Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives : final report.
Date: 2022-10-26
Institutions: Directorate-General for Environment
Subjects: EU Member State, EU environmental policy, World Health Organisation, air quality, application of EU law, directive (EU), environmental law, environmental monitoring, environmental standard, health risk, pollution control, prevention of pollution, regulatory policy

Study to support the impact assessment for 
a revision of the EU Ambient Air Quality 
Directives

Specific Contract under Framework Contract ENV/F1/
FRA/2019/0001

Final Report 

Written by 
Trinomics
October 2022

EUROPEAN COMMISSION 

Directorate-General for Environment
Directorate C
Unit C3

European 
Commission B-1049 
Brussels

Contract details 

European Commission - DG Environment 

Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Specific Request Nr 28 under Framework Service Contract No ENV/F1/FRA/2019/0001 

Economic analysis of environmental policies and analytical support in the context of Better Regulation 

Presented by 

Consortium led by: 

Trinomics B.V. 

Westersingel 34 

3014 GS Rotterdam 

The Netherlands 

Contact 

Ms. Lisa Korteweg 

E: lisa.korteweg@trinomics.eu 

T: +31 (0)6 8280 6171 

Ms. Irati Artola 

E: irati.artola@trinomics.eu 

T: +31 (0)165 8108 

Mr. David Birchby 

E: David.birchby@ricardo.com 

T: +44 (0)1235 753555 

Contributors: David Birchby1, Beth Conlan1, Hetty Menadue1, Martina Alvarez1, Ella Wingard1, James 

Southgate1, Jack Dubey1; Zbigniew Klimont2, Gregor Kiesewetter2; Chris Heyes2; Fabian Wagner2; 

Bruce Denby-Rolstad3; Peter Janoska4, Irati Artola4, Oana Forestier4, Pavla Cihlarova4, Rob Williams4; 

Stijn Janssen5, Hans Hooyberghs5; Mike Holland6; Toon Vandyck7 

1Ricardo; 2IIASA; 3Met.No; 4Trinomics; 5VITO; 6EMRC; 7JRC 

Date 

Rotterdam, 21 October 2022 

LEGAL NOTICE 

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

CONTENTS 

Executive summary ................................................................................... 7 

1 

Introduction .......................................................................................11 

Introduction to the report ................................................................... 11 

Objectives of the study ....................................................................... 11 

2  Political and legal context ......................................................................13 

The issue of air quality: general overview on why legislation is relevant .......... 13 

European level ................................................................................. 13 
  Legislation targeting directly the improvement of air quality ................................... 13 
  Other relevant pieces of EU legislation regarding air quality .................................... 15 
  Main international EU commitments regarding air quality ........................................ 15 

International level ............................................................................. 16 

National level ................................................................................... 17 

3  What is the problem and why? ................................................................19 

The problem of air pollution ................................................................. 19 

Problems and drivers .......................................................................... 20 
  Environment and health shortcomings ............................................................... 20 
  Enforcement and governance shortcomings ........................................................ 25 
  Monitoring and assessment shortcomings ........................................................... 28 
Information and communication shortcomings ..................................................... 31 
  Obsolete provisions ..................................................................................... 32 

  Who is affected by the problems? .......................................................... 32 

4  Why should the EU act? .........................................................................35 

Legal basis ....................................................................................... 35 

Subsidiarity ..................................................................................... 35 

5  What should be achieved? ......................................................................36 

Objectives of intervention ................................................................... 36 

Intervention logic .............................................................................. 36 

6  Approach to the analysis .......................................................................40 

Overview of approach to the analysis ...................................................... 40 

Quantitative modelling ....................................................................... 42 
  Limitations of the approach ........................................................................... 47 

Literature review .............................................................................. 48 

Consultation activities ........................................................................ 48 
Inception impact assessment ......................................................................... 49 
  Online public consultation............................................................................. 49 

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  Targeted survey ......................................................................................... 50 
  Targeted interviews .................................................................................... 51 
  Stakeholder meetings .................................................................................. 52 

7  What are the interventions to achieve the objectives? ..................................54 

The baseline and maximum feasible reduction scenarios .............................. 54 
  Approach to building the baseline and a maximum (technically) feasible reduction (MTFR) 

scenario 

54 

  Trends in air pollutant emissions and concentrations under the baseline and MTFR scenario55 
  Problem: Projected health and environment outcome shortcomings ........................... 85 
  Problem: Projected enforcement and governance shortcomings ............................... 108 
  Problem: Projected air quality assessment and monitoring shortcomings ..................... 111 
  Problem: Information and communication shortcomings ........................................ 115 
  Summary of the baseline ............................................................................. 116 

Intervention areas and long-list of interventions ...................................... 118 

Assessment and constructing illustrative policy options ............................. 123 

8  Results of quantitative analysis to support revision to air quality standards ...... 125 

Environmental impacts ..................................................................... 125 
Impacts on air pollution emissions (Indicator #1) ................................................. 125 
Impacts on air pollution concentration (Indicator #1) ............................................ 142 
  Health impacts (Indicator #2) ........................................................................ 152 
  Ecosystem impacts (Indicator #3) ................................................................... 156 
  Links with climate change (Indicator #4) ........................................................... 164 
  Synergies with other EU policies (Indicator #11) .................................................. 166 

Economic impacts ............................................................................ 172 
  Costs and benefits to society (Indicator #5) ....................................................... 172 
  Costs of measures (Indicator #6) .................................................................... 173 
  Macro-economic effects, international competitiveness and trade (Indicator #7) ........... 178 

Social impacts ................................................................................ 181 
  Effects of scenarios on spatial regions with a low/high proportion of population in a 
vulnerable age group (indicator #8) .................................................................................. 181 
  Societal effects (indicator #9) ....................................................................... 183 
  Employment impacts (Indicator #10) ............................................................... 187 

9  Analysis of interventions ..................................................................... 189 

Overview ...................................................................................... 189 

Policy area 1 .................................................................................. 190 
  Summary of analysis ................................................................................... 190 
  Discussion ............................................................................................... 197 

Policy area 2 .................................................................................. 199 
  Summary of analysis ................................................................................... 199 
  Discussion ............................................................................................... 204 

Policy area 3 .................................................................................. 205 

5 

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  Summary of analysis ................................................................................... 205 
  Discussion ............................................................................................... 211 

Benefit Cost Ratio Summary ............................................................... 212 

10  Analysis of illustrative policy packages .................................................... 214 

Shortcoming I ................................................................................. 214 
  Policy options I-1, I-2 and I-3: air quality objectives ............................................ 215 
  Policy option I-4: establish objectives for additional air pollutants .......................... 226 
  Policy option I-5: Revise average exposure reduction obligations ............................. 226 
  Policy option I-6: regular review of EU air quality standards .................................. 229 

Shortcoming II ................................................................................ 231 
  Policy option II-1: revise approach to addressing exceedances and establishing AQ plans  233 
  Policy option II-2: revise number of air pollutants subject to ‘limit values’ ................. 234 
  Policy option II-3: revise implementation timeline for measures ............................. 235 
  Policy option II-4: revise legal tools available in case of non-compliance ................... 236 
  Policy option II-5: revise alert/information thresholds and action plans ..................... 237 
Outline ............................................................................................................ 237 
  Policy option II-6: Revise approach to transboundary air pollution ........................... 237 

Shortcoming III................................................................................ 239 
  Policy Option III-1: Revise requirements for air quality assessment .......................... 240 
  Policy Option III-2: Revise requirements for monitoring continuity ........................... 242 
  Policy Option III-3: Expand the requirements to monitor other pollutants .................. 243 
  Policy Option III-4: Revise requirements for monitoring quality ............................... 243 
  Policy Option III-5: Introduce requirements for modelling quality ............................ 244 

Shortcoming IV ............................................................................... 245 
  Policy option IV-1: revise requirements for up-to-date air quality data ..................... 246 
  Policy option IV-2: revise requirements for air quality health data ........................... 246 
  Policy option IV-3: revise requirements of a harmonised air quality indices ................ 247 

11  Summary of policy options ................................................................... 248 

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  Executive summary 

Ambient air pollution is recognised as the single biggest environmental threat to human health (WHO, 

2021). Ambient air pollution is a principal source of morbidity and mortality, and it is estimated that it 

causes 4.9 million premature deaths worldwide every year due to health risks such as stroke, heart 

disease, and lung cancer (WHO, 2021).  

As part of the European Green Deal, the Commission adopted the EU Action Plan “Pathway to a Healthy 

Planet for All: EU Action Plan: ‘Towards Zero Pollution for Air, Water and Soil’” on 12 May 2021. The 

Plan aims to reduce air, water and soil pollution levels so that they are no longer considered harmful to 

health and natural ecosystems by 2050. As part of this, the EU is revising the Ambient Air Quality 

Directives (AAQ Directives), to align air quality standards more closely with the recommendations of the 

World Health Organisation (WHO) (WHO, 2021). The revision also aims to build on the lessons learnt 

from the 2019 evaluation (‘fitness check’) of the AAQ Directives (European Commission, 2019), 

including that the Directives have been partially effective in improving air quality, but not fully 

effective, particularly where there is a remaining gap to achieve air quality standards in certain cases. 

The Fitness Check outlined several lessons learnt to inform policy making. The purpose of this study is 

to support the European Commission with the revision of the AAQ Directives and its accompanying 

impact assessment.  

Four problem areas have been defined to frame the planned revision to the AAQ Directives. These are: 

1) environment and health shortcomings, 2) enforcement and governance shortcomings, 3) monitoring 

and assessment shortcomings, and 4) information and communication shortcomings. This study 

identified, developed and assessed policy options and interventions contained therein to address these 

problems. Three general, and five specific objectives that the options and interventions should achieve 

were identified and summarised in the table below. 

Category of 

objectives 

Description 

• 

to avoid, prevent or reduce the harmful effects of air pollution on human health and the 

environment, in line with the European Green Deal and the Zero Pollution Action Plan; 

General 

• 

• 

to further enhance the effectiveness of EU air quality legislation; 

to improve the efficiency of the legislation taking into account the lessons learnt from the 

fitness check, making it easier to meet a given level of effectiveness.  

• 

Improve ambient air quality to the extent possible taking into account the latest scientific 

advice, feasibility, costs, and benefits – and ensure legislation can respond in an appropriate 

and effective manner to future changes in underlying evidence base. 

• 

Assure air quality plans are an effective means of identifying, planning and mitigating an 

Specific 

exceedance situation (by taking relevant, effective and proportionate measures) – and 

include clearer provisions on stakeholder participation, access to justice, penalties and 

compensation linked to clean air in EU legislation. 

• 

Further improve monitoring as an effective and reliable tool which is consistently applied to 

identify exceedance areas – and harvest opportunities offered by air quality models to 

underpin the development of plans and monitor exceedances. 

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Category of 

objectives 

Description 

• 

Provide information to citizens around health impacts of air pollution issues (targeting the 

concerns of citizens) – and ensure that the public in all Member States receive the same high 

quality and timely information about their air quality. 

• 

Simplify existing provisions where feasible to improve the effectiveness and efficiency of air 

quality management – and decrease associated administrative burden if and where possible. 

The assessment is structured according to the three key areas: 

•  Policy Area 1: a closer alignment of the EU air quality standards with scientific knowledge 

including the latest recommendations of the World Health Organization (WHO).  

•  Policy Area 2: improving the air quality legislative framework, including provisions on penalties 

and public information, in order to enhance effectiveness, efficiency and coherence. 

•  Policy Area 3: strengthening of air quality monitoring, modelling and plans. 

In total, 69 interventions were identified and considered as part of the Impact Assessment study: 22 in 

Policy Area 1 (further assessed in groups of 7 scenarios), 27 in Policy Area 2 and 20 in Policy Area 3.  

Each intervention has a number of associated impacts, with the exact impact, size and significance 

depending on the individual intervention. To assess the impacts, the study has followed a methodology 

designed to meet the requirements of the Better Regulation Guidelines (European Commission, 2021) 

and to provide the European Commission with timely evidence collection, stakeholder engagement and 

analysis of information gathered. 

Based on the Better Regulation Guidelines, interventions should be compared on the basis of how they 

address the objectives considering their effectiveness, efficiency and coherence. All interventions were 

screened for their likely key economic, environmental, and social impacts across the core stakeholders 

affected – competent authorities, other public authorities, industry (large and smaller businesses), 

citizens and workers. Twelve indicators have been defined to capture and present the key economic, 

environmental, and social impacts associated with the interventions being considered. All interventions 

across the three Policy Areas were appraised against this set of indicators, to ensure consistency in the 

analysis and presentation of results. Across each of these specific indicators, available evidence on the 

effectiveness, efficiency and coherence of the Policy Packages was collated, assessed and, where 

possible, quantified in comparison to the baseline. To support the assessment of impacts, evidence 

gathering has comprised of three main activities: Quantitative modelling, in particular focusing on the 

impacts of different air quality standards under Policy Area 1 - this has been carried out using an 

integrated assessment framework which has been extensively deployed to explore projections of air 

pollution and the impacts of mitigation strategies at EU-level under similar studies; detailed literature 

review and extensive stakeholder engagement. 

Following the assessment, the interventions have then been grouped into illustrative policy packages, 

combining interventions across Intervention and Policy Areas. These packages are combined and 

assessed in order to explore the interactions, linkages and dependencies between interventions in 

different Intervention and Policy areas. 

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Assessing air quality, addressing exceedances of standards, providing timely information to the public 

and ensuring all stakeholders play their part to establish clean air for all, are complex processes with 

many interlinkages between these activities. Overall, each of these activities have substantial 

importance and each should be addressed for a successful improvement to the delivery of clean air 

across Europe. In reaching such policy decisions it is important to recognise the synergies between the 

various policy options and all of the policy sub-options.  

The cost-benefit analysis conducted suggests there are significant benefits to be gained from setting 

more ambitious air quality standards, and that the benefits gained are likely to significantly outweigh 

the costs. In setting revised objectives for pollutants of concern, consideration should be given not only 

to the value to gained for human health and the environment, but also to how such objectives could be 

met and at what cost, how revisions in monitoring and assessment may impact on these and how such 

information can be readily communicated to the public. Furthermore, even if objectives for pollutants 

are not revised, should changes be made to aspects of monitoring and assessment, then this may impact 

on the pollution burden. For example, should the use of more monitoring, such as indicative monitoring 

and/or modelling be encouraged through policy sub-options, then the understanding of pollutant levels 

across a wider spatial area may increase and impact on where action should be taken. 

The improvement of air quality plans is seen as a key success factor of a revised Directive. This is 

required to bring transparency to the measures Member States are to implement in cases of non-

compliance. Improvement is needed on the effectiveness and efficiency of air quality plans. For any 

revised air quality objectives set for pollutants it is important that a pathway to compliance can be set 

out within an updated air quality planning process. Key milestones on this pathway to compliance 

should be transparent and policy sub-options to address the governance and enforcement of the 

directive should be considered crucial to achieve revised air quality objectives in the near term.  

Some policy sub-options proposed consider the longer term air quality across Europe. While air quality 

modelling of pollutants to 2030 and 2050 have been presented to support this impact assessment, other 

longer term issues such as the importance of pollutants of emerging concern have also been considered. 

In addition, the consideration of a regular review of EU air quality standards is also proposed. Gathering 

data and information on current levels of such emerging pollutants to support research will be key to 

inform how we should deal with such pollutants over the longer term as the scientific evidence 

increases.  

All 69 interventions have been assessed against 12 indicators which cover environmental, societal, 

economic and cost consequences/impacts and all offer benefits to the improvement of air quality for 

human health and the environment. While these have been amalgamated into policy options to address 

the identified shortcomings of the AAQ Directive, some of the interventions offer lower benefits when 

assessed in isolation. However, many of these are likely to bring more benefits when assessed 

synergistically with other interventions. For example, many interventions under the policy option for 

monitoring and assessment are a prerequisite to determine levels of pollution and how these compare 

to any revised air quality standards.  These interlinkages between and within policy options are 

therefore an important aspect of bringing these together into an integrated policy package for further 

consideration by decision makers to deliver a clear pathway for cleaner air for all. 

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1  Introduction 

Introduction to the report 

This is the Final Report for the “Study to support the impact assessment for a revision of the EU 

Ambient Air Quality Directives”, which is Service Request 28 under framework contract 

ENV.F.1/FRA/2019/0001. The specific contract commenced on 29 April 2021 and runs until 29 October 

2022 (i.e. 18 months). This report has been submitted by Ricardo, the lead consultants appointed to 

conduct this study in partnership with Trinomics, VITO, Norwegian Meteorological Institute and IIASA. 

This report is structured as follows: 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Section 2 presents an overview of the political and legal context; 

Section 3 discusses the problems and drivers under consideration in this impact assessment 

study; 

Section 4 outlines the rationale for EU action; 

Section 5 sets out the objectives for the interventions; 

Section 6 presents a summary of the approach to evidence gathering and analysis; 

Section 7 outlines the baseline and options to achieve the objectives; 

Section 8 presents the results of the quantitative modelling assessment around air quality 

standards; 

Section 9 presents the analysis of the interventions; 

Section 10 presents analysis of the illustrative policy packages; 

Section Error! Reference source not found. summarises the analysis of policy options; 

Section Error! Reference source not found. sets out a framework for monitoring and 

evaluation of the impacts. 

The main body of the report is supported by several detailed appendices, which include the stakeholder 

consultation synopsis (Appendix 2), a more detailed description of the methodologies and approaches 

adopted to appraise the impacts (Appendices 3 – 8), and the results of the analysis for individual 

interventions (Appendix 10). 

  Objectives of the study 

Assuring the best possible air quality, minimising population exposure to harmful levels of air pollutants 

and reducing their deposition to ecosystems have been on the agenda of the EU for several decades. 

Policies aimed at reducing emissions have brought a continuous decline in the levels of most air 

pollutants in the EU in recent decades. However, air pollution continues to be a significant problem 

(Section 3.1).  

The EU’s strategy to improve air quality rests on three pillars:  

1.  Ambient air quality standards set out in the Ambient Air Quality Directives (AAQ Directives). 

Member States which exceed the limit values are required to develop and adopt air quality 

plans; 

2.  The national emission reduction obligations set by the National Emission reduction 

Commitments Directive (NEC Directive) for the most important transboundary air pollutants; 

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

3.  Emission limits and efficiency standards for key sources of air pollution. These standards are 

set out at EU level in dedicated legislation. 

The main objectives of the AAQ Directives are to: define common methods to monitor and assess air 

quality; ensure that information on air quality is made public, maintain good air quality and improve it 

where it is not good, and establish standards of air quality to achieve across the EU. The AAQ Directives 

set out standards for 12 pollutants: Fine particulate matter (PM2.5), Particulate matter (PM10), Sulphur 

dioxide (SO2), Nitrogen dioxide (NO2, including Nitrogen oxide, NOx), Lead (Pb), Carbon monoxide (CO), 

Benzene (C6 H6), Ground-level ozone (O3), Arsenic (As), Cadmium (Cd), Nickel (Ni) and Benzo(a)pyrene 

(BaP). 

As part of the European Green Deal, the Commission adopted the EU Action Plan “Pathway to a Healthy 

Planet for All: EU Action Plan: ‘Towards Zero Pollution for Air, Water and Soil’” on 12 May 2021. The 

Plan aims to reduce air, water and soil pollution levels so that they are no longer considered harmful to 

health and natural ecosystems by 2050. As part of this, the EU is revising the AAQ Directives, to align 

air quality standards more closely with the recommendations of the World Health Organisation (WHO) 

(WHO, 2021). It is important to recognise that the WHO guideline values do not consider the technical 

feasibility or the economic, political and social aspects of the achievement of the guideline levels; 

thus, assessing the full impacts of the differing guideline values is important.  

The revision also aims to improve overall EU legislation for clean air, building on the lessons learnt from 

the 2019 evaluation (‘fitness check’) of the AAQ Directives (European Commission, 2019). Namely that 

the Directives have been partially effective in improving air quality, but not fully effective, particularly 

where there is a remaining gap to achieve air quality standards in certain cases. The Fitness Check 

outlined several lessons learnt to inform policy making. 

The purpose of this study is to support the European Commission with the revision of the AAQ 

Directives. This assessment focusses on revisions that aim to ensure that future legislation takes the 

latest scientific evidence for the protection of human health and the environment into account. It is 

accompanied by consideration of options to strengthen the basis for effective action, including via 

better air quality monitoring, modelling and air quality plans. The assessment is structured according to 

the three key areas established by the Inception Impact Assessment (European Commission, 2021): 

•  Policy Area 1: a closer alignment of the EU air quality standards with scientific knowledge 

including the latest recommendations of the World Health Organization (WHO).  

•  Policy Area 2: improving the air quality legislative framework, including provisions on penalties 

and public information, in order to enhance effectiveness, efficiency and coherence. 

•  Policy Area 3: strengthening of air quality monitoring, modelling and plans. 

Alongside this impact assessment support study, a separate but related study ran in parallel, exploring 

non-legislative solutions to the shortcomings considered in this study: “Strengthening of air quality 

monitoring, modelling and plans under the Ambient Air Quality Directives” (Conlan et al., 2022). This 

study complements the evidence gathered under the present impact assessment support study, and is 

referred to throughout.   

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

2  Political and legal context 

  The issue of air quality: general overview on why legislation is relevant  

Air pollution and poor air quality is one of the biggest current global environmental and health 

challenges (see Section 3.1). To manage the negative effects on human health and the environment, 

since the early 1970s the EU has aimed, through a series of instruments, standards, and legislative 

packages to achieve healthy levels of air quality.   

  European level  

  Legislation targeting directly the improvement of air quality 

The first major legislative instrument concerning air quality to be introduced by the EU was the Air 

Quality Framework Directive 96/62/EC and its daughter Directives, which established air quality 

standards for a range of pollutants including ozone, particulate matter (PM10) and nitrogen dioxide 

(NO2), in the period up to 2004. There are two current Ambient Air Quality Directives (or “AAQ 

Directives”): 2008/50/EC and 2004/107/EC. Directive 2008/50/EC on ambient air quality and cleaner 

air for Europe1 establishes ambient air quality objectives to reduce harmful effects on human health 

and the environment. It sets out the methods of assessing ambient air quality in Member States, sets 

limit and targets values for key pollutants (SO2, NO2, PM10 and PM2.5, Pb, CO, C6 H6) and promotes 

transparency and cooperation between Member States. Directive 2008/50/EC merged previously 

existing EU air quality legislation2,3,4 into a single directive, with the exception of Directive 

2004/107/EC relating to As, Cd, Hg, Ni, and polycyclic aromatic hydrocarbons (PAH) in ambient air5 

(Fourth Daughter Directive), which continued to be a stand-alone directive. Directive 2004/107/EC sets 

target values for these pollutants to reduce their effects on human health and the environment. 

Hereafter these Directives (2008/50/EC and 2004/107/EC) are referred to jointly as “AAQ Directives”.  

In 2013, the Clean Air Policy Package was adopted based on a review of EU policy to date. This policy 

package included a Clean Air Programme for Europe (European Commission, 2013) – setting objectives 

for 2020 and 2030 - as well as a proposal for Directives on the reduction of national emissions of certain 

atmospheric pollutants (the NEC Directive) and on the limitation of emissions of certain pollutants into 

the air from medium combustion plants (the MCP Directive6). This was followed, in 2018, by the 

adoption of a Communication: "A Europe that protects: Clean air for all” that provided national, 

regional and local actors with practical help to improve air quality in Europe. 

The European Commission completed a Fitness Check in 2019 (European Commission, 2019) of the AAQ 

Directives to examine whether they had been successful in meeting their objectives between 2008 to 

2018 through public consultations and stakeholder workshops. It evaluated the relevance, 

effectiveness, efficiency, coherence, and EU added value of these Directives. The Fitness Check 

concluded that these Directives have been partially effective in improving air quality and achieving air 

quality standards but that not all their objectives had been met.  

1 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32008L0050  
2 https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A31996L0062  
3 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31999L0030  
4 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32000L0069  
5 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32004L0107    
6 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32015L2193  

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The Fitness Check of the AAQ Directives found that although provisions on air quality standards (i.e. 

limit and target values) were seen as successful in incentivising action across Member States leading to 

a general lowering of air pollutant concentrations, current air quality standards for several pollutants, 

including PM2.5, are not as ambitious as recent scientific advice suggests is appropriate for the 

protection of public health.   

The Fitness Check also found that the AAQ Directives have given flexibility to competent national 

authorities to ensure air quality monitoring and air quality measures optimally fit local circumstances 

(in line with the subsidiarity principle ). However, additional guidance or implementing acts could help 

to further harmonise the approaches applied to monitoring, information provisions, and air quality plans 

and measures. Air quality plans were identified as one of the most fundamental elements of the AAQ 

Directives in terms of incentivising remedial action by EU Member States. Nonetheless, compliance 

verification was found to be hampered through the lack of clear requirements for Member States to 

report on the implementation of air quality plans or update them with additional measures when 

progress is insufficient. Coordination and consistency in the actions of authorities within and across 

Member States was also deemed insufficient. In addition, the flexibility offered to Member States’ 

competent authorities with regards to their monitoring network was argued by some to give too much 

leeway, reducing confidence in the comparability of monitored air quality. However, the Fitness Check 

concluded that this does not appear to amount to a systemic shortcoming in the EU-wide monitoring 

network: overall, the monitoring network ensures that reliable and representative air quality data is 

available. 

Finally, the Fitness Check found that the successful establishment of an EU-wide e-reporting system 

based on machine-readable formats encourages up-to-date reporting of air quality data and supports 

further use of air quality modelling which is increasingly reported but would benefit from further 

guidance. Further elaboration of the problems identified in relation to the AAQ Directives are presented 

in Section 3. 

In addition, the European Green Deal, approved in 2020, introduced a set of policy initiatives with the 

overarching aim of making the EU climate neutral by 2050. This included initiatives to further enhance 

the EU air quality legislation to avoid, prevent or reduce the harmful effects of air pollution on human 

health and the environment. As set out in the introduction to this study, the EU has adopted a Zero 

Pollution Action Plan as part of the Green Deal which (among other things) sets out the ambition to 

revise EU pollution standards to align them more closely with the latest WHO Air Quality Guidelines 

(WHO, 2021).  

In July 2021, as part of the EU Recovery Plan (in place to tackle the socio-economic consequences of 

the COVID-19 pandemic), EU leaders agreed on a comprehensive package of €1 824.3 billion which 

combines the €1 074.3 billion multiannual financial framework (MFF) and an extraordinary €750 billion 

recovery effort, Next Generation EU to help transform the EU through its major policies, particularly 

the European Green Deal, the digital revolution and resilience. It was also agreed that 30% of the total 

expenditure from the MFF and Next Generation EU would target climate-related projects. The Plan also 

presents an opportunity to prioritise clean air, as it flags an urgent need to boost residential and public 

building renovations to kick-start the EU economy and reduce emissions. 

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  Other relevant pieces of EU legislation regarding air quality 

In addition to these key pieces of legislation and overreaching policy packages to improve air quality in 

the EU, the Commission has  set regulations around the main sources, and main pollutants, within the 

Union. This includes the following: 

• 

Road transport: emissions of PM, NOx, unburnt hydrocarbons (HC) and CO are regulated within the 

EU framework for the type approval of cars, vans trucks, buses and coaches – commonly known as 

"Euro" standards for light-duty vehicles (cars and vans)7 and heavy-duty vehicles (trucks, buses and 

coaches)8. 

•  Non-Road Mobile Machinery (NRMM): since 2017, emissions from these engines are regulated by 

the  ’NRMM  Regulation’:  Regulation  (EU)  2016/16289  on  requirements  relating  to  gaseous  and 

particulate pollutant emission limits and type-approval for internal combustion engines for non-

road mobile machinery. 

•  Maritime  transport:  SO2  emissions  from  shipping  in  the  EU  are  regulated  in  Directive  (EU) 

2016/80210. Since 2020, ships in all EU waters (except SOx-ECAs) are required to use fuels with a 

sulphur content of no more than 0.5%. 

• 

Agriculture: ammonia (NH3) emissions reductions measures are included in Annex III part 2 of the 

NEC Directive11.  

• 

Energy and industrial sources: Emissions from these sources have been reduced thanks to a series 

of regulations including:  the Energy Efficiency Directive12, the Industrial Emissions Directive13 and 

the Directive on the Sulphur Content of Certain Liquid Fuels14. 

• 

Paint:  Emissions  of volatile organic compounds due to the use of organic  solvents in paints are 

regulated by Directive 2004/42/EC ("the Paints Directive")15. 

•  Domestic  heating:    Commission  Implementing  Regulations  under  the  Ecodesign  Directive 

(2009/125/EC)16 set emission limit values for solid fuel local space heaters ((EU) 2015/1185)17 and 

for  solid  fuel  boilers  ((EU)  2015/1189)18.  Emission  limit  values  are  complemented  by  energy 

labelling provisions adopted via the Energy Labelling Directive (2010/30/EU)19 for energy labelling 

of  local  space  heaters  (Commission  Delegated  Regulation  (EU)  2015/1186)20  and  for  solid  fuel 

boilers (Commission Delegated Regulation (EU) 2015/1187)21. 

  Main international EU commitments regarding air quality 

In the international context, the EU has participated and shaped the discussion around air quality through 

its commitments to, and participation in, a series of Conventions, among which the following stand out: 

• 

Participation  in  the  UNECE  Convention  on  Long-Range  Transboundary  Air  Pollution  (the  Air 

Convention), adopted in 1979. This Convention has been extended by 8 Protocols, of which the EU 

is  part  of  seven. The  original  Gothenburg  protocol  (adopted  in  1999), formed  the  basis  for  the 

original  NEC  Directive  2001/81/EC22.  The  protocol  was  revised  in  2012  and  the  reduction 

7 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32007R0715  
8 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32009R0595  
9 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32016R1628  
10 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32016L0802  
11 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2016.344.01.0001.01.ENG  
12 https://eur-lex.europa.eu/eli/dir/2012/27/oj  
13 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010L0075  
14 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32016L0802    
15 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32004L0042  
16 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=celex%3A32009L0125  
17 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2015.193.01.0001.01.ENG  
18 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2015.193.01.0100.01.ENG  
19 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32010L0030  
20 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32015R1186  
21 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2015.193.01.0043.01.ENG  
22 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32001L0081  

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commitments established for 2020 for the EU and its Member States have been transposed into EU 

law  by  the  new  Directive  on  National  Emission  Reductions  (Directive  2016/2284/EU23).  The 

amended  protocol  was  ratified  by  Council  Decision  (EU)  2017/175724  in  follow-up  to  the 

Commission Clean Air Policy Package. 

• 

Participation in the UN Environmental Programme, Stockholm Convention on Persistent Organic 

Pollutants, adopted on 22 May 2001. 

• 

Participation in the work on UN Environmental Assembly resolution UNEP/EA.3/Res.8 (UNEP, 2017) 

(December 2017) on Preventing and reducing air pollution to improve air quality globally. 

• 

Commitment to the UN Sustainable Development Goals, several of which are directly or indirectly 

linked to improvements in air quality. 

• 

Adoption of the 2015 World Health Assembly Resolution which emphasised the need to redouble 

the efforts of Member States and WHO to protect populations from the health risks posed by air 

pollution.  

• 

• 

Participation in the WHO ministerial conferences on environment and health. 

Commitment  to  the  WHO  guidelines  on  air  quality,  which  are  used  as  the  scientific  basis  for 

legislation for the EU Directives. 

International level  

In 1958, the WHO released its first publication in the WHO Technical Report Series on air pollution and 

health – known as Air pollution (WHO, 1958). The report was concise, mainly providing an overview of 

air pollution science, the sources of air pollutants, factors affecting ambient concentrations, methods 

of measuring concentrations of pollutants and effects on health. This was the first time that the 

introduction of air quality guidelines (AQGs) was considered. In 1964, the WHO published a new report - 

Atmospheric pollutants (WHO, 1964) – which called for international guides to air quality. This 

eventually led to the development of the first edition of the WHO AQGs. 

The first edition of the WHO AQGs was published in 1987, known as Air quality guidelines for Europe 

(WHO, 1987). It provides recommendations in the form of numerical values/ranges or unit risk factors 

for a total of 28 air pollutants (including Cd, CO, Pb, O3, NO2, SO2, among others). The second edition 

of these guidelines was published in 2000. In it, the WHO set out guideline values for many individual 

substances (updating and consolidating earlier recommendations on air pollution) with the intention of 

providing instruction on how to avoid the adverse health implications linked to air pollution (WHO, 

2000). The document provided recommendations in the form of numerical values/ranges and unit risk 

factors for the pollutants included in the previous edition, in addition to butadiene, polychlorinated 

biphenyls, dibenzodioxins and dibenzofurans, fluoride and platinum. A separate section for indoor air 

pollutants was also provided. 

The guidelines on reducing the effects on health of air pollution for PM, O3, NO2, and SO2 were updated, 

in a new WHO publication, in 2005 (WHO, 2005). This was the first time that interim targets were 

proposed for PM, O3 and SO2. 

The guidelines for these pollutants were subsequently reviewed and updated in 2021 (WHO, 2021). The 

key outcomes of this publication are new air quality guideline exposure levels and interim targets for 

23 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2016.344.01.0001.01.ENG  
24 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2017.248.01.0003.01.ENG  

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

PM2.5, PM10, O3, NO2, SO2 and CO. In addition to the guideline exposure levels, the WHO has also 

outlined a series of less stringent interim targets for PM2.5, PM10, SO2 and O3, which, if met, would still 

be expected to lead to a significant decline in health conditions and diseases as a result of air pollution. 

The WHO also provides guidance for policymakers when considering air quality management 

opportunities and summarises information on air pollution sources, population exposure, quantifying 

the health burden of air pollution, and developing air quality standards.  

  National level  

For the purposes of air quality assessment and management, the AAQ Directives oblige Member States 

to divide their territories in zones and agglomerations, each of which has to be classified in relation to 

the assessment thresholds for ambient concentrations of each pollutant.  The Directives, require 

Member States to ensure compliance with the limit and target values; therefore, air quality plans – to 

reduce concentration of air pollutants - are required in polluted zones and agglomerations where there 

are exceedances.  

The Fitness Check of the AAQ Directives included an analysis of the monitoring and assessment regimes 

for all the Member States in 2015, as well as case studies on the implementation of the air quality 

legislation in Bulgaria, Germany, Ireland, Italy, Slovakia, Spain, and Sweden.25 In the analysis the 

number and type of nitrogen dioxide and particulate matter sampling points reported by the Member 

States to the Commission for the year 2015, compared to their minimum required number, without 

considering the use of other methods such as modelling or indicative measurement was reviewed and 

gaps identified. Overall, it was concluded that the Directives were partially effective in improving air 

quality and achieving air quality standards in the EU; that the remaining gap to achieve the agreed 

standards is too wide in certain cases; and that action taken by Member States to meet air quality 

standards and keep exceedances as short as possible was insufficient.  

While the AAQ Directives set a series of standards on pollutant concentrations in ambient air for all 

Member States to comply with, the NEC Directive sets national reduction commitments for the 

emissions of five pollutants (SO2, NOx, volatile organic compounds (VOCs), NH3 and PM2.5). National air 

quality strategies and plans should set out the nation’s air quality objectives and recognise that action 

at different scales may be required to meet the air quality guidelines at national, regional, and local 

levels. Each Member State also has the option of setting more strict standards for air pollutants in their 

national legislation. Therefore, national legislation of air quality standards, as well as measures 

implemented to reduce the effects of poor air quality, vary between Member States.  

For example, in Sweden, air quality standards imposed by the AAQ Directives are relevant, but the 

Swedish legislation goes beyond the values imposed in the AAQ Directives, for example setting a daily 

limit value for PM2.5 and for NO2 (which is not contemplated in the Directives), as well as lower hourly 

limit values for SO2 (while it is set at 350µg/m3 in the Directives, Swedish standards set it at 200µg/m3). 

In Ireland, there are additional complementary laws regarding residential solid fuel use (primary source 

of fine particulate matter air pollution in the country) for which there is no EU legislation. Further 

examples on how legislation and policy measures to control and reduce pollutants emission and 

25 
fad52af779f1?p=1&n=10&sort=modified_DESC 

https://circabc.europa.eu/ui/group/cd69a4b9-1a68-4d6c-9c48-77c0399f225d/library/b5d2b8f5-a6c4-4610-b1ed-

17 

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concentrations align or go beyond the standards set by the AAQ Directives are detailed in the Fitness 

Check case studies of Bulgaria, Germany, Spain, Slovakia (European Commission, 2019). 

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

3  What is the problem and why? 

  The problem of air pollution 

Ambient air pollution is recognised as the single biggest environmental threat to human health (WHO, 

2021). Ambient air pollution is a principal source of morbidity and mortality, and it is estimated that it 

causes 4.9 million premature deaths worldwide every year due to health risks such as stroke, heart 

disease, and lung cancer (WHO, 2021).  

Over the past decade, public awareness surrounding the global challenge of air pollution and its health 

implications has grown. Governments are being increasingly pressurised by NGOs, public health 

communities, and citizens who are demanding legislative changes to manage local, national, and global 

air quality. Additionally, the economic burden due to poor health and diseases caused by air pollution 

increases the pressure on governments to improve air quality. Some NGOs and citizen stakeholders have 

initiated court cases against local authorities and governments for poor air quality that does not meet 

legal standards. Such cases have been won by NGOs in courts in EU jurisdictions. Recent judgements 

passed include: 

• 

Against France (October 2019)26, Federal Republic of Germany (June 2021)27 and the UK (March 

2021)28 for systematic exceedance of NO2 limit values in certain zones and failure to keep the 

exceedance period as short as possible.  

• 

Against the Italian Republic (November 2020)29 and Romania (April 2020)30 for systematic and 

persistent exceedance of PM10 and failure to keep the exceedance period as short as possible 

(November 2020). 

In total, the European Commission has ongoing air quality infringement cases against 13 Member States 

for NO2, 14 Members States for PM2.5/PM10 and 1 Member State for SO2

31. In addition, there are breaches 

of the EU Ambient Air Quality Directives’ limit values and parameters for air quality monitoring 

(European Commission, 2022).  

The EU aims to improve overall EU legislation for clean air, in particular, where the implementation 

and operation of the EU legislation could be improved to more effectively and efficiently deliver its 

objectives, as identified by the Fitness Check. Findings from the Fitness Check show that: 

• 

• 

There are ongoing health and environmental challenges in the EU caused by poor air quality 

and exposure to harmful air pollutants; 

Existing standards exceed the current health guidelines based on scientific evidence. There is 

no legal flexibility to amend the standards in accordance with evolving technologies and 

science; 

•  While air quality standards contribute to improved air quality, limit values are more effective 

than target values,  and provisions are not designed to minimise short term exposure; 

•  Ongoing exceedances are indicative of the fact that existing penalties are failing as a 

deterrent, while legal enforcement action is an effective tool; 

26 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A62018CJ0636&qid=1653906483310  
27 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A62018CJ0635&qid=1653906057988  
28 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A62018CJ0664&qid=1653906483310  
29 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A62018CJ0644&qid=1653906483310  
30 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A62018CJ0638&qid=1653906483310  
31 Communication with European Commission, May 2022 

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

• 

Inconsistencies between Member States regarding air quality plans, monitoring, modelling and 

information reduce the effectiveness of air quality standards: 

o 

Exceedances are occurring despite the measures set in air quality plans; 

o  Measures can be considered disproportionate to the exceedance; 

o 

Local air quality is affected by emissions outside the local area. Air quality plans do 

not always facilitate planning with stakeholders responsible for emission sources (a 

problem where local air quality is impacted by emissions outside the air quality zone); 

o 

Flexibilities provided by the AAQ Directives have led to disparate approaches to 

monitoring and modelling that make it difficult to assess and report air quality in a 

comparable way. 

• 

Reporting on air quality can be made more accessible (as regards monitoring and modelling 

data, and air quality information more generally). Despite public interest, information on air 

quality is not always made publicly available. 

Four problem areas have been defined by the European Commission in its Intervention Logic to frame 

the planned revision to the AAQ Directives. These are: 1) environment and health shortcomings, 2) 

enforcement and governance shortcomings, 3) monitoring and assessment shortcomings, and 4) 

information and communication shortcomings. Figure 1 presents an overview of the problems and their 

drivers. In keeping with this structure, this section covers the problems to be addressed, the drivers of 

these problems and how these may evolve without any further policy intervention.  

Figure 1 Overview of problems (left) and their drivers (right) 

Environment and health shortcomings

EU standards are not aligned with scientific 
advice

•Exceedances above health guidelines and negative health impacts persist
•Lack of flexibility to adapt to evolving science and new recommendations

Enforcement and governance shortcomings

Exceedances are not always addressed 
sufficiently and/or in a timely manner. Air 
quality plans do not always address all 
sources effectively

•Insufficient penalties and damages linked to exceedances
•Air quality plans and measures have often proven ineffective
•Local air quality is impacted by emissions outside local control
•Some measures may seem disproportionate and/or ineffective

Monitoring and assessment shortcomings

Flexibilities may sometimes impact the 
comparability of data

•Monitoring rules offering flexibility are sometimes stretched
•Modelling ability has improved, allowing for more detailed analysis

Information and communication 
shortcomings

Public feels under-informed about poor air 
quality and its impacts

•Concerns about health impacts have increased and have not been addressed
•Public information is not always available and not harmonised

  Problems and drivers 

  Environment and health shortcomings 

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The figure below shows that in 2019 many EU residents remained exposed to ambient air pollutant 

concentrations above EU standards and those recommended by WHO (Figure 2). This is despite ongoing 

improvements to air quality (Figure 3).     

Figure 2 Share of EU urban population exposed to air pollutant concentrations above EU standards and WHO 
guidelines (based on 2019 pollutant levels) 

Source: (EEA, 2021)

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Figure 3 Annual mean concentrations for NO2, PM10, O3, and PM2.5, observed at (sub)urban background stations (2000 – 2017)* 

NO2: 

O3: 

Source:  (EEA, 2019)

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PM10: 

PM2.5: 

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

In addition to improvements to air quality, emissions of pollutants have decreased. SO2, PM2.5, PM10, O3 

and NO2, as well as As, Cd, Ni, Pb, Hg and BaP emissions have decreased between 2000 and 2018. While 

NH3 emissions have also decreased in this timeframe, the reductions are comparatively small. Figure 4 

also shows  GDP, illustrating that reductions in emissions over this timeframe are decoupled from GDP 

growth (i.e. the emissions have gone down despite an increase in GDP). 

Figure 4 Emissions in EU by air pollutant, 2000-2018: (a) SO2, NOX, NH3, PM10, PM2.5, NMVOCs, CO, CH4 and BC; 
(b) As, Cd, Ni, Pb, Hg and BaP (index 2005 = 100). EU28 GDP (2010, % of 2000 level) 

Source: (EEA, 2021) 

Figure 5 presents the share of emissions by sector, showing that key sources in the EU include 

agriculture (namely of NH3, NMVOCs and CH4), industry (namely of SO2, NMVOCs and select heavy 

metals), energy supply (namely of SO2 and select heavy metals) and the residential, commercial and 

institutional sector (energy use for heating). 

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Figure 5 Emissions in EU by main sectors, 2000-2018 (SOX, NOX, NH3, PM10, PM2.5, NMVOCs, CO, CH4 and BC (% 
2000 levels) compared with sectoral activity (% 2000 levels, except waste (kg per capita)) 

Source: (EEA, 2021) 

Despite improvements in air quality in the EU, evidence shows that poor air quality continues to impact 

the health of citizens in the EU, especially in cities. In 2019, air pollution is still a major cause of health 

impacts – both in terms of mortality and morbidity. Estimates of the number of premature deaths 

attributed to key air pollutants in the 27 EU Member States for the year 2019 are as follows: 307,000 

premature deaths were attributed to chronic exposure to fine particulate matter; 40,400 premature 

deaths were attributed to chronic nitrogen dioxide exposure; 16,800 premature deaths were attributed 

to acute ozone exposure (EEA, 2021). There are two dimensions to this problem: 1) ongoing 

exceedances of EU air quality standards, and 2) EU standards are not aligned with scientific advice. 

The Fitness Check concluded that while air quality standards contribute to improved air quality, limit 

values are more effective than target values, with the mandatory nature of the former serving as an 

important success factor. Thus, where used, the extent to which target values are an effective 

mechanism to limit exceedances above EU air quality standards is under review.  

Focussing on health aspects, the WHO guidelines are based on a growing scientific evidence base 

demonstrating the harmful impact of air quality pollutants on human health and the environment. As 

set out in Table 1, the WHO guidelines include guideline values with lower concentration levels than 

the EU air quality standards (including for PM2.5, PM10 and SO2). Comparing the WHO guidelines with EU 

standards, it is apparent that the two are not aligned and that this is a driving factor for persistent 

exceedances above health guidelines. Moreover, there is no mechanism in place to trigger regular 

review of air quality standards (based on scientific evidence). Thus, the current legal framework lacks 

flexibility to adapt to evolving science and new recommendations. 

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Table 1 Comparison of standards contained in EU AAQ Directives and WHO guidelines 

Pollutant 

Averaging period 

Fine particulate 
matter (PM2.5) 

Particulate matter 
(PM10) 

Sulphur dioxide 
(SO2) 

Nitrogen dioxide 
(NO2) 

Lead (Pb) 
Carbon monoxide 
(CO) 
Benzene (C6H6) 
Ground-level ozone 
(O3) 
Arsenic (As) 

Cadmium (Cd) 

Nickel (Ni) 
Benzo(a)pyrene 
(BaP) 

24 hours 

1 year 

24 hours 

1 year 

10 minute 

1 hour 

24 hours 

1 hour 

24 hour 

1 year 

1 year 
Max. daily 8 hour 
mean 
1 year 
Max. daily 8 hour 
mean 
1 year 

1 year 

1 year 

1 year 

AAQ DIRECTIVES 
standards 
(concentration) 

n/a 
25 µg/m3 (LV) 
50 µg/m3 (LV) 
40 µg/m3 (LV) 

n/a 
350 µg/m3 (LV) 
125 µg/m3 (LV) 
200 µg/m3 (LV) 

n/a 
40 µg/m3 (LV) 
0.5 µg/m3 (LV) 

10 mg/m3 (LV) 

5 µg/m3 (LV) 

120 µg/m3 (TV) 

6 ng/m3 (TV) 
5 ng/m3 (TV) 
20 ng/m3 (TV) 
1 ng/m3 (TV) 

AAQ DIRECTIVES 
standards (number 
of exceedances 
permitted)  
- 

- 

35 days / year 

- 

- 

24 hours / year 

3 days / year 

18 hours / year 

- 

- 

- 

- 

- 
25 days avg. over 3 
years 
- 

- 

- 

- 

WHO Guidelines*** 
(concentration) 

15 µg/m3 ** 
5 µg/m3 ** 
45 µg/m3 ** 
15 µg/m3 ** 
500 µg/m3 ** 

n/a ** 
40 µg/m3 ** 
200 µg/m3 ** 
25 µg/m3 ** 
10 µg/m3 ** 
0.5 µg/m3 * 

10 mg/m3 ** 

1.7 µg/m3 * 

100 µg/m3 ** 

6.6 ng/m3 * 
5 ng/m3 * 
25 ng/m3 * 

0.12 ng/m3 * 

Notes: (LV) = limit value; (TV) = target value; *Taken from WHO (2000) Air Quality Guidelines for Europe (Second Edition)  ** WHO (2021) WHO global air 

quality guidelines  *** Note this does not include all WHO guidelines for all air pollutants or averaging periods. WHO guidelines also include interim guideline 

values, not presented here. 

In addition, the Fitness Check refers to mounting evidence that exposure (short-term (24 hours) and 

long-term (annual)) to air pollutants, which is currently outside the scope of the AAQ Directives, has an 

impact on human health (i.e. black carbon, ultrafine particles and ammonia). Moreover, for PM2.5, 

there is a greater understanding of short-term exposure occurring from peak periods of air pollution 

(which is currently not regulated by the AAQ Directives). 

The WHO guideline values do not consider the technical feasibility or the economic, political and social 

aspects of the achievement of the guideline levels. These impacts are assessed as part of this study to 

the extent that this is possible.  

  Enforcement and governance shortcomings 

Enforcement and governance shortcomings have together led to ongoing instances of exceedances of air 

quality standards and high exposure of some of Europe’s urban population to air pollution above the 

standards established by the AAQ Directives. While the number of zones reporting exceedances of the 

limit or target values decreased between 2008 and 2017 for all air pollutants except PM2.5 (4 in 2008 

and 8 in 2017), the Fitness Check concluded that in 2017 there remained a number of zones that 

exceeded the respective limit values. This is an ongoing challenge. For example, in 2020, limit values 

for annual averages were exceeded in 31 zones for NO2, 10 for PM10 and 13 for PM2.5 (EEA, 2020). 

Although the frequency, extent and magnitude of exceedances have decreased since 2008, the Fitness 

Check concludes that, where exceedances occur, enforcement action at the EU level is not always 

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adequate with the result that exceedances are not always addressed sufficiently and/ or in a timely 

manner.  

Directive 2008/50/EC states only that penalties must be effective, proportionate and dissuasive. This 

has led to different approaches to enforcement between Member States and a limited use of penalties 

in Member States with little impact on air pollution reduction. The extent to which enforcement action 

is effective, proportionate and dissuasive is unclear from the evidence included in the Fitness Check. 

The Fitness Check did however highlight the effectiveness of enforcement action by the European 

Commission and civil society by way of proceedings in court (both before the Court of Justice of the EU 

and before national courts), which has led to actionable rulings to accelerate air quality improvements 

to achieve air quality standards. 

The European Commission has increased its enforcement action against Member States for systematic 

and persistent exceedances of limit values. These have resulted in multiple infringement cases related 

to the breach of pollutant limit values (a total of 14 cases for PM10 and/or PM2.5, 14 for NO2 and 1 for 

SO2). The number of continued exceedance situations can be seen as an indication that Member State 

penalties are not sufficiently effective, proportionate nor dissuasive, with the effect that the 

legislation has not been adequately implemented.  

As summarised in the Fitness Check, court proceedings from cases before national courts and from 

cases before the Court of Justice of the EU show that the claimants often maintain that air quality 

plans were not adequate and/ or sufficient measures were not adopted to address air pollution 

problems. While the defences maintain that challenges in meeting EU standards arise because of 

external factors (including socio-economic conditions, cost and administrative difficulties, natural 

sources, meteorological conditions, and emissions occurring from outside the local areas), the fact 

remains that certain air quality plans currently adopted by national authorities and the measures 

contained therein do not always facilitate planning to adequately address the air quality challenge. 

Linked to enforcement, an overarching issue for governance shortcomings is that air quality plans do 

not always effectively address all sources of pollution affecting air quality. Reasons for this identified in 

the Fitness Check include: 

• 

The AAQ Directives do not require Member States to report on the implementation of air 

quality plans, or to update them when new measures are adopted or when progress is 

insufficient – only to update plans at the end of the plan’s period (European Commission, 

2019).  This makes it difficult to verify compliance with the air quality plan provisions of the 

AAQ Directives. However, it was also found in a targeted survey conducted as part of the 

“Strengthening of air quality monitoring, modelling and plans under the Ambient Air Quality 

Directives” study (Conlan et al., 2022), that of the representatives of 14 Member States, 10  

reported that their air quality plans had been updated over the past 5 years with many of the 

current air quality plans being published between 2018-2020, and these were an update of 

previous plans dated in the range 2011-2016. These plan updates may have been driven by 

infringement proceedings brought by the European Commission for failure to meet certain limit 

values. 

• 

There are a lack of national plans for measuring ambient air policy effectiveness and an 

absence of performance indicators. 

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• 

Air quality plans are not viewed as an emergency tool to address serious hazards to public 

health, as such urgency is not always evident in the planning process. 

•  Methods used for forecasting the evolution of air quality, and the underlying assumptions and 

uncertainties, vary between and within Member States. There is limited information available 

on the approaches taken. As such, the projected impacts included in air quality plans are often 

lacking rigour and cannot be compared with one another. 

• 

Evidence of public participation during the adoption of air quality plans is not always apparent. 

It is often unclear which aspects of this planning process have been open to public consultation 

and what this involved. 

• 

There is a lack of awareness of air quality across the institutions responsible for sectoral 

emission control.  This has led to short-term thinking and delayed national action on improving 

air quality policy.  

•  Not all air pollutant precursors are directly attributable to emission sources, for example, O3 

concentrations are highly influenced by meteorological conditions. Measures can therefore 

seem disproportionate to sectors. 

• 

The extent of devolution to local level authorities has been found to have both positive and 

negative implications for efficiency. Sometimes, devolution to local level authorities has led to 

unclear direction (compared to action led by national authorities) and weak communication 

across different tiers of government. Competences and the division of responsibilities to 

implement the measures are not always suitably defined. Coordination between different 

levels of governance (national, regional, local) is a key challenge. 

• 

As regards funding, the Fitness Check refers to instances where EU funds are used to support 

projects that may have adverse effects on air quality. The example used relates to biomass 

investments (in the 2014-2020 multi-annual financial framework period, EUR 1.6 billion was 

allocated to biomass under the cohesion policy’s objective of supporting the shift to a low-

carbon economy). The actual impact of these investments on air quality is dependent on the 

specific projects and contexts.  

An additional problem occurs as a result of transboundary air pollution. The 2021 EMEP Status Report 

for transboundary particulate matter, photo-oxidants, acidifying and eutrophying components shows 

the extent of transboundary pollution in Europe and the way in which external factors such as the 

weather contribute to further challenges (EMEP, 2021). Member States face both intra-EU and extra-EU  

transboundary air pollution. While transboundary air pollution is primarily addressed by the NEC 

Directive (Directive 2016/2284/EU), the Convention on Long-range Transboundary Air Pollution (the Air 

Convention) and the Gothenburg Protocol, the AAQ Directives include provisions to facilitate Member 

State’s planning in this regard (a mechanism for joint cooperation between Member States on joint or 

coordinated air quality plans in case of transboundary air pollution, Article 25 of Directive 2008/50/EC). 

However, the Fitness Check findings show that this provision is rarely complied with. Reasons for low 

compliance include: “lack of resources at local authority level to solve issues with air pollution in 

neighbouring Member States close to common borders, lack of guidance on how Article 25 should be 

implemented in practice given different legislative settings across Member States, or perceptions that 

Article 25(2) should only be called upon when Member States were not able to solve a dispute by 

themselves”. The Fitness Check findings highlight that the lack of coordination is likely to affect the 

understanding of which measures may prove most useful and effective.  

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  Monitoring and assessment shortcomings  

Findings from the Fitness Check show that there are uncertainties regarding the current monitoring 

rules. Uncertainties arise from flexibilities (provisions intended to facilitate Member States), instances 

where the problem of air quality has evolved, and lack of clarity in the current provisions. These 

flexibilities and uncertainties are key drivers which have led to monitoring and assessment shortcomings 

where diverging approaches have sometimes impacted the comparability of data.  

First, the assessment of exposure and exceedance of air quality is not always representative. Air 

quality management and assessment is carried out by air quality zone or agglomeration. Therefore, the 

definition of air quality zones and agglomerations in Member States is the basis for reporting air quality 

information under Directive 2008/50/EC. In most Member States the definition of the air quality zones 

have not changed over the last 10 years (Conlan et al., 2022). However, Member States differ in their 

methods of establishing air quality zones, with many relying on existing administrative units and their 

boundaries as well as on the population density over these existing administrative units. Others, 

however, also take into account available information on air quality levels, involving pre-existing 

monitoring data as well as modelling and emission information.   

These differences in approach have led to further inconsistencies, such as how to determine the area 

where the measured exceedances apply. In principle, this relates to the area of representativeness of a 

specific sampling point, so that the area with exceedance of limit values should be the same as the 

area of representativeness of the sampling points measuring the exceedances. The consequence of this 

is a lack of consistency for the calculation of exposure and exceedance indicators which Member States 

should report, which means data for indicators of air quality are either not reported because they are 

difficult to calculate (among the findings for the study “Strengthening of air quality monitoring, 

modelling and plans under the Ambient Air Quality Directives”), or where the data are reported, they 

are not comparable. Very few Member States report these indicators on an annual basis (see Table 2 for 

those who reported in 2020). 

Table 2 Number of Member States reporting exceedance/exposure indicators in 2020 

Indicator 

Ecosystem Areas Exposed 

Population Exposed 

Road Length in exceedance 

Surface Area in exceedance 

Source: (EEA, 2021) 

Number of Member States reporting 

6 

15 

6 

16 

Another issue is that siting criteria for sampling points lacks clarity for a full assessment of air 

quality. Annex III to Directive 2008/50/EC provides criteria for siting monitoring stations for all air 

pollutants except ozone (O3), whilst Annex VIII describes the siting criteria for ozone. Siting criteria are 

given on two different scales: a) a macroscale siting criterion that defines the general position of 

monitoring stations within a zone; and b) a microscale siting criterion that addresses the immediate 

vicinity of the monitoring station.  

According to responses to a survey undertaken for (Conlan et al., 2022), the majority of Member States 

find it difficult to determine the best location for monitoring sites but in addition once a site is 

established it is difficult to know what spatial area it represents. This is important as it impacts the 

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spatial coverage of the monitoring network to ensure the maximum pollution concentrations are 

included. It also impacts the assessment of the size of population exposed to poor air quality. 

Therefore, the full assessment of air quality has shortcomings which are unlikely to change without 

further clarity. 

In  addition,  the  given  definition  of  sampling  point  types  and  classification  lacked  clarity  particularly 

around  the  role  of  industrial  sampling  points  and  whether  they  should  be  linked  to  specific  industrial 

plant. This has resulted in industrial sampling points not necessarily being located in the best position to 

assess population exposure or there can be too few sampling points to do this comprehensively. This has 

resulted in incomplete information to assess the impact of emissions from industrial sites. 

A related issue is that the minimum number of sampling points are not always adequate to fully 

assess air quality. The Fitness Check concluded that most zones in the Member States have the 

required minimum number of sampling points. However, the extent to which there are sufficient 

sampling points in the right locations was brought into question. Findings from a survey undertaken for 

(Conlan et al., 2022) show that among Member States there is a generalised view in that the monitoring 

of ozone outside cities does not necessarily require revision, while the monitoring of complex mixtures 

of pollution in urban areas, such as for particulate matter, requires an increased number of fixed 

measurements. 

Annexes III, V, VIII and IX to Directive 2008/50/EC define the number and type of sampling points 

required for the assessment of air pollution. However, when Member States do not increase their 

sampling points above the minimum number, they do not always have the capability of identifying areas 

of maximum concentration levels in urban areas based on a limited number of fixed measurements 

alone. Therefore, this can lead to unidentified pollution hotspots, where public health could be 

negatively impacted. 

The  use  of  indicative  measurements  to  assess  air  quality  is  unclear.  Under  Directive  2008/50/EC, 

Member  States  can  rely  on  supplementary  air  quality  assessment  methods  including  indicative 

measurements. Some Member States are now including  these in their reporting  (primarily passive NO2 

diffusion tubes results, used in Belgium, France and Germany). It is not always clear how these methods 

have to be implemented and what data quality is sufficient to apply the methods in a formal assessment 

process. This has led to uncertainty in data quality and how much weight can be put on this data to assess 

air quality. 

Low-cost sensor technology is rapidly emerging in Europe, often driven by citizen science, academic or 

commercial initiatives. Many Member States are facing local initiatives where low- cost sensor 

technology is used (with or without expert knowledge) in the air quality debate. Given the large variety 

of sensor technologies currently available on the market and the lack of a general application 

framework for sensor networks, it is hard to identify sensor uncertainty in a generic way and assess the 

quality of the extracted information. 

Alongside problems relating to monitoring, there have been substantial developments as regards the 

use of modelling techniques since the AAQ Directives entered into force. Modelling is increasingly used 

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by Member States to assess air quality, driven by improved modelling ability (through FAIRMODE32) (see 

Table 6-5 of the accompanying evaluation to the Fitness Check summarising Member State use of 

modelling to assess air quality).  

Modelling can be helpful for various air quality management practices. Findings from a targeted survey 

undertaken (Conlan et al., 2022) of experts involved in monitoring, modelling and development of plans 

showed that 61% of respondents (n=79) reported that they used complex modelling to assess air quality. 

Of these, most used modelling for the development of air quality plans (75%) and source apportionment 

(70%) and less for the assessment of exceedances (62%), health impact (51%) or for now casting (44%).  

For those using models for air quality plans only 26% of respondents to the survey used complex 

modelling to estimate future projections with and without measures to determine when compliance is 

likely. To show if exceedance periods are kept as short as possible, as required by the provisions in the 

AAQ Directives, this model application is required, and therefore many Member States are unable to 

present such evidence.  

There are a wide range of modelling approaches in use across Europe, which leads to low comparability 

between modelling results between Member States. Models can be used over a wide range of spatial 

scales from many kilometres down to one metre. A key issue is the lack of a harmonised approach on 

how to use modelling as a supplementary assessment method. Current practice lacks consistency as, for 

example, results of a regional scale model with a resolution of a few kilometres cannot be compared to 

the results of a street scale model.  

For the estimation of  exceedance situation indicators, street scale models are generally used. This is a 

sound choice because many exceedances have a local character and require modelling tools with 

sufficient spatial resolution to be captured. Modelling tools are regularly used for the detection of new 

hot spots, but only a small fraction of these modelling results are actually reported under the e-

Reporting framework. Most of the modelling exercises on hot spot detection are used to inform the 

public. Consequently, as not all modelling data are reported, there is confusion as to what is official 

data and what is informal data, and there is a low level of confidence associated with these various 

datasets. 

The quality of modelling is fundamental to its usefulness in air quality assessment but in practice, the 

quality of modelling sometimes is not robust.  A basic component of robustness is model validation, 

where the outputs from the model are statistically compared to monitoring data available within the 

model domain. This informs the level of confidence that can be applied to the model results.  

Findings from a survey by (Conlan et al., 2022), showed that the majority (75%) of modelling 

applications used in the context of the AAQ Directives are validated. This could be considered as a 

significant fraction. However, this also means that many (25%) of the modelling applications are still 

not validated which could be seen as a serious concern to the overall quality of the modelling. 

FAIRMODE have proposed a Modelling Quality Objective (MQO) and in slightly more than half of the 

32 FAIRMODE or the Forum for Air quality Modelling was launched in 2007 as a joint response initiative of the 
European Environment Agency (EEA) and the European Commission Joint Research Centre (JRC). The forum is 
currently chaired by the Joint Research Centre. Its aim is to bring together air quality modelers and users in order to 
promote and support the harmonized use of models by EU Member States, with emphasis on model application under 
the European Air Quality Directives. For further information see: https://fairmode.jrc.ec.europa.eu/ 

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cases where modelling is validated, the harmonised FAIRMODE MQO (Janssen & Thunis, 2020) is already 

used as the QA/QC framework.  

In addition, there is some confusion over how many monitoring stations are required to validate a 

model and in particular what process should be followed when there are only a limited number of 

stations available in the modelling domain. Adding to this, definitions are not included in the AAQ 

Directive for the type of monitoring station (traffic, industrial or background) and the area 

classification (urban, suburban or rural), resulting in inconsistencies between Member States and within 

Member States. It is also challenging to verify compliance with the minimum requirements between 

traffic and background stations. 

To summarise, the legislation does not support wide use of modelling, which makes it more difficult to 

compare data. Issues affecting comparability of air quality data have arisen from inconsistencies in the 

use of indicative measurements, and the selection of monitoring station types (traffic, background). In 

addition, emission inventories are not referenced in the AAQ Directives but provide input to modelling 

(among other things). The AAQ Directives are not sufficiently clear about the use of modelling and the 

need to report modelling results. This in turn impacts the comparability of modelled data to assess air 

quality in the EU. 

Information and communication shortcomings  

There is a growing body of evidence and a rapidly evolving communication technology, information on 

air quality, associated health impacts and measures to address exceedances. This information is not 

always readily available to the public or in an accessible format that the general public can understand. 

These factors are contributing to a general feeling among the public of being under informed. A 2019 

Eurobarometer survey found that more than half of Europeans (54%) say they are not informed about air 

quality problems (European Commission, 2019). 

The availability of public and comparable information on air quality in Member States enables the 

public to identify where air pollution levels are particularly high and better understand the risks to 

health. While there is a wealth of information concerning air quality, information is not always publicly 

available or accessible. The Fitness Check established that air quality is of importance to EU citizens 

and that many are of the opinion that air quality has deteriorated in the EU. The fact that air quality 

has in fact improved is indicative of the fact that information is not readily available and/ or clear. 

Findings from the Fitness Check show that air quality data is available at EU level (via Air Quality e-

Reporting database, the EEA’s EIONET Reporting Obligation Database and the EEA’s on-line information 

services and European Air Quality Index). Overall, the Fitness Check concluded that the AAQ Directives 

have facilitated the availability and accessibility of reliable and comparable air quality data across the 

EU, with a clear EU added value. However, further harmonisation of the way air quality information is 

presented would be both possible and desirable, and help ensure even higher comparability. 

Information concerning impacts of air quality is not consistently available at Member State level. As a 

result, public concerns about health impacts continue and there is a feeling of being under-informed. 

