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Review of the National Air Pollution Control Programme – Denmark

___________________________________________________ Final Report for European Commission – DG Environment Specific contract 070201/2018/791186/SER/ENV.C.3

ED 11495 | Issue Number 3 | Date 06/03/2020

Review of the National Air Pollution Control Programme – Denmark | i

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Date:

06 March 2020

Ricardo Energy & Environment reference:

Ref: ED11495 - Issue Number 3

Review of the National Air Pollution Control Programme – Denmark | ii



Table of contents

1 Introduction ................................................................................................................ 1

Review of the National Air Pollution Control Programmes ................................................ 1

Methodology ...................................................................................................................... 2

NAPCP submission documents ........................................................................................ 3

2 Projected compliance with NECD emission reduction commitments .................... 5

Margin of compliance ........................................................................................................ 5

Projected compliance and consistency with projections submitted under Article 10(2) .... 6

3 Findings of the in-depth NAPCP review ................................................................. 11

NAPCP overview (M) ...................................................................................................... 11

Executive summary (O) ................................................................................................... 11

The national air quality and pollution policy framework (M, O) ....................................... 11

Progress made by current PaMs in reducing emissions and the degree of compliance with

national and EU obligations, compared to 2005 (M, O) .............................................................. 12

Projected situation assuming no change in currently adopted PaMs (M, O) .................. 14

Policy options considered to comply with emission reduction commitments for 2020 and

2030, intermediate emission levels for 2025 and stakeholder consultation (M, O) .................... 15

The policies selected for adoption by sector including timetable for adoption,

implementation and review and responsible competent authority (M, O) .................................. 19

Projected combined impacts of PaMs on emission reductions, air quality and the

environment and associated uncertainties (where applicable) (M, O) ....................................... 21

4 Conclusions and recommendations ....................................................................... 24

Conclusions ..................................................................................................................... 24

Recommendations .......................................................................................................... 25

Appendices

Appendix 1 Completeness assessment

Appendix 2 Assessment of the risk of non-compliance

Review of the National Air Pollution Control Programme – Denmark | iii



Abbreviations

BaP Benzo(a)pyrene

BAT Best Available Technique

BC Black Carbon

CH4 Methane

CO2 Carbon dioxide

EEA European Environment Agency

EU European Union

GHG Greenhouse Gas

kt Kilo tonne

NAPCP National Air Pollution Control Programme

NECD National Emission reduction Commitments Directive (Directive (EU) 2016/2284)

NECP National Energy and Climate Plans

NH3 Ammonia

NMVOC Non-Methane Volatile Organic Compounds

NO2 Nitrogen dioxide

NOx Nitrogen oxides

O3 Ozone

PaMs Policies and Measures

PM10 Particulate matter 10 micrometres or less in diameter

PM2.5 Particulate matter 2.5 micrometres or less in diameter

RAG Red; Amber; Green [rating]

SO2 Sulphur dioxide

WAM With Additional Measures

WHO World Health Organisation

WM With Measures

Review of the National Air Pollution Control Programme – Denmark | 1



1 Introduction

Review of the National Air Pollution Control Programmes

1.1.1 This report

The following report presents the results of the review of the National Air Pollution Control Programme

(NAPCP) submitted to the European Commission by Denmark on 1 April 2019.

EU Member States are required to prepare and report their NAPCP according to the minimum content

and common format (Commission Implementing Decision (EU) 2018/1522)1 stipulated by Article 6 of

the Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants2,

hereafter referred to as the Directive or the NECD3. The NAPCP should demonstrate compliance with

the Member State’s respective emission reduction commitments and set out how compliance will be

achieved.

This review has been undertaken alongside a review of national air pollutant emission projections

developed and reported by Member States under Article 10(2) of the NECD. These reviews have been

commissioned by the European Commission as Service Request 2 under the Framework Contract No

ENV.C.3/FRA/2017/0012 (specific contract 070201/2018/791186/SER/ENV.C.3).

The review of the first NAPCPs and of the air pollution projections with regards to their fulfilment of the

requirements of the NECD will both contribute to the Commission’s reporting on the implementation of

the NECD required under Article 11 of the NECD. This report feeds into the horizontal review report

under the contract which presents conclusions and recommendations from the review at the EU-level.

The horizontal report also contains, for each Member State, an assessment of its risk of non-compliance

with its emission reduction commitments, based on a cross-analysis of the information provided in the

NAPCPs and projection submissions under Article 10(2) of the NECD. This risk assessment is also

presented in Appendix 2 to the present report, while details on the methodology for that complete

assessment are found in the horizontal report.

1.1.2 Objectives of the NAPCP review

The purpose of the following report is to determine Member State compliance with the requirements of

the NECD. The scope of the NAPCP review includes:

The use of the NAPCP common format.

NAPCP compliance with the minimum content requirements of the Directive (mandatory content

(M)).

The extent to which the optional content requirements (O) of the Directive are reported and what

added value this brings to the quality of the NAPCP.

Consistency between the NAPCP and the information in the air pollutant emission projections

that were due to be submitted by Member States by 15 March 2019.

The extent to which Member States are reliant on additional PaMs (as included in the ‘With

Additional Measures’ (WAM) scenario) to achieve compliance.

1 Commission Implementing Decision (EU) 2018/1522 of 11 October 2018 laying down a common format for national air pollution control

programmes under Directive (EU) 2016/2284 of the European Parliament and of the Council on the reduction of national emissions of certain

atmospheric pollutants, OJ L 256, 12.10.2018, p. 87.

2 Directive (EU) 2016/2284 of 14 December 2016 on the reduction of national emissions of certain atmospheric pollutants, amending Directive

2003/35/EC and repealing Directive 2001/81/EC, OJ L 344, 17.12.2016, p.1.

3 Directive (EU) 2016/2284 repeals and replaces the previous National Emission Ceilings Directive (2001/81/EC) and is generally referred to as the

new NECD or simply the NECD.




The extent to which the evidence provided on selected PaMs is robust and the level of confidence

it provides that the Member States will achieve their 2020 and 2030 emission reduction

commitments.

The extent to which additional PaMs are put forward in view of wider air quality objectives as

set out in Article 1(2) of the NECD (referring to the objectives of the Ambient Air Quality Directives,

the Union’s long-term objective of achieving levels of air quality in line with the air quality guidelines

of the World Health Organisation (WHO), the Union’s biodiversity and ecosystem objectives

and coherence with climate and energy policy priorities).

The degree of coherence with other plans and programmes in other policy areas,

predominantly the National Energy and Climate Plans (NECP).

Methodology

The key components of the review process are outlined in Figure 1-1. A comprehensive description of

the process, methodology and checks followed are detailed in accompanying review guidelines which

were provided to the NAPCP reviewers responsible for conducting this report.

Figure 1-1 Overview of the NAPCP review methodology

A central review team was used to conduct the initial screening checks. The purpose of the initial

screening was to document Member State submissions in one central data log. For example, the

information recorded includes the date, language and length of the NAPCP submission; accompanying

annexes are similarly reviewed and logged and links to external websites are checked. The initial

checks also record if the Member State uses the NAPCP common format.

The completeness assessment and in-depth review checks are structured according to the section

headings of the NAPCP common format. Together, the review findings inform the extent to which the

NAPCP is compliant with the minimum content requirements, the extent to which evidence is robust

and the level of confidence that the Member State will achieve its commitments.

NAPCP completeness is rated according to a RAG rating (Red, Amber, Green rating as described in

Appendix 1) while the in-depth checks involve a series of questions with pre-defined responses to be

chosen from, designed to systematically determine the robustness and reliability of the evidence

submitted.




NAPCP submission documents

An overview of the Member State’s NAPCP is presented in the table below. This information was

gathered as part of the NAPCP initial screening.

Table 1-1 Overview of the Member State NAPCP submission documents

Initial screening check Response Additional comment

Was the NAPCP submitted by

1 April 2019?

Yes A complete and final version of the initial NAPCP

was submitted on 1 April 2019.

Was the common format used? Partially The structure of the common format was used but

the numbering of the respective sections is not

aligned.

What is the length of the

NAPCP?

75 pages

What language is the NAPCP

reported in?

English

What language is the

supporting documentation

reported in?

Danish

How many external documents

are referenced or provided in

the NAPCP?

Two

Is it possible to identify the

required information in the

external documents (i.e. is the

page and chapter reference

provided)?

Partially All external documents are referenced but page

and chapter numbers are not provided.

Can all external documents be

accessed?

Yes All external documents are publicly available.

Completeness assessment

A completeness assessment was conducted to identify gaps in reporting according to the minimum

content requirements of the common format (Commission Implementing Decision (EU) 2018/1522).

The completeness assessment also reviewed the extent of reporting of optional content by the Member

State. The results show a few gaps in Member State reporting, as presented in Appendix 1 to this

review. To summarise, the Danish NAPCP includes the minimum content required for the following:

Policy priorities for emission reductions and other relevant policy priorities and the responsible

authorities involved (table 2.2.1 of the NAPCP).

Progress made by current PaMs in reducing emissions and improving air quality is described by

the Member State together with transboundary impacts (tables 2.3.1, 2.4.2 and 2.4.3 of the

NAPCP).

Projected emissions and emission reductions with existing measures and their projected impact on

improving air quality (tables 2.5.1 and 2.5.2.1 of the NAPCP).




