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Review of National Air Pollutant Projections and Assessment of National Air Pollution Control Programmes

___________________________________________________ Intermediate Horizontal Review Report for European Commission – DG Environment Specific contract 070201/2019/819608/SFRA/ENV.C.3

ED 12960 | Issue Number 3 | Date 10/06/2020

Review of National Air Pollutant Projections and Assessment of National Air Pollution Control Programmes | i

Ricardo Confidential Ref: Ricardo/ED12960/Issue Number 3

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This report is the Copyright of European Commission. This document has been prepared by Ricardo Energy & Environment, a trading name of Ricardo-AEA Ltd under contract 070201/2019/819608/SFRA/ENV.C.3 dated 01/01/2020 for the European Commission. However, it reflects the views only of the authors, and the European Commission cannot be held responsible for any use which may be made of the information contained therein. The contents of this report may not be reproduced, in whole or in part, nor passed to any organisation or person without the specific prior written permission of European Commission. Ricardo Energy & Environment accepts no liability whatsoever to any third party for any loss or damage arising from any interpretation or use of the information contained in this report, or reliance on any views expressed therein, other than the liability that is agreed in the said contract

Author:

Natalia Anderson, Hetty Menadue, Ben Grebot (Ricardo) Chris Dore (Aether)

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Chris Green

Date:

10 June 2020

Ricardo Energy & Environment reference:

Ref: ED12960 - Issue Number 3

Review of National Air Pollutant Projections and Assessment of National Air Pollution Control Programmes | ii



Table of contents 1 Introduction and objectives ...................................................................................... 5

1.1 This report ......................................................................................................................... 5

1.2 Objectives of the review of air pollutant emission projections and NAPCPs .................... 5

1.3 Coverage of EU Member States in this report .................................................................. 6

2 Methodology .............................................................................................................. 8

2.1 Overview ............................................................................................................................ 8

2.2 Methodology for the review of air pollutant emission projections .................................... 10

2.2.1 Focus and scope of the review .............................................................................. 10

2.2.2 Assessing the quality of projections submissions .................................................. 11

2.3 Methodology for the assessment of NAPCPs ................................................................. 14

2.3.1 Focus and scope of the review .............................................................................. 14

2.3.2 Assessment of the NAPCPs .................................................................................. 15

2.4 Centralised review ........................................................................................................... 18

2.5 Assessing risk of non-compliance with NECD emission reduction commitments .......... 18

2.5.1 Margin of compliance ............................................................................................. 18

2.5.2 Deciding on the risk of non-compliance ................................................................. 20

3 Review results .......................................................................................................... 26

3.1 Overview of Member State reporting .............................................................................. 26

3.1.1 Timeliness of reporting ........................................................................................... 26

3.1.2 Projections scenarios reported ............................................................................... 26

3.1.3 Reference year for projections ............................................................................... 27

3.1.4 Reporting on PaMs ................................................................................................. 27

3.1.5 Responsiveness ..................................................................................................... 27

3.2 Completeness assessment ............................................................................................. 37

3.2.1 Mandatory content .................................................................................................. 37

3.2.2 Optional content ..................................................................................................... 45

3.3 Progress towards emission reduction commitments and a linear emission reduction trajectory ..................................................................................................................................... 46

3.3.1 Projected compliance with 2020 -2029 emission reduction commitments ............ 47

3.3.2 Projected compliance with 2030 onwards emission reduction commitments ........ 53

3.3.3 Emission reduction trajectory ................................................................................. 59

3.3.4 Use of flexibilities .................................................................................................... 61

3.4 Quality of Member State projections ............................................................................... 62

3.4.1 Overview................................................................................................................. 62

3.4.2 Method.................................................................................................................... 62

3.4.3 Quality – by quality criteria ..................................................................................... 62

3.4.4 Transparency ......................................................................................................... 66

3.4.5 Comparability ......................................................................................................... 67

Review of National Air Pollutant Projections and Assessment of National Air Pollution Control Programmes | iii



3.4.6 Completeness ........................................................................................................ 68

3.4.7 Consistency ............................................................................................................ 69

3.4.8 Accuracy ................................................................................................................. 70

3.4.9 Recommendations and Encouragements .............................................................. 72

3.5 PaMs considered and selected for adoption ................................................................... 74

3.5.1 Overview................................................................................................................. 74

3.5.2 Quality of reporting on the PaMs ............................................................................ 78

3.5.3 PaMs selected for adoption per sector ................................................................... 79

3.5.4 Assessment of costs and benefits of PaMs considered and selected for adoption .............................................................................................................................. 106

3.5.5 Assessment of improvements in air quality and impacts on the environment ..... 109

3.6 Coherence ..................................................................................................................... 109

3.6.1 Coherence of NAPCPs and air emission projections ........................................... 110

3.6.2 Coherence of NAPCPs with air quality policy priorities ........................................ 112

3.6.3 Coherence of NAPCPs with energy and climate change priorities and national energy and climate plans (NECPs) ........................................................................................ 114

4 Risk of non-compliance with emission reduction commitments ....................... 116

5 Conclusions and recommendations ..................................................................... 120

5.1 Reporting ....................................................................................................................... 120

5.2 Quality of Member State projections ............................................................................. 121

5.3 NAPCPs and policies and measures selected for adoption .......................................... 122

5.4 Progress towards emission reduction commitments and associated risk of non-compliance ................................................................................................................................ 123

Appendix A Overall quality of air pollutant emission projections (scores used in the risk assessment)

Appendix B Risk of non-compliance: Member State level assessment

Review of National Air Pollutant Projections and Assessment of National Air Pollution Control Programmes | iv



Abbreviations

BaP Benzo(a)pyrene

BAT Best Available Technique

BC Black Carbon

CAP Common Agricultural Policy

CDR Central Data Repository

CH4 Methane

CLRTAP Convention on Long-range Transboundary Air Pollution

CO2 Carbon dioxide

EEA European Environment Agency

EMRT-NECD Emission Review Tool for the National Emission reduction Commitments Directive

EU European Union

ETS Emission trading system

GHG GreenHouse Gas

IED Industrial Emissions Directive (Directive 2010/75/EU)

IIR Informative Inventory Report

IPPU Industrial Processes and Product Use

Kt Kilotonne

MCPD Medium Combustion Plant Directive (Directive (EU) 2015/2193)

NAPCP National Air Pollution Control Programme

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

NECP National Energy and Climate Plans

NFR Nomenclature for Reporting

NH3 Ammonia

NMVOC Non-Methane Volatile Organic Compounds

N2O Nitrous oxide

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

TRT Technical Review Team

WAM With Additional Measures

WHO World Health Organisation

WM With Measures

Review of National Air Pollutant Projections and Assessment of National Air Pollution Control Programmes | 5



1 Introduction and objectives

1.1 This report

This report presents results of the horizontal EU-wide review of the National Air Pollution Control Programmes (NAPCPs) and air pollutant emission projections submitted by the EU Member States to the European Commission in 2019, in line with their reporting obligations set out in Article 10 of Directive (EU) 2016/2284 of the European Parliament and of the Council of 14 December 2016 on the Reduction of National Emissions of Certain Atmospheric Pollutants1 (NECD). The report has been prepared for the European Commission as part of the study commissioned by the European Commission under the Framework Contract ENV.C.3/FRA/2017/0012 (specific contracts 070201/2018/791186/SER/ENV.C.3 and 070201/2019/819608/SFRA/ENV.C.3).

This report has been produced alongside individual Member State-level reports documenting findings of the review of the national air pollutant emission projections and individual Member State-level reports documenting results of the assessment of NAPCPs.

1.2 Objectives of the review of air pollutant emission projections and NAPCPs

The overall purpose of the review of the NAPCPs and air pollutant emission projections was to determine Member State compliance with the requirements of the NECD, specifically in terms of:

Projected compliance or non-compliance with the emission reduction commitments set out in

Annex II to the NECD;

Quality of the air pollutant emission projections;

Credibility of the policies and measures (PaMs) selected for adoption; and

Fulfilling the minimum content requirements for NAPCPs specified in Annex III Part 1 of the

NECD.

The specific objectives of the review are shown in Table 1-1 below.

1 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016L2284&from=EN

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016L2284&from=EN




Table 1-1 Specific objectives of the review

Reporting Specific objectives of the review

Air pollutant emission projections

Assess the projected compliance or non-compliance with the emission reduction

commitments set in the NECD.

Assess the quality of the projections based on defined criteria

To develop recommendations, in consultation with the Member States, on how

the quality of the projections can be improved for future submissions.

