level of 15 µg/m3 has been calculated. These 
objectives would be relevant in areas with cultural assets and other materials that 
require protection from corrosion and soiling. 
The quantitative impact assessment of the Strategy concentrated on five major 
impacts of the five major polluta nts, as illustrated in Table 1 
                                                 
29 http://www.euro.who.int/eprise/main/WHO/Progs/AIQ/Activities/20020530_1  
30 Given that there is a finite back ground concentration of ozone, the analyses presented here are only 
based upon situations wher e 8-hour mean ozone concentrations ex ceed 35 parts per billion (ppb), which 
corresponds to an ozone equivalent concentration of 70 micrograms per cubic metre (µg/m3). 
31 For many of these impacts a “critical load” is defined. This represents a quantified amount of, for 
example, acid deposition below which the ecosystem is not expected to be at risk. 
32 The compensating effects of pollutants should also be considered : in some cases, the acidification 
effects persist as compensating effects between PM  and SOx do not take place anymore, given the 
reduction of PM but the still high level of SOx from Eastern Europe might balance this (results from the 
GARP II report - Chapter 11 "Forest and Ecosystem damage"). 
33 Such a critical level is expressed in terms of an accumulated concentration in hours above a threshold of 
40 ppb (equivalent to 80 µg/m3). For forest the critical level is 5, 000 part per billion hours (ppb.hours). 
34 http://www.corr-institute.se/MULTI-ASSESS/   
 
EN 28   EN Table 1: Multi-pollutant/multi-e ffect approach of the Strategy 
 Primary 
PM SO 2 NO x VOC NH 3 
Health effects :      
- Particulate matter √ (22%) √ (19%) √ (13%)  √ (46%) 
- Ground-level ozone    √ √  
Vegetation effects :      
- Ground-level ozone   √ √  
- Acidification  √ (27%) √ (24%)  √ (49%) 
- Eutrophication   √ (37%  √ (63%) 
Source: RAINS. Percentages represent the relative contri bution of each primary pollutant to the effect, as 
estimated by RAINS at EU-25 level, fo r a marginal change over 2020 baseline.  This calculation is not available 
for ground-level ozone. 
2.1.2.  Current trends in air quality 
Air pollution travels long distances and it has long been recognised as posing 
significant risks to human health and the environment. Therefore, air pollution has long been regulated at European level. Fo r example, the first Community legislation 
to reduce air pollution from passenger cars was introduced  as early as 1970,
35 
followed by legislation on ambient air quality.36 Subsequently, there have been 
Community measures to address emissions from large combustion plants, to prevent 
emissions from large industrial installations  in an integrated way, to improve fuel 
quality, to reduce the VOC content of pr oducts, to improve the framework for the 
management of ambient air quality, and to  set national emission limits for important 
atmospheric pollutants. 
Reductions in air emissions should lead  to better air quality. However, the 
relationship between primary pollutant  emissions and air quality is not 
straightforward. Air quality is affected not only by local emissions but also by the 
interactions between these pollutants, thei r long-range transport in the atmosphere, 
natural emissions and meteorological condi tions. There is increasing evidence that 
air pollution travels even longer distances  than thought before. Such hemispheric 
transport of air pollution between the contin ents is a new emergi ng issue and will be 
discussed in section 8.3.  
Ambient concentrations of PM 10 before 2000 decreased due  to measures tackling 
contributing sources such as large combusti on plant and diesel ve hicles. More recent 
measurement data over the period 1997 to 2001 show a decreasing trend in ambient 
PM 10 concentrations up to 1999 and then a sli ght increase up to 2001. Over the entire 
period concentrations have been redu ced by around 15-20%, though the picture 
varies across Europe as ther e is a mix of decreasing, stat ic and increasing trends in 
                                                 
35 Directive 70/220/EEC, L 76, 6.4.1970, p.1. 
36 Council Directive 85/203/EEC of 7 March 1985 on air quality standards for nitrogen dioxide, and 
Council Directive 80/779/EEC of 15 July 1980 on ai r quality limit values and guide values for sulphur 
dioxide and suspended particulates.  
 
EN 29   EN concentrations. Whilst there ha s been some monitoring of PM 2.5 concentrations since 
legislative requirements were introduced in  1999, it is insufficien t to determine long-
term trends. 
The situation for ozone polluti on is partly dependent on emi ssions in the EU, but also 
on the background ozone concentrations of  air coming to Europe (also known as 
hemispheric background). That ozone bac kground concentration has been observed 
to increase in recent decades and is projecte d to increase further due to the increased 
emissions of ozone precursors over the Northern hemisphere. Hence, there are 
concerns that the reduction in emission of oz one precursors in Europe is being partly 
neutralised by the increased background ozone  levels over the northern hemisphere.37 
2.2. Trends in air pollution levels up to 2020: the CAFE Baseline 
2.2.1.  Trends in pollutant emissions 
Community-wide and national policies have  brought about and wi ll continue to 
deliver substantial emissions reductions  in Europe. The CAFE programme has 
brought together information on the likely levels of air pollu tion given present 
policies for the period 2000-2020. This CAFE baseline38,39 (see Annex 2 for details) 
takes into account future economic developm ent, as well as the effect of emissions 
control legislation. Some legislation has not been included because it leaves the 
Member States substantial discretion as  to its implementation or attainment.40 
Emissions of most air pollutants are projected to decline in the EU-25 even if 
economic growth takes place (Figure 2). The forecasts for emissions in the EU-25 of 
specific air pollutants under the baseline scenario are as follows. 
– Large reductions for sulphur dioxide (SO 2) (68% by 2020 compared to 2000) 
are expected as a consequence of the decline in coal consumption and full implementation of the large combusti on plant directive amongst others. 
– Emissions of nitrogen oxides (NO
x) are projected to decrease by 49% over the 
period 2000-2020 because of a decline in traditional emissions (e.g. from road transport) so that in the future other s ectors such as domestic heating, industrial 
and combustion processes, maritime sh ipping and non-road machinery will 
make more important contributions.  
– The emissions of volatile organic compounds (VOC)  are projected to decline 
by 45% over the period 2000-2020. The largest reduction should come from mobile sources and the use of solvents and paints. 
                                                
 
37 See EMEP/CCC Report 1/2005, http://www.nilu.no/ projects/ccc/reports/cccr1-2005.pdf  
38 http://www.europa.eu.int/comm/environmen t/air/cafe/general/pdf/cafe_lot1.pdf  
39 http://europa.eu.int/comm/environment/air/cafe/general/pdf/scenarios_cafe.pdf  
40 For example, the current ambient air quality legislation has not been included directly in the baseline 
because it sets environmental quality standards but does not propose the measures that the Member 
States must take to meet those standards. A second example is attainment of the ceilings in the National 
Emissions Ceiling Directive, as this Directive does not prescribe the measures to be implemented but 
only imposes an obligation for the ceilings to be attained. However, in both cases where the national 
source-based measures are known (Community-wide or national) these have been included in the 
baseline. 
 
EN 30   EN – Ammonia (NH 3) emissions are not likely to cha nge. As the vast majority of 
ammonia emissions come from agriculture  it would have been important to 
include the impact of the recent Common Agriculture Policy (CAP) reform on 
ammonia emissions. However, as it was not yet known, at the moment of the assessment, how Member States will exact ly implement the CAP reform, it has 
not been possible to revise  the baseline emissions. The impact of CAP reform 
on ammonia emissions has to be carefully estimated, and this will be done in the context of the review of the NECD. 
– Emissions of primary particulate matter in the PM
10 size fraction are 
projected to decrease by 39% fo r the EU-25 over the period 2000-2020.41 
Reductions in the power generation and transport sectors are primarily responsible for these improvements. The fine fraction (i.e. PM
2.5) is predicted 
to decline by around 45%. Th is is partly due to th e implementation of more 
stringent emission standards for road ve hicles such as the Euro 5 emission 
limits for heavy duty engines.   
Figure 2: EU-25 land-based emissi ons of pollutants from 1990 to 2020  
 0500010000150002000025000
1990 2000 2010 2020kilo tonnesSO2
NOx
VOCs
NH3
 
Source: CAFE Baseline final report. Land-based emissions of pollutants covered by the NECD 
With the effect of all these policy changes, the relative importance of different land 
based sources is also forecast to change. (Table 2) In contrast to the expected reductions in emissions from land-based sources, the maritime sector is becoming 
an even larger source of air pollutio n. It is projected that emissions of SO
2 from the 
maritime sector will increase by around 45% while emissions of NO x will increase 
by approximately 67%. With these growth rates, emissions of SO 2 and NO x from the 
maritime sector should surpass total emissions from land-based sources by 2020. 
                                                 
41 So far 14 out of 25 Member States have reported PM emission inventories, thus limiting the validation 
of the quality of the RAINS calculations. 
 
EN 31   EN Table 2: Emissions by sect or for EU-25 (% total) 
 % land based sources 
 SO 2 NO X VOC NH 3 PM 2.5 
 2000 2020 2000 2020 2000 2020 2000 2020 2000 2020 
Power generation 57.4 21.6 17.8 13.6 0.9 1.3 0.4 0.6 8.5 5.7
Industry 18.7 29.8 9.6 14.5 0.5 0.7 0.1 0.1 1.9 1.9
Households 7.6 7.2 5.5 10.1 7.2 9.0 0.7 0.6 38.7 39.3
Transport 4.6 7.7 61.3 51.2 38.9 17.5 2.0 0.6 28.9 20.3
Agriculture 0.0 0.0 0.0 0.0 0.5 1.0 91.1 92.7 3.9 7.1
Processes 11.7 33.7 5.8 10.6 51.9 70.5 5.8 5.4 18.2 25.8
Total land (kt) 8,735 2,805 11,581 5,888 10,661 5,916 3,824 3,686 1,749 964
International sea 
transport (kt) 2,430 3,526 3,557 5,951 n/a n/a n/a n/a n/a n/a
Share of land 
based sources %  27.8 125.7 30.7 101.1 n/a n/a n/a n/a n/a n/a
Source: RAINS 
Most of the significant emission reduction was achieved for emitting sectors 
regulated at European level. In that sens e European legislation has been successful 
and ensured a real decoupling between emi ssions of pollutants and economic growth. 
The important future emitting sectors are not  regulated at European level and often 
consist of a large number of smaller emitters  which are more complicated to regulate 
and control. 
2.2.2.  Trends in particulate matter concentrations 
Ambient concentrations of PM 2.5 are projected to decrease from 2000 to 2020 
(Figure 3) as a result of changes in pr imary emissions and al so in the precursor 
emissions of secondary aerosol (SO 2, NO x, and NH 3). As explained above 
(Section 2.1)) the secondary ae rosol contribution is systematically underestimated in 
models. The changes in PM 2.5 levels over time shown in Figure 3 give an estimate of 
reductions in PM 2.5 levels than can be expected fr om the reductions in emissions in 
2000 and 2020. It should also be kept in mind, however, that these changes may be 
masked year to year by change s in meteorological conditions. 
 
EN 32   EN Figure 3: Loss in life expectancy attributable to anthropogenic PM 2.5 in 2000 and 2020 
 
  
2000 Baseline 2020 
Source: RAINS. Note: Calculation based on meteorological conditions of 1997. 
Rationale for using 1997 meteorological conditions in this Impact Assessment 
Impacts of air pollution depend not only on the emissions but also on meteorology. For 
instance, in 2003 the concentrations of ozone a nd particulate matter were high in many EU 
Member States which experienced an excepti onally hot and sunny summer. In the CAFE 
baseline report an average meteorology was calculated for 1997, 1999, 2000 and 2003 and 
these results were used for the CAFE Baseline report.  
However, the impact assessment was calcul ated using 1997 meteorology because it was not 
possible to calculate all combinations of mete orological conditions in time for this impact 
assessment42. Year 1997 was chosen as it was considered the most representative of all four 
available years. In order to compare like-with-like  the environmental and health effects of 
different scenarios baseline calculations up to 2020 were calcul ated by using 1997  
meteorological conditions and these were compared  with the situation in 2000 using also the 
meteorological conditions of 199743. Thus, unless otherwise stated, all environmental and 
health effects of different scenarios in this Impact Assessment use the same 
meteorological conditions of 1997.  
2.2.3.  Trends in ground-level ozone concentration 
Following the WHO advice that “ the largest burden on public health may be 
expected from the many days wi th mildly elevated concen trations, and not with the 
few days with very high concentrations ”,44 control strategies now address general 
                                                 
42 It takes about 3 months for a supercomputer to run all scenarios for one meteorological year. Thus, only 
one year could be counted for this impact assessmen t and 1997 was chosen as the most representative 
year. For the calculations of the revi sion emissions ceilings directive, five meteorological years will be 
calculated. 
43 Had a different meteorogical conditions been selected, the results in the Impact Assessment would have 
been biased and reflected rather the impact of me teorology rather than the change of anthropogenic 
emissions of air pollution. 
44 Modelling and assessment of the health impact of particulate matter and ozone : Summary report 
prepared by the joint Task Force on the Health  Aspects of Air Pollution of the World Health 
Organization/European Centre for Environment and Health and the Executive Body  
http://www.unece.org/env/documents/200 4/eb/wg1/eb.air.w g1.2004.11.e.pdf   
 
EN 33   EN background concentrations45 and not just very high but short-term concentrations, 
because of the observed health effects of high ozone levels from relatively low atmospheric concentration. While the health problems related to PM
2.5 are most 
severe in North-West Europe, the issue of  ozone is particularly important in the 
Mediterranean Member States. Despite appreciable improvements, many of the 
densely populated areas in the south c ould still be at risk by 2020 (Figure 4). 
Figure 4: Health effects attr ibutable to exposure ground-le vel ozone (ppb.days) in 2000 
and 2020  
2000 Baseline 2020 
Source: RAINS. Note: Calculation based on meteorological conditions of 1997. 
The ozone critical level46 for forests was frequently passed in 2000 in large parts of 
the European Union. Baseline emission reductions will improve the situation, but will not be sufficient to eliminate the risk even by 2020 (Figure 5)). 
                                                
 
45 The indicator used for assessing ozone health imp acts is called SOMO35, and co rresponds to the sum of 
excess of daily maximum 8-h means over the cut-off of 35 ppb (which is equivalent to 70 µg/m3) 
calculated for all days in a year. Previous Community objectives for ozone focused on reducing human 
exposure to concentrations above a threshold of 60 parts per billion (120 µg/m3). 
46 The Working Group on Effects of the LRTAP Co nvention recommended that the metric “accumulated 
ozone over a threshold of 40 ppb” (AOT40) be used as the indicator for ozone damage to vegetation. 
The revised ozone critical level for forests is  5,000 parts per billion hours (ppb.hours). 
 
EN 34   EN Figure 5: Evolution of ozone ex posure for forests in 2000 and 2020 
 
  
2000 Baseline 2020 
Source: RAINS. Note: Calculation are based on the meteorological conditions of 1997, 1999, 2000 and 2003, 
using ecosystem-specific deposition to forest. The maps were not available for 1997 meterological data alone. 
However, the difference would be sm all. The critical level for forest trees is set at 5 ppm.hours. 
2.2.4.  Trends in acidification and eutrophication 
Sulphur deposition has fallen significantly over the past 20 years and large areas are 
now expected to be protected from fu rther acidification. In 2000, acidifying 
deposition was still above critical loads47 in parts of central and north-west Europe. 
The percentage of EU-25 forest  areas receiving acid depos ition above their critical 
load is projected to decrease from 23% in  2000 to 13% in 2020 (Figure 6). For those 
areas still at risk, ammonia is projected to  be the dominant source of acidification in 
the future.48 The projected trend for so-called “semi-natural” ecosystems49 is 
similar (decrease from 23% to 9%) (Figure 7). 
                                                 
47 The concept of critical loads is used as the quantitative indicator for sustainable levels of sulphur and 
nitrogen deposition. Critical loads databases are compiled by the Coordination Centre for Effects (CCE) 
of the CLRTAP, which combines quality-controlled critical load estimates submitted by each of the 
national focal centres designated by each party to the CLRTAP. Currently more than 1.6 million 
monitoring sites are included in the database 
48 The compensating effects of polluta nts should also be considered. In  some cases acidification effects 
persist because compensating effects between PM and SO X do not take place anymore, given the 
reduction of PM but the still high level of SO X from Eastern Europe (results from the GARP II report - 
Chapter 11 "Forest and Ecosystem damages"). 
49 Only six Member States have provided estimates of  critical loads for “semi-natural” ecosystems, which 
are nature and landscape protection areas, many of them designated as “Nat ura 2000” areas under the 
EU Habitat directive : France, Germany, Ire land, Italy, the Netherlands and the UK 
 
EN 35   EN Figure 6: Evolution in forest area with acid  deposition above critical loads in 2000 and 
2020 
2000 Baseline 2020 
Source: RAINS. Note: Calculation results are based on the meteorological conditions of 1997, using ecosystem-
specific deposition to forests. 
Critical loads for freshwater bodies ( lakes and streams ) have been estimated only 
for three EU Member States and Norway.50 Figure 8 shows a significant decline in 
acid deposition between 2000 and 2020, but th is may not allow recovery from 
acidification as deposition ma y remain above the critical loads. Even when acidic 
deposition can be reduced to levels below th e critical load, there may be a time-lag of 
several decades before chemi cal and biological recovery  
Figure 7: Percentage of the area of semi-natural ecosystems receiving acid deposition 
above the critical loads in 2020 and 2020 
2000 Baseline 2020 
Source: RAINS. Note: Calculation results are based on the meteorological conditions of 1997, using ecosystem-
specific deposition. 
                                                 
50 Finland, Sweden and the UK.  
 
EN 36   EN Figure 8: Percentage of freshwater ecosystems area receiving acid deposition above the 
critical loads in 2020 and 2020 
 
  
2000 Baseline 2020 
Source: RAINS. Note: Calculation results are based on meteorological conditions of 1997, using ecosystem-
specific deposition. 
Excess nitrogen deposition poses a threat to a wide range of ecosystems endangering 
bio-diversity through changes in plant communities. Excess ni trogen deposition 
above critical loads is currently widesprea d, due to the limited reductions in nitrogen 
deposition over the past 10 years. Fo r the period 2000-2020, the protection of 
ecosystems from eutrophication is expected  to improve only slightly (Figure 9) 
mainly because of the relatively sm all decline in ammonia emissions.  
Figure 9: Evolution of the percentage of the total ecosystem area receiving nitrogen 
deposition above the critical load s for nutrient nitrogen in 2000 and 2020 
 
 
2000 Baseline 2020 
Source: RAINS. Note: Calculation results are based on meteorological conditions of 1997, using grid-average 
deposition. Critical loads data base of 2003. 
 
EN 37   EN 2.3. Quantification and valuation of health impacts of air pollution 
As explained above, in princi ple the impacts of air polluti on fall into two categories, 
those on health and those on the environmen t. Health impacts can be quantified and 
monetised, while for environmental impacts th is is only possible for the impacts of 
ozone on crop yield and of aci dic deposition on buildings. 
2.3.1.  Quantification of health impacts 
The methodology followed by the impact assess ment (See Annex 2) aimed to neither 
systematically over-estimate nor under-estimate the health effects. The impact assessment is consistent with the WHO’s “Systematic Review of Health Aspects of 
Air Quality in Europe”
 51 and the advice of UNECE WHO Joint Task Force on 
Health. Health impacts have been estimate d for both particulate matter and ozone for 
short-term (acute) and long- term (chronic) exposure.  
Despite the improvement in pollutant emi ssions, health impacts from air pollution 
across the EU are still projected to be very large in 2020. Mortality and morbidity 
effects from exposure to particulate matter are expected to be significantly larger 
than those associated with ozone. 
For particulate matter, the average loss in st atistical life expectan cy should decrease 
from around 8.1 months in 2000 to 5.5 mont hs in 2020 (Figure 3). Correspondingly, 
in 2020 it is estimated that some 2.5 million lif e years will be lost in the EU-25. This 
is equivalent to about 271,000 premature d eaths. The morbidity effects associated 
with particulate matter include around 66,000 serious/cardiac hospital admissions in 
2020 and larger numbers of less serious effects such as 23 million respiratory 
medication-use days and two hundred million restricted activity days. 
For ozone, the annual impacts are projected to include some 20,000 acute mortalities 
(cases of deaths brought forward) in 2020 without any notable decrease from the 
situation in 2000.52 Ozone exposure is also projected to lead to less serious health 
impacts, including more than 20 million respiratory medication-use days.  
Table 3 summarises the total annual health impacts across the EU-25 for the baseline 
situation from 2000 to 2020. The impacts are split into acute and chronic mortality 
(i.e. premature deaths) and morbidity (i.e. illness) for particulate matter and ozone. 
Note two alternative metrics are used for the presentation of chronic mortality for particulate matter. The first is in terms of y ears of life lost and th e second in terms of 
numbers of deaths. 
                                                
 
51 See http://www.euro.who.int/document/e79097.pdf   and answers to follow-up questions 
http://www.euro.who.int/document/e82790.pdf  
52 The relative stability in health impacts from ozone is due to the nature of ozone concentrations changes, but also 
the population at risk (i.e. the aging population in Europe) which increases. 
 
EN 38   EN Table 3: Estimated health effects of air pollution in from 2000 to 2020  
Effect Unit 2000 Baseline 
2020
Chronic and acute mortality 
PM Chronic mortality*)  Thousands life years lost 3,619 2,467
PM Chronic mortality *)  Premature deaths 347,900 271,600
PM Infant mortality Premature deaths 680 350
Ozone acute mortality Pr emature deaths 21400 20800
PM morbidity effects 
Chronic bronchitis Cases 163,800 128,100
Respiratory hospital admissions Cases 62,000 42,300
Cardiac hospital admissions Cases 38,300 26,100Restricted activity days (RADs) Million days 347.7 222.0
Respiratory medication Use (children) Million days 4.2 2.0
Respiratory medication Use (adults) Million days 27.7 20.9LRS (including cough) among ch ildren Million days 192.8 88.9
LRS among adults with chronic symptoms Million days 285.3 207.6
Ozone morbidity effects 
Respiratory hospital admissions Cases 14000 20100
Respiratory medication Use (Children) Million days 21.4 12.9
Respiratory medication Use (Adults) Million days 8.8 8.2
Minor Restricted Activity Days (MRADs) Million days 53.9 42.4
Cough and lower respiratory symptoms (LRS) (children) Million days 108.1 65.3
*) Chronic mortality due to PM has been calculated in two alternative  ways . 
Note: Assuming 1997 meteorological year. Source: CBA CAFE Baseline (2005) 
The methodology used  has been developed following extensive stakeholder dialogue 
and has been peer-reviewed by leading expe rts in the field. The values used for 
expressing health impacts in monetary terms are the most up-to-date available. The values are presented as an annual impact in euros for the EU-25. 
Methodologically, there is still debate as to how mortality should be valued.  Two 
methods can be used. The first is the “value of st atistical life” ( VSL) approach where 
a pre-determined monetary VSL is multiplied by the change in the number of deaths to arrive at a monetary valuation. Th e second is the “value of life year” ( VOLY ) 
approach, which applies a value to changes in  life expectancy to arrive at a monetary 
valuation. The two methods have contras ting strengths and weaknesses. Following 
the independent external peer review of the CAFE Cost-Benefit Analysis 
methodology, this impact assessment presen ts results for both the VSL and the 
VOLY approaches to show in a transparent manner the inherent uncertainty of both 
approaches.  
Thus, for chronic mortality due to particul ate matter, alternative values have been 
used (Table 4). The first two values are based on the VSL approach. The first uses 
the median of values of VSL, i.e. the valu e for which half of the values are greater 
and half of the values are smaller. The second uses the arithmetic mean (i.e. non-weighted average) of the responses. Th e third and fourth values use the VOLY 
approach based upon the median and m ean values of life years lost.  
 
EN 39   EN The health damage costs are dominated by particulate matter, with premature 
mortality being most important. Morbidity is also significant however. The most 
important categories for particulate matter related morbidity arise from restricted activity days ( RADs ), minor restricted activity days ( MRADs ), cases of chronic 
bronchitis, and to a lesser extent additional days with lower respiratory symptoms (LRS). These morbidity effects contribute significantly to the total damage costs of 
PM.  However, it should be kept in mind that the basis of evidence for quantifying 
them is more limited than for mortality, and it has been evaluated much less intensively by the air pollu tion research community.
53 
Table 4: Values of health effects of air pollution  
 Value of statistical life (VSL) (€) Value of life years (VOLY) (€) 
Median 980,000 52,000 
Mean 2,000,000 120,000 
Source: NewExt54 (2004) and CAFE Cost-Benefit Analysis methodology (2005)  
2.3.2.  Health damage of air pollution up to 2020 
The total annual damage costs associated w ith particulate matter and ozone in 2020 
are estimated at between €189 billion and €609 billion, depending on the mortality 
valuation method used. (Table 5). These co sts are dominated by particulate matter, 
with mortality being more important than morbidity. Table 6 breaks down the figures for the different Member States, where th e costs reflect their specific situation.  
It could be important to include the effect s of chronic exposure to ozone on health, 
and the social implications of air pollution health impacts, but there is inadequate 
evidence available to make a firm conclusion at this point in time. 
                                                
 
53 For example, the exposure-response functions for the most influential endpoints are based on a few 
studies, mostly in the USA. They build on structured interviews about occurrence of symptoms and days when activity is restricted by health, wherea s mortality is a definite end-point; and there are 
limited data on background rates in Europe. On the other hand, these are endpoints which are expected 
to be affected by PM. They have been included in many other major cost-benefit analysis of air 
pollution, including by the US EPA. The WHO-UNECE Task Force on Health considers that the 
morbidity evaluations for CAFE CBA are a significant step forward and should be included, with due 
regard to the uncertainties. The methodology for the morbidity effects is described in more detail in Volume 2 of the Methodology for the Cost-Benefit Analysis of the CAFE Programme (AEAT, March 
2005) 
54 « New Elements for the Assessment of External Cost s from Energy Technologies », project financed by 
DG Research, Technological Development and Demonstration (RTD). EU 5th FP, duration 2001-2003. 
Project co-ordinator : Institute of Energy Economic s and the Rational Use of Energy (IER), University 
of Stuttgart ( http://www.ier.uni-stuttgart.de )  
 
EN 40   EN Table 5: Values of health damage due to air pollution in EU-25 in 2020 (millions of 
euros)  
 Median values based on Mean values based on 
  Value of 
Life Years Value of 
Statistical 
Life*) Value of Life 
Years Value of 
Statistical 
Life*) 
Mortality from particulate matter *)         
Chronic mortality from particulate matter 129,000 289,556 265,965 547,200
Infant  (0-1yr) mortality 495 990 495 990
Sub-total  129,495 290,546 266,460 548,190
       
Morbidity from particulate matter      
Chronic bronchitis 24,011 24,011 24,011 24,011
Restricted activity days (RADs) 18,515 18,515 18,515 18,515
Lower respiratory symptoms among children 3,413 3,413 3,413 3,413
Lower respiratory symptoms in adults with chronic symptoms 7,974 7,974 7,974 7,974
Other morbidity effects 159 159 159 159
Sub-total 54,072 54,072 54,072 54,072
       
Total particulate matter 183,567 344,618 320,532 602,262
       
Mortality from ozone      
Acute mortality from ozone 1,085 2,435 1,085 2,435
          
Morbidity from ozone         
Lower respiratory symptoms among children 2,508 2,508 2,508 2,508
Minor Restricted Activity Days 1,629 1,629 1,629 1,629
Other morbidity effects 60 60 60 60
Sub-total ozone morbidity 4,197 4,197 4,197 4,197
       
Total ozone 5,282 6,6334 5,282 6,633
       
TOTAL PM AND OZONE 188,848 351,250 325,813 608,893
*) Distinction is made only in the case of chronic mortality due to particulate matter     
Source: CBA CAFE Baseline (2005)  
 
EN 41   EN Table 6: Values of health damage due to ai r pollution in Member St ates in 2020 (billions 
of euros)  
 Median values based on Mean values based on 
  Value of 
Life Years Value of 
Statistical 
Life*) Value 
of Life 
Years Value of 
Statistical 
Life*) 
Austria 3.3 6.2 5.6 10.3 
Belgium 7.1 13.3 12.0 22.4 Cyprus 0.3 0.5 0.4 0.6 Czech Republic 4.4 8.1 7.7 14.4 Denmark 1.8 3.4 3.2 6.1 Estonia 0.2 0.5 0.5 0.9 Finland 0.9 1.6 1.5 2.8 France 26.9 50.1 42.4 78.7 Germany 40.6 75.8 73.8 139.0 Greece 4.2 7.9 8.2 15.4 Hungary 5.0 9.4 9.9 18.6 Ireland 0.9 1.6 1.2 2.2 Italy 23.0 42.6 44.6 84.2 Latvia 0.8 1.5 1.2 2.1 Lithuania 0.8 1.4 1.9 3.6 
Luxembourg 0.3 0.5 0.4 0.7 
Malta 0.2 0.3 0.3 0.5 Netherlands 10.4 19.5 16.8 31.3 Poland 18.0 33.3 30.2 56.1 Portugal 2.4 4.4 4.3 8.0 Slovakia 2.5 4.7 4.1 7.7 Slovenia 0.9 1.6 1.5 2.9 Spain 10.0 18.3 17.3 32.2 Sweden 1.9 3.6 3.2 6.0 United Kingdom 22.1 41.2 33.7 62.2 
Total 188.8 351.2 325.8 608.9 
Source: CBA CAFE Baseline (2005)  
 
 
EN 42   EN 2.4. Environmental and non-health impacts 
Non-health impacts have been estimated across EU-25 for the baseline from 2000 to 
2020. Some of these impacts have been valued in monetary terms. For these, the main effects are damage to crops (i.e. re duced crop yield) and damage to materials 
(excluding historic buildings and cultural heritage). The two main pollutants of 
concern are ozone (for crops) and SO
2 (for materials). 
The impacts and benefits of reduced crop damage due to ozone and reduced material 
damage due to reduced SO 2 emissions have been expresse d in monetary terms, using 
the approach outlined in the CAFE CBA methodology (Table 7). These impacts are 
small in relation to health damage overall. However, effects from ozone on crops are similar in magnitude to ozone-related health impacts. 
Table 7: Ozone and SO
2 damage to crops and materi als in 2000 and 2020 (billion of 
euros) 
 
 2000 Baseline 2020 Difference 
Crop damage due to ozone 2.8 1.5 1.3 
Materials damage due to SO2 and ozone  1.1 0.7 0.4 
Total 3.9 2.2 1.7 
Source: CAFE CBA.  
As there is a lack of objective valuation methodology at EU Level, other effects have 
not been quantified in moneta ry terms. However, the Thematic Strategy still tries to 
provide information to prompt stakeholders  to consider whether the impacts that 
have not been quantified are likely to be important enough  to change the balance of 
costs and benefits. As explai ned in the CAFE CBA methodology55: 
– inclusion of impacts on forests, freshwaters and other ecosystems could add 
significantly to the benefits qua ntified for emission reductions. 
– inclusion of the damage to cultural assets and some impacts on crops from 
interactions with pests and pathogens may be important. However, there is 
inadequate evidence available to make a firm conclusion at this point in time. 
                                                 
55 Methodology for the Cost-Benefit Analysis of the CAFE Programme (AEAT, March 2005) 
 
EN 43   EN 3. THE LONG -TERM OBJECTIVES  
The 6th EAP gives a clear obligation to develop a thematic strategy that will achieve 
“levels of air quality that do not give ri se to significant negative impacts on and 
risks to human health  and the environment ”.  The 6th EAP also reiterates the long-
term objective contained in the National Emissions Ceilings Directive of no 
exceedence of critical loads and levels for acidification, eutrophication and 
ground-level ozone.56 
3.1. Current policies will not bring ab out the long term objective 
The discussion in Section 2 sets out the expected levels of air quality and the degree 
of protection for natural ecosystems in 2020 that will  be provided by effective 
implementation of current policies. Clearly, the long-term objectiv e will not be met 
under current policies: 
– PM 2.5 would still reduce average statistica l life expectancy by 5.0 months and 
cause some 272,000 premature deaths; 
– 46% of ecosystem areas would still be subject to unsustainable deposition 
levels of nutrient nitrogen; 
– Critical loads for acid ification would be exceeded in  about 10% of the area of 
European forests; 
– About 55% of forest areas would still be exposed to ozone above the critical 
level. 
In 2020, therefore, the EU would still be a long way from the long-term objectives 
laid down in the 6th EAP and so further action is required.  
3.2. A point of reference – The maximu m technically feasibly reduction 
In order to assess the potential for furthe r action to meet the long term objective, a 
scenario has been analysed in which all possible technical emissions abatement are 
deployed irrespective of cost. This is the “Maximum Technically Feasible 
Reduction” scenario (MTFR). This scenario  is made up of cost-effective sets of 
measures which go beyond current legislat ion and which deliver environmental 
improvements in a cost-optimal manner.57 
The MTFR scenario was used to find out how far it is possible to reduce 
environmental and health damage due to  air pollution irrespective of cost. The 
human health and environmental improvement s associated with the MTFR scenario 
were projected in the same manne r as for the baseline situation.  
                                                 
56 Article 1, Directive 2001/81/EC, L 309, 27.11.2001, p. 22. 
57 See a description of the measures included in MTFR  in  CAFE Report #2: The “Current Legislation” 
and the “Maximum Technically Feasible Reduction” cases for the CAFE baselin e emission projections. 
(http://www.iiasa.ac.at/rains/C AFE_files/baseline3v2.pdf).. 
 
EN 44   EN The implementation of the MTFR scenar io would bring about a considerable 
additional decrease of all pollutants comp ared with the baseline, but would not 
eliminate them altogether. This improvement is particularly important in the case of 
ammonia (additional 37%) while for VOC the improvement is limited to 15%. (Figure 10) 
Figure 10: Levels of pollutant emission s in the CAFE Baseline and in Maximum 
Technologically Feasible Reduction in 2020 (2000 emissions = 100%) 
0%10%20%30%40%50%60%70%80%90%100%
SOX NOX NH3 PM2.5 VOC% Emissions 2000
CAFE Baseline 2020 MTFR 2020
 
Source: RAINS 
The impact on health from particulate ma tter and ground-level ozone would decrease 
by 30% and 15% respectively. This means that, even with the MTFR scenario, 190.000 people would be estimated to die prematurely every year, and average 
European average life expectancy would st ill have to be reduced by 3.8 months from 
exposure to air pollution. Also  other significant health im pacts related to morbidity 
would remain of concern. 
Environmental impacts would also still occu r. Even after application of technical 
measures in the MTFR scenario, 28% of fore st would still be exposed to ozone above 
the critical level, 15% of ecosystems w ould be at risk from excessive nutrient 
nitrogen, while 3 % of European forests and 5% of lakes would st ill be at risk from 
acidification. 
In addition to the MTFR option above, other non-technical measures are also 
possible, e.g. changing demand in the different sectors. An “illustrative” scenario for such a structural shift was examined us ing the PRIMES energy model, assuming a 
carbon constrained economy that would lead to a carbon price of €90/tonne CO
2 in 
2020 (see Annex 2). This scenario  gives a reduction in EU-25 CO 2 emissions of 
about 20% compared with 1990. Howeve r, effects on air pollution were not 
negligible under this scenario but represent only an additional decrease in emissions of around 2% in the case of NO
x, and 0.2% for VOC. In addition, such a scenario 
would also necessitate policy measures to shift demand (i.e. a tax on carbon or CO 2), 
with the consequent costs. These were not examined further. This was partly due to 
 
EN 45   EN the fact that such a scenario was extremely likely to be less cost-effective in terms of 
air pollution reduction than the opt ions considered further below. 
Against a backdrop of the energy consump tion and economic activity described in 
the baseline, it is apparent that the long-term objective cannot be met. Even if the EU undertook the most expensive and currently  available emission control measures 
there would still be signifi cant negative impacts on health and the environment.  
More needs to be done to attain Commun ity long-term objectives for air pollution. 
However, the application of all technical m easures irrespective of cost will still not 
deliver those objectives – and may be excessively costly. 
This Thematic Strategy is ambitious, but at the same time strikes a fair balance 
between economic and environmental dimens ions. It recognises and is consistent 
with the Lisbon Strategy objectives and the Community’s Sustainable Development 
Strategy. 
Reflecting this, the policy options dealt with in the following chapter reflect the need 
to find a balance between the costs and bene fits of action and determine how far to 
go in closing the gap between the current environmental problems and the long-term 
objective. 
 