Additional PaMs considered and selected PaMs for adoption have been reported by the Member

State using the EEA PaM-tool; the Member State provides the minimum content for this reporting

requirement (tables 2.6.1 - 2.6.4 and table 2.7 of the NAPCP).

Projected emissions and emission reductions with additional measures (table 2.8.1 of the NAPCP).

The completeness assessment found that the projected impact on improving air quality under a WM

scenario did not cover all potentially relevant air quality pollutants. The NAPCP reports current

challenges with O3 but not any projected impacts.

According to the minimum content of the common format, the Member State is required to provide an

explanation to justify where a non-linear trajectory is followed in the NAPCP projections under the WAM

scenario. The NAPCP projections indicate that SO2 emissions will increase under the WAM scenario

towards 2025 and for NH3 the NAPCP projections assume no reductions in emissions until 2025, thus

in both cases a linear downwards trajectory is not followed. The NAPCP does not include an explanation

to justify a non-linear trajectory.

Denmark has reported some of the optional content from the NAPCP common format including:

The use of graphics to portray current progress achieved (table 2.4.2 of the NAPCP) and projected

impact on air quality improvements (table 2.5.2.1 of the NAPCP).

An account of the uncertainties associated with the NAPCP WM projections (table 2.5.1 of the

NAPCP).

Additional pollutants expected to benefit from the additional PaMs considered (table 2.6.1 of the

NAPCP).

An overview of the optional measures relating to agriculture that have been adopted (with reference

to Annex III, Part 2 of the NECD) (table 2.6.3 of the NAPCP).

An explanation for the PaMs selected for adoption in the NAPCP (table 2.6.4).




2 Projected compliance with NECD emission

reduction commitments

Margin of compliance

There are several different metrics that can be used to show the “margin of compliance” i.e. the margin

by which compliance with the NECD emission reduction commitments is achieved or missed.

The following two approaches have been used in the overall assessment of NAPCPs and projections

to calculate the margin of compliance:

1. Calculating the difference between an emission reduction commitment and the

projected emission reductions (difference expressed in percentage points) – this

approach is presented in the NAPCP review reports and follows the same approach as required

in the NAPCP format. The emission reduction commitments specified in Annex II of the NECD

are defined as percentage reductions on the 2005 emissions. Projected emissions of pollutants

in 2020 and 2030 are compared to the 2005 emissions to calculate the projected emission

reductions. These projected reductions are then divided by the 2005 emissions to obtain the

projected reductions as a percentage of the 2005 emissions. These percentage reductions are

then compared to the legally binding percentage reduction, with the difference between them

representing the compliance margin expressed as percentage points. As such, negative

percentage points indicate that the emission reduction commitment will not be met.

Figure 2-1 The margin of compliance

Example

A Member State emitted 500 kt of a pollutant in 2005 and had a 20% emission reduction commitment

for 2020. If the 2020 projected emission is 360 kt, the projected emission reduction is 140 kt. This

equates to 28% of 2005 emissions. The projected margin of compliance is 8 percentage points. This

is illustrated in the figure below.

200

250

300

350

400

450

500

550

2005 2010 2015 2020

Emission reduction commitment

(% of 2005 emission)

Compliance margin

Compliance threshold




2. Calculating the difference between projected emissions and the compliance threshold

(expressed as a percentage of the compliance threshold) – this approach is presented in

the projections review reports and follows the same approach as used in the context of

emissions inventories.

Given that each emission reduction commitment specified in Annex II of the NECD is defined

as a percentage reduction on the 2005 emissions, these two values can be combined to

express a “compliance threshold” i.e. the maximum emission that can be emitted by a Member

State from 2020 and 2030 onwards, and still be compliant with the emission reduction

commitment for a pollutant. Projected emissions (under the WM and WAM scenarios) can be

compared to the compliance threshold, and the compliance margin expressed as a percentage

of the compliance threshold.

Example

A Member State emitted 500 kt of a pollutant in 2005 and had a 20% emission reduction commitment

for 2020. The maximum the Member State can emit in 2020 to achieve its 2020 emission reduction

commitment (the “compliance threshold”) is 400 kt. If the 2020 projected emission is 360 kt, the

commitment will be met by 40 kt and the projected margin of compliance is 10% of the compliance

threshold.

Mathematically these two approaches are different as they use different reference points. However,

they yield the same conclusions concerning compliance or non-compliance with the NECD

reduction commitments. The largest numerical differences between the two approaches occur when

there are significant differences between the 2005 emissions and the projected emissions for 2020 or

2030 (this is in particular the case for SO2).

The percentage point approach is used in the review of the NAPCP to understand the margin of

compliance between the projected emission reductions presented in the NAPCP and the legally binding

percentage emission reduction commitments (see Section 2.2 of this report).

The results of the projections review and of the assessment of the NAPCPs are brought together in the

risk assessment for individual Member States (see Appendix 2 of this report), using the margin of

compliance expressed as a percentage of the compliance threshold based on projections submitted

under Article 10(2). The methodology for assessing the risk of non-compliance is explained in the

accompanying horizontal review report.

Projected compliance and consistency with projections

submitted under Article 10(2)

According to the WM projections presented in the NAPCP (table 2.5.1 of the Danish NAPCP),

the 2020-29 national commitments for NOx, NMVOC and SO2 are projected to be achieved. For

2030 onwards, only NOx and NMVOC are projected to meet the corresponding commitments. In

this scenario, the NOx commitments will be met by 2 and 1 percentage points for 2020-29 and

2030 onwards, respectively.

With additional measures (WAM scenario, table 2.8.1 of the Danish NAPCP), the 2020-29 and

2030 onwards emission reduction commitments for NH3 and PM2.5 are projected to be missed.

NOx, NMVOC and SO2 national emission reduction commitments are projected to be achieved

for both 2020-29 and 2030 onwards. The additional PaMs are expected to increase the margin

of compliance for NOx. The SO2 2030 onwards commitment is projected to be achieved by 1

percentage point.




The projections presented in this section are derived from the information reported by the Member State

in their NAPCP. The Danish NAPCP includes projections dated December 2018 based on historical

inventory data from 2016. These are the same projections as submitted separately by Denmark under

Article 10(2) of the NECD on 15 March 2019.4 In Figure 2-2 and Figure 2-3, the emission reductions

needed for 2025 are interpolated according to the 2020-29 and 2030 onwards commitments set out in

the NECD. Additional information is included to demonstrate the extent to which the projections meet

the Member State commitments (shown, for each of the pollutants, as the difference expressed in

percentage points between the projected emission reduction described in the NAPCP and the legal

commitment). The percentage points do not represent the extent to which total emissions projected

(kt) compare to the emission reduction commitment (in terms of kt of emissions).

Under the WM scenario, progress towards the 2020-29 emission reduction commitments is as

follows:

SO2 – The projections of SO2 emissions under the WM scenario show that Denmark can comply

with the 2020-29 reduction commitments specified in the NECD with existing measures. In 2020,

compliance with the emissions reduction commitments is projected to be achieved with a margin of

24 percentage points.

NOx – The projections of NOx emissions under the WM scenario show that Denmark can comply




NMVOC – The projections of NMVOC emissions under the WM scenario show that Denmark can

comply with the 2020-29 reduction commitments specified in the NECD with existing measures. In

2020, compliance with the emissions reduction commitments is projected to be achieved with a

margin of 8 percentage points.

NH3 – The projections of NH3 emissions under the WM scenario show that Denmark cannot comply


compliance with the emissions reduction commitments is projected to be missed with a margin of


PM2.5 – The projections of PM2.5 emissions under the WM scenario show that Denmark cannot

comply with the 2020-29 reduction commitments specified in the NECD with existing measures. In

2020, compliance with the emissions reduction commitments is projected to be missed with a


Under the WM scenario, progress towards the 2030 onwards commitments is as follows:

SO2 – The projections of SO2 emissions under the WM scenario show that Denmark cannot comply

with the 2030 onwards reduction commitments specified in the NECD with existing measures. In


margin of 6 percentage points. Furthermore, between 2020 and 2030, SO2 emissions are projected

to increase by 6% compared to the 2005 baseline (1,490 kt).

NOx – The projections of NOx emissions under the WM scenario show that Denmark can comply


4 The 2005 baseline emissions data for NMVOC is different between the two projections with a difference of 2 kt (107 kt compared with 109 kt for

the NAPCP projections). The reason why is unclear from the information reported; however, the difference does not affect Denmark’s projected

compliance with its national emission reduction commitment for this pollutant.





margin of 1 percentage point.

NMVOC – The projections of NMVOC emissions under the WM scenario show that Denmark can

comply with the 2030 onwards reduction commitments specified in the NECD with existing

measures. In 2030, compliance with the emissions reduction commitments is projected to be

achieved with a margin of 9 percentage points.

NH3 – The projections of NH3 emissions under the WM scenario show that Denmark cannot comply




PM2.5– The projections of PM2.5 emissions under the WM scenario show that Denmark cannot

comply with the 2030 onwards reduction commitments specified in the NECD with existing


missed with a margin of 14 percentage points.

Denmark reports that there is a considerable margin of uncertainty associated with the projections which

may affect projected compliance with the 2020-29 or the 2030 onwards commitments. The uncertainty

is greatest for the projections up to 2030.

Figure 2-2 Projected attainment of emission reduction commitments (WM scenario used in the NAPCP)

Note: The extent to which the projections meet the Member State commitments is shown, for each of the pollutants,

as the difference expressed in percentage points between the projected emission reduction described in the

NAPCP and the legal commitment. A negative number indicates that the commitment is projected to be missed.

