1. Survey on the implementation of the EU Air Quality Directive – preliminary results –
Dick van den Hout, TNO
Contributions by Lorenz Moosmann, Christian Nagl and Wolfgang Spangl (UBA), Marita Voogt (TNO)
SEG meeting, 19/20 Jan 2012

2. Approach
In support of the review of the Air Quality Directive and the Fourth Daughter Directive, a survey has been conducted in order to identify implementation strengths and weaknesses, as well as opportunities and threats regarding the objectives of the directive.
The survey was aimed at three target groups:
(Informed) general public,
Experts and practitioners,
SEG members.
Three questionnaires:
General public: short online questionnaire, closed questions (yes/no, multiple choice), one open question (free text reply);
Experts: detailed online questionnaire, mainly closed questions, a few open questions;
SEG members: ed informal questionnaire, all questions open.
All three questionnaires had about ten questions, which addressed the same topics.
Response period: mid June – 15 October 2011

3. The two online questionnaires
General public
599 replies
10% on behalf of an organisation (18 NGO, 8 business, 8 government, 5 research, 20 other)
Not proportionally divided over MSs: 39% from IT, 16% BE, …
Experts and practitioners
250 replies
63% on behalf of an organisation
Affiliations (all respondents):
Government (87 replies)
Business (65)
NGO (33)
Research (29)
Other (21)
This presentation will focus on the questionnaire for SEG members.

4. Example of the replies by the general public

5. Example of the replies by experts and practitioners
*) Other (free text replies): adverse meteorology, adverse topography, traffic, lack of political will

6. Responses of SEG members
*) Other: third countries, associations of regional/local administrations,
various international organisations
In total: 75 invited, 40 responding

7. Analysis of replies of SEG members
Most replies were carefully phrased. Hence, summarizing the replies inevitably causes loss of detail and nuance.
We’ve read all replies carefully and converted these into summary statements. This resulted in a database of statements and their origins.
The total number of statements per question was typically around 100, and up to 300.
The statements for a question were subsequently clustered. The overview is based on these clusters.

8. Preliminary results - SEG
The analysis is ongoing, so these are preliminary results!
Below summaries are given per question. Statements are listed according to the number of stakeholders that stated them.
Note that even the top statement usually is given by less than 50% of the respondents, so is not a commonly expressed view. Often opposing views were also given, but the highest frequency determines what is listed below.
In the report, but not in this presentation, a division in four stakeholder groups will be made:
Member States,
Business Associations,
Environmental NGOs,
Other.

9. Question 2 - The Thematic Strategy on Air Pollution
Coherence of policies / legislation is important (31 respondents); in particular:
More coherence of EU wide emission reductions with deadlines of AQ standards (timing, delay of NECD, unexpected trends of real world emission) (23 rs)
Look at synergies (17 rs) and trade-offs (17 rs) with Climate Change policy
Balance ambition with wider societal needs, aim at level playing field, realistic objectives, regulatory stability (18 rs); further ambition is needed (14 rs)
A thorough review / integrated assessment is important (consistent, realistic, solid science base, up-to-date methodology) (14 rs)
More attention for specific sources (shipping emissions, biomass burning/small scale combustion, non-road mobile machinery) (12 rs)
Positive comments about 6th Environmental Action Plan / Thematic Strategy on Air Pollution / air pollution legislation (12 rs) …

10. Question 3 - The approach of the AQ directives
Agreement with the global approach (20 respondents); however also concerns about the complexity (9 rs)
There are weaknesses/opportunities in how assessment/standards relate to (reduction of) population exposure (16 rs)
Take into account that local/regional/national authorities have limited control of air pollution (11 rs)
Flexibility (derogations, time extensions) is important (11 rs)
Consider compliance assessment over three years instead of one year (11 rs)
Consider relating provisions/standards more to harmful constituents (black carbon, ultrafine PM) (8 rs)
Aim at coherence with other policy areas (8 rs) …

11. Question 4.1 - The air quality standards of the directives
More attention for health relevant PM fractions is needed (17 respondents)
EU level / international measures are needed to meet the limit values (12 rs)
Base standards on solid and up-to-date evidence (12 rs)
Tighten PM air quality standards (7 rs)
Simplify the set of standards (7 rs)
Increasing the focus on exposure (e.g. AEI) is useful (7 rs)
Flexibility (derogations, time extensions) is important, consider keeping this (5 rs); but others reject derogations (4 rs) …

12. Question 4.2 - Other national air quality standards recommended for consideration in the review
9 Member States and 2 third countries replied to this question.
7 of these mentioned national standards other than the EU standards; a few were suggested for consideration in the review.