EN 46   EN 4. THE MAIN POLICY OPTIONS CONSIDERED FOR THE STRATEGY  
4.1. The broad approach for settin g the interim objectives 
The approach taken in the Strategy to set interim objectives was similar in many 
respects to that followed earlier when de veloping the National Emissions Ceilings 
Directive. The scenarios were explored, us ing the RAINS model in  an iterative way, 
and the cost and benefits of closing the gap in environmental impact between the 
baseline emissions in 2020 and the MT FR scenario. However, there were 
differences, too. During the development of th e NEC Directive, the target setting was 
based mainly on closing the gap between th e base year (which was then 1990) and 
the “no effect” level (in 2010). As an inte rim objective “50% gap closure” between 
the initial situation and “no effect” was agreed. During the development of the Thematic Strategy it was realised that the approach used in NEC Directive could not 
be repeated mainly because in the enlarged EU, Member States were in different initial positions. Thus, new approaches were  called for setting targets (see Box). 
Approaches to target setting 
One traditional approach (applied, e.g., in the air quality directives) focuses on 
environmental improvements at the most pollute d sites by imposing absolute limits (or caps) 
on air quality (or effect indicators) that need to be achieved throughout the entire territory of 
the EU. Applied to the air quality management problems at hand, it turned out that 
substantial spatial variations in the environm ental indicators exist over Europe, even if the 
values of these indicators for individual grid cells  are aggregated to the Member States level. 
The adoption of an absolute target, while  it would force maximum measures in some 
Member States, would not require any improvements for other Member States, because they 
would achieve this level already in the b aseline (current legislation case) without any 
additional measures. Thus, such uniform targets expressed in absolute terms of air quality or 
environmental impact indicators would result in uneven distributions of environmental 
improvements and abatement burdens. In add ition, economic analysis has shown that, 
especially for pollution problems where no clear ‘no effect’ threshold could be identified, 
larger benefits could be accrued from wide -spread improvements at moderately polluted 
places compared to approaches that focus solely  on a few hot spots, and thus benefit only a 
limited number of people or ecosystems. 
As an alternative, earlier analyses for the na tional emission ceilings directive and for the 
CLRTAP Gothenburg Protocol applied the “gap  closure” concept, which calls for uniform 
relative improvements of the environmental indicators as an interim target. For NEC 
Directive, the “gap closure” concept specified  environmental targets in relation to the gap 
between the present environmental situation (at that time the status of 1990) and the ultimate 
environmental policy target of achieving no-eff ects levels (quantified through critical loads 
or at that time AOT40/60 for ozone). With this approach, more even or “equitable” 
distributions of economic burdens and envir onmental benefits could be achieved, which 
made these accords politically acceptable. Howeve r, if, in order to establish a notion of 
“equity” in terms of environmental improvement s, a uniform gap closure percentage target 
were used for all Member States, this target would be constrained by the Member State with 
the lowest feasibility, and would in the end ma ke only a minor contribution to ambient levels 
of pollution. 
This process was undertaken within the CAFE Working Group on Target Setting and 
Policy Assessment (WG TSPA). The objectiv e was to find a bala nce between cost-
 
EN 47   EN effective measures that would give optimum  environmental and health benefits for 
Member States and the EU as a whole, a nd accounting for aspects of equity so that 
no population group or Member State would experience disproporti onately high risks 
or costs. The process is described below. 
4.1.1.  First set of policy options 
Three scenarios have been explored in depth to assess the cost and benefits of closing 
the gap between the environmental situation calculated in the baseline scenario in 2020 and the MTFR scenario for 2020. These s cenarios represent differing levels of 
ambition based on the gap closure concept, i.e.  the percentage of the gap to be closed 
between the 2020 baseline and the MTFR (exc luding transport sect or), for losses in 
life expectancy from exposure to particulate matter, for the cases of premature deaths 
attributable to ozone, for accumulated exce ss deposition over the critical loads for 
acidification, and for accumulated excess deposition for eutrophication.
58 
As mentioned in Section 4.1 the definiti on of a “gap” was different in the 
development of the Strategy compared with the development of the National Emissions Ceilings Directive. Now the “gap” was defined as the difference between the MTFR and the baseline in 2020. In the NEC Directive the “gap” was the 
difference between “no effect” level and the starting point. In other words, the “gap” 
in the Strategy is in between the “gap” as this was defined in the NEC Directive.  
The following four metrics are used as impact  indicators, for which the gap closure is 
applied
59: expectancy from exposure to particul ate matter; cases of premature deaths 
attributable to ozone; accumulated exces s deposition over the critical loads for 
acidification; accumulated excess deposition for eutrophication. 
– For health impacts attributable to PM 2.5, RAINS used the loss in statistical 
life expectancy as calculated by RAIN S for each grid cell as the impact 
indicator for which the environmental gap closure target is specified. Formally, 
this is equivalent to a gap clos ure calculated for the annual mean 
concentrations of PM 2.5, for each grid cell of 50 km x 50 km.60 Grid average 
values have been used for this explorat ory series of calculations, but inclusion 
of City-Delta results in subsequent runs allowed a better representation of 
human exposures in urban areas. (see Annex 2) 
– For health impacts attributable to ozone , RAINS calculated the number of 
premature deaths attributable to ozon e (SOMO35) on a grid basis and summed 
them for each Member State. The gap cl osure was then applied to the country-
balance only, i.e. it is not requested for each individual grid cel l as long as the 
overall improvement within a given count ry is achieved. Formally, this is 
                                                 
58 The detail of these initial scenarios is described in: IIASA Report A - Results from the RAINS Multi-
Pollutant/Multi-Effect Optimization including Fine Particulate Matter; Background paper for the 
meeting of the CAFE Working Group on Target Setting and Policy Advice, January 14, 2005 
59 In the RAINS optimization, emission reductions are driven by the environmen tal targets specified for 
the various environmental endpoints. Thus, the choice of the environmental endpoint and of the 
absolute and relative improvements imposed on the selected criteria has critical influence not only on 
the absolute levels of resulting emission reductions, but also on the distribution of abatement burdens 
across countries and sectors. 
60  See Annex 2 
 
EN 48   EN equivalent to a gap clos ure calculated on the basi s of population-weighted 
SOMO35 grid data.  
– For acidification , RAINS applied the gap clos ure concept to the total 
deposition of acidifying compounds in  excess of the critical loads for 
acidification, accumulated over all ecosy stem types (forests, semi-natural, 
water) and ecosystem areas in a count ry. While this accumulated excess 
deposition cannot be interpre ted to be proportional to ecological damage in a 
strict sense, it provides a continuous scale for quantifying excess deposition. 
For this exploratory set of computations , RAINS uses a linear  representation of 
the accumulated excess deposition function. The implications of an optimized emission reduction scenario can then be displayed for each grid cell in terms of ecosystems area with acid deposition above/below critical loads.  
– For eutrophication , RAINS applied the same “accumulated excess deposition” 
concept as for acidification. The gap clos ure is requested on a country basis, 
i.e. there is flexibility to  compensate improvements at “hard to attain” targets at 
individual receptor sites by additional gains in other areas within the same 
country. 
After analysing these three ambition levels two issues became apparent. Firstly, 
reduction of concentrations of particulat e matter in air was closely correlated to 
reduction not only of primary particul ate matter emissions but also of NO
x, SO 2 and 
NH 3, as the latter are also precursors to secondary PM 2.5 concentrations. Only VOC 
emissions were not correlated with PM 2.5 concentrations. Sec ondly, it was evident 
that control costs started to increase signi ficantly at about 75% between the baseline 
and MTFR in 2020. Thus, it was conclude d that the following model rounds would 
concentrate on PM 2.5 exposure and focus on the range between 50% and 100% of 
MTFR .61 Thirdly, it became evident that di fficulties may arise when imposing 
improvements where air pollution impacts ar e relatively small (“cleaning already 
clean air”) or in peripheral regions. 
4.1.2.  Focusing on particulate matter 
It became clear during the first set of policy options that the reduction of NO x, SO 2, 
ammonia and PM 2.5 are collinear. In other words, reducing PM 2.5 concentrations also 
reduces emissions of NO x, SO 2, ammonia and PM 2.5, albeit not in equal proportions. 
Thus, during subsequent model runs, seve ral particulate matter emission reduction 
options were investigated. Th ree target setting principles for particulate matter were 
explored62: 
• A “capping value” concept . This requires PM 2.5 concentrations in urban 
background air sheds everywhere in th e EU-25 to be below a certain upper 
level. The RAINS model, with the City-D elta corrected urban concentrations of 
                                                 
61 Given that it was also known that it was possible to incorporate road transport and international 
maritime emissions reduction into the MTFR, subsequent model rounds in the Impact Assessment 
include these sources. 
62 The results of these scenario runs are described in IIASA Report B - Target Setting Approaches for 
Cost-effective Reductions of Population Exposure to Fine Particulate Matter in Europe (IIASA, 
February 2005) 
 
EN 49   EN particulate matter, is capable of  reproducing concentrations of PM 2.5 at urban 
background locations, although the model cannot reproduce “hot spots” in 
street canyons nor can it account for co mponents derived from  organic aerosol.  
A separate study has been done by the EEA63 on the increment in narrow street 
canyons. The study shows that in such street canyons with heavy traffic the PM2.5 levels could be up to 10 ug/m3 higher than the urban background with the present vehicle fleet and about 5 ug/ m3 higher than the urban background 
with the vehicle fleet of the 2020 CA FE baseline. Hence, an adjustment
64of up 
to 5 µg/m3 would need to be added to co mputed values by the City-Delta 
methodology to obtain concentrations at  street canyons. To be feasible, a 
generally applicable “cap” must be achievable everywhere. In some cities (excluding the port cities) in the model calculations is was not possible to 
reduce urban background 
PM 2.5 in 2020 much below m odelled concentrations 
of 15 µg/m3, even with full application of all available control measures at the 
European scale. On the other hand, ther e are very few places where a modelled 
level of 20 µg/m3 would remain exceeded. Thus, a sequence of scenarios has 
been calculated to bring modelled PM 2.5 concentrations in urban background 
air below uniform target levels of 15, 15.5, 16, 16.5, 17 and 19 µg/m3. 
– A “gap closure” approach . The gap closure is a fixed percentage of  
improvement in PM 2.5 exposure for each grid, between the baseline scenario 
and the MTFR. As vehicle emission sta ndards need to be introduced as a 
Community-wide measure, and not for individual Member States, the RAINS optimization exploring the scope for addi tional measures on st ationary sources 
was carried out twice for given environmen tal targets, with and without further 
road measures introduced in all Memb er States. With equal environmental 
objectives, a comparison of the emission control costs between these two cases 
allowed conclusions to be drawn about the cost-effectiveness of further road 
measures.  
– A “Europe-wide” target . This would explore th e cost-effectiveness of 
measures to achieve health improvements irrespective of the location of the improvement. The optimization identified those measures in the EU-25 that 
would achieve a given improveme nt of years of life lost ( YOLL ) at least cost. 
The location where the health benefit occurs was thus not taken into account, and the optimization allocated measures to those regions where benefits are 
largest across the EU. The bene fit of a unit of reduced PM
2.5 concentration, 
however depends on the popul ation density in the a ffected area. The more 
people living in an area, the more effective will be a reduction of PM concentration in that area. While this approach optimizes th e use of resources, 
it might compromise on (perceived) equi ty aspects, because not all Member 
States may receive equitable environmental improvements.  
                                                
 
63 Air pollution levels at hotspot areas of selected  cities, EEA ETC/ACC Final report June 2005 draft 
64 As the EMEP model, on which the RAINS model rests its calculations of PM dispersion, does not 
quantify contributions from natural sources, i.e., mi neral dust, sea salt and biogenic material and of 
secondary organic aerosols, an assumption has been made that the mineral contribution amounts in 
Mediterranean countries at 3 µg/m3, in Scandinavia at 1 µg/m3, and all other countries at 2 µg/m3.  
 
EN 50   EN In addition two other proposals were made on setting targets. Thes e will be explored 
in detail during the impact assessment of the National Emissions Ceilings Directive. 
It was decided to refine further the th ree target setting approaches (“capping”, 
“country specific gap closure” and “EU-wide  target setting”) with three ambition 
levels for PM and the carrying out of sensitivity analysis and robustness tests.65 
– The ”capping” approach showed difficulties bringing annual mean PM 2.5 
concentrations below 17 µg/m3 in urban areas with high local emission 
densities ( inter alia , due to PM emissions from ships in harbours) and the low 
wind speeds given in the available data se t. If two of the binding cities were 
excluded66 from the optimization process the cost-effectiveness of this 
approach improved. However, this appro ach still remained less cost-effective 
and triggered an uneven distribution of  costs and benefits across Member 
States. 
– Uniform “gap closure” in terms of health-relevant PM 2.5 exposure was 
performed including a sensitivity cas e with a cut-off threshold of the 
concentration-respons e function at 7µg/m3 for less polluted sites.67 This 
approach increased equity and effici ency, reducing annual costs for a given 
scenario by €800 million for e.g. 80% of th e MTFR at EU level, with visible 
effects for those Member States wher e the lack of cut-off entailed high 
abatement costs with only marginal benefits.  
– Finally, the Europe-wide approach of improvement of PM 2.5 health impacts 
irrespective of their locations, remained most cost-effective, but also superior 
to the other approaches for many equ ity criteria. However, the difference 
between alternative approaches were narrow, due to the adjustments made in the target setting (exclusion of some of the "driving grids or cities" and cut-off 
for PM
2.5 exposure) (Figure 11). 
A preliminary cost-benefits analysis (where benefits are calculated only from 
reduced exposure to particulate matter) of these scenarios showed that benefits are 
higher than costs, even with low estimates of benefits. The gap closure approach was 
proven to be more cost-effective and have higher benefit/cost ratio than the limit 
value approach at comparable ambition leve ls. This empirical result was an expected 
outcome as the gap-closure approach is th eoretically more efficient than the limit 
value approach. 
                                                 
65 The results of these scenarios are described in IIASA Report C  - Exploratory CAFE scenarios for 
further improvements of European air quality (IIASA, March 2005) 
66 These cities were Genoa and Thessaloniki. While  there are obvious uncertainties in the present 
modelling approach that call for caution in calculating results for individual cities, the general features 
of such a limit value approach and of potential ex ceptions will hold also for practical implementation in 
the real world. 
67 There is some logic for the use of th is somewhat arbitrary cut-off of 7µgm-3 as this lies at the lower end 
of the range of concentrations used to derive the dose response function from epidemiological studies. 
 
EN 51   EN Figure 11: Cost-effectiveness of the target setting approaches: Emission control costs 
(billions of euros per year) vs. Year s of life gained (million years) 
0,04,08,012,016,0
0 5 10 15 20 25 30 35 40
Cumulative years of life gained (million years)"Capping"Gap 
closure
EU wide 
objectivebillions of euros
[137][97]
[Cumulative life years lost (million years)][107] [117] [127]STOP
MTFR
[96]41Current 
legislation
 
Source: IIASA Note: The line for the "capping" approach does not continue to the MTFR, where the 
concentration limit ap proach becomes infeasible, because the limit va lue will be exceeded in some area, even if 
all countries are at MTFR emissions.  
 
EN 52   EN 4.2. Final set of policy options 
The different environmental and health targets on PM, acidification, eutrophication 
and ozone were combined in a joint opt imization. Such an approach builds on 
important economic synergies between cont rol measures for different air quality 
problems. PM and ozone are complementary targets, and appropriate combination of ambition levels for different end points need ed further exploration. For that purpose, 
a screening of ambition levels for the i ndividual optimization runs was performed, 
calculating 24 sets of different  ambition levels of joint optimization scenarios. This 
resulted in 360 model runs.
68 The proposed ambition levels combine the health-
related PM 2.5 and ozone objectives with those of environmental protection for 
acidification, eutrophication and ozon e damage to vegetation (Table 8). 
Table 8: Definition of three ambition levels  for interim targets for air pollution up to 
2020 
   Ambition level  
 2000 Baseline 
2020 Scenario 
A Scenario 
B Scenario 
C MTFR69 
EU-wide cumulative 
years of life years lost 
(YOLL, million) 203  137  
(0%) 110  
(65%) 104  
(80%) 101  
(87%) 96  
(100%) 
Acidification (country-
wise gap closure on cumulative excess deposition)
70 120 30 
(0%) 15 
(55%) 11 
(75%) 10 
(85%) 2 
(100%) 
Eutrophication (country-wise gap closure on cumulative 
excess deposition)
71 422 266 
(0%) 173 
(55%) 138 
(75%) 120 
(85%) 87 
(100%) 
Ozone (gap closure on SOMO35)
72 4081 2435 
(0%) 2111 
(60%) 2003 
(80%) 1949 
(90%) 1895 
 (100%) 
 
                                                 
68 These model runs are reported in IIASA, A final set of scenarios for the Clean Air for Europe (CAFE) 
programme, CAFE Scenario Analysis Report #6, April 2005 
69 The percentage refers to the difference between Baseline 2020 and Maximum Technically Feasible 
Reduction (MTFR) 
70 Average accumulated excess acidification equivalents per hectare 
71 Average accumulated excess eutro phication equivalents per hectare 
72 SOMO35 in parts per billion days 
 
EN 53   EN 5. IMPACT ASSESSMENT OF THE OPTIONS  
Throughout this section the three ambition levels for interim objectives till 2020, 
labelled Scenarios A, B and C will be assessed. The overall pu rpose is to have 
enough information to decide which of the Scenarios would for the basis for the interim objective. 
The three levels of ambition between the baseline and the maximum technically 
feasible reduction were subjected to a full cost-benefit analysis. This was complemented by analysis with the GEM-E3 general equilibrium model to see the impact on competitiveness, employment and other general equilibrium effects. This impact assessment does not include the de tailed assessment of individual measures
73 
of each interim objective, as this will be performed in due time together with each 
legislative proposal. 
The impact assessment of the range of polic y options responds to the objectives of 
the Lisbon and Sustainable Development strategies. On the one hand it aims at defining the most effective and efficient re gulation as part of the efforts of the 
European Institutions and Member States to fulfil the Lisbon objectives in 2010; on the other hand it ensures polic y coherence between the ec onomic, environmental and 
social dimensions. Following the principle of  proportionality, the analysis focuses on 
the most significant impacts and the most important distributive effects, and the depth of analysis matches th e significance of the impacts.
74 
5.1. Impact on pollutant emissions 
The reduction in pollutant emissions corresponding to the different ambition levels is 
not homogeneous across pollutants and Memb er States. The dispersion is more 
evident in the case of SO 2 and PM, for which the levels of ambition are the greatest, 
together with NH 3. Tables 9 and 10 indicate that the reduction effort for different 
pollutants varies. For instance, under Scenario B, SO 2 emissions would be reduced 
by a further 44% but VOC emissions by only 17% from where they would be with 
current legislation in 2020. Furthermore, th e reduction efforts in different Member 
States vary depending on the pollutant and the abatement options. (See Figure 12 for 
details.) 
Table 9: Emission reductions for the three ambition levels in 2020, in kilotonnes 
   Baseline Ambition level in 2020 
  Emissions 
in 2000 emissions 
in 2020 Scenario
A Scenario
B Scenario 
C 
SO 2 8735 2805 1704 1567 1462 
NOx 11581 5888 4678 4297 4107 
VOC 10661 5916 5230 4937 4771 
NH 3 3824 3686 2860 2598 2477 
PM 2.5 1749 964 746 709 683 
Source: RAINS 
                                                 
73 Except for the impact of proposed limit values for PM 2.5 which is described in Chapter 7. 
74 “Impact Assessment: Next Steps - In support of competitiveness and sustainable development”, 
SEC(2004)1377 
 
EN 54   EN Table 10: Emission reductions for the three ambition levels in relation to baseline 
emissions in the EU in 2020, in percentage 
 Baseline Ambition level in 2020 
 emissions 
in 2020 Scenario
A Scenario
B Scenario
C 
SO 2 100% -39% -44% -48%
NOx 100% -21% -27% -30%
VOC 100% -10% -17% -19%
NH 3 100% -22% -30% -33%
PM 2,5 100% -23% -26% -29%
Source: RAINS 
Figure 12: Emission reductions for the three am bition levels and the MTFR in relation 
to baseline emissions in Member States in  2020 [Baseline emissions in 2020 = 100%] 
0%10%20%30%40%50%60%70%80%90%100%
SO 2 Scenario A Scenario B Scenario C
0%10%20%30%40%50%60%70%80%90%100%
NO x Scenario A Scenario B Scenario C
 
Source: RAINS. Note: The grey area represents the sc ope for emission reduction in the MTFR in relation to 
baseline emissions in 2020 
 
EN 55   EN 0%10%20%30%40%50%60%70%80%90%100%
VOC Scenario A Scenario B Scenario C
0%10%20%30%40%50%60%70%80%90%100%
NH 3 Scenario A Scenario B Scenario C
0%10%20%30%40%50%60%70%80%90%100%
PM2.5 Scenario A Scenario B Scenario C 
Source: RAINS. Note: The grey area represents the sc ope for emission reduction in the MTFR in relation to 
baseline emissions in 2020 
 
EN 56   EN 5.2. Impact on air qualit y and human health 
5.2.1.  Loss in life expectancy attributable to exposure to fine particulate matter 
Exposure to fine particulate matter has seve ral severe effects on human health and is 
clearly linked to increased mortality a nd morbidity. The mortality effect may be 
expressed as changes in life expectancy or  as numbers of premature deaths. Scenario 
B would, on average, reduce loss of life expectancy due to exposure to PM 2.5 to 4.1 
months instead of 5.5 months in the base line for 2020. Changes in life expectancy 
could also be expressed as changes in the cumulative number of life years lost in the 
EU: the RAINS model estimates  that in 2020 the cumulati ve number of years of life 
lost (EU-wide YOLL) is about 137 million, and Scenario B would reduce number of 
life years lost to about 104 million. 
Based on the calculations from RAINS further analysis within the CBA framework 
allowed an assessment of the number of people dying prematurely every year. 
Scenario B would correspond to a reducti on of premature deaths by about 66,000 
people per year compared with the baseline for 2020. Regional differences in the EU are projected to prevail (Fi gure 13) and some regions in North-West EU would still 
have loss of average life expectancy in the range of 9 to 12 months in 2020. 
However, all regions in the EU would s ee a major improvement over and above the 
baseline in 2020 with Scenario B. 
Figure 13: Loss in life expectancy attributable to anthropogenic PM
2.5 (months) for the 
three ambition levels in 2020 – compa red with 2000 and the baseline in 2020 
 
  
2000 Scenario B in 2020 
 
  
  
Baseline 2020 Scenario A in 2020 Scenario C in 2020 
Source: RAINS. Note: Calculation results are based on meteorological conditions of 1997. 
 
EN 57   EN 5.2.2.  Health effects attributable to  exposure to ground-level ozone 
Scenario B would considerably reduce the number of deaths brought forward due to 
ozone exposure75 all over the EU (Figure 14). At the same time, other health-related 
impacts due to ozone would also be reduce d. It is estimated that almost 5000 people 
less would die prematurely due to ozone exposure in Scenario B, bringing the 
number down to 17,000 by 2020. In Scenario A, the reduction would be about 1000 
people less. However, in Scenario C the si tuation is no longer projected to improve. 
Reaching the interim objective would bring about considerable improvement but 
some regions would still have el evated levels of ozone in 2020. 
Figure 14: Health effe cts attributable to exposure grou nd-level ozone (ppb.days) for the 
three ambition levels in 2020 – compa red with 2000 and the baseline in 2020 
 
  
2000 Scenario B in 2020 
 
 
Baseline 2020 Scenario A in 2020 Scenario C in 2020 
Source: RAINS.  Note: Calculation results are based on meteorological conditions of 1997. 
                                                 
75 above a cut-off of 35 ppb 
 
EN 58   EN 5.3. Direct costs of measures 
Annual abatement costs of the measures in cluded in the three ambition levels are 
estimated to vary from €5.9 billion in S cenario A to €14.9 billi on in Scenario C. 
Table 11 disaggregates the costs by pollutant  and major source. It should be noted 
that the impact in terms of health and e nvironment is not the same between different 
scenarios. For instance, the difference betw een Scenarios A and B is not the same as 
the difference between B and C. 
Table 11: Annual abatement cost per pollutant  for each ambition level in 2020 (millions 
of euros) 
Ambition level Scenario A Scenario B Scenario C MTFR
SO 2 800 1,021 1,477 3,124
NOx 903 2,752 4,255 6,352
NH 3 1,785 3,770 5,410 13,584
Primary PM 2.5 411 695 908 12,335
VOC 157 573 935 2,457Road transport (both PM
2.5 and NOx) 1,868 1,868 1,868 n/a
Total  5,923  10,679 14,852  over 39,720
Source: RAINS.  
Figure 15 gives a sectoral br eakdown of the costs of the measures. As further 
explained in Chapter 6, this is a preliminar y estimate that does not take into account 
substantial issues: 
– For transport, the costs forecast relate to one emission reduction scenario based 
on a single source of data. Future emissions standard s will be defined on the 
basis of a more detailed impact assess ment (See Section 5.5.2.). Accompanying 
and non-technological measures may also influence in a positive way the cost-
effectiveness of these standards. 
– For energy, additional measures of ener gy efficiency could trigger additional 
emissions reduction. 
– For agriculture, estimates do not take in to account the impact of the Common 
Agricultural Policy reform or the im plementation of the nitrate and IPPC 
directives (see section 5.5.1). All these el ements will be analysed in depth 
during the review of the national emi ssion ceilings. The objective will be to 
promote measures which are synergetic  for the various environmental media 
and at the same time to help achieve  various environmental objectives with 
cost effective measures. Moreover, the d ecrease in ozone damage to crops has 
to be taken into account (see section 5.7.5.). For Scen ario B, it would amount 
to 415 million euros in 2020, corresponding to  more than 10% of the direct 
cost of the measures for Agriculture. 
 
EN 59   EN Figure 15: Sectoral distribution of the cost  of the measures associated with each 
ambition level in 2020 (mi llions of euros)  
0200040006000800010000120001400016000
Scenario A Scenario B Scenario CMillion €/yearAgriculture (animals)
Agriculture (crops)
Small Combustion Plants
Large Combustion Plants (industry)
Large Combustion Plants (power and heat)
Transport
Fuel production and conversion
Other industrial process and waste
 
Source: RAINS.  
5.4. Uncertainties 
If the costs and benefits of air pollution control were known with absolute confidence 
there would be no problem in comparing th e two. However, costs and benefits are 
subject to uncertainties, some of which ( on both sides of the co st-benefit equation) 
are significant. This section provides an analysis of the major sources of 
uncertainty76, as well as an indication of the di rection and potential importance of the 
biases. In the following section, a sensitiv ity analysis is provided on the most 
relevant uncertainties. 
5.4.1.  Modelling framework 
The peer-review of the RAINS integrated  assessment model (which underpins the 
development of the strategy) has highlighted  uncertainties due to (1) biases in the 
model; (2) a lack of scientif ic understanding; and (3) and an inability to predict 
future behaviour. The model has been cons tructed by the International Institute for 
Applied Systems Analysis (IIASA) so as to  be conservative in  its performance and 
assumptions. Such systematic biases th erefore tend toward  overestimates of 
parameters like costs and favour a strategy of lower ambition. 
The biggest gap in the scientific understanding for this Thematic Strategy relates to 
the attribution of effects to individual sp ecies of particle or other pollutants: The 
discussion of the potential effects of diffe rent toxicities for th e components of the 
                                                 
76 An extended description of the uncertainties in th e quantification of benef its with both RAINS and 
CBA, but also in the dispersion modelling work carried out using the EMEP model and the costs analysis carried out using the RAINS model is provided in Volume 3: Uncertainty of the Methodology 
for the Cost-Benefit Analysis for the CAFE Programme (AEAT, March 2005), as well as in the Review 
of the RAINS Integrated Assessment Model (See Annex 1) 
 
EN 60   EN PM mixture, i.e. primary PM 2.5, sulphates and nitrates has do be done in a qualitative 
way, as attempts to quantify long term h ealth impacts of indivi dual components have 
not a sufficient scientific underpinning at the moment. The Systematic Review of 
Health Aspects of Air Pollution in Europe  (WHO, June 2004) considered this issue 
and noted that toxicological studies ha ve highlighted that primary, combustion-
derived particles have a high toxic potency; and that several other components of the 
PM mix – including sulphates and nitr ates – are lower in toxic potency. 
Unfortunately there is a lack of any established risk estimates for the different components. It is therefore currently not possible to prec isely quantify the 
contributions from different sources and diffe rent PM components to  health effects.  
However, we believe there is value in expl oring this as a sensitivity analysis, for 
example to differentiate betw een policies that reduce primary rather than secondary 
particles from combustion. (See section 5.5.5.  for a sensitivity analysis. As this 
strategy is an integrated strategy which a ddresses the natural environment as well as 
health, the results of the analysis (e missions reductions, co sts) do not change 
significantly from the proposed scenarios). 
The choice of meteorological year is important for mode lling pollutant dispersion 
and chemistry. The economic analysis has been conducted on the basis of a single 
meteorological year (1997) due to resource an d timing constraints. It is true that air 
quality can vary sign ificantly between year s, but 1997 was chosen as it represents an 
average year. However, more detailed baseline estimations of effects have also been undertaken which use four different a nd contrasting meteorological years (1997, 
1999, 2000 and 2003). 
There may be biases (with no indication of  the direction) due to the quality of 
emission inventories, which will vary between pollutants (SO2 emissions, for 
example, are known with a far better leve l of confidence than PM emissions). 
Negative bias may also arise because of th e potential for switching to cleaner fuels or 
production systems by the baseline year for reasons unrelated to air quality 
regulation. Positive bias may arise through pos sible legislative change in other areas 
that could cause emissions to increase. 
Omission of some existing and future ab atement measures from the RAINS model 
could lead to an overes timation of costs and underestimation of the maximum 
feasible reduction. (See below sensitivity analysis on Agriculture and Transport). 
Moreover, ex-ante  cost estimates are often considerab ly higher than the real costs of 
measures as evaluated ex-post. The study performed by AEA Technology for the UK 
DEFRA in December 2004, clearly stated that the ex-ante  costs of the UK National 
Air Quality Strategy were overestimated by  up to a factor of 5 (c.a. ex-ante estimate 
of £16-23 billion for the period 1990 to 2001 compared to the ex-post  cost estimate 
of the order of €3 billion for the same period). 
5.4.2.  Health Impacts of air pollution 
For the quantification of the mo rtality impact of exposure to fine particles, the central 
estimate of the dose-response function for particulate ma tter, adopted by WHO Task 
force on health for IAM, has been chos en. This may mean that we seriously 
underestimate the health impacts as well as overestimate them: The results given 
here can be used with result s from the analysis of scen arios to define probability 
 
EN 61   EN distributions – simply divide values by a factor 2.5 to obtain the lower end of the 
95% confidence interval and multiply by 1.7 to obtain the upper end. 
The CAFE-CBA Methodology has identified a number of health impacts which was 
not felt appropriate to include in the core  analysis. Sensitivity  analysis has been 
undertaken on these effects to assess their importance. In terms of the number of 
additional health impacts for PM 2.5, the sensitivity analysis shows these additional 
impacts (Restricted Activity Days and addi tional cases of Chronic Bronchitis) are 
important, with hundreds of millio ns of additional potential ca ses or days of illness. 
They represent additional benefit in monetary terms betw een 13% and 43%, 
depending on the valuation method for the co re mortality benefits. In terms of the 
number of additional health impacts fo r ozone (mainly Allergic rhinitis 
consultations), the sensitivity analysis s hows these additional impacts are important 
in monetary terms, between 63% and 93% additional benefits, although they are not 
relevant compared with PM 2.5 impacts. 
5.4.3.  Non-health and ecosystem impacts 
The integrated assessment modelling underestimates ecosystem sensitivity by 
ignoring the 5% most sensitive ecosystems in each grid cell of the European modelling domain. Moreover, the coarse s cale atmospheric dispersion modelling (50 
km resolution) can significantly undere stimate actual deposition to sensitive 
ecosystems. There is a tendency for sensitive ecosystems to be situated in elevated 
regions which receive greater rainfall and orographically enhanced deposition. 
In theory, it would be possibl e to go straight from critica l loads or critical levels 
exceedance to valuation of bene fits for ecosystems, were suitable data available from 
willingness to pay studies. Although the liter ature in this area is growing, it is not 
currently adequate for a Europe-wide appraisa l such as this.  Earlier studies tended to 
take a very simplistic perspective of  impacts on ecosystems rendering them 
unsuitable for use in a policy context. 
One area where there is potential for shor t term success in quantification of the 
monetary value of pollution da mage relates to ozone effect s on forests, as it has been 
done for Sweden. However, an in-depth analysis using the same methodology across 
Europe, capable of providing input to the core quantifica tion, was not undertaken in 
the context of this Thematic Strategy, gi ven the complexities of modelling forest 
growth over decades and of forecasting tre nds in forest management practices in 
response to changing supply of timber and demand.  
It was not possible to quantify the damage to cultural heritage in the same way as for 
materials in utilitarian applications because of a lack of data on stock at risk and 
restoration and other costs. 
5.4.4.  Conclusions 
The costs and benefits of different Scen arios have been calculated by using the 
meteorological year of 1997. While 1997 is  on the average a rather typical 
meteorological year, some uncertainties are inherent in the analysis. On the other hand, as the costs and benefits relate changes between the baseline in 2020 and 
 
EN 62   EN different scenarios in 2020, the uncertainty of the difference is considered relatively 
small. 
The probability that the total benefit for each scenario according to core estimates 
would exceed the total cost  is given by Figure 16. For Scenario A and Scenario B 
there is a high probability that incremen tal benefit will exceed incremental cost, 
irrespective of the a pproach taken to mortality valuat ion.  For Scenario C there is 
again a high probability of excess benef it in all cases except where mortality is 
valued using the median VOLY, in which case the probability falls to a little under 
50%.  For the MTFR scenario (Maximum Technically Feasible Reduction according 
to the assumptions and measures included in the RAINS model) there is little 
probability of incremental benefit exceeding co st, irrespective of the approach taken 
for mortality valuation. 
Figure 16: Comparison of the prob ability of benefit exceeding cost 
0%10%20%30%40%50%60%70%80%90%100%
VOLY – median VOLY – mean VSL – median VSL – mean probability benefits > costsScenario A Scenario B Scenario C MTFR
 
Note: This does not include consideration of sensitivity to cost uncertainty or unquantified benefits. 
Source: CAFE CBA.  
 
Based on the significant body of ev idence (see AEA Technology, 2005) that 
forecasted costs of pollution control ar e generally overestimated, the results 
summarised above were combined with sens itivity analysis on estimated costs for 
each scenario and on the magnitude of non qua ntified benefits. Variation in costs had 
little effect on scenarios A or B.  The magnitude of unquantified benefits only 
became significant in one case, for Scenar io B, where cost was assumed to be 
underestimated by the RAINS model by 20%. These are considered to be unlikely. 
Based on the uncertainty analysis th e following conclusions are drawn:: 
• Scenario A:  The conclusion that bene fit would exceed cost across the EU25 for 
Scenario A is robust according to the un certainty assessment performed, with a 
probability in excess of 95% of gaining a net benefit. 
 
EN 63   EN • Scenario B:  Again, the analysis suggest s that the conclusion that benefit would 
exceed cost across the EU25 is robust acco rding to the uncertainty assessment 
performed, though with a slightly reduced probability compared to Scenario A. 
• Scenario C:  There is certainly a case ma de for moving to Scenario C, though for 
stakeholders who prefer to use the medi an VOLY for mortality valuation it is 
clearly less robust than the cas e for moving to Scenario B. 
5.5. Sensitivity analysis 
Sensitivity runs were carried out  by IIASA with the RAINS model.77 The impact of 
variations in the baseline scenario (e.g. us ing national projections) were carried out 
for those Member States th at had provided their nationa l emission projections up to 
2020. A total of 10 Member States  had provided a scenario.78 In some cases there 
was a discrepancy between the Member St ates projection and the CAFE baseline. 
However, in most cases the Member States  projection did not in clude climate change 
measures (to be compatible with the Kyoto Protocol). Further, the emission 
projections were not meeting the obliga tions of the National Emissions Ceiling 
Directive. Finally, at EU level the discrepanc ies were still rather small given the fact 
that there are overall uncertainties in making projections up to 2020. Therefore, the 
uncertainties relating to the differences be tween Member States projections and the 
CAFE baseline were considered relatively small and not of concern for setting the 
interim objectives. It was noted, however, that during 2005 the Member States and 
the Commission need update the emissi on projections up to 2015 and 2020. This 
work underpins the urgency of the analysis  to set up the National Emission Ceilings. 
5.5.1.  Influence of the chosen environmental endpoints 
The CAFE scenarios identify sets of emission control measures that simultaneously 
achieve the environmental ta rgets for the four endpoints of concern (human health 
effects from PM, acidification, eutrophicat ion and ground-level oz one). Thereby, in a 
cost-optimized solution each measure is justified by concrete environmental achievements for at least one of these endpoints. 
There is no objective procedure for allocati ng weights to the different environmental 
endpoints on a purely scientific  basis. In order to provide  objective elements for the 
judgment from decision maker, a further se nsitivity analysis has been carried out 
targeting on health impacts attributable to PM
2.5 only. 
                                                 
77 The results are be reported in IIASA, A final set of scenarios for the Clean Air for Europe (CAFE) 
programme, CAFE Scenario Analysis Report #6, April 2005 
78 For details, see Sensitivity analysis with national energy and agricultural projections in IIASA: 
“Exploratory CAFE scenarios for further improvements of European air quality”.  Background paper 
for the meeting of the CAFE Working Group on Target Setting and Policy Advice, March 17, 2005 
 
EN 64   EN  
Table 12: Emission control costs for the single -effect and multi-effect optimization cases 
(million €/yr) 
 Scenario  A   Scenario B Scenario C 
Costs  PM 
optimized  Joint 
optimization PM 
optimizedJoint 
optimizationPM 
optimizedJoint 
optimization MTFR
Road 1 868 1 868 1 868 1 868 1 868 1 868 1 868 
SO 2 885 800 1 265 1 021 1 911 1 477 3 124 
NO X 168 903 511 2 752 1 597 4 255 6 352 
NH 3 1 489 1 785 3 598 3 770 5 005 5 410 13 584 
PM 2.5 565 411 837 695 1 045 908 12 335 
VOC 0 157 0 573 0 935 2 457 
Total 4 974 5 923 8 080 10 679 11 426 14 852 39 720 
Source: RAINS 
Difference emerge not only in overall emission reduction costs, but also in terms of 
reduction requirements for indi vidual pollutants. As show n in Table 12, with the 
chosen target levels a purely health- and PM-driven optimization suggests more 
emphasis on the reduction of SO2 emissions - and obviously on PM2.5 emissions - than a case including ecosystem impacts. In contrast, a strategy including ecosystem targets (including ground-leve l ozone) asks for larger NOx and VOC reductions. The 
pressure on NH3 emissions is similar in both cases.
79 In summary, it can be stated 
that in the central Thematic Strategy am bition levels the stringency of SO2 and 
PM2.5 reductions are determined at the ma rgin by the selected  health objectives, 
while ecosystems-related targets (including ozone) control the resulting NOx and VOC reductions. The required levels of cuts  in ammonia emissions are determined 
by both health and ecosystems targets. 
Finally, a strategy targeting at PM H ealth impact only would already deliver 
ancillary benefits for ozone, eutrophicati on and acidification. Reaching the level of 
ambition of Scenario B for PM
2.5 health objective only w ould deliver a greater 
improvement in eutrophication and aci dification than additional targets 
corresponding to the Scenario A of ambition. This is due to the abatement in primary 
pollutant that contribute not only to PM 2.5, but also to those e nvironmental objectives 
(namely SO 2 and NH 3). This is not the case for ozone  where additional effort would 
be required from the ancillary benefits of  the level of ambition of Scenario A for 
PM 2.5 only to the achievement of th e level of ambition A for ozone. 
                                                 
79 The joint optimization asks for some more ammonia reductions in the EU-25 as a whole than PM 
optimization. This is caused by the spatial differen ces of health and ecosystems impacts. Cost-effective 
achievement of the health targets require more ammonia reductions in  central Europe (Germany, Czech 
Republic, Poland), the UK and in Italy, while the ecosystems targets imply more stringent ammonia measures in Austria, Denmark, France, Ireland, Spai n, Greece, Sweden, Finland.  To meet the combined 
targets in each country requires ther efore a wider Europe-wide spread of ammonia reductions than any 
optimization for a single effect alone. 
 
EN 65   EN  
Table 13: Ozone and environmental ancillary benefits 
 Scenario(see Table 8)
 Optimization based on: A B C
All targets 60% 79% 89% Eutrophication (country-
wise gap closure on cumulative excess 
deposition, % MTFR
) PM only 47% 65% 79%
All targets 78% 90% 95% Acidification (country-wise 
gap closure on cumulative 
excess deposition, % MTFR) PM only 77% 89% 94%
All targets 53% 77% 88%
Ozone (gap closure on 
SOMO35, % MTFR) PM only 16% 24% 42%
Source: RAINS 
5.5.2.  Agriculture 
Given that this Strategy has highlighted the importa nce of ammonia reduction, a 
specific uncertainty analysis was carried out on this. The first analysis was to check 
whether there were differences between the RAINS cost and activity data and those supplied by Member States. For this analysis  a revised set of RAINS cost curves was 
prepared that was first used for the scenarios incorporating the national activity projections (nine Member States had provi ded these). The verified cost curves 
include improved assumptions on incorpora tion of solid pig and cattle manures and 
result in lower costs of these options than  originally estimated in the RAINS model. 
According to the preliminary analysis of IIASA, the annual cost of Scenario B is 
expected to be about €0.6 billion lower. Thus, the annual abatement costs that were estimated at €3.8 billion per annum are more likely to be €3.2 billion in 2020. 
All the estimates in this impact asse ssment have not taken into account three 
developments which influence ammonia emissions. These are the reform of the Common Agricultural Policy (CAP), the implications of the implementation of the Nitrates Directive, and th e impacts of reducing ammoni a emission through the IPPC 
Directive. The main reason for not estimating these effects is the fact that it is not 
known in enough detail how Memb er States will apply CAP and what the impacts of 
the two directives are on emissions of  ammonia at national and EU level.  
IIASA recently implemented a CAP reform agricultural scenario developed with the 
CAPRI model by the University of Bonn. It  performed an initial analysis of its 
impact on ammonia emissions and the cost s of achieving Scenario B when a CAP 
scenario set of cost curves and emissions is used. In this initial analysis, ammonia emission would decrease in 18 Member States and increase in 7 up to 2020. The overall effect of the CAP reform – accordin g to these preliminary estimates – would 
be a reduction of ammonia emissions by 210 kilotonnes. This  change is not 
insignificant as it would be about 10% of  the estimated need for a reduction of 
 
EN 66   EN ammonia emissions between the baseline in 2020 and Scenario B in 2020.80 These 
impacts are also likely to be important at Member State leve l. Thus, they need to be 
carefully reviewed with the Member States  during revision of the NEC Directive. 
Preliminary analysis indicates  that the CAP reform could reduce the projected annual 
compliance cost of reaching Scenario B level of ammonia reduction by some €0.5 
billion in 202081. 
Due to lack of data, it has not been possi ble at this stage to  conduct a quantitative 
analysis on the possible impact of implementation of the Nitrates Directive. This analysis will be done during re vision of the NEC Directive. 
A preliminary analysis was carried out on how much the compliance costs would be 
reduced to meet Scenario B by 2020, if Me mber States applied the IPPC Directive 
for ammonia emissions in the agricultural  sector. Full application of the IPPC 
Directive would reduce annual costs by a bout €0.9 billion per annum. Optimistically 
full implementation of IPPC could remove  an additional 150 to 230 kilotonnes of 
ammonia by 2020. If it can be assumed that th e IPPC Directive is fully applied, the 
annual compliance costs of Scenario B would be reduced by €0.6-€0.9 billion
 (see 
Table 14 for a summary of the uncertainty analysis). 
In sum, when analysing the impact of four  different sources of uncertainties in the 
emission reduction of ammonia – abatement cost data and the impact of CAP reform, Nitrates Directive and IPPC Directive – it is possible that on the one hand the cost 
estimates in ammonia emissions are overestimated in this Strategy, and on the other hand the baseline for NH3 is likely to underestimate the actual reduction up to 2020 by 360-450 kt. All together, the compliance co sts of Scenario B could be between 
40% and 50% lower than estimated. This issue will be analysed carefully during revision of the NEC Directive.  
                                                
 
80 The difference is about 3% of the baseline emissions of ammonia in 2020. 
81 The CAP reform will also have an impact on the use of fertilisers. The European Fertilizer 
Manufacturers Association expects a 5.1% decrease of nitrogen mineral fertilizer use in the EU15 in the 
period 2003 to 2013, essentially  due to the recent CAP reform. 
 