As the projections under the WM scenario demonstrate a gap in compliance with the Member State

NECD emission reduction commitments for certain pollutants, the Danish NAPCP includes projections

under a ‘With Additional Measures’ (WAM) scenario.




Under the WAM scenario, progress towards the 2020-29 emission reduction commitments is as

follows:

SO2 – The projections of SO2 emissions under the WAM scenario show that Denmark can comply

with the 2020-29 reduction commitments specified in the NECD with additional measures. In 2020,



NOx – The projections of NOx emissions under the WAM scenario show that Denmark can comply

with the 2020-29 reduction commitments specified in the NECD with additional measures. In 2020,



NMVOC – The projections of NMVOC emissions under the WAM scenario show that Denmark can

comply with the 2020-29 reduction commitments specified in the NECD with additional measures.

In 2020, compliance with the emissions reduction commitments is projected to be achieved with a


NH3 – The projections of NH3 emissions under the WAM scenario show that Denmark cannot


In 2020, compliance with the emissions reduction commitments is projected to be missed with a


PM2.5– The projections of PM2.5 emissions under the WAM scenario show that Denmark cannot


In 2020, compliance with the emissions reduction commitments is projected to be missed with a


Under the WAM scenario, progress towards the 2030 onwards commitments is as follows:

SO2 – The projections of SO2 emissions under the WAM scenario show that Denmark can comply

with the 2030 onwards reduction commitments specified in the NECD with additional measures. In


margin of 1 percentage point.

NOx – The projections of NOx emissions under the WAM scenario show that Denmark can comply

with the 2030 onwards reduction commitments specified in the NECD with additional measures. In



NMVOC – The projections of NMVOC emissions under the WAM scenario show that Denmark can

comply with the 2030 onwards reduction commitments specified in the NECD with additional


achieved with a margin of 10 percentage points.

NH3 – The projections of NH3 emissions under the WAM scenario show that Denmark cannot




PM2.5– The projections of PM2.5 emissions under the WAM scenario show that Denmark cannot




As was reported for the WM scenario, there is a considerable margin of uncertainty associated with the

projections under the WAM scenario.




Figure 2-3 Projected attainment of emission reduction commitments (WAM scenario) used in the NAPCP

Note: The extent to which the projections meet the Member State commitments is shown, for each of the pollutants,

as the difference expressed in percentage points between the projected emission reduction described in the

NAPCP and the legal commitment. A negative number indicates that the commitment is projected to be missed.

Further analysis related to the risk of non-compliance, taking into account the information provided in

both the NAPCP and the projections submissions, is presented in Appendix 2.




3 Findings of the in-depth NAPCP review

NAPCP overview (M)

The NAPCP was submitted in keeping with the deadline of 1 April 2019.

The common format was used but the numbering for the sections does not align.

The title of the programme and responsible authority are specified in table 2.1.1 of the NAPCP.

The NAPCP adheres to the common format specified by the Commission Implementing Decision (EU)

2018/1522, pursuant to Article 6 of the NECD. The NAPCP is made up of one main report of 75 pages

in length. The complete submission was made on 1 April 2019. PaMs were submitted via the EEA PaM-

tool on 1 April 2019.

Of the 12 external links provided in the NAPCP, all are in working order. References to supporting

documents are partially complete with page and chapter numbers not provided. External documents

referenced are publicly available and cover related policy documents and national legislation,

supporting national datasets, as well as signposting to the website where the NAPCP is published. A

reference is also included for a forthcoming report covering the costs of PaMs to reduce NH3 emissions;

however, as the report is still in preparation, no link is included in the NAPCP.

The title and responsible authority for the development of the Danish NAPCP is reported in accordance

with section 2.1 of the common format. An external weblink is provided to direct to a website hosting

the consultation documents for the NAPCP for Denmark.

The transboundary impact of air pollution is outlined in the NAPCP; however, there is no evidence of a

transboundary consultation being conducted.

Executive summary (O)

With reference to the optional content of section 2.2 of the common format, Denmark does not provide

an executive summary in its NAPCP.

The national air quality and pollution policy framework (M, O)

Air quality policy priorities are described and refer to emission sources including priorities for

wood burning stoves, vehicles, ships, and industry.

Denmark is working towards achieving a climate neutral society by 2050 which involves clean

energy through greater use of renewables in energy production, transport systems, industrial

processes and households.

It also includes a qualitative account of the national air quality priorities with respect to national

legislation and policies, international commitments and source specific national legislation for the

regulation of wood burning stoves, vehicles, ships, and industry. The NAPCP includes WHO data

relating to the impacts of air quality on human health in Denmark but does not outline the respective

WHO guideline values for air quality pollutants. The priority pollutants specified are NO2 and PM2.5. This

is consistent with the information reported by the EEA air quality country fact sheet5 for Denmark.

5 Air pollution country fact sheets 2018: https://www.eea.europa.eu/themes/air/country-fact-sheets/2018-country-fact-sheets [last accessed:

14/06/2019]

https://www.eea.europa.eu/themes/air/country-fact-sheets/2018-country-fact-sheets




However, the NAPCP review finds that O3 should also be stated among the policy priorities as

exceedances of the O3 target value are reported in the NAPCP.

Denmark describes the policy priorities for ETS and non-ETS sectors with regards to GHG reduction

targets up to 2020 and 2030. Beyond 2020, it refers to the EU climate and energy policy priorities up to

2030 and 2050 as outlined in a national energy agreement signed by the government in 2018 to achieve

a climate neutral Denmark by 2050. The agreement recognises the importance of clean energy for both

climate change and air pollution, describing how Denmark will contribute to EU efforts and how these

national efforts will be financed. The policy priorities concerning renewable energy are set out in the

2018 national energy agreement which includes renewable energy targets as stated in the Danish

NAPCP. Energy efficiency objectives are not among the relevant policy priorities outlined despite their

potential to contribute to emission reductions, notably in view of the expected increase in use of biomass

for power and heat generation and the fact that wood burning is the largest source of PM2.5 in Denmark.

However, the NAPCP does stress the need to develop better emission factors for small biomass-fired

combustion plants that are not subject to continuous measurements (section 2.5.1 of the NAPCP).

Denmark provides an overview of relevant policy priorities for transport, agriculture, household and

industry with respect to climate and air national policies.

The relevant authorities are reported in the NAPCP in accordance with the minimum content

requirements of section 2.3.2 of the common format. National government ministries are responsible

for policy making and policy implementation, while regional authorities are responsible for enforcement,

reporting and monitoring and supporting with implementation. The NAPCP review finds that the

involvement of national and regional authorities can facilitate a consistent approach between regions.

It also finds that the specific roles attributed to the regional authorities can strengthen implementation

through targeted support.

Optional reporting concerning the responsible authorities for specific source sectors is not provided by

Denmark.

Progress made by current PaMs in reducing emissions and

the degree of compliance with national and EU obligations,

compared to 2005 (M, O)

3.4.1 Progress made by current PaMs in reducing emissions

Challenges are identified as: PM2.5 (primarily from households and wood burning stoves but also

from road transport); NH3 (from agriculture); and NOx (from road transport and power plants).

Current PaMs and relevant existing EU legislation reported (table 2.3.1 of the NAPCP) include:

o clean fuel and the establishment of a scrappage system for old wood burning stoves

o improved livestock manure management relating to application techniques and storage

o the establishment of environmental zones in cities restricting vehicle access, setting

environmental and energy requirements for taxis and adopting technical solutions

o application of best available techniques by industry

In accordance with section 2.4.1 of the common format, an outline of key initiatives is reported relating

to current PaMs and relevant EU legislation adopted between 1990 and 2016. Progress is reported in

relation to the current challenges in Denmark which are reported as: PM2.5 (primarily from households

and wood burning stoves but also from road transport); NH3 (from agriculture); and NOx (from road

transport and power plants).




The current PaMs and relevant EU legislation are described individually according to the NECD

pollutants. The impacts of the existing PaMs are described between 1990 and 2016 and graphics are

used to illustrate pollutant emissions over the stated time period.

The key initiatives reported include:

The use of cleaner fuel and the establishment of a scrappage system for old wood burning stoves

(targeting household energy consumption to reduce PM2.5).

Improved livestock manure management relating to application techniques and storage (targeting

the agriculture sector and NH3).

The establishment of environmental zones in cities restricting vehicle access, setting environmental

and energy requirements for taxis and adopting technical solutions (the requirement for new petrol

vehicles to be fitted with catalytic converters in 1990 is highlighted for significantly reducing NOx

emissions from the transport sector).

The application of emission standards for small and medium combustion plants as well as industry

compliance with best available technique conclusions under the Industrial Emissions Directive.

Current PaMs targeting NH3, PM2.5 and black carbon are also reported, as set out in Annex III, Part 2

of the NECD. This includes a ban on burning of agricultural residues and practices to reduce NH3

emissions from the application of manure and slurry spreading and its storage.

3.4.2 Progress made by current PaMs in improving air quality

In accordance with section 2.4.2 of the common format, Denmark provides an outline of progress made

by current PaMs on improvements to air quality, generally reporting that concentrations of air pollutants

under the Ambient Air Quality Directive are below the respective standards6. Exceedances of the EU

target value for O3 are reported for three urban background locations and concentrations of VOCs in

urban background areas were relatively high. It is reported that a major proportion of O3 is caused by

long-range transportation of air pollution from central and southern parts of Europe. While

concentrations for PM are below the limit values in Denmark, the NAPCP includes additional information

to demonstrate progress achieved for ultrafine PM as well as for PM10 and PM2.5, indicating a 40%

decrease in the number of particles with a diameter between 41 and 550 nm between 2002 and 2016.