Findings from the Fitness Check include: 

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• 

Relevant air quality information was accessible for 11 out of 28 Member States (at the time of 

the Fitness Check) and only 12 Member States were found to publish annual reports with 

information on exceedances and their effects; 

• 

Directive 2008/50/EC requires Member States to set information and alert thresholds for O3, 

NO2 and SO2 that, in case of exceedance trigger the provision on informing the public (Article 

19 of the Directive) and in case of risk of exceedance trigger the provision on the development 

of short-term action plans (Article 24 of the Directive). However, approaches between Member 

States vary in relation to the collection, assessment and reporting of information. Moreover, 

the provision does not extend to PM (only 13 Member States have set information and alert 

thresholds for PM10 and only 2 for PM2.5). Overall, the levels of thresholds can vary considerably 

between Member States and within them. 

•  Member State authorities do not always use available media platforms and technology, such as 

social media and smartphone apps, to disseminate information. 

  Obsolete provisions 

The Fitness Check highlights that the AAQ Directives include provisions that have become redundant: 

• 

Five-year timeframe allowing for postponement of attainment deadlines and the exemption 

from the obligation to apply certain limit values until June 2011 (Article 22 of Directive 

2008/50/EC and Annex XV, Section B on the information to be provided under this provision); 

• 

2013 European Commission review of the provisions related to PM2.5 and, as appropriate, other 

• 

• 

pollutants (Article 32 of Directive 2008/50/EC); 

2010 European Commission review of the Directive 2004/107/EC (Article 8 of Directive 

2004/107/EC). 

The references in Directive 2008/50/EC to margins of tolerance that were applicable until a 

certain date (e.g.: until 1 January 2020 for NO2) 

  Who is affected by the problems? 

Table 3 shows an overview of stakeholders affected by the problems set out in Section 3.2.  

Table 3 Overview of stakeholders affected 

Stakeholder 

Related problems 

Impact on stakeholder group 

Citizens are exposed to poor air quality. 

Citizens residing in hot spots are particularly 

vulnerable as a result of high exposure to air 

Environment and health shortcomings - 

pollution. 

EU standards are not aligned with 

Citizens with existing medical conditions and 

scientific advice. 

citizens in vulnerable groups (such as children, 

pregnant women and the elderly) may be at 

Information and communication 

higher risk from exposure. Likely to have 

shortcomings - Public feels under 

increased concerns with the knowledge that 

informed about poor air quality and its 

they are particularly vulnerable to poor air 

impacts. 

quality. 

Due to current dissemination of information, 

citizens do not have equal access to relevant 

information allowing them to make informed 

32 

Citizens 

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Stakeholder 

Related problems 

Impact on stakeholder group 

Business 

association/ 

business 

organisation 

decisions that may help reduce their exposure 

to poor air quality, or even how they may 

contribute to improving air quality in their local 

area. 

Environment and health shortcomings - 

Businesses may be affected by productivity 

EU standards are not aligned with 

impacts of poor air quality (e.g. reduced 

scientific advice. 

workforce, lower agricultural yields, etc.) 

The lack of flexibility to amend standards in 

Enforcement and governance 

accordance with evolving technologies and 

shortcomings -  

science may hinder businesses from investing in 

Air quality plans do not always address 

new technologies that could improve air 

all sources effectively 

quality. 

There is a risk of contributing to an uneven 

Monitoring and assessment 

playing field between businesses operating in 

shortcomings - 

different Member States if standards are made 

Flexibilities may sometimes impact the 

more stringent by some and not others (e.g. to 

comparability of data 

align with WHO guidelines). 

The need to address poor air quality in hot 

spots requires urgent and costly action at local 

Enforcement and governance 

level. Efficiency opportunities are missed where 

shortcomings -  

the approach to assist communication and 

Air quality plans do not always address 

planning between authorities is not 

Regional and local 

all sources effectively 

standardised. 

competent 

authorities 

Exceedances will continue to be adversely 

Monitoring and assessment 

affected by transboundary emission sources 

shortcomings - 

with limited support to address the issue at 

Flexibilities may sometimes impact the 

source. 

comparability of data 

Uncertainty over competences and 

Enforcement and  governance 

shortcomings -  

Air quality plans do not always address 

all sources effectively 

Monitoring and assessment 

shortcomings - 

Flexibilities may sometimes impact the 

comparability of data 

National 

competent 

authorities 

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responsibilities between local, regional and 

national authorities.  

Risk of inefficiencies when planning and 

implementing measures in air quality plans. 

Reduced capacity to learn from other Member 

States owing to disparities in monitoring and 

modelling. Lack of a level playing field where 

exceedances may be reported using disparate 

monitoring and modelling methods. 

Uncertainty over competences and 

responsibilities between local, regional and 

national authorities. May act as a deterrent for 

authorities to act as needed to address air 

quality issue. There is also a risk of facing 

enforcement actions by the European 

Commission in case of persistent exceedances. 

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Stakeholder 

Related problems 

Impact on stakeholder group 

Environmental 

Enforcement and governance 

resources to identify areas with air quality 

organisations and 

shortcomings - Exceedances are not 

standard exceedances, investigate the causes 

Non-governmental 

always addressed sufficiently and/ or 

and find remedies (i.e. taking authorities to 

organisations 

timely 

court where air quality plans are failing to 

Non-governmental organisations are investing 

Monitoring and assessment 

Academic/research 

shortcomings - 

institution 

Flexibilities may sometimes impact the 

comparability of data 

deliver air quality improvements).  

Disparities between monitoring and modelling 

will affect access to comparable data at EU 

level.  

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4  Why should the EU act? 

  Legal basis  

The legal basis for the EU to act on air quality lies in Articles 191 and 192 of the Treaty on the 

functioning of the European Union (TFEU). In accordance with Article 191(1) of the TFEU, EU policy on 

the environment shall contribute to pursuit of the following objectives: “preserving, protecting and 

improving the quality of the environment; protecting human health; prudent and rational utilisation of 

natural resources; promoting measures at international level to deal with regional or worldwide 

environmental problems, and in particular combating climate change.”. This is the same legal basis 

that underpins the current Ambient Air Quality Directives.  

  Subsidiarity 

In accordance with Article 4(2), point (e) of the TFEU, environment is an area of shared competence 

between the EU and the Member States, which means that EU action must respect the principle of 

subsidiarity. Under this principle, the EU can only act if the proposed action cannot be sufficiently 

achieved at Member States’ level (necessity of EU action) and can be better achieved at EU level 

(added value of EU action).  

Having regard to the subsidiarity principle and to what is set out in Articles 191, 192 and 193 of the 

TFEU: 

• 

• 

• 

• 

• 

EU air quality standards are needed to assure an equal degree of protection for EU citizens. 

Transboundary air pollution contributing to poor air quality requires EU intervention. 

EU intervention shall respect the flexibility needed to account for the environmental 

conditions in the various regions of the EU – particularly to account for transboundary air 

pollution and meteorological conditions that affect air quality; 

The effectiveness of the current EU air quality standards demonstrates the benefit of EU 

action. 

In view of the risks to disparate impacts relating to economic and social development between 

regions, EU intervention is appropriate to ensure a fair playing field. 

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5  What should be achieved? 

  Objectives of intervention 

General objectives for the impact assessment were defined in the Inception Impact Assessment 

(European Commission, 2021): 

• 

• 

• 

to avoid, prevent or reduce the harmful effects of air pollution on human health and the 

environment, in line with the European Green Deal and the Zero Pollution Action Plan; 

to further enhance the effectiveness of EU air quality legislation; 

to improve the efficiency of the legislation taking into account the lessons learnt from the 

fitness check, making it easier to meet a given level of effectiveness.  

This is complemented by a suite of specific objectives, as presented in Figure 6. 

Intervention logic 

Figure 7 presents the intervention logic summarising: 

• 

• 

• 

The shortcomings, their drivers and the consequences of inaction; 

External factors;  

Focus areas for further and/ or improved EU intervention. 

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Figure 6 – Objectives for the intervention 

Shortcoming 

Drivers 

Intervention needs 

Specific objectives 

Exceedances above 

health guidelines and 

negative health impacts 

Environment and health 

persist 

shortcomings 

Lack of flexibility to 

adapt to evolving science 

and new 

recommendations 

•  Reduce exposure to harmful levels of air pollution, 

with reference to best-practice guidance regarding 

safe levels of exposure 

•  Ensure legislation can appropriately and effectively 

respond to future changes in underlying evidence 

base 

•  Penalties should be proportionate and sufficiently 

Insufficient penalties and 

dissuasive to underpin effective enforcement  

damages linked to 

•  Ensure citizens’ rights to compensation are 

exceedances 

effectively enshrined and supported by the 

Directive 

•  Minimise the risk that limit values are exceeded 

Enforcement and 

Air quality plans and 

•  Air quality plans should be an effective means of 

governance shortcomings 

measures have often 

identifying, planning and mitigating an exceedance 

proven ineffective or may 

issue 

seem disproportionate 

•  Measures proposed should be relevant, effective 

and proportionate to the problem 

Specific objective 1: Improve ambient air quality to 

the extent possible taking into account the latest 

scientific advice, feasibility, costs, and benefits – and 

ensure legislation can respond in an appropriate and 

effective manner to future changes in underlying 

evidence base. 

Specific objective 2: Assure air quality plans are an 

effective means of identifying, planning and 

mitigating an exceedance situation (by taking 

relevant, effective and proportionate measures) – and 

include clearer provisions on stakeholder 

participation, access to justice, penalties and 

compensation linked to clean air in EU legislation. 

Local air quality is 

impacted by emission 

outside control 

Monitoring rules offering 

flexibility are ‘stretched’ 

in instances 

Monitoring and 

assessment shortcomings 

•  Resolution of exceedance issues should effectively 

involve all relevant stakeholders and sources 

•  Monitoring should be an effective tool which is 

consistently applied to identify exceedance areas 

Specific objective 3: Further improve monitoring as an 

effective and reliable tool which is consistently 

applied to identify exceedance areas – and harvest 

37 

Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Shortcoming 

Drivers 

Intervention needs 

Specific objectives 

Modelling ability has 

•  Ensure that modelling is used consistently to 

opportunities offered by air quality models to 

improved, allows for 

underpin the development of plans and monitor 

underpin the development of plans and monitor 

much more detail 

exceedances 

exceedances. 

Information and 

communication 

shortcomings 

Relevant to all 

shortcomings 

Concerns about health 

•  Information provided to citizens around air pollution 

impacts have increased, 

issues should be sufficient, and relevant (targeting 

not addressed 

the concerns of citizens) 

•  Public information is available and harmonised. 

Public information is not 

Information should be clear and coherent, based on 

always available, and not 

a robust evidence base, and be consistent across 

harmonised 

Member States 

Specific objective 4: Provide information to citizens 

around health impacts of air pollution issues 

(targeting the concerns of citizens) – and ensure that 

the public in all Member States receive the same high 

quality and timely information about their air quality. 

Specific objective 5: Simplify existing provisions 

where feasible to improve the effectiveness and 

n/a 

•  Horizontal need for simplification 

efficiency of air quality management – and decrease 

associated administrative burden if and where 

possible. 

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Figure 7 – Intervention Logic (DG ENV) 

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6  Approach to the analysis 

  Overview of approach to the analysis 

A range of interventions have been defined to revise various elements of the AAQ Directives under the 

three Policy Areas. Each intervention has a number of associated impacts, with the exact impacts, their 

size and significance depending on the individual intervention. To assess the impacts, the study has 

followed a methodology designed to meet the requirements of the Better Regulation Guidelines 

(European Commission, 2021) and to provide the European Commission with timely evidence collection, 

stakeholder engagement and analysis of information gathered. 

Based on the Better Regulation Guidelines, interventions should be compared on the basis of how they 

address the objectives considering their effectiveness, efficiency and coherence. All interventions were 

screened for their likely key economic, environmental, and social impacts across the core stakeholders 

– competent authorities, other public authorities, industry (large and smaller businesses), citizens and 

workers. Twelve indicators have been defined to capture and present the key economic, 

environmental, and social impacts associated with the interventions being considered. All interventions 

across the three Policy Areas will be appraised against this set of indicators, to ensure consistency in 

the analysis and presentation of results. The twelve indicators are defined in Table 4.  

Across each of these specific indicators, available evidence on the effectiveness, efficiency and 

coherence of the Policy Packages was collated, assessed and, where possible, quantified in comparison 

to the baseline. To support the assessment of impacts, evidence gathering has comprised of three main 

activities: Quantitative modelling, in particular focusing on the impacts of different air quality 

standards under Policy Area 1 - this has been carried out using an established mature integrated 

assessment framework, as described in Section 6.2 (further information in Appendix 3); detailed 

literature review (see Section 6.3) and extensive stakeholder engagement (see Section 6.4). 

Where possible the study has sought to quantitatively assess the impacts, but this has not been possible 

in all cases. Where quantification was not possible, impacts were assessed in a qualitative way, clearly 

indicating the type of most important impacts and their likely magnitude. For interventions considered 

under Policy Areas 2 and 3, quantitative assessment of impacts is much more challenging. The effects 

of these options on key indicators (e.g. levels of air pollution) are more indirect, uncertain and 

therefore difficult to isolate, attribute and measure. In these cases, the analysis is predominantly 

qualitative, based on evidence gathered from the literature (not least the preceding Fitness Check of 

the Ambient Air Quality Directives and the parallel study on “Strengthening of air quality monitoring, 

modelling and plans under the Ambient Air Quality Directives” (see chapter 2.1.1.)), feedback from 

stakeholder engagement and stakeholder engagement. As such, the overall assessment combines both 

quantified and non-quantified effects.  

Across all interventions, the effects have consistently been mapped to the twelve indicators for 

consistency, assigning a ‘score’ based on an underlying framework. In general, colour-coding is used to 

summarise the qualitative assessment of impacts referring to the direction (positive or negative) and 

magnitude (small or large) of any expected impacts, relative to the baseline (see Table 5).  

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Table 4 : Twelve indicators used as the basis for the in-depth assessment  

Broad impact 

category 

Indicator  

Concentration levels of air pollutants, at (a) background locations, and (b) ‘hot-

spot’ (incl. both traffic and industry-related) locations, and their development over 

time; 

Health impacts of air pollution, for example the health impacts resulting from 

exposure to particulate matter (PM2.5 and/or PM10), nitrogen dioxide and ozone; 

Ecosystem impacts of air pollution, including acidification, eutrophication, ozone 

damage to vegetation and agricultural yields; 

Links between air pollution and climate change, including increased ozone levels 

due to global warming, and co-benefits or trade-offs between climate and air 

pollution abatement measures; 

Environmental 

impacts 

Indicator 

# 

1 

2 

3 

4 

Synergies with other goals of the (upcoming) EU Zero Pollution Action Plan on air, 

water and soil. This includes premature death reduction (indicator 2) and 

ecosystem impact (indicator 3) goals. It additionally reflects the synergistic role of 

11 

indoor pollution (notably in terms of exposure and health impacts) or co-benefits in 

reducing noise pollution. 

Cost to society due to air pollution, including health and healthcare impacts and 

costs, lost working days, crop and animal value loss, losses to other assets and 

other costs avoided by taking action to reduce air pollution; 

Measures needed to meet EU air quality standards - and their costs, including costs 

for key economic sectors, and regional differences across the EU of the costs and 

benefits of the air pollution abatement measures; 

Positive and negative impacts on the EU’s international competitiveness, including 

tapping into innovation potential for clean air technologies; 

Administrative burden of air quality management, in particular as relates to air 

5 

6 

7 

quality assessment regimes (including monitoring, modelling, and reporting of 

12 

Economic 

impacts 

related data) (Indicator #12) 

Effects of air pollution on sensitive population groups, including children, pregnant 

women, elderly citizens and those suffering from pre-existing conditions; 

Social impacts 

Societal impacts of air pollution and societal impacts of air pollution abatement 

measures, including resulting inequalities (i.e. who is most affected, who bears the 

costs); 

Effects of measures to address impacts of air pollution on employment; 

8 

9 

10 

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 5: Coding used to present expected impacts 

+++  

++   

+ 

(+)   

+/- 

0 

(-) 

- 

- - 

- - - 

Very significant direct positive impact (e.g. Indicator 1 – Air Quality: full alignment WHO AQG for 
PM2.5*)  
Significant direct positive impact 

 Small direct positive impact  

Indirect positive impact  

Both direct positive and negative impacts, and balance depends on how implemented  

No impact or only very indirect impacts 

Indirect negative impact 

Small direct negative impact 

Significant direct negative impact 
Very significant direct negative impact (e.g. Indicator 6 – Mitigation Costs: costs of maximum 
feasible technical potential (MTFR or MFR) and more*) 

*Examples included in the table are illustrative and relate to specific indicators. The range for each indicator has been set to define 

the maximum positive and negative effect for that indicator specifically (hence as such, for Indicator 1 describing Air Quality effects, 

the maximum positive effect will be associated with full alignment with the WHO AQG for PM2.5). All interventions across all Policy 

Areas 1, 2 and 3 have been assessed using a consistent scale for each indicator, to ensure consistency and comparability in the 

assessment across Policy Areas. As such, the scoring inherently captures a comparative, relative assessment across indicators. 

  Quantitative modelling 

Quantitative modelling has been conducted with the state-of-the-art, regional models, including: the 

Greenhouse gas – Air pollution Interactions and Synergies (GAINS) model and MET Norway’s chemical 

transport model (EMEP CTM) with the uEMEP downscaling extension for fine resolution. The models 

were used to estimate air pollutants’ emissions, ambient concentrations, ecosystem impacts, and to 

assess the feasibility of attaining particular air quality targets as well as respective measures and their 

costs. 

The GAINS integrated assessment model, developed at the International Institute for Applied Systems 

.
5) 
Analysis (IIASA), addresses air pollution impacts on human health from fine particulate matter (PM2

and ground level ozone (O3), vegetation damage caused by ground level ozone, the acidification of 

terrestrial and aquatic ecosystems and excess nitrogen deposition on soils. GAINS brings together data 

and projections of the economic development and structure, emission control potential and costs of 

mitigation measures, the formation and dispersion in the atmosphere of - as well as the inter-relations 

between - pollutants such as sulphur dioxide (SO2), nitrogen-oxides (NOx), particulate matter (PM), non-

methane volatile organic compounds (NMVOCs) and ammonia (NH3). GAINS assesses more than 1,000 

emission control measures for all emission sources in the EU and key air pollutants, computes the 

atmospheric dispersion of pollutants and analyses the costs and environmental impacts of pollution 

control strategies. The emission characteristics of sources and measures, their current application rates 

as well as their costs are updated regularly drawing on the work of international task forces33 and 

working groups as well as occasional consultations with Member States34, industrial stakeholders, and 

peer reviewed studies. The last update of the data and assumptions was done during the study 

supporting the development of the second Clean Air Outlook while preliminary assumptions about Euro 

7 were introduced only during this study using CLOVE consortium proposal. The assumptions, as used in 

33 For example, UNECE Task Force on Techno-Economic Issues (TFTEI), Task Force on Emission Inventories and Projections (TFEIP) and 
respective updates to the EMEP/EEE guidebook, Task Force on Reactive Nitrogen (TFRN)  
34 The last formal consultations with the MS were done during the thematic Strategy work, but currently a new round of consultations 
takes place within the ongoing support for the third Clean Air Outlook 

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

the 2nd Clean Air Outlook, are available in the online GAINS model application (GAINS, 2022). More 

details on the atmospheric calculations in the GAINS model, and a discussion on the consistency with 

the EMEP CTM model, are given in Appendix 3. 

In its optimisation mode, GAINS identifies the cost-effective emission control strategies that can be 

used to inform policy processes and international negotiations on mitigation of atmospheric air 

pollutants to achieve proposed concentration or emission reduction targets. The GAINS cost-

effectiveness analysis proceeds in two broad steps. First, starting from the baseline, the lowest 

technically feasible emission level is established by minimizing the total emissions, while ignoring the 

costs. The model then chooses the most effective portfolio of emission reduction technologies for each 

country and each pollutant, while respecting the relevant technological constraints, such as maximum 

application rates, capital vintage structure and limitations in the scheduling of new technologies. The 

result is what is called the maximum (technically) feasible scenario (MTFR or MFR), which, together 

with the baseline scenario defines the space of feasible scenarios: the emissions of any cost-effective 

reduction scenario will lie between the baseline and MTFR levels. Note: The GAINS model only contains 

technical measures for which unit costs can be robustly quantified. The values for unit costs of non-

technical measures, i.e. those that involve behavioural changes such as a shift in diet, depend on the 

exact methodology that is used to quantify them, and hence it is more challenging to estimate costs 

with certainty. Therefore, the benefits of packages comprising of such measures are best estimated on 

a scenario basis without reference to cost-effectiveness vis-a-vis alternative measures. 

In a second step, a specific target is set in the model, and the optimisation routine identifies that 

portfolio of emission reduction technologies which reaches the given target at lowest costs. Such a 

target can be formulated, e.g., as a concentration target at the grid level in GAINS, or as a population-

weighted concentration target at the country level, or an emission target.  

Here we have deployed the optimization to identify cost-effective solutions to predefined 

concentration targets at the grid-cell level. In particular, targets are set for 15 µg/m3, 10 µg/m3 and 

5 µg/m3 for the years 2030 and 2050 (also 20 µg/m3 for the year 2030). In some locations some of these 

targets cannot be reached, i.e., even at the lowest technically feasible concentration level (i.e., in the 

MTFR scenario) the concentration level in these grid-cells exceeds the target level. This happens in 

heavily polluted areas and would, if the target values are taken strictly literally, mean that such a 

target cannot be achieved everywhere in Europe, and thus render the target setting infeasible. In 

Section 8.1.1 more details are given on how targets are set in such situations.  

The EMEP CTM is a state of the art atmospheric chemistry transport model, and includes a recently 

developed novel, but well documented (see Denby et al., 2020; EMEP report 2020) uEMEP (urban EMEP) 

downscaling module that allows the estimation of ambient air pollution concentrations down to a grid 

resolution of approximately 250x250 m2 for the whole of Europe. Downscaling is carried out where 

suitable high resolution emissions proxies are available. This includes the emission sectors for traffic, 

shipping, aviation, non-mobile sources and residential heating. All other sectors are modelled using the 

EMEP model at a resolution of 0.1o. Gridded EMEP emissions are redistributed using the emission proxies 

and high resolution concentrations are calculated, providing consistency between scales. Downscaling is 

carried out only on primary emissions, with the exception of NO2 that is calculated based on a 

simplified NOX – OX chemistry scheme. For this application annual mean concentrations are calculated 

with the EMEP model under different policy scenarios for the following pollutants: SO2, NO2 and NOx, 

43 

 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

PM10, PM2.5, NMVOC, O3, NH3, BaP, benzene and carbon monoxide (CO). Downscaling of annual mean 

concentrations is applied to a selection of these pollutants, namely PM2.5, PM10, NO2, BaP, Benzene 

and CO. More details concerning the methodology is provided in Appendix 3. 

The ‘headline indicator’ of the extent of the alignment with the revised WHO Air Quality Guidelines 

(and for expressing the level of ambition of different scenarios assessed) is the annual mean 

concentration of fine particulate matter (PM2.5), as this air pollutant at its current levels is associated 

with the most harmful effects on human health. The scenarios are defined based on assumptions of 

different PM2.5 levels as a headline indicator. 

The GAINS and EMEP models provide analysis of many of the impacts in the scope of this study. That 

said, some further calculations and post-processing was required to bring out further impacts associated 

with the interventions. This was the case for the assessment of health, social cost, and impacts on 

vulnerable groups.  

We have developed a tiered approach to quantify the health impacts of air pollution. The first Tier 

quantifies the premature mortality caused by the long-term exposure to  particulate matter and the 

peak exposure to ozone using the concentration response functions (CRF) recommended by the recent 

systematic reviews of the WHO (Chen & Hoek, 2020; Huangfu & Atkinson, 2020). The second Tier 

focuses on health outcomes considered in the HRAPIE recommendations (WHO, 2013). This Tier includes 

health outcomes caused by the short-term (cardiovascular hospital admissions, respiratory hospital 

admissions, restricted activity days and lost working-days) and long-term exposure (chronic bronchitis in 

adults, bronchitis symptoms in children, infant mortality) to air pollution. We consider these outcomes 

as the second Tier of the approach, as they have been put forward by the WHO, and have undergone a 

greater degree of review (relative to pathways and CRFs which were not included in the HRAPIE study). 

Acknowledging that there have been developments in the underlying evidence base since HRAPIE, but 

that the WHO has not yet undertaken a comprehensive, recent review of morbidity pathways, we have 

added a Third Tier, which focuses on morbidity effects beyond HRAPIE. This third Tier is included to 

incorporate new insights that became apparent after the HRAPIE study in 2013, and to provide a more 

complete overview of the health impact due to air pollution. We have undertaken our own targeted 

review of literature to explore whether there are pathways beyond HRAPIE for which there is 

convincing evidence for inclusion and included three additional health outcomes in the primary analysis 

(asthma in children, lung cancer, stroke (CVA)), and three additional health effects in a sensitivity 

analysis (COPD, Diabetes Mellitus Type 2 and myocardial infarction). Details on the methodology for the 

three Tiers are provided in Appendix 5.  

For the main analysis, quantification of health impacts for comparing the benefits of different policy 

options is limited to the impact of air pollution concentrations in excess of the revised WHO Air Quality 

Guidelines (from 2021). Health effects below these concentrations are not considered, and all results 

(maps, bar graphs and numbers) thus refer to the health impact above these cut-off values. This 

approach has been adopted given that: 

• 

The guideline exposure levels have been subject to extensive review work from WHO and 

represent an up to date overview of scientific knowledge on the subject, including on levels 

above which the health impacts are well documented. 

• 

There is added uncertainty in the applicability of concentration response functions below the 

guideline exposure levels suggested by the WHO.  

44 

 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

It is acknowledged, however, that this approach likely underestimates the total impact of air pollution 

on health, and thus also underestimates the likely benefits of action to improve air quality. For this 

reason, further quantification of the assumptions have been carried out in sensitivity runs, in which it is 

assumed that health impacts also occur below the WHO Air Quality Guidelines.  

Health impacts are quantified for all years and scenarios under consideration, at NUTS2 resolution for 

mortality and country resolution for morbidity. As the uncertainty around the results will increase when 

the spatial resolution is increased, the main report focuses on results up to NUTS1 for mortality, and up 

to country level for morbidity. Higher resolution data will be provided in separate datasets. Only 

countries in the EU-27 are considered. The methodology builds on the results of Indicator #1, starting 

from the uEMEP annual mean concentrations for NO2 and PM2.5 and the EMEP SOMO35 indicator (defined 

as the yearly sum of the daily maximum of 8-hour running average over 35 ppb) for O3. The main 

analysis uses the standard modelling results, including anthropogenic and natural sources of pollution, 

and omitting the bias adjustment, because sensitivity tests in the annex indicate that the impact of the 

bias adjustment on the relative health impact of the scenarios is limited. The methodology is aligned as 

much as feasible with previous European air pollution cost-benefit analyses (including Clean Air Outlook 

I and II), and with the yearly assessment reports provided by the European Environmental Agency (EEA).  

Alongside the detrimental welfare effect of air pollution on health outcomes, exposure to air pollution 

also results in related healthcare expenditures, crop yield losses due to ozone, absence from work due 

to illness (including of dependent children) and lower productivity at work can imply a drag on the 

economy. Improving air quality can therefore bring economic gains. However, air pollution control 

comes at a gross cost, as it requires costly investments and purchases of abatement equipment. A 

priori, it is unclear whether air pollution control policies therefore lead to net economic gains or losses, 

and how these are distributed across stakeholders. To shed some light on these macro-economic trade-

offs, we conducted analysis by linking the GAINS model with the JRC-GEM-E3 model. GEM-E3 (European 

Commission, 2022) is an applied general equilibrium model that covers the interactions between the 

Economy, the Energy system and the Environment. It represents the whole economy and the 

interactions between key actors: firms, households and governments in the EU and in the rest of the 

world. Linking between GAINS, EMEP and JRC-GEM-E3 has been done in previous work, such as the 1st 

and 2nd Clean Air Outlook (European Commission, 2022), and both models feature in a broader 

modelling toolbox e.g. in the assessment of the EU long-term climate strategy (Weitzel et al. 2019). 

The overall quantitative modelling flow is summarised in the following figure. 

45 

Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Figure 8 – Modelling framework  

Notes: ‘(I1)’ refers to the 12 separate indicators, defined in the TOR for this study, against which the different interventions are to be assessed.

46 

 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

  Limitations of the approach 

The strength of an impact assessment is linked to the robustness of the evidence that has been 

gathered. Information on robustness of evidence and uncertainty and caveats around each analysis step 

are included throughout this document (and accompanying appendices) under each relevant section. 

Upfront it is important to note the following general limitations around the modelling specifically: 

• 

Pollutant modelling: Calculations of emissions made with the GAINS model for several 

scenarios are provided to MET Norway for use in the EMEP/uEMEP models. Both GAINS and 

EMEP/uEMEP also use information provided by the Member States as part of their reporting of 

the national emissions; GAINS model emission estimates for past years have been compared 

and documented in the Second Clean Air Outlook (Amann, 2018) report and further updated to 

align to the possible extent with the 2021 national reporting within the NECD obligations. 

Beyond uncertainties in the data and methods available to estimate emissions, the quality of 

these submitted national emissions may vary from Member State to Member State.  

GAINS uses linear transfer coefficients to calculate ambient PM2.5 concentration levels at 7 km 

resolution, which are in this study only used in the GAINS optimization for achieving different 

ambient PM2.5 targets. Since the transfer coefficients are based on perturbation simulations of 

the EMEP CTM, GAINS and EMEP models are roughly consistent but there are differences 

related to various factors like EMEP model version, meteorological years, spatial emission 

distribution used. Typically, these lead to slightly higher ambient PM2.5 concentrations in 

GAINS, or in other words the EMEP/uEMEP model is somewhat more optimistic about ambient 

concentrations for a given emission scenario, in particular under strong mitigation cases. More 

discussion is provided in Appendix 3. 

In general, for all pollutants modelled with the EMEP/uEMEP models, except BaP, we see a 

negative bias in the results, indicating missing emission sources or underestimation of 

submitted emissions. This is particularly evident with the CO and Benzene calculations with a 

substantial negative bias of around 50%. Validation of the model calculations for all compounds 

is provided in the Appendix (see Appendix 3 – validation of concentration modelling). Negative 

bias of < 20% is calculated for NO2, PM2.5, O3 and BaP for these preparatory calculations. The 

pollutants NO2 and PM2.5 have less negative bias, ~ -20%, and O3 and BaP have a slightly 

positive bias. Validation of the model calculations for all compounds is provided in Appendix 3 

(see Section Validation of concentration modelling). As part of the uncertainty analysis of the 

concentration and exposure modelling a bias adjustment has been applied to assess the 

importance of the biases on the results. 

It is not possible to realise highly accurate emission distributions for all of Europe at 250 or 25 

m resolution. At station sites, for instance, there will be significant additional noise due to 

errors in the redistribution proxies. However, on a statistical level, when sufficient stations are 

available then we expect the methodology to provide good general estimates of the 

concentrations and their frequency distributions. This is important to be aware of when 

scenarios are predicting just a handful of stations in exceedance. This will depend entirely on 

the very local modelled emissions in close vicinity to the stations. 

47 

 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

•  Health impacts: We only consider mortality related to long-term exposure to PM, NO2 and O3. 

Other pollutants and mortality due to short-term exposure are not considered. In addition, we 

only consider morbidity related to long-term exposure to PM. Other pollutants and morbidity 

due to short-term exposure are not considered. We focus on a limited number of ‘health 

endpoints’ (i.e. diseases) for which a causal relationship between exposure to air pollution and 

the occurrence of the disease exists. These limitations mean that health impacts are likely to 

be somewhat under-estimated by the modelling framework.  

Following assessment of impacts of the policy options against the above impact indicators, we have 

identified which assumptions and/or data points result in the largest uncertainty in the results. 

Sensitivity analysis has been conducted around these key assumptions. The results of this analysis are 

presented alongside the central results, in Sections 7 and 8 of this document and in the relevant 

Appendix. 

  Literature review 

The literature review formed a critical part of the data collection and formation of the evidence base 

underpinning the study. The literature review included materials from a wide range of stakeholders, 

including industry, local and national governmental authorities, researchers, and non-governmental 

organisations (NGOs). Key data sources included existing policy reports from the European Commission 

and other public bodies (including existing evaluations, impact assessments, studies, audits, 

information on infringements, complaints, court rulings), academic papers, techno-scientific 

publications, databases, in particular data from EUROSTAT to support the quantitative assessment; and 

other grey literature, such as position papers, proceedings of conferences, symposia and meetings. 

The literature review started with the identification of ‘information and data’ needs for the overall 

project along with the identification of relevant data sources. The identified literature was subject to a 

preliminary screening that determined the availability and reliability of information. A final list of 

relevant references was then identified, allowing a critical assessment of the information gathered. The 

detailed review of the literature allowed the identification of potential gaps, contradictory statements, 

and additional questions that were then discussed during the consultation activities. A bibliography of 

the sources on which the study has drawn is included in Appendix 1. 

This task built on the extensive evidence base collated and analysed as part of the Fitness Check of the 

EU Ambient Air Quality Directives (2019) (European Commission, 2019) (hereafter the Fitness Check) as 

well as on the ongoing study for the Commission on ‘Strengthening air quality monitoring, modelling 

and plans under the Ambient Air Quality Directives’, which looks at options to improve the 

implementation of air quality assessment beyond changes in the legislative framework (for example, via 

additional guidance or exchanges on good practice). 

  Consultation activities 

This section provides an overview of the consultation activities undertaken as part of the study. 

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Inception impact assessment 

An Inception Impact Assessment was published by the European Commission in December 2020 

(European Commission, 2021). Inception Impact Assessments are useful to gather initial ideas regarding 

the problems the initiative aims to tackle, as well as to ask for relevant data (European Commission, 

n.d). As part of this exercise, stakeholders were able to upload written contributions in the form of 

position papers or other documents between 17 December 2020 and 14 January 2021, and 63 provided 

feedback. The contributions received as well as statistics on stakeholder type and country of origin are 

accessible on the “Have your say”- webpage (European Commission, 2021).  

This initial feedback received from stakeholders was synthesised in an Excel file. From each feedback, 

we extracted the metadata (author, high level summary, etc.) as well as information of potential 

relevance to the impact assessment, including: 

• 

• 

• 

• 

• 

• 

• 

Comments on the problem / objectives; 

Comments on the baseline / current status; 

Policy suggestions on limit values, legislative changes, and technical measures related to 

monitoring, modelling and air quality plans; 

Recommendations and policy ideas; 

Proposed factors for consideration and assessment criteria; 

Comments on the impacts of policy options (economic, social, environmental); 

References to further material. 

This information formed part of the knowledge base used by the project team to create a long list of 

policy interventions.  

  Online public consultation 

The online public consultation (OPC) was open for 12 weeks, from 23 September 2021 until 

16 December 2021 (European Commission, 2021). The aim of this consultation was to collect the views 

of citizens and other stakeholders in order to inform the impact assessment, especially with regard to 

designing potential (regulatory and non-regulatory) measures to reduce air pollution, strengthen air 

quality monitoring, modelling and plans, and reduce the related impacts on environment and society. 

The online public consultation had a total of 31 questions (excluding introductory questions about 

respondent profile) and was structured as follows: 

• 

Part 1: Questions about the respondents’ profile and why they are answering the 

questionnaire; 

• 

• 

Part 2: General questions section – on respondents’ views on air quality issues; 

Part 3: Specialised questions section – on respondents’ views on air quality measures and their 

impacts. This section focused on more technical aspects of the topics/measures considered by 

the Directives’ revision, requiring some degree of knowledge on the topic; 

• 

Part 4: Concluding questions & remarks – where respondents could share their thoughts on 

topics not covered by the questions and provide further information, including documents. 

The questionnaire contained a mix of closed- and open-ended questions, the latter enabling 

respondents to either explain their replies to closed questions, or to provide other comments or 

information of relevance to the impact assessment. The online public consultation was shared via email 

with a variety of stakeholders from all EU Member States, including public authorities at local, regional 

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

or national level. In addition, it was advertised during the first workshop held on 23 September 2021 as 

well as on the European Commission’s website. The objective of this dissemination was to ensure a high 

level of participation but also participation that was as representative as possible in terms of 

geographical spread and stakeholder type. 

The methodology for the (ongoing) analysis of the OPC results can be summarised in a number of steps. 

Raw data was obtained from EUSurvey and was subsequently imported into an Excel template. The 

consultants checked whether there were any duplicate replies, and no campaigns were identified. The 

same template was used to create graphics summarising the closed questions, which can be reproduced 

for different purposes in the study and/or by the Commission without further references and/or 

difficulty. Regarding open-ended questions, the approach to their analysis depends on the nature of the 

open-ended question. For questions in which respondents could provide an answer not already included 

in the multiple-choice options and explain this answer, a quantitative analysis was undertaken using the 

software R to identify keywords and how often they were mentioned. For other open-ended questions 

(e.g., "please explain your answer, if you wish to"), a number of open replies was selected to analyse 

qualitatively, with the aim of ensuring  a representative sample of replies in terms of opinions 

expressed (both rather positive and negative) as well as in terms of the respondent's background 

(country of origin and stakeholder type). Finally, any attachments, links or other materials submitted 

by stakeholders including position papers, were analysed and summarised separately.  

A total of 934 responses were received, and 116 position papers were submitted. The targeted section 

received a total of 555 responses. On average, open questions received 124 individual responses, with a 

minimum of 11 and a maximum of 406 individual responses. 

  Targeted survey 

The targeted survey was designed in two parts: the first part was published on 13 December 2021 

containing questions about closer alignment of the EU air quality standards with the latest 

recommendations of the World Health Organization (i.e., Policy Area 1). The second part was published 

on 13 January 2022 and contained questions about improving the current air quality legislative 

framework, including provisions on penalties and public information (i.e., Policy Area 2) and questions 

on strengthening air quality monitoring, modelling and plans (i.e., Policy Area 3). Both parts of the 

targeted survey were open until 11 February 2022.  

The objective of the targeted survey was to seek in-depth views of organisations with an interest in, 

and/or who are working with, EU rules on air quality regarding how specific provisions in the current air 

quality rules could be revised. 

Part 1 of the targeted survey contained 26 main questions (excluding introductory questions, and 

further sub-divided in some instances). The questions focused on: 

•  How to address air pollutants covered by the latest World Health Organization (WHO) Air 

Quality Guidelines? (i.e. PM2.5, PM10, O3, NO2, SO2, CO); 

•  How to address air pollutants covered by earlier editions of the WHO Air Quality Guidelines 

only? (i.e. arsenic, cadmium, nickel, lead, benzene, polycyclic aromatic hydrocarbons); 

•  How to address air pollutants for which there are no WHO guideline levels or reference levels? 

(i.e. black carbon, ultrafine particles, ammonia, others); 

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

•  What type of EU air quality standards should apply for different pollutants? (i.e. limit values, 

target values, long-term objectives, average exposure levels, alert thresholds, other); 

•  What are the likely costs and expected benefits from setting revised EU air quality standards? 

(i.e. societal cost, societal benefits, implementation and administrative costs, implementation 

barriers); and 

• 

Concluding remarks, providing the opportunity to add comments and to upload relevant 

supporting evidence or materials. 

Part 2 of the targeted survey included 78 questions (excluding introductory questions and further sub-

questions). All questions asked for stakeholder inputs regarding the different intervention areas (A 

through N) being considered for Policy Areas 2 and 3 regarding: 

• 

• 

• 

The baseline scenario; 

The extent to which individual interventions would address the identified shortcomings; and 

Administrative costs expected to result from the introduction of the individual intervention.  

As for the OPC, the questionnaires for part 1 and 2 contained a mix of closed- and open-ended 

questions, the latter enabling respondents to either explain their replies to closed questions, or to 

provide other comments or information of relevance to the impact assessment.  

Due to the level of expertise needed to answer, the targeted survey was specifically disseminated to 

targeted stakeholders including: public authorities (i.e., on local, regional and national level), industry 

& businesses, civil society & NGOs, and academia & research. The survey was sent via email to over 330 

potential respondents from the 27 EU Member States. 

Part 1 of the targeted stakeholder survey received in total 139 replies from 24 Member States. Part 2 of 

the survey received 93 replies from 22 Member States. 

  Targeted interviews 

Targeted interviews were conducted to fill in information gaps that had not been filled by the 

literature review or the previous consultation activities. A total of four interviews were conducted in 

April 2022 (two public authorities, one NGO, and one academic organisation). In addition, one 

stakeholder declined to be interviewed and instead sent written answers (public authority). All the 

interviews focused on Policy Area 2, as the main remaining information gaps were in this Policy Area. A 

list of questions was sent to each interviewee prior to the meeting, which were then discussed during 

the calls.  

These targeted interviews have allowed us to: 

• 

• 

• 

• 

Clarify any relevant issues that have emerged as a result of the previous stakeholder input; 

Address gaps in the online survey e.g. information / data on countries which were 

underrepresented and allow for territorial balance in our assessment; 

Complement results; 

Dive deeper into interesting issues raised in the online survey that the project team would like 

to have more information on; 

• 

Validate findings from the survey. 

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

  Stakeholder meetings 

Two stakeholder meetings have taken place in the context of the impact assessment study. The first 

stakeholder meeting took place on 23 September 2021. The meeting was a full day hybrid event and its 

purpose was to assist in identifying and confirming the issues for the impact assessment, and gather 

initial stakeholder views on the proposed interventions and their ambition levels for the revision of the 

Ambient Air Quality Directives, specifically in relation to each individual Policy Area. 

The meeting was attended by 31635 participants (with a total of 401 registered participants). Invitations 

were sent directly to a wide range of stakeholder groups, with the largest group represented at the 

meeting being public authorities. The outcomes of the first stakeholder meeting were used to further 

define and tailor the specific interventions for all Policy Areas.  

Regarding stakeholder inputs on Policy Area 1, the discussion touched upon many different topics. For 

example, a number of stakeholders reflected on the need to fully align EU air quality standards with 

the WHO guideline exposure, ideally by 2030 or consideration of additional pollutants. Other pollutants, 

like PM10, ozone, ammonia, ultrafine particles and black carbon were discussed. Regarding Policy Area 

2, there was a general support for the proposed elements to be tackled and possible interventions to be 

introduced. However, stakeholder views differed as to the conditions for implementation and timing. 

For example, there was a consensus regarding the use of limit values, however divergences regarding 

their form (i.e. in terms of whether the limit values triggering should be defined at local and/or 

regional level, legal nature of limit values or even alternative technologies). Regarding feedback on 

Policy Area 3, stakeholders provided feedback on all proposed intervention areas. For example, 

regarding augmenting assessment regime rules the use of models to supplement assessment methods 

was welcomed, though it was noted this should not be at the expense of a reduced monitoring network. 

The second stakeholder meeting took place on 4 April 2022. This meeting was also a hybrid event, and 

aimed at collecting feedback from stakeholders on the preliminary results of the study – notably on 

modelling and on the results from the OPC and targeted Stakeholder Survey - that would assist in 

verifying and complementing the results. The meeting was attended by 25736 participants (with a total 

of 382 registered participants). Similarly to the first meeting, invitations were sent to a wide range of 

stakeholder groups, and public authorities were the most-represented group. 

The main topics discussed were updates on the progress of the revision of the EU air quality rules and 

on the modelling analysis of air quality improvement potential. Furthermore, stakeholders were given 

the opportunity to comment on the outcomes of the OPC as well as the targeted Stakeholder Survey. On 

the OPC, stakeholders were for example curious whether similarities existed within responses of 

individual stakeholder groups, whether any campaigns had been identified or whether the focus of the 

analysis also included analysis split by Member State. The presentation of the updated results on the air 

quality improvement potential (i.e., on the modelling results on air pollutant concentration and 

exposure and on the health impacts of different pollutants) was commented on by a variety of 

stakeholders. For instance, public authorities highlighted the importance of all relevant studies being 

considered within the analysis and offered to provide additional inputs and civil society & NGOs as well 

as research & academia stakeholders discussed the suitability of applying the WHO Guidelines, which 

35 The consultants contributing to the study and the participants from the European Commission were not taken into 
account. 
36 The consultants contributing to the study and the participants from the European Commission were not taken into 
account. 

52 

 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

are intended for global application, to Europe. Afterwards, the results of the targeted Stakeholder 

Survey were presented per Policy Area. Here again, a variety of stakeholders asked clarification 

questions and expressed their views on the results obtained.  

53 

 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

7  What are the interventions to achieve the 

objectives? 

  The baseline and maximum feasible reduction scenarios  

  Approach to building the baseline and a maximum (technically) feasible reduction (MTFR) 

scenario 

The baseline provides a critical reference point against which to assess changes and impacts of the 

formulated policy options. The baseline serves as the counterfactual for examining how the situation is 

expected to change in the case of no further changes to the AAQ Directives. The baseline provides an 

overview of the current situation, considering economic, social, and environmental aspects, and 

describes expected future trends based on the current situation and extrapolation of known trends (in 

the absence of further policy options).    

The starting point is defined by the current status of implementation of different obligations under the 

existing EU Directives relevant for air pollutant releases as well as national legislation, if stricter than 

the EU law. This defines the existing political and legal context at the EU and at the national level. The 

current status of implementation is well defined in several existing studies, including the second Clean 

Air Outlook (CAO2) (European Commission, 2021). This baseline builds on the backdrop of existing 

measures and policies already committed (including some which might require introduction of further 

measures in the near term). In line with the Commission’s Better Regulation guidelines, policy proposals 

(even though still subject to modifications in the course of policy making cycle) form part of the 

baseline assumptions. Policies and measures included in the baseline are considered to continue over 

the duration of the analysis period. A full list of the policies and programmes included in the baseline 

can be found in Appendix 3, section ‘Legislation and policies included in the baseline’. 

Key elements of the baseline that have been updated since CAO2 include:  

• 

The broader policy environment and potential changes - including revised European 

Commission climate targets (Fit for 55) as reflected in the underlying energy and agricultural 

scenarios37,  

• 

Draft proposal for the Euro 7 emission standards and its timeline, as developed by the CLOVE 

Consortium, 

•  New knowledge about real-world emission factors and share of high emitting vehicles, 

• 

• 

• 

Confirmed changes at Member State level (i.e. adopted policies and measures towards 

compliance with the EU and national legislation, as set out in Member States’ NAPCPs), 

Sulphur Emissions Control Area (SECA) in the Mediterranean Sea from 2025 (EU Directive 

2005/33/EC Sulphur content of marine fuel MARPOL Annex VI Air Pollution), 

Assumptions about the development in non-EU countries are of relevance owing to the impact 

of transboundary pollution. In particular, new data and projections (energy and agriculture) 

for the Western Balkans, Ukraine, Moldova, and Georgia are available from a recently 

completed EU funded project38, and under the UNECE Long Range Transboundary Air Pollution 

(LRTAP) Convention on review of the Gothenburg Protocol new projections and updates of the 

37 https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=SWD:2021:0611:FIN:EN:PDF  
38 Extension of the EU Energy and Climate Modelling Capacity to include the Energy Community and its Nine Contracting Parties 
(ENER/2020/OP/0005) 

54 

 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

policies for remaining EECCA countries are under development building on data from the World 

Energy Outlook 2021 (IEA, 2021), 

•  Updates of the GAINS model with data and information from the 2021 national inventory 

submissions within the NECD, these include: updated information about fuelwood use, 

structure of installations in residential sector and their trends (if reported in the Informative 

Inventory Reports) and new documented emission factors.  

The baseline does not include data from the revision of the IED for agriculture that was published on 

the 5th April 2022. While the impact assessment study of revised IED39 indicated the potential impact on 

emissions (reduction of about 115-185 kt NH3 or 3-5% of the current total EU-27 NH3 emissions), the 

detailed implementation in the GAINS model is still ongoing and will be completed within the work on 

the third Clean Air Outlook.  

The baseline is defined for the period 2015 to 2050 with specific focus on 2030 and 2050, the period for 

which the analysis of interventions has been developed.  

The baseline contains quantitative assessments where these are possible to define, and qualitative 

narrative where quantitative data is not available. The quantitative assessment captures emissions and 

concentrations of air pollutants, associated health and environmental impacts, control costs as well as 

costs to society. Qualitative assessment is predominantly applied to assess the more detailed elements 

of implementation (where information is lacking) and other aspects which do not lend themselves well 

to quantification (e.g. elements under Policy Areas 2 and 3). Both quantitative and qualitative elements 

of the baseline are subject to limitations, as described throughout the remainder of this section. It is 

worth recalling that the baseline primarily aims to establish a reference point against which the impact 

of different interventions can be assessed, focusing on relative changes across scenarios rather than on 

absolute effects. 

The main information sources used for building the baseline have been the Fitness Check, the study 

supporting the process of the revision of air quality rules on strengthening the provisions on air quality 

monitoring, modelling and plans (Conlan et al., 2022) and the Inception Impact Assessment.  

  Trends in air pollutant emissions and concentrations under the baseline and MTFR scenario 

Effective air quality standards across the EU are essential for Member States to ensure that their 

citizens are protected from the adverse effects of air pollution. The AAQ Directive aims to set clear and 

actionable air quality standards that are in accordance with scientific advice to minimise harmful 

effects on human health and ecosystems. Under our baseline we assume that air quality standards 

will be maintained in the form of limit values and target values established for the EU by the 

current AAQ Directives and its predecessor legislation. In other words, we expect the standards to 

remain set at the current level in terms of the pollutant coverage as well as the level of stringency. 

As noted, the updated WHO Guidelines include recommendations for standard setting which are stricter 

than EU standards for some pollutants.  

Baseline assumptions for the definitions of different types of air quality standards reflect current 

legislation (cf. Directive 2008/50, Articles 2, 12 to 16 and Annexes VII, XI to XIV; Directive 2004/107, 

39 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52022PC0156  

55 

 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Articles 2, 3 and Annex I). This means that current challenges with the definition of standards for 

different pollutants will continue, building upon the relevance of the actual limit or target value 

defined by the standards above. Key definition aspects that will impact on the baseline in this regard 

are the application of limit and target values for specific pollutants, the impact of the Average 

Exposure Indicator, and consequential Exposure Reduction Targets for each Member State.  

Air pollutant emissions  

We estimate that, considering current economic and environmental policies included in the baseline, 

the EU-27 will continue to see a decline in emissions of key air pollutants (Figure 9). Compared to 2015, 

by 2030 emissions of PM2.5, NOx, and SO2 are estimated to drop by 50 to 70%, NMVOC by 25%, while for 

ammonia (NH3) about a 5% reduction is expected. The trends are expected to continue towards 2050 

but with much smaller further reductions.  

The key drivers of emissions change towards 2030 are different for each pollutant: 

• 

for PM2.5 most of the reduction is due to reduced use of coal and biomass in the residential 

sector and transition to cleaner technologies, 

• 

for NOx recent legislation and fuel trends (less diesel and increase of hybrid and full electric 

vehicles) are the key drivers,   

• 

for SO2, significant reduction in coal use in power plants and residential coal use decline are 

among major factors 

• 

For NMVOC, reduction in residential heating sector coal use (see PM2.5) and transport changes 

(see NOx) are key contributors 

• 

For NH3, the (limited) decline is mostly driven by structural changes (livestock numbers), 

including reduction of mineral nitrogen fertilizer application. 

Figure 9 – Trends of air pollutant emissions in the EU-27; baseline scenario, GAINS model 

These trends continue towards 2050, however at slower rate with much smaller contribution from 

further reductions in the power sector, which for SO2 and NOx show a small increase after 2035 owing to 

increasing biomass and gas use in the underlying energy scenario (Figure 10). For NMVOC a moderate 

reduction is estimated, mostly due to changes in the transport sector and residential heating. Emissions 

56 

 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

of NH3 do not change much in the baseline, with most of the reduction being due to a change in 

livestock numbers and improvements in efficiency of fertilizer application rather than application of 

control measures. Further emission reductions are expected from recently proposed revision of the IED, 

including cattle and reducing the farm size threshold for pigs and poultry39.  

Figure 10 –Emission of key air pollutants in the Baseline scenario for the EU-27; GAINS model 

Emissions of air pollutants for all Member States in the baseline scenario, as calculated in the GAINS 

model, are shown in Table 6 for 2030 and 2050.  

57 

 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 6- Emissions of air pollutants under the baseline scenario in 2030 and 2050. Units: kilotons/yr 

PM2.5  

SO2  

NOx  

NH3  

VOC  

2030 

2050 

2030 

2050 

2030 

2050 

2030 

2050 

2030 

2050 

Austria  

Belgium  

Bulgaria  

Croatia  

Cyprus  

Czech Rep.  

Denmark  

Estonia  

Finland  

France  

Germany  

Greece  

Hungary  

Ireland  

Italy  

Latvia  

Lithuania  

Luxembourg  

Malta  

Netherlands  

Poland  

Portugal  

Romania  

Slovakia  

Slovenia  

Spain  

Sweden  

EU-27  

10.2 

13.0 

17.7 

10.2 

0.8 

15.9 

10.6 

2.3 

11.7 

99.2 

69.5 

22.2 

30.2 

6.2 

72.5 

6.9 

7.5 

0.8 

0.2 

13.7 

75.0 

26.3 

43.5 

9.4 

9.2 

87.0 

14.5 

8.0 

1.7 

9.4 

81.3 

61.6 

18.6 

12.2 

6.2 

49.4 

3.6 

3.8 

0.7 

0.1 

11.6 

52.1 

23.4 

31.4 

5.7 

3.3 

72.7 

13.5 

10.4 

11.9 

11.3 

5.3 

0.7 

8.3 

30.7 

40.7 

5.8 

2.0 

6.7 

28.6 

22.4 

4.4 

2.2 

10.8 

26.7 

14.8 

9.3 

5.0 

20.7 

76.0 

5.5 

2.0 

16.4 

57.7 

62.0 

91.8 

66.5 

25.6 

6.3 

96.6 

63.1 

13.3 

72.8 

69.6 

88.7 

33.5 

16.9 

4.4 

55.5 

34.7 

8.2 

46.8 

64.8 

68.7 

43.6 

37.5 

8.2 

93.9 

67.5 

11.7 

31.2 

65.0 

65.9 

43.5 

35.8 

8.5 

86.5 

64.0 

11.4 

33.7 

55.9 

75.0 

49.7 

37.0 

5.7 

116.8 

52.9 

11.7 

43.7 

42.1 

66.0 

34.1 

29.6 

4.4 

94.5 

44.6 

10.3 

46.1 

379.0 

244.7 

577.1 

564.9 

496.0 

425.3 

139.3 

108.9 

473.4 

272.0 

549.8 

518.0 

687.5 

590.1 

23.9 

17.9 

7.0 

6.1 

6.7 

5.8 

89.1 

66.4 

58.1 

59.8 

40.3 

43.5 

56.5 

73.9 

53.4 

69.7 

124.2 

121.3 

95.8 

65.4 

48.7 

73.7 

42.4 

48.7 

66.2 

58.3 

290.2 

193.5 

336.4 

313.6 

613.0 

516.8 

2.8 

9.9 

1.1 

0.6 

15.4 

136.9 

20.2 

35.1 

11.0 

3.1 

82.3 

13.0 

2.2 

5.1 

1.0 

0.5 

13.1 

72.1 

14.3 

27.7 

10.8 

1.5 

66.7 

10.7 

25.1 

32.2 

8.3 

2.1 

11.8 

15.8 

5.1 

1.4 

16.6 

43.8 

6.0 

1.3 

16.9 

41.6 

5.7 

1.3 

22.4 

25.0 

6.6 

2.0 

17.3 

15.9 

5.8 

1.7 

116.2 

71.5 

122.6 

120.9 

139.2 

122.2 

302.9 

171.7 

287.1 

282.3 

362.3 

279.6 

74.6 

127.1 

37.9 

16.9 

46.5 

74.8 

28.2 

6.7 

50.7 

46.8 

89.1 

166.2 

154.2 

119.4 

24.9 

16.9 

25.1 

16.0 

69.3 

22.6 

75.8 

91.8 

50.3 

15.8 

326.9 

191.5 

461.0 

448.4 

424.9 

390.4 

53.3 

33.7 

50.0 

50.9 

84.1 

67.5 

686.2 

520.9 

799.1 

583.7 

2977.5 

1871.1 

3392.1 

3265.1 

3821.9 

3202.9 

To define the scope for further (beyond baseline) emission mitigation, the GAINS model was applied to 

calculate the maximum technically feasible reduction (MTFR) scenario for 2030 and 2050 (Figure 11). 

This scenario assumes application of further technical measures to the extent feasible by 2030 and 

2050, considering the lifetime of installed capacity, i.e., no premature scrapping of existing equipment 

is considered. No further, beyond what is included in the baseline, structural or behaviour driven 

measures are considered,  at either the local nor regional level. The estimated potential includes local 

and technological constraints to the extent that they are reflected in the model drawing on previous MS 

consultations and technology information but ignores any potential financial constraints. For example, 

on the first aspect, for agricultural NH3 emissions, the constraints that limit application of specific 

techniques (e.g., manure injection or trailing shoe technology to reduce loses from manure application 

on fields) on steep slopes or stony soils are considered. The minimum size of farms on which measures 

58 

 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

can be introduced according to the specifications of the GAINS model is 15 livestock units (LSU); to be 

noted that this is far smaller than the size threshold of 150 LSU proposed in the IED revision above  

which farms fall within the scope of the Directive (as the MTFR scenario strives to project what is 

possible by using the complete technical potential). There are also some sectors where no further 

options are available, e.g., road transport where Euro 7 is considered the best technology for internal 

combustion engines and there are no measures to reduce non-exhaust emissions from transport. While 

the fact that the model does not include potential further development of current mitigation 

techniques can be seen as conservative, the calculation assumes that the mitigation technology works 

as designed and its respective limit values are effectively enforced, which has not been always the case 

in the past. 

Figure 11 – Scope for further emission mitigation of key precursors of PM2.5 in 2030 and 2050 in the EU27. 
Changes shown relative to 2015; GAINS model 

Since current legislation is expected to reduce emissions of SO2 and NOx, further potential is rather 

limited and even declines in the long-term owing to the reduced used of fossil fuels. The remaining 

potential identified for industrial processes - see Figure 12 – is limited. For PM2.5, very limited, if any, 

potential remains to reduce emissions from power or industrial sectors . Key further mitigation can be 

achieved in the residential sector and also by enforcing bans on the open burning of various agricultural 

residues that, in spite of existing legislation, are still burned. For NMVOC, apart from some potential in 

the residential sector and agricultural burning, further reductions in solvent use applications were 

estimated. For ammonia, mitigation of emissions from mineral nitrogen fertilizer application (primarily 

addressing application of urea) and livestock offers significant reduction potential assuming. For 

livestock, this assumes that measures addressing housing, storage, and application of manures on land 

would be introduced in an integrated manner (as proposed in the revised IED), but for a much larger 

number of farms than is currently the case (as per baseline assumptions), especially for cattle. 

The mitigation potential shown in Figure 12 varies strongly between MSs depending on the structure of 

emission sources and local constraints. 

59 

 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Figure 12 – Emission of key air pollutants in the Baseline and MTFR scenario for the EU27; GAINS model 

Emissions of air pollutants for all Member States in the MTFR scenario, as calculated in the GAINS 

model, are shown in Table 7 for 2030 and 2050. 

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 7- Emissions of air pollutants under the MTFR scenario in 2030 and 2050. Units: kilotons/yr 

PM2.5  

SO2  

NOx  

NH3  

VOC  

2030 

2050 

2030 

2050 

2030 

2050 

2030 

2050 

2030 

2050 

Austria  

Belgium  

Bulgaria  

Croatia  

Cyprus  

6.4 

10.1 

7.7 

4.0 

0.5 

Czech Rep.  

12.3 

Denmark  

Estonia  

Finland  

France  

Germany  

Greece  

Hungary  

Ireland  

Italy  

Latvia  

Lithuania  

Luxembourg  

Malta  

Netherlands  

Poland  

Portugal  

Romania  

Slovakia  

Slovenia  

Spain  

Sweden  

EU-27  

6.2 

8.8 

4.9 

2.4 

0.4 

7.5 

6.0 

1.0 

7.6 

59.0 

50.3 

13.4 

8.5 

4.8 

7.2 

15.3 

19.2 

2.8 

0.3 

13.9 

7.2 

1.8 

10.7 

54.0 

75.8 

9.5 

5.0 

2.1 

6.3 

13.7 

4.9 

1.9 

0.3 

8.4 

4.5 

0.8 

8.0 

47.9 

76.0 

52.0 

15.8 

4.1 

63.9 

52.3 

10.1 

51.7 

54.7 

67.9 

26.6 

9.3 

2.1 

29.1 

27.7 

5.9 

28.7 

38.8 

50.9 

29.9 

19.3 

5.6 

66.0 

52.5 

9.3 

22.3 

38.9 

48.1 

29.2 

18.2 

5.6 

59.9 

48.5 

9.0 

22.6 

39.4 

60.4 

30.9 

16.8 

3.6 

74.6 

33.7 

7.9 

30.7 

31.5 

51.3 

21.9 

13.6 

2.5 

54.1 

26.5 

6.7 

23.5 

37.0 

331.5 

194.6 

411.3 

378.4 

382.1 

327.4 

62.9 

383.1 

203.1 

331.1 

305.5 

445.3 

374.6 

6.3 

5.9 

2.0 

72.9 

49.6 

48.4 

44.3 

29.6 

35.8 

42.6 

47.4 

97.3 

39.4 

43.6 

94.9 

64.7 

34.9 

32.9 

48.8 

29.1 

32.7 

7.6 

1.5 

9.4 

69.4 

57.5 

14.6 

11.6 

4.7 

55.4 

37.6 

32.8 

38.4 

236.4 

133.4 

244.0 

226.0 

456.5 

372.3 

3.4 

3.7 

0.7 

0.1 

11.7 

48.7 

11.5 

21.9 

4.7 

3.3 

38.8 

13.1 

435 

2.4 

2.3 

0.6 

0.1 

10.2 

31.2 

10.2 

14.1 

3.6 

1.6 

28.3 

12.4 

335 

2.3 

4.7 

0.4 

0.5 

10.9 

76.8 

9.4 

12.1 

4.6 

2.1 

33.0 

12.6 

427 

1.9 

3.0 

0.4 

0.5 

10.1 

29.5 

6.6 

9.2 

5.4 

0.6 

30.1 

10.4 

309 

20.2 

24.8 

5.0 

1.7 

9.2 

11.2 

1.9 

1.1 

12.8 

28.8 

3.7 

0.9 

13.0 

26.8 

3.4 

0.9 

11.3 

13.6 

4.6 

1.5 

8.3 

8.5 

3.7 

1.2 

89.9 

55.3 

117.3 

115.6 

108.2 

90.1 

209.3 

107.1 

165.3 

161.7 

257.1 

193.8 

51.5 

93.1 

23.2 

14.2 

26.4 

47.5 

15.1 

4.2 

32.8 

107.8 

15.0 

11.2 

29.7 

96.7 

15.0 

10.4 

65.4 

75.6 

42.5 

12.9 

55.9 

55.2 

28.5 

10.4 

237.9 

110.1 

252.5 

234.8 

294.7 

256.9 

42.6 

2309 

25.6 

1307 

35.9 

2252 

36.1 

2112 

68.5 

2670 

53.5 

2182 

Air pollutant concentrations (Indicator #1) 

Modelling of concentrations based on the emission scenarios has been carried out with the uEMEP/EMEP 

model configuration. This allows annual mean concentrations to be calculated at high resolution for all 

of Europe. For calculations at Airbase station sites, all stations included, the resolution is 25m. For 

mapping and exposure purposes the resolution is 250m. Verification was carried out for the reference 

year 2015. This showed a negative bias in the modelling for most pollutants. To address this a bias 

adjustment was assessed to show the effect of model bias for future scenarios. For details concerning 

the modelling and the bias adjustment see Appendix 3. 

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Station exceedances 

The concentration distributions at station sites in the EU-27 are shown in the Figure 13 for the Baseline 

and MTFR scenarios for the downscaled pollutants PM2.5, PM2.5, NO2 and BaP. Also shown are the non-

downscaled EMEP calculated pollutants for SOMO35, O3 26’th highest daily 8 hour max and SO2. The 

other modelled pollutants of Benzene and CO are not shown as these both have model bias ~ -50%. In 

addition, Figure 13 shows the calculation with bias adjustment for PM2.5 and NO2. The following points 

can be noted concerning the station calculations. 

PM2.5 

• 

• 

• 

• 

PM2.5 concentrations for the reference year 2015 have a bias of -19% 

There is a significant reduction in PM2.5 concentrations even by 2030 with less than 5 stations 

exceeding 15 µg/m3 for the baseline scenario. 
For a large number of stations, PM2.5 concentrations of < 5 µg/m3 remain unattainable, 
independent of the scenario. 
The one station still above 25 µg/m3 in 2050 is in Stockholm, caused by non-exhaust road 
transport emissions. Non-exhaust emissions are not part of the scenario measures but for this 
city these emissions appear overestimated (see Appendix 3). 

