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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


3.3.3 Member State Information Requests 15

3.3.4 Case Studies 16


3.4 SEG 1 - High-Level Cost Assessment Conclusions 16

4 SEG 2: Do not relate air quality plans and zones 19



4.3 SEG 2 – Assessment of Evidence 19



4.3.3 Member State Information Request 20



4.4 SEG 2 - High-Level Assessment Conclusions 21

5 SEG 4: Reduce assessment reporting for standards that are largely met. 23




ii








5.4 SEG 4 High-Level Assessment Conclusions 26

6 SEG 5: Clarify the definition of the risk of exceedence 28









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


7.2 What are SEG 7 sub-options? 31








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


8.2 What are the SEG 8/9 sub-options? 35

8.3 SEG 8/9 – Assessment of Evidence 36






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


9.2 What are SEG 10 sub-options? 41

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Review of: Provisions for Air Quality Measurement, Air Quality Modelling, Management Framework,

Assessment, and Public Information; and Stakeholder Consultation Support








10 SEG 20: Require that the public is informed about exceedence of Limit Values as

soon as they occur. 45


10.2 What are the options? 45







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


11.2 What are the SEG 21/22 sub-options? 51

11.3 SEG 21/22 – Assessment of Evidence 51






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


12.1.3 SEG 4 Information Request Responses 80

12.1.4 SEG 5 Information Request Responses 84


SEG 8/9 Information Request Responses 93



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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

v



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 13: TNO Report (2012) SWOT analysis for SEG 4 24 Table 14: Summary of Member States Information Request Responses for SEG 4 24





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 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 27: Summary of Member States Information Request Responses for SEG 1042




Table 31: Member States with Online public information systems 48


Table 33: SEG 21/22 sub-options from TNO Report (2012) 51



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 51: SEG 8/9 – Information Request Responses 93



Table 54: SEG 21/22 – Information Request Responses 104

Table 55: Supporting evidence for SEG 1 130



Table 58: European (from EU 27+) online public information systems 133

Table 59: European (from EU 27+) and Global Air Quality Indices 143

vii



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

2



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.



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.



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



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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Review of: Provisions for Air Quality Measurement, Air Quality Modelling, Management Framework, Assessment, and Public Information; and Stakeholder Consultation Support


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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requirements for hotspots

(both macro and micro siting)

for monitoring in hot-spots.


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.


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.



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.



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.



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Review of: Provisions for Air Quality Measurement, Air Quality Modelling, Management Framework, Assessment, and Public

Information; and Stakeholder Consultation Support

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-

9



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

11



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

13



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

14



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


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

15



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.


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.

16



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).


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.

17



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.

18



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

19



4 SEG 2: Do not relate air quality plans and zones


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.


Table 8 provides the sub-options for this SEG Recommendation including the pros and cons provided

in the 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











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


Regulatory Stability Moderately Unfavourable -2

20




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.


SEG 2

Sub-Option


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.

21



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.


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.

22



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.


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

23



5 SEG 4: Reduce assessment reporting for standards that are largely met.


The effort of assessment (especially monitoring requirements) and reporting could be reduced for

pollutants with (almost) no exceedences of environmental standards.


Table 12 provides the sub-options for this SEG Recommendation including the pros and cons

provided in the TNO Report (2012).



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

24



even in a case of low concentrations.












Health / Env Improvement Slightly Unfavourable -1

Harmonisation among MS Slightly Unfavourable -1


Burden to MS Moderately Favourable 2

Subsidiarity Neutral 0

Complexity of Legislation Slightly Favourable 1




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.





following Table.


SEG 4

Sub-Option


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

25



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.


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

26



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.

27



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

28



6 SEG 5: Clarify the definition of the risk of exceedence


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.






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.







29




The findings of the SWOT analysis are not explicit from the TNO Report (2012).


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.





following Table.


SEG 5

Sub-Option


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.

30



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.


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).


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)

31



7 SEG 7: Reduce the administrative burden regarding the development of Short Term Action Plans





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?





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







32








Health / Env Improvement Slightly Unfavourable -1

Harmonisation among MS



Subsidiarity Moderately Favourable 2

Complexity of Legislation Moderately Favourable 2

Cost of Implementation Slightly Favourable 1



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.





following Table.


SEG 7

Sub-Option


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.

33



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.


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.



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.


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

35



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.