EN 67   EN  
Table 14: Change in compliance costs of  ammonia of Scenario B with updated 
cost data, the implications of the CAP reform and assuming vigorous 
implementation of the IPPC directive . 
 Annual cost in 2020 
 Lower 
estimate Higher 
estimate 
 €bn % €bn % 
Original estimate of the compliance costs to reach 
Scenario B 3.77  3.77 
Source of uncertainty:    
• Updated cost estimate taking into account 
reduced costs of manure management -0.60 -16% -0.60 -16%
• Possible impact of CAP reform (reduction 
emissions in the baseline by 210 kt) -0.46 -12% -0.46 -12%
• Impact of compliance costs due to vigorous 
implementation of the IPPC directive (reduction emissions in the baseline by 150-230 kt) -0.60 -16% -0.85 -23%
Sub-total cost reduction -1.66 -44%  -1.91  -51%
Compliance cost for Scenario B taking into 
account all uncertainties 2.11  1.86 
Source: RAINS 
5.5.3.  Road Transport 
In all three Scenarios A, B and C it had been assumed that emissions from road 
transport sector could be reduced by lo wering emission limit values under current 
legislation. The current standards for new passenger cars and light commercial 
vehicles (Euro 4) have been in for ce since the beginning of 2005. For heavy duty 
vehicles, Euro 4 emission limit values ar e entering into force in October 2005 and 
Euro 5 in October 2008. Due to the internal market rules of the EU it is not possible 
to have different vehicle emission limits  across the Member States. Thus under 
Scenarios A, B and C it was assumed that all Member States apply tighter emission 
limits. 
The RAINS model had included such furthe r emission reductions for passenger cars 
and light duty vehicles assuming that th ey would be mandatory from 2010 onwards 
and would reduce both pa rticulate matter and NO X emissions82. The main source for 
the light duty vehicle emissions  reductions wa s RICARDO (2003)83.For new heavy 
duty vehicles, the assumption was that tig htened emission limit values would take 
effect from 2013 in all Member States. Th e cost data for the emission reductions 
were introduced to the RAINS database in the same manner as for emission reductions from all other sectors. 
                                                
 
82 See Section 2.1 of CAFE Report #4: ( http://www.iiasa.ac.at/rains/CAF E_files/CAFE-B-full-feb3.pdf ). 
83 RICARDO, Support for updating the RAINS model concerning road transport – final report, November 
2003, available at http://www.citepa.org/forums/egtei/RD03_162101_5.zip   
 
EN 68   EN It was important to see whether the assumed emission reductions in the road 
transport sector were cost-effective in relation to the possibilities of reducing NO X 
and PM emissions from other sectors. For th is purpose, three scenarios were run with 
the RAINS model. The environmental and h ealth objectives of Scenarios A, B and C 
were maintained up to 2020. However, unde r these new scenarios it was assumed 
that the road transport sector would not be able to reduce NO X and PM emissions 
beyond current legislation. This would impl y that the estimated annual compliance 
costs of the road transport sector of €1.9 billion would be saved in 2020. To maintain 
the achievement of the health and envir onmental objectives, other sectors would 
need to compensate for the shortfall and take additional measures. Of specific interest was whether the costs of Scen arios A, B and C without road emission 
reduction measures would be higher or lower than Scenarios A, B and C with road 
measures. From these alternative model runs  (Table 15) it became evident that if the 
environmental ambition level of Scenario A were maintained, other sectors would need to reduce emissions so that their annual compliance costs would increase by €2.1 billion in 2020. This compares with the savings of €1.9 billion in 2020 if road 
emission measures are not undertaken. Thus , under Scenario A the EU as a whole 
would have additional compliance costs of  €200 million if road emission measures 
were not taken. In other words, the mode lling suggests that incl uding road sector 
measures to Scenario A was cost-effective compared with other sectors. 
Table 15: Impact of excluding additional road emission re duction measures on annual 
compliance costs in 202 0, billions of euros 
Scenario
A Scenario
B Scenario 
C MTFR 
Core scenarios  
Measures reducing emissions from all stationary sources 4.1 8.8 13.0 37.9
Measures reducing emissions from transport sector 1.9 1.9 1.9 n/a
Total core scenario 5.9 10.7 14.9 > 39.7
  
Alternative scenarios   
Measures reducing emissions from all st ationary sources 6.1 >37.9 >37.9 >37.9
Measures reducing emissions from transport sector 000  n / a
Total core scenario 6.1 >37.9 >37.9 > 39.7
 
Difference 0.2 >27.2 >27.2 n/a
Source: RAINS. Note: Sums do not add up due to rounding errors 
When the same analysis was repeated for Scenarios B and C it emerged that without 
road emission reduction measures it wa s not possible to reach the interim 
environmental and health objectives by 2020. In other words, even if all measures in 
the Maximum Technical Feasible Reducti on Scenario were und ertaken – costing 
each year about €40 billion per year – the interim objectives would still not be 
achieved. In sum, road emission reduction measures are indispensable to reach the 
interim objectives of Scenarios B and C cost-effectively.  
Apart from the work by RICARDO (2003) , the Commission had independently 
started preparations for new emission sta ndards for light-duty vehicles and heavy-
duty vehicles by sending out questionnaires  to the stakeholders. A questionnaire on 
light-duty vehicles was sent  in February 2004 and a nother one on heavy-duty 
 
EN 69   EN vehicles in May 2004.  These questionnaires requested cost and technology data on a 
number of emission reduction scenarios fo r light and heavy duty vehicles.  All 
responses were received by the beginning of  June 2004 for light-duty vehicles and 
somewhat later for heavy-duty vehicles. The light duty vehicle emission and cost 
data has been validated by a panel of independent experts and will be used in the impact assessment of the new Euro 5 standard  for light duty vehicl es. That work took 
more time than expected because of the need  to interpret the rath er diverse responses 
received, to fill data gaps and to further consult with the stakeholders. The final element of industry input was only received in February 2005. Because of the work on light-duty vehicle data, the validation of heavy duty vehicle emission reduction 
and cost data could not yet be starte d and will be undertaken later in 2005.  
Based on the review of the light duty vehi cle emission data, it appears that the 
reduction potential for NO
X is overestimated in the RI CARDO (2003) data given the 
incremental cost. Thus, the cost estimates used in this impact assessment for light duty vehicles are likely to be unde restimated for light duty vehicles. 
On the other hand, , it seems that RICA RDO (2003) may have underestimated the 
potential for NO
X reduction from heavy duty vehi cles. Overall, the reduction 
potential for NO X from transport measures has thus  uncertainties and the same is the 
case for the estimated costs, which need to be considered approximative at this stage. 
The impact assessment of further road measures will use the updated emission 
reduction and cost data and will thus give a more accurate picture of the reduction 
potential from light a nd heavy duty vehicles. 
5.5.4.  Maritime Transport 
The baseline assumes implementation of the currently decided control measures to 
reduce emissions from seagoing ships. These include for SO 2 the EU sulphur 
proposal as per Common Position, i.e., 1.5% su lphur marine fuel oil for all ships in 
the North Sea and the Baltic Sea; 1.5% sulphur fuel for all passenger ships in the 
other EU seas; low sulphur marine gas oil; and 0.1% sulphur fuel at berth in ports. 
For NO X, implementation of the MARPOL NO X standards for all ships built since 
2000 have been assumed. 
A sensitivity case has been analysed to explore the cost-effectiveness of further 
emission reduction measures for sea-going ships in the context of tightened ambition levels for land based sources. Optimizations for the Scenarios A, B and C have been 
repeated with the additional assump tion that ships would reduce their NO
X emissions 
further through slide valve re trofits for slow speed engi nes. For 2020, costs of this 
measures are estimated at €28 million peryear. 
The analysis reveals this option as highly cost-effective for all the three analysed 
cases. Maintaining the environmental interim targets of Scenarios A, B and C, respectively, implementation of this NO
X control measure would relax costly 
emission control measures at land-based sour ces and thereby lead to substantial cost 
savings (Table 16). 
 
EN 70   EN  
Table 16: Costs for the sensitivity case with further measures for ships compared to the 
central scenarios (€ million per year) 
Sensitivity case with measures for ships  CAFE scenario 
without ship 
measures : Costs 
for land based 
sourcesCosts for 
land-based 
sourcesCosts for 
ships Total costs  
 Cost difference 
to the central 
CAFE cases
Scenario A 5923 5783 28 5811 -112
Scenario B 10679 10492 28 10520 -159Scenario  C 14852 14499 28 14527 -325
Source: RAINS 
5.5.5.  Robustness of results on particulate matter 
A sensitivity case has been constructed which takes Scenario B as the starting point 
but ignores any reduction target for years of life lost from exposure to PM 2.5. 
However, the environmental interim objectives of Scenario B for ecosystems and ozone would be kept.  The aim of the scenario is to unde rstand how robust 
Scenario B would be if assumptions about the human health benefits derived from 
reduced exposure to particulate matter we re altered fundamentally. The extreme case 
is to assume that there would be no hum an health benefits from reducing the 
concentration of particulate matter. If this  were the case, the interim objectives for 
environmental issues would be mainta ined, while there would be no interim 
objective for particulate matter.  The su mmary results are presented in Table 17. 
Table 17: Robustness of the Strategy: Conse quences if morbidity and mortality due to 
particulate matter exposure were excl uded as an interim objective  
 Unit Scenario B Scenario B 
without  target 
for reducing 
life years lost 
(PM 2.5) Difference % 
Life years lost 
(cumulative) millions 104 114 9.6% 
Emissions in 2020   
SO 2 kilotonnes 1567 2034 29.8% 
NOx  kilotonnes 4678 4301 -8.1% 
VOC  kilotonnes 4937 4917 -0.4% 
NH 3  kilotonnes 2598 2661  2.4% 
PM 2.5  kilotonnes 709 938 32.3% 
Annual abatement cost  € billion 10.7 9.0 -15.9% 
Source: RAINS 
 
This sensitivity case shows that even if targets for human health were not considered 
at all, the chosen environmental interim objectives would still signify very similar 
emission reductions in the EU. While wit hout targets on human health the EU would 
need to reduce its SO 2 emissions by about a third less and primary PM 2.5 emissions 
 
EN 71   EN not at all, emission reductions of NOx w ould actually need to be almost 10% higher 
than otherwise. Compliance costs for the environmental targets alone would be 15% 
lower than for the scenario that addresses health targets, too.  
It is possible to interpret this result di fferently. Assuming that reaching the ecosystem 
interim objectives would cost €9 billion per annum in 2020, the additional annual 
cost of reaching the interim objective of hu man health in terms of PM would cost 
only €1.7 billion extra. This interpretation needs to be kept in mind in the impact assessment of the reduction of the averag e annual urban background concentration in 
the EU between 2010 and 2020. 
In sum, if the interim objective for human health due to particulate matter were not 
considered, the attainment of the interim objectives for environmental reasons would 
entail a very similar air pollution abatemen t strategy in the EU. Even the costs would 
be only 15% lower if the mortality and morbidity aspects of particulate matter 
exposure were not considered at all. The multi-pollutant/multi-effect approach with 
simultaneous objectives on health and e nvironment is an important means for 
safeguarding robustness and thus lends suppor t for the strategic choice made by the 
Commission for the Strategy, namely in favour of Scenario B. 
5.6. Comparing costs and health impacts 
5.6.1.  Health impact 
Changes in health damage of the different policy options are assessed using the 
methodology outlined in Section 2.3 and gi ven in detail in the CBA methodology 
reports. The major monetised benefits of policy options would come from reduced 
premature deaths and reduced  loss of life expectancy. Also benefits from reduced 
morbidity contribute significan tly to the overall benefits. Again, it must be kept in 
mind that the basis of evidence for quantifyi ng the most influential morbidity health 
endpoints is more limited than for mortality (see Section 2.3).
  
 
EN 72   EN  
Table 18: Change in annual health  impacts over baseline in 2020  
End point  Pollut-
ant Unit Scenario
A Scenario 
B Scenario
C MTFR
Chronic mortality (years) PM thousand 492.5 600.8 654.6 744.6
    
Chronic mortality (premature deaths) PM thousand 53.8 65. 7 71.681.4
Infant mortality (0-1 years) (premature deaths) PM  70 80 90 100
Chronic bronchitis (over 27 years) PM thousand 25.5 31.1 33.9 38.5
Respiratory hospital admissions (all ages) PM thousand 8.5 10.3 11.2 12.8
Cardiac hospital admissions (all ages) PM thousand 5.2 6.4 6.9 7.9
Restricted activity days (15-64 years) PM million 44.4 54.1 58.9 67.0
Respiratory medication use (children 5-14 years) PM million 0.4 0.5 0.5 0.6
Respiratory medication use (adults over 20 years) PM million 4.2 5.1 5.5 6.3
Lower respiratory symptom (LRS 5-14 years) PM million 17.7 21.7 23.6 27.0
LRS among adults (over 15years) with chronic symptoms PM million 41.4 50.5 55.0 62.6
Acute mortality (premature deaths) O3 thousand 1.6 2.2 2.5 3.0
Respiratory hospital admissions (over 65years) O3 thousand 1.6 2.1 2.5 2.9
Minor restricted activity days (MRADs 15-64 years) O3 million 3.2 4.3 4.9 5.9
Respiratory medication use (5-14 years) O3 million 1.0 1.3 1.5 1.8
Respiratory medication use (over 20 years) O3 million 0.6 0.8 1.0 1.1
Cough and lower respiratory symptom (LRS 0-14 years) O3 million 4.9 6.6 7.5 9.1
Source: CAFE Cost-Benefit Analysis 
Table 19: Change in annual health impacts over baseline in 2020 (millions of euros)  
Endpoint  Pollut-
ant Scenario
A Scenario 
B Scenario 
C MTFR
Chronic mortality – VOLY – (median value) PM 25,750 31,412 34,225 38,927
Chronic mortality – VSL – (median value) PM 52,72 6 64,313 70,122 79,680
   Chronic mortality – VOLY – high (mean value) PM 57,798 70,508 76,822 87,377
Chronic mortality – VSL – high (m ean value) PM 108,479 132,319 144,271 163,935
Infant mortality (0-1 years) – (median value) PM 100 121 132 150
Infant mortality (0-1 years) – (mean value) PM 199 242 264 300Chronic bronchitis (over 27 years) PM 4,786 5,827 6,348 7,219
Respiratory and cardiac hospital admissions  PM 27 34 37 42
Restricted activity days (RADs 15-64 years) PM 3,703 4,512 4,915 5,589Respiratory medication use PM 4 5 6 7
Lower respiratory symptoms PM 2,272 2,774 3,022 3,440
   
Acute mortality (VOLY median) O 3 83 110 127 152
Acute mortality (VOLY mean) O 3 18 6 248 285 342
Respiratory hospital admissions and medication use  O 3 56  7 9
Minor restricted activity days (MRADs 15-64 years) O 3 124 165 190 228
Cough and lower respiratory symptoms (0-14 years) O 3 189 252 290 349
Total with mortality – VOLY – (median value)  37,043 45,218 49,299 56,112
Total with mortality – VSL – (median value)  64,019 78,119 85,196 96,865
   
Total with mortality – VOLY –(mean value)  69,293 84,573 92,18 6104,902
Total with mortality – VSL – (m ean value)  119,974 146,384 159,635 181,460
Source: CAFE Cost-Benefit Analysis  
 
EN 73   EN The costs and health benefits can be compared in different way based on the 
information in Tables 18 and 19. The cost  per life year saved is estimated to increase 
from about €12,000 under Scenario A to over €53,000 under MTFR. The NewExt (Table 3) estimated that the value
 of each life year lost would be either €52,000 or 
€120,000 depending on whether the median or mean  value is used. The cost per life 
saved is also estimated to increase from about €110,000 per life saved (i.e. premature 
fatality avoided) to about €490,000. The valu e of statistical life was estimated in 
NewExt to be between €1 and €2 million de pending on whether the median or mean 
value is used. Thus, the cost-effectiven ess of the MTFR based on human health 
seems justifiable, but barely so. 
5.6.2.  Marginal analysis: Optimal ambition level for PM 2.5 health 
A way of defining the optimal ambition leve l would be to compare the cost per life 
year saved against the marginal benefit of  a life year saved. This balance should be 
limited to the costs for reducing PM 2.5 concentration only (therefore excluding 
additional costs linked with acidifica tion, eutrophication and ground-level ozone 
targets), with the monetary valuation of both mortality and morbidity effects due to reduced PM
2.5 concentration. The optimum is the point where marginal costs and 
marginal benefits are equalized. The reason is that at this point the total benefits minus the total costs (i.e. the net benefits) are maximised.  
Converting this theoretical construct to marg inal cost and marginal benefit curves is 
somewhat problematic in the case of costs,  as a precise estimation of the marginal 
costs is made difficult by the small number of points available for defining the total cost curve (as marginal cost are availabl e in RAINS at pollutant level). Marginal 
costs have therefore been estimated around scenarios A, B and C as well as some 
additional points. Marginal benefits in te rms of reduced mortality and morbidity due 
to particulate matter have also been cal culated using the lower and upper bound in 
the valuation range for the life of year lost  as provided by the Cost Benefit Analysis. 
As can be seen in Figure 17, the point wh ere marginal costs and benefits (lower 
bound) are equalized is betw een scenarios B and C.  
It should also be noted that the largest improvements are estimated to materialise 
from moving from the baseline to Scenar io A. The marginal costs of moving from 
Scenario A to B and further to C are estim ated to increase rather sharply while 
marginal benefits remain flat.   
Further, it needs to be empha sized, that in the analysis thus far, the environmental 
benefits of reduced air pollution have not  been included. A prope r analysis of the 
environmental impacts needs therefore to be undertaken for defining the proper level of ambition for all the targets.  
 
 
EN 74   EN Figure 17: Marginal Cost and Benefits – PM 2.5  Health ambition level 
020.00040.00060.00080.000100.000120.000140.000160.000180.000200.000
0 100 200 300 400 500 600 700
years life saved ('000) related to reduction in PM2.5concentrationsMarginal costs and benefits in eurosMarginal benefits of mortality (VOLY 
median) and morbidity 
improvementsAB CMarginal cost
Levels of AmbitionMarginal benefits of mortality 
(VOLY mean) and morbidity 
improvements
020.00040.00060.00080.000100.000120.000140.000160.000180.000200.000
0 100 200 300 400 500 600 700
years life saved ('000) related to reduction in PM2.5concentrationsMarginal costs and benefits in eurosMarginal benefits of mortality (VOLY 
median) and morbidity 
improvementsAB CMarginal cost
Levels of AmbitionMarginal benefits of mortality 
(VOLY mean) and morbidity 
improvements
 
In order to see how uncertainty in the e ffects would affect th e analysis, Figure 18 
illustrates the impact of a 10% increase or  decrease of the effect of PM2.5 on life 
years. While in Figure 17 the optimal point of marginal benefits and costs -- when 
the median a value of life year lost is used -- would be between points B and C, it 
would be between A and B if the effect were lower than the central estimates of RAINS. 
Figure 18: Effect of uncertainty on the ambiti on level related to health effects of PM
2.5 
 
020.00040.00060.00080.000100.000120.000140.000160.000180.000200.000
0 100 200 300 400 500 600 700
years life saved ('000) related to reduction in PM2.5concentrationsMarginal costs and benefits in eurosMarginal benefits of mortality (VOLY 
median) and morbidity 
improvementsAB CMarginal costuncertaintyLevels of AmbitionMarginal benefits of mortality 
(VOLY mean) and morbidity 
improvements
020.00040.00060.00080.000100.000120.000140.000160.000180.000200.000
0 100 200 300 400 500 600 700
years life saved ('000) related to reduction in PM2.5concentrationsMarginal costs and benefits in eurosMarginal benefits of mortality (VOLY 
median) and morbidity 
improvementsAB CMarginal costuncertaintyLevels of AmbitionMarginal benefits of mortality 
(VOLY mean) and morbidity 
improvements
 
EN 75   EN  
 
5.7. Impact on ecosystems 
This section gives the impacts of reduced air pollution on ecosystems. In order to 
compare the situation in 2000 accurately w ith the projected ambition levels, it was 
necessary to re-run the EMEP model with ex actly the same meteorological year as in 
the optimisation, i.e. 1997. Thus the diffe rences presented in the three ambition 
levels and the base year are comparable. There were three kinds of impacts on ecosystems reported: impacts on Acid deposi tion to semi-natural ecosystems and 
freshwater bodies, and ex cess nitrogen deposition. 
5.7.1.  Acid deposition to forest ecosystems 
Acidification of forest ecosystems has been reassessed using a more precise 
ecosystem-specific deposition to forests and nine times higher resolution in the 
grids
84 as compared with the previous assessment made for the development of the 
NEC Directive. This improved scient ific knowledge and model precision has 
increased our understanding of the impact s of acidification on forests. Most 
importantly the ecosystem deposition accounted for in the new methodology has increased the estimated deposition to forest s, since “dry deposition” is substantially 
higher to forests than to grass land or the average deposition in a 50 km x 50 km grid 
of the EMEP model.  
Improvements are expected following the present environment policies, but major 
acidification problems would remain in areas with sensitive ecosystems and high 
emissions (Figure 19). It is estimated that the percentage of the area of forest eco-
systems receiving acid deposition above th e critical loads would be reduced by over 
50% i.e. by 124,000 km
2 by 2020 to 119,000 km2. Scenario B would reduce the area 
receiving acid deposition above the cri tical load further by about 60,000 km2. In 
Scenario A the reduction would be 8,000 km2 less than in Scenario B, and in 
Scenario C the reduction would be 4,000 km2 more.  
 
 
                                                 
84 The earlier maps were based on 150 km x 150 km grid squares while the maps in the present assessment 
are based on a 50x50 km resolution. You can fit nine 50x50 km grids into one 150x150 km grid. 
 
EN 76   EN  
Figure 19: Percentage of forest area receiving acid deposition  above the critical loads for 
the three ambition levels in 2020 – comp ared with 2000 and the baseline in 2020 
 
  
2000 Scenario B in 2020 
 
Baseline 2020 Scenario A in 2020 Scenario C in 2020 
Note: Calculation results are based on the meteorological conditions of 1997, using ecosystem-specific 
deposition to forests. 
 
EN 77   EN 5.7.2.  Acid deposition to semi-natural ecosystems 
The area of semi-natural ecosy stems receiving acid depositio n above the critical load 
is estimated only some Member States (Fi gure 20) due to a lack of information on 
critical loads for many countries. In th e Member States where information is 
available the area of semi-natural ecosystems receiving acid deposition above the critical load is estimated to decrease  by 80% in 2020 under the present policies. 
Under Scenario B the area would be further reduced by about 3,000 km
2 in these 
Member States. In Scenario A, the semi -natural ecosystems receiving deposition 
above critical load is esti mated to be about 1,000 km2 higher.   
Figure 20: Percentage of the area of semi-nat ural ecosystems receiving acid deposition 
above the critical loads for the three ambiti on levels in 2020 – compared with 2000 and 
the baseline in 2020 
2000 Scenario B in 2020 
 
  
  
Baseline 2020 Scenario A in 2020 Scenario C in 2020 
Source: RAINS. Note: Calculation results are based on the meteorological conditions of 1997, using ecosystem-
specific deposition. 
 
EN 78   EN 5.7.3.  Acid deposition to freshwater bodies 
The area of freshwater ecosystems in thes e EU Member States receiving a deposition 
of acid above the critical load is es timated to decrease by about 40% or 13,000 km2 
to about 19,000 km2 under Scenario B between the years 2000 and 2020 (Figure 21). 
Under Scenario A the reduc tion would be about 1,000 km2 less and under Scenario C 
about 1,000 km2 more. 
Figure 21: Percentage of freshwater ecosystems area receiving acid deposition above the 
critical loads for the three ambition leve ls in 2020 – compared with 2000 and the 
baseline in 2020 
 
  
2000 Scenario B in 2020 
 
Baseline 2020 Scenario A in 2020 Scenario C in 2020 
Source: RAINS. Note: Calculation results are based on meteorological conditions of 1997, using ecosystem-
specific deposition. 
 
EN 79   EN 5.7.4.  Excess nitrogen deposition 
Emissions of nitrogen-containing pollutants,  such as ammonia and nitrogen oxides, 
are eventually deposited on the ground in various forms of nut rient nitrogen and 
hence contribute to eutrophicat ion of ecosystems, such as forests and fresh waters. In 
the present assessment deposition of nutri ent nitrogen to the sea has not been 
assessed. 
The present nitrogen deposition widely exceed  the critical loads over large areas of 
the EU corresponding to about 733,000 km2 in 2000 and down to about 590,000 in 
2020 under present policies. Scenario B would reduce the area with excess 
deposition of nitrogen above the cr itical load by a further 215,000 km2, but 
substantial and severe eutrophication problems would remain in many Member 
States (22). Under the low ambiti on scenario, an area about 50,000 km2 less would 
be protected and under Scenario C an additional area about 28,000 km2 would be 
protected as compared to Scenario B. 
Figure 22: Percentage of total ecosystems ar ea receiving nitrogen deposition above the 
critical loads for eutrophication for the emis sions for the three ambition levels in 2020 – 
compared with 2000 and the baseline in 2020 
 
  
2000 Scenario B in 2020 
 
Baseline 2020 Scenario A in 2020 Scenario C in 2020 
Source: RAINS. Note: Calcul ation results are based on meteorological conditions of 1997, using grid-average 
deposition . 
Information from the literature provides insight into the types of effect that could 
occur, but there is still no sound basis at present for further quantification impacts 
and valuation of impacts on different type s of ecosystems. Therefore this Impact 
Assessment does not go further in quantifying ecological impacts outside of 
 
EN 80   EN agriculture, other than simply  using the results from RAINS in terms of critical load. 
However, as the omission of monetised eco system benefits may trigger a significant 
bias towards underestimation of total benef its, further research will be undertaken. 
5.7.5.  Other non-health effects 
Ozone is recognised as the most serious regional air pollutant problem for the 
agricultural sector in Europe at the pr esent time. Ozone affects vegetation by 
impeding growth, and hence reducing crop  yield. Dose response functions are 
available for only a few crops and species  of natural vegetation, since only a few 
have been studied.85 The impact of ozone is concen trated in the growing season, 
mainly May to August. 
There are large differences in damage to  crops throughout the EU, depending on 
agricultural activity, soil moisture and ozone  concentration (Figure 23). The loss of 
wheat yield in the EU due to ozone is estimated at 8028 kilotonnes in 2000. Scenario B would reduce that ozone dama ge to about 2960 kilotonnes in 2020. The 
monetary valuation (Table 20) indicates th at the overall damage  to crops (mainly 
wheat yield loss) corresponds to some 2800 million euros in 2000 and about 1500 million euros in 2020 under present policies. Scenario B would reduce the damage to 
crops by a further 415 million euros in 2020. 
Table 20: Annual crop damage in EU -25 per in 2020 (millions of euros) 
2000 Baseline 2020 Scenario A Scenario B Scenario C MTFR 
2799 1511 1179 1096 1052 621 
Source: CAFE Cost-Benefit Analysis 
                                                 
85 Impact on vegetation is closely related to the availability of soil water since the stomata, the small 
orifices on the leaves through which plants take up atmospheric gases like carbon dioxide and other 
gases, close in dry conditions. 
 
EN 81   EN Figure 23: Reduction of impacts of ozone on wheat yields in  EU-25 for emissions for the 
three ambition levels in 2020 – compared with 2000 and the baseline in 2020 (tonnes) 
 
2000 Scenario B in 2020 
 
  
Baseline 2020 Scenario A in 2020 Scenario C in 2020 
Source: CAFE Cost-Benefit Analysis. Note: Calculation re sults are based on the meteorological conditions of 
1997. 
 
EN 82   EN  
5.8. Summary of costs and benefits 
Table 21 summarises the results of th e three ambition levels. The largest 
improvements are estimated to materialise from moving from the baseline to Scenario A. It seems evident that going be yond Scenario C is difficult to justify even 
if the overall health and envi ronmental benefits are likely  to be higher than the 
corresponding costs. The reason is that regarding the health impact from PM
2.5, the 
marginal benefits beyond Scenario C become lower than the marginal costs, and Scenario C already provides a substant ial level of improvement for natural 
environment compared to the baseline by 2020..   
Table 21: Alternative environmen tal ambition levels up to 2020 
 Human health  Natural environment 
Ecosystem area exceeded 
acidification 
(000 km2) Ambition 
level Cost of 
reduction 
(€bn) Life 
Years 
Lost 
(million) 
due to 
PM 2.5 Premature 
deaths 
(thousands) 
due to 
PM 2.5 and 
ozone Range in 
monetised 
health 
benefits86 
(€bn) ForestsSemi-
natural Fresh-
water Ecosystem 
area 
exceeded 
eutrophicat-
ion  
(000 km2) Forest 
area 
exceeded 
ozone 
(000 km2)
2000  3.62 370 - 243 24 31 733 827 
Baseline 
2020  2.47 293 - 119 8 22 590 764 
Scenario A 5.9 1.97 237 37 – 120  67 4 19 426 699 
Scenario B 10.7 1.87 225 45 – 146  59 3 18 375 671 
Scenario C 14.9 1.81 219 49 – 160  55 3 17 347 652 
MTFR 39.7 1.72 208 56 – 181  36 1 11 193 381 
Note: In addition, the range of benefits for reduced damage to agricultural crops is between €0.3 and €0.5 
billions for scenarios A, B and C. In addition, the damage to materials and buildings will be smaller. Ecosystem 
benefits have not been monetised but still need to be considered . 
Moreover, before selecting which of the s cenarios would be the most appropriate one 
for an interim objective, the assessment of wider economic and social impacts is 
required. 
                                                 
86  Lower  value is based on the median of the value of a life year lost (VOLY) and higher value is based 
on mean value of a statistical life (VSL). 
 
EN 83   EN 5.9. Wider economic and social impacts 
5.9.1.  Competitiveness 
The Commission estimated the impacts of the interim objectives on competitiveness, 
using the GEM-E3 general equilibrium model,87 described in more detail in Annex 2. 
The model has already been used on a nu mber of occasions for European policy 
support,88 and allows analysis of impact on GDP, domestic pr oduction, employment 
and prices in Member States, and impact at  sectoral level. It  is not intended to 
convert results on either into a metric that could be combin ed directly wi th quantified 
impacts on health, agriculture, etc, to give  a total benefit for comparison with the 
RAINS-generated cost information.  Instea d, the GEM-E3 provides an indication of 
the likely direction and magnitude of eff ects of air quality improvement policies in 
these areas (e.g. “Are these pol icies likely to have a signif icant effect on employment 
across Europe or in specific sectors or country?”). If macro-economic effects appear 
to be significant, it could be appropriate to adjust policies or to investigate further 
before finalising recommendations. 
The costs of meeting Scenarios A, B a nd C were estimated at 0.04%, 0.08% and 
0.12% of EU-25 GDP in 2020 respectively (See  Table 22). Perhaps surprisingly, the 
Strategy has very little impact on overall em ployment. There are some sectoral shifts 
and some differences between Member States . However, they cancel each other out. 
There would be a small positive impact to exports. However, imports are estimated to grow more, mainly due to the terms of trade effect. 
The general equilibrium analysis takes in to account the possible economic effects of 
industrial relocation from the EU to other countries, be they industrial (e.g. the US 
and Japan) or developing (e.g. China and India), assumi ng that they do not introduce 
additional protection for the environment or human health from air pollution. In other 
words, the reductions in GDP and employme nt in the EU are partly driven by the 
assumption that environmental standards in non-EU countries are lower. 
Another important caveat is that the m easures from RAINS optimizations are 
implemented into GEM-E3 as end-of-pip e measures, without any kind of market-
based instruments. This may lead to a considerable over-estimation of the impact. An 
alternative scenario including flexible mech anisms would be helpful, but it was not 
technically possible to r un this scenario for this impact assessment. 
Due to lack of detailed data, the modelling runs of GEM-E3 do not take into account 
efforts to improve the environment in  non-EU industrialised and developing 
countries and the increase d compliance costs and the demand for technologies to 
reduce air pollution. If developments in other countries could be modelled, the 
                                                
 
87 The model was developed with the support of the 5th Research Framework Programme and is currently 
being used to develop the modelling capability of the Commission in the IQ-TOOLS project under the 
6th Framework Programme. The model and its database were updated in 2004 and extended to 8 New 
Member States (Hungary, Poland, Slovenia, Estonia, Latvia, Lithuania, Czech Republic and Slovakia). 
88 See Kouvaritakis, Paroussos, Van Regemorter: Th e macroeconomic evaluation of energy tax policies 
within the EU, with the GEM-E3-Europe model – Study for the European Commission DG TAXUD; 
http://europa.eu.int/comm/taxation_customs/resources /documents/economictax ation_final_report.pdf     
 
EN 84   EN impact of the Strategy on competitiveness in the EU would be mitigated, even 
reversed. 
Table 22: Macroeconomic impacts of three scenarios compared to baseline in 2020 
 Scenario A Scenario B Scenario C 
Gross Domestic Product -0.04% -0.08% -0.12%
(€ Billion) -5.616,5 -11.565,7 -17.115,8
Private consumption -0.06% -0.13% -0.20%
(€ Billion) -4.668, 7 -9.679,9 -14.387,4
Investment -0.01% -0.02% -0.03%
(€ Billion) -292,2 -607,3 -881, 7
Final energy consumption -0.12% -0.24% -0.34%
Exports to rest of the world 0.00% 0.01% 0.02%
Imports from rest of the world 0.04% 0.10% 0.15%
Employment 0.00% 0.00% 0.00%
(thousand jobs) -6.5 4.0 10.4
Real wage rate -0.04% -0.09% -0.14%
Relative consumer price 0.00% 0.00% 0.00%
Real interest rate 0.01% 0.02% 0.03%
Terms of trade 0.04% 0.08% 0.12%
Source: GEM-E3 
The analysis should be completed taking in to consideration the fact that other 
countries are also taking important steps to  reduce their air pollution, for instance on 
March 10, 2005, the US EPA issued th e Clean Air Inte rstate Rule ( CAIR ) in 28 
Eastern States covering a population of over 200 million. With an estimated annual 
compliance cost of $4.6 billion in the pow er plant sector, CAIR will reduce SO 2 
emissions in all States by over 70% and NO x emissions in the 28 Eastern States by 
over 60% from 2003 levels to 2020. In addition, the US has emission limit values for 
passenger cars that are much more stringent that current Euro 4 standards in the EU 
and the situation is the sa me for heavy duty vehicles.89 These recent air pollution 
laws in the US cost policies cost  about $12 billion per annum in 2020.  
In addition, the NOx State Implementation Plan (SIP)  addressed reduces 
significantly ozone non-attainment problems in North-Eastern US costing about $2 
billion. However, some of these costs have been subsumed by CAIR and are thus not 
completely additional to the other policies.  In sum, the recent air pollution laws -- 
which are comparable to the interim objectives in the Strategy -- ar e estimated to cost 
for transport and power generation sector s alone in the US between $12 and $14 
billion per annum (Figure 24).  
                                                 
89 The recent vehicle emission sta ndards are "Tier II Vehicle (Final Rule 12/1999)" and "Heavy-Duty 
Diesel Rule (Final Rule 12/2000)".  Source: www.epa.gov   
 
EN 85   EN Figure 24: Annual cost of transport and othe r past rules that US EPA has promulgated 
– comparison with Scenario B 
Clean Air Interstate 
RulePassenger cars (Tier 
II)Heavy-Duty Diesel 
RuleNOx State 
Implementation Plan 
Call
0246810121416
CAFE Scenario B US legislation€bn, $bn
 
Source: US EPA and this impact assessment 
Many developing countries are taking acti on against air pollution. For instance, 
China has started to take serious action ag ainst air pollution by requiring coal- fired 
power plants to reduce SO 2 and NO x emissions and has adopted “Euro 3” emission 
limit values for light vehicles  from 2007 onwards (see Box). 
The positive impacts of reduced mortality and increased health status were not 
estimated in GEM-E3. For instance, impr oved air quality reduces the number of 
illnesses and thus not only increases th e quality of life but also increases 
productivity. Reduction in sick days will directly contribute by increasing GDP. 
However, due to modelling uncertainties this feedback to the economy was not 
modelled, and thus the genera l equilibrium results overestimate the compliance costs 
in this respect. 
Overall, the attainment of the interim objectives in the Strategy is not expected to 
impact European competitiveness relative to other developed countries such as the 
USA and Japan. This is because these countries have similar or more stringent air pollution policies in place. For instance, current vehicle emission standards in the USA and Japan are more stringent and their air quality limit values are similar.  
Improving competitiveness and mitigating damage to human health and the 
environment can be complementary. The EU can gain advantages and create 
opportunities by focusing research and deve lopment on resource-e fficient and less 
polluting technologies that other countries will eventually need to adopt. For instance, as some Member States in th e 1980s introduced new technologies to reduce 
 
EN 86   EN NO X and SO 2 emissions, they are now selling this  technology to other parts of the 
world, including developing countries  
 
Reducing SO 2 and NO X emissions in China 
In China, coal-fired power plants are subject to  several regulations. China has had demanding air 
pollution emission standards since 2003. Almost a ll newly built and expanded coal-fired units must 
install flue gas desulphurization (FGD) units to m eet these new standards. For old coal fired power 
plants, sulphur content of coal needs to be below 0.5% to meet the emission standard by 2010. China 
has also set a levy on SO 2 emissions which is currently 630 RMB (i.e. about €60) per tonne of SO 2, 
roughly equivalent to annualized co st of FGD installation in China90. China intends to set a similar 
levy also on NO X emissions. Furthermore, all pure conde nsing type generators below 50 MW are 
phased out due to legislation. 
Chinese government offers an incentiv e to electricity producers to in stall FGDs. The incentive varies 
regionally but the intent is to cover the opera tion costs of FGD. Chinese government is also 
monitoring the emissions through continuous emissi on monitoring systems to ensure full compliance 
to the emissions standards. Finally, China is look ing carefully at the feasib ility of starting a cap and 
trade programme to reduce air pollution. 
Concerning mobile sources, new emission standards for heavy duty trucks entere d into force in China 
from 1 July 2005. For light duty vehicles, the current emission limits in China are Euro 2, and all new 
light duty vehicles to need to meet Euro 3 sta ndards from on 1 July  2005 in Beijing, and from 1 
January 2007 in other parts of China. The feasibility  of setting Euro 4 standards (which entered into 
force in the EU in 2005) for 2010 are currently being assessed. 
In sum, the Chinese policies to reduce SO 2 and NO x emissions are similar to those of the EU and 
trailing by about 5 to 10 years. 
Source:  Air Pollution Control Division, State Environmental Protection Administration of China.  
For details, see: http: //www.zhb.gov.cn/english/  
The sectoral impacts are rather small (Table 23). The price increase remains small, 
which can be partly explained by the co st effectiveness of the measures. The 
equipment goods sectors benefit from incr eased demand for abatement equipment, 
while the consumer goods industry is proj ected to suffer from the decrease in 
consumption.  
The reduction of SO2 and NO X emissions from power generation sector will increase 
the power generation costs by (about 2)  billion euros per annum in 2020. As 
production costs of power generation will be increased these costs will eventually be 
reflected in the wholesal e price of power. In 2020, th e predicted electricity 
consumption in the CAFE baseline was 3856 TWh. Thus, the estimated increase in 
electricity price is about 0.05 eurocents pe r kWh being about 1 % of the wholesale 
price of electricity. The exact  increase will depend on the fuel mix in each Member 
State. 
                                                 
90  For comparison, in Galicia (Spain), there is a levy of up to €42 per tonne of SO 2 while in Denmark the 
levy for power plants is €2670 per tonne of SO 2. In the US the price of SO 2 in their emission trading 
market has been between €50 and €200 per tonne of SO 2. 
 