Figure 13 Number of EU27 air quality stations calculated to be in exceedance of specified annual mean 
concentration levels for PM2.5 (WITHOUT bias adjustment) 

PM10 

• 

• 

• 

PM10 concentrations for the reference year 2015 have a bias of -33% 

There are few observed concentrations (77 out of 2280), even in 2015, that exceed the limit 

value of 40 µg/m3. The negative model bias results in only 5 sites exceeding 40 µg/m3 in 2015. 

In 2030 and 2050 there are almost no station sites >15 µg/m3. This number will be larger in an 

unbiased model (see next Section) 

62 

 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

• 

The two stations still above 40 µg/m3 in 2050 are one in Stockholm, due to non-exhaust 

emissions, and from high PM10 industrial emissions near Dunkirk. Non-exhaust emissions in 

Stockholm are very likely overestimated. 

Figure 14 Number of EU27 air quality stations calculated to be in exceedance of specified annual mean 
concentration levels for PM10 (WITHOUT bias adjustment) 

NO2 

•  NO2 concentrations for the reference year have a bias of -23% 

• 

There are significant reductions in NO2 concentrations already in 2030 and further to 2050, 

when less than 60 stations, representing 2% of all stations, are still above 10 µg/m3. These 

reductions are obtained chiefly though NOX emission reductions from road transport. 

There is little difference between the Baseline and MTFR scenarios. 

The one station still above 40 µg/m3 in 2050 is in the port city of Genova. Shipping emissions 

• 

• 

are very likely overestimated here. 

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Figure 15 Number of EU27 air quality stations calculated to be in exceedance of specified annual mean 
concentration levels for NO2 (WITHOUT bias adjustment) 

Benzo(a)pyrene (BaP) 

• 

• 

• 

• 

BaP concentrations are well modelled with a small positive bias, + 11%. 

The high BaP concentrations are primarily dominated by measurement sites in Poland and 

secondly at measurement sites in Italy and Spain (See Appendix 3) 

The number of stations in exceedance of the AAQD limit value of 1 ng/m3 does not reduce to 0 

until 2050.  

The WHO recommended concentration of 0.12 ng/m3 is only achieved for more than half the 

population in the 2050 MTFR scenario. 

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Figure 16 Number of EU27 air quality stations calculated to be in exceedance of specified annual mean 
concentration levels for BaP. (WITHOUT bias adjustment) 

SOMO35 

• 

• 

SOMO35, a health indicator without a limit value, is well modelled with little bias, +1% 

There is a gradual decrease in concentrations from 2020 to 2030 and 2050 with few stations 

registering above 4000 ppb.d in 2050 

• 

There is also a decrease in SOMO35 with MTFR compared to Baseline 

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Figure 17 Number of EU27 air quality stations calculated to be in exceedance of specified concentration levels 
for SOMO35 (WITHOUT bias adjustment) 

O3 26’th highest daily 8 hour max 

• 

This pollutant indicator is not downscaled and results are from the EMEP model 

•  O3 26’th daily has a model bias of -11% with a tendency to underestimate higher 

concentrations (See Appendix 3) 

•  O3 26’th daily currently has a target value of 120 µg/m3 which is exceeded at a large number 

of stations. 

• 

The tendency to underestimate higher concentrations will also influence the scenario 

calculations and the modelling estimates in 2030 and 2050 will reflect this. 

• 

There is a slight decrease in O3 26’th daily with MTFR compared to Baseline and there is a 

general decreasing trend from 2030 to 2050 

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Figure 18 Number of EU27 air quality stations calculated to be in exceedance of specified concentration levels 
for O3 26’th highest daily 8 hour max (WITHOUT bias adjustment) 

SO2 

• 

• 

• 

This pollutant indicator is not downscaled and results are from the EMEP model. 

SO2 concentrations for the reference year have a bias of -27%. 

In 2015 there are very few observed SO2 exceedances of a 20 µg/m3 reference value and in 

2030 and 2050 there are no modelled exceedance of this value. 

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Figure 19 Number of EU27 air quality stations calculated to be in exceedance of specified concentration levels 
for SO2 (WITHOUT bias adjustment) 

The other modelled compounds of CO and Benzene are not shown but presented in the Appendix. These 

pollutants both showed significant negative bias, around -50%, most likely indicating poor emission 

data. Modelling results for these two pollutants will have a limited usefulness for any scenario 

assessment. 

Sensitivity to bias adjustment of station concentrations 

There is generally a negative bias to the modelled pollutants. To assess the impact of modelled bias on 

scenario outcomes a bias adjustment has been implemented. The methodology is described in Appendix 

3 (Section ‘Bias adjustment’). Bias adjustment was implemented in the modelling to assess the impact 

of model bias on future scenarios, assuming that the bias was caused either by downscaling dispersion 

bias or bias in emissions on a country basis. This was intended as a sensitivity test but will likely give 

more realistic results than calculations without bias adjustment.  

As a default, bias adjusted concentrations are not used in the assessment. This is because without bias 

adjustment the contribution of the various sources is known. With bias adjustment it is not known 

which sources are responsible for the bias so this adjustment must be made homogeneously across all 

downscaled sources.  

A ‘bias adjustment’ was implemented to some of the modelling to calibrate modelled concentrations 

and concentration monitored at sampling points for the year 2015 (i.e. at Airbase station sites). 

Notably, such bias adjustment was implemented for the station exceedance calculations for PM2.5 and 

NO2. This is based on the assumption that such bias is caused either by downscaling dispersion bias, or 

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residual bias in emissions reported on a country basis. For the population exposure estimates this bias 

adjustment has not been applied. See the underpinning support study on the revision of the Ambient Air 

Quality Directives. 

Bias adjustment has only been applied for the pollutants PM2.5, PM10 and NO2. These pollutants have 

sufficient measurement data on a country basis to apply the adjustment.  The bias in O3 indicators were 

not large and, as a secondary pollutant, bias adjustment was not relevant. 

The bias adjustment in the form of a scaling factor was applied to the locally emitted component per 

country, and applied for all scenarios. The following points can be made concerning this adjustment on 

these three pollutants: 

• 

Bias adjustment for PM2.5 gives the same overall picture for station exceedances in 2030 and 

2050. The number of stations above > 5 µg/m3 increases with the adjustment, depending on 

the scenario. For the 2030 baseline there is almost no change but for the 2050 MTFR the 

number of stations above > 5 µg/m3 roughly doubles with the bias adjustment. 

• 

In absolute terms the bias adjustment increases PM2.5 station concentrations by an average of 

2.6 µg/m3 in 2015 and by 0.7 µg/m3 for the 2050 MTFR scenario (the difference in the absolute 

size of the bias being due to generally reduced concentration levels). 

• 

Bias adjustment for PM10 increases the number of stations in the 2030 baseline > 40 µg/m3 

from 2 to 14. This is indicative of the uncertainty surrounding the calculation. 

•  With bias adjustment for PM10 the number of sites in 2030 > 15 µg/m3 increases from around 60 

to 300 – 600, which is a significant increase in station numbers showing a large uncertainty. 

• 

Bias adjustment for NO2 gives the same overall picture for station exceedances in 2030 and 

2050. The number of stations > 10 µg/m3 in 2030 increases from around 22% to 30%. 

Final results for mapping and exposure do not include this adjustment unless it is specifically 

mentioned. The existence of modelling bias, though significantly smaller than the overall change in 

concentrations, should always be kept in mind when drawing conclusions from the results. 

We conclude that the overall picture concerning the reduction in pollutant concentrations at station 

sites remains the same, both with and without bias adjustment, but there remains an uncertainty when 

the number of stations close to any particular threshold concentration is small. This uncertainty is 

largest for PM10 which also had the largest negative bias. When interpreting the scenario results for 

further application the impact of modelling bias should always be considered. 

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Figure 20 Number of EU27 air quality stations calculated to be in exceedance of specified concentration levels 
for PM2.5, PM10 and NO2 (WITH bias adjustment) 

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Population exceedance 

The number of people exposed above selected annual mean concentrations in the EU27 for PM2.5, NO2 
and BaP are shown for the baseline and MTFR scenarios in  

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Figure 21. No bias adjustment is used in the population exposure calculations. In general, these follow 

very similar scenario trends to the station calculations, but modelled population exposure 

concentrations tend to be lower than modelled concentrations at station sites. This reflects site 

positioning that is often intended to measure at high concentrations sites rather than at background 

exposure sites. 

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Figure 21 EU27 population in exceedance of specified concentration levels for the pollutants PM2.5, NO2 and BaP for 
all Baseline and MTFR scenarios (WITHOUT bias adjustment) 

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Population exposure and source contributions 

The following figures show the population exposed over the indicated annual mean concentration. The 

scenarios 2020 base, 2030 base, 2030 MTFR are shown for PM2.5 and NO2. Also included are the relative 

source contributions for the given exposure level. A detailed description of how the local and non-local 

source contributions are derived is provided in Appendix 3 (Section ‘Explanation of the EMEP/uEMEP 

downscaling source contribution methodology’). The following points can be noted concerning the 

station calculations. 

PM2.5  

• 

530,000 inhabitants are exposed to PM2.5 concentrations > 25 µg/m3 in 2020 and this is chiefly 

attributable to residential emissions of primary PM2.5. 

• 

16,000 inhabitants are exposed to PM2.5 concentrations > 25 µg/m3 in 2030 but this number is 

well within the uncertainty of the methodology. 

• 

In 2030 non-exhaust PM2.5 emissions from road transport become a significant source 

contribution in some cities, notably Nordic countries. Non-exhaust emissions remain unchanged 

for all scenarios. 

• 

Local primary PM2.5 sources (all sources in lower case letters), that are emitted from within 

the ± 0.4o window, account for 22% of the total PM2.5 European exposure in 2020. 

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Figure 22 Population exposure with source contribution for the EU27. Base 2020 PM2.5 (WITHOUT bias adjustment) 

Figure 23 Population exposure with source contribution for the EU27. Base 2030 PM2.5 (WITHOUT bias 
adjustment) 

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Figure 24 Population exposure with source contribution for the EU27. MTFR 2030 PM2.5 (WITHOUT bias 
adjustment) 

NO2 

• 

In 2020 the major source of NOX contributing to NO2 concentrations for all exposure levels is 

local road traffic, i.e. emitted from within the ± 0.4o window. 

• 

In 2030 road traffic contributes very little and the dominant source leading to exposures above 

10 µg/m3 is shipping. There is a large degree of uncertainty in these local emission sources at 

ports 

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Figure 25 Population exposure with source contribution for the EU27. Base 2020 NO2 (WITHOUT bias 
adjustment) 

Figure 26 Population exposure with source contribution for the EU27. Base 2030 NO2 (WITHOUT bias 
adjustment) 

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Figure 27 Population exposure with source contribution for the EU27. MTFR 2030 NO2 (WITHOUT bias 
adjustment) 

BaP 

• 

• 

• 

In 2020 the dominant source for BaP is residential heating, followed by some individual 

industrial emissions. 

In 2020 around 80 million inhabitants were exposed above the current EU limit value of 1 

ng/m3. This was mostly in Poland and in Northern Italy. In 2030 this is reduced to 15 million. 

In 2030 industrial sources of BaP dominate and are the cause of the remaining exceedances. 

These exceedances are chiefly the result of one individual industrial plant in Northern Italy, 

Vicenza, and some lesser contributions in Spain and Poland. To illustrate this, the exposure 

calculation has been carried out after the removal of Italy. These emissions remain uncertain, 

both in the present day, and how they will evolve in the future. 

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Figure 28 Population exposure with source contribution for the EU27. Base 2020 BaP (WITHOUT bias 
adjustment) 

Figure 29 Population exposure with source contribution for the EU27. Base 2030 BaP (WITHOUT bias 
adjustment) 

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Figure 30 Population exposure with source contribution for the EU27. MTFR 2030 BaP (WITHOUT bias 
adjustment) 

Source contributions per country 

To assess the differences between countries, the population weighted source and PM species 

contributions are provided per country for the pollutants PM2.5, NO2 and BaP. We show the 2020 base, 

2030 base and the 2030 MTFR. 

PM2.5 

• 

The population weighted concentration of PM2.5 for the EU27 in 2020 is calculated to be 8.7 

µg/m3. This varies across the EU27 from around 4 µg/m3 in Ireland to 14 µg/m3 in Malta. This is 

reduced to 5.2 µg/m3 for the 2030 MTFR scenario. 

• 

• 

Significant decreases occur from 2020 to 20350 for many European countries, mostly as a result 

of changes in the primary residential heating sector and secondary inorganic aerosols (SIA) 

The Southern Mediterranean countries of Malta (MT), Cyprus (CY), Greece (EL) and Spain (ES) 

are significantly influenced by wind-blown dust and to a lesser extent sea salt. These two 

factors contribute around 7 µg/m3 in Malta. 

• 

Secondary organic aerosols (SOA) change very little between the scenarios 

Figure 31 Population weighted concentrations and source contributions per country. Base 2020 PM2.5  (WITHOUT 
bias adjustment) 

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Figure 32 Population weighted concentrations and source contributions per country. Base 2030 PM2.5  (WITHOUT 
bias adjustment) 

Figure 33 Population weighted concentrations and source contributions per country. MTFR 2030 PM2.5 (WITHOUT 
bias adjustment) 

NO2 

• 

The population weighted concentration of NO2 for the EU27 in 2020 is calculated to be 9.9 

µg/m3. This varies across the EU27 from around 4 µg/m3 in Cyprus to 16 µg/m3 in The 

Netherlands. This is reduced to 5.1 µg/m3 for the 2030 MTFR scenario. 

• 

In 2020, all countries have a significant contribution from road traffic, but by 2030 this is 

predicted to be much reduced. 

• 

In 2020 the Mediterranean countries of Malta and Cyprus have two of the lowest NO2 

exposures. However,  an increase in shipping contributions from 2020 to 2030 and a strongly 

reduced road transport contribution in many other countries results in Malta having one of the 

highest exposures to NO2 of any European country.  

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Figure 34 Population weighted concentrations and source contributions per country. Base 2020 NO2 (WITHOUT 
bias adjustment) 

Figure 35 Population weighted concentrations and source contributions per country. Base 2030 NO2 (WITHOUT 
bias adjustment) 

Figure 36 Population weighted concentrations and source contributions per country. MTFR 2030 NO2 (WITHOUT 
bias adjustment) 

BaP 

• 

The population weighted concentration of BaP for the EU27 in 2020 is calculated as  0.74 

ng/m3. This varies across the EU27 from < 0.1 ng/m3 in Malta to 3.2 ng/m3 in Poland. This 

reduces to 0.2 µg/m3 for the 2030 MTFR scenario. 

• 

The dominant source of BaP is residential heating. In the emission inventories for the scenario 

calculations BaP emissions are coupled to PM2.5 combustion emissions. The significant 

decreases in Residential BaP contributions thus also reflects the decrease in PM2.5 residential 

contributions. 

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Figure 37 Base 2020 BaP (WITHOUT bias adjustment) 

Figure 38 Base 2030 BaP (WITHOUT bias adjustment) 

Figure 39 MTFR 2030 BaP (WITHOUT bias adjustment) 

Figure 40 Base 2050 BaP (WITHOUT bias adjustment) 

Heavy metals 

Heavy metals were not directly captured in the integrated modelling system. As such, a wider review of 

data and literature has informed the analysis. A review of the latest monitoring data suggests that: 

• 

Arsenic 

o 

5 monitoring sites out of those with over 85% data coverage40 do not meet the current 

EU standard for arsenic of 6 ng/m3.   

o  Monitoring sites in industrial areas show the highest arsenic concentrations with an 

average of 1.38 ng/m3. 

40 Data coverage refers to the annual average percentage of valid measurement. The EEA states that annual 
statistics with coverage less than 75% averaged over a year should not be included in air quality assessments. Annual 
statistics with coverage less than 85% averaged over a year should not be included in compliance checks.  

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o  The median, lower and upper quartiles, and maximum value are lower for background 

sites compared to industrial sites.  

• 

Cadmium 

o 

1 monitoring site out of those with over 85% data coverage does not meet the current 

EU standard for cadmium of 5 ng/m3.   

o  Monitoring sites in industrial areas show the highest cadmium concentrations with an 

average of 0.54 ng/m3. 

o  The median, lower and upper quartiles, and maximum value are lower for background 

sites compared to industrial sites.  

• 

Lead 

o  All monitoring sites in 2019 with over 85% data coverage were compliant with the EU 

standard for lead of 0.5 μg/m3. 

o  Monitoring sites in industrial areas show the highest lead concentrations with an 

average of 0.022 μg/m3. 

o  The median, lower and upper quartiles are lower, but the maximum value is higher 

for background sites compared to industrial sites.  

•  Nickel 

o 

2 monitoring sites out of those with over 85% data coverage do not meet the EU 

standard for nickel of 20 ng/m3.   

o  Monitoring sites in industrial areas show the highest nickel concentrations with an 

average of 4.76 ng/m3. 

o  The median, lower and upper quartiles, and maximum value are lower for background 

sites compared to industrial sites.  

Further disaggregation of the monitoring data can be found in Appendix 4.  

The monitoring data show broad compliance with the existing EU standards and WHO AQGs. Measured 

concentrations at 11 monitoring sites across the EEA reporting countries were not in compliance with 

the existing EU standards in 2019 for arsenic, cadmium, and nickel, as set out in Table 8. The highest 

number of sites exceeding the EU standard was for arsenic. No monitoring sites in EEA reporting 

countries exceeded the EU standard for lead in 2019.  

These 11 monitoring stations may be representative of the situations giving rise to exceedances that 

could also occur at other locations across the European Union, where no air quality monitoring is 

currently carried out. Further investigation into these 11 locations was carried out to identify the 

potential causes of these exceedances. Similar conclusions could potentially be drawn at other 

comparable locations across the EU.  

Table 8 Number of sites that are not in compliance with the EU concentration standards for arsenic, lead, 
cadmium, and nickel in 2019 across EEA reporting countries. 

Data Coverage 
Above 85% 
Below 85% 

Arsenic 
5 
3 

Lead 
0 
0 

Cadmium 
1 
0 

Nickel 
2 
1 

The monitoring sites that were found to exceed the existing EU standards are mostly industrial 

suburban monitoring sites, and are located in Belgium, France, Norway, Finland, Poland and Italy. 

Analysis of the presence of E-PRTR industrial sites in the vicinity of each of these monitoring stations 

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indicated that the key sources of metals giving rise to the measured exceedances are likely to be 

industrial metal production facilities. The distances between the exceeding monitoring site and 

potential E-PRTR source range from 0.5 km to 3.6 km. 

Costs of air pollution measures 

Costs of implemented air pollution policies, specifically including costs associated with emission 

reduction measures in power plants, industry, transport, residential combustion, and agricultural 

sectors are estimated at about 75 billion €/year in the EU27 in 2030, similar to current levels. The 

majority of costs are in the transport and industrial sectors (Figure 41). Costs are estimated to decline 

in the longer term, i.e., after 2030, primarily due to structural changes embedded in the EU Fit for 55 

strategy, resulting in a strong decline in fossil fuel use which results in a reduced requirement for end 

of pipe controls in the power sector and later on in transportation owing to the strong increase of 

alternative propulsion systems.  

Figure 41 - Total air pollution control costs (only costs of emission control measures) by sector in the baseline 
scenario for EU-27; GAINS model.

Employing all available mitigation potential as defined in the MTFR scenario would increase total air 

pollution mitigation costs in the EU27 by about 24 and 22 billion €/year in 2030 and 2050, respectively 

(see Section 8.2.2, Figure 80). The majority of additional costs would be associated with measures in 

industry, agriculture and residential combustion with only minor additional costs for the transport and 

power sectors. The latter two sectors include most significant structural changes (reducing fossil fuel 

use) and are subject to strict emission limit standards with only small, if any, further technical 

mitigation potential.  

The cost of air pollution control measures applied in the Baseline scenario, as calculated by the GAINS 
model for 2030 and 2050, are shown in  

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Table 9 for each Member State. Cost for the MTFR scenario are available in Section 8.2.2, Table 53 and 

Table 54). 

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Table 9 Total air pollution emission control costs under the Baseline scenario as estimated by GAINS. Units: 
M€/yr. 

2030 

2050 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

EU-27 

2211 

2439 

855 

547 

122 

2328 

1280 

244 

1800 

11818 

12845 

1423 

1369 

1093 

9526 

245 

512 

238 

64 

3116 

6957 

1336 

1990 

534 

446 

8227 

1649 

75210 

1241 

1681 

337 

194 

34 

829 

737 

75 

966 

5601 

4641 

393 

619 

518 

2970 

68 

197 

51 

22 

1968 

3392 

481 

944 

243 

135 

3783 

800 

32875 

  Problem: Projected health and environment outcome shortcomings 

Driver: Exceedances above health guidelines and negative health impacts persist 

Health impacts - baseline 

Results for attributable mortality (Tier 1) 

The baseline total number of yearly attributable deaths in the EU-27 for the three pollutants under 

consideration (PM2.5, NO2, O3) is shown in the bar graphs in Figure 42. As can be seen from the charts, 

despite the methodologically conservative approach taken (i.e. only the health impacts of air pollution 

levels above WHO air quality guideline levels are considered here, which may lead to an underestimate 

of the total health impacts of air pollution), an important health impact is observed in all the years 

under consideration. Although there is a significant uncertainty due to the 95% uncertainty range 

around the relative risks, the order of magnitude of the impact is clear for the two most important 

pollutants from a health impacts perspective: PM2.5 and NO2. In the historic year (2015), the yearly 

number of premature deaths is of the order of hundreds of thousands for particulate matter, and of the 

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order of tens of thousands for nitrogen dioxide41. For ozone, the central estimate for the yearly number 

of attributable deaths is also of the order of tens of thousands, but this result is much more uncertain, 

as the lower boundary of the uncertainty interval is at zero and the upper boundary in the hundreds of 

thousands.42   

Under the baseline scenario, which include assumptions on published proposals on more stringent 

climate policies and vehicle emission standards, the mortality caused by exposure to NO2 and PM2.5 

decreases significantly between 2015 and 2030. However, there would still be a considerable number of 

premature deaths each year observed in 2030, with tens of thousands of attributable deaths per year 

caused by the exposure to PM2.5 and thousands of deaths caused by the exposure to NO2. These numbers 

correspond to decreases of attributable mortality of 75% for particulate matter and of 90% for nitrogen 

dioxide, in comparison with the historical year (2015). By 2050, the attributable mortality is further 

reduced by a further 50% (in comparison with the 2030 results) for particulate matter, and by 80% (in 

comparison with the 2030 results) for nitrogen dioxide. These large ameliorations in the health impacts 

are driven by substantial decreases in the concentrations of the pollutants between 2015 and 2030, and 

2050, respectively.  

The results for ozone show a different pattern. The mortality caused by the exposure to ozone remains 

approximately constant from the historical year. Note that these results do not consider the potential 

impact of climate change, as the meteorological data is the same for each year, which could have a 

significant impact on the concentrations for ozone peaks (i.e. higher temperatures may lead to more 

ozone pollution peaks). 

41 Note that these results do not correct for an overlap in the premature deaths between the different pollutants, and, as such, a 
simple addition of the numbers is not allowed. 
42 Note that these results differ from the results reported by the EEA in its assessment of the air quality in 2015 (EEA, 2017), because 
updated concentration response functions have been used in the current analysis. A sensitivity study in the annexes focuses on this 
aspect.  

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Figure 42 Number of yearly premature deaths in the EU-27 caused by the exposure to air pollution at levels 
above the WHO AQ guidelines for the baseline scenarios for three pollutants (PM2.5, top-left; NO2, top-right; O3, 
bottom) 

Notes:  Impacts for the four reporting years considered in the study (2015 in blue, 2020 in cyan, 2030 in orange and 2050 in green) 

are included. The filled bars and the numbers refer to the central estimate (rounded to the nearest 100 for NO2 and the nearest 1000 

for PM2.5, respectively), while the black lines provide the 95-percentage uncertainty estimate based on the uncertainty on the 

relative risks. 

Figure 43 maps43 the baseline scenario number of premature deaths attributable to air pollution per 

capita for all countries in the EU-27 for 2015 and 2030. To facilitate a comparison between 2015 and 

2030, the colour scale is fixed per pollutant. The charts indicate a strong regional effect for the chronic 

mortality caused by the exposure to particulate matter. The impact is larger in Eastern and Southern 

European countries than in most Northern and Western European countries (with exception from 

Germany, the Netherlands and Belgium). On a country level, the highest impact is observed in Italy, 

Croatia, Hungary and Bulgaria, although for Italy most of the impact is in Northern Italy (North West 

and North East regions), as indicated by the detailed maps per NUTS 1 level in the appendix. Because of 

the strong reductions in the particulate matter concentrations, the attributable mortality per capita is 

much smaller in 2030 than in 2015. The spatial pattern also changes slightly, as the relative reductions 

are smaller in Southern Europe compared to other regions (including Eastern Europe). These results are 

apparent when the results per NUTS 1 region are considered: all the regions with the highest mortality 

per capita in 2030 are located around the Mediterranean (Sardinia + Sicily, Malta, Greek Isles (Nisia 

Aigaiou, Kriti)). Note that part of this impact is related to air pollution from natural sources, which are 

not reduced by any of the baseline policy measures.  

The maps for nitrogen dioxide reflect the nature of nitrogen dioxide pollution: because concentration 

hotspots are mostly linked to important local road traffic and shipping emissions, the highest impact is 

also observed at these locations. In the historic baseline year (2015), the highest attributable mortality 

per capita on a country level is observed in countries with highly polluted cities (Greece, Belgium and 

43  Tables with detailed results on the (absolute) number of attributable deaths are provided in the annex, as are 
maps per NUTS 1 level. 

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the Netherlands). Zooming in to the NUTS1 regions, the highest mortality per capita is observed in the 

regions which surround  cities with high traffic and / or shipping emissions, such as Attica (Athens), 

Madrid, Ile-de-France (Paris), Brussels, Berlin, North West Italy (Milan), Flanders (Antwerp) and West 

Netherlands (Amsterdam). Due to strong reductions in NOX emissions, the health impact is also strongly 

reduced in 2030 in comparison with the baseline year. Because the reductions in road traffic emissions 

are much larger than the reductions in shipping emissions, there is a shift in high impact locations from 

regions with significant contributions of road traffic emissions to regions in which both road traffic and 

shipping emissions are important. For example, in 2030, the list of regions with the highest per capita 

impact includes East Spain (Valencia and Barcelona) and Northern Greece (Thessaloniki). This effect is 

even more pronounced in 2050, when all impact is related to high concentrations in several ports 

around the Mediterranean (due to an increase in international shipping emissions).   

For ozone, a strong North-West to South-East  gradient is observed: the impact of measures included in 

the baseline scenario is smaller in Western and Northern Europe compared to Southern and South-

Eastern Europe. The countries with the largest remaining health impact per capita are Italy, Croatia, 

Hungary, Romania and Bulgaria, while detailed results indicate that the highest per-capita remaining 

health impact per NUTS1 level is observed in North-West Italy (related to high concentrations in the Po 

Valley), on the Greek Isles (Nisia Aigaiou, Kriti region), and in all regions in Bulgaria. Although the total 

impact in the EU-27 in 2030 is similar to the total impact in 2015, the charts indicate that the total 

impact would be distributed differently than in the past. The impact per capita remains high in some of 

the hotspots (Italy and Bulgaria) but is significantly reduced in other countries (Croatia, and to a lesser 

extent Hungary and Romania). On the other hand, the impact per capita increases slightly in most 

Northern and Western European countries, which is partially related to a reduction in NOx emissions, 

yielding higher ozone concentrations. Note that these results do not consider the impact of climate 

change, as the meteorological data assumed for scenario analyses is the same for each year, which 

could have a significant impact on the concentrations for ozone peaks, especially for the Mediterranean 

countries.  

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Figure 43 : Yearly number of premature deaths per 100.000 inhabitants caused by the exposure to air pollution 
at levels above the WHO AQ guidelines for three pollutants (PM2.5, top; NO2, middle; O3, bottom). 

Notes: The maps show results for the baseline in 2015 (left row) and 2030 (right row) per country. The colour scale is the same for 

both years, but differs between the pollutants.  

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Results for attributable morbidity (Tier 2 and Tier 3) 

Table 10 provides an overview of the morbidity impact from the second (morbidity according to HRAPIE) 

and third Tiers (additional health outcomes beyond HRAPIE: stroke, lung cancer and asthma in children) 

of analysis. As with the chronic mortality results, for all health outcomes, the baseline shows a strong 

reduction in impact over time. Because the underlying incidence rates for the most recent historic data 

are also used as the incidence rates for the future year, these results only take into account the health 

impact due to a reduction in the air pollution and due to changes in the demography (according to 

Eurostat projections). Impacts due to improvements in health care, a more / less healthy lifestyle, etc., 

are not considered. A notable exception is infant mortality, for which the  Eurostat projections 

concerning the number of deaths in the age group from 0 to 1 year for 2030 and 2050 have been used. 

The results also correspond quantitatively with those for chronic mortality related to PM2.5 exposure. 

When comparing the results for the baseline year (2015) and 2030, a reduction of around 75% is 

observed for most of the health outcomes. In the next 20-year period, a further reduction of around 55 

to 60 % (relative to the 2030 baseline morbidity) is expected. The reduction in infant mortality (ca. 85% 

between 2015 and 2030, and ca. 80% between 2030 and 2050) is even larger, due to a reduction in the 

baseline mortality rate according to the Eurostat projections. These findings illustrate how the impact 

for the other health outcomes might be further reduced, if improvements in health care are also 

considered.  

Table 10: Morbidity caused by the exposure to PM2.5 pollution in the EU27 under the baseline scenarios for 
2015, 2030 and 2050.  

Health outcome 

Unit 

2015 

2030 

2050 

3 (1 ; 5) 

24,500  

Infant Mortality 

Deaths per year 

112 (57 ; 192) 

15 (7 ; 27) 

Bronchitis in Children  

(age 6 -12) 

Chronic Bronchitis  

in adults 

Cases per year 

Incidence per year 

276,000  

61,000  

(0 ; 600,000) 

(0 ; 136,000) 

(0 ; 54,900) 

96,400  

24,500 

10,700  

(35,200 ; 147,000) 

 (8,760 ; 38,000) 

(3,820 ; 16,600) 

Cardiovascular hospital 

Admissions per 

61,600  

14,100  

5,370  

admissions 

year 

(11,600 ; 112,000) 

(2,650 ; 25,600) 

(1,010 ; 9,740) 

Respiratory hospital 

Admissions per 

61,500  

14,500  

5,920  

admissions 

year 

(0 ; 127,000) 

244,000,000 

(0 ; 30,100) 

59,500,000 

(0 ; 12,300) 

25,600,000 

Restricted activity days 

Days per year 

(219,000,000 ; 

(53,300,000 ; 

(22,900,000 ; 

273,000,000) 

66,900,000) 

28,700,000) 

91,500,000 

21,200,000 

8,260,000  

Lost working days 

Days per year 

 (78,000,000 ; 

(18,000,000 ; 

(7,030,000 ; 

Stroke (CVA) 

Incidence per year 

Lung cancer 

Incidence per year 

Asthma in children  

(age < 16 years) 

Incidence per year 

105,000,000) 

24,300,000) 

9,470,000) 

45,800 

11,500  

4,780  

 (39,400 ; 52,000) 

(9,800 ; 13,100) 

(4,090 ; 5,460) 

17,000 

4,260  

1,800  

 (7,870 ; 25,300) 

 104,000 (38,000 ; 

161,000) 

(1,950 ; 6,440) 
23,700 (8,180 ; 
38,300) 

(823 ; 2,720) 

9,500 (3,260 ; 

15,400) 

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Health impacts: MTFR scenario  

Results for attributable mortality (Tier 1) 

The impact of the MTFR scenario on the total number of yearly attributable deaths in the EU-27 for the 

three pollutants under consideration (PM2.5, NO2, O3) is shown in the bar graphs in Figure 44 (total 

number of premature deaths) and Figure 45 (relative differences between the baseline and the MTFR). 

Note that these charts and numbers refer to the health impacts above the WHO air quality guideline 

concentrations, and that all excess mortality caused by concentrations below these cut-offs are not 

taken into account. As indicated by the sensitivity tests in the annexes, the number of premature 

deaths avoided under the scenario increases if the cut-off value is lowered (because reductions of 

concentrations below the WHO air quality guidelines are not taken into account in the current 

assessment), while the relative impact of the scenarios decreases with a reduction of the cut-off value 

(because the scenario does not affect a substantial part of the mortality below the counterfactual 

concentration).  

As can be seen from the charts, the measures taken under the MTFR scenario have a significant impact 

on the health impact caused by exposure to particulate matter. Under the MTFR scenario, the 

attributable mortality decreases by more than 55% relative to the baseline scenario in 2030, and by 

approximately 50% relative to the baseline scenario in 2050. Despite these strong reductions, a 

significant health impact due to air pollution still remains with the MTFR scenario, with more than 

20,000 yearly attributable deaths in 2030 and more than 10,000 yearly attributable deaths in 2050. The 

impact of the scenarios for nitrogen dioxide is somewhat more limited, with relative reductions of 29% 

(2030) and 16% (2050) for the MTFR scenario. Under the MTFR scenario, more than 2,500 yearly 

attributable deaths remain in 2030, a number that further decreases to approximately 500 yearly 

attributable deaths in 2050. For ozone, the impact of the scenarios is  limited. Under the MTFR 

scenario, the number of premature deaths reduces by 10% in 2030 and by  8% in 2050.  

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Figure 44 : Number of yearly premature deaths in the EU-27 caused by exposure to air pollution at levels above 
the WHO AQ guidelines for the MTFR scenario for three pollutants (PM2.5, top-left, NO2, top-right, O3, bottom). 

Notes: Impacts for the four reporting years considered in the study (2015 in blue, 2020 in cyan, 2030 in orange and 2050 in green) are 
included. The filled bars and the numbers refer to the central estimate (rounded to the nearest 100 for NO 2 and the nearest 1000 for 
PM2.5, respectively), while the black lines provide the 95-percentage uncertainty estimate based on the uncertainty on the relative 
risks. 

Figure 45: Relative impact of the scenarios on the number of yearly premature deaths in the EU-27 caused by 
the exposure to air pollution at levels above the WHO AQ guidelines for three pollutants (PM2.5, top-left, NO2, 
top-right, O3, bottom). 

Notes: Impacts for the two future reporting years considered in the study (2015 in blue, 2020 in cyan, 2030 in orange and 2050 in 
green) are included.  

The bar graphs in Figure 46 and Figure 47 show the impact of the MTFR scenario on the number of yearly 

attributable deaths per capita for all countries in the EU-27, while the maps in Figure 48 show the 

relative impact of the MTFR scenario per NUTS 1 region. Note that we do not provide the regional 

breakdown of the impact of the MTFR for ozone, because this (and other) scenario(s) only has a limited 

impact on health impacts.  

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The bar plots indicate a strong regional difference in the impact of the MTFR scenario on the chronic 

mortality caused by the exposure to particulate matter. Smaller impacts are observed in Southern 

Europe in comparison with the impact in other regions. The relative reduction in mortality is markedly 

smaller in Cyprus, Greece and Malta (with impact of the MTFR less than 20% for all these countries in 

2030 and 2050), and to a lesser extent in Italy (impact around 35% in 2030 and 2050). In this region, 

the natural contribution to the concentrations is much larger, and this important share of the total 

pollution cannot be reduced by the emission scenarios. The modest relative impact of the MTFR for 

the Mediterranean regions becomes especially evident on the maps at NUTS1 level, with  a minor 

impact of the scenarios observed in all NUTS 1 regions in Greece, Italy, Malta and Cyprus, and in 

Southern Spain, both in 2030 and 2050. The relative reduction is also limited in Eastern-Sweden 

(mainly due to limited reductions in non-exhaust traffic emissions in the Stockholm area), but the 

baseline health impact is already low in this region. (The maps for the OPT-scenarios presented in 

Section 8 are similar to the maps for the MTFR-scenario (although with smaller relative reductions), 

and also reflect the remarks made in this paragraph).  

The maps for nitrogen dioxide reflect the nature of nitrogen dioxide pollution: because concentration 

hotspots are mostly linked to important local emission hotspots, and the highest reductions in 

attributable mortality under the MTFR scenarios are observed at the hotspots for which the emissions 

are reduced by the greatest margin. The charts indicate that the largest impact is observed in the 

countries with impact mainly related to road traffic and industrial emissions (Belgium, Spain, the 

Netherlands and France in 2030 and Greece and Spain in 2050), while the impact of the MTFR scenario 

is limited in the countries in which (international) shipping emissions provide an important 

contribution (Greece, Italy and Slovenia in 2030; and Italy and Malta44 in 2050). The maps per NUTS1 

region further substantiate these findings.  

44 Note that the premature mortality related to the exposure to nitrogen dioxide increases between 2030 and 2050 due to 
increase in international shipping emissions at a single port. Because of the small total population of Malta, these local 
effects dominate the country totals.  

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Figure 46 Impact of the MTFR scenario on the number of yearly premature deaths per country caused by the 
exposure to air pollution at levels above the WHO AQ guidelines for two pollutants (PM2.5, left, NO2, right). 
Impacts for 2030 are considered. 

Notes: The filled bars refer to the central estimate for the number of attributable deaths per 100.000 inhabitants, while the black 
lines provide the 95-percentage uncertainty estimate based on the uncertainty on the relative risks. The values indicate the 
percentual change between the base line and the MTFR scenario. These values have been hidden for countries with less than 1 death 
per 1 million inhabitants under the baseline scenario (because the uncertainty on the relative reductions is very large for these 
locations). 

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Figure 47 Impact of the MTFR scenario on the number of yearly premature deaths per country caused by the 
exposure to air pollution at levels above the WHO AQ guidelines for two pollutants (PM2.5, left, NO2, right).  
Impacts for 2050 are considered. 

Notes: The filled bars refer to the central estimate for the number of attributable deaths per 100.000 inhabitants, while the black 
lines provide the 95-percentage uncertainty estimate based on the uncertainty on the relative risks. The values indicate the 
percentual change between the base line and the MTFR scenario. These values have been hidden for countries with less than 1 death 
per 1 million inhabitants under the baseline scenario (because the uncertainty on the relative reductions is very large for these 
locations).  

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Figure 48 Relative impact of the MTFR scenario on the number of yearly premature deaths per NUTS1 region 
caused by the exposure to air pollution for two pollutants (PM2.5, left; NO2, right).  Impacts for the MTFR 
scenario in 2030 (top figures) and 2050 (bottom figures) are considered. 

Notes: Results have been hidden for regions with less than 1 death per 1 million inhabitants under the baseline scenario (grey 
locations). 

Results for attributable morbidity (Tier 2 and Tier 3) 

Table 11 provides an overview of the impact of the MTFR scenario on the morbidity outcomes 

considered in the second (morbidity according to HRAPIE) and third Tier (additional health outcomes 

beyond HRAPIE: stroke, lung cancer and asthma in children). 

As with the results for chronic mortality, for all health outcomes, a strong reduction in impact under 

the MTFR scenario is observed. The results also correspond quantitively with those for the chronic 

mortality caused by PM2.5 exposure. The relative impact of the MTFR scenario for 2030 varies from 56% 

(for chronic bronchitis) to 61% (for respiratory hospital admissions), which is in line with a 57% 

reduction in overall mortality. For 2050, the relative impact of the MTFR scenario is between 50% (for 

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chronic bronchitis) and 55% (for cardiovascular hospital admissions), which is also in line with the 50% 

reduction in overall mortality.  

Table 11: Morbidity caused by the exposure to PM2.5 pollution in the EU27 under the baseline and MTFR 
scenarios for 2030 and 2050. Values have been rounded to the nearest integer.  

Health outcome 

Unit 

2030 baseline 

2030 MTFR 

2050 baseline 

2050 MTFR 

Infant Mortality 

Bronchitis in 

Children  

(age 6 -12) 

Deaths  

per year 

Cases  

per year 

15 (7 ; 27) 

6 (3 ; 11) 

3 (1 ; 5) 

1 (0 ; 2) 

61,000  

25,500  

24,500  

11,600  

(0 ; 136,000) 

(0 ; 57,100) 

(0 ; 54,900) 

(0 ; 25,900) 

Chronic Bronchitis  

Incidence 

24,500 

10,700  

10,700  

5,260  

in adults 

per year 

 (8,760 ; 38,000) 

(3,820 ; 16,600) 

(3,820 ; 16,600) 

(1,880 ; 8,160) 

Cardiovascular 

Admissions 

14,100  

5,540  

5,370  

2,430  

hospital admissions 

per year 

(2,650 ; 25,600) 

(1,040 ; 10,100) 

(1,010 ; 9,740) 

(456 ; 4,410) 

Respiratory 

Admissions 

14,500  

5,670 ( 

5,920  

2,680  

hospital admissions 

per year 

(0 ; 30,100) 

0 ; 11,800) 

(0 ; 12,300) 

(0 ; 5,560) 

Restricted activity 

Days  

days 

per year 

Lost working days 

Days  

per year 

59,500,000 

25,800,000 

25,600,000 

12,500,000 

(53,300,000 ; 

(23,100,000 ; 

(22,900,000 ; 

(11,200,000 ; 

66,900,000) 

29,000,000) 

28,700,000) 

14,100,000) 

21,200,000 

8,390,000  

8,260,000  

3,790,000  

(18,000,000 ; 

(7,150,000 ; 

(7,030,000 ; 

(3,220,000 ; 

24,300,000) 

9,630,000) 

9,470,000) 

4,340,000) 

Stroke (CVA) 

Lung cancer 

Incidence 

11,500  

4,830  

4,780  

2,270  

per year 

(9,800 ; 13,100) 

(4,130 ; 5,520) 

(4,090 ; 5,460) 

(1,950 ; 2,600) 

Incidence 

4,260  

1,830  

1,800  

876  

per year 

(1,950 ; 6,440) 

(835 ; 2,760) 

(823 ; 2,720) 

(401 ; 1,320) 

Asthma in children  

Incidence 

23,700 (8,180 ; 

9,840 (3,370 ; 

9,500 (3,260 ; 

4,420 (1,530 ; 

(age < 16 years) 

per year 

38,300) 

15,900) 

15,400) 

7,120) 

Health impacts – summary baseline and MTFR 

From the analysis, several conclusions can be drawn regarding health impacts under the baseline and 

MTFR scenarios:  

•  Under the baseline policy plans, the mortality caused by exposure to NO2 and PM2.5 decreases 

significantly from 2015 to 2030. However, there would still be a considerable number of 

premature deaths each year observed in 2030, with tens of thousands of attributable deaths per 

year caused by exposure to PM2.5 and thousands of deaths caused by  exposure to NO2. 

• 

For particulate matter, the baseline attributable mortality is larger in Eastern and Southern 

European countries, in comparison with the impact in most Northern and Western European 

countries (which is in line with the spatial pattern of the baseline emissions and natural 

contributions) 

• 

The results for nitrogen dioxide reflect the nature of nitrogen dioxide pollution: because 

concentration hotspots are mostly linked to important local shipping and traffic emissions. The 

highest baseline mortality is also observed at these locations 

• 

Results for morbidity follow the same pattern as those observed for the PM2.5 mortality. 

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• 

The impact of the MTFR scenario is somewhat more limited for the mortality caused by nitrogen 

dioxide pollution (relative reductions of 29% (2030) and 16% (2050) scenario). 

Costs to society 

The human and environmental effects of air pollution place a cost on society. The costs to society are 

estimated on the basis of the health impacts calculated for Indicator #2 and ecosystem impacts for 

Indicator #3. These effects are combined with monetary impact values to capture the cost to society. In 

the case of human health, this represents impact on: lost utility or welfare, lost labour (or productivity) 

and health care costs. By monetising the effects of air pollution they can be more readily compared to 

the costs of mitigation action. 

Detail on the approach taken to monetisation is included in Appendix 6. For human health impacts, the 

monetary unit values applied in CAO2 have been applied, where relevant. The CAO2 proposed monetary 

values were derived from an extensive literature review of the latest valuation approaches (by 

organisations such as the OECD) which concluded in December 2020. This impact assessment study has 

also considered pathways not included in CAO2 under Tier 3 – for these pathways, a targeted literature 

review was undertaken to underpin the selection of an appropriate monetary value.  

The results of the analysis are presented in the following tables, which present the absolute effects for 

the baseline and MTFR scenario, alongside the difference (or net effect) of the scenario relative to the 

baseline. In line with CAO2, two sets of results are presented which present different approaches to 

monetising the impacts on mortality: a ‘VSL’ or value of statistical life approach, which monetises the 

number of deaths, and a VOLY or Value of statistical life year approach, which instead monetises life 

years lost. The results present the monetary benefits in the given assessment year. For the aggregate 

assessment, the mortality effects associated with NO2 are excluded to avoid the risk of overlap with the 

mortality effects of PM2.5. 

Table 12 presents costs to society, showing that air pollution continues to place a heavy burden on 

society going forward. The human health costs of ongoing exposure to unsafe levels of air pollution are 

estimated to be up to €740 bn per annum in 2020 (based on the higher VSL approach). The health 

burden reduces in the baseline through continued improvements as a consequence of policies in the 

baseline. The MTFR scenario could deliver significant societal benefits – around €141 bn per annum in 

2030 and €77 bn in 2050. The size of the potential benefit reduces due to the ongoing improvements in 

the baseline, which reduce the potential additional benefit that can be achieved. 

Table 12–Costs to society (valuation of health impacts) – central (all values €bn 2015 prices, EU27) 

VSL 

VSL 

VOLY 

VOLY 

Net VSL 

Net VOLY 

Scenario 

Baseline 

MTFR 

Baseline 

MTFR 

MTFR 

MTFR 

2030 

 444  

 303  

 140  

 92  

 141  

 48  

2050 

 332  

 256  

 90  

 68  

 77  

 22  

2020 

 739 

- 

 251  

- 

- 

- 

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Links with climate change 

The baseline scenario includes EU climate goals of EU-wide reduction of GHG emissions by at least 55% 

by 2030, compared to 1990 levels37 resulting, among others, in decline of fossil fuel use. Beyond CO2, 

these changes also have co-benefits on emissions of non-CO2 greenhouse gases (not shown) as well as 

short-lived climate forcers (SLCFs), including cooling (e.g., SO2) and warming (e.g., black carbon (BC)) 

species. However, the energy scenario underlying this strategy also implies further use of biomass 

combustion in power generation and for residential heating. Combustion of biomass leads to emissions 

of air pollutants, including black carbon, especially from older and inefficient residential heating 

installations. Compared to the Reference scenario, the ‘MIX55’ scenario37,45 used here for the baseline 

and all other scenarios, has (beyond an increase of biomass use in the power sector) a slower decline of 

biomass use for residential heating resulting in a trade-off for air pollution and climate as emissions of 

PM2.5 and BC from the residential sector are slightly higher in the MIX55 scenario, compared to the 

Reference scenario, although in both of them they continue to decline. As indicated below, the 

baseline scenario includes assumptions about technology improvement over time and the MTFR case 

explores potential for further reduction through a more rapid roll-out of the cleanest combustion 

technologies; yet the assumed amount of energy generation from biomass is the same in the baseline 

and MTFR. 

The SO2 trend is shown above in Figure 9 and Figure 10, and will lead to additional warming of the 

atmosphere, which will be partly offset by the reduction of CO2 and CH4 (lesser demand for fossil fuels 

results in lower losses from coal, oil, and gas production and distribution systems, e.g., Hoglund et al., 

2020) as well as black carbon (BC).  

Additionally, air pollution measures have an impact on SLCFs, including SO2 as well as black carbon 

(BC), where fleet turnover, wider penetration of more efficient and pellet stoves and boilers will result 

in further reductions of BC emission. Figure 49 shows the trend in BC emissions in the baseline, 

highlighting the impact of fuel shifts as well as application of technology in transport and residential 

heating sectors that dominate current emissions and will remain key sources of BC, albeit the total 

emissions are estimated to decline by 65% to 2030, and by over 80% to 2050, compared to 2015. 

45 ‘Reference’ and ‘MIX’ scenarios refer to scenarios modelled in the context of the Fit for 55 package of climate measures; For 
details of the Reference scenario refer to Annex 10.4 

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Figure 49 –Emission of black carbon (BC) in the baseline scenario for the EU-27; GAINS model 

Ecosystem impacts 

This section presents indicators on ecosystem impacts in terms of acidification and eutrophication from 

excess deposition of nitrogen (for acidification and eutrophication) and sulphur (for acidification). 

Results are calculated with the GAINS model using critical loads approved by the Air Convention in 2017 

(Hettelingh et al., 2017).  

Maps of ecosystem areas exceeding critical loads for acidification and eutrophication from deposition of 

nitrogen and sulphur are shown in Figure 50 to Figure 54 for the Baseline and MTFR scenarios. Table 13 

to Table 16 present the exceedance of critical loads (percentages of area above critical load) for 

eutrophication and acidification respectively under the Baseline scenario in 2030 and 2050, for 

different types of ecosystems. Eutrophication is still a widespread problem in Europe, with an 

estimated 74% of all ecosystem areas exceeding critical loads. Despite improvements in 2030 and even 

further in 2050,  ~65% of ecosystem areas are still expected to exceed critical loads for eutrophication 

in 2050 under the Baseline. Under the MTFR scenario, this is reduced to 48% in 2050. Acidification is 

much less of an issue, with 4.8% of ecosystem areas currently exceeding the critical loads, decreasing 

to 3.1% in 2030 and 2.4% in 2050 under the Baseline scenario (1.2% in 2050 under the MTFR scenario).  

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Figure 50 . Shares of ecosystem area exceeding critical loads for eutrophication (left) and acidification (right) in 
2020. 

Figure 51 – Shares of ecosystem areas exceeding critical loads for eutrophication in 2030: Baseline (left) and 
MTFR (right) 

Figure 52 – Shares of ecosystem areas exceeding critical loads for eutrophication in 2050: Baseline (left) and 
MTFR (right) 

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Figure 53– Shares of ecosystem areas exceeding critical loads for acidification in 2030: Baseline (left) and MTFR 
(right) 

Figure 54– Shares of ecosystem areas exceeding critical loads for acidification in 2050: Baseline (left) and MTFR 
(right) 

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Table 13 - Exceedance of critical loads (percentages of area above critical load) for eutrophication in 2020 for 
different types of ecosystems; GAINS model 

% Total 

ecosystems 

area exceeded 

% Forest area 

% Catchment 

% Semi-natural 

exceeded 

area exceeded 

area exceeded 

2020 

2020 

2020 

2020 

0 

0 

0 

0 

0 

0 

0 

0 

5.9 

0 

8.8 

0 

0 

0 

64.5 

0 

0 

0 

0 

27.2 

0 

0 

0 

0 

0 

0 

0 

10.5 

43.2 

79.9 

100 

100 

100 

0 

100 

79.7 

0 

79.1 

54.4 

100 

100 

0.1 

40.8 

99.8 

100 

100 

100 

66.6 

9.1 

99.5 

100 

100 

100 

98.3 

12.3 

75.4 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovak 

Republic 

Slovenia 

Spain 

Sweden 

EU-27 avg. 

48.6 

2.5 

96.7 

86 

100 

100 

100 

70.6 

1.5 

73.1 

71.8 

95.6 

95.6 

7 

44.6 

92.4 

98.8 

100 

99.7 

71.4 

60.5 

99.5 

94.6 

93.7 

97.3 

98.2 

12.3 

74.2 

50.1 

0.8 

95.2 

74.6 

100 

100 

100 

66.8 

1.2 

72.8 

72.4 

85.9 

92.5 

22.7 

46.3 

87.8 

98.4 

100 

95 

83 

61.4 

99.6 

91.9 

92 

96.5 

98 

0 

74.1 

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Table 14 - Exceedance of critical loads (percentages of area above critical load) for eutrophication under the 
Baseline scenario in 2030 and 2050, for different types of ecosystems. 

% Total 

ecosystems 

area exceeded 

% Forest area 

% Catchment area 

% Semi-natural area 

exceeded 

exceeded 

exceeded 

2030 

2050 

2030 

2050 

2030 

2050 

2030 

2050 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

34.8 

1 

31 

0.8 

93.6 

90.5 

82.9 

82.3 

100 

100 

100 

96.1 

99.7 

98.9 

38.7 

15.5 

0.8 

0.6 

65.1 

60.9 

66.9 

62.7 

94.1 

93.1 

89.3 

80.1 

7.2 

5.9 

34.7 

30.2 

87.1 

71.7 

98.1 

96.9 

100 

100 

99.9 

100 

Netherlands 

69.2 

67.5 

Poland 

Portugal 

Romania 

52.3 

45.5 

99.1 

98.3 

93.8 

92 

Slovak Republic 

90.2 

88.2 

36.6 

0.4 

90.7 

69 

100 

100 

99.5 

28.3 

0.2 

64.6 

67.4 

81.2 

81.7 

22.7 

35.1 

79.2 

97.4 

100 

100 

81.5 

53.1 

98.8 

90.7 

87.6 

76 

31.9 

0.2 

86.2 

67.8 

100 

96.1 

98 

3.6 

0 

60.2 

63.3 

78 

65.9 

19.2 

30 

54.6 

95.9 

100 

100 

80.8 

46.2 

97.7 

88 

84.9 

71.4 

96.5 

0 

0 

0 

0 

0 

0 

0 

0 

0 

4.5 

0 

6.4 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

3.7 

0 

2.7 

0 

0 

0 

55.8 

53.3 

0 

0 

0 

0 

0 

0 

0 

0 

20.9 

14.3 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

7 

28.5 

29.1 

100 

100 

100 

0 

100 

63.3 

0 

78.5 

51.5 

100 

100 

0.4 

33.7 

99.7 

100 

100 

100 

64.5 

5 

99.4 

100 

100 

99.8 

97.8 

9.6 

73.7 

27.9 

28.6 

100 

100 

100 

0 

100 

44.1 

0 

78.1 

43.3 

100 

100 

0.1 

30.2 

99.1 

99.5 

99.8 

100 

62.9 

3.2 

99 

100 

100 

99.7 

97.5 

6.1 

72.5 

Slovenia 

Spain 

Sweden 

81.2 

77.6 

97.5 

97.1 

97.1 

9.6 

6.1 

0 

EU-27 avg. 

69.2 

65.5 

67.2 

62.3 

8.4 

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Table 15 - Exceedance of critical loads (percentages of area above critical load) for acidification in 2020 for 
different types of ecosystems; GAINS model 

% Total 

ecosystems area 

exceeded 

2020 

% Forest area 

% Catchment 

% Semi-natural 

exceeded 

area exceeded 

area exceeded 

2020 

2020 

2020 

0 

0 

0 

0 

0 

0 

0 

0 

0.4 

0 

96.4 

0 

0 

3 

0 

0 

0 

0 

0 

32.5 

0 

0 

0 

0 

0 

0 

2.8 

2.8 

0 

0 

0 

0 

0 

0 

0 

0 

0 

24.1 

37 

0 

0 

0 

0 

0 

0 

0 

0 

75.2 

0.5 

0 

0 

0 

0 

0 

0 

0.9 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovak Republic 

Slovenia 

Spain 

Sweden 

EU-27 avg. 

0 

0.7 

0 

1.9 

0 

40.8 

3 

0 

0.4 

2.1 

31.2 

0.1 

4.2 

0.3 

0 

1.5 

25.3 

10.2 

0 

85.9 

15.1 

0.4 

0.1 

1.7 

0 

0 

2.8 

4.8 

0 

0.7 

0 

3.4 

0 

40.8 

5.4 

0 

0 

1.2 

31 

0.2 

7.2 

0.3 

0 

2.5 

35.1 

15.3 

0 

92 

15.3 

0.7 

0.1 

2.1 

0 

0 

0 

7.4 

107 

 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 16- Exceedance of critical loads (percentages of area above critical load) for acidification under the 
Baseline scenario in 2030 and 2050, for different types of ecosystems 

% Total 

ecosystems 

area exceeded 

% Forest area 

% Catchment 

% Semi-natural 

exceeded 

area exceeded 

area exceeded 

2030 

2050 

2030 

2050 

2030 

2050 

2030 

2050 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

0 

0.5 

0 

0.8 

0 

Czech Rep. 

18.9 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

0.8 

0 

0.4 

0.7 

22 

0.1 

2.1 

0.3 

0 

1.1 

22 

6.9 

0 

0 

0.5 

0 

0.4 

0 

9.8 

0.5 

0 

0.4 

0.2 

16.6 

0.1 

1.7 

0.2 

0 

0.6 

19.2 

0.3 

0 

0 

0.5 

0 

1.4 

0 

18.9 

1.4 

0 

0 

0.6 

21.8 

0.2 

3.5 

0.3 

0 

1.8 

30.5 

10.4 

0 

0 

0.5 

0 

0.8 

0 

9.8 

1 

0 

0 

0.2 

16.3 

0.2 

2.9 

0.2 

0 

0.9 

26.6 

0.4 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0.4 

0 

88.7 

0.4 

0 

82 

0 

0 

3 

0 

0 

0 

0 

0 

0 

0 

3 

0 

0 

0 

0 

0 

Netherlands 

84.3 

83.1 

91.3 

90.5 

19.9 

16.6 

Poland 

Portugal 

Romania 

Slovak 

Republic 

Slovenia 

Spain 

Sweden 

EU-27 avg. 

6.3 

0.4 

0 

3.3 

0.4 

0 

0.8 

0.1 

0 

0 

2.3 

3.1 

0 

0 

2.2 

2.4 

6.4 

0.7 

0 

1 

0 

0 

0 

3.4 

0.7 

0 

0.2 

0 

0 

0 

4.7 

3.4 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

2.3 

2.3 

2.2 

2.2 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

3.8 

27.6 

0.8 

24.1 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

72.4 

0.4 

70.3 

0.2 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0.5 

0.4 

Valuation of ecosystem impacts 

As for human health, detrimental impacts of exposure to air pollution on the environment carries with 

it a societal cost. Methods have been developed over many years to monetise these impacts, such that 

they can be compared (alongside the human health effects) to the costs of mitigation. The approaches 

to monetising these impacts in this study are the same as those deployed under CAO2 (further detail is 

included in Appendix 6). 

The following table presents the monetised impacts of air pollution on the environment under the 

baseline and MTFR scenario. The MTFR can deliver substantial ecosystem benefits, however the 

108 

 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

aggregate size of these benefits is still smaller than the human health benefits (estimates range from 

EUR bn 48 – 141 per annum in 2030 – see Section 7.1.3). 

The size of the damage in the baseline reduces over time alongside further emissions reductions 

delivered through current policy. This is particularly the case for materials damage driven by ongoing 

falls in SO2. The highest material damage in the baseline in 2030 is estimated for Germany, followed by 

Poland. 

The analysis considers all agricultural crop production in the EU, focused on the effects of ozone. The 

countries most affected by crop damages are France, Italy and Spain in the baseline, and hence these 

are also those that gain most under the MTFR scenario. 

Table 17– Monetised material damage impacts per annum – baseline and MTFR – EURm 2015 prices 

2015 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

Baseline 

MTFR 

Net MTFR 

 1,871  

 1,136  

914  

662  

517  

465  

447  

- 

- 

- 

- 

- 

- 

436  

226  

- 

- 

- 

- 

- 

- 

442  

269  

172  

Table 18– Monetised crop damage impacts per annum – baseline and MTFR – EURm 2015 prices 

Baseline 

MTFR 

Net MTFR 

2015 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

11,758  

10,691  

10,320  

9,877  

9,629  

9,518  

9,450  

9,459  

- 

- 

- 

- 

- 

- 

9,472  

404  

- 

- 

- 

- 

- 

- 

9,110  

348  

Table 19– Monetised forest damage impacts per annum – baseline and MTFR – EURm 2015 prices - LOW46 

Total damage by scenario 

2015 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

Baseline 

MTFR 

Net MTFR 

20,326  

19,050  

18,551  

17,975  

17,648  

17,478  

17,371  

17,374  

- 

- 

- 

- 

- 

- 

17,486  

488  

- 

- 

- 

- 

- 

- 

16,954  

420  

Table 20– Monetised forest damage impacts per annum – baseline and MTFR – EURm 2015 prices - HIGH 

Total damage by scenario 

2015 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

Baseline 

MTFR 

Net MTFR 

20,326  

19,050  

18,551  

17,975  

42,882  

42,470  

42,211  

42,217  

- 

- 

- 

- 

- 

- 

17,486  

488  

- 

- 

- 

- 

- 

- 

41,194  

1,023  

46 Note that there is no difference between HIGH and LOW estimate for forest damage in 2030 as only after 2030 different 
assumptions are used to monetise the reduced carbon sequestration potential due to forest damage. 

109 

 
 
 
 
                
                
                
                
                
                
                
                
                
                
  
 
                 
                 
                
                    
                    
                    
                    
                    
                    
                    
                       
                       
  
          
          
          
          
          
          
          
          
          
          
                
                
 
          
          
          
          
          
          
          
          
          
          
                
            
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 21– Monetised ecosystem damage impacts per annum – baseline and MTFR – EURm 2015 prices - LOW 

Total damage by scenario 

2015 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

Baseline 

MTFR 

Net MTFR 

4,215  

3,901  

3,769  

3,588  

3,485  

3,422  

3,386  

3,375  

- 

- 

- 

- 

- 

- 

2,588  

1,000  

- 

- 

- 

- 

- 

- 

2,328  

1,047  

Table 22– Monetised ecosystem damage impacts per annum – baseline and MTFR – EURm 2015 prices - HIGH 

Total damage by scenario 

2015 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

Baseline 

MTFR 

Net MTFR 

12,644  

11,702  

11,308  

10,765  

10,455  

10,267  

10,157  

10,124  

- 

- 

- 

- 

- 

- 

7,765  

3,000  

- 

- 

- 

- 

- 

- 

6,984  

3,140  

  Problem: Projected enforcement and governance shortcomings 

Driver: Insufficient penalties and damages linked to exceedance 

Where the established limit values or target values for ambient air quality are not met, the Directives 

require Member States to prepare and implement air quality plans and measures. Directive 2008/50/EC 

requires Air Quality Plans to identify the main emission sources responsible for pollution, detail the 

factors responsible for exceedances, and spell out the abatement measures planned to reduce 

pollution. Air quality plans shall be reported to the Commission no later than two years after the 

exceedance occurred. Member States can select the measures to achieve the air quality standards, but 

exceedance periods must be kept as short as possible. However, it has been found (European 

Commission, 2021) that the current framework under the AAQ Directives has resulted in delays in 

implementing measures across Member States, with data showing persistent exceedances of the current 

air quality standards for at least one air pollutant in the majority of Member States. While the number 

of Member States continuing to exceed the limit values has begun to decrease, the problem persists. 

Directive 2008/50/EC currently states, as per Article 30, that Member States shall lay down the rules on 

penalties applicable to infringements of the national provisions adopted pursuant to that Directive. 

Article 9 provides the equivalent for Directive 2004/107/EC. These articles do not, however, set a 

specific level at which penalties must be set nor does it specify which provision might be concerned, 

stating only that penalties must be effective, proportionate and dissuasive. This lack of detail has led 

to a limited use of penalties in Member State with little impact on air pollution reduction. Access to 

justice and compensation for health damage suffered from air pollution is currently not addressed in 

the Ambient Air Quality Directives. It is assumed that the current problems that derive from the nature 

of the existing provisions under the AAQ Directives would remain present and would limit their 

effectiveness to a similar extent. 

If the provisions on penalties (Article 30 under Directive 2008/50/EC  and Article 9 under Directive 

2004/107/EC) remain the same, and if no  provisions on access to justice and health damage 

compensations are added, the situation as regards the exceedances of air quality standards will 

remain as currently is. Namely, many Member States exceed the limit values for different pollutants, 

even though the number of Member States that do exceed the limit values has slowly been decreasing. 

The baseline therefore does not anticipate the current situation worsening, it is more likely to remain 

the same or slightly improve. The penalties provisions in place under the AAQ Directives will also 

110 

                      
                      
                      
                      
                      
                      
                      
                      
                      
                      
                      
                      
 
                    
                    
                    
                    
                    
                    
                    
                    
                      
                      
                      
                      
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

therefore remain the same, without further specifying the types of penalties, their levels or how 

damages should be compensated. Under the baseline situation the current AAQ Directives do not 

provide individuals with an explicit provision on access to justice. In practice this means that 

individuals do not have an explicit provision derived from EU legislation to rely upon before national 

courts in cases of air quality rules stemming from the AAQ Directives.  

Driver: Air Quality Plans and measures have often proven ineffective 

The requirement to prepare air quality plans when limit or target values are exceeded is one of the 

fundamental provisions of the AAQ Directives. There is an obligation to prepare and publish an air 

quality plan within two years of the identification of an exceedance. Article 23 of Directive 2008/50/EC 

sets a clear obligation for competent authorities to take action to keep the exceedance period “as short 

as possible”. This obligation has resulted in actions to improve air quality in the EU, including 

enforcement and legal actions initiated by individuals, NGOs and the Commission. 