NAPCPs

Assess the following:

Compliance of the NAPCP with the minimum content requirements of the NECD

and the use of the common reporting format.

The extent to which the optional content specified in the NECD is 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.

The extent to which Member States are reliant on additional PaMs to achieve

compliance with the emission reduction commitments.

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

level of confidence this provides on whether the Member State will meet their

2020-29 and 2030 onwards 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.

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

principally the National Energy and Climate Plans (NECP).

1.3 Coverage of EU Member States in this report

This review assesses air pollutant projections and NAPCPs for the EU-282. The coverage of Member State projections and NAPCP in this report has been determined by their availability. As regard Member State projections that were due by 15 March 2019, all Member States have been assessed. As regards NAPCPs, due by 1 April 2019, the coverage reflects the situation at the time of finalisation of this report:

Two Member States had not yet reported their NAPCP (Greece and Romania).

Draft Italy NAPCP was made public on the CDR too late for full inclusion in this report. The results of the assessment of the draft NAPCP submitted by Italy are included in section 3.1 Overview of Member State reporting and section 4 Risk of non-compliance with emission reduction commitments, but not yet in other sections of this report. This is because the draft Italy NAPCP was only made public on the CDR after the analysis for those sections was finalised.

Luxembourg draft NAPCP has not been formally published on the CDR and is therefore not included in this report.

Assessments of the NAPCPs for Slovakia, Malta, Latvia and Hungary were still ongoing due to their late submissions. The Slovakia and Malta NAPCPs are reflected in sections 3.1 Overview of Member State reporting and 3.5 PaMs considered and selected for adoption, but not yet in the remaining sections of this report. For Latvia, this report reflects the content of the draft NAPCP as the assessment of the final NAPCP was still ongoing. For Hungary, the final NAPCP arrived too late to be included in the report.

The information considered in this report is shown in Figure 1-1. Completeness of Member State reporting at the time of submission of this report is discussed in sections 3.1 and 3.2.

2 The reporting obligations assessed in this report pertain to 2019 when the EU counted 28 Member States.




Figure 1-1 Coverage of EU Member States in the report related to 2019 NECD obligations




2 Methodology 2.1 Overview

The review followed a logical process, starting with the collection of data and reports submitted in the EEA’s Central Data Repository (CDR) and then progressing through three phases: desk-based review, centralised review and reporting, as presented in Figure 2-1. Table 2-1 provides a description of each phase of the review process.

Figure 2-1 Overview of the review process




Table 2-1 Overview of each step of the review process

Phase Projections NAPCPs

Desk-based review

Initial checks were undertaken, and

information was passed to the review

team via upload to the EMRT-NECD3

to support them in the desk-based

review. During this period, the review

team established question and

answer chains with Member States

through the EMRT-NECD on-line

platform in order to answer or resolve

issues raised. Issues were then

closed with an accompanying

conclusion and recommendation

where relevant.

Initial checks were undertaken covering the language of submission, number of documents provided, the use of the common format and of the EEA-PaM tool and the completeness of the NAPCP. The checks undertaken during the in-depth review followed the structure of the NAPCP common format. Completeness of reporting was assessed using a red-amber-green rating. Member States were not contacted with questions regarding the NAPCP review.

Centralised review4

Undertaken after the completion of the desk review.

Provided an opportunity for selected members of the review team to discuss

review results for each Member State, integrate projections and NAPCP

reviews, undertake a quality assessment for each Member State, close out

any outstanding issues, discuss any cross-cutting issues, agree solutions to

unusual or challenging issues, and ensure the consistency of work across the

review teams.

Reporting

Review reports were compiled for

each Member State and sent to them

for comment before finalisation.

Review reports were compiled for each Member State.

Findings of the review of projections and NAPCPs were assessed and summarised horizontally in the horizontal review report.

Feedback gathered from the Member States on the full review process is summarised in the review evaluation report.

The methodology for the review was designed to allow for the air pollutant emission projections and NAPCPs to be assessed in an integrated way. During the desk-based review, this included checks on:

1. Consistency between the 2019 air pollutant emission projections and the emission projections included in the NAPCP

2. Content of the NAPCP before posing the question to the Member States concerning the projections methodology

3. Consistency between the PaMs selected for adoption in the NAPCP and the With Additional Measures (WAM) scenarios submitted with the air pollutant emission projections.

Results from the review of air pollutant emission projections and NAPCPs were then discussed by the project team at the centralised review meetings, where applicable (see section 2.4 below). However, the delays in Member States reporting (particularly the NAPCPs) and limited detail reported on the methodologies for deriving air emission projections have meant that in practice full integration was only possible for a small number of Member States.

3 The EMRT-NECD is an on-line platform maintained by the European Environment Agency that allows review teams to log findings, communicate with Member State representatives, and formulate conclusions and recommendations. The platform was expanded and tailored to specifically support the projections review.

4 The centralised review meeting was held on 17 and 18 September 2019. Review results for France and Malta were not covered in this meeting due to the late submissions of Article 10(2) projections and NAPCPs by these Member States.




2.2 Methodology for the review of air pollutant emission projections

2.2.1 Focus and scope of the review

The project team planned and undertook a comprehensive technical review of air pollutant emission projections which were due to be reported by Member States under Article 10(2) of the NECD by 15 March 2019. This involved reviewing the projections data reported by each Member State in the projections reporting template (CLRTAP Emission Inventory Reporting Guidelines5: Annex IV, 2014), and supporting information provided in Informative Inventory Reports in accordance with Article 10(2) of the NECD. In some cases, it was also necessary to refer to material included in the NAPCP and/or a stand-alone projections methodology report provided by the Member States.

The quality of air pollutant emissions projections was reviewed against the quality criteria referred to in Part 2 of Annex IV of the NECD (transparency, consistency, comparability, completeness and accuracy).

The NECD specifies several minimum criteria for projections which were reviewed as follows:

Clear identification of the adopted and planned policies and measures included in the

projections: This was assessed by reviewing supporting documentation provided alongside

the projections. The findings were presented within the context of the relevant quality criteria.

For example, a lack of information on the adopted policies and measures was captured as a

transparency issue, whereas information that suggests some policies and measures were

incorrectly omitted were captured as a completeness or accuracy issues.

Sensitivity analysis performed for the projections: Where a sensitivity analysis was

reported by a Member State, the methodology and data were reviewed. Any issues found were

discussed with the Member State, and recommendations and encouragements were made

accordingly.

A description of methodologies, models, underlying assumptions and key input and

output parameters: This was assessed by reviewing supporting documentation, with the

findings presented within the context of the relevant quality criteria.

Table 2-2 below provides details of the scope of the projections review.

5 Reporting templates and instructions are available from the CLRTAP’s Centre on Emission Inventories and Projections: https://www.ceip.at/ms/ceip_home1/ceip_home/reporting_instructions/annexes_to_guidelines/

https://www.ceip.at/ms/ceip_home1/ceip_home/reporting_instructions/annexes_to_guidelines/




Table 2-2 Summary of the scope of the review

Scope element Coverage and description

Emission projection submission

2019 NECD projection submission.

Submissions were based on many different versions of the

historical inventory.

Member States 28 Member States6

Pollutants SO2, NOX, NMVOC, NH3, PM2.5 (BC, where included)

Sectors

The source resolution is defined as that of the NFR codes in the projections reporting template (Annex IV, 2014).

The focus was on (but not limited to) source categories identified

as key categories in the reference year.

Years

2020, 2025, 2030 (2040 and 2050, where available)

2020 and 2030 were included as they relate to demonstrating

compliance with emission reduction commitments.

2025 was included due to the requirement relating to a linear

trajectory as stipulated by Article 4(2) of the NECD.

2040 and 2050 were additionally included in scope, although

reporting of these years is optional so was not always covered.

2.2.2 Assessing the quality of projections submissions

The projections review followed the processes presented in the Projections Review Guidelines (2019) and its subsequent 2020 iteration, developed as part of this contract and shared with the Member States and the project team at the beginning of the review. During the review, sector experts performed checks on the emission projections and supporting documentation provided by Member States. The desk-based review resulted in specific recommendations and encouragements aimed at supporting Member States in improving their projections for their next submission. Following this, at the centralised review, the lead reviewers undertook a quality assessment of the projections.

The lead reviewers assessed the quality of the projections against each quality criterion for each pollutant and year. This drew on the detailed information obtained from the desk reviews. The lead reviewers worked in a collaborative way to ensure that the approach used was consistent across all Member States. They also discussed their findings to agree common approaches to specific issues that arose during the review.