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: SEG 8/9 sub-options from TNO Report (2012)


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. - -

36



8.3 SEG 8/9 – Assessment of Evidence


of the SEG 8/9 Recommendations. This is based upon evidence from the TNO Report (2012) SWOT







Table 23: TNO Report (2012) SWOT analysis for SEG 8/9



Harmonisation among MS Slightly Favourable 1




Complexity of Legislation Slightly Unfavourable -1




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).





following Table.


SEG 8/9

Sub-Option


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

37



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.


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.

38



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


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.

39



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

41



9 SEG 10: Promote Member States developing national or regional air quality strategies or plans


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?





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.

42













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.





following Table.


SEG 10

Sub-Option


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

43



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.


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.


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.

44



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

45



10 SEG 20: Require that the public is informed about exceedence of Limit Values as soon as they occur.


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?





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.







46









Harmonisation among MS Neutral 0





Cost of Implementation Slightly Unfavourable -1



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





following Table.


SEG 20

Sub-Option


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

47



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).


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).

48



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.

49



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.


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

51



11 SEG 21: Harmonise AQ indices in the EU & SEG 22: Develop a Common AQ Index


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: SEG 21/22 sub-options from TNO Report (2012)


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


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

52



Member State Case Studies and Member State Consultation Survey in addition to the expert-based

judgement of the Project Team.


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):



Health / Env Improvement Slightly Favourable 1

Harmonisation among MS Moderately Favourable 2





Cost of Implementation Moderately Unfavourable -2

Regulatory Stability Neutral 0




Harmonisation among MS Highly Favourable 3

Admin burden to Commission Highly Unfavourable -3


Subsidiarity Highly Unfavourable -3

Complexity of Legislation Moderately Unfavourable -2

Cost of Implementation Moderately Unfavourable -2

Regulatory Stability Moderately Unfavourable -2


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.





following Table.


SEG 21/22

Sub-Option


53



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.

54




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


AQI may not have been found.

55



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.

57



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


would result in cost savings for Member States but this is completely dependent to the detailed of the

58



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.

59



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.


AQI may not have been found.

60



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.

61



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

62



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

63



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


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 existing staff time for maintenance? (working days per

annum)


annum)


to the maintenance of equipment / facilities (e.g. finance, energy costs etc)?

Additional

Comments


64



Table 42: Cost Category 3 – New Data Generation & Compilation


Data Generation

Please provide a description of the type of changes to data generation costs?


Please quantify any changes in existing staff time for data generation? (working days per

annum)


annum)


to data generation?

Data Compilation

Please provide a description of the type of changes to data compilation costs?


Please quantify any changes in existing staff time for data compilation? (working days per

annum)


annum)


to data compilation?

Additional

Comments


Table 43: Cost Category 4 – Reporting & Administration


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)


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)


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


65



Table 44: Cost Category 5 – Additional Staff Levels and Staff Time


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


Table 45: Cost Category 6 – Staff Capacity Development


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


66



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).

67



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.

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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. 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.

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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)

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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.

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No

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SE

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






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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DE

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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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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RO

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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CZ

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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DE

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





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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GB

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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HR

See previous

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-

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SE

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






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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DE

-

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FI

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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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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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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DE -

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FI

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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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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GB

It is not clear what this recommendation would require MS to do. We are not able to estimate costs.

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HR

See previous

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RO

there is no experience on this issue.

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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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CZ

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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FR

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

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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HR

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.

CC1 CC2 CC3 CC4 CC5 CC6

http://jogszabalykereso.mhk.hu/cgi_bin/njt_doc.cgi?docid=140874.569529

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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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CZ

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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DE

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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FR

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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HR

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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SE

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



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.

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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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HR

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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-

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RO

In your Member State, is assessment and reporting relaxed for those standards that are largely met? Yes

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SE

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. ?).

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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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HR

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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-

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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



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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RO

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

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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

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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.

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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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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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DE

These values are not exceeded in Germany.

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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.

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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.

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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.

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HR

Yes. It has been prepared as a response to factual situation based on air quality measurements.

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HU

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LT

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Staff Time

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RO

not yet according to the provisions of new framework directive

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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.

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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.

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91



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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DE

-

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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.

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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.

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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.

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HR

Yes. It has been prepared as a response to factual situation based on air quality measurements.


92




HU

CC1

Equip & Facilities

CC2

Ops & Maintenance

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Data Gen & Compil

CC4

Report & Admin

CC5

Staff Time

CC6

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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

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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

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Data Gen & Compil

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93



SEG 8/9 Information Request Responses

Table 51: SEG 8/9 – Information Request Responses


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

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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

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DE

Synergies and trade-offs from climate measures are already considered in our AQ plans, e.g. increased wood combustion.