However, while many air quality plans have been prepared across Europe at national, regional and local 

level to comply with the AAQ Directives, the continuing (although decreasing) high levels of air 

pollution show that air quality plans have not been sufficient to ensure compliance with limit and 

target values as soon as possible. Findings from the Fitness Check indicate that air quality plans have 

not always delivered improvements in air quality or addressed all sources effectively. Some measures 

may be ineffective or seem disproportionate. As of May 2022, a total of 29 infringement cases against 

18 Member States are ongoing for exceedances of PM10, PM2.5, NO2 or SO2 concentration levels or flawed 

monitoring.47 Fifteen of these cases have been referred to the Court of Justice of the European Union, 

of which eleven cases have received a ruling. This indicates that air quality plans are continuing to fail 

to deliver the required improvement in air quality.  

Under the baseline scenario, requirements for action required in case of exceedances, including the 

establishment of Air Quality Plans (i.e., intervention area C under Policy Area 2), are assumed to 

remain identical to what is currently in place. The assumption followed is that the current problems 

that derive from the nature of the existing requirements for action in case of exceedances would 

remain present and would limit the effectiveness of the AAQ Directives to a similar extent.  

The effectiveness of air quality plans is expected to be limited in the same way with the measures 

contained therein not always being updated to match the changing air quality context of a location (for 

instance new drivers of air pollution or worsening air quality in general) nor the best available 

solutions. 

An additional underlying issue affecting the effectiveness of air quality plans is poor coordination 

between public authorities and the unclear allocation of responsibilities. This can lead to insufficient 

action being taken by public authorities or to a mismatch of action. Added to this, citizens are not 

systematically consulted in the development of air quality plans. Their contribution could make the 

plans more legitimate and more effective.  

47 In addition, there is also an infringement case against the United Kingdom addressing exceedances of NO₂. 

111 

 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Driver: Some measures may seem disproportionate, ineffective 

Annex XV to Directive 2008/50/EC states a number of essential elements that are required for an air 

quality plan. While respondents to a survey (Conlan et al., 2022) reported that all of these remain 

essential and were to be included in plans, the most important of these elements according to the 

stakeholders responding were: Determining the sources responsible for pollution, followed by 

Localisation of excess pollution, e.g. region, city or measuring station and Analysis of the situation 

e.g. details of those factors responsible for the exceedance. A third of stakeholders said that air 

quality plans still required improvement. Improvements suggested included better characterisation of 

the exceedance, specifying the area where the measures should apply, and targeted action to improve 

the effectiveness of the measures themselves. Reviews of Air Quality Plans show that current practice 

by almost all Member States is to include hundreds of measures in their plans, many of which are not 

likely to be highly effective in solving the air quality problem as soon as possible but are longer term 

and strategic. 

Furthermore, many Member States either do not provide any quantification on the projected 

attainment of limit values or use less robust methods to illustrate impacts of measures within their Air 

Quality Plans. In a survey for (Conlan et al., 2022), 71% of respondents used complex modelling to 

quantify baseline concentrations. However, only 26% used complex modelling to estimate future 

projections with and without measures to determine when compliance is likely. Assumptions within 

modelling are not always apparent and there is often a lack of evidence to justify that these are not 

overly optimistic. Very few Air Quality Plans explain the methods used for forecasting the evolution of 

air quality and the underlying assumptions and uncertainties. Therefore, even when modelling is used 

to support air quality planning it is often difficult to judge whether the modelling is fit for purpose and 

whether compliance is likely with the implementation of the chosen measures. 

Where plans include future projections of concentrations these scenarios are often modelled only for 

five-year intervals. Such practice makes it difficult to verify whether other measures would allow 

achieving compliance at an earlier date. In addition, in a recent targeted stakeholder survey (Conlan et 

al., 2022) of air quality managers at local, regional and national level, most respondents said that 

measures in their current plan are expected to deliver the desired effect within three to four years. 

However, four stakeholders thought that the current plan will never provide the expected impact. The 

overall consequence is unknown confidence in when, or indeed if, measures included in Air Quality 

Plans will improve air quality sufficiently to protect human health. 

This means that some measures set-up by competent authorities within Member States are expected to 

remain insufficiently ambitious to reduce air pollution to a safe level, partly due to the fact that the 

obligation for measures to keep the exceedance period as short as possible is not specific enough in the 

text of the Directive. This problem is also partly due to a lack of coordination between short-term 

action plans and air quality plans, which can lead to insufficient action as well as inefficient actions 

being taken by public authorities.  

Driver: Local air quality is impacted by emissions outside control 

Air Quality Plans are required to clearly localise the excess pollution, provide an assessment of the 

pollution situation, list and quantify the main emission sources responsible for the pollution and provide 

details of those factors responsible for the exceedance, and detail possible measures for the 

improvement of air quality. Measures adopted with a view to reducing pollution need to be described, 

112 

   
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

including with a timetable for implementation as well as estimates of the improvement in air quality. In 

line with the principle of subsidiarity, the choice of measures is left to Member States, to ensure that 

these are appropriate and cost-effective within the specific context of respective local and national 

circumstances. However, as stated in Section 3, competences, and the division of responsibilities to 

implement the measures are not always suitably defined, and coordination between different levels of 

governance (national, regional, local) is a key challenge. In addition, stakeholders are not 

systematically consulted when Air Quality Plans are designed. 

If the provisions to guide the development of Air Quality Plans, including on who to involve and on 

vertical and horizontal coordination between levels of governance in their establishment and their 

implementation (i.e., intervention area D under Policy Area 2), are not further specified, the same 

consequences as described above are expected, namely that Air Quality Plans and associated measures 

would remain insufficient, inefficient and/or ineffective in some instances. In the conclusions on 

coherence in the Ambient Air Quality Fitness Check, it is stated that “gaps in coordination in many 

Member States remain an obstacle to achieving the AAQ Directives’ objectives, as does coordination 

between national and sub-national authorities.” The assumption taken in the baseline is that this 

situation would not significantly improve without further EU intervention. 

Driver: Lack of flexibility to adapt to evolving science and new recommendations 

EU standards are not fully aligned with the latest scientific advice. The AAQ Directives have enabled a 

review of stringency in the past, but this is not systematic. Directive 2008/50, Article 32 provided 

grounds for one off review on the basis of specific evidence (e.g. WHO guidance or reduction potentials 

in Member States), but does not provide a mandate for regular reviews. To ensure relevance of AAQ 

Directives, appropriate mechanisms are needed to flexibly adapt to evolving science and new 

recommendations to protect human health. Without measures to ensure that the AAQ Directives set 

meaningful standards to protect human health and ecosystems in accordance with evolving scientific 

understanding, current standards might lose relevance as new scientific and technological evidence 

become available.  

Under the baseline we assume that all of the air pollutants currently covered by the Directive continue 

to be relevant, as their respective harmful effects are confirmed (Fitness Check). Directives 2004/107 

and 2008/50 might not cover all the pollutants that might have harmful effects on health. Evidence also 

shows that there is a need for ongoing assessment of whether standards for pollutants not currently in 

scope of the AAQ Directives48 should be added to ensure relevance of the directives.  

  Problem: Projected air quality assessment and monitoring shortcomings 

Driver: Monitoring rules offering flexibility are stretched in certain instances 

Member States have been monitoring air quality for many decades and by 2020 there were over 4 000 
air quality monitoring stations with nearly 16 000 sampling points ( 

48 Scientific evidence points to serious adverse health effects at lower concentration levels than set by the EU air quality standards 
for several air pollutants, most notably for particular matter, sulphur dioxide, benzene and benzo(a)pyrene (and to a lesser degree 
also for ground-level ozone) (European Commission, 2019). 

113 

 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 23) to measure specific pollutants across Europe.  

Monitoring, using common methods to assess air quality, has been a key component of the previous Air 

Quality Framework Directive and its daughter Directives, which has been carried through the current 

AAQ Directives 2004/461/EC and 2008/50/EC. Directive 2008/50/EC provides rules to assess ambient air 

quality, including how, when, and where to assess air quality. This includes provisions related to fixed 

measurements of air pollutant concentrations, and when and how it is appropriate to supplement fixed 

measurements of air pollutant concentrations with other assessment methods (i.e. modelling, objective 

estimation, indicative measurements). Directive 2008/50/EC also includes definitions of data quality 

objectives for the different methods and different air pollutants.  

In terms of fixed measurements of pollutant concentrations, the provisions include: minimum numbers 

of sampling points for each pollutant, criteria for siting of these sampling points, and the reference 

methods for assessment of pollutant concentrations. Consequently, the assessment of air quality has, 

most commonly  relied on monitoring techniques using fixed reference methods as specified in these 

Directives rather than indicative measurements or modelling. 

The AAQ Directive requires a minimum number of  monitoring sites per zone and pollutant, depending 

on its air pollution levels and population density (Annexes V and IX of the AAQ Directive). In most of the 

analysed zones, the legal provisions for  the minimum number of  monitoring sites are fulfilled. 

However, in some zones PM2.5 monitoring sites were missing. 

114 

 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 23 shows data from the total number of monitoring stations and the number of sampling points 

per pollutant as reported by Member States to the data repository Central Data Repository (CDR) for the 

year 2020. To assess the extent to which the minimum number of sampling points required by the AAQ 

Directives is achieved, it is necessary to review air pollution levels and population density (as per the 

criteria for determining the minimum sampling points in Annexes V and IX of the AAQ Directive). 

Further requirements specify the ratio between PM10 and PM2.5 monitoring sites, and between urban 

background/traffic sites (both with a ratio of between 0.5 and 2, respectively).  

Based on a sample of zones in Austria, France, Germany, Italy and Poland, an assessment (European 

Parliament, 2019) on the extent to which the minimum number of sampling points is met concluded: 

•  NO2 and PM (PM10 + PM2.5): Minimum number of sampling points achieved 

•  O3: Minimum number of sampling points achieved, except in the case of one zone (PL1201, 

Kraków) 

• 

PM2.5 and PM10 ratio: Ratio is exceeded in a number of zones 

•  Urban background/traffic site ratio: Dedicated traffic-related monitoring sites are often 

missing and the ratio of NO2 urban background to urban traffic sites is outside the prescribed 

range in several zones 

115 

 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 23 Total number of monitoring stations and number of sampling points per pollutant by Member State for  
the year 2020 (EEA, 2021)  

r
e
b
m
e
M

e
t
a
t
S

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
ES 
FI 
FR 
GR 
HR 
HU 
IE 
IS 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
Total 

s
n
o
i
t
a
t
S

177 
218 
42 
6 
183 
590 
15 
10 
596 
53 
589 
25 
22 
36 
51 
10 
631 
18 
11 
13 
5 
79 
277 
63 
145 
80 
20 
43 
4008 

0
1

M
P

5
.
2

M
P

2
O
S

2
O
N

3
O

O
C

120 
67 
40 
2 
150 
368 
7 
7 
471 
28 
378 
20 
11 
30 
39 
7 
530 
13 
5 
6 
3 
65 
242 
53 
27 
47 
18 
37 
2791 

58 
69 
10 
5 
93 
216 
10 
8 
259 
17 
194 
12 
11 
17 
36 
6 
291 
5 
4 
6 
5 
46 
124 
23 
7 
24 
6 
37 
1599 

65 
25 
28 
3 
60 
102 
2 
9 
413 
11 
111 
12 
8 
24 
10 
8 
209 
12 
3 
7 
3 
15 
103 
25 
37 
2 
5 
16 
1263 

138 
122 
25 
3 
96 
532 
13 
9 
517 
22 
409 
22 
13 
24 
21 
9 
587 
13 
8 
9 
4 
70 
142 
51 
122 
44 
12 
29 
3066 

104 
43 
21 
3 
67 
256 
7 
10 
421 
15 
316 
20 
15 
19 
18 
1 
323 
13 
6 
8 
5 
45 
102 
44 
71 
26 
8 
18 
2005 

26 
19 
18 
2 
22 
84 
6 
7 
194 
1 
21 
10 
4 
22 
5 
1 
198 
9 
3 
2 
2 
9 
69 
14 
25 
4 
3 
15 
795 

6
H
6
C

20 
32 
20 
1 
39 
104 
3 
4 
117 
3 
64 
8 
3 
14 
2 
1 
231 
2 
1 
6 
2 
6 
61 
3 
38 
2 
2 
12 
801 

0
1

M
P

n
i

b
P

11 
29 
11 
2 
59 
89 
4 
5 
123 
3 
57 
3 
2 
16 
5 
1 
131 
5 
2 
5 
3 
1 
74 
1 
30 
1 
4 
6 
683 

0
1

M
P

n
i

s
A

11 
29 
7 
2 
58 
88 
4 
5 
120 
5 
54 
2 
2 
16 
5 
1 
136 
5 
2 
5 
3 
1 
73 
1 
23 
1 
4 
6 
669 

0
1

M
P

n
i

P
a
B

32 
20 
15 
1 
53 
105 
2 
5 
99 
7 
56 
3 
3 
18 
5 
1 
161 
5 
2 
5 
1 
3 
158 
1 
4 
1 
4 
16 
786 

0
1

M
P

n
i

d
C

12 
23 
12 
2 
59 
89 
4 
5 
120 
5 
54 
3 
2 
16 
5 
1 
136 
5 
2 
5 
3 
1 
72 
1 
32 
1 
4 
6 
680 

0
1

M
P

n
i

i

N

11 
29 
7 
2 
59 
89 
4 
5 
119 
5 
55 
3 
2 
16 
5 
1 
133 
5 
2 
5 
3 
1 
72 
1 
29 
1 
4 
6 
674 

While this established monitoring network provides comparable, reliable and often real time 

information to the public a number of issues have been identified for improvement which are specific 

to monitoring (Fitness Check (European Commission, 2019) and (Conlan et al., 2022)). The AAQ 

Directive also affords flexibility regarding the  microscale criteria, which applies only “in so far as 

practicable” (and the macroscale criteria only “where feasible”). The data collected by both the 

Fitness Check and the (Conlan et al., 2022) study from stakeholder consultation indicates that the way 

certain flexibilities permitted by the Directives have been interpreted and implemented by Member 

States has hampered comparability at EU level. Assuming no change to the baseline, the inconsistency 

in the calculation of exposure and exceedance indicators would be expected to continue as would the 

limited use of Member States reporting exceedance/ exposure indicators and the application of the 

micro siting criteria. As the determination of exposure indicators is intrinsically linked to the concept of 

sampling point representativeness, this would also continue to affect the comparability of monitoring 

between Member States. 

Under the baseline scenario, requirements for monitoring of air pollutants, are assumed to remain 

identical to what is currently in place. However, over recent years there have been technological 

developments in monitoring techniques, and it is likely these will continue to develop. For example, 

some Member States use low-cost sensors, and there has been much discussion through the AQUILA49 

49 AQUILA, or the Network of Air Quality Reference Laboratories. The objectives of the Aquila network are to provide 
expert judgement, to promote the harmonisation of air quality measurements among EU, EFTA and CCs, to co-

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and FAIRMODE air quality expert communities on their merits. However, until a quality standard for 

low-cost sensors is agreed within the air quality community, uncertainty around their quality will 

remain. The use of passive diffusion tubes to supplement NO2 fixed reference monitoring has increased 

in recent years and it is assumed this is likely to continue while there remains an NO2 exceedance issue.   

Furthermore, while requirements under the AAQ Directive 2008/50/EC remain the same there is likely 

to be limited scope to adequately address the identified shortcomings across Europe. The spatial 

representativeness of sampling points, linked with the minimum number of sampling points, is likely to 

remain an issue and the comparability of air quality data may not improve. Without clarification 

regarding the ambiguities in the provisions for the microscale siting criteria, coupled with the issues 

identified for the number and distribution of monitoring stations, the extent to which the microscale 

siting criteria will ensure representative and consistent monitoring strategies for air pollutants in all 

zones will be limited. 

Driver: Modelling ability has improved, allows for much more detail 

While there is an option within the AAQ Directives to use modelling to supplement information from 

fixed sampling points, there is no obligation to do so. The Fitness Check concluded that the number of 

Member States submitting modelling results as part of the assessment documentation (under Dataflow D 

on the EIONET portal) has increased significantly in recent years (from four in 2013 to 12 in 2017) 

(European Commission, 2019). As part of the (Conlan et al., 2022) study, survey respondents reported 

that a reason for not submitting modelling results as part of the assessment documentation (despite 

having access to modelling results) is a lack of clarity on how and under which conditions modelling can 

be used to support the implementation of the Directive and air quality management practices in 

general. Added to this, the lack of technical guidance to enhance and harmonise modelling quality 

further deters Member States from submitting modelling results as part of the assessment 

documentation (Conlan et al., 2022). Depending on the purpose of the modelling application, different 

fitness-for-purpose criteria might exist. At present, current practices on the use of modelling remain 

disparate across Member States. 

Modelling has improved in recent years and under the baseline this is likely to continue. The FAIRMODE 

air quality expert community is working on a number of improvement tasks including methods for 

source apportionment, micro-scale modelling, high resolution emissions, exposure and exceedance 

indicators and robustness of air quality projections. It is expected that this work will further promote 

and support the harmonised use of models by Member States, with emphasis on model application 

under the AAQ Directives. This is somewhat likely to address the identified shortcomings of the 

Directives. However, FAIRMODE is a voluntary working group, with consensus associated with the 

production of guidance that requires discussion and time. Therefore, while it is envisaged that 

modelling will continue to be improved, the use of models within Member States is likely to remain 

variable. Consequently, modelling associated with air quality plan development is also unlikely to 

significantly improve under the baseline scenario. Table 24 sets out the number of Member States 

reporting modelling and indicative measurement data and exceedance/exposure indicator reporting. 

Little change is expected to happen in the future without changes to the underlying drivers.  

ordinate QA/QC activities, method development and validation, to participate in standardisation activities, to 
develop common research projects and pilot studies and to offer a forum for information exchange in form of 
training courses, workshops and conferences. For further information see: 
https://www.eea.europa.eu/themes/air/links/networks/aquila-network 

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Table 24 Number of Member States reporting data and likely change without intervention 

Indicator 

2020 

Likely evolution without 

intervention 

# Member States reporting indicative 

measurement data  

# Member States reporting modelled data 

# Member States reporting Ecosystem Area 

exposed 

# Member States reporting Population indicative 

measurement data 

# Member States reporting Road Length in 

exceedance 

# Member States reporting Surface Area in 

Exceedance  

*Value for 2017 

7 (3 for NO2) 

Slight increase 

12* 

6 

15 

6 

16 

Slight increase 

Static 

Static 

Static 

Static 

  Problem: Information and communication shortcomings 

The AAQ Directives include provisions on reporting and dissemination of public information enabling 

improved reporting systems. The EEA launched an upgraded air quality database available via the 

EIONET portal which follows the rules for reciprocal exchange of information and reporting on AAQ 

Directive 2004/107/EC and Directive 2008/50/EC and the rules set out in the Commission Implementing 

Decision 2011/850/EU and the Commission's guidance documents IPR Guidance Part I and IPR Guidance 

Part II. The Air Quality e-Reporting database contains current / live data on the status of air quality 

collected from the Member States and reported to the EEA (European Commission, 2019).  

The air quality data reported by Member States is made available to the public by the EEA; both in their 

original form, as well as via aggregated assessment data. Air quality information is also made available 

by national, as well as by regional and local authorities in many cases. More recently, there is also 

evidence that information is made available by private operators (e.g. AirCare (AirCare, 2022), 

AirVisual (IQAir, 2022)). The extent to which this information is comparable at EU level is limited. 

Namely owing to the fact that the AAQ Directives have not defined information and alert thresholds for 

some pollutants which has resulted in a non-harmonised approach across Member States, entailing 

extensive differences in government and/or media coverage of alarming levels of air pollution. 

Similarly, the absence of a common metric used for publicised air quality indices often means that the 

same data is presented in different ways in different locations (national air quality indices in different 

European countries are different from one another and from the European Air Quality Index in terms of 

‘bands’ and ‘thresholds’). Furthermore, it was found in the above mentioned studies that  not all air 

quality data reported is equally useful and the successful establishment of an EU-wide e-reporting 

based on machine-readable formats now allows for further efficiency gains – and opens the way for 

further up-to-date reporting of air quality data and to make further use of air quality modelling (which 

is increasingly reported, but would benefit from further guidance). 

Furthermore, the results of the Fitness Check and the (Conlan et al., 2022) study show that under the 

current legislative framework of the AAQ Directive the general public is not sufficiently informed 

regarding health impacts from air pollution. The European Court of Auditors reviewed air quality 

information made available online across six different Member States, and found that the quality and 

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availability of public information on air quality in the Member States was not always clear or useful for 

the citizens regarding the health impacts and measures to take to mitigate risks (European Court of 

Auditors, 2018).  

If the legislative framework is maintained, the general public will remain insufficiently informed 

regarding air quality/pollution and its impact on their health, or how it compares to neighbouring 

Member States. Furthermore, inefficiencies and certain administrative burdens for public authorities 

will remain in relation to reporting. Currently the roles and responsibilities of different tiers of Member 

States’ national governments are not clearly delineated and understood by public authorities.  

  Summary of the baseline 

In the absence of further changes to the AAQ Directives, other factors will continue to have an 

influence on the achievement of its objectives going forward. 

Compliance with existing air quality standards is anticipated to continue to improve. Emission policies 

(e.g., air pollutant legislation, but also climate change policies to meet new greenhouse gas emissions 

targets such as Fit for 55) and sector specific policies (e.g. vehicle emissions standards, efficiency 

standards and emission limits for residential heating installations) will continue to place downward 

pressure on emissions. In addition, Member States may also continue to take action to work towards 

compliance with the existing EU and national legislation and developments in non-EU countries will 

impact on transboundary pollution. However, there are drivers of change that would be expected to 

increase emissions of air pollutants, which will contrast against emission and sectoral policies 

(regulating emissions at source). For example, demographic changes and higher incomes (that may 

otherwise lead to an increase in activities resulting in higher air pollutant emissions, e.g., consumption, 

fuel use, vehicle ownership, etc.) will likely continue to place an upward pressure on emissions.  

From the detailed modelling, as presented in further detail in section 7.1.2 above, overall, current 

policies will result in a continued decline in emissions of key air pollutants. Compared to 2015, 

emissions of PM2.5, NOx, and SO2 are estimated to drop by 50 to 70% to 2030, NMOVC by 25%, while for 

ammonia (NH3) only about 5% reduction is calculated by 2030. The trends are expected to continue 

towards 2050 but with much smaller further reductions. This reduction in emissions translates into 

improvements in air pollutant concentrations to 2030 and 2050. For instance, much lower numbers of 

people are expected to be exposed to PM2.5 concentrations above the current WHO recommendation by 

2030 and 2050. However, it is unlikely that compliance with WHO recommended (and even existing) air 

quality standards will be achieved in all places up to 2050.  

Meanwhile it is likely that the underlying scientific evidence base linking air pollution to environment 

and health impacts will continue to be strengthened. Likewise technological solutions will continue to 

progress, with more effective air pollution mitigation measures likely becoming available or more cost-

effective over time. 

With respect to issues around AQ governance and monitoring, as experience and knowledge associated 

with the implementation of air quality plans grows, there may be some sharing of best practice and 

learning across local, regional, national authorities and between Member States. This will happen to the 

extent that it is encouraged, practices are transparent and the mechanisms exist to facilitate 

information sharing. Furthermore, where there is public awareness around air quality issues, there may 

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be pressure placed on authorities to improve practices. However, without legislative change, such 

progress is not guaranteed. Comprehensive progress across all Member States would be even less likely. 

Furthermore, progress is not guaranteed to comprehensively address the various issues identified 

around governance and monitoring to date, namely that: penalties are insufficient and citizens do not 

have access to justice, plans and the measures contained in them, are ineffective or disproportionate, 

and stakeholders are not appropriately engaged in the development of plans. As such, it is highly likely 

that a subset of Air Quality Plans are likely to continue to fail to deliver compliance in the shortest time 

possible. With respect to access to justice, where further cases for compensation are brought to court, 

this could build up case law at a national level50. However, comprehensive and consistent access for all 

EU citizens is not guaranteed.  

External (regional or transboundary) pollution sources will continue to be a key factor resulting in some 

localised exceedances(external sources are critical in many cases, but not all). This issue may increase 

with the general drive to lower levels of concentrations overall (background becomes higher proportion 

of overall concentrations). In some cases, emitters of ‘external’ pollution may engage in the 

formulation of Air Quality Plans (e.g. where there is public awareness of an issue, and/or where this fits 

with industry desires, e.g. CSR schemes). But there is no guarantee that this will take place 

comprehensively across all Member States and all exceedances, nor that any engagement will follow 

best practice (such as relevant stakeholders being engaged at the right time, in the right way and 

regarding the right issues) and be effective to assist the quality of the Air Quality Plan. 

Over recent years there have been technological developments in monitoring techniques, which are 

likely to continue. E.g. some Member States are using low-cost sensors and passive diffusion tubes. 

Modelling has also improved in recent years and under the baseline this is likely to continue. The 

FAIRMODE air quality expert communities are working on a number of improvement tasks including 

methods for source apportionment, micro-scale modelling and high resolution emissions. It is expected 

that this work will further promote and support the harmonised use of models. As better practices 

become normalised, the cost of adopting these practices should also decrease. 

Interest and attention amongst citizens regarding air pollution is particularly high at present which 

could drive authorities to respond to the issue at local level, increasing the disparities between regions 

and Member States. With increasing focus, more activities and information might be brought forward by 

business organisations, environmental organisations or non-governmental organisations (e.g. mobile 

device applications, advice services). However, where information is disseminated by third parties or 

authorities, this will likely continue to differ in terms of the presentation, messaging, content, 

underpinning evidence base and advice provided. 

The following table presents a summary of the baseline, which forms the reference benchmark against 

which the analysis of interventions in the remaining sections of this report is performed.  

50 For example, see the recent C-286/21 PM10 case in France. Compensation is addressed in the preliminary reference case C-61/21 
for which the AG opinion has been delivered, but not yet the CJEU ruling. 

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Table 25– Summary of the baseline 

Problem  

Assumptions on whether / how this problem persists 

(I) Environment and health 
shortcomings  
are likely to persist (even if 
some further air quality 
improvements can be expected 
as air emissions decrease) 

(II) Governance and 
enforcement shortcomings  
are very likely to persist, leading 
to continued persistent air 
quality exceedance situations  

(III) Monitoring and assessment 
shortcomings  
are likely to persist (at least 
partially), even if some aspects 
of this can be addressed by non-
legislative measures  

(IV) Information and 
communication shortcomings  
are likely to persist (at least 
partially), even if some aspects 
of this can be addressed by non-
legislative measures 

•  Further reduction in air pollutant concentrations will lead to continued 
reduced exposure to air pollution and reductions in health burden. 
•  However, EU air quality standards remain significantly above WHO 

recommendations, resulting in health (and environmental) challenges. 
•  Without updated EU air quality standards (and associated requirement to 
take action when there are exceedances) there is little incentive to act. 

•  As scientific understanding of health impacts of air pollution is further 
updated, EU air quality standards may need corresponding updates. 

•  Continued (limited) air quality improvement in air quality will reduce 
pressure on Member States to act (despite continued health impacts). 
Low level of coordination when designing and implementing air quality 
plans between different levels of governance hampers additional action. 

• 

•  Air quality plans and measures contained therein are not reviewed, nor 
updated for changing context, even if plans are deemed insufficient. 

•  Member States continue to interpret EU rules differently leading to 

different approaches to implementation and limited enforcement action. 

•  While air quality monitoring and assessment continues to deliver a 
generally sound basis for policy action, but inconsistencies remain. 
•  Without further guidance or legislation, there remains an incentive to 
stretch monitoring rules in order to avoid monitoring all exceedances. 
Spatial representativeness of sampling points is likely to remain an issue 
hampering the reliability and comparability of air quality assessments. 

• 

•  The use of models is likely to remain variable, and modelling associated 

with air quality plan development is not used to its full potential. 

•  A wealth of information on current air quality, and the health and 

environment impacts of air pollution, is collected and made available. 
•  Accessibility of information on air quality will continue to improve, but 

authorities are not expected to go beyond the mandatory requirements.  
•  There is a risk of continued lack of comparability of air quality data and 
health assessments (especially when disseminated by third parties). 

•  General public (and vulnerable populations) will continue to feel 

insufficiently informed regarding air quality and its impact on health. 

Intervention areas and long-list of interventions  

As set out in Section 3, the revision of the Directives is considering multiple, connected problems and 

drivers. To better consider the linkages between the problems and drivers, three Policy Areas were 

defined in the Intervention Logic: 

• 

• 

Policy Area 1: a closer alignment of the EU air quality standards with scientific knowledge 

including the latest recommendations of the World Health Organization (WHO) 

Policy Area 2: improving the air quality legislative framework, including provisions on penalties 

and public information, in order to enhance effectiveness, efficiency and coherence 

• 

Policy Area 3: strengthening of air quality monitoring, modelling and plans. 

Under each Policy Area, long-lists of interventions were identified to tackle the problems and drivers. 
These interventions were defined based on: (a) the Fitness Check; (b) the feedback provided by 
stakeholders to the Inception Impact Assessment, including the AQUILA and FAIRMODE air quality expert 
communities; (c) the expertise of the project team, (d) input from the parallel study ‘Strengthening of 
air quality monitoring, modelling and plans under the Ambient Air Quality Directives’ and (e) the 
literature review. Where several interventions address a common theme or driver, interventions have 
been grouped into 27 Intervention Areas. The 27 Intervention Areas are presented in  

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Figure 55 below. 

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Figure 55 – List of intervention areas and mapping to current AAQ Directives Articles and Annexes 

Policy 

Intervention 

Area 

area 

Intervention area name 

Mapping to 

Mapping to 

Directive 

2004/107 

Directive 

2008/50 

How to ensure the timely adjustment of 

EU air quality standards to evolving 

8 

32 

scientific or technological knowledge? 

Which types of air quality standards or 

2, 3 

A 

B 

C 

D 

combination thereof are appropriate? 

What action should be mandated in case 

air quality standards are not respected? 

Who should be involved in the 

preparation of air quality plans, and how 

should their preparation and 

implementation be coordinated? 

How to assess and address transboundary 

M 

air pollution in local/regional air quality 

E 

F 

G 

management? 

What legal tools should be available to 

address breaches of the obligations? 

How to best inform the public on air 

quality? 

How to improve air quality assessment 

regimes, including the scope to combine 

monitoring, modelling and other 

assessment methods? 

How to improve the minimum number 

2, 12-16 

Annex II 

17, 18, 19, 23,  

24 

23 

Annex XV 

20-21 

30 

26, 27 

Annex XII 

5-11 

Annex II 

3 

9 

7 

4 

H 

and type of sampling points required for 

Annex III, V, VIII 

I 

J 

K 

L 

N 

O 

P 

measuring air pollution concentrations? 

How to ensure continuity in the 

monitoring of air quality? 

How to ensure the reliable micro and 

macroscale siting of monitoring stations? 

Which requirements on data quality are 

needed to assess and report air quality? 

Which additional air pollutants should be 

Annex V 

Annex III 

Annex I 

measured and to what extent should 

Annex III, V, X 

monitoring requirements be expanded? 

Which minimum information should be 

included in an air quality plan? 

EU air quality standards for particulate 

matter (PM2.5) 

EU air quality standards for particulate 

matter (PM10) 

123 

Annex XV 

Annex XIV 

Annex XI 

2 

2 

2 

2 

3 

2 

2 

3 

3 

3 

3 

3 

3 

3 

1 

1 

 
 
 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Policy 

Intervention 

Area 

area 

Intervention area name 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

Q 

R 

S 

T 

U 

V 

W 

X 

Y 

Z 

Ø 

EU air quality standards for nitrogen 

dioxide (NO2) 

EU air quality standards for ozone (O3) 

EU air quality standards for sulphur 

dioxide (SO2) 

EU air quality standards for carbon 

monoxide (CO) 

EU air quality standards for benzene 

EU air quality standards for 

benzo(a)pyrene (BaP) 

EU air quality standards for lead (Pb) 

EU air quality standards for arsenic (As) 

EU air quality standards for cadmium (Cd) 

EU air quality standards for nickel (Ni) 

EU air quality standards for pollutants of 

emerging concern 

Mapping to 

Mapping to 

Directive 

2008/50 

Annex XI 

Annex VII 

Annex XI, XII, 

XIII 

Annex XI 

Annex XI 

Annex XI 

Directive 

2004/107 

Annex I 

Annex I 

Annex I 

Annex I 

N/A 

In total, 69 interventions were identified and considered as part of the Impact Assessment study: 22 in 

Policy Area 1 (further assessed in groups of 7 scenarios), 27 in Policy Area 2 and 20 in Policy Area 3. 

These are listed in the tables below. 

Table 26 – Interventions under Policy Area 2 (i.e. the legal framework) 

Improving the air quality legislative framework, including provisions on penalties and public information 

Intervention area A: How to ensure the timely adjustment of EU air quality standards to evolving scientific or 
technological knowledge?  

• 

• 

• 

• 

(A1) Introduce a mechanism for adjusting EU air quality standards upon publication of new scientific advice 
(including, but not limited to, the publication of new WHO guidelines).  

(A2) Introduce a mechanism for adjusting EU air quality standards based on technical progress in air 
pollution reduction. 

(A3) Introduce a provision to allow for EU Member States to adopt more stringent standards in light of the 
new technical and scientific progress coupled with an obligation to notify the European Commission. 

(A4) Keep and periodically update a list of priority air pollutants to ensure air pollutants of emerging 
concern are monitored. 

Intervention area B: Which types of air quality standards or combination thereof are appropriate? 

• 

• 

• 

• 

• 

(B1) Establish short-term EU air quality standards (daily or hourly) for additional air pollutants that currently 
only have annual or seasonal standards e.g. PM2.5. 

(B2) Define alert thresholds and information thresholds for all air pollutants as triggers for alerting the 
public and taking short-term action. 

(B3) Expand the application of the exposure reduction targets (relative reduction in exposure).  

(B4) Provide guidance on the provisions concerning types of EU air quality standards and on the action to be 
taken in case of exceedance of different types of standards. 

(B5) Establish limit values for additional air pollutants (i.e. for air pollutants currently subject to target 
values).  

Intervention area C: What action should be mandated in case air quality standards are not respected? 

• 

(C1) Further specify the obligation to take measures to keep exceedance periods as short as possible. 

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• 

• 

• 

• 

(C2) Reformulate the term “as short as possible” with a defined time period. 

(C3) Require a clearer coordination between short-term action plans and air quality plans. 

(C4) Introduce an obligation for effective short-term action plans for each pollutant to prevent / tackle air 
pollution events. 

(C5) Mandate regular updates of air quality plans. 

Intervention area D: Who should be involved in the preparation of air quality plans, and how should their 
preparation and implementation be coordinated?  

• 

• 

(D1) Establish a requirement for Member States to involve specific actors in air quality plan development and 
to specify coordination arrangements for the development and implementation of air quality plans. 

(D2) Introduce a requirement for Member States harmonise air quality plans and air quality zones (and 
require a ‘one zone, one plan’ approach). 

Intervention area M51: How to assess and address transboundary air pollution in local/regional air quality 
management?  

• 

• 

(M1) Require the use of an agreed methodology when assessing transboundary air pollution/contributions to 
local/regional air pollution. 

(M2) Require transboundary cooperation and joint action on air quality if assessments of transboundary air 
pollution/contributions above certain thresholds (to be defined) 

Intervention area E: What legal tools should be available to address breaches of the obligations? 

• 

• 

• 

• 

(E1) Introduce minimum levels for financial penalties. 

(E2) Introduce specific provisions that guarantee a right to compensation for damage to health. 

(E3) Set up a fund to be fed by the payment of penalties and which can be used to compensate material 
damage or finance air quality measures. 

(E4) Introduce an explicit ‘access to justice’ clause in the Ambient Air Quality Directives. 

Intervention area F: How to best inform the public on air quality? 

• 

• 

• 

(F1) Introduce more specific requirements to ensure regular reporting of up–to–date data / information 
(instead of allowing Member States to report data as available). 

(F2) Require Member States to provide specific health / and health protection information to public as soon 
as exceedances occur. 

(F3) Mandate specific communication channels with citizens, including user-friendly tools for public access 
to air quality and health risks information and monitoring to use (for example, smartphone apps and/or 
social media dedicated pages). 

• 

(F4) Require Member States to use harmonised air quality index bands. 

Other: 

• 

Merge provision of Directives 2008/50 and 2004/107 

Table 27– Interventions under Policy Area 3 (i.e. air quality monitoring, modelling and plans) 

Intervention area G: How to improve air quality assessment regimes, including the scope to combine monitoring, 
modelling and other assessment methods? 

• 

• 

• 

(G1) Allow / continue to allow the use of indicative monitoring to substitute fixed monitoring as part of air 
quality assessment.  

(G2) Make the use of air quality modelling mandatory as part of air quality assessment (in some 
circumstances). 

(G3) Require a regular review of the assessment regime following clear criteria defined in the Directive. 

Intervention area H: How to improve the minimum number and type of sampling points required for measuring air 
pollution concentrations? 

• 

• 

(H1) Change the minimum number of sampling points that are required per air quality zone.  

(H2) The minimum number of sampling points for measuring PM10 and PM2.5 will be considered 
independently from each other.  

51 Intervention area M falls between D and E as originally this sat as part of Policy Area 3, but was moved during the 
course of the study to sit under Policy Area 2, but the original naming convention was retained. 

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

• 

(H3) Simplify the definitions of types of monitoring station and/or sampling point locations - and only 
differentiate for them to distinguish between hotspots or background concentrations. 

Intervention area I: How to ensure continuity in the monitoring of air quality? 

• 

• 

• 

(I1) Specify that sampling points with exceedances of limit values for any of the pollutants measured under 
the Ambient Air Quality Directives should be maintained for a defined number of years.  

(I2) Include the requirement to monitor long-term trends if fixed monitoring stations are discontinued (by 
assessing air quality via indicative measurements or air quality modelling). 

(I3) Establish a protocol to follow should a sampling point have to be re-located due to, for example, 
infrastructure development or changes in the assessment regimes. 

Intervention area J: How to ensure the reliable micro and macroscale siting of monitoring stations? 

• 

• 

• 

(J1) Further clarify (and reduce flexibilities related to) the macro-siting criteria for sampling points.  

(J2) Further clarify (and reduce flexibilities related to) the micro-siting criteria for sampling points.  

(J3) Introduce the concept of a spatial representative area which should be estimated (and reported) for 
each sampling point (irrespective of exceedances being measured or not). 

Intervention area K: Which requirements on data quality are needed to assess and report air quality? 

• 

• 

• 

• 

(K1) Further define the data quality requirements for sampling points / measurements used for air quality 
assessments.  

(K2) Make it mandatory to provide up-to-date information on the pollutant concentration for certain air 
pollutants for a minimum number of sampling points per air quality zone.  

(K3) Introduce a standardized ‘modelling quality objective’ as a quality control mechanism to assess whether 
a modelling based assessment is fit-for-purpose. 

(K4) Modify the definition of measurement uncertainty by defining it in absolute values and not in 
percentage values (or a combination of both). 

Intervention area L: Which additional air pollutants should be measured and to what extent should monitoring 
requirements be expanded? 

• 

• 

• 

(L1) Require monitoring stations that measure continuously certain emerging air pollutants (e.g. called 
“supersites” across the Member States).  

(L2) Require monitoring of additional air pollutants at a minimum number of sampling points and with 
relevant data quality requirements.  

(L3) Expand the list of required and/or recommended volatile organic compounds (VOCs) to measure. 

Intervention area N: Which minimum information should be included in an air quality plan? 

• 

(N1) Refine the minimum information to be included in an air quality plan. 

Table 28– Interventions under Policy Area 1 (i.e. air quality standards for specific pollutants) 

Closer alignment of the EU air quality standards with scientific knowledge including the latest recommendations 
of the World Health Organization (WHO) 

Intervention area O: EU air quality standards for particulate matter (PM2.5) 

• 

• 

• 

(O1) Revise long-term (annual) air quality standards 

(O2) Introduce short-term air quality standards and/or alert/information thresholds 

(O3) Revise average exposure obligations and reduction targets 

Intervention area P: EU air quality standards for particulate matter (PM10) 

• 

• 

• 

(P1) Revise long-term (annual) air quality standards 

(P2) Revise short-term air quality standards and/or alert/information thresholds 

(P3) Introduce average exposure obligations and reduction targets 

Intervention area Q: EU air quality standards for nitrogen dioxide (NO2) 

• 

• 

• 

(Q1) Revise long-term (annual) air quality standards 

(Q2) Revise short-term air quality standards and/or alert/information thresholds 

(Q3) Introduce average exposure obligations and reduction targets 

Intervention area R: EU air quality standards for ozone (O3) 

• 

(R1) Revise long-term (peak-season) air quality standards 

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• 

• 

(R2) Revise short-term air quality standards and/or alert/information thresholds 

(R3) Introduce average exposure obligations and reduction targets 

Intervention area S: EU air quality standards for sulphur dioxide (SO2) 

• 

• 

(S1) Revise long-term (annual) air quality standards 

(S2) Revise short-term air quality standards and/or alert/information thresholds 

Intervention area T: EU air quality standards for carbon monoxide (CO) 

• 

(T1) Revise short-term air quality standards 

Intervention area U: EU air quality standards for benzene  

• 

(U1) Revise long-term (annual) air quality standards 

Intervention area V: EU air quality standards for benzo(a)pyrene (BaP) 

• 

(V1) Revise long-term (annual) air quality standards 

Intervention area W: EU air quality standards for lead (Pb) 

• 

(W1) Revise long-term (annual) air quality standards 

Intervention area X: EU air quality standards for arsenic (As) 

• 

(X1) Revise long-term (annual) air quality standards 

Intervention area Y: EU air quality standards for cadmium (Cd) 

• 

(Y1) Revise long-term (annual) air quality standards 

Intervention area Z: EU air quality standards for nickel (Ni) 

• 

(Z1) Revise long-term (annual) air quality standards 

Intervention area Ø: EU air quality standards for pollutants of emerging concern 

• 

(Ø1) Introduce air quality standards for additional pollutants 

 Assessment and constructing illustrative policy options 

As described in Section 6, all 69 interventions across the 27 Intervention Areas have been assessed 

based on their effectiveness, efficiency and coherence and have been scored against the 12 indicators. 

The detail of the analysis is set out in the Assessment Sheets presented in the Appendix, and 

summarised in Section 9. The appraisal of the interventions under Policy Area 1 also draws on the more 

detailed quantitative modelling, the results of which are set out in Section 8.  

Underneath the interventions, different variants are possible. These variants have been considered in 

the analysis, in particular where and how the scoring may change depending on the variant. 

Following the assessment, the interventions have then been grouped into illustrative policy packages, 

combining interventions across Intervention and Policy Areas. The first stage in policy option analysis 

was to construct a number of illustrative packages. These are combined and assessed in order to 

explore the interactions, linkages and dependencies between interventions in different Intervention 

and Policy areas, but do not necessarily include the final, preferred package for implementation.  

For the interventions in Policy Area 1, the illustrative Policy Packages directly reflect potential EU 

standards suggested for either 2030 or 2050, respectively – for each of the 12 air pollutants. This 

corresponds to 13 different possible intervention areas, i.e. one per pollutant + 1 for ‘new’ pollutants. 

Our analysis looked at combinations of these standards in 7 sets of standards (or scenarios), each of 

which reflected a combination of standards for all pollutants for 2030 or 2050 respectively (4 levels of 

ambition for 2030, 3 for 2050).  

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For interventions under Policy Areas 2 and 3, identifying which can be grouped into high, medium and 

low ambition packages is broadly based on the value to be derived from the intervention, taking 

account of the costs and benefits but also the linkages and interactions between interventions across 

Policy Area.  

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8  Results of quantitative analysis to support 

revision to air quality standards  

  Environmental impacts 

Impacts on air pollution emissions (Indicator #1) 

As discussed in Section 6, under baseline scenario assumptions, emissions are expected to decline for 

all air pollutants, however, for ammonia the change is only expected to be marginal. Implementation of 

all technical measures (excluding any further structural, transformational measures, e.g., driven by 

lifestyle changes) defined in the GAINS model could reduce emissions further and doing so identifies 

scope for further strengthening emission limit values, introducing new legislation or accelerating wide 

application of proven but not yet widespread measures - this is illustrated in the maximum feasible 

reduction (MTFR) case. 

Figure 56 shows the baseline and MTFR emissions, as well as the emission reductions necessary 

compared to the baseline (from the cost optimal point of view – see Appendix 3) to achieve the policy 

targets (to the extent they are achievable within the scope for mitigation identified in the GAINS 

model)  of 20, 15, 10 and to 5 µg/m3, respectively, for annual mean ambient PM2.5 concentrations for 

2030 and 2050.  

The preliminary analysis (using the concentration modelling functionality in GAINS, i.e. prior to the 

more detailed concentration modelling exercise deploying EMEP) indicates that achieving the 20 and 15 

ug/m3 targets for PM2.5 by 2030 or 2050 appears to be feasible and does not require significant 

additional emission reduction at the EU-27 level, compared to the baseline scenario trajectory, which 

already includes Fit-for-55 policy developments resulting in significant GHG reductions that support 

strong reduction of air pollutant emissions associated with reduced fossil fuel use. Achieving these 

targets would also not require significant reductions in emissions of individual Member States - several 

countries could stay at the baseline level while some are estimated to only need to moderately reduce 

their emissions.  

The picture changes when more stringent targets of 10 ug/m3 and then 5 ug/m3 are applied, for the 

latter the emissions are nearly at the MTFR level and there are several grids (regions) where such 

concentrations cannot be achieved. As was indicated in Section 6.2, the more stringent targets cannot 

be reached in all grid cells, even in the MTFR scenario, i.e., for the 5 ug/m3 case, in about 40% of all 

EU27 grids such concentrations are not achievable according to GAINS calculations (see more details 

about target setting in Appendix 3). For both targets the emission reductions are large at the EU level 

(Figure 56) and also for individual Member States. 

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Figure 56 Emission trajectories for key air pollutants in the baseline, policy, and MTFR scenarios. EU-27; GAINS 
model  

Notes: Figure shows the baseline and MTFR emissions (red bars) and emission reductions calculated for the respective policy targets 

(blue bars); note the text above (and Appendix 3) about the feasibility of the more ambitious targets. 

Key sectors where major emission reductions are achieved in the cost-optimal scenarios where the 10 

and 5 ug/m3 targets are set are: industry, agriculture (NH3) and residential heating (PM2.5). Reduction of 

industrial emissions (both combustion and processes) is relevant for several pollutants. For residential 

heating, PM2.5 emissions can be reduced by addressing biomass combustion for residential hearing, since 

the role of coal is declining and abatement potential around coal becomes less and less relevant 

(assuming effective implementation of the climate related targets for reduction of reliance on, and use 

of, fossil fuels). 

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Figure 57 – Emission trajectories for key air pollutants, and by key sector, in the baseline, policy, and MTFR 
scenarios. EU-27; GAINS model 

Emissions of air pollutants under the different policy scenarios in 2030 are given in Table 29 to Table 

33, under scenarios in 2050 in Table 34 to Table 38  

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Table 29 - Emissions of SO2 for different policy scenarios in 2030. Units: kilotons/yr 

Member State 

Baseline 

Target 

Target 

Target 

Target  

20ug/m3 

15ug/m3 

10ug/m3 

5ug/m3 

MTFR 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

EU-27 

8 

31 

41 

6 

2 

27 

9 

5 

21 

76 

139 

24 

7 

6 

66 

3 

10 

1 

1 

15 

137 

20 

35 

11 

3 

82 

13 

8 

31 

41 

6 

2 

27 

9 

5 

21 

76 

121 

24 

7 

6 

36 

3 

10 

1 

1 

15 

137 

20 

34 

11 

3 

82 

13 

8 

17 

19 

3 

2 

16 

8 

2 

13 

64 

89 

10 

5 

6 

33 

3 

5 

1 

1 

12 

77 

20 

12 

5 

2 

82 

13 

8 

17 

19 

3 

0 

14 

8 

2 

14 

54 

80 

10 

5 

5 

33 

3 

5 

1 

1 

12 

77 

10 

12 

5 

2 

33 

13 

7 

15 

19 

3 

0 

14 

7 

2 

12 

54 

77 

10 

5 

2 

33 

2 

5 

1 

1 

11 

77 

9 

12 

5 

2 

33 

13 

7 

15 

19 

3 

0 

14 

7 

2 

11 

54 

76 

10 

5 

2 

33 

2 

5 

0 

1 

11 

77 

9 

12 

5 

2 

33 

13 

799 

748 

526 

444 

431 

427 

The following figure shows an illustration of the tabulated Member State results highlighting additional 

mitigation effort beyond the baseline. The additional mitigation efforts are split into sectoral 

contributions at an aggregated level (more detailed sector/measure allocation are provided in  

Appendix 3). For SO2, key additional reductions are achieved in the power sector and industry (see 

Appendix 3 for more details). In the OPT20 case, additional mitigation is only estimated to be required 

for a few countries, predominantly Italy where additional mitigation is necessary, including for other 

precursors of PM2.5. The level of additional mitigation required increases in OPT15 towards OPT5, but 

between OPT10 and OPT5 cases there is not a lot of additional reduction as most of the potential is 

already achieved  in the OPT10 case (compared to the MTFR levels). In general, the mitigation potential 

is not large in absolute terms as current legislation is expected to effectively reduce SO2 emissions 

compared to current levels.  

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Figure 58 - Emissions reduction of SO2 for different policy scenarios in 2030, split by MS. Units: kilotons/yr 

133 

 
 
 
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Table 30. Emissions of NOX as calculated from GAINS under different policy scenarios in 2030. Units: kilotons/yr 

Member 

State 

Baseline 

Target 

Target 

Target 

Target  

20ug/m3 

15ug/m3 

10ug/m3 

5ug/m3 

MTFR 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

EU-27 

62 

92 

67 

26 

6 

97 

63 

13 

73 

379 

473 

89 

66 

58 

290 

25 

32 

8 

2 

116 

303 

75 

127 

38 

17 

327 

53 

60 

92 

66 

25 

6 

95 

63 

13 

72 

375 

454 

89 

65 

58 

248 

25 

32 

8 

2 

116 

289 

75 

125 

38 

15 

326 

53 

54 

84 

55 

20 

6 

73 

58 

13 

66 

370 

405 

74 

51 

58 

247 

24 

26 

8 

2 

103 

225 

75 

102 

26 

15 

326 

49 

55 

84 

55 

19 

4 

74 

58 

13 

68 

358 

408 

77 

53 

58 

241 

24 

26 

8 

2 

103 

232 

72 

102 

26 

16 

265 

49 

51 

78 

55 

18 

4 

73 

55 

12 

62 

346 

396 

76 

57 

52 

241 

21 

26 

8 

2 

95 

244 

59 

102 

29 

15 

260 

47 

2978 

2886 

2616 

2549 

2485 

48 

76 

52 

16 

4 

64 

52 

10 

52 

331 

383 

73 

50 

48 

236 

20 

25 

5 

2 

90 

209 

52 

93 

23 

14 

238 

43 

2309 

As for SO2, the following figure shows illustration of the tabulated Member State results highlighting 

additional mitigation effort required beyond the Baseline for NOx. More detailed sector/measure 

allocation is provided in Appendix 3. Key additional reductions, although rather small in absolute terms 

compared to current levels, are achieved in industry and non-road machinery (see Appendix 3 for more 

details). Similarly to SO2, the level of additional mitigation increases from the OPT15 case with only 

small additional reductions when moving from the OPT10 to OPT5 targets; as discussed earlier and in 

Appendix 3, the limited mitigation potential constrains the achievement of targets for large areas, 

especially in the OPT5 case.  

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Figure 59 - Emissions reductions of NOX as calculated from GAINS under different policy scenarios in 2030, split 
by MS. Units: kilotons/yr 

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Table 31. Emissions of NH3 as calculated from GAINS for different policy scenarios in 2030. Units: kilotons/yr 

Member State 

Baseline 

Target 

Target 

Target 

20ug/m3 

15ug/m3 

10ug/m3 

Target  

5ug/m3 

MTFR 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

EU-27 

65 

69 

44 

37 

8 

94 

67 

12 

31 

577 

550 

56 

74 

124 

336 

17 

44 

6 

1 

123 

287 

51 

166 

25 

17 

461 

50 

61 

69 

42 

37 

8 

90 

67 

12 

31 

576 

533 

54 

73 

124 

254 

17 

41 

6 

1 

122 

281 

50 

159 

23 

14 

447 

50 

51 

69 

33 

23 

8 

68 

62 

12 

31 

559 

398 

43 

47 

124 

253 

17 

29 

6 

1 

120 

166 

50 

118 

15 

13 

447 

50 

51 

61 

32 

19 

6 

68 

62 

12 

31 

463 

417 

44 

48 

123 

249 

17 

29 

6 

1 

119 

166 

50 

111 

15 

15 

290 

50 

41 

51 

32 

21 

6 

68 

55 

9 

23 

431 

339 

44 

48 

115 

251 

14 

31 

4 

1 

117 

172 

36 

113 

15 

12 

282 

38 

39 

51 

30 

19 

6 

66 

52 

9 

22 

411 

331 

43 

47 

97 

244 

13 

29 

4 

1 

117 

165 

33 

108 

15 

11 

252 

36 

3392 

3239 

2811 

2554 

2369 

2252 

The following figure illustrates the additional mitigation effort required beyond the Baseline for NH3 for 

the tabulated Member States . More detailed sector/measure allocation is provided in Appendix 3. Key 

additional reductions are achieved in agriculture (a key NH3 source) to address mineral nitrogen 

application and improve storage and application of livestock manures on land (see Appendix 3 for more 

details). Since NH3 still offers significant mitigation potential, there is a steady increase in mitigation 

effort beyond the baseline that is fairly equally distributed across Member States in the OPT10 and 

especially OPT5 case, which is approaching the maximum possible reductions achievable with technical 

measures (MTFR) although it is still not possible to attain the targets in a large number of grid-cells, 

especially under the OPT5 case (see Appendix 3 for more details about grid-cell based target setting).  

136 

 
 
 
 
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Figure 60 - Emissions reductions of NH3 as calculated from GAINS under different policy scenarios in 2030, split 
by MS. Units: kilotons/yr 

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Table 32. Emissions of VOC as calculated from GAINS for different policy scenarios in 2030. Units: kilotons/yr 

Member State 

Baseline 

Target 

Target 

Target 

20ug/m3 

15ug/m3 

10ug/m3 

Target  

5ug/m3 

MTFR 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

EU-27 

56 

75 

50 

37 

6 

117 

53 

12 

44 

496 

687 

96 

65 

49 

613 

22 

25 

7 

2 

139 

362 

89 

119 

69 

23 

425 

84 

3822 

54 

74 

43 

32 

5 

111 

52 

11 

42 

489 

661 

95 

64 

47 

529 

21 

23 

7 

2 

138 

336 

85 

99 

66 

17 

52 

74 

41 

28 

5 

104 

52 

11 

41 

486 

604 

75 

42 

47 

518 

19 

20 

7 

2 

137 

317 

85 

92 

60 

21 

49 

72 

39 

18 

5 

94 

52 

11 

41 

439 

568 

72 

44 

47 

467 

19 

20 

7 

2 

137 

303 

81 

94 

60 

17 

46 

67 

38 

18 

5 

92 

50 

11 

39 

448 

564 

72 

45 

47 

474 

18 

20 

7 

2 

129 

303 

78 

94 

59 

16 

39 

60 

31 

17 

4 

75 

34 

8 

31 

382 

445 

65 

35 

33 

456 

11 

14 

5 

2 

108 

257 

65 

76 

43 

13 

418 

82 

3602 

418 

82 

3440 

328 

82 

3166 

342 

76 

3161 

295 

68 

2670 

The following figure shows illustrates the additional mitigation effort required beyond the Baseline for 

NMVOC for the tabulated Member States More detailed sector/measure allocation is provided in 

Appendix 3. Key additional reductions are achieved in solvent use (included in ‘Other’ in the figure 

below) and the residential sector through accelerated implementation of cleaner biomass burning 

technologies for residential heating (see Appendix 3 for more details). Since NMVOC emissions are not a 

major PM2.5 precursor, the additional mitigation is not as widespread as for other precursors. Owing to 

the fact that the cost-effective solutions, aiming to achieve the set policy targets, are always sought 

from the baseline case, there is a possibility that more ambitious reductions are calculated for a single 

country in less ambitious policy cases than for the next more ambitious target, e.g., see Slovenia. This 

is because of the transboundary pollution impact, typically, due to emission reductions in neighbouring, 

often large, countries that are needed to attain their own targets. However, more stringent policy 

targets (e.g., OPT10, OPT5) will require further measures to be implemented locally, resulting in 

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increasing mitigation efforts as shown below for the case of Slovenia (see also Section 8.1.2 and 

Appendix 3 for detailed discussion of target setting).  

Figure 61 - Emissions reductions of VOC as calculated from GAINS under different policy scenarios in 2030, split 
by MS. Units: kilotons/yr 

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Table 33. Emissions of PM2.5 as calculated from GAINS for different policy scenarios in 2030. Units: kilotons/yr 

Member State 

Baseline 

Target 

Target 

Target 

20ug/m3 

15ug/m3 

10ug/m3 

Target  

5ug/m3 

MTFR 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

EU-27 

10 

13 

18 

10 

1 

16 

11 

2 

12 

99 

69 

22 

30 

6 

73 

7 

7 

1 

0 

14 

75 

26 

43 

9 

9 

87 

15 

10 

13 

12 

10 

1 

15 

11 

2 

11 

97 

68 

22 

30 

6 

58 

7 

7 

1 

0 

13 

70 

26 

27 

9 

5 

87 

14 

8 

13 

12 

6 

1 

14 

10 

2 

11 

92 

64 

15 

12 

6 

56 

5 

4 

1 

0 

13 

51 

26 

23 

6 

9 

87 

14 

8 

12 

9 

4 

1 

14 

10 

2 

11 

72 

64 

15 

13 

6 

56 

5 

4 

1 

0 

13 

51 

18 

24 

6 

5 

40 

14 

7 

10 

8 

5 

1 

13 

8 

2 

10 

72 

60 

15 

13 

6 

56 

4 

4 

1 

0 

12 

52 

12 

24 

5 

4 

40 

13 

6 

10 

8 

4 

0 

12 

8 

1 

9 

69 

58 

15 

12 

5 

55 

3 

4 

1 

0 

12 

49 

11 

22 

5 

3 

39 

13 

686 

634 

561 

478 

455 

435 

The following figure shows illustrates the additional mitigation effort required beyond the Baseline for 

PM2.5 for the tabulated Member States More detailed sector/measure allocation is provided in Appendix 

3. Key additional reductions are achieved in the residential sector through the accelerated 

implementation of cleaner biomass burning technologies as well as agriculture measures (the effective 

banning of open burning of agricultural residues) and, in some cases, industrial processes (see Appendix 

3 for more details). For some Member States, the additional mitigation is estimated already for the 

OPT20 case, e.g., Italy, Romania, Bulgaria, Slovenia, owing to local pollution. The residential sector 

mitigation potential plays a key role and it also delivers most in terms of reducing PM exposure as is 

shown later in the report. As discussed for NMVOC, the impact of transboundary pollution can  result in 

counterintuitive results when policy ambition increases and always starting from the baseline case; see 

Slovenia and the discussion in the NMVOC section, section 8.1.2, as well as in Appendix 3 about target 

setting. 

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Figure 62 – Emissions reductions of PM2.5 as calculated from GAINS under different policy scenarios in 2030, split 
by MS. Units: kilotons/yr 

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Table 34. Emissions of SO2 as calculated from GAINS for different policy scenarios in 2050. Units: kilotons/yr 

Member State 

Baseline 

Target 

15ug/m3 

Target 

Target  

10ug/m3 

5ug/m3 

MTFR 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

EU-27 

7 

29 

22 

4 

2 

15 

5 

2 

16 

58 

109 

18 

7 

6 

58 

2 

5 

1 

1 

13 

72 

14 

28 

11 

1 

67 

11 

7 

29 

22 

4 

2 

15 

5 

2 

16 

58 

109 

18 

7 

6 

57 

2 

5 

1 

1 

13 

72 

14 

21 

11 

1 

67 

11 

584 

576 

6 

18 

5 

2 

0 

8 

5 

1 

10 

37 

63 

6 

6 

6 

38 

2 

3 

1 

0 

11 

29 

7 

9 

5 

1 

6 

14 

5 

2 

1 

8 

4 

1 

9 

37 

63 

6 

6 

3 

38 

2 

3 

1 

0 

10 

29 

7 

9 

5 

1 

6 

14 

5 

2 

0 

8 

4 

1 

8 

37 

63 

6 

6 

2 

38 

2 

3 

0 

0 

10 

29 

7 

9 

5 

1 

30 

10 

322 

30 

10 

311 

30 

10 

309 

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Table 35 - Emissions of NOx as calculated from GAINS for different policy scenarios in 2050. Units: kilotons/yr 

Member State 

Baseline 

Target 

15ug/m3 

Target 

Target  

10ug/m3 

5ug/m3 

MTFR 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

EU-27 

70 

89 

33 

17 

4 

56 

35 

8 

47 

245 

272 

60 

40 

44 

193 

12 

16 

5 

1 

71 

172 

47 

75 

28 

7 

191 

34 

1871 

67 

89 

32 

16 

4 

51 

35 

8 

45 

231 

268 

58 

40 

43 

184 

12 

16 

5 

1 

71 

160 

47 

71 

28 

6 

58 

80 

27 

12 

2 

34 

29 

8 

40 

200 

221 

47 

30 

43 

134 

11 

11 

5 

1 

66 

110 

42 

49 

16 

6 

58 

68 

27 

11 

2 

38 

29 

7 

37 

200 

208 

46 

31 

38 

134 

10 

12 

3 

1 

58 

126 

33 

51 

19 

4 

55 

68 

27 

9 

2 

29 

28 

6 

29 

195 

203 

44 

30 

36 

133 

9 

11 

2 

1 

55 

107 

26 

47 

15 

4 

183 

34 

1805 

118 

29 

1430 

125 

29 

1407 

110 

26 

1307 

143 

 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 36. Emissions of NH3 as calculated from GAINS for different policy scenarios in 2050. Units: kilotons/yr 

Member State 

Baseline 

Target 

15ug/m3 

Target 

Target  

10ug/m3 

5ug/m3 

MTFR 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

EU-27 

65 

66 

43 

36 

8 

87 

64 

11 

34 

565 

518 

53 

70 

121 

314 

17 

42 

6 

1 

121 

282 

47 

154 

25 

16 

448 

51 

62 

66 

42 

35 

8 

82 

63 

11 

34 

561 

499 

51 

69 

121 

282 

17 

39 

6 

1 

120 

274 

47 

145 

22 

15 

433 

51 

50 

66 

32 

19 

6 

62 

58 

11 

32 

470 

392 

40 

44 

121 

231 

17 

27 

6 

1 

118 

162 

46 

100 

15 

13 

267 

51 

42 

48 

31 

20 

6 

61 

50 

9 

24 

400 

315 

40 

44 

112 

231 

13 

29 

4 

1 

116 

173 

33 

103 

15 

11 

264 

38 

3265 

3156 

2456 

2234 

39 

48 

29 

18 

6 

60 

49 

9 

23 

378 

306 

39 

44 

95 

226 

13 

27 

3 

1 

116 

162 

30 

97 

15 

10 

235 

36 

2112 

144 

 
 
 
 
 
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Table 37. Emissions of VOC as calculated from GAINS for different policy scenarios in 2050. Units: kilotons/yr 

Member State 

Baseline 

Target 

15ug/m3 

Target 

Target  

10ug/m3 

5ug/m3 

MTFR 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

EU-27 

42 

66 

34 

30 

4 

95 

45 

10 

46 

425 

590 

74 

42 

49 

517 

17 

16 

6 

2 

122 

280 

76 

92 

50 

16 

390 

68 

3203 

41 

65 

31 

25 

4 

89 

44 

10 

45 

419 

569 

72 

40 

47 

498 

16 

16 

6 

2 

120 

263 

74 

75 

49 

14 

38 

63 

29 

14 

3 

66 

43 

10 

32 

376 

475 

55 

36 

47 

381 

15 

15 

6 

2 

119 

235 

69 

71 

47 

14 

38 

59 

28 

15 

3 

71 

41 

10 

31 

388 

474 

57 

36 

47 

382 

15 

15 

6 

2 

114 

242 

68 

71 

46 

13 

382 

65 

3079 

281 

65 

2608 

304 

60 

2635 

32 

51 

22 

14 

3 

54 

26 

7 

24 

327 

375 

49 

29 

33 

372 

8 

8 

4 

1 

90 

194 

56 

55 

29 

10 

257 

53 

2182 

145 

 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 38 Emissions of PM2.5 as calculated from GAINS for different policy scenarios in 2050. Units: kilotons/yr 

Member State 

Baseline 

Target 

15ug/m3 

Target 

Target  

10ug/m3 

5ug/m3 

MTFR 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

EU-27 

10 

12 

11 

5 

1 

11 

8 

2 

9 

81 

62 

19 

12 

6 

49 

4 

4 

1 

0 

12 

52 

23 

31 

6 

3 

73 

13 

10 

12 

9 

5 

1 

11 

8 

2 

9 

80 

61 

18 

12 

6 

43 

4 

4 

1 

0 

11 

52 

23 

20 

6 

3 

72 

13 

7 

12 

7 

3 

0 

9 

8 

2 

9 

62 

55 

14 

9 

6 

38 

3 

3 

1 

0 

11 

37 

14 

16 

4 

3 

29 

13 

6 

9 

5 

3 

0 

8 

6 

1 

8 

62 

53 

14 

9 

6 

38 

3 

2 

1 

0 

10 

33 

11 

16 

4 

2 

29 

12 

6 

9 

5 

2 

0 

8 

6 

1 

8 

59 

50 

13 

9 

5 

38 

2 

2 

1 

0 

10 

31 

10 

14 

4 

2 

28 

12 

521 

495 

376 

352 

335 

Impacts on air pollution concentration (Indicator #1) 

Reduction of population mean exposure in 2030 

The Member State level impact of local and regional mitigation efforts (beyond the Baseline), in order 

to address the specified policy targets are illustrated below.  