EN 87   EN The thematic strategy will also benefit th e agricultural sector. This is because the 
reduced ozone concentrations will increase  agricultural productivity. It has been 
estimated that the monetary value alone of increase crop (wheat) production due to 
lower ozone concentrations will be a bout 0.5 billion euros (check) per annum. 
Table 23: Sectoral impact on production at air pollution scenarios (% difference 
compared to the baseline in 2020) 
 Scenario A Scenario B Scenario C 
Agriculture -0.19% -0.46% -0.72%
Energy production -0.09% -0.16% -0.23%
Ferrous and non-ferrous metals -0.01% 0.03% 0.07%
Chemical products -0.01% -0.01% 0.01%
Other energy-intensive sectors -0.05% -0.03% -0.01%Electrical goods 0.12% 0.26% 0.40%
Transport equipment -0.01% -0.02% -0.04%
Other equipment goods 0.24% 0.53% 0.81%Consumer goods industries -0.05% -0.13% -0.21%
Construction -0.01% -0.02% -0.03%
Telecommunication services 0.02% 0.05% 0.08%Transport 0.00% 0.02% 0.05%
Services of credit and insurances 0.01% 0.03% 0.04%
Other market services -0.01% -0.02% -0.04%Non market services -0.01% -0.02% -0.03%
Source: GEM-E3 
5.9.2.  Social Impacts 
The net effect on employment at EU-25 level was estimated to be neither positive 
nor negative. This is because of the fact th at sectoral variations  cancel each other out 
(Table 24). The demand decrease (except for the sectors delivering abatement 
equipment) has a negative eff ect on employment, but on th e other hand the real wage 
decrease (to get an equilibrium on the la bour market) and the energy price increase 
favour the demand for labour. These effects balance each other out. 
GEM-E3 model projects that there w ould be no impact on households through 
variations in consumer  prices (Table 22). 
Regarding impact on social inclusion, CAFE cost-benefit analysis has been 
reviewing evidence on the following issues: (a ) variation of exposur e to air pollution 
amongst communities who rate poorly on social deprivation indices; (b) variation in 
susceptibility of different groups to hea lth impacts (e.g. due to poorer nutrition or 
less access to health care). Quantitative a ssessment of links be tween air pollution 
impacts and social deprivation is not possible at this stage because of a lack of data, 
although there is evidence that air quality tends to be worse in poorer communities. Therefore the benefits of reduced air pollution are likely to favour proportionally 
more lower income groups and thus have  a positive impact on social inclusion. 
 
EN 88   EN Table 24: Sectoral impact on employment at EU level in 2020 
Source: GEM-E3 
Finally, job quality would improve together with needs for retraining in firms. For 
example, better technology is  required to achieve reduc tions in vehicle or plant 
emissions and so this could correlate with a shift towards relatively hi-tech production. 
5.9.3.  Impact on innovation and research 
Recent evidence indicates that in general hi gh environmental standards coupled with 
a transparent and non-discriminatory regulat ory framework constitute an engine for 
business opportunities and innovation.
91 Implementation of the Strategy  is expected 
to lead to increased use of pollution c ontrol technologies to reduce air pollution. 
Historical evidence indicates that as a result of this cap acity expansion, learning-by-
doing will be enhanced.92 Consequently, the costs of air pollution control 
technologies may be reduced by around 10 % every time capacity doubles. Global expansion of capacity in flue gas desulphurization and de-NO
x installations in the 
past entailed a reduction in investment  costs by around 40% over the last 20 years.93 
The number of patents in response to air quality legislation in creased in Germany, 
Japan and the US.  
                                                 
91 See SEC (2005) Main report: overall summary. Im pact assessment and ex-ante evaluation for the 
proposal for the Council and European Parliament decisions on the 7th Framework Programme (EC and 
Euratom), Draft Commission Staff Working Paper, page 7. 
92 No assumption on this basis is already included in the cost estimates. 
93  See Rubin, E. (2004) Clean coal: oxymoron or bridge to a sustainable (low carbon) future? Paper 
presented at the workshop on Technology Policy for Climate Change Mitigation, 16 December Paris. 
Carnegie Mellon University, Pittsburgh, Pennsylvania. Variation vs. Baseline 2020 Scenario A Scenario B Scenario C 
EU-25 thousand % thousand % thousand %
Agriculture -25.1 -0.17% -45.8 -0.31% -73.8 -0.50%
Coal -3.6 -1.51% -4.8 -2.01% -6.3 -2.64%
Oil -0.4 -0.11% -0.8 -0.23% -0.9 -0.26%
Gas -0.4 -0.12% -1.1 -0.34% -1.6 -0.49%
Electricity 4.2 0.22% 5.8 0.30% 9.2 0.48%Ferrous and non-ferrous metals  0.4 0.01% 2.1 0.05% 4.7 0.11%
Chemical products 0.7 0.02% 1.1 0.03% 2.1 0.06%Other energy intensive -1.6 -0.02% 1.6 0.02% 4.7 0.06%
Electric goods 6.6 0.15% 12.7 0.29% 19.7 0.45%
Transport equipment 0.0 0.00% 0.0 0.00% -0.5 -0.01%Other equipment goods 30.6 0.35% 56.9 0.65% 86.6 0.99%Consumer goods industries -4.2 -0.03% -8.4 -0.06% -12.6 -0.09%Construction 0.0 0.00% 0.0 0.00% 0.0 0.00%
Telecommunication services 0.7 0.02% 1.6 0.05% 2.6 0.08%
Transport 2.1 0.02% 5.2 0.05% 8.3 0.08%Services of credit and insurances 2.6 0.04% 4.6 0.07% 6.6 0.10%Other market services -14.9 -0.02% -22.4 -0.03% -29.8 -0.04%Non market services -4.3 -0.01% -4.3 -0.01% -8.5 -0.02%
Total -6.5 0.00% 4.0 0.00% 10.4 0.00%
 
EN 89   EN The European Counc il of March 200394 reiterated the impo rtant contribution of 
environment policy to growth and employment, and also to  the quality of life, in 
particular through the development of eco -innovation and eco-technology as well as 
the sustainable management of natural res ources, which lead to the creation of new 
outlets and new jobs. In additi on to its growth in the internal market, this sector has 
considerable e xport potential. 
5.10. Other environmental impacts 
Measures to further improve air quality will also help  to achieve environmental 
improvements in other policy areas.  
5.10.1.  Climate 
The CAFE programme has shown that there are additional benefits to be obtained by 
ensuring coherence between climate change an d air pollution policies, particularly in 
respect of simultaneously reducing climate and air emissions in the most cost-effective way
95. There are other specific  linkages and overlaps.  
– Tropospheric ozone is a regional and hemis pheric air pollutant but also a direct 
greenhouse gas. It has increased in con centration to the point where ozone is 
now estimated to have provided the thir d largest increase in direct radiative 
forcing since the pre-industrial era. 
– Control of methane and NO x emissions on a hemisphe ric scale would reduce 
the formation of ozone considerably. 
– Primary particulate matter in the form of “black/elementary carbon” has a 
deleterious effect on human health and contributes to atmospheric warming.  
Thus reduced ozone concentrations and reduced emissions of particulate matter from 
road vehicles are ‘no regret s’ policies from the perspec tive of both climate change 
and air pollution policy.  
There may, however, be instances where policies will conflict. For example, 
secondary aerosols formed in the atmosphere from emissions of sulphur dioxide and nitrogen oxides have a negativ e impact on human health, but significantly cool the 
atmosphere. 
5.10.2.  Links to soil and water quality 
Atmospheric deposition of acidifying subs tances and nitrogen compounds contribute 
directly to potential critical load ex ceedences for terrestrial ecosystems and 
freshwater ecosystems. Soil processes and ch emistry dictate the quantity and rate at 
which chemical substances leach from soil into groundwater and freshwater 
ecosystems. The critical load formulations  for terrestrial and freshwater ecosystems 
are based upon soil properties and chemistry, and so there is a direct link between 
                                                
 
94 Paragraph 19 of Presidency Conclusions – Brussels, 22 and 23 March 2005 
95 GEM-E3 scenarios show that CO2 emissions in the EU-25 will be smaller in scenarios B and C than in 
the baseline. 
 
EN 90   EN atmospheric deposition, critical loads, soil quality and water quality. Ultimately, 
detailed soil and water quality monitoring can assist in assessing the effectiveness of 
air pollution policies. 
Contributions to marine pollution come from  direct anthropogenic riverine inputs but 
also from atmospheric deposition. It is pos sible to quantify the atmospheric inputs of 
pollutants such as nitrogen into European  seas using the atmospheric modelling and 
integrated assessment modelling tools, whic h are used routinely in developing the 
thematic strategy on air pollution. 
5.10.3.  Sustainable use of resources and waste recycling 
The measures undertaken in the framework of the Strategy  will contribute to a 
reduced requirement to utilise na tural resources (e.g. fossil fuels). 
Increase recycling (thereby re ducing other processes such as incineration) can reduce 
combustion-related air emissions. 
5.10.4.  Other 
The recently adopted fourth daughter direc tive on ambient air quality addresses the 
atmospheric deposition of mercury. The dir ective will introduce methods to monitor 
such deposition as a means to understand better the behaviour of mercury in the 
environment. No amendments are propos ed to this legisl ation. The proposed 
reductions in combustion-related emissions  from fossil fuel burning will lead 
indirectly to lower emissions of  mercury into the atmosphere. 
These interim objectives will be used as the basis for the revision of the NEC 
Directive in 2006 as well as other legislat ion covering air pollution. To the extent 
sources not covered by the NEC directive are included, the percentages would be 
adjusted as appropriate. 
 
EN 91   EN 6. MEASURES AND INSTRUMENTS  
In order to meet the interim objectives of the Strategy, specific measures will need to 
be undertaken at Community and Member St ate level. The RAINS model is capable 
of providing a broad indication of the sector s and types of measures that could be 
addressed to attain particular emissions reductions for individual pollutants. These 
are discussed below, along with the meas ures that the Commission is currently 
considering proposing. It should be noted th at the abatement measures included in 
the databases of the RAINS model are cons tantly updated with la test information. 
Thus, the measures below provide a snap shot of those measures that were 
particluarly cost-effective in  the estimations made for the Thematic Strategy on Air 
Pollution.  
6.1. Emission reduction measures for meetin g the ambition level of the Strategy – 
indicative outcome of RAI NS optimisation process 
Tables 25a to 25e below show which s ectors require additi onal measures (beyond 
those in the “current legislation” baseline ) in order to achieve the cost-optimal 
emissions reductions associated with Scenar io B. Broad categories of measures in 
individual sectors are also indicated, along with their contribution to the level of 
emissions reduction associated with  each of the three scenarios. 
6.1.1.  SO2 emissions 
For emissions of SO 2, the use of low-sulphur heavy fu el oil (below 1%) is selected 
for most Member States, even for the lowest  ambition level, while the use of flue gas 
desulphurisation depends more on country -specific conditions and the ambition 
level. 
 
EN 92   EN  
Table 25a: RAINS - sectoral contri bution and measures to reduce SO 2 emissions 
 Scenario A Scenario B Scenario C 
 Baseline 
emissions in 
2020 (kt) Reduction 
from 
baseline 
(kt) Share of 
total 
reduction 
in EU-25 Reduction 
from 
baseline 
(kt) Share of 
total 
reduction 
in EU-25 Reduction 
from 
baseline 
(kt) Share of 
total 
reduction 
in EU-25 
Conversion 645 325 30% 356 29% 364 27% 
Process 693 261 24% 294 24% 304 23% 
Industry 435 191 17% 221 18% 229 17% 
Power plants 606 199 18% 208 17% 240 18% 
Transport 217 98 9% 130 11% 138 10% 
Domestic 202 23 2% 24 2% 63 5% 
Waste 7 4 0% 5 0% 5 0% 
Total 2805 1101 100% 1238 100% 1343 100% 
Measures identified by the RAINS model to bring about these emissions reductions are as follows: 
• Low-sulphur heavy fuel oil with sulphur content of less than 1% and gas oil with less than 0.1% for use 
for residential and commercial boilers 
• Low-sulphur coal and fuel oil in industrial combustion, in-furnace sulphur control measures and flue 
gas desulphurisation in the higher ambition case 
• Retrofitting flue gas desulphurisation for existing power generation plants and use of high-efficiency 
FGD in new plants 
• In the fuel production sector, use of low-sulphur fuel oil, controls on refinery processes and flue gas 
desulphurisation for the higher ambition case 
• Restrictions on open burning of agricultural and municipal wastes and better waste management 
• Further reductions in the sulphur content of fuels used in na tional shipping/fishing 
6.1.2.  NO x emissions 
Table 25b: RAINS - sectoral contri bution and measures to reduce NO x emissions 
 
 Scenario A Scenario A (without 
further road transport 
measures) Scenario B Scenario C 
 Baseline 
emissions 
in 2020 
(kt) Reduction 
from 
baseline 
(kt) Share of 
total 
reduction 
in EU-25 Reduction 
from 
baseline 
(kt) Share of 
total 
reduction 
in EU-25 Reduction 
from 
baseline 
(kt) Share of 
total 
reduction 
in EU-25 Reduction 
from 
baseline 
(kt) Share of 
total 
reduction 
in EU-25 
Transport 3013 388 32% 0 0% 388 24% 388 22% 
Industry 660 284 23% 364 32% 375 24% 404 23% 
Process 538 286 24% 314 28% 322 20% 327 18% 
Power plants 801 112 9% 225 20% 271 17% 403 23% 
Conversion 264 118 10% 154 14% 160 10% 174 10% 
Domestic 596 10 1% 56 5% 63 4% 71 4% 
Waste 15 12 1% 13 1% 13 1% 13 1% 
Total 5888 1210 100% 1125 100% 1592 100% 1780 100% 
Measures identified by the RAINS model to bring about these emissions reductions are as follows: 
• Primary combustion measures for oil-fired and gas- fired boilers in the residential and commercial 
sectors and also light fuel-fired boilers in the higher ambition case 
• Primary combustion measures and selective non-catalytic reduction (SNCR) for industrial combustion 
for lower ambition levels, and se lective catalytic reduction (SCR) in the higher ambition case 
• For power plants, changes in primary combustion for all plants not required to fit SCR and fitting of 
SCR for all new coal- and oil-fired power plants 
• In the fuel production sector, use of SNCR for all countries and all levels of ambition and SCR for the 
higher case in countries where NO x reductions are required 
• Restrictions on open burning of agricultural and municipal wastes and better waste management 
• Further measures on light-duty and heavy-duty diesel vehicles 
 
EN 93   EN Primary measures to reduce NO x emissions from small combustion sources have 
been clearly identified as a cost-effec tive option by the RAINS model. For large 
combustion sources, Selective Non-Cata lytic Reduction (SCNR) and Selective 
Catalytic Reduction have been identified as cost-effective depending on the level of environmental ambition chosen. Measures on al l types of diesel vehicles have also 
been identified as cost-effective by th e RAINS modelling, though will be subject to 
more detailed review in the impact assessment for future emission standards. 
6.1.3.  PM
2.5 emissions 
For reducing emissions of particulate matter, particle filters of various types 
(electrostatic precipitators, cyclones or fa bric filters) are clearly identified as being 
cost-effective in nearly all sectors. Particle filters for diesel road vehicles have also 
been identified as cost-effective measures, though will be subject to more detailed 
review in the impact assessment for future emission standards. 
Table 25c: RAINS - sectoral contri bution and measures to reduce PM 2.5 emissions 
  Scenario A Scenario A (without 
further road transport 
measures) Scenario B Scenario C 
  Baseline 
emissions 
in 2020 
(kt) Reduction 
from 
baseline 
(kt) Share of 
total 
reduction 
in EU-25 Reduction 
from 
baseline 
(kt) Share of 
total 
reduction 
in EU-25 Reduction 
from 
baseline 
(kt) Share of 
total 
reduction 
in EU-25 Reduction 
from 
baseline 
(kt) Share of 
total 
reduction 
in EU-25 
Domestic 319 70 32% 77 39% 104 41% 127 45% 
Process 213 49 22% 49 25% 51 20% 52 18% 
Waste 46 42 19% 42 21% 42 16% 42 15% 
Power plants 55 22 10% 22 11% 22 9% 22 8% 
Industry 12 4 2% 4 2% 4 2% 5 2% 
Other 112 3 2% 3 2% 3 1% 3 1% 
Conversion 15 3 1% 3 1% 3 1% 4 1% 
Transport 194 26 12% 0 0% 26 10% 26 9% 
Total 964 218 100% 200 100% 255 100% 282 100% 
Measures identified by the RAINS model to bring about these emissions reductions are as follows: 
• Use of cyclones and fabric filter dedusters for boilers in the commercial sector and new residential 
boilers (mainly biomass-fired)  
• Use of high-efficiency dedusters fo r all countries and all ambition levels and maintenance measures 
• For power plants, use of high-efficiency dedusters for all existing and new boilers using solid fuels and 
good-housekeeping measures on oil- fired boilers (for all countries and all ambition levels). Likewise 
for the fuel production sector and coking plants 
• Restrictions on open burning of agricultural and municipal wastes and better waste management 
• Further measures on light-duty and heavy-duty diesel vehicles and low-sulphur fuels for national 
shipping and fishing vessels 
6.1.4.  Ammonia emissions 
With respect to reducing amm onia emissions under Scenario A, it is estimated that 
about 65% of the reduction comes from lives tock activities, and the remaining 35% 
from reduced use of mineral fertiliser where urea is used more effectively and partly 
replaced by ammonium nitrate.  This is the case for all ambition levels. The reduction 
from livestock is achieved primarily through greater use of low-ammonia manure-spreading methods, which produces 80 to 90 % of the required re duction in this 
sector. The rest is achieve d through the introduction of  low-emission housing with 
integrated closed storage for poultry. Meas ures on poultry and fe rtiliser use appear 
cost-effective for all scenarios and for all countries. Use of low-ammonia manure-
 
EN 94   EN spreading methods is suggested by the model for dairy cows and pigs and to a lesser 
extent for other cattle and is  required in about half of the EU Member States. 
Under Scenario B about half of the required reduction is  achieved from poultry and 
fertiliser use as described above. The additional reductions over Scenario A are achieved primarily through more extensive application of pig and cattle manures 
with low-ammonia spreading methods in most Member States. In addition, better 
storage of manure from pigs and cattle is suggested for some countries. Small 
reductions are also made th rough efficient application of sheep manure and better 
control of end-of-pipe emissions from the nitrogenous fertiliser industry. The latter 
measures feature for nearly half of the EU Member States. 
Table 25d: RAINS - sectoral contri bution and measures to reduce NH
3 emissions 
 Scenario A Scenario B Scenario C 
  Baseline 
emissions 
in 2020 
(kt) Reduction 
from 
baseline 
(kt) Share of 
total 
reduction in 
EU-25 Reduction 
from 
baseline 
(kt) Share of 
total 
reduction in 
EU-25 Reduction 
from 
baseline 
(kt) Share of 
total 
reduction in 
EU-25 
Poultry 470 267 32% 272 25% 274 23% 
Fertiliser use 660 275 33% 275 25% 275 23% 
Pigs 800 110 13% 183 17% 250 21% 
Dairy cows 644 122 15% 174 16% 199 16% 
Other cattle 676 44 5% 150 14% 161 13% 
Processes 54 5 1% 26 2% 38 3% 
Other animals 166 2 0% 7 1% 12 1% 
Other 215 0 0% 0 0% 0 0% 
Total 3686 826 100% 1088 100% 1209 100% 
Measures identified by the RAINS model to bring ab out these emissions reductions are as follows:  
• Use of low-ammonia manure-spreading methods 
• Better use of fertiliser and reduced em issions from fertiliser manufacture 
• Better storage of animal wastes from the pig and cattle sectors 
• Low-emission housing for the intensive poultry sector 
• Low-nitrogen feedstuffs 
Scenario C requires an additional reduction of 120 kilotonnes of ammonia beyond 
Scenario B. The model indicates that th is can be achieved through reduced nitrogen 
feeding strategies for pigs in about half of  the Member States and greater use of low-
ammonia manure-spreading methods for pigs  and cattle (for nearly all Member 
States). Further small reductions are estim ated for dairy cows using low-emission 
housing, low-ammonia application of sheep manures in most Member States, and 
further reductions in  emissions from the fertiliser i ndustry, although th e latter do not 
amount to a major proportion of the overa ll emissions reductions required. 
6.1.5.  VOC emissions 
The VOC emissions reduction requirements of  the three scenarios vary between 700 
and 1150 kilotonnes in 2020. Some 20 to 30% of  that reduction is to come from 
process emissions (e.g. control of fugitive lo sses from the organic chemical industry) 
and a change in road asphalting methods (a  move away from cutback to emulsion 
bitumen).  
The other reductions can be ach ieved in paint application (coatings), solvent use and 
liquid fuel production. A Europe-wide ban on open burning of agricultural residues 
 
EN 95   EN and more efficient combustion of biomass in  the residential sector (see also the 
section on particulate ma tter) are also seen as co st-effective measures under 
Scenario B. 
Between 10 and 15% of the reduction (for A and C respectively) is achieved from 
liquid fuel production, while under Scen arios A and B improved flaring and 
reduction of fugitive losses in refineries (process and storage) play a prominent role in most countries. Under Scenario B and especially Scenario C, reduction of emissions from oil and gas platforms in  the UK makes a significant contribution 
(nearly half of the reducti on achieved in the ‘Conversion’ sector under Scenario C). 
In addition, measures for gaso line distribution appear in countries that have not yet 
introduced such legislation (Stage II). 
Table 25e: RAINS - sectoral contribution and measures to reduce VOC emissions 
  Scenario A Scenario B Scenario C 
 Baseline 
emissions 
in 2020 (kt) Reduction 
from 
baseline 
(kt) Share of 
total 
reduction 
in EU-25 Reduction 
from baseline 
(kt) Share of 
total 
reduction 
in EU-25 Reduction 
from 
baseline 
(kt) Share of 
total 
reduction 
in EU-25 
Coatings 1008 183 27% 300 31% 335 29% 
Solvents 1402 156 23% 246 25% 269 24% 
Processes 880 219 32% 239 24% 244 21% 
Conversion 763 80 12% 125 13% 167 15% 
Waste 182 42 6% 51 5% 55 5% 
Domestic 531 5 1% 16 2% 73 6% 
Transport 1036 0 0% 0 0% 0 0% 
Other 114 0 0% 0 0% 0 0% 
Total  5916 685 100% 977 100% 1143 100% 
Measures identified by the RAINS model to bring about these emissions reductions are as follows: 
• Control of fugitive emissions from the chemical industry 
• Use of emulsified bitumen for road surfacing 
• Decreased flaring and lower fugitive losses in fuel production processes 
• Reduced solvent use in the coatings industry and decorative paints 
• Restrictions on burning of agricultural residu es and improved residential biomass burning 
• Reduced solvent use and solvent content of products such as printing inks and adhesives 
• End-of-pipe controls on solvent emissions from installations 
Further reduction of the solvent content of coatings used in industrial applications 
and for decorative purposes (or more widespread use of low-solvent or solvent-free coatings) still appears to be an attractive option in all scenarios. Under Scenario A 
about 25% of the total reduction is expected to come from the ‘Coatings’ sector with 
more than 70% achieved in industrial applic ations. However, these reductions appear 
in only a few countries. Under Scenario B mo re than half of the countries implement 
measures in this sector, achieving 30% of the total reduction requ ired, again mostly 
from industrial application of paints, esp ecially wood coatings. Under Scenario C a 
slightly larger reduction is expected, mostly  from decorative paint applications (both 
professional and do-it-yourself) requiring more stringent control than under the 
‘Products Directive’ – the so-called ‘DECO Paint Directive’. This measure is one of 
the solutions for virtually all Member States. 
The remaining 20% of the reduction required under all scenarios is in the ‘solvent 
use’ sector. This encompasses a large number of activities with installations of varying sizes. Therefore a mixture of alternative end-of-pipe measures (carbon 
 
EN 96   EN adsorption and thermal incineration) is re quired to attain the estimated reductions. 
Especially under Scenario A a variety of sectors each contribute small amounts to the 
total reduction, while under Scenarios B a nd C further reductions in the printing 
sector, especially packaging, through subs titution of adhesives and inks for low-
solvent or solvent-free inputs, reducti on in the solvent content of cleaning and 
dampening agents, and wider use of carbon ad sorption play a significant role (up to 
70% of reductions). Further reductions ar e expected in metal degreasing, industrial 
adhesive application and a number of smaller sectors. 
6.2. Measures considered 
Following the indicative  results of the integrated assessment modelling associated 
with the three ambition scenarios, the meas ures described below will be considered 
by the Commission for further action. These measures are at different stages of 
consideration and development and generally each will need to be accompanied by a detailed and careful impact assessment befo re definitive proposals are put forward. 
6.2.1.  Revision of the National Emi ssions Ceilings Directive 
The Commission will propose revised emi ssion ceilings in the NECD in 2006 based 
upon the interim objectives id entified in th is strategy. 
The natural instrument for setting emissi on reduction targets is the NEC Directive, 
which sets emission ceilings for each Member  State. At the moment, this Directive 
sets emissions ceilings for four pollutants (NO
x, SO 2, NH 3 and VOC) which are to be 
attained by 2010 but leaves the Member States to decide ho w. This allows flexibility 
and reduces costs. The Commission will put forward a proposal to amend this 
Directive in 2006 and establish new ceilings that are consistent with the interim 
objectives of the Strategy and Scenario B. The Commission will also review other aspects of the NECD, including simplifyi ng implementation and reporting, using 
emissions trading schemes and introduci ng targets for primary particulates  
The integrated assessment modelling demonstrated that further measures need to be 
taken to reduce NO
x and SO 2 emissions from large combustion plant in the power 
production, industrial and fuel  production sectors. Curre ntly the Commission has no 
plans to amend the existing obligations in the Large Combustion Plant Directive 
(LCPD) which regulates large boilers w ith a thermal rating in excess of 50 MWh. 
However, the Commission will, inter alia,  pursue the option of introducing regional 
(including regional transboundary ) emissions trading for NO x and SO 2 when revising 
the NEC Directive in 2006. This would perm it individual plants to trade emissions 
reductions that go beyond current LCPD limits. 
6.2.2.  Revision of vehicle emissions limits  
As specified in Directive 98/69/EC, the “Euro 4” emission limits entered into force 
for cars and other light-duty vehicles on 1 January 2005. Given the continuing health 
risks posed by PM and ozone, a number of Member States  have announced that they 
intend to give tax incentives for vehicles th at meet even tighter limit values. In this 
situation, and driven by a desire to prevent fragmentation of the internal market, the 
 
EN 97   EN Commission has put forward a framework fo r fiscal incentives for cleaner diesel 
vehicles96 to go beyond the current Euro 4 standa rd for diesel cars. The integrated 
assessment modelling shows that further meas ures on diesel particulates from light-
duty and heavy-duty diesel vehicles ma y be warranted. The Commission will put 
forward a proposal later in 2005 to revise downwards the current Euro 4 emissions 
limits for light-duty diesel vehicles. Th ese new limits will be in line with the 
Commission’s previous framework for fiscal incentives, but will be accompanied by a separate impact assessment. 
New vehicle emission sta ndards and Nitrogen dioxide 
Two ambient air quality standards exist for nitrogen dioxide (NO 2) which enter into force on 
1 January 2010. The first is a maximum hourly  concentration of 200µgm-3 (not to be 
exceeded more than 18 times per calendar y ear) and the second, and probably the most 
stringent, is a maximum annual average concentration of 40µgm-3.  
High temperature combustion results in the emission of a mix of nitrogen oxides (NO X) in 
the form of nitric oxide (NO) and nitrogen di oxide. Nitrogen dioxide can also be formed 
from the atmospheric oxidation of nitric oxide . The amount of directly emitted nitrogen 
dioxide depends upon the particular combusti on conditions such as temperature and oxygen 
content of the fuel-air mixture. 
The concentration of nitrogen dioxide in air that is measured at a particular air quality 
monitoring station will be influenced by the ma gnitude of nitrogen dioxide emissions nearby 
and by the amount of nitric oxide that can be converted locally in the vicinity of the sampling 
point. This latter contribution de pends upon the local availability of oxidants in the air such 
as ozone. Road vehicles contribute significantly to emissions of nitrogen oxides and to the 
measured concentrations of nitrogen dioxide in urban areas. Historically, nitric oxide 
comprised around 90% of the NO X mixture emitted from road vehicles. 
There are currently exceedences of the air qualit y limit values for nitrogen dioxide in urban 
areas. Moreover, preliminary indications show that exceedences will re main in 2010 when 
the limit values enter into force even though em issions of nitrogen oxides are decreasing as a 
result of European vehicle exhaust standards. In this context, a cause of concern is the 
increasing proportion of directly emitted nitrogen dioxide97. This is because of three factors. 
First, diesel vehicles comprise an increasing fraction of the vehicle fleet and diesel vehicles 
emit a greater proportion of nitrogen dioxide. S econd, some diesel particulate filters actively 
convert nitric oxide to nitrogen dioxide in orde r to destroy soot particles, thereby increasing 
the proportion of nitrogen dioxide. Thirdly, the proportion of nitrogen dioxide increases in 
slow moving traffic. 
The reported results from the DEFRA study a bove may have implications for future 
European vehicle emission standards. More specifically, emission limit values for total NO X 
may need to be modified so as to (1) reflect  better the proportion emitted as nitrogen dioxide 
and (2) contribute to attainment of Community  air quality objectives for nitrogen dioxide. 
                                                 
96 SEC(2005) 43 of 12 January 2005 
http://www.europa.eu.int/comm/enterprise/automotive/pagesbackground/pollutant_emission/sec_2005_43.pdf  
 
97 “Nitrogen dioxide in the United Kingdom, prepared for the Department for Environment, Food and 
Rural Affairs by the Air Quality Expert Group, March 2004. 
http://www.defra.gov.uk/environment/airquality/aqeg   
 
EN 98   EN As specified in Directive 88/77/EC, the “Euro 5” emission limit values for heavy-
duty vehicles will enter into force from October 2008 . A proposal for further 
tightening of the emissions from heavy-dut y vehicles will be put forward by the 
Commission shortly after the proposal for Euro 5 standards for cars and light-duty 
vehicles. 
6.2.3.  Emissions from small-scal e combustion installations 
The integrated assessment modelling demons trated the potential of measures to 
reduce PM 2.5 emissions in the residential and commercial combustion sector, 
particularly in respect of residential bi omass combustion. High-efficiency dedusters 
were also cost-effective for use in  the industrial combustion sector.  
Small combustion plants are an increasingl y important source of emissions, but they 
are not regulated at Community level. For industrial combustion sources below 
50 MWh the Commission will assess whether it is appropriate to extend the scope of 
the IPPC Directive when it is reviewed in  2006. Harmonised technical standards will 
also be developed for domestic combus tion appliances and associated fuels, 
including coal and biomass. Inefficient biomass combustion can emit relatively high 
amounts of particulate matter and meth ane, thus diminishing the positive 
contribution made by biomass as a renewa ble source. Therefore efforts should be 
made to ensure that biomass is incinerated under optimal conditions. 
Efforts could be also be made  to shift away from the use of coal and other solid fossil 
fuels for domestic heating, particularly in the most polluted areas. In the case of low-
income households, the Commission will c onsider how Community funds could be 
used to help promote such a shift and cleaner combustion methods, without 
excluding cleaner use of coal. 
More efficient use of energy, greater use of renewable fuels and better use of natural 
resources can all help to reduce emissions of harmful particulate matter as well as 
mitigating the impacts of climate change and addressing concerns over the security of energy supplies. To that end, if feas ible, small residential and commercial 
buildings could be included in an extended directive on energy efficiency. 
6.2.4.  VOC emissions from refuelling of passenger cars 
The Commission will examine the scope for,  and cost-effectiveness of, Community 
action to reduce emissions from the refuelling of cars at service sta tions ( “Stage II”). 
If appropriate, a legislative proposal  will be developed in early 2006.  
6.2.5.  NO
x and SO 2 emissions from ships in European seas 
Unless action is taken, emissions of sulphur  dioxide and nitrogen oxides from ships 
in EU seas are projected to be greater than all land-based emissions in 2020. Action 
is needed, but shipping is a global i ndustry and clearly global solutions are 
preferable, particularly as the Law of the Sea98 imposes limits on what can be 
regulated on a regional or national basi s. Mindful of these constraints, the 
Commission has already taken action on sh ip emissions, adopting an EU strategy 
                                                 
98  United Nations Convention on the Law of the Sea, to which the Community is a Party. 
 
EN 99   EN accompanied by a proposal for a directive on sulphur in marine fuel.99 The directive 
will set sulphur limits for fuels used in all EU seas and ports. It was finalised by the 
European Parliament in April 2005 and will be formally adopted later this year. 
A scenario for ship emissions was developed, which applied to all ships irrespective 
of flag and in all EU seas. This incl uded the existing legislation plus the 
implementation of relatively straightforward additional measures: 
– International Maritime Organisation NO x emission standards for all ships built 
since 2000 (as set out in the MARPOL Convention, Annex VI  on air pollution); 
– limits on marine fuel sulphur, as provided for in the abovementioned proposal for 
a directive, i.e. 1.5% sulphur fuel oil for all ships in the North Sea and the Baltic Sea; 1.5% sulphur fuel for all passenger ships in the other EU  seas; 0.1% sulphur 
fuel for all ships at berth in ports; 
– slide valve retrofit on all slow-speed engi nes installed before 2000 (later engines 
already have these) with co sts below €50 per tonne of NO
x avoided; 
– internal engine adjustments for all new engines after 2010.  
Scenario B for all EU sources of air pollu tion was estimated with and without this 
package of measures on ship emissions. The additional cost of these measures for ships was estimated by the RAINS model at €28 million per annum. However, application of the measures for ships results in cost savings for land-based sources of €159 million per annum whilst maintaining th e same level of environmental and 
health protection. Clearly, measures for ship s can be very cost-effective in reducing 
emissions and result in net savings of €131 million per annum. 
The Commission therefore intends to take the following action: 
• pursue negotiations on stricter air emissi on standards for ships under Annex VI to 
the International Maritime Organisatio n’s Marine Pollution Convention. The 
Council has called on the Commission to consider EU regulation for NO
x 
emissions if no tighter st andards are agreed by 2006;100 
• promote the use of shore-side electricity by developing guidelin es and considering 
energy tax exemptions for ships using such facilities;  
• ensure that low-emission operation is app lied effectively as a criterion for EU 
funding (Marco Polo and Motorways of the Sea); 
• examine the feasibility of using market-based instruments to promote low-
emission shipping, including differentiate d port dues in the context of the 
Commission’s forthcoming proposal on maritime infrastructure charging; 
                                                 
99 Communication from the Commission to the European Parliament and the Council on a European 
Union strategy to reduce atmospheric emissions from seagoing ships, COM(2002) 595. 
100 Council conclusions of 23.12.2003 (16369/03). 
 
