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Review of: Provisions for Air Quality
Measurement, Air Quality Modelling,
Management Framework,
Assessment, and Public
Information; and Stakeholder
Consultation Support Assessment of the Stakeholder Expert Group Recommendations for the revision of the current Air Quality Legislation
Client: European Commission, DG Environment
28th June 2013
Review of: Provisions for Air
Quality Measurement, Air Quality
Modelling, Management
Framework, Assessment, and
Public Information; and
Stakeholder Consultation Support
Assessment of the Stakeholder Expert Group Recommendations for the revision of the current Air Quality Legislation
Client: European Commission, DG Environment
Authors:
Enda Hayes, Jo Barnes, Rosemary Bailey, Tim
Chatterton, Duncan Laxen, Jimi Irwin, Martin Bigg
and Jim Longhurst
UWE - University of the West of England, Bristol, UK
Mohammed Hussen Alemu, Louise Martinsen, Berit
Hasler, Jørgen Brandt, and Ole Hertel
DCE - Danish Centre for Environment and Energy,
Aarhus University (AU), Denmark
28th June 2013
Table of Contents
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Review of: Provisions for Air Quality Measurement, Air Quality Modelling, Management Framework, Assessment,
and Public Information; and Stakeholder Consultation Support
List of Tables v
List of Figures vii
1 Introduction to the Stakeholder Expert Group Recommendations 1
1.1 Introduction 1
1.2 Introduction to the selected SEG Recommendations 1
2 Impact Assessment Methodology 8
2.1 Challenges in assessing the SEG Recommendations 8
2.2 Addressing the SEG Challenges 8
2.3 Key Methodological Steps 9
2.3.1 UK and Danish Workshops 9
2.3.2 Top-down Project Team Assessment 9
2.3.3 Bottom-Up Member State Information Requests 10
2.3.4 Case Study Assessment 11
2.3.5 Member State Consultation Survey 11
2.4 Key Assumptions 11
2.5 Overview of the SEG Assessment Results 12
3 SEG 1: Standardise Compliance Projections 13
3.1 What is the problem? 13
3.2 What are the SEG 1 sub-options? 13
3.3 SEG 1 - Assessment of Evidence 14
3.3.1 TNO Report (2012) SWOT Analysis 14
3.3.2 UK and Danish Workshops 14
3.3.3 Member State Information Requests 15
3.3.4 Case Studies 16
3.3.5 Member State Consultation Survey 16
3.4 SEG 1 - High-Level Cost Assessment Conclusions 16
4 SEG 2: Do not relate air quality plans and zones 19
4.1 What is the problem? 19
4.2 What are the SEG 2 sub-options? 19
4.3 SEG 2 – Assessment of Evidence 19
4.3.1 TNO Report (2012) SWOT Analysis 19
4.3.2 UK and Danish Workshops 20
4.3.3 Member State Information Request 20
4.3.4 Case Studies 21
4.3.5 Member State Consultation Survey 21
4.4 SEG 2 - High-Level Assessment Conclusions 21
5 SEG 4: Reduce assessment reporting for standards that are largely met. 23
5.1 What is the problem? 23
5.2 What are the SEG 4 sub-options? 23
5.3 SEG 4 – Assessment of Evidence 24
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5.3.1 TNO Report (2012) SWOT Analysis 24
5.3.2 UK and Danish Workshops 24
5.3.3 Member State Information Request 24
5.3.4 Case Studies 25
5.3.5 Member State Consultation Survey 25
5.4 SEG 4 High-Level Assessment Conclusions 26
6 SEG 5: Clarify the definition of the risk of exceedence 28
6.1 What is the problem? 28
6.2 What are the SEG 5 sub-options? 28
6.3 SEG 5 – Assessment of Evidence 28
6.3.1 TNO Report (2012) SWOT Analysis 29
6.3.2 UK and Danish Workshops 29
6.3.3 Member State Information Request 29
6.3.4 Case Studies 29
6.3.5 Member State Consultation Survey 30
6.4 SEG 5 - High-Level Cost Assessment 30
7 SEG 7: Reduce the administrative burden regarding the development of Short Term
Action Plans 31
7.1 What is the problem? 31
7.2 What are SEG 7 sub-options? 31
7.3 SEG 7 – Assessment of Evidence 31
7.3.1 TNO Report (2012) SWOT Analysis 32
7.3.2 UK and Danish Workshops 32
7.3.3 Member State Information Request 32
7.3.4 Case Studies 33
7.3.5 Member State Consultation Survey 33
7.4 SEG 7 - High-Level Cost Assessment 33
8 SEG 8: Promote the assessment of synergetic measures in air quality plans & SEG 9:
Promote the consideration of antagonisms with other policies in the development of air
quality measures. 35
8.1 What is the problem? 35
8.2 What are the SEG 8/9 sub-options? 35
8.3 SEG 8/9 – Assessment of Evidence 36
8.3.1 TNO Report (2012) SWOT Analysis 36
8.3.2 UK and Danish Workshops 36
8.3.3 Member State Information Request 36
8.3.4 Case Studies 37
8.3.5 Member State Consultation Survey 37
8.4 SEG 8/9 - High-Level Cost Assessment 37
9 SEG 10: Promote Member States developing national or regional air quality strategies
or plans 41
9.1 What is the problem? 41
9.2 What are SEG 10 sub-options? 41
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9.3 SEG 10 – Assessment of Evidence 42
9.3.1 TNO Report (2012) SWOT Analysis 42
9.3.2 UK and Danish Workshops 42
9.3.3 Member State Information Request 42
9.3.4 Case Studies 42
9.3.5 Member State Consultation Survey 43
9.4 SEG 10 - High-Level Cost Assessment 43
10 SEG 20: Require that the public is informed about exceedence of Limit Values as
soon as they occur. 45
10.1 What is the problem? 45
10.2 What are the options? 45
10.3 SEG 20 – Assessment of Evidence 45
10.3.1 TNO Report (2012) SWOT Analysis 46
10.3.2 UK and Danish Workshops 46
10.3.3 Member State Information Request 46
10.3.4 Case Studies 46
10.3.5 Member State Consultation Survey 47
10.4 SEG 20 - High-Level Cost Assessment Conclusions 47
11 SEG 21: Harmonise AQ indices in the EU & SEG 22: Develop a Common AQ Index51
11.1 What is the problem? 51
11.2 What are the SEG 21/22 sub-options? 51
11.3 SEG 21/22 – Assessment of Evidence 51
11.3.1 TNO Report (2012) SWOT Analysis 52
11.3.2 UK and Danish Workshops 52
11.3.3 Member State Information Request 52
11.3.4 Case Studies 53
11.3.5 Member State Consultation Survey 54
11.4 SEG 21/22 - High-Level Cost Assessment Conclusions 54
12 Summary 57
Annex 1: SEG Information Request & Results 60
Introduction to the SEG Information Request 60
Information Request Structure 60
12.1.1 Establishing the Current Baseline within Member States 62
12.1.2 Recommendation Implementation Cost Categories 63
SEG Information Requests Results 66
SEG 1 Information Request Responses 66
SEG 2 Information Request Responses 76
12.1.3 SEG 4 Information Request Responses 80
12.1.4 SEG 5 Information Request Responses 84
SEG 7 Information Request Responses 89
SEG 8/9 Information Request Responses 93
SEG 10 Information Request Responses 98
SEG 20 Information Request Responses 102
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SEG 21/22 Information Request Responses 104
Annex 2: SEG Consultation Survey and Results 108
Copy of the SEG Consultation Survey 108
Summary of the SEG Consultation Responses from Member States 119
Annex 3: Supporting evidence for SEG 1, SEG 4 & SEG 10 130
Annex 4: Review of Member State Online Public Information (SEG 20) 133
Annex 5: Review of Member State Air Quality Indices (SEG 21 / 22) 138
The purpose of Air Quality Indices: 138
12.1.5 Linking air quality to health 138
Providing simple overview information for policy formulation or monitoring 138
Drawing the public’s attention of air quality and raising awareness 139
Types of Air Quality Indices 139
AQI Assessment Methodology 140
Key Findings 141
European Common Air Quality Index (CAQI) 149
Hourly and daily CAQI: 149
Annual (YACAQI): 149
CAQI Index Calculation 150
Revised YACAQI 151
Conclusions: 151
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List of Tables
Table 1: Justification summary for SEG Recommendations taken forward for assessment3
Table 2: Indicative Cost Categorisation 12
Table 3: Overview of SEG Results 12
Table 4: SEG 1 sub-options from TNO Report (2012) 13
Table 5: TNO Report (2012) SWOT analysis for SEG 1 14
Table 6: Summary of Member States Information Request Responses for SEG 1 15
Table 7: SEG 1 - High-Level Cost Assessment 17
Table 8: SEG 2 sub-options from TNO Report (2012) 19
Table 9: TNO Report (2012) SWOT analysis for SEG 2 19
Table 10: Summary of Member States Information Request Responses for SEG 2 20
Table 11: SEG 2 - High-Level Cost Assessment 22
Table 12: SEG 4 sub-options from TNO Report (2012) 23
Table 13: TNO Report (2012) SWOT analysis for SEG 4 24 Table 14: Summary of Member States Information Request Responses for SEG 4 24
Table 15: SEG 5 sub-options from TNO Report (2012) 28
Table 16: Summary of Member States Information Request Responses for SEG 5 29
Table 17: SEG 5 - High-Level Cost Assessment 30
Table 18: SEG 7 sub-options from TNO Report (2012) 31
Table 19: TNO Report (2012) SWOT analysis for SEG 7 32 Table 20: Summary of Member States Information Request Responses for SEG 7 32
Table 21: SEG 7 - High-Level Cost Assessment 33
Table 22: SEG 8/9 sub-options from TNO Report (2012) 35
Table 23: TNO Report (2012) SWOT analysis for SEG 8/9 36
Table 24: Summary of Member States Information Request Responses for SEG 8/936
Table 25: SEG 8/9 - High-Level Cost Assessment 38
Table 26: SEG 10 sub-options from TNO Report (2012) 41
Table 27: Summary of Member States Information Request Responses for SEG 1042
Table 28: SEG 20 sub-options from TNO Report (2012) 45
Table 29: TNO Report (2012) SWOT analysis for SEG 20 46
Table 30: Summary of Member States Information Request Responses for SEG 2046
Table 31: Member States with Online public information systems 48
Table 32: SEG 20 - High-Level Cost Assessment 49
Table 33: SEG 21/22 sub-options from TNO Report (2012) 51
Table 34: TNO Report (2012) SWOT analysis for SEG 21 52
Table 35: TNO Report (2012) SWOT analysis for SEG 22 52
Table 36: Summary of Member States Information Request Responses for SEG
21/22 52
Table 37: Summary of Member States with an AQI 54
Table 38: Common Baseline Assessment Question for each Recommendation 62
Table 39: Recommendation specific questions for SEG 62
Table 40: Cost Category 1 – Equipment and Facilities 63
Table 41: Cost Category 2 – Operation and Maintenance 63
Table 42: Cost Category 3 – New Data Generation & Compilation 64
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Table 43: Cost Category 4 – Reporting & Administration 64
Table 44: Cost Category 5 – Additional Staff Levels and Staff Time 65
Table 45: Cost Category 6 – Staff Capacity Development 65
Table 46: SEG 1 – Information Request Responses 66
Table 47: SEG 2 – Information Request Responses 76
Table 48: SEG 4 – Information Request Responses 80
Table 49: SEG 5 – Information Request Responses 84
Table 50: SEG 7 – Information Request Responses 89
Table 51: SEG 8/9 – Information Request Responses 93
Table 52: SEG 10 – Information Request Responses 98
Table 53: SEG 20 – Information Request Responses 102
Table 54: SEG 21/22 – Information Request Responses 104
Table 55: Supporting evidence for SEG 1 130
Table 56: Supporting evidence for SEG 4 131
Table 57: Supporting evidence for SEG 10 132
Table 58: European (from EU 27+) online public information systems 133
Table 59: European (from EU 27+) and Global Air Quality Indices 143
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List of Figures
Figure 1: Key Methodological Steps in the Assessment of Options 10
Figure 2: Approximate costs based on number of NO2 Annual Mean exceedence zones
(from 2011 461 Forms) at approximate cost of €6,000 per zone 18
Figure 3: Approximate average cost savings based on a 10% reduction of the monitoring
network for Benzene, Lead, Carbon Monoxide and Sulphur Dioxide in each Member
State (2011) 27
Figure 4: Indicative costs for Scenario B (SEG 8/9) 39
Figure 5: Approximate costs of collating local plans to a national level based on the
number of zones exceeding the NO2 annual mean (based on ‘461’ Forms 2011) 44
Figure 6: Process Diagram of the Member States Information Requests for AQUILA.
FAIRMODE and SEG 61
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1 Introduction to the Stakeholder Expert Group Recommendations
1.1 Introduction
This report is prepared in fulfilment of Task 3 under Special Agreement 4 as part of the
Framework Contract ENV C3/2001/FRA/008 in response to a request from the European
Commission, Directorate-General Environment (DG-Environment): Services to support the
“Review of the Thematic Strategy on Air Pollution – Provision for Air Quality Measurement,
Air Quality Modelling, Management Framework, Assessment, and Public Information; and
Stakeholder Consultation Support”.
This report provides an assessment of a selection of recommendations from the first public
stakeholder consultation for the Air Policy Review, conducted between 2011 and 2012,
summarised in a self-standing report prepared by the Environment Agency Austria (UBA)
and the Netherlands Institute for Applied Scientific Research (TNO) “Recommendations for
the EU Air Policy Review” (TNO-060-UT-2012-00877). This report is referred to as the TNO
Report (2012) in this document.
The aim of this document is to provide analysis for the European Commission with respect to
the potential impacts on Member States should the selected Stakeholder Expert Group
(SEG) Recommendations be implemented, with a particular focus on the potential financial
impacts.
1.2 Introduction to the selected SEG Recommendations
Following consultation with DG-Environment, a shortlist of eleven SEG Recommendations
were identified from the full list of twenty-two recommendations provided in the TNO Report
(2012). The key criteria for considering the inclusion (or exclusion) of the 22 options in the
TNO Report (2012) were:
Was the option specifically requested by DG-Environment in the tender specification for
Specific Agreement 4 or at the Project Inception Meeting?
Based upon the description and SWOT analysis of the recommendations reported by TNO,
would the recommendation have implications in terms of amending the Air Quality Directive
(as opposed to simply being a recommendation for provision of guidance or sharing good
practice)?
Is the option likely to be addressed in Task 1 (AQUILA Recommendations) or Task 2
(FAIRMODE Recommendations) under the tender specification for Specific Agreement 4?
Assessment of remaining options based upon TNO SWOT analysis, own expertise and
comparison with other options already under consideration.
The justification for the inclusion or exclusion of the various SEG Recommendations can be
found in Table 1 below. Of the eleven SEG Recommendations being taken forward for
analysis, four had common themes and therefore could be merged into two
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recommendations making a total of nine recommendations for assessment (i.e. SEG 8/9 and
SEG 21/22).
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Table 1: Justification summary for SEG Recommendations taken forward for assessment
Name Justification for inclusion / exclusion Include?
1 Standardise compliance
projections
This recommendation is primarily concerned with the variability of approaches taken by
Member States in projecting future air quality levels in air quality plans and the
standardisation of the projection methodologies.
This recommendation was included for assessment following discussion with European
Commission at the Project Inception Meeting.
2 Do not relate air quality plans
to zones
This recommendation considers the relation of air quality plans and zones (Art 23.1 of the
Air Quality Directive 2008/50/EC).
The inclusion of this recommendation was specifically requested by the European
Commission in the project tender specifications
3 Give guidance and best
practice examples on air
quality plans and measures
This recommendation is primarily concerned with the dissemination and promotion of
guidance and best practice examples as requested by Member States and NGOs.
As a ‘support’ orientated recommendation, this was not shortlisted for assessment.
x
4 Reduce
assessment/reporting for
standards that are largely
met
This recommendation concerns the reduction of assessment and reporting for pollutants
with no exceedences of environmental standards.
The inclusion of this recommendation was specifically requested by the European
Commission in the project tender specifications
5 Clarify the definition of the
risk of exceedence
This recommendation concerns the clarification of the risk of exceedence which requires
Member States to develop Short Term Action Plans.
The inclusion of this recommendation was specifically requested by the European
Commission in the project tender specifications
6 Provide best practice
examples of air quality
management
This recommendation is primarily concerned with the dissemination and promotion of best
practice examples including the possibility of bilateral consultations and study tours.
As a ‘support’ orientated recommendation, this was not shortlisted for assessment.
x
7 Reduce the administrative
burden regarding the
development of short term
action plans
This recommendation concerns the reduction of the administrative burden in the
development of Short Term Action Plans
The inclusion of this recommendation was specifically requested by the European
Commission in the project tender specifications
8 Promote the assessment of
synergistic measures in air
This recommendation is primarily concerned the promotion of ‘win-win’ measures in air
quality plans. This option is closely linked with Recommendation 9 below. As a
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Name Justification for inclusion / exclusion Include?
quality plans ‘management’ orientated recommendation, this is included for further consideration. Given
the obvious overlap between SEG 8 and SEG 9 it is suggested that these recommendations
could be considered as one.
9 Promote the consideration of
antagonisms with other
policies in the development
of AQ measures
Closely linked to Recommendation 8, this recommendation is primarily concerned with the
consideration of ‘trade-offs’ with other policy measures. As a ‘management’ orientated
recommendation, this is included for further consideration. Given the obvious overlap
between SEG 8 and SEG 9 it is suggested that these recommendations could be
considered as one.
10 Promote Member States
developing national or
regional air quality strategies
or plans
This option considers the combination of several individual air quality plans (for each
exceedance situation) into a single regional / national air quality plan, citing the Netherlands
and the UK as examples.
This recommendation was included for assessment following discussion with European
Commission at the Project Inception Meeting.
11 Investigate the networks in
Member States; if needed
enforce provisions
This recommendation is designed to improve the harmonization of monitoring network in
Europe. It suggests that a study may be required to consider the monitoring networks in
detail and further support required from EEA for Member States.
As an ‘investigative' recommendation, this recommendation was not shortlisted.
x
12 Ensure correct station
classification (role ETC/ACC)
This recommendation considers the improvement in the classification of monitoring stations
which may be addressed by the intensification of EEA support.
As a ‘support’ recommendation, this recommendation was not shortlisted.
x
13 Require national reports to
COM on network
design/assessment
methodology
This recommendation would require the inclusion of a provision within the AQD to require
Member States to report how their monitoring network was designed and established. This
option would require an amendment to the AQD and could be consider a ‘management’
option which may complement the options being considered in Task 1 (AQUILA
Recommendations).
As a recommendation covering AQUILA options, this recommendation was not shortlisted.
x
14 Give more guidance on
station siting and network
design
This recommendation considers the requirement for more guidance on station siting and
network design, as such is closely linked to other options.
As a ‘support’ recommendation, this recommendation was not shortlisted.
x
15 Give more detailed siting This recommendation considers the provision of more detailed requirements within the AQD x
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Name Justification for inclusion / exclusion Include?
requirements for hotspots
(both macro and micro siting)
for monitoring in hot-spots.
As a recommendation covering AQUILA options, this recommendation was not shortlisted.
16 Reduce the minimum
number of ozone stations in
N-Europe
This recommendation considered modifying Annex IX of the AQD for a lower number of
monitoring stations in Northern Europe than in Southern Europe.
As a recommendation covering AQUILA options, this recommendation was not shortlisted.
x
17 Stimulate the use of satellite
data
This recommendation considered the utilisation of satellite data for air quality assessments
and for improving and validating models.
As an ‘investigative’ orientated recommendation, this recommendation is not shortlisted..
x
18 Promote regular assessment
of transboundary air pollution
by EEA
This recommendation promotes the regular assessment and wider dissemination of
transboundary air pollution information.
As a ‘support’ orientated recommendation, this option is not shortlisted.
x
19 Give guidance and best
practice on adequate and
timely public information
This recommendation seeks to clarify when and how public information should be provided
through an investigation of Member States practices and the development of guidance.
As an ‘investigative’ and ‘support’ orientated recommendation, this option is not shortlisted.
x
20 Require that the public is
informed about exceedences
of limit values as soon as
they occur
The Air Quality Directive 2008/50/EC requires that the public is immediately informed on an
exceedence of an information or alert threshold but there is no explicit requirement
regarding the exceedence of limit values.
The inclusion of this recommendation was specifically requested by the European
Commission in the project tender specifications
21 Harmonise AQ Indices in the
EU
This recommendation concerns the harmonisation of air quality indices currently utilised by
Member States around Europe. Given the obvious overlap between SEG 21 and SEG 22 it
is suggested that these recommendations could be considered as one.
The inclusion of this recommendation was specifically requested by the European
Commission in the project tender specifications
22 Develop a common AQ Index A Common Air Quality index (CAQI) has been developed by cities in CITEAIR and
INTERREG. This recommendation concerns the implementation of the CAQI. Given the
obvious overlap between SEG 21 and SEG 22 it is suggested that these recommendations
could be considered as one.
The inclusion of this recommendation was specifically requested by the European
Commission in the project tender specifications
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The selected SEG Recommendations to be taken forward are summarised below, including the sub-
option suggested in the TNO Report (2012):
SEG 1: Standardise compliance projections.
- SEG 1(a): Disseminate existing guidance. In 2008 guidance on air quality plans has been
updated, which includes guidance on projections. It has however not yet been disseminated by
the Commission; this can be done.
- SEG 1(b, c & d): Provision of New Guidance, Workshops and Website. FAIRMODE may have a
major role in this.
- SEG 1(e): Make Europe-scale projections on emissions and concentrations better available to
local authorities. The emission and concentration data may be (based on) the EMEP and IIASA
results obtained during policy preparation projects. These data could be made available on a
website of the Commission, EEA or e.g. the GMES Atmospheric Monitoring Service. Note that
this possibility only standardises European data used in compliance projections – but this may
be the most important weakness for local authorities.
- SEG 1(f): Harmonise or standardise modelling of compliance projections
- SEG 1(g): Provide a catalogue of measures that (also) can be used as a benchmark for judging
the effectiveness of measures.
SEG 2: Do not relate air quality plans to zones.
- SEG 2(a): Change in Art 23.1 “air quality plans are established for those zones and
agglomerations” into “air quality plans are established”.
- SEG 2(b): If Annex XV(A) is retained in the revision, change the term “zone” into “surrounding
area”. If Annex XV is not kept, no change is needed.
SEG 4: Reduce assessment / reporting for standards that are largely met.
- SEG 4(a): Further reduction of the assessment requirements for pollutants with low levels (e.g.
SO2, lead, benzene, CO), either by modifying the assessment thresholds, or by modifying the
data quality objectives for different assessment methods.
- SEG 4(b): Withdraw assessment requirements for pollutants and zones where no exceedances
have been observed over a long period.
SEG 5: Clarify the definition of the risk of exceedence.
- SEG 5(a): Guidance on the necessity to prepare action plans in relation to exceedance of alert
thresholds and on short term action plans for ozone already exists. Dissemination could be
intensified or the Guidance on AQ plans and short term action plans developed in 2009 could
be disseminated. Note that the guidance does not relate to the risk of exceedance of limit or
target values.
- SEG 5(b): Develop new guidance in collaboration with e.g. WG on Implementation.
SEG 7: Reduce the administrative burden regarding the development of short term action
plans.
- SEG 7(a): Withdraw the SO2 and/or NO2 alert threshold
- SEG 7(b): Provide guidance and good practice examples (see the recommendations in the
recent AEAT report on short term action plans). Note that guidance on the necessity to prepare
action plans in relation to exceedance of alert thresholds and on short term action plans for
ozone already exists.
SEG 8 & 9: Promote the assessment of synergetic measures in air quality plans & Promote
the consideration of antagonisms with other policies in the development of air quality
measures.
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- SEG 8&9(a): Include a provision requiring consideration of other policies in AQ plans and/or
national programmes.
- SEG 8&9(b): Workshops for exchanging best practices.
- SEG 8&9(c): Provision of guidance documents.
SEG 10: Promote Member States developing national or regional air quality strategies or
plans
- SEG 10(a): Promote in guidance to Member States that local air quality plans are merged into
overarching air quality plans at the regional or national level (as in the Netherlands).
- SEG 10(b): Promote in guidance that Member States report local air quality plans as aggregate
air quality plans (as in the UK).
SEG 20: Require that the public is informed about exceedences of Limit Values as soon as
they occur
- SEG 20(a): Add a provision requiring Member States to inform the public as soon as a Limit
Value is being exceeded.
SEG 21 & 22: Harmonise air quality indices in the EU & Develop a Common Air Quality Index
- SEG 21 & 22(a): Develop a common air quality index through an EU working group and
promote it in subsequent guidance to Member States.
- SEG 21 & 22(b): Develop a common air quality index through an EU working group and include
a requirement to publish a daily air quality index in air quality legislation.
The details of these SEG recommendations are discussed further in subsequent sections.
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2 Impact Assessment Methodology
2.1 Challenges in assessing the SEG Recommendations
In subsequent sections we analyse and assess the selected recommendations from SEG. However, it
should be recognised that the recommendations of SEG, compared to AQUILA (Task 1) and
FAIRMODE (Task 2), have not been subject to the same intensive development processes and
subsequently, in many instances the recommendations are not sufficiently well-defined to allow for the
quantification and monetisation of their impact should they be implemented. This theme is consistent
across all of the SEG options. The SEG Recommendations and sub-options are of a general nature, in
the sense that there is a wide spectrum of possible ways to implement the recommendations, e.g.
from provisions written into legislation, to general guidance. Additionally, without knowing the specific
details, it is difficult to accurately quantify the impacts of their implementation and subsequently
monetise these impacts e.g. what would proposed guidance contain, what is proposed text to be
included as a provision in legislation etc.?
For example, SEG 2 provides possible changes to the text in Art 23.1 and subsequently allows for
Member States to be able to interpret the recommendation accordingly. Conversely, SEG 8/9
suggests the inclusion of “a provision requiring the consideration of other policies” but the detail of
where the provision may be included in legislation and the interpretation of the term ‘consideration’ is
not provided. Without this information there is the potential for substantial variability in interpretation
by Member States and subsequently in the impacts identified, resulting in inherent residual ambiguities
in the findings. For example, one Member State responded in their Information Request “whether or
not there will be additional costs and the amount will depend on the guidance given and how much
this differs from the way we do the modelling at this moment”.
Additionally, the level of cost detail required is often not available (even to make broad cost
estimations) due to various issues, e.g. devolution of responsibilities, integration of management
processes etc. For example, one Member State responded “Sorry for being so weak in financial
issues. They are rather difficult to count. Short term action plans, for example, are prepared by local
governments involving authorities within the work. It is hard to decide how much is done by either of
them.”
2.2 Addressing the SEG Challenges
The challenges outlined above made an accurate quantification and monetisation of the SEG
Recommendations unfeasible, these challenges were further manifested in the Member State
Workshops and the qualitative response to the SEG Member State Information Requests. In January
2013, the Project Team held an internal meeting to amend the methodology to address these
challenges. The proposed solution, which was conveyed to and agreed by DG-Environment, was to
undertake a qualitative analysis of the impact of the recommendations and to provide, where feasible
high-level expert-based assessment of the likely cost implications.
The data for the qualitative assessment was provided from the TNO SWOT analysis (TNO Report,
2012), the Member State Workshops and Member State Information Requests. The high-level
resource/cost information is primarily generated from the Member State Case Studies and the expert-
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based opinion of the Project Team. Where the cost implications could not be quantified and/or
monetised an indicative cost implication (High/Medium/Low) is applied based on balance of evidence.
An assessment of the consequences of the recommendations can lead to several possible results,
depending on how the recommendations are interpreted. Member States were unable to
quantitatively assess the likely impact of these recommendations and monetise that impact. To
address this issue, we have pursued an approach where we have created possible scenarios for the
implementation of the recommendations, where appropriate, and we have qualitatively assessed the
impact of the recommendation for differing scenarios, and where possible we have attempted to
quantify (and monetise) this impact. This has required some assumptions to be made which are
transparent throughout the report. The resulting assessment of the SEG recommendations does not
contain the same quantitative detail as Task 1 (AQUILA) and Task 2 (FAIRMODE) but the assessment
provided will aid in the evolution of these recommendations into policy–ready options.
2.3 Key Methodological Steps
The evidence generated for this assessment has come from a number of key methodological steps.
These steps are outlined in Figure 1 below and in the supportive text.
Given the lack of detailed quantifiable data from the SEG Information Requests, the proposed
methodological steps outlined for AQUILA and FAIRMODE were followed but with a slight variation.
Utilising the qualitative data provided in the Information Request, the data generated in the earlier UK
and Danish workshops and our in-house knowledge and experience, we have taken the SEG
recommendations forward to generate a high-level expert-based analysis which includes (where
possible) quantification and monetisation of the potential impact. While this top-down approach does
not provide the same depth of cost analysis that can be achieved for AQUILA and FAIRMODE, it does
provide an important analysis which will take the SEG recommendations further forward in their
evolution and provide a baseline by which better defined future iterations of the SEG
Recommendations can be assessed.
2.3.1 UK and Danish Workshops
The primary purpose of the initial UK and Danish workshops was to aid the project team in fully
understanding the implications of the proposed Recommendations. Attended by air quality
practitioners from organisations such as national governments, environmental consultancies,
Environment Agency (England & Wales), European Environment Agency, academics etc., these
workshops allowed for a round-table high-level discussion of the various Recommendations, which
assisted the Project Team in framing the problem, scoping the potential solutions and contextualising
the impacts from a Member State’s perspective. This was an important step to understand the
associated challenges and the likely impact of the Recommendations on Member States and
subsequently, allow the Project Team to adjust our methodology accordingly.
2.3.2 Top-down Project Team Assessment
As with the AQUILA and FAIRMODE methodology, we built upon the data generated to date from the
Information Request and UK/Denmark workshops, utilising our Project Team’s in-house expertise and
knowledge to undertake an expert-based cost analysis of the SEG options based on the minimum
requirement required to implementation the options. Outputs from this step were delivered quite
quickly and this generated proxy data and subsequently provided an assumed outline cost
assessment for each Member State.
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Figure 1: Key Methodological Steps in the Assessment of Options
2.3.3 Bottom-Up Member State Information Requests
We calibrated the proxy data from Step 1 with qualitative and semi-quantitative responses from the
Information Requests and case studies of three Member States (case studies selected against high,
medium and low economic cases) to verify and, if necessary, calibrate the results from Step 1. Unlike
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AQUILA and FAIRMODE, this was done through expert-judgement based on qualitative data. This
step improved the accuracy of the outputs from Step 1 and provided bench-marks for each Member
State going forward into the Member State Consultation Survey and the Member State Workshop.
2.3.4 Case Study Assessment
In order to further contextualise the responses from the top-down and bottom-up approaches, a
minimum of three case studies were selected. The criteria for the selection of these case studies were
(not in order of importance):
• To build upon the quality of responses from Information Requests.
• Reflect high, medium and low air quality capacities and capabilities.
• Reflect high, medium and low economies.
The case studies chosen for the SEG recommendations were the United Kingdom, Sweden and
Croatia. These countries were chosen as they were the Member States who provided the best quality
of responses to the Information Request, including some high-level cost implications. Additionally,
they reflect Member States with differing air quality challenges, available resources and management
structures. For example, the United Kingdom has a centralised management approach and is one of
the more advanced Member States in terms of technical / scientific capacity and capabilities. Sweden
has a slightly different management structure in that air quality responsibilities are devolved to a
regional level and subsequently the level of air quality issues and capacity / capabilities vary across
the country. Croatia, as an accession Member State, has a substantial programme of capacity and
capability development underway and therefore some recommendations, which may result in a
reduction in burden for established Member States, may not have a similar impact for Croatia. This
variation in case studies allowed for the variances in the impact of the Recommendations to be
considered.
2.3.5 Member State Consultation Survey
Member States were consulted on the draft cost assessments for each option and asked to quality
assess and provide context to the findings. This permitted the Member State to indicate if the cost
assessment from Steps 1 and 2 was too high or too low and to indicate where changes may be made
to make the cost assessment more accurate. Once this consultation was completed (along with the
workshop findings), we revisited the primary cost analysis calculations with the Member State
responses and adjust accordingly, therefore continually improving the accuracy of the analysis.
During the consultation phase, the Member State meeting provided a forum for participants to review,
identify and comment on any key themes, trends and observations in the draft findings to date. The
workshop served to expand upon the testing of the findings from the consultation survey and utilised
the experience of the workshop participants to help provide further context to the results and clarify
any residual ambiguities.
2.4 Key Assumptions
In order to undertake these impact assessments two key assumptions were made. These
assumptions include:
Guidance is considered non-statutory: Within the context of these SEG recommendations, we
have assumed that any guidance provided is non-statutory i.e. any guidance is provided to Member
States as a support tool for them to inform their own decision making processes but Member
States do not have to strictly adhere to any guidance.