As previously shown, limited additional efforts are needed in the 20 µg/m3 case, with the exception of 

a few countries, e.g., Italy, Bulgaria, Romania, Slovenia and primarily involving emission reductions 

from residential heating. The objective of achieving 15 µg/m3 in 2030 requires many countries to 

employ additional measures. These are mostly in residential heating and agriculture (involving 

measures to reduce ammonia emissions as well as primary PM2.5 from the open burning of residues, that 

remains a common practice in some countries). Moving towards 10 µg/m3requires an increase in efforts, 

as has been shown before (Section 8.1.1).  Considering the Baseline scenario and the technical 

mitigation potential defined in the GAINS model, there is not much additional mitigation possible when 

146 

 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

setting the ambition to a level of 5 µg/m3, which is close to MTFR levels. Note the feasibility issues that 

remain within the scenarios/modelling framework – as discussed earlier in the report in Section 6. 

Overall, the largest benefits result from addressing residential combustion and agriculture.  

The contribution of transboundary air pollution  varies across countries (shown on the right-hand – 

extended bar for each Member State), but it is important for the less ambitious targets. It is evident 

that there are some ‘trade-offs’ between local and transboundary contributions to the reduction of 

concentrations – due to transboundary impacts, e.g. in Slovenia (see the discussion in Section 8.1.1).  

147 

 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Figure 63 – Reduction of population mean concentrations in 2030 (Member States own and transboundary 
contribution (right-extended bar)); GAINS model 

148 

 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Station exceedances 

The number of EU27 stations within selected annual mean concentration ranges are presented for PM2.5 

and NO2. All Baseline, MTFR and optimised (OPT) scenarios are presented. Baseline and MTFR results 

have already been presented in Section 7.1.2. The following points can be made: 

• 

For PM2.5, the optimised scenarios show steady reductions in the region between Baseline and 

MTFR. Even so, the optimised scenarios for 5 µg/m3 (OPT05) do not manage to achieve their 

goals with 270 out of 994 station sites still having concentrations > 5 µg/m3. 

• 

For NO2, there is little difference as a result of optimisation. Indeed, there is little difference 

between the Baseline and MTFR scenarios for NO2. Almost all the possible reductions in NOX 

emissions have already been achieved in the baseline scenario. 

Figure 64 Number of stations above selected annual mean concentrations in the EU27 for PM2.5 and NO2 
(WITHOUT bias adjustment) 

149 

 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Sensitivity to bias adjustment 

As noted in Section 7.1.2, there is generally a negative bias to the modelled pollutants. To correct for 

the impact of modelled bias on scenario outcomes a bias adjustment has been implemented. The 

methodology is described in Appendix 3 (Section ‘Bias adjustment’). The figure below presents the ‘bias 

corrected’ results for the impacts of the scenarios on the concentrations at Airbase station sites for 

PM2.5 and NO2. 

Figure 65 - Number of stations above selected annual mean concentrations in the EU27 for PM2.5 and NO2 (WITH 
bias adjustment) 

Population exceedance 

The number of people exposed in the EU27 to above selected annual mean concentration ranges is 

presented for the pollutants PM2.5 and NO2. All Baseline, MTFR and optimised (OPT) scenarios are 

150 

 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

presented. Baseline and MTFR results have already been presented in Section 7.1.2. The following 

points can be made: 

• 

• 

The exposure calculations follow the same trends as seen for the station site calculations. 

As in the station calculations the optimised scenarios do not attain their goals, with the 

exception of the less ambitious optimisations of 20 and 15 µg/m3 with < 80 thousand inhabitants 

exposed above 15 µg/m3. This is well within the uncertainty of the calculations. 

• 

By 2050 all scenarios come close to attaining the WHO recommended NO2 concentration level of 

10 µg/m3 but there would still be 4 – 6 million inhabitants exposed above this level. 

151 

 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Figure 66 Number of people exposed above selected annual mean concentrations in the EU27 for PM2.5 and NO2 
(WITHOUT bias adjustment) 

152 

 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Box – Sensitivity of the assessment to the policy baseline 

This support study to the Impact Assessment of the revision of the AAQ Directives commenced in 

April 2021. In parallel, revisions were also being considered to the Industrial Emissions Directive 

(IED). Over the course of this study, the proposed revisions to the IED were published, alongside a 

supporting impact assessment (IA). However, the integrated impact modelling under this study was 

too advanced at that point to allow reflection and incorporation of the proposed IED updates into 

the central modelling for the present study. As such, the central baseline does not capture any 

potential effect of revisions to the IED proposed in 2022. For this sensitivity, an alternative 

baseline was developed based on assumptions around what the IED could deliver in terms of 

emissions reductions (although noting that precise estimates of the impacts are not available and 

as such illustrative assumptions were used).   

Overall, additional emissions reductions included under the IED sensitivity in the sensitivity 

baseline lead to only small relative changes overall: 

• 

Members State specific population weighted exposure to NO2 and PM2.5 changes by less 

than 0.2 ug/m3, however effects locally can be more significant.  

• 

Reduced concentrations at a small number of stations are observed with mostly 

moderate concentration levels.  

• 

NO2 and PM2.5 exposure distribution for the EU27 population changes insignificantly.  

Hence the key results and conclusions of the central analysis would not change substantially as a 

result of this sensitivity. Further detail is provided in Appendix 9. 

Population exposure and source contributions 

The optimised calculations show similar results to the baseline and MTFR scenarios but with a general 

reduction in concentrations from Baseline to MTFR. These have already been presented in Section 7. In 

Figure 67 we show the exposure distribution for the two optimised, OPT20 and OPT05, for the 2030 

calculation of PM2.5. These are quite similar, but the OPT05 calculation shows some further reduction in 

the residential sector, leading to a reduction in PM2.5 exposure > 10 µg/m3 from 15.6 to 10.6 million 

inhabitants. 

153 

 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Figure 67 Population exposure with source contribution for the EU27. OPT20 (top) and OPT05 (bottom) 2030 
PM2.5 (WITHOUT bias adjustment) 

Heavy metals 

As noted in Section 7, heavy metals were not directly captured by the integrated modelling.  

Analysis of the latest monitoring data is presented in the table below. This shows, for each heavy 

metal, the number of monitoring sites above different thresholds, disaggregated by monitoring site 

type: background, industrial, and traffic. The thresholds refer to the proposed thresholds (Table 39) 

and display the number of monitoring sites that would be impacted if the EU standards were to be 

updated to lower concentrations. The number of exceeding monitoring sites increases as the 

concentration threshold decreases for each heavy metal.    

154 

 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 39 Summary statistics of the heavy metal concentrations in EEA reporting countries in 2019, split by 
station type. The counts above thresholds 3, 4, and 5 relate to the proposed thresholds. Monitoring sites refer 
to above 85% data coverage. 

Pollutant 

e
p
y
T

e
t
i
S

Nickel 
ng/m3 

l
a
i
r
t
s
u
d
n
I

c
i
f
f
a
r
T

d
n
u
o
r
g
k
c
a
B

Lead 
μg/m3 

l
a
i
r
t
s
u
d
n
I

c
i
f
f
a
r
T

Arsenic 
ng/m3 

l
a
i
r
t
s
u
d
n
I

c
i
f
f
a
r
T

Cadmium 
ng/m3 

l
a
i
r
t
s
u
d
n
I

c
i
f
f
a
r
T

d
n
u
o
r
g
k
c
a
B

d
n
u
o
r
g
k
c
a
B

d
n
u
o
r
g
k
c
a
B

Mean 

1.62 

4.76 

2.11 

0.0082 

0.0221 

0.0061 

0.802 

1.38 

0.567 

0.215 

0.545 

0.195 

Minimum 

0.00 

0.40 

0.077 

0.0008 

0.001 

0.001 

0.03 

0.013 

0.069 

0.009 

0.02 

0.033 

Maximum 

13.5 

77.6 

9.85 

0.221 

0.215 

0.029 

16.2 

21.3 

1.73 

3.80 

5.72 

0.946 

Total count 

219 

70 

59 

237 

74 

64 

227 

69 

58 

229 

76 

62 

Count above 
WHO guideline 

Count above 
EU standard 

Count above 
threshold 3 

Count above 
threshold 4 

Count above 
threshold 5 

0 

0 

3 

2 

2 

3 

32 

30 

- 

- 

0 

0 

0 

15 

- 

0 

0 

0 

1 

4 

0 

0 

0 

2 

9 

0 

0 

0 

0 

0 

2 

2 

6 

14 

76 

2 

3 

5 

7 

0 

0 

0 

0 

0 

0 

2 

2 

1 

1 

3 

6 

35 

19 

12 

17 

0 

0 

0 

0 

4 

Table 40 Summary table of the number of monitoring sites that are in exceedance of the proposed 
concentration thresholds for nickel, lead, arsenic, and cadmium. For the concentration thresholds, WHO 
guideline levels or 1/100,000 lifetime risk levels are presented in bold font. Existing EC standards are shown in 
blue font. 1/1,000,000 lifetime risk levels are shown in italic font. 

Nickel 

Lead 

Arsenic 

Cadmium 

Targeted 
Stakeholder 
Survey 
Thresholds 

Threshold 1: 
WHO guideline 

Threshold 2: EU 
standard 
Threshold 3: 
Low 
Threshold 4: 
Mid 
Threshold 5: 
High 

n
o
i
t
a
r
t
n
e
c
n
o
C

)
3
m
/
g
n
(

25 

20 

10 

2.5 

- 

e
v
o
b
a

t
n
u
o
C

d
l
o
h
s
e
r
h
t

2 

2 

6 

77 

- 

n
o
i
t
a
r
t
n
e
c
n
o
C

)
3
m
/
g
μ
(

0.5 

0.5 

0.25 

0.15 

0.05 

e
v
o
b
a

t
n
u
o
C

d
l
o
h
s
e
r
h
t

0 

0 

0 

3 

n
o
i
t
a
r
t
n
e
c
n
o
C

)
3
m
/
g
n
(

6.6 

6 

4 

2 

e
v
o
b
a

t
n
u
o
C

d
l
o
h
s
e
r
h
t

4 

5 

11 

21 

13 

0.66 

130 

n
o
i
t
a
r
t
n
e
c
n
o
C

)
3
m
/
g
n
(

5 

5 

2.5 

1.5 

0.5 

e
v
o
b
a

t
n
u
o
C

d
l
o
h
s
e
r
h
t

1 

1 

5 

8 

33 

This simple analysis shows that small reductions in standards across the pollutants will only bring a 

relatively low number of new exceedances, but larger changes would implicate a much larger number 

of sites in exceedances. Furthermore, the ‘new’ exceedances will not be limited to industrial 

monitoring stations, but also background. For Nickel, 2 stations are in exceedance for the current limit 

value, but when this is substantially reduced to 2.5 ng/m3 the number of stations in exceedance rises to 

77. A similar scale of challenge is seen for arsenic, where 5 monitoring stations are in exceedance but 

under the most stringent proposed limit value change, the number of stations rises to 130. Lower 

155 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

challenges are seen for both lead and cadmium, where under the most stringent proposed limit value 

change, the number of exceedance situations changes from 0 to 13 (Pb) and 1 to 33 (Cd). 

The analysis looked further into the potential sources of pollution at current exceedance sites. In 

summary, 75% of the reported exceedances for the assessed heavy metals in 2019 could potentially be 

explained by a reported pollutant release from an E-PRTR industrial site within a 10 km radius of the 

monitoring station. These industrial sites are a mix of thermal power stations, precious metal 

producers, copper manufacturers, flat glass manufacturers, and non-ferrous crude metals producers, 

and are located between 0.5 km and 3.6 km  from the monitoring sites exceeding EU standards. 

However, for some sites no point source could be identified. As such there is still large uncertainty in 

the underlying data linking measured concentrations to sources, making it challenging to assess what 

the implications of lower standards would be. 

This analysis is inherently uncertain due to the limitations and completeness of the data within E-PRTR. 

Although we observe the potential scale of the challenge to attain more stringent limit values for heavy 

metals, more evidence is required to bring more confidence. Dispersion modelling of the reported 

emissions from E-PRTR registered facilities, potentially supplemented by national databases, would 

improve the robustness of these conclusions and allow further assessment of population exposure to 

heavy metal pollution. If air quality standards are tightened, exceedances would be recorded at many 

more monitoring stations. A systematic investigation of the causes of these exceedances would become 

still more important. More comprehensive and systematic reported data from industrial sites and air 

monitoring sites would provide wider evidence to support the evaluation of potential future changes to 

the EU heavy metal standards. 

  Health impacts (Indicator #2) 

Results for attributable mortality (Tier 1) 

The impact of the various scenarios on the total number of yearly attributable deaths in the EU-27 for 

the three pollutants under consideration (PM2.5, NO2, O3) is shown in the bar graphs in Figure 68 (total 

number of premature deaths) and Figure 69 (relative differences between the baseline and the 

scenarios).  

For particulate matter, the relative impact of the OPT scenarios depends on the nature of the scenario. 

If the baseline concentrations are already close to the target concentrations of the scenarios (as e.g. 

for the OPT20μg/m3 scenario in 2030 and the OPT15μg/m3 in 2050), the health impact of the scenarios 

is rather limited (respectively 15% and 8% for the OPT20μg/m3 scenario in 2030 and the OPT15μg/m3 in 

2050). For all other scenarios, the health impact for the OPT scenarios is significant (at least 38% in 

2030 and at least 46% in 2050), and in many cases the difference between the health impact of the OPT 

scenarios and the MTFR scenario is rather limited. For example, the difference in health impact 

between the OPT10μg/m3 and the MTFR is only 8% in 2030 and only 4% in 2050.  

For nitrogen dioxide, the impact (relative to the baseline) for the OPT scenarios depends on the year 

under consideration. For 2030, the OPT20μg/m3 only has a limited impact (2%), while the impact 

gradually increases for the more stringent scenarios (12%, 16%, and 20% respectively for OPT15μg/m3, 

OPT10μg/m3 and OPT05μg/m3). In 2050, the impact (relative to the baseline) of the OPT15μg/m3 

scenario is small (1%), while the impact for the other OPT-scenarios is very similar to the impact of the 

MTFR scenario (14% reduction for both the OPT10μg/m3 and OPT05μg/m3, compared to 16% for MTFR). 

156 

 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Finally, for ozone, the impact of the OPT scenarios is small, with  only marginal reductions for the 

OPT20μg/m3 and the OPT15μg/m3 scenario. 

The bar graphs in Appendix 5 show the impact of the OPT scenarios on the number of yearly 

attributable deaths per capita for all countries in the EU-27. These charts indicate that the spatial 

pattern of the relative impact of the OPT-scenarios is similar to the spatial pattern of the relative 

impact of the MTFR scenario (although with smaller relative reductions). All remarks and conclusions 

concerning the spatial pattern of the impact of the MTFR scenario are thus valid for the OPT scenario.  

Figure 68 : Number of yearly premature deaths in the EU-27 caused by the exposure to air pollution at levels 
above the WHO AQ guidelines for all scenarios for three pollutants (PM2.5, top-left, NO2, top-right, O3, bottom).   

Notes: Impacts for the four reporting years considered in the study (2015 in blue, 2020 in cyan, 2030 in orange and 2050 in green) are 
included. The filled bars and the numbers refer to the central estimate (rounded to the nearest 100 for NO 2 and the nearest 1000 for 
PM2.5, respectively), while the black lines provide the 95-percentage uncertainty estimate based on the uncertainty on the relative 
risks. 

157 

 
 
 
 
 
 
 
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Figure 69 Relative impact of the scenarios on the number of yearly premature deaths in the EU-27 caused by 
the exposure to air pollution at levels above the WHO AQ guidelines for three pollutants (PM2.5, top-left, NO2, 
top-right, O3, bottom).   

Notes: Impacts for the two future reporting years considered in the study (2030 in orange and 2050 in green) are included.  

Results for attributable morbidity (Tier 2 and Tier 3) 

Figure 70 provides an overview of the relative impact of the scenarios on the morbidity from the second 

(morbidity according to HRAPIE) and third Tiers (additional health outcomes beyond HRAPIE: stroke, 

lung cancer and asthma in children). For all health outcomes, the results correspond qualitatively and 

quantitively with those for the chronic mortality caused by PM2.5 exposure. The relative impact of the 

OPT scenarios depends on the nature of the scenario. If the baseline concentrations are already close to 

the target concentrations of the scenarios, the health impact of the scenarios is rather limited, in line 

with the results for mortality (see Figure 69). For all other scenarios, the health impact for the OPT 

scenarios is significant, and in many cases the difference between the health impact of the OPT 

scenarios and the MTFR scenario is rather limited.  

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Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Figure 70 Relative impact of the scenarios on the morbidity in the EU-27 caused by the exposure to air pollution 
at levels above the WHO AQ guidelines for 2030 (top) and 2050 (bottom). 

Notes: The various bars correspond to the various morbidity outcomes considered in the main analysis of the study (Tier 2 and Tier3).  

Health impacts - summary results 

The following conclusions regarding the health impacts of the scenarios can be drawn from this 

analysis: 

• 

The measures taken under the MTFR scenario have a significant impact on the health impact 

caused by the exposure to particulate matter (reductions of more than 55% in 2030, and of 

159 

 
  
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

approximately 50% in 2050). Despite these strong reductions, a significant health impact 

remains under the application of the MTFR scenario, with more than 20,000 yearly attributable 

deaths in 2030 and more than 10,000 yearly attributable deaths in 2050. 

• 

The relative impact of the other scenarios depends on the nature of the scenario. If the 

baseline concentrations are already close to the target concentrations of the scenarios (e.g. 

OPT20μg/m3 scenario in 2030 and the OPT15μg/m3 in 2050), the health impact of the scenarios 

is rather limited. For all other scenarios, the difference in health impact for the OPT scenarios 

is similar to the health impact of the MTFR scenario. 

• 

For particulate matter, a strong regional difference in the impacts of the MTFR scenario is 

observed, with  smaller relative impacts observed in Southern Europe in comparison with other 

regions (due to the impact of natural contributions and the minor reductions in shipping 

emissions). For nitrogen dioxide, the highest reduction in attributable mortality is observed at 

the hotspots for which the emissions are reduced by the greatest margin. 

• 

Results for morbidity show a similar pattern to the results for mortality. 

  Ecosystem impacts (Indicator #3) 

Maps of ecosystem areas exceeding critical loads for acidification and eutrophication from deposition of 

nitrogen and sulphur are shown in Section 7 for the Baseline and MTFR scenarios. Table 41 to Table 44 

differentiate the impacts of the different scenarios in terms of area shares of different types of 

ecosystems where critical loads for eutrophication and acidification are exceeded by Member State.  

160 

 
 
 
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Table 41. - Percent of total ecosystem area exceeding critical loads for eutrophication from deposition of 
nitrogen for different policy scenarios in 2030. 

Member State 

Baseline 

Target 

Target 

Target 

20ug/m3 

15ug/m3 

10ug/m3 

Target  

5ug/m3 

MTFR 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

EU-27 

34.8 

1 

93.6 

82.9 

100 

100 

99.7 

38.7 

0.8 

65.1 

66.9 

94.1 

89.3 

7.2 

34.7 

87.1 

98.1 

100 

100 

69.2 

52.3 

99.1 

93.8 

90.2 

81.2 

97.5 

9.6 

69.2 

31.6 

1 

92.1 

82.1 

100 

99.4 

99.6 

37 

0.8 

63.8 

66 

93.4 

87.6 

6.8 

22.1 

85.6 

97.6 

100 

100 

69 

50.6 

99 

93.3 

89.4 

72.7 

97.4 

9.6 

67.3 

20.6 

0.5 

83.8 

75.7 

100 

52.8 

99.2 

20.5 

0.7 

46.8 

58.5 

89.9 

70.3 

6.5 

19.7 

70.7 

94.2 

99.9 

99.7 

67.1 

27 

96.1 

82.9 

77.7 

67.3 

92 

6.7 

58 

11.6 

0.4 

83.9 

75.2 

100 

42.4 

98.7 

12.8 

0.4 

41.5 

52.6 

89.7 

70.1 

4.8 

19.6 

62.4 

94 

97.7 

99.7 

61.3 

25.2 

84.9 

83 

77.4 

63.8 

90.6 

5.5 

55.2 

9.2 

0.4 

80.5 

71.7 

100 

33.9 

98.3 

11.7 

0.1 

37.8 

51.3 

88.7 

69.9 

2.6 

18 

58.3 

92.8 

94.5 

99.7 

59.9 

22.2 

79.8 

80.6 

74.5 

62.6 

88.2 

5.1 

52.9 

20.4 

0.9 

85.2 

78.1 

100 

51.4 

99.2 

20.5 

0.7 

62 

58.2 

89.7 

70.3 

6.7 

21.2 

70.7 

94.2 

99.9 

100 

67.7 

26.7 

99 

84.5 

78.9 

65.6 

97.3 

7 

61.3 

161 

 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 42- Percent of total ecosystem area exceeding critical loads for acidification from deposition of nitrogen 
and sulphur for the different policy scenarios in 2030.  

Member State 

Baseline 

Target 

Target 

Target 

20ug/m3 

15ug/m3 

10ug/m3 

Target  

5ug/m3 

MTFR 

0 

0.1 

0 

0 

0 

8 

0.3 

0 

0.4 

0.1 

9.4 

0.1 

0.3 

0.1 

0 

0 

8.6 

0 

0 

81.9 

1.4 

0.3 

0 

0 

0 

0 

2.1 

1.6 

0 

0.1 

0 

0 

0 

7.4 

0.3 

0 

0.4 

0 

8.8 

0.1 

0.3 

0 

0 

0 

7.6 

0 

0 

81.7 

1.2 

0.3 

0 

0 

0 

0 

2.1 

1.5 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

0.8 

0 

0.4 

0.7 

22 

0.1 

2.1 

0.3 

0 

1.1 

22 

6.9 

0 

Netherlands 

84.3 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

EU-27 

6.3 

0.4 

0 

0.8 

0 

0 

2.3 

3.1 

0 

0.5 

0 

0.8 

0 

0 

0.5 

0 

0.5 

0 

18.9 

16.3 

0.7 

0 

0.4 

0.6 

0 

0.5 

0 

0.1 

0 

8.2 

0.3 

0 

0.4 

0.4 

0 

0.4 

0 

0.1 

0 

8.1 

0.3 

0 

0.4 

0.1 

20.5 

12.8 

12.9 

0.1 

0.4 

0.3 

0 

0.1 

8.4 

0.3 

0 

82.8 

1.6 

0.4 

0 

0 

0 

0 

2.1 

1.8 

0.1 

2.1 

0.3 

0 

0.9 

21.6 

6.7 

0 

84.2 

5.7 

0.4 

0 

0.5 

0 

0 

2.3 

3 

0.1 

0.4 

0.3 

0 

0.1 

8.4 

0.3 

0 

83.1 

1.6 

0.4 

0 

0 

0 

0 

2.2 

1.9 

162 

 
 
 
 
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Table 43. - Percent of total ecosystem area exceeding critical loads for eutrophication from deposition of 
nitrogen for different policy scenarios in 2050. 

Country 

Baseline 

Target 

Target 

15ug/m3 

10ug/m3 

Target  

5ug/m3 

MTFR 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

EU-27 

31 

0.8 

90.5 

82.3 

100 

96.1 

98.9 

15.5 

0.6 

60.9 

62.7 

93.1 

80.1 

5.9 

30.2 

71.7 

96.9 

99.9 

100 

67.5 

45.5 

98.3 

92 

88.2 

77.6 

97.1 

6.1 

65.5 

27.4 

0.6 

89.7 

81.4 

100 

84.3 

98.7 

14.6 

0.6 

59.7 

61.5 

92.4 

77.9 

5.8 

25.1 

69.8 

96.4 

99.9 

100 

67.3 

43.4 

98 

90.3 

86.3 

72.2 

96.8 

6 

64 

13.6 

0.5 

77.8 

68.3 

100 

28.5 

97 

10.8 

0.3 

41.9 

52.6 

88.7 

67.8 

5.6 

15.9 

56.2 

89.6 

98 

100 

60.9 

17.6 

92.5 

74.4 

68 

62.4 

89.3 

4.7 

52.8 

7.1 

0.2 

76.6 

68.2 

100 

23 

93.3 

9.5 

0.1 

33.1 

46.1 

88.6 

67.7 

3.8 

15.6 

50.8 

89.6 

91.7 

100 

57.2 

18.3 

82.3 

75.5 

67.8 

60.1 

88.5 

3.3 

50.2 

5.9 

0.1 

74 

64.2 

100 

21.6 

92.4 

9.3 

0 

30.1 

44.8 

88.1 

66.3 

2.3 

14.7 

48.9 

86.3 

72.2 

100 

56.7 

15.6 

77.9 

71.2 

64.4 

57.7 

85.5 

3.2 

47.9 

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Table 44.  Percent of total ecosystem area exceeding critical loads for acidification from deposition of nitrogen 
and sulphur for the different policy scenarios in 2050 

Country 

Baseline 

Target 

Target 

15ug/m3 

10ug/m3 

Target  

5ug/m3 

MTFR 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

EU-27 

0 

0.5 

0 

0.4 

0 

9.8 

0.5 

0 

0.4 

0.2 

0 

0.5 

0 

0.4 

0 

8.8 

0.3 

0 

0.4 

0.2 

16.6 

15.7 

0.1 

1.7 

0.2 

0 

0.6 

19.2 

0.3 

0 

83.1 

3.3 

0.4 

0 

0.1 

0 

0 

2.2 

2.4 

0.1 

1 

0.2 

0 

0.5 

16.2 

0.3 

0 

82.9 

2.9 

0.4 

0 

0.1 

0 

0 

2.2 

2.3 

0 

0.2 

0 

0 

0 

5.9 

0.3 

0 

0.4 

0.1 

9 

0.1 

0 

0.2 

0 

0 

6.6 

0.2 

0 

81.4 

0.7 

0.4 

0 

0 

0 

0 

2 

0 

0 

0 

0 

0 

5.1 

0.3 

0 

0.4 

0 

6.1 

0.1 

0 

0 

0 

0 

6.6 

0 

0 

79.6 

0.7 

0.4 

0 

0 

0 

0 

2 

0 

0 

0 

0 

0 

4.3 

0.2 

0 

0.4 

0 

5.7 

0.1 

0 

0 

0 

0 

6.5 

0 

0 

79.3 

0.6 

0.3 

0 

0 

0 

0 

2 

1.5 

1.2 

1.2 

164 

 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Box – Sensitivity of the assessment to computation of health impacts 

The analysis of the scenarios included calculations of the health impacts of air pollution, both in 

absolute terms (to assess the necessity of taking additional action on air pollution in the first place) 

and in relative terms (to assess the relative merits of different policy options considered). These 

calculations are based on the latest available evidence consolidated in the 2021 WHO AQGs and 

their underpinning scientific reviews. Since their publication, however, additional epidemiological 

studies have been published, including studies that focus on the risk of exposure to relatively low 

levels of air pollution. These point to a possibly quantifiable health impacts also below guideline 

exposure levels recommended by the WHO (i.e. the ‘cut-off value’), as well as to a supra-linear 

form of the exposure-response relationship (i.e. the ‘relative risk’, with a higher effect per 

additional exposure at low pollutant concentrations than at high concentrations). In addition, there 

is also uncertainty around the health impact computations associated with the source of pollution 

assessed (e.g. inclusion of non-anthropogenic sources or not), the morbidity pathways includes, and 

the air quality data used (i.e. resolution of modelling or application of bias correction or not). 

Sensitivity tests have therefore been performed to explore the sensitivity of the central results to 

key assumptions (i.e. related to ‘cut-off value’ and the ‘relative risk’).  

The sensitivity test confirmed that the assumptions made have a significant impact on the absolute 

impact of air pollution, and the health impact figures presented in the central analysis are likely to 

underestimate the total health impact of air pollution. For the health impacts of PM2.5 in 2015, for 

example, the estimates of premature mortality range from 213,900 to 524,200. This range of 

estimates of absolute impacts widens further (based on the relative difference between low and 

high estimates) for calculation for future years, as more and more people are expected to be 

exposed to air pollution at lower concentration levels only. Reassuringly, this sensitivity analysis also 

indicates that the effect on the relative benefits between the scenarios analysed in this impact 

assessment is only affected minimally. Under all sensitivity tests, the ranking of the net benefits or 

benefit-cost ratios between the scenarios does not change. Further detail is provided in Appendix 9. 

Valuation of ecosystem impacts 

The following table presents the monetised impacts of air pollution on ecosystems under the baseline 

and MTFR scenario. The size of the damage in the baseline and scenarios reduces over time alongside 

further emissions reductions delivered through current policy. The monetised benefits increase with the 

ambition under each scenario, as further reductions in air pollutant emissions are delivered. The 

scenarios and MTFR can deliver substantial ecosystem benefits, however the aggregate size of these 

benefits is still smaller than the human health benefits. 

165 

 
 
 
 
 
 
 
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Table 45– Monetised material damage impacts per annum – baseline and MTFR – EURm 2015 prices 

2015 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

1,871  

1,136  

914  

Total damage by 
scenario 

Baseline 

Target 20ug/m3 

Target 15ug/m3 

Target 10ug/m3 

Target  5ug/m3 

MTFR 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

Benefit by scenario relative to Baseline 

Target 20ug/m3 

Target 15ug/m3 

Target 10ug/m3 

Target  5ug/m3 

MTFR 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

662  

633  

481  

466  

458  

436  

29  

181  

196  

204  

226  

517  

465  

447  

442  

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

430  

286  

281  

269  

- 

12  

156  

160  

172  

Table 46 – Monetised crop damage impacts per annum – baseline and MTFR – EURm 2015 prices 

Total damage by scenario 

2015 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

11,758  

10,691  

10,320  

9,877  

9,629  

9,518  

9,450  

9,459  

Baseline 

Target 20ug/m3 

Target 15ug/m3 

Target 10ug/m3 

Target  5ug/m3 

MTFR 

- 

- 

- 

- 

- 

Benefit by scenario relative to Baseline 

Target 20ug/m3 

Target 15ug/m3 

Target 10ug/m3 

Target  5ug/m3 

MTFR 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

9,809  

9,689  

9,623  

9,600  

9,472  

67  

188  

254  

276  

404  

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

9,415  

9,200  

9,201  

9,110  

- 

44  

259  

258  

348  

166 

            
            
                
                
                
                
                
                
                
 
                
                
                
                
                
                
                
                
                  
                
                  
                
                
                
                
                
                
 
                 
                 
                
                    
                    
                    
                    
                    
                    
 
                    
                    
                    
                    
                    
                    
                    
                    
                          
                       
                          
                       
                       
                       
                       
                       
                       
  
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 47– Monetised forest damage impacts per annum – baseline and MTFR – EURm 2015 prices - LOW52 

Total damage by scenario 

2015 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

20,326  

19,050  

18,551  

17,975  

17,648  

17,478  

17,371  

17,374  

Baseline 

Target 20ug/m3 

Target 15ug/m3 

Target 10ug/m3 

Target  5ug/m3 

MTFR 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

Benefit by scenario relative to Baseline 

Target 20ug/m3 

Target 15ug/m3 

Target 10ug/m3 

Target  5ug/m3 

MTFR 

- 

- 

- 

- 

- 

Baseline 

Target 20ug/m3 

Target 15ug/m3 

Target 10ug/m3 

Target  5ug/m3 

MTFR 

Benefit by scenario relative to Baseline 

Target 20ug/m3 

Target 15ug/m3 

Target 10ug/m3 

Target  5ug/m3 

MTFR 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

17,906  

17,752  

17,688  

17,659  

17,486  

69  

222  

287  

316  

488  

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

17,321  

17,082  

17,080  

16,954  

52  

292  

293  

420  

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

17,906  

17,752  

17,688  

17,659  

17,486  

69  

222  

287  

316  

488  

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

42,090  

41,505  

41,501  

41,194  

- 

127  

712  

716  

1,023  

Table 48– Monetised forest damage impacts per annum – baseline and MTFR – EURm 2015 prices - HIGH 

Total damage by scenario 

2015 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

20,326  

19,050  

18,551  

17,975  

42,882  

42,470  

42,211  

42,217  

52 Note that there is no difference between HIGH and LOW estimate for forest damage in 2030 as only after 2030 
different assumptions are used to monetise the reduced carbon sequestration potential due to forest damage. 

167 

          
          
          
          
          
          
          
          
          
 
          
          
          
          
          
          
          
          
                  
 
                
                  
                
                
                
                
                
                
 
          
          
          
          
          
          
          
          
          
          
          
          
          
          
          
          
          
                  
                
                
                
                
                
                
                
            
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 49 – Monetised ecosystem damage impacts per annum – baseline and MTFR – EURm 2015 prices - LOW 

Total damage by scenario 

2015 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

Baseline 

Target 20ug/m3 

Target 15ug/m3 

Target 10ug/m3 

Target  5ug/m3 

MTFR 

Benefit by scenario relative to Baseline 

Target 20ug/m3 

Target 15ug/m3 

Target 10ug/m3 

Target  5ug/m3 

MTFR 

4,215  

3,901  

3,769  

3,588  

3,485  

3,422  

3,386  

3,375  

3,488  

3,140  

2,883  

2,726  

2,588  

101  

448  

706  

863  

1,000  

3,291  

2,585  

2,443  

2,328  

83  

790  

931  

1,047  

Table 50– Monetised ecosystem damage impacts per annum – baseline and MTFR – EURm 2015 prices - HIGH 

Total damage by scenario 

2015 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

12,644  

11,702  

11,308  

10,765  

10,455  

10,267  

10,157  

10,124  

Baseline 

Target 20ug/m3 

Target 15ug/m3 

Target 10ug/m3 

Target  5ug/m3 

MTFR 

Benefit by scenario relative to Baseline 

Target 20ug/m3 

Target 15ug/m3 

Target 10ug/m3 

Target  5ug/m3 

MTFR 

10,463  

9,420  

8,648  

8,177  

7,765  

302  

1,345  

2,117  

2,588  

3,000  

9,874  

7,754  

7,330  

6,984  

250  

2,370  

2,794  

3,140  

  Links with climate change (Indicator #4) 

As discussed earlier in Section 7.1.3, the Fit for 55 strategy brings in reductions in the use of fossil fuels 

and efficiency improvements that result in lower emissions of CO2 and short-lived climate forcers 

(SLCFs). For Black Carbon, this impact is shown in the evolution of the baseline emissions while the 

additional reduction associated with the technical mitigation measures necessary to achieve the 

increasing ambition of PM2.5 concentrations is shown for the respective policy scenarios as well as MTFR 

(see Figure 71; blue bars for policy scenarios). 

168 

                      
                      
                      
                      
                      
                      
                      
                      
 
 
 
                      
 
 
 
 
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
                         
 
 
 
 
 
 
 
                         
 
 
 
                           
 
 
 
                         
 
 
 
                         
 
 
 
                         
 
 
 
                         
 
 
 
                      
 
 
 
                      
 
                    
                    
                    
                    
                    
                    
                    
                    
 
 
 
                    
 
 
 
 
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
                         
 
 
 
 
 
 
 
                      
 
 
 
                         
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
                      
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Figure 71– Emissions of black carbon (BC) in the baseline and MTFR scenarios (red bars) and additional 
mitigation of BC achieved in the cost-optimal policy scenarios targeting PM2.5 concentration targets; GAINS 
model 

Figure 72 - Emission of BC for the baseline, policy, and MTFR scenarios by sector for the EU27; GAINS model 

Achieving PM2.5 policy targets of 20 and 15 ug/m3 in 2030 and 2050 is not associated with significant 

additional measures, compared to the baseline (also compare Section 8.1.1), and therefore no sizable 

reductions of BC are visible. The more ambitious targets of 10 ug/m3 and especially 5 ug/m3 necessitate 

mitigation of primary sources of PM2.5 and therefore results in co-beneficial BC reduction. Most of the 

reduction is achieved as a result of changes in the residential heating sector, i.e. introducing cleaner 

169 

 
 
 
 
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burning technologies, and effective enforcement of a ban on the field burning of agricultural residues 

(Figure 72).  

  Synergies with other EU policies (Indicator #11) 

Synergies with the Zero Pollution Action Plan   

The Commission adopted the EU Action Plan “Pathway to a Healthy Planet for All: EU Action Plan: 

‘Towards Zero Pollution for Air, Water and Soil’” on 12th May 2021 as a part of the European Green 

Deal. To deliver the objectives of the EU Zero Pollution Action Plan, a set of key action areas has been 

identified, with the AAQ Directives playing an important role alongside relevant source policies in 

reducing air pollution. To evaluate synergies with the Action Plan, several of its goals are mapped to 

corresponding indicators in this impact assessment: 

• 

• 

Premature death reduction goal (Indicator 2) 

Ecosystem impact goal (Indicator 3) 

•  Noise pollution (Indicator 11) 

• 

Indoor air pollution (Indicator 11). 

Indoor air pollution  

Indoor air quality is highly affected by both indoor and outdoor sources of pollution (European Court of 

Auditors, 2018). Key assumptions for synergy analysis are that a) outdoor air can enter and affect the 

indoor environment and b) indoor air pollution from incomplete fuel combustion poses an important 

direct health risk in households (WHO, 2014). 

In 2020, emissions from biomass combustion for residential heating represented nearly 50% of total 

anthropogenic emissions of PM2.5 in the EU27 (GAINS model). 83% of PM2.5 emissions from domestic use 

came from biomass in 2020. This poses challenges for both AAQ Directives and ZPAP and the NEC 

Directive. Total residential biomass use is expected to decrease by 19% by 2030, compared to 2020, and 

then to decline by a further 22% between 2030 and 2050. However, the residential sector will continue 

to partly rely on the use of biomass to meet its energy needs.  

Figure 73- Residential Biomass Activity and Emissions GAINS model      

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Residential boilers, stoves and fireplaces are the key technologies used for biomass combustion. They 

therefore represent key activity sources for ambient air pollution and indoor air pollution.Emissions 

from small-scale residential biomass combustion are a major source of indoor and outdoor particulate 

matter (PM) air pollution. As a result of the decline in residential biomass use in these three key 

technologies, PM2.5 emissions significantly decline. The performance of stoves, boilers, and fireplaces 

has also been shown to be influenced by fuel properties, technology, and user behaviour (firing 

procedures). 

Figure 74- Residential Biomass Activity and Emissions  from stoves and fireplaces (PM2.5 emissions and energy 
use in petajoules (PJ)); GAINS model53  

In the baseline, PM2.5 emissions linked to residential biomass combustion in fireplaces, stoves and 

boilers compared to 2020 are expected to decline by 54% by 2030 and then by an additional 59% 

between 2030 and 2050. In the MTFR Scenario, PM2.5 emissions will fall by more than 75% by 2030 

compared to 2020. By 2050, PM2.5 emissions will be reduced by a further 54% compared to 2030, which 

corresponds to PM2.5 emissions of only 11% of 2020 levels (Error! Reference source not found.Figure 74 

above). In addition to reducing the residential use of biomass, the main driver of this significant 

reduction in PM2.5 pollution is improved technology54. While in 2020, open fireplaces are estimated to 

represent 53% of all fireplaces, their share is expected to be reduced to 19% by 2030 in the baseline 

scenario. In the MTFR Scenario, such fireplaces are expected to account for only 2% of all fireplaces in 

2030. Newly built ‘closed’ fireplaces will be dominant, reducing emissions further. 

Reduction of outdoor air pollution will also reduce indoor pollution. Improved performance of 

fireplaces, stoves or boilers will result in lower indoor-outdoor (I/O) ratios. Currently available 

literature on I/O ratios only focuses on different sources of pollution from biomass combustion, e.g. in 

fireplaces, boilers or stoves under different circumstances (e.g. ventilation, season). The literature 

does not provide comparisons of different technologies. As a result, we consider the range of I/O ratios 

between 0.7 and 3.4 for PM2.5 emissions regardless of the type or technology of residential heating 

53 Note - 2020 data is all from baseline, it has only been used for comparative purposes in MTFR. 
54 PRIMES energy projection, compatible with the Fit for 55 goals provides development of total biomass use in residential sector but 
the split of installations (stoves, pellets, etc) are estimated independently in GAINS. 

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(Chen & Zhao, 2011) (Figure 75). We see clear synergies between the objectives of ambient air 

pollution and indoor air pollution reduction from residential biomass combustion.   

Figure 75 – Indoor – Outdoor Air quality relationship – Baseline (left) and MTFR Scenario (right) 

However, the reduction in outdoor and indoor air pollution will vary significantly across EU Member 

States due to different changes in biomass use and technology improvements. Residential biomass use is 

expected to decline in most EU countries between 2020 and 2050 (unlike use of biomass for power 

generation, which is expected to increase, as above). The reduction is expected to range from almost 

80% in Sweden to only 17% in Bulgaria. However, in Poland, Denmark, Luxembourg and the Netherlands 

the residential use of biomass is expected to increase. While in Poland the growth is modest, at only 

2%, in the Netherlands residential biomass use, especially biogas, is expected to increase by 67% 

between 2020 and 2050. The use of firewood in residential properties is expected to decline in all EU 

Member States except Denmark and Luxembourg. Additionally, several EU MS promote biogas 

production, with a subsequent impact on ambient air pollutants. There are several routes to producing 

biogas and biomethane, with energy crops being the primary source of growth in Europe to date. The 

gasification route to biomethane uses woody biomass (in addition to municipal solid waste and 

agricultural residues) as a feedstock, which consists of residues from forest management and wood 

processing (IEA, 2020). Crop residues55 are another prominent feedstock option.  

Despite some slight increases in biomass use in some EU countries, PM2.5 emissions are expected to 

decline in all Member States as a result of improved technology. In 16 Member States, PM2.5 is expected 

to decrease by at least 80% between 2020 and 2050 in the baseline scenario with even further 

reductions in the MTFR Scenario. The lowest decline is expected in the Netherlands, only 28% in 

baseline scenario and 32% in MTFR Scenario. This is due to the use of closed fireplaces with air control 

and more advanced stoves already being widespread in 2020.  

55 Residues from the harvest of wheat, maize, rice or other coarse grains, sugar cane and other oilseeds.    

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Figure 76 - Residential biomass use outlook in the baseline across EU27; GAINS model   

Note: Netherlands increase is mainly driven by increase in biogas use.  

Noise pollution 

Road traffic is the top source of noise pollution in Europe (EEA, 2020), followed by rail, aircraft and 

industry. Literature review shows that an estimated 113 million people are affected by long-term day-

evening-night traffic noise levels of at least 55 dB (EEA, 2020). In addition, 22 million citizens are 

exposed to high levels of railway noise, 4 million to high levels of aircraft noise and less than 1 million 

to high levels of noise caused by industry. These values are likely to be underestimates, given that the 

Environmental Noise Directive does not comprehensively cover all urban areas, roads, railways and 

airports across Europe. 

Figure 77 Distribution of European population exposed to sound levels above 55 dB Lden, by noise source 
(millions). Includes populations living in large agglomerations (>100 000 inhabitants) and close to major 
infrastructure 

The Europe-wide trends are confirmed by granular country level data on sources of noise pollution 

included in the ‘2021 Noise country fact sheets’56. The trend of road transport being the key source of 

noise pollution is confirmed in different geographical parts of Europe as per the following examples:  

56 Country fact sheets summarise information on noise pollution for selected EEA member countries and are based on the latest 
official noise data reported every five years by EEA member countries under the Environmental Noise Directive (END) (EEA, 2021).  

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• 

Finland - the main source of noise pollution is noise from roads, followed by rail and air 

(though the latter two being a marginal source).  

•  Germany - the main source is road transport, closely followed by rail, with air and industry 

being a small source of noise pollution. 

• 

• 

Portugal - while road noise is still the main source of noise pollution, the next most significant 

source is air, with rail having a small impact.  

Romania - road noise is the main source, followed by a small share of rail, industry and air.  

Road transport is a key contributor towards ambient air pollution, with cars representing the highest 

share of PM2.5 and NOx emissions in the transport sector in 2020. A significant reduction of both NOx and 

PM2.5 emissions from road transport is expected in the baseline scenario due to stricter vehicle emission 

standards, but also due to the expected progressive shift in the fuels used in road transport from liquid, 

notably fossil fuels, to electricity. Typically electric vehicles emit less noise than conventionally fuelled 

vehicles, hence the transition to less air polluting vehicles will also have consequences for noise 

pollution. The use of vehicles with EURO6/VI standard will increase between 2020 and 2030 for diesel, 

gasoline and gas road transport vehicles across all categories (cars, buses, heavy duty vehicles, light 

duty vehicles). Use of both diesel and gasoline is however expected to decrease in cars, light duty 

vehicles, buses and heavy-duty vehicles, while the use of electricity in road transport increases. This is 

a result of the anticipated  shift from internal combustion engines (ICEs) towards the use of electric 

power trains. By 2050 all liquid fuels for ICEs will drop significantly and will be substituted by the use of 

electricity. The highest increase of electricity use is expected in cars and light duty vehicles, where it 

will account for 85% and 76%, respectively, of total energy use by 2050.  

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Figure 78 – Energy use and PM2.5 emissions in baseline in different transport activities (in PJ)   

Figure 79 – Energy use and NOx emissions in baseline in different transport activities (in PJ)   

PM2.5 emissions 

NOx emissions 

The Environmental Noise Directive obliges the EU Member States to prepare action plans to reduce 

noise from transport in agglomerations. Reduction of noise in urban areas will require a mix of global 

and local actions, with the improvement of the vehicle fleet needs to be accompanied by the 

deployment of better tyres and better roads. The ’avoid and shift strategy’ aims to reduce road 

transport via the promotion of active mobility modes, such as walking or cycling, which are emissions 

free. Promoting the use of public transport, so that it contributes a greater share of overall km of 

vehicle travel, sis also part of this strategy.. Support for the electrification of transport is considered as 

one of the key measures to reduce ambient air pollution from transport. While electric vehicles 

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produce PM pollutants from tyre and break friction, they produce no tailpipe emissions, thus 

electrification reduces PM, NOx and SOx from fuel combustion. Electric power trains emit less noise 

pollution than ICE, but tyre road friction still causes some noise pollution. In urban environments, 2-

wheelers and trucks are particularly polluting in terms of noise. While significant electrification is 

envisaged for cars, LDVs and some  buses, HDVs are lagging behind due to a lack of technological 

alternatives. In spite of an expected reduction in local air pollutants, an increase of noise is foreseen 

for all modes by 2030 relative to 2015 due to the increase in the number of vehicles. By 2050 the 

increased number of electric vehicles could lead, for road only, to a limited benefit in terms of noise 

reduction57. Synergies between air pollution and noise are therefore of primary importance in the urban 

environment. A full spectrum of measures needs to be considered to maximise synergies, including an 

overall reduction in road transport in urban areas and improvements to vehicle tyres and road surfaces 

to reduce both noise and air pollution. The impacts of electrification on noise would therefore remain 

limited unless other specific measures are adopted that benefit the fleet renewal and at the same time 

target noise, as well as CO2 and air pollutant emissions reductions57. 

  Economic impacts 

  Costs and benefits to society (Indicator #5) 

Table 51 shows the results of the analysis, presenting the absolute effects for the baseline and each 

scenario, alongside the difference (or net effect) of the scenarios relative to the baseline, each valuing 

the human health impacts of the scenarios. In line with CAO2, two sets of results are presented which 

present different approaches to monetising the impacts on mortality: a ‘VSL’ or value of statistical life 

approach, which monetises the number of deaths, and a VOLY or Value of a life year approach, which 

instead monetises life years lost. The results present the monetary benefits in the given assessment 

year. For the aggregate assessment, the mortality effects associated with NO2 are excluded to avoid the 

risk of overlap with the mortality effects of PM2.5. 

57 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A52020SC0331  

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Table 51- Costs and benefits (“NET” values) to society (valuation of health impacts – both mortality and 
morbidity) per year – central (all values €bn 2015 prices, EU27) 

Approach to 

valuing mortality  

VSL 

VSL 

VSL 

VSL 

VSL 

VSL 

VOLY 

VOLY 

VOLY 

VOLY 

VOLY 

VOLY 

Net VSL 

Net VSL 

Net VSL 

Net VSL 

Net VSL 

Net VOLY 

Net VOLY 

Net VOLY 

Net VOLY 

Net VOLY 

Scenario 

Baseline 

OPT20 

OPT15 

OPT10 

OPT5 

MTFR 

2020 

 739  

- 

- 

- 

- 

- 

Baseline 

 251  

OPT20 

OPT15 

OPT10 

OPT5 

MTFR 

OPT20 

OPT15 

OPT10 

OPT5 

MTFR 

OPT20 

OPT15 

OPT10 

OPT5 

MTFR 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

2030 

2050 

 444  

 408  

 352  

 325  

 317  

 303  

 140  

 128  

 109  

 100  

 97  

 92  

 36  

 92  

 119  

 127  

 141  

 12  

 31  

 40  

 43  

 48  

 332  

 -    

 320  

 266  

 263  

 256  

 90  

 -    

 87  

 71  

 70  

 68  

- 

 12  

 66  

 69  

 77  

- 

 3  

 19  

 20  

 22  

As can be seen from the results in the table, there is a range in the monetised human health benefits 

(i.e. reduced costs) depending on the approach taken and scenario. Monetised benefits are smaller 

under the VOLY than VSL approach. The benefits increase, as expected, with the ambition of the 

scenario. The benefits reduce over time as more progress is made in the baseline, which erodes the 

additional benefit of further action under the mitigation scenarios. Across all scenarios, mortality 

effects contribute the vast majority of the overall valued effects: the share of morbidity effects in the 

total valuation of human health benefits ranges from 1-6% across scenarios and years under the VSL 

approach, to 5-19% under the VOLY approach. 

  Costs of measures (Indicator #6) 

Costs of air pollution emission control measures applied in the different policy scenarios, relative 

(additional) to the baseline scenario costs, are shown in Figure 80. Consistently with the results for 

emission reductions associated with the policy options analysed in this work, the additional costs of 

reaching 20 and 15 µg/m3 targets in 2030 and 2050, respectively, are very small, especially when 

considering total air pollution mitigation costs (see Section 7.1.2).  

The costs increase strongly for the scenarios addressing 10 and 5 µg/m3 targets with cost burden shared 

primarily between industry, residential sector, and agriculture. As discussed earlier (Section 6.2, 7.1.1, 

and Appendix 3), the feasibility of attaining the 5 ug/m3 policy target is very limited for a large number 

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of grid-cells for which even the MTFR scenario does not enable concentrations to reduce below 5 ug/m3 

and the costs would increase further, by over a factor of three, compared to the 5 ug/m3 policy case.  

Figure 80 - Air pollution control costs (EU-27 total) beyond the Baseline, for different policy scenarios and 
sectors; Source: GAINS model. 

Table 52– Air pollution control costs (EU-27 total) beyond the Baseline, per year, for different policy scenarios 
(all values €bn 2015 prices); Source: GAINS model. 

Scenario 

Power 

sector 

2030 

OPT20 

OPT15 

OPT10 

OPT5 

MTFR 

2050 

OPT15 

OPT10 

OPT5 

MTFR 

0.02 

0.30 

0.33 

0.41 

0.96 

0.01 

0.18 

0.18 

0.33 

Industry 

Residential  Transport  Agriculture 

Total 

0.19 

1.18 

2.40 

2.44 

13.09 

0.02 

2.47 

2.33 

13.00 

0.16 

0.72 

1.29 

1.87 

2.84 

0.01 

0.65 

1.45 

2.06 

0.01 

0.08 

0.08 

0.13 

1.14 

0.00 

0.02 

0.03 

0.10 

0.18 

1.00 

1.47 

2.16 

6.04 

0.01 

1.35 

2.09 

6.25 

0.56 

3.28 

5.58 

7.02 

24.06 

0.05 

4.67 

6.08 

21.74 

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Table 53- Air pollution control costs (by MS and EU-27) beyond the Baseline, for different policy scenarios in 
2030 (all values €bn 2015 prices); Source: GAINS model. 

Country 

OPT20 

OPT15 

OPT10 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
EU-27 

0.000 

0.000 

0.001 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.002 

0.000 

0.000 

0.000 

0.448 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.001 

0.094 

0.000 

0.010 

0.000 

0.000 

0.031 

0.026 

0.078 

0.040 

0.000 

0.107 

0.016 

0.005 

0.021 

0.026 

0.360 

0.187 

0.263 

0.000 

0.550 

0.007 

0.104 

0.000 

0.000 

0.021 

0.965 

0.001 

0.389 

0.068 

0.008 

0.000 

0.005 

0.034 

0.033 

0.142 

0.131 

0.009 

0.163 

0.015 

0.004 

0.017 

0.864 

0.418 

0.164 

0.190 

0.001 

1.020 

0.007 

0.103 

0.000 

0.002 

0.022 

0.897 

0.024 

0.426 

0.066 

0.011 

0.811 

0.004 

OPT5 

0.206 

0.208 

0.142 

0.110 

0.009 

0.234 

0.122 

0.030 

0.101 

1.009 

1.058 

0.174 

0.161 

0.023 

0.910 

0.041 

0.088 

0.005 

0.002 

0.169 

0.706 

0.101 

0.423 

0.056 

0.041 

0.816 

0.075 

MTFR 

0.585 

0.435 

0.337 

0.260 

0.042 

0.878 

0.595 

0.092 

0.781 

3.777 

4.089 

0.731 

0.559 

0.342 

2.042 

0.169 

0.263 

0.046 

0.009 

0.749 

2.313 

0.505 

1.042 

0.329 

0.123 

2.577 

0.393 

0.558 

3.278 

5.580 

7.021 

24.063 

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Table 54- Air pollution control costs (by MS and EU-27) beyond the Baseline, for different policy scenarios in 
2050 (all values €bn 2015 prices); Source: GAINS model. 

Country 

OPT15 

OPT10 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Rep. 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
EU-27 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.020 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.001 

0.027 

0.000 

0.000 

0.000 

0.000 

0.047 

0.017 

0.074 

0.102 

0.010 

0.100 

0.008 

0.003 

0.013 

0.490 

0.367 

0.134 

0.146 

0.000 

1.057 

0.000 

0.057 

0.000 

0.002 

0.003 

0.692 

0.030 

0.395 

0.059 

0.006 

0.855 

0.004 

OPT5 

0.155 

0.173 

0.156 

0.093 

0.010 

0.162 

0.104 

0.026 

0.074 

0.689 

0.869 

0.128 

0.147 

0.015 

1.008 

0.037 

0.067 

0.003 

0.001 

0.150 

0.621 

0.108 

0.365 

0.060 

0.044 

0.747 

0.067 

MTFR 

0.499 

0.404 

0.307 

0.224 

0.040 

0.758 

0.556 

0.081 

0.457 

3.405 

3.883 

0.702 

0.485 

0.311 

1.977 

0.158 

0.220 

0.044 

0.009 

0.710 

1.940 

0.453 

0.920 

0.315 

0.103 

2.432 

0.351 

0.049 

4.670 

6.079 

21.744 

The distribution of additional control costs associated with the air pollution technology in 2030, , is 

provided in Figure 81 below showing these costs in relation to GDP. OPT20 requires only minor 

additional effort in a limited number of countries. Efforts need to increase significantly to achieve 

OPT10. Further efforts, for all countries, are estimated to be required for the OPT5 case, but as shown 

before (Section 6.2, 7.1.1, and Appendix 3), there is an issue of feasibility in this scenario/model 

setting. There is a large increase in costs in MTFR (as shown above: over three times the total cost 

associated with OPT5). 

EU27 additional air pollution control costs in 2030 remain below 0.10% of EU27 GDP for all scenarios 

apart from the MTFR (where they increase to around 0.25%). For some individual Member States the 

additional costs reach or surpass 0.20% of national GDP in scenarios OPT15 and more ambitious 

scenarios and reach up to above 0.50% of national GDP in the MTFR scenario in a few MSs.  

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Figure 81 – Additional (compared to baseline) air pollution control costs in 2030 for policy scenario and MTFR, 
shown as % of GDP; GAINS model 

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Box – Sensitivity of the assessment to the allocation of grid cells 

The scenarios are assessed on the basis of a modelling approach which ‘optimises’ the selection of 

mitigation options in order to meet a given air pollutant concentration – i.e. mitigation options are 

selected to achieve emission reductions of a certain pollutant in ascending cost order, until 

sufficient abatement has been selected to meet the necessary air pollutant concentration limit. This 

optimisation occurs for each ‘grid cell’ (i.e. the spatial disaggregation of the model) individually and 

uses the highest concentration increment attained anywhere within the respective 28km grid cell as 

a constraint. In some cases however, additional analysis showed that the highest concentrations in 

some grid cells containing both EU and non-EU population (i.e. those cells on the EU border) are in 

fact driven by concentrations outside the EU border, typically due to border cities in the 

neighbouring country. In these cases, it is the higher concentrations beyond the EU border which is 

driving the measures taken by the model. Such situations were found along the Eastern and South-

eastern EU border to Belarus, Ukraine, Serbia, Bosnia-Herzegovina, and Turkey. As a sensitivity case, 

the optimization for attaining different ambient PM2.5 concentration levels was repeated but now 

excluding grid cells with cities close to the border but outside the EU. A total of 13 grid cells were 

excluded from the analysis as a result.  

The sensitivity test concluded that although some specific impacts change under particular scenarios 

change, the overall pattern of net benefits and BCR remains the same as the central analysis – i.e. 

under all sensitivity tests, the ranking of the net benefits or benefit-cost ratios between the 

scenarios does not change. Excluding these grid cells excluded several cells that had relatively high 

concentrations in the baseline. Hence under the scenarios, mitigation action was no longer required 

in these cells to achieve the air pollution standards. In turn, the emissions reduction and also the 

costs associated with mitigation was lower under the sensitivity analysis – hence the central analysis 

somewhat overstates mitigation costs for some scenarios (the following table presents the mitigation 

costs under the sensitivity and a comparison to the central analysis). The sensitivity case has a 

stronger impact on some scenarios in some years, relative to others. Namely, emission reductions 

under OPT15 in 2030, and OPT10 in 2050 are significantly reduced, with a smaller reduction of for 

OPT10 in 2030, and all other scenarios are broadly the same. This is driven by the baseline 

concentrations in both the EU and non-EU areas of the border cells, and how they compare to the 

different standards. Further detail is provided in Appendix 9. 

Table: Variance in mitigation costs between central and sensitivity analysis 

2030 

2050 

OPT20 

OPT15 

OPT10 

OPT5 

OPT15 

OPT10 

OPT5 

Central 

Sensitivity 

-560 

-560 

-3,280 

-5,580 

-7,020 

-992 

-5,107 

-7,020 

Difference 

0 

-2,288 

-473 

0 

-50 

-50 

0 

-4,670 

-6,080 

-3,704 

-6,080 

-966 

0 

  Macro-economic effects, international competitiveness and trade (Indicator #7) 

Air pollution has detrimental welfare impacts by affecting health outcomes. In addition, related 

healthcare expenditures, crop yield losses due to ozone, absence from work due to illness (including of 

dependent children) and lower productivity at work can imply a drag on the economy. Improving air 

quality can therefore bring economic gains. However, air pollution control comes at a gross cost, as it 

requires costly investments and purchases of abatement equipment. A priori, it is unclear whether air 

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pollution control policies therefore lead to net economic gains or losses, and how these are distributed 

across stakeholders. To shed some light on these trade-offs, the JRC has conducted a cost-benefit- 

analysis by linking the GAINS model with the JRC-GEM-E3 model. This has been done in previous work, 

such as the 1st and 2nd Clean Air Outlook (European Commission, 2022), and both models feature in a 

broader modelling toolbox e.g. in the assessment of the EU long-term climate strategy (Weitzel et al. 

2019). The key information that flows from GAINS to JRC-GEM-E3 is the abatement cost associated to 

further air pollution controls induced by more ambitious policy measures and targets. These costs serve 

as inputs into the JRC-GEM-E3 analysis. 

The JRC-GEM-E3 model represents the whole economy and the interactions between key actors: firms, 

households and governments in the EU and in the rest of the world. End-of-pipe abatement costs from 

GAINS are treated as costly (intermediate) expenditures on abatement goods and services, and 

therefore generate additional demand for the sectors that deliver these goods and services. 

Furthermore, the model captures the potential loss in competitiveness of firms that need to incur 

abatement costs by reflecting price-driven international trade flows. For households, a loss of income 

or raised expenditure on abatement technologies will imply that less funds are available to purchase 

other goods. The economic modelling framework covers these interactions to provide an economy-wide 

picture of the implications of additional air pollution control costs. 

On the benefit side, this analysis concentrates on productivity gains from clean air. The empirical basis 

stems from recent OECD work (Dechezleprêtre, Rivers, & Stadler, 2019) that quantifies the causal 

impact of PM2.5 pollution on productivity in the EU for the period 2000-2015. More specifically, we 

derive labour productivity gains by combining the point estimate on the impact of PM2.5 on GDP per 

worker, with the changes (compared to Reference) in population-weighted PM2.5 concentrations from 

the GAINS model. The corresponding changes in labour productivity feed into the JRC-GEM-E3 model, 

where labour constitutes an input to the production process of the various economic sectors. 

The results are displayed in  

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Table 55. They are complementary to estimates of the direct benefits brought by air pollution control 

measures presented earlier. Results are presented here as percentage changes compared to the 

baseline – in each column, the numbers on the left-hand side indicate the impact when the 

macroeconomic benefits from cleaner air are not considered (excluding market benefits), the numbers 

on the right side include market benefits of cleaner air.  

The key insight is that all scenarios improve aggregate economic outcomes in the EU compared to a 

situation of unchanged policy. The most ambitious 5 μg/m3 scenarios (i.e. 6 and 7) imply larger gross 

costs, but these are more than compensated for by productivity gains, as reflected by the positive 

impact on GDP and private consumption. The size of the net benefit increases with the ambition of the 

scenario – so OPT5 delivers a greater net benefit than OPT20. Although the level of mitigation action 

and associated costs increases with ambition, so too do the benefits – and the increase in the benefits is 

greater than the increase in costs as standards become more stringent. The net benefits in 2030 are 

greater than those in 2050. This is driven by the underlying reduction in emissions and improvement in 

concentrations which occurs anyway in the baseline. Overtime, these improvements reduce the amount 

of additional effort needed under the scenarios to achieve higher ambition standards, hence also 

reducing the associated impacts (costs and benefits) of the mitigation scenarios. 

With the exception of livestock-based agriculture, all sectors raise output compared to the baseline 

when productivity gains of clean air are accounted for. While productivity benefits limit output 

reduction in the livestock sector, they are not sufficient to fully offset output losses induced by higher 

abatement spending. 

Once the productivity gains from clean air are factored in, results indicate enhanced competitiveness of 

the EU economy as indicated by an improved trade balance and higher exports. With respect to 

exports, it is true that the additional mitigation costs will place upward pressure on prices, and ceteris 

paribus EU goods/services become less competitive. That said, under the scenarios there is also a more 

productive labour force, which implies more competitive industry as labour is an important production 

factor. This effect also feeds through to prices, with the net effect being a reduction in prices and 

increase in exports. Imports also increase  because there is an overall net increase in economic output, 

which subsequently leads to a net increase in income for households. This translates to a net increase 

in consumption, of which a portion will be imports, hence overall imports also increase. 

On the benefit side, this analysis concentrates on productivity gains from clean air. The empirical basis 

stems from recent OECD work (Dechezleprêtre et al. 2019) that quantifies the causal impact of PM2.5 

pollution on productivity in the EU for the period 2000-2015. More specifically, we derive labour 

productivity gains by combining the point estimate on the impact of PM2.5 on GDP per worker, with the 

changes (compared to Baseline) in population-weighted PM2.5 concentrations from the GAINS model. 

The corresponding changes in labour productivity feed into the JRC-GEM-E3 model, where labour 

constitutes an input into the production process of the various economic sectors. A few caveats are 

important to take into consideration when interpreting these results. Here, we focus exclusively on 

productivity benefits from clean air, which implies that other ‘market’ benefits are not included, such 

as reduced healthcare expenditures and increased crop yields. Furthermore, additional ‘non-market’ 

benefits, such as ecosystem impacts and reductions in premature mortality or life years lost due to air 

pollution, are not included in the results displayed in the table below. While these benefits are not 

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included in the economy-wide assessment in this section, they are discussed in other sections of this 

report. 