EN 100   EN • consider whether/how to incorporate in ternational shipping  when revising the 
NEC Directive.  
6.3.  Integration of air quality concerns into other sectors 
6.3.1.  Agriculture 
Cattle farming, the pig and poultry sector an d the use of mineral fertilisers account 
for the vast majority of ammonia emi ssions. The recent reform of the Common 
Agricultural Policy should bring about a reduction in ammonia emissions from 
agricultural sources following:  (1) the removal of the link between financial support 
and the obligation to retain specific number of animals; (2) the removal of incentives 
towards intensification which w ill result in a reduction of mineral fertiliser use; and 
(3) the introduction of obligatory cross comp liance with environmental directives as 
a condition for granting the full direct payments. Further improvements are also 
expected to result from an effective implementation of certain environmental 
Directives, such as the Nitrates Directive, 101 the IPPC Directive, the Environmental 
Impact Assessment Directive and the Water Framework Directive. 
However, these improvements could be insu fficient to meet the objectives of the 
Strategy. Given that nitrogen plays a role in several environmental problems, the 
Commission will pursue a coherent approach  to nitrogen management consistent 
with the recent Nanjing Declaration102. Priority will be attached to measures and 
policies to reduce “excessive” nitrogen use in agriculture and which simultaneously 
address nitrates in water, and ammonia a nd nitrous oxide emissions to air. Such 
policies could address (1) the nitrogen conten t of animal feedstuffs; (2) excessive use 
of nitrogen fertilisers; and (3) the promotion of further research into the nitrogen 
cycle and its environmental implications.  
In order to comply with existing and new emissions ceilings for ammonia when the 
NECD is revised in 2006, the Member States will have to prepare plans and programmes to demonstrate how they will meet these ceilings. The achievement of 
reduction objectives may require the de velopment of national actions plans, 
including obligati ons applicable at farm level.  
The current Rural Development Regulati on and the Commission proposals for rural 
development for 2007-13 provide several po ssibilities to tackle  ammonia emissions 
from agricultural sources. These include m easures related to fa rm modernisation, 
meeting standards and agri-environment. The Commission urges the Member States 
to make full use of these measures. In particular, Member States can design agri-environment schemes which go beyond environmental legislative obligations and minimum requirements for fertiliser use iden tified in rural development programmes. 
These could also help towards a more e ffective compliance with the CLRTAP code 
of good farming practice.
103 
                                                 
101 Directive 91/676/EEC, OJ L 375, 31.12.1991, p.1. 
102 3rd International nitrogen conference, October 2004 Nanjing China. 
103 As required in Annex IX of the CLRTAP Gothenburg Protocol 
 
EN 101   EN 6.3.2.  Transport 
In keeping with the commitments made in the White Paper on a common transport 
policy,104 the Commission will further encourage shifts towards less polluting modes 
of transport, alternative fuels and the internalisation of externalities into transport costs. With regard to infrastructure charging, the Commission has already made proposals as regards the charges for the use of road transport infrastructure 
applicable to heavy vehicles (Eurovigne tte) and a common framework for all modes 
will follow. Other possible measures are presented below and these could be complemented by additional measures when  the White Paper is reviewed in 2005”. 
6.3.2.1.  Land transport  
The Commission will be considering m easures to reduce emissions such as: 
• practical guidelines for differentiated charging according to air pollution 
damage and impacts in envi ronmentally sensitive areas; 
• mandatory inclusion of external ener gy and air pollution costs in public 
procurement decisions for vehicles and transport services; 
• establishment of a common framework for designating low-emission zones. 
Moreover, since older road vehicles cause  disproportionate levels of pollution, 
Member States should consider retrofitting and scrapping schemes, particularly for public service vehicles, when drawing up pl ans and programmes to meet air quality 
objectives. In its thematic strategy on th e urban environment,  the Commission is 
exploring how best to help Member St ates and local authorities devise and 
implement sustainable urban transport pl ans which combine improvements in public 
transport with demand management in order to  ensure a fair contribution of transport 
activities to the achievement of air quali ty, noise and climate change objectives”. 
6.3.2.2.  Aviation 
Measures offering potential synergies be tween climate change and air quality
105 will 
be discussed in a forthcoming communicati on on the use of economic instruments to 
reduce the climate change  impact of aircraft. 
6.3.3.  Community Funds 
Community funds could be used to s upport attainment of the environmental 
objectives described above, notably in connection with the development of 
sustainable transport systems, sustainable and cleaner energy supplies in urban areas, 
and for institutional capacity-building to a llow more effective implementation of air 
pollution abatement measures. 
                                                 
104 COM(2001) 370 final, 12.9.2001. 
105 The impact of air transport on the air quality in the vicinity of transport is not limited to emissions from 
airplanes during taxi, take-off and landing, and should take into account those from ground based traffic 
induced by air transport (transport of passengers, staff and goods to/from airports; busses, trucks and 
service vehicles on runways) 
 
EN 102   EN 6.4. Applying effective policy instruments  
While preparing the Strate gy, in 2004 the Commission, toge ther with the CLRTAP, 
organised a Conference on Policy Instrument s to Reduce Air Pollution. It concluded 
that both traditional regul ation and market-based inst ruments could be applied 
successfully to reduce emissions of NO x and SO 2. In practice, market-based 
instruments often build on the legislative ba sis, and are used together with direct 
regulation as part of policy packages. Recen tly EU Member States have used various 
types of market-based instruments affected  by different sets of  Community rules on 
taxes, State aid, emission trading an d internal market considerations.  
Since market-based instruments are still at the pilot stage and not yet applied 
routinely, experimentation with flexible instruments in the policy mix should be 
encouraged. Furthermore, additional ex-post  evaluations of the instruments currently 
used should be carried out more systematically.  
The Commission will propose legislati on based on a clear long-term policy 
framework for air pollution, so that this is compatible with its other objectives, 
notably those of climate change. In this context, when considering instruments it will be particularly mindful to meet specific objectives. Economic instruments, including 
NO
x and SO 2 emissions trading both for fixed insta llations and for ships, are part of 
such considerations to ensure that the environmental objectives are met at the lowest cost and, thus, with minimum impact on competition. The Commission will analyse the scope for introducing such instruments, inter alia  during revision of the NECD in 
2006.  
Looking at the legislation on specific s ources, “averaging, banking and trading” 
schemes could perhaps be used as co st-effective policy instruments. The 
Commission has already proposed such inst ruments, first in 2000 for reducing air 
pollution from non-road machinery and then again in 2003 for phasing out 
fluorinated greenhouse gases fr om mobile air conditioners.
106 
Conference on Policy Instruments to Reduce Air Pollution 
The Commission hosted a conference on policy instruments to reduce air pollution in 
Brussels on 11 and 12 November 2004 together with the CLRTAP Network of Experts on 
Benefits and Economic Instrume nts. The main objectives were: 
(a) to bring together the latest research findi ngs from practical applications of economic and 
other instruments to reduce air pollution in the EU and ECE countries; 
(b) to give policy guidance for finalisation of  the Thematic Strategy on Air Pollution; and 
(c) to provide input for the forthcoming revi ew of the 1999 Gothenburg Protocol, which will 
be formally initiated after the Protocol enters into force.  
For details, see http://europa.eu.int/comm/e nvironment/air/nebei_workshop/index.htm. 
                                                 
106 COM(2000) 840 of 18.12.2000 and COM(2003) 492 of 11.8.2003. 
 
EN 103   EN 7. IMPACT ASSESSMENT FOR DIRECTIVE ON “AMBIENT AIR QUALITY AND CLEANER 
AIR FOR EUROPE ” 
A proposal to revise substantially existin g Community legislation on ambient air 
quality accompanies the Thematic Strategy on air pollution. An impact assessment is 
therefore required to support this proposal. However, rather than create a separate 
assessment with unnecessary duplication of work, the detailed assessment to support 
the specific options set out in the proposal has been included here. This is logical 
given that the same economic modelling fram ework has been used in both cases and 
given the transferability of results from the Thematic Strategy to the legislative proposal. 
7.1. Better regulation: Streamlining current air quality legislation 
In line with the general initi ative to streamline existing legislation, the new proposal 
will aim at revision of (i) the first daughter  directive on ambient air quality including 
the air quality framework directive (96/62/EC ), (ii) the second and the third daughter 
directives (2000/69/EC, 2002/3/ EC) and (iii) the Council Decision on the exchange 
of information related to air quality mon itoring in general (97/101/EC). This would 
lead to one comprehensive Directive cove ring the abovementioned regulations. In 
doing this the new proposal will aim at  some overall objectives such as: 
– Condensing everything into a single lega l act and removing obsolete provisions 
– Bringing data provision, assessm ent and reporting into the 21
st century 
– Reforming and modernising wh at did not work well enough 
– Updating limit values according to the latest science. 
Implementation of the current directives  would be improved and strengthened. A 
general provision on natural contributions w ould be included, so that Member States 
will be able to discount natural contributions to measured levels of pollutants as 
Member States have no power to tackle such sources. 
In addition, there may be compliance problems in the short term with some ambient 
air quality standards. Th e Commission proposes to permit a delay for their 
attainment. This would be re stricted to individual zone s or agglomerations, provided 
a Member State can demonstrate objectively verifiable conditions (including strict 
compliance with certain Community legislation contributing to an improvement of air quality). As a quid pro quo,  the Member State woul d have to develop and 
implement an air pollution abatement programm e to ensure that the limit values are 
attained upon expiry of the extension. It has not been possible to quantify the impact 
of this proposal, which is a “safety va lve” against unduly high abatement costs in 
exceptional situations. However, all reasonabl e measures need to have been taken. 
Thus, a delay of the attainment date can be regarded as a means of safeguarding 
against uncertainty between the models th at predict air quality and the actual 
situation in specific locations in the EU.  
 
EN 104   EN Due to the proposed regulation, the PM 2.5 monitoring network needs to be expanded 
by an estimated 800-1200 stati ons, given that some 100 PM 2.5 monitoring stations 
already exist in the Community.107 It should be noted that under current air quality 
legislation there is a requirement to monitor PM 2.5 concentrations.108 Thus, the 
proposed regulation does not in itself increase the monitori ng requirements. In other 
words, the Commission does not consid er that the additional monitoring 
requirements increase the regulat ory burden for Member States. 
For transparency, the Commission has es timated the costs of establishing and 
running 1200 additional PM 2.5 monitoring stations, assuming that 1000 of them 
would use the existing monitoring infrastruc ture (Table 26). When modelling is also 
employed, it may be possible to reduce the re quired additional numbe r of stations to 
about 800, with 700 of them using the existi ng monitoring infrastructure. This needs 
to be seen in a context where PM 2.5 will be subject to regulation from 2010 onwards 
following establishment of the percentage  reduction in the average urban background 
concentrations of PM 2.5 for the period 2010 and 2020. Thus about half of the costs 
will be incurred from 2008 onwards as urban background monitoring of PM 2.5 needs 
to have been established. To assess progress towards compliance with the 
concentration cap in 2010, it  is required that all PM 2.5 monitoring stations  are in 
place at the time of transposition of the new Directive. 
Table 26: Annualised investment and running costs of PM 2.5 compliance 
monitoring in EU-25 by 2010 (thousands of  euros). Four options are explored: 
additional 800 or 1200 stations, with/without 500 SO 2 measurement 
replacement. 
    Cost per station Total 
   Stations Option 1 Option 2 Option 1 Option 2 
Additional PM 2.5 measurement 
points (no infrastructure needed) 700 9.3 5.2 6500 4500
Additional PM 2.5 measurement 
points (infrastructure needed) 100 11.8 7.7 1200 800
Total  800    7700  5300
   
Additional PM 2.5 measurement 
points (no infrastructure needed) 1000 9.3 5.2 9280 7250
Additional PM 2.5 measurement 
points (infrastructure needed) 200 11.8 7.7 2400 1550
Total 1200     11600 8800
Option 1: Assuming no replacement of SO 2 station monitoring 
Option 2: Assuming that 500 SO 2 monitoring stations will be replaced by PM 2.5  monitoring 
 
                                                 
107 In comparison, there are about 1000 measurement points for PM 10 in the EU-25. 
108 Article 5 (2) of the 1st daughter directive states that “Member State shall ensure that measuring station 
to supply data on concentrations of PM 2.5 are installed and operated. Each Member State shall choose 
the number and siting of the stations at which PM 2.5 is to be monitored as representative of 
concentrations of PM 2.5 within that Member State.” However no minimum requirement for the number 
of stations has been given, as was the case for PM 10.  
 
EN 105   EN One specific issue is that Member States s eem to have an over capacity of monitoring 
points on SO 2 at least when compared with the requirements of the current air quality 
legislation. Therefore, Ta ble 23 also gives the estimates assuming that 500 
monitoring points of SO 2 could be replaced by PM 2.5 monitoring stations.109 While 
there would be no saving in investment co sts, there would be a saving as far as 
recurrent costs (in particular labour costs) are concerned.  
In sum, the Commission estimates that th e annualised costs of running the additional 
PM 2.5 monitoring stations would be between €5.3 and €11.6 million, depending on 
what extent Member States employ modelling and replace SO 2 monitoring with 
PM 2.5 monitoring.  
A general scheme for background monitoring will be integrated, following the 
approach introduced with the fourth daught er directive. It will build upon current 
monitoring requirements under the CLRTAP a nd will permit a greater use of models 
in the assessment of air quality which Memb er States are obliged to undertake. Thus, 
in the longer term, the Commission anticipates a shift towards greater use of modelling and less use of more expensiv e monitoring. In accordance with this 
general scheme, the current proposal will introduce a requirement for the background 
monitoring of PM
2.5 mass concentrations and chemical speciation. It is estimated that 
monitoring should take place at approxima tely 40 stations in the EU-25, with 
estimated annualized110 investment and running costs of €1 million. It is considered 
that a minimum of 75% of stations will already be  operational under the EMEP 
programme111 or to meet the requirements of  the fourth daughter directive.112 New 
sampling equipment, increased station ma intenance costs, labour and especially 
chemical analysis costs (estimated at an annual cost of €24.000 per station, assuming 
weekly measurements of major inorganics , elemental and organic carbon) contribute 
to the final estimate. 
The reporting obligations based on the Exchange of Information Decision and under 
the air quality legislation (framework and da ughter directives) wi ll be amended in 
such a way that all information will eventua lly feed into a shared information system 
to be established under the INSPIRE directive when adopted.113 The shared 
information system will be used for public information, for the state of environment assessments, and for checking compliance with the environmental objectives. The provisions for reporting will be prepared so as to allow a smooth shift towards future 
requirements under the INSPIRE Directive. It is also important to ensure that air 
                                                
 
109 Estimation of overcapacity explicitly refers only to  comparison with the requirements of the European 
air quality legislation. Member States might have additional reasons to continue with monitoring. In addition, the geographical distribution of overcapacity  is very non-uniform across EU-25. However, the 
continuation of certain monitoring programmes on ‘historical grounds’, rather than current and future 
information needs, has been acknowledged to have important potential to streamline environmental monitoring in general. 
110 Throughout these estimates investment costs have been annualised using a 4% discount rate. The 
assumption is that measurement equipment will have a lifetime of 10 years. 
111 Protocol on a European Monitoring and Evaluation Programme under the Convention on Long Range 
Transboundary Air Poll ution (www.u nece.org) 
112 Directive 2004/107/EC OJ L23, 26.1.2005, p. 3 relating to arsenic, cadmium, mercury, nickel and 
polycyclic aromatic hydrocarbons in ambient air. 
113 Proposal for a Directive of the European Parliament and of the Council establishing an infrastructure for 
spatial information in the Community (INSPIR E) COM(2004) 516 final, SEC (2004) 980. 
 
EN 106   EN quality assessment - required  to be performed throughout th e territory of the Member 
State - will be made available in the ge o-referenced format. This would enable 
efficient GIS tools to be used for further assessments at European scale, and for enhanced public information. This shared information system is expected to reduce the administrative burden upon the Member St ates in terms of reducing the numbers 
of reports that have to be prepared a nd transmitted to the Commission. Only data 
needs to be made available, simplifying th e tasks of Member States while providing 
information to citizens faster. 
7.2. Health advice 
Exposure to particulate matter in ambient ai r is associated with various impacts on 
health.  
– Increase in lower respiratory symptoms 
– Reduction in lung function in children 
– Increase in chronic obstr uctive pulmonary disease 
– Reduction in lung function in adults 
– Reduction in life expectancy, owing main ly to cardiopulmonary mortality and 
probably to lung cancer 
As previously described, particles can be classified accordi ng to their aerodynamic 
diameter so that, for example, PM
10 and PM 2.5 refer to all particles with a diameter 
less than 10 microns (µm) and 2.5 microns respectively. Fine part iculates are those 
of less than PM 2.5 while coarse particulat es are those in the PM 10-2.5 fraction. Current 
Community legislation (Directive 1999/30/EC ) has established daily and annual limit 
values for PM 10 which came into force on 1 January 2005. The daily limit value is set 
at 50µg/m3 as a 24-hour average not to be excee ded more than 35 times per calendar 
year. Annual average concentrat ions shall not exceed 40µg/m3. Directive 
1999/30/EC also contains indicative limit values for PM 10 to be attained by 1 January 
2010. However, these values would need to be  confirmed by the Institutions before 
becoming legally binding. 
In the Summary of its Systematic Review of Health Aspects of Air Pollution in 
Europe, the WHO commented that114  
“Many studies have found that fine particle s have serious effects on health, such as 
increases in mortality rate s and in emergency hospital admissions for cardiovascular 
and respiratory reasons. Thus there is good reason to reduce exposure to such particles. Coarse particles seem to have effects on, for example,  hospital admissions 
for respiratory illness, but their effect on mortality is less clear. Nevertheless, there 
is sufficient concern to consider reducing exposure to coarse particles as well as to 
fine particles. Up to now, coarse and fi ne particles have be en evaluated and 
regulated together, as the focus has been on PM
10. However, the two types have 
different sources and may have different eff ects, and tend to be poorly correlated in 
                                                 
114 Systematic Review of Health Aspects of Air Pollution  in Europe ,  WHO Regional Office for Europe, 
June 2004, www.euro.who.int   
 
EN 107   EN the air. The systematic revi ew therefore recommended that consideration be given to 
assessing and controlling c oarse as well as fine PM ”. 
The Commission services consulted the Scientific Committee on Health and 
Environmental Risks ( SCHER ) on some specific questions related to air pollution 
that had not been addressed in the WHO pr oject "Systematic review of air pollution 
health aspects in Europe". On 18 Marc h 2005, SCHER adopted its response (see 
Box). The SCHER specifically stated that  there is increasing epidemiological 
evidence that exposure to PM 2.5 may be associated with adverse health effects 
especially in susceptible  populations and vulnerable groups. The SCHER also 
pointed to the fact that at present there is no European study on the exposure-response function for long-term PM
2.5 effects, so setting a PM 2.5 standard could be 
surrounded with uncertainties. However,  SCHER acknowledges the evidence of 
PM 2,5 as health relevant. It further implied th at health impact assessments should be 
based on the best available exposure response function, i.e. derived from U.S. studies 
to take account of uncertainties.  
The Working Group on PM was established as an integral part of the CAFE 
programme and endorsed by the CAFE Steer ing Group to assi st the European 
Commission in reviewing Directive 1999/30/EC. The Working Group included 
experts from Member States, industry, NGOs, CLRTAP, the World Health Organization and the European Environmen t Agency. In the light of WHO health-
related findings, the PM Working Group recommended
115 the use of PM 2.5 rather 
than PM 10 as the principal metric for assessin g exposure to particulate matter. The 
Group further recommended that a PM 2.5 limit should replace the existing PM 10 limit 
values and that the PM 10 indicative limit values should be reclassified as target 
values to help control the coarse fraction, PM 2.5-10. 
                                                 
115 http://europa.eu.int/comm/environment/air/cafe/pdf/working_groups/2nd_position_paper_pm.pdf   
 
EN 108   EN  
Opinion of the Scientific Committee on Health and Environmental Risks 
This opinion is publicly available at the following web site: 
http://europa.eu.int/comm/h ealth/ph_risk/committees/ 04_scher_opinions_en.htm 
"The SCHER agrees, that there is increasing epidemiological evidence that acute PM 2.5 exposure is related to 
adverse health effects, especially in susceptible and vulnerable groups. However, ther e is currently a lack of 
knowledge on the exposure-response function for health effects in Europe following chronic exposure. Thus the 
establishment of an air quality standard based upon PM 2.5 will be surrounded with uncertainties. The major 
sources of PM 2.5 and thus the toxicity are different between the USA and Europe, and even within Europe due to 
different type and level of economic activities. These d ifferences may influence the exposure-response function 
used for HIA.  
The SCHER acknowledges the evidence for PM 2.5 as health-relevant. The importan ce of separate guidelines for 
coarse and fine particles are evident and presently ther e is not sufficient health effects-related evidence 
available to exclude PM 10 as a standard and to favour PM 2.5 mass based standard as the sole health-relevant 
indicator. Similar to the US EPA recommendation,  SCHER proposes to continue monitoring both PM 2.5, and the 
PM 10-PM 2.5 fraction, as the relative importance of these two fractions has not been fully resolved. The sources 
and chemical composition of coarse and fine particles differ and thus the toxicity of the particles. Furthermore, 
the ratio between the two types of particles differs greatly with the season and geographic regions.  
The SCHER recommends that, in the absence of a robust European E-R function, the E-R function based upon 
the US data could in general be used for HIA. However, there are uncertainties in applying non-European 
exposure-response functions to European populations, e.g., differences in monitoring protocols and PM sources. 
Differences in the sources of PM may have consequences for the toxicity and therefore for the exposure – 
response function. 
The SCHER acknowledges the large difference in toxicity of particles depending on their size and chemical 
composition. This toxicity will furthermore depend on th e source of the particles, and will furthermore show both 
seasonal and geographical variations. A systematic approach to study the toxicity as a function of these 
variables is warranted. Integration of toxicological information into epidemiological studies will facilitate the 
establishment of more accurate  exposure-response function. 
The SCHER is aware of the emerging evidence of variation in susceptibility, acquired or genetic, to ambient 
PM 2.5. This variation should be considered when establishing the air quality guidance values in order to protect 
the most susceptible and vulnerable groups.  
A critical level for ozone to protect the vegetation in Europe has been established within the convention on 
LRTAP. New experimental studies suggest that a new AOT40 value should be introduced to protect forests from 
harmful effects due to ozone." 
 
EN 109   EN 7.3. Reducing exposure to PM 2.5   
 The overwhelming evidence that the Comm ission has received can be summarised 
as follows: (i) there is a health risk from PM 2.5, (ii) PM 2.5 is a better metric to 
represent the general health risks of ambient levels of particulate matter, and (iii) the 
risk from the coarse fraction (between PM 2.5 and PM 10) cannot be ignored. Given 
this, the Commission has considered the fo llowing options for revising the existing 
provisions of Directive 1999/30/EC in relati on to particulate matte r in ambient air. 
Each option assumes that the existing limit values for PM 10 remain in force.  
(1) Introduce a legally binding require ment to reduce annual average 
concentrations of PM 2.5 throughout the territories of  the Member States by a 
given percentage in 2020 relative to the position in 2010 as determined by three years of monitoring of PM
2.5 concentrations in urban background 
locations; 
(2) Introduce a target to reduce annua l average concentrations of PM 2.5 
throughout the territories of  the Member States by a given percentage in 2020 
relative to the position in 2010 as determ ined by three years of monitoring of 
PM 2.5 concentrations in urban background locations; 
(3) Replace the indicative limit values for PM 10 for the year 2010 by a legally 
binding limit value for annual av erage concentrations of PM 2.5 to be attained 
by 2010. Such a limit value would be designed to offer a high degree of 
protection  to the population and would apply everywhere in the territory of 
the Member States; 
(4) Replace the indicative limit values for PM 10 for the year 2010 by a legally 
binding “cap” for annual average concentrations of PM 2.5 to be attained by 
2010. Such a “cap” or ceiling would be designed to limit unduly high risks  to 
the population and would apply everywhere  in the territory of the Member 
States; 
(5) Replace the indicative limit values for PM 10 for the year 2010 by a non- 
binding target for th e annual average concentrations of PM 2.5 to be attained as 
far as possible by 2010. Such a target valu e would be numerica lly identical to 
the limit value in option (2) above;  
(6) Do nothing, i.e. do not introduce any requirement to reduce human exposure 
to PM 2.5. 
Given the overwhelming health evid ence and risks from exposure to PM 2.5, option 
(6) of doing nothing is not a viable option. Th is would also be inconsistent with the 
Community policy on the environment, wh ich urges a precautionary approach. 
Integrated assessment modelling has shown that options (1) a nd (2) are the most 
cost-effective ways of reducing exposure to PM 2.5 and also provide the highest net 
benefits. This has been shown for both th e “European-wide” optimisation of health 
impacts and optimisations using a “gap-closure” approach in each individual grid-cell of the European modelling domain. The difference between (1) and (2) is in the 
legal characteristic of the requiremen t to reduce th e average urban background 
 
EN 110   EN concentration. While in (1) the requirement would be le gally binding in (2) it would 
be attained where possible. 
Options (1) and (2) is demonstrably more cost-effective than option (3). This is 
because a stringent limit value has its greatest impact in locations where 
concentrations are highest. However, thes e are not necessarily places where most 
people are exposed to PM 2.5. Due to the nature of the risk posed by PM 2.5 (i.e. no 
threshold for effects) it is more cost-eff ective to reduce concentrations where most 
people are exposed. This approach would maximise health benefits for given 
abatement expenditure. In addition, the uncertainties identified by the SCHER 
associated with setting a stringent air qua lity limit value would argue against using 
this approach at this stage. 
One of the underlying principles of current  Community policy on ambient air quality 
is that of equity and guaranteeing a mini mum standard of air quality for all EU 
citizens. One way to achieve this is to im plement either option (3 ), (4) or (5). The 
main difference between option (3) and (4) wo uld be in the severity of the chosen 
level. In option (4) the cap would preven t only unduly high risk s for the population. 
Such a cap would be set at a relative ly high level to reflect the underlying 
uncertainties in the use of US risk estimates  and to ensure that attainment remained 
technically feasible. It would not be intende d to provide high levels  of protection that 
are associated with the traditional limit va lue concept embodied in current ambient 
air quality legislation. Give n that the cap is meant to limit unduly high risks to the 
population, it is appropriate that such a cap apply everywhere in the territory of the 
Member States. Option (5) would be non- binding, would not necessarily oblige the 
Member States to take the appropriate m easures to reduce levels and so would not 
guarantee minimum standards of air quality in practice.  
The Commission considered whether there would be enough data to determine a 
legally binding reduction requirement. On bala nce, it considered it prudent to opt for 
a target value and establish in 2008-2010 the PM 2.5 concentrations in urban 
background stations. Based on these measurem ents, plus improved modelling data up 
to 2020, the Commission will propose the legally binding obligation to reduce average urban background concentrations. 
Based on the above considerations, the Commission proposes a combination of 
options (2) and (4) i.e. a relative reducti on in annual average c oncentrations to be 
attained by 2020 relative to 2010 and a general cap for PM
2.5 annual average 
concentrations to be attained in 2010. The current limit values for PM 10 will remain 
unchanged whereas the Stage II indicative limit values for 2010 w ill not be given 
legal force.  
7.3.1.  Reducing average urban background concentration of PM 2.5  
The Commission proposes that Member States  have first a concentration reduction 
target, which would be later converted to a legal obligation – based on a review of 
the Directive on Ambiant Air Quality and Cl eaner Air for Europe –  to reduce the 
average urban PM 2.5 background level. The Commi ssion proposes to set this 
requirement so as to be consistent within  the range set betwee n Scenarios A and B. 
 
EN 111   EN The Commission has analysed the projec ted urban background concentration of 
PM 2.5 in about 150 European cities. Table 27 shows the projected reductions in PM 2.5 
concentrations between 2010 and 2020 in th e baseline and Scenarios A and B.  
Table 27: Illustrative calculation of the reduction of annual average urban 
background concentration of PM 2.5 in Member States in 2020 compared with 
the PM 2.5 concentrations in 2010*)  
Member State Baseline Scenario A Scenario B 
Austria 6% 17% 20% 
Belgium 7% 18% 20% 
Cyprus**) .. .. .. Czech Republic 10% 27% 30% Denmark 4% 15% 19% 
Estonia 7% 13% 15% 
Finland 5% 8% 10% France 7% 19% 22% Germany 5% 21% 25% Greece***) 5% 9% 10% 
Hungary 8% 27% 30% 
Ireland 8% 20% 23% Italy 11% 20% 23% Latvia 4% 11% 12% Lithuania 6% 15% 17% Luxembourg**) .. .. .. 
Malta**) .. .. .. 
Netherlands 4% 21% 25% Poland 14% 29% 30% Portugal 2% 8% 15% Slovakia 7% 24% 26% 
Slovenia 6% 18% 21% 
Spain 5% 13% 15% Sweden 5% 12% 14% United Kingdom 7% 24% 27% 
EU-25 average  7% 19% 22% 
Note: The index has been calculated assuming all Member States comply with the NECD in 2010. EU-
25 average is an arithmetic (unweighted) average.  
*) Reduced concentrations due to the Directive to reduce sulphur content in marine fuels has not been 
include. Thus, underestimates to some extent. **) No data available 
***) Large transboundary transport from Acced ing Countries explains mainly why the reduction 
percentage is relatively small. 
Source: Calculations for the Commission by RAINS  
 
In Scenario B the unweighted average c oncentration reduction would be 22% (the 
population weithted average is somewhat hi gher, i.e. 25%) while  the reduction in 
Scenario A is a couple of percentage points lo wer. It can be seen that it would not be 
cost-effective or equitable to propose that all cities in Me mber States be required to 
reduce their concentrations by the same  percentage. However, due to data 
uncertainties, the Commission considers it prudent to wait first for good monitoring 
data for 2008-2010 before establishing the exact reduction requirement. Therefore, 
 
EN 112   EN the Commission proposes first to have only a concentration reduction target of 20% 
for each Member State between 2010 and 2020.  
It should be noted that Table 27 us es modelled concentrations of PM 2.5. Current 
modelling capabilities are restricted whic h means that certai n contributions to 
observed concentrations cannot be predicted. These include, for example, the contribution derived from the reactions of organic compounds in the atmosphere and 
natural contributions from windblown dust,  sand and sea spray are not included in 
the model. As such, an amount of approximately 5µg/m
3 must be added to the 
modelled results to reflect these additiona l contributions and the likely increased 
concentrations in urban hotspots.  
The RAINS model demonstrated a clear rela tionship between the expected reduction 
in average PM 2.5 concentrations in urban area s between 2010 and 2020 compared 
with the estimated concentration in each city in 2010. Although there was significant 
scatter in the data, a clear trend can be s een which showed that the more polluted the 
city in 2010 the greater will be the expected reduction in PM 2.5 concentrations during 
the 2010-2020 period. Table 28 shows the percentage reductions in average 
concentrations of PM 2.5 between 2010 to 2020 for differe nt levels of ambition for the 
protection of health. This varies from 1.0% to 2.1% per 1µg/m3 of PM 2.5 expected in 
2010 for the baseline and the MTFR scenarios respectively. 
Table 28: Slopes of the relationship  between modelled concentrations in 
European cities in 2010 and the percent age reduction in these concentrations 
between  2010 and 2020 
 Baseline 
2020 Scenario 
A Scenario 
B Scenario 
C MTFR 
Percentage reduction between 
2010 and 2020 per 1µg/m3 of 
PM 2.5 expected in 2010 1.0% 1.6% 1.8% 1.9% 2.1% 
Source: Calculations for the Commission by RAINS.  
The percentage reductions in Table 28 ar e based upon modelling results for a limited 
set of cities and are necessarily subject to uncertainties. These can be mitigated in several ways when developing a proposal fo r legislation. Firstly, any obligation for 
Member States to reduce PM
2.5 concentrations should a pply to concentrations 
measured in urban areas averaged over real measurements undertaken in cities 
throughout their territory. He nce the national average c oncentration measured in 
2010 will not be unduly influenced by elevated concentrations in particular cities. 
Secondly, Member States will have flexibi lity to reduce concentrations where it is 
most cost effective as there would be no strict requirement to reduce by the same 
amount in each and every city. Thirdly, one could cap the maximum reduction that 
any particular Member State will have to undertake. Finally, one can recognise that 
where air quality is already good it is unfai r to require further improvements. These 
principles need to be as embodied in the relationship to be used to determine each 
Member State’s concentration reduction target for urban PM 2.5 concentrations.  
 
 
EN 113   EN Specifically, the Commission proposes that  the following elements comprise the 
approach: 
1. Each Member State will be obliged to reduce the average urban background 
concentration of PM 2.5 in their territory by a specific percentage between 
2010 and 2020 measured in the baseline c oncentration to be established for 
2010.  
2. This requirement would not be applied for very low concentrations. A lower 
threshold is proposed to be at 7 µg/m3. Below this there is no obligation to 
reduce average levels further. This would prevent “cleaning of clean air”; 
3. It could be possible to introduce also an upper threshold above which there is 
no further increase in th e percentage reduction. 
Therefore, the Commission proposes a two-stage approach to establish the 
requirement to reduce annual average urban background concentration of 
PM 2.5 between 2010 and 2020. Firstly, each Member State would have a 
concentration reduction target of 20% for PM 2.5 between 2010 and 2020. 
Secondly, once the monitoring data of PM 2.5 for 2008-2010 are available, the 
concentration reduction target would be differentiated by Member State and 
made legally binding for the period between 2010 and 2020. 
7.3.2.  Establishing a concentration cap for PM 2.5 
 In order to establish a concentration cap the Commission used the following 
methodology: Based upon existing measuremen ts, one can extrapolate or estimate 
the concentration of PM 2.5 for a given level of PM 10. Given that the air quality limit 
value for PM 10 entered into force on 1 January  2005 the Commission proposes to set 
the cap at a level that is no more stringe nt that the equivalent limit value for PM 10. 
The current air quality limit value for PM 10 is 40 µg/m3 as an annual average. This 
would be equivalent to between 24 and 28 µg/m3 for PM 2.5. The current daily (24-
hour) air quality limit value for PM 10 is 50 µg/m3 and it cannot be exceeded by more 
than 35 days. It is estimated that this is a slightly more stringent requirement than the 
annual limit value, i.e. below 24 to 28 µg/m3 for PM 2.5.  
In sum, given the current limit values for PM 10 and the view that the cap for PM 2.5 
should not itself set a more stringen t requirement to Member States, the 
Commission proposes that the concentration cap for PM 2.5 in 2010 be 25 µg/m3 
expressed as annual average.   
7.4. Costs and benefits of the proposal for regulating PM 2.5 
To calculate the costs of this strategic ap proach requires a subset of the costs of 
Scenarios A and B of the Strategy. It is further assumed that by 2010 all Member States will comply with the annual air quality limit values for PM
10. As the PM 2.5 cap 
for 2010 has been set at a level equivalent to the current PM 10 annul limit value, this 
implies that the PM 2.5 limit value will also be attained with no additional costs. If for 
some reason a Member State is not able to comply with the limit value, but has made 
every effort to do so, the proposed “safet y valve” (i.e. Article 20 of the proposed 
 
EN 114   EN “Directive for Ambient Air Quality and Clean er Air for Europe”) would mean, that 
for the purposes of compliance costs in 2015 or 2020, no additional cost is estimated.  
Given the assumptions outlined above, Ta ble 29 shows the annual compliance costs 
for PM 2.5 in 2020. The annual costs of the proposed new approach to regulate PM 2.5 
are estimated to be €2.6 billion lower in  2020 than the total compliance costs of 
Scenario B of the Strategy (s ee Table 11 in Chapter 5).  
Table 29: Illustrative calculation of compliance costs to reduce the average 
urban background concentration of PM 2.5 by an average of 25% (Scenario B) or 
20% (Scenario A) in the EU-25 between 2010 and 2020 (million euros)  
 Cost of 
Scenario B 
with PM 2.5 
only Cost of 
Scenario A 
with PM 2.5 
only Incremental 
cost from 
Scenario A to 
B 
Austria 144.3 66.5 77.8
Belgium 460.6 178 282.6
Cyprus 3.4 3.4 0.0
Czech Republic 169.6 104.4 65.2
Denmark 69.5 28.5 41.0
Estonia 8.8 7.2 1.6
Finland 28.1 22.9 5.2
France 1588.7 874.4 714.3
Germany 1821.5 986.3 835.2
Greece 49.3 42.5 6.8
Hungary 179.5 118.1 61.4
Ireland 44.6 37.5 7.1
Italy 772.8 534.1 238.7
Latvia 11.5 10.3 1.2
Lithuania 39.4 18.1 21.3
Luxembourg 21.5 16.7 4.8
Malta 1.5 1.3 0.2
Netherlands 417.6 200.9 216.7
Poland 603.5 560.8 42.7
Portugal 164.5 136.9 27.6
Slovakia 74.6 51.1 23.5
Slovenia 35.8 25 10.8
Spain 506.5 351.1 155.4
Sweden 87.8 25.7 62.1
UK 774.7 572.7 202.0
EU-25 8079.6 4974.4 3105.2
Source: RAINS 
Cost of Scenario A with PM 2.5 only would be almost €1 b illion or almost 20% lower 
than implementing Scenario A with all m easures. The compliance cost of reaching 
this reduction requirement is likely to be between €5 and €8 billion per annum.  
Table 30 gives the benefits of the reduction of PM 2.5 concentration in Member States 
assuming the reductions in concentrations to be compatible with Scenario B. Table 31 gives the cost/benefit ratios of Tables  29 and 30. Overall the health benefits of 
reaching the average concentration reduction by 25% in the EU are five times higher than costs when the lowest benefits are us ed as the basis for estimation. If the highest 
 
EN 115   EN values were used the benefits would outwei gh the costs 17 times. It is also important 
to see whether moving form Scenario A to Scenario B would bring additional benefits. This is also the case as the benef its of this are still at least 2.5 times higher 
than costs. However, in two Member States
116 in this incremental analysis the 
benefits are projected to be slightly lower than costs. However, overall, the benefits 
are still more than two times higher than costs for these Member States.  
Table 30: Illustrative calculation of be nefits from increased life expectancy and 
health of the reduced average urba n background concentrations of PM 2.5 by an 
average of 25% in the EU-25 between 2010 and 2020 (based on Scenario B) 
 VOLY (median) VSL (media n) VOLY (mean) VSL (mean) 
 Benefits Incremental 
benefits Benefits Incremental 
benefits Benefits Incremental 
benefits Benefits Incremental 
benefits 
Austria 730 145 1237 246 1366 272 2313 460 
Belgium 1525 281 2581 475 2871 529 4843 892 
Cyprus*) 6 1 8 2 11 2 15 3 
Czech Rep. 1227 188 2185 336 2292 352 4105 630 
Denmark 370 87 672 157 699 163 1269 297 
Estonia 31 6 60 11 57 11 114 21 
Finland 50 12 86 21 94 23 162 40 
France 6435 1361 10288 2176 12148 2570 19219 4065 
Germany 10719 2097 19703 3854 20166 3944 37232 7283 
Greece 311 44 611 87 583 83 1158 165 
Hungary 1452 163 2867 321 2711 304 5435 609 
Ireland 213 43 300 61 400 81 551 112 
Italy 4738 816 9393 1619 8889 1532 17844 3075 
Latvia 108 18 155 27 200 34 285 49 
Lithuania 112 15 278 37 209 28 536 71 
Luxembourg 84 17 112 23 158 32 203 42 
Malta 13 2 21 3 24 4 39 6 
Netherlands 2714 525 4401 851 5114 989 8225 1591 
Poland 4039 325 6816 548 7519 605 12710 1022 
Portugal 484 229 885 419 906 429 1669 789 
Slovakia 699 77 1154 127 1301 143 2147 236 
Slovenia 198 39 358 70 369 72 673 132 
Spain 1739 424 3099 756 3247 792 5818 1419 
Sweden 247 56 421 96 465 106 791 180 
UK 6442 1071 9894 1646 12099 2012 18355 3053 
EU-25 44685 8044 77586 13968 83902 15113 145712 26242 
Source: CAFE Cost-Benefit Analysis. Note: Incremental benefit means the bene fits that accrue when changing from 
Scenario A to B. VOLY/VSL median and mean are explained in Chapter 2 
*) The negligible incremental cost data for Cyprus is probably inaccurate because of modelling uncertainties 
 
                                                 
116 These were Lithuania and Sweden. 
 
EN 116   EN  
Table 31: Illustrative calculation of co st/benefit ratios from increased life 
expectancy and health of the reduced average urban background concentration 
of PM 2.5 by an average of 25% in the EU-25 between 2010 and 2020. 
 VOLY (median) VSL (media n) VOLY (mean) VSL (mean) 
 Benefits Incremental 
benefits Benefits Incremental 
benefits Benefits Incremental 
benefits Benefits Incremental 
benefits 
 Costs Incremental 
costs Costs Incremental 
costs Costs Incremental 
costs Costs Incremental 
costs 
Austria 5.1 1.9 8.6 3.2 9.5 3.5 16.0 5.9 
Belgium 3.3 1.0 5.6 1.7 6.2 1.9 10.5 3.2 
Cyprus 1.7 n.a. 2.3 n.a. 3.2 n.a. 4.4 n.a. 
Czech Rep. 7.2 2.9 12. 9 5.2 13.5 5.4 24.2 9.7 
Denmark 5.3 2.1 9.7 3.8 10.1 4.0 18.3 7.2 
Estonia 3.5 3.7 6.9 6.7 6.5 6.7 13.0 12.8 
Finland 1.8 2.3 3.1 4.0 3.3 4.4 5.8 7.7 
France 4.1 1.9 6.5 3.0 7.6 3.6 12.1 5.7 
Germany 5.9 2.5 10.8 4.6 11.1 4.7 20.4 8.7 
Greece 6.3 6.5 12.4 12.8 11.8 12.2 23.5 24.3 
Hungary 8.1 2.7 16.0 5.2 15.1 4.9 30.3 9.9 
Ireland 4.8 6.1 6.7 8. 6 9.0 11.5 12.4 15.8 
Italy 6.1 3.4 12.2 6. 8 11.5 6.4 23.1 12.9 
Latvia 9.4 15.1 13.4 22.7 17.3 28.6 24.7 41.2 
Lithuania 2.8 0.7 7.1 1.7 5.3 1.3 13.6 3.3 
Luxembourg 3.9 3.6 5.2 4.8 7.3 6.7 9.4 8.8 
Malta 8.7 10.5 14.1 15. 8 16.1 21.1 26.2 31.6 
Netherlands 6.5 2.4 10. 5 3.9 12.2 4.6 19.7 7.3 
Poland 6.7 7.6 11.3 12. 8 12.5 14.2 21.1 23.9 
Portugal 2.9 8.3 5.4 15.2 5.5 15.6 10.1 28.6 
Slovakia 9.4 3.3 15.5 5.4 17.4 6.1 28.8 10.0 
Slovenia 5.5 3.6 10.0 6.5 10.3 6.7 18.8 12.3 
Spain 3.4 2.7 6.1 4. 9 6.4 5.1 11.5 9.1 
Sweden 2.8 0.9 4.8 1.5 5.3 1.7 9.0 2.9 
UK 8.3 5.3 12.8 8.1 15.6 10.0 23.7 15.1 
EU-25 5.5 2.6 9.6 4. 5 10.4 4.9 18.0 8.5 
Source: CAFE Cost-Benefit Analysis  Note: Incremental benefit means the benefits that accrue when 
changing from Scenario A to B. VOLY/VSL median and mean are explained in chapter 2. 
The social and other economic implicati ons of the proposed cap and reduction in 
urban background concentration of PM 2.5 are very similar to those presented in 
Chapter 5. As the annual compliance cost for PM 2.5 is €2.6 billion (i.e. about 25%) 
less than the total complianc e cost of the Strategy, the general equilibrium effects 
were modelled117 only for PM 2.5 (Table 32). 
                                                 
117 Analysis of macroeconomic and competitiveness ef fects with GEM-E3 of CAFE Scenarios (AEAT, 
August, 2005) 
 
EN 117   EN Table 32: Illustrative calculation of macroeconomic impacts of Scenarios A and 
B – PM 2.5 only compared to baseline in 2020 
Macroeconomic Aggregates 
EU-25  Scenario A for 
PM 2.5 Scenario B for 
PM 2.5 
Gross Domestic Product -0.03% -0.06% 
Employment 0.00% 0.00% 
Private Consumption -0.06% -0.11% Investment -0.01% -0.01% Final Energy Consumption -0.11% -0.17% Exports to RW 0.00% 0.02% 
Imports 0.04% 0.09% 
Real Wage Rate -0.04% -0.08% Relative Consumer Price 0.00% 0.01% Real Interest Rate 0.01% 0.02% Terms of Trade 0.03% 0.05% 
Source: GEM-E3 
In summary, the Commission proposes a cap of  25 micrograms per cubic metre to be 
attained by 2010, and proposes that a concentrati on reduction target of 20% between 
2010 and 2020, which would be converted – based on a review of the Directive on Ambiant Air Quality and Cleaner Air for Europe –  to a legally binding reduction requirement once the monitoring data are ava ilable. The benefits of the proposal are 
estimated to be between €37 billion and €145 billion per annum in 2020. These are 
between 6 and 18 times higher than the estimated costs ranging between €5 and €8 billion per annum. (Table 33). 
Table 33: Illustrative summary of the annual costs and benefits from increased 
life expectancy and health of the reduced average urban background concentration of PM
2.5 by 20% (Scenario A) of PM 2.5 and by 25% (Scenario B) 
in the EU-25 between 2010 and 2020 (billions of euros) 
Total costs and benefits 
  Scenario A Scenario BIncremental costs 
and benefits from 
Scenario A to B 
Cost (€bn) 5.0 8.1 3.1 
Benefits (€bn)    
 VOLY (median) 36.7 44.7 8.0 
 VSL (median) 63.6 77.6 14.0 
 VOLY (mean) 68.8 83.9 15.1 
 VSL (mean) 119.5 145.7 26.2 
Benefit/Cost ratio    
 VOLY (median) 6.3 5.5 2.6 
 VSL (median) 11.7 9.6 4.5 
 VOLY (mean) 12.8 10.4 4.9 
 VSL (mean) 22.9 18.0 8.5 
This conclusion is further strengthened by the fact that the incremental benefits 
between Scenarios A and B are between 3 an d 9 times higher than the incremental 
costs. In other words, the impact of the proposed manner to regulate PM 2.5 on human 
health is clearly beneficial.  
 