CC1

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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.

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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

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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.

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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.

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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.

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CC5

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LT

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RO

Not yet. It will be taken into consideration

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SE

Not in any standardised manner. Is down to the Local and Regional Authorities to take this into consideration.

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Option 8&9(b): Workshops for exchanging best practices.

BE


also different.

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CZ Not so much yet. We are preparing MEDIUM-TERM AIR PROTECTION STRATEGY FOR THE CZECH REPUBLIC, where we will consider synergies and


95



CC1

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DE

-

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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.

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FR



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.

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CC2

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GB



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HR

There is a need for capacity building in this area.

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HU

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LT

-


96




RO


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SE


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Option 8&9(c): Provision of guidance documents.

BE


also different.

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CZ

Not so much yet. We are preparing MEDIUM-TERM AIR PROTECTION STRATEGY FOR THE CZECH REPUBLIC, where we will consider synergies and


CC1

Equip & Facilities

CC2

Ops & Maintenance

CC3

Data Gen & Compil

CC4

Report & Admin

CC5

Staff Time

CC6

Capacity Dev

DE

-

CC1

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CC2

Ops & Maintenance

CC3

Data Gen & Compil

CC4

Report & Admin

CC5

Staff Time

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FI

-

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FR



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



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GB



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HR

-

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HU

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LT

-

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Ops & Maintenance

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RO


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SE


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98






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.

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CZ

In CZ we have a national plan and also air quality plans for zones and agglomerations and they are interconnected.

CC1

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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

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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

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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.

CC1

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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

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Ops & Maintenance

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CC4

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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

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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

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CC2

Ops & Maintenance

CC3

Data Gen & Compil

CC4

Report & Admin

CC5

Staff Time

CC6

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LT

-

CC1

Equip & Facilities

CC2

Ops & Maintenance

CC3

Data Gen & Compil

CC4

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CC5

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CC6

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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

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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

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100



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

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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

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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

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.


101




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

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CC5

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HU

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.

CC1

Equip & Facilities

CC2

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LT

-

CC1

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CC4

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CC5

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CC6

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RO

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

CC1

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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

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http://www.kvvm.hu/olm/index.php

http://oki.antsz.hu/kornyezet_egeszsegugyi_indikatorok

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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.

CC1

Equip & Facilities

CC2

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CZ

Yes. CHMI already informs public in such situations. The costs are insignificant and difficult to quantify.

CC1

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DE

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.

CC1

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FR

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?).

CC1

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GB

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

103



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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LT

-

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RO

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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SE

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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CC5

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CC6

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http://www.kvvm.hu/olm/docs/2011_automata_ertekeles.pdf

http://oki.wesper.hu/files/levego/Levegominoseg_LHI.pdf

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SEG 21/22 Information Request Responses

Table 54: SEG 21/22 – Information Request Responses


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

CC1

Equip & Facilities

CC2

Ops & Maintenance

CC3

Data Gen & Compil

CC4

Report & Admin

CC5

Staff Time

CC6

Capacity Dev

CZ

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.

CC1

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DE

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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GB

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.irceline.be/~celinair/english/abindex_en.html

http://www.ilmanlaatu.fi/

http://www.ilmanlaatu.fi/ilmansaasteet/indeksi/indeksi.php

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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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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).

CC1

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HU

-

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Data Gen & Compil

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Report & Admin

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LT

-

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RO

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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SE

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


http://zrak.mzoip.hr/


106




CZ

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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DE

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FI

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.

CC1

Equip & Facilities

CC2

Ops & Maintenance

CC3

Data Gen & Compil

CC4

Report & Admin

CC5

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Capacity Dev

GB

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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CC1

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HU

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Report & Admin

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LT

-

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RO

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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SE

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 ([email protected])

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

mailto:[email protected]

109



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

110



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


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


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.


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.


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


is appropriate?

Yes No

Comments:

Question 2.2: Does your Member State currently relate its air quality plans with zones?

Yes No

Description:



Comments:

112



SEG Recommendation 4: Reduce assessment reporting for standards that are largely met.


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.



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)



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:



Comments:

SEG Recommendation 5: Clarify the definition of the risk of exceedence





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.


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.



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)



is appropriate?

Yes No

Comments:



Comments:

114



SEG Recommendation 7: Reduce the administrative burden regarding the development of

short-term action plans





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.