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Table 55 Results of macro-economic benefit-cost analysis. Source: JRC-GEM-E3. 

Cost only | Net 
effect incl. 
benefits 
% change 
relative to 
baseline 

Gross Domestic 
Product 
Private 
Consumption 

Exports* 

Imports** 

Sector output 

Crops 

Livestock 

20µg 

15µg 

10µg 

5µg 

15µg 

10µg 

5µg 

2030 

2030 

2030 

2030 

2050 

2050 

2050 

0 | 0.10 

-0.02 | 0.26 

-0.04 | 0.38 

-0.05 | 0.44 

0 | 0.03 

-0.02 | 0.29 

-0.03 | 0.36 

0 | 0.12 

0 | 0.11 

-0.02 | 0.34 

-0.03 | 0.49 

-0.04 | 0.57 

-0.02 | 0.32 

-0.03 | 0.46 

-0.03 | 0.56 

0.01 | 0.02 

0.03 | 0.06 

0.05 | 0.10 

0.07 | 0.13 

0 | 0.04 

0 | 0.04 

0 | 0 

-0.02 | 0.37 

-0.02 | 0.46 

-0.02 | 0.37 

-0.02 | 0.48 

0.04 | 0.08 

0.05 | 0.11 

-0.02 | 0.15 

-0.19 | 0.30 

-0.26 | 0.45 

-0.32 | 0.50 

0 | 0.06 

-0.17 | 0.38 

-0.30 | 0.36 

-0.09 | 0.05 

-0.45 | -0.06 

-0.62 | -0.05 

-1.01 | -0.36 

-0.01 | 0.05 

-0.54 | -0.10 

-0.91 | -0.37 

Power sector 

0 | 0.11 

0 | 0.30 

0.01 | 0.44 

0.01 | 0.50 

Fossil fuels 

-0.01 | 0.08 

-0.09 | 0.18 

-0.10 | 0.28 

-0.11 | 0.32 

Industry 

Services 

0 | 0.13 

0 | 0.09 

0.02 | 0.38 

0.01 | 0.53 

0.02 | 0.63 

0 | 0.26 

0 | 0.38 

0 | 0.45 

0 | 0.04 

0 | 0.03 

0 | 0.05 

0 | 0.03 

0.02 | 0.34 

0.02 | 0.41 

-0.04 | 0.24 

-0.03 | 0.29 

0 | 0.40 

0 | 0.29 

0.01 | 0.51 

0 | 0.37 

Notes: Economic outcomes of clean air policy in the EU. Source: JRC-GEM-E3. The first number in a cell, before the 

“|”, represents gross costs only. The second number in a cell (after the vertical line) represents the net effect, i.e. 

benefits minus costs. ; * positive exports denotes an increase in exports; ** positive imports denotes an increase in 

imports. 

  Social impacts 

   Effects of scenarios on spatial regions with a low/high proportion of population in a vulnerable 

age group (indicator #8) 

This section details the results of analysis to understand how the modelled changes in air quality are 

likely to impact spatial regions with a low/high proportion of residents who are likely to be vulnerable 

to changes in pollutant concentration due to their age. A description of the methodology used to 

undertake this analysis is detailed in Appendix 7. In summary, the approach takes the 2030 modelled air 

pollutant impacts across the different scenarios for the four pollutants with the highest documented 

impact on human health (PM2.5, PM10, NO2, Ozone), and overlays these with various mapped 

demographic characteristics to explore whether there a trends or patterns in the spatial distribution of 

effects across different demographic groups.  

The following subsections provide commentary as to how each scenario is predicted to change the 

concentration of each pollutant (PM2.5, PM10, NO2, Ozone) in scaled areas with low (quintile 1) or high 

(quintile 5) proportions of citizens whose health is most likely to be impacted by the changes in 

pollutant concentration due to their age. This analysis looks at the effects on spatial areas which have a 

low/high proportion of inhabitants under the age of 14 years old, or older than 65 years old.  

This section of the report provides a summary of the results of the analysis – detailed results are 

presented in Appendix 7. The analysis investigates whether there is a statistical correlation between 

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the proportion (low-high) of citizens in each demographic and the change in baseline concentration 

value, this was undertaken using the Spearman Rank Correlation technique. The results are presented 

in tabulated form for each pollutant at the end of this section.  

Correlation analysis of the changes in pollutant concentration from the 2030 baseline model 

A Spearman’s rank correlation analysis was undertaken for each pollutant, scenario and sensitivity 

group to investigate the link between demographic characteristic and level of air pollutant reduction. 

Results displaying a positive figure show a positive correlation - i.e. the reduction in air pollutant 

concentration is lower in the areas representing the lower proportion of the demographic (quintile 1), 

compared to the level of reduction in areas with a higher proportion (quintile 5). A negative value 

indicates the reverse. The maximum values, showing the strongest possible trend, displayed using this 

technique can only be -1 or 1, values close to 0 represent a weak trend. For the following tables, the 

quantity for each demographic rises with quintiles – i.e. the number of children or elderly is highest in 

quintile 5, and lowest in quintile 1. 

Table 56 Spearman rank correlation analysis of change in PM2.5 pollutant concentration to sensitive demographic  

Spatial 

Sensitivity 

scale 

class 

NUTS 3 

Citizens aged 

under 14 

Citizens aged 

over 65 

Pollutant correlation coefficient 

MTFR 

OPT_05mug  OPT_10mug  OPT_15mug  OPT_20mug 

-0.06 

-0.07 

-0.08 

-0.12 

-0.28 

-0.22 

-0.21 

-0.18 

-0.16 

-0.05 

Table 57 Spearman rank correlation analysis of change in PM10 pollutant concentration to sensitive demographic  

Spatial 

Sensitivity 

scale 

class 

NUTS 3 

Citizens aged 

under 14 

Citizens aged 

over 65 

Pollutant correlation coefficient 

MTFR 

OPT_05mug  OPT_10mug  OPT_15mug  OPT_20mug 

-0.06 

-0.07 

-0.08 

-0.12 

-0.28 

-0.23 

-0.21 

-0.19 

-0.17 

-0.06 

Table 58 Spearman rank correlation analysis of change in NO2 pollutant concentration to sensitive demographic  

Spatial 

Sensitivity 

scale 

class 

NUTS 3 

Citizens aged 

under 14 

Citizens aged 

over 65 

Pollutant correlation coefficient 

MTFR 

OPT_05mug  OPT_10mug  OPT_15mug  OPT_20mug 

0.09 

-0.02 

-0.03 

-0.02 

-0.25 

-0.37 

-0.28 

-0.29 

-0.27 

-0.08 

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Table 59 Spearman rank correlation analysis of change in Ozone pollutant concentration to sensitive 
demographic  

Spatial 

Sensitivity 

scale 

class 

NUTS 3 

Citizens aged 

under 14 

Citizens aged 

over 65 

Pollutant correlation coefficient 

MTFR 

OPT_05mug  OPT_10mug  OPT_15mug  OPT_20mug 

-0.36 

-0.39 

-0.35 

-0.29 

-0.31 

0.03 

0.08 

0.03 

-0.02 

0.02 

Table 57Error! Reference source not found. and Table 56Error! Reference source not found. show 

that for PM10 and PM2.5 respectively the pattern of results shows there is not a strong correlation 

between change in pollutant concentration under the modelled scenarios for children or for elderly 

groups. The table shows that the coefficient remains fairly constant across the scenarios, suggesting the 

pattern of effects remains consistent across scenarios. Table 58 shows similar findings with the respect 

to changes in NO2 pollutant, with the exception of elderly groups, where a moderate negative 

correlation is observed for several scenarios – i.e. the reductions in NO2 are found to be smaller for 

areas with higher numbers of elderly people, relative to areas with fewer elderly people.  

Table 59Error! Reference source not found. shows that for ozone there is a fairly strong correlation 

between quintile class and change in pollutant concentration for children, but the relationship for 

elderly groups is weak. For children, the correlation coefficients across all scenarios are negative – 

namely the reduction in air pollutant concentrations is greater for areas with a lower proportion of 

children. Again, the coefficient remains fairly constant across the scenarios, suggesting the pattern of 

effects remains consistent across scenarios.  

In summary, the effects appear to vary by pollutant and demographic characteristic. Under the 

mitigation scenarios, there is the potential for the elderly to benefit disproportionately less from 

reductions in PM2.5, PM10 and NO2; whilst children may benefit disproportionately less from changes in 

Ozone. This may be because these groups tend to live in areas with lower air pollution levels to begin 

with. A useful finding is that the pattern of impacts remains consistent across scenarios – i.e. all are 

predicted to have a similar distributional effect. 

  Societal effects (indicator #9) 

Taking action to achieve lower air pollutant standards will place a range of impacts on citizens, and 

different groups in society. Action will provide both benefits, namely through reductions in exposure to 

harmful air pollutants, but also costs. These effects could vary between different groups in society 

depending on a range of parameters. This study has taken a quantitative approach to considering the 

potential patterns of air pollution exposure effects across different groups, and has assessed the 

potential variation in costs between demographic groups qualitatively.  

Quantitative analysis of the distribution of air pollution reduction benefits 

The same approaches described within section 8.3.1 have been used to also understand the impacts of 

each modelled scenario on sensitive social groups. To understand the impacts, this analysis has used the 

euro per inhabitants (i.e. income per person), rate of unemployment and level of education datasets 

available from the Eurostat database. These datasets were only available at NUTS 2 spatial resolution. 

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This resolution is lower than that which was available to understand the impacts on sensitive 

demographic groups, meaning that the results from this analysis were more generalised than those 

shown in 8.3.1. Further detail on the results and underlying methodology can be found in Appendix 7. 

The following tables details the results from the analysis undertaken to understand the strength of 

correlations between the two factors. Generally across all combinations of pollutant, scenario and 

demographic variables, the correlation is weak. The only exception is for ozone and levels of education, 

where a moderate negative correlation is identified across all scenarios – i.e. the pollutant reduction 

scenarios appear to deliver smaller reductions in areas where there is a greater proportion of people 

with low levels of educational attainment. 

Table 60 Spearman rank correlation analysis of change in PM2.5 pollutant concentration to sensitive demographic  

Spatial 

scale 

NUTS 2 

Sensitivity class 

MTFR 

OPT_05mug  OPT_10mug  OPT_15mug  OPT_20mug 

Pollutant correlation coefficient 

Euros per 

inhabitant 

Rate of 

unemployment 

Proportion 

educated at 

levels 5-8 

institutions 

-0.08 

-0.08 

-0.25 

-0.21 

-0.01 

-0.03 

-0.02 

0.02 

-0.15 

-0.04 

-0.05 

-0.05 

-0.15 

-0.33 

-0.43 

Table 61 Spearman rank correlation analysis of change in PM10 pollutant concentration to sensitive demographic  

Spatial 

scale 

NUTS 2 

Sensitivity class 

MTFR 

OPT_05mug  OPT_10mug  OPT_15mug  OPT_20mug 

Pollutant correlation coefficient 

Euros per 

inhabitant 

Rate of 

unemployment 

Proportion 

educated at 

levels 5-8 

institutions 

-0.08 

-0.08 

-0.26 

-0.21 

-0 

0 

0.01 

0.04 

-0.14 

-0.03 

-0.05 

-0.04 

-0.15 

-0.33 

-0.42 

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Table 62 Spearman rank correlation analysis of change in NO2 pollutant concentration to sensitive demographic  

Spatial 

scale 

NUTS 2 

Sensitivity class 

MTFR 

OPT_05mug  OPT_10mug  OPT_15mug  OPT_20mug 

Pollutant correlation coefficient 

Euros per 

inhabitant 

Rate of 

unemployment 

Proportion 

educated at 

levels 5-8 

institutions 

0.04 

0.1 

-0.04 

-0.01 

0.03 

0 

-0.01 

-0.03 

-0.19 

-0.12 

0.15 

0.12 

0.02 

-0.11 

-0.31 

Table 63 Spearman rank correlation analysis of change in Ozone pollutant concentration to sensitive 
demographic  

Spatial 

scale 

NUTS 2 

Sensitivity class 

MTFR 

OPT_05mug  OPT_10mug  OPT_15mug  OPT_20mug 

Pollutant correlation coefficient 

Euros per 

inhabitant 

Rate of 

unemployment 

Proportion 

educated at 

levels 5-8 

institutions 

-0.19 

-0.18 

-0.28 

-0.26 

-0.13 

-0.12 

-0.1 

-0.1 

-0.22 

-0.19 

-0.44 

-0.45 

-0.49 

-0.49 

-0.48 

Qualitative analysis of distribution of costs 

There will be costs associated with the implementation of mitigation techniques to reduce emissions of 

air pollutants. As for the benefits, the costs falling on different groups in society, economic sectors and 

countries may vary. Patterns of distribution in how the costs fall will depend on a series of parameters 

or indicators. Impacts could vary at the: 

• 

• 

• 

Member State level: EU countries (with different GDPs, employment levels, sectors, etc.) 

could be affected differently by costs as they would have to implement different 

mitigation measures.  

Sectoral level: different sectors (i.e. industry, agriculture) could be impacted differently 

by these costs, also affecting employment levels and wages. 

Household and social level: households with different income and education levels and age 

profile (i.e. elderly people, children) could also be affected in different ways. 

No definitive conclusions can be drawn at this stage regarding distributional patterns of costs associated 

with the mitigation potential as the distribution of costs will be strongly determined by the specific 

policy actions adopted in each Member State, region or local level to deliver the technical 

abatement. However, the analysis has identified a number of risk factors (and opportunities) – i.e. 

factors that suggest there is  potential for a certain societal group to face disproportionate costs, 

relative to other groups. These are only risk factors because (as noted above), the true risk will depend 

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on the specific policy mechanisms. Furthermore, competent authorities could introduce complementary 

policies to mitigate any potential distributional effects. However, if left unchecked, these risk factors 

could evolve into disproportionate impacts for more vulnerable groups in society. Opportunities have 

also been identified – i.e. where there is the potential for vulnerable groups to benefit proportionally 

more from mitigation measures.  

A number of risk factors have been identified for lower income households. Meanwhile, there is no 

strong evidence to conclude that demographic  groups such as children or elderly people would have to 

bear higher costs than other groups. Risk factors (and opportunities) have been identified by 

considering potential patterns of impacts on a Member State, sectoral and household level. In some 

cases, costs will be placed directly on sectors and households, in others the potential impacts (and 

risks) will be indirect. The table below sets out the risk factors identified in this analysis. 

Table 64. Summary of societal impacts of air pollution and societal impacts of air pollution abatement measures, 
including resulting inequalities 

Viewpoint 

Risks 

Opportunities 

• 

Costs likely to be greater for certain 

(e.g. energy intensive) sectors of the 

economy. This could have an indirect 

effect on the viability of some 

businesses in these sectors, 

employment and linked supply 

chains.   

•  Where costs feed through to impacts 

on employment, it is important to be 

Sectoral (indirect 

mindful of potential variations in 

impacts through 

labour force demographics between 

businesses) 

affected sectors. 

• 

SMEs in affected sectors could be at 

greater risk as they have fewer 

resources and activities over which 

to spread additional costs 

• 

Costs could be passed through to 

consumers through higher prices, 

which could carry indirect 

disproportionate effects for different 

households.  

• 

Productivity benefits from improved 

health of workforce are estimated in the 

modelling to outweigh the additional 

costs for all sectors (with the exception 

of agriculture) 

• 

Agriculture will also benefit from 

reduced crop losses, as shown by the 

GAINS models and efficiency gains from 

mitigation measures (e.g. precision 

farming) 

• 

The development of low-emission goods 

and services industries could become 

more competitive as governments 

promote these mitigation policies 

creating jobs and increasing wages 

• 

Abatement measures that support 

energy efficiency and use of renewable 

energy help SMEs stay competitive in the 

mid- and long-term and improve 

resilience towards volatile fossil fuel 

prices 

•  Households using solid or more 

• 

Some mitigation measures (e.g. energy 

emissions intensive fuels for heating 

efficiency) may lead to private benefits 

(and cooking) will likely be more 

(e.g. energy bill reductions) 

Direct household 

effective. As such, some Member 

• 

Poorer households tend to use public 

impacts 

States (where use of solid fuels is 

transport to a greater extent, and as 

more prevalent) will be likely more 

such may benefit most from 

affected, and Member States should 

improvements to service provision and 

also be mindful of potential 

networks. 

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Viewpoint 

Risks 

Opportunities 

demographic variance in the use of 

solid fuels when implementing 

additional abatement 

•  Households will also face varying 

costs depending on their transport 

behaviour. Households with greater 

private transport use will face 

additional costs where these sources 

are targeted by Member States, and 

policy-makers should pay attention 

to how emissions are targeted and 

who may be most affected. 

Households may also face additional 

costs of using public transport, 

depending on how improvements are 

funded 

As shown in the table, there are a number of risk factors and opportunities for low income households 

from efforts to implement mitigation measures. The potential for distributional effects will need to be 

carefully managed by competent authorities to ensure that opportunities are seized, and risks managed 

properly. 

  Employment impacts (Indicator #10) 

The JRC-GEM-E3 modelling results also include outcomes on employment changes by sector. In these 

simulations, we have assumed that wage setting is flexible such that it can fully accommodate labour 

market adjustments. This implies that aggregate, national unemployment levels are driven by 

fundamental factors that are unaffected by clean air policy. In other words, this assumption implies 

that the results will not pick up any potential aggregate net job creation associated with increased GDP 

and output levels as shown in Table 55 , and the results may therefore be interpreted as conservative 

estimates. 

The results displayed in Table 65 indicate two consistent findings across all scenarios and years. First, 

we observe a creation of jobs in industry, which relates directly to the production of equipment 

required to abate emissions and the associated investments. While industry also faces increased 

abatement costs as shown in Figure 80, in terms of net effect on jobs, this is more than offset by 

increased demand for abatement goods from all sectors (including households). Second, the agricultural 

sector experiences job losses compared to the reference, which relates to output losses (livestock 

sector) or a transition of workers into the ‘industry’ sector (from crops sector).  

Overall, the magnitude of the employment changes is limited in relative terms such that they may be 

largely absorbed by ongoing labour market dynamics (entry into, and exit from, the labour market), and 

may be dwarfed by other economic developments. One caveat worth mentioning here is that the 

productivity benefits are applied uniformly across all sectors. A stronger empirical evidence base would 

help refining (the sector-specific elements of) the analysis, e.g. by differentiating productivity impacts 

of air pollution for vulnerable workers.  

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Table 65. Employment transition across sectors in the EU.. 

Cost only | Net effect 
(benefit-cost) 

1000 jobs, change rel. 
to baseline 

Employment 

20µg 

15µg 

10µg 

5µg 

15µg 

10µg 

5µg 

2030 

2030 

2030 

2030 

2050 

2050 

2050 

Crops 

-1 | -2 

-15 | -17 

-18 | -18 

-19 | -19 

0 | 0 

-10 | -9 

-17.4 | -16 

Livestock 

-2 | -3 

-20 | -24 

-23 | -29 

-25 | -31 

0 | -1 

-17 | -20 

-18.9 | -22 

Power sector 

0 | -2 

0 | -6 

0 | -7 

0 | -8 

0 | -1 

0 | -4 

0.2 | -5 

Fossil fuels 

0 | 0 

0 | 0 

0 | 0 

0 | -1 

0 | 0 

0 | 0 

0 | 0 

Industry 

Services 

3 | 24 

25 | 81 

30 | 104 

34 | 115 

0 | 7 

15 | 66 

22.6 | 81 

1 | -17 

10 | -33 

11 | -49 

10 | -57 

0 | -6 

12 | -33 

13.5 | -38 

Source: JRC-GEM-E3. Given the assumption of flexible wage setting, positive and negative employment effects 

balance out for a given year and scenario. Adding of numbers in a given column of this table does not yield zero in 

all cases due to rounding 

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9  Analysis of interventions 

  Overview 

All 69 interventions across the 27 Intervention Areas have been assessed based on their effectiveness, 

efficiency and coherence and have been scored against the 12 indicators. The detail of the analysis is 

set out in the Assessment Sheets presented in the Appendix 10. This section presents a summary of the 

analysis of the interventions across each Policy Area. 

The classification used to determine the significance of the impacts against the 12 indicators is 

presented below together with the colour coding used in the summary analysis tables included in this 

section.  

Table 66 Classification to determine the significance of impacts  

[Note: Where significance is classified as a range (to reflect multiple variants within an intervention), the colour 

coding is based on the most significant impact] 

+++  

++   

+ 

(+)   

+/- 

0 

(-) 

- 

- - 

- - - 

Very significant direct positive impact (e.g. Indicator 1 – Air Quality: full 
alignment WHO AQG for PM2.5)  
Significant direct positive impact 

 Small direct positive impact  

Indirect positive impact  
Both direct positive and negative impacts, and balance depends on how 
implemented  
No impact or only very indirect impacts 

Indirect negative impact 

Small direct negative impact 

Significant direct negative impact 
Very significant direct negative impact (e.g. Indicator 6 – Mitigation Costs: 
costs of maximum feasible technical potential (MTFR) and more) 

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  Policy area 1 

  Summary of analysis 

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+++ 

--- 

Revise  standards  for  annual  PM2.5  A  sample  of  variants  has  been  selected  for  the  modelling  in 
distinct 5 ug steps. More ambitious standards can achieve greater improvements in air quality, with 
corresponding  benefits  for  health  and  ecosystems.  Administrative  burden  will  also  scale  with 
ambition (impacting Member State competent authorities) as the more ambitious the standard, the 
more  new  zones  will  be  identified  as  requiring  measures  to  avoid  exceedances.  Similarly, 
mitigation/adjustment  costs  increase  with  ambition.  The  costs  of  such  action  are  uncertain  and 
depend on the starting point for each one, but these could imply significant change in behaviour at 
local  or  national  level.  As  the  level  of  ambition  increases,  the  cost  of  mitigation/adjustment 
measures will increase on a non-linear basis. There are several challenges for implementation (see 
Section 9.2.2). Specific to PM2.5 is the fact that this pollutant may be emitted directly by  natural 
sources. It is also a transboundary pollutant. The extent to which standards can address these issues 
is uncertain. Stakeholders firmly recognise the value of an annual average standard for PM2.5, which 
applies as a limit value to all territories in the EU, but opinions vary on what level of ambition is 
appropriate  by  when.  [BCR:  High*  (*Compliance  which  more  ambitious  standards  requires  non-
technical or local mitigation, the costs of which are uncertain)] 

0  to 
+++ 

0  to 
+++ 

0  to 
+++ 

0  to 
+++ 

0 to + 

0 to -
-- 

+ / - 

0  to 
++ 

+ / - 

0 

0  to 
+++ 

0 to -
-- 

Introduce standards for daily PM2.5: The intervention considers the introduction of a new standard. 
Variants  take  the  same  approach  as  described  for  O1.  Short-term  standards  are  not  modelled 
explicitly, and hence judgements regarding the balance of costs and benefits are more uncertain. 
Greater health benefits are typically associated with chronic exposure (in assessment), but where 
the risk of peaks is quite high and considering this intervention in isolation, the benefits would be 
much more significant. Administrative burden will also scale with ambition (impacting Member State 
competent authorities). In addition, short-term compliance measures to tackle peak concentrations 
specifically  may  be  more  disruptive  in  nature  (albeit  for  a  short-time)  and  carry  a  higher  cost. 
Challenges for implementation are the same  as for O1. It appears that there is merit in having a 
standard  to  manage  peak  alongside  annual  average  concentrations  –  this  is  underlined  by 
stakeholders and the advice of the WHO, who explore that even a small number of extreme peaks 
could have a significant impact. [BCR: High]. The indicators present a range as the significance of 
impacts will depend on the level of standard set. It is challenging to precisely define the level at 
which  the  indicator  score  would  change.  That  said,  based  on  the  modelling  and  wider  evidence 

195 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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gathering, expert judgement suggests that: low (non-zero) impacts could be associated with a 60 
ug/m3 standard (99th percentile), moderate impacts with a 40 ug/m3 standard (99th percentile), and 
the  highest  scoring  associated  with  a  15  ug/m3  standard  (99th  percentile)  –  note  these  standards 
would be different where a different percentile (i.e. number of permitted exceedances per year) 
was considered. 

0  to 
++ 

0  to 
++ 

0  to 
++ 

0  to 
++ 

0  to 
++ 

0 to -
- 

0 to + 

0  to 
+++ 

+ / - 

0 to + 

0  to 
++ 

0 to -
- 

Revise average exposure standards for PM2.5: The extent to which this intervention contributes to 
air quality improvements is partly dependent on the level of ambition. However, regardless of the 
level of ambition, revisions to average exposure targets can facilitate targeted reductions of PM2.5 
and attaining the reduction obligations is expected to deliver health benefits. A benefit of setting 
average  exposure  targets  is  that  they  can  complement  limit  values  by  targeting  background 
concentrations more specifically. Benefits to ecosystems will occur as a co-benefit of the measures 
implemented to attain the reduction targets. Costs can be significant depending notably on the level 
of  ambition,  arising  primarily  from  measures  to  attain  the  reduction  targets  and  administrative 
burden.  There  is  potential  to  reduce  the  administrative  burden  by  taking  more  coordinated  and 
centralised action. [BCR: High] 

0  to 
+++ 

0  to 
+++ 

0  to 
+++ 

0  to 
+++ 

0 to + 

0 to -
-- 

0 to + 

0  to 
+++ 

+ / - 

0 to + 

0  to 
+++ 

0 to -
- 

Revise standards for annual PM10: Modelling shows that this intervention could have a significant 
positive  impact  on  air  quality.  The  health effects  across  the  variants  will  scale  with  the  level  of 
ambition,  even  if  health  effects  are  more  closely  associated  with  exposure  to  finer  particulate 
matter (PM2.5). The mitigation costs of lower standards for PM10 have not been modelled. Many of 
the measures which mitigate PM2.5 would also mitigate PM10 emissions, hence the measures and costs 
would  be  similar.  Administrative  burden  will  also  scale  with  ambition  (impacting  Member  State 
competent authorities). There are several challenges for implementation (see discussion for Policy 
Area  1).  Stakeholders  firmly  recognise  the  value  of  an  annual  average  standard  for  PM10,  which 
applies as a limit value across all territories of the EU. Furthermore, stakeholders also affirm the 
additional value of a standard for PM10 alongside PM2.5 and show a general interest for improvement. 
However, opinion varies on what level of ambition is appropriate and by when it should be achieved. 
[BCR: high]. The indicators present a range as the significance of impacts will depend on the level 
of standard set. It is challenging to precisely define the level at which the indicator score would 
change. That said, based on the modelling and wider evidence gathering, expert judgement suggests 
that: low (non-zero) impacts could be associated with a 30 ug/m3 standard, moderate impacts with 
a 20 ug/m3 standard, and the highest scoring associated with a 15 ug/m3 standard. 

0  to 
+++ 

0  to 
+++ 

0 to + 

0 to + 

0 to + 

0 to -
-- 

+ / - 

0  to 
++ 

+ / - 

0 

0  to 
+++ 

0 to -
- 

Revise  standards  for  daily  PM10:  Short-term  standards  are  not  modelled,  and  hence  judgements 
regarding the balance of costs and benefits are more uncertain. Greater health benefits are typically 
associated  with  chronic  exposure  and  with  PM2.5,  but  where  the  risk  of  peaks  is  quite  high  and 
considering  this  intervention  in  isolation,  the  benefits  would  be  much  more  significant.  The 
mitigation costs will increase with the level of ambition and will depend on the action taken. Expert 
judgement suggests many of the actions taken to mitigate peak concentrations will be the same as 
those to tackle annual average concentrations, which means the costs  may be similar in order of 
magnitude. Administrative burden will also scale with ambition (impacting Member State competent 
authorities). There are several challenges for implementation (see  Section 9.2.2). It appears that 

O3

P1

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there is merit in having a standard to manage peak alongside annual average concentrations – this is 
underlined by stakeholders and the advice of the WHO, who explore that even a small number of 
extreme peaks could have a significant impact. Stakeholders voted positively that they see additional 
value in a standard to manage peak concentrations of PM10. However, the additional value of a short-
term PM10 standard may be limited if set alongside a corresponding standard for PM2.5, since both 
are likely to share similar sources and hence, control strategies [BCR: High] The indicators present 
a range as the significance of impacts will depend on the level of standard set. It is challenging to 
precisely  define  the  level  at  which  the  indicator  score  would  change.  That  said,  based  on  the 
modelling and wider evidence gathering, expert judgement suggests that: moderate impacts with a 
50-45 ug/m3 standard, and the highest scoring associated with a 45 ug/m3 standard. 

0  to 
++ 

0  to 
++ 

0  to 
++ 

0  to 
++ 

0 to + 

0 to -
- 

0 to + 

0  to 
++ 

+ / - 

0 to + 

0  to 
++ 

0 to -
- 

Introduce average exposure standards for PM10: The extent to which this intervention contributes 
to air quality improvements is partly dependent on the level of ambition. A benefit of setting average 
exposure targets is that they can complement limit values by targeting background concentrations 
more specifically. Benefits to ecosystems will occur as a co-benefit of the measures implemented to 
attain the reduction targets. Costs can be significant, depending notably on the level of ambition, 
and arising primarily from measures to attain the reduction targets and administrative burden. There 
is potential to reduce the administrative burden by taking more coordinated and centralised action. 
An  average  exposure  standard  for  PM10  may  not  offer  significant  additional  value  alongside  the 
similar existing standard for PM2.5, since both are likely to share similar sources and hence, control 
strategies. [BCR: Medium to Low] 

0  to 
+++ 

0  to 
++ 

0  to 
+++ 

0 to + 

0  to 
++ 

0 to -
- 

0 to + 

0 to + 

+ / - 

0 to + 

0  to 
++ 

0 to -
-- 

Revise  standards  for  annual  NO2:  The  health  benefits  of  action  targeting  the  revision  of  NO2 
concentrations  may  be  smaller  (assuming  there  are  no  co-benefits  by  way  of  particulate  or  GHG 
emission reductions). The mitigation costs of lower standards for NO2 have not been modelled, as 
such contrasting benefits and costs is more uncertain.  The modelling does show however a broad 
alignment with a 20 µg/m3 standard by 2030, and with the WHO Air Quality Guidelines by 2050, with 
only a small number of people which remain exposed to concentrations above these levels (around 
4-  6  million  respectively).  Hence  the  additional  costs  and  benefits  of  these  options  are  both 
negligible  (although  in  practice  a  reduction  in  the  standard  will  help  reinforce  this  delivery). 
Increasing ambition above the baseline will require the uptake of measures not captured in GAINS, 
and hence for which the costs are uncertain. However, expert judgement would suggest that costs 
of localised activity may be more disruptive and imply a higher cost (albeit at a local level). Several 
challenges  for  implementation  have  been  identified  (see  Section  9.2.2).  Stakeholders  firmly 
recognise the value of an annual-average standard for NO2, applying as a limit value to all territory. 
Furthermore, stakeholders also show a general interest for improvement but opinion varies on what 
level of ambition is appropriate and by when it should be achieved. The majority of stakeholders 
feel alignment with the WHO Air Quality Guidelines would not be appropriate by 2030, but most feel 
a target in the range from 20-30 µg/m3 would be achievable, with full alignment to 2050.  [BCR: 
high]  The  indicators  present  a  range  as  the  significance  of  impacts  will  depend  on  the  level  of 
standard set. It is challenging to precisely define the level at which the indicator score would change. 
That said, based on the modelling and wider evidence gathering, expert judgement suggests that: 
low (non-zero) impacts could be associated with a 30 ug/m3 standard, moderate impacts with a 20 
ug/m3 standard, and the highest scoring associated with a 10 ug/m3 standard. 

P3

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0  to 
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0 to + 

0  to 
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0 to + 

0 to -
-- 

+ / - 

0 to + 

+ / - 

0 

0  to 
++ 

0 to -
-- 

Revise/introduce standards for hourly/daily NO2: The measure considers both the existing standard 
(1-hour) and the potential introduction of a new (24-hour) standard. In isolation, there is a strong 
case for a standard managing NO2 peak concentrations. It appears that there is also merit in having 
a  standard  to  manage  peak  alongside  annual  average  concentrations  –  this  is  underlined  by 
stakeholders and the WHO Air Quality Guidelines, who explore that even a small number of extreme 
peaks  could  have  a  significant  impact.  However,  the  effectiveness  of  a  peak  concentration  as  a 
safety net (and indeed its additional value over an annual standard) decreases with the number of 
allowed exceedance days per year. Short-term standards are not modelled, and hence judgements 
regarding the balance of costs and benefits is more uncertain. Greater health benefits are typically 
associated  with  chronic  exposure,  but  where  the  risk  of  peaks  is  quite  high  and  considering  this 
intervention  in  isolation,  the  benefits  would  be  much  more  significant.  The  mitigation  costs  will 
increase with the level of ambition and will depend on the action taken. Expert judgement suggests 
many of the actions taken to mitigate peak concentrations will be the same as those to tackle annual 
average concentrations – which implies the costs may be a similar order of magnitude. Administrative 
burden will also scale with ambition (impacting Member State competent authorities). [BCR: High] 
The indicators present a range as the significance of impacts will depend on the level of standard 
set. It is challenging to precisely define the level at which the indicator score would change. That 
said,  based  on  the  modelling  and  wider  evidence  gathering,  expert  judgement  suggests  that: 
moderate impacts with a daily 40 ug/m3 standard, and the highest scoring associated with a daily 
25 ug/m3 standard. 

0  to 
++ 

0 to + 

0  to 
++ 

0 to + 

0 to + 

0 to -
- 

0 to + 

0 to + 

+ / - 

0 to + 

0 to + 

0 to -
- 

Introduce average exposure standards for NO2: The impact on air quality and ecosystems will vary,  
notably with the level of ambition, and benefits only become significant with medium to high levels 
of ambition. A benefit of setting average exposure targets is that they can complement limit values, 
and target background concentrations specifically, rather than limiting focus on pollution hotspots. 
This is also important for NO2 as a precursor, including to PM, but less important overall for NO2 
given the more location specific nature of exposure. Costs can be significant, arising primarily from 
measures to attain the reduction targets and administrative burden.  There is potential to reduce 
the  administrative  burden  by  taking  more  coordinated  and  centralised  action.  Should  an  average 
exposure indicator be introduced, limit values applying in all places would be required to ensure 
that emissions reductions happen at all hotspots and ensure that the benefits achieved by more and 
less disadvantaged groups are more proportionate [BCR: Medium] 

0  to 
+++ 

0 to + 

0  to 
+++ 

0 to + 

0 to + 

0 to -
-- 

0 to - 

0 to + 

+ / - 

0 

0 to + 

0 to -
-- 

Introduce standards for peak-season O3: The effectiveness of the intervention will scale vary with 
the level of ambition. However, given high levels of existing exceedance, the benefit to air quality 
is  expected  to  be  high.  Human  health  benefits  tend  to  be  more  linked  with  exposure  to  other 
pollutants and hence can be small. Likewise, ecosystem effects typically comprise a lower proportion 
of the overall benefit of air quality action, relative to human health effects (albeit this is based on 
an evidence base which has predominantly focused on the valuation of human health effects, for 
which by extension is more well explored and understood). The cost of achieving different standards 
for O3 have not been modelled directly so costs are uncertain. Costs will increase with the level of 
ambition. 

Q2

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Controlling  ozone  concentrations  is  complex  and  challenging  and  is  driven  in  part  by  control  of 
precursors  but  also  by  the  meteorological  conditions.  As  such  it  is  questionable  whether  very 
ambitious standards for ozone would be feasible in all locations. This is perhaps underlined by the 
difference  of  opinion  amongst  stakeholders  as  to  whether  limit  or  target  values  would  be  most 
appropriate. Furthermore, there is currently broad exceedances of both the existing EU target value 
and the WHO Air Quality Guidelines, as such substantial effort would be required to meet an even 
stricter target, whereas the benefits of such action (at least in economic impact assessment) often 
rank below action taken around other pollutants. There are several challenges for implementation 
(see Section 9.2.2). [BCR: High* (*Controlling ozone concentrations is complex and challenging, as 
such it is questionable whether very ambitious standards for ozone would be feasible in all locations)] 

0  to 
+++ 

0 to + 

0  to 
++ 

0 to + 

0 to + 

0 to -
-- 

0 to - 

0 to + 

+ / - 

0 

0 to + 

0 to -
-- 

Revise  standards  for  8-hour  O3:  There  remains  a  clear  need  for  a  standard  to  regulate  peak 
concentrations of ozone. However, controlling ozone concentrations is complex and challenging, and 
is  driven  in  part  by  control  of  precursors  but  also  by  the meteorological  conditions.  As  such  it  is 
questionable whether very ambitious standards for ozone would be feasible in all locations. This is 
perhaps underlined by the different of opinion amongst stakeholders as to whether limit or target 
values  would  be  most  appropriate.  Given  the  size  of  existing  levels  of  exceedance,  and  the 
challenges in controlling ozone concentrations, the costs of increasing ambition or switching to a 
limit value might be significant. Human health benefits tend to be more linked with exposure to 
other  pollutants  and  hence  can  be  small.  Likewise,  ecosystem  effects typically  comprise  a  lower 
proportion of the overall benefit of air quality action, relative to human health effects (albeit this 
is based on an evidence base which has predominantly focused  on the valuation of human health 
effects,  for  which  by  extension  is  more  well  explored  and  understood).  Several  challenges  for 
implementation  have  been  identified  (see  Section  9.2.2).  [BCR:  High*  (*Controlling  ozone 
concentrations  is  complex  and  challenging,  as  such  it  is  questionable  whether  very  ambitious 
standards  for  ozone  would  be  feasible  in  all  locations)]  The  indicators  present  a  range  as  the 
significance of impacts will depend on the level of standard set. It is challenging to precisely define 
the level at which the indicator score would change. That said, based on the modelling and wider 
evidence gathering, expert judgement suggests that: moderate impacts would be associated with a 
120-100 ug/m3 standard, and the highest scoring associated with a 100 ug/m3 standard. 

0  to 
++ 

0 to + 

0  to 
++ 

0 to + 

0 to + 

0 to -
- 

0 to - 

0 to + 

+ / - 

0 

0 to + 

0 to -
- 

Introduce average exposure standards for O3: The impact on air quality and ecosystems will vary,  
notably with the level of ambition, and benefits only become significant with medium to high levels 
of ambition. A benefit of setting average exposure targets is that they can complement target and 
limit  values,  and  target  background  concentrations  specifically.  Costs  can  be  significant,  arising 
primarily  from  measures  to  attain  the  reduction  targets  and  administrative  burden.  There  is 
potential to reduce the administrative burden by taking more coordinated and centralised action. It 
is  uncertain  whether  an  average  exposure  standard  would  offer  a  useful  complement  and  afford 
additional management options in the case of O3, given the specific chemical characteristics of ozone 
generation and its links with meteorological conditions (resulting in pronounced local and year-to-
year variability). [BCR: Medium – Low] 

0 to + 

0 to + 

0 to + 

0 to + 

0 to + 

0 to - 

0 

0 

0 

0 

0 to + 

0 to - 

Revise standards for annual SO2: Revisions to this standard were not modelled and therefore the 
balance  of  costs  and  benefits  is  more  uncertain.  There  has  been  substantial  progress  around  SO2 
emissions  and  concentrations  historically.  This  may  also  suggest  that  a  majority  of  the  low-cost 

R2

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actions may have already been captured. Furthermore, the benefits per tonne of pollutant abated 
are smaller than for other pollutants (e.g. PM2.5). The WHO did not include an AQG recommendation 
around long-term exposure to SO2 with which an EU standard targeting human health could align. In 
addition, stakeholders provided limited input regarding the value and level of such a standard [BCR: 
Medium] The indicators present a range as the significance of impacts will depend on the level of 
standard set. It is challenging to precisely define the level at which the indicator score would change. 
That said, based on the modelling and wider evidence gathering, expert judgement suggests that: 
low (non-zero) impacts would be associated with a 20 ug/m3 standard. 

0 to + 

0 to + 

0 to + 

0 to + 

0 to + 

0 to - 

0 

0 

0 

0 

0 to + 

0 to - 

Revise standards for daily/hourly SO2: This measure considers both: (a) changes to the existing EU 
limit values and (b) addition to or substitution of the existing EU standard with alternative short-
term standards in the WHO Air Quality Guidelines. Revisions to this standard were not modelled and 
so the  balance of costs and benefits is more uncertain. Based on the monitoring data, there was 
broad compliance with the existing EU  standards in 2019. The monitoring data also suggests high 
levels of compliance with lower standards. Given overlap in key sources, there is an important link 
to  the  interventions  setting  standards  for  PM,  as  action  to  achieve  these  targets  will  also  drive 
progress towards this intervention. No monitoring data is available over a 10-minute period, which 
makes  it  challenging  to  draw  conclusions  around  the  impact  and  merit  of  introducing  a  new  10-
minute standard alongside, or instead of, other short-term standards for SO2. As described for S1, 
historical  progress  for  SO2  may  suggest  that  low-cost  actions  have  already  been  captured. 
Stakeholders propose  that the WHO standards could be met with limited additional effort. [BCR: 
Medium] The indicators present a range as the significance of impacts will depend on the level of 
standard set. It is challenging to precisely define the level at which the indicator score would change. 
That said, based on the modelling and wider evidence gathering, expert judgement suggests that: 
low (non-zero) impacts would be associated with a 40 ug/m3 standard. 

0 to + 

0 to + 

0 

0 to + 

0 

0 to - 

0 

0 

0 

0 

0 to + 

0 to - 

Revise standards for daily/8-hour CO: This measure considers both: (a) changes to the existing EU 
limit value and (b) addition to or substitution of the existing EU standard with alternative short-term 
standards  in  the  WHO  Air  Quality  Guidelines.  Based  on  the  monitoring  data,  there  was  broad 
compliance with the existing EU standards in 2019. The monitoring data also suggests high levels of 
compliance with lower standards. From the modelling performed, a certain level of improvement 
can  be  made  through  abatement  measures  for  moderate  cost.  However,  achieving  further 
improvements  going  beyond  the  WHO  AQGs  will  require  the  take  up  of  non-technical  or  local 
measures not captured by the modelling, thus the costs are uncertain. Given overlap in key sources, 
there is an important link to the interventions setting standards for PM, as action to achieve these 
targets  will  also  drive  progress  towards  this  intervention.  Health  benefits  are  more  commonly 
associated  with  PM2.5,  as  such  the  benefits  per  tonne  of  CO  reduction  are  relatively  lower. 
Introducing new standards will introduce additional complexity and administrative burden for public 
authorities. Stakeholders propose that the existing EU standards can be met with limited additional 
effort and propose to remain at the existing standard. For the introduction of an additional standard 
the response to the targeted stakeholder was uncertain.  [BCR: Medium] 

0 to + 

0 to + 

0 

0 

0 

0 to - 

0 

0 

0 

0 

0 

0 to - 

Revise standards for annual benzene: Monitoring data suggests there is broad compliance with the 
existing  standard  in  2019  and  low  exceedances  relative  to  the  WHO  Air  Quality  Guidelines,  not 
accounting for further improvements in the baseline. The negative impact of benzene is however 

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also lower in relation to  other pollutants. [BCR: Low/medium] The indicators present a range as 
the significance of impacts will depend on the level of standard set. It is challenging to precisely 
define the level at which the indicator score would change. That said, based on the modelling and 
wider  evidence  gathering,  expert  judgement  suggests  that:  low  (non-zero)  impacts  could  be 
associated with a 5 ug/m3 standard, and moderate impacts with a 1.7 ug/m3 standard. 

0  to 
++ 

0 to + 

0 

0 to + 

0 to + 

0 to - 

+/- 

0 to + 

+/- 

+/- 

0 to + 

0 to -
-- 

Revise standards for annual benzo(a)pyrene: This intervention considers both: (a) changing from 
target  to  limit  value  and  (b)  aligning  the  standard  with  the  WHO  Guideline.  Emissions  and 
concentrations of BaP have been modelled directly and reductions in the baseline are anticipated to 
be  significant  compared  to  the  baseline  but  smaller  compared  to  other  pollutants.  A  moderate 
number  of  sites  will  remain  in  exceedance  in  2030  in  the baseline,  with  high  BaP  concentrations 
primarily occurring in specific regions in three Member States. The number of sites exceeding could 
be minimised through further measures. To 2050, there is broad compliance with the existing EU 
standard under the baseline already, and further action could achieve a lower one. BaP is mainly 
associated with detrimental health impacts [BCR: Medium/Low] The indicators present a range as 
the significance of impacts will depend on the level of standard set. It is challenging to precisely 
define the level at which the indicator score would change. That said, based on the modelling and 
wider evidence gathering, expert judgement suggests that: moderate impacts could be associated 
with  a  0.7  ug/m3  standard,  high  impacts  with  a  0.4  ug/m3  standard,  and  the  highest  scoring 
associated with a 0.12 ug/m3 standard. 

0 to + 

0 to + 

0 to + 

0 

0 to + 

0 to - 

0 to - 

0 

+ / - 

0 to - 

0 to + 

0 to - 

Revise standards for annual lead. The benefits of reducing concentrations would be significant on 
a  per  emission  basis,  but  lower  overall  than  for  pollutants  that  are  present  more  widely  in 
concentrations above WHO guideline levels. The costs of a stricter standard depends on the level of 
ambition. Compliance with the current target value is already very high, also pointing to low costs 
for a limit value. Costs of a stricter standard would strongly depend on the specific control measures 
deployed at an individual site to abate emissions. Given many sites will fall under the scope of a 
relevant IED BREF, many low-cost measures may already have been adopted. There is an important 
link  to  L3  regarding  monitoring  of  additional  heavy  metals  to  improve  the  evidence  base.   [BCR: 
Low/Medium] 

0 to + 

0 to + 

0 to + 

0 

0 to + 

0 to - 

0 to - 

0 

+ / - 

0 to - 

0 to + 

0 to - 

Revise standards for annual arsenic: Based on the monitoring data, only a very limited number of 
sites currently exceed the existing target value. As such the costs (and benefits) of implementing 
the  standard  as  a  limit  value  could  be  small,  but  this  could  help  drive  compliance  of  the  few 
remaining sites (some of which have very high concentrations – max 21 ng/m3 in 2019) and ensure 
continued performance at compliant sites. The benefits of reducing emissions would be significant 
on  a  per  emission  basis,  but  lower  overall  than  for  pollutants  that  are  present  more  widely  in 
concentrations  above  WHO  guideline  levels.  Costs  would  strongly  depend  on  the  specific  control 
measures  deployed  at  an  individual  site  to  abate  emissions.  Given  many  sites  will  fall  under  the 
scope of a relevant IED BREF, many low-cost measures may already have been adopted. There is an 
important link to L3 regarding monitoring of additional heavy metals to improve the evidence base. 
[BCR: Low/Medium] 

V1

W1

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0 to + 

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Revise standards for annual cadmium: Costs (and benefits) of implementing the standard as a limit 
value  could  be  small,  but  this  could  help  drive  compliance  at  the  remaining  sites  and  ensure 
continued performance at compliant sites. The benefits of reducing emissions would be significant 
on a per emission basis. There is an important link to L3 regarding monitoring of additional heavy 
metals to improve the evidence base. [BCR: Low/Medium] 

0 to + 

0 

0 

0 

0 

0 to - 

0 to - 

0 

+ / - 

0 to - 

0 

0 to - 

Revise standards for annual nickel: Based on the monitoring data, only a very limited number of 
sites currently exceed the existing target value. As such the costs (and benefits) of implementing 
the  standard  as  a  limit  value  could  be  small,  but  this  could  help  drive  compliance  of  the  few 
remaining  sites  and  ensure  continued  performance  at  compliant  sites.  The  benefits  of  reducing 
emissions would be significant on a per emission basis, but lower overall than for pollutants that are 
present more widely in concentrations above WHO guideline levels. Costs would strongly depend on 
the specific control measures deployed at an individual site to abate emissions. There is an important 
link to L3 regarding monitoring of additional heavy metals to improve  the evidence base.   [BCR: 
Low] 

0  to 
++ 

0 to + 

0 to + 

0 to + 

0 to + 

0 to -
- 

+/- 

0 to + 

+ / - 

+/- 

0 to + 

0 to --
- 

Introduce  standards  for  additional  air  pollutants:  Setting  standards  would  go  beyond  latest 
scientific  advice  and  the  extent  to  which  they  may  reduce  negative  health  impacts  is  therefore 
uncertain. A clear benefit of this intervention would be a requirement to monitor concentrations 
and  this  information  could  subsequently  be  used  to  gain  more  scientific  evidence  about  health 
effects.  Therefore  this  intervention  is  strongly  linked  to  monitoring  interventions  (L1  and  L2). 
Administrative burden would vary with ambition (with more air quality plans required in cases of the 
high  ambition  variant  to  account  for  the  greater  number  of  exceedances).  There  would  be  costs 
associated with additional monitoring required (link to L1 and L2). [BCR: Low] 

  Discussion 

Policy Area 1 explores long- and short-term limit values as well as average exposure indicators. The 

Fitness Check of the Ambient Air Quality Directives found that limit values have been more effective 

than other standards in driving down air pollutant concentrations. However, average exposure 

indicators can complement limit values by addressing larger areas where air quality needs 

improvement. In this way, the inclusion of average exposure indicators is expected to help reduce the 

average exposure of the population to harmful air pollutant concentration levels. Reducing average 

exposure can also facilitate compliance with limit values. 

For setting standards for various pollutants (both long and short term), variants of the intervention 

consider different levels at which the standard can be set below the existing EU standard, such as 

interim targets where these have been set in the WHO air quality guidelines. Variants can also consider 

different timeframes over which a standard should be achieved. For average exposure indicators, 

variants are based on different initial concentrations (µg/m3) and look at whether the reduction targets 

202 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

should be based on annual or daily exposure, and whether they should be set at a regional or national 

level. 

Across all interventions reviewed for Policy Area 1, the more ambitious standards can achieve greater 

improvements in air quality, with corresponding benefits for health and ecosystems. Health benefits are 

more closely associated with exposure to finer particles PM2.5. Between long- and short-term standards, 

greater health benefits are typically associated with chronic exposure (in assessment), but where the 

risk of peaks is quite high and considering this intervention in isolation, the benefits would be much 

more significant. Short-term standards are reviewed for PM2.5, PM10, NO2, O3 and SO2. Generally, 

positive impacts are found for air quality, health and ecosystems. For benzene, BaP and heavy metals, 

the revisions are targeted to relatively fewer cases of exceedances, and benefits are significant in those 

cases but smaller in broader terms. 

Administrative burden will also scale with ambition (mainly impacting Member State competent 

authorities). The costs of abatement measures can only be estimated rather broadly. Depending on the 

pollutant, past abatement measures taken and technological and other developments since, low-cost 

abatement measures may already have been adopted in the past. Short-term compliance measures to 

tackle peak concentrations specifically may be more disruptive in nature (albeit for a short-time) and 

carry a higher cost. For interventions that review the use of average exposure indicators, there is 

potential to reduce the administrative burden by taking more coordinated and centralised action, 

notably coordinating with actions that address limit values. 

For interventions relating to heavy metals, there is an important link to interventions under Policy Area 

3 (L2), and the need to enhance the evidence base around the source apportionment of sites with high 

concentrations of heavy metals. 

For the intervention to introduce standards for additional pollutants, it is important to note that this 

intervention in the form of target values could provide the first step towards setting limit values as it 

would require monitoring concentrations and this information could subsequently be used to set limit 

values – indeed this intervention could improve the effectiveness of linked monitoring interventions (L1 

and L2). 

203 

 
 
 
 
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  Policy area 2 

  Summary of analysis 

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(+) 

(+) 

+ 

0 

0 

0 

(+) 

0 

0 

+ 

(-) 

Introduce review triggered by scientific progress: Introduction of a mechanism that will provide a basis for 
the  alignment  of  the  AAQ  Directive  with  the  latest  scientific  knowledge  will  directly  contribute  towards 
reductions  in  air  quality  concentrations.  Meeting  the  direct  objective  of  air  quality  reduction  will 
subsequently indirectly protect EU population from harmful exposure to air pollution and indirectly benefit 
ecosystems. Direct costs estimated for this intervention are small administrative costs for the Commission. 
[BCR: High] 

A2 

(+) 

(+) 

(+) 

(+) 

0 

0 

0 

0 

0 

0 

(+) 

(-) 

Introduce review of EU air quality standards triggered by technical progress: This measure introduces a 
mechanism for adjusting EU air quality standards based on technical progress in air pollution reduction. This 
intervention would formalise consideration of technological progress in the AAQ Directive and could have a 
small positive indirect impact on improvements in air quality concentrations as advances in the technological 
knowledge  might  lead  to  revisions  in  the  AAQ  Directive  due  to  the  enhanced  technical  feasibility  of  its 
implementation.  However,  the  process  would  be  driven  by  technology  considerations,  not  health 
considerations, and therefore addresses the objective of protecting human health only to some extent. Direct 
costs estimated for this intervention are small administrative costs for the Commission. [BCR: Low] 

A3 

(+) 

(+) 

(+) 

(+) 

0 

0 

0 

(+) 

 0 

0 

0 

(-) 

Introduce  option  to  notify  stricter  standards:  This  measure  introduces  a  provision  to  allow  EU  Member 
States to adopt more stringent standards in light of the new technical and scientific progress coupled with 
an obligation to notify the European Commission. This intervention has a potential to have a small indirect 
impact on reducing air pollution concentrations as it would contribute to sharing of information, including on 
scientific and technical data that can be used by the EU and other EU Member States. This intervention has 
been assessed under the assumption that it will enhance the Commission’s evidence base regarding Member 
State policy action at EU level. Direct costs estimated for this intervention are small administrative costs for 
EU  Member State competent authorities.  The benefit cost ratio of this measure is considered high as low 
administrative burden would lead to an improved knowledge base. [BCR: High] 

A4 

(+) 

(+) 

(+) 

(+) 

0 

0 

0 

0 

0 

0 

0 

- 

Introduce a list of priority air pollutants: This measure aims to keep and periodically update a list of priority 
air pollutants with a view to monitoring air pollutants of emerging concern. This intervention is likely to have 
a small indirect impact on air quality as the monitoring of identified priority pollutants could eventually lead 
to  regulating  them  in  the  AAQ  Directive.  Black  carbon,  UFP,  ammonia,  PFAS,  dioxins  and  PCB  have  been 
specifically  highlighted  as  possible  priority  air  pollutants.  Direct  costs  estimated  for  this  intervention  are 
small  administrative  costs  for  the  Commission.  Additional  burden  would  potentially  be  borne  by  the  EU 
Member States if they were required (or voluntarily choose) to monitor priority emerging air pollutants, in 
particular if the content of the list changed frequently.[BCR: Low] 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

B1 

+ 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

(-) 

Introduce additional short-term standards: Short-term peaks are not always driven by the same sources as 
long-term average concentrations, hence merit a separate standard to focus action here also. Furthermore, 
setting short-term limit values can complement the achievement of other standards (e.g. long-term limits) 
by effectively identifying and effectively implementing effective emission reduction measures for short-term 
peaks,  which  will  also  form  part  of  the  long-term  averaging  period.  This  intervention  could  therefore 
contribute  to  improvement  in  air  quality  and  consequent  health  benefit  alongside  others.  The  extent  of 
impacts  is  very  much  dependent  on  the  standards  set  (interventions  under  Policy  Area  1).  Direct  costs 
estimated with this intervention are small administrative costs for the Commission. Implementation may be 
challenging as there is a lack of consensus over which short term standards best target risks associated with 
exposure. [BCR: High] 

B2 

+ 

+ 

(+) 

(+) 

0 

0 

0 

+ 

0 

0 

(+) 

(-) 

Introduce additional alert/information thresholds: Alert  and information thresholds provide a trigger for 
alerting the public and  developing short term action. Short-term action is expected to benefit air quality 
indirectly to a small extent. Better information (on all relevant air pollutants) for the public would enable 
citizens, in particular vulnerable groups, to take more targeted and effective personal measures to reduce 
their exposure to harmful air pollution, thereby having a direct small positive impact on human health. This 
intervention  is  expected  to  have  small  direct  administrative  costs  for  the  Commission  and  competent 
authorities. [BCR: Medium] 

B3 

(+) 

(+) 

(+) 

(+) 

(+) 

0 

0 

(+) 

0 

0 

(+) 

(-) 

Revise  definition  of  average  exposure  standards:  This  may  improve  the  way  that  the  average  general 
population exposure reduction is monitored and addressed. The average exposure indicator (AEI) is currently 
measured in urban background stations, which might not always be reflective of general population exposure. 
As  a  result,  this  measure  is  likely  to  provide  better  targeting  of  general  air  pollution  exposure  reduction 
measures, thereby contributing to further protection of public health from harmful air pollution and reducing 
the air quality cost to society. It could also improve the effectiveness of implementing mitigation measures. 
Direct costs estimated with this intervention are small administrative costs for the Commission and Member 
States. [BCR: High] 

B4 

(+) 

(+) 

(+) 

(+) 

0 

0 

0 

0 

0 

0 

(+) 

(-) 

Introduce guidance on addressing exceedances: While varying circumstances across different EU Member 
States are a challenge for developing effective guidelines, guidance could contribute towards better targeting 
of air pollution action, thereby contributing towards either more cost-effective response to exceedances or 
reducing  the  air  quality  cost  on  society  by  further  protecting  the  general  population  from  harmful  air 
pollution. It is difficult to estimate indirect compliance and potential mitigation costs. Direct costs estimated 
with this intervention are small administrative costs for the Commission. [BCR: Medium]  

B5 

++ 

+ 

+ 

+ 

+ 

- 

0 

+ 

0 

0 

0 

(-) 

Introduce limit values for additional air pollutants: Limit values have proved more effective in reducing air 
pollutant concentrations than other standards, as evidenced in the Fitness Check of the Ambient Air Quality 
Directives. Introduction of limit values for all pollutants, where these would prove feasible, would strengthen 
the  AAQ  Directive.  Direct  costs  estimated  with  this  intervention  are  medium  administrative  costs  for  the 
Commission, associated with the review of the AAQ Directive as well as additional monitoring needs (which 
would depend on the selection of pollutants for which limit values would be defined). One reason for setting 
target values rather than limit values is to take account of the specific formation mechanisms, for example 
in the case of ozone (also due to a strong role of transboundary sources and annual variations in meteorology 
for this air pollutant). [BCR: Medium] 

C1 

(+) 

(+) 

(+) 

(+) 

(+) 

0 

0 

0 

(+) 

0 

(+) 

-- 

 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Revise obligations to take measures triggered by exceedances of air quality standards: This measure would 
specify the ‘type of measures’ that competent authorities must take to ensure that exceedance periods can 
be kept as short as possible. Since authorities would be provided with a long-list of measures to select from, 
this would lead to a systematic approach to developing an air quality plan and reduce the time to explore 
potential measures. The intervention holds the potential to result in more effective measures which in turn 
can bring positive benefits in terms of air quality and related impacts, however this also depends on funds 
for implementation of measures and properly trained staff in competent authorities. The fact that the type 
of measures to be included in air quality plans is further defined does not guarantee these measures will be 
taken.  The  success  of  this  intervention  relies  on  the  capability  (knowledge,  skills,  competences)  of 
Competent Authorities in charge of designing air quality plans to develop effective plans. This intervention 
will not result in any additional relevant direct costs for competent authorities as the obligation to develop 
air quality plans already exists. [BCR: Medium] 

C2 

(+) 

(+) 

(+) 

(+) 

(+) 

0 

0 

0 

(+) 

0 

(+) 

-- 

Revise/clarify  the  term  ‘as  short  as  possible’:  Specifying  a  clear  time  period  within  which  air  quality 
standards have to be respected holds the potential to result in faster action which in turn can bring indirect 
positive benefits in terms of air quality and related impacts. Introducing a fixed timeframe will  provide a 
maximum time span within which results have to be achieved, improving the speed of response rates in many 
cases. However, as there is no one-size-fits-all timeframe, there is a risk that a fixed timeframe will slow 
down action in some cases where compliance could be achieved before the end of the fixed term. There may 
also be effective long-term measures that cannot be fully implemented within the given timeframe. A fixed 
timeframe may also weaken previous interpretations of the term ‘as short as possible’ by the courts. [BCR: 
Medium] 

C3 

(+) 

(+) 

(+) 

0 

(+) 

0 

0 

0 

(+) 

0 

0 

- 

Revise short-term action plans and air quality plans: Coordination between short term action plans and air 
quality  plans  would  lead  to  synergies  among  actions  and  avoid  inefficiencies  or  inconsistencies.  Small 
administrative  costs  may  be  incurred  for  Member  State  competent  authorities  related  to  coordination 
activities which are expected to be more than off-set by efficiency gains. According to several respondents 
to  the  targeted  stakeholder  survey,  the  revised  Directive  could  require  that  short  term  action  plans  are 
included in air quality plans. Also, to facilitate this linkage between the two types of plans, the Ambient Air 
Quality Directives should include the minimum content that short-term action plans should contain. [BCR: 
Medium] 

C4 

+ 

+ 

+ 

(+) 

(+) 

0 
to 
- 

(-) 

+ 

(+) 

(-) 

(+) 

- 

Introduce additional short-term action plans for other pollutants: An obligation for effective short-term 
action  plans  for  each  pollutant  would  prompt  further  action  to  bring  emissions  and  concentrations  down 
compared to the current situation, thus expected to benefit air quality and protect in particular sensitive 
groups from immediate health risks. Additional administrative burden is expected from this intervention as 
it imposes additional requirements (i.e. additional work) to Member State competent authorities. Risks linked 
to this intervention have to do with time-lag risk and separation of source and pollution. Short term action 
plans  may  be  effective  only  to  a  limited  extent  where  pollution  episodes  cannot  be  influenced  by  local 
measures  or  in  case  of  secondary  pollutants  for  which  it  is  not  straight  forward  to  identify  immediate 
measures. [BCR: Medium] 

C5 

(+) 

(+) 

(+) 

(+) 

(+) 

- 

0 

0 

(+) 

0 

(+) 

--- 

Introduce a requirement to update air quality plans: Requiring regular updates of air quality plans would 
increase the effectiveness of plans and thus have an ‘indirect’ positive effect on air quality. Mitigation costs 
and administrative burden are expected to directly impact Member States’ competent authorities responsible 

 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

for  the  updating  of  air  quality  plans  and  implementation  of  measures.  A  risk  identified  for  this  measure 
relates to the fact that the process of drafting air quality plans tends to be long. [BCR: Medium] 

D1 

(+) 

(+) 

(+) 

0 

0 

0 
to 
- 

0 

0 

0 

0 

0 

-- 

Revise requirements to involve stakeholders: This measure seeks to improve the involvement of all relevant 
actors  in  the  design  and  implementation  of  air  quality  plans.  This  may  possibly  be  done  by  adding  a 
requirement for consulting and involving government authorities at various levels, and by introducing a new 
’public participation’ clause for the development of air quality plans. [BCR: High] 

D2 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

-- 

Introduce  a  ‘one  zone,  one  plan’  requirement:  This  measure  aims  to  increase  the  effectiveness  of  the 
Ambient Air Quality Directives by tackling the current mismatch between the zones of air quality monitoring 
and air quality plans. However, the benefits and added value of this intervention are unclear while it would 
generate some costs (and considerable administrative burden). Overall it is unclear what the added value of 
this intervention would be and a global approach does not seem helpful as air quality plans and air quality 
zones are very specific to local conditions. Arguments against this intervention in the Targeted Stakeholder 
Survey  revolve  around  changes  that would  be  needed  in terms  of  governance  /  responsibilities  as  well  as 
around additional administrative burden that the intervention would lead to. [BCR: Low] 

M1 

(+) 

(+) 

(+) 

(+) 

0 

0 
to 
(+
) 

0 

0 

0 

0 

(+) 

-- 

Introduce  methodology  to  assess  transboundary  contribution:  This  measure  aims  to  facilitate  and 
harmonise the used methodology when assessing transboundary air pollution/contributions to local/regional 
air pollution. The effectiveness of this intervention to improve air quality is impacted by the lack of an agreed 
methodology  between  Member  States  or  from  expert  groups.  Implementing  this  intervention  would  imply 
additional costs for Member States who would need to align their methodology to assess transboundary air 
pollution.  A  challenge  for  implementation  is  that  it  may  be  unclear  where  the  responsibility  lies  for 
transboundary air pollution assessment and action. In addition, assessment expertise is needed to conduct 
the modelling and there is a risk of limited expertise at local level. [BCR: High]  

M2 

(+) 

(+) 

(+) 

(+) 

(+) 

- 

0 

0 

0 

0 

(+) 

- 

Revise  obligations  for  transboundary  cooperation:  Requiring  joint  transboundary  cooperation  above  a 
specific  threshold  would  foster  transboundary  cooperation  and  in  turn  improve  air  quality  in  bordering 
regions,  and  benefit  health  and  ecosystems  in  these  areas.  Implementing  this  intervention  would  imply 
additional costs for competent authorities, especially in bordering countries were transboundary air pollution 
is an issue. Implementation challenges include enforcement (where one Member State cannot enforce action 
in another), lack of funds at local/regional authority level and acceptability of authorities and industry to 
implement measures to bring air improvements elsewhere. [BCR: Medium] 

E1 

(+) 

(+) 

(+) 

(+) 

(+) 

(-) 

0 

0 

(+) 

0 

(+) 

(-) 

Introduce  minimum  levels  for  financial  penalties:  Effective  minimum  penalty  levels  should  discourage 
competent authorities and industry or other private entities from breaching provisions of the Directives or 
measures adopted pursuant to the Directives, thus indirectly benefiting air quality, ecosystems and health. If 
effective, it would lead to competent authorities and industry implementing more measures to avoid breaches 
(and  therefore  avoid  high  fines).  This  would  indirectly  generate  additional  costs  for  these  actors,  though 
related  to  achieving  compliance.  The  additional  administrative  burden  of  clarifying  levels  of  financial 
penalties  is  low  and  would  facilitate  their  implementation.  The  risks  for  implementation  have  to  do  with 
determining  penalty  levels  applicable  across  the  EU  and,  more  indirectly,  with  difficulties  concerning 

 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

enforcement of breaches, as well as with the need for timely action and a faster process in light of breaches 
[BCR: Medium – High] 

E2 

(+) 

(+) 

(+) 

(+) 

(+) 

- 

0 

0 

(+) 

0 

(+) 

0 

Introduce  right  to  health  damage  compensation:  This  measure  would  work  as  an  effective  incentive  for 
competent  authorities  and  industry/business  to  implement  more  effective  measures,  which  in  turn  would 
benefit  air  quality,  health  and  ecosystems.  This  measure,  if  implemented,  would  require  competent 
authorities and/or industry (polluters) to pay  compensation  to those who have suffered damage to health 
from air pollution and would therefore carry mitigation costs for those who are held accountable for breaches 
of air quality standards. It would also carry administrative burden for competent authorities and/or industry 
(polluters)  as  they  would  need  to  put  in  place  and  manage  the  compensation  scheme  and  deal  with  a 
potentially increasing number in lawsuits by citizens / civil society, though only in case of continued non-
compliance. Implementation challenges include the difficulty of proving the causal link between pollution 
and long-term health effects and the question of accountability (who is held responsible). [BCR: Medium] 

E3 

0  to 
(+) 

0  to 
(+) 

0 to (+) 

0  to 
(+) 

0 

0 
to 
(+
) 

0 

0 

(+) 

0 

0  to 
(+) 

(-) 

Introduce  a  fund  to  be  fed  by  penalties  paid:  A  dedicated  fund  would  make  available  funding  for 
compensation for health damage suffered and facilitate access to funding of the implementation of mitigation 
measures (leading to measures being more readily implemented). However, it could also lead to competent 
authorities using the fund to finance measures that they would implement in any case, without leading to 
‘more’ (i.e. additional) measures being implemented, which is a risk the governance of the fund would have 
to  address.  The  effectiveness  of  this  measure  requires  a  solid  framework  of  penalties  and  procedures 
(administrative, legal) that ensure that penalties are duly paid. Setting up and administering such a fund will 
generate additional burden. Risks for implementation include a potential conflict of interest in cases where 
the authority that has to pay also administers the fund and the alignment with national budgetary rules. The 
organisation of the fund could provide safeguards to avoid that the budget from which the penalty is paid 
into the fund is not the one benefiting from it. [BCR: Low] 

E4 

(+) 

(+) 

(+) 

(+) 

(+) 

(-) 

0 

0 

(+) 

0 

0 

0 

Introduce  an  explicit  ‘access  to  justice’  provision:  There  is  a  gap  in  the  AAQ  Directives  with  regard  to 
‘access to justice’ and including such a provision in the legislation would be a coherent step, in line with 
other environmental Directives, Article 47 of the EU Charter on fundamental Rights, the Aarhus Convention 
and the case law of the Court of Justice of the EU. Public judicial enforcement of the obligations under the 
AAQ Directives has already led to multiple national rulings (in several Member States) mandating national 
authorities to take action to improve air quality. Introducing an explicit provision would enable such actions 
by citizens that are currently unable to do so because of strict national procedural requirements. In turn, 
this would indirectly benefit air quality and human health as a whole. Additional administrative burden for 
Member States (probably central / national government) and industry may occur as an increase in lawsuits 
may be expected; this would largely depend on whether national authorities have already taken the necessary 
measures to comply with the Aarhus Convention and the relevant case law of the Court of Justice of the EU. 
The implementation of the intervention carries risks in terms of capacity from Member States to deal with 
additional legal claims. [BCR: High] 

F1 

0 

(+) 

0 

0 

0 

0 

0 

(+) 

0 

0 

0 

-- 

Revise provisions related to up-to-date data: Up-to-date data and information on air quality would allow 
citizens to make decisions that may impact on their health, such as deciding not to participate in outdoor 
leisure activities or opting for a cleaner transport route. Hence there is a benefit in ensuring consistent access 
for citizens across Member States to real-time, appropriate information, which is publicly accessible. Having 
such  information  /  data  would  be  particularly  important  for  vulnerable  groups.  The  benefits  of  the 

 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

intervention  are  indirect  while  its  costs  are  negligible  but administrative  burden  will  increase  slightly  for 
Member States. There are risks around the accuracy of real-time information. [BCR: Medium/High] 

F2 

0 

(+) 

0 

0 

0 

0 

0 

0 

0 

0 

0 

- 

Introduce requirement to provide AQ health data: Information on health (protection) would allow citizens 
to make decisions that may impact on their health such as deciding not to exercise outdoors or opting for a 
cleaner transport route. Ensuring that information is provided to allow citizens to take timely action would 
increase the effectiveness of information provided, whilst the costs are considered negligible since relevant 
information and the systems to provide it are already in place. [BCR: Medium] 

F3 

0 

0 

0 

0 

0 

0 

0 

(+/-) 

0 

0 

0 

--- 

Introduce  use  of  specific  communication  channels:  Obliging  competent  authorities  to  use  a  set  of 
information channels would lead to a better, and more consistently informed public with indirect benefits 
on health. The cost of developing (in particular where these are not currently in place) specific, high-tech 
channels may be more costly, which may divert resources from other, more productive, means. [BCR: Low] 

F4 

0 

(+) 

0 

0 

0 

0 

0 

(+) 

0 

0 

0 

- 

Introduce requirements for harmonised AQ index: Consistency in the information provided to citizens will 
aid clarity and uniformity in the opportunity provided to all EU citizens to take action to reduce their exposure 
with indirect benefits for health. However, there  are concerns that the European Air Quality Index is not 
effective (e.g. around its ability to represent multi-pollutant effects), and that complete harmonisation may 
restrict the ability of Member States to tailor advice and information to the specific situation in each Member 
State. The intervention will increase administrative burden for competent authorities (regional or national) 
as it will require these to adapt their index bands. [BCR: Medium] 

  Discussion 

Many of the interventions reviewed for Policy Area 2 do not entail significant direct environmental, 

social or economic impacts but would form an important means for  

• 

• 

• 

ensuring that more effective and efficient action is taken to achieve the air quality standards 

(for instance by enabling more targeted action); 
ensuring timely action is taken to achieve air quality standards (for instance through dissuasive 
penalties)reducing administrative burden (for instance by enabling more synergies between air 
quality plans and short-term action plans); and 
Future proofing EU standards by ensuring they are reviewed regularly  

Thus, the majority of the benefits identified are indirect, derived from expert judgement, and also 

interpretation of the way in which the interventions will underpin and complement changes to other 

interventions under review, notably for Policy Area 1.  