The PaMs are described at an individual level with respect to emission reductions and contributions to

air quality improvements achieved between 1990 and 2016 (table 2.3.1 of the NAPCP). Progress

achieved in terms of improvements to ambient air concentrations is described for the year 2017 only

(table 2.4.2 of the NAPCP). Maps are used to illustrate concentrations of the air quality pollutants.

3.4.3 Current transboundary impact of national emission sources

In accordance with section 2.4.3 of the common format, the Danish NAPCP includes a brief qualitative

outline of the impacts of transboundary air pollution accompanied by quantitative data to show the

primary receiving countries of SO2, NOx, NH3 and PM2.5 from Denmark. The North Sea and the Baltic

Sea are particularly affected, followed by Sweden.

The consultation undertaken as part of the development of the Danish NAPCP does not include

references to a transboundary consultation.

6 In the NAPCP, Denmark refers to the annual median rather than the annual average; however, based on the maps also provided, it is understood

that the Member State is compliant with the EU air quality standards and that the reported information is referring to the annual average of pollutant

concentrations.




Projected situation assuming no change in currently adopted

PaMs (M, O)

With existing measures (table 2.5.1 of the NAPCP), the 2020-29 national commitments for NOx,

NMVOC and SO2 are projected to be achieved.

For 2030 onwards, only NOx and NMVOC are projected to achieve the corresponding

commitments.

A high margin of uncertainty associated with the projections is reported in qualitative terms.

Projected impacts on air quality show that Denmark can comply with EU air quality objectives

under a WM scenario (table 2.5.2.1). The projections focus on PM2.5 and NO2 only and therefore

no conclusion can be drawn for the O3 target value.

As presented in Section 2.2 of this report, and in accordance with section 2.5.1 of the common format,

emission projections under a WM scenario for all NECD pollutants in 2020-29 and 2030 are reported in

the NAPCP compared with a 2005 base year.

Under the WM scenario, Denmark is projected to meet its 2020-29 and 2030 onwards national

commitments for NOx and NMVOC. For NOx, the emission reduction commitment for 2030 onwards is

projected to be achieved by 1 percentage point.

However, Denmark is projected to miss its NH3 and PM2.5 commitments for both 2020-29 and 2030

onwards with existing measures. The SO2 emission reduction commitment for 2020-29 is reported to

be achieved but for 2030 onwards is projected to be missed. Moreover, SO2 emissions are projected to

slightly increase between 2020 and 2030 by 6% compared to the 2005 baseline (1,490 kt).

A high margin of uncertainty associated with the projections is reported in qualitative terms7. The

greatest issue leading to the margin of error for Denmark relates to PM emissions and the lack of

information on wood burning by households and small biomass fired combustion plants. Uncertainties

relating to the transport sector are also reported owing to differences in real time emissions from

vehicles versus emission factors. For NH3, the projections assume a significant growth in the dairy

sector and number of livestock, subject to market uncertainties.

The information included in the NAPCP is based on projections developed in 2018. The projections are

up to date to capture the majority of current PaMs, using 2016 as the latest historical year available.

Among the current PaMs listed, the following were implemented in 2017, indicating that their impact will

be projected rather than reported in the inventory emissions data: adoption of best available techniques

(BAT) by industry (concerning medium combustion plant, power plants and intensive rearing of poultry);

standards to regulate domestic stoves; and a ban on pet coke.

In accordance with section 2.5.2. of the common format, Denmark demonstrates the expected extent

of compliance with EU air quality objectives under a WM scenario. However, the projections focus on

PM2.5 and NO2 only and therefore no conclusion can be drawn for O3. It is considered that projections

for concentrations of O3 would be useful in light of the challenges reported previously under current

progress for this pollutant as a result of long-range transboundary pollution.

The quantitative data provided considers developments in the exposure indicator for PM2.5 and NO2

concentrations in various Danish cities, showing that reductions in exposure and in pollutant

concentrations are projected for 2020 and by 2030. Compliance with the corresponding EU air quality

7 The uncertainties associated with emission developments up to 2030 exclude NOx and NMVOC emissions from livestock and agricultural land

and relate to particulate matter (more widely than PM2.5). As such, the emission reductions between 2005 and 2030 shown in table 2 of the NAPCP

are different to the emission reductions for the same time period shown in table 2.5.1. The emission reductions in table 2.5.1 are referred to for the

review of the NAPCP.




limit standards is projected for the pollutants and areas considered. Both the qualitative description and

the quantitative data provided are consistent.

Policy options considered to comply with emission reduction

commitments for 2020 and 2030, intermediate emission

levels for 2025 and stakeholder consultation (M, O)

Denmark has considered 5 individual PaMs and 1 package of 11 PaMs for adoption.

PaMs considered target pollutants with the greatest compliance gap with the emission reduction

commitments under the WM scenario: PM2.5 (seven PaMs), NH3 (six PaMs), and NOx emissions

(five PaMs), and to a lesser extent SO2 (two PaMs). No PaMs target NMVOC emissions.

The PaMs considered for NH3 and PM2.5 target sectors contributing the largest share of the total

emissions of these pollutants (agriculture and energy supply). No PaMs were considered for the

main sectors emitting SO2: combustion in industry, energy industries and non-industrial

combustion and industrial processes.

Expected emission reductions of PaMs considered for adoption have been reported for the

majority of the PaMs considered.

PaMs considered are coherent with the air quality and climate and energy policy priorities.

3.6.1 Summary of the information reported

The assessment presented in this section is based on the information reported via the EEA PaM-tool.

Where relevant, it is complemented with the information from the main body of the NAPCP.

Denmark has considered 5 individual PaMs and one package (Climate and Clean Air Package) of 11

PaMs. Six of these considered PaMs are in agriculture, three in energy supply and seven in the transport

sector.

The descriptions of PaMs are generally clear with sufficient detail to understand what the PaM will

involve and how the estimated emission reductions will be delivered. The type of policy instruments

most commonly include a combination of regulatory (nine), economic and fiscal (five), and voluntary

instruments (four). The mix of policy instruments with a focus on regulatory instruments is considered

suitable for delivering the emission reductions estimated.

Exceptions are as follows:

Insufficient detail is reported on the setting up of a committee on NH3 emission reduction measures.

The measure is expected to deliver a large share of the overall NH3 emission reductions projected,

with emission reductions estimated for the year 2020. The proposed implementation timescales

(2019-2022) together with the limited detail make the PaM less credible at this stage.

Among the PaMs considered, several concern the implementation of existing EU legislation (e.g.

the application of BAT, implementation of the Ecodesign Directive and emission limits to road

vehicles). It is unclear in these cases how the PaMs are additional.

Controls to limit sulphur emissions from shipping are beyond the scope of the NECD.




Agriculture (6 individual PaMs, 3 of which are part of the Climate and Clean Air Package)

NH3 emission requirements (use of Best Available Techniques and limit values) in

environmental permits for livestock farms

Reduced emissions from inorganic fertilisers

Other measures within agriculture (*) (targeting primarily greenhouse gas emissions,

including promoting of specific farming techniques, re-parcelling fund, set-aside scheme for

organic soil and climate research in agricultural field)

Setting up a committee on NH3 emission reduction measures (*)

Improved animal housing (*)

Improved management of manure

Energy supply (3 individual PaMs, one of which is part of the Climate and Clean Air Package)

Accelerated replacement of old wood burning stoves (*)

Campaigns for correct operation of stoves and subsidies for technology development

Maintaining existing emission limits for new wood burning stoves (the PaM assumes

continuation of the existing limit values for new wood burning stoves until 2022 when the new

limit values come into force through the implementation of the Ecodesign Directive).

Transport (7 individual PaMs which are part of the Climate and Clean Air Package)

Control of sulphur emissions from ships (*)

Last petrol car sold in 2030 (*)

Scrapping of old diesel cars (*)

Introduction of environmental zones in five largest cities in Denmark (*) (tighter emission

limits for diesel trucks, buses, and light goods vehicles within the zones)

Enforcement and control of trucks for correct installation of NOx treatment system (*)

Environmentally friendly cruise ships (*)

Green buses and taxis (*)

Note: the PaMs with (*) are part of the Climate and Clean Air Package. PaMs in bold have been selected

for adoption.

3.6.2 Pollutants targeted and projected emission reductions

Under the WM scenario (see Figure 2-2), additional measures are required to meet the emission

reduction commitment for PM2.5 and NH3 in 2020 and 2030, and for SO2 in 2030. The NAPCP review

also finds that additional PaMs targeting NOx, SO2 and NMVOCs would help to increase the margin of

compliance projected.




The PaMs considered target PM2.5 (7 PaMs), NH3 (6 PaMs), and NOx emissions (5 PaMs), and to a

lesser extent SO2 (2 PaMs). No PaMs target NMVOC emissions. Further pollutants affected by the

PaMs considered for adoption include CO2 (4 PaMs), BC (3 PaMs), PAHs (3 PaMs) and CH4 (2 PaMs).