EN 118   EN 8. MONITORING AND EVALUATION  
8.1. Evaluation and review of policies  
Given the expected advances in our understanding of the adverse health and 
environmental impacts likely in the future, it is appropriate that the targets and policies described in this strategy be reviewed on an ongoing basis. Such reviews 
should also take account of advances in our knowledge of pollution abatement costs 
and assess retrospectively the effectiveness of existing measures. This Strategy will be reviewed in  five year policy cycles a nd will feed into the final evaluation of the 
EAP. Ongoing assessment of policies will al so continue on the basis of existing 
indicators and reported info rmation. In the coming years, however, more work will 
be required to inform such a review. 
The EEA and Eurostat have developed i ndicators to monitor the impacts of air 
emissions on human health and the envi ronment. Long-term monitoring of 
environmental effects of air pollution will  be undertaken in a ssociation with the 
UNECE Convention on Long-range Trans boundary Air Pollution. Activities under 
CAFE will link with the established structur es of the effects-oriented activities under 
the Convention in order to  assist and support coope ration in monitoring and 
assessment activities. Monitoring, mode lling, assessment and mapping will follow 
agreed methodologies and focus on status and trends in: forests, including soils and 
ground vegetation; (semi-)natural ecosystems and protected areas;
118 agricultural 
receptors; aquatic ecosystems including coastal and marine waters;119 materials 
including cultural heritage. Eutrophication, ac idification and ozone effects and their 
trends will be monitored; related biodive rsity and effects of climate change will 
receive specific attention. The results of m onitoring together with  detailed reports on 
emissions and air quality from the Member States will provide the basis for assessing 
the effectiveness of Community and Member States´ policies.  
To carry out the review effectively, the Commission needs to ensure that the 
scientific and economic knowledge is system atically collected, updated and analysed 
by the modelling tools that have been de veloped during the CAFE programme. Thus, 
it will make specific call for proposals in the Preparatory Action of the LIFE programme for this task. 
8.2.  Consultative arrangements 
Following adoption of the Strategy, the ne xt major task will be revision of the 
National Emissions Ceilings Directive and the ongoing implementation of air quality 
legislation. The institutional framework will need to be adapted accordingly. 
The CAFE Steering Group, or a similar group, w ill continue to be the main forum for 
future stakeholder participation and c onsultation. In addition, a Working Group on 
“National Emission Ceilings and Policy In struments” was created in May 2005 to 
help out with the technical  work on revising the National Emissions Ceilings 
                                                
 
118 Protected areas are not currently se parately assessed under the Convention 
119 Coastal and marine waters are not currently monitored under the Convention 
 
EN 119   EN Directive. AQUILA120 network of national referen ce laboratories, hosted by JRC, 
already now monitors implementation of the air quality directives with regard to 
quality of assessments of am bient air quality and assists the Commission in efforts of 
further harmonisation and better comparability  of data between the Member States. 
Greater use is also likely to be made of the Regulatory Co mmittee on air pollution 
particularly for monitoring and reporting on implementation of existing legislation. 
Data Exchange Group has been created in  2004, consisting of air quality data 
handling experts from the Member States a nd the EEA, which will assist in drafting 
of the Implementing provisions on reporti ng to be adopted through Comitology. The 
committee will also be used to coordinate Community views on technical issues, which may arise in international fora. 
8.3. Research needs including financial implications  
Community air pollution policy is built on robust scientific and technical knowledge 
and the first review of policies about fi ve years will require new scientific and 
technological information on:  
– Emission sources, atmospheric chem istry and pollutant dispersion,
 particularly 
on the hemispheric scale, and a bette r understanding of th e origin of air 
pollutants to support policy development 
– The effects of air pollution on hea lth and the environment  including the risks of 
nutrient nitrogen and the recovery of ecosystems  
– The costs, effectiveness and benef its of measures actually deployed. 
In addition, the structural and societal changes occurring in Europe after the 
accession of new Member States will need to be addressed, including changes in 
trade and industry and the enlarg ed trans-European networks. 
8.3.1.  Emission sources, atmospheric ch emistry and pollutant dispersion  
The emissions of air pollutants depend on bot h the activities in the different sectors 
of society and the emission control technologies applied.  Emissions may change over 
time, particularly as a result of global cha nges in trade and industry. To some extent 
these changes are covered by the present an alysis and policy development, but there 
is a need to improve understa nding. Research n eeds should be gear ed towards better 
integration of multi-scale processes from th e global scale to the local scale. Such 
integrated approaches should be  included into the framework of risk analysis and risk 
management, and capable of addressing cha nges in important sectors like transport, 
trade, energy and agriculture. Methods to account for emerging technologies also 
need to be developed. 
Looking at global scale, it needs to be r ecognised that air pollution is emitted in 
different parts of the world. As an example, a global atmospheric map of nitrogen dioxide pollution has been produced by the European European Space Agency (ESA), based on the recent observations of Envisat, the world's largest satellite for 
                                                
 
120 http://ies.jrc.cec.eu.int/Units/eh/Projects/Aquila/  
 
EN 120   EN environmental monitoring (Figure 25). It s hows there are three main sources of NO 2 
emissions in the Northern hemisphere: Eur ope, Northern America and Eastern Asia.  
Figure 25: Global atmospheric map of nitrogen dioxide pollution, 2003-2004 
 
Source: ESA (http://www.esa.int/e saEO/SEM340NKPZD_index_0.html ) 
There is an urgent need to  better understand how the changing patte rns of emissions 
over the Northern hemisphere impact on air pollution over Eu rope through the 
transcontinental transport of air pollutants such as particulate matter, ozone, persistent organic pollutants, and merc ury. The UNECE has recently set up a Task 
Force on hemispheric transport of air pollu tion, jointly chaire d by the Commission 
and the US EPA. One objective of the Task  Force is to assess scientific knowledge 
on the hemispheric transport of particul ate matter of natural and anthropogenic 
origin, and the chemical and physical characteristics of these emissions.  
Long-term monitoring of envir onmental effects of air pollution will be undertaken in 
association with the UNECE Conven tion on Long-range Transboundary Air 
Pollution. Activities will link to  the established st ructures of the effects-oriented 
activities under the Convention in orde r to assist and support cooperation in 
monitoring and assessment activities . Monitoring, modelling, assessment and 
mapping will follow agreed methodologies and focus on status and trends in: forests 
including soils and ground vegetation; (s emi-)natural ecosystems and protected 
areas
121; agricultural receptors; aquatic eco systems including coastal and marine 
waters122; materials including cultural herita ge. Eutrophication, acidification and 
ozone effects and their trends will be monitored; related biodiversity and effects of climate change will receive specific atte ntion. The results of monitoring together 
with detailed reports on emissions and air quality from the Member States will 
provide the basis for assessing the effectiv eness of Community and Member States´ 
policies. The monitoring activities and the rela ted scientific work will continue to be 
reviewed regularly. 
 
 
                                                
 
121 Protected areas are not currently se parately assessed under the Convention 
122 Coastal and marine waters are not currently monitored under the Convention 
 
EN 121   EN Other research priorities include  
– the formation of secondary organic aerosols and how different emission 
sources contribute to the particulate ma ss and appropriate EU-wide monitoring 
(see below)  
– the links between air pollution and climate change, and climate impact on air 
pollution.  
– improved methods for assessing air po llution, at local a nd regional level, 
including the integrated use of monitoring data from the ground and space 
instruments and assessment models.  
8.3.2.  Effects of air pollution on health and the environment  
In order to develop and refine strategies to avoid health impact we need new research 
or updated information on: 
– how the changing sources and composition of  air pollution in Europe impact on 
the human population; health -related studies are need ed on exposure patterns 
and the effects of air pollu tion abatement and policies ( ex post  evaluations). 
– the exposure routes, sensitivity and vulnerability of the population and 
different population groups, which may also change with time.   
– the health effects of long-term exposure to ozone, nitrogen oxides and 
particulate matter (and their different si ze fractions) relevant for present and 
future air pollution. For airborne partic les, we are specif ically concerned by 
fuel-source specific risk. Further research is also needed to understand the specific composition effects of particul ate matter (e.g. secondary organic and 
inorganic aerosols, metals). The resear ch would include bo th air pollution 
epidemiology and toxicology.  
– Specifically it is necessary to start l ong-term studies on the impact of air 
pollution on different European populati on groups including children, and to 
follow these groups (cohort) over a long period of time. This is also very 
closely linked with the Environment a nd Health Strategy of the Commission (a 
joint initiative by DG ENV, DG SANCO and DG RTD).  
– The environmental effects of air pollution are considerable, through 
acidification and eutrophication of waters  and soils and high concentrations of 
ground-level ozone. Priority areas for fu rther research would include improved 
methods to quantify ozone damage to crops and other vegetation and improved 
understanding of the dynamic effects of  ecosystem recovery (including 
biodiversity) from pollution damage. N itrogen in the ecosystems and as a 
pollutant plays a key role in many environmental pro cesses, but better 
understanding is needed to address the ni trogen issue in a more integrated way.  
 
EN 122   EN 8.3.3.  Costs, effectiveness and benefits of measures 
Present pollution policy is a main driver  for further development of abatement 
technologies for those sectors and sources th at contribute such as energy, transport, 
industry and agriculture. This is a con tinued effort for research and technology 
development, but is also cl osely linked with economic asp ects. It is therefore also 
important to give support for the introduction of new t echnologies (demonstration 
programmes) and abatement techniques for be nch and feasibility testing, pilot scale 
and early full-scale introduction. 
– For new vehicles and other mobile sour ces, future on-board diagnostics and 
emissions monitoring equipment would be required to assess and further 
control emissions. As an example, th e ERTRAC network investigates the 
medium term research needs in the transport sector. 
– Other combustion sources also give rise  to high emissions of nitrogen oxides 
and particulate matter and cost-effectiv e technologies are needed to reduce 
these emissions. A major research effort is needed to develop integrated approaches to facilitate the developm ent and implementation of the effective 
emission abatement strategies that exis t in EU Member States. This requires 
extensive knowledge of the origins and interplay of all major pollution sources, 
taking into account the asso ciated costs and benefits and other possible factors 
arising from the adoption of these abatement strategies. 
Risk assessment, risk communication and risk management require comprehensive 
tools for integrated assessment of air pollu tion and policy options and these need to 
be further developed. These tools need  to integrate regi onal and local urban 
problems, and also the influence between  air pollution policy and other sector 
policies. They should include  the use of technical and non-technical measures and 
tools to evaluate various policy instrume nts, including market-based instruments, 
legislation and voluntary agreement.  
Integrated assessment tools should be  further developed for assessing the 
effectiveness of measures, and the positive and negative factors for the different sectors of society. They should also be able  to assess more in depth the effects of 
sustainable development of all three aspe cts (economic, social and environmental). 
Ex ante  evaluations also need to be more systematically compared with ex post 
evaluations of policy effectiv eness, both for the costs of measures and the assessment 
of benefits. 
Risk communication would include the deve lopment of indicator s to be used to 
communicate with non-experts. The indica tors should be easy to understand and 
could be related to long-term and interim objectives. These indicators could be based 
on monitoring of air pollution and its eff ects (environment and health monitoring) 
and complemented by other assessment techniques such as modelling. (One 
important step in this direction is the de velopment of the health-relevant Strategic 
Development Indicator.) Also the developm ent of EU-wide air quality indices could 
be envisaged. 
 
EN 123   EN 8.3.4.  Financial implications 
The research community should take adva ntage of EU RTD f unding opportunities 
and the capabilities of the Joint Research  Centre of the European Commission to 
address these issues with the fu ll support of Member States.  
It is vital to address the gaps in knowle dge on the nature and impacts of particulate 
matter. Additional efforts are therefore required to obtain enhanced chemical, temporal and size-resolved measurement data, not captured by regulatory monitoring 
throughout the EU. Research infrastructure which will provide such data is often 
referred to as ‘ superstations ’. An integrated European-wide research project will, 
through an elaborate assessment, combine the data from ‘ superstations ’ with the data 
from surrounding ‘satellite’ stations (regul ar network stations, enhanced for the 
duration of the contract), additional measurement campaigns, detailed emission inventories and a comprehensive monitoring of the impacts on the human health. The 
Commission estimates that the annualized  investment and running costs of this 
research network of ‘ superstations ’ would be about five tim es higher than the normal 
background monitoring. Thus, th e annualised costs of ‘ superstations ’ are estimated 
at €5 million. An important share of these co sts is due to the investment on research 
infrastructure. This needs w ould be covered by the budget already allocated to this 
purpose in the 7
th Research Framework Programme as proposed by the Commission 
for the financial perspectives 2007-2013. 
 
EN 124   EN 9. STAKEHOLDER AND PUBLIC CONSULTATION  
9.1. Public consultation 
According to Eurobarometer – a survey ba sed on a random sample in each Member 
State – EU citizens have rated air pollu tion as one of the five environmental 
problems of most concern in 2002 and 2004. Overall almost 50% of Europeans are 
“very worried” about air pollution (see Fi gure 26), while there are differences 
between Member States. It is striking th at the share of “ver y worried” about air 
pollution was higher in the new Member  States than in the EU-15 in 2004. 
Figure 26: Percentage of the population “v ery worried” by air pollution in 2002 
and 2004 in EU-25  
0 1 02 03 04 05 06 07 08 0German yAustriaGreeceDenmarkIrelandItalyLuxembourgSpainBelgiumFranceFinlandCyprusCzech RepublicEs toniathe UKthe NetherlandsPolandLatviaSwedenSlovakiaSloveniaPortugalHungaryMaltaLithuaniaNew Member StatesEU15
2004
2002
 
Source: Eurobarometer 
 
EN 125   EN The Commission launched a public consulta tion on air pollution in December 2004 
and January 2005. This consultation shoul d be seen against the background of 
general public concern about air pollution in  Europe. The consultation was held in 
the form of a questionnaire, available on the in ternet to anyone to fill in. In view of 
the setup, the results should not be seen as the opinions of the EU population at large, 
but as a representation of th e views of those interested in air pollution, aware of the 
consultation and able to fill in the questionnaire. The response - 11587 questionnaires filled in - was larger than received in any previous consultation of this kind.  
The response was far from evenly distribut ed over the countries ; half was from 
Portugal. Most respondents (89%) were ‘i ndividuals’, 6% labelled themselves as 
‘experts’ (from research bodies or public authorities), 2% represented business and 
2% were from NGOs. There were di fferences between categories, with 
representatives of NGOs te nding to be somewhat more concerned and in favour of 
ambitious reduction measures than indivi duals, and representatives from business 
even less so. Experts from research and pub lic authorities were on average somewhat 
less concerned than other individuals.  
Several conclusions relevant for this St rategy were drawn from the consultation. 
There are good reasons for the Commission to continue its policy of pushing for air 
quality information to be available to the public. Very many respondents were concerned about air qualit y, particularly about the impacts on environment and 
health. They attach high priority to impr oving air quality and cal led for Scenario C. 
The international and European levels were seen as the most appropriate competence 
level for taking action. Indus trial production and traffic were given as the main 
targets for measures, and respondents were also prepared to take individual action 
themselves to improve air quality.  
These results were taken into account in the Strategy when defining the ambition 
level, focusing on health and environment objectives and identifying the possible and 
acceptable measures to be taken to redu ce air pollution. Measures to simplify 
legislation and to improve public informati on will also meet the concerns raised in 
the public consultation. 
9.2. Stakeholder consultation 
A Clean Air for Europe (CAFE) Steering Group
123 composed of representatives 
of the Member States, industry, and non- governmental and some international 
organisations was set up to advise the Commission on the environmental ambition concerning the Strategy. It met 14 times over the time frame of the preparation of the 
Strategy.  
A Working Group on Target-Setting and Policy Assessment
124 (WG TSPA ), 
representing a mosaic of European stakehol ders and invited experts, was set up with 
the purpose of assisting the Commission in the development of air quality related 
targets for the protection of human health and the environment, and giving advice on 
issues related to policies and measures a nd their effect on air quality and other 
                                                 
123 http://europa.eu.int/comm/environment/air/cafe/meetings/steering_group.htm 
124 http://europa.eu.int/comm/environment/air/cafe/working_groups/wg_target_setting.htm 
 
EN 126   EN aspects of economic, societal and environmen tal development. Its main task was to 
assist in the initial setting of policy-rele vant air quality indicat ors for the Baseline 
scenarios and initial targets for Integrated Assessment Modelling ( IAM ), to support 
the qualitative and quantitative assessment of the results of IAM, including Cost-
Benefit Analysis, to make recommendations for alternative model runs (“scenarios”) 
for the IAM, to assist in the analysis of  the policies and measures related to the 
development of the Thematic Strategy and to recommend the most appropriate options for the CAFE work programme,  and the final report of the CAFE 
programme. The WG TSPA met 12 times in all during preparation of the Thematic 
Strategy on Air Pollution. 
Since the issue of particulate matter wa s identified at the onset of the CAFE 
programme a Working Group on Particulate Matter
125 (WG on PM ) was set up 
with national experts.  The main objective of the WG on PM was to give support to 
the Commission in its review of the Ai r Quality Directive 1999/30/EC relating to 
airborne PM and its preparation of the Thematic Strategy on Air Pollution. With respect to the Directive, the main tasks we re to assess the air quality situation with 
regard to the PM limit values and to re view the Position Paper on PM published in 
1997 with regard to information obtained since, and also to collect together 
information on predictive studies on the atta inability of the limit values, considering 
contributions from long-range transport and local sources. With the aim of 
supporting preparation of the Thematic St rategy, the WG on PM had the task of 
considering the WHO work on health effect s of PM and to give  recommendations 
for concrete targets for integrated assessment. A further task was to review the results of the integrated assessment m odelling work on PM, wh ich took place in a 
joint meeting between the WG TSPA and experts from the WG on PM. In all the 
WG on PM had seven meetings with the full group. Most importantly  it reviewed the 
Position paper on PM from 1997, and unde rtook far-reaching consultation on its 
content with experts and stakeholders, inter alia  through a consultation workshop in 
Stockholm in 20 and 21 of October 2003. The final report is available on the web.
126 
The Commission has set up a Working Group on Implementation127 (WGI ) with 
experts from Member States and some other stakeholders . The main objective of the 
group is to assist in colle cting experiences of impl ementation of air quality 
legislation in the Member States, to ma ke assessments of the implementation and 
effectiveness of air quality legislation and to assist the Commission in preparing amendments to directives. The WGI has, inter alia , the tasks of:  
– identifying and listing problems in impl ementing the legislation in Member 
States;  
– developing, as appropriate, specific gui dance to support Member States in 
implementing the legislation;  
                                                
 
125 http://europa.eu.int/comm/environment/air/cafe/working_groups/wg_particulate_matter.htm 
126 http://europa.eu.int/comm/environment/air/cafe/pdf/working_groups/2nd_position_paper_pm.pdf 
127 http://europa.eu.int/comm/environment/air/cafe/working_groups/wg_implementation.htm 
 
EN 127   EN – investigating possibilities of st reamlining and harmonising reporting 
requirements within the air quality fr ame work directives, its daughter 
directives and the directive on national emission ceilings;  
– examining particular problems in Accession Candidate Countries in 
implementing the aquis .  
The WGI has also organised workshops  on implementation, "Meeting the Limit 
Values", held in Bruges on 17 and 18 September 2001. The WGI will also continue its work on the follow-up to the Thematic Strategy on Air Pollution, but with a revised mandate. 
The Commission has also organised a large number of workshops and other meetings 
to consult with stakehol ders, such as Member St ates experts and NGOs. The 
Commission has actively participated in  meetings organised by others, giving 
presentations of policy relevance and s eeking various stake holders’ views on key 
issues. In many cases too our consultants and Member State representatives have 
presented key issues to their stakeholders.  
9.3. Consultation within the Commission 
In addition to DG ENV consultations with European stakeholders internal 
consultations with other Commission depart ments have been a regular feature of the 
preparation of the Thematic Strategy. Throughout the CAFE programme 10 Inter-
Service meetings were held. Five of them  were informal meetings, between 2001 and 
2003, and the other five were formal during 2004-2005, and focused on the impact assessment of the Thematic Strategy. 
 
EN 128   EN 10. COMMISSION PROPOSAL AND GROUNDS  
10.1. Selection of the interim objectives for the Thematic Strategy up to 2020 
The previous sections analys ed in detail the environmental and health impacts of 
three possible sets of interi m objectives. They also tested  the robustness and analysed 
the impact of scenarios in wider cont exts, whether economic (e.g. competitiveness 
and sectoral implications) social (e.g. employment and social inclusion) or 
environmental (e.g. climate change, water a nd soil policies). Overall, the foregoing 
analysis has demonstrated that an inte rim objective beyond Scenario C would be 
justified only if the higher end of the statistical values for life years lost were used in the benefit assessment. Given the uncertain ties concerning the benefit estimates, it 
would be prudent to concl ude that the case for select ing an interim objective beyond 
Scenario C would be rather weak. 
It was also demonstrated that while costs would increase quite rapidly from Scenario 
A to Scenario C, the environmental and health benefits would increase relatively modestly. The impact on competitiveness – estimated by a general equilibrium 
model – would be generally similar, albeit somewhat lower than the direct sectoral 
costs estimated by the RAINS integrated assessment model. Also the overall macroeconomic impact was shown to be fair ly small. For instan ce, the impact of 
Scenario B on gross domestic product was pr ojected to be 0.08% in 2020. It should 
be noted that between 2000 and 2020 gross dom estic product is proj ected to increase 
by over 50%.  
Another point to note is that the analysis a ssumed that the rest of the world would not 
reduce air pollution while the EU implements the Thematic Strategy on Air Pollution. However, key competing economies (e.g. the USA
128 and China) are 
making efforts similar to th e action proposed in the Strategy. In other words, as 
countries outside the EU are also reducin g their air pollution, the impact of air 
pollution policies in the EU on competitiven ess will be mitigated. Consequently, the 
costs – in terms of competitiveness – shown in this impact assessment are overestimated because the impact of the air pollution abatement policies of other 
economies in the world has been excluded from the analysis.  
It was also shown that the overall impact on employment was negligible. In some 
sectors employment would increase while in others it would decrease. The sectors 
where employment seems likely to increase would be those where the educational requirements are relatively high. This woul d be compatible with  the Lisbon strategy 
of increasing competitiveness in the EU by rais ing the skill levels of  the labour force.  
To sum up, all three scenarios were shown to pass the cost-benefit test and their 
wider economic and social impacts were de monstrated to be compatible with the 
EU’s Lisbon and sustainable development st rategies. Consequently, all that remains 
to be done is to select the interim objectives for the Strategy up to 2020.  
                                                
 
128 For instance, the recently announced Clean Air Inte rstate Rule programme in the USA will induce an 
annual abatement cost to the power generation sector of $5 billion. 
 
EN 129   EN Scenario C has the advantage of delivering high environmental and health benefits. 
However, at the same time the annual costs of Scenario C are about €4 billion higher than in Scenario B. A cautious marginal analysis approach, ta king into account the 
uncertainties, shows that the optimum level of ambition for PM he alth benefits is 
between B and C. Regarding the other targ ets for ecosystems and ozone for which a 
monetary valuation is not fully available, additional ecosystem benefits between Scenarios A and B are relatively small co mpared with the increase in costs. 
Therefore, it seems justified to select a final scenario which represents a combination of Scenarios A and B, i.e. a level of am bition for human health protection from PM 
close to Scenario B with a level of prot ection for ecosystems based on Scenario A. 
This delivers the lowest levels of air po llution that can be justified in terms of 
benefits and costs whilst attempting to prevent undue risks fo r the population. This 
strategy would yield monetised benefits fo r human health and crop damage of €42.7 
billion per annum with associated co sts of € 7.1 billion per annum. Table 34 
summarises the alternative ambition levels and shows the chosen combination labeled as “Strategy”. 
Table 34: Alternative environmen tal ambition levels up to 2020 
Baseline Policy Scenarios  
2000 2020 A B C Strategy 
SO2  -68% -80% -82% -83% -82% 
NOx  -49% -60% -63% -65% -60% 
VOC  -45% -50% -54% -55% -51% 
NH3  -4% -25% -32% -35% -27% Emissions 
(relative to year 
2000) 
PM2.5  -45% -57% -59% -61% -59% 
Impacts of particulate matter on health 
Premature mortalities 348,000 272,000 218,000 206,000 200,000 210,460 
Months of life expectancy lost 8.1 5.5 4.4 4.1 4.0 4.2 
Total PM Damage costs to human 
health per annum  €268bn €184bn €147bn €139bn €136bn €142bn 
Cost per annum ( Particulate Matter 
& human health )  - - + €5.0 + €8.1bn +€11.4 +€6.6bn 
Health Benefits (PM) per annum  - - + €37bn + €45bn + €49bn +€42bn 
Environment & ozone impacts on health 
Monetised ozone damage costs per 
annum ( health , crops, materials ) €13.3bn €7.5bn €6.8bn €6.6bn €6.4bn €6.8bn 
Cost per annum ( health (ozone) and 
Environment ) - - +€0.5bn +€2.6bn +€3.4bn €0.5bn 
Ozone monetised benefits for health  - - +€0.4bn +€0.5bn +€0.6bn €0.4bn 
Ozone monetised benefits to 
agricultural crops - - +€0.3bn +€0.4bn +€0.5bn €0.3bn 
Forests 243 119 67 59 55 63 
Semi-
natural 24 8 4 3 3 3 Area of ecosystems at 
risk to acidification 
(000 km2) Freshwaters 31 22 19 18 17 19 
Area of ecosystems at risk to 
eutrophication (000 km2) 733 590 426 375 347 416 
Area of ecosystems at risk from 
ozone (000 km2) 827 764 699 671 652 699 
Note: Ecosystem benefits have not been monetised but s till need to be considered. Depending on the type of 
ecosystem and type of function valued, research has shown that each hectare improved could be worth between 
€250 and €155,000. In addition, damage to buildings and materials will also be reduced. 
 
EN 130   EN The strategy presented in Table 34 appears to present a more optimal balance 
between economic and environmental dimensi ons and is more consistent with the 
Lisbon Strategy objectives a nd the Community’s Sustaina ble Development Strategy. 
However, the Commission will look again at this issue when reviewing this Strategy 
in about five years and may adjust th e basis on which the following challenging 
interim health and environmental objectives are set. 
By 2020 emission reductions would be re quired in the EU-25 of 82% for SO 2, 60% 
for NOx, 51% for VOCs, 27% for NH 3 and 59% for PM 2.5 relative to the position in 
2000. 
The strategy would, on average, reduce loss of life expectancy due to exposure to 
PM 2.5 to 4.2 months instead of 5.5 months in the baseline for 2020. Based on the 
calculations from RAINS further analysis  within the CBA framework allowed an 
assessment of the number of people dyi ng prematurely every year. The Strategy 
would correspond to a reduction of premat ure deaths by about 61,500 people per 
year compared with the baseline for 2020.  
The number of deaths brought fo rward due to ozone exposure129 all over the EU 
would be reduced by about 1000 people (Figure 27). At the same time, other health-
related impacts due to ozone  would also be reduced. Ho wever, some regions would 
still have elevated levels of ozone in 2020. 
Figure 27: Maps on air quality health  impact of the Thematic Strategy 
 2000 Baseline 2020 Strategy 
Loss in life 
expectancy attributable to 
anthropogenic 
PM
2.5 (months) 
Health effects attributable to 
exposure 
ground-level 
ozone 
(ppb.days) 
                                                 
129 above a cut-off of 35 ppb 
 
EN 131   EN  Table 35: Change in annual health impacts over baseline in 2020  
End point Poll. Unit 2000 Baseline 
2020 Strategy 
2000 % Change 
over 
baseline 
Chronic mortality (years) PM thousand 3619 2467 1911,5 -23% 
Chronic mortality (premature deaths) PM thousand 695,8 271,6 210,9 -22% 
Infant mortality (0-1 years) (prema ture deaths) PM  680 350 270 -23% 
Chronic bronchitis (over 27 years) PM thousand 163,8 128,1 99,4 -22% 
Respiratory hospital admissions (all ages) PM thousand 62 42,3 32,8 -22% 
Cardiac hospital admissions (all ages) PM thousand 38,3 26,1 20,2 -23% 
Restricted activity days (15-64 years) PM million 347,7 222 172 -23% 
Respiratory medication use (children 5-14 years) PM million 4,2 2 1,55 -23% 
Respiratory medication use (adults over 20 years) PM million 27,7 20,9 16,2 -22% 
Lower respiratory symptom (LRS 5-14 years) PM million 192,8 88,9 68,9 -22% 
LRS among adults (over 15years) with chronic 
symptoms PM million 285,3 207,6 160,9 -22% 
Acute mortality (premature deaths) O3 thousand 21,4 20,8 19,2 -8% 
Respiratory hospital admissions (over 65years) O3 thousand 14 20,1 18,5 -8% 
Minor restricted activity days (MRADs 15-64 
years) O3 million 21,4 12,9 9,7 -25% 
Respiratory medication use (5-14 years) O3 million 8,8 8,2 7,2 -12% 
Respiratory medication use (over 20 years) O3 million 53,9 42,4 41,8 -1% 
Cough and lower respiratory symptom (LRS 0-14 
years) O3 million 108,1 65,3 60,4 -8% 
Source: CAFE Cost-Benefit Analysis 
Table 36: Change in annual health impacts over baseline in 2020 (millions of euros)  
Endpoint  Pollutant  Strategy
Chronic mortality – VOLY – (median value) PM 29,041
Chronic mortality – VSL – (median value) PM 59,500
  
Chronic mortality – VOLY – high (mean value) PM 65,186Chronic mortality – VSL – high (mean value) PM 122,416
Infant mortality (0-1 years) – (median value) PM 112
Infant mortality (0-1 years) – (mean value) PM 224
Chronic bronchitis (over 27 years) PM 5,392
Respiratory and cardiac hospital admissions  PM 31
Restricted activity days (R ADs 15-64 years) PM 4,173
Respiratory medication use PM 5
Lower respiratory symptoms PM 2,563
  
Acute mortality (VOLY median) O 3 83
Acute mortality (VOLY mean) O 3 186
Respiratory hospital admissions and medication use  O 3 5
Minor restricted activity days (MRADs 15-64 years) O 3 124
Cough and lower respiratory symptoms (0-14 years) O 3 189
Total with mortality – VOLY – (median value)  41,718
Total with mortality – VSL – (median value)  72,177
  Total with mortality – VOLY –(mean value)  78,078
Total with mortality – VSL – (mean value)  135,308
Source: CAFE Cost-Benefit Analysis  
 
EN 132   EN The contribution of the Strategy to ecosy stem and non-health benefits can be 
estimated as follows: 
– The Strategy would reduce the forest area receiving acid deposition above the 
critical load further by about 56,000 km2. The area of freshwater ecosystems 
(Figure 28) in these EU Me mber States receiving a de position of acid above the 
critical load is estimated to be  further reduced by decrease by 3,000 km2. 
– The Strategy would reduce the area with  excess deposition of nitrogen above the 
critical load by a further 174,000 km2, but substantial and severe eutrophication 
problems would remain in many Me mber States (Figure 28).  
– The area of ecosystems at risk from  ozone would further decrease by 65,000 km2. 
The overall damage to crops (mainly wheat yield loss, Figure 28) would be further 
reduced by about 330 million euros in 2020. 
Figure 28: Maps on air quality impact on  ecosystems of the Thematic Strategy 
 2000  Baseline 2020  Strategy  
Percentage of 
freshwater ecosystems 
area receiving 
acid deposition above the 
critical loads 
 
  
Percentage of 
total 
ecosystems 
area receiving nitrogen 
deposition 
above the critical loads 
 
  
Reduction of 
impacts of 
ozone on wheat 
yields 
 
  
Source: RAINS. Note: Calculation results are based on meteorological conditions of 1997. 
 
EN 133   EN To sum up, the Strategy would trigger by 2020 improvements of (relative to 2000): 
– 47% in life expectancy lost from exposure to particulate matter 
– 10% fewer cases of acute mort ality from exposure to ozone 
– 74% less forest area and 39% less freshwater area wh ere acidification critical 
loads are exceeded 
– 43% less area where critical load s for eutrophication are exceeded 
– 15% less forest area where critical levels are exceeded due to ozone 
These improvements include both the effect of this Strategy and the cumulative 
effect of current legisla tion. Figure 29 demonstrates how these improvements are 
divided. 
Figure 29: Improvement of health a nd environment due to the Thematic 
Strategy 
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Health (PM2.5)
Health (ozone)
Forest acidification
Ecosystem acidification
Freshwater acidification
Eutrophication
Forest damage (ozone)Current legislation
Further improvement
 
Source: RAINS and CAFE Cost-Benefit Analysis 
Annual abatement costs of the measures included in the Thematic Strategy are 
estimated at €7.1 billion. Table 37 and Figure 30 disaggregate the costs by pollutant and major source. As explained in Chapter 6, this is a preliminary estimate that does 
not take into account subs tantial issues, such as: 
– For transport, the costs forecast relate to one emission reduction scenario based on 
a single source of data. Future emissions standards will be defined on the basis of a more detailed impact assessment (See Section 5.5.2.). Accompanying and non-
 
EN 134   EN technological measures may also influence in a positive way the cost-
effectiveness of these standards. 
– For energy, additional measures of energy efficiency could trigger additional 
emissions reduction. 
– For agriculture, estimates do not take into account the impact of the Common 
Agricultural Policy reform or the implementation of the nitrate and IPPC directives (see section 5.5.1). Moreover, th e decrease in ozone damage to crops 
has to be taken into account (see secti on 5.7.5.). It would amount to €0.3 billion in 
2020, corresponding to more than 13% of th e direct cost of the measures for 
Agriculture. 
Table 37: Annual abatement cost per po llutant for the Thematic Strategy by 
2020 (millions of euros) 
Ambition level Annual Cost 
(€ million)
SO 2 934 
NO x 998 
NH 3 2.595 
Primary PM 2.5 636 
VOC 118 
Road transport (both PM 2.5 and NO x) 1.868 
Total  7.149 
Source: RAINS.  
Figure 30: Sectoral distribution of the cost  of the measures associated with the 
Thematic Strategy (millions of euros and % total).  
Other industrial 
process and waste; 
819; 11%
Fuel production and 
conversion; 262; 4%
Transport; 1.964; 27%
Large Combustion 
Plants (power and 
heat); 381; 5%Large Combustion 
Plants (industry); 569; 
8%Small Combustion 
Plants; 559; 8%Agriculture (crops); 
279; 4%Agriculture (animals); 
2316; 33%
 
Source: RAINS 
 
EN 135   EN All these elements will be analysed in depth during the review of the National 
Emission Ceilings Directive. The objective will be to promote measures which are 
synergistic for the various environmental media and at the same time to help achieve various environmental objectives with cost effective measures.  
Attainment of these targets is estimated to cost about 0.05% of the EU-25 GDP in 
2020. No net change in employment is expe cted to result. Production lost through ill 
health would also be reduced  whilst those in lower inco me groups may be expected 
to benefit most as these groups are genera lly exposed to the highest levels of air 
pollution. 
Although the effect on GDP is slighly negative, it is know n that high environmental 
standards can be an engine for business gr owth and innovation. Th e EU can also gain 
competitive advantages and create opportunities by focusing research and development on resource-efficient and less polluting technologies that other 
countries will eventually n eed to adopt. Whilst devel oped countries, like the USA 
and Japan, already have similar air polluti on policies in place, it is clear that 
developing countries like China and Korea ar e also increasingly concerned about air 
pollution, are taking positive steps to limit em issions and are looking for policy and 
technical inspiration from Europe. 
10.2. Better regulation –– cutting red tape  and streamlining current air quality 
legislation 
In order to improve the regulatory fram ework on air quality in line with the 
Commission’s strategic objectives for 2005-200 9 calling for better regulation, it is 
indispensable to modernise and simplify the current air quality legislation – and to 
reduce its volume – in order to improve  the competitiveness of the European 
economy.  
The Commission therefore proposes to combin e the Framework Directive, the First, 
Second and Third Daughter Directives, and the Exchange of Information Decision 
into a single Directive on “Ambient Air Quality and Cleaner Air for Europe”. This will cut red tape, clarify and simplify ambiguous provisions, repeal obsolete provisions, modernise and reduce re porting requirements and introduce new 
provisions on fine particulat es. The Fourth Daughter Direct ive will be merged later 
by means of a simplified “codification” process. While the impact of this modernisation and simplification exercise ca nnot be quantified in monetary terms, it 
is certain to have positive effects on competitiveness by reducing bureaucracy and increasing transparency. 
It is necessary to address certain problems which have occurred with implementation 
of the current air quality legislation. The Commission proposes to allow Member 
States to extend the deadline for complia nce in affected zones if objectively 
verifiable conditions are met, including information about compliance with certain Community legislation c ontributing to improvement  of air quality. As a quid pro quo  
the Member States would have to develop and implement an air pollution abatement programme to ensure that the limit values  are attained by the time the extension 
expires. It has not been possi ble to quantify the impact of  this proposal, which is a 
“safety valve” against unduly high abatemen t costs in exceptional situations.  
 