Direct benefits primarily relate to air quality and have been identified for five of the interventions 

reviewed for Policy Area 2 (interventions to: introduce review triggered by scientific progress;  

introduce additional short-term standards; introduce additional alert/information thresholds; introduce 

limit values for additional air pollutants, and introduce additional short-term action plans for other 

pollutants). Introducing limit values for additional air pollutants would have the potential for the most 

significant direct benefits among the interventions assessed for Policy Area 2. It is important to note 

that the benefits are dependent on the pollutant. For example, in the case of ozone, the use of target 

values is better suited than limit values due to the specific mechanisms of ozone formation in the 

atmosphere and the particularly strong role of transboundary sources and annual variations in 

meteorology for this air pollutant.  

 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Many of the interventions within Policy Area 2 are expected to incur small administrative costs for the 

Commission, administrative costs for competent authorities, and some abatement costs (identified for 7 

of the interventions reviewed). Costs relate to additional monitoring needs, updating of air quality 

plans and implementation of measures, transboundary cooperation, financial penalties (however only in 

cases of non-compliance), and the use of specific communication channels. Indirect costs were also 

identified as a possible result of introducing an explicit ‘access to justice’ clause (however only in cases 

of non-compliance). 

  Policy area 3 

  Summary of analysis  

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(+) 

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5

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7

0 

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8

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9

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0 

(+) 

s
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y
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.
1
1

e
v
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s
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.
2
1

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--- 

t
n
e
m
y
o
l
p
m
E

n
o

s
t
c
a
p
m

I

.
0
1

0 

Revise  rules  related  to  indicative  sampling  points:  When  used  to  supplement  (not  substitute),  fixed 
monitoring  such  as  in  places  where  it  is  not  possible  to  place  a  fixed  monitoring  station  that  meets  the 
requirements of the Directive, additional indicative monitoring contributes to a better overall understanding 
of the air quality assessment process since additional sampling data is at hand. This contributes to an overall 
improved  air  quality  assessment  process  with  indirect  benefits  to  air  quality,  health  and  ecosystems. 
However, the substitution of fixed monitoring stations by lower quality indicative monitoring devices is seen 
by  many  stakeholders  as  a  major  risk  to  degrade  an  important  pillar  in  air  quality  management. 
Administrative burden is dependent on implementation: where used to supplement fixed monitoring, there 
would be an increase in costs and administrative burden, whereas substitution of fixed monitoring stations 
by indicative monitoring would result in cost savings. [BCR: High] 

G2

(+) 

(+) 

(+) 

0 

0 

0 

0 

(+) 

(+) 

0 

0 

--- 

Introduce requirements for AQ modelling: Variants relate to the possible use of air quality modelling and 
include:  

(1) For short term air quality forecasting (up to a few days ahead); 
(2) For assessment of air quality for compliance checking purposes; 
(3) For air quality near real time mapping and informing the public; 
(4) For evaluation of monitoring network design; 
(5) For estimation of population exposure and exceedance situation indicators; 
(6) For source apportionment estimations; 
(7) For assessment of long-range air pollutant transport; 
(8) For future projections in support of air quality management and planning; 
(9)  As  alternative  to  fixed  monitoring  (when  placing  such  monitoring  in  line  with  the  Directive  is  not 
possible).  

Air  quality  modelling  improves  air  quality  monitoring  and  assessment,  thus  allowing  for  a  better 
understanding  of  air  quality  concentrations,  supporting  a  more  effective  and  more  targeted  air  quality 
management.  The  administrative  burden  may  increase  for  Competent  Authorities  (to  meet  the  reporting 
requirement). The increase is likely to depend on the current modelling capability and practices within each 
Member  State.  There  are  risks  for  implementation  linked  to  technical  capacity  and  potential  lack  of 
modelling guidance and/  or lack of resources for training and capacity building. There is also a  risk  that 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Member States may view the introduction of a mandatory requirement of modelling as a reason to reduce 
their  monitoring  network.  There  is  strong  support  across  all  stakeholder  types  for  the  mandatory  use  of 
modelling for most of the nine use case variants in at least some instances. Some respondents, however, 
explained further that modelling should be (strongly) recommended in most of these use cases but only made 
mandatory for all Member States in one case, i.e. for future projections in support of air quality management 
and planning. [BCR: High/Medium] 

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(-) 

Revise rules for regular review of AQ assessment: This intervention would require Member States to follow 
set criteria in their reviews of their assessment regime  which rely on monitoring and/or  modelling data. 
This would provide a more harmonised review of air quality assessment across Europe  leading to a more 
transparent and coherent view of air quality status for wider public access. All Member States have ready 
access to fixed term monitoring, and most have modelling capability, so our expert view is that the costs 
for this intervention are insignificant. Administrative burden may be significant if the period for review is 
annual (stakeholder respondents favored the retention of 5-year reviews). [BCR: Low] 

H1

+ 

+ 

+ 

0 

+/- 

0 

0 

0 

0 

0 

0 

--- 

Revise  minimum  number  of  sampling  points:  The  intervention  would  involve  changing  the  minimum 
number of sampling points per air quality zone for each pollutant should be revised with latest scientific 
knowledge.  

Changing  the  minimum  number  of  sampling  points  required  has  potential  for  an  increase  or  decrease  in 
monitoring  for  the  assessment  of  air  quality (a  reduction  in  the  minimum  number  of  monitoring  stations 
would be detrimental to air quality, public health, ecosystems and costs to society but lessen administrative 
burden, while an increase in the minimum number of stations would have a positive impact on air quality, 
health  and  ecosystem  but  increase  administrative  burden).  Costs  arising  from  an  increased  number  of 
stations would be incurred from greater laboratory analysis, and the additional staff needed for servicing 
and maintenance and data management. There is little/no support from stakeholders for any decrease in 
the minimum number of sampling points, while an increase of monitoring stations was favoured for at least 
some  pollutants  and  with  a  minimum  to  measure  population  exposure.  While  additional  monitoring  is 
associated with high costs, many Member States report monitoring above the current required number of 
sampling locations, and therefore in practice an increase in monitoring required is overall beneficial. [BCR: 
Medium for increase in sampling points]  

H2 

(+) 

(+) 

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0 

0 

--- 

Simplify combined PM10/PM2.5 monitoring: This intervention de-couples the current minimum number of 
sampling points for PM10 and PM2.5, which should be set independently and cannot substitute one another. 
PM2.5  is  a  key  pollutant  for  public  health  risk  assessment.  Given  its  important  impacts  on  mortality  and 
morbidity, it is essential for it to be considered and assessed independently from PM10. Clarifying and giving 
more focus on the assessment of this pollutant in the revised AAQ Directive would bring benefit to driving 
action  in  areas  of  exceedance  to  improve  public  health  protection.  Many  Member  States  have  already 
increased their sampling of PM2.5 so in practice this intervention is unlikely to involve large costs, though for 
those  Member  States  who  monitor  at  minimum  levels  only,  costs  may  be  significant  as  those  for  new 
monitoring samplers are often high and comes with on-going maintenance costs. Public Authorities report 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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no real increase in administrative burden to monitor PM10 and PM2.5 separately. There is a time lag associated 
with this intervention (to establish the new sites) and this may risk air quality in the short term. Additional 
staff is needed to support sampler operation and data management. [BCR: High] 

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Simplify  the  definitions  of  sampling  points  types:  Currently  station  classification  includes  a  number  of 
categories such as Urban, Suburban, Rural, Industrial,  traffic, background. Station classification could be 
simplified to identify sites only as hotspots or background locations. This may enable identifying a key source 
of  pollution  currently  missing  in  the  classification  which  is  that  due  to  residential  combustion.  As  this 
intervention  is  a  desk  task  to  reclassify  the  current  sites  it  is  unlikely  to  have  any  real  impact  on 
administrative burden. To be effectively implemented, this intervention would require guidance. However, 
a  more  simplified  classification  risks  loss  of  clarity  and  misunderstanding  on  the  site  differences  and the 
main sources of pollution. The full reporting of site meta data under the IPR and e-reporting by all Member 
States  and  clarification  of  terms  further  in  the  AAQ  Directive  could  greatly  help  to  address  this 
shortcoming.BCR: Low] 

I1

(+) 

(+) 

(+) 

0 

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Introduce obligations to maintain sampling points: Providing clarity on the circumstances when sampling 
points  may  be  relocated  would  reduce  flexibility  to  close  stations  but  allow  for  increased  datasets  for 
pollutant trend analysis. Requiring a set timeframe for the operation and maintenance of sampling points 
with exceedances of limit values for any of the pollutants under the AAQ Directives would result in better 
datasets for assessment and trend analysis. In most cases this would be a prerequisite for more effective 
and more targeted air quality management. [BCR: High] 

I2

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(+) 

(+) 

0 

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(-) 

Introduce obligations to monitor long-term trends: Including a requirement to monitor long-term trend in 
the cases of relocation of fixed monitoring stations would allow for increased datasets for pollutant trend 
analysis. Assessing long-term trends in pollution data is important for the assessment and management of 
air quality. There is significant benefit to scientific understanding and policy development to protect health 
and the environment to have access to a long-established network of monitors. Costs for this intervention 
depend on the variant. Administrative burden and costs of monitoring could increase as the amount of fixed 
monitoring stations would remain the same, but it may be required to increase indicative measurements at 
all previous fixed measurement locations for long-term trend monitoring and analysis. However, where fixed 
monitoring stations could be replaced by indicative monitoring or modelling a cost saving is likely. For this 
intervention to be successful, it is important to align with those proposed interventions with the objective 
of improving quality of indicative monitoring and modelling. [BCR: Low] 

I3

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(+) 

0 

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- 

Introduce  a  protocol  for  relocated  sampling  points:  A  protocol  could  include  an  assessment  of  site 
representativeness, co-location of monitoring for a minimum time period, to assist in the assessment of data 
quality  for  trend  analysis  from  the  old  and  new  sampling  points  and  hence  increase  robustness  and 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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transparency  especially  when  areas  are  in  exceedance.  This  intervention  while  helpful  for  greater 
assessment harmonisation is likely to have little impact on air quality and other indicators. The costs for 
this  intervention  are  low.  Although,  reduced  flexibility  to  relocate  samplers  when  necessary,  may  risk 
increased administration burden on Member States to find an alternative monitoring location. [BCR: Medium] 

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Revise  macro-scale  siting  of  sampling  points:  The  siting  criteria  are  open  for  interpretation  and  not 
implementing  the  intervention  could  compromise  the  harmonisation  and  comparability  of  air  quality 
measurement  data  within  the  EU.  Inconsistencies  can  impact  on  the  number  of  monitoring  stations,  the 
number and extent of exceedances identified, the need for measures to improve air quality, and the costs 
associated with these activities. This could also lead to issues of inequality in the implementation of the 
requirements and affect the proportionality of any potential infringement action. This intervention would 
increase  the  administrative  burden  for  competent  authorities  in  terms  of  sampling  point  evaluation  and 
reporting of the relevant indicators. Most stakeholders support the implementation of this intervention since 
it will increase the comparability and harmonisation of air quality data over Europe. However, the same 
stakeholders  indicate  that  some  flexibility  is  still  required  in  order  to  deal  with  practical  selection  and 
installation of sampling points. [BCR: Medium] 

J2

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(+) 

0 

0 

(+) 

0 

0 

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-- 

Revise micro-scale siting of sampling points: Variants include: 
(1) Harmonise the micro-scale siting criteria laid down in Annex III and Annex VIII of Dir. 2008/50/EC and 
Annex III of Dir. 2004/107/EC – aligning with 2008/50/EC provisions.  
(2) Clarify whether micro-scale siting criteria are applicable to sampling points for indicative measurements 
in addition to sampling points for fixed measurements. 
(3) Clarify the flexibility related the unrestricted flow around the inlet of sampling points. 
(4) Clarify the flexibility related to the height of the inlet of sampling points. 
(5)  Clarify  the  flexibility  related  to  the  distance  to  the  kerbside  (or  other  metrics)  of  traffic-oriented 
sampling points.  

Revisions to micro-siting criteria, which also apply to indicative monitoring, may have an indirect benefit to 
society costs due to an indirect improvement on public health. Where new indicative monitoring is being 
planned  this  intervention  may  give  access  to  a  higher  quality  monitoring  dataset  to  assist  air  quality 
assessment, underpinning air quality action. There is a low administrative burden, unless the intervention 
leads to the disqualification of existing sites (in which case the administrative burden would be high). Costs 
are relatively low, particularly if this intervention does not result in the disqualification of established long-
term sampling locations. The most concern raised by stakeholders about micro-siting criteria for sampling 
points is related to traffic sites, particularly in urban areas. However, these are complex environments with 
pollution concentrations varying in small micro-environments. Some level of flexibility is needed to local 
monitoring network managers to ensure monitoring effectiveness and efficiency. [BCR: Medium] 

J
(+) 

J3

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(+) 

0 

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(+) 

0 

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--- 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Introduce  obligation  for  spatial  representativeness:  For  every  sampling 
location,  a  spatial 
representativeness  (SR)  area  should  be  estimated  and  reported.  This  area  of  representativeness  is  an 
essential indicator of the sampling location. 
A tiered approach is available to assess SR of monitoring sites: 
• 
• 
• 
• 
The concept of an SR area helps to clarify and harmonise air quality assessment based on monitoring data. 
It  serves  multiple  purposes  in  this  process:  assessment  of  population  exposure  and  exceedance  situation 
indicators  based  on  the  monitoring  data,  monitoring  network  design  and  selection  of  stations  for  model 
validation  and  data  assimilation.  When  modelling  capacity  is  available  higher  Tier  methods  are  rather 
straightforward to apply. Stakeholders indicate that there is a clear need for better definition for spatial 
representativeness and it would be useful to introduce this concept to the Ambient Air Quality Directives in 
order to ensure comparability between Member States. [BCR: High to Medium depending on the Tier] 

Tier 1: assessment based on expert judgement; 
Tier 2: assessment based on proxy data or indicative measurement campaigns; 
Tier 3: assessment based on fit-for-purpose modelling according to FAIRMODE Guidance; 
Tier 4: assessment based on combination of modelling and indicative monitoring. 

K1

(+) 

(+) 

(+) 

0 

0 

0 

0 

0 

0 

0 

0 

- 

Revise AQ monitoring data quality objectives: Variants for this intervention include:   
(1) Further align data aggregation requirements to be met for specific periods (e.g. hourly, daily, 8-hour or 
annual) or the whole year.  
(2) Further align the data coverage (time coverage and data capture) requirements for all air pollutants. 
(3) For ozone, align data coverage requirements for both for the full calendar year and for the period of 
April to September, as well as for the AOT40 indicator. 
(4) For indicative measurements, set separate data coverage requirements for annual mean values and for 
short-term mean values. 

(5) For calibration and validation of air quality modelling, introduce specific data quality requirements for 
sampling points / measurements (that are less strict than those used for air quality assessments). 

To make the full use  of available data a protocol/guidance specifying appropriate methods for assessing 
compliance and estimating statistical parameters to account for low data coverage or significant data losses 
should be published. This intervention would improve data quality requirements for sampling points which 
is likely to increase robustness of data and may supplement evidence for trend analysis and modelling. This 
may lead to indirect improvements in air quality, health and ecosystems which may indirectly reduce costs 
to society as clarity is provided over the use of data. The costs for this are low or may even be a cost saving 
as administrative burden may reduce as modelling is likely to cost less than additional fixed  or indicative 
measurements. [BCR: Medium] 

K2

0 

(+) 

0 

0 

0 

0 

0 

0 

0 

0 

0 

-- 

Introduce up-to-date data at all sampling points: This intervention would increase the harmonisation of 
the reporting of real-time air quality information, which during pollution episodic events, brings benefit to 
the public. Up to date data also helps to improve the accuracy of air quality forecast modelling. Costs are 
low and those Member States already publishing real time data are unlikely to be impacted. There are risks 
to implementation in cases of monitoring sampler or IT system failure as this would inhibit publication of 
air  quality  data  in  real-time.  Increased  resources  may  be  needed  for  some  Member  States  to  ensure 
immediate data quality. [BCR: Low] 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Introduce AQ modelling data quality objectives: Modelling Quality Objective (MQO) would need to be met 
in the validation and QA/QC processes of modelling systems. FAIRMODE has proposed such a MQO which is 
currently under evaluation for becoming a CEN standard. High quality modelling applications will contribute 
to better air quality assessment and planning process. This results in high quality information for the public 
at large, better source allocation and source identification and eventually better air quality planning. There 
would be a small administrative burden as some of the modelling systems  would have to be upgraded to 
meet the quality standards [BCR: High] 

K4 

(+) 

(+) 

(+) 

0 

0 

0 

0 

0 

0 

0 

0 

- 

Revise approach to AQ assessment uncertainty: Revised monitoring uncertainty and how this is designed, 
particularly  important  particularly  when  air  quality  standards  are  low,  could  improve  the  quality  of 
measurement data leading to overall improved air quality and reducing health and ecosystem impacts. While 
it  is  unlikely to bring  significant  benefits  to  air  quality  management  it  is  an  important  aspect to  clarify. 
Changes  in  the  calculation  for  uncertainty  may  have  a  negative  impact  on  existing  long-established 
monitoring  datasets  should  it  not  comply  with  uncertainty  standards.  This  would  negatively  impact  data 
quality and overall assessment of pollutant levels for those in non-compliance. Overall, stakeholders saw 
benefit in combining uncertainty in both absolute and percentage terms. [BCR: Medium] 

L1 

(+) 

(+) 

(+) 

0 

(+) 

0 

0 

0 

0 

0 

0 

--- 

Introduce  concept  of  monitoring  at  ‘super-sites’:  Further  establishment  of  supersites  across  Europe, 
particularly for observing emerging pollutant trends would bring large benefits for their future assessment 
and control. Most benefit would be gained if these sites were established at both urban and rural locations. 
Monitoring is very costly and there is a significant administrative burden (for capital and maintenance costs 
as well as more staff and training needs), however some Member States already monitor with a supersite 
network in operation, i.e. Finland. [BCR: Medium] 

L2

(+) 

(+) 

(+) 

(+) 

(+) 

0 

0 

0 

0 

0  0 

--- 

Introduce obligations to monitor more pollutants: Possibilities for which additional air pollutants should 
be  monitored,  include:  Ultrafine  particles,  Ammonia,  Fine  combustion  particles,  Oxidative  potential, 
Additional heavy metals,  Hydrogen sulphide (H2S) and other reduced sulphur compounds (TRS), Nitro-PAHs 
and  Pesticides.  Monitoring  of  emerging  pollutants  is  essential  to  advance  our  understanding  of  current 
pollution loads, but also to assess source apportionment and underpin modelling to assess future projected 
levels. This intervention would facilitate research on these emerging pollutants and support epidemiological 
studies of pollutants of most concern to health. Monitoring of air pollution is costly, and even more so for 
pollutants  which  are  not  widely  monitored.  Administrative  burden  would  be  high,  and  likely  to  include 
capacity  building  to  train  site  operators.  Monitoring  for  these  pollutants  would  be  essential  to  setting 
standards for additional pollutants and the setting up of a priority watchlist (links with Policy Area 1 and 
intervention Ø1 and Policy Area 2 and intervention A4). [BCR: High] 

L3

(+
) 

(+) 

(+) 

0 

0  0 

0 

0 

0 

0 

0 

--- 

Revise  list  of  VOC  to  monitor:  Further  elaboration  of  VOC  monitoring  is  necessary  to  develop  scientific 
knowledge to support emission control though costs are high (for new analysers to measure more VOCs, and 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

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additional  resources  that  may  be  needed  to  service  and  maintain  sites  and  manage  and  report  data). 
However, the merit of monitoring more (or other) VOCs in addition to those regularly monitored is unclear. 
Further  monitoring  should  be  accompanied  by  data  quality  and  siting  specifications  with  appropriate 
guidance. [BCR: Low] 

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+ 

+ 

(+) 

(+) 

- 

0 

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0 

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-- 

Revise the information in air quality plans: Variants include: 
(1) Require a quantification of emission reduction in t/a for air quality measures. 
(2) Require estimates of concentration reduction of planned air quality measures in µg/m³ at all sampling 
points in exceedance. 
(3) Require an assessment of health impacts of the status-quo and after the implementation of air quality 
measures. 
(4) Require an emission source apportionment of all relevant sectors that contribute to the exceedance (in 
line with the existing National Air Pollution Control Programmes). 
(5) Require that an assessment of emissions and the responsible actors for those emissions should be carried 
out (e.g. city level, regional level, national level, and transboundary contributions). 
It is expected that this intervention would provide an improved framework for air quality planning which 
gives rise to better air quality plans and eventually an improved air quality. Additional administrative burden 
expected to setup of a comprehensive and adequate air quality plan requires more resources for more in-
depth analysis and more governance amongst various stakeholders involved in the planning process. [BCR: 
High] 

  Discussion 

Policy Area 3 consists of interventions that seek to improve and harmonise monitoring and modelling, as 

well as extend the monitoring to pollutants of emerging concern, thus strengthening the evidence base 

and providing the foundation to enable effective and efficient air quality management across all 

Member States. This policy area also includes the minimum content that air quality plans should 

contain. 

For the majority of the interventions reviewed under Policy Area 3, the impacts have been assessed as 

small, and more often than not, indirect. Only one intervention is expected to result in direct positive 

impacts (revise the information in air quality plans). It is expected that this intervention would provide 

an improved framework for air quality planning which would give rise to better air quality plans and 

eventually an improved air quality and consequent benefits for health and ecosystems.  

It is important to underline that, while the individual impact of Policy Area 3 interventions  is often 

assessed as small and/or indirect,  they are often important to underpin the effectiveness of air quality 

standards, air quality plans and governance. Although not presented in the summary table above, 

linkages with interventions in Policy Areas 1 and 2 are key. This detail is in the accompanying appendix 

detailing the interventions. Linkages between the interventions are incorporated in Section 10 in the 

grouping of interventions into policy options and packages. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

No mitigation costs have been identified for any of the interventions under Policy Area 3 but 

administrative burden is significant in four cases, namely where capacity building is needed to train site 

operators and where additional resources may be needed to service and maintain sites and manage and 

report data. 

  Benefit Cost Ratio Summary 

 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 67 summarises the benefit cost ratio for all 69 interventions considered in this impact 

assessment. These are presented by policy areas, and the most uncertainty lies in those interventions 

that focus on air quality standards as the variation in the proposed standard has a large impact on the 

BCR. Priority areas identified in interventions associated with revisions to the legislative framework 

include: 

• 

• 

• 

• 

• 

• 

• 

Introduction of a review triggered by scientific progress. 

Introduction of stricter standards. 

Introduction of short term standards. 

Introduction of additional short term action plans. 

Revision of the requirements to involve stakeholders. 

Introduction of a method to assess transboundary pollution. 

Introduction of an explicit `access to justice’ clause. 

Priority areas identified in interventions associated with revisions to air quality monitoring, modelling 

and air quality plans include: 

• 

• 

• 

• 

• 

• 

• 

• 

Revision of the rules related to indicative sampling points. 

Introduction of requirements for AQ modelling. 

Simplification for combining PM10/PM2.5 monitoring. 

Introduction of obligations to maintain sampling points. 

Introduction of obligations for spatial representativeness. 

Introduction for AQ modelling data quality objectives. 

Introduction for obligations to monitor more pollutants. 

Revision of the information required in air quality plans. 

 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 67 Benefit Cost Ratio (BCR) for all 69 specific interventions considered in this impact assessment 

Focus on EU air quality standards  BCR 

35  C3 

1  O1  Revise standards for annual PM2.5 

2  O2 

Introduce standards for daily PM2.5 

3  O3 

Revise  average  exposure  standards 
for PM2.5 

4  P1  Revise standards for annual PM10 

5  P2  Revise standards for daily PM10 

H 

H 

36  C4 

37  C5 

L-H 

38  D1 

H 

L 

39  D2 

40  M1 

6  P3 

Introduce 
standards for PM10 

average 

exposure 

L-H 

41  M2 

7  Q1  Revise standards for annual NO2 

8  Q2 

9  Q3 

10  R1 

for 

standards 

Revise/introduce 
hourly/daily NO2 
Introduce 
standards for NO2 
Introduce  standards  for  peak-season 
O3 

exposure 

average 

H 

H 

L 

42  E1 

43  E2 

44  E3 

L/M 

45  E4 

11  R2  Revise standards for 8-hour O3 

L/M 

46  F1 

12  R3 

Introduce 
standards for O3 

average 

exposure 

L/M 

47  F2 

13  S1  Revise standards for annual SO2 

L 

48  F3 

14  S2  Revise standards for daily/hourly SO2  L 

49  F4 

15  T1  Revise standards for daily/8-hour CO  L 

16  U1  Revise standards for annual benzene  L/M 

50  G1 

M 

M 

M 

M 

H 

L 

H 

to 

to 

for 

involve 

assess 

requirements 

transboundary 

‘one  zone,  one  plan’ 

Revise  short-term  action  plans  &  air 
quality plans 
Introduce  additional  short-term  action 
plans 
Introduce requirement to update air quality 
plans 
Revise 
stakeholders  
Introduce  a 
requirement 
Introduce  methodology 
transboundary 
Revise  obligations 
cooperation 
Introduce  minimum  levels  for  financial 
penalties  
Introduce 
compensation  
Introduce  a  fund  to  be  fed  by  penalties 
paid 
Introduce  an  explicit  ‘access  to  justice’ 
clause 
Revise  provisions  related  to  up-to-date 
data 
Introduce  requirement 
health data 
Introduce  use  of  specific  communication 
channels 
Introduce  requirements  for  harmonised 
AQ index 
Focus on AQ monitoring, modelling, plans 
Revise rules related to indicative sampling 
points 

to  health  damage 

to  provide  AQ 

right 

H 

H 

L 

L 

M 

M 

M 

M/H 

M/H 

17  V1 

Revise 
benzo(a)pyrene 

standards 

for 

annual 

L/M 

51  G2 

Introduce requirements for AQ modelling   M/H 

18  W1  Revise standards for annual lead 

L/M 

52  G3 

19  X1  Revise standards for annual arsenic 

L/M 

53  H1 

Revise  rules  for  regular  review  of  AQ 
assessment 
Revise  minimum  number  of  sampling 
points 

L 

M 

20  Y1  Revise standards for annual cadmium  L/M 

54  H2   Simplify combined PM10/PM2.5 monitoring  H 

21  Z1  Revise standards for annual nickel 

22  Ø1 

Introduce  standards  for  additional  air 
pollutants 

Focus on AQ legislative framework 

23  - 

24  A1 

25  A2 

26  A3 

Merge provision of Directives 2008/50 
and 2004/107 
Introduce review triggered by scientific 
progress 
Introduce 
technical progress 
Introduce  option 
standards 

to  notify  stricter 

triggered 

review 

by 

27  A4 

Introduce a list of priority pollutants  

28  B1 

29  B2 

30  B3 

31  B4 

32  B5 

33  C1 

34  C2 

additional 

short-term 

Introduce 
standards  
Introduce  additional  alert/information 
thresholds  
Revise definition of average exposure 
standards 
Introduce  guidance  on  addressing 
exceedances 
Introduce limit values for additional air 
pollutants 
Revise  obligations 
exceedances  
Revise/clarify definition of ‘as short as 
possible’ 

triggered  by 

L 

L 

H 

L 

H 

L 

H 

M 

H 

M 

M 

M 

M 

55  H3 

56 

I1 

57 

I2 

58 

I3 

59  J1 

60  J2 

61  J3 

62  K1 

63  K2 

64  K3 

65  K4 

66  L1 

67  L2 

for 

relocated 

Simplify the definitions of sampling points 
types 
Introduce obligations to maintain sampling 
points 
Introduce obligations to monitor long-term 
trends 
Introduce  a  protocol 
sampling points 
Revise  macro-scale  siting  of  sampling 
points 
Revise  micro-scale  siting  of  sampling 
points 
Introduce 
representativeness 
Revise  AQ  monitoring  data  quality 
objectives  
Introduce  up-to-date  data  at  all  sampling 
points 
Introduce  AQ  modelling  data  quality 
objectives 
Revise  approach 
uncertainty 
Introduce concept of monitoring at ‘super-
sites’ 
Introduce  obligations  to  monitor  more 
pollutants 

to  AQ  assessment 

obligation 

spatial 

for 

68  L3  Revise list of VOC to monitor 

L 

H 

L 

M 

M 

M 

M 

M 

L 

H 

M 

M 

H 

L 

69  N1  Revise the information in air quality plans  H 

 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

10 Analysis of illustrative policy packages 

  Shortcoming I 

Box I Highlights from Policy Option I (POI) 

POI is a package which considers 27 policy interventions in different combinations to address the 

shortcoming identified in the AAQ Directive fitness check around environment and health protection. 

Policy options have been developed to tackle four underlying drivers, some of which can be 

supplemented with further interventions to develop the overall policy package. Three variants are 

presented around the ‘revising air quality objectives’ variant, resulting in six options overall. The six 

options are: 

• 

• 

• 

• 

• 

• 

Revising air quality objectives equivalent to 5 µg/m3 PM2.5 

Revising air quality objectives equivalent to 10 µg/m3 PM2.5 

Revising air quality objectives equivalent to 15 µg/m3 PM2.5 

Establishing air quality objectives for additional air pollutants 

Revising average exposure reduction obligations 

Providing for a regular review of EU air quality standards. 

Air quality standards are fundamental to drive action for the protection of human health and the 

environment. The WHO air quality guidelines (AQGs) published in 2021 provides a new benchmark for 

the setting of air quality standards for many of pollutants covered by the AAQ Directives. Policy 

options I-1, I-2 and I-3 consider evidence for 12 air pollutants and proposes new standards for the 

majority of these with varying levels of ambition.  

Setting health based-air quality standards for a number of emerging pollutants (e.g. UFP, Black 

Carbon and Ammonia) has been considered under option I-4. However, the evidence for this is too 

weak to support  recommendation at this time.  

AEI is currently measured in urban background stations, which might not always be reflective of 

general population exposure. Furthermore, an AEI only exists for PM2.5, but could complement other 

standards to drive concentration reductions in other pollutants. Option I-5 proposes defining 

standards on a regional basis or including additional stations in the calculation of metrics to improve 

the approximation of exposure, whilst considering the merits of AEIs for the different pollutants. 

Likewise requiring that Member States to develop AQ Plans where obligations are not being met, will 

ensure that action is taken to address exceedances (and/or ensure enforcement action can be 

taken).  

There is currently no mandate for regular reviews of air quality standards. Such a review is 

introduced within policy option I-6 which would be triggered by scientific progress. 

 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 68 Policy Options to address environment and health shortcomings (I) 

Policy options 

Policy option I-1  
- air quality objectives 
equivalent to 5 µg/m3 
 PM2.5 
Policy option I-2 
- air quality objectives 
equivalent to 10 µg/m3 
 PM2.5 
Policy option I-3 
- air quality objectives 
equivalent to 15 µg/m3 
 PM2.5 
Policy option I-4 
- establish objectives for 
additional air pollutants 
Policy option I-5 
- revise average exposure 
reduction obligations 
Policy option I-6 
- regular review of EU air 
quality standards 

Specific measures included  
in the respective policy option  

(+ specific measures assessed as sub-options) 

Revise and/or introduce 
standards for target year 
2030 for 12 air pollutants:  
PM2.5, PM10, NO2, O3, SO2, 
CO, BaP, benzene, Pb, As, 
Cd, Ni  

Ø1 

B3 

A1 

O3 

A3 

+ 

+ 

+ 

+ 

+ 

I-1a, I-2a, I-3a: 
Same standards as ‘parent’ options, with  
a later target year 

II-3a: 
P3  

II-1a:  A2  

II-3b: 
R3  

II-1b: 
A4  

II-3c: 
Q3  

 Policy options I-1, I-2 and I-3: air quality objectives 

Outline 

Policy options I-1, I-2 and I-3 focus on revising or introducing standards for each of the 12 air pollutants: 

PM2.5, PM10, NO2, O3, SO2, CO, BaP, benzene, Pb, As, Cd, Ni. As such they draw on a large number of 

underpinning interventions: O1, O2, P1, P2, Q1, Q2, R1, R2, S1, S2, T1, U1, V1, W1, X1, Y1 and Z1.  

The benefits and costs of the different interventions vary depending on the pollutant, and level of 

ambition. In addition, the impacts will vary depending on the timeline for achievement (the impacts of 

achieving standards in 2030 is greater than that in 2050) and for short-term standards, on the number 

of permitted exceedances in a given year. 

Three policy options have been defined representing three different levels of ambition: 

• 

Policy option I-1 - air quality objectives equivalent to 5 µg/m3 PM2.5: This option simulates 

complete alignment with the WHO AQGs. 

• 

Policy option I-2 - air quality objectives equivalent to 10 µg/m3 PM2.5: Implies a moderate 

improvement over the baseline, with high take up of technical mitigation potential, leaving a 

moderate number of exceedances to be dealt with at local level. 

• 

Policy option I-3 - air quality objectives equivalent to 15 µg/m3 PM2.5: Implies a small 

improvement over the baseline, with moderate take up of technical mitigation potential, 

leaving a small number of exceedances to be dealt with at local level.  

The remaining discussion proceeds pollutant by pollutant and standard by standard, providing an 

illustration of the potential ambition that could be allocated to each policy option. 

PM2.5 – annual average [O1 - BCR: High58]: The modelling suggests that by 2030, there will be broad 

compliance with both a 20 and 15 µg/m3  target – for the latter only around 400,000 people will remain 

living in areas of exceedance under OPT15. Under OPT10, around 11 million people remain living in 

areas exceeding 10 µg/m3, implying a moderate level of effort would be needed at local level to meet 

58 As discussed in other sections. The BCR of this and other standards is ranked as high, but is somewhat uncertain. 
This is because the modelling does not predict complete compliance with the standard is achievable through 
technical mitigation only. As such the additional costs (and benefits) of full compliance are uncertain.  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

this ambition. Under OPT5, around 225 million remain in areas of exceedance. Key contributors to 

remaining exceedances above the WHO AQGs appear to be residential (and some road transport) in 

those areas remaining with higher concentrations (e.g. above 15 µg/m3), and non-anthropogenic 

sources in areas just exceeding the WHO AQGs (between 5 – 15 µg/m3). To 2050, a fairly similar pattern 

of results holds: with 0.05m, 8.2m and 108m people living in areas exceeding 15 µg/m3 (OPT15), 10 

µg/m3 (OPT10) and 5 µg/m3 (OPT5) respectively. Amongst stakeholders who responded to the targeted 

Stakeholder Survey, a small overall majority favoured moving in line with the WHO AQG to 2050 

(majority of NGOs and research), but some (public authorities and industry) still favoured less ambitious 

standards. Hence even to 2050, full alignment with the WHO AQG appears challenging – as such the 

standards proposed for 2030 are also retained for the post-2030 option. 

PM2.5 – short-term target [O2 - BCR: High]: The intervention considers the introduction of a new 

standard. In isolation, and alongside the annual average standard for PM2.5, there is a strong case for a 

standard managing PM2.5 peak concentrations. This is underlined by the opinions provided by 

stakeholders through the Targeted Stakeholder Survey and the advice of the WHO, the latter make the 

point that even a small number of extreme peaks could have a significant negative health impact. 

However, the effectiveness of limiting peak concentration as a safety net (and indeed its additional 

value over an annual standard) decreases with the number of exceedance days allowed per year. In 

addition, there is a question as to whether a peak standard for PM2.5 would offer additional value 

alongside a peak standard for PM10. Both are likely to share similar sources, and hence control 

strategies. Hence the additional value would increase to the extent that peaks in each are not 

correlated, and any unique sources driving peaks in PM2.5 can be controlled (i.e. are not from natural 

sources). That said, the WHO have introduced a daily AQG alongside the daily AQG for PM10, the more 

gradated interim targets and guideline for PM2.5 offer greater flexibility to increase ambition and the 

additional cost of monitoring is likely to be small, whilst having a short-term standard for PM2.5 

recognises it is this fraction that is more commonly associated with detrimental health effects. 

Short-term standards for PM2.5 were not captured directly in the modelling. Analysis of current 

monitoring data suggests there are currently broad exceedances of the WHO AQG, but this does not 

capture further improvements going forward in the baseline. Assuming that the statistical relationship 

between long and short-term metrics holds going forward, a multiplier can be applied to annual 

average standards to suggest a complementary daily standard. The multiplier will vary depending on 

the percentile chosen: the multiplier for PM2.5 (99th percentile) is close to 4. This suggests daily limits of 

60 µg/m3 and 40 µg/m3 respectively under options I-3 and I-2. The majority of public authorities, NGOs 

and research organisations considered a 25 µg/m3 level appropriate for 2030 (although the majority of 

industry opted for no standard) and aligning with the WHO AQG in 2050 (with the same pattern across 

stakeholder types as 2030). That said, given that the modelling suggests a similar pattern of results for 

the long-term standard between 2030 and 2050, the options have the same illustrative numerical 

standard for both the 2030 and post-2030 options. 

PM10 – annual average [P1 - BCR: High]: The modelling suggests that by 2030, there will be broad 

compliance with a 30 µg/m3 target – only around 13,000 people will remain living in areas of 

exceedance in OPT15. Under OPT10, around 2.7 million people remain living in areas exceeding 20 

µg/m3, implying a moderate level of effort would be needed at local level to meet this ambition. Under 

OPT5, 13.7 million remain in areas exceeding the WHO AQG 15 µg/m3. This suggests that the WHO AQG 

for PM10 is more achievable than that for PM2.5, however it is acknowledged that there is greater 

 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

uncertainty around the modelling of PM10, which suggests the selection on PM10 standards should be 

more conservative. The analysis chimes well with opinion of stakeholders noted through the targeted 

Stakeholder Survey: For 2030, the majority favoured some reduction from the current standard (most 

selecting 30 or 20µg/m3). To 2050, a fairly similar pattern of results holds: with 0.15m, 2.85m and 

13.5m people living in areas exceeding 30 µg/m3 (OPT15), 20 µg/m3 (OPT10) and 15 µg/m3 (OPT5) 

respectively. Amongst stakeholders who responded to the targeted Stakeholder Survey, to 2050, a large 

overall majority favoured moving in line with the WHO AQG, driven by the majority of NGOs, public 

authorities and research that responded in this way, with industry favouring a less ambitious reduction. 

However, the modelling suggests alignment with the WHO AQG in 2050 would still be challenging, hence 

the standards for 2030 are retained for the post-2030 option (also reflecting greater uncertainty in the 

modelling). 

PM10 – short-term target [P2 - BCR: Low]: The intervention considers the revision of the existing daily 

standard. It appears that there is merit in having a standard to manage peak alongside annual average 

concentrations. However, in addition, there is a question as to whether a peak standard for PM10 would 

offer additional value alongside a peak standard for PM2.5. Both are likely to share similar sources, and 

hence control strategies. Hence the additional value would increase to the extent that peaks in each 

are not correlated, and any unique sources driving peaks in PM10 can be controlled (i.e. are not from 

natural sources). That said, the WHO have introduced a daily AQG for PM2.5 alongside the daily AQG for 

PM10, and any cost saving of not having a short-term target for PM10 is likely to be small. 

Short-term standards for PM10 were not captured directly in the modelling. Analysis of current 

monitoring data suggests there are currently a small level of exceedances against the existing EU 

standard (around 10% of sites), and broad exceedances of the WHO AQG (69% of sites). However, this 

does not capture further improvements going forward in the baseline. Assuming that the statistical 

relationship between long and short-term metrics holds going forward, a multiplier of around 3.5 (99th 

percentile) relative to the long-term standard could apply, suggesting daily limits above the existing 

daily limit value of 50µg/m3. The majority of all stakeholder types except research and academics 

considered the existing 50 µg/m3 level appropriate for 2030 (although a sizeable minority of all groups 

and the majority of researchers felt 45 µg/m3 was appropriate for 2030). A significant majority of all 

groups (except industry) opted for alignment with the WHO AQG in 2050, although based on the 

modelling of average annual pollutants and the statistical multiplier, this may be challenging. As such 

this is only considered in option I-2 and I-1 for 2050. 

NO2 – annual average [Q1 - BCR: High]: The modelling suggests that by 2030, there will be broad 

compliance with a 30 µg/m3 target – only around 500,000 people will remain living in areas of 

exceedance under OPT15. Under OPT10, around 3.5 million people remain living in areas exceeding 20 

µg/m3, implying a moderate level of effort would be needed at local level to meet this ambition. Under 

OPT5, 42.5 million remain in areas exceeding 10 µg/m3. For 2030, the majority of stakeholders 

favoured some reduction from the current standard, with most selecting a moderate reduction to 

30µg/m3. The remaining exceedances relative to the WHO AQG appear to come from shipping, which 

would therefore be the focus of any local action to tackle remaining exceedances. 

To 2050, there is broad compliance with both 30 and 20 µg/m3 targets – with only 0.2m and 0.9m 

people are living in areas exceeding these levels under OPT15 and OPT10 scenarios respectively. Hence 

20 µg/3 is proposed for the I-3 option for post 2030. The modelling also generally suggests only 

 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

moderate non-compliance with the WHO AQGs to 2050: Under OPT5, around 5m people remain living in 

areas exceeding 10 µg/m3 – as such this is adopted for both I-1 and I-2 scenarios. Amongst stakeholders, 

a small overall majority favoured moving in line with the WHO AQG to 2050 (majority of NGOs and 

research organisations), but some (public authorities and industry) still favoured less ambitious 

standards. This somewhat matches stakeholder opinion, with a strong overall majority favouring moving 

in line with the WHO AQG to 2050, driven by the majority of NGOs, public authorities and research that 

responded in this way. 

NO2 – short-term targets [O2 - BCR: High]: The intervention considers both the revision of an existing 

standard (1-hour) and the potential introduction of a new (24-hour) standard. The effectiveness of peak 

concentration as a safety net (and indeed its additional value over an annual standard) decreases with 

the number of allowed exceedance days per year. There is a question as to whether a 1-hour or 24-hour 

peak standard, or both together, would offer the most effective solution. Both are likely to share 

similar sources, and hence control strategies. In addition, stakeholders were less positive about 

introducing a new 24-hour EU standard, in the context of an existing 1-hour standard and noted 

complexity in having multiple standards for multiple pollutants. However, the additional burden of a 

further standard is low given no new monitoring is required. In addition, the WHO noted their 1-hour 

Guideline from 2000 remains valid whilst introducing the new 24-hour AQG. Indeed, the WHO conflated 

the existing 1-hour Guideline with a higher, interim 24-hour target, and as such, the additional steps 

offered by the 24-hour interim targets and guideline provide the opportunity to increase ambition.   

Short-term standards for NO2 were not captured directly in the modelling. Analysis of current 

monitoring data suggests there is broad compliance with the existing 1-hour EU standard, but broad 

exceedance of the WHO 24-hour AQG, although this does not account for further anticipated reductions 

in emissions in the baseline to 2030 and 2050. Again, assuming the statistical relationship between 

annual and daily concentrations holds, this suggests a daily limit 3x above the annual (99th percentile), 

implying standards of 60 and 90 µg/m3 under options I-2 and I-3 respectively for 2030. This also 

corresponds with the views of stakeholders: in response to the targeted Stakeholder Survey where the 

majority of public authorities and research opted for 50 µg/m3 as the appropriate level for 2030, with 

NGO’s split between 50µg/m3 and alignment with the WHO AQGs (majority of industry selected ‘no 

standard’). To 2050, the majority of public authorities, NGOs and research organisations opted for full 

alignment with the WHO AQGs.  

Given the options introduce a new 24-hourly limit, no increase in the ambition of the 1-hour standard is 

included in the options. 

O3 - peak-season [R1 – BCR: Low/Medium]: There remains a clear need for a standard to regulate 

seasonal concentrations of ozone. However, it is not clear that an additional ozone standard targeting 

human health effects of seasonal exposure would deliver additional value over and above the existing 

target. In particular as there are similarities in the way in which the current EU standard for the 

protection of vegetation and the WHO AQG for the protection of human health are defined (e.g. they 

both look at excess concentrations in peak season) and as such would be somewhat correlated. 

Controlling ozone concentrations is complex and challenging and is driven in part by control of 

precursors but also by the meteorological conditions. As such it is questionable whether more ambitious 

standards for ozone would be feasible in all locations. This is perhaps underlined by the difference of 

opinion amongst stakeholders as to whether limit or target values would be most appropriate. 

 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Furthermore, there is currently broad exceedances of both the existing EU target value and the WHO 

AQG, as such substantial effort would be required to meet an even stricter target, whereas the benefits 

of such action (at least in economic impact assessment) often rank below action taken around other 

pollutants. Hence existing target values are retained for all options, but there is a link to average 

exposure indicators under option I-5 and whether such a standard for ozone could help drive progress. 

O3 – short-term targets [R2 – BCR: Low/Medium]: There remains a clear need for a standard to 

regulate short-term concentrations of ozone. However, controlling ozone concentrations is complex and 

challenging, and is driven in part by control of precursors but also by the meteorological conditions. As 

such it is questionable whether very ambitious standards for ozone would be feasible in all locations. 

This is perhaps underlined by the different of opinion amongst stakeholders as to whether limit or 

target values would be most appropriate. Furthermore, the benefits of such action (at least in 

economic impact assessment) often rank below action taken around other pollutants. The monitoring 

data shows there is currently broad exceedances of both the existing EU target value and the WHO 

AQG. The modelling data however suggests that there will be broad compliance with the EU standard by 

2030, but still substantial non-compliance with the WHO AQG both under the baseline (585/1778 sites) 

and MTFR (348/1778 sites). Hence existing target values are retained under all options, but limit values 

could be considered. Given a change in standard is challenging, there is a link to average exposure 

indicators under option I-5 and whether such a standard for ozone could help drive progress. Post-2030 

there is some continued improvement to 2050, although moderate exceedances of the WHO AQG 

remain even in 2050 under the baseline (321 sites) and MTFR (185 sites), as such the same standards as 

for 2030 are again proposed. 

SO2 – annual average [S1 – BCR: Low]: There is no existing EU standard nor WHO AQG. Given only 

limited focus has been placed on this by stakeholders, one could infer revisions to this critical limit are 

not high priority amongst stakeholders. Furthermore, without a specific direction from the WHO there 

is no consistent body of peer reviewed evidence with which an EU standard targeting human health 

could align. There has been substantial progress around SO2 emissions and concentrations historically. 

This may also suggest that a majority of the low-cost actions may have already been captured. As such, 

no option has been included in the policy options. 

SO2 – short-term targets [S2 – BCR: Low]: This intervention considers both: (a) changes to the existing 

EU limit values and (b) addition to or substitution of the existing EU standard with alternative short-

term standards in the WHO Guideline. Based on the monitoring data, there was broad compliance with 

the existing 24-hour and 1-hour EU standards in 2019. In fact, there is currently broad compliance with 

the WHO AQG (only 49 or 3.7% sites exceeded in 2019). Again, assuming a constant statistical 

relationship between annual and daily averages of around 4.5, given there is broad achievement of a 10 

ug/m3 annual average in 2030, this provides support that the WHO AQG is achievable. Stakeholders 

propose that the WHO AQG standards could be met with limited additional effort, and there is even 

some appetite to move beyond the existing 1-hour standard (and hence also beyond the WHO AQG). 

Hence the WHO AQGs are adopted across all options. Introducing a new 10-minute standard will 

introduce additional complexity and administrative burden for public authorities, and as such is not 

included in the options. 

CO – short-term targets [T1 – BCR: Low]: This intervention considers both: (a) changes to the existing 

EU limit value and (b) addition to or substitution of the existing EU standard with alternative short-term 

 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

standards in the WHO Guideline. Based on the monitoring data, there was broad compliance with the 

existing daily maximum 8-hour EU standard in 2019, which matches the WHO AQG. The monitoring data 

also suggests high levels of compliance with lower standards, although a large ‘zero’ response in the 

site data reduces confidence in this assessment and this would go beyond the WHO AQG. Introducing 

new standards will introduce additional complexity and administrative burden for public authorities. 

Furthermore, monitoring data highlights the same stations at risk under an 8-hour maximum, 24 or 1-

hour average, suggesting there would be some overlap in the effects of different standards. But there is 

a larger ‘non-zero’ data return available for both the 24 and 1-hour standards, perhaps suggesting that 

these are simpler to monitor, report and understand. Given CO is harmful when inhaled in large 

amounts over a short space of time, a 1-hour standard, in line with the WHO AQG, may support better 

enforcement and better target risks of CO than a 24-hour standard. 

Benzene – annual average [U1 – BCR: Low/Medium]: The majority of stakeholders favour alignment 

with the WHO AQG in the short term and feel this can be achieved with limited additional effort (with 

the exception of industry). There is broad compliance with the existing standard in 2019 and low 

exceedances relative to the WHO AQG (11%), not accounting for further improvements in the baseline. 

BaP – annual average [V1 – BCR: Low/Medium]: This intervention considers both: (a) changing from 

target to limit value and (b) aligning the standard with the WHO Guideline. Based on the modelling, a 

moderate number (62/334) of sites) or 16m people) will remain in exceedance in 2030 in the baseline. 

However, this does not capture further ambition possible under the policy scenarios – MTFR 

demonstrates the number of sites exceeding could reduce to 10 (or to 3.3m people exposed). Hence 

even setting the existing standard as a limit value (alongside standards for other pollutants) implies 

moderate ambition (I-2). For option I-3, a target value is retained and the standard changed to 1.0. To 

2050, there is broad compliance with the existing EU standard. Furthermore, additional abatement 

potential can be adopted to achieve even broad compliance with a lower standard: under MTFR only 4 

sites (or around 16m people exposed) remain non-compliant against a 0.4 ng/m3 standard in the 

baseline. 

Lead – annual average [W1 – BCR: Low/Medium]: The existing EU standard is equivalent to the current 

WHO AQG, and as such this intervention considers going further in lieu of further guidance from the 

WHO. Based on the monitoring data, no sites currently exceed the EU standard and only a very limited 

number of sites would fall into exceedance under a lower limit value (8 sites against a 0.15 µg/m3 

standard). The benefits of reducing emissions would be significant on a per emission basis, but low 

overall (taking into account that this would affect only few sites). However, the costs of such action are 

highly uncertain given limitations in the underlying evidence. Furthermore, there is a strong preference 

amongst stakeholders for continued consistency with the WHO AQG (perhaps reflecting that without a 

revised AQG they see no strong mandate on health grounds to go further at this stage). 

Arsenic – annual average [X1 – BCR: Low/Medium]: The existing EU standard is already below the 

current WHO AQG. Based on the monitoring data, only a very limited number of sites currently exceed 

the existing target value. As such the costs (and benefits) of implementing the standard as a limit value 

could be small, but this could help drive compliance of the few remaining sites (some of which have 

very high concentrations – max 21 ng/m3 in 2019) and ensure continued performance at compliant sites. 

In terms of going further, the benefits of reducing emissions would be significant on a per emission 

basis and even a large increase in ambition would only bring fairly few sites into exceedance (e.g. 

 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

under a 3 ng/m3 standard, the number of exceedances rises from 8 to 24). Indeed, setting a lower 

target value may drive further improvements at sites which subsequently fall into exceedance. 

However, the costs of such action are highly uncertain given limitations in the underlying evidence. 

Furthermore, there is a strong preference amongst stakeholders to remain at the existing EU standard 

(perhaps reflecting that in lieu of a revised AQG there is no strong mandate on health grounds to go 

further at this stage). 

Cadmium – annual average [Y1 – BCR: Low/Medium]: The existing EU standard is already consistent 

with the current WHO AQG. Based on the monitoring data, only one site currently exceeds the existing 

target value. As such the costs (and benefits) of implementing the standard as a limit value could be 

small, but this could help drive compliance at the remaining site (concentrations of 5.7 ng/m3 in 2019) 

and ensure continued performance at compliant sites. In terms of going further, the benefits of 

reducing emissions would be significant on a per emission basis and even a large increase in ambition 

would only bring fairly few sites into exceedance (e.g. under a 2.5 ng/m3 standard, the number of 

exceedances rises from 1 to 11). Indeed, setting a lower target value may drive further improvements 

at sites which subsequently fall into exceedance. However, the costs of such action are highly uncertain 

given limitations in the underlying evidence. Furthermore, there is a strong preference amongst 

stakeholders to remain at the existing EU standard (perhaps reflecting that in lieu of a revised AQG 

there is no strong mandate on health grounds to go further at this stage). 

Nickel – annual average [Z1 – BCR: Low]: The existing EU standard is already below the current WHO 

AQG. Based on the monitoring data, only three sites currently exceed the existing target value. As such 

the costs (and benefits) of implementing the standard as a limit value could be small, but this could 

help drive compliance at the remaining sites (which can be substantial exceedances – maximum 

concentrations 77 ng/m3 in 2019) and ensure continued performance at compliant sites. In terms of 

going further, the benefits of reducing emissions would be significant on a per emission basis and even 

a large increase in ambition would only bring fairly few sites into exceedance (e.g. under a 10 ng/m3 

standard, the number of exceedances rises from 3 to 12). Indeed, setting a lower target value may 

drive further improvements at sites which subsequently fall into exceedance. However, the costs of 

such action are highly uncertain given limitations in the underlying evidence. Furthermore, there is a 

strong preference amongst stakeholders to remain at the existing EU standard (perhaps reflecting that 

in lieu of a revised AQG there is no strong mandate on health grounds to go further at this stage). 

Summary  

The tables below summarise the illustrative options for 2030 and post-2030. 

 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 69 – Illustrative air pollutant standards for the three policy options - 2030 

Baseline 
(current) 

Policy 
option I-1 
(2030) 

Policy option 
I-2 (2030) 

Policy 
option I-3 
(2030) 

25 / 20   LV  O1 

5 

LV 

10  LV 

15  LV 

- 

- 

O2 

(99%) 15  

LV 

40 (99%)  LV 

60 (99%)  LV 

40  LV 

P1 

15 

LV 

20  LV 

30  LV 

(35 days) 
50  

LV 

P2 

(99%) 45  

LV 

50 (99%)  LV 

50 (90th)  LV 

40  LV 

LV 

10 

LV 

20  LV 

30  LV 

- 

- 

Q2 

(99%) 25  

LV 

60 (99%)  LV 

90 (99%)  LV 

(18 hours) 
200  

LV  Q2 

(99.98%) 200  

LV 

200  LV 

200  LV 

18,000  TV  R1 

60* 

LV 

18,000  TV 

18,000  TV 

(25 days) 
120 

TV  R2 

(99%) 100  

LV 

120 (25 days)  TV  120 (25 days)  TV 

- 

- 

S1 

- 

- 

- 

- 

- 

- 

(3 days) 
125 
(24 hours) 
350 

LV 

S2 

(99%) 40  

LV 

40  LV 

40  LV 

LV 

S2 

(99.98%) 350  

LV 

350  LV 

350  LV 

- 

- 

T1 

35 

LV 

35  LV 

35  LV 

10  LV 

T1 

10 

LV 

10  LV 

10  LV 

5  LV  U1 

1.7 

LV 

1.7  LV 

3  LV 

1  TV  V1 

0.12 

LV 

1.0  LV 

1.0  TV 

0.5  LV  W1 

0.5 

LV 

0.5  LV 

0.5  LV 

6  TV  X1 

6.0 

LV 

6.0  LV 

6.0  LV 

5  TV  Y1 

5.0 

LV 

5.0  LV 

5.0  LV 

20  TV 

Z1 

20 

LV 

20  LV 

20  LV 

PM2.5 
(annual) 
[µg/m3] 
PM2.5 (daily) 
[µg/m3] 
PM10 (annual) 
[µg/m3] 
PM10 (daily) 
[µg/m3] 
NO2 (annual) 
[µg/m3] 
NO2 (daily) 
[µg/m3] 
NO2 (hourly) 
[µg/m3] 
O3 (peak-
season) 
[AOT40 
µg/m3] 
O3 (8-hour 
mean) 
[µg/m3] 
SO2 (annual) 
[µg/m3] 
SO2 (daily) 
[µg/m3] 
SO2 (hourly) 
[µg/m3] 
CO (1-hour) 
[mg/m3] 
CO (8-hour) 
[mg/m3] 
Benzene 
(annual) 
[µg/m3] 
BaP (annual) 
[ng/m3] 
Lead 
(annual) 
[µg/m3] 
Arsenic 
(annual) 
[ng/m3] 
Cadmium 
(annual) 
[ng/m3] 
Nickel 
(annual) 
[ng/m3] 

Note: * figure expressed according to WHO AQG metric of ‘average daily maximum 8-hour mean O3 concentrations of 60 µg/m3, in 

the six consecutive months with the highest six-month running-average O3 concentration’. 