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.



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



is appropriate?

Yes No

Comments:



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.


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

115



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.


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.


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.


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


Comments:

SEG Recommendation 10: Promote MS developing national or regional air quality strategies or

plans


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.


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).



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)


Question 10.1: Do you feel our qualitative judgement on the implication of this SEG


Yes No

Comments:



Comments:

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SEG Recommendation 20: Require that the public is informed about exceedence of Limit

Values as soon as they occur.


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.


Recommendation 20(a): Add a provision requiring Member States to inform the public as soon as a

Limit Value is being exceeded.


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)




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

118



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


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.


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.


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)

119



provided by EEA

SEG Recommendation 21 & 22 Questions



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


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

120



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



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

121



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



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 -

122





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.


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%

123



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.



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



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 -



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

124



exceedances. Therefore we do not favour any new activities in this context.



IE -

SEG Recommendation 7: Reduce the administrative burden regarding the development of

short-term action plans



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 -



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.



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.



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.”

125



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


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.


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



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 -

126





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.



IE -

Recommendation 20: Require that the public is informed about exceedence of Limit Values as

soon as they occur.



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/




http://www.irceline.be/

http://www.vmm.be/

http://www.ibgebim.be/

http://193.190.182.213/WebAirQuality/accueil.aspx


http://www.vmm.be/



127



Limit Value Yes Belgium : http://www.irceline.be/




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


http://www.vmm.be/



http://portal.chmi.cz/files/portal/docs/uoco/web_generator/svrs/svrs_PM10_1_CZ.html




http://portal.chmi.cz/files/portal/docs/uoco/web_generator/exceed/index_CZ.html

http://portal.chmi.cz/files/portal/docs/uoco/web_generator/exceed/index_CZ.html

http://uk-air.defra.gov.uk/latest/


http://www.epa.ie/whatwedo/monitoring/air/reports/



128



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



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/




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 - -


http://www.vmm.be/



http://portal.chmi.cz/portal/dt?portal_lang=en&nc=1&menu=JSPTabContainer/P1_0_Home

http://portal.chmi.cz/portal/dt?portal_lang=en&nc=1&menu=JSPTabContainer/P1_0_Home

http://uk-air.defra.gov.uk/forecasting/

http://www.epa.ie/whatwedo/monitoring/air/index/


129



DE - -

GB - -

IE - -

Question 21/22.5: Do you have any comment on this SEG Recommendation going forward


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 -

130



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

131




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

132




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

133



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.


The Department of Labour Inspection (DLI), and Ministry of Labour and Social Insurance (MLSI).

http://www.airquality.dli.mlsi.gov.cy/

Czech Republic

Index.


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

















134





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.


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.


















http://oki.wesper.hu/

http://www.kvvm.hu/olm/info.php?lang=en&id=6






135





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.


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

http://www.meteo.lv/pakalpojumi/gaisa-kvalitates-informacija/gaisa-kvalitates-merijumu-dati/?nid=540&cid=1034










http://193.219.133.8/ap3/292/

http://193.219.133.8/ap3/292/

http://193.219.133.8/ap3/292/

http://193.219.133.8/ap3/292/














http://sojp.wios.warszawa.pl/?par=2

136





(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









http://www.qualar.org/INDEX.PHP?page=1
























137





United Kingdom

Index. Latest measurement page contains clear alerts.

Department for Environment, Food and Rural Affairs.






138



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

139



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.

140



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

http://www.airqualitynow.eu/

141



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

142



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.

143



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)


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

/









http://www.klab.ee/seire/airviro/api.html

http://www.klab.ee/seire/airviro/api.html



144



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


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/












http://193.219.133.8/ap3/292/

http://193.219.133.8/ap3/292/

145



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


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










http://www.malopolska.pl/Obywatel/EKO-prognozaMalopolski/Malopolska/Strony/default.aspx







146



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=





http://airnow.gov/

http://airnow.gov/index.cfm?action=airnow.canada



http://www.ec.gc.ca/cas-aqhi/default.asp?Lang=En



147



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.


http://www.epd-asg.gov.hk/

http://www.epd-asg.gov.hk/

http://www.semc.com.cn/home/index.aspx

http://www.semc.com.cn/home/index.aspx

http://airqualitynow.eu/

149



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.

http://www.airqualitynow.eu/

150



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.

151



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,

152



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 [email protected]

W www.ecorys.nl

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