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On-going Member State capability enhancement: In the context of these SEG
recommendations, we have assumed that Member States, as part of their day-to day activities, are
engaged in capability enhancement to ensure that they are up to date with latest air quality
management science and techniques.
Based on responses from Member States in the earlier Information Request, case study interviews
and expert-based judgement, we have applied the following cost categorisations to these SEG
recommendations where an indicative quantifiable cost implication cannot be determined. They are
provided here for information and will be referred to throughout this document. Additional
assumptions, specific to individual SEG recommendations, are discussed in the relevant sections
below.
Table 2: Indicative Cost Categorisation
Cost Description Cost Range (Euros)
High Additional Cost Burden > €60,000
Medium Additional Cost Burden € 20,000 - €60,000
Low Additional Cost Burden < € 20,000
Cost Neutral € 0
Low Cost Burden Reduction < € 20,000
Medium Cost Burden Reduction € 20,000 - €60,000
High Cost Burden Reduction > €60,000
2.5 Overview of the SEG Assessment Results
Following this methodology we have been able to provide high-level indicative costs for six of the nine
SEG Recommendations considered and we have utilised the cost categorisation outlined above for
the remaining three SEG Recommendations (Table 3). Each SEG Recommendation is considered
individually in the following sections.
Table 3: Overview of SEG Results
SEG Recommendation High-Level Indicative Quantified Results
Indicative Cost Categorisation
SEG 1
SEG 2
SEG 4
SEG 5
SEG 7
SEG 8/9
SEG 10
SEG 20
SEG 21/22
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3 SEG 1: Standardise Compliance Projections
3.1 What is the problem?
In air quality plans, projections of future air quality levels need to be made in order to see whether the
plans are adequate to meet the air quality standard. Member States have widely varying approaches
to this, and the credibility of the projections is not always clear, leading to an uneven playing field.
Member States are also very different in their capabilities to make projections. There are several
possibilities for harmonising the compliance projections.
3.2 What are the SEG 1 sub-options?
Table 4 provides the sub-options for this SEG Recommendation including the pros and cons provided
in the TNO Report (2012).
Table 4: SEG 1 sub-options from TNO Report (2012)
Option Description Pros Cons
1 (a) Disseminate existing guidance. In 2008,
guidance on air quality plans was
updated, which included guidance on
projections. It has, however, not yet
been disseminated by the Commission;
this can be done.
Better expertise in Member
States on compliance
projections
Guidance needs to be
checked and possibly
updated
1
(b, c & d)
Provision of New Guidance, Workshops
and Website. FAIRMODE may have a
major role in this.
- -
1 (e) Make Europe-scale projections on
emissions and concentrations better
available to local authorities. The
emission and concentration data may
be (based on) the EMEP and IIASA
results obtained during policy
preparation projects. These data could
be made available on a website of the
Commission, EEA or e.g. the GMES
Atmospheric Monitoring Service. Note
that this possibility only standardises
European data used in compliance
projections – but this may be the most
important weakness for local
authorities.
More realistic air quality
projections and more
credible air quality plans
Harmonisation of air quality
projections
Building up and
maintaining a data
infrastructure is
burdensome (but may fit
well in the remit of EEA
or GMES Atmospheric
Services)
1(f) Harmonise or standardise modelling of
compliance projections
Better insight into credibility
of projections
Often improvement of
projections
Harmonisation
Burden to MS
Should not interfere with
existing good practice
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1(g) Provide a catalogue of measures that
(also) can be used as a benchmark for
judging the effectiveness of measures.
Tool for informing policy
makers on possible
measures
Insight for policy makers in
the effectiveness of
measures
Insight for Commission in the
effectiveness of measures in
Member States
The development
requires substantial
effort
3.3 SEG 1 - Assessment of Evidence
The following section provides an assessment of the available evidence to determine the likely impact
of the SEG 1 Recommendation. This is based upon evidence from the TNO Report (2012) SWOT
analysis, the UK and Danish Workshops, the Member State SEG Information Requests, the Member
State Case Studies and Member State Consultation Survey in addition to the expert-based judgement
of the Project Team.
3.3.1 TNO Report (2012) SWOT Analysis
In their SWOT analysis, TNO Report (2012) assessed this recommendation as follows (the burden to
Member States is highlighted in bold):
Table 5: TNO Report (2012) SWOT analysis for SEG 1
Aspects Relevant for Prioritisation Importance of Aspect Score
Health / Env Improvement Moderately Favourable 2
Harmonisation among MS Moderately Favourable 2
Admin burden to Commission Moderately Unfavourable -2
Burden to MS Moderately Unfavourable -2
Subsidiarity Moderately Unfavourable -2
Complexity of Legislation Moderately Unfavourable -2
Cost of Implementation Neutral 0
Regulatory Stability Slightly Unfavourable -1
3.3.2 UK and Danish Workshops
Delegates recognised that harmonisation or standardisation of compliance projections would be
incredibly difficult to achieve and would require substantial effort from the Commission and detailed
consultation with Member States. It was suggested that harmonisation or standardisation of
compliance projections may be neither possible nor particularly desirable for Member State who
already employ their own models which may be more locally appropriate, though it was argued that
Member States without existing modelling capacity would benefit from standardisation. The
development of guidance and exchange of activities would help the air quality community and as a
consequence, broad standardisation of methodologies may be the outcome.
There was some ambiguity in the delegates’ interpretation of this option regarding the catalogue of
measures that could be used as a benchmark for judging the effectiveness of measures. Workshop
delegates were unclear whether the benchmarking would benefit Member States or be used to
penalise those that were not complying. It was argued by delegates that the value of making Europe-
scale projections of emissions and concentrations better available to local authorities was dependent
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on the user, however, from a scientific perspective, it was suggested that it would be useful to
compare existing models.
Delegates agreed that the standardisation or harmonisation of compliance projections would incur cost
implications on all Member States but this would vary depending on existing baseline capacities,
capabilities and methodologies utilised. Additionally, without knowing the details of proposed
standardisation or harmonisation is was not deemed possible for Member States to be able to
accurately determine the cost implications as it was not possible to determine how different the
proposed method would deviate from Member States current activities. However, any standardisation
methodology would incur a cost implication on all Member States.
3.3.3 Member State Information Requests
All Information Request responses for this Recommendation can be found in Annex 1.
Depending on the sub-option being considered the cost implications varied between respondents.
Sweden and Croatia provided indicative costs for baseline activities but predominantly all responses
were qualitative rather than quantitative. The qualitative responses are outlined in the following Table.
Table 6: Summary of Member States Information Request Responses for SEG 1
SEG 1
Sub-Option
Cost Increase Cost Neutral Cost Decrease No Assessment
Option 1(a) 7
BE, CZ, FI, FR, HR,
HU, LT
2
DE, SE
0 2
GB, RO
Option 1(b,c,d) 4
BE, FR. HR, LT
3
CZ, DE, SE
0 4
FI, GB, HU, RO
Option 1(e) 1
HR
6
BE, CZ, DE, FR, LT,
SE
0 4
Fi, GB, HU, RO
Option 1(f) 4
BE, CZ, DE, LT
2
FR, SE
0 5
FI, GB, HR, HU, RO
Option 1(g) 1
LT
6
BE, CZ, DE, FR,
HR, SE
0 4
FI, GB, HU, RO
The Information Request responses indicated that the cost implications varied depending on the
options being considered, however, the responses do support the SWOT analysis in the TNO Report
(2012) and the UK / Danish Workshops that the implementation of a harmonised or standardised
compliance projection methodology or support tools would incur a cost impact on Member States.
Member States were unable to provide an estimation of costs due to the lack of detail in the
recommendation and sub-options e.g. “the amount will depend on guidance given and how much this
differs from the way we do modelling at the moment (BE)” and “it is not clear what this
recommendation would require Member States to do…we are not able to estimate costs (GB)”.
The overall theme from Member State responses was that the case for a standardised compliance
projection methodology had not yet been made but it may be a useful step forward. However,
substantial consultation with the Member States would be required to develop this approach.
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3.3.4 Case Studies
United Kingdom
The UK stated that the implementation of a standardised compliance projection methodology would
have substantial cost implications for all Member States, but the scale of the cost is unknown without
knowing the details of the proposed method. There would be substantial variation in burden across all
Member States and the level of burden would depend on the method by which a standardised
approach is implemented (e.g. through guidance or through a legislative requirement). The various
sub-options for this recommendation would have differing impacts. Further conversations with UK
colleagues in a Devolved Administration (i.e. Welsh Government) provided indicative costs of
approximately £5,000 (approximately €6,000) per zone per pollutant to model for compliance
projection although this indicative cost may vary substantially depending on the size of the zone and
scale of this problem.
Sweden
Sweden suggested that a standardise compliance projection would incur costs to develop baseline
capabilities and capacities but this would vary from Member State to Member State and may not be
substantial (see FAIRMODE Report). Sweden suggested that this recommendation would be
desirable but more guidance and follow-up would be required. In Sweden’s Information Request
response they outlined that they had commissioned modelling studies for three cities for NO2 at a cost
of 135,000SEK i.e. €5,400 per city.
Croatia
Croatia use monitoring data to identify baseline measurements and to identify whether measures have
been implemented, with modelling to determine how much of a reduction is required. Timescale for
implementation of measures is dependent on cost of implementation and the availability of resources.
Measures were devised based on their suitability to achieve the Limit Values and so the timescale for
achievement of the Limit Value is somewhat implicit. Croatia is currently upgrading its monitoring
network to meet compliance requirements (see Recommendation 4) and so this would be an
additional cost of implementing this Recommendation. In principle this Recommendation would be
useful, particularly if guidance included good practice Member State case studies. Croatia agrees with
the qualitative judgement for this recommendation that there would be a cost implication for all
Member States (€20-60k, but closer to €60k).
3.3.5 Member State Consultation Survey
All Consultation Survey responses for this Recommendation can be found in Annex 2.
The consultation responses again highlighted the likely large variation in the cost implications for the
various different sub-options and the variation between Member States depending on their baseline
activities. The majority of respondents (80%) agreed with our high-level cost assessment, i.e. the
implementation of this recommendation would have a medium cost (€20-€60k) for those Member
States that already have an exceedence and have already, or are in the process of, undertaking the
development of an air quality action plan and projections. One respondent, who disagreed, did state
that “any implementation of this option would be likely to involve cost”.
3.4 SEG 1 - High-Level Cost Assessment Conclusions
The available evidence all indicates that the implementation of this option would incur additional cost
on Member States but that the quantification of this cost could not be determined due to the lack of
specificity in the recommendation and sub-options.
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Based on this evidence we have estimated that there are two likely scenarios and subsequent cost
implications as outlined in the Table below.
Table 7: SEG 1 - High-Level Cost Assessment
Scenario Description Qualitative High Level Cost Assessment Cost
Assessment
A A Member State has no
exceedences and therefore
does not have the need to
develop air quality plans
and project future air
quality concentrations.
The provision of standardised compliance
projection guidance and support tools would
be useful for these Member States but would
have no cost implications unless that Member
State has an exceedence in the future.
Cost Neutral
B A Member State has an
exceedence and has
already, or is in the
process of, undertaking the
development of an air
quality action plan and
projections.
It is recognised that there is variation in the
approaches Member States take to
compliance projections. However, the scale of
cost burden will vary among Member States
and will be depend on how a standardised
projection methodology is promoted, e.g.
through guidance or through legislation.
This indicative cost implication is based on the
requirement for a Member State to adapt and
build capacity and capabilities for a
standardise approach.
The cost of actually implementing a
standardised approach may be much higher
depending on the methodology, number of
zones exceeding etc. (see Figure below).
Medium
Additional Cost
Burden
(€20 – €60k)
Should a standardise compliance projection approach be applied across all Member States using a
modelling methodology, then based on the approximate costs provide through the case studies, an
indicative cost could be estimated. It is important to note that this would be the actual cost of
undertaking a proposed standardise modelling method, it does not include the cost of establishing
baseline modelling capacity and capabilities (these costs are outlined in the FAIRMODE Report).
Using indicative worst-case costs provided by the UK case study, the approximate cost of compliance
projection per zone can be estimated at €6,000. Utilising data provided by Member States through
their ‘461’ Forms, the number of zones exceeding the annual mean Limit Value for NO2 has been
determined (See Annex 3). Applying the indicative modelling cost of €6,000 per zone this gives an
approximate cost of compliance projection using modelling across all Member States. It should be
noted that UK, FR, NL, CZ, BE and DK already utilised modelling as a supplementary assessment
methodology.
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Figure 2: Approximate costs based on number of NO2 Annual Mean exceedence zones (from
2011 461 Forms) at approximate cost of €6,000 per zone
€ 342.000
€ 282.000
€ 240.000
€ 156.000
€ 54.000
€ 54.000
€ 48.000
€ 30.000
€ 24.000
€ 18.000
€ 18.000
€ 12.000
€ 12.000
€ 12.000
€ 12.000
€ 6.000
€ 6.000
€ 6.000
€ 6.000
€ 6.000
€ 6.000
€ -
€ -
€ -
€ -
€ -
€ -
€ - €
-
€ 5
0.0
00
€ 1
00
.00
0
€ 1
50
.00
0
€ 2
00
.00
0
€ 2
50
.00
0
€ 3
00
.00
0
€ 3
50
.00
0
€ 4
00
.00
0
DE
IT
UK
FR
AT
NL
ES
PL
CZ
BE
SK
BG
HU
PT
RO
DK
EL
FI
LU
LV
SE
CY
EE
HR
IE
LT
MT
SI
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4 SEG 2: Do not relate air quality plans and zones
4.1 What is the problem?
There is no good reason for relating air quality plans to zones (Art. 23.1 of the AQD), which are very
diverse in size and population. Although this does not seem to be a major problem for Member
States, a change could be considered. Relevant sources may be located outside the zone where the
exceedance takes place.
4.2 What are the SEG 2 sub-options?
Table 8 provides the sub-options for this SEG Recommendation including the pros and cons provided
in the TNO Report (2012).
Table 8: SEG 2 sub-options from TNO Report (2012)
Description Pros Cons
2 (a) Change in Art 23.1 “air quality plans are established
for those zones and agglomerations” into “air quality
plans are established”.
More
consistent
legislation
Member States do in practice
not develop AQ plans for zones
so change may not be needed
2 (b) Option 2(b): If Annex XV(A) is retained in the revision,
change the term “zone” into “surrounding area”. If
Annex XV is not kept , no change is needed.
More
consistent
legislation
Does not seem a problem so a
change may not be needed
4.3 SEG 2 – Assessment of Evidence
The following section provides an assessment of the available evidence to determine the likely impact
of the SEG 2 Recommendation. This is based upon evidence from the TNO Report (2012) SWOT
analysis, the UK and Danish Workshops, the Member State SEG Information Requests, the Member
State Case Studies and Member State Consultation Survey in addition to the expert-based judgement
of the Project Team.
4.3.1 TNO Report (2012) SWOT Analysis
In their SWOT analysis, TNO Report (2012) assessed this recommendation as follows (the burden to
Member States is highlighted in bold):
Table 9: TNO Report (2012) SWOT analysis for SEG 2
Aspects Relevant for Prioritisation Importance of Aspect Score
Health / Env Improvement Slightly Favourable 1
Harmonisation among MS Slightly Unfavourable -1
Admin burden to Commission Slightly Unfavourable -1
Burden to MS Slightly Favourable 1
Subsidiarity Moderately Favourable 2
Complexity of Legislation Slightly Favourable 1
Cost of Implementation Neutral 0
Regulatory Stability Moderately Unfavourable -2
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4.3.2 UK and Danish Workshops
The administrative linkage between air quality plans and zones are useful to facilitate management of
the exceedence, however the lack of conjunction between zones and agglomerations and sub-national
administrative boundaries (e.g. local authorities) makes it difficult to join up national and local
management plans. For this reason it may be preferable to allow the link between air quality plans
and zones to be broken but to retain flexibility for Member States.
It was considered by workshop attendees that the implementation of this option would be cost neutral
as regardless of the wording in the Air Quality Directive, Member States would still have to make the
linkage and the plan would have to be developed for an exceedence.
4.3.3 Member State Information Request
All Information Request Responses for this Recommendation can be found in Annex 1.
Depending on the sub-option being considered the cost implications varied between respondents. All
responses were qualitative rather than quantitative. The qualitative responses are outlined in the
following Table.
Table 10: Summary of Member States Information Request Responses for SEG 2
SEG 2
Sub-Option
Cost Increase Cost Neutral Cost Decrease No Assessment
Option 2(a) 2
DE, LT
6
BE, CZ, FR, HR,
HU, SE
0 3
FI, GB, RO
Option 2(b) 0 8
BE, CZ, DE, FR,
HR, LT, RO, SE
0 3
HU, GB, FI
Predominantly, Member States have echoed the assessment in the UK and Danish workshops that
the implementation of this SEG Recommendation is unlikely to have cost implications but that the
relationship between air quality plans and zones across Member States is not straightforward and the
Member States take a varied and flexible approach. This approach is largely dependent on the area
of technical exceedence, location of sources and the management structure within specific Member
States.
For SEG 2(a) - Change in Art 23.1 “air quality plans are established for those zones and
agglomerations” into “air quality plans are established”, Germany and Lithuania both identified
additional cost implications. These cost implications were associated with changes to data generation,
reporting structures, and staff time including capacity development to adapt to changes. The other
Member States identified this option as cost neutral.
For SEG 2(b) - Option 2(b): If Annex XV(A) is retained in the revision, change the term “zone” into
“surrounding area”. If Annex XV is not kept , no change is needed, all Member States stated that this
option would be cost neutral as it would not change their current activities.
No quantitative data was provided for this SEG recommendation as baseline costs were unknown and
Member States were unable to quantify the changes in resources or costs where this occurred.
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4.3.4 Case Studies
United Kingdom
During the case study interview, UK was unable to provide further insight into the resources and costs
associated with their baseline activities or how the implementation of the recommendation would
impact on their resources. They did suggest that there may be additional cost implications associated
with the recommendation but this would vary substantially for each Member State. The UK did not feel
that the case had been sufficiently made for this recommendation and that it was not clear how the
potential implementation of this recommendation related back to the IPR Guidance.
Sweden
During the case study interview, Sweden was unable to provide further insight into the resources and
costs associated with their baseline activities or how the implementation of the recommendation would
impact on their resources as the activities associated with this recommendation were too broad and
disaggregated across different administrations to be quantified. They did state that our qualitative
judgement below was appropriate and that in their Member State the implementation of this
recommendation would be cost neutral.
Croatia
Croatia currently operates a hybrid system requiring local plans but also compiling these as national
plans, in order to fill capability gaps at a local level and to tie the plans to zones. Croatia felt that the
relating of plans to zones doesn’t really add anything to the process, other than linking to the reported
exceedences, therefore implementation of this Recommendation would imply a cost reduction
(~<€60k) as they could effectively reduce the duplication of effort. On the other hand, the current
system is established and has been operating for many years and it would therefore probably be
retained in order to maintain continuity and avoid any unforeseen costs associated with ensuring that
the local plans were sufficient to meet the reporting requirements alone.
4.3.5 Member State Consultation Survey
The majority of respondents concurred with our qualitative judgement on the implication of this SEG
Recommendation as outlined below. The UK indicated that they thought the cost implications could
potentially be higher.
Respondents stated that rephrasing the wording would not have much effect on real-life and ‘given
that the concept of zones was to manage air quality, I don’t see the value of zones if the plans don’t
relate to them’ (IE).
4.4 SEG 2 - High-Level Assessment Conclusions
Based on the balance of available evidence, it is unlikely that the implementation of this
recommendation would result in additional cost implications for Member States.
Member States through the Information Requests and the Case Studies were unable to provide
quantitative impacts either in resources/costs for their baseline activities or future activities should this
recommendation be implemented. It is difficult to determine the resources/cost of the minimum
requirements as these are quite broad for the development of an action plan and varied across
Member States. Subsequently, the impact assessment for this recommendation can only be made
qualitatively.
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Depending on the way in which the recommendation is implemented, there may be some costs
incurred for the refinement of an air quality plan and data gathering. Air quality plans would still have
to be developed and the presence (or absence) of a link between the air quality plan and zone would
have little cost on the plans development. However, the flexible nature that Member States operate
should be noted as there does not appear to be a common approach applied.
Table 11: SEG 2 - High-Level Cost Assessment
Qualitative High Level Cost Assessment Cost Assessment
Sub-option 2(a) – There may be cost implications for a selection of Member States
but this is not quantifiable. Therefore the assumed ‘Low Additional Cost Burden’
category is applied.
Low Additional
Cost Burden
(<€20k)
Sub-option 2(b) – Based upon the available evidence this option is likely to be cost
neutral for all Member States.
Cost
Neutral
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5 SEG 4: Reduce assessment reporting for standards that are largely met.
5.1 What is the problem?
The effort of assessment (especially monitoring requirements) and reporting could be reduced for
pollutants with (almost) no exceedences of environmental standards.
5.2 What are the SEG 4 sub-options?
Table 12 provides the sub-options for this SEG Recommendation including the pros and cons
provided in the TNO Report (2012).
Table 12: SEG 4 sub-options from TNO Report (2012)
Description Pros Cons
4 (a) Further reduction of the
assessment
requirements for
pollutants with low
levels (e.g. SO2, lead,
benzene, CO), either
by modifying the
assessment thresholds,
or by modifying the
data quality objectives
for different
assessment methods.
Saving efforts and costs
for air quality assessment
and reporting
“Reduced” requirements for
assessment are already laid down in the
Directive 2008/50/EC and 2004/107/EC by
requiring different assessment regimes,
depending on the concentration levels
compared to the assessment threshold.
Therefore, the suggestion for reduction of
assessment and reporting requirements
seems already fulfilled.
The present assessment
thresholds and data quality objectives are
laid down in such a way to be sure not to
overlook any exceedences of environmental
objectives. Any “weakening” of the
assessment criteria will extend “inaccurate”
assessment to higher concentration levels,
which are more critical with respect to
exceedences.
4 (b) Withdraw assessment
requirements for
pollutants and zones
where no exceedances
have been observed
over a long period.
Saving efforts and costs
for air quality assessment
and reporting
Abandoning assessment would
mean the loss of information about pollutant
levels, even in case of increasing
emissions, At least some “objective
estimation” would be necessary to be sure
that concentrations remain low – a
procedure which is covered by the existing
assessment requirements in Directive
2008/50/EC and 2004/107/EC.
There are several pollutants with
no-threshold effects on human health,
assessment of which should be continued
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even in a case of low concentrations.
5.3 SEG 4 – Assessment of Evidence
The following section provides an assessment of the available evidence to determine the likely impact
of the SEG 4 Recommendation. This is based upon evidence from the TNO Report (2012) SWOT
analysis, the UK and Danish Workshops, the Member State SEG Information Requests, the Member
State Case Studies and Member State Consultation Survey in addition to the expert-based judgement
of the Project Team.
5.3.1 TNO Report (2012) SWOT Analysis
In their SWOT analysis, TNO Report (2012) assessed this recommendation as follows (the burden to
Member States is highlighted in bold):
Table 13: TNO Report (2012) SWOT analysis for SEG 4
Aspects Relevant for Prioritisation Importance of Aspect Score
Health / Env Improvement Slightly Unfavourable -1
Harmonisation among MS Slightly Unfavourable -1
Admin burden to Commission Slightly Unfavourable -1
Burden to MS Moderately Favourable 2
Subsidiarity Neutral 0
Complexity of Legislation Slightly Favourable 1
Cost of Implementation Neutral 0
Regulatory Stability Slightly Unfavourable -1
5.3.2 UK and Danish Workshops
Workshop delegates proposed that this recommendation was desirable but given the minimal cost the
requirements should be retained, albeit at a reduced level, to confirm trends and to indicate any
changes. As indicated in TNO Report (2012), the delegates also identified that the reduced”
requirements for assessment are already laid down in the Directive 2008/50/EC and 2004/107/EC
therefore, the suggestion for reduction of assessment and reporting requirements seems already
fulfilled. Delegates suggest that the implementation of this recommendation was unlikely to change
Member State activities.
5.3.3 Member State Information Request
All Information Request Responses for this Recommendation can be found in Annex 1.
Depending on the sub-option being considered the cost implications varied between respondents. All
responses were qualitative rather than quantitative. The qualitative responses are outlined in the
following Table.
Table 14: Summary of Member States Information Request Responses for SEG 4
SEG 4
Sub-Option
Cost Increase Cost Neutral Cost Decrease No Assessment
Option 4(a) 0 4
DE, FR, HR, SE
5
BE, CZ, HU, LT, RO
2
FI, GB
Option 4(b) 3
DE, LT, SE
4
BE, CZ, FR, HR
4
FI, GB, HU, RO
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Predominantly, Member States have highlighted that the implementation of this recommendation
would either be cost neutral or would result in costs reductions primarily due to the reduction in
monitoring equipment and the associated savings in operation and maintenance. Member States
echoed the TNO Report (2012) and the workshop delegates in that provisions within the current
Directive already provide flexibility to reduce the resources required for assessment where
concentrations were low but recognised that this could be taken further.
No quantitative data was provided for this SEG recommendation as Member States were unable to
assess the cost implications without knowing the specific details of the modification being suggested.
5.3.4 Case Studies
United Kingdom
The UK undertakes an assessment of their monitoring network as part of their 5-year review and
managing their costs and administrative burden. This was recently undertaken and the UK reduced
their monitoring network by 4 Benzene, 25 Carbon Monoxide and 16 Sulphur Dioxide instruments.
They have not yet amended their Lead network. UK stated that this rationalisation of their network as
brought about an indicative saving within the region of £10,000 - £50,000 (approx. €11,600 - €58,000)
but could not be more definitive in the exact figure or how that saving was disaggregated by cost
categories (e.g. Equipment & Facilities, Operation & Maintenance etc).
Taking an average value of saving of €34,800 for the reduction of 45 instruments from their network,
this equates to an approximate saving of €773 per instrument reduced in the UK1
Sweden
During the Swedish case study they stated that they thought the recommendation was unnecessary as
the current concept was work sufficiently. They suggested that SO2 should not be removed and the
limit value was too high and should be brought in line with WHO. Sweden agreed with our judgement
on the cost savings should the recommendation be implemented and although they were unable to
specify how many monitoring would be reduced (their monitoring network is quite minimal) they gave
an estimated saving of €10,000 - €20,000. This cost saving is in keeping with the UK figures.
Croatia
The monitors reported in AirBase v6 are only urban network sites as the monitoring network was being
established at the time. There are actually currently 22 monitoring sites and this is being expanded to
meet the compliance network requirements, though there will be a reduction of some monitors, e.g. for
CO and SO2 from 8 monitors to 2. The actual numbers have not been formally approved at present so
cannot yet be released. The cost of reduction will be outweighed by the anticipated increase; the cost
of setting up the new/replacement monitoring network (over the next two years) will be ~60% increase
on current costs of~€650k (based on 22 stations) including setting up labs, etc. The compliance
network will also be complemented with modelling as it is anticipated that this will save costs in the
long-run.
5.3.5 Member State Consultation Survey
Member States agreed with our qualitative judgement that the implementation of this
Recommendation would result in a cost reduction as the Member States would consider reducing their
monitoring network. However, this recommendation would need to recognise the necessity for an EU
minimum network of monitoring sites and the importance of the maintenance of data for trends.
1 Please note this is an indicative value and not based on actual cost saving assessment by the Member State
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5.4 SEG 4 High-Level Assessment Conclusions
Based on the balance of available evidence, it is likely that the implementation of this recommendation
would result in cost savings for Member States but this is completely dependent to the detailed of the
recommendation implementation route and its uptake by Member States.
The implementation of this recommendation may achieve a saving in equipment and running costs
primarily due to the possible reduction in monitoring instrumentation (should Member States choose to
do so). However, this is dependent on each Member State. There would be negligible reduction in
staff time due to assumption that multiple pollutants are monitored at each site and therefore sites are
not fully decommissioned.
Based on the case study evidence, an indicative cost saving range of €257 - €1289 (average €773)
per instrument reduced from the network could be applied. The total cost saving per Member
State is dependent on the number of instruments reduced from their national network. The following
figure provides indicative costs should a 10% reduction in the number of monitoring instruments be
applied for all Member States at an average rate of €773 per instrument. The baseline number of
monitoring instruments was derived from the Member States ‘461’ Forms (2011) (See Annex 3). It
should be noted that these figures may not be applicable for some newer Member States as they are
working towards increasing their monitoring network e.g. see Croatia case study.
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Figure 3: Approximate average cost savings based on a 10% reduction of the monitoring
network for Benzene, Lead, Carbon Monoxide and Sulphur Dioxide in each Member State
(2011)
€67.328
€67.251
€27.673
€26.746
€26.205
€22.185
€15.537
€14.842
€9.894
€8.117
€5.798
€5.411
€4.406
€3.865
€2.860
€2.319
€2.242
€1.623
€1.546
€1.391
€1.391
€1.391
€1.160
€1.082
€928
€850
€618
€541 -
€
10
.00
0 €
20
.00
0 €
30
.00
0 €
40
.00
0 €
50
.00
0 €
60
.00
0 €
70
.00
0 €
80
.00
0 €
ES
IT
FR
PL
DE
RO
AT
CZ
BE
PT
GB
BG
HU
NL
SK
SI
GR
IE
EE
DK
HR
LT
SE
MT
FI
LU
LV
CY
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6 SEG 5: Clarify the definition of the risk of exceedence
6.1 What is the problem?
Where there is a risk that the levels of pollutants will exceed one or more of the alert thresholds,
Member States shall draw up short term action plans in order to reduce the risk or duration of such an
exceedance. Where this risk applies to one or more limit values or target values, Member States may
draw up such short-term action plans. The directive does not specify how to determine whether a risk
exists. This has been addressed in the Guidance on AQ plans and short term action plans (produced
in 2009), but it has not been disseminated yet.
6.2 What are the SEG 5 sub-options?
Table 15 provides the sub-options for this SEG Recommendation including the pros and cons
provided in the TNO Report (2012).
Table 15: SEG 5 sub-options from TNO Report (2012)
Description Pros Cons
5 (a) Guidance on the necessity to prepare
action plans in relation to exceedance of
alert thresholds and on short term action
plans for ozone already exists.
Dissemination could be intensified or the
Guidance on AQ plans and short term
action plans developed in 2009 could be
disseminated. Note that the guidance does
not relate to the risk of exceedance of limit
or target values.
More
harmonised
interpretation of the
“risk of exceedence”.
The guidance
needs to be updated on
some points.
5 (b) Develop new guidance in collaboration with
e.g. WG on Implementation.
Harmonised
interpretation of the
“risk of exceedence”.
Member States
may not wish to invest
time in this and may
prefer to leave it a
subsidiarity matter.
6.3 SEG 5 – Assessment of Evidence
The following section provides an assessment of the available evidence to determine the likely impact
of the SEG 5 Recommendation. This is based upon evidence from the TNO Report (2012) SWOT
analysis, the UK and Danish Workshops, the Member State SEG Information Requests, the Member
State Case Studies and Member State Consultation Survey in addition to the expert-based judgement
of the Project Team.
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6.3.1 TNO Report (2012) SWOT Analysis
The findings of the SWOT analysis are not explicit from the TNO Report (2012).
6.3.2 UK and Danish Workshops
It was argued by delegates that there was little evidence that STAPs have been very useful other than
for providing information to the public. The requirement to prepare STAPs was criticised as diverting
effort from tackling more important exceedences of long-term average Limit Values. It was suggested
that Alert Thresholds and Information Thresholds should be re-examined with respect to addressing
public exposure, and that it may be beneficial to reduce these values in order to provide the public with
better, more frequent, information, which could help raise public awareness of air quality issues. The
indication from delegates is that the cost implications associated with this recommendation are mainly
borne by the European Commission rather than Member States.
6.3.3 Member State Information Request
All Information Request Responses for this Recommendation can be found in Annex 1.
Depending on the sub-option being considered the cost implications varied between respondents. All
responses were qualitative rather than quantitative. The qualitative responses are outlined in the
following Table.
Table 16: Summary of Member States Information Request Responses for SEG 5
SEG 5
Sub-Option
Cost Increase Cost Neutral Cost Decrease No Assessment
Option 5(a) 2
DE, LT
5
BE, CZ, FR, HR, SE
0 4
FI, GB, HU, RO
Option 5(b) 1
LT
5
BE, CZ, DE, FR, SE
0 5
FI, GB, HR, HU, RO
Member States were unable to provide any quantitative data for the implication of this
recommendation. The Information request responses indicate that Member States have various
methods for determining ‘risk’.
The qualitative responses suggests that there would be no cost implications associated with this
option as Short term Action Plans would still have to be considered and without knowing how ‘risk’
would be the defined, Member States are not able to compare it their own methods and thus
accurately determine the implications of a ‘new’ definition. Germany and Lithuania suggested that
there may be cost implications for staff time and reporting
6.3.4 Case Studies
United Kingdom
The UK stated that without knowing what the implementation of this recommendation would require
Member States to do there is no way of accurately determining the impact. They were uncertain how
the risk of exceedence (e.g. 80% of threshold) could be further clarified from the existing guidance.