Assessment of some of the quality criteria with a reasonable degree of certainty was often challenging due to a lack of detailed information reported by the Member States on the methodologies used. Where reporting was limited or non-existent, the lead reviewers made their assessments to the extent possible on the basis of the information available.

The quality assessment was made against the following quality criteria (details of the rating scheme are included in Table 2-3 below):

1. Transparency of reporting

This assessed the transparency of the data submission and information provided on the methodologies and calculations used to determine the emission projections (whether provided in the IIR or other documents).

6 The EU comprised 28 Member States at the time of the reporting deadline for air pollutant emission projections in 2019.




2. Comparability of projections

This assessed whether the data submission was made in the correct format, i.e. using the emission projections template (Annex IV, 2014). To the extent possible, definitions used in calculating emission projections were assessed against best practice definitions. This provides information on the extent to which it is possible to compare the emission projections with submissions from other Member States.

3. Completeness of reporting

This assessed the completeness of the data that has been reported. This was checked by reviewing whether the projections data submitted in the Annex IV template indicated missing source sectors. In addition, the supporting documentation was checked, and Member States were asked whether specific sources (within the source sectors reported in the Annex IV data file) had been omitted.

4. Consistency of projections

This assessed the internal consistency of the emission projections (across the pollutants, years and sectors). It was challenging to assess this where little or no supporting documentation was provided on calculation methodologies, input data and assumptions.

Consistency between the emission projections submission and data underpinning greenhouse gas projections submitted with the National Energy and Climate Plans (NECPs) was also assessed. However, there were significant challenges in making this comparison because data formats are not easily comparable, and it was only possible to compare key underlying datasets for future years such as population and GDP.

5. Accuracy of projections

In determining emission projections there are many different sources of uncertainty, and it is particularly challenging to quantify uncertainties. In addition, shortcomings flagged in some other quality criteria impact on the level of accuracy. For example, issues associated with completeness will impact on the level of accuracy. However, accuracy can be assessed by considering whether Tier 2 or higher methodologies have been used for key sources.

It is also informative to assess the differences between the year x-3 and x-2 emissions inventories if the projections are based on the year x-3 inventory, as this indicates the extent to which current projections can be expected to be revised in the future7.

For each pollutant, and the years 2020-2029 and 2030, these five quality criteria above were given a rating of either: good, minor improvements required, or major improvements required. The criteria for selecting the different ratings are provided in Table 2-3 below.

Where quality issues were identified by the review team, consultation was undertaken with the Member State to ensure a sufficiently detailed understanding of the issue. The review team have then made recommendations or encouragements where they have considered action is required to improve the quality of the Member States’ data or supporting documentation to meet best practice standards. These recommendations and encouragements were often highly detailed or technical in nature. The recommendations and encouragements were also collectively used to inform the quality assessment detailed above.

7 This aspect is also relevant to the comparability and consistency criteria.




Table 2-3 Quality assessment – rating scheme guidance

Scope element Good Minor Improvements Required Major Improvements Required

Transparency Used where the reporting of methodologies is comprehensive

Used to indicate that the reporting of methodologies is of a reasonable standard, but that there are areas where more information is needed to attain a level that equates to good practice

Used to indicate that the reporting of methodologies is poor or non-existent

Comparability

Used to indicate the use of Annex IV reporting template, comprehensive use of definitions that meet best practice, and projections based on year x-3 or year x-2

Used to indicate use of Annex IV reporting template, definitions that broadly meet best practice, and projections based on year x-3 or year x-2

Used to indicate use of reporting that is not in the Annex IV template, and/or projections that are not based on year x-2 or year x-3

Completeness Used to indicate that the Technical Review Team (TRT) found no missing sources

Used to indicate that the TRT found missing sources or were not able to confirm the presence of all sources, but that the impact on the national total was considered to be relatively small

Used to indicate that the TRT found a missing key source, and/or several missing sources entailing a substantial impact on projected national totals

Consistency

Used to indicate that the TRT found no inconsistencies across the time series and pollutants, or between historical estimates and projections

Used to indicate that the TRT found inconsistencies that had a minor impact on the projected national totals

Used to indicate that the TRT found inconsistencies that had a substantial impact on projected national totals

Accuracy

Used to indicate that the TRT believed that projections for all key categories were calculated by using a Tier 2 or higher approach, and/or that all emissions are quantified to a level of accuracy that represents best practice

Used to indicate that the TRT believed that projections for most key categories were calculated by using a Tier 2 or higher approach, and/or that all major sources are quantified to a level of accuracy that represents best practice

Used to indicate that the TRT believed that projections for few or no key categories were calculated by using a Tier 2 higher approach, and/or that some major sources are not quantified to a level of accuracy that represents best practice




6. Overall quality of projections, for use in the assessment of the risk of non-compliance

In addition to assessing the five quality metrics above, it was necessary to determine a single rating for an overall quality of projections for each pollutant and each year, for use in the assessment of the risk of non-compliance (see section 1 and Appendix B).

The projections review determined that the required metric was not the same as would be obtained by an aggregation of the five quality ratings described above. This is because the metric required for input into the assessment of the risk of non-compliance is not significantly influenced by e.g. transparency of reporting but is heavily dependent on e.g. the accuracy of the projections. Thus, the metric had to represent the likelihood and extent to which the projections may be recalculated in future submissions.

The following approach was followed to conclude on the overall quality rating:

1. The accuracy ratings for each pollutant and each year were used as a starting point.

2. Where completeness or consistency ratings were lower than the accuracy rating, the lead reviewers investigated the underlying reasons for these ratings on a case by case basis and determined whether they might significantly impact on the likelihood and extent to which projections might be recalculated in future submissions. If this was the case, the lead reviewers “downgraded” the accuracy rating by one level i.e. changed a good rating to minor improvements, and minor improvements to major improvements.

3. The option to improve the accuracy rating, using similar logic, was also available to the lead reviewers i.e. where the completeness and/or consistency ratings were substantially better than that for accuracy, then “upgrading” the accuracy score by one level was possible.

The result was that accuracy scores were used for 19 of the 28 Member States reviewed. The following cases were the exceptions:

Accuracy ratings were “downgraded” one level due to completeness and/or consistency issues for: Austria (NMVOC), Czechia (SO2, NOX, NMVOC), Estonia (SO2, PM2.5), Croatia (SO2), Netherlands (SO2, NOX, NMVOC, NH3, PM2.5), Poland (NMVOC), Romania (NMVOC).

Accuracy ratings were “upgraded” one level due to consistency and completeness ratings for: Latvia (NOX, NMVOC) and Spain (NMVOC, PM2.5).

The results of this assessment are presented in section 0 and detailed in Appendix A.

2.3 Methodology for the assessment of NAPCPs

2.3.1 Focus and scope of the review

The project team planned and undertook a comprehensive assessment of NAPCPs reported by the Member States under Article 10(1) of the NECD. This involved reviewing the NAPCPs reported by each Member State, any supporting documents submitted and information on the additional PaMs considered and selected for adoption reported via the EEA PaM-tool.

The review of the NAPCPs focused on checking:

If the NAPCP common format has been used and followed correctly and the extent to which Member States have followed the NAPCP Guidance document8 when preparing initial NAPCPs.

If the NAPCP is compliant with the minimum content requirements of the NECD (completeness of reporting).

If the information in the NAPCP is consistent with the information in the latest projections.

The extent to which Member States are reliant on additional PaMs (the WAM scenario) to

achieve compliance and whether additional PAMs are put forward in view of wider air quality objectives as set out in Article 1(2) of the NECD (i.e. the AAQD objectives; the Union’s long-term objective of achieving levels of air quality in line with the air quality guidelines of WHO).

8 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2019.077.01.0001.01.ENG

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2019.077.01.0001.01.ENG




The extent to which the evidence provided on selected PaMs is robust and the level of confidence it provides that Member State will meet their 2020 and 2030 emission reduction commitments.

The extent to which optional content requirements of the NECD are reported and understanding the value additional reporting brings to the robustness of the evidence and the level of confidence it provides that the emission reduction commitments will be met.

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

principally the National Energy and Climate Plans (NECP).

Table 2-4 below provides details of the general scope of the NAPCP review.

Table 2-4 Summary of the scope of the NAPCP review

Scope element Coverage and description

NAPCP common format and accompanying documents

All sections of the NAPCP common format and accompanying documentation uploaded by the Member States to the CDR as either final or draft. Where the Member State has not used the common format, the same checks were carried out regarding content.

Additional PaMs submission

2019 and 2020 submissions of additional PaMs via the EEA PaMs tool.