Where quantified, the expected emission reductions achieved by the PaMs are expressed in kt/year. A

range has been reported in one instance concerning expected emission reductions for CO2. No

emission reductions were reported for NH3 emission requirements in environmental permits for livestock

farms. No reason was reported why and the NAPCP review finds that this is reporting gap. No emission

reduction was quantified for campaigns for the correct operation of stoves and subsidies for technology

development. This is justified given its nature (i.e. it is difficult to predict the emission saving from PaMs

concerning enforcement and behavioural change).

No emission reductions have been quantified at PaM level for the following PaMs forming part of the

Climate and Clean Air Package:

Control of sulphur emissions from ships

Other measures within agriculture

Improved animal housing

Enforcement and control of NOx fraud

Environmentally friendly cruise ships

Based on the reported information it is not possible to determine if emission reductions from these PaMs

are captured in the figures provided for the whole package.

For the remaining PaMs, emission reductions were either quantified at the level of the individual PaM

or for a group of PaMs. It is unclear how NH3 emission reductions have been estimated for setting up

the committee on NH3 emission reduction measures given that there is no clarity on the types of PaMs

that will be selected for adoption by the committee. Table 3-1 presents the total emission reductions

estimated for PaMs considered for adoption.

Table 3-1 Projected total emission reductions (kt/ year) from the PaMs considered for adoption

Pollutant 2020 2025 2030

NH3 12.2 12.2 12.2

PM2.5 0.4 0.9 3.1

NOx 0 2.8 20.6

SO2 Not estimated

NMVOC No PaMs considered

The PaMs considered target pollutants with the greatest compliance gap with the emission reduction

commitments. When comparing the total emission reductions estimated for PaMs considered for

adoption (Table 3-1) to the 2005 baseline, the PaMs considered expect to deliver the following emission

reductions in 2020, 2025 and 2030 (where estimated):

NOx: 1 percent in 2025 and 11 percent in 2030. Emission reductions were not estimated for 2020.

NH3: 14 percent in 2020, 2025 and 2030.

PM2.5: 2 percent in 2020, 3 percent in 2025 and 12 percent in 2030.

Given the emission reduction commitments for NH3 and PM2.5 for 2030 are projected to be missed, and

the commitment for SO2 will only just be met under the WAM scenario (see Section 2 of this report), as

well as uncertainties associated with the projections, the NAPCP review finds that further additional

PaMs should be considered by Denmark to reduce emissions of all five pollutants.




According to the information reported via the EEA PaM-tool, six PaMs have not been included in the

projection scenarios. This includes PaMs where no estimated emission reductions have been reported

(as described above) and four PaMs reported as part of the Climate and Clean Air Package, which

includes the setting up a committee on NH3 reducing measures. It is expected that the latter has been

excluded from the WAM owing to the uncertainties described above.

3.6.3 Coherence between the PaMs considered and policy priorities

The PaMs considered are aligned with the policy priority to facilitate cleaner fuel use in household

combustion and small combustion plant. All PaMs considered were also reported as relevant to the

AAQD. PaMs for transport and agriculture were also reported as relevant to the climate and energy

objectives.

The impact on air quality has been taken into account for all PaMs. All Danish air quality zones were

compliant with EU air quality objectives at the time of the NAPCP and so the impact of the PaMs

considered on air quality is not with respect to meeting EU air quality objectives. The impact on air

quality is considered for reduced concentrations of PM and decreases in nitrogen deposition; despite

reported exceedances of the EU target value for O3 in 2016, the impact of the PaMs on O3

concentrations is not reported. The PaMs considered under the Climate and Clean Air Package are

also expected to contribute to further decreases in nitrogen deposition.

3.6.4 Responsible authorities and timescales for implementation of PaMs considered

The PaMs considered include a range of policy instruments although regulatory instruments are the

most commonly described (with respect to agriculture, energy supply and transport sectors)

accompanied by voluntary campaigns, fiscal instruments and research.

The responsibility for implementation of the PaMs considered is attributed to authorities at the level of

national government only. This is aligned with the roles reviewed in Section 3.3.

Of the PaMs reported, one is only part of the WM scenario: implementation of campaigns for the correct

operation of stoves and subsidies for technology development. The implementation period for this PaM

began in 2017 and is ongoing. Two PaMs are reported as being in both WAM and WM scenarios. It is

unclear how these PaMs are additional to current PaMs as they are described as forming part of existing

initiatives.

Furthermore, two of the additional PaMs were implemented in 2018 (NH3 emission requirements (use

of Best Available Techniques and limit values) in environmental permits for livestock farms; and green

buses and taxis in cities). The PaMs are included in the WAM scenario projections which were

developed in 2018; however, they are not additional with respect to the NAPCP.

The remaining PaMs will be implemented in 2019 (eight) and 2020 (four). Implementation is generally

expected to span over 1 to 11 years (from 2020 up to 2030), which is in keeping with the projected

emission reductions. Implementation of the PaM to reduce emissions from inorganic fertilisers is

planned for the year 2019 only with estimated emission reductions reported up to the year 2030. It is

unclear from the description provided how this PaM will be implemented in such a short timescale and

deliver the estimated emission reductions.

3.6.5 Details of the methodology for evaluation and selection of PaMs

Denmark does not provide details of the methodology for the evaluation and selection of the PaMs

considered.

3.6.6 Estimation of costs and benefits of the individual PaM or package of PaMs

considered

Denmark reported costs for nine PaMs via the EEA PaM-tool. The total costs of the PaMs considered

for adoption is over EUR 89 million. The most expensive PaMs are in the agricultural sector




(establishment of a Committee on NH3 reducing measures and other measures within agriculture which

are planned to take effect from 2019); as well as the road transport sector (scrapping old diesel vehicles

which will be operational in 2019 and 2020). The costs (breakdown per year) and benefits of PaMs were

considered when the PaMs were selected for adoption, as reported in Table 2.6.4 of the NAPCP.

3.6.7 Impacts on air quality and the environment of individual PaMs or packages of

PaMs considered

The only information reported regarding air quality impacts of PaMs considered for adoption concerns

the Climate and Clean Air Package. The Package is expected to contribute to the decrease in nitrogen

deposition and emission of atmospheric pollutants particularly PM2.5 and emissions of substances

contributing to the formation of secondary particulate matter.

Denmark does not describe the impact of the PaMs considered with reference to the WHO guideline

values for air pollution.

The policies selected for adoption by sector including

timetable for adoption, implementation and review and

responsible competent authority (M, O)

Denmark has selected 15 PaMs for adoption across transport (7 PaMs), agriculture (5 PaMs)

and energy supply (3 PaMs).

Of the additional PaMs selected for adoption, the PaM with the largest impact on NH3 emissions

is the establishment of a national committee for NH3 emission reducing measures. However,

there is uncertainty whether the estimated emission reductions from the PaM will be realised in

practice within the required timescales.

Based on the evidence available, emission reductions estimated from the PaMs selected to

reduce emissions of PM2.5 appear realistic. The PaMs also tackle the largest contributor of BC

emissions (i.e. combustion in other sectors).

Only two PaMs have been selected for adoption to reduce SO2 emissions, neither includes any

estimation of emission reductions.

The NAPCP indicates that funding has been allocated to support implementation of each

selected PaM.

The PaMs adopted are coherent with climate and energy policy priorities.

3.7.1 Assessment of the credibility of the PaMs selected for adoption per sector

The NAPCP does not provide an explanation of the choices made to select PaMs for adoption. Instead

section 2.6.4. of the NAPCP provides additional description of each selected PaM.

Agriculture

The required agricultural measures listed in Annex III, Part 2 to the NECD are part of existing measures

already adopted and being implemented by Denmark. In the case of the optional measures listed,

Denmark reports that it has not established a national advisory code of good agricultural practices for

the proper management of harvest residue and no explanation is given why.

In relation to the other optional measures Denmark has established a national committee for NH3

emission reducing measures which is charged with formulating PaMs and allocating the necessary

funds for their implementation to ensure that the Member State will meet its national emission reduction

commitments for NH3. The PaM is expected to deliver emission reductions from 2020 onwards;




however, the short implementation period and the lack of detail reported in the NAPCP on the measures

to be selected by the committee reduce the credibility of this PaM.

Energy supply

Of the PaMs targeting energy supply, only one is considered by the NAPCP review to be additional:

support to replace old stoves. The PaM entered into effect on 4 February 2019 and will run until

December 2020 (or when the allocated funds are spent). The PaM description outlines the scale of the

PaM (in terms of allocated funds and the likely number of stoves which will be replaced as a result).

Estimated emission reductions are reported for PM emissions and are considered feasible in view of

the scale of activity and the implementation period.

The PaM will be accompanied by a regulation establishing limit values for new stoves and a voluntary

information campaign on the use of wood burning stoves in the domestic sector. The review finds that

both PaMs are existing rather than additional owing to the years they were implemented (2008 and

2017, respectively).

Transport

The PaMs targeting the transport sector are well described. The implementation periods are clearly

established, and the scale of operation and allocated funds are reported. However, of the seven

adopted, only two are assessed as relevant additional PaMs by the NAPCP review. These are the

scheme to scrap old diesel vehicles and the enforcement and control of measures to address NOx fraud.

The estimated emission reductions for these PaMs are considered appropriate in the given timescale.

The remaining five PaMs either concern existing PaMs (according to the implementation periods and

the descriptions reported) or existing EU initiatives (regarding Euro standards for vehicles). It is unclear

from the information reported how the estimated emission reductions for these PaMs will be additional

to current progress projected. Furthermore, two of the additional PaMs relate to the enforcement and

control of sulphur emissions from ships in Danish waters which is beyond the scope of the NECD.