 
 
 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 70– Illustrative air pollutant standards for the three policy options – post 2030 

Baseline 
(current) 

Policy option 
I-1 (post-
2030)* 

Policy option 
I-2 (post-
2030)* 

Policy option 
I-3 (post-
2030)* 

25 / 20   LV  O1 

5  LV 

10  LV 

15  LV 

-  LV  O2 

(99%) 15   LV 

40 (99%)  LV 

60 (99%)  LV 

40  LV 

P1 

15  LV 

20  LV 

30  LV 

(35 days) 50   LV 

P2 

(99%) 45   LV 

45 (99%)  LV 

50 (99%)  LV 

40  LV  Q1 

10  LV 

10  LV 

20  LV 

- 

- 

Q2 

(99%) 25   LV 

25 (99%)  LV 

40 (99%)  LV 

(18 hours) 
200  

LV  Q2 

(99.98%) 200   LV 

200  LV 

200  LV 

18,000  TV 

R1 

60**   LV 

18,000  TV 

18,000  TV 

(25 days) 120  TV 

R2 

(99%) 100   LV 

100  TV 

120  TV 

- 

- 

S1 

- 

- 

- 

- 

- 

- 

(3 days) 125  LV 

S2 

(99%) 40   LV 

40  LV 

40  LV 

(24 hours) 
350 

LV 

S2 

(99.98%) 350   LV 

350  LV 

350  LV 

- 

- 

T1 

10  LV 

T1 

35  LV 

10  LV 

35  LV 

10  LV 

35  LV 

10  LV 

5  LV 

U1 

1.7  LV 

1.7  LV 

1.7  LV 

1  TV 

V1 

0.12  LV 

0.4  LV 

0.7  LV 

0.5  LV  W1 

0.5  LV 

0.5  LV 

0.5  LV 

6  TV 

X1 

6.0  LV 

6.0  LV 

6.0  LV 

5  TV 

Y1 

5.0  LV 

5.0  LV 

5.0  LV 

20  TV 

Z1 

20  LV 

20  LV 

20  LV 

PM2.5 
(annual) 
[µg/m3] 
PM2.5 (daily) 
[µg/m3] 
PM10 (annual) 
[µg/m3] 
PM10 (daily) 
[µg/m3] 
NO2 (annual) 
[µg/m3] 
NO2 (daily) 
[µg/m3] 
NO2 (hourly) 
[µg/m3] 
O3 (peak-
season) 
[AOT40 
µg/m3] 
O3 (8-hour 
mean) 
[µg/m3] 
SO2 (annual) 
[µg/m3] 
SO2 (daily) 
[µg/m3] 
SO2 (hourly) 
[µg/m3] 
CO (1-hour) 
[mg/m3] 
CO (8-hour) 
[mg/m3] 
Benzene 
(annual) 
[µg/m3] 
BaP (annual) 
[ng/m3] 
Lead 
(annual) 
[µg/m3] 
Arsenic 
(annual) 
[ng/m3] 
Cadmium 
(annual) 
[ng/m3] 
Nickel 
(annual) 
[ng/m3] 

Note: * 2050 is defined as an illustrative target year post 2030 – in practice, standards can be set for any year post 2030 (although this 

will have a consequent impact on the benefits and costs of achieving such standards); **figure expressed according to WHO AQG 

metric of ‘average daily maximum 8-hour mean O3 concentrations of 60 µg/m3, in the six consecutive months with the highest six-

month running-average O3 concentration’. 

The overall benefit-cost ratio of all options is high. As demonstrated by the modelling, both the costs 

and benefits increase with ambition, with the most ambitious options delivering significant benefits 

(namely in terms of human health improvements) which significantly outweigh the costs. These are 

summarised for the different modelling scenarios in the following tables.  

 
 
 
 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 71 presents and aggregates the monetised benefits associated with each scenario, relative to the 

baseline. Table 72 presents the total gross benefits relative to the mitigation costs, and the resulting 

total net benefit of the scenarios. Note these estimates do not include the administrative burden, 

which will scale with the ambition of the standards and the number of new exceedances that need to 

be tackled. But overall, given the costs are in the EUR millions, any new administrative burden is 

considered unlikely to change the overall, net positive balance of costs and benefits.  

Table 71 – Benefits of policy options, relative to the baseline (EURm, 2015)59 

Impact 

2030 

2050 

OPT20 

OPT15 

OPT10 

OPT5 

OPT15 

OPT10 

OPT5 

Mortality (VOLY) 

 9,505  

 25,182  

 32,394  

 34,734  

 2,897  

 16,287  

 16,935  

Human health 

Mortality (VSL) 

 33,486  

 85,697  

 110,517  

 118,764  

 11,097  

 63,194  

 65,804  

Morbidity 

 2,343  

 6,141  

 7,992  

 8,610  

 529  

 3,121  

 3,310  

Material 

Crops 

Low  
 High 

Low  

 High 

Environmental 
health 

Forests 

Ecosystems 

Low  

 High 

TOTAL GROSS 
BENEFIT 

29 

67 

 69  

 69  

181 

196 

188 

 222  

 222  

254 

 287  

 287  

204 

276 

 316  

 316  

12 

44 

 52  

 127  

156 

160 

259 

 292  

 712  

258 

 293  

 716  

 101  

 448  

 706  

 863  

 83  

 790  

 931  

 302  

 1,345  

 2,117  

 2,588  

 250  

 2,370  

 2,794  

 12,113  

 32,363  

 41,828  

 45,003  

 3,617  

 20,905  

 21,888  

 36,295  

 93,775  

 121,363  

 130,758  

 12,059  

 69,813  

 73,042  

Note: In some cases, summing the individual impacts in the table does not exactly equate to the totals presented. All totals 

presented are correct, and the variance is due to rounding of individual impacts for presentation in the table. 

Table 72 – Costs and net benefit of the policy options, relative to the baseline (EURm, 2015) 

Impact 

2030 

2050 

TOTAL GROSS 
BENEFIT 

Mitigation costs 

TOTAL NET 
BENEFIT 

Low  

 High 

Low 

High 

OPT20 

OPT15 

OPT10 

OPT5 

OPT15 

OPT10 

OPT5 

 12,113  

 32,363  

 41,828  

 45,003  

 3,617  

 20,905  

 21,888  

 36,295  

 93,775  

 121,363  

 130,758  

 12,059  

 69,813  

 73,042  

-560  

-3,280  

-5,580  

-7,020  

-50  

-4,670  

-6,080  

11,553 

29,083 

36,248 

37,983 

3,567 

16,235 

15,808 

35,735 

90,495 

115,783 

123,738 

12,009 

65,143 

66,962 

Note: In some cases, summing the individual impacts in the table does not exactly equate to the totals presented. All totals 

presented are correct, and the variance is due to rounding of individual impacts for presentation in the table. 

Alongside the core cost-benefits analysis results presented in the above two tables, two further sets of 

sensitivity results have been produced for illustration, as presented in the following two tables. 

59 Macro-economic impact, including productivity impacts, are not included here. 

 
 
 
 
 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

The core set of results presented above focus on the valuation of the health and ecosystem impacts 

(indicators 2, 3 and 5), in comparison to the mitigation costs (indicator 6). As such, this follows the 

approach adopted in previous studies, for example, Clean Air Outlook 2. These results do not take into 

account the wider macro-economic effects, as modelled under Indicator 7, in part due to the potential 

for overlap with impacts modelled under Indicators 2, 3 and 5. As part of this study, the extent of these 

overlaps has further been considered, with a view to combining the results from the core cost-benefit 

and macro-economic analysis into a single compiled set of cost-benefit analysis results.  

Indicator 7 captures the impact of air pollution on labour productivity, using an aggregate relationship 

based on recent OECD work (Dechezleprêtre et al. 2019 ) - the coarse nature of this relationship makes 

it challenging to accurately identify what underlying effects are or are not captured (i.e. how the 

change in air pollution manifests into a change in productivity). Given the direct link to labour force 

participation, expert judgement suggests that at least this would capture work-days lost (WDL). In 

theory the OECD relationship may also capture other effects, e.g. wider morbidity effects where the 

change in health may also affect labour market participation and on-the-job productivity. However, the 

other morbidity health pathways in this study (i.e. other than WDL, such as RADs) are valued 

predominantly considering the direct health care costs only, and do not assess the potential for lost 

wages – as such the potential for the assessment to capture impacts on labour productivity for these 

wider morbidity effects is much lower.  

This uncertainty aside, Table 73 presents an illustration of the potential effect of including the much 

broader assessment of productivity (in place of the quantification of work days lost). As presented 

below, the productivity effect is significantly greater than the estimate of WDL, and hence further 

increases the net benefit of the policy options. Furthermore, the assessment of productivity effects is 

significantly greater than the overall assessment of morbidity effects, hence even where the overlap is 

greater than that accounted for here, this alternative approach to assessing labour market effects 

would still likely increase the net benefit of the scenarios relative to the core cost-benefit analysis. Due 

to the magnitude, taking up and further exploring this channel in future research would be a 

worthwhile endeavour. 

Table 73 - Costs and net benefit of the policy options, relative to the baseline (EURm, 2015) – sensitivity around 
productivity impacts 

Impact 

2030 

2050 

OPT20 

OPT15 

OPT10 

OPT5 

OPT15 

OPT10 

OPT5 

TOTAL GROSS 
BENEFIT  

Low  

 High 

 12,113  

 32,363  

 41,828  

 45,003  

 3,617  

 20,905  

 21,888  

 36,295  

 93,775  

 121,363  

 130,758  

 12,059  

 69,813  

 73,042  

WDL1 

 481  

 1,318  

 1,705  

 1,854  

 98  

 622  

 663  

Productivity2 

 14,998  

 42,998  

 63,067  

 74,020  

 5,330  

 48,106  

 59,617  

Notes: 1. Included in total gross benefit. 2. Not included in total gross benefit, but presenting an alternative approach of estimating 

productivity impacts (‘high’ case compared to WDL). 

Linkages 

This problem has important links to all other policy options. 

 
 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

 Policy option I-4: establish objectives for additional air pollutants 

Outline 

This policy option contains one option: Introduce standards to the AAQ Directives for air pollutants for 

which there are no WHO guideline levels or reference levels (e.g. ammonia, black carbon (BC), ultra-

fine particles (UFP), others). These could take the form of annual or peak standards, and could be 

expressed as limit, target values or otherwise. There was a clear preference amongst stakeholders that 

annual targets were favoured over peak targets for these pollutants.   

These pollutants are not in scope of the WHO guidelines as they concluded that there is insufficient 

data on which to provide recommendations and interim target levels for BC, UFP and ammonia. Thus, 

setting standards would go beyond latest scientific advice and the extent to which they may reduce 

negative health impacts is uncertain. 

More monitoring and evidence are needed before standards can be set for these additional pollutants, 

both around existing pollution levels and health effects, to understand the scale of the problem before 

standards can be set. At the same time, introducing standards can be a driver for additional monitoring. 

The extent to which it contributes to air quality improvements and ecosystems is dependent on the 

level of ambition. Setting standards would go beyond the latest scientific advice and the extent to 

which they may reduce negative health impacts is uncertain. However, this intervention would provide 

the first step towards setting limit values as it would require monitoring concentrations and this 

information could subsequently be used to set limit values. 

Costs are significant, arising primarily from measures to attain the reduction targets and administrative 

burden. There is potential to reduce the administrative burden by taking more coordinated and 

centralised action; however, as none of the pollutants are currently in scope, the administrative burden 

of introducing this intervention would be significant (as well as the costs associated with additional 

monitoring required).  

Sub-options  

There are no sub-options for policy option I-4.  

Linkages 

There are important linkages with a number of other policy options: 

• 

• 

Policy options I-1 to I-3: action to tackle other air pollutants will also somewhat reduce 

emissions and concentrations of emerging pollutants 

Policy option I-6: Introducing a mechanism for adjusting EU air quality standards (based on 

scientific advice, technical progress or maintaining a list of priority air pollutants for emerging 

pollutants). 

• 

Policy option III-3: without monitoring it would not be possible to enforce (and even set) 

standards. Indeed, having a standard would drive the requirement for monitoring and increase 

the effectiveness of this measure. 

 Policy option I-5: Revise average exposure reduction obligations 

Outline 

This policy package contains 5 potential options: B3 which considers how average exposure standards 

could be expressed, and O3, P3, Q3 and R3 which consider whether standards should be set for PM2.5, 

 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

PM10, NO2 and Ozone respectively (with existing standards being revised in the case of PM2.5). These 

measures go hand-in-hand as one should consider the most appropriate form of target, alongside for 

which pollutants, and what level they should be set.  

The analysis suggests there may be benefit in changing the way in which average exposure standards 

are expressed (B3). AEI is currently measured in urban background stations, which might not always be 

reflective of the general population exposure. The general consensus amongst stakeholders is that 

defining standards on a regional basis or including additional stations in the calculation of metrics 

would improve the approximation of exposure. Likewise requiring that Member States develop AQ Plans 

where obligations are not being met, will ensure that action is taken to address exceedances (and/or 

ensure enforcement action can be taken) [BCR B3: high]. 

Average exposure standards can offer an effective complement to absolute limit values especially 

where absolute limits are more conservative. Likewise, there will be interactions between standards set 

for different pollutants. Hence their effectiveness and impact are critically linked to short and long-

term limit values defined for different pollutants. Average exposure standards, where an obligation is 

set at a lower level than the overall standard, can drive further improvement in areas where exposure 

is higher. Where these are defined as relative reductions, they can drive further progress where limit 

values have already been reached. Finally, they can also stimulate (and ensure) action on national or 

regional pollution sources is taken to help tackle exceedances at hotspots (although it is noted there is 

overlap with other regulation especially the NECD). Given its regional nature, the high ambition set by 

the updated WHO AQG, and as it is the key pollutant associated with health effects, maintaining an 

average exposure standard for PM2.5 forms an important part of the policy option [BCR O3: high]. 

Sub-options  

Under the existing AAQ Directives, average exposure standards only exist for PM2.5.  

Policy Sub-Option I-5a inclusion of intervention P3: Introduce average exposure obligations and 

reduction targets. The merits of introducing an average exposure standard for PM10 (P3) will critically 

depend on the outcome of the interventions considering changes to long and short-term absolute 

standards (P1 and P2), and other average exposure standards (PM2.5). The additional value of an 

average exposure standard for PM10 would increase to the extent that peaks are not correlated with 

PM2.5 peaks, and any unique sources driving peaks in PM10 can be controlled (i.e. are not from natural 

sources). Both PM10 and PM2.5 share similar sources and control strategies, hence this option is likely to 

deliver very limited additional value over I-5, whilst increasing administrative costs [BCR P3: 

Low/High].  

Policy Sub-Option I-5b inclusion of intervention R3: Introduce average exposure obligations and 

reduction targets. The merits of introducing an average exposure standard for Ozone (Q3) will critically 

depend on the outcome of the interventions considering changes to long and short-term absolute 

standards (R1, R2 and B5). Existing target value standards for ozone are not widely complied with, 

perhaps in part drive by the fact they are target values. However, the feasibility of setting limit values 

for ozone (B5) is questionable given the importance of transboundary sources and natural factors, and 

relative limitations around control options. To that end, average exposure standards for ozone could 

help drive some improvement where target values do not drive air quality improvement and absolute 

limit values are not feasible and could provide another metric of understanding. However, the ability to 

 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

control concentration levels that pose a challenge to absolute limit values could also pose a challenge 

to average exposure standards, and the mitigation options are similarly more uncertain (relative to 

other pollutants) [BCR R3: Low/Medium].  

Policy Sub-Option I-5c inclusion of intervention Q3: The merits of introducing an average exposure 

standard for NO2 (Q3) will critically depend on the outcome of the interventions considering changes to 

long and short-term absolute standards (Q1 and Q2), and other average exposure standards (PM2.5) given 

NO2 is a precursor of PM2.5. As for I-5a, given this intervention considers the introduction of a new 

standard, a key question is what additional value this will add over and above existing standards. Given 

NO2 is a precursor or PM2.5, to a certain extent Option I-5 alone will drive similar action to reduce NO2 

concentrations in a step-wise fashion. Furthermore, given NO2 is less of a ‘regional’ pollutant relative 

to PM, and is more concentrated in hotspots, this reduces the additional value that Q3 could deliver 

over and above a limit value applying everything (Q1). But such a measure can complement absolute 

limit values to support easing pressure at hotspots  [BCR Q3: Low]. 

 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Box – Level of ambition for average exposure targets 

Alongside the selection of for which pollutants should average exposure indicators and targets be 

defined, there are a number of other parameters associated with the policy options, in particular: the 

level of reduction to be achieved, the geographical disaggregation of the regions to which targets 

apply, and the baseline against which reduction targets are set.  

Additional analysis around AEIs is presented in Appendix 4 – ‘Average exposure and percentage 

reductions in concentrations’. This presents analysis undertaken using the results of the central 

modelling. This compares the relative concentration reductions for PM2.5 and NO2, between the 2020 

baseline and the OPT10 scenario in 2030, on the basis of NUTS1 regions, factoring in all pollution 

sources (i.e. anthropogenic and non-anthropogenic).  

The results of the analysis show that for PM2.5: 

• 

• 

• 

Those regions with higher concentrations in 2020 tend to achieve larger relative reductions to 

2030 under the OPT10 scenario 

There is a wide range in the relative reductions achieved: the reduction at the 5th percentile 

is estimated to be 13.1%, relative to a 46.6% estimated at the 95th percentile 

In the 2020 baseline, 72 of 88 NUTS1 regions have an AEI in excess of the WHO AQG in 2020. 

The majority of these 72 regions then achieve a reduction of more than 25% in concentrations 

under the 2030 OPT10 scenario (61 regions achieve a reduction of 25% or more). However, this 

leaves 11 NUTS1 regions which do not achieve at least a 25% reduction. 

• 

The ability of some regions to achieve large relative reductions may be affected by significant 

non-anthropogenic sources which are more difficult to tackle (and indeed are not targeted in 

the GAINS model). 

For NO2:  

• 

• 

There is a wide range in the relative reductions achieved: the reduction at the 5th percentile 

is estimated to be 21.4%, relative to a 52.6% estimated at the 95th percentile 

In the 2020 baseline, only 8 of 88 NUTS1 regions have an AEI in excess of the WHO AQG. Under 

the OPT10 scenario, all 8 regions achieve a relative reduction in NO2 concentrations of 35% or 

more, with 3 achieving a reduction of over 50%. 

• 

The ability of some regions to achieve large relative reductions may be affected by sources 

which may not be significant in 2020, but become more significant over time – in particular 

those areas which are susceptible to emissions from shipping. 

Linkages 

There are important linkages with a number of other policy options: 

• 

• 

• 

I-1 to I-3 will define absolute standards for the same, or linked pollutants 

I-6 will define the frequency of revision of standards 

II-2 will define the requirements for other standards. 

 Policy option I-6: regular review of EU air quality standards 

 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Outline 

There is currently no mandate for regular reviews of air quality standards. Intervention A1 (BCR: High) 

introduces a review triggered by scientific progress. This policy option contains three possible variants, 

as follows:  

1. 

Introduce a binding schedule of reviews of technical and scientific progress to be undertaken 

by the European Commission - under this variant the Commission would undertake a periodic 

review of technical and scientific progress related to air quality pollutants.  

2. 

Introduce a mechanism for adjusting EU air quality standards upon publication of new WHO 

guidelines - under this variant the Commission would undertake a WHO guidelines related 

review of technical and scientific progress related to air quality pollutants, with a view to 

present a proposal to update the Directive to the European Parliament and the Council.  

3. 

Introduce a mechanism for adjusting air quality standards based on (other) latest scientific 

advice. - under this variant the Commission would undertake a review of new scientific 

knowledge of relevance for air quality pollutants of technical and scientific progress related to 

air quality pollutants, with a view to present a proposal to update the Directive to the 

European Parliament and the Council. 

To complement the mandate for regular reviews of air quality standards, this policy option would 

include a provision to allow Member States to notify the European Commission should they adopt more 

stringent standards in light of the new technical and scientific progress (intervention A3). This would 

enable the European Commission to collect information on technical and scientific knowledge and to 

identify where national/local standards surpass the EU standard, enabling information sharing across 

Member States. 

Direct costs estimated with this policy option are small administrative costs, while direct benefits could 

be large. Poor air quality imposes a high cost on society, so this intervention has potentially large 

indirect benefits. It is difficult to estimate indirect compliance costs.  

Sub-options  

Two sub-options are also under consideration to complement policy option I-6. 

Sub-Option I-6a inclusion of intervention Policy A2: Introduce a mechanism for adjusting EU air 

quality standards based on technical progress in air pollution reduction. Accordingly, the Commission 

would undertake regular reviews of technical progress related to air quality pollutants (this adjustment 

mechanism would look at new information related to the cost of implementing standards that are more 

stringent). Direct costs estimated are small administrative costs. Direct benefits are difficult to 

estimate. Health benefits are likely to be indirect. As poor air quality imposes a high cost on society, 

indirect benefits of this intervention are potentially large. It is difficult to estimate indirect compliance 

costs. We would argue for a medium rating primarily as technological progress is indirectly already 

taken into account when revising the AAQ Directive (e.g. via underlying modelling analysis). This 

intervention would allow this process to be made formal and enable links to be drawn between 

technology progress and health benefits [BCR A2: Low]. 

Sub-Option I-6b inclusion of intervention Policy A4: Keep and periodically update a list of priority air 

pollutants to ensure air pollutants of emerging concern are monitored. The Commission would be 

 
 
 
 
 
 
   
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

required to establish and periodically update a list of additional priority air pollutants to ensure air 

pollutants of emerging concern are monitored. Accordingly, the Commission would regularly update a 

“watch list” for emerging substances as part of the latest technical and scientific review and to demand 

monitoring of such at Member State level. This sub-option would provide a first step for developing 

standards for air quality pollutants that are currently not covered in the AAQ Directive. The Commission 

would be responsible for the watch list, but Member States would need to contribute with monitoring. 

Direct costs estimated are small administrative costs. It is not possible to estimate eventual indirect 

compliance costs. Direct benefits are difficult to estimate, given that this measure will not directly 

lead to revision of the standards. If the identified priority pollutants became regulated via the AAQ 

Directive, this would likely be due to their significant impact on health, which would mean potentially 

large indirect benefits [BCR A4: Low]. 

Linkages 

There are important linkages with a number of other policy options as introducing a review mechanism 

may facilitate revisions to the AAQ Directives by providing the evidence base and legal grounds for 

amending certain provisions (depending on the outcome of the review), in particular: 

• 

• 

• 

Policy option I-5 – it may facilitate the option of expanding exposure reduction targets  

Policy option II-2 – it may facilitate revisions to limit values  

Policy option II-5 – it may facilitate revisions to alert/ information thresholds and action plans. 

In addition, this policy option (namely sub-option II-1b) is expected to complement policy option III-1 

and the introduction of a regular review mechanism of the assessment regime following clear criteria 

defined in the Directive.  

  Shortcoming II 

Box II Highlights from Policy Option II 

POII explores 19 policy interventions (and 2 policy interventions assessed as sub-options) with 

relevant contributions to addressing shortcomings identified in the AAQ Directive fitness check 

around the provision to address governance and enforcement. Policy options have been developed to 

tackle six underlying drivers, some of which can be supplemented with further interventions to 

develop the overall policy package. The six specific drivers are: 

• 

• 

• 

• 

• 

• 

Revising the approach to addressing exceedances and establishing air quality plans 

Revising the number of air pollutants subject to `limit values’ 

Revising the implementation timeline for measures 

Revising the legal tools available in case of non-compliance 

Revising the alert/information thresholds and action plans 

Revising the approach to exceedances due to transboundary air pollution. 

Policy option II-1 offers significant benefit and is key to addressing all exceedance situations and 

delivering action to improve air quality. It should help clarify the obligation to develop effective air 

quality plans and is highly important to the overall objective of the AAQ Directives to provide clean 

air for everyone.  

Limit values better aid the implementation and enforcement of the Directives, a widespread opinion 

also held by stakeholders. Policy option II-2 includes interventions to replace target values with limit 

 
 
 
 
  
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

values, although most benefit would be gained for pollutants where current compliance with target 

values is low e.g. PaH and ozone.  

The purpose of policy option II-3 is to prompt competent authorities to take measures to reduce air 

pollution to a safe level in a timely manner. Policy option II-4 clarifies the penalties to be applied to 

competent authorities where their level of ambition to improve air quality is not sufficient. It also 

clarifies how citizens can rely on legal provisions should they suffer as a result of exceedance 

situations. Furthermore, citizens would benefit from policy option II-5 which would help to drive 

action during episodes of high pollution and help inform the public of such, so they are better 

informed to take action to protect their health. 

Finally, policy option II-6 would provide for a common methodology to assess transboundary 

contributions which would help competent authorities to assess the relevance of transboundary 

transport of air pollution. This in turn would enhance co-operation between neighbouring countries, 

help reduce disagreements on the evidence and magnitude of transboundary pollution, and in turn 

facilitate bilateral discussions. 

 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 74 Policy options to address governance and enforcement shortcomings (II) 

Policy options 

Specific measures included  
in the respective policy option  

Policy option II-1  
- revise approach to addressing exceedances 
and establishing AQ Plans 
Policy option II-2 
- revise number of air pollutants subject to ‘limit 
values’ 
Policy option II-3 
- revise implementation timeline for measures 
Policy option II-4 
- revise legal tools available in case of non-
compliance 
Policy option II-5 
- revise alert/information thresholds and action 
plans 
Policy option II-6 
- revise approach to transboundary air pollution 

B4 

C1 

C3 

D1 

N1 

+ 

B1 

B5 

C2 

C5 

C1 

E1 

E2 

E4 

+ 

B2 

C4 

F2 

F4 

M1  M2 

II-
1a: 
D2 

II-
4a: 
E3  

 Policy option II-1: revise approach to addressing exceedances and establishing AQ plans 

Outline 

This policy option contains five interventions in the core package, covering different actions related to 

the exceedance of limit values and the development of air quality plans: B4 introduces guidance on how 

to address exceedances and on the actions to be taken in case of exceedance of different types of 

standards. Guidance is provided in terms of suitable response measures and on the type of plans to be 

used [BCR B4: Medium]. This intervention is complemented by intervention C1 which further specifies 

the obligation on taking measures to keep exceedance periods as short as possible [BCR C1: Medium] 

and C3 focussing on clearer coordination between short-term action plans and air quality plans. Such 

coordination between short-term action plans and air quality plans would lead to synergies between 

actions, and possibly competent authorities, and the avoidance of inefficiencies [BCR C3: Medium]. To 

guarantee effectiveness and efficiency in the setup and implementation of the air quality plan, 

intervention D1 revises the requirements to involve all relevant stakeholders in the design of the plan. 

This also contributes to the required governance structures for effective policy implementation [BCR 

D1: High]. Finally, the policy option includes intervention N1 which refines the minimum information to 

be included in an air quality plan. This latter intervention prescribes the methodological framework of 

an air quality plan and how the effectiveness of the plan is evaluated. This N1 intervention comes with 

variants emphasising various aspects of the planning process [BCR N1: High]. 

The benefit gained via this policy option is significant and is key to addressing all exceedance situations 

and delivering action to improve air quality. This policy option should clarify the obligation to develop 

effective air quality plans and consequently costs to achieve compliance in as short a time as possible 

are likely to be relatively low. Overall, this policy option is extremely important to the overall 

objective of the AAQ Directives to provide clean air for everyone.  

Sub-options  

Policy Option II-1 could be enhanced by the inclusion of a further intervention presented below: 

Policy Sub-Option II-1a inclusion of intervention D2: Introduce a requirement for Member States to 

harmonise air quality plans and air quality zones (and require a ‘one zone, one plan’ approach). As a 

sub-option to this policy option, D2 could be added, introducing a requirement for Member States to 

harmonise air quality plans and air quality zones (and require a ‘one zone, one plan’ approach). This 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

intervention aims to increase the effectiveness of the Ambient Air Quality Directives by tackling the 

current mismatch between the zones used for assessment and the areas covered by air quality 

management and planning practices. A better alignment of these geographical zones could improve the 

overall efficiency of the AAQ Directives’ implementation. However, this could also interfere with 

Member State competence on internal administrative organisation of the state. 

Linkages 

There are important linkages with other policy options: 

• 

• 

• 

• 

II-3: revise implementation timeline for measures 

II-6: revise approach to exceedances due to transboundary air pollution 

III-5: introduce requirements for modelling quality 

IV-2: revise requirements for air quality health data. 

 Policy option II-2: revise number of air pollutants subject to ‘limit values’ 

Outline 

This policy option contains two potential interventions: B1 which considers the implementation of new 

short-term standards for pollutants to achieve greater alignment with the latest WHO AQGs, and B5 

which considers switching to limit values for those pollutants where standards are currently set as 

target values, namely for: 

• 

• 

• 

air pollutants that tend to depend on transboundary precursors and /or annual variations in 

meteorology (i.e. ozone). 

air pollutants that tend to correspond to specific point source emissions (i.e. most heavy 

metals). 

air pollutants that tend to correspond to emissions from specific widespread practices (e.g. as 

is the case for most polycyclic-aromatic hydrocarbons (PaH)). 

This policy option provides the facilitating legal basis for such standards to be set, and hence it is an 

important component of a wider solution that could be effective in improving air quality and thereby 

improving health protection. It goes hand-in-hand with (and the true impacts are determined by) the 

ambition of the standards set under other interventions (O2, P2, Q2, R2, S2 and T1). As such this 

measure has only low direct costs, but the potential for high benefits [BCR B1: high]. 

Limit values better aid the implementation and enforcement of the Directives, a widespread opinion 

also held by stakeholders. Where there is widespread compliance with existing target values (i.e. heavy 

metals), the impacts of this measure would be small and only affect a limited number of sites but could 

help maintain this positive performance going forward. For PaH and ozone, where current compliance 

with target values is much lower, the impacts would be higher. Although there is likely to be further 

improvement in compliance with existing target values going forward in the baseline, the feasibility of 

setting limit values for ozone is questionable given the importance of transboundary sources and 

natural factors in its formation, feeding into challenges around control options. Where target values are 

changed to limit values, the impacts and risks will critically depend on the standard set, hence there is 

a key interaction with interventions under policy area 1. Depending on the accompanying levels set, 

this intervention could have a small direct effect on improving air quality and thereby improving health 

protection as well as impacting on sensitive groups. [BCR B5: Medium] 

 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Together, this option is critical for facilitating enforcement of the AAQ Directives. That said, this option 

alone will deliver only small additional administrative burden whilst providing the basis for large, 

indirect benefits. 

Sub-options  

There are no sub-options for policy option II-2. 

Linkages 

There are important linkages with a number of other policy options: 

• 

• 

• 

• 

• 

I-1 to I-3: impacts will be critically determined by standards set for each pollutant 

I-5: indirect link to average exposure indicators, which will also interact with achievement of 

short and long-term standards 

I-6: any standards may need to be updated in the future depending on changes to the 

underlying evidence base.  

II-4: limit values better support enforcement of the AAQ Directives, which links to the legal 

tools available in case of non-compliance 

III-1: changes to the range and type of standards may have implications for monitoring 

requirements placed on MS.  

 Policy option II-3: revise implementation timeline for measures 

Outline 

This policy option would amend the legal text to include specific timeframes in which exceedance 

periods must be addressed and for which air quality plans must be updated. The purpose of this policy 

option is to prompt competent authorities to take measures to reduce air pollution to a safe level in a 

timely manner. Regular updates to air quality plans would help the effectiveness of measures and 

would therefore lead to faster action to address exceedances of air quality standards.  

This would involve replacing the current “as short as possible” wording with a specific time period 

within which competent authorities must bring an end to the exceedance of the limit values (amending 

Article 23(1) of Directive 2008/50/EC) [C2 BCR: Medium]. This current provision is open to 

interpretation and risks exceedances remaining systematic and persistent.  

This policy option would also entail introducing a legal duty for competent authorities to update air 

quality plans at regular intervals to keep exceedance periods as short as possible [C5 BCR: Medium]. 

The specific frequency of the update would be determined taking into account the administrative 

burden such updates entail. Based on feedback received from the Targeted Stakeholder Survey, 

updating air quality plans every 3 years is seen as reasonable by stakeholders60. This measure is 

intended to enhance effectiveness of air quality plans by ensuring the relevance of air quality plans and 

associated measures in a changing air quality context for a specific location (i.e. to ensure that 

measures in an air quality plan address new challenges for air quality). It would be important to define 

to what extent air quality plans should be updated.  

60 Based on responses to Targeted Stakeholder Survey where replied ranges from requiring revisions yearly to every 
10 years, with a few stakeholders – including national and regional authorities - mentioning three (3) years as 
adequate.  

 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

On the one hand, this intervention could bring high indirect benefits resulting from more effective air 

quality plans. On the other hand, for countries (regions and municipalities) which face exceedances, 

this measure will result in additional costs from having to update plans regularly. 

Sub-options  

There are no sub-options for policy option II-3. 

Linkages 

There are important linkages with a number of other policy options: 

• 

II-1: This includes revisions to further specify the obligation to take measures to keep 

exceedance periods as short as possible. By clarifying the measures needed to keep 

exceedance periods as short as possible, it will complement policy option II-3 which seeks to 

prompt competent authorities to take measures to reduce air pollution to a safe level in a 

timely manner. This also includes revisions to establish a requirement for Member States to 

involve all relevant stakeholders in air quality plan development and to specify coordination 

arrangements for the development and implementation of air quality plans. In doing so, it will 

complement policy option II-3 which seeks to prompt competent authorities to take measures 

to reduce air pollution to a safe level in a timely manner. 

• 

II-4: This will include provisions to revise the legal tools available in case of non-compliance, 

thus strengthening enforcement (which in turn will prompt competent authorities to take 

measures to reduce air pollution to a safe level in a timely manner, as is the intention of 

policy option II-3). 

 Policy option II-4: revise legal tools available in case of non-compliance 

Outline 

This policy option sets out interventions, which, taken together, will strengthen the legal tools 

available to the public when Member States fail to comply with the Directives. It contains four 

interventions. The first C1 BCR: Medium, further specifies the obligation to take measures to keep 

exceedance periods as short as possible. This sets a benchmark by which Member States should consider 

measures to improve air quality. If a Member State still fails to comply with limit values, intervention 

E1 (BCR: Medium/High) sets out minimum financial penalties that could be levied on competent 

authorities failing to establish effective air quality plans or polluters failing to respect measures under 

air quality plans. The two remaining interventions (E2 BCR: Medium and E4 BCR: High) are directed to 

those suffering damage as a result of failure to comply with the provisions in the Directive. E2 supports 

a right to compensation for damage suffered due to air pollution while E4 proposes an explicit provision 

on access to justice for citizens. Together this policy option clarifies the level of ambition needed and 

the penalties to be applied if this is not taken up by competent authorities. It also clarifies how citizens 

can rely on legal provisions should they suffer as a result of exceedance situations 

Sub-options  

Policy Option II-4 could be enhanced by the inclusion of a further interventions presented below: 

Policy Sub-Option II-4a inclusion of intervention E3: Set up a fund to be fed by the payment of 

penalties and which can be used to compensate damage to health or finance air quality measures. 

While such a fund would be useful to highlight that air quality is an issue that should be addressed and 

it may provide ready access to funds by which competent authorities can take action, it remains 

 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

uncertain which air quality measures would be eligible for funding and who would manage such a fund. 

Moreover, there is also a risk of interfering with Member States’ national funding responsibilities.  

Linkages 

• 

II-2 – revision of the number of air pollutants subject to ‘limit values’ may result in more 

exceedances which in turn will impact the penalties that p may be levied and the number of 

compensation damage claims and access to justice court proceedings. 

• 

II-3 - revise implementation timeline for measures. Penalties and access to justice are 

impacted on when measures are required to be implemented.  

 Policy option II-5: revise alert/information thresholds and action plans 

Outline 

This policy option aims to revise alert and information thresholds and short-term action plans with four 

interventions. B2 introduces additional alert/information thresholds which do not currently address PM 

concentrations. This intervention is likely to have a small positive impact on human health and societal 

costs associated with reduction of healthcare costs via enhanced protection during air pollution 

episodes (e.g. via reduced hospital admissions) [BCR B2: Medium]. This is linked to intervention C4 

which introduces additional short-term action plans for each pollutant to tackle episodic pollution 

events. While this may be beneficial, the impact of this intervention on costs is negligible or slightly 

negative. Countries which do not exceed alert thresholds will not be affected by this intervention [BCR 

C4: Medium]. F2 introduces a requirement to provide AQ health data which is beneficial to individuals, 

particularly those sensitive to air quality during periods of high pollution. It only has a small additional 

cost as many Member States already have the capability to publicise air quality in real time [F2 BCR: 

Medium]. In addition to this, intervention F4 introduces requirements for harmonised AQ index across 

Europe to make air pollution information more readily accessible to members of the public, which will 

help inform citizens of their health risk to air pollution. [BCR F4: Medium].   

This policy option is not particularly costly to implement but it does bring good benefits to drive action 

during episodes of high pollution and help inform the public of such, so they are better informed to 

take action to protect their health. 

Sub-options  

There are no sub-options for policy option II-5. 

Linkages 

• 

II-1 on revisions for the obligations on how to establish AQ plans. Short term action plans are 

similar to air quality plans developed to address long term exceedances of limit values and 

there should be co-ordination in the approach. 

 Policy option II-6: Revise approach to transboundary air pollution 

Outline 

This option contains two interventions which focus on assessing and addressing transboundary air 

pollution in local/regional air quality management: M1 would require the use of an agreed methodology 

when assessing transboundary air pollution/contributions to local/regional air pollution; and M2 would 

 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

require transboundary cooperation and joint action on air quality where the air pollution contribution 

from  transboundary sources are above certain thresholds. 

A common methodology to assess transboundary contributions would help competent authorities to 

assess the relevance of transboundary transport of air pollution. This in turn would enhance co-

operation between neighbouring countries, help reduce disagreements on the evidence and magnitude 

of transboundary pollution, and in turn facilitate bilateral discussions. A common methodology to assess 

transboundary air pollution is not yet in place, although there are agreements for many aspects through 

the Cooperative Programme for Monitoring and Evaluation of the Long-range Transmission of Air 

Pollutants in Europe EMEP and specifically their Task Force on Measurements and Modelling. However, 

the effectiveness of a common methodology is impacted by the willingness of Member States to co-

operate and implement mitigation measures within a joint air quality plan. Implementing this 

intervention would imply additional costs for Member States who do not have the adequate competency 

to measure and model transboundary pollution in place. In addition, there could be additional 

mitigation costs for Member States where transboundary pollution is an issue for having to adapt their 

air quality plans and implement further measures to reduce transboundary pollution. Coherence with 

the methodology used in the EMEP (European Monitoring and Evaluation Programme) for international 

co-operation to solve transboundary air pollution problems under the Convention on Long Range 

Transboundary Air Pollution (CLRTAP) should be taken into account. Although there are likely to be 

additional costs incurred by  many Members States dealing with transboundary issues  the benefits are 

anticipated to outweigh the costs [BCR M1: High]. 

Intra- and inter-EU transboundary air pollution cannot be reduced by one country alone. Article 25 of 

Directive 2008/50/EC states that Member States concerned with transboundary pollution 'shall' 

cooperate to mitigate air pollution for instance through drawing joint or coordinated air quality plans. 

However, the provision limits the obligation to cooperate to exceedances ‘due to significant 

transboundary transport’ which, in practice, results in a lack of cooperation. This intervention would 

imply additional costs for competent authorities in bordering countries were transboundary pollution is 

an issue, through the need to design joint air quality plans. Coherence with the NEC Directive and 

Convention on Long Range Transboundary Air Pollution (CLRTAP) Gothenburg Protocol are also 

important considerations. But requiring joint transboundary cooperation above a specific threshold 

would foster transboundary cooperation and in turn improve air quality in bordering regions and could 

also lead to a more efficient (lower cost) response to reducing concentrations at exceedance points. 

This will become increasingly important going forward as transboundary sources become a 

proportionately higher contributor to overall air pollutant concentrations [BCR M2: medium].  

Interventions M1 and M2 complement each other, as M1 would remove a potentially important 

stumbling block to the effectiveness of M2. 

Sub-options  

There are no sub-options for policy option II-6. 

Linkages 

• 

II-1a: where intervention D2 is included (‘one plan one zone’), this could present a barrier to 

transboundary co-operation between countries. 

 
 
 
 
 
 
 
 
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  Shortcoming III 

Box III Highlights from Policy Option III 

POIII considers 14 policy interventions with relevant contributions to address shortcomings identified 

in the AAQ Directives fitness check around monitoring and assessment of air quality. Policy options 

have been developed to tackle five underlying drivers, and each of these can be supplemented with 

further interventions to develop the overall policy package. The five specific drivers are: 

• 

• 

• 

• 

• 

Improving air quality assessment; 

Require monitoring continuity; 

Require monitoring of other pollutants; 

Improve monitoring quality; 

Introduce modelling quality requirements. 

Although all five policy options could make relevant contributions, Option III-1 presents a particularly 

significant opportunity to enhance the effectiveness of (and the environmental benefits that flow 

from) the AAQ Directives’ implementation and would make a significant contribution to the overall 

impacts of this policy package. This policy option seeks to increase the use of key tools for the 

assessment of air quality, which have historically been limited by an approach reliant on fixed 

monitoring at a minimum number of sampling points. This option mandates the use of models, which 

could deliver wider spatial coverage for air quality assessment purposes. Use of models should be 

supported with sufficient  monitoring sites. This policy option also focuses on the improved use of 

monitoring both spatially and temporally to assess air quality.  

To support the enhanced assessment that can be derived from increased monitoring and binding use 

of models under Policy option III-1, Policy options III-4 and III-5 offer more rigorous quality levels in 

both monitoring and modelling. These quality standards could greatly improve air quality 

management and the harmonisation across all Member States.  

With developing knowledge and understanding of the science of air pollution both on health and 

ecosystem impacts, the research community requires monitoring of emerging pollutants of concern. 

Policy option III-3 offers the opportunity to ensure monitoring networks are in place and of good 

quality to support this research.  

It is also important to track and evaluate how emission reduction and air quality management policy 

is shaping air quality over the longer term to ensure health and environmental impacts are reduced. 

Policy option III-2 offers a good opportunity to establish monitoring protocols to assess air pollution 

levels over the longer term and ensures that any relocation of a sampling point is done following 

clear rules and a protocol. 

 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 75 Policy options to address monitoring & assessment shortcomings (III) 

Policy options 

Specific measures included  
in the respective policy option  

Policy option III-1  
- revise requirements for air quality assessment 

G1  G2 

H1 

H2 

L1 

(+ specific measures assessed as 
sub-options) 
III-
1c: 
K2  

III-
1b: 
H3  

III-1d: 
J3 

+ 

Policy option III-2 
- revise requirements for monitoring continuity 

I1 

I3 

Policy option III-3 
- expand requirements to monitor other air 
pollutants 

L1 

L2 

Policy option III-4 
- revise requirements for monitoring quality  

J1 

J2 

K1 

Policy option III-5 
- introduce requirements for modelling quality 

G2 

K3 

+ 

+ 

+ 

III-
1a: 
G3  
III-
2a: 
I2  
III-
3a: 
L3  
III-
4a: 
K4  

 Policy Option III-1: Revise requirements for air quality assessment 

Policy option III-1 includes interventions which aim to widen the scope for air quality assessment, 

improve the minimum number and type of sampling points and expand monitoring requirements. It is 

made up of five interventions and includes four sub-options. G1(BCR: High) on encouraging the use of 

indicative monitoring and G2 (BCR: Medium/High) mandating the use of models in certain 

circumstances. These interventions offer a far wider spatial assessment, and, importantly, enable 

comprehensive source apportionment and future projections of air quality. These techniques go hand in 

hand and should be part of all responsible air quality managers’ toolkits. In addition this policy option  

includes two further interventions which are likely to result in an increase in the minimum number of 

sampling points (H1 change the minimum number of sampling points (H1 BCR: Medium) and H2 the 

minimum number of sampling points for PM10 and PM2.5 to be considered independently (H2 BCR: 

High)). These likely additional sampling points could be further used to support air quality model 

validation and ensure a broader coverage of monitoring in specific situations. In addition, this policy 

option includes the establishment of “supersites” which monitor a suite of pollutants and help underpin 

the scientific understanding of air quality.  

This policy option is viewed (by the project team) as the most critical revision required to enhance the 

current air quality assessment regime, and at least partly address the identified shortcoming.  

The cost of this policy option is likely to be relatively low, as many of the interventions are already in 

place. The benefits gained from further monitoring and widespread modelling to support certain 

aspects of air quality assessment and management are high. The approach and rigour given to the 

assessment of air quality is fundamental to underpinning effective planning and mitigation, and 

subsequently to the overall objectives of the AAQ Directives. This policy option is viewed as the basic 

level to support that assessment and resolve the identified shortcomings.  

Sub-options 

Policy Option III-1 could be enhanced by the inclusion of further interventions. These are presented 

below: 

Policy Sub-Option III-1a inclusion of intervention G3: Require a regular review of the assessment 

regime following clear criteria defined in the Directive. This intervention builds in a time-based review 

point of the assessment regime. As our data knowledge and understanding increases, which includes 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

new monitoring techniques, advances in modelling, our concern of pollutants develops or dissipates, it 

is important to capture such developments in our air quality assessment approach. However, many of 

these scientific developments already get incorporated into best assessment processes and are 

supported by expert communities such as AQUILA on monitoring and FAIRMODE on modelling (G3 BCR: 

Low).  

Policy Sub-Option III-1b inclusion of intervention H3: Simplify the definitions of types of monitoring 

station and/or sampling point locations - and only differentiate for them to distinguish between 

hotspots or background concentrations. The addition of this intervention to policy option III-1 brings 

clarity on where monitoring stations are placed, which in turn is important to support any mandatory 

modelling and assessment. While on the face this intervention is a monitoring site reclassification 

system, it does offer a re-focus to monitor, and hence assess, in areas of high emissions where 

populations are exposed (hotspots) other than roadside and industrial sites. For example, it could help 

address the issue that residential combustion emissions are not a focus of the assessment process but 

yet are a public health concern. In particular, residential combustion is a key source of PM2.5, which has 

been highlighted by WHO as a major health risk, this intervention could result in a more robust 

assessment regime. This intervention, however, is unlikely to make much difference to monitoring 

networks as areas with residential combustion sources of emission are most likely already being 

assessed. In addition, stakeholders reported that this intervention could result in an over simplification 

of the current monitoring site categorisation (H3 BCR: Low).  

Policy Sub-Option III-1c inclusion of intervention K2: Make it mandatory to provide up-to-date 

information on the pollutant concentration for certain air pollutants for a minimum number of 

sampling points per air quality zone: The addition of this intervention to Policy Option III-1 is focussed 

on timely access to available monitoring data. This brings the advantage of tracking air quality closely, 

which is important to support air quality forecasters and all air quality managers who are implementing 

measures to achieve compliance with limit values. These data also underpin wider assessment of air 

quality across Europe including the assessment of transboundary pollution. However, as many Member 

States already provide access to their monitoring data in real-time, albeit the data are provisional, this 

intervention is unlikely to bring significant benefits across Europe (K2 BCR: Low)  

Policy Sub-Option III-1b inclusion of intervention J3: Introduce the concept of a spatial 

representative area which should be estimated (and reported) for each sampling point (irrespective of 

exceedances being measured or not). The estimation of spatial representativeness that this 

intervention brings has the benefit of assessing the monitoring network and identifying any gaps for 

assessment purposes. A proper assessment of the spatial representativeness of sampling point locations 

will contribute to the overall comparability and harmonization of air quality data. It will also support 

the use of monitoring data in the assessment process, more specifically the estimation of the 

population exposure and the exceedance indicators. It has the potential to have high benefits especially 

to those countries whose monitoring networks just meet minimum numbers of stations. However, for 

others, monitoring networks are typically adequate especially in urban areas.(J3 BCR: Medium)  

Links with other options 

• 

III-2 Revise requirements for monitoring continuity where I1 ensures monitoring continues to 

support assessment purposes; 

 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

• 

III-3 Expand the requirements to monitor other pollutants where both L1 and L2 support the 

monitoring of additional pollutants. Where limit and target values are set for such additional 

pollutants their assessment against such will be required; 

• 

• 

III-4 Revise the requirements for monitoring quality which increases the robustness of 

monitoring data that is needed for air quality assessment; 

III-5 Introduce requirements for modelling quality which sets out standards to support the 

mandatory introduction of modelling under certain circumstances. 

 Policy Option III-2: Revise requirements for monitoring continuity 

To improve the effectiveness of the AAQ Directives, enhance air quality assessment procedures and clarify 

and  update  the  existing  legal  requirements,  POIII-2  comprises  two  policy  interventions  (I1  BCR:  High) 

Specify that sampling points with exceedances of limit values for any of the pollutants measured under 

the  Ambient  Air  Quality  Directives  should  be  maintained  for  a  defined  number  of  years  and  (I3  BCR: 

Medium) Establish a protocol to follow should a sampling point have to be re-located due to, for example, 

infrastructure development or changes in the assessment regimes.  

This policy option provides clarity on the requirements to continue to monitor, which removes the 

flexibility for competent authorities to close a monitoring site without due consideration for all 

pollutants. This risk is of particular concern where limit values are exceeded. This supports the 

development of an air quality plan and is used to assess the impact of the plan following 

implementation. Public access to information on air quality, particularly where an exceedance has been 

recorded, is important for the protection of health.  

This policy option also provides limited flexibility to competent authorities where changes occur to 

affect the performance of a sampling point, such as infrastructure changes. The introduction of a 

monitoring site relocation protocol will help ensure consistency in pollution trend datasets which are 

invaluable over the longer term to assess by how far policy and measures are improving air quality.  

I1 is an important intervention and brings significant benefit to support action to improve air quality in 

known hotspots and has little additional cost.  While I3 supports the longer-term evaluation of air 

pollution where sites are relocated the benefit is high but as a small number of sites are relocated, for 

different reasons, it brings medium overall benefits to air quality across Europe.  

Policy Option III-2 could be enhanced by the inclusion of a further intervention.  

Sub-options 

Policy Sub-Option III-2a inclusion of intervention I2: Include the requirement to monitor long-term 

trends if fixed monitoring stations are discontinued (by assessing air quality via indicative 

measurements or air quality modelling). The assessment of long-term trends in pollution brings merit, 

in that it allows an overall assessment of emissions and air quality used in many monitoring and 

evaluation studies. This intervention builds in a requirement to continue to monitor in a location where 

a competent authority wishes to cease monitoring with a reference sampler. Assessment of long-term 

trends in concentrations would be replaced with indicative samplers or modelling. However, both of 

these have higher uncertainties compared to a reference sampler, so care should be taken overall data 

quality may decrease. This intervention is not expected to bring significant benefits across Europe  

 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Links with other options 

• 

PO III-1 Revise requirements for air quality assessment where the continuity of monitoring is 

important to enable assessment of air quality over the longer term. 

 Policy Option III-3: Expand the requirements to monitor other pollutants  

To improve the effectiveness of the AAQ Directives, enhance air quality assessment procedures and 

clarify and update the existing legal requirements, POIII-3 comprises two policy interventions (L1) 

Require monitoring stations that measure continuously certain emerging air pollutants (e.g. called 

“supersites” across the Member States) and (L2) Require monitoring of additional air pollutants at a 

minimum number of sampling points and with relevant data quality requirements. The assessment of air 

quality cannot be robustly carried out without ambient monitoring of the pollutants of concern.  

Equally, as the scientific knowledge advances, and to underpin that scientific research, monitoring of 

pollutants that are suspected to be of concern is also fundamental. A basic monitoring network of 

emerging pollutants to support such research is key for developing understanding and assessment of 

overall air quality. These interventions are complementary as L1 enables the comparison of emerging 

pollutants and their trends with already monitored pollutants e.g. NOx and PM. Monitoring at supersites 

enables the study of pollutant interactions. However, the number of supersites will be limited and 

therefore L2 which requires a minimum number of sites will help inform of the overall spatial 

concentration coverage of emerging pollutants to be mapped. 

While the establishment of supersites brings high benefit to our overall understanding of air quality and 

emerging pollutants their installation costs are high (L1 BCR: Medium). L2, setting a minimum number of 

sites, has lower comparative costs (L2 BCR: High).  

Sub-options 

Policy Option III-3 could be enhanced by the inclusion of a further intervention. This is presented 

below: 

Policy Sub-Option III-3a inclusion of intervention L3: Expand the list of required and/or 

recommended volatile organic compounds (VOCs) to measure. VOCs are a large group of chemicals that 

are found in many products used for the construction and maintenance of buildings. While there is a 

requirement to monitor some of these substances already in Annex X of Directive 2008/50/EC, this 

intervention requires measurement of additional VOCs which would support the further understanding 

of levels of these diverse group of chemicals in the atmosphere. In the future it is expected that a 

reduction of automotive emissions will be observed as well as solvent emissions from regulated 

industrial activities. This may relatively increase the contribution of other ozone precursors related to 

biogenic sources and emerging emission sources for example, solvent use, architectural emissions, new 

industrial processes, agricultural activities, wastewater and indoor environments. However, the list of 

potential VOCs is extensive and without further analysis into the merits of additional (mandatory) 

monitoring the costs for this intervention are high (L3 BCR: Low).  

Links with other options 

• 

PO III-1 Revise requirements for air quality assessment to include emerging pollutants. 

 Policy Option III-4: Revise requirements for monitoring quality  

 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

To improve the effectiveness of the AAQ Directives, enhance air quality assessment procedures and 

clarify and update the existing legal requirements, POIII-4 comprises three policy interventions (J1 BCR: 

Medium) Further clarify (and reduce flexibilities related to) the macro-siting criteria for sampling points 

and (J2 BCR: Medium) Further clarify (and reduce flexibilities related to) the micro-siting criteria for 

sampling points. These offer clarity on specific issues regarding siting criteria to help harmonise air 

quality monitoring across all Member States. In addition, (K1 BCR: Medium) which further defines the 

data quality requirements for sampling points / measurements used for air quality assessments, sets 

new rules for air quality data management as part of quality assurance/control processes. Therefore, 

this policy option provides support to enhance the quality of monitoring across Europe. As air pollution 

can vary across a short spatial scale, clarity on the detailed macro and micro-siting criteria which 

influences concentrations observed is important to ensure harmonisation to enhance the comparability 

of data. Overall, this policy option sets out the key interventions to increase and clarify the quality of 

monitoring data. While clarity within the provisions to increase monitoring quality brings benefit, 

competent authorities still require some flexibility in siting their monitoring stations. Changes to 

aspects of J2 on micro-siting criteria should not risk what has been deemed as acceptable quality of 

long term datasets from long established sites. Overall, further harmonisation of monitoring quality 

offers high benefit for the comparability of data but any sites which would require to be relocated 

comes with a medium cost, albeit these are not expected to be large in number.  

Sub-options 

Policy Option III-4 could be enhanced by the inclusion of further interventions. These are presented 

below: 

Policy Sub-Option III-4a inclusion of intervention K4: Modify the definition of measurement 

uncertainty by defining it in absolute values and not in percentage values (or a combination of both). 

Confidence in the use of air quality data comes with an understanding of measurement uncertainty. 

This intervention offers a definition of uncertainty both as an absolute and percentage value. This is 

important as for lower limit values uncertainty is better defined in absolute terms ensuring data 

quality. However, feedback from stakeholders supported a combination of both values to be used. 

While the costs for implementing this intervention are low, the benefits to the wider suite of pollutants 

that are measured are also relatively low.  

Links with other options 

• 

PO III-1 Revise requirements for air quality assessment where this policy option to improve 

monitoring quality is important to ensure a robust evidence base for assessment purposes. 

 Policy Option III-5: Introduce requirements for modelling quality  

To improve the effectiveness of the AAQ Directives, enhance air quality assessment procedures and 

clarify and update the existing legal requirements, POIII-5 comprises two policy interventions - (G2) 

Make the use of air quality modelling mandatory as part of air quality assessment (in some 

circumstances) and (K3) Introduce a standardized ‘modelling quality objective’ as a quality control 

mechanism to assess whether a modelling-based assessment is fit-for-purpose.  Air quality models are 

used extensively across Europe, with many support networks available to Member States e.g. EMEP, 

FAIRMODE. Many binding activities, e.g. reporting of short term forecasts, assessing and reporting the 

impacts of air quality plans, are not possible to reliably do without the use of models. The mandatory 

 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

use of models in some circumstances, supported by further monitoring, will lead to more robust 

assessment of air quality over wider spatial areas.  

Therefore, this policy option provides support to enhance the quality of modelling across Europe. 

However, unlike in the measurement of air pollution concentrations, there are no legal requirements to 

direct their use or to meet a certain standard in model techniques (besides setting a level of 

uncertainty not to be exceeded, see Annex I of Directive 2008/50). This policy option sets out the 

circumstances where modelling is required (G2) and the expected level of quality to be met (K3).   

This policy option offers significant support  to the  identification of air quality problems and assessing 

measures to help drive action to improve air quality as part of air quality planning. Models are viewed as 

essential tools for all air quality managers. The benefits are significant and as most Member States already 

have a modelling system in place the costs for implementing this policy option are relatively low.  

Links with other options 

• 

III-1 Revise requirements for air quality assessment where this policy option to introduce 

mandatory modelling is important to ensure a robust evidence base for assessment purposes. 

  Shortcoming IV 

Box IV Highlights from Policy Option IV 

POIV considers 4 policy interventions with relevant contributions to addressing shortcomings 

identified in the AAQ Directive fitness check around the provision of air quality information to the 

public. Policy options have been developed to tackle three underlying drivers, and each of these can 

be supplemented with further interventions to develop the overall policy package. The three specific 

drivers are: 

• 

• 

• 

Revising requirements for up-to-date data; 

Revising requirements for air quality health data; 

Revising requirements for a harmonised air quality indices. 

To deliver cleaner air action is needed at all levels. While governments can implement measures to 

reduce emissions it is essential that the public has ready access to information on air quality to 

support decisions at the individual level. It could help protect sensitive individuals, particularly 

during episodic events of high concentrations, to take necessary steps to reduce their personal 

exposure. In addition, access to information on air quality raises public awareness and brings 

benefits of encouraging uptake of lower emission activities such as use of cleaner transport.  

 This policy option offers some indirect benefits to air quality, but these are likely small, but 

benefits to public health are likely higher. The additional costs to inform the public are relatively 

small as most Member States already have systems in place. 

 
 
 
 
 
 
 
  
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

Table 76 Policy options to address information and communication shortcomings (IV) 

Policy options 

Specific measures included  
in the respective policy option  

(+ specific measures 
assessed as sub-options) 

Policy option IV-1  
- revise requirements for up-to-date data 

F1 

K2 

Policy option IV-2 
- revise requirements for air quality health data 

Policy option IV-3 
- revise requirements of a harmonised air 
quality indices 

F2 

F4 

+ 

IV-
2a: 
F3  

 Policy option IV-1: revise requirements for up-to-date air quality data 

Outline 

This option contains two interventions: F1 which would specify: the timeframe for reporting, the 

data/information to be reported; and K2 which would make it mandatory to provide up-to-date 

information on the pollutant concentration for certain air pollutants for a minimum number of sampling 

points per air quality zone. 

Up-to-date data and information on air quality would allow citizens to make decisions that may impact 

on their health, such as deciding not to participate in outdoor leisure activities or opting for a cleaner 

transport route. Hence there is a benefit in ensuring consistent access for citizens across Member States 

to real-time data and appropriate information, which is publicly accessible. Having such information / 

data would be particularly important for vulnerable groups. There would be some additional 

administrative burden for Member States, furthermore no single communication channel would achieve 

universal coverage and to achieve the benefits would rely on citizens paying attention to, 

understanding, and acting in response to information provided. Where action is taken, the indirect 

benefits would likely outweigh the costs [F1 BCR: Medium]. 

It is also important to highlight there are around the accuracy of real-time information. K2 would 
increase the harmonisation of the reporting of real-time air quality information which, during pollution 
episodic events, and for forecasters brings benefit to the public. Costs are low and those Member States 
already publishing real time data are unlikely to be impacted. There are risks to implementation in 
cases of monitoring sampler or IT system failure as this would inhibit publication of air quality data in 
real-time. Increased resources may be needed for some Member States to ensure immediate data 
quality. [K2 BCR: Low] 

Linkages 

• 

• 

IV-2 and IV-3 - would influence the information to be provided. 

III-4 - Clarity is required if published data under intervention K2 is as provisional data, which 

would not have had time for full quality checks as required under intervention K1. 

 Policy option IV-2: revise requirements for air quality health data 

Outline 

This policy option comprises of one intervention: F2 which would require Member States to provide 

information to the public around the health effects of exposure as soon as exceedances of alert 

thresholds occur. Ensuring that information is provided at the moment it is most relevant and can allow 

citizens to take timely action would increase the effectiveness of information provided. However, 

initial set up costs may be high and this intervention would require closer interaction between health 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

practitioners and policy makers (F2 BCR: Medium).  This option had a high level of support from 

stakeholders. 

Sub-options 

Policy Option IV-2 could be enhanced by the inclusion of a further intervention as presented below: 

Policy Sub-Option IV-2a inclusion of intervention F3: Mandate specific communication channels with 

citizens including user-friendly tools for public access to air quality and health risks information and 

monitoring their use (for example, smartphone apps and/or social media dedicated pages).  Some 

channels may provide faster, more accessible access to information for some groups. However, some 

groups (and in particular some vulnerable groups) will engage with certain communication channels 

more than others. Furthermore, the cost of developing (in particular where these are not currently in 

place) specific, high-tech channels may be more costly, which may divert resources from other, more 

productive, means (F3 BCR: Low).  

Linkages 

• 

PO IV-1 and IV-3 - would influence how and what information is provided. 

 Policy option IV-3: revise requirements of a harmonised air quality indices 

Outline 

This policy option comprises one intervention: F4 which would require Member States to use 

harmonised air quality index bands. Consistency in the information provided to citizens will aid clarity 

and uniformity in the opportunity provided to all EU citizens to take action to reduce their exposure. 

Several variants exist, including adopting the European Air Quality Index (from the EEA) in full, to 

adopting consistent bands. Some stakeholders have expressed doubts around the effectiveness of the 

European Air Quality Index generally (e.g. around its ability to represent multi-pollutant effects), and 

that complete harmonization may restrict the ability of Member States to tailor advice and information 

to the specific situation in each Member State. In any case it seems that any harmonisation in terms of 

bands would be a positive step forward and could go alongside a review of the European Air Quality 

Index itself in order to tackle its flaws (F4 BCR: Medium). 

Linkages 

• 

IV-1 and IV-2 - would influence how and what information is provided. 

 
 
 
 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

11 Summary of policy options  

Four policy options have been proposed to address the four identified shortcomings of the AAQ 

Directives on: 

1.  Environment and Health 

2.  Governance and enforcement 

3.  Monitoring and assessment 

4. 

Information and communication. 

Within each policy option there are a number of sub-options, each of which has a set of proposed 

interventions to improve the Directives. Assessing air quality, addressing exceedances of standards, 

providing timely information to the public and ensuring all stakeholders play their part to establish 

clean air for all, are complex processes with many interlinkages between these activities. Overall, each 

of these activities have substantial importance and each should be addressed for a successful 

improvement to the delivery of clean air across Europe. In reaching such policy decisions it is important 

to recognise the synergies between the various policy options and all of the policy sub-options.  

The cost-benefit analysis conducted suggests there are significant benefits to be gained from setting 

more ambitious air quality standards, and that the benefits gained are likely to significantly outweigh 

the costs. In setting revised objectives for pollutants of concern, consideration should be given not only 

to the value to gained for human health and the environment, but also to how such objectives could be 

met and at what cost, how revisions in monitoring and assessment may impact on these and how such 

information can be readily communicated to the public. Furthermore, even if objectives for pollutants 

are not revised, should changes be made to aspects of monitoring and assessment, then this may impact 

on the pollution burden. For example, should the use of more monitoring, such as indicative monitoring 

and/or modelling be encouraged through policy sub-options, then the understanding of pollutant levels 

across a wider spatial area may increase and impact on where action should be taken. 

The improvement of air quality plans is seen as a key success factor of a revised Directive. This is 

required to bring transparency to the measures Member States are to implement in cases of non-

compliance. Improvement is needed on the effectiveness and efficiency of air quality plans. For any 

revised air quality objectives set for pollutants it is important that a pathway to compliance can be set 

out within an updated air quality planning process. Key milestones on this pathway to compliance 

should be transparent and policy sub-options to address the governance and enforcement of the 

directive should be considered crucial to achieve revised air quality objectives in the near term.  

Some policy sub-options proposed consider the longer term air quality across Europe. While air quality 

modelling of pollutants to 2030 and 2050 have been presented to support this impact assessment, other 

longer term issues such as the importance of pollutants of emerging concern have also been considered. 

In addition, the consideration of a regular review of EU air quality standards is also proposed. Gathering 

data and information on current levels of such emerging pollutants to support research will be key to 

inform how we should deal with such pollutants over the longer term as the scientific evidence 

increases.  

All 69 interventions have been assessed against 12 indicators which cover environmental, societal, 

economic and cost consequences/impacts and all offer benefits to the improvement of air quality for 

 
 
 
 
 
 
 
Study to support the impact assessment for a revision of the EU Ambient Air Quality Directives 

human health and the environment. While these have been amalgamated into policy options to address 

the four shortcomings of the AAQ Directive, some of the interventions offer lower benefits when 

assessed in isolation. However, many of these are likely to bring more benefits when assessed 

synergistically with other interventions. For example, many interventions under the policy option for 

monitoring and assessment are a prerequisite to determine levels of pollution and how these compare 

to any revised air quality standards.  These interlinkages between and within policy options are 

therefore an important aspect of bringing these together into an integrated policy package for further 

consideration by decision makers to deliver a clear pathway for cleaner air for all. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
GETTING IN TOUCH WITH THE EU 

In person 

All over the European Union there are hundreds of Europe Direct information centres. You can find the 
address of the centre nearest you at: https://europa.eu/european-union/contact_en 

On the phone or by email 

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FINDING INFORMATION ABOUT THE EU 

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