Member States

28 Member States9, of which the following are not featured in this horizontal review report:

2 Member States have not reported their NAPCPs at the time of this report (Greece and Romania)

Draft Luxembourg NAPCP has not been formally published on the CDR and is therefore not included in this report.

As stated in section 1.3, draft Italy NAPCP was made public on the CDR too late for full inclusion in this report. The results of the assessment of the draft NAPCP submitted by Italy are included in section 3.1 Overview of Member State reporting and section 4 Risk of non-compliance with emission reduction commitments, but not yet in other sections of this report. This is because the draft Italy NAPCP was only made public on the CDR after the analysis for those sections was finalised.

Assessments of the NAPCPs for Slovakia, Malta, Latvia and Hungary were still ongoing due to their late submissions. The Slovakia and Malta NAPCPs are reflected in sections 3.1 Overview of Member State reporting and 3.5 PaMs considered and selected for adoption, but not yet in the remaining sections of this report. For Latvia, this report reflects the content of the draft NAPCP as the assessment of the final NAPCP was still ongoing. For Hungary, the final NAPCP arrived too late to be included in the report.

2.3.2 Assessment of the NAPCPs

Initial screening checks of the NAPCPs

The initial checks were carried out for each NAPCP prior to the in-depth review to assess the basic information about the submission such as whether it followed the common format, is a final or draft NAPCP and the language of submission.

In-depth checks

The in-depth checks were designed as a series of questions with pre-defined responses, to systematically determine the robustness and reliability of the evidence submitted. The checks were designed to determine:

9 The EU comprised 28 Member States at the time of the deadline for submission of NAPCP on 1 April 2019.




1. Completeness of the NAPCP: 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)10. The completeness assessment also reviewed the extent of optional reporting by Member States.

For the mandatory reporting requirements, the status has been assessed using the traffic light red-amber-green rating as presented in the table below.

Table 2-5 Traffic light red-amber-green rating for completeness assessment of mandatory reporting

Red No information provided for mandatory reporting requirement

Amber Evidence is incomplete or too 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 (e.g. where mandatory reporting requirements apply only where a non-linear emission reduction trajectory is followed)

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 to be a gap in reporting.

Table 2-6 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 too unclear to meet optional reporting requirement

2. Robustness of the NAPCP:

The checks to determine the robustness of the evidence presented in the NAPCP referred to both mandatory and optional content and were aligned with different sections of the common format. A summary of the checks conducted per section of the NAPCP common format is presented in Table 2-7.

10 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.




Table 2-7 Overview of the in-depth checks

Section of the NAPCP common format

Summary of the checks conducted

2.1 Title of the programme, contact information and websites

Is the information provided sufficient? Is the documentation on the consultation process clear? Is there evidence to support the need for a transboundary consultation and if so, is there any evidence of a transboundary consultation being conducted?

2.2 Executive summary Is the summary consistent with the common format and the main content of the NAPCP and is it ten pages or less in length?

2.3 The National air quality and pollution policy framework

Are the national emission reduction commitments correctly listed? Are all key air quality pollutants described? Have all relevant policy objectives been described? Are all relevant roles attributed to the authorities and is this supportive of implementation of the NAPCP?

2.4 Progress made by current PaMs in reducing emissions and meeting compliance with national and EU obligations, compared to 2005

Is the progress made by current PaMs sufficiently described? Is the progress in reducing emissions and improving air quality linked to specific PaMs? Is an assessment of transboundary impact of emissions justified, conducted and does it consider both the impacts of inbound and outbound pollution?

2.5 Projected situation assuming no change in currently adopted policies and measures

Are emission reductions projected to meet the emission reduction commitments and with what margin? Is the NAPCP based on and consistent with the 2019 projections? Is the description of the projected improvements in air quality complete and provided for all pollutants for which there are air quality challenges?

2.6 Policy options considered to comply with emission reduction commitments for 2020 and 2030, intermediate emission levels for 2025 and stakeholder consultation

Do the PaMs considered for adoption target all pollutants under the NECD where a gap in meeting the emission reduction commitment(s) is identified? Are all measures in Annex III, Part 2 of the NECD selected for adoption, and if not, what are the reasons? Is the expected impact of PaMs, in terms of projected emission reductions, provided for all PaMs and if not, is that justified? What emission reductions are expected to be delivered by the PaMs and are there pollutants for which further PaMs should be considered? Are all PaMs correctly identified as additional PaMs? Are the PaMs in line with the policy priorities, and has their impact on air quality been sufficiently assessed? Have the costs of PaMs been considered?

2.7 The policies selected for adoption by sector including timetable for adoption, implementation and review and responsible competent authority

Are the PaMs selected for adoption in each sector credible: is the description sufficient, is it clear what actions will be implemented, are the assumptions behind the projected emission reductions and selected policy instruments reasonable? On that basis, are the PaMs likely to deliver the emission reductions projected in the NAPCP? Are the PaMs coherent with plans and programmes set up in other relevant policy areas, particularly energy and climate?

2.8 Projected combined impacts of PaMs on emission reductions, air quality and the environment and associated uncertainties (where applicable)

Will the emission reductions projected under the WAM scenario reported for 2020, 2025 and 2030 meet the national emission reduction commitment in the NECD? Do the PaMs selected for adoption target the key emitting sectors? Are the projected emission reductions for 2020 and 2030 likely to be achieved? Is the linear trajectory followed and justified based on the information provided? Has the impact of the selected PaMs on air quality and environment been assessed?




2.4 Centralised review

The centralised review was conducted during a two-day meeting in London on 17 and 18 of September 2019 and covered the Member States for which assessments of Article 10(2) projections had been completed (all Member States except for France and Malta). The meeting was attended in person by the Lead Reviewers, Project Manager and two QAQC Managers responsible respectively for the quality assurance of the reviews of air pollutant emission projections and NAPCPs. NAPCP reviewers were dialled in to the meeting as required.

The first day of the centralised review focused on finalising the projections review and ensuring that the quality of the projections was assessed in a consistent way. The objective for the second day was for the project team to work together on assessing the risk of non-compliance with the NECD emission reduction commitments (see section 2.5) for each Member State for which assessments of Article 10(2) projections and NAPCPs (2019 submissions) had been completed. This ensured the risk assessment was done in a consistent manner, integrating the findings of the projections review and NAPCP review. Findings of the risk assessment have since been updated where new or revised NAPCPs were submitted after the centralised review.

2.5 Assessing risk of non-compliance with NECD emission reduction commitments

2.5.1 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 2-2 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.

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 meet 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).

In this horizontal review 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. The methodology for assessing the risk of non-compliance applies 5% and 20% thresholds to the margin of compliance calculated using projections submitted under Article 10(2) (and expressed as a percentage of the

200

250

300

350

400

450

500

550

2005 2010 2015 2020

Emission reduction commitment

(% of 2005 emission)

Compliance margin

Compliance threshold




compliance threshold). The purpose of the 5% and 20% thresholds is to qualify the certainty of meeting the emission reduction commitments as explained further in the next section.

2.5.2 Deciding on the risk of non-compliance

A decision tree has been used to determine the risk of non-compliance at Member State level per pollutant and year. The decision tree, presented in Figure 2-3 and Figure 2-4, includes five broad questions (see Table 2-8). Responses to these questions were derived from the review of 2019 air pollutant emission projections and NAPCPs. Following the decision tree, the resulting risk of non-compliance was concluded as either high (H), medium (M) or low (L).

Background to the thresholds applied in the risk assessment

Recalculations in the historical emission estimates within the inventory represent changes that arise from methodological improvements. The magnitudes of recalculations vary significantly from year to year, Member State to Member State and pollutant to pollutant.

For projections, recalculations arise from two main types of change – a revision to the historical emission estimates that the projections are based on, and to the projection drivers (the scaling factors or datasets that provide the best estimates for trends in future years).

Such information is not readily available on the recalculation of projections, but it is available for the recalculation of historical emission estimates.

A comparison of the 2018 and 2019 submissions of historical emission estimates showed that following the emission estimates for 2016 (the most recent data in both datasets):

Nearly 15% of national totals (for each pollutant and each Member State) were revised upwards by more than 5%.

8% of national totals were revised upwards by more than 10%.

4% of national totals were revised upwards by more than 20%.

Emission projections are also impacted by recalculations of the drivers (which are not assessed here). A combined impact of changes in both the historical estimates and the drivers could substantially increase the percentage of totals exceeding the thresholds indicated above.

For the purposes of assessing the risk of non-compliance, threshold values are needed which represent “low risk” and “high risk” of revision. After due consideration, expert opinion has concluded that there is a low likelihood of a given emissions projection being revised upwards by more than 20%, and a high likelihood of an upwards revision of more than 5%. That formed the basis for the thresholds used in the risk assessment methodology.