They consider that there would only be minor costs associated with the implementation of this
recommendation related to capacity enhancement.
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Sweden
Sweden stated that they recognised the recommendation may be beneficial especially if it included
PM10. However, like the UK, they could not determine the impact of implementation beyond capacity
development.
Croatia
Croatia agrees with the qualitative assessment that the long-term cost implications of this
Recommendation are unknown as it is unclear what the guidance will entail. However, if this
Recommendation were to be implemented, the cost of reviewing and implementing the guidance is
likely to be <€20k.
6.3.5 Member State Consultation Survey
The uncertainty associated with this Recommendation did not permit Member States to accurately
assess the cost implications associated with this recommendation. There was a difference in the
qualitative assessment of the impact of this recommendation with Czech Republic stating that our
qualitative judgement (below) was acceptable and they “welcome the guidance on AQ plans and
assessment of its measures”. Conversely, Germany indicated that “new guidance requiring a re-
assessment of the situation could result in substantial costs”.
6.4 SEG 5 - High-Level Cost Assessment
The long-standing cost implications are unknown as, there is no indication as to exactly how the risk
would be redefined and therefore the impact on Member States cannot be determined. Qualitative
assessment comments from Member States Information Requests and case studies indicate that the
implementation of this option is unlike to have cost implications although Germany and Lithuania did
identify additional costs associated with reporting and staff time (this was not quantified).
Table 17: SEG 5 - High-Level Cost Assessment
Qualitative High Level Cost Assessment Qualitative
Cost Assessment
Short Term Action Plan would continue to be developed so there would be
no medium or high-level cost implications although the provision of
guidance may result in cost savings for new Member States.
The implementation of guidance may require the reassessment of existing
situations which could lead to substantial cost implications. However,
without knowing the content of that guidance these costs cannot be
determined.
The sub-options require the provision of guidance and therefore the only
real costs that can be assessed are immediate capacity development costs
to adapt to methodologies within guidance.
Low Additional
Cost Burden
(<€20k)
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7 SEG 7: Reduce the administrative burden regarding the development of Short Term Action Plans
7.1 What is the problem?
Where there is a risk that the levels of pollutants will exceed one or more of the alert thresholds,
Member States shall draw up short term action plans in order to reduce the risk or duration of such an
exceedance. Where this risk applies to one or more limit values or target values, Member States may
draw up such short-term action plans. The development of such plans is associated with an
administrative burden and the effectiveness of the plans is questioned in some cases.
7.2 What are SEG 7 sub-options?
Table 18 provides the sub-options for this SEG Recommendation including the pros and cons
provided in the TNO Report (2012).
Table 18: SEG 7 sub-options from TNO Report (2012)
Description Pros Cons
7 (a) Withdraw the SO2 and/or NO2 alert
threshold
Reduction of burden to
administration
Less health protection
Might be
disappointing for
Member States who
have fully
implemented the
provisions
7 (b) Provide guidance and good practice
examples (see the recommendations
in the recent AEAT report on short
term action plans). Note that guidance
on the necessity to prepare action
plans in relation to exceedance of alert
thresholds and on short term action
plans for ozone already exists.
Supports the
development of short
term actions plans in
Member States
Requires an effort for
the Commission
7.3 SEG 7 – Assessment of Evidence
The following section provides an assessment of the available evidence to determine the likely impact
of the SEG 7 Recommendation. This is based upon evidence from the TNO Report (2012) SWOT
analysis, the UK and Danish Workshops, the Member State SEG Information Requests, the Member
State Case Studies and Member State Consultation Survey in addition to the expert-based judgement
of the Project Team.
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7.3.1 TNO Report (2012) SWOT Analysis
In their SWOT analysis, TNO Report (2012) assessed this recommendation as follows (the burden to
Member States is highlighted in bold):
Table 19: TNO Report (2012) SWOT analysis for SEG 7
Aspects Relevant for Prioritisation Importance of Aspect Score
Health / Env Improvement Slightly Unfavourable -1
Harmonisation among MS
Admin burden to Commission Moderately Unfavourable -2
Burden to MS Moderately Favourable 2
Subsidiarity Moderately Favourable 2
Complexity of Legislation Moderately Favourable 2
Cost of Implementation Slightly Favourable 1
Regulatory Stability Slightly Unfavourable -1
7.3.2 UK and Danish Workshops
Delegates did not perceive this option as desirable, despite the obvious reduction of burden on
Member States as the loss of useful long-term trend data was not recommended. As a balance
between these two options, it was suggested that there should be some flexibility for Member States to
decide whether to continue monitoring these pollutants. Does anywhere exceed NO2 and SO2 alert
thresholds? Removal of requirement to implement STAPs and therefore a reduction in burden for
Member States but assume Member States continue to generate data to report against other NO2 and
SO2 objectives therefore no major reduction in high equipment costs.
7.3.3 Member State Information Request
All Information Request Responses for this Recommendation can be found in Annex 1.
Depending on the sub-option being considered the cost implications varied between respondents. All
responses were qualitative rather than quantitative. The qualitative responses are outlined in the
following Table.
Table 20: Summary of Member States Information Request Responses for SEG 7
SEG 7
Sub-Option
Cost Increase Cost Neutral Cost Decrease No Assessment
Option 7(a) 0 4
BE, DE, HR, SE
3
CZ, FR, LT
4
FI, GB, HU, RO
Option 7(b) 1
RO
6
BE, DE, FR, HR, LT,
SE
1
CZ
3
FI, GB, HU
All Member States indicated that there would be no cost implications or a slight reduction in costs
associated with the implementation of this recommendation. Only Belgium appears to have use for
Short Term Action Plans but these are associated with stricter national thresholds in Flanders for the
management of industry. Romania indicated that there may be cost implications for sub-option 7(b) as
they do not appears to be currently acting in accordance with the Directive.
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7.3.4 Case Studies
United Kingdom
The UK highlighted the lack of evidence that Short Term Action Plans actually work. There may be a
negligible saving due to the reduction in alert data compilation and reporting (this may happen anyway
through the new systems providing real-time data to EEA). The UK assessed this option as being cost
neutral as there would be no change to their current operations.
Sweden
Sweden stated that there are no exceedences for these alert thresholds and therefore short-term
action plans are not necessary. Sweden suggested that PM10 should be considered. Sweden
assessed this option as being cost neutral as there would be no change to their current operations.
Croatia
Croatia agrees that the implementation of this Recommendation would be of negligible benefit or cost
neutral.
7.3.5 Member State Consultation Survey
Member States indicated that they predominantly concurred with our qualitative assessment but
suggested that ‘it should be investigated in the first place whether this threshold should be lowered
(based on the latest recommendation of the WHO) before it is withdrawn (BE)’. GB also suggested
that UTD data flows within e-reporting may reduce the burden for alert thresholds.
7.4 SEG 7 - High-Level Cost Assessment
Based on the balance of available evidence, it is likely that the implementation of this recommendation
would be cost neutral for most Member States.
Member States have indicated that their exceeedence of NO2 and SO2 alert thresholds rarely / never
happen, this is supported by EEA Report (2012) which indicates that no Member State exceeded the
NO2 or SO2 alert threshold. Therefore the removal of this threshold would have no impact on Member
States as they would still need to monitor, assess and report against other NO2 and SO2 objectives
therefore no major reduction in high equipment costs.
Table 21: SEG 7 - High-Level Cost Assessment
Qualitative High Level Cost Assessment Qualitative
Cost
Assessment
Member State Information Requests and Case Studies indicated that the
implementation of this recommendation would result in little change in their current
activities. Some Member States may achieve minor cost savings related to monitoring,
reporting and staff time. Member States were unable to quantify this saving.
Cost Neutral
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8 SEG 8: Promote the assessment of synergetic measures in air quality plans & SEG 9: Promote the consideration of antagonisms with other policies in the development of air quality measures.
8.1 What is the problem?
Measures often improve air quality and reduce the emissions of greenhouse gases as well, but there
are also antagonisms, e.g. higher energy demand by technologies for reducing emissions of air
pollution, higher CO2 emissions due to detours of traffic to reduce exceedance along a road.
Therefore, measures that are synergetic with other policies should be preferred. Measures to reduce
the emissions of greenhouse gases and to improve energy efficiency most often improve air quality as
well. However, some of these measures might lead to an increase in air pollutants. This is especially
true for biomass combustion, carbon capture and storage. In addition, climate change issues are often
of higher priority than air quality. On the other hand, measures to reduce emissions of air pollutants
may reduce energy efficiency. Therefore, antagonisms and interactions have to be considered in
policies. It doesn’t seem to be realistic to change provisions in the ongoing revision of the Monitoring
Mechanism Decision 2004/280/EC. Therefore such a possibility is not included.
8.2 What are the SEG 8/9 sub-options?
Table 22 provides the sub-options for this SEG Recommendation including the pros and cons
provided in the TNO Report (2012).
Table 22: SEG 8/9 sub-options from TNO Report (2012)
Description Pros Cons
8 & 9 (a) Include a provision requiring consideration
of other policies in AQ plans and/or
national programmes.
Clear
instructions to consider
issues beyond air quality
If requirements
are detailed enough,
quantitative information
on impacts will have to
be provided
Would cover all
future air quality and/or
NEC programmes in EU
27
Subsidiarity
It might be
necessary to provide
guidance on reporting in
order to get comparable
programmes
Will take some
time until full effect
8 & 9 (b) Workshops for exchanging best practices. - -
8 & 9 (c) Provision of guidance documents. - -
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8.3 SEG 8/9 – Assessment of Evidence
The following section provides an assessment of the available evidence to determine the likely impact
of the SEG 8/9 Recommendations. This is based upon evidence from the TNO Report (2012) SWOT
analysis, the UK and Danish Workshops, the Member State SEG Information Requests, the Member
State Case Studies and Member State Consultation Survey in addition to the expert-based judgement
of the Project Team.
8.3.1 TNO Report (2012) SWOT Analysis
In their SWOT analysis, TNO Report (2012) assessed this recommendation as follows (the burden to
Member States is highlighted in bold):
Table 23: TNO Report (2012) SWOT analysis for SEG 8/9
Aspects Relevant for Prioritisation Importance of Aspect Score
Health / Env Improvement Moderately Favourable 2
Harmonisation among MS Slightly Favourable 1
Admin burden to Commission Slightly Unfavourable -1
Burden to MS Moderately Unfavourable -2
Subsidiarity Moderately Unfavourable -2
Complexity of Legislation Slightly Unfavourable -1
Cost of Implementation Neutral 0
Regulatory Stability Slightly Unfavourable -1
8.3.2 UK and Danish Workshops
Delegates recognised the need for coherent EU policy to raise the profile of air quality and reduce
resources wasted on conflicting policies and duplication of effort, but that it would only be viable if
there was a reciprocal requirement to promote the consideration of air quality at other levels and in
other policies. It was also argued that this requirement was already written into the Directive and so
was already happening in Member States to a certain extent but to differing degrees of effectiveness.
There was also the risk that the financial burden to Member States could potentially be huge if this
was made a prescriptive process and required comprehensive quantitative assessment (e.g.
modelling).
8.3.3 Member State Information Request
All Information Request Responses for this Recommendation can be found in Annex 1.
Depending on the sub-option being considered the cost implications varied between respondents. All
responses were qualitative rather than quantitative. The qualitative responses are outlined in the
following Table.
Table 24: Summary of Member States Information Request Responses for SEG 8/9
SEG 8/9
Sub-Option
Cost Increase Cost Neutral Cost Decrease No Assessment
Option 8/9(a) 3
BE, HR, LT
4
CZ, DE, FR, SE
0 4
FI, GB, HU, RO
Option 8/9(b) 0 6
BE, CZ, DE, FR, LT,
SE
0 5
FI, GB, HR, HU, RO
Option 8/9(c) 0 7 0 4
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BE, CZ, DE, FR, LT,
RO, SE
FI, GB, HR, HU
Most Member States indicated that they already considered synergistic/antagonistic measures so no
additional costs. Others suggested that there would be some additional data generation, reporting,
staff and capacity development costs.
8.3.4 Case Studies
United Kingdom
The UK stated that the implementation of this recommendation may have differing cost implications
depending on the implementation method. The enforcement of a standardised method is not
supported as it could place a large burden on Member States. The consideration of synergise and
antagonisms is already undertaken through inter-departmental consultation but the imposition of a
quantitative assessment requirement could have a substantial burden and suggest a resource
requirement of approximately 25 days per measure / policy to be considered.
Sweden
Sweden stated that this is already undertaken at a local level but there is no standardised approach.
They suggested a phased approach to the implementation in that guidance should be provided (and
will be welcomed) followed by a provision in the Directive if there is a need to make the requirement
stronger. Sweden suggested that a lower resource may be required of only 5 days per measure /
policy option.
Croatia
Croatia agrees with the qualitative assessment of the impact of this Recommendation, adding that
they would categorise themselves as scenario B. As they have not yet considered this, Croatia
estimated that the cost would be 30 person days (10 policy and 20 scientific), equivalent to €5,000
per measure. In principle this Recommendation would be desirable.
8.3.5 Member State Consultation Survey
Respondents indicated that qualitative consultation would not be cost neutral and that meaningful
consultation could potentially be a very large burden. Respondents correctly identified that the
proposed number of person days for the quantitative assessment of options may vary depending on
the measures and the nature of the air quality plan. Respondents identified the difficulty in influencing
other policy areas and suggested that the implementation of this recommendation should not mean
‘more detailed analysis but another ‘best’ and ‘worst’ case scenario to take into account when
analysing the need for a genuine air quality measure (DE)’.
8.4 SEG 8/9 - High-Level Cost Assessment
This activity is undertaken in some capacity by most Member States although usually through inter-
departmental consultation. The cost implications are dependent on the interpretation of the term
‘consideration’ as this may be ‘consideration’ through consultation and qualitative assessment or
‘consideration’ through detailed quantitative assessment of options. Subsequently, two potential cost
scenarios are likely but these are largely dependent on the exact wording and implementation route of
the recommendation. The scenarios are outlined in the table below.
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The cost implications for Scenario 2 can be further extrapolated using labour tariffs taken from the EU
Standard Cost Model (see accompanying report entitled “Methodology of Cost Assessment of the
Recommendations of AQUILA, FAIRMODE and SEG”). Applying an average input of 20 person days
to undertake detailed quantitative assessment of synergies and antagonisms, an indicative cost per
measure can be determined (Figure 4). This is an indicated cost provided as an example and the cost
would grow depending on the number of measures to be assessed.
Table 25: SEG 8/9 - High-Level Cost Assessment
Scenario Description Qualitative High Level Cost Assessment Cost
Assessment
A ‘Consideration’ =
Inter-
departmental
consultation and
qualitative
assessment
During the consideration of options all Member
States will undertake some inter-departmental
consultation. The majority of air quality
measures overlap with other policy areas. The
qualitative assessment of this option may be
undertaken within this consultation process.
Low Additional Cost
Burden
(<€20k)
B ‘Consideration’ =
Detailed
Quantitative
Assessment
Detailed quantitative assessment of measures
may require input from policy and scientific staff.
It is anticipated that each measure may require
an average input of 20 person days per
measure (e.g. 5 policy days and 15 scientific
days). This scenario would vary in each
Member State and may require the
establishment of minimum capacity e.g.
modelling.
Low/Medium/High
additional cost
burden
dependent on
number of
measures to be
quantitatively
assessed.
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Figure 4: Indicative costs for Scenario B (SEG 8/9)
€ 458
€ 755
€ 756
€ 781
€ 1.029
€ 1.058
€ 1.180
€ 1.413
€ 1.565
€ 1.640
€ 1.992
€ 2.367
€ 2.676
€ 3.160
€ 3.317
€ 3.766
€ 4.275
€ 4.344
€ 4.430
€ 4.604
€ 4.618
€ 4.680
€ 4.715
€ 5.002
€ 5.120
€ 5.504
€ 5.936
€ 6.111
€ 0
€ 1
.00
0
€ 2
.00
0
€ 3
.00
0
€ 4
.00
0
€ 5
.00
0
€ 6
.00
0
€ 7
.00
0
Bulgaria
Lithuania
Latvia
Romania
Hungary
Estonia
Slovakia
Czech…
Poland
Croatia
Malta
Slovenia
Portugal
Greece
Spain
Cyprus
Netherlands
Finland
Sweden
Austria
Italy
France
Ireland
Germany
Denmark
Belgium
Luxembourg
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9 SEG 10: Promote Member States developing national or regional air quality strategies or plans
9.1 What is the problem?
Instead of developing individual air quality plans for each exceedance situation or for collections of
exceedance situations in the territories of separate local authorities, such plans may be merged in an
overarching national or regional air quality plan. The Netherlands merged a large number of air quality
plans into a single National Sanitation Programme that was reported as a single air quality plan to the
Commission. In the UK local air quality plans have been drafted according to the national air quality
policy strategy and for reporting these under the AQ directives DEFRA combined these to a small set
or overarching AQ plans.
9.2 What are SEG 10 sub-options?
Table 26 provides the sub-options for this SEG Recommendation including the pros and cons
provided in the TNO Report (2012).
Table 26: SEG 10 sub-options from TNO Report (2012)
Description Pros Cons
10 (a) Promote in guidance to
Member States that
local air quality plans
are merged into
overarching air quality
plans at the regional or
national level (as in the
Netherlands).
Possibilities for synergy and
coherence in the development of the local
plans.
Better possibilities to involve high
levels of expertise.
Merging
development projects run by
different local authorities in
very complicated.
In the likely case that
individual air quality plans are
changed or even cancelled,
the overarching air quality
plan needs to be adapted.
Local plans that in
itself would deteriorate air
quality can be rendered
acceptable when legally
combined with plans in other
areas that improve air quality.
10 (b) Promote in guidance
that Member States
report local air quality
plans as aggregate air
quality plans (as in the
UK).
Enables Member States to use
their own system of air quality policy
provision for local authorities.
Burden reduction for the
Commission due to the decrease in
number of air quality plans received.
Possibly substantial
loss of specificity in the
information reported, as a
result of the aggregation.
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9.3 SEG 10 – Assessment of Evidence
The following section provides an assessment of the available evidence to determine the likely impact
of the SEG 10 Recommendation. This is based upon evidence from the TNO Report (2012) SWOT
analysis, the UK and Danish Workshops, the Member State SEG Information Requests, the Member
State Case Studies and Member State Consultation Survey in addition to the expert-based judgement
of the Project Team.
9.3.1 TNO Report (2012) SWOT Analysis
In their SWOT analysis, TNO Report (2012) assessed this recommendation as follows (the burden to
Member States is highlighted in bold):
9.3.2 UK and Danish Workshops
Delegates stated that the localisation policies don’t go in hand with Air Quality Directive. While the
implementation of this recommendation would help national government bring action data together
through a mandate, the primary cost implication would be the collation of this local data and the
development of a national plan. They did acknowledge that the recommendations sub-options were
very ‘soft’ as the implementation pathway was to be guidance and therefore there may not be a
burden.
9.3.3 Member State Information Request
All Information Request Responses for this Recommendation can be found in Annex 1.
Depending on the sub-option being considered the cost implications varied between respondents. All
responses were qualitative rather than quantitative. The qualitative responses are outlined in the
following Table.
Table 27: Summary of Member States Information Request Responses for SEG 10
SEG 10
Sub-Option
Cost Increase Cost Neutral Cost Decrease No Assessment
Option 10(a) 2
DE, LT
4
BE, CZ, HR, SE
0 5
FI, FR, GB, HU, RO
Option 10(b) 2
DE, RO
5
BE, CZ, HR, LT, SE
4
FI, FR, GB, HU
Member States indicated that the cost implications associated with this option would be completely
dependent on implementation methodology. Most Member States report as local plans (exception of
UK and Netherlands) but a varying approach is applied dependant on the pollutant being assessed
e.g. NO2 may be a local plan but O3 would be a national plan. Member States were concerned that
the level of detail in local air quality plans which is specific to local sources and local conditions may
be lost to the aggregation at a national level. While the majority of Member States indicated that this
option would be cost neutral, some additional costs were suggested for data generation, reporting and
staff time.
9.3.4 Case Studies
United Kingdom
The UK stated that the TNO sub-option does not accurately reflect their activities. In the UK,
information from local authority plans are collated and included in air quality plans for zones. The UK
highlighted that the implementation of the JRC toolkit which would aggregate up actions from a local
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level may potentially have a cost saving overall. In the UK information Request they gave an
approximate annual costs associated with the collation of this data as £40,000 per annum (€46,300).
Sweden
Sweden stated that predominantly air quality plans are local except from the larger cities of Stockholm
and Gothenburg where the air quality plans have been developed regionally. Sweden considered that
the implementation of this recommendation may be beneficial but was unable to provide cost
estimation on the impact for their Member State.
Croatia
Croatia currently compiles their local plans and reports these nationally, and it is considered that this
approach works well. In terms of developing air quality strategies the preference would be for a
national rather than regional approach. As this Recommendation is already being undertaken the
impact of implementation would be minimal, however, there may be cost savings in standardising and
simplifying the current system. On the other hand centralisation may jeopardise the implementation of
local action plans, and investing in ensuring there is capacity and awareness at a local level to avoid
this could incur a cost.
9.3.5 Member State Consultation Survey
While most Member States concurred with of qualitative cost assessment, the United Kingdom did
highlight the tools being developed by the JRC for air quality plans data flows for e-reporting may have
a role in reducing costs and burden for Member States. Germany stated that a ‘merging’ or
‘aggregation’ of local or regional plans cannot substitute a national plan which should cover additional
measures beyond the means of the local authorities and consequently, they did not support this
recommendation.
9.4 SEG 10 - High-Level Cost Assessment
Promotion of guidance does not lead to any new imposition of costs. Depending on specific
recommendations in guidance, costs of taking it up may vary widely. The UK estimated the cost of
£40,000 (€46,300) for the collation of data from local plans which is included in air quality plans for
zones in the UK. Extrapolating these costs for UK zones exceeding the NO2 Limit Value this provides
an approximate cost of £1000 (€1,160) per exceeding zone.
Using exceedences of NO2 Limit Value as an example, the following figure provides an indication of
the number of zones exceeding in each Member State (based on ‘461’ Forms for 2011 (see Annex 3)).
Applying the proxy UK costs of collating the data, the following indicative costs may be incurred by
Member States. This does not include any costs for rewriting the local plans into a national plan.
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Figure 5: Approximate costs of collating local plans to a national level based on the number of
zones exceeding the NO2 annual mean (based on ‘461’ Forms 2011)
€ 66.120
€ 54.520
€ 46.400
€ 30.160
€ 10.440
€ 10.440
€ 9.280
€ 5.800
€ 4.640
€ 3.480
€ 3.480
€ 2.320
€ 2.320
€ 2.320
€ 2.320
€ 1.160
€ 1.160
€ 1.160
€ 1.160
€ 1.160
€ 1.160
€ -
€ -
€ -
€ -
€ -
€ -
€ - €
-
€ 1
0.0
00
€ 2
0.0
00
€ 3
0.0
00
€ 4
0.0
00
€ 5
0.0
00
€ 6
0.0
00
€ 7
0.0
00
DE
IT
UK
FR
AT
NL
ES
PL
CZ
BE
SK
BG
HU
PT
RO
DK
EL
FI
LU
LV
SE
HR
CY
EE
IE
LT
MT
SI
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10 SEG 20: Require that the public is informed about exceedence of Limit Values as soon as they occur.
10.1 What is the problem?
The AQD requires that the public is immediately informed on exceedance of an information or alert
threshold and on the air quality levels daily and annually. Because there is no explicit public
information requirement regarding the exceedance of limit values, this information may be not receive
due attention.
10.2 What are the options?
Table 28 provides the sub-options for this SEG Recommendation including the pros and cons
provided in the TNO Report (2012).
Table 28: SEG 20 sub-options from TNO Report (2012)
Description Pros Cons
20 (a) Add a provision requiring
Member States to inform the
public as soon as a Limit
Value is being exceeded.
Active public information
on the most important
events under the air quality
legislation is important.
For daily or hourly Limit
Values: The exceedence will be
predictable long before the day on
which the allowed number of
excedences of the numerical value is
exceeded, unless that day is at the
end of the year. Hence the actual
day of exceedence is not very
relevant.
For annual Limit Values: It
becomes gradually clear whether the
Limit Value will be exceeded.
Additional burden on
Member States
Public information on
exceedences is already required on
an annual basis.
10.3 SEG 20 – Assessment of Evidence
The following section provides an assessment of the available evidence to determine the likely impact
of the SEG 20 Recommendation. This is based upon evidence from the TNO Report (2012) SWOT
analysis, the UK and Danish Workshops, the Member State SEG Information Requests, the Member
State Case Studies and Member State Consultation Survey in addition to the expert-based judgement
of the Project Team.
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10.3.1 TNO Report (2012) SWOT Analysis
In their SWOT analysis, TNO Report (2012) assessed this recommendation as follows (the burden to
Member States is highlighted in bold):
Table 29: TNO Report (2012) SWOT analysis for SEG 20
Aspects Relevant for Prioritisation Importance of Aspect Score
Health / Env Improvement Moderately Favourable 2
Harmonisation among MS Neutral 0
Admin burden to Commission Slightly Unfavourable -1
Burden to MS Moderately Unfavourable -2
Subsidiarity Moderately Unfavourable -2
Complexity of Legislation Slightly Unfavourable -1
Cost of Implementation Slightly Unfavourable -1
Regulatory Stability Slightly Unfavourable -1
10.3.2 UK and Danish Workshops
Delegates stated that this option was not considered to be feasible given the necessary delays in
calculating and reporting Limit Value exceedences to take account of data ratification and adjustment,
e.g. for natural sources, and the issue of the formal compliance statement nine months after the year-
end and suggested that public information should remain linked to Alert and Information Thresholds
rather than Limit Values. All countries have real time air quality information which is good for informing
people but this is a proxy for invalidated data and cannot be used to assess Limit Values due to need
for QA/QC. However, should the recommendation be implemented then the primary requirement
would be on Member States to report the information through their public information systems
10.3.3 Member State Information Request
All Information Request Responses for this Recommendation can be found in Annex 1.
Depending on the sub-option being considered the cost implications varied between respondents. All
responses were qualitative rather than quantitative. The qualitative responses are outlined in the
following Table.
Table 30: Summary of Member States Information Request Responses for SEG 20
SEG 20
Sub-Option
Cost Increase Cost Neutral Cost Decrease No Assessment
Option 20(a) 2
FR, LT
7
BE, CZ, DE, HR,
HU, RO, SE
2
FI, GB
Many Member States reported that they already provide real-time data through their public information
systems and as such the cost implication may be cost neutral or low. No quantitative data was
provided. However, there were concerns which echoed that found in the case studies about the
reporting of limit values as soon as they occur as annual means can only be calculated with a full year
of data, some pollutants require the subtraction of natural contributions, exceedance can only be
declared once data have been checked and ratified.
10.3.4 Case Studies
United Kingdom
As outlined in their Information Request response the UK are not supportive of this recommendation
and highlighted a recent agreement in Brussels (w/b 18th Feb 2013) where Member States annual
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data set has to have 90% data capture to be able to report a limit value exceedence e.g. PM10 annual
data set has to be 90% to even make a comparison against daily mean limit values. This agreement
appears to negate the need for this recommendation. UK does report real-time or near real-time data
on their web-site and deem this as sufficient.
Sweden
Sweden suggested that this activity already occurs due to the provision of real or near real-time data
and this is often used as a proxy. The true impact of this recommendation lies in the specific details
as to how it should be implemented e.g. will Member States be required to specifically highlight
exceedences or is it sufficient to just report the data? Therefore the costs implications are largely
dependent on the existing public information system in place. Sweden provided an indicative cost for
setting up a system for delivering near real-time data to the national data host is estimated to be
around 100,000 SEK (€12,000). This would however, be highly dependent on local authorities having
the IT competence to set up the system at their end. This does not include costs for presentation of
this information and information on exceedences on the internet.
Croatia
Croatia currently has an online presence to report real-time data to the public. There is also an
elaborate two-stage system for the alert threshold: a pre-warning message when the threshold is close
to being breached to local designated authorities in the area of potential exceedence and also to
industrial facilities, e.g. power plants, oil refineries, to alert them to prepare for the possibility of an
exceedence. The second phase, when the exceedence occurs, local authorities have to implement
their short-term action plan, which includes alerting the public. There is public misunderstanding
between the hourly and annual LVs, driven by the media, who do not accept that there are different
averaging periods and that short-term high concentrations are not necessarily exceedences. It is
difficult to estimate the cost of setting-up and operating the alert system as it is not exclusive to air
quality and is part of a wider system to alert the public to other emergencies. A proportion of the cost
could be estimated as <€5k and operating costs for <€1k (to be confirmed in consultation survey
response).
10.3.5 Member State Consultation Survey
Member States indicate that the publication of data from telemetric monitoring stations is not that
expensive using currently available IT tools. Belgium did provide indicative running costs for a public
information system of “1 FTE plus €10,000 for IT”. Consultation responses support the provision
timely information not only to inform the public but also neighbouring Member States. However, the
problem identified in the Information Request, Case Studies and Workshops was again raised as
“information about attainment or otherwise of limit and target values can only be made using ratified
data and there are established mechanism for reporting. It is also important that the attainment status
is reporting officially by the Member State (GB)”.
10.4 SEG 20 - High-Level Cost Assessment Conclusions
Most Member States have existing public information systems on which hourly and daily exceedences
are reported. Annual Limit Values are more challenging as they can only be calculated with a full year
of data, some pollutants require the subtraction of natural contributions, exceedance can only be
declared once data have been checked and ratified (when this process is complete then Member
States report any exceedences).
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N.B. In terms of a Limit Value exceedence, we have interpreted ‘occur’ as the time at which a Member
State is confident of the data quality and it is appropriate to report an exceedence. However, this is
already undertaken in most cases.
To determine the baseline activity of Member States a desk-based review of Member States online
public information systems was undertaken. The primary aim was to determine if a Member State has
an existing online presence through which exceedences may be reported as soon as they occur2. The
following table provides a summary of the review of the web presence that Member States may have
for the reporting of air quality data to the public (this is supported by a more detailed table in Annex 4)
Table 31: Member States with Online public information systems
MS Public friendly online
public alert system
(8 Member States)
‘Indirect’ online public
alert system i.e.
through data provision
(17 Member States)
No easily identifiable
public alert system
(3 Member States)
AT
BE
BG
HR
CY
CZ
DK
EE
FI
FR
DE
GR
HU
IE
IT
LV
LT
LU
MT
NL
PL
PT
RO
SK
SI
ES
SE
2 Please note, this table reflects the ability of a UK researcher to easily find the required information. As a consequence of translation issues some
websites may not have been found. Additionally, other public alert systems may be utilised e.g. radio, television etc which have not been
reflected in this table.
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GB
The following table provides an indicative cost implication for each Member State based on the
evidence available. For those Member States with existing public alert systems it is assessed that the
cost implications with be negligible. For those Member States without existing public information
systems there would be cost implication of a system set-up and on-going maintenance with a
minimum requirement of one technical officer to maintain the system.
Table 32: SEG 20 - High-Level Cost Assessment
Description Qualitative High Level Cost
Assessment
Cost Assessment Member
States
A Member State
already has
reporting
processes in
place and already
reporting
exceedences
(either explicitly or
using proxy)
Most Member States have an online
presence which they utilise to report
exceedences of Alert and Information
Thresholds as required. Additionally, this
online presence is utilised to provide
general air quality information to the
public. The provision requiring Member
States to inform the public as soon as a
Limit Value is being exceeded would not
add significant cost.
Cost
Neutral
AT, BE, DK,
DE, ES, GR,
HR, CY, CZ,
EE, FI, FR,
HU, IE, LV,
LU, MT, NL,
PL, PT, RO,
SK, SI, GB SE
B Member State
does not have
reporting
processes in
place
If a Member State does not have a public
information system then this would have
to be set up and there would be a cost
implication. This assumes Member State
has technical capacity to deliver.
Low set-up costs for a
basic system €12,000
plus minimum
requirement of 1
technical to maintain it.
IT, BG, LT
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11 SEG 21: Harmonise AQ indices in the EU & SEG 22: Develop a Common AQ Index
11.1 What is the problem?
In order to characterise the overall air quality on a certain day, an Air Quality Index (AQI) index composed of the
data for the concentration of the most relevant pollutants can be used. This simple index, e.g. good – moderate –
bad, can be used to inform the general public, especially regarding the current situation or a forecast for the next
day(s). Several cities in the EU are already using such an index. A Common Air Quality Index (CAQI) has been
developed by cities through the CITEAIR project funded by the INTERREG programme. .
11.2 What are the SEG 21/22 sub-options?
Table 33 provides the sub-options for this SEG Recommendation including the pros and cons
provided in the TNO Report (2012).
Table 33: SEG 21/22 sub-options from TNO Report (2012)
Description Pros Cons
21 & 22(a) Develop a common air
quality index through an EU
working group and promote it
in subsequent guidance to
Member States.