3.7.2 PaMs selected for adoption

Denmark has selected 15 PaMs for adoption, although only 8 are additional according to the NAPCP

review. The PaMs excluded from adoption across the PaMs considered are:

Campaigns for correct firing and subsidies for technology development (energy supply sector) –

this PaM was adopted in 2017 and forms part of the WM projection scenario.

Improved management of manure (agricultural sector) – the decision to adopt this PaM will be taken

by the committee on ammonia reducing measures. As part of the preparation of the Climate and

Clean Air Package, measures concerning spreading of manure were considered but excluded due

to the potential burden on the industry. A dedicated committee is to investigate the PaMs that would

deliver the emission reductions required without affecting the competitiveness of the industry.

The projected emission reductions from PaMs selected for adoption is presented in Table 3-2.

Table 3-2 Projected total emission reductions (kt/ year) from the PaMs selected for adoption

Pollutant 2020 2025 2030

NH3 9.4 9.4 9.4

PM2.5 0.4 0.9 3.1

NOx Not estimated 2.8 20.6

SO2 Not estimated




Pollutant 2020 2025 2030

NMVOC No PaMs selected

PaMs selected for adoption target pollutants with the greatest compliance gap with the emission

reduction commitments. Compared to a 2005 baseline, the PaMs selected for adoption expect to deliver

the following emission reductions in 2020, 2025 and 2030 (where estimated):

NOx: 1 percent in 2025 and 11 percent in 2030. Emission reductions were not estimated for 2020.

NH3: 11 percent in 2020, 2025 and 2030.

PM2.5: 2 percent in 2020, 3 percent in 2025 and 12 percent in 2030.

Denmark does not indicate how progress in implementation of the selected PaMs will be monitored with

no indicators or targets defined by the NAPCP. No issues concerning the implementation of the selected

PaMs are identified in the NAPCP. The selected PaMs will be implemented by national government and

regional environmental protection agencies.

3.7.3 Feedback from the consultation undertaken

Denmark does not report on how the final selection of PaMs for adoption and the design of these PaMs

may be linked with the conclusions from the consultation.

3.7.4 Sources of funding

For each of the PaMs selected for adoption, the Danish NAPCP outlines how much funding has been

allocated to support implementation. It does not consistently specify which funding mechanisms or

sources will be used. The national committee for NH3 emission reducing measures will allocate funding

to any future additional PaMs selected to reduce NH3 emissions.

3.7.5 Coherence with plans and programmes set up in other relevant policy areas

The information in the NAPCP is limited to statements that the selected PaMs for adoption will contribute

to the improvement of air quality and that the Member State is already compliant with all air quality

targets. The PaMs are also intended to support wider national contributions for achieving the

international climate targets and targets for more extensive use of renewable energy.

Selecting the Danish Energy and Clean Air package of PaMs for adoption demonstrates that coherence

with climate and energy policies was considered when developing the NAPCP.

The PaMs included for the energy sector in the draft Danish NECP are broader ranging than those

described by the NAPCP (with regards to renewable energy initiatives which are not referred to by the

NAPCP). For transport, the additional PaMs selected by the NAPCP include those listed by the draft

NECP as well as PaMs relating to shipping and vehicle restrictions in cities. For agriculture, the PaMs

included in the draft NECP differ to those included in the NAPCP as they target mitigation potential

which can be achieved through research and innovation.

Projected combined impacts of PaMs on emission

reductions, air quality and the environment and associated

uncertainties (where applicable) (M, O)

Under the WAM scenario reported in the NAPCP, Denmark is projected to meet its 2020-29 and

2030 onwards national commitments for NOx, NMVOC and SO2. It is projected to miss the

respective commitments for NH3 and PM2.5 (table 2.8.1 of the NAPCP).

The additional PaMs reduce the risk of non-compliance for NOx.




A high margin of uncertainty associated with the projections is reported.

A linear trajectory is not followed for SO2 and NH3. An explanation is required according to the

minimum content of the NAPCP, but no information is provided in the NAPCP.

The selected PaMs are projected to improve air quality with regards to PM2.5 concentrations and

to further decrease nitrogen deposition (table 2.8.2 of the NAPCP).

3.8.1 Likelihood of achievement of projected emission reductions

According to the projections included in the NAPCP, emission reductions under the WAM scenario for

2020 and 2030 will not meet the NH3 and PM2.5 national emission reduction commitments in the NECD.

Denmark is projected to meet its 2020-29 and 2030 onwards national commitments for SO2, NOx and

NMVOC.

Uncertainties associated with the projected emissions are reported by Denmark and relate to:

PM emissions and the lack of information on wood burning by households and small biomass fired

combustion plants. Denmark reported that a more complete inventory on PM will be developed in

2019.

For NH3, the uncertainty in the projections relates to the fact that the detail of the chosen PaMs is

undefined (as explained in Section 3.6.1 of this report).

The uncertainties identified by Denmark pose a risk to the attainment of the emission reduction

commitments for all pollutants and their respective commitments for both 2020-29 and 2030.

Notwithstanding the margin of uncertainty reported by Denmark (as described in Section 3.5 of this

report), non-compliance is greatest for projected NH3 and PM2.5 emissions with respect to the 2020-29

commitments.

Conclusions from the NAPCP review on whether the projected emission reductions per pollutant are

likely to be realised in practice are presented in Table 3-3.

Table 3-3 Likelihood of achieving the projected emissions reductions (WAM scenario)

Do the PaMs selected for adoption

target the key emitting sectors?

Are the projected emission reductions for

2020 and 2030 likely to be achieved?

SO2 Partly.

PaMs adopted to reduce SO2 target

the shipping sector at open sea which

is beyond the remit of the NECD (but

might have some relevance for

compliance with AAQD limit values).

No.

Emission reductions are not estimated for

SO2. As such, the credibility of the projected

emission reductions cannot be assessed.

Furthermore, any emission reductions

achieved by the PaMs described will not affect

compliance with the emission reduction

commitment because only emissions from

inland shipping are relevant under the

Directive.

NOX Yes.

PaMs are adopted targeting the

transport sector which is a key source

of NOx in Denmark.

Yes

The NOx emission reduction commitments are

projected to be achieved under the WM

scenario.

Under the WAM scenario, further estimated

emission reductions are projected as a result




Do the PaMs selected for adoption

target the key emitting sectors?

Are the projected emission reductions for

2020 and 2030 likely to be achieved?

of the PaMs adopted. While these reductions

are likely to be achieved, the NAPCP review

finds that the PaMs are not additional and

therefore the estimated emission reductions

should be reported under the WM scenario.

NMVOC N/A

Denmark is projected to meet the

emission reduction commitments for

NMVOC under a WM scenario.

Additional PaMs are not required or

considered.

N/A

NH3 Yes.

PaMs target the agriculture sector as

the key source of NH3.

No.

Estimated emission reductions associated

with the establishment of the NH3 emission

reduction committee are unlikely to be

achieved in the reported timescale as the type

and scale of action is not defined.

PM2.5 Yes.

Emissions from combustion in the

domestic sector is a key source of PM

in Denmark. Support to replace old

stoves will reduce emissions from this

source.

Yes.

Estimated emission reductions are considered

likely in view of the scale of the PaM and the

available funds to support it. The existing

supporting information and regulatory policy

instruments will facilitate.

This analysis of the credibility of the PaMs in achieving emission reductions has also been used in the

assessment of the risk of non-compliance, presented in Appendix 2.

3.8.2 Deviation from the linear trajectory for 2025

According to section 2.8.2 of the common format, where a non-linear trajectory is followed by pollutants

under the WAM scenario, the Member State is required to explain why. The projections reported by

Denmark demonstrate that SO2 emissions will increase under the WAM scenario towards 2025. Thus,

a linear trajectory is not followed. However, no explanation is provided to explain why this is the case.

3.8.3 Use of flexibilities

With reference to section 2.8.3 of the common format, Denmark has not reported any information with

regard to the use of flexibilities.

3.8.4 Projected impacts on air quality and the environment.

With reference to section 2.8.4 of the common format, Denmark reports that the selected PaMs are

projected to improve air quality with regards to PM2.5 concentrations and to further decrease nitrogen

deposition (table 2.8.2 of the NAPCP). The Member State reports that it expects to comply with EU air

quality standards; however, there is no evidence provided to support this statement and there is no

analysis to show how the selected PaMs will contribute to improvements in air quality and in particular

for O3 (where challenges have been identified in current progress reported by the Member State).




4 Conclusions and recommendations

Conclusions

Denmark submitted its NAPCP on 1 April 2019, meeting the NECD deadline. The NAPCP follows the

structure of the common format established by the Commission Implementing Decision (2018/1522)

but it does not use the same numbering for the tables.

The minimum content is generally provided for all aspects of the NAPCP. The omissions observed have

limited impact on the overall completeness of the NAPCP, as follows:

The information reported in section 2.4.3 of the NAPCP indicates that domestic emissions of

Denmark have a transboundary impact but there is no evidence that a transboundary consultation

was undertaken for the development of the NAPCP (section 2.1.1 of the NAPCP).

For air quality, O3 is identified as a challenge under current progress (section 2.4.2 of the

NAPCP). The projected impacts of current PaMs on improving air quality only includes NO2 and

PM2.5 (section 2.5.2.1 of the NAPCP) while projected impacts of additional PaMs only refers to

PM2.5 (section 2.8.2 of the NAPCP). The lack of information for O3 is considered a gap in

reporting.