Table 2-8 Decision tree questions to determine the risk of non-compliance

Decision tree question Description of the question Assessment criteria

Can the Member State meet the emission reduction commitments under the WM / WAM scenario? (projections submitted under Article 10(2))

Projected compliance with the 2020 and 2030 emission reduction commitments on the basis of the 2019 projections (WM and WAM) reported by Member States under Article 10(2) of the NECD.

Yes: The commitment can be met.

No: The commitment cannot be met.

NR (not reported): WAM is not reported but the Member State is required to provide WAM scenario as it cannot meet the emission reduction commitments with existing measures.

n/a: WAM is not required because the Member State can meet the emission reduction commitments with existing measures.

Are the projections submitted under Article 10(2) considered to be of good quality?

Quality of the 2019 projections (WM and WAM) reported by Member States under Article 10(2) of the NECD according to their transparency, completeness, consistency and accuracy (see [Table 2-3] for the explanation of the rating scheme used and definitions of minor and major improvements).

Yes: Projections are of good quality.

Partially: Projections require minor improvements.

No: Projections require major improvements.

n/a: It was not possible to conclude on quality of projections because e.g. the projections were not made available to the review team on time.

Are the NAPCP projections consistent with the latest projections submitted under Article 10(2) (WM/ WAM)?

Consistency of the projections used in the NAPCP and the 2019 projections reported under Article 10(2) of the NECD.

Yes: No inconsistencies

Partially: Minor inconsistencies which impact on the margin of projected compliance but do not lead to different conclusions on the projected compliance.

No: Inconsistencies leading to different conclusions on the projected compliance with emission reduction commitments.

n/a: Either the NAPCP projections or the 2019 projections reported under Article 10(2) were not available for the review.





Does the NAPCP present credible additional PaMs selected for adoption (WAM)?

Credibility of the additional PaMs selected for adoption and the certainty in the projected emission reductions according to the information reported in the NAPCP.

Yes: PaMs selected for adoption appear credible. Estimation of emission reductions is considered robust based on the information presented in the NAPCP.

Partially: PaMs selected for adoption are not judged as fully credible; PaMs may not deliver the estimated emission reductions, implementation of PaMs and/or achievement of emission reductions is not considered in the review as fully realistic based on the information presented in the NAPCP.

No: PaMs selected for adoption are found not credible and/or unlikely to deliver the estimated emission reductions, or no additional PaMs have been selected for adoption in the NAPCP despite WM projections demonstrating non-compliance with emission reduction commitments.

n/a: PaMs are not required because the Member State can meet the emission reduction commitments with existing measures.

Is the margin of compliance (percentage of the compliance threshold) under WAM scenarios (when available, and otherwise under WM) likely to ensure compliance with the emission reduction commitments? (projections submitted under Article 10(2))

Where the review of the Article 10(2) projections concluded that projections require no or minor improvements, compliance with commitments is considered uncertain if the commitment is projected to be achieved by 5 percent of the compliance threshold or less. The justification for this approach is that changes to emission projections to address any quality issues flagged in the review are unlikely to change the margin of compliance by more than 5 percent of the compliance threshold and move a Member State in or out of compliance, if the compliance margin is small.

Where the review of Article 10(2) projections concluded that projections require major improvements, compliance with commitments is considered uncertain if the commitment is projected to be achieved by 20 percent of the compliance threshold or less, as larger changes in

Where the quality of projections requires no or minor improvements:

Yes: The commitment is projected to be achieved by more than 5 percent.

No: The commitment is projected to be achieved by 5 or less.

Where the quality of projections requires major improvements:

Yes: The commitment is projected to be achieved by more than 20 percent.

No: The commitment is projected to be achieved by 20 or less.





projections values can be expected when addressing quality issues.

Where the WAM scenario is needed but not provided, or when the PaMs selected for adoption in the NAPCP are found in the review as not credible, the extent of projected compliance is based on the WM scenario in the 2019 projections reported by Member States under Article 10(2).




Figure 2-3 Decision tree for determining the overall risk of non-compliance with emission reduction commitments (WM scenario)




Figure 2-4 Decision tree for determining the overall risk of non-compliance with emission reduction commitments (WAM scenario)




3 Review results This section presents results of the review of Member State emission projections and NAPCPs.

3.1 Overview of Member State reporting

An overview of Member State reporting on air pollutant emission projections and NAPCPs is presented in Table 3-1 and discussed below.

All Member States have submitted projections and results of their review are included in this horizontal review report.

By the time of finalising this report, 24 Member States had submitted final NAPCPs and two (Italy and Luxembourg) NAPCPs were draft versions. Of these:

4 NAPCPs (Slovakia, Malta, Latvia, and Hungary) were submitted too late for full inclusion in this horizontal review report. For Slovakia and Malta a partial review of the NAPCPs could be undertaken by the time of preparation of this horizontal review report. The status of reporting and overview of the contents of these NAPCPs have been reflected in this section and Table 3-1. For Latvia, this report reflects the content of the draft NAPCP submitted as the assessment of the final NAPCP was still ongoing. For Hungary, the NAPCP could not be included in the report.

1 draft NAPCP (Italy) had not been formally published on CDR in time to be fully included in the analysis of this report. The status of reporting and overview of the contents of the draft NAPCP for Italy has however been reflected in Table 3-1 below and section 4.

1 draft NAPCP (Luxembourg) has not been formally published on CDR and was not included in the analysis of this report.

2 Member States (Greece and Romania) did not submit NAPCPs either in a draft or final version by the time of this report.

The NAPCPs of 21 Member States are therefore covered in this report in full. 20 of these are final versions and 1 is a draft version publicly available on the CDR (Latvia).

11 Member States (Belgium, Bulgaria, Croatia, Cyprus, Finland, France, Lithuania, Netherlands, Poland, Portugal, United Kingdom) have reported their NAPCPs in the common format. A further 11 (Austria, Czechia, Denmark, Germany, Italy, Ireland, Malta, Slovakia, Slovenia, Spain, Sweden) have partially followed the format e.g. used the same or similar headings but have not used the tables or have used the common format to signpost to the relevant sections in the accompanying document. NAPCPs submitted by 2 Member States (Estonia, Latvia (draft), Malta) were judged as not following the common format.

3.1.1 Timeliness of reporting

16 Member States adhered to the reporting deadline of 15 March 2019 for the projections. Only 8 Member States (Belgium, Denmark, Estonia, Finland, Netherlands, Portugal, Sweden and United Kingdom) submitted their final NAPCPs by the deadline of 1 April 2019. Only 7 Member States submitted both their projections and NAPCPs in line with the deadlines set in the NECD.

8 Member States (Austria, Bulgaria, Cyprus, Germany, France, Lithuania, Malta and Poland) submitted final NAPCPs after 1 April 2019. A draft NAPCP for Italy was submitted on 1 April 2019 but only formally published on CDR at a later date. 1 Member State (Luxembourg) submitted its draft NAPCPs after 1 April 2019 but has not published it on CDR.

8 NAPCPs (from Czechia, Croatia, Hungary, Ireland, Latvia, Slovakia, Slovenia and Spain) were initially submitted as draft versions, with the final NAPCPs resubmitted at a later date.

3.1.2 Projections scenarios reported

All Member States reported a WM scenario with their 2019 projections submitted under Article 10(2), with 19 also reporting a WAM scenario. However, 9 Member States that reported only a WM scenario projected non-compliance with one or more emission reduction commitments (Austria, Hungary, Italy, Luxembourg, Poland, Portugal, Slovenia, Sweden and the United Kingdom). Similarly, several Member




States that reported a WAM scenario also forecast non-compliance with one or more emission reduction commitments under the WAM scenario. Therefore, these Member States did not report a scenario that shows how they will comply with the emission reduction commitments for all pollutants. A more detailed assessment of compliance reporting is given in section 3.3.

Similarly, all NAPCPs presented WM projections. Where the WM scenario showed non-compliance with emission reduction commitments, all Member States except for 2 (Portugal and Slovakia11) included a WAM scenario. 5 Member States (Austria, Poland, Slovenia, Sweden and United Kingdom) did not submit a WAM scenario with their Article 10(2) projections, although there was a WAM scenario in the NAPCP and PaMs selected for adoption.