Harmonisation
of public information
Raises public
awareness of air pollution
Subsidiarity; many authorities
may prefer to choose their own way of
informing the public about air quality.
Because of differences in
average concentration levels in
European regions it may be difficult to
achieve agreement on the definitions
of index ranges.
A single index for all
pollutants does not well characterise
the levels for each individual pollutants
e.g. primary pollutants can be high on
days with low ozone concentrations.
21 & 22(b) Develop a common air
quality index through an EU
working group and include a
requirement to publish a
daily air quality index in air
quality legislation.
As above As above but the subsidiarity problem
is more pronounced.
11.3 SEG 21/22 – Assessment of Evidence
The following section provides an assessment of the available evidence to determine the likely impact
of the SEG 21/22 Recommendations. This is based upon evidence from the TNO Report (2012)
SWOT analysis, the UK and Danish Workshops, the Member State SEG Information Requests, the
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Member State Case Studies and Member State Consultation Survey in addition to the expert-based
judgement of the Project Team.
11.3.1 TNO Report (2012) SWOT Analysis
In their SWOT analysis, TNO Report (2012) assessed this recommendation as follows for SEG 21 and
SEG 22 (the burden to Member States is highlighted in bold):
Table 34: TNO Report (2012) SWOT analysis for SEG 21
Aspects Relevant for Prioritisation Importance of Aspect Score
Health / Env Improvement Slightly Favourable 1
Harmonisation among MS Moderately Favourable 2
Admin burden to Commission Moderately Unfavourable -2
Burden to MS Moderately Favourable 2
Subsidiarity Moderately Unfavourable -2
Complexity of Legislation Slightly Unfavourable -1
Cost of Implementation Moderately Unfavourable -2
Regulatory Stability Neutral 0
Table 35: TNO Report (2012) SWOT analysis for SEG 22
Aspects Relevant for Prioritisation Importance of Aspect Score
Health / Env Improvement Moderately Favourable 2
Harmonisation among MS Highly Favourable 3
Admin burden to Commission Highly Unfavourable -3
Burden to MS Moderately Unfavourable -2
Subsidiarity Highly Unfavourable -3
Complexity of Legislation Moderately Unfavourable -2
Cost of Implementation Moderately Unfavourable -2
Regulatory Stability Moderately Unfavourable -2
11.3.2 UK and Danish Workshops
The implementation of this option was generally perceived as a positive, particularly to give strength of
the EU approach and to avoid the inevitable confusion arising between multiple AQI. However, given
that that many Member States had already invested considerable resources to develop their own AQI
it was recognised that there may be some resistance to conversion to a harmonised EU index.
Delegates questioned the relevance of a CAQI e.g. does Copenhagen really want to compare with the
Po Valley. The delegates suggested that there may be a cost implication for those Member State that
have to amend their existing AQI and this would be higher than those Member States currently without
an AQI.
11.3.3 Member State Information Request
All Information Request Responses for this Recommendation can be found in Annex 1.
Depending on the sub-option being considered the cost implications varied between respondents. All
responses were qualitative rather than quantitative. The qualitative responses are outlined in the
following Table.
Table 36: Summary of Member States Information Request Responses for SEG 21/22
SEG 21/22
Sub-Option
Cost Increase Cost Neutral Cost Decrease No Assessment
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Option 21/22(a) 2
DE, GB
5
BE, CZ, FR, LT, SE
4
FI, HR, HU, RO
Option 21/22(b) 2
DE, GB
5
BE, CZ, FR, LT, SE
4
FI, HR, HU, RO
For the majority of Member States that responded there was estimation that the implementation of this
recommendation was cost neutral (except UK and Germany). Only the UK provided a quantitative
response – all other MS provided qualitative response. There was a mixed response to the desirability
of a CAQI with some MS supporting it (e.g. Czech Republic and Hungary) while others are less
favourable (e.g. Finland and UK). Both UK and Germany indicated costs implications associated with
the reporting of a CAQI
Germany does not currently have an AQI and therefore recognised the cost implications of
setting this up.
UK has an existing bespoke UK AQI which would cost approximately £75,000 - £100,000
(€86,800 - €116,000) to amend across the UK.
11.3.4 Case Studies
United Kingdom
The UK stated that the case for harmonisation had not been sufficiently made and highlighting the
extensive resources already dedicated to the development of the own UK bespoke AQI based on the
recommendation of their expert committee (COMEAP). The also reiterated the point that it is not
important to know how air quality in the UK compares to other MS given the number of variables
involved. The estimate that the cost of amending of their national air quality forecasting and
information systems would be approximately £10,000 (€11,600) but amendment would also have to be
made to systems at the Devolved Administrations, regional and local levels resulting in a potential cost
implication of £75,000 - £100,000 (€86,800 - €116,000) across the UK. The UK also highlighted the
fact that they report real-time or near real-time monitoring data to the EEA and that the EEA may be
the appropriate location to report a CAQI allow Member States to continue reporting their own local
AQI.
Sweden
Sweden does not have a standard AQI reported at a national level and different local authorities have
their own individual AQI. Sweden recognised that they should have a CAQI (at least within Sweden)
and they estimated the set-up costs at approximately €20,000 at a national level. This cost may be
higher when considering the need to amend local AQI.
Croatia
Croatia does not currently have an AQI, just the real-time data online showing whether stations are
below or above the threshold. Croatia would estimate the set-up costs of establishing an AQI would be
between €5,000-€10,000 (to be confirmed in consultation survey response), though they are currently
planning on changing the system anyway so amending the revised system would potentially be less
cost and possibly within normal capability development. Croatia currently provides some real-time data
to the EEA (but unsure whether this is for all pollutants), so under Scenario C, costs would be largely
minimal. If the EEA were to establish a common AQI, then MS would probably implement and report
this on their systems. This Recommendation would be supported by Croatia in order to help convey air
quality information to the public more helpfully and to provide a comparable AQI across MS.
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11.3.5 Member State Consultation Survey
Most Member States agreed with our qualitative cost assessment. The cost of amending existing AQI
varied, Belgium suggested that it would be approximately 1 month of work but this would be largely
dependent on the CAQI to be implemented. The UK reiterated the cost of £100,000 to amend all AQI
nationally, regionally and locally. There doesn’t appear to be mush support from respondents for a
CAQI with Germany, United Kingdom and Ireland not in favour of an integrated approach. Ireland are
also about (April 2013) to launch a new AQI using a multi-sector approach which is not in common
with CITEAIR. The United Kingdom and Ireland were both in favour of Scenario C outlined below.
11.4 SEG 21/22 - High-Level Cost Assessment Conclusions
Based on an extensive desk-based web-review3, many Member States have an existing AQI and
therefore the implementation of a CAQI may just require adjustment of their existing systems but the
level of adjustment is unknown until the CAQI is confirmed (See Annex 5). Alternatively, some
Member States may choose to retain their own AQI and also report the CAQI although this may lead
to some confusion for the public and is not supported. The following table provides a summary of the
review of air quality indices that Member States have for the reporting of air quality data to the public.
Table 37: Summary of Member States with an AQI
MS Air Quality Index Available
(15 Member States)
No Air Quality Index
(13 Member States)
AT
BE
BG
HR
CY
CZ
DK
EE
FI
FR
DE
GR
HU
IE
IT
LV
LT
LU
MT
NL
PL
PT
3 Please note, this table reflects the ability of a UK researcher to easily find the required information. As a consequence of translation issues some
AQI may not have been found.
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MS Air Quality Index Available
(15 Member States)
No Air Quality Index
(13 Member States) RO
SK
SI
ES
SE
GB
Assuming a CAQI applied across all Member States, the worst-case cost implications are outlined
below. This is based on the UK estimation of the adjustment required and therefore may be
considered worst case as this cost includes the adjustment of systems at for Devolved
Administrations, regionally and locally.
Description Qualitative High Level Cost Assessment Cost
Assessment
Member States
A Member State has
an existing air
quality index
which is adjusted
accordingly.
This scenario is based on the assumption that
should a CAQI be established then Member
States would adjust their AQI accordingly at a
national and local level. The input required to
adjust any existing index is unknown at this
stage until a CAQI is required.
Worst-case
based on UK
approximate
costs
>€100,000
BE, HR, CY, CZ,
EE4, FI, FR, HU,
IE, IT, LT, LU,
PL, PT, RO, GB
B Member State has
no AQI and is
required to
establish and
report a common
air quality index
This scenario would require a Member State to
establish and report a common air index. There
would be less cost than Scenario A as the
background activities to define an AQI is already
done for the Member State.
Medium
Additional
Cost Burden
(€20-€60k)
AT, BG, DK, DE,
GR, IT, LV, MT,
NL, SK, SI, ES,
SE
C EEA report a
common air
quality index not
Member States
Through the provision of real-time date from
Member States to the EEA, a common AQI is
reported centrally. Member States continue with
their own AQI’s and link to the common AQI
provided by EEA
Low Additional
Cost Burden
(<€20k)
All Member
States
4 Cost implication may be lower for Estonia as their system follows the CITEAIR methodology.
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12 Summary
An analysis was undertaken for the European Commission with respect to the potential impacts on
Member States should the selected Stakeholder Expert Group (SEG) Recommendations be
implemented, with a particular focus on the potential financial impacts.
The selected SEG Recommendations were:
SEG 1: Standardise compliance projections.
SEG 2: Do not relate air quality plans to zones.
SEG 4: Reduce assessment / reporting for standards that are largely met.
SEG 5: Clarify the definition of the risk of exceedence.
SEG 7: Reduce the administrative burden regarding the development of short term action plans.
SEG 8 & 9: Promote the assessment of synergetic measures in air quality plans & Promote the
consideration of antagonisms with other policies in the development of air quality measures.
SEG 10: Promote Member States developing national or regional air quality strategies or plans
SEG 20: Require that the public is informed about exceedences of Limit Values as soon as they
occur
SEG 21 & 22: Harmonise air quality indices in the EU & Develop a Common Air Quality Index
It should be recognised that the recommendations of SEG, compared to AQUILA (Task 1) and
FAIRMODE (Task 2), have not been subject to the same intensive development processes and
subsequently, in many instances the recommendations are not sufficiently well-defined to allow for the
quantification and monetisation of their impact should they be implemented. The challenges made the
accurate quantification and monetisation of the SEG Recommendations unfeasible; these challenges
were further manifested in the Member State Workshops and the qualitative response to the SEG
Member State Information Requests. The proposed solution was to undertake a qualitative analysis of
the impact of the recommendations and to provide, where feasible high-level expert-based
assessment of the likely cost implications.
A synopsis of the headline findings are provided below.
SEG 1 – Standardise Compliance Projections
The available evidence indicates that the implementation of this option would incur additional cost on
Member States but that the quantification of this cost could not be determined due to the lack of
specificity in the recommendation and sub-options. Additionally, Member States would need to
develop their modelling capacity and capabilities (see FAIRMODE Report).
SEG 2 - Do not relate air quality plans and zones
Depending on the way in which the recommendation is implemented, there may be some costs
incurred for the refinement of an air quality plan and data gathering. Air quality plans would still have
to be developed and the presence (or absence) of a link between the air quality plan and zone would
have little cost on the plans development. However, the flexible nature that Member States operate
should be noted as there does not appear to be a common approach applied.
SEG 4 – Reduce assessment reporting for standards that are largely met
Based on the balance of available evidence, it is likely that the implementation of this recommendation
would result in cost savings for Member States but this is completely dependent to the detailed of the
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recommendation implementation route and its uptake by Member States. The implementation of this
recommendation may achieve a saving in equipment and running costs primarily due to the possible
reduction in monitoring instrumentation (should Member States choose to do so). However, this is
dependent on each Member State.
SEG 5 – Clarify the definition of the risk of exceedence
The long-standing cost implications are unknown as, there is no indication as to exactly how the risk
would be redefined and therefore the impact on Member States cannot be determined. Qualitative
assessment comments from Member States Information Requests and case studies indicate that the
implementation of this option is unlike to have cost implications although Germany and Lithuania did
identify additional costs associated with reporting and staff time (this was not quantified).
SEG 7 – Reduce the administrative burden regarding the development of Short Term Action
Plans
Member States have indicated that their exceeedence of NO2 and SO2 alert thresholds rarely / never
happen, this is supported by EEA Report (2012) which indicates that no Member State exceeded the
NO2 or SO2 alert threshold. Therefore the removal of this threshold would have no impact on Member
States as they would still need to monitor, assess and report against other NO2 and SO2 objectives
therefore no major reduction in high equipment costs.
SEG 8/9 - Promote the assessment of synergetic measures in air quality plans & Promote the
consideration of antagonisms with other policies in the development of air quality measures.
This activity is undertaken in some capacity by most Member States although usually through inter-
departmental consultation. The cost implications are dependent on the interpretation of the term
‘consideration’ as this may be ‘consideration’ through consultation and qualitative assessment or
‘consideration’ through detailed quantitative assessment of options.
SEG 10 - Promote Member States developing national or regional air quality strategies or plans
Member States indicated that the cost implications associated with this option would be completely
dependent on implementation methodology. Most Member States report as local plans (exception of
UK and Netherlands) but a varying approach is applied dependant on the pollutant being assessed
e.g. NO2 may be a local plan but O3 would be a national plan. Depending on specific
recommendations in guidance, costs of taking it up may vary widely.
SEG 20 – Require that the public is informed about exceedence of Limit Values as soon as they
occur
Many Member States reported that they already provide real-time data through their public information
systems and as such the cost implication may be cost neutral or low. However, there were concerns
which echoed that found in the case studies about the reporting of limit values as soon as they occur
as annual means can only be calculated with a full year of data, some pollutants require the
subtraction of natural contributions, exceedance can only be declared once data have been checked
and ratified. Twenty-five Member States were found to have existing online public alert systems which
may be utilised to implement this recommendation at a low cost. The remaining three Member State
may require the establishment of such systems at an additional cost.
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SEG 21/22 - Harmonise AQ indices in the EU & Develop a Common AQ Index
Based on an extensive desk-based web-review5, many Member States have an existing AQI and
therefore the implementation of a CAQI may just require adjustment of their existing systems but the
level of adjustment is unknown until the CAQI is confirmed (See Annex 5). Alternatively, some
Member States may choose to retain their own AQI and also report the CAQI although this may lead
to some confusion for the public and is not supported. Fifteen Mmeber State were found to have an
existing AQI.
5 Please note, this table reflects the ability of a UK researcher to easily find the required information. As a consequence of translation issues some
AQI may not have been found.
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Annex 1: SEG Information Request & Results
The following Annex provide an introduction to the structure of the SEG Information Requests which
were provided to Member States as a means to reporting their current baseline activities and to
assess the likely impact should a recommendation be implemented.
Introduction to the SEG Information Request
To monetise the impact of the SEG, AQUILA and FAIRMODE recommendations the Information
Requests were utilised to generate detailed information regarding the resources needed for
implementation of each of the Recommendations. A prerequisite for making the required cost
calculations is that sufficient, and sufficiently reliable, information can be obtained regarding the
resources necessary for implementation. As the resource requirement may vary substantially across
Member States, e.g. due to variability in air quality initiatives currently in place and/or differences in
organisational structures, the resources required to get from the current status quo to a situation of full
implementation of the different recommendations is likely to be very different for the various Member
States. This implies that Member State specific information regarding the current status quo, along
with detailed quantitative information about resource requirements, needed to be collated for each
individual recommendation.
Subsequently, there were two primary aims of the Information Requests:
1. To provide a structure by which individual Member States could qualitatively and quantitatively
describe their current activities and resources relevant to specific AQUILA, FAIRMODE and
SEG recommendations.
2. To provide a structure by which individual Member States could qualitatively and quantitatively
describe the potential impact on their activities and resources of specific AQUILA, FAIRMODE
and SEG recommendations.
The Information Requests were provided to Member States as an online survey and an Excel
Spreadsheet.
Information Request Structure
As the SEG, AQUILA and FAIRMODE recommendations span a very broad spectrum of initiatives the
implementation of the separate recommendations is very different in terms of resource requirements;
not just in terms of the amount of resources required, but also in terms of the type of resources
required. For some recommendations, it is only a sub-set of the cost categories that are relevant, e.g.
capacity building related recommendations where investment costs are likely to be irrelevant, while for
others all cost categories need to be considered by Member States.
To allow for ease of management and familiarity between the AQUILA, FAIRMODE and SEG tasks, a
broadly common structure was applied to each recommendation within the Information Requests.
This is outlined as follows:
Introduction to the Recommendation and a description of the inherent issues.
Introduction to any sub-options.
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Selection of questions related to the current Member State activities and dedicated resources.
Selection of questions, under six cost categories, related to changes in Member State activities and
resources should a Recommendation be implemented. The cost categories were:
- Equipment and Facilities
- Operation and Maintenance
- New Data Generation and Compilation
- Reporting and Administration
- Additional staff levels and staff time
- Staff capacity development
The process diagram below provides a description of the structure of the Information Requests (Figure
6).
Figure 6: Process Diagram of the Member States Information Requests for AQUILA. FAIRMODE
and SEG
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12.1.1 Establishing the Current Baseline within Member States
To qualitatively and quantitatively determine the current baseline activities and resources for Member
States relevant to each Recommendation within AQUILA, FAIRMODE and SEG we asked a common
baseline question (see Table 38) and some Recommendation specific questions (if required - Table
39). Rather than asking Recommendation specific questions FAIRMODE simply included an
additional common question for each option of:
“Does your Member State currently conform to the standards or practices specified in the
recommendation above? Please clarify your response”.
Once Member States had provided information on their current baseline activities and resources, they
were asked:
“Would the implementation of this option have an impact on ANY costs within your Member
State (either increase or decrease costs)?”
A ‘Yes’ Response took the Member to the Implementation Cost Categories while a ‘No’ response to
the Member State to the next Recommendation to be considered
Table 38: Common Baseline Assessment Question for each Recommendation
Sub-Heading Cost Categories
Considering your current activities
related to this option, please
provide an estimate of your
current baseline annual cost using
the following cost categories?
Equipment
Facilities
Operation
Maintenance
Data Generation
Data Compilation
Reporting
Administration
Additional Staff Costs
Staff Capacity Development
Table 39: Recommendation specific questions for SEG
Recommendation Questions
Rec 1 Please outline the approach taken in your Member State to ensure compliance
projection.
Rec 2 With regard to Article 23.1 of Directive 2008/50/EC, in your Member State do air quality
plans relate to zones and agglomerations? (Please provide details as necessary.)
Rec 4 In your Member State, is assessment and reporting relaxed for those standards that are
largely met? (Please provide details as necessary.)
Rec 5 With regard to the preparation of short term action plans, in your Member State how is
the ‘risk’ of exceedence determined? (Please provide details as necessary.)
Rec 7 Has a short term action plan been prepared in response to the identification of a risk of
exceedence? (Please provide details as necessary.)
Rec 8/9 Are synergies and antagonisms between air quality plans and other policies considered
in your Member State? (Please provide details as necessary.)
Rec 10
In your Member State, have air quality plans been developed as single overarching
regional or national plans as in the Netherlands, or as an aggregate of local air quality
plans as in the UK (or any other method)? (Please provide details as necessary.)
Rec 20 In your Member State, is the public informed about exceedences of limit values as soon
as they occur? (Please provide details as necessary.)
Rec 21/22 If an air quality index is used in your Member State is this a bespoke index or one utilised
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from another source? (Please provide details as necessary.)
12.1.2 Recommendation Implementation Cost Categories
While the current / baseline questions for each Recommendation varied depending on the
Recommendation being analysed, the question structure for the Cost Categories was consistent
throughout the AQUILA, FAIRMODE and SEG Information Requests. Where possible, Member
States were asked to provide further information (description, quantity, cost per unit) on the impact that
the implementation of a Recommendation would have in the various Cost Categories. This question
structure is outlined in the following tables (Table 40, Table 41, Table 42, Table 43,
Table 44 and Table 45).
Table 40: Cost Category 1 – Equipment and Facilities
Sub-Heading Questions
Equipment
Please describe any changes in equipment?
Please quantify the changes in equipment? (number of units)
Please estimate the cost in changes to equipment? (cost per unit)
Facilities
Please describe any changes in facilities?
Please quantify the changes in facilities? (number of units)
Please estimate the cost in changes to facilities? (cost per unit)
Others
Please describe any changes in 'others'?
Please quantify the changes in 'others'? (number of units)
Please estimate the cost in changes to 'others'? (cost per unit)
Additional
Comments
Any additional comments?
Table 41: Cost Category 2 – Operation and Maintenance
Sub-Heading Questions
Operation
Please provide a description of the type of changes to operation costs?
Please quantify any changes in staff levels? (number of FTE staff)
Please quantify any changes in existing staff time for operation? (working days per
annum)
Please quantify any changes to staff capacity development time? (working days per
annum)
If not previously provided, please describe and quantify any other changes in costs related
to operation of equipment / facilities (e.g. finance, energy costs etc)?
Maintenance
Please provide a description of the type of changes to maintenance costs?
Please quantify any changes in staff levels? (number of FTE staff)
Please quantify any changes in existing staff time for maintenance? (working days per
annum)
Please quantify any changes to staff capacity development time? (working days per
annum)
If not previously provided, please describe and quantify any other changes in costs related
to the maintenance of equipment / facilities (e.g. finance, energy costs etc)?
Additional
Comments
Any additional comments?
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Table 42: Cost Category 3 – New Data Generation & Compilation
Sub-Heading Questions
Data Generation
Please provide a description of the type of changes to data generation costs?
Please quantify any changes in staff levels? (number of FTE staff)
Please quantify any changes in existing staff time for data generation? (working days per
annum)
Please quantify any changes to staff capacity development time? (working days per
annum)
If not previously provided, please describe and quantify any other changes in costs related
to data generation?
Data Compilation
Please provide a description of the type of changes to data compilation costs?
Please quantify any changes in staff levels? (number of FTE staff)
Please quantify any changes in existing staff time for data compilation? (working days per
annum)
Please quantify any changes to staff capacity development time? (working days per
annum)
If not previously provided, please describe and quantify any other changes in costs related
to data compilation?
Additional
Comments
Any additional comments?
Table 43: Cost Category 4 – Reporting & Administration
Sub-Heading Questions
Reporting
Please describe how the implementation of this option may affect reporting?
Does the implementation of this option require any changes in staff levels for reporting?
(please quantify the number of FTE staff)
Does the implementation of this option require any changes in existing staff time for
reporting? (please quantify the number of working days per annum)
Please provide an estimate of total change in costs for reporting?
Meetings
Please describe how the implementation of this option may affect meeting time?
Does the implementation of this option require any changes in staff levels for meetings?
(please quantify the number of FTE staff)
Does the implementation of this option require any changes in existing staff time for
meetings? (please quantify the number of working days per annum)
Please provide an estimate of total change in costs for meetings?
Administration
Please describe how the implementation of this option may effect administration time?
Does the implementation of this option require any changes in staff levels for
administration? (please quantify the number of FTE staff)
Does the implementation of this option require any changes in existing staff time for
administration? (please quantify the number of working days per annum)
Please provide an estimate of total change in costs for administration?
Additional
Comments
Please describe and quantify any other costs or comments not considered above? e.g.
transport for meetings
Any additional comments?
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Table 44: Cost Category 5 – Additional Staff Levels and Staff Time
Sub-Heading Questions
Staff Levels or
Time
Please describe the reasons for the changes in staff levels and/or staff time?
Does the implementation of this option require any changes in staff levels? Please quantify
(number of FTE staff)
Does the implementation of this option require any changes in existing staff time? Please
quantify (working days per staff per annum)
If possible, please provide an estimate cost of the total change in staff time?
Additional
Comments
Any additional comments?
Table 45: Cost Category 6 – Staff Capacity Development
Sub-Heading Questions
Capacity
Development
Please describe the reasons for the changes in staff capacity development?
Does the implementation of this option require any changes in staff capacity development
time? Please quantify (working days per staff per annum)
If possible, please provide an estimate of other costs associated with the change in
capacity development? e.g. internal / external training costs, course fees etc
Additional
Comments
Any additional comments?
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SEG Information Requests Results
The following Tables provide the results from the SEG Information Requests provided by Member States. As previously discussed, the majority of responses
provided only included qualitative assessments and therefore little quantitative data was available.
Cost Implication Colour Key:
Cost Increase Cost Neutral Cost Decrease No Cost Assessment
SEG 1 Information Request Responses
Table 46: SEG 1 – Information Request Responses
MS Member State Comments
Option 1(a): Disseminate existing guidance. In 2008 guidance on air quality plans has been updated, which includes guidance on projections. It has however not
yet been disseminated by the Commission; this can be done.
BE
Compliance projections are calculated using deterministic air quality models. Modelling is performed at the interregional level (IRCEL) and by the three regions. In
Flanders, the modelling of background concentrations the BelEUROS model with a spatial resolution of 15x15 km is used. For higher resolution modelling (till 1 km²),
the AURORA-model is used. To calculate the impact of e.g.industrial sources, traffic, ... at the local scale, the bigaussian IFDM (Immission Frequency Distribution
Model) model is used. Projections in streetcanyons are modelled using streetbox models.
Whether or not there will be additional costs and the amount will depend on the guidance given and how much this differs from the way we do the modelling at this
moment.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
CZ
Presently we assess only effect of measures from Air Quality Plans on air quality. We are preparing MEDIUM-TERM AIR PROTECTION STRATEGY FOR THE
CZECH REPUBLIC, which will concern projections for locations with exceedences. We support the idea of common guidance and/or projections used by all member
states.
It will be necessary to strengthen personal capacities to be able to process meaningfully such data.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
DE We use several different approaches. In general projections start with regional modelling based on emission projections. The effects of local measures are based on
expert judgement or on modelling whereby the urban background concentrations are kept constant (conservative approach).
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CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
FI
Limit value exceedances have been observed only in Helsinki Metropolitan Area which is defined as an agglometarion. PM10 daily limit value has been exceeded in
2005 (max. 49 exceedance days) and 2006 (max. 37). Both explaned by winter sanding. NO2 annual limit + MOT exceeded in 2006 (max. 42 ug/m3). Exceedances
also in 2007-2012. Air quality plan prepared in 2008. Time extention granted in 2012. There are no special requirements regarding the projections. EU guidance
documents used as reference.
Cost implications related to projections depend on possible future exceedances. Costs may increase if limit values are tightened or if local emissions increase.
Unvavourable weather conditions can also increase concentrations above limit values in areas where levels are normally just below the limit.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
FR
Compliance projections are made in the framework of the local air quality plans (i.e. in the so-called "Plan de Protection de l'Atmosphère-PPA"), on the basis of local
inventories and modelling results. The consequence is that the tools can differ from a region to another (26 administrative regions in France), as the way of
elaborating emission sources inventories but we work in order to harmonize. The objective is nevertheless the same (i.e. the compliance with the limit and target
values) and a national scenario (the OPTINEC scenario) is disseminated and used as a 'baseline scenario' in all regions.
It can be an increase or a decrease (high dependancy on the recommandations/requirements of the guidance and the impact on existing local tools (which may have
already covered the new orientations).
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
GB
It is not clear what this recommendation would require MS to do. We are not able to estimate costs. Standardisation of compliance projections are not recommended
by FAIRMODE and iit is not possible to comment on how guidance which we havent seen may or may not assist us. Further attempts to standardise practice across
the EU through prescription may not succeed. Suggestions on improvements could apply equally to compliance assessments and emissions inventories, not just
projections. Directive needs to take into account the different approaches in MS, including those MS who use and report modelled data.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
HR
a) monitoring of air pollutants in zones and agglomerations; b) modelling of air pollutants in zones and agglomerations; c) annual reporting and assessment of air
quality; d) preparation of action plans; Baseline costs €805k
There will be change in cost related to FAIRMODE activities, i.e. Implementation of models (see FAIRMODE questionnaire)
There will be additional costs in relation to development of database for modelling results (see FAIRMODE questionnaire)
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
HU In the lack of models expert estimates are used. They are obviously not really harmonised but most often give quite exact numbers. Obviously we would appreciate
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any help - guidance, FAIRMODE or others as well. We may have problem with English knowledge at local autority side, unfortunately.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
LT
-
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
RO
No
CC1
Equip & Facilities
CC2
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This is only done on an ad-hoc basis. There is a relatively unspecific requirement in the legislation for the authorities, when developing action plans, to estimate the
likely effects of different measures, but no specific requirement to carry out routine compliance projections. The info provided on effects of measures varies widely
between action plans. Compliance projections have, however, recently been carried out for the four Swedish cities (Stockholm, Gothenburg, Umeå and Uppsala) with
exceedences of the limit value for NO2, with a view to notifying the Commission on a time extension. No data is available on the costs to authorities of assessing
the effect of measures during action planning. Altough it is likely to be a very low cost. In carrying out compliance projections for a possible time extension notification
for NO2 to 2015, the modelling assessments were carried out by consultants and cost approx 100,000 SEK for Stockholm and Uppsala combined, and 35,000 SEK
for Umeå. The provision of guidance would not have any impact on costs, but could increase cost-effectivenes of action planning if the guidance proves to be
effective.
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Option 1(b, c & d): Provision of New Guidance, Workshops and Website. FAIRMODE may have a major role in this.
BE
Compliance projections are calculated using deterministic air quality models. Modelling is performed at the interregional level (IRCEL) and by the three regions. In
Flanders, the modelling of background concentrations the BelEUROS model with a spatial resolution of 15x15 km is used. For higher resolution modelling (till 1 km²),
the AURORA-model is used. To calculate the impact of e.g.industrial sources, traffic, ... at the local scale, the bigaussian IFDM (Immission Frequency Distribution
Model) model is used. Projections in streetcanyons are modelled using streetbox models.
Whether or not there will be additional costs and the amount will depend on the guidance given and how much this differs from the way we do the modelling at this
moment.
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CZ It seems to be reasonable to prepare new guidance which will take into account latest development and specific local conditions in different member states. We
suppose, this task will be coordinated by EU/FAIRMODE group.
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We don't see a big difference to option 1a. In our reply we assume that an appropriate level of model complexity will be chosen. In particular any model selection
should take place with a view to the quality of the input/emission data. A workshop would be welcome.
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Guidance (existing and possibly new), workshops and Website could be helpful. However, when local authorities are responsible for plans and projections the
language barrier may sometimes limit the usefulness of such information channels. Guidance provided only in English will not treat Member States equally. Use of
consultants may also be challenging for local authorities if there is not enough know-how to evaluate the competence of such contractors. Both service providers and
authorities need guidance and support.
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Compliance projections are made in the framework of the local air quality plans (i.e. in the so-called "Plan de Protection de l'Atmosphère-PPA"), on the basis of local
inventories and modelling results. The consequence is that the tools can differ from a region to another (26 administrative regions in France), as the way of
elaborating emission sources inventories but we work in order to harmonize. The objective is nevertheless the same (i.e. the compliance with the limit and target
values) and a national scenario (the OPTINEC scenario) is disseminated and used as a 'baseline scenario' in all regions.
It can be an increase or a decrease (high dependancy on the recommandations/requirements of the guidance and the impact on existing local tools (which may have
already covered the new orientations).
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GB
It is not clear what this recommendation would require MS to do. We are not able to estimate costs. FAIRMODE is not recommending the standardisation of
projections. Not clear how you can cost guidance, workshops and a website or the impact on any of future events/documents on processes.
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In areas where compliance has yet to be achieved, there is an obligation to make an action plan on a local/regional/national level with measures that would lead to
achieving of required standards of air quality. Plan for reduction of air pollutants at national level is based on all relevant information (monitoring data, modelling data,
emission sources and emission data in agglomerations and zones) including influence of long-range transboundary transport of air pollution. Baseline costs €100k
costs are related to FAIRMODE activities, details are in FAIRMODE questionnaire responses
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At this time there is no action taken on this issue.
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Again, no direct change in cost, but could increase cost-effectivenes of action planning if the guidance & information exchange proves to be effective.
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Option 1(e): Make Europe-scale projections on emissions and concentrations better available to local authorities. The emission and concentration data may be
(based on) the EMEP and IIASA results obtained during policy preparation projects. These data could be made available on a website of the Commission, EEA or
e.g. the GMES Atmospheric Monitoring Service. Note that this possibility only standardises European data used in compliance projections – but this may be the
most important weakness for local authorities.
BE
We already use data provided by EMEP and IIASA for our baseline and projections
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The opening of these datasets to wide user’s community must be accompanied by the preparation of the clear user’s guide to avoid an incorrect application of the
data.
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In our reply we assume that the use of such data would be optional. Under this condition we consider it helpful to have such results available.
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Support this recommendation.
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FR
Compliance projections are made in the framework of the local air quality plans (i.e. in the so-called "Plan de Protection de l'Atmosphère-PPA"), on the basis of local
inventories and modelling results. The consequence is that the tools can differ from a region to another (26 administrative regions in France), as the way of
elaborating emission sources inventories but we work in order to harmonize. The objective is nevertheless the same (i.e. the compliance with the limit and target
values) and a national scenario (the OPTINEC scenario) is disseminated and used as a 'baseline scenario' in all regions.