13. Question 5.1 – Assessment
Extend model use, together with better quality assurance of models (10 rs)
Suggestions related to equivalence of PM monitors (7 rs)
Assessment should be further harmonised (6 rs)
Number of monitoring stations is insufficient (4 respon-dents, vs 3 respondents stating that the number is appropriate)
Use of satellite data should be promoted (3 respondents, vs 3 respondents stating that quality of satellite data is insufficient) …

14. Question 5.2 – Costs of a monitoring station
Annual marginal costs of an urban background PM station (automatic method) were typically around € (range – €).
Annual marginal costs of a remote background station for HM and PAH (in PM10) were – €; the information provided was rather heterogeneous.

15. Question 6 – Air Quality Management
Provisions should be strengthened / revised (participation, consultation, scrutiny of the air quality plans) (18 respondents)
Provide guidance and support related to air quality planning (11 rs)
Consider trade-offs with climate change mitigation measures (8 rs)
Limited effectiveness, e.g. of short-term measures (6 rs)
The present provisions are seen as appropriate (5 rs) …

16. Question 7 – Public information
Support for a common air quality index (13 respondents in favour vs. 5 critical respondents)
Provisions on public information are appropriate (8 rs)
Focus on certain aspects such as information during high-pollutant events, best-practice examples, sources (6 rs)
Simplify public access to air quality data (4 rs)
Inform the public better / sooner about exceedance (4 rs) …

17. Question 8 - Governance
Reduce burden for authorities, both related to monitoring and reporting (9 respondents, mostly general recommendations)
Costs of abatement measures are an important barrier to implementation of air quality policy (7 rs)
Other barriers, such as too tight timeframes and lack of cooperation between sectors and administrative levels (6 rs)
Guidance / best practice examples for implementing abatement measures (5 rs)
Public acceptance is critical for implementing measures, especially in the area of traffic (4 rs) …

18. Question 9 – Scientific and technological innovations
New components and metrics, such as black carbon, particle numbers and deposition of heavy metals (9 rs)
Need to do more research on health impacts (8 rs)
Various suggestions how to improve and promote modelling (7 rs)
Use of up-to-date research findings in the review (6 rs)
Suggestions on improving support/guidance for effectively using results of research projects (4 rs) …

19. Question 11 – Your own involvement in the review process
Preparedness/commitment to collaborate (14 respondents)
Contribution of expertise, experts, specified research results (10 rs)
Involvement/consultation of parties represented by SEG member (7 rs); for that purpose, timely provision of discussion documents is requested (2 rs)
Proposal for providing a specified contribution (revision proposal, hosting a workshop, …) (4 rs)
Request for transparency/access to data to faciliate contributing to the review (2 rs)

20. Question 10 - Your most important issues (1/5)
Give more attention to the most harmful fractions of PM (13 respondents)
More consistency of air quality standards with EU-level real-world emission reductions (EURO5) and achieved ceilings (NECD) is needed (9 rs)
Recommendations on improving (specified aspects of) the integrated assessment (9 rs)
Flexibility is important / keep derogation possibilities (8 rs)
Further attention for modelling is needed (5 rs)
More ambition is needed / tighten standards (5 rs)
Reduce the burden of assessment / administration / reporting (4 rs)
Simplify the set of air quality standards (3 rs)
Include 4th Daughter Directive in the Air Quality Directive (3 rs) …

21. Question 10 - Your most important issues (2/5)
Most important issues for Member States (13 respondents):
Recommendations on improving (specified aspects of) the integrated assessment (6 respondents)
Give more attention to the most harmful fractions of PM (5 rs)
More consistency of air quality standards with EU-level real-world emission reductions (EURO5) and achieved ceilings (NECD) is needed (4 rs)
Flexibility is important / keep derogation possibilities (4 rs)
Reduce the burden of assessment / administration / reporting (4 rs)
Further attention for modelling is needed (4 rs)
Simplify the set of air quality standards (3 rs)
Include 4th Daughter Directive in the Air Quality Directive (3 rs) …

22. Question 10 - Your most important issues (3/5)
Most important issues of Business Associations (13 respondents):
A level playing field is important (3 respondents), between sectors and internationally
Focus more on the most harmful PM fractions (3 rs)
A thorough/integrated assessment of review decisions is needed (3 rs) …

23. Question 10 - Your most important issues (4/5)
Most important issues of Environmental NGOs (5 respondents):
More ambition is needed; tighten the standards (4 respondents)
Include/consider a standard for black carbon / ultrafine particles (4 rs) …

24. Question 10 - Your most important issues (5/5)
Most important issues for Other Stakeholders (9 respondents):
More consistency of air quality standards with EU-level real-world emission reductions (EURO5) and achieved ceilings (NECD) is needed (4 respondents)
Attention for specific sources is asked (small combustion installations, agriculture) (3 rs) …

25. Reporting our analysis
The report will include the three questionnaires and will be public.
In the report, the SEG stakeholders will be divided in the four groups mentioned above; replies will not be related to individual stakeholders.
The comments by the SEG will be presented as SWOT analyses of the AQD per stakeholder group.
The report is due May 2012.

26. Thank you!