3.1.3 Reference year for projections

The projections reporting template (CLRTAP Emission Inventory Reporting Guidelines, Annex IV 2014) includes a column for reporting emissions from the historical inventory on which the projections are based (emissions from the reference year). Out of 28 Member States, only 2 (Finland and Italy) did not provide reference year emissions data in the reporting template but the data was found by the review team in other sources. Some Member States did report data but did not indicate the year that the data pertained to, and it was necessary to either obtain this information from the IIR or ask the Member State during the review. Having obtained information from the reported data files, IIRs or liaison with Member States, it was possible to conclude the following:

2 Member States (Finland and Poland) based their projections on emissions in 2015 (year x-4);

9 Member States based their projections on emissions in 2016 (year x-3) (Bulgaria, Croatia, Denmark, Estonia, France, Germany, Latvia, Romania and Spain); and

the remaining 17 Member States based their projections on emissions in 2017 (year x-2), i.e. from the emissions inventory submission made in 2019.

The reference years for projections included in the NAPCPs are largely inconsistent with the reference years of projections reported under Article 10(2) of the NECD. However, some Member States used projections that were fully consistent with the Article 10(2) submissions (see section 3.6.1 for further details of the consistency assessment).

3.1.4 Reporting on PaMs

The majority of the Member States that need to adopt additional PaMs to achieve their respective emission reduction commitments have reported information on the additional PaMs considered and selected for adoption as part of their NAPCP submission. Estonia and Latvia did not select additional PaMs for adoption, and for France and Poland the review has found that all PaMs reported have already been adopted (i.e. they are existing PaMs). Cyprus projects to achieve all emission reduction commitments for 2020-2029 and 2030 onwards and thus did not have to select additional PaMs for adoption. It did, however, report existing PaMs via the EEA-PaM tool. 20 Member States reported their PaMs using the EEA-PaM tool (Belgium, Croatia, Cyprus, Czechia, Denmark, Estonia, France, Germany, Spain, Ireland, Italy, Latvia, Lithuania, Malta, Poland, Portugal, Slovakia, Slovenia, Sweden and United Kingdom). 2 Member States (Austria and Bulgaria) did not report on its PaMs using the EEA-PaM tool despite the information being included in the main body of the NAPCP. Finland and the Netherlands did not consider additional PaMs for adoption (as they project to achieve all of their emission reduction commitments with existing PaMs) and have therefore not reported any information via the EEA-PaM tool.

3.1.5 Responsiveness

As part of the projections review, Member States were contacted by the review team with questions. All Member States were responsive during the review. Since many Member States reported draft or final NAPCPs after the reporting deadline, it was necessary to delay the review of projections for some Member States compared to the timescales initially envisaged in view of feeding information from the NAPCPs into the projections review. This substantially increased time window for the projections reviews meant that engagement with some Member States occurred several months after the start of

11 Slovakia reported a WAM scenario with Article 10(2) projections




the desk review. In particular, the review of projections for France and Malta were undertaken several months after the review of other Member States.




Table 3-1 Overview of Member State reporting

Colour coding

Requirement is met Requirement is partially met

Requirement is not met

n/a Requirement is not applicable to the Member State

- Content was not assessed

Projections NAPCP

MS Submission Date

Scenarios Base year (Note 1)

Submission Date

Status Use of the common Format

Scenarios Consistency with projections

Selected additional PaMs

PaMs reported via the EEA-PaM Tool

Additional comments

AT 15/03/2019 WM 2017 31/07/2019 Final Partial WM, WAM Yes Yes No Despite some inconsistencies between the projections and the NAPCP noted in the review, they are very small and thus overall the projections in the NAPCP are considered consistent with 2019 projections submission.

BE 15/03/2019 WM, WAM 2017 01/04/2019 Final Yes WM, WAM Yes Yes Yes While the NAPCP was submitted on time and all reporting requirements have been satisfied, the review has found that in their NAPCP Belgium reported the content of three regional plans, showing little integration between them.

BG 18/06/2019 WM, WAM 2016 26/09/2019 Final Yes WM, WAM Minor issues Yes No Despite some inconsistencies between the projections and the NAPCP noted in the review, they are small and do not impact conclusions on projected compliance with emission reduction commitments. PaMs were not




Projections NAPCP

MS Submission Date


Submission Date





Additional comments

submitted using the EEA-PaMs tool.

CY 15/03/2019 WM 2017 24/05/2019 Final Yes WM (WAM not required)

Yes n/a Yes Additional PaMs not selected for adoption as WM scenario showed compliance with emission reduction commitments. PaMs submitted via EEA-PaM tool are current PaMs.

CZ 14/04/2019 WM, WAM 2017 13/01/2020 Final Partial WM, WAM Yes Yes Yes The headings of the NAPCP do not correspond to the common format. However, in the Annex to the NAPCP, Czechia provided a table to map the contents of the NAPCP to the reporting requirements of the common format.

DE 28/05/2019 WM, WAM 2016 22/05/2019 Final Partial WM, WAM Minor issues Yes Yes Inconsistencies between projections and NAPCP apply only to NH3 under the WAM scenario and do not affect the assessment of compliance with the emission reduction commitments under the WAM scenario.

DK 15/03/2019 WM, WAM 2016 01/04/2019 Final Partial WM, WAM Minor issues Yes Yes The NAPCP is based on 2019 projections however minor differences in the projections under the WAM scenario have been noted in the review.




Projections NAPCP

MS Submission Date


Submission Date





Additional comments

EE 13/03/2019 WM, WAM 2016 29/03/2019 Final No WM, WAM Minor issues No Yes Inconsistencies between projections and NAPCP do not affect the assessment of compliance with the emission reduction commitments under the WAM scenario.

Additional PaMs considered but not selected for adoption.

EL 04/07/2019 WM, WAM 2017 No NAPCP submission by the time of finalisation of the report.

ES 14/03/2019 WM, WAM 2016 03/10/2019 Final Partial WM, WAM Yes Yes Yes The report follows the same order as the common format and includes most of the same sections although the common format is not used.

FI 15/02/2019 WM None (2015)

29/03/2019 Final Yes WM (WAM not required)

Minor issues n/a n/a Additional PaMs not selected for adoption as WM scenario showed compliance with emission reduction commitments.

Inconsistencies between projections and NAPCP do not affect the assessment of compliance with the emission reduction commitments.

FR 01/10/2019 WM, WAM 2016 09/10/2019 Final Yes WM, WAM Major issues No Yes The projections in the NAPCP are inconsistent with projections submitted under Article 10(2). The differences affect the conclusions on




Projections NAPCP

MS Submission Date


Submission Date





Additional comments

compliance with emission reduction commitments for some pollutants. The review has found that all PaMs reported in the NAPCP are existing (i.e. not additional) PaMs.

HR 15/03/2019 WM, WAM 2016 11/10/2019 Final Yes WM, WAM Major issues Yes Yes The main inconsistency between the projections in NAPCP and Article 10(2) concerns compliance with NH3 emission reduction commitment.

HU 18/03/2019 WM Not stated (2017)

18/05/2020 Final - - - - - The final NAPCP has been submitted, but too late for inclusion in this report.

IE 15/03/2019 WM, WAM 2017 13/02/2020 Final Partial WM, WAM Major issues Yes Partial The common format is not fully followed, but headings used in the NAPCP correspond to the headings in the common format.

Inconsistencies between WM scenario projections affect projected compliance for SO2 and between WAM scenario projections for NMVOCs.

The PaMs were reported via the EEA-PaM tool on 26/09/2019 and were not subsequently updated to align them with the final NAPCP.




Projections NAPCP

MS Submission Date


Submission Date





Additional comments

IT 14/03/2019 WM None (2017)

01/04/2019 Draft Partial WM, WAM Major issues Yes Yes The NAPCP is a draft version. The common format is not fully followed, but some of the headings used in the NAPCP correspond to the headings in the common format. Inconsistencies between projections and NAPCP affect projected compliance with 2020-29 commitments for NMVOC.

LT 02/04/2019 WM, WAM Not stated (2017)

02/06/2019 Final Yes WM, WAM Major issues Yes Yes Inconsistencies between projections and NAPCP affect projected compliance with 2020-29 commitments for SO2, NOX and PM2.5. and affect projected compliance with 2030 onwards commitment for SO2.

LU 15/03/2019 WM 2017 03/05/2019 Draft - - - - - The draft NAPCP has not been formally published on CDR and has not been included in the analysis of this report.

LV 28/03/2019 WM, WAM 2016 02/04/2019 Draft No WM, WAM Yes Yes Yes The final NAPCP was submitted on 16 April 2020. The common format is not followed in the draft NAPCP. The review has found inconsistencies in reporting on PaMs via the EEA-PaM tool and in the NAPCP including




Projections NAPCP

MS Submission Date


Submission Date





Additional comments

on whether PaMs have been selected for adoption.