The work which is done at the national level is EMEP and IIASA compliant. Nonetheless, hypotheses, especially activity hypotheses and yet more to the point local
activity hypotheses, may differ from those taken by IIASA. France would not be beholden to projections using hypotheses it has no say in.
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It is not clear what this recommendation would require MS to do. It is not clear whether MS would have to use these projections or whether they would be considered
a benchmark for comparison or compliance. If provided for information they might be useful to MS at little cost but if compliance with them were to be enforced then
we would not support this idea, which could be a major burden on MS. We are not able to estimate costs.
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See previous
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At this time there is no action taken on this issue.
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Again, no direct change in cost, but could increase cost-effectivenes of action planning.
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Option 1(f): Harmonise or standardise modelling of compliance projections
BE
Compliance projections are calculated using deterministic air quality models. Modelling is performed at the interregional level (IRCEL) and by the three regions. In
Flanders, the modelling of background concentrations the BelEUROS model with a spatial resolution of 15x15 km is used. For higher resolution modelling (till 1 km²),
the AURORA-model is used. To calculate the impact of e.g.industrial sources, traffic, ... at the local scale, the bigaussian IFDM (Immission Frequency Distribution
Model) model is used. Projections in streetcanyons are modelled using streetbox models.
Whether or not there will be additional costs and the amount will depend on the guidance given and how much this differs from the way we do the modelling at this
moment.
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CZ
Several activities in progress are trying to harmonize modelling procedures. It will be important to follow in these activities not to establish a new one. CHMI takes part
in some of them. To extend such activities we need to strengthen personal capacities at modelling department.
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Attempt to harmonise is basically a good thing. However, exceedance situations differ and require different approaches - from fairly simple assessment to highly
sophisticated modelling excercise. Standard models are not likely to come available in the near future. They could also distort competition and hinder model
development.
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Compliance projections are made in the framework of the local air quality plans (i.e. in the so-called "Plan de Protection de l'Atmosphère-PPA"), on the basis of local
inventories and modelling results. The consequence is that the tools can differ from a region to another (26 administrative regions in France), as the way of
elaborating emission sources inventories but we work in order to harmonize. The objective is nevertheless the same (i.e. the compliance with the limit and target
values) and a national scenario (the OPTINEC scenario) is disseminated and used as a 'baseline scenario' in all regions.
A national guidance was elaborated in order to harmonise the the methodologies for compliance projections in the local plans (PPA).
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GB The FAIRMODE recommendations do not include a recommendation that modelling should be standardised or harmonised.
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See FAIRMODE questionnaire response
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At this time there is no action taken on this issue.
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Again, no direct change in cost, but could increase cost-effectivenes of action planning.
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Option 1(g): Provide a catalogue of measures that (also) can be used as a benchmark for judging the effectiveness of measures.
BE
In the directive 2008/50/EC, annex XV, B, 3, there is a catalogue of examples of measures that can be used in the action plans. The knowledge on the effectiveness
of measures could be interesting, but this will probably also depend on the specific characteristics of a county / region (e.g. the number of diesel cars, the intensity of
wood burning, ...)
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CZ
This could be helpful, but can be difficult to manage comparability in all EU member states. Estimated baseline costs CZK1.3m
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Support this recommendation. Effectiveness of individual measures can be high, medium or low. Sometimes, it is not possible to quantify these effects in an exact
way. In particular, when changes in concentrations are predicted to be very small the results should be handled with caution and always bearing in mind the overall
uncertainty of the method..
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FR
Compliance projections are made in the framework of the local air quality plans (i.e. in the so-called "Plan de Protection de l'Atmosphère-PPA"), on the basis of local
inventories and modelling results. The consequence is that the tools can differ from a region to another (26 administrative regions in France), as the way of
elaborating emission sources inventories but we work in order to harmonize. The objective is nevertheless the same (i.e. the compliance with the limit and target
values) and a national scenario (the OPTINEC scenario) is disseminated and used as a 'baseline scenario' in all regions.
A catalogue of measures (with examples of quantification of their effectiveness) can be really useful but it is necessary to study the concrete way of using and
implementing them in the local compliance projections because the effectiveness of a measure may greatly differ from a situation to another. (Having a common
efficiciency indicator would be very helpfull but is this achievable?). In France such a catalogue was already elaborated but it is hard to implement and use as regard
to the very different concrete situations.
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It is not clear what this recommendation would require MS to do. We are not able to estimate costs.
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See previous
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RO
there is no experience on this issue.
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Again, no direct change in cost, but could increase cost-effectivenes of action planning.
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SEG 2 Information Request Responses
Table 47: SEG 2 – Information Request Responses
MS Member State Comments
Option 2(a): Change in Art 23.1 “air quality plans are established for those zones and agglomerations” into “air quality plans are established”.
BE
Actions are based on the locations in exceedance and are focused on the relevant sources that are the main cause of the exceedences. They usually do not
correspond with a whole zone. Some actions will only have an impact in some parts of a zone. Other actions will have an impact on the air quality in the whole zone
(and even outside the zone). The relations between air quality plans and zones is thus not always straightforward
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The problem originates from the topic written in point 1: “zones… are very diverse in size and population”. We suggest to start with unification of the idea of zones to
make them comparable across all member states and continue with the concept of the AQ plans.
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Yes; however, all relevant sources whether inside or outside of the zone or agglomeration are taken into account
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FI
The air quality plan for the Helsinki Metropolitan Area (HSY) consists of 4 separate municipal plans (Helsinki, Vantaa, Espoo, Kauniainen) and a framework plan for
the whole area which is by definition, an agglomeration. The plan for the city of Helsinki is most detailed because limit value exceedances have been observed there.
The regional plan for the whole agglomeration is necessary because the public transport is organized in close co-operation with neighbouring cities. Traffic planning
and infrastructure projects are also to a large extent overarching the whole region. Apart from the Helsinki Metropolitan Area the zone consept has very little
relevance with air quality plans.
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If an exceedance is reported in a zone, a thorough study is done in order to estimate the real surface and population impacted by the exceedance. This study consists
in the first step in the elaboration of the air quality plan which defines the "perimeter" of the exceedance and therefore the "area of application" of the plan. In addition,
a study of emission sources (both stationnary and mobile) linked to this exceedance is also done and municipalities concerned by one or several major sources are
involved in the air quality plan.
In conclusion, the proposed change of formulation in article 23.1 does not affect the work which is already done.
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The link between zones and plans should be kept flexible, there are pros and cons to the linkages. Assessment and management are clearly linked to enable
progress to be tracked, therefore disagree with above reasoning - there are reasons for linking zones to plans..We do not think that this would have any cost
implications for the UK but are not clear what costs current or future activities would relate to so can't provide any data. A major negative regarding zones is
communicating the scale of the exceedence problem (the whole area does not exceed but is labelled as such). It is important to link administrative areas to zone
boundaries to be able to implement action at the appropriate levels. Responsibilities for action and development and implementation of appropriate action will differ
depending on the exceedence situation and pollutant in question.
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Not yet. They were related to administrative regions (20) and the region of the city of Zagreb. In addition, plans are made for agglomeration areas. Zones (5) are
made of two or more administrative regions, depending on similarities and other dominating characteristics. In this way air quality plans could be combined to
complete one for the zone(s). We support the proposed change of wording.
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HU
Territory of zones are not the same as the purview of the local environmental agencies. Zone distribution in Hungary is very special: there are some areas with higher
air pollution designated, one agglomeration and there is the greatest zone called 'other territory of the country' with relatively low air pollution. Air quality plans are
prepared by the 10 local environmental agencies. (Moreover environmental plans prepared by local governments contain air quality parts.) Agencies usually have
more than one air quality zone withing their areas, and consequently within their plans and programs (find them at
http://www.kvvm.gov.hu/index.php?pid=9&sid=47&hid=1078 and http://www.kvvm.hu/index.php?pid=1&sid=1&hid=2029). These programs are complemented by
nation-wide measures such as the intersectoral PM10 abatement program of 2011 (http://jogszabalykereso.mhk.hu/cgi_bin/njt_doc.cgi?docid=140874.569529).
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The air quality plans will be established in those areas where limit values are exceeded. The area could be a part of agglomeration or a part of zone
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No, action plans are developed by local or regional authorities and cover only areas with exceedences, rather than the zone as a whole. We do not have any
information available on the costs of action planning by Local and Regional Authorities.
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Option 2(b): If Annex XV(A) is retained in the revision, change the tem “zone” into “surrounding area”. If Annex XV is not kept , no change is needed.
BE
Actions are based on the locations in exceedance and are focused on the relevant sources that are the main cause of the exceedences. They usually do not
correspond with a whole zone. Some actions will only have an impact in some parts of a zone. Other actions will have an impact on the air quality in the whole zone
(and even outside the zone). The relations between air quality plans and zones is thus not always straightforward
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The problem originates from the topic written in point 1: “zones… are very diverse in size and population”. We suggest to start with unification of the idea of zones to
make them comparable across all member states and continue with the concept of the AQ plans.
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To our view the information required by Annex XV would have to be reported in any case - be it on the current zones or on new administrative areas to be used for
AQ assessment.
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FI
The air quality plan for the Helsinki Metropolitan Area (HSY) consists of 4 separate municipal plans (Helsinki, Vantaa, Espoo, Kauniainen) and a framework plan for
the whole area which is by definition, an agglomeration. The plan for the city of Helsinki is most detailed because limit value exceedances have been observed there.
The regional plan for the whole agglomeration is necessary because the public transport is organized in close co-operation with neighbouring cities. Traffic planning
and infrastructure projects are also to a large extent overarching the whole region. Apart from the Helsinki Metropolitan Area the zone consept has very little
relevance with air quality plans.
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If an exceedance is reported in a zone, a thorough study is done in order to estimate the real surface and population impacted by the exceedance. This study consists
in the first step in the elaboration of the air quality plan which defines the "perimeter" of the exceedance and therefore the "area of application" of the plan. In addition,
a study of emission sources (both stationnary and mobile) linked to this exceedance is also done and municipalities concerned by one or several major sources are
involved in the air quality plan.
In conclusion, the proposed change of formulation in article 23.1 does not affect the work which is already done.
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GB As before the link should be kept flexible and there are some good reasons to link assessment and air quality management to enable progress to be tracked. We do
not think that this would have any direct cost implications.
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Not yet. They were related to administrative regions (20) and the region of the city of Zagreb. In addition, plans are made for agglomeration areas. Zones (5) are
made of two or more administrative regions, depending on similarities and other dominating characteristics. In this way air quality plans could be combined to
complete one for the zone(s). We support the proposed change of wording.
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HU
-
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LT
-
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RO
the air quality plans will be established in those areas where limit values are exceeded. The area could be a part of agglomeration or a part of zone
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No, action plans are developed by local or regional authorities and cover only areas with exceedences, rather than the zone as a whole. We do not have any
information available on the costs of action planning by Local and Regional Authorities.
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12.1.3 SEG 4 Information Request Responses
Table 48: SEG 4 – Information Request Responses
MS Member State Comments
Option 4(a): Further reduction of the assessment requirements for pollutants with low levels (e.g. SO2, lead, benzene, CO), either by modifying the assessment
thresholds, or by modifying the data quality objectives for different assessment methods.
BE
There is currently no reduction in assessment for pollutants
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CZ
The CHMI reduces the number of monitoring sites (particularly for SO2, CO, monitoring of lead is connected to other HM). We cannot estimate the change in cost, it
depends on the modification of the requirements.
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DE
Our assessment follows the provisions given in the Directive. Where possible we use objective estimates respecting the LAT. Therefore we don't see any further
relaxation from the modifications mentioned.
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FI
PM10 (daily) and NO2 (annual) are the only pollutants exceeding the limit values. Long term objectives for ozone and the target values for HM and BaP have also not
been met at all zones. The Air Quality Act requires the minimum number of monitoring stations to be established in each zone. Modelling is not used in annual
compliance checking and therefore the minimum number cannot be further reduced. However, in the northern part of Finland the number of stations is not always
sufficient. In central and southern parts of the country there are more stations than the minimum required. All assessment results are reported to the Meteorological
Institute and the MoE. Reporting to the EU is relaxed so that we try to meet the minimum criteria of the Directives.
CC1
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FR
For pollutants for which standards are largely met, the provisions of the directives are strictly applied as they do not imply a large number of monitoring stations.
Indeed, for a few pollutants (SO2, Pb, benzene, CO, …), the concentrations are lower than the lower assessement thresholds which do not involve a required number
of monitoring sites (but objective estimation and/or modelling). To our point of view, there is no need to reduce the assessement thresholds but we must think about a
european requirement about a minimum network for these pollutants (must we keep at least one monitoring site per region/per zone, etc. ?).
We propose instead to think about a european requirement about a minimum network for these pollutants.
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GB
Important to reflect improvements being made and to provide scope to address pollutants of growing concern whilst managing costs and adminstrative burdens.
Provisions within the current directive already provide flexibility to reduce assessment effort where concentrations are very low but could be taken further. We are
not able to provide an estimate of costs for this option without knowing what the proposed change is.
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Regular annual reporting and assessment is made for all pollutants covered by regulation regardless their levels. Nevertheless, development of monitoring is made in
such a way that pollutants with very low levels are not measured anymore (SO2, CO, lead). Plan is to use either indicative measurements or model outputs.
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HU
So far there was no change but it would have a sense. Eventhough they cannot be stop entirely - they may cause problems at a later stage. I have to mention the
example of SO2 and local biomass heating. While SO2 concentrations were far under limit values after a shift in residential heating from gas to biomass caused an
increase in ambient concentrations. Altough they are still under limit values now we have to have an eye on them.
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In your Member State, is assessment and reporting relaxed for those standards that are largely met? Yes
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Where levels of air pollutants are low the requirement is merely to use objective estimation, which is hardly a burden on member states. This system with assessment
thresholds is adequate and should not be altered. Using this approach, assessment of pollutants with low concentrations has been relaxed, even if some
measurements are kept voluntarily in order to continue time-series trends. An important consideration with regard to this recommendation should be whether levels
are also low in relation to WHO's air quality guidelines. E.g. for SO2, levels are above the guideline values in a number of places withtin the EU. It is thus much more
appropriate to lower the limit values rather than remove assessment requirements for this pollution. Should WHO guideline values not be exceeded anywhere in the
EU, the relevance of a limit value and assessment requirements then becomes a more relevant discussion.
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Option 4(b): Withdraw assessment requirements for pollutants and zones where no exceedances have been observed over a long period.
BE
There is currently no reduction in assessment for pollutants
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CZ
The improvement of the AQ models must precede such decision. We have to keep the ability to correctly assess the AQ levels also in “clean”regions.
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DE
The required information is included in our routine AQ assessment by modelling. Therefore in general assessment requires no additional effort where concentrations
are below the LAT.
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FI
Reducing the reporting could be considered especially if and when the new Implementing Provision - with extrermely detailed information on equipment and QA/QC -
is put into use.
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FR
For pollutants for which standards are largely met, the provisions of the directives are strictly applied as they do not imply a large number of monitoring stations.
Indeed, for a few pollutants (SO2, Pb, benzene, CO, …), the concentrations are lower than the lower assessement thresholds wh ich do not involve a required number
of monitoring sites (but objective estimation and/or modelling). To our point of view, there is no need to reduce the assessement thresholds but we must think about a
european requirement about a minimum network for these pollutants (must we keep at least one monitoring site per region/per zone, etc. ?).
CC1
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GB
Important to reflect improvements being made and to provide scope to address pollutants of growing concern whilst managing costs and adminstrative burdens.
Provisions within the current directive already provide flexibility to reduce assessment effort where concentrations are very low but could be taken further. We are
not able to provide an estimate of costs for this option without knowing what the proposed change is.
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Criteria have to be defined, both in terms of measurement obligations and assessment requirements.
Number of measurements might decrease, decreasing the total cost of measurement programme. It is hypothetical, so exact costs are not known yet
Cutting of measurement programme will be reflected in operation and maintenance costs. It is hypothetical, so exact costs are not known yet
These costs will be somewhat reduced. Nevertheless, these parameters would have to be addressed in some way through reporting (either through modelling results
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or indicative measurements).
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HU
-
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LT
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RO
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SE
This would remove the need to carry out objective estimations, but this does not involve significant costs, since it can be reasonably achieved for pollutants with very
low concentrations by carrying out a qualitative assessment using previous assessment data.
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12.1.4 SEG 5 Information Request Responses
Table 49: SEG 5 – Information Request Responses
MS Member State Comments
Option 5(a): Guidance on the necessity to prepare action plans in relation to exceedance of alert thresholds and on short term action plans for ozone already
exists. Dissemination could be intensified or the Guidance on AQ plans and short term action plans developed in 2009 could be disseminated. Note that the
guidance does not related to the risk of exceedance of limit or target values.
BE
Different air quality models (both deterministic and neural network) are used to forecast the risk of exceedences of the EU information/alert thresholds for ozone and
the Belgian alert threshold for PM10. When an exceendance of the PM10 alert threshold is forecasted (for two consecutive days), the short term action plans enter
into force (e.g. 90 km/h on highways in the three regions, free public transport and temporarely reductions of industrial emissions in some hotspots in the Walloon
region, ...). More information on the short term action plans in BE (and the other MS) can be found at the CIRCABC website :
https://circabc.europa.eu/faces/jsp/extension/wai/navigation/container.jsp : Here you can find the answers of different MS, including BE on a questinnaire concerning
short term action plans
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CZ
In Czech Republic there has not been exceedance of alert thresholds for SO2 and NO2 lately (since winter 1996/1997). But we have set new alert thresholds also for
PM10. Based on the maps of PM10 annual average concentrations and PM10 daily limit value exceedance number, probability of smog alert thresholds violation is
estimated by the statistical approach in regular 1x1 km network over the whole Czech Republic territory. Regions-in-risk where operation of smog warning system
might be meaningful were marked using these maps. In the next step, particle pollution sources located in these regions or their near surrounding were selected from
the emission database. Using a simplified Gaussian dispersion model, a contribution of selected sources to the PM10 concentration level in potential smog regions
was estimated. Sources with the significant contribution to the human exposure to PM10 in their vicinity were put into group of sources obliged to apply regulation
measures during the smog episodes. Air pollution level is not directly predicted in Czech Republic because the performance of the present forecasting
methods/models is not satisfactory. Correlation studies of the meteorological conditions and air quality were provided and the typical situations leading to high
pollution episodes in particular regions were selected. Forecasting of the air pollution episodes occurrence probability is based on the meteorological forecast solely,
issuing of signals is strictly conditioned by the monitored limit violation. Only a signal repeal based on the meteorological forecast is allowed.
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DE
From our assessment we decided that short term action plans are currently not applicable. Therefore we don't see any need for guidance on the risk of exceedance.
Performing an assessment of the risk of exceedance would mean extra work.
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FI
The 'risk' is not determined. It has been outlined that the risk has to be evaluated on a case-by-case basis. Assessment thresholds of the Directives are not
considered to be suitaile for risk evaluation. Any fixed percentage of the limit value is equally bad for such evalution because the emission sources vary and because
some pollutants are quite stabile and others fluctuate considerably.
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FR
Work on this complex topic is in progress. This issue is addressed in a spatial context. Currently, maps of daily maximum (O3) and daily average concentrations
(PM10) are produced both in diagnostic mode (by combining measured concentrations and deterministic model simulations of the previous day) and in forecasting
mode (combining statistical forecasts at the monitoring stations and deterministic model forecasts for the next days). They are then compared to the relevant
information and alert threshold. Ongoing investigations aim at introducing the concept of probability of exceedance. Such developments have already been carried
out for exceedances of PM10 and NO2 limit values on an annual scale.The objective was to delimit areas where the probability of exceeding a given value (annual
limit value, maximum number of daily exceedances in a year) is above a certain threshold (adjusted from validation tests). This probability is calculated in the
probabilistic framework of geostatistics using spatial estimates based on observation data and numerical model simulations and taking the uncertainty of those maps
(error variance) into account. Those developments will be readjusted on a short term basis to better identify the areas where the information and alert thresholds are
likely to be exceeded. Difficulties relate to the higher variability of data on this short time scale and to the necessity of better including the different sources of
uncertainty.
No change is costs but it depends on the SU clarification of the definition of ‘risk’
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GB
We think that the most important element of short term action plans are those concerning public information. It is not clear what this recommendation would require
MS to do. We are not able to estimate costs.
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HR
The risk of exceedence of the alert thresholds has not been addressed as a consequence of the fact that no alert thresholds have been exceeded in Croatia in a later
years. Nevertheless, there were cases in the past when the alert thresholds have been exceeded (city of Sisak) and are quality measurements have been used as a
basis for the risk assessment.
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HU
In Hungary the following circumstances make the preparation of a short term action plan compulsory: (1) every town with more than 200 000 inhabitants, (2) every
city in which the concentration of any air pollutant is higher than (2a) the long term health related limit value or (2b) the short term (60 minutes, 24 hours) limit values
on two monitoring sites in more than 30% of the measures, (3) every city where there is a risk of exceedance of the alert threshold. (Annex II of the Governmental
Decree 306/2010. (XII.23.) on the protection of air) Last one (risk of exceedance) has no proper definition. I have to add that from 2008 on there are information and
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alert thresholds for PM10 in the Hungarian legislation. These are the only thresolds which made smog alert plans implemented. There were no cases of SO2 or NO2
threshold exceedances. Today around 15 Hungarian cities have their smog alert plan.
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LT
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there is no assessment on this issue.
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SE
Risk of exceedence is not determined in a standardised manner in Sweden. We do not have any specific short term action plans, but there are however some short
term measures implemented in some cities to reduce PM10 concentrations during Spring. Meteorology has a major impact here and prognoses are carried out for the
following day to indicate whether there is a risk of exceeding the daily limit value.
These prognoses are carried out individually by some authorities. Baseline costs for this are probably very low, once the method has been developed, but we do not
have any information on these costs.
But could increase cost-effectiveness of action planning.
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Option 5(b): Develop new guidance in collaboration with e.g. WG on Implementation.
BE
Different air quality models (both deterministic and neural network) are used to forecast the risk of exceedences of the EU information/alert thresholds for ozone and
the Belgian alert threshold for PM10. When an exceendance of the PM10 alert threshold is forecasted (for two consecutive days), the short term action plans enter
into force (e.g. 90 km/h on highways in the three regions, free public transport and temporarely reductions of industrial emissions in some hotspots in the Walloon
region, ...). More information on the short term action plans in BE (and the other MS) can be found at the CIRCABC website :
https://circabc.europa.eu/faces/jsp/extension/wai/navigation/container.jsp : Here you can find the answers of different MS, including BE on a questinnaire concerning
short term action plans
CC1
Equip & Facilities
CC2
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CC3
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CC4
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CC5
Staff Time
CC6
Capacity Dev
CZ
In Czech Republic there has not been exceedance of alert thresholds for SO2 and NO2 lately (since winter 1996/1997). But we have set new alert thresholds also for
PM10. Based on the maps of PM10 annual average concentrations and PM10 daily limit value exceedance number, probability of smog alert thresholds violation is
estimated by the statistical approach in regular 1x1 km network over the whole Czech Republic territory. Regions-in-risk where operation of smog warning system
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might be meaningful were marked using these maps. In the next step, particle pollution sources located in these regions or their near surrounding were selected from
the emission database. Using a simplified Gaussian dispersion model, a contribution of selected sources to the PM10 concentration level in potential smog regions
was estimated. Sources with the significant contribution to the human exposure to PM10 in their vicinity were put into group of sources obliged to apply regulation
measures during the smog episodes. Air pollution level is not directly predicted in Czech Republic because the performance of the present forecasting
methods/models is not satisfactory. Correlation studies of the meteorological conditions and air quality were provided and the typical situations leading to high
pollution episodes in particular regions were selected. Forecasting of the air pollution episodes occurrence probability is based on the meteorological forecast solely,
issuing of signals is strictly conditioned by the monitored limit violation. Only a signal repeal based on the meteorological forecast is allowed.
CC1
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DE
We don't see any additional implication for MS cmp. to Option 5a
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FI
The 'risk' is not determined. It has been outlined that the risk has to be evaluated on a case-by-case basis. Assessment thresholds of the Directives are not
considered to be suitaile for risk evaluation. Any fixed percentage of the limit value is equally bad for such evalution because the emission sources vary and because
some pollutants are quite stabile and others fluctuate considerably.
See option 5(a) and option 1 (b,c,d).
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FR
Work on this complex topic is in progress. This issue is addressed in a spatial context. Currently, maps of daily maximum (O3) and daily average concentrations
(PM10) are produced both in diagnostic mode (by combining measured concentrations and deterministic model simulations of the previous day) and in forecasting
mode (combining statistical forecasts at the monitoring stations and deterministic model forecasts for the next days). They are then compared to the relevant
information and alert threshold. Ongoing investigations aim at introducing the concept of probability of exceedance. Such developments have already been carried
out for exceedances of PM10 and NO2 limit values on an annual scale.The objective was to delimit areas where the probability of exceeding a given value (annual
limit value, maximum number of daily exceedances in a year) is above a certain threshold (adjusted from validation tests). This probability is calculated in the
probabilistic framework of geostatistics using spatial estimates based on observation data and numerical model simulations and taking the uncertainty of those maps
(error variance) into account. Those developments will be readjusted on a short term basis to better identify the areas where the information and alert thresholds are
likely to be exceeded. Difficulties relate to the higher variability of data on this short time scale and to the necessity of better including the different sources of
uncertainty.
No change is costs but it depends on the SU clarification of the definition of ‘risk’
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GB
We think that the most important element of short term action plans are those concerning public information. It is not clear what this recommendation would require
MS to do. We are not able to estimate costs.
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HR
In order to determine whether a risk exists if there are no measurements or measurements do not reflect factual situation one should utilise assessment and
modelling tools that take into account local and regional sources of air pollutants. In case that measurement show that there is no exceedence of alert thresholds
assessment of risk is not necessary.
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HU
-
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LT
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RO
there is no assessment on this issue.
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SE
But could increase cost-effectiveness of action planning.
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CC4
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SEG 7 Information Request Responses
Table 50: SEG 7 – Information Request Responses
MS Member State Comments
Option 7(a): Withdraw the SO2 and/or NO2 Alert Threshold
BE
Yes. See 5a + Flanders uses more stringent alert tresholds for SO2 and NO2. When these thresholds are exceeded, industry is obligated to temporarely reduce SO2
and NOx emissions. The Flemish alert thresholds however were not exceeded anymore the last decade. A coordinating protocol harmonizes the short term actions in
the 3 Belgian regions.
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CZ
See comment in option 5(a). 7a - We support this decision. The smog warning system does not have any cost. There can be some changes in the operation of
measurement stations.
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CC4
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CC5
Staff Time
CC6
Capacity Dev
DE
These values are not exceeded in Germany.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
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CC5
Staff Time
CC6
Capacity Dev
FI
The City of Helsinki and the Helsinki Metropolitan Area have a short term action plan that coveres NO2, PM10, PM2,5 (mainly transboundary episodes), O3 and
sudden smoke episodes (transboundary). Information and alert thresholds for ozone and the alert threshold for NO2 are incorporated in the plans. Alert thresholds
have never been exceeded and the plans have only limited effects on air quality. PM10 is an exception. According to the plan road maintenance authority is
requested to start dust binding measures if the daily concentration exceeds 50 ug/m3. In this case the 'risk' means that the 50 ug/m3 concentration has been
exceeded and the weather forecast for the following day indicates that the weather situation is not changed and that road dust episode can be expected to continue.
The measures have reduced exceedance days but measures cannot be taken if the temperature is below - 5 °C.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
FR
In every county (french "départements"), a short term action plan is set by the local State authority, no matter the risks of exceedance. These plans define the
procedure, information, recommandation and measures that will be automatically implemented in case of exceedance of the information-recommandation threshold
and the alert threshold for NO2, SO2, O3 and PM10. A national review of these plans is being led at the moment. It mostly aims at harmonizing them at a national
scale, allowing them to use models in order to anticipate exceedances and allowing them to better deal with pollution episodes at a scale that is larger than the
administrative limits of the "départements". When the risk of exceedance is too high or when the short term action plans are implemented too often, an air quality
plan (ie longer term plan) is prepared.
90
Review of: Provisions for Air Quality Measurement, Air Quality Modelling, Management Framework, Assessment, and Public
Information; and Stakeholder Consultation Support
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
GB
These thresholds are very very rarely exceeded and therefore are not currenlty driving action. Withdrawal may be a sensible action. The most important element of
short term action plans are those concerning public information. There would be little or no cost implication of this recommendation.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
HR
Yes. It has been prepared as a response to factual situation based on air quality measurements.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
HU
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
LT
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
RO
not yet according to the provisions of new framework directive
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
SE
No, exceedences of these alert thresholds are highly unlikely in Sweden and we do not, therefore, consider short term action plans to be necessary here. Should
there be exceedences of this value at a location in the EU, I would argue that these values are highly relevant and should not be removed.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
Option 7(b): Provide guidance and good practice examples (see the recommendations in the recent AEAT report on short term action plans). Note that guidance
on the necessity to prepare action plans in relation to exceedance of alert thresholds and on short term action plans for ozone already exists.
BE
Yes. See 5a + Flanders uses more stringent alert thresholds for SO2 and NO2. When these thresholds are exceeded, industry is obligated to temporarily reduce SO2
and NOx emissions. The Flemish alert thresholds however were not exceeded anymore the last decade. A coordinating protocol harmonizes the short term actions in
the 3 Belgian regions.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
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Review of: Provisions for Air Quality Measurement, Air Quality Modelling, Management Framework,
Assessment, and Public Information; and Stakeholder Consultation Support
CZ
See comment in option 5(a). 7a - We support this decision. The smog warning system does not have any cost. There can be some changes in the operation of
measurement stations.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
DE
-
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
FI
The City of Helsinki and the Helsinki Metropolitan Area have a short term action plan that coveres NO2, PM10, PM2,5 (mainly transboundary episodes), O3 and
sudden smoke episodes (transboundary). Information and alert thresholds for ozone and the alert threshold for NO2 are incorporated in the plans. Alert thresholds
have never been exceeded and the plans have only limited effects on air quality. PM10 is an exception. According to the plan road maintenance authority is
requested to start dust binding measures if the daily concentration exceeds 50 ug/m3. In this case the 'risk' means that the 50 ug/m3 concentration has been
exceeded and the weather forecast for the following day indicates that the weather situation is not changed and that road dust episode can be expected to continue.
The measures have reduced exceedance days but measures cannot be taken if the temperature is below - 5 °C.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
FR
In every county (french "départements"), a short term action plan is set by the local State authority, no matter the risks of exceedance. These plans define the
procedure, information, recommandation and measures that will be automatically implemented in case of exceedance of the information-recommandation threshold
and the alert threshold for NO2, SO2, O3 and PM10. A national review of these plans is being led at the moment. It mostly aims at harmonizing them at a national
scale, allowing them to use models in order to anticipate exceedances and allowing them to better deal with pollution episodes at a scale that is larger than the
administrative limits of the "départements". When the risk of exceedance is too high or when the short term action plans are implemented too often, an air quality
plan (ie longer term plan) is prepared.
No change is costs but it can depend on the content of the guidance.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
GB
Not clear that this recommendation would be effective. There is no evidence that short term action is effective and the main issue remains public information. Not
clear what changes (if any) this recommendation would introduce so cannot provide costs.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
HR
Yes. It has been prepared as a response to factual situation based on air quality measurements.
CC1 CC2 CC3 CC4 CC5 CC6
92
Review of: Provisions for Air Quality Measurement, Air Quality Modelling, Management Framework, Assessment, and Public
Information; and Stakeholder Consultation Support
Equip & Facilities Ops & Maintenance Data Gen & Compil Report & Admin Staff Time Capacity Dev
HU
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
LT
-
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
RO
not yet according to the provisions of new framework directive
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
SE
We would welcome guidance focused on exceedences of the daily and hourly limit values for PM10 and NO2, respectively. This could increase cost-effectiveness of
action planning.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
93
Review of: Provisions for Air Quality Measurement, Air Quality Modelling, Management Framework,
Assessment, and Public Information; and Stakeholder Consultation Support
SEG 8/9 Information Request Responses
Table 51: SEG 8/9 – Information Request Responses
MS Member State Comments
Option 8&9(a): Include a provision requiring consideration of other policies in AQ plans and/or national programmes.
BE
Not enough since they are sometimes established by different administrations. The responsible authorities or ministers for these administrations are in most cases
also different.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
CZ
Not so much yet. We are preparing MEDIUM-TERM AIR PROTECTION STRATEGY FOR THE CZECH REPUBLIC, where we will consider synergies and
antagonisms with climate change policy.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
DE
Synergies and trade-offs from climate measures are already considered in our AQ plans, e.g. increased wood combustion.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
FI
With a limited experience on air quality plans, the answer is that planners obviously have to take synergies and antagonisms into account but they are not specifically
addressed in the plan itself.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
FR
The synergies and antagonisms are largely considered as new plans promoting synergetic measures in energy, climate and air quality were prepared since 2010 in
each region (les 'schémas régionaux climat-air-énergie'). In these plans in particular, sensible zones were defined where measures in favor of climate and energy
must not affect the air quality. Those are zones in which air quality should be improved (limit values have been exceeded or are likely to be exceeded) and which are
more particularly sensitive to poor air quality because of the presence of population or ecosystems. At the national level, the air quality unit was included in 2008 in
the General Directorate of Energy and Climate and works in synergy with the department in charge of climate change. But there are still efforts to make to combine
win-win strategies concerning climate (especially biomass issue, which is increasing) and air quality.