EN 136   EN It is also necessary to bring the reporti ng requirements for air quality into the 21st 
century by using the Internet as the ma in means of delivery and making this 
compatible with INSPIRE.  
The costs and benefits of cutting red tape and of modernising air quality legislation 
could not be quantified in monetary te rms. However, the changes are clearly 
beneficial in terms of lower implemen tation costs and faster, more accurate 
information. The Commission therefore c onsiders the simplification and better 
regulation approach justified. 
10.3. Proposal for regulating particulate matter and other air pollution 
In the light of recent health  evidence, the Commission considers it justified to adopt 
the following approach: 
No change in current limit values 
Based on the advice received from the scientific community – the WHO ’Systematic 
review on air pollution hea lth aspects in Europe’ and the Commission’s Scientific 
Committee on Health and Environmental Risk s – the Commission is not proposing to 
revise the current limit and target values for air pollutants set by the European air 
quality legislation. However, the Commission proposes to repeal the indicative limit 
value for PM 10 for 2010 and – on the basis of scientific advice and health evidence – 
to start regulating fine partic ulate matter below 2.5 microns (“PM 2.5”) differently. 
Reducing annual average urban ba ckground concentrations of PM 2.5 between 2010 
and 2020 
The latest scientific evidence confirms that PM 2.5 is responsible for significant 
negative effects on human h ealth and leads to substantial loss of life amongst 
European citizens. What is more, there is no identifiable threshold below which particulate matter would pose no risk to human health. Becaus e of this evidence, it is 
vital to regulate fine particulate matter di fferently from certain other air pollutants. 
The Commission proposes an effective and proportionate approach: setting a 
concentration reduction target of 20 % between 2010 and 2020 for all Members 
States, and – as part of the review of  the Directive on Ambient Air Quality and 
Cleaner Air for Europe - revise this into  a legally binding re duction of the average 
annual urban background concentration of PM
2.5 once the monitoring data for 2008-
2010 of urban background monitoring st ations has established the baseline.  
The Commission proposes to require each Member State to re duce average annual 
urban background concentrations of PM 2.5 between 2010 and 2020 by a specific 
percentage  per cubic metre measured in the baseline concentration. This would start 
in 2010. It also proposes that average a nnual urban background concentrations be 
calculated as a three-year running averag e – starting from the period between 2008 
and 2010 – thus moderating the impact of meteorological variab ility. The reduction 
would be based on the arithme tic (or population weighted) me an of all measurements 
of PM 2.5 concentrations made in urban backgr ound locations in th e territory of the 
individual Member State. This reduction re quirement should be set to be consistent 
to the ambition level proposed in th e Thematic Strategy on Air Pollution.  
 
EN 137   EN Benefits and costs of regulating PM 2.5 at EU level 
The benefits of the Commission’s proposal for a two-staged appr oach to reduce the 
average urban background concentration between 2010 and 2020 will total between €37 billion and €119 billion per annum in 2020. This is between seven and 24 times 
higher than the estimated costs of between €5 and €8 billion per annum.  
As the benefits demonstrably out weigh the costs of regulating PM
2.5 the Commission 
considers that it has demonstrated th at the proposed method to regulate PM 2.5 
justified. However, the exact definition of  the reduction requirement will be made 
after the monitoring data from 2008-2010 will be available. 
Capping unduly high risk  
The Commission also proposes a concentr ation cap of 25 micrograms per cubic 
metre, expressed as an annua l average, to be attained by 2010. The cap is set at a 
level entirely consistent with the existing limit value for PM 10 and is therefore 
expected to place no additional burden  on Member States. The cap will apply 
throughout the territory of  the Member States.  
This approach is expected to entail no additional implementation costs apart from 
certain costs to monitor PM 2.5 concentrations. These costs are estimated at between 
€5 million and €12 million per annum depending how much less monitoring Member States would carry out for SO
2.  
The main reason for proposing the concentra tion cap is to make sure that reducing 
average PM 2.5 concentrations will have no unint ended consequences, which would 
expose some Europeans to unduly high PM 2.5 concentrations. 
 
EN 138   EN ANNEXES  
 
EN 139   EN ANNEX 1  
 
CAFE reference documents  
The forthcoming Thematic Strategy on Air Pollution and its Impact Assessment are 
based on other relevant documents produced  by the Commission in the framework of 
the CAFE Programme130: 
Strategy, Orientation  
• 6th Environment Action Programme   
• Communication "The Clean Air for Eu rope (CAFE) Programme: Towards a 
Thematic Strategy for Air Quality" COM(2001)245   
Methodology  
• Methodology for the Integrated Assessment Modelling 
– Review of the Rains Integrated Assessment Model   
– Documentation of the RAINS model appr oach prepared for the RAINS peer 
review 2004   
• Methodology for the Cost-Benefit Analys is of the CAFE Programme (AEAT, 
March 2005):  
– Volume 1: Overview of Methodology   
– Volume 2: Health Impact Assessment   
– Volume 3: Uncertainty : Methods and First Analysis   
– Peer review Cost-Benefit Analys is of the CAFE Programme report   
• Health Effects of Air Pollution  
– Systematic review of health effects of  air pollution in Europe (WHO, June 2004)   
– Second Position Paper on Particul ate Matter (CAFE Working Group on 
Particulate Matter, December 2004 )  
Integrated Assessment Modelling and Cost-Benefit Analysis  
• Baseline 
– Energy Baseline Scenarios for the Clean Air for Europe (CAFE) programme. 
(NTUA, December 2004 )  
                                                 
130 All the documents are available on Europa website at : 
http://europa.eu.int/comm/environment/air/cafe/general/keydocs.htm   
 
EN 140   EN – CAFE Scenario Analysis Report 1, "Bas eline Scenarios for the Clean Air for 
Europe (CAFE) Programme" (IIASA, February 2005)   
– CAFE Cost-Benefit Analysis: Baseline Analysis 2000 to 2020  (AEAT, April 
2005)  
• Scenarios  
– CAFE Scenario Analysis Report Nr. 2, "The “Current Legislation” and the 
“Maximum Technically Feasible Reduc tion” cases for the CAFE baseline 
emission projections" (IIASA, November 2004)   
– CAFE Scenario Analysis Report Nr. 3, "First Results from the RAINS Multi-
Pollutant/Multi-Effect Optimization includ ing Fine Particulate Matter" (IIASA, 
January 2005)   
– CAFE Scenario Analysis Report Nr. 4, "Target Setting Approaches for Cost-
effective Reductions of Population Exposure to Fine Particulate Matter in Europe" 
(IIASA, February 2005)   
– CAFE Scenario Analysis Report Nr. 5, "E xploratory CAFE scenarios for further 
improvements of European ai r quality" (IIA SA, March 2005)   
– CAFE Scenario Analysis Report Nr. 6, "A final set of scenarios for the Clean Air 
For Europe (CAFE) programme" (IIASA, June 2005)   
– Cost-Benefit Analysis of Policy Opti on Scenarios for the CAFE programme 
(AEAT, August 2005)  
Measures  
• Review and ex-Post Evaluation of current policies and measures: 
– Recommendations on the review of Directive 1999/30/EC (WG on 
Implementation, June 2004)   
– Review of the National Emission Ceiling Directive   
– Assessment of the Effectiven ess of European Air Quality Policies and Measures 
(DMU, 2004):  
– Shell report ,  
– Case Studies on EU and US Approache s ( Acidification, Eutrophication and 
Ground-Level Ozone ,  
– Air Quality Standards a nd Planning Requirements ,  
– Controlling Emissions from High-Emitting Vehicles ,  
– Approaches towards Particulate Matter ,  
 
EN 141   EN – Survey to assess successes and failures  of the EU Air Quality Policies ,  
– Study on transparency and public participation ,  
– Report on databases ,  
– Lessons learned and Recommendations ,  
– "Ex-post" Evaluation of Short-term and Local Measures in the CAFE Context 
(AEAT, January 2005   
• New Measures:  
– Assessment of Air Emission impact of  emerging technologies (DFIU/IFARE, 
November 2004)   
– Small scale combustion installa tions (AEAT, November 2004)   
– Evaluation of the Potential Scope for and Costs of Further Reductions of 
Emissions of VOCs from Refuelling Operatio ns at Service Stations ("Stage II") in 
an Enlarged European Union (ENTEC, to be published)  
– Report of the conference  on policy instruments on air pollution (November 2004)  
Stakeholder and Public Consultation  
• Public views on air pollution in the Eur opean Union, Results of the European 
Commission's public consultation on air pollution (TNO, April 2005)   
• CAFE Steering group   
• Working Group on Target Setting and Policy Assessment   
• Working Group on Particulate Matter   
• Working Group on Implementation   
 
EN 142   EN ANNEX 2  
 
Methodology and models for the impact assessment  
This annex describes the methodologies deve loped for the construction of the CAFE 
baseline and the tools used by DG Envi ronment during the CAFE Programme to 
develop the Strategy, including assessment of policy options, namely the PRIMES, 
RAINS, CBA and GEM-E3 models. 
BUILDING THE CAFE  BASELINE  
A baseline of future energy consumption, em issions and air polluti on is required in 
order to make an assessment of the effec tiveness of current po licies and to propose a 
strategy to address remaining problem s and to make progress towards the 
Community air pollution objectives. This baseli ne must be as realistic as possible and 
incorporate the full effects of current polic ies to combat air pollution. An extensive 
dialogue therefore took place between the Commission, its contractors, Member States and stakeholders to ensure that  a robust and consistent baseline was 
developed. 
A consistent EU-wide baseline was constr ucted that built upon economic projections 
from DG ECFIN, agricultural projections from DG AGRI and information from the 
Member States. An EU-wide baseline was preferred in order to avoid inconsistencies in methodologies and to take into account th e facts that market integration makes it 
more and more difficult to construct a na tional baseline in isolation from other 
Member States and that national baselines  may include some strategic behaviour. 
The baseline takes into account: – what changes are likely in the output of the pollution s ources (i.e. how much more 
energy and emissions are likely to be required given the most plausible GDP 
growth rate); 
– what autonomous technological devel opment might induce (e.g. new plants tend 
to be more efficient and cleaner than old ones); 
– what legislation will be in place to control emissions; and 
– what role external factors could play (e .g. movements in world market prices of 
coal, gas and oil). 
The approach taken to construct the baseline was first to develop a consistent EU-
wide energy scenario using the PRIMES m odel for all of the EU-25 Member States. 
These energy balances were then used  as exogenous input to the RAINS model 
which gave estimates of emissions up until 2020 and also predicted the environmental damage caused by those emissions for the EU-25 region. Emissions projections are built upon a thorough know ledge of current emissions and 
corresponding air pollution levels. These ha ve been established on the basis of 
emission inventories and air quality measurements reported by Member States under 
Community legislation or to the CLRTAP. 
 
EN 143   EN Demographic and economic hypothesis 
The starting point for the CAFE baseline  is the “Long-Range Energy Modelling” 
(LREM) study from DG Energy and Tran sport, finalised in December 2002131. 
CAFE has taken the LREM base case and used revised demographic and macroeconomic assumptions which reflect  the latest information and trends. 
The EU-25 population remains fairly stable at 2000 levels, according to EUROSTAT 
historical data and project ions for population and the projections of the United 
Nations Global Urban Observatory a nd Statistics Unit of UN-HABITAT for 
household size. 
The current situation in each country, together  with clearly identifiable trends and the 
identifiable driving forces of growth fo r each economy, were used to determine the 
growth rates in individual br anches of industry. As a re sult, GDP growth in the EU 
averaging 2.3% per annum in 2000-2030 was us ed. This is modest compared to the 
ambitions of the Lisbon stra tegy, but high compared with the current weak state of 
the EU economy. Faster economic growth was assumed in the new Member States 
(3.5% per annum in 2000-2030) combined with gradual convergence of the EU 
economies throughout the projection period. However, even in 2030 per capita GDP in the acceding countries will remain more  than 30% below the EU average (from 
55.5% lower in 2000). 
Economic modernisation will also continue  throughout the projection period - on the 
one hand in the form of restructuring away from primary and secondary sectors towards services and on the other hand through dematerialisa tion of industrial 
production (a trend driven by a shift away from energy-intensiv e processes and an 
increasing proportion of new i ndustrial activities with high  value added and a lower 
material base).  
Economic development assumptions for EU-25 for the CAFE baseline 
80%100%120%140%160%180%
2000 2005 2010 2015 2020GDP Primary energy use Passenger km
Freight ton-km Cattle lifestock Sea transport 
Source: Baseline Scenarios for the Clean Air for Europe (CAFE) Programme - Final Report 
                                                 
131 This assessment covered the EU Member States (P RIMES model), the 13 EU candidate countries (ACE 
model), Norway and Switzerland (ACE model). For  a detailed analysis of the assumptions and results 
see the publication by DG Energy and Transport: “European Energy and Transport – Trends to 2030”. 
 
EN 144   EN Sectoral developments 
In order to construct the ba seline, assumptions had to be made on how firms will 
innovate (because of competition, change of production methods, replacement of old 
equipment, etc.) and how this innovation re lates to changes in GDP and then to 
emissions. The following sectors are consider ed particularly important in the air 
quality context: energy production, tran sport, industry and agriculture. 
Energy and transport projections are produ ced by the PRIMES energy market model 
for EU-25. LREM was taken as the basis for the CAFE baseline; however, this 
baseline assumed explicitly that no further climate policy measures would be taken. It was important to know the implications for air pollution assuming EU-25 were to meet its Kyoto Protocol obligations. Afte r consulting the Climate Change Unit of 
DG Environment it was decided that – for the purposes of the CAFE baseline scenario – all measures to comply enta iling a marginal cost of up to €12/tCO
2 would 
be taken in EU-25. Above this cost it was implicitly assumed that Joint 
Implementation or Clean Development Mech anism measures plus other means of 
compliance (e.g. carbon sequestration) would be used.  
It was also assumed that by 2020 the carbon constraint would increase slightly. For 
the purposes of the CAFE baseline it was a ssumed that the compliance cost in the EU 
would be €20/tCO 2. Again, the implicit assumption wa s that measures along the lines 
of Joint Implementation, th e Clean Development Mechanism or carbon sequestration 
would be undertaken where compliance costs were higher. For 2015 it was assumed that the compliance cost w ould be in between the 2010 a nd 2020 levels. This means 
that the compliance cost was assumed to be €16/tCO
2 in 2015. All other assumptions 
(e.g. about demographics, economic growth and its sectoral composition) were kept constant. However, within sectors the increasing cost per tonne of CO
2 would shift 
the patterns of consumption of energy and transport fu els towards greater fuel 
efficiency and lower CO 2 emissions. 
In addition to the two modified LREM pr ojections (i.e. without and with climate 
measures), two further scenarios were  developed in the CAFE Programme:  
– National projections for energy use up to  2020. These were submitted by some 10 
Member States but not all of the projectio ns gave complete sectoral coverage and 
it was therefore not always possible to  compare them fully with the CAFE 
baseline.  
– An “illustrative climate” scenario, assuming a 20% reduction in CO 2 emissions in 
2020 compared to 1990 corresponding to a compliance cost in 2020 of €90 per 
tonne of CO 2. It was considered important to se e what the implications of such a 
scenario would be for air pollution.  
The CAFE baseline scenario incorporat es updated energy, economic and financial 
information (taking 2000 as the base year).  It reflects recent tr ends and policies in 
place, such as the fuel efficiency agreement with the car industry, the liberalisation of 
the electricity and gas markets, existing policies on energy efficiency and renewable 
energy sources, ongoing infrastructure pr ojects and current nuclear policies. 
 
EN 145   EN The projected trend for the EU-25 energy system in the CAFE baseline scenario 
shows that despite the evid ence of further de-linking  of economic growth from 
energy demand in EU-25, energy demand is e xpected to continue to grow. During 
the period 2000 to 2020 primary energy demand in EU-25 is set to increase by 9.2% compared to GDP growth of 58.6%, implying that energy intensity in EU-25 (expressed as primary energy demand per un it of GDP) will improve at a rate of 
1.85% per annum. Improvements in energy efficiency (on both the demand and the supply sides), changes in the structure of EU industry, saturation in demand for some 
important energy needs and the policies alr eady in place are some of the key drivers 
for the projected intensity gains.  
EU-25 primary energy indicators 1995-2020 (1990 = 100)  
020406080100120140160180200220
1995 2000 2005 2010 2015 2020405060708090100110GDP
Primary Energy Demand
CO2 emissions
Energy IntensityCarbon intensity
 
Source: PRIMES, Energy Baseline Scenarios for the CAFE Programme 
Significant changes will also occur in the demand-side fuel mix as a result of the 
projected shifts towards the use of more efficient and less carbon-intensive energy 
sources. Solid fuels will decline continuously  over the projecti on period accounting 
for just 2.5% of energy needs on the demand side in EU-25 by 2020 (down from 5.3% in 2000 and 11.7% in 1990). Liquid fuels will remain the main energy carrier 
in demand sectors in EU-25 over the projectio n period, but will grow at rates well 
below average, constantly losing market share. By 2020 some 76% of demand for liquid fuels is projected to come from the transport sector, compared to 67% in 2000. 
Following the introduction of an EU-wide CO
2 emissions trading scheme, CO 2 
emissions are projected to decline further than  observed in the recent past, falling to 
7.4% below 1990 levels in 2010 (from 1990 to 2000 CO 2 emissions fell by 2.8% 
whereas the corresponding primary energy needs grew by 6.2%). However, beyond 
2010 once more and more use has been made of the options available for shifting the 
fuel mix towards less carbon-intensive en ergy sources, carbon inte nsity is projected 
to deteriorate with CO 2 emissions in 2020 down by 3.6% on 1990 levels. 
 
EN 146   EN The transport baseline used for the CAFE in tegrated assessment is derived from the 
PRIMES energy projection. This  ensures consistency with the energy baseline, and 
the projections include trends in emissions from international transport. The transport 
baseline is supplemented by the outco me of an upgraded version of the 
TREMOVE132 model, an integrated simulation to ol developed with in the framework 
of the Auto-Oil II Programme for strategic anal ysis of the costs and effects of a wide 
range of policy instruments applicable to  local, regional and European transport 
markets.  
The ammonia emissions from agriculture are taken from the CAPRI133 model 
specifically constructed for modelling agricultural production (and emissions). 
Effect of legislation 
In order to convert economic activity into air pollution and air quality it is necessary 
to know how current environmental and othe r legislation – both in EU-15 and in the 
new Member States134 – will affect emissions in the future. A large number of 
directives lay down minimum requirements to control emissions from specific 
sources. These are listed below: 
                                                 
132 http://www.tremove.org   
133  For a description of the CAPRI (Common Agricultural Policy Regional Impact Analysis) modelling 
system see http://www.agp.uni-bonn.de/a gpo/rsrch/capri/capri_e.htm   
134 It has been assumed that all new Member States w ill have fully implemented the ‘acquis’ by 2015 to 
2020. 
 
EN 147   EN  
Measures considered for the CAFE baseline 
Directive 2001/80/EC of the European Parliament and of the Council of 23 October 2001 on the limitation of 
emissions of certain pollutants into the air from large combustion plants135 
Council Directive 96/61/EC of 24 September 1996 concerning integrated pollution prevention and control136 
Council Directive 1999/32/EC of 26 April 1999 relating to  a reduction in the sulphur content of certain liquid 
fuels and amending Directive 93/12/EEC137 
Directive 98/70/EC of the European Parliament and of the Council of 13 October 1998 relating to the quality 
of petrol and diesel fuels and amending Council Directive 93/12/EEC138 
European Parliament and Council Directive 94/63/EC of  20 December 1994 on the control of volatile organic 
compound (VOC) emissions resulting from the storage of pe trol and its distribution from terminals to service 
stations139 
Council Directive 1999/13/EC of 11 March 1999 on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations
140 
Directive 2004/42/EC of the European Parliament and of the Council of 21 April 2004 on the limitation of 
emissions of volatile organic compounds due to the use of organic solvents in certain paints and varnishes and 
vehicle refinishing products and amending Directive 1999/13/EC141 
Directive 2000/76/EC of the European Parliament and of the Council of 4 December 2000 on the incineration 
of waste142  
Directive 2002/51/EC of the European Parliament and of the Council of 19 July 2002 on the reduction of the 
level of pollutant emissions from two- and three-wheel motor vehicles and amending Directive 97/24/EC143  
Directive 1998/69/EC of the European Parliament and of the Council of 13 October 1998 relating to measures 
to be taken against air pollution by emissions from motor vehicles and amending Council Directive 70/220/EEC
144  
Directive 2002/88/EC of the European Parliament and of the Council of 9 December 2002 amending Directive 
97/68/EC on the approximation of the laws of the Member States relating to measures against the emission of 
gaseous and particulate pollutants from internal combustion engines to be installed in non-road mobile machinery
145  
Council Directive 88/77/EEC of 3 D ecember 1987 on the approximation of the laws of the Member States 
relating to the measures to be taken against the emission of gaseous pollutants from diesel engines for use in 
vehicles146  
                                                 
135 OJ L 309, 27.11.2001, p. 1. 
136 OJ L 257, 10.10.1996, p. 26. 
137 OJ L 121, 11.5.1999, p. 13. 
138 OJ L 350, 28.12.1998, p. 58. 
139 OJ L 365, 31.12.1994, p. 24. 
140 OJ L 85, 29.3.1999, p. 1. 
141 OJ L 143, 30.4.2004, p. 87. 
142 OJ L 332, 28.12.2000, p. 91. 
143 OJ L 252, 20.9.2002, p. 20. 
144 OJ L 350, 28.12.1998, p. 1. 
145 OJ L 35, 11.2.2003, p. 28. 
146 OJ L 36, 9.2.1988, p. 33. 
 
EN 148   EN The baseline of future emissions include s all of those known measures, both national 
and Community, which have a direct imp act on emissions. The baseline projections 
take no account of caps imposed on to tal national emissions by the National 
Emission Ceilings Directive, nor of compliance with the Air Quality Framework and Daughter Directives to avoid local polluti on “hot spots”. The NECD and the ambient 
air quality legislation only have an indi rect impact on emissions because they 
establish environmental quali ty standards or emissions caps. Member States must 
adopt specific direct measures in order to comply with their provisions. It is these 
direct measures and policies which are m odelled in the RAINS integrated assessment 
model. It is not capable of handling/estima ting the impact of indirect measures such 
as NECD. 
The annual emissions ceilings in the NE CD come into force in 2010. Currently, 
several Member States may have difficulty in attaining their ceilings for nitrogen 
oxides. This is not a widespread probl em however. If ceilings for particular 
pollutants are met after the at tainment date of 2010, then our current analyses will 
have over-estimated the costs associated wi th the policy scenarios. This is because 
costs associated with attainment of the NECD should be associ ated with existing 
legislation rather than the thematic stra tegy. Member States will take the same 
measures either before or after 2010, th e issue of whether the costs should be 
attributed to the thematic strategy or implementation of existing legislation. 
Other legislation could have a significant i ndirect impact on air quality. For instance, 
changes in the common agricultural pol icy could have an impact on ammonia 
emissions. Implementation of the Landfills Directive (which shifts waste from landfills to incinerators) coul d change air emissions as we ll. As mentioned above, the 
legislation to redu ce energy-related CO
2 emissions is included147 and an alternative 
scenario without additional climate cha nge measures beyond the “Kyoto Protocol” 
has been introduced so that the specific im pact of these measures on air quality can 
be assessed.  
METHODOLOGY FOR QUANTIFYING THE HEALTH IMPACT OF AIR POLLUTION  
The methodology followed in the impact assess ment aimed neither systematically to 
over-estimate nor under-estimate the health  effects. The impact assessment is 
consistent with the WHO’s “Systematic Review of Health Aspects of Air Quality in 
Europe”148 and with the advice of the UNECE WHO Joint Task Force on Health. 
Health impacts have been estimated for both particulate matter and ozone for short-
term (acute) and long-term (chronic) exposure. 
Particulate matter 
The figures for particulate matter are base d on the health evidence on the fine 
fraction (PM 2.5) based on long-term exposure. Th e WHO proposed using the risk 
factors derived from the epidemiological st udies carried out in the USA, because of 
the shortage of such studi es in the EU to date.  
                                                 
147 See report on Energy Baseline S cenarios for the CA FE Programme. 
148 See http://www.euro.who.int/document/e79097.pdf  and answers to follow-up questions 
http://www.euro.who.int/document/e82790.pdf  
 
EN 149   EN The RAINS model and the health impact as sessment are based on the advice from 
the WHO Joint Task Force on Health. Th e RAINS model has been extended to 
include the additional effect of urban air pollution (through the City Delta project149). 
WHO advice has been drawn on to estimate the changes, in terms of loss of statistical life expectancy, attributable to changes in the anthropogenic fraction of 
PM
2.5 emissions. The Joint Task Force recommended applying a linear 
concentration-response functi on associating changes with health impacts (6% change 
in mortality hazard per 10 µg/m3 PM 2.5). This excludes the health impacts of 
particulate matter from natural sources and of secondary organic aerosols. Secondary 
organic aerosols have not been included in  the RAINS model for lack of information. 
A substantial fraction of th e secondary organic aerosols could be of anthropogenic 
origin; the impact of anthropogenic emi ssions is underestimated in the RAINS 
model. In the cost-benefit analysis the RA INS assessment of the health impact due to 
particulate matter was supplemented by speci fic quantification of infant mortality 
and assessment of morbidity due to partic ulate matter. Using life-table methods, the 
analysis expresses health impacts in term s of years of life lost because of air 
pollution. However, there are methodological difficulties with estimates of the value 
of a life year (VOLY). Therefore, an altern ative method to estimat e the effect of air 
pollution has been used, in the form of es timation of premature mortality. The value 
of statistical life (VSL) has been applied to premat ure mortality. However, the 
methods used to derive the number of prem ature deaths are approximate and to some 
extent over-estimate the true fraction attributable. 
The analysis of mortality from long-term exposure applies only to adults. There is 
now substantial evidence that higher levels of air pollution are associated with a wide 
range of adverse effects on foetal and in fant health, including mortality. In this 
impact assessment, the cases attributable ha ve been estimated, rather than life-years. 
This is consistent with the approach used in the USA. 
                                                 
149 http://rea.ei.jrc.it/netshare/thunis/citydelta/  
 
EN 150   EN City-Delta project 
The objective of the City-Delta project is to e xplore systematic differences (deltas) between 
rural and urban background air quality, how these deltas de pend on urban emissions and 
other factors, how they vary across cities and how  they vary across models. In the first phase 
of the project general differences were explored  for numerous cities and over a cross-section 
of European models. In the second phase (City -Delta II) a limited number of models on 
regional and urban scale and a limited number of  cities (Berlin, Milan, Paris and Prague) 
were selected to derive functional relationships between air pollution at regional level and 
the urban background levels detected. 
The functional relationships derived are releva nt for the situation in European cities and 
depend on key parameters such as wind speed and emission densities at low and high 
sources. So far functional relationships have been developed for the annual average urban 
background PM 2.5 concentration in European cities. The calculated values for urban 
background concentrations have been compared to the data obtained on PM 2.5 from 
monitoring in a wide range of European c ities and are generally within the 30 percent 
difference band. Intercomparison shows systemat ic underestimation by the calculated values 
compared to the monitored values. Other di screpancies remain for some cities due to 
topography (e.g. valleys or basins) which have not been properly resolved and represented in 
large-scale models along with issues linked with  the cities effectively divided into several 
grids in the large-scale EMEP model.  
The functional relationships for the annual averages for PM 2.5 have been used to assess more 
accurately the exposure and health impact on the European urban population. The same 
functional relationships are used for assessm ent of the future urban increment of PM 2.5 and to 
assess the effects of implementation of Community-wide emission control measures. 
Further development of the methodology and va lidation of the functional relationships are 
expected later. This would include functi onal relationships for annual urban background 
ozone levels and measur es to improve the parameterisation of the functional relationships for 
PM 2.5 and to validate the relationships. 
Ozone 
Effects of daily ozone exposure on ‘acute ’ mortality have been calculated at 
concentrations greater than  35ppb (parts per billion, whic h is equivalent to 70 µg/m3) 
as a maximum 8-hour mean. A risk estimate of a 0.3% increase in daily mortality per 
10 µg/m3 ozone has been used. This factor is based on the meta-analysis from 
European studies on the health impact of  ozone and part of the WHO systematic 
review. The health impacts here can best be described as “deaths brought forward” 
because of ozone. This signifies that people whose deaths are brought forward by 
higher air pollution belong largely (but no t exclusively) to a group of sensitive 
people with cardio-re spiratory conditions. Some peopl e affected by ozone have a 
disease or are elderly. In at least so me of these cases, the actual loss of life 
expectancy is likely to be small – the death might have occurred within the same year 
and, for some, might only be brought forw ard by a few days. In this impact 
assessment it has been assumed that, on  average, each death has been brought 
forward by 12 months. 
The quantifiable impact on morbidity incl uded major effects, such as hospital 
admissions and the development of chronic respiratory disease, plus effects which 
are less serious, but are likely to affect  a greater number of people, for example 
 
EN 151   EN changes in frequency of use of medicines to  control asthma and days of restricted 
activity. When the impact and the values we re combined in the analysis the most 
important health-related issues to emerge were mortality, restricted activity days and chronic bronchitis. 
Atmospheric modelling 
Detailed baseline reports on quantification of the environmental impacts and health 
effects have been published separately (see Annex 1). The full EMEP atmospheric model (to predict air concen trations and deposition) us ing the average for the 1997, 
1999, 2000 and 2003 meteorological years has been  calculated to a ssess the impact 
of air pollution on human heal th and the environment. However, as the EMEP model 
takes several months to calculate the im pacts of different RA INS scenario runs 
covering all the meteorological years, in th is impact assessment the most typical of 
the four years, i.e. 1997, was selected and all the model calculations made 
consistently assumed 1997 meteorological conditions.  
While for the EU as a whole 1997 was a rela tively normal meteor ological year, this 
is not necessarily the case in any particular Member State. However, these differences between meteorological years do  not matter much as long as the impact 
assessment is not carried out  on measures that would a ffect a single particular 
Member State. As the Thematic Strategy on Air Pollution imposes no direct obligations on specific Member States the c hoice of 1997 as the reference year seems 
justifiable.  
Consequently, the output from the RAIN S model for the 1997 meteorological year 
was used for the cost-benef it analysis for this impact assessment. 1997 is the only 
year for which source-receptor relationshi ps are available for use in the RAINS 
integrated assessment model. Although the RAINS model is an approximation of the 
full EMEP model, it has been used to provide  a consistent data set for the baseline 
years of 2000 and 2020 and for the different le vels of ambitions. This allows sensible 
analysis of incremental costs and benefits for each of the policy scenarios compared 
to the baseline years (see table below). 
Differences in quantification of  the mortality effects of PM
2.5 between the full 
EMEP atmospheric model and RAINS 
 RAINS (1997 only) Full EMEP model (four 
meteorological years) 
 2000 2020Differ-
ence 2000 2020 Differ-
ence 
Average loss in statistical life expectancy 8.1 5.0 -3.1 8.6 5.4 -3.2 
Thousand life 
years lost 3.6 2.5 -1.1 3.1 1.9 -1.2 
However, because the 1997 meteorological year is used throughout the impact 
assessment, the baseline impacts presented in this impact assessment are slightly 
 
EN 152   EN different to those indicated in the CAFE baseline report (2004)150. However, as can 
be seen in the above table, the differen ce between the reference year (2000) and the 
baseline for 2020 is very small. 
Throughout this impact assessment, morta lity due to PM can be expressed on the 
basis of four different metrics (see tabl e below). The RAINS integrated assessment 
model can optimise the cumulative reduction in life years lost. In addition, RAINS 
can produce an estimate of the average stat istical life expectancy as a result of 
different measures to reduce air polluti on. The CBA model annua lises the cumulative 
life years lost. The advantage of the annual fi gure for life years lost is that it can be 
compared with the annual costs of reducing air pollution. Finally, as  it is difficult to 
communicate statistical life expectancies or life years lost to the general public, the 
CBA methodology gives an alternative metric of mortality due to particulate matter. 
This is the number of premature deaths. Th ese two metrics can be  used to calculate 
the monetised benefits of reducing air pollution. 
Correspondence between different PM 2.5 metrics used in the impact assessment 
 Average loss in 
statistical life 
expectancy 
(months) Cumulative  life 
years lost 
(million years) Annual  life 
years lost 
(million years) Annual 
premature 
deaths 
(thousands) 
(Source) (RAINS) (RAINS) (CBA) (CBA) 
2000 8.07 203 3.62 348 
Baseline 2020  5.46 137 2.47 272 
Scenario A  4.37 110 1.97 218  
Scenario B 4.14 104 1.87 206 
Scenario C 4.02 101 1.81 200  
MTFR 3.82 96 1.72 190  
Source: RAINS and CAFE CBA. 
Note: All calculations are based on the 1997 meteorological year. 
MODELLING FRAMEWORK USED FOR CAFE  INTEGRATED ASSESSMENT  
The models are used to understand, on the one  hand, what the situat ion is likely to be 
in the future if no (furthe r) action is taken (the “basel ine”) and, on the other hand, the 
environmental and economic implications  of policies and measures to reduce 
emissions (scenarios/policy options). Th e modelling framework was made up of 
RAINS, PRIMES, the cost-benefit analys is and GEM-E3 and is used for multi-
sectoral assessment of policy to impr ove air quality, including an optimisation 
procedure in the RAINS model. 
                                                 
150 Baseline Scenarios for the Clean Air for Europe (CAFE) Programme (IIASA, October 2004 – Corrected 
February 2005) available at http://europa.eu.int/comm/environment/air/cafe/general/pdf/cafe_lot1.pdf  
 
EN 153   EN Modelling framework used in the impact assessment 
RAINSPRIMES
(Partial 
Equilibrium on 
Energy Market)Activity in 
Agriculture and 
other sectorsGDP, 
Demographic 
assumptions
Activity
Emission 
Factors
Emissions
Air Quality
ImpactTarget SettingPolicy  
Options
Cost-Benefits 
AnalysisGEM E-3
(General 
Equilibrium Model)Energy
Scenarios
EMEP
(Source-
response 
relationships)
Macro-economic & 
Competitiveness 
Impact
 
 
RAINS integrated assessment model 
The Regional Air Pollution Information and Simulation (RAINS) model151 has been 
developed by the International Institute for Applied Systems Analysis (IIASA). 
RAINS has been used, for example, for cal culation of the ceilings in the National 
Emissions Ceilings Directive as well as analysis of the Large Combustion Plants 
Directive. In the CAFE Progr amme, RAINS is used to de velop (1) a robust baseline 
scenario; (2) an operational integrated  assessment modelling (IAM) framework 
allowing a large number of scenarios to be  analysed within CAFE; (3) scenarios 
reflecting the various options  for improving air quality in  the enlarged EU for the 
period up to 2020.  
The model combines information on economic and energy development, emission 
control potential and costs, atmospheric di spersion characteristics and environmental 
sensitivities towards air pollution. It quant ifies the contributions of the main air 
pollutants152 to threats to human health posed by fine particulates and ground-level 
ozone as well as to the ri sk of damage to ecosystems from acidification, excess 
nitrogen deposition (eutrophication) and expos ure to high ambient levels of ozone. 
The model has been subjected to a pe er review in the context of CAFE153. 
                                                 
151 A detailed description of the RAINS model, on-line access to certain parts of the model as well as all 
input data to the model are available on the Internet ( http://www.iiasa.ac.at/r ains/review/index.html ). 
152 RAINS includes the following pollutants: sulphur dioxide (SO 2), nitrogen oxides (NO x), ammonia 
(NH 3), non-methane volatile organic compounds (VOC) and primary emissions of fine (PM 2.5) and 
coarse (PM 10 - PM 2.5) particles. It also includes estimates of emissions of relevant greenhouse gases 
such as carbon dioxide (CO 2) and nitrous oxide (N 2O). Work is in progress to add methane (CH 4), as 
another direct greenhouse gas, as well as carbon monoxide (CO) and black carbon (BC) to the model 
framework. 
153 http://europa.eu.int/comm/environment/air/cafe/activities/rain_model.pdf   
 
EN 154   EN RAINS distinguishes 21 categories of fuel  use in six economic sectors. The time 
scale extends from 1990 to 2020. Emission estimates are based on national data 
reported to relevant intern ational organisations such as the Convention on Long-
range Transboundary Air Pollution and th e UN Framework Convention on Climate 
Change (UNFCCC).  
Future economic trends – and more specifically the development of the energy 
supply system, of the transport sector and of agriculture – are exogenous input to the 
RAINS model. Data on transport and ener gy activity were derived from “European 
Energy and Transport – Trends to 2030”  based on the PRIMES model, while 
transport emission factors were taken from the sources shared by TREMOVE. 
Agricultural projections cam e from the CAPRI model. 
Flow of information in the RAINS model 
Economic
activitiesEmission control
policies
Agricul ture
NOxemissionsSO2emissions
Solvents, fuels,
industryEnergy useNH3dispersion
S dispersion
VOC emissionsNH3emissions
TransportCritical loads
f. acidification
C ritical loads f.
eutrophicationNOxdispersion
O3form ationNH3control
& costs
NOx/VO C  
control&costs
VOC control
& costs
Emission 
control costsC ritical levels
for ozoneEnvironmental
targets
Pri mary PM 
dispersionOther activitiesPM control
& costsPri mary PM 
emissionsSecondary 
aerosols
PM Popul ati on 
exposureSO2control
& costs
NOxcontrol
& costs
O3Population
exposureEconomic
activitiesEmission control
policies
Agricul ture
NOxemissionsSO2emissions
Solvents, fuels,
industryEnergy useNH3dispersion
S dispersion
VOC emissionsNH3emissions
TransportCritical loads
f. acidification
C ritical loads f.
eutrophicationNOxdispersion
O3form ationNH3control
& costs
NOx/VO C  
control&costs
VOC control
& costs
Emission 
control costsC ritical levels
for ozoneEnvironmental
targets
Pri mary PM 
dispersionOther activitiesPM control
& costsPri mary PM 
emissionsSecondary 
aerosols
PM Popul ati on 
exposureSO2control
& costs
NOxcontrol
& costs
O3Population
exposure
 
 
The RAINS model covers a variety of tec hnical means for reducing emissions of the 
pollutants considered. The model estimates th e potential rate of utilisation of the 
available technologies and the specific costs for each count ry, taking into account the 
most important country-specific parameters . The description of the emission control 
options comes from the RAINS databases, updated in collaboration with the Centre 
of the CLRTAP’s Expert Group on T echno-Economic Issues (EGTEI). 
The RAINS model uses functional relati onships characterisi ng the link between 
annual emissions and the spec ific metric of exposures154 relevant to the individual 
                                                 
154 For instance, deposition of acidifying and eutroph ying compounds is expressed as annual deposition 
rates, reflecting the cumulative nature of acidifica tion and eutrophication. For fine particles, mortality 
 
EN 155   EN environmental end points considered in RAIN S. These relationships are derived from 
the EMEP Eulerian atmospheric dispersion models155 which describe chemical 
formation and pollutant transport in the at mosphere between the sources of emissions 
and the receptor sites, using a grid system with 50 km x 50 km spatial resolution for calculating rural background concentrations  and deposition of pollutants. The 
RAINS model includes grid-s pecific information on the share of urban and rural 
population, the age structure, the populat ion trend up to 2050 and age-specific 
mortality rates.
 