An explanation for the use of a non-linear trajectory is required but missing for SO2 where a linear

trajectory of emissions reductions is not reported between 2020 and 2030 (under the WAM

scenario).

The NAPCP identifies a gap in compliance with the Member State NECD emission reduction

commitments with existing PaMs (WM scenario). Thus, additional PaMs are considered and selected

for adoption in the NAPCP.

The analysis of the additional PaMs considered and selected for adoption has demonstrated that:

The PaM with the largest expected impact on NH3 emissions is the establishment of a national

committee for NH3 emission reducing measures. It is highly unlikely that the committee will be

able to achieve the estimated emission reductions within the required timescales because the

specific planned actions remain undefined in the NAPCP.

PaMs targeting PM2.5 emission reductions have been considered for the household and the road

transport sectors which are the largest contributors to emissions of PM2.5. Emission reductions

estimated from the PaMs selected to reduce emissions of PM2.5 appear realistic. The PaMs also

tackle the largest contributors of BC emissions.

Only two PaMs selected for adoption are expected to reduce SO2 emissions but no estimation of

associated emission reductions has been reported. Both PaMs concern emissions from the

shipping sector at open sea which is outside the scope of the NECD from a compliance

perspective. There may be some impacts of these PaMs on emissions from domestic shipping

which would be relevant. No PaMs were considered for the main sectors emitting SO2 i.e.

combustion in industry, energy industries, non-industrial combustion and industrial processes.

No PaMs adopted are reported to have an impact on NMVOC emissions.

Despite selecting additional PaMs for adoption, the projections under the WAM scenario show that

Denmark is not expected to meet its national emission reduction commitments for NH3 and PM2.5 for

2020-29 and for 2030 onwards. Under the WAM scenario, the SO2 reduction commitment is projected

to be narrowly attained. The NAPCP projections are the same as those submitted under Article 10(2).

Accordingly, the risk assessment that was conducted as part of the horizontal review (and factors in

submissions for both the NAPCP and the Article 10(2) projections) finds that Denmark is at high risk

of non-compliance for SO2, NH3 and PM2.5 (see Appendix 2).

Positive highlights from the review of the NAPCP for Denmark are:




The detailed description of current PaMs together with implemented EU legislation provides a

good basis for understanding progress achieved to date for reduction of emissions to air as well

as improvements to air quality.

Both existing and additional measures relating to agriculture in Annex III, Part 2 to the NECD

are reported in the NAPCP. This enables the NAPCP review to establish how mandatory

measures in the NECD have been adopted.

Uncertainties associated with the projected emissions are reported by Denmark are well

described, adding credibility to the NAPCP projections reported.

The use of costs and benefits to justify the selection of PaMs adopted as well as outlining how

much funding has been allocated to support implementation. This information helps to

demonstrate the credibility of the PaMs adopted.

Coherence between the NAPCP, draft NECP and air quality policy priorities is demonstrated

by selecting for adoption the Climate and Clean Air Package and reporting the projected

impacts of selected PaMs on nitrogen deposition.

Recommendations

Recommendations are prioritised according to the following categories:

1. Ensuring compliance – non-compliance with the NECD, where the minimum content is not

reported and/or the Member State does not demonstrate how it may achieve its emission reduction

commitments.

2. Areas for improvement – the NAPCP is reported to be compliant with its emission reduction

commitments and provides the minimum content required by the common format but uncertainties

are identified. Clarification and/ or additional information could improve quality of the NAPCP.

3. Encouragements – where optional reporting could be provided to improve the quality of the

NAPCP and/or where the NAPCP could be closer aligned with the guidance document on

preparation of initial NAPCPs.

Ensuring compliance

The projected compliance gap for NH3 and PM2.5 under the WAM scenario should be addressed

in the NAPCP to ensure compliance with Article 1 of the NECD.

Under the WAM scenario, the 2020-29 and 2030 emission reduction commitments for NH3 and

PM2.5 are projected to be missed. To ensure compliance, further PaMs to those selected for

adoption in the NAPCP should be considered by Denmark to address this.

NH3 emission reductions are dependent on the committee for NH3 emission reducing measures.

The NAPCP should include a clear timeframe for decision-making by the national committee for

NH3 emission reduction measures. It should be demonstrated that plans are in place to ensure

compliance with the NH3 national emission reduction commitment.

The reported WAM projection scenario indicates that NH3 and SO2 emissions will not follow a linear

trajectory towards attainment of the 2030 emission reduction commitment. The document should

clearly acknowledge and explain the issue of deviating from the linear trajectory for 2025 for these

pollutants.

Areas for improvement

Under the WAM scenario, Denmark is projected to achieve the SO2 2030 emission reduction

commitment by 1 percentage point. It is recommended that further PaMs to those selected for

adoption in the NAPCP are considered by Denmark for this pollutant.




In accordance with the NECD, where appropriate, transboundary consultations shall be conducted

(Article 6(6)). Member States should provide links to relevant website(s) on the consultation

undertaken (section 2.1.1. of the common format). Denmark identifies transboundary air pollution

transfers with neighbouring countries. However, evidence is needed to show that consultation on

the NAPCP has been undertaken with the affected neighbouring countries or if no consultation has

been undertaken then on the reasons why.

A qualitative description is provided for projected improvements in air quality for PM2.5 and NO2

only. In the light of the challenges described under current progress for O3, the lack of information

is considered a gap. The inclusion of assessment of impacts on O3 in the WM projections would

improve the completeness of the information provided.

Encouragement

The Danish NAPCP includes an outline of the transboundary impact of air pollution but does not

include any details concerning the methodology applied. An outline of the methodology used to

develop the quantitative data reported, and/or signposting to the methodology used would

strengthen the robustness and transparency of the data provided.

For a selection of the PaMs considered, costs have been reported via the EEA PaM-tool. More

detailed information is included in the NAPCP concerning costs and benefits, but the information is

different. Consistency between the information provided in the NAPCP and reported via the EEA

PaM-tool would strengthen the robustness of the NAPCP.

To strengthen the expected projected compliance with the EU air quality limit values, Denmark

could consider progress towards achieving the air quality values included in the WHO guidelines.

Additional information on contributions to secondary PM per sector could help with identifying

further additional PaMs to reduce PM2.5 emissions.

Meeting the Air Quality Directive O3 target value is likely to present an ongoing challenge and

therefore PaMs addressing NMVOC emissions and/or additional PaMs for NOx emissions, as

precursors to O3, could be considered.




Appendix 1 Completeness assessment

A completeness assessment was conducted to identify gaps in reporting according the minimum

content requirements of the common format (Commission Implementing Decision (EU) 2018/1522).

The completeness assessment also reviewed the extent of optional reporting by Member States.

For mandatory reporting requirements, the status has been assessed using the traffic light RAG rating

as presented in the table below.

Table A1- 1 Traffic light RAG rating for completeness assessment of mandatory reporting

Red No information provided for mandatory reporting requirement

Amber Evidence is incomplete or unclear to meet reporting requirement

Green Evidence is sufficient to meet reporting requirement

N/A Mandatory reporting requirement not relevant for the given Member State or

mandatory only when available and not available in the given Member State (e.g.

where mandatory reporting requirements apply only where a non-linear emission

reduction trajectory is followed)

Table A1- 2 Completeness assessment of the NAPCP – mandatory content

Reference to the NAPCP common

format

RAG

Rating

Explanation

2.1 Title of the programme contact

information and websites

Amber The Danish NAPCP is appropriately

introduced except that the year of publication

is not provided although it can be deduced

from the website links provided.

2.3.1 Policy priorities and their

relationship to priorities set in other

relevant policy areas

Green Denmark provides a detailed overview of the

relevant policy priorities for emission

reductions and other relevant policies

including air quality, climate change and

energy, transport and agriculture. The

NAPCP also refers to policy priorities

concerning household and industry sectors

in relation to air quality policy priorities.

2.3.2 Responsibilities attributed to

national, regional and local authorities

Green The Danish NAPCP meets all reporting

requirements relating to the responsibilities

attributed to national, regional and local

authorities.

2.4.1 Progress made by current PaMs in

reducing emissions, and the degree of

compliance with national and Union

emission reduction obligations

Green The Danish NAPCP reports progress made

by current PaMs in reducing emissions. The

references provided are complete but do not

include chapter and page references.


improving air quality, and the degree of

compliance with national and Union air

quality obligations

Green Denmark reports on progress achieved by

current PaMs in improving air quality by

providing the main conclusions from the





format

RAG

Rating

Explanation

latest monitoring report for select air

pollutants, describing compliance.

2.4.3 Where relevant, current

transboundary impact of national emission

sources

Green Denmark describes the impact of

transboundary air pollution accompanied by

quantitative data.

2.5.1 Projected emissions and emission

reductions (WM scenario)

Green Denmark reports projections under a WM

scenario in its NAPCP, showing emission

reductions compared with a 2005 base year

for all NECD pollutants against the Member

State commitments (as stipulated by the

NECD). The NAPCP includes all requested

information relating to the development of

the projections.

2.5.2 Projected impact on improving air

quality (WM scenario)

Amber Denmark provides a qualitative description

of projected improvements in air quality for

PM2.5 and NO2. The challenges described

under current progress for O3 indicate that

the lack of information for this pollutant could

be considered a gap. References are

reported but chapter and page numbers are

not included.