In conclusion, an important effort is already made (therefore a new provision in the directive encouraging this kind of promotion would be neutral) but the real effective
solution would be to consider the impact on the air quality of the other policies, in the other directives; and especially in the european policies dealing with climate
change and renewable energy sources
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
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Review of: Provisions for Air Quality Measurement, Air Quality Modelling, Management Framework, Assessment, and Public
Information; and Stakeholder Consultation Support
GB
Synergies and antagonisms are already included in planning and development of measures. No cost information is available for this. The enforcement of a
standardised method is not supported and could place a large burden on MS.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
HR
There is awareness that antagonisms exist in some areas/sectors, but they have not been addressed yet in a synergic manner.
In order to address the synergies more reporting and guidelines for reporting will be needed. It will introduce additional costs. Additional time/staff will be needed to
address this topic. It needs further analysis to calculate costs. Staff capacity development will be needed too to address the issue of synergies.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
HU
Obviously there are synergies and antagonisms. Any guidance or workshop can help to clarify them. There is a general aim in governance/administration to
implement environmental measures through other legal/sectoral instruments. In practice it is not entirely fulfilled, hard to follow and check.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
LT
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
RO
Not yet. It will be taken into consideration
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
SE
Not in any standardised manner. Is down to the Local and Regional Authorities to take this into consideration.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
Option 8&9(b): Workshops for exchanging best practices.
BE
Not enough since they are sometimes established by different administrations. The responsible authorities or ministers for these administrations are in most cases
also different.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
CZ Not so much yet. We are preparing MEDIUM-TERM AIR PROTECTION STRATEGY FOR THE CZECH REPUBLIC, where we will consider synergies and
antagonisms with climate change policy.
95
Review of: Provisions for Air Quality Measurement, Air Quality Modelling, Management Framework,
Assessment, and Public Information; and Stakeholder Consultation Support
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
DE
-
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
FI
Workshops are ok. Air quality plans should not be expanded with descriptive chapters on synertgies and antagonisms althouygh they are part of the decision making
process.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
FR
The synergies and antagonisms are largely considered as new plans promoting synergetic measures in energy, climate and air quality were prepared since 2010 in
each region (les 'schémas régionaux climat-air-énergie'). In these plans in particular, sensible zones were defined where measures in favor of climate and energy
must not affect the air quality. At the national level, the air quality unit was included in 2008 in the General Directorate of Energy and Climate nd works in synergy
with the department in charge of climate change. But there are still efforts to make to combine win-win strategies concerning climate (especially biomass issue, which
is increasing) and air quality.
Workshops for exchanging best practices could be useful (a few were already organised) but it does not affect the cost of the air quality plans.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
GB
Synergies and antagonisms are already included in planning and development of measures. No cost information is available for this. The enforcement of a
standardised method is not supported and could place a large burden on MS.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
HR
There is a need for capacity building in this area.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
HU
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
LT
-
CC1 CC2 CC3 CC4 CC5 CC6
96
Review of: Provisions for Air Quality Measurement, Air Quality Modelling, Management Framework, Assessment, and Public
Information; and Stakeholder Consultation Support
Equip & Facilities Ops & Maintenance Data Gen & Compil Report & Admin Staff Time Capacity Dev
RO
Not yet. It will be taken into consideration
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
SE
But could increase cost-effectiveness of action planning.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
Option 8&9(c): Provision of guidance documents.
BE
Not enough since they are sometimes established by different administrations. The responsible authorities or ministers for these administrations are in most cases
also different.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
CZ
Not so much yet. We are preparing MEDIUM-TERM AIR PROTECTION STRATEGY FOR THE CZECH REPUBLIC, where we will consider synergies and
antagonisms with climate change policy.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
DE
-
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
FI
-
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
FR
The synergies and antagonisms are largely considered as new plans promoting synergetic measures in energy, climate and air quality were prepared since 2010 in
each region (les 'schémas régionaux climat-air-énergie'). In these plans in particular, sensible zones were defined where measures in favor of climate and energy
must not affect the air quality. At the national level, the air quality unit was included in 2008 in the General Directorate of Energy and Climate nd works in synergy
with the department in charge of climate change. But there are still efforts to make to combine win-win strategies concerning climate (especially biomass issue, which
is increasing) and air quality.
Guidance documents as workshops (previous worksheet) could be useful but it does not affect the cost of the air quality plans.
97
Review of: Provisions for Air Quality Measurement, Air Quality Modelling, Management Framework,
Assessment, and Public Information; and Stakeholder Consultation Support
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
GB
Synergies and antagonisms are already included in planning and development of measures. No cost information is available for this. The enforcement of a
standardised method is not supported and could place a large burden on MS.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
HR
-
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
HU
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
LT
-
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
RO
Not yet. It will be taken into consideration
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
SE
But could increase cost-effectiveness of action planning.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
98
Review of: Provisions for Air Quality Measurement, Air Quality Modelling, Management Framework, Assessment, and Public
Information; and Stakeholder Consultation Support
SEG 10 Information Request Responses
Table 52: SEG 10 – Information Request Responses
MS Member State Comments
Option 10(a): Promote in guidance to Member States that local air quality plans are merged into overarching air quality plans at the regional or national level (as
in the Netherlands).
BE
An aggregate of local air quality plans.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
CZ
In CZ we have a national plan and also air quality plans for zones and agglomerations and they are interconnected.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
DE
Currently national and regional plans are developed separately. However national plans are not available for all pollutants where exceedances occur. There is no
compilation of local plans as we consider this of no added value as detailed information would be lost.
Reporting of additional national plans would be required.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
FI
National air quality plan has not been considered necessary because EU limit values are largely met and source based measures can reduce emissions of major air
pollutants. The only air quality plan we have is a combination of local plans and a regional plan.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
FR
In France, there are different levels of air quality plans: the national level ('plan particules' for example), the regional level ('schémas régionaux climat-air-énergie') and
the local level ('plans de protection de l'atmosphère') in order to answer the directive provisions and to achieve the limit or target values. Such plans may be merged
in an overarching national or regional air quality plan as proposed but it depends on the pollutants. Indeed, it can be relevant for ozone or particles (for which the
pollution is more on a high-scale and for which local measures are necessary but not necessarily sufficient). For NO2 however, measures are mainly local because of
the prevalence of the near-by sources, although national (even european...) regulation can be the most effective to target emissions from vehicles and comply with
the NO2 limit values. Furthermore, many actions must be defined, adopted and undertaken at a very local level in order to be efficient. Merging air quality plans could
result in a loss of acceptability and implementation at this level.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
99
Review of: Provisions for Air Quality Measurement, Air Quality Modelling, Management Framework,
Assessment, and Public Information; and Stakeholder Consultation Support
GB
Not clear what the recommendation would entail in practice and we do not agree that this was the approach adopted by the UK. Information from local authorities is
already collated and included in air quality pland for zones in the UK. A rough estimate of the annual costs associated with the collation of these data is £40k.
Different approaches are suitable for different pollutants depending on their sources and control options. There isnt a one size fits all approach to the development of
plans.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
HR
Within the project with Flamish Government action plans for 3 agglomeration where excedences of some pollutants occured is drafted. Those plans is separate plans
and it will not be a part of the National plan, because it need to be prepared at the county level.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
HU
In Hungary they are somehow between the two types mentioned: neither NL, nor UK like. All 10 local environmental agencies prepare their own air quality plan for
their territories. All local government of cities have to prepare environmental plans that contains air quality / air pollution part. On the top of these there are special
nation-wide programs like the intersectoral PM10 program of 2011. These programs are all different: they contain measures for different level (local for cities, regional
for the agencies and nation-wide for the last one). They effectively complement each other.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
LT
-
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
RO
In your Member State, have air quality plans been developed as single overarching regional or national plans as in the Netherlands, or as an aggregate of local air
quality plans as in the UK (or any other method)? NO
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
SE
Generally, they are local air quality plans. For the largest cities of Stockholm and Gothenburg, the action plans have, however, been developed regionally.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
100
Review of: Provisions for Air Quality Measurement, Air Quality Modelling, Management Framework, Assessment, and Public
Information; and Stakeholder Consultation Support
Option 10(b): Promote in guidance that Member States report local air quality plans as aggregate air quality plans (as in the UK).
BE
An aggregate of local air quality plans.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
CZ
In CZ we have a national plan and also air quality plans for zones and agglomerations and they are interconnected.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
DE
Currently national and regional plans are developed separately. However national plans are not available for all pollutants where exceedances occur. There is no
compilation of local plans as we consider this of no added value as detailed information would be lost.
Reporting of additional national plans would be required.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
Capacity Dev
FI
National air quality plan has not been considered necessary because EU limit values are largely met and source based measures can reduce emissions of major air
pollutants. The only air quality plan we have is a combination of local plans and a regional plan.
CC1
Equip & Facilities
CC2
Ops & Maintenance
CC3
Data Gen & Compil
CC4
Report & Admin
CC5
Staff Time
CC6
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FR
In France, there are different levels of air quality plans: the national level ('plan particules' for example), the regional level ('schémas régionaux climat-air-énergie') and
the local level ('plans de protection de l'atmosphère') in order to answer the directive provisions and to achieve the limit or target values. Such plans may be merged
in an overarching national or regional air quality plan as proposed but it depends on the pollutants. Indeed, it can be relevant for ozone or particles (for which the
pollution is more on a high-scale and for which local measures are necessary but not necessarily sufficient). For NO2 however, measures are mainly local because of
the prevalence of the near-by sources, although national (even european...) regulation can be the most effective to target emissions from vehicles and comply with
the NO2 limit values. Furthermore, many actions must be defined, adopted and undertaken at a very local level in order to be efficient. Merging air quality plans could
result in a loss of acceptability and implementation at this level
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Not clear what the recommendation would entail in practice and we do not agree that this was the approach adopted by the UK. Information from local authorities is
already collated and included in air quality pland for zones in the UK. A rough estimate of the annual costs associated with the collation of these data is £40k.
Different approaches are suitable for different pollutants depending on their sources and control options. There isnt a one size fits all approach to the development of
plans.
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Within the project with Flamish Government action plans for 3 agglomeration where excedences of some pollutants occured is drafted. Those plans is separate plans
and it will not be a part of the National plan, because it need to be prepared at the county level.
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Yes. The webpage of the Hungarian Air Quality Network (http://www.kvvm.hu/olm/index.php) contains real-time data with about an hour delay. For the capital,
Budapest, health authority's webpage provide data on the level of air pollution (http://oki.antsz.hu/kornyezet_egeszsegugyi_indikatorok). In case of exceedance of
information/alert thresholds public is informed according to the short term action plans (via television, radio, internet, etc.). As these plans are prepared and
implemented by the local governments (with involving relevant authorities) information is disseminated by them. Exceedance of other limit values are not highlighted
otherwise.
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n your Member State, have air quality plans been developed as single overarching regional or national plans as in the Netherlands, or as an aggregate of local air
quality plans as in the UK (other any other method)? YES, local level
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Generally, they are local air quality plans. For the largest cities of Stockholm and Gothenburg, the action plans have, however, been developed regionally.
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SEG 20 Information Request Responses
Table 53: SEG 20 – Information Request Responses
MS Member State Comments
Option 20: Add a provision requiring Member States to inform the public as soon as a Limit Value is being exceeded.
BE
Exceedances of limit values or target values are published updated on an hourly or daily basis on the website of the Belgian Interregional Environment Agency and
on the websites of the regional environmental agencies.
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Yes. CHMI already informs public in such situations. The costs are insignificant and difficult to quantify.
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All AQ are data available from the internet where there are all year long #presented in the context LV information.
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FI
Near real time data on the exceedances of daily and hourly limit values (numerical calue) can be found in the National Air Quality Portal. Local networks may have
additional information on their websites.
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The main concern of national authorities is to assure that the public is informed about the air quality levels on daily and annually basis and in case of exceedance of
an information or alert threshold (as it is well related in the 'description of the issue'). Nevertheless, for PM10, France introduced information and alert thresholds
which do not exist in the european legislation. In particular, we try to match the limit value with the information threshold which is 50 µg/m3. This recommendation
suits us quite well but it is needed to define precisely the time when a limit value is considered to be exceeded (annual or daily) because the notion of 'calendar year'
is not really optimal for public information and all the exceedances are established on the basis of a calendar year (for example for PM10 it can happens that a lot of
daily exceedences occur in january-february, even if the 35 days are not attained. Must we communicate it to the public?).
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his recommendation is not pragmatic and we do not this that this would be desirable or even possible in many instances (annual means can only be calculated with a
full year of data, some pollutants require the subtraction of natural contributions, exceedance can only be declared once data have been checked and ratified). It is
not possible to provide an estimate of costs becuase this change could not be implemented. Not clear how you would calculate baseline costs. This recommendation
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should not be considered further.
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Croatia have system for public information on exceedance or alerth treshold on the air qualuty levels daily and annually by using the 112 alert system.
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HU
We would really appreciate a harmonized air quality index. In Hungary we have two kinds of them: one prepared and used for air quality assessments (at the end of
the report: http://www.kvvm.hu/olm/docs/2011_automata_ertekeles.pdf) and one by the health authorities (http://oki.wesper.hu/files/levego/Levegominoseg_LHI.pdf).
It would be nice to have a harmonized one.
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the public is informed about exceedences of limit values as soon as they occur through daily information on AQ which are available on public sites and on public
information boards. These daily information uses quality index from 1-6 ( from excellent to very bad) associated with colours (from green to red) and they are
established taking into account the limit values for each of the pollutants:SO2, NO2, CO, O3 and PM10.
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Generally not. A limited number of local authorities do, however, present this information on their websites. This information is most-widely made available in annual
reports on air quality for the previous year.
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SEG 21/22 Information Request Responses
Table 54: SEG 21/22 – Information Request Responses
MS Member State Comments
Option 21 & 22(a): Develop a common air quality index through an EU working group and promote it in subsequent guidance to Member States.
BE
We established a Belgian AQ index. This "belATMO' air quality index is an index from 1 tot 10 (1 good, 10 very bad AQ) and is based on the based on the severity of
the European limit/target values. This index is calculated every hour based on the real-time measured concentrations of NO2, SO2, PM10 and O3 and is available at
the website of the Belgian Interregional Environment Agency and on the websites of the regional environmental agencies. Forecasts of this index are also available at
the different websites. More info : http://www.irceline.be/~celinair/english/abindex_en.html
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A lot of projects and other activities dealing with this topic were done. We use our own index and we support the unification of AQ index.
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We do not use any index as health effects from different pollutants show different health effects and affect different groups of population.
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FI
Air quality index has been designed for national purposes. Description can be found at http://www.ilmanlaatu.fi/ or directly
http://www.ilmanlaatu.fi/ilmansaasteet/indeksi/indeksi.php
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FR
A national air quality index is used in France ('Indice ATMO'), with a proper methodology of choice of the stations and a specific scale. It concerns only air quality
background situations. The development of a european common air quality index (like CITEAIR) would be interesting but it initially requires a commonly adopted strict
framework of index calculation (which must be the same from a member state to another).
No change in costs but it depends on the nature and the methodology used for this common index.
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The case for harmonisation has not been made, introducing a common index alongside MS indices may increase public confusion. The general public don't
neccessarily need to know what's happening in other countries on a daily basis to regulate their exposure. Guidance for MSs on how to develop an index and
examples of best practice might be useful. The UK has a bespoke air quality index based on the recommendations of an expert committee (COMEAP
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http://www.hpa.org.uk/webc/HPAwebFile/HPAweb_C/1317137023144). There would be a substantial cost associated with making any changes to the index. Cost
estimate for implementing a revised air quality index is £10k for the revisions that would be required to UK national air quality forecasting and information systems.
Devolved Administration, regional and local systems would also need to be revised and research would be needed in order to understand the implications of any
changes before implementation. The total cost to the MS would therefore be likely to be in the range £75k - £100k
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At the web page of the Ministry for Evniromental and Nature Protection is direct link to the web page of the State Network for Air Quality monitoring where all hourly,
daily and montrhly data are recorded (http://zrak.mzoip.hr).
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Yes. In our country we are using a set of index from 1 to 6, from bad to excelent, based on the diferent ranges of concentrations and specifically for each pollutants
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No standard air quality index is used.
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Option 21 & 22(b): Develop a common air quality index through an EU working group and include a requirement to publish a daily air quality index in air quality
legislation.
BE
We established a Belgian AQ index. This "belATMO' air quality index is an index from 1 tot 10 (1 good, 10 very bad AQ) and is based on the based on the severity of
the European limit/target values. This index is calculated every hour based on the real-time measured concentrations of NO2, SO2, PM10 and O3 and is available at
the website of the Belgian Interregional Environment Agency and on the websites of the regional environmental agencies. Forecasts of this index are also available at
the different websites. More info : http://www.irceline.be/~celinair/english/abindex_en.html
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A lot of projects and other activities dealing with this topic were done. We use our own index and we support the unification of AQ index.
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COMMON AIR QUALITY INDEX IS NOT SUPPORTED. It would propably be difficult to agree on a common index with common threshold concentrations. Such an
index - with high thresholds - could lead to a situation where rural areas and Nordic countries in general would have always good or excellent air quality. If the
thresholds were set at vere low concentration levels more polluted countries would suffer bad air quality most of the time. For general population it is more important
to have information on local air quality situation and changes in it.
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FR
A national air quality index is used in France ('Indice ATMO'), with a proper methodology of choice of the stations and a specific scale. It concerns only air quality
background situations. The development of a european common air quality index (like CITEAIR) would be interesting but it initially requires a commonly adopted
strict framework of index calculation (which must be the same from a member state to another).
No change in costs but it depends on the nature and the methodology used for this common index.
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The case for harmonisation has not been made, introducing a common index alongside MS indices may increase public confusion. The general public don't
neccessarily need to know what's happening in other countries on a daily basis to regulate their exposure. Guidance for MSs on how to develop an index and
examples of best practice might be useful. The UK has a bespoke air quality index based on the recommendations of an expert committee (COMEAP
http://www.hpa.org.uk/webc/HPAwebFile/HPAweb_C/1317137023144). There would be a substantial cost associated with making any changes to the index. Cost
estimate for implementing a revised air quality index is £10k for the revisions that would be required to UK national air quality forecasting and information systems.
Devolved Administration, regional and local systems would also need to be revised and research would be needed in order to understand the implications of any
changes before implementation. The total cost to the MS would therefore be likely to be in the range £75k - £100k
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HR At the web page of the Ministry for Evniromental and Nature Protection is direct link to the web page of the State Network for Air Quality monitoring where all hourly,
daily and montrhly data are recorded (http://zrak.mzoip.hr).
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In our country we are using a set of index from 1 to 6, from bad to excelent, based on the diferent ranges of concentrations and specifically for each pollutants
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No standard air quality index is used.
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Annex 2: SEG Consultation Survey and Results
This Annex provides a copy of the SEG Consultation Survey for information and a summary of the
SEG Consultation responses from Member States
Copy of the SEG Consultation Survey
Background
In November 2012, you received an Information Request asking for possible costs and resources
required for your Member State should the SEG recommendations be implemented. Thank you to
everyone who took the time to respond to this request.
The SEG Recommendations have not been sufficiently developed to allow for comprehensive in-
depth impact analysis however we have undertaken an expert-based high-level qualitative
assessment of the recommendations and where possible attempted to quantify any impacts on
Member States.
We would like to provide you with the opportunity to review our findings to date and comment on the
validity of the results within the context of your Member State
The following short consultation survey should take approximately 45 minutes to complete.
We appreciate your participation in this consultation.
If you have any questions on this survey please contact: Enda Hayes (enda.hayes@uwe.ac.uk)
Introduction to SEG Recommendations
A selection of SEG Recommendations are being considered for their impacts upon Member States, in
particular, impacts where there would be cost implications (either an increase or decrease).
In the following case study interview, we want to test our assumptions and assessments of the SEG
recommendation while we will also request your thoughts on the individual recommendations and how
they will impact on your Member State.
As reminder, the SEG Recommendations being considered are:
Recommendation 1: Standardise compliance projections
Recommendation 2: Do not relate air quality plans to zones
Recommendation 4: Reduce assessment / reporting for standards that are largely met
Recommendation 5: Clarify the definition of the risk of exceedence
Recommendation 7: Reduce the administrative burden regarding the development of short term
action plans
Recommendation 8: Promote the assessment of synergetic measures in air quality plans
Recommendation 9: Promote the consideration of antagonisms with other policies in the
development of AQ measures
Recommendation 10: Promote Member States developing national or regional air quality strategies
or plans
Recommendation 20: Require that the public is informed about exceedences of Limit Values as
soon as they occur
Recommendation 21 & 22: Harmonise air quality indices in the EU & Develop a Common air
quality index
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Assumptions within this Assessment
ASSUMPTION 1 - Within the context of these SEG recommendations, we have assumed that any
guidance provided is non-statutory i.e. any guidance is provided to Member States as a support tool
for them to inform their own decision making processes but Member States do not have to strictly
adhere to any guidance.
Do you agree with this assumption for your Member State? Yes / No
What role does guidance play in the application of Directive requirements in your Member State?
ASSUMPTION 2 - In the context of these SEG recommendations, we have assumed that Member
States, as part of their day-to day activities, are engaged in capability enhancement to ensure that
they are up to date with latest air quality management science and techniques.
Do you agree with this assumption for your Member State? Yes / No
Are there any additional points you with like to make about this assumption?
ASSUMPTION 3 - Based on responses from Member States in the earlier Information Request, case
study interviews and expert-based judgement we have applied the following cost categorisations to
these SEG recommendations. They are provided here for information and will be referred to
throughout this document.
Cost Description Cost Range (Euros)
High Additional Cost Burden > €60,000
Medium Additional Cost Burden € 20,000 - €60,000
Low Additional Cost Burden < € 20,000
Cost Neutral € 0
Low Cost Burden Reduction < € 20,000
Medium Cost Burden Reduction € 20,000 - €60,000
High Cost Burden Reduction > €60,000
SEG Recommendation 1: Standardise Compliance Projections
What is the problem?
In air quality plans projections of future air quality levels need to be made in order to see whether the
plans are adequate to meet the air quality standard. Member States have widely varying approaches
to this, and the credibility of the projections is not always clear, leading to an uneven playing field.
Member States are also very different in their capabilities to make projections.
What are the options?
Recommendation 1(a): Disseminate existing guidance. In 2008 guidance on air quality plans has
been updated, which includes guidance on projections. It has however not yet been disseminated
by the Commission; this can be done.
Recommendation 1(b, c & d): Provision of New Guidance, Workshops and Website. FAIRMODE
may have a major role in this.
Recommendation 1(e): Make Europe-scale projections on emissions and concentrations better
available to local authorities. The emission and concentration data may be (based on) the EMEP
and IIASA results obtained during policy preparation projects. These data could be made available
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on a website of the Commission, EEA or e.g. the GMES Atmospheric Monitoring Service. Note
that this possibility only standardises European data used in compliance projections – but this may
be the most important weakness for local authorities.
Recommendation 1(f): Harmonise or standardise modelling of compliance projections
Recommendation 1(g): Provide a catalogue of measures that (also) can be used as a benchmark
for judging the effectiveness of measures.
High-Level Impact Assessment
Scenario Description Qualitative High Level Cost Assessment Cost
Assessment
A A Member State has no
exceedences and therefore
does not have the need to
develop air quality plans and
project future air quality
concentrations.
The provision of standardised compliance projection guidance
and support tools would be useful for these Member States but
would have no cost implications.
Cost Neutral
B A Member State has an
exceedence and has already,
or is in the process of,
undertaking the development
of an air quality action plan
and projections.
It is recognised that there is variation in the approaches Member
States take to compliance projections. However, the scale of
cost burden will vary among Member States and will be depend
on how a standardised projection methodology is promoted e.g.
through guidance or through legislation.
Medium
Additional Cost
Burden
(€20 – €60k)
SEG Recommendation 1 Consultation Questions
Question 1.1: Do you feel our qualitative judgement on the implication of this SEG Recommendation
is appropriate?
Yes No
Comments:
Question 1.2: Which scenario would you place your Member State in?
Scenario A Scenario B
Question 1.3: Do you agree with our cost assessment for your chosen scenario?
Yes No
Comments:
Question 1.4: Do you have any comment on this SEG Recommendation going forward including
preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
Comments:
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SEG Recommendation 2: Do not relate air quality plans and zones
What is the problem?
There is no good reason for relating air quality plans to zones (Art. 23.1 of the AQD), which are very
diverse in size and population. Although this does not seem to be a major problem for Member
States, a change could be considered. Relevant sources may be located outside the zone where the
exceedance takes place. Furthermore, the zone concept in Annex XV(A) Information to be included
in […] AQ plans …, historically based on the zone definition in the Exchange of Information Decision
(EoI), is fundamentally different from the zone concept of the AQ Directive. In the Implementing
Decision 2011/850/EC no reference is made to zones according to the EoI concept.
What are the options?
Recommendation 2(a): Change in Art 23.1 “air quality plans are established for those zones and
agglomerations” into “air quality plans are established”.
Recommendation 2(b): If Annex XV(A) is retained in the revision, change the term “zone” into
“surrounding area”. If Annex XV is not kept, no change is needed.
High-Level Impact Assessment
Qualitative High Level Cost Assessment Cost
Assessment
Depending on the way in which any change is implemented, there may be some costs incurred
for the refinement of an air quality plan and data gathering.
Air quality plans would still have to be developed and the presence (or absence) of a link
between the air quality plan and zone would have little cost on the plans development.
Low Additional
Cost Burden
(<€20k)
SEG Recommendation 2 Questions
Question 2.1: Do you feel our qualitative judgement on the implication of this SEG Recommendation
is appropriate?
Yes No
Comments:
Question 2.2: Does your Member State currently relate its air quality plans with zones?
Yes No
Description:
Question 2.3: Do you have any comment on this SEG Recommendation going forward including
preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
Comments:
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SEG Recommendation 4: Reduce assessment reporting for standards that are largely met.
What is the problem?
The effort of assessment (especially monitoring requirements) and reporting could be reduced for
pollutants with (almost) no exceedences of environmental standards.
What are the Options?
Recommendation 4(a): Further reduction of the assessment requirements for pollutants with low
levels (e.g. SO2, lead, benzene, CO), either by modifying the assessment thresholds, or by
modifying the data quality objectives for different assessment methods.
Recommendation 4(b): Withdraw assessment requirements for pollutants and zones where no
exceedances have been observed over a long period.
High-Level Impact Assessment
Qualitative High Level Cost Assessment Cost
Assessment
We estimated that implementation of these options may achieve a saving in running costs
primarily due to the possible reduction in monitoring instrumentation (should Member States
chose to do so). However, this is dependent on each Member State.
There would be negligible reduction in staff time and maintenance due to assumption that
multiple pollutants are monitored at each site and therefore sites are not fully decommissioned.
This recommendation would need to recognise the necessity for an EU minimum network of
monitoring sites and the importance of the maintenance of data for trends.
Low Cost
Burden
Reduction
(<€20k)
SEG Recommendation 4 Questions
Question 4.1: Do you feel our qualitative judgement on the implication of this SEG Recommendation
is appropriate for your Member State?
Yes No
Comments:
Question 4.2a: Should this recommendation be implemented might your Member State consider
reducing your monitoring network?
Yes
(go to Question 4.2b and 4.2c below)
No
(go to Question 4.3)
Comments:
Question 4.3b: If ‘Yes’, approximately how much might you reduce your network for each of the
following pollutants? For information, the table below provides 2010 monitoring numbers taken from
EIONET (Airbase-V6)
Pollutant Possible Change
Benzene e.g. XX% reduction
CO e.g. no change
Pb
NO2
O3
PM10
PM2.5
PAH
SO2
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Question 4.2c: Approximately how much might this reduce your annual network costs (value and/or percentage
terms)?
Comments:
Question 4.4: Do you have any comment on this SEG Recommendation going forward including
preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
Comments:
SEG Recommendation 5: Clarify the definition of the risk of exceedence
What is the problem?
Where there is a risk that the levels of pollutants will exceed one or more of the alert thresholds,
Member States shall draw up short term action plans in order to reduce the risk or duration of such an
exceedance. Where this risk applies to one or more limit values or target values, Member States may
draw up such short-term action plans. The directive does not specify how to determine whether a risk
exists. This has been addressed in the Guidance on AQ plans and short term action plans (produced
in 2009), but it has not been disseminated yet.
What are the options?
Recommendation 5(a): Guidance on the necessity to prepare action plans in relation to
exceedance of alert thresholds and on short term action plans for ozone already exists.
Dissemination could be intensified or the Guidance on AQ plans and short term action plans
developed in 2009 could be disseminated. Note that the guidance does not relate to the risk of
exceedance of limit or target values.
Recommendation 5(b): Develop new guidance in collaboration with e.g. WG on Implementation.
High-Level Impact Assessment
Qualitative High Level Cost Assessment Cost
Assessment
The long-standing cost implications are unknown as, there is no indication as to exactly how the
risk would be redefined and therefore the impact on Member States cannot be determined. The
options require the provision of guidance and therefore the only real costs that can be assessed
are immediate capacity development costs to adapt to guidance.
Low Additional
Cost Burden
(<€20k)
SEG Recommendation 5 Questions
Question 5.1: Do you feel our qualitative judgement on the implication of this SEG Recommendation
is appropriate?
Yes No
Comments:
Question 5.2: Do you have any comment on this SEG Recommendation going forward including
preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
Comments:
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SEG Recommendation 7: Reduce the administrative burden regarding the development of
short-term action plans
What is the problem?
Where there is a risk that the levels of pollutants will exceed one or more of the alert thresholds,
Member States shall draw up short term action plans in order to reduce the risk or duration of such an
exceedance. Where this risk applies to one or more limit values or target values, Member States may
draw up such short-term action plans. The development of such plans is associated with an
administrative burden and the effectiveness of the plans is questioned in some cases.
What are the options?
Recommendation 7(a): Withdraw the SO2 and/or NO2 alert threshold
Recommendation 7(b): Provide guidance and good practice examples (see the recommendations
in the recent AEAT report on short term action plans). Note that guidance on the necessity to
prepare action plans in relation to exceedance of alert thresholds and on short term action plans
for ozone already exists.
High-Level Impact Assessment
Qualitative High Level Cost Assessment Cost
Assessment
EEA Report (2012) indicates that no Member State exceeded the NO2 or SO2 alert threshold
therefore the removal of this threshold would have no impact on Member States as they would
still need to monitor, assess and report these pollutants for other objectives.
There may be a negligible saving due to the reduction in alert data compilation and reporting
(this may happen anyway through the new systems providing real-time data to EEA)
Cost Neutral
SEG Recommendation 7 Questions
Question 7.1: Do you feel our qualitative judgement on the implication of this SEG Recommendation
is appropriate?
Yes No
Comments:
Question 7.2: Do you have any comment on this SEG Recommendation going forward including
preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
Comments:
SEG Recommendation 8: Promote the assessment of synergetic measures in air quality plans
&
SEG Recommendation 9: Promote the consideration of antagonisms with other policies in the
development of air quality measures.
What is the problem?
Measures often improve air quality and reduce the emissions of greenhouse gases as well, but there
are also antagonisms, e.g. higher energy demand by technologies for reducing emissions of air
pollution, higher CO2 emissions due to detours of traffic to reduce exceedance along a road, higher.
Therefore, measures that are synergetic with other policies should be preferred. Measures to reduce
the emissions of greenhouse gases and to improve energy efficiency most often improve air quality as
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well. However, some of these measures might lead to an increase in air pollutants. This is especially
true for biomass combustion, carbon capture and storage. In addition, climate change issues are
often of higher priority as air quality. On the other hand, measures to reduce emissions of air
pollutants may reduce energy efficiency. Therefore, antagonisms and interactions have to be
considered in policies. It doesn’t seem to be realistic to change provisions in the on-going revision of
the Monitoring Mechanism Decision 2004/280/EC. Therefore such a possibility is not included.
What are the options?
Recommendation 8&9(a): Include a provision requiring consideration of other policies in AQ plans
and/or national programmes.
Recommendation 8&9(b): Workshops for exchanging best practices.
Recommendation 8&9(c): Provision of guidance documents.
High-Level Impact Assessment
This activity is undertaken in some capacity by most Member States. The cost implications are
dependent on the interpretation of the term ‘consideration’ as this may be ‘consideration’ through
consultation and qualitative assessment or ‘consideration’ through detailed quantitative assessment of
options.