Health impacts of PM and ozone 
The EMEP model used by RAINS has certai n drawbacks, such as not taking into 
account high pollution peaks, over-estimating PM and ozone levels in winter and not 
describing the daily variance in PM and oz one levels. For nitrates, one important 
point to note is that EMEP uses the highly uncertain monitoring data as there are currently no measurements for total nitrat e. Consequently, winter values for total 
nitrate are overestimated in EM EP as well as values for NH
3 and NH 4+. The 
problems with wet deposition of sulphate in EMEP can be summed up as: it rains too often and too little in th e model. In the case of NO
x, concentrations are 
underestimated, especially for ground-level sources, as the EMEP model starts to 
work from 19 m on. For PM, seasonal va riations in emissions are always 
underestimated (but less in winter) and unaccounted masses (i.e. measurement 
artefacts) or particles bound to water dropl ets are only partly taken into account. Up 
to now RAINS has improved on some of thes e issues but the fo llowing points are not 
yet taken into consideration: (a) secondary  aerosols, e.g. from VOC-based emissions; 
(b) natural background; (c) th e PM fraction that is cu rrently not identified by 
measurements or forms measurement artefacts; (d) seasonal effects in winter and 
summer in Southern and Northern Eur ope, which can be improved and on which 
work is in progress; (e) for NO x, influences of VOC emissions and vice versa; and 
(f) non-linearities of  effects between PM 2.5 and the entire nitrogen fraction and 
SOMO35 changes for ozone in spring (possibl y due to the titration of ozone from 
free troposphere) – these non-lin earities are also included.  
For PM and ozone no thresholds have been detected. Consequently, a limit approach 
or an approach based on cutting ‘ bad issues ’ or peak concentration would not be 
suitable. Here, it should be noted that on the one hand these data are mostly based on epidemiological studies which naturally have  a lower sensitivity for detecting such a 
threshold compared to detailed toxicological studies either in vivo  or in vitro . On the 
other hand, it is important to recognise th at these conclusions are also based on in 
vivo animal studies and cohort studies (whe re a defined population group is followed 
over a long period of time, e.g. 5 to 10 y ears or even longer – these cohorts are 
difficult to establish and even more diffi cult to maintain, which means that ongoing 
financial support is needed). PM exposure is  linked to arrhythmia (i.e. a deviation 
from or disturbance of the normal heart rhyt hm). Mortality is linked primarily to PM 
                                                                                                                                                        
 
impacts are estimated on the basis of long-term cohort studies, which were originally regressed against 
annual mean concentrations of fine particles. For ground-level ozone, vegetation-relevant exposure will be expressed in terms of an AOTx, i.e. hourly ozone concentrations in excess of a certain threshold 
accumulated over the vegetation period. 
155 For a description of the EMEP model and its results see http://www.emep.int . 
 
EN 156   EN and not to ozone, while cardiovascular dis eases are another major effect (e.g. linked 
to black smoke (soot)). In addition, most effects will occur at ‘ normal 
concentrations ’ for PM 2.5, such as ~5-20µg/m3, although another important point to 
note is that different types of PM 2.5 are not equally hazardous – more work is 
essential here, including more detailed m onitoring. Moreover, the chronic effects of 
PM on mortality seem to outweigh a ll the acute effects and so far PM 2.5 is seen as an 
appropriate indicator for these effects. 
RAINS does not address compliance in  local short-term hot-spots reporting 
exceedance in terms of air pollution. RAINS uses  the evidence from cohort studies. It 
also uses the data from the US cancer so ciety together with the life tables from 
EUROSTAT. Amongst the critical assumpti ons made in the model, no threshold 
together with a linear dose response cu rve is assumed for its methodology and the 
impact linked to anthropogenic PM  is extrapolated beyond 35µg/m3 PM 2.5. 
Moreover, no effects are assumed from natu ral PM despite the fact that these are 
used positively to help patients with pulm onary-based diseases. Also, no effects for 
younger population groups below 30 years old and infant mortality are included in 
RAINS. Nor are secondary organic aerosols  and natural sources  for PM included. 
For PM, a loss of life expectancy of between 3 and 13 months is estimated and for EU-25 from 6 to 9 months have been include d. Finally in relation to PM, it must be 
remembered that the accuracy of the output from the RAINS model on health 
depends on the accuracy of the dispersion calculation and the significant meteorological impacts. For oz one, much smaller effects are taken into account in 
RAINS than for PM. A relative risk factor of an 1.003/10 µg/m
3 increase in the daily 
maximum 8-hours mean together with a ‘ cut-off ’ value of 35 ppb from WHO 
(i.e. SOMO 35) is incorporated in RAINS.  Also, a premature death by 6 months due 
to ozone is assumed. The peer review c oncluded that RAINS is following the WHO 
approach and recommended further improve ments relating to its underestimation of 
the health effects from both ozone and PM – in urban areas only in the case of PM. 
On ozone-related health effect s, the model’s description of  the regional concentration 
of ozone and its relationshi p with emissions within Eu rope is acknowledged as 
reliable, although no spatial re solution is given in the urban-scale ozone exposure 
assessment, and non-lineari ties in response to NO x and VOC controls remain to be 
resolved. (The importance of background ozone will be addressed in the course of further development of the EMEP/RAINS  framework.) RAINS has followed the 
WHO recommendations and health effects are underestimated by not including other 
health outcomes (only short-term effects on mortality are estimated) and the use of the 35 ppb cut-off (no effects below 35 ppb are quantified). 
On PM, RAINS has followed the WHO recommendations. Only WHO exposure-
response relationships for mortality in adults were included in RAINS. Emission control is limited to the effects of anth ropogenic primary part icles and secondary 
inorganic aerosols, resulting in considerable underestimation of PM
2.5 concentrations 
from the EMEP model, as secondary orga nic and natural aerosols were omitted.  
Only exposure-response functi ons reflecting the effect of  urban background exposure 
may currently be applied in RAINS, re sulting in a spatial scale too large for 
modelling urban air quality to quantify the full magnitude of health effects and in 
inconsistency between measured and m odelled urban air concentrations. RAINS 
modelling of urban air quality has been im proved by incorporating the revised results 
 
EN 157   EN of the City Delta project156, i.e. wind speed influences, population density differences 
and reductions of the EMEP grid cells from 50 km x 50 km to 2, 5 and 10 km. 
However, the validation was hampered by the shortage of monitoring data from 
reliable sources. For natural PM, levels of 1-3 µg/m3 were used. These were 
somewhat arbitrary based on literature, which shows values of about 1 µg/m3 for 
Northern Europe and about 3 µg/m3 for Southern Europe. For Spanish cities the 
RAINS model underestimates the PM 2.5 concentrations compared to actual 
measurements. It is not yet clear if this is  due to the measurements (this seems to be 
more likely given the current difficulties with PM measurements) or to the modelling. The RAINS peer review also clea rly highlighted that  these difficulties 
need to be solved. Local reductions in cities lying in valleys have a dramatic influence on the RAINS scenarios compar ed to cities located in flat areas. 
Impact on ecosystems 
For acidification and eutrophication, RAIN S relies on the EMEP model. So far 
comparability has been achieved between th e data from actual monitoring and the 
results from modelling. However, as hi ghlighted by the RAIN S peer review, the 
static modelling approach currently used by the RAINS model will need to be 
replaced in the future by the dynamic modelling approach, including impacts on 
biodiversity such as changes in the presence of populati ons of different species. 
– On acidification, atmospheri c depositions calculated fo r coastal areas by EMEP 
do not reflect the effects of shipping sour ces. Deposition in complex terrain (hills, 
forest edges, etc.) is stil l underestimated, which could lead to underestimation of 
the need for controls. 
– No final agreement has yet been reached on how results from dynamic modelling 
could be handled in RAINS,  but application of the dyna mic approach may also be 
limited by the lack of input data in cluding deposition of base cations. 
– On eutrophication, the spatial scale of the reductions in the nitrogen impact (like 
that of urban air quality) is small in re lation to the 50 km x 50 km scale of the 
RAINS model. Critical loads are probably smaller than in present assessments and 
this could lead to underestimation of the controls required in  order to achieve a 
certain environmental status. 
– The fixed critical loads approach currently  used will not be able to pick up the 
dynamic aspects involved in eutrophi cation of ecosystems and further 
development of dynamic models is needed in order to include nitrogen processes 
in vegetation and soils. 
On the effects of ozone on vegetation, th e AOT30 or AOT40 are well established for 
measuring effects and it is recommended that  they be used, while  the review of the 
EMEP model concluded that source-receptor matrices can be established for policy 
purposes. Humidity and climatic conditions such as light and temperature together 
with nutrient availability are taken into account. RAINS does not yet apply a flux 
approach for crops. In addition, RAINS need s further improvements on small effects 
                                                
 
156 http://rea.ei.jrc.it/netshare/thunis/citydelta/  
 
EN 158   EN related to grid-average data such as the sulphur/ammonia co-deposition which 
actually takes place. Howe ver, it must be noted that this is negligible from the overall 
European point of view but can have a dramatic influence when local emission 
reduction measures are implemented in differe nt regions in Member States, as shown 
by national models such as the ASAM model used in the UK. These drawbacks were highlighted in the RAINS peer review. 
Emission control 
For a given activity scenario, RAINS is used  to identify the lowest-cost combination 
of emission controls meeting user-supplied air quality targets, taking into account regional differences in emission cont rol costs and atmospheric dispersion 
characteristics. The optimisation function is used to search for the lowest-cost mixes of controls for the six pollutants (SO
2, NO x, VOC, NH 3, primary PM 2.5, primary 
PM 10-2.5 (=coarse PM)) over the various sector s of the economy in all European 
countries which would simultaneously achieve user-specified targets for human health impacts (e.g. expressed in terms of reduced life exp ectancy), ecosystems 
protection (e.g. expressed in terms of excess acid and nitrogen deposition) and 
maximum allowed violations of WHO guide  values for ground-level ozone, etc. 
In the RAINS model, emission control costs are evaluated at the production level, not 
at the level of consumer prices. Any mark-ups added to production costs by 
manufacturers or dealers do not represent actual resour ce use and are therefore 
ignored. Any taxes added to production costs are similarly ignored as transfers. The 
same applies to subsidies. 
From the three components of expenditu re on emission control (investment, fixed 
operating costs and variable operating cost s), RAINS calculates annual costs per unit 
of activity level. Subsequently, these co sts are expressed per tonne of pollutant 
abated. The annual cost method is applied, ta king into account a un iform interest rate 
of 4% and constant prices for the year 2000. 
Some of the parameters are considered common to all countries. These include 
technology-specific data, such as removal efficiencies, un it investment costs, fixed 
operating and maintenance costs, as well as parameters used for calculating variable 
cost components such as the extra de mand for labour, energy and materials. 
Country-specific parameters ch aracterise the type of cap acity operated in a given 
country and its operating conditions. These parameters include the average size of installations in a given sector, operating hours, annual fuel consumption and vehicle 
mileage. Costs for labour, electricity, fuel and other materials as well as for waste 
disposal also fall in to that category. 
Although based on the same principles, th e methodologies for calculating costs for 
individual sectors need to reflect the re levant differences, e.g. in terms of capital 
investment. Separate formulas are theref ore developed for stationary combustion 
sources, stationary industr ial processes and mobile sources (vehicles).  
The peer review highlighted that a sensitiv ity analysis must be performed at country 
and sector level in order to gain a bette r understanding of any po ssible biases. This 
work is currently in progress. Also, in the future RAINS should be able to obtain 
 
EN 159   EN more up-to-date data on technologies and th eir costs from differe nt data providers, 
notably EGTEI. 
The RAINS model deals mainly with technical measures. Th is could introduce a bias 
in the results in that it over-emphasises costly (end-of-pipe) solutions and overlooks 
less expensive options implied or inherent in  structural changes and reactions of the 
economy to market stimuli. However, if the energy mix includes such changes 
RAINS would calculate these effects. For ex ample, the inclusion of climate change 
policies in the impact assessment on the Thematic Strategy on Air Pollution has induced certain structural changes and th ese have been estimated in the RAINS 
model. 
The inclusion of non-technologi cal measures, in particular  in the transport sector,
157 
would produce a more accurate estimate of  the cost of policy. If non-technical 
measures are included, environmental benefits could be realised more cost-effectively.  
Other basic general drawbacks include the quality of monitoring data (bearing in 
mind the current problems with PM monitoring, sampling and measurements as inputs; the uncertainties and classificati ons of different emission data and their 
aggregation levels such as those from VOCs ; incorporation of vari ability of scenarios 
based on different meteorological years; and inclusion of improvements in relation to 
the current 50 km x 50 km grid size. 
PRIMES energy market model 
The PRIMES
158 model is used in conjunction wi th the RAINS model to feed in 
energy production and consumption in differe nt Member States. It  was developed by 
the National Technical University of At hens (NTUA) and has been used, among 
others, by DG TREN for “European Ener gy and Transport – Trends to 2030”. 
The model determines the equilibrium by fi nding the prices of each energy source at 
which the quantity producers see fit to s upply matches the quantity which consumers 
in the Member States wish to use. The equi librium is static (within each time period) 
but repeated in a time-forward pat h, under dynamic relationships. The model 
represents in detail th e available energy demand and supply technologies and 
pollution abatement technologies. It reflects considerations about market economics, 
industrial structure (e.g. imp act of liberalisation), ener gy/environmental policies and 
regulations. PRIMES is designed for forecas ting, scenario construction and analysis 
of policy impact. It covers a me dium- to long-term scale (2030). 
 
                                                 
157 The original plan was that TREMOVE would provide sectoral input data for RAINS in the context of 
the CAFE Programme. This proved impossible due to the timetable for the two projects (as the final version of TREMOVE was not scheduled until a point when RAINS was already performing 
simulations). In the context of the forthcoming review of the NEC Directive, TREMOVE will be 
recalibrated to ensure consistency with RAINS and will be used to analyse technological measures as 
well as to introduce elements reflecting the reactions of the economy to market stimuli in the process of 
optimisation of transport measures. 
158 http://www.e3mlab.ntua.gr   
 
EN 160   EN Cost-benefit analysis 
The methodology has been developed under the ‘Service Contract for Cost-Benefit 
Analysis (CBA) of Air Quality Related Issues, in particular in the Clean Air for 
Europe (CAFE) Programme’.  The objective of the service contract was to establish 
the capability to assess the costs and benefits  of air pollution po licies and to analyse 
scenarios generated within the CAFE  Programme. The methodology paper: 
– defined the overall rationale for the CBA,  in particular by demonstrating how it 
builds on the impact assessment carried out in the RAINS integrated assessment model and the TREMOVE transport model; 
– identified a general framework for quan tifying impacts, including links to the 
other models; 
– identified the assumptions and data (stock  at risk inventorie s, response functions, 
unit valuations) that will form the ba sis for quantification of the benefits; 
– set out the approaches for extending th e CBA to unquantifiable impacts and for 
addressing other uncertainties; 
– took account of the views expressed by stakeholders during the consultation 
process from December 2003 to October 2004; 
– took account of the suggestions of the inde pendent scientific peer review which 
was carried out from July to September 2004. 
The role of cost-benefit a nalysis in the CAFE Programme 
The links between different pollutants and th e direct effects listed in the table below 
define the rationale behind the CAFE Progr amme: the only way to develop the most 
cost-effective strategies for control of these impacts is through simultaneous 
reduction of the pollutants covered by CAFE. 
Direct and indirect impacts addresse d in the cost-benefit analysis 
 PM 2.5 SO 2 NO x  VOCs NH 3 
Direct impacts      
Tropospheric ozone formation,  leading to effects on 
health, crops, materials and ecosystems   9 9  
Health impacts from primar y pollutants and secondary 
pollutants (ozone and aerosols)  9 9 9 9 9 
Ecosystem acidification  9 9  9 
Ecosystem eutrophication   9  9 
Damage to building and other materials  9 9   
Indirect impacts      
Changes in greenhouse gas em issions as a result of 
measures employed to control CAFE pollutants 9 9 9 9 9 
Wider social and economic effects from impacts and 
the measures recommended for their control 9 9 9 9 9 
The relationship between the CBA and the ot her models and activities linked to the 
CAFE Programme is illustrated in the diag ram below. The links from the RAINS and 
 
EN 161   EN CBA models to scenario development and ta rget setting are shown by a dashed line 
to highlight the fact that  although these processes will be influenced by model 
outputs, they are not direct outputs of the models. 
It is important to draw a distinction between the roles of the RAINS and CBA 
models. RAINS identifies a cost-effective se t of measures for meeting pre-defined 
health and environmental quality targets. The CBA model takes this analysis a stage 
further by assessing the magnit ude of benefits and whethe r the overall benefits are 
higher or lower than the estimated costs. 
 
Scenario development 
and target setting
EMEP
Modelling of pollutant 
concentration across 
Europe on 50 x 50 kmgrid
Other models
TREMOVE
PRIMES
Etc.RAINS model
Processing of
pollutant data
Assessment 
vs. targets, e.g.
critical loads
exceedence, mortality
Cost analysisCBA
Quantification of impacts
Health, crops, 
materials, social and 
macroeconomic
effects, etc.
Monetisation of impacts
Where possible
Comparison of costs 
and benefits
Extended CBA
Related activities
EC DG Research Programmes
UNECE Working Groups under Convention on Long-Range 
Transboundary Air Pollution (CLRTAP)
WHO Europe commentary on air pollution impactsActivities specific to CAFE
 
Quantification of benefits and comparison with costs 
The methodology largely builds on the ExternE159 methodology called Impact 
Pathway Analysis that, starting from the so urces of pollution and actual emissions of 
pollutants, identifies concentrations and e xposure and finally arrives at the estimation 
of impacts and their monetary valuation. Th is approach follows a logical progression 
through the following stages: 
– quantification of emissions (in CA FE, covered by the RAINS model); 
– description of pollutant dispersion across Europe (in CAFE, covered by the 
RAINS and EMEP models); 
– quantification of expos ure of people, environments a nd buildings that are affected 
by air pollution; 
                                                 
159 European Commission, DG Research, ExternE – Externalities of Energy, EC, Luxembourg, Vol. 1 to 
10, 1995 and 1999. 
 
EN 162   EN – quantification of the im pacts of air pollution; 
– valuation of the impacts; and 
– description of uncertainties (in CAFE, with specific reference to their effect on the 
balance between the costs of pollution control quantified by the RAINS model 
and the associated benefits). 
The quantification of impacts varies, de pending on the availability of data and 
models: 
– For health impacts, damage to crops and damage to building materials, it is 
generally possible to quantif y the impacts including their values. Uncertainties can 
be addressed using statistical me thods and sensitivity analysis.  
– For damage to ecosystems and cultural he ritage, it is possible to quantify the 
impacts relative to a measure of risk. Ho wever, it is not possible to value these 
impacts in the analysis. Examples of risk measures include: 
– the rate of deposition of acidifying pollu tants relative to the critical load 
for acidification (as an indicator of the risk of acidification to 
biodiversity); and 
– the rate of corrosion of building mate rials as an indicator of risks to 
historic monuments. 
– Other impacts are not currently quantifia ble in terms of impact or monetary 
value, permitting only a qualitative analysis. Examples include reduced visibility due to air pollu tion and the social dimensions of health impacts. 
Given the limits to quantification, an  ‘extended CBA’ has been developed. The 
purpose is to provide a complete picture of  whether the effects that have not been 
valued or quantified could have a signifi cant effect on the balance of costs and 
benefits. For each impact a data sheet ha s been prepared containing the following 
types of information: 
– definition of impact; 
– knowledge of the link to air pollution; 
– distribution of impacts across Europe; 
– contextual information on the scale of associated economic effects; 
– consideration of whether th e impact seems likely to be  important as far as the 
CAFE Programme is concerned, givi ng reasons for conclusions drawn. 
Assessing the benefits of reduced  air pollution for human health 
Earlier cost-benefit analysis has shown that  health impacts will generate the largest 
quantified monetary benefits when air pollution is reduced. The pollutants of most 
concern here are fine particles and ground- level ozone, both of which occur naturally 
 
EN 163   EN in the atmosphere. Fine particle concentra tions close to ground level are increased by 
emissions from human activity, whether th rough direct emissions of ‘primary’ 
particles or indirectly th rough the release of gaseous  pollutants (especially SO 2, NO x 
and NH 3) which react in the atmosphere to form ‘secondary’ particles. Ozone 
concentrations close to ground level are increased by anthropogenic emissions, 
particularly of VOCs and NO x. 
The quantification of health impacts addre sses the impacts related to both long-term 
(chronic) and short-term (acute) exposur es. The quantification deals with both 
mortality (i.e. deaths) and morbidity (i.e. il lness). The mortality effects quantified in 
the CAFE cost-benefit analysis include impacts on infants as well as adults. The morbidity effects that can be quantified include major effects, such as hospital admissions and the development of chronic respiratory disease. They also include 
less serious effects, which are likely, howev er, to affect a greater number of people, 
for example changes in the frequency of use of medicine to cont rol asthma and days 
of restricted activity. When the impact and the values are combined in the analysis, 
the most important health-related issues ar e mortality, restricted activity days and 
chronic bronchitis. 
Major advances have been made in health  valuation in recent years. The latest 
European “willingness to pay” estimates have been included in the CAFE CBA 
methodology. Accordingly, the most up-to-date information is adopted for a range of 
morbidity effects and mortality in the c ontext of air pollution. The question of the 
method which should be used to value mo rtality is still being debated. The two 
methods which can be used – value of statis tical life (VSL, applie d to the change in 
number of deaths) and value of life y ear (VOLY, applied to changes in life 
expectancy) – have contrasting strengt hs and weaknesses. For the CAFE CBA 
methodology, the independent external peer reviewers suggested that both the VSL 
and the VOLY approaches be used to show transparently the uncertainty inherent in 
these two approaches. 
Assessing the benefits of reduced air pollution for the environment 
Ozone is recognised as the most serious re gional air pollution problem for agriculture 
in Europe. The literature has linked some air pollutants other than ozone to crop 
damage (e.g. SO
2, NO 2, NH 3), but generally at higher levels than are currently 
experienced. When developing the CAFE  CBA methodology it was concluded that 
the direct impacts of these pollutants on ag riculture are likely to be small. By 
contrast, the indirect effects of these polluta nts could be significant. This is mainly 
because air pollution could stimulate th e performance of insects and other 
agricultural pests, which would then have a more severe impact on crop yield than 
they would have done without air pollution. Development of methods in this area has 
drawn, in particular, on the Integrated C ooperative Programme (ICP) on Vegetation, 
and ICP/MM (Mapping and Modelling). 
The methods for quantification of damage to  materials are based on work carried out 
by the ICP Materials Europe-wide Inte rnational Cooperative Programme and 
quantification under various studies for DG Research, particularly ExternE and 
associated projects such as GARP (Green  Accounting Research Project). The most 
significant impacts are on natural stone an d zinc-coated materials. The ‘impact 
pathway’ approach works well for applica tions in everyday life. This could, in 
 
EN 164   EN theory, be applied to cultura l and historic buildings. However, in practice there is a 
lack of data at several points in the impact  pathway with respect to the stock at risk 
and valuation. As a result, th e effects of air pollution on cu ltural heritage cannot be 
quantified and therefore need to be a ddressed qualitatively  through the extended 
CBA framework.  
The effects of acidification, eutrophicati on and ground-level ozone can be expressed 
in general terms as ranging from loss of species (e.g. trout and salmon from rivers and lakes in northern Europe) to more s ubtle effects, for example the relative 
abundance of different species in grassla nd or moorland. Stock at risk data for 
ecosystem impacts have been collated over a period of many years through the Coordination Centre for Effects in th e Netherlands. A framework for describing 
exceedance of critical loads a nd levels is included in the RAINS model. Valuation of 
these impacts is not yet possible because of limited research in this area of specific relevance to reductions in air pollutant em issions. The effects of reduced air pollution 
on ecosystems will therefore be calculated as part of the extended CBA, drawing extensively on the result s generated by RAINS. 
One major outcome of the process will be an updated BeTa table
160 which  shows the 
value of a reduction of one tonne of  pollutant in a specific location. 
GEM-E3 general equilibrium model 
Macro-economic effects have been assessed with the GEM-E3161 model, an applied 
general equilibrium model simultaneously re presenting world regions or EU Member 
States linked through endogenous  bilateral trade. GEM-E3 aims at covering the 
interactions between  the economy, the energy system and the environment. The 
model simultaneously calcula tes the competitive mark et equilibrium under the 
Walras law and determines the optimum balance for energy demand/supply and 
emission/abatement. One major aim of GEM-E3  in supporting policy analysis is 
consistent evaluation of dist ributional effects across coun tries, economic sectors and 
operators. It implicitly assumes that while the EU implemented, for instance, additional air pollution abatement policies the rest of the world would not do so. 
Although global, the model exhibits a suffici ent degree of disaggregation concerning 
sectors, structural features of energy/e nvironment and policy-oriented instruments 
(e.g. taxation). The model formulates production technologies on an endogenous 
basis allowing for price-driv en derivation of all inte rmediate consumption and 
services from capital and labour. On the demand-side the model formulates 
consumer behaviour and distinguishes betw een durable (equipment) and consumable 
goods and services. The model is dynamic,  driven by accumulation of capital and 
equipment. Technological progress is e xplicitly represented in the production 
functions and for each production factor. 
The model formulates pollution permits fo r atmospheric pollutants and flexibility 
instruments allowing for a variety of opti ons, including allocation (grandfathering, 
                                                
 
160 See http://europa.eu.int/co mm/environment/enveco/air /betaec02aforprinting.pdf   
161 GEM-E3 has been developed as a multinational collaboration project, partly funded by the European 
Commission, DG Research, 5th Framework progra mme and by national authorities. Further 
developments are continuously under way : see http://www.gem-e3.net . 
 
EN 165   EN auctioneering, etc.), user-defined bubbles for traders, various exemption schemes, 
various systems for re venue recycling, etc. 
The model evaluates the ener gy-related emissions of CO 2, NO x, SO 2, VOC and PM 
as a function of the energy consumption and abatement level per branch and per 
pollutant. These emissions are then converted  into the concentra tions/depositions of 
pollutants, taking into account the tr ansportation (between countries) and 
transformation of the polluta nts. In the final step, the damage generated by these 
concentrations/depositions of  pollutants is calculated in  physical units and valued 
through the valuation function. 
Three types of instruments are formulated : taxes, tradable pollution permits and 
emission standards (upper bounds on sectors and/or countries). A variety of policy 
regimes associated with these instrument s are considered (bur den-sharing rules, 
limits on trade, recycling mechanism). The possibility for market forces on permit 
markets is also modelled. 
Calibration of GEM-E3 to RAINS 
The emissions of the different pollutants (NO x, SO 2, VOC, PM 10 and NH 3) have been 
calibrated to the RAINS baseline scenario associating the RAINS activities with the 
GEM-E3 sectors. A distinction is draw n between emissions linked to energy 
consumption and emissions linked to the production of a given sector, depending on 
the emission source identified in RAINS. Emission coefficients were calculated for 2000 and then an evolution factor for 2000- 2020 was applied, based on the evolution 
in the RAINS data. For the emissions linked to production, only the PM and VOC emissions were adapted.  
The marginal abatement cost curves per sector and per c ountry were estimated on the 
basis of the cost curves from RAINS, af ter aggregating the data into the GEM-E3 
classification. It was not possible to derive  abatement cost curv es for all pollutants 
and all sectors, because the number of ab atement technologies considered in RAINS 
was too small for some pollutants and sectors.  
The conversion of bottom-up data from RAIN S into data for the GEM-E3 aggregate 
sectors can only be approximate. This increa ses the margins of error in the results 
with GEM-E3. The aggregate level of GE M-E3 should give a reasonably accurate 
initial evaluation of the macroeconomic im pact of policies ai ming at reducing air 
pollution. However, the analysis at sector and, in particular, Member State level is 
surrounded by relatively large uncertainties. 
The benefits of reducing air pollution are evaluated with the figures calculated by the 
cost-benefit analysis for the damage per tonne  of pollutant in each  EU Member State. 
This allows calculation of the total EU-wide benefit from the reduction in air pollution but no allocation by country. The eval uations are carried out with the ‘low’ 
damage figure from AEAT. 
The scenarios modelled in GEM-E3 
The baseline scenario in the impact assessme nt assumed that the EU will achieve its 
Kyoto objective and that it  will continue implemen ting a climate policy beyond 
 
EN 166   EN 2012. Specifically, it was assumed that a “s hadow price” of a climate policy operated 
in the PRIMES model (i.e. a recyclable CO 2 tax) would ensure some decarbonisation 
in the EU as a whole up to 2020. The “sha dow price” was assumed to be €12/tonne 
in 2010, €16/tonne in 2015 a nd €20/tonne in 2020. The revenues from the tax were 
recycled in GEM-E3 model runs thr ough a reduction in the employers’ social 
security contribution. Also it was assumed that the resource allocation induced by the 
policy occurs within the EU by imposing the condition that th e EU current account 
remains constant relative to GDP compared to the reference through a flexible interest rate. These assumptions were maintained in all policy scenarios. 
The ambition levels, as derived from the aggregation into the sectors covered by 
GEM-E3 of the reduction imposed  by RAINS, have been inco rporated as a constraint 
into GEM-E3 in 2020. The associated costs were calculated in the model, given the 
marginal abatement cost curves by sector estimated on the basis of the RAINS marginal cost curves. The additional meas ures on transport going beyond the current 
legislation have also been implemented. GEM-E3 does not incl ude all the reduction 
imposed in RAINS
162 but it includes the reduction induced by the decrease in energy 
consumption or sectoral demand due to the price increase. 
UNCERTAINTY  
If the costs and benefits of air pollution control were known with absolute confidence 
there would be no problem in comparing th e two. However, costs and benefits are 
subject to uncertainties, some of which ( on both sides of the co st-benefit equation) 
are significant. Knowledge of these uncertain ties and the availability of information 
to describe them vary. Furthermore, some uncertainties are statistical and continuous 
in nature, others relate to discrete choi ces (e.g. selection of approaches for the 
valuation of air-pollution–related mortality ) whilst yet others simply stem from a 
lack of knowledge. It is clear from this that it will be difficult to develop a fully 
consistent approach to define uncerta inty across the entire CAFE analysis. 
Consideration of uncertainty in any co mparison of costs and benefits cannot, 
therefore, be an automatic process. Aware ness needs to be raised of the component 
uncertainties of each part of the analysis . The most important of these component 
uncertainties should be highlighted and qua ntified to the extent possible. Account 
also needs to be taken of how satisfactor y the assessment of uncertainty is. Although 
assessment of uncertainty is complex, it is si mplified to an extent by the fact that a 
small number of issues are likely to dominate any consideration of uncertainty163. 
These are: 
– quantification of the mort ality impact of exposure to fine particles; 
– valuation of mortality impacts from  particles and ot her pollutants; 
– assessment of effects of ch ronic exposure to particle s on the prevalence of 
bronchitis; 
                                                 
162 For some sectors there are no ab atement cost curves (cf. above). 
163 In some situations others may become important, but in general those listed here will dominate. 
 
EN 167   EN – attribution of effects to individual species of partic le or other pollutants; 
– failure to quantify monetary benefits with respect to ecosystems; 
– inter-annual variability  in meteorology; 
– various types of uncertainty in cost estimates. 
Uncertainties in RAINS modelling 
The RAINS model is used to calculate pollution loadings, environmental impacts and 
cost-effective strategies. The RAINS p eer review team identified four key 
uncertainties associated with these calculations: 
(1) uncertainties in basic scientific understanding; 
(2) uncertainties due to assumptions and simp lifications in the ha ndling of data or 
the design of elements of the RAINS model which could introduce biases; 
(3) uncertainties due to statistical va riance in input data collection; 
(4) uncertainties related to socio-econo mic and technological development. 
It is impossible to quantify uncertainties  stemming from incomplete scientific 
information and knowledge gaps. However, sensitivity scenarios can be devised to test the model’s robustness against differences  in scientific unde rstanding (e.g. health 
impacts) and also to test different a ssumptions concerning socio-economic and 
technological development. For example, one scenario with relatively severe CO
2 
reductions and another ignoring health eff ects due to secondary aerosols have both 
been tested. In both cases the central scen arios for the Strategy were robust against 
different underlying assumptions. 
A statistical analysis was conducted of the uncertainties associated with key input 
parameters for the RAINS model usi ng error propagation analysis. When 
uncertainties in emissions, atmospheric tr ansport, deposition and critical loads are 
combined, the overall error in critical load ex ceedances is predicted to be in the order 
of 5%. This is lower than the estimate erro r for any of the indi vidual parameters due 
to the fact that the parameters  are independent of each other. 
The effects of other potential biases in the RAINS model can also be minimised by 
the way the model framework is construc ted and operated. For example, setting 
environmental targets on a relative basis (“ gap closure”) can reduce the effect of 
absolute biases. In addition, a conservative ap proach is taken to th e selection of cost 
data and the abatement potential of technol ogies to avoid overestimating the potential 
of the control strategies modelled. 
The impact assessment includes an addi tional sensitivity analysis linked with 
alternative theories on the health impact of  PM (primary versus secondary particles) 
and the implications of post-Kyoto climate regimes. Further sensitivity analyses will 
be conducted in the context of revision of the NEC Directive, such as taking into 
account national energy and agricultural pr ojections and inter-a nnual meteorological 
variability. 
 
EN 168   EN  
 
Uncertainties in cost-benefit analysis 
A variety of methods for dealing with un certainties in the CAFE-CBA have been 
investigated, including164: 
– statistical techniques, for uncertainties which can be described quantitatively; 
– sensitivity analysis, for demonstrating the effect of discrete choices made in the 
methodology, such as: 
– systematic variation in single parameters; 
– use of different methods for mortality valuation; 
– use of single years to describe me teorology in pollutant modelling; 
– bias analysis, frequently linked to gaps  in the analysis (e.g. the omission of 
abatement techniques from the cost assessment or the omission of impacts from the benefits analysis). Given that these uncertainties are by definition unquantifiable, normally they can only be dealt with subjectively. However, sufficient information exists to different iate between what is and what is not 
important and to determine the directi on of bias introduced to the analysis. 
Statistical uncertainties are investigated in depth for the benefits analysis. The report 
identifies the method to be used, likely ra nges in terms of 90% confidence intervals 
around best estimates for PM and ozone damage, and the parameters which have the 
greatest effect. Combined assessment of PM  and ozone uncertainties is a simple 
extension of the method and will be carried  out during scenario investigation. Given 
that mortality is the predomin ant impact in the PM assessmen t it is not surprising that 
the most influential uncertainties there concern quantificati on and valuation of 
mortality. For ozone, the picture is more mixed, with mortality and minor restrictions 
on activity both important contributors. When  the ‘sensitivity’ functions are added in, 
uncertainties on assessment and valuation of respiratory symptoms in adults 
predominate in the case of  ozone. None of the sens itivity functions has any 
significant effect on uncertainties in PM assessment. 
For scenario analysis the quantified variation in benefit estimates can now be used to 
quantify the probability that benefits w ill exceed the point estimates of costs 
generated by the RAINS model. Similar statis tical assessment of errors in these cost 
estimates is not yet possible. However, it is possible to investigate the effect of 
uncertainty in costs using a stepwise se nsitivity analysis. This would involve 
assessment of the probability of benefits ex ceeding a series of cost estimates varying 
by set percentages around the core estimates  from RAINS. Turn ing to sensitivity 
analysis, the following conclusions have been drawn: 
                                                
 
164 Methodology for the Cost-Benefit Analysis of th e CAFE Programme - Part 3: Uncertainty (AEAT, 
April 2005). 
 
EN 169   EN – Statistical analysis shows that variation in results due to different methods for 
mortality valuation is not as large for PM assessment as originally suspected, with significant overlap in the ranges for VOLY (value of life year) and VSL 
(value of statistical life) methods. Howe ver, it is significa nt enough to include 
separate results for the two approaches when reporting. 
– Sensitivity to differences in the risks posed  by different types of particle will be 
investigated if and when proposals ar e made for future policy assessments. 
– The effect of the use of a cut-point for the ozone health assessment will be 
factored into the stratified sensitivity analysis where there is specific concern over the effects of ozone. Where ozone is not a key driver this sensitivity is 
unlikely to be important. 
– The choice of meteorologi cal year is important for modelling pollutant 
dispersion and chemistry. It can be acc ounted for by using four different and 
contrasting meteorological years (1997, 1999, 2000 and 2003). Where this is 
not done, the effect on health impact assessment can be estimated for each 
country by reference to figures presented in the report. 
– The stratified sensitivity analysis used previously in assessment of the NEC 
and Ozone Directives and the Gothe nburg Protocol should be retained 
principally for ozone assessments. For scenarios dominated by PM it plays a smaller role because of the higher confid ence in quantification of the dominant 
impact (mortality) and the very limited effect of the functions identified in Volume 2 for sensitivity analysis. These add just a few percent to the total PM 
damage. 
The results of the EMEP, RAINS and CAFE-C BA models are inevitably subject to a 
number of unquantified biases in additio n to the uncertainties already mentioned. 
The most important of these are: 
– EMEP modelling: omission of secondary organic aerosols; 
– RAINS modelling: emission starting point bias, omi ssion of some abatement 
techniques, failure to take account of futu re technical developments and lack of 
differentiation of partic le species by effect; 
– Benefits modelling: omission of impact s on ecosystems and cultural heritage 
and non-differentiation of pa rticle species by effect. 
The analysis undertaken here provides an  indication of the di rection and potential 
importance of these biases. It should be not ed that the scale of bias can be very 
substantial and, as such, could affect the conclusions drawn on the balance of costs and benefits, although this is likely to  vary considerably between regions and 
scenarios. Knowledge of these biases, howev er, opens up the possibility of factoring 
them into appraisal of the results of th e cost-benefit analysis, for example, using 
stepwise sensitivity analysis. The need to do so depends on the initial outcome of the 
CBA and the likely direction of  the most important biases. 
 
EN 170   EN Clearly, these uncertainties s hould not be considered in  isolation. Stakeholders 
should instead seek to develop an overv iew of them in order to understand the 
reliability of any conclusions drawn on the balance of costs and benefits for particular cases. A protocol is being de fined so that information on the different 
uncertainties present can be brought together in a unified assessment.