2.6.1 Details concerning the PaMs

considered in order to comply with the

emission reduction commitments

(reporting at PaM level)

Green Denmark provides the minimum content for

this reporting requirement using the EEA

PaM-tool.

2.6.2 Impacts on air quality and the

environment of individual PaMs or

packages of PaMs considered in order to

comply with the emission reduction

commitments



PaM-tool.

2.6.4 Additional details concerning the

measures from Annex III Part 2 to

Directive (EU) 2016/2284 targeting the

agricultural sector to comply with the




PaM-tool.

2.7.1 Individual PaMs or package of PaMs

selected for adoption and the competent

authorities responsible



PaM-tool.

2.7.2 Assessment of how selected PaMs

ensure coherence with plans and

programmes set up in other relevant

policy areas



PaM-tool.





format

RAG

Rating

Explanation

2.8.1 Projected attainment of emission

reduction commitments (WAM)

Green Denmark reports projections under a WAM

scenario in its NAPCP, showing emission

reductions compared with a 2005 base year

for all NECD pollutants against the Member

State commitments (as stipulated by the

NECD). The NAPCP includes all requested

information relating to the development of

the projections.

2.8.2 Non-linear emission reduction

trajectory

Red Denmark has not reported any information

with regard to non-linear trajectory.

However, the projections demonstrate that

SO2 emissions will actually increase under

WAM scenario towards 2025. For NH3,

projections assume no reductions in

emissions until 2025, thus a linear trajectory

is not followed.

2.8.3 Flexibilities N/A Denmark has not reported any information

with regard to flexibilities. Therefore, it is

assumed that flexibilities are not applicable.

The rating used for the completeness assessment of optional reporting by Member States refers to only

two categories, whereby the Member State either reported the information (Green) or it did not (White).

This rating reflects the fact that the reporting is optional and therefore where the information was not

provided, or where it was incomplete or unclear, the assessment should not consider this a gap in

reporting.

Table A1- 3 Rating for completeness assessment rating of optional reporting

Green Evidence is sufficient to meet reporting requirement

White No information provided for optional reporting requirement or evidence is

incomplete or unclear to meet optional reporting requirement




Table A1- 4 Completeness assessment of the NAPCP - optional content


format

RAG

Rating

Explanation

2.2 Executive summary White Denmark does not provide an executive

summary in its NAPCP.

2.3.1 Policy priorities and their

relationship to priorities set in other

relevant policy areas: Reference to WHO

guideline values

White The Danish NAPCP includes WHO data

relating to the impacts of air quality on

human health in Denmark but does not

outline the respective WHO guideline values

for air quality pollutants and Denmark's

progress towards meeting them.

2.3.2 Responsibilities attributed to

national, regional and local authorities:

Source sectors under the responsibility of

the authority

White Denmark does not provide information

concerning the source sectors under the

responsibility of the authorities listed.


reducing emissions, and the degree of

compliance with national and Union

emission reduction obligations: Provision

of graphics

Green The Danish NAPCP includes graphics to

illustrate the emission reductions achieved

per pollutant.


improving air quality, and the degree of

compliance with national and Union air

quality obligations: Provision of graphics

and progress made in a specific air quality

zone

Green Denmark provides maps to illustrate air

concentrations. It does not include

histograms to show the number of compliant

zones. Progress achieved is described in the

Danish NAPCP in relation to certain air

quality zones where issues of compliance

have been identified.

2.4.3 Methodologies and data used to

show the current transboundary impact of

national emission sources

White Quantitative data is referenced but the

methodology used is not outlined. It can be

assumed from the source provided that the

data is derived in compliance with the

EMEP/EEA air pollutant emission inventory

guidebook.

2.5.1 Associated uncertainties of the

projected emissions and emission

reductions (WM scenario)

Green Denmark provides a detailed account of the

associated uncertainties for the WM

projections.

2.5.2 Quantitative data on the projected

impact on improving air quality (WM

scenario)

Green Denmark provides quantitative data showing

the projected impact on improving air quality

for NO2 and PM2.5.

2.6.1 Details about additional pollutants

concerning the PaMs considered in order

to comply with the emission reduction

commitments: Reporting of affected

Green The affected pollutants go beyond the scope

of the NECD. The additional PaMs

considered by Denmark are expected to

affect CH4, CO2 and PAHs.





format

RAG

Rating

Explanation

pollutant(s) beyond the scope of the

NECD

2.6.3 Estimation of costs and benefits of

the individual PaM or package of PaMs

considered in order to comply with the


White Denmark has provided limited information

concerning the estimation of costs for

selected individual PaMs.

2.6.4 Additional details concerning the

optional measures from Annex III Part 2 to

Directive (EU) 2016/2284 targeting the

agricultural sector to comply with the


Green Denmark reports which of the optional

measures from Annex III, Part 2 to the

NECD have been adopted and which have

not. All except the national advisory code of

good agricultural practices for the proper

management of harvest residue have been

established by the Member State.

2.7.1 Individual PaMs or package of PaMs

selected for adoption and the competent

authorities responsible: Reporting of

relevant comments arising from the

consultation and provision of interim

targets and indicators

White Denmark does not report any comments

arising from the consultation specific to the

PaMs adopted for selection and it does not

provide indicators and targets to monitor

progress.

2.7.2 Explanation of the choice of

selected measures

Green Denmark includes an explanation for the

PaMs selected for adoption in the NAPCP

report.

2.8.4 Projected improvement in air quality

(WAM)

White Denmark does not report any details

concerning the projected number of non-

compliant and compliant air quality zones

reported for PM2.5, NO2, PM10, O3 or other. It

indicates that air quality improvements are

expected for PM2.5 but no evidence is

provided to support this.

2.8.5 Projected impacts on the

environment (WAM)

White Denmark does not provide any information

regarding the projected impacts on the

environment for the base year, 2020, 2025

and 2030. It indicates that reductions in

nitrogen deposition is expected but no

evidence is provided to support this.




Appendix 2 Assessment of the risk of non-compliance The description of the methodology used for this assessment is presented in the Horizontal Report.

In the following tables, the information used in the decision tree process is presented in black font.

Information not used in the decision tree process is presented in grey font and italics.

Where information is required but not reported, the response to the decision tree question is ‘not

reported’ (NR). Where information is not required and not reported, the response to the decision tree

question is ‘not applicable’ (n/a).

Risk of non-compliance with 2020-2029 emission reduction commitments

Decision tree question Relevant

scenario

2020 – 2029

SO2 NOx NMVOC NH3 PM2.5

Can the Member State

achieve the emission

reduction commitments?

(projections submitted

under Article 10(2))

WM Yes Yes Yes No No

WAM Yes Yes Yes No No

Are the projections

submitted under Article

10(2) considered to be of

good quality?

WM,

WAM

Yes Yes Yes Yes Yes

Are the NAPCP projections

consistent with the latest

projections submitted under

Article 10(2)?

WM Yes Yes Yes Yes Yes

WAM Yes Partially Yes Partially Yes

Does the NAPCP present

credible additional PaMs

selected for adoption?

WAM Partially Yes n/a No Partially

Is the margin of compliance

(percent of the compliance

threshold) likely to ensure

compliance with the

emission reduction

commitments? (projections


10(2))

WM Yes

(37)

Yes (5) Yes

(11)

No (-8) No (-8)

WAM Yes

(39)

Yes (8) Yes

(11)

No (-8) No (-7)

Risk of non-compliance L L L H H

Additional comments on

high risk scores

The review has concluded that Denmark is at a high-risk of non-

compliance with NH3 and PM2.5 emission reduction commitment

for 2020-2029. This is driven by Denmark projecting to miss

these emission reduction commitments according to their

projections and WM and WAM scenarios in the NAPCP (despite

introducing additional PaMs).




Risk of non-compliance with 2030 onwards emission reduction commitments

Decision tree question Relevant

scenario

2030 onwards

SO2 NOx NMVOC NH3 PM2.5

Can the Member State

achieve the emission

reduction commitments?

(projections submitted

under Article 10(2))

WM No Yes Yes No No

WAM Yes Yes Yes No No

Are the projections


10(2) considered to be of

good quality?

WM,

WAM

Yes Yes Yes Yes Yes

Are the NAPCP projections

consistent with the latest

projections submitted under

Article 10(2)?

WM Yes Yes Yes Yes Yes

WAM Yes Partially Yes Partially Partially

Does the NAPCP present

credible additional PaMs

selected for adoption?

WAM Partially Yes n/a No Partially

Is the margin of compliance

(percent of the compliance

threshold) likely to ensure

compliance with the

emission reduction

commitments? (projections


10(2))

WM No (-14) No (2) Yes

(13)

No (-7) No (-32)

WAM No (2) Yes

(11)

Yes

(14)

No (-7) No (-29)

Risk of non-compliance H L L H H

Additional comments on

high risk scores

The review has concluded that Denmark is at a high-risk of non-

compliance with SO2, NH3 and PM2.5 emission reduction

commitments for 2030 and onwards.

For SO2 this is driven by:

Emission reductions from additional PaMs selected for adoption in the NAPCP to reduce SO2 emissions not being quantified. No PaMs were selected for adoption in the main sectors emitting SO2.

Low margin of projected compliance

For NH3 and PM2.5 this is driven by:

Denmark projecting to miss these emission reduction commitments according to their projections and WM and WAM scenarios in the NAPCP (despite adopting additional PaMs).

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