Scenario Description Qualitative High Level Cost Assessment Cost
Assessment
A ‘Consideration’ =
Inter-departmental
consultation and
qualitative
assessment
During the consideration of options all Member States
will undertake some inter-departmental consultation.
The majority of air quality measures originate from
other policy areas. The qualitative assessment of this
option may be undertaken within this consultation
process.
Cost Neutral
B ‘Consideration’ =
Detailed
Quantitative
Assessment
Detailed quantitative assessment of measures may
require input from policy and scientific staff. It is
anticipated that each measure may require an average
input of 15 person days per measure (e.g. 5 policy days
and 10 scientific days). This scenario would vary in
each Member State and may require the establishment
of minimum capacity e.g. modelling.
Low/Medium/High
additional cost
burden
dependent on
number of
measures to be
considered
SEG Recommendation 8&9 Questions
Question 8/9.1: Do you feel our qualitative judgement on the implication of this SEG
Recommendation is appropriate?
Yes No
Comments:
Question 8/9.2: In Scenario B, we have estimated an average input of 15 person-days per measure
(described as 5 policy days and 10 scientific days). Do you think that this is appropriate?
Yes No
(if not please provide alternative)
Comments:
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Question 8/9.3: Do you have any comment on this SEG Recommendation going forward including
preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
Comments:
SEG Recommendation 10: Promote MS developing national or regional air quality strategies or
plans
What is the problem?
Instead of developing individual air quality plans for each exceedance situation or for collections of
exceedance situations in the territories of separate local authorities, such plans may be merged in an
overarching national or regional air quality plan. The Netherlands merged a large number of air quality
plans into a single National Sanitation Programme that was reported as a single air quality plan to the
Commission. In the UK local air quality plans have been drafted according to the national air quality
policy strategy and for reporting these under the AQ directives DEFRA combined these to a small set
or overarching AQ plans.
What are the options?
Recommendation 10(a): Promote in guidance to Member States that local air quality plans are
merged into overarching air quality plans at the regional or national level (as in the Netherlands).
Recommendation 10(b): Promote in guidance that Member States report local air quality plans as
aggregate air quality plans (as in the UK).
High-Level Impact Assessment
Qualitative High Level Cost Assessment Cost
Assessment
The cost implication for this recommendation is dependent on guidance but as it is assumed that
guidance is non-statutory Member States is unlikely to substantially change their reporting
activities.
The provision of guidance would be helpful for new Member States and there may be low cost
implications for adaptation.
Low Additional
Cost Burden
(<€20k)
SEG Recommendation 10 Questions
Question 10.1: Do you feel our qualitative judgement on the implication of this SEG
Recommendation is appropriate?
Yes No
Comments:
Question 10.2: Do you have any comment on this SEG Recommendation going forward including
preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
Comments:
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SEG Recommendation 20: Require that the public is informed about exceedence of Limit
Values as soon as they occur.
What is the problem?
The AQD requires that the public is immediately informed on exceedance of an information or alert
threshold and on the air quality levels daily and annually. Because there is no explicit public
information requirement regarding the exceedance of limit values, this information may be not receive
due attention.
What are the options?
Recommendation 20(a): Add a provision requiring Member States to inform the public as soon as a
Limit Value is being exceeded.
High-Level Impact Assessment
Most Member States have existing public information systems on which hourly and daily exceedences
are reported. Annual Limit Values are more challenging as annual means can only be calculated with
a full year of data, some pollutants require the subtraction of natural contributions, exceedance can
only be declared once data have been checked and ratified (when this process is complete then
Member States report any exceedences).
N.B. In terms of a Limit Value, we have interpreted ‘occur’ as the time at which a Member State is
confident of the data quality and it is appropriate to report an exceedence.
Scenario Description Qualitative High Level Cost Assessment Cost Assessment
A Member State
already has reporting
processes in place
Most Member States have an online presence which
they utilise to report exceedences of Alert and
Information Thresholds as required. Additionally,
this online presence is utilised to provide general air
quality information to the public. The provision
requiring Member States to inform the public as
soon as a Limit Value is being exceeded would not
add significant cost.
Cost Neutral
(may apply to 26
out of 28 Member
States)
B Member State does
not have reporting
processes in place
If a Member State does not have a public
information system then this would have to be set
up and there would be a cost implication.
Medium Additional
Cost Burden
(may apply to 2 out
of 28 Member
States)
SEG Recommendation 20 Questions
Question 20.1: Do you feel our qualitative judgement on the implication of this SEG
Recommendation is appropriate?
Yes No
Comments:
Question 20.2: Does your Member State currently report the following to the public as soon as they
occur?
Exceedences of Alert Thresholds Yes / No Please provide weblink
Exceedences of Information Thresholds Yes / No Please provide weblink
Exceedences of Limit Values Yes / No Please provide weblink
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Question 20.3: Can you give indicative costs for the set-up and annual operation of a public
information system suitable for reporting against this recommendation?
Set-up costs Annual running costs
Question 20.4: Do you have any comments on this SEG Recommendation going forward? (e.g.
desirability, usefulness, concerns etc.)
Comments:
SEG Recommendation 21: Harmonise AQ indices in the EU
&
SEG Recommendation 22: Develop a common AQ Index
What is the problem?
In order to characterise the overall air quality on a certain day, an index composed of the data for the
concentration of the most relevant pollutants can be used. This simple index, e.g. good – moderate –
bad, can be used to inform the general public, especially regarding the current situation or a forecast
for the next day(s). Several cities in the EU are already using such an index. A common AQ index has
been developed by cities in CITEAIR and INTERREG.
What are the options?
Recommendation 21 & 22(a): Develop a common air quality index through an EU working group
and promote it in subsequent guidance to Member States.
Recommendation 21 & 22(b): Develop a common air quality index through an EU working group
and include a requirement to publish a daily air quality index in air quality legislation.
High-Level Impact Assessment
Assuming a brand new index is developed, the cost implications would be as below. Many Member
States have an existing index and therefore the implementation of a common index may just require
adjustment of their existing systems but the level of adjustment is unknown until the common index is
developed.
Scenario Description Qualitative High Level Cost Assessment Cost Assessment
A Member State has an
existing air quality
index which is
adjusted accordingly.
This scenario is based on the assumption that
should a common air quality index be
established then Member States would adjust
their index accordingly. The input required to
adjust any existing index is unknown at this
stage until a common index is required.
High Additional Cost
Burden
(>€60k)
B Member State has no
AQI and is required to
establish and report a
common air quality
index
This scenario would require a Member State to
establish and report a common air index. There
would be less cost than Scenario A as the
background activities to define an AQI is already
do for the Member State.
Medium Additional
Cost Burden
(€20-€60k)
C EEA report a
common air quality
index not Member
States
Through the provision of real-time date from
Member States to the EEA, a common AQI is
reported centrally. Member States continue with
their own AQI’s and link to the common AQI
Low Additional Cost
Burden
(<€20k)
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provided by EEA
SEG Recommendation 21 & 22 Questions
Question 21/22.1: Do you feel our qualitative judgement on the implication of this SEG
Recommendation is appropriate?
Yes No
Comments:
Question 21/22.2: Does your Member State have an Air Quality Index?
Yes
(please go to Question 21/22.3)
No
(please go to Question 21/22.4)
If ‘Yes’ please provide weblink:
Question 21/22.3: If you had to amend your Air Quality Index, can you give indicative costs for this?
Amendment costs
Question 21/22.4: If you do not have an Air Quality Index, can you give indicative costs for the set-up
and annual operation of an Air Quality Index in your Member State?
Set-up costs Annual running costs
Question 21/22.5: Do you have any comment on this SEG Recommendation going forward including
preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
Comments:
Summary of the SEG Consultation Responses from Member States
The following section provides a summary of the responses received to the SEG Consultation Survey
to Member States.
Assumption 1
Within the context of these SEG recommendations, we have assumed that any guidance provided is
non-statutory i.e. any guidance is provided to Member States as a support tool for them to inform their
own decision making processes but Member States do not have to strictly adhere to any guidance.
MS Do you agree with this
assumption for your Member
State?
What role does guidance play in the application of Directive
requirements in your Member State?
BE Yes Some play an important role. The derogation requests (for PM10 and
NO2 f. ex. were based on the guidance documents.
CZ Yes We find guidance a useful tool to implement Directive, so we tend to
follow them.
DE Yes Guidance has been helpful in the context of monitoring and reporting.
As for compliance we feel that no prejudice to the understanding of
the legal text should be made by a guidance documented.
GB No Guidance of a formal nature can often influence activities within a
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Member State but is not generally seen as something which must be
strictly adhered to.
IE Yes Guidance is a useful tool for interpreting and implementing the
Directives in a manner that will comply with EC expectations.
Assumption 2
In the context of these SEG recommendations, we have assumed that Member States, as part of their
day-to day activities, are engaged in capability enhancement to ensure that they are up to date with
latest air quality management science and techniques.
MS Do you agree with this
assumption for your Member
State?
Are there any additional points you with like to make about this
assumption?
BE Yes No
CZ Yes We suppose that it is also followed by EC, so it would be beneficial to
inform Member States about preferred techniques and methods.
DE Yes -
GB No Disagree that capacity building to keep up to date with latest science
and techniques is necessarily provided for within costed resources.
Member States will keep abreast of latest developments to be
informed but wouldn’t necessarily go and purchase the latest
measurement equipment for example
IE Yes We find the AQUILA forum is particularly useful for this activity.
SEG Recommendation 1: Standardise Compliance Projections
Question 1.1: Do you feel our qualitative judgement on the implication of this SEG
Recommendation is appropriate?
MS Yes/No Comments
BE Yes -
CZ Yes
DE Yes -
GB No We consider that any implementation of this option would be likely to involve cost.
IE Yes There is potential for a high additional cost burden depending on what the
standardised methodology is.
Question 1.2: Which scenario would you place your Member State in?
MS Scenario A Scenario B
BE Yes
CZ Yes
DE Yes
GB Yes
IE Yes
Question 1.3: Do you agree with our cost assessment for your chosen scenario?
MS Yes/No Comments
BE No Cost assessment is high, > € 60k if the used models would have to be adapted. In
the Flemish situation the modelling is done by an expert group (Vito - Flemish
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Institute for Technological Research) that is funded to develop, adapt and run
models.
CZ No We do not expect any additional burden, as we have already started actions to
improve air quality, which includes also the preparation of new air quality plans. If
there are any additional requirements in the revised directive, we expect higher
costs.
DE No Rec. 1(a, e and g) would result in only minor if at all additional costs, whereas Rec 1
(f) might result in high additional costs.
GB No If there is to be a legislative requirement then the burden of this option could be
much higher.
IE Yes -
Question 1.4: Do you have any comment on this SEG Recommendation going forward
including preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
MS Comments
BE No
CZ -
DE -
GB We consider that there would be a large variation in the cost implication of the different options a)-g)
and their interpretation and this has not been considered in this analysis. See also our response on
desirability, usefulness, concerns etc in our response for this option in the Dec 2012 questionnaire.
IE Ways to minimise costs and implementation difficulties for MSs should be considered, e.g. develop
a standard and reference method that corresponds to less-expensive commercial models/methods
or develop a method using GMES tools.
SEG Recommendation 2: Do not relate air quality plans and zones
Question 2.1: Do you feel our qualitative judgement on the implication of this SEG
Recommendation is appropriate?
MS Yes/No Comments
BE Yes -
CZ Yes It has no impact on our costs, because even now MS can define zones due to their
needs.
DE Yes -
GB No We think that the cost could potentially be higher than this.
IE Yes -
Question 2.2: Does your Member State currently relate its air quality plans with zones?
MS Yes/No Comments
BE Yes Yes, because it is induced by the directive. But, we take account of all sources (also
sources outside the zone). It is clarified in the action plan what are the main sources
causing the exceedances and which part of the zone is affected.
CZ Yes -
DE Yes -
GB Yes This linkage is currently provided in the submission according to Decision
2004/224/EC. The linkage with zones will be stronger and more explicit within the e-
reporting requirements for air quality plans under decision 2011/840/EU.
IE Yes -
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Question 2.3: Do you have any comment on this SEG Recommendation going forward
including preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
MS Comments
BE -
CZ -
DE The rephrasing would not have much effect in real life. Establishing air quality plans for zones is a
proven concept, which should not be changed.
GB See also our response on desirability, usefulness, concerns etc in our response for this option in
the December 2012 questionnaire.
IE Given the concept of zones is to manage air quality, I don’t see the value of zones if the plans don’t
relate to them.
SEG Recommendation 4: Reduce assessment reporting for standards that are largely met.
Question 4.1: Do you feel our qualitative judgement on the implication of this SEG
Recommendation is appropriate for your Member State?
MS Yes/No Comments
BE Yes The question is too vague to give a clear answer
CZ Yes Reduction costs could be negligible, but still reasonable.
DE Yes -
GB Yes However we consider that the provisions in the current AQD are sufficient. See
original response.
IE Yes -
Question 4.2a: Should this recommendation be implemented might your Member State
consider reducing your monitoring network?
MS Yes/No Comments
BE Yes We could consider to reduce the monitoring for CO and SO2 in certain zones,
however at a certain minimum stations the monitoring would continue.
CZ Yes We are not able to quantify possible reduction of monitoring stations, specific
proposal of this reduction and also additional study would be needed. Extent of the
national monitoring network depends on the national aims of air quality assessment
and management.
DE Yes -
GB Yes The monitoring network is already reviewed on a 5-year cycle. The changes noted
below are those already made during 2012 as a result of this existing process.
IE Yes -
Question 4.3b: If ‘Yes’, approximately how much might you reduce your network for each of
the following pollutants? For information, the table below provides 2010 monitoring numbers
taken from EIONET (Airbase-V6)
MS Possible Change in Pollutant Instrumentation
Benzene CO Pb NO2 O3 PM10 PM2.5 PAH SO2
BE Already
50%
Already
30%
CZ - - - - - - - - -
DE Significant Significant Some None None None Hardly any None Significant
GB 5% 70% 35%
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IE Not
estimated
Not
estimated
Not
estimated
Not
estimated
Not
estimated
Not
estimated
Not
estimated
Not
estimated
Not
estimated
Question 4.2c: Approximately how much might this reduce your annual network costs (value
and/or percentage terms)?
MS Comments
BE It is impossible to answer in a short time interval.
CZ Strongly depends on the scale of monitoring requirements reduction. Probably mean cost reduction.
DE Not known due to federal structure. The information on monitoring numbers taken from EIONET is
wrong for Germany. Pb and PAH are monitored and reported for several stations.
GB No further changes would be made.
IE Not estimated at this time.
Question 4.4: Do you have any comment on this SEG Recommendation going forward
including preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
MS Comments
BE -
CZ The total amount of monitoring stations in the table below is misleading, because it summarises
number of measurements that are in most cases on the same measuring site.
DE It must be ensured that sufficient information with valuable data quality will still be available when
reducing the monitoring obligations.
GB See also our response on desirability, usefulness, concerns etc in our response for this option in the
December 2012 questionnaire.
IE -
SEG Recommendation 5: Clarify the definition of the risk of exceedence
Question 5.1: Do you feel our qualitative judgement on the implication of this SEG
Recommendation is appropriate?
MS Yes/No Comments
BE Yes -
CZ Yes -
DE No New guidance requiring a re-assessment of the situation could result in substantial
additional costs.
GB - It is very unclear what is being suggested in this option. It would be useful to clarify
that there are two assessment of risk that are relevant here.
1) Level of risk of exceedance at a location at which a STAP should be prepared.
2) Level of risk of exceedance on a specific day in order to trigger implementation of
the STAP.
IE Yes -
Question 5.2: Do you have any comment on this SEG Recommendation going forward
including preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
MS Comments
BE -
CZ We welcome the guidance on AQ plans and assessment of its measures.
DE We came to the conclusion that short term measures are not cost-efficient in addressing
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exceedances. Therefore we do not favour any new activities in this context.
GB See also our response on desirability, usefulness, concerns etc in our response for this option in the
December 2012 questionnaire.
IE -
SEG Recommendation 7: Reduce the administrative burden regarding the development of
short-term action plans
Question 7.1: Do you feel our qualitative judgement on the implication of this SEG
Recommendation is appropriate?
MS Yes/No Comments
BE No It is a fact that the current alert thresholds for SO2 and NO2 have not been exceeded
anymore the last years. The current alert threshold for NO2 is 400 µg/m³. It should be
investigated in the first place whether this threshold should be lowered (based on the
latest recommendations of the WHO) before it would be withdrawn.
CZ Yes -
DE Yes -
GB Yes Requirements for UTD data flows within e-reporting may reduce these burdens for
alert thresholds.
IE Yes -
Question 7.2: Do you have any comment on this SEG Recommendation going forward
including preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
MS Comments
BE BE is in favour to introduce information and/or alert thresholds for PM10 (PM2.5). The short term
impact of particulate matter on human health is indeed not negligible. Different MS are currently
using different info/alert thresholds, and this confuses e.g. people living near the MS country
borders. Harmonisation at the EU level is thus appropriate.
CZ -
DE We would welcome any reduction of the number of air quality standards while keeping the level of
protection.
GB See also our response on desirability, usefulness, concerns etc in our response for this option in the
December 2012 questionnaire.
IE -
SEG Recommendation 8: Promote the assessment of synergetic measures in air quality plans
& SEG Recommendation 9: Promote the consideration of antagonisms with other policies in
the development of air quality measures.
Question 8/9.1: Do you feel our qualitative judgement on the implication of this SEG
Recommendation is appropriate?
MS Yes/No Comments
BE No Consideration is not cost neutral in terms of time, and detailed qualitative analyse is
not neutral in terms of costs. We also don’t agree with that “The majority of air quality
measures originate from other policy areas.” It would be better to write: “The majority
of air quality measures overlaps with other policy areas.”
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CZ Yes -
DE Yes -
GB No We think that costs would be larger. Meaningful consultation could potentially be a
very large burden.
IE Yes -
Question 8/9.2: In Scenario B, we have estimated an average input of 15 person-days per
measure (described as 5 policy days and 10 scientific days). Do you think that this is
appropriate?
MS Yes/No Comments
BE Yes It depends on the type of measure and can vary therefore.
CZ - We are not able to contest your estimation.
DE No These numbers might differ substantially depending on the measure and the nature
of the AQ plan.
GB No We think costs would be more like 25 days than 15 days.
IE - Not estimated at this time.
Question 8/9.3: Do you have any comment on this SEG Recommendation going forward
including preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
MS Comments
BE No
CZ -
DE In many cases “other policies” can hardly be influenced (e.g. climate). Therefore “consideration of
synergies and antagonisms” should not mean a more detailed analysis but another “best” and
“worst” case scenario to take into account when analysing the need for genuine AQ measures.
GB See also our response on desirability, usefulness, concerns etc in our response for this option in the
December 2012 questionnaire
IE Include a provision requiring consideration of other policies in EU-level policies and programmes.
The disconnect between the areas comes from EU level therefore the issue should be addressed
there first.
SEG Recommendation 10: Promote MS developing national or regional air quality strategies or
plans
Question 10.1: Do you feel our qualitative judgement on the implication of this SEG
Recommendation is appropriate?
MS Yes/No Comments
BE Yes -
CZ Yes -
DE Yes -
GB No It is not clear what would be required by this option. However the costs of collecting
and summarising information on local measures from many local authorities can be
quite high. Tools being developed by JRC for air quality plans data flows for e-
reporting may have a role here.
IE Yes -
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Question 10.2: Do you have any comment on this SEG Recommendation going forward
including preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
MS Comments
BE No
CZ In CZ we have a national plan and also air quality plans for zones and agglomerations and they are
interconnected.
DE A “merging” or “aggregation” of local or regional plans cannot substitute a national plan which
should also cover additional measures beyond the means of the local authorities. Consequently, we
do not support this SEG recommendation 10.
GB See also our response on desirability, usefulness, concerns etc in our response for this option in the
December 2012 questionnaire.
IE -
Recommendation 20: Require that the public is informed about exceedence of Limit Values as
soon as they occur.
Question 20.1: Do you feel our qualitative judgement on the implication of this SEG
Recommendation is appropriate?
MS Yes/No Comments
BE Yes For option A (which is the case for our region). A yearly limit value can also be
controlled by a moving yearly average. In this case the yearly limit values can be
checked every day. It is obvious that the public should be well informed about air
quality levels in his/her country. Air quality measurements are performed with
telemetric monitoring stations. The publication of these data is not that expensive
using the current available IT tools. It also of great importance that real-time AQ
data is published as soon as possible, not only to inform the public, but also to inform
neighbouring member states. Air pollution is a transboundary problem, and MS need
to have access to the air pollution measurements from their neighbours to improve
e.g. air quality forecasts.
CZ Yes -
DE No The judgement addresses only the technical part. However the additional
communication would definitely increase the costs.
GB No
IE Yes -
Question 20.2: Does your Member State currently report the following to the public as soon as
they occur?
MS Threshold /
LV
Y/N Comments
BE Alert
Threshold
Yes Belgium : http://www.irceline.be/
Flanders : http://www.vmm.be
Brussels : http://www.ibgebim.be
Wallonia : http://193.190.182.213/WebAirQuality/accueil.aspx
Information
Threshold
Yes Belgium : http://www.irceline.be/
Flanders : http://www.vmm.be
Brussels : http://www.ibgebim.be
Wallonia : http://193.190.182.213/WebAirQuality/accueil.aspx
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Limit Value Yes Belgium : http://www.irceline.be/
Flanders : http://www.vmm.be
Brussels : http://www.ibgebim.be
Wallonia : http://193.190.182.213/WebAirQuality/accueil.aspx
CZ Alert
Threshold
Yes http://portal.chmi.cz/files/portal/docs/uoco/web_generator/svrs/svrs_PM10_1_
CZ.html
Information
Threshold
Yes http://portal.chmi.cz/files/portal/docs/uoco/web_generator/svrs/svrs_PM10_1_
CZ.html
Limit Value Yes http://portal.chmi.cz/files/portal/docs/uoco/web_generator/exceed/index_CZ.ht
ml
DE Alert
Threshold
- -
Information
Threshold
- -
Limit Value - -
GB Alert
Threshold
Yes http://uk-air.defra.gov.uk/latest/
Information
Threshold
Yes http://uk-air.defra.gov.uk/latest/
Limit Value No
IE Alert
Threshold
Yes www.epa.ie/whatwedo/monitoring/air/reports/
Information
Threshold
Yes www.epa.ie/whatwedo/monitoring/air/reports/
Limit Value Yes www.epa.ie/whatwedo/monitoring/air/reports/
Question 20.3: Can you give indicative costs for the set-up and annual operation of a public
information system suitable for reporting against this recommendation?
MS Set-up Costs Annual Running Costs
BE €0 - system already exists 1 full time equivalent + 10000 euro (IT, …)
CZ - -
DE - -
GB - -
IE - -
Question 20.4: Do you have any comments on this SEG Recommendation going forward? (e.g.
desirability, usefulness, concerns etc.)
MS Comments
BE Exceedences of Target Values (ozone, PM2.5, …) should also be included
CZ -
DE Relating to Qu.20.2: We always inform on current AQ levels and put them in relation to AQ
standards, however we do not issue specific warnings. Any immediate information on the
exceedance of LV (to be distinguished from Alert and Inf.Treshholds) is only useful if there are
recommendations for action either to reduce emissions or to protect one’s health.
GB We do not think this option is either desirable or practical. Please see our response on desirability,
usefulness, concerns etc in our response for this option in the December 2012 questionnaire.
Information about attainment or otherwise of limit and target values can only be made using ratified
data and there are established mechanisms for reporting. It is also important that the attainment
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status is reported officially by the MS. We think that this option should be discarded and not be
given any further consideration.
IE -
SEG Recommendation 21: Harmonise AQ indices in the EU & SEG Recommendation 22:
Develop a common AQ Index
Question 21/22.1: Do you feel our qualitative judgement on the implication of this SEG
Recommendation is appropriate?
MS Yes/No Comments
BE Yes -
CZ Yes We do not understand the quantification of additional cost burden.
DE - -
GB Yes
IE Yes
Question 21/22.2: Does your Member State have an Air Quality Index?
MS Y/N Comments
BE Yes Belgium : http://www.irceline.be/
Flanders : http://www.vmm.be
Brussels : http://www.ibgebim.be
Wallonia : http://193.190.182.213/WebAirQuality/accueil.aspx
CZ Yes http://portal.chmi.cz/portal/dt?portal_lang=en&nc=1&menu=JSPTabContainer/P1_0_
Home
DE No
GB Yes http://uk-air.defra.gov.uk/forecasting/
IE Yes www.epa.ie/whatwedo/monitoring/air/index/ - will be obsolete in 1 month. NB: a new
AQI will be launched in April 2013.
Question 21/22.3: If you had to amend your Air Quality Index, can you give indicative costs for
this?
MS Amendment Costs
BE This depends on the type of index. The current Belgian Index (more info :
http://www.irceline.be/~celinair/english/abindex_en.html) is an index with 10 index scales. If a
common EU index also uses 10 scales, but only with different concentration classes, the costs to
adapt the BE index will be marginal. The implementation of a complete new index (e.g. the CAQI
index) will be more costly (1 month work )
CZ -
DE -
GB STG£100,000
IE -
Question 21/22.4: If you do not have an Air Quality Index, can you give indicative costs for the
set-up and annual operation of an Air Quality Index in your Member State?
MS Set-up Costs Annual Running Costs
BE - -
CZ - -
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DE - -
GB - -
IE - -
Question 21/22.5: Do you have any comment on this SEG Recommendation going forward
including preferences for the options provided? (e.g. desirability, usefulness, concerns etc.)
MS Comments
BE Belgium already uses an air quality index (AQI) to inform the general public about the current and
forecasted air pollution. This “BelATMO” AQI uses 10 concentration ranges and is based on the
concentrations of SO2, NO2, PM10 and ozone. A “sub-index” is calculated for each of those four
pollutants, and the general index is the highest of these four sub-indexes. The concentration ranges
are based on the European limit values (the target value for ozone). An index value of 6, 7 or 8 is
assigned to that limit value depending on the number of allowed exceedances of the European limit
or target values. It is thus important to notice that the Belgian index is not a “health” index, but an
index based on limit/target values. Belgium does support the introduction of a common European
AQI (as for example used in the Citeair project), but it is preferable that the index values and
concentration ranges have a link with the European limit / target values or are completely based on
the impact on human health (and then eg. based on the WHO guidelines). The Citeair CAQI
(‘Common Air Quality Index”, established in the framework of the interreg project “Citeair”) index is
neither a health index, nor based on the limit or target values in the air quality directive (e.g. the
Citeair index uses an hourly concentration range while the target value for ozone is an 8-hour
mean).
CZ We cannot estimate costs of the amendment of Air Quality Index due to the short time given for the
completion of this survey.
DE As the affected groups as well as individual measures differ by pollutant we do not support any
integrated AQ index.
GB Changing the existing UK index could be very confusing for the public. Scenario C would seem a
better idea and would build on existing UTD data flows. See also our response on desirability,
usefulness, concerns etc in our response for this option in the December 2012 questionnaire.
IE The new AQIH in Ireland was developed using a multi-sector approach (Air Quality, Health,
Meteorology, Policy). This approach was not used in CITEAIR. A Common AQI must not require
additional monitoring to the CAFÉ Directive, e.g. extra stations or continuous PM. Scenario C is the
most practical solution.
Additional Comments
Member States were given the opportunity to provide any additional comments.
MS Comments
BE -
CZ -
DE -
GB -
IE -
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Annex 3: Supporting evidence for SEG 1, SEG 4 & SEG 10
The following Annex provides supporting evidence for the figures in SEG 1, SEG 4 and SEG 10.
Table 55: Supporting evidence for SEG 1
MS Modelling (as supplementary assessment)
Number of zones exceeding based on ‘461’ Forms (2011)
Approximate Costs @ €5,858/zone
DE No 57 €342,000
IT N/A 47 €282,000
UK Yes 40 €240,000
FR Yes 26 €156,000
AT No 9 €54,000
NL Yes 9 €54,000
ES No 8 €48,000
PL No 5 €30,000
CZ Yes 4 €24,000
BE Yes 3 €18,000
SK No 3 €18,000
BG No 2 €12,000
HU No 2 €12,000
PT No 2 €12,000
RO No 2 €12,000
DK Yes 1 €6,000
GR No 1 €6,000
FI No 1 €6,000
LU No 1 €6,000
LV No 1 €6,000
SE No 1 €6,000
CY No 0 €0
EE No 0 €0
HR N/A NA N/A
IE No 0 €0
LT No 0 €0
MT No 0 €0
SI No 0 €0
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Table 56: Supporting evidence for SEG 4
MS
Monitoring Instrument Network Approximate Cost Savings
Sulphur Dioxide
Lead Benzene Carbon Monoxide
Total
Lower Cost Saving (10% @ €257)
Average Cost Saving (10% @ €773)
Upper Cost Saving (10%@ €1289)
ES 435 97 88 251 871 €22,385 €67,328 €112,272
IT 306 0 198 366 870 €22,359 €67,251 €112,143
FR 260 0 24 74 358 €9,201 €27,673 €46,146
PL 130 91 54 71 346 €8,892 €26,746 €44,599
DE 159 0 54 126 339 €8,712 €26,205 €43,697
RO 91 53 56 87 287 €7,376 €22,185 €36,994
AT 0 156 1 44 201 €5,166 €15,537 €25,909
CZ 73 62 30 27 192 €4,934 €14,842 €24,749
BE 62 4 40 22 128 €3,290 €9,894 €16,499
PT 53 1 13 38 105 €2,699 €8,117 €13,535
GB 45 0 6 24 75 €1,928 €5,798 €9,668
BG 28 9 17 16 70 €1,799 €5,411 €9,023
HU 24 0 12 21 57 €1,465 €4,406 €7,347
NL 20 6 2 22 50 €1,285 €3,865 €6,445
SK 12 5 10 10 37 €951 €2,860 €4,769
SI 19 4 2 5 30 €771 €2,319 €3,867
GR 13 0 2 14 29 €745 €2,242 €3,738
IE 12 0 3 6 21 €540 €1,623 €2,707
EE 9 2 2 7 20 €514 €1,546 €2,578
DK 2 7 1 8 18 €463 €1,391 €2,320
HR 8 0 2 8 18 €463 €1,391 €2,320
LT 8 0 3 7 18 €463 €1,391 €2,320
SE 9 0 2 4 15 €386 €1,160 €1,934
MT 4 3 3 4 14 €360 €1,082 €1,805
FI 7 0 0 5 12 €308 €928 €1,547
LU 6 0 2 3 11 €283 €850 €1,418
LV 4 0 2 2 8 €206 €618 €1,031
CY 2 3 1 1 7 €180 €541 €902
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Table 57: Supporting evidence for SEG 10
MS Number of zones exceeding based on ‘461’ Forms (2011)
Approximate Costs @ €1,160/zone
DE 57 €66,120
IT 47 €54,520
UK 40 €46,400
FR 26 €30,160
AT 9 €10,440
NL 9 €10,440
ES 8 €9,280
PL 5 €5,800
CZ 4 €4,640
BE 3 €3,480
SK 3 €3,480
BG 2 €2,320
HU 2 €2,320
PT 2 €2,320
RO 2 €2,320
DK 1 €1,160
GR 1 €1,160
FI 1 €1,160
LU 1 €1,160
LV 1 €1,160
SE 1 €1,160
HR N/A €0
CY 0 €0
EE 0 €0
IE 0 €0
LT 0 €0
MT 0 €0
SI 0 €0
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Annex 4: Review of Member State Online Public Information (SEG 20)
The following Annex provides a summary of the review of Member States online public information.
This information was collated to support the assessment of SEG Recommendation 20.
Key: National index Alert system
Regional/local index / index by pollutant Indirect 'alert' system i.e. indices representing health risk
No index. No data. Some data reported as measurements
no alert/public information
Table 58: European (from EU 27+) online public information systems
Country AQ reporting format Public alert system details
AQ info source type Available at (URL)
Austria No index, city-level measurements displayed online.
AQ values exceeding limits are highlighted with a coloured box. Not an explicit ‘alert’ system but does show where limit values are exceeded.
Federal Environment Agency.
http://www.umweltbundesamt.at/umweltschutz/luft/luftguete_aktuell/tgl_bericht/
Belgium Index.
No explicit 'alert' system but index values/colours indicate impact on health therefore acts as an indirect 'alert' system.
Interregional Cell for the Environment: run and managed under cooperative agreement between the Regions of Brussels, Flanders and Wallonia.
http://www.irceline.be/~celinair/english/homeen_java.html
Bulgaria No index. No publicly available measurements.
n/a n/a n/a
Croatia National index by city (and by pollutant).
No explicit 'alert' system but index values/colours act as an indirect 'alert' system.
The National Network for Monitoring Air Quality.
http://zrak.mzoip.hr/default.aspx?id=6
Cyprus Index.
No explicit 'alert' system but index values/colours indicate impact on health therefore acts as an indirect 'alert' system.