MT 31/07/2019 WM, WAM 2017 18/03/2020 Final Partial WM, WAM Yes Yes Yes The common format is not fully followed, but some of the headings used in the NAPCP correspond to the headings in the common format.

NL 04/04/2019 WM, WAM 2017 01/04/2019 Final Yes WM (WAM not required)

Minor issues n/a n/a Inconsistencies between projections and NAPCP do not affect the assessment of compliance with the emission reduction commitments under the WAM scenario.

PL 15/03/2019 WM 2015 27/06/2019 Final Yes WM, WAM Major issues No Yes Inconsistencies between projections and NAPCP affect compliance with the emission reduction commitments under the WM scenario. Poland did not submit WAM scenario with 2019 projections.

No additional PaMs have been considered (PaMs reported are existing PaMs).

PT 05/07/2019 WM 2017 01/04/2019 Final Yes WM Major issues No Yes No additional PaMs are considered by Portugal. Information reported to the PaMs tool by Portugal concerns existing PaMs.

Inconsistencies between projections and NAPCP affect projected compliance for SO2




Projections NAPCP

MS Submission Date


Submission Date





Additional comments

(commitment projected to be achieved under the projections reported under Article 10(2), but not in the NAPCP).

RO 15/03/2019 WM, WAM 2016 No submission by the time of finalisation of the report.

SE 14/03/2019 WM Not stated (2017)

01/04/2019 Final Partial WM, WAM Yes Yes Yes Projections and NAPCP are consistent for WM scenario but no WAM projections scenario is reported under Article 10(2).

SK 16/03/2019 WM, WAM Not stated (2017)

03/03/2020 Final Partial WM Yes Yes Yes The common format is not fully followed, but headings used in the NAPCP correspond to the headings in the common format (with different numbering).

The NAPCP does not include WAM scenario projections despite PaMs having been selected for adoption in the NAPCP.

Sl 13/03/2019 WM 2017 10/10/2019 Final Partial WM, WAM Major issues Yes Yes PaMs were reported via the EEA-PaM tool on 25/11/2019.

Inconsistencies between projections and NAPCP affect projected compliance with 2020-2029 emission reduction commitments for SO2 and NOX (commitments not




Projections NAPCP

MS Submission Date


Submission Date





Additional comments

projected to be achieved under Article 10(2) but projected to be achieved in the NAPCP).

UK 15/03/2019 WM 2017 29/03/2019 Final Yes WM, WAM Minor issues Yes Yes Inconsistencies between projections and NAPCP do not affect the assessment of compliance with the emission reduction commitments. No WAM scenario is reported under Article 10(2).

Note 1: Some Member States did not specify the reference year with their projections submitted under Article 10(2), but it was specified either in the IIR or confirmed by the Member State during the review. This is shown as “Not stated” followed by the reference year in brackets. Where no reference year data were reported in the Article 10(2) submission, “None” is indicated, and the reference year is included in brackets, again determined either from the IIR of through consultation with the Member State




3.2 Completeness assessment

The completeness assessment determined whether the Member States have complied with the minimum content requirements for the NAPCPs specified in Article 6 and Annex III and Annex IV(2) to the NECD and the reporting requirements for air pollutant emission projections specified in Article 10(2) and Annex I Table C to the NECD.

3.2.1 Mandatory content

A summary of completeness of Member State reporting on projections and NAPCPs is presented in Table 3-2 and described below for each reporting obligation12. Overall, Member States reported the majority of the mandatory content required by the NECD.

3.2.1.1 Reporting mandatory content of the NAPCPs

The majority of Member State submissions contained sufficient information to meet the mandatory reporting requirements (Table 3-2); however, detail was found to be insufficient in many cases (resulting in an amber or red rating). Gaps and insufficient detail were more commonly identified where Member States did not fully use the common format or did not report via the EEA-PaM Tool.

The most significant reporting gaps (in terms of establishing overall Member State compliance with their respective emission reduction commitments) were found to be where no information on additional PaMs was provided, or where there were gaps in reporting on emission projections (typically under a WAM scenario, however in a few cases gaps were also identified in reporting of WM scenario projections). Major gaps in reporting on the additional PaMs and the WAM scenario were identified for 4 Member States (Estonia, France, Poland and Portugal) and led to a red rating. For 7 Member States (Austria, Bulgaria, Croatia, Czechia, Ireland, Latvia and Slovenia) minor gaps in reporting of the additional PaMs were found.

Less significant but more common gaps in reporting were the lack of provision of the year of the inventory data used to underpin the projections and lack of explanations for non-linear emission trajectories (as well as failing to acknowledge where a non-linear emission trajectory was projected). Through the completeness assessment, it became apparent that the NAPCP common format did not facilitate reporting of the historical inventory year as it was unclear where the information should be reported. Furthermore, where Member States were not required to consider and select PaMs for adoption (because they projected to meet the emission reduction commitments with existing measures), the common format did not facilitate reporting on the implementation of measures for the agriculture sector listed in Annex III Part 2 (this reporting requirement applies to existing as well as additional PaMs) and an explanation for non-linear emission trajectories.

3.2.1.2 Reporting mandatory content of projections (pollutants, sectors and years)

All submissions provided projections for all the mandatory pollutants, and for all mandatory years (see Table 3-2 below). All sectors were also reported by all Member States.

However, there were numerous examples of specific sources being omitted. These omissions were typically small sources that did not have a large impact on the national total of the pollutant in question. All these omissions are detailed in the projections report that have been prepared for each Member State. Where the omission of sources did give rise to a large impact on the national total, it has been noted in the additional comments column in Table 3-2 below.

12 Review of the NAPCPs for Slovakia and Malta was not completed by the time of finalisation of this report and the results of their completeness assessments are therefore not included in this section.




Table 3-2 Completeness of Member State reporting on mandatory content

Colour coding

Content is fully complete

Content is mostly complete, minor gaps identified

Content is incomplete, major gaps identified

n/a Content is not applicable to the Member State

- Content was not assessed

Projections NAPCP

MS Coverage of pollutants13

Coverage of sectors1

Years Additional comments NAPCP PaMs Additional comments

AT All All Ref, 2020, 2025, 2030 Amber Amber Projected improvements in air quality under WM scenario are not described in terms of the projected degree of compliance with EU air quality objectives.

Austria does not report via the EEA-PaM tool; however, information on PaMs is complete in the summary table provided with the NAPCP.

BE All All Ref, 2020, 2025, 2030 Amber Green Information on the non-linear trajectory followed for NH3 and NMVOC and the year of the historical inventory data underpinning the projections were not reported.

BG All All Ref, 2020, 2025, 2030 Amber Amber The NAPCP is mostly complete but does not include submission date, the responsible competent authorities’ contact details and information on stakeholder consultation. No hyperlinks to the

13 This summary notes only whether the Member State’s projections lacks estimates of emissions of a particular pollutant across all sectors, or estimates from a particular sector for all pollutants, without an appropriate notation key. There are numerous cases where specific sources have been omitted for some pollutants. These have been included in the additional comments where there is a large impact on the national total projections is large. All of the detailed omissions are provided in the Member State specific projections review reports.




Projections NAPCP




publicly available supporting datasets have been provided.

Bulgaria does not report via the EEA-PaM tool. It has not provided information on the impacts on air quality and the environment of individual PaMs or packages of PaMs considered for adoption.

CY All All Ref, 2020, 2025, 2030 Green n/a The reporting has been found complete. Cyprus has not considered additional PaMs as it projects to meet its national emission reduction commitments under a WM scenario.

CZ All All Ref, 2020, 2025, 2030 Some sources are not included in the projections e.g. NMVOC from some industrial processes. Projected emissions of both NOX and NMVOC from agriculture are not included.

Amber Amber The NAPCP has been found mostly complete, however no explanation is provided by Czechia to justify the non-linear emission reduction trajectory projected for NH3. There are some inconsistencies in reporting on the PaMs in the NAPCP and the EEA-PaM tool.

DE All All Ref, 2020, 2025, 2030 Amber Green When describing policy priorities, no information is provided for some sectors. The year of the historical inventory data underpinning the projections is not reported.

DK All All Ref, 2020, 2025, 2030 Amber Green Projected improvements in air quality under WM scenario are not described for O3. Information on the non-linear trajectory followed for SO2 and NH3 was not reported.




Projections NAPCP




EE All All Ref, 2020, 2025, 2030 Projected emissions of both NOX and NMVOC from Agriculture are not included.