The Department of Labour Inspection (DLI), and Ministry of Labour and Social Insurance (MLSI).
http://www.airquality.dli.mlsi.gov.cy/
Czech Republic
Index.
No explicit 'alert' system but index values/colours indicate impact on health therefore acts as an indirect 'alert' system.
Unclear, presumed Government.
http://czechairwatcher.appspot.com/
Denmark No index. Monitoring station results only.
No alert system in place. real-time monitoring data available online.
DCE - National Centre for Environment and Energy at the University of Aarhus.
http://www2.dmu.dk/atmosphericenvironment/byer/forside.htm
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Country AQ reporting format Public alert system details
AQ info source type Available at (URL)
Estonia Index.
No alert system in place. The index does not appear to be used for public information.
Estonian Environmental Research Centre (EKUK), operating on behalf of government.
http://www.klab.ee/teenused/keskkond/ohu-uuringud/
Finland Index.
No explicit 'alert' system but index values/colours indicate impact on health therefore acts as an indirect 'alert' system
Ministry of the Environment and Finnish Meterological Institute.
http://www.ilmanlaatu.fi/
France Index.
Regional authority air pollution websites contain index value data for region, monitoring stations and alerts by variety of methods: text news feed, symbols (coloured) with ATMO index value and description of cause of alert and actions to be taken.
Fédération des Associations Agréées de Surveillance de la Qualité de l'Air. The Ministry of Ecology, Sustainable Development, Transport and Housing (MEDDTL).
http://www.atmo-france.org/fr/index.php?/2008043044/indice-de-qualite-d-air/id-menu-275.html
Germany No index. Pollutants measured mapped individually.
Preliminary, continuously measured data from monitoring stations and AQ networks is publicly available but no public alert system.
Federal Environment Agency (UBA).
http://www.env-it.de/umweltbundesamt/luftdaten/index.html?setLanguage=en
Greece No index. Pollutants measured and reported separately.
Clearly reports current pollution levels in relation to 'public information threshold', 'alarm threshold' and 'thresholds for long-term objective of protecting health'.
Ministry of Environment, Energy and Climate Change.
http://www.minenv.gr/1/12/122/12204/g1220400.html
Hungary
Air Hygiene Index, and national monitoring network and indices by city and pollutant.
OKI ‘Air Hygiene Index’ contains index information and clear alert/information system for informing the public. Monitoring network data for each monitoring station shows index category and % of ‘occupational exposure limit’, ‘information threshold’ and ‘alert threshold’.
National Institute of Environmental Health (OKI) Hungarian Air Quality Monitoring System. Hungarian Meteorological Service.
http://oki.wesper.hu/ http://www.kvvm.hu/olm/info.php?lang=en&id=6 http://www.met.hu/levegokornyezet/varosi_legszennyezettseg/meresi_adatok/tajekoztato/
Ireland
Index. Notice of current AQ status displayed at top of web page by city with index and data by monitoring station, but not a very
Environmental Protection Agency.
http://www.epa.ie/whatwedo/monitoring/air/index/ Reported at multiple
city level.
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Country AQ reporting format Public alert system details
AQ info source type Available at (URL)
public-friendly alert system.
Italy Some regional indices per pollutant. Not real time. Modelled data.
None found
The Italian Environment Protection and Technical Services Agency, APAT (Agenzia per la Protezione dell'Ambiente e per i servizi Tecnici). (NO INFORMATION FOUND DUE TO UNRESPONSIVE WEB LINKS)
http://ita.arpalombardia.it/ITA/qaria/doc_DistribSpazialeCalcolata.asp http://www.areeurbane.apat.it/site/it-IT/ - http://www.apat.gov.it http://www.isprambiente.gov.it/it/temi/aria/qualita-dellaria
Latvia
No index. Accessing some AQ data requires payment. Government page for 'air protection' is blank.
Blank page.
Ministry of Environmental Protection and Regional Development. Pay-to-access data from Latvian Environment, Geology and Meteorology Centre.
http://www.meteo.lv/pakalpojumi/gaisa-kvalitates-informacija/gaisa-kvalitates-merijumu-dati/?nid=540&cid=1034 http://www.varam.gov.lv/eng/darbibas_veidi/air_protection/
Lithuania Index.
‘Dial’ index indicator next to each monitoring station map point, with tabular information by pollutant. Not an explicit 'alert' but linked to levels of harm. Innovative 'dial' graphic and google map-based system is very public-friendly.
Environmental Protection Agency.
http://193.219.133.8/ap3/292/ http://gamta.lt/cms/index
Luxembourg
Index. Side bar on map indicates index colour and risk. When forecasts show deterioration in air quality, a newsletter detailing the causes and duration of this episode is offered.
Ministry of Environment.
http://www.environnement.public.lu/air_bruit/dossiers/PA-reseaux_mesure_air/reseau_automatique/resultats_mesures_live/index.html
Also pollutant-specific monitoring.
Malta
Health-based index for each pollutant, shown in interactive map and coloured bar.
No explicit 'alert' system but index values/colours indicate impact on health therefore acts as an indirect 'alert' system.
Malta Environment and Planning Authority.
http://www.mepa.org.mt/page.aspx?n=6FCF156C9E32BC85B24E
Netherlands
Measurement scales for each pollutant based on concentrations (ie. not an index). Uses coloured maps.
No explicit 'alert' system but index values/colours acts as an indirect 'alert' system.
Rural Air Quality Monitoring Network, National Institute for Public Health and Environment.
http://www.lml.rivm.nl/index.html
Poland Regional indices. Warsaw regional air The Regional http://sojp.wios.warsz
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Country AQ reporting format Public alert system details
AQ info source type Available at (URL)
(Warsaw and Malopolska examples)
pollution website contains index value/colour for current air pollution level and the highest value is the "alert threshold". Malapolska region has an index with associated risks and a 'warning' message from the Regional Crisis Management Team when pollution levels are high. RSS feeds available for other websites to have a 'current air pollution' banner displayed.
Inspectorate of Environmental Protection in Warsaw. Office of the Marshal of the Malopolska Region Portal.
awa.pl/?par=2 http://www.malopolska.pl/Obywatel/EKO-prognozaMalopolski/Krakow/Strony/default.aspx http://monitoring.krakow.pios.gov.pl/iseo/
Portugal Index.
Index linked to level of harm. Website includes ability to check number of exceedence days and alerts, suggesting there is an alert system when threshold reached.
Portuguese Environment Agency.
http://www.qualar.org/INDEX.PHP?page=1 http://www.qualar.org/INDEX.PHP?page=3&subpage=1
Romania Index.
No explicit 'alert' system but index values/colours linked to limit values therefore acts as an indirect 'alert' system.
Ministry of Environment and Forests.
http://www.calitateaer.ro/indici.php
Slovakia
No index. Pollutants measured and mapped/tabulated individually
Ozone smog warning system in place: "caution" when information threshold is exceeded, and "warning" when alert threshold exceeded.
Slovak Hydrometeorological Institute.
http://www.shmu.sk/sk/?page=1&id=oko_imis
Slovenia
No index. Pollutants measured and mapped/tabulated individually, but colour-coded by risk.
No explicit 'alert' system but index values/colours linked to limit values therefore acts as an indirect 'alert' system.
Slovenian Environment Agency.
http://www.arso.gov.si/zrak/kakovost%20zraka/podatki/amp/
Spain
No index. AQ data for monitoring stations available as graphs by pollutant. Some municipal level indices.
Some municipal level alerts based on information/alert thresholds.
Ministry of Agriculture, Food and Environment.
http://www.magrama.gob.es/es/calidad-y-evaluacion-ambiental/temas/atmosfera-y-calidad-del-aire/calidad-del-aire/mediciones/
Sweden
No index. Pollutants measured and mapped/tabulated individually.
No explicit 'alert' system but pollutant concentration values/colours act as an indirect 'alert' system.
Miljömål.se - the Swedish environmental portal, run by the Environmental Protection Agency.
http://www.miljomal.se/Miljomalen/Alla-indikatorer/Indikatorsida/?iid=105&pl=1
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Country AQ reporting format Public alert system details
AQ info source type Available at (URL)
United Kingdom
Index. Latest measurement page contains clear alerts.
Department for Environment, Food and Rural Affairs.
http://www.umweltbundesamt.at/umweltschutz/luft/luftguete_aktuell/tgl_bericht/
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Annex 5: Review of Member State Air Quality Indices (SEG 21 / 22)
The following Annex contains supporting information for SEG Recommendations 21 and 22: Review
of Existing Air Quality Indices and Proposed Harmonised Air Quality Indices. As outlined in the
Tender Specifications there was a requirement to assess possible information gaps and collect key
additional information when needed for the operational definition and assessment of recommended
options. There was an expectation to frame the problem and substantiate the assessment of options
by providing an overview of existing Air Quality Indices in different Member States and beyond in
other advanced countries (USA, Canada, etc), as well as of existing proposed harmonised Air Quality
Indices, making use of state of the art information such as the results of the INTERREG project
CITEAIR.
The purpose of Air Quality Indices:
“Air quality indices aim at expressing the concentration of individual pollutants on a common scale
where effects, usually health effects, occur at a value that is common to all pollutants” (Shooter and
Brimblecombe, 2009, cited in Plaia and Ruggieri, 2011). Air Quality Indices (AQIs) aim to improve
and simplify the communication of important air quality information. There are three main reasons for
using an AQI:
1. The ability to link air quality to health impacts to inform the public. AQIs are potentially
powerful here.
2. To condense complex data to provide an information overview.
3. To draw the public’s attention to air quality issues and raise awareness.
12.1.5 Linking air quality to health
The EU Framework Directive requires Member States to inform the public of the status of ambient air
quality. The primary purpose of an AQI is to do this in a clear and easily understandable way. Given
that the main impact on the general public of poor air pollution is health-based, AQIs are inherently
health-related. Many AQIs are explicitly health-based, in that the values or bands are determined by
relative health impact of different levels of pollution. This allows the public to understand the impact of
current ambient air quality on their health. Health-based indices are very popular in Europe and
around the world.
However, the CITEAIR report (2012) is critical of health-based indices because: their focus on short-
term exposure makes them less suitable for raising awareness; and the interaction between air
pollution and health impact is poorly understood and/or often hard to quantify. A local city
index/warning system is often found to be better for warning the public of health impacts, rather than a
common index. The problems with linking air quality to health impacts in an AQI are discussed in
more detail below.
Providing simple overview information for policy formulation or monitoring
Year-average indices are more useful for policy formulation and long term monitoring. However, a
single figure such as that produced for an AQI hides increasingly complex calculations and analysis,
and the implications are often hard to interpret for policy purposes. For example, there is a need to
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consider spatial representativeness and averaging. However, it is important to remember that the
point of making an AQI is to arrive at a single relative parameter that gives an indication of progress,
to enable improved public communication, so limitations posed by the ‘single figure’ are acceptable
for the purposes of the AQI despite being less useful for policy and long term monitoring.
Drawing the public’s attention of air quality and raising awareness
The public both suffers from, and is a source, of urban air pollution. Municipal governments have a
keen interest in trying to influence behaviour and travel choices (the predominant source of pollution)
and raising awareness is one method of doing so. From a time perspective, hourly updated indices
allow greater engagement, encouraging the public to ‘check back’ and identify specific episodes of
high pollution (e.g. rush hour). However, a problem with many short term AQIs, especially when
based on health impacts is the differentiation of impact over long and short timescales: often short
term indices show a situation as ‘good’ when long term it is exceeding thresholds. This can create
confusion.
Types of Air Quality Indices
There is a wide interest in Air Quality Indices (AQIs), but lack of a common strategy allowing
comparisons. As shown below in examples from Member States, there is considerable variation in the
methods and types of AQIs currently used. The number of index classes (and their colours), scale,
relative descriptive terms, pollutants considered, class boundaries, averaging times, update
frequency, and threshold values vary between different indices. Approaches to making an index also
vary by pollutant, and some indices consider the conjoint effect of pollutants, whereas others are
based on the single most dangerous pollutant.
Air quality standards/guidelines and the descriptors (good, bad, moderate) used for health-based
AQIs differ depending on the underlying relationships assumed between exposure to air pollution and
human health impact. Exposure to outdoor air pollution may be associated with a broad spectrum of
effects and generally health impact metrics are defined in terms of increase on daily mortality and/or
hospital admissions, whereas pollutant exposure metrics are based on pollutant concentration and
duration of exposure. The exposure-response relationship therefore differs depending on the metrics
used (Plaia and Ruggieri, 2011).
Single-pollutant indices are generally used to assess the impact of air pollution on health from short-
term exposure to pollutants, estimating the effects of each pollutant individually rather than the
combined effect of all pollutants. This is the most common approach as it is the most simple, but the
main drawback of single-pollutant indices is that they may overestimate the total effect since the
various pollutant concentrations may be correlated. On the other hand, generalised additive models
may produce unstable results or heterogeneous estimates (Plaia and Ruggieri, 2011). There is also
an additional level of complexity if all pollutant interactions are captured, and there is uncertainty
about the impact of pollutant interactions.
WHO (2000) advise that “in general, the guidelines address single pollutants, whereas in real life
exposure to mixtures of chemicals occurs, with additive, synergistic or antagonistic effects. In dealing
with practical situations or standard-setting procedures, therefore, consideration should be given to
the interrelationships between the various air pollutants”. The majority of existing AQIs take the
highest single pollutant approach when deciding the index value.
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As mentioned above, the scales, thresholds and boundaries of an AQI can also vary by type; either
health based or pollutant concentration-based. Health-based indices have a clear advantage and
disadvantage. The advantage is that the index value displayed is easy to interpret: it either does or
does not cause health effects. The disadvantage is that the index nearly always indicates air quality is
good and pollution is low, whereas the limit values for long term exposure are often exceeded. This is
the paradox between short and long term air quality criteria.
The CITEAIR project (2012:8) found that the different consequences of different exposure times
poses an awkward communication problem: “A health-based index meant to warn people for short-
term exposure to adverse air quality is mainly in the good part of the index scale, indicating that air
quality is not a problem. Though this could be true from the short-term exposure point of view, the
long-term exposure (even to low levels of air pollution) is often worrisome.”
Limit value exceedences for long-term exposure (e.g. year averages) are exceeded in many urban
areas even if a health-based air quality index is virtually continuously signalling that there are no
problems. In this case a health-based index might add to the confusion, as an AQI on a city website
suggests there is no problem, yet an air quality action plan is needed to comply to legal standards.
There is therefore a need for greater differentiation of impact. The CITEAIR project found that short
term indices are best not being health-based as greater differentiation at the lower end is needed to
show the broader range of AQ impacts. in addition, health-based indices are also found to rarely
succeed in changing behaviour: “Today there are better, more targeted ways to inform the select
group of people that really needs to adapt their activities in the face of pollution episodes than a
general index presented on a website” (CITEAIR 2012:8).
The US and UK air quality standards are typical examples of health-based indices, and nearly always
show that air quality is ‘good’. Other AQIs such as the French ATMO index are linked to values in the
EU directive. In this index, the top end of the scale ends in the middle of the health-based scales. This
provides better differentiation at the lower end of the scale to assure that air pollution is not always
‘good’, however it is difficult to attach any health interpretation to the index and a qualification of
‘moderate’ or ‘poor’ is arbitrary. In general, different indices agree better during high-pollution
episodes, but with less air pollution they differ more.
The variety of approaches that currently exist therefore make it very important to clearly state the
methods and type of AQI being presented in order for appropriate interpretation and responses to be
undertaken. Current AQIs in Europe and globally have varying levels of transparency of methods and
information being presented: these existing AQIs and public communication/alert systems have been
reviewed and the results presented below.
AQI Assessment Methodology
A review of current air quality indices and public information and alert systems was undertaken across
all 28 Member States (including Croatia), as well as a selection of international examples. Information
on each Member State was obtained through several means: searches of Member State Environment
Department/Agency website(s); web searches using search terms such as “[Member State] air quality
index pollution” in both English and corresponding member state language; third-party websites such
as http://www.airqualitynow.eu/; and from information contained in responses to the Information
Requests. It is recognised that many sub-regions, municipalities and cities have their own AQ
monitoring and reporting systems but for the purposes of this report only national-level information
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was collated and included. Where necessary, translation software was used to interpret non-English
web pages.
The review has produced two tables, Table 58 (Annex 4) shows a summary of the information
provided online by each Member State, including the presence/absence or an AQI (and/or other AQ
information), and the presence/absence and type of public information and alert system. This table
also details the organisation and course of information for each Member State. The table is colour
coded to demonstrate the relative detail and accessibility of information. For example, those websites
with a clear index system are shown in dark green; light green depicts those with some kind of AQ
information (perhaps pollutant specific indices); and white shows those with little or no AQI system.
On public information, dark blue shows those Member States with a clearly accessible and ‘public-
friendly’ system of alerts and information; light blue shows those with information that could be
accessed by the public and indirectly inform them of current AQ status and risk (for example, an index
that indirectly conveys a level of risk or information that could be interpreted by the public but is less
‘user-friendly’); and white shows those with no public information and alert system.
Table 59 contains detailed information on Member States with a publicly available AQI. The criteria for
inclusion was the presence of an Index which presents a single arbitrary figure or other result for
ambient air quality (as opposed to multiple indices for multiple pollutants, or un-translated AQ
monitoring data). This table details the number of index categories, scale, pollutants and calculation
approach taken
It should be noted that the following findings reflects the ability of a UK researcher to easily find the
required information. As a consequence of translation issues some AQI may not have been found.
Key Findings
Of the Member States, 8 were found to have a clear and easily accessible system of
informing/alerting the public about current air quality. These are detailed in the table, but examples
include current air quality status or ‘alert’ status box highly visible on the main page; e-newsletter or
text alerts; or a clear statement of air quality in relation to thresholds (information and alert). The
majority (17) had an indirect public information system, for example, no explicit system of informing
the public but information available and accessible online that could be used by a member of the
public interested in current air quality. Examples include real-time monitoring station data without
interpretation; an index of current air quality (n.b. these were not included in the top public information
category where there was no further interpretation of risk for the public); or websites with information
that was not easily navigable. Only 3 countries did not provide any public information on current air
quality, largely due to missing web pages and/or broken hyperlinks.
The review of AQIs in Table 59 across the Member States has found that 15 have an AQI (Hungary
and Poland have 2, both of which are included in the table). Of the 17 AQIs in the table, 7 are health-
based and 9 are non-health based (corresponding to EU limit values or alert thresholds). The
Croatian AQI had no information. This contrasts with the international examples, of which most are
health-based.
The average (mean, median and mode) number of index categories was 5; 8 used a scale between 1-
10; 7 had no numerical scale and used categories or colours only. This contrasts with the international
examples, which largely use scales from 0-hundreds. Twelve AQIs had hourly data and all had 24
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hour data as a minimum. All AQIs reported NO2, SO2, PM10 and O3. CO was included in 13 AQIs and
PM2.5 was included in 7 AQIs. Lead, benzene, black carbon, hydrogen sulphide and NOx were
occasionally found but often for general reporting rather than as a core component of the AQI.
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Table 59: European (from EU 27+) and Global Air Quality Indices
Country No.
index
catgs
Index
value
range
Reporting
time
period(s)
NO
2
SO
2
PM
10
PM
2.5
O3
CO
Pb
C6H
6 (B
en
ze
ne
)
H2S
(hy
dro
gen
su
lph
ide
)
NO
x
Type of
index
Calculation
method
Presentation
format
Available at (URL)
Belgium 10 1-10 Daily ● ● ● ● Non-health
based:
European
guidelines
Highest
single
pollutant
Index data
(graphs and
index headline)
http://www.irceline.be/~
celinair/english/homeen
_java.html
Croatia 4 None
(colour
only)
Hourly ● ● ● ● ● ● ● ● No
information
No
information
Interactive map http://zrak.mzoip.hr
Cyprus 4 None
(colour
only)
Current
situation
and
Highest
last 24
hours
● ● ● ● ● ● Health-
based
(impact)
Highest
single
pollutant
Interactive map http://www.airquality.dli.
mlsi.gov.cy/
Czech
Republic
6 None
(colour
only)
Hourly (8
hour for
CO)
● ● ● ● ● Non-health
based (limit
values)
Highest
single
pollutant
Interactive map http://czechairwatcher.
appspot.com/
Estonia 5 Pollutant-
specific
Hourly,
daily (CO 8
hour)
● ● ● ● ● Non-health
based
Two worst -
as CITEAIR
Pollutant graphs http://www.klab.ee/seir
e/airviro/api.html
Finland 5 0-50 Hourly ● ● ● ● ● ● Health-
based
(impact)
Highest
single
pollutant
Interactive map http://www.ilmanlaatu.fi
/
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Country No.
index
catgs
Index
value
range
Reporting
time
period(s)
NO
2
SO
2
PM
10
PM
2.5
O3
CO
Pb
C6H
6 (B
en
ze
ne
)
H2S
(hy
dro
gen
su
lph
ide
)
NO
x
Type of
index
Calculation
method
Presentation
format
Available at (URL)
France 3? 1-10 Daily ● ● ● ● Non-health
based,
corresponds
to EU alert
threshold
Highest
single
pollutant
Interactive map.
Index
represented by
Giraffe
http://www.atmo-
france.org/fr/index.php
?/2008043044/indice-
de-qualite-d-air/id-
menu-275.html
Hungary
Air Quality
Monitoring
System)
5 1-5 Hourly ● ● ● ● ● ● Non-health
based (limit
values,
alarm
thresholds)
Lowest
single
pollutant
Maps per city,
coloured points
on map
indicating index
value
http://www.kvvm.hu/ol
m/index.php
Hungary
(National
Institute of
Environmen
tal Health)
4 1-4 Hourly,
Daily
● ● ● ● Health-
based
(impact)
Highest
single
pollutant
Interactive map -
city level
information and
alerts
http://oki.wesper.hu/
Ireland 5 None
(categori
es only -
pollutant
specific)
Hourly
(PM10
rolling
24hr)
● ● ● ● ● Non-health:
based on
limit values
and
assessment
thresholds
Second
lowest rating
(> 95
percentile)
for the day.
Text index
headline only
http://www.epa.ie/what
wedo/monitoring/air/ind
ex/
Lithuania 5 0-5 Hourly, 8
hourly, 24
hour
● ● ● ● Health-
based
(impact)
Highest
single
pollutant
Interactive map http://193.219.133.8/ap
3/292/
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Country No.
index
catgs
Index
value
range
Reporting
time
period(s)
NO
2
SO
2
PM
10
PM
2.5
O3
CO
Pb
C6H
6 (B
en
ze
ne
)
H2S
(hy
dro
gen
su
lph
ide
)
NO
x
Type of
index
Calculation
method
Presentation
format
Available at (URL)
Luxembour
g
10 1-10 Hourly, 8
hourly (O3
and CO) or
24 hour
● ● ● ● ● Non-health
based,
corresponds
to EU alert
threshold
Highest
single
pollutant
Interactive map http://www.environnem
ent.public.lu/air_bruit/d
ossiers/PA-
reseaux_mesure_air/re
seau_automatique/resu
ltats_mesures_live/inde
x.html
Major pollutants forming index are NO2, PM10 and O3)
Poland
(Warsaw
region)
5 None
(catg.s
only -
pollutant
specific)
Hourly,
daily
● ● ● ● ● ● ● ● Non-health
based (limit
values,
alarm
thresholds)
Highest
single
pollutant
Interactive map -
tagged locations
with pollutant
info
http://sojp.wios.warsza
wa.pl/?par=2
Poland
(Malopolska
Region)
4 None
(colours
only)
Daily ● ● ● ● ● Health-
based
(impact)
Unclear Index category
(good/bad) and
map
http://www.malopolska.
pl/Obywatel/EKO-
prognozaMalopolski/M
alopolska/Strony/defaul
t.aspx
Portugal 5 None
(catg.s
only -
pollutant
specific)
Daily ● ● ● ● ● ● Non-health
based (limit
values,
alarm
thresholds)
Highest
single
pollutant
Interactive map -
coloured areas
http://www.qualar.org/I
NDEX.PHP?page=1
CO and SO2 not mandatory for index calculation
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Country No.
index
catgs
Index
value
range
Reporting
time
period(s)
NO
2
SO
2
PM
10
PM
2.5
O3
CO
Pb
C6H
6 (B
en
ze
ne
)
H2S
(hy
dro
gen
su
lph
ide
)
NO
x
Type of
index
Calculation
method
Presentation
format
Available at (URL)
Romania 6 1-6 Hourly ● ● ● ● ● ● ● ● ● Health-
based
(impact)
Highest
single
pollutant (at
least 3
present)
Interactive map -
coloured areas
and site index
information by
pollutant
http://www.calitateaer.r
o/indici.php
NOx, Benzene, PM2.5 not included in index)
UK 4 1-10 Updated
hourly
● ● ● ● ● Health-
based
(impact)
Highest
single
pollutant
Interactive map -
coloured areas
and index value
information
http://uk-
air.defra.gov.uk/latest/
International examples
USA 6 0-500 Daily ● ● ● ● ● ● Health-
based
(impact)
Highest
single
pollutant
Interactive map
- coloured areas
http://airnow.gov/
CO and Pb not in the AQI
Canada Air
Quality
Indices
(AQIs)
4 0-500 Daily ● ● ● ● ● ● Non-health
based, to
raise
awareness
only.
Highest
single
pollutant
interactive map -
coloured areas
http://airnow.gov/index.
cfm?action=airnow.can
ada
CO and Pb not in the AQI
Canada Air
Quality
Health
4 1-10+ Today,
tonight,
tomorrow
● ● ● Health-
based
(impact)
Sum of the
health risks
from each
City index
values and
risk/health
http://www.ec.gc.ca/cas
-
aqhi/default.asp?Lang=
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Country No.
index
catgs
Index
value
range
Reporting
time
period(s)
NO
2
SO
2
PM
10
PM
2.5
O3
CO
Pb
C6H
6 (B
en
ze
ne
)
H2S
(hy
dro
gen
su
lph
ide
)
NO
x
Type of
index
Calculation
method
Presentation
format
Available at (URL)
Index
(AQHI)
pollutant impact En
Hong Kong 5 0-500 Daily ● ● ● ● ● Non-health
based (limit
values)
Highest
single
pollutant
Index value only http://www.epd-
asg.gov.hk/
China 7 0-300 Daily ● ● ● ● ● Non-health
based
Unclear Shanghai: text
headline index
http://www.semc.com.c
n/home/index.aspx
EU CAQI /
CITEAIR
5 0-100 Hourly,
daily,
yearly
● ● ● ● ● ● Non-health-
based (limit
values)
Highest
single
pollutant
Table of cities
and index
values for
background and
roadside
http://airqualitynow.eu/
PM2.5, NO2, O3 primary pollutants. Also takes into
account PM2.5, CO and SO2.
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European Common Air Quality Index (CAQI)
The table above demonstrate the wide range of different approaches currently being
undertaken across EU Member States and beyond. Although local circumstances often
dictate the need for certain types/feature of indices, there is a need for greater
harmonisation. One attempt at this is the European Common Air Quality Index (CAQI).
This was developed in the course of the CITEAIR project, operational since 2006 on
www.airqualitynow.eu. It was made for the purposes of easily comparing the air quality in
different European cities in real time (not replace existing indices). Many cities use
national or city-specific reporting methods making them hard to compare, and the
purpose of the CAQI is to raise awareness on urban air quality. Unlike many AQIs, it has
no direct link to short term health effects.
In the CAQI, all detailed measurements for a city are converted into a single relative
figure for hourly, daily and yearly averaged data (representing a city’s general air quality
conditions throughout the year). Nearly 100 cities have been included, from an initial 8 in
2006. All data is obtained from Airbase.
Two situations are defined, background and roadside, in order to make cities more
comparable. Calculating for background and traffic situations is undertaken for 2 reasons:
1. Draws attention to the role of traffic as a source of pollution as the traffic index is
mostly higher than background.
2. Makes cities more comparable as monitoring strategies differ: some don’t monitor
traffic sites, some focus on traffic as most polluted sites. Stratifying by background and
roadside makes the results more comparable.
Hourly and daily CAQI:
Indices from 0 (very low) to >100 (very high), based on 3 pollutants of major concern:
PM10, NO2, and O3. It also takes into account data on PM2.5, CO and SO2 if available. See
below, left, for index values. Two situations are defined, background and roadside, in
order to make cities more comparable.
Annual (YACAQI):
This is a relative measure of annual average air quality in relation to EU limit values. Most
indices cover short term air quality situation only. It is calculated for background and
roadside using a ‘distance to target’ method where the target is the EU limit value. If the
index is higher than the average for one or more pollutant the limit values are not met,
and vice versa. The YACAQI is aimed at better taking into account long term exposure to
air pollution based on WHO recommendations.
Despite widespread acceptance, questions continue to exist:
Having two indices alongside each other (a local one and the CAQI as an international
one for comparison purposes) might confuse the public.
The index is not well adapted to local situations.
The index is too complicated (too many pollutants).
The index is not good in reflecting health effects of the air quality.
However, the first 2 are the “essence of the index”: a new common index to allow
international comparisons.
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Index values: >1 (limit exceeded by one or more pollutants, 1 (EU standards fulfilled on
average), <1 situation is better than the requirements on average. See below, right for
index values.
CAQI YACAQI
CAQI Index Calculation
The index is derived through a ‘calculation grid’, inspired by threshold values as they
occur in the EU Air Quality Directives, on values used in similar indices and on a number
of pragmatic considerations such as frequent changes at the lower end of the pollution
scale. This is used for the hourly index. The daily index is calculated using the highest
hourly sub-index value, and therefore has higher values than the hourly index.
31 background and 27 traffic stations used in the analysis, from Belgium, Czech
Republic, Germany, Finland, France, Italy, Spain, Sweden and the UK. Only 6 cities had
both background and traffic data.
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The average occurrence of the different classes for the sub indices is shown in the table:
the majority are in the first class indicating pollution is very low.
Revised YACAQI
This is also calculated for traffic and background sites, and year average concentration
data is submitted by cities for each pollutant. It does not necessarily reflect the complete
and balanced picture a city reports under the EU guidelines. Sub-indices are shown in the
table.
Conclusions:
This review of AQIs and public information has shown that the majority of countries are
reporting near real-time and daily information on air quality status to the public. The level
of public accessibility varies quite considerably, from comprehensive alert systems and
user-friendly information, to basic presentation of monitoring station data with no
interpretation. Achieving the latter is anticipated to be the most resource intensive stage
of public information, and translation into a basic user-friendly interface a relatively easy
further step. this should mean that all Member States should be able to achieve a good
level of accessible public information with relatively little effort.
Just over half of Member States had an AQI, of which many are already very similar in
terms of pollutants reported, scale (mostly 1-5) and number of categories, and approach
(based on EU-limit values). This supports the use of a common index, as it would allow
comparison between them. It would also assist those member states without an AQI to
create one, reducing costs. A CAQI would also involve a central point of access for all
AQIs, aiding public access, as finding information on some Member States was
challenging. A CAQI could also raise awareness about AQ across Member States
through publicity surrounding the establishment of something ‘new’, i.e. if the public are
aware of the creation of a ‘new common reporting format’ they might access AQ data
when they were not aware of it before.
However, a CAQI that corresponds to the CITEAIR proposal would add additional burden
to the majority of Member States, as the CITEAIR CAQI differs quite considerably from
many existing indices. For instance, a scale of 1-100, the separate analysis of
background and roadside sites, and the inclusion of yearly indices. Also, the CITEAIR
CAQI does not correlate to or provide health advice, which is the purpose of many AQIs,
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particularly non-EU. Only Estonia explicitly uses the CITEAIR CAQI methodology. This
raises concerns about the burden and additional layer of bureaucracy that a CAQI would
add to Member States. In addition, the unlinking of health-impacts would be detrimental:
many Member Sstates link their index to health impacts (even if the index categories are
not based on health impacts). Two indices (a local and international (CAQI) may also
confuse the public, which would contradict the purpose of the index. Furthermore, many
countries do not have issues with air quality – reflected by the lack of an AQI, in
Scandinavian countries for example – and so a CAQI may not be helpful or necessary for
these countries. Although a method of comparison between Member States is useful, air
quality is inherently linked to local circumstances and so a system most applicable to
those circumstances would seem more appropriate. Comparisons between Member
States and cities may not be useful if circumstances differ so widely.
In conclusion, care should be taken in implementing a Common Air Quality Index for
Member States. This should take account of differing air quality circumstances and
reporting needs, and commonalities between existing approaches, and not add additional
burden to Member States.
Sound analysis, inspiring ideas
BELGIUM – BULGARIA – HUNGARY – INDIA – THE NETHERLANDS – POLAND – RUSSIAN FEDERATION – SOUTH AFRICA – SPAIN – TURKEY – UNITED KINGDOM
P.O. Box 4175
3006 AD Rotterdam
The Netherlands
Watermanweg 44
3067 GG Rotterdam
The Netherlands
T +31 (0)10 453 88 00
F +31 (0)10 453 07 68
E netherlands@ecorys.com
W www.ecorys.nl
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