Amber Red The year of the historical inventory data underpinning the projections is not reported. Estonia does not provide projected impacts on air quality under a WM scenario. Information reported in the NAPCP contradicts information reported via the EEA PaM-tool. No explanation is presented in the NAPCP to justify the non-linear trend in emission reduction for NH3.

PaMs selected for adoption are not reported.

EL All All Ref, 2020, 2025, 2030 - - No submission by the time of finalisation of the report.

ES All All Ref, 2020, 2025, 2030 Green Green The reporting has been found complete.

FI All All 2020, 2025, 2030 Data for the reference year were not reported

Amber n/a The NAPCP is very brief and relies on references to external content with limited information provided in the NAPCP itself.

Finland has not considered additional PaMs as it projects to meet its national emission reduction commitments under a WM scenario.

FR All All Ref, 2020, 2025, 2030 Red Red Main gaps are lack of reporting on: progress made by current PaMs in reducing NMVOC emissions, the current transboundary impact of national emission sources and the projected impact on improving air quality under WM scenario.




Projections NAPCP




France provides the mandatory content via the EEA-PaM tool; however, the review has found that all PaMs reported were already adopted (i.e. should be categorised as existing PaMs).

HR All All Ref, 2020, 2025, 2030 Some sources are not included in the projections e.g. NMVOC from some industrial processes, PM2.5 and NH3 from some agriculture sources. Projected emissions of both NOX and NMVOC from Agriculture are not included.

Amber Amber The year of the inventory data underpinning the projections is not provided. Information on air quality impacts of WM scenario is very brief. Reporting in the NAPCP is inconsistent with reporting in the EEA-PaM tool.

HU All All Ref, 2020, 2025, 2030 Data were reported for the reference year in Annex IV, but the year was not specified.

- - The NAPCP had not been submitted on time to be included in this report.

IE All All Ref, 2020, 2025, 2030 Amber Amber Information on the non-linear trajectory followed for NH3 and NMVOC was not reported in the draft NAPCP.

Information on PaMs is incomplete, (detail is missing on the type of PaMs, impacts on air quality and coherence with other policy priorities).

IT* All All 2020, 2025, 2030 Projected emissions of NH3 and PM2.5 are missing from some agricultural sources. Projected emissions of both NOX and NMVOC from Agriculture are not included.

- - The draft NAPCP had not been formally published on CDR in time to be included in the analysis of this report.




Projections NAPCP




Data for the reference year were not reported.

LT All All Ref, 2020, 2025, 2030 Data were reported for the reference year in Annex IV, but the year was not specified.

Green Green The reporting has been found complete.

LU All All Ref, 2020, 2025, 2030 - - The draft NAPCP has not been formally published on CDR and has not been included in the analysis of this report.

LV* All Ref, 2020, 2025, 2030 Amber Amber The emission reduction projections reported in the draft NAPCP for the WM scenario have only been reported in histograms. Emission projections under the WM scenario are not reported otherwise. Projections on the impact on air quality have not been provided under the WM scenario.

There is a discrepancy between the draft NAPCP and the EEA-PaM tool regarding PaMs selected for adoption.

Final NAPCP was subsequently submitted but too late to include it in the analysis of this report.

MT All All Ref, 2020, 2025, 2030 - - Assessment of completeness of the NAPCP was not concluded by the time of submission of this report.




Projections NAPCP




NL All All Ref, 2020, 2025, 2030 Green n/a Netherlands has not considered additional PaMs as it projects to meet its national emission reduction commitments under a WM scenario.

PL All All Ref, 2020, 2025, 2030 Amber Red Reporting on current progress in improving air quality is not provided.

Reporting on WM projections scenario includes gaps. Mandatory information is missing for some PaMs. Inconsistencies in reporting via the EEA-PaM tool and the NAPCP have been found. The review has found that all PaMs reported were already adopted (i.e. should be categorised as existing PaMs).

PT All All Ref, 2020, 2025, 2030 Red Red Projections under a WAM scenario are not reported despite some commitments being missed under WM scenario. No additional PaMs have been considered.

RO All All Ref, 2020, 2025, 2030 - - No submission by the time of finalisation of the report.

SE All All Ref, 2020, 2025, 2030 Data were reported for the reference year in Annex IV, but the year was not specified.

Amber Green Policy making and enforcement roles are not described. The year of the historical inventory underpinning the projections has not been reported.

SK All All Ref, 2020, 2025, 2030 Data were reported for the reference year in Annex IV, but the year was not specified.

- - Assessment of completeness of the NAPCP was not concluded by the time of submission of this report




Projections NAPCP




SI All All Ref, 2020, 2025, 2030 Projected emissions of SO2 from some industrial process emissions are not included. Projected emissions of both NOX and NMVOC from agriculture are not included.

Amber Amber Policy priorities for certain sectors, the date of the projections and projected degree of compliance with EU air quality standards under the WM scenario are not reported in the NAPCP.

The main gap in reporting on the PaMs is lack of quantification of projected emission reductions from the PaMs considered and selected for adoption.

UK All All Ref, 2020, 2025, 2030 Amber Green For several reporting requirements the UK has reported very limited content. The inventory year underpinning the projections was not provided.

Notes: (*) Results of the assessment of draft NAPCP




3.2.2 Optional content

3.2.2.1 Reporting optional content of the NAPCP

The provision of optional content in the NAPCPs was variable between Member States. The most commonly reported optional content was:

The provision of graphics to accompany mandatory reporting (15 Member States provided graphics to show progress made by current PaMs in reducing emissions and 12 to show progress made in improving air quality).

Optional measures relating to agriculture in Annex III, Part 2 to the NECD (15 Member States).

The identification of authorities responsible for source sectors (13 Member States).

The provision of an executive summary (11 Member States).

Associated uncertainties of the projected emissions (10 Member States).

Methodologies and data used to show the current transboundary impact of national emission sources (9 Member States).

Some estimation of costs and benefits of additional PaMs was provided by 6 Member States (Bulgaria, Czechia, Croatia, Denmark, Estonia and Sweden). In addition, Cyprus reported information on the costs of some of the already adopted PaMs. The projected impacts on the environment (under a WAM scenario) was not reported by any Member State.

3.2.2.2 Reporting optional content of projections (pollutants, years and sensitivity analysis)

There was relatively little reporting of optional content. 14 of the Member States included projections for black carbon (BC), and only 4 Member States included reporting of projections for 2040 and/or 2050 (see Table 3-8 below).

6 Member States (Croatia, Finland, Ireland, Latvia, Spain and the United Kingdom) reported information on sensitivity analysis. The detail and extent of the information reported, or provided during the review, varied greatly. It was typically information on a basic sensitivity analysis which considered the impact of varying key input datasets. Finland provided some sensitivity analysis during the review, and the United Kingdom reported ranges for different PaMs and scenarios in their NAPCP (which is more informative than reporting results from a sensitivity analysis).

Table 3-3 Completeness of Member State reporting on optional content for projections

Member State Black Carbon Years Sensitivity Analysis

Austria - - -

Belgium - - -

Bulgaria - - -

Croatia - 2040, 2050 Reported in IIR

Cyprus Reported - -

Czechia Reported - -

Denmark Reported - -

Estonia - - -

Finland Reported Provided during the

review

France - - -

Germany - - -

Greece Reported 2040 -




Member State Black Carbon Years Sensitivity Analysis

Hungary Reported - -

Ireland Reported - Reported in IIR

Italy - - -

Latvia Reported - Reported in IIR

Lithuania - - -

Luxembourg - - -

Malta Reported - -

Netherlands Reported - -

Poland - - -

Portugal Reported 2040, 2050 -

Romania Reported - -

Slovakia - - -

Slovenia - - -

Spain - 2040 Reported in IIR

Sweden Reported - -

United Kingdom Reported - Reported in NAPCP

3.3 Progress towards emission reduction commitments and a linear emission reduction trajectory

The projections for 2020 and 2030 submitted by Member States under Article 10(2) of the NECD have been compared against the emission reduction commitments for 2020-2029 and 2030 onwards.

There are 4 Member States (Croatia, Cyprus, Finland and the Netherlands) which report compliance with all of the 2020 and 2030 emission reduction commitments under the WM scenario.

For all other cases, three types of outcome involving non-compliance are presented in the following sections:

1. The WM scenario projects non-compliance, and the WAM scenario projects compliance. This indicates that the introduction of additional PaMs delivers the required impacts on the projected emissions to ensure compliance.

2. The WM scenario projects non-compliance, and the WAM scenario also projects non-compliance. This indicates that the introduction of additional PaMs does not deliver the required impacts on the projected emissions to ensure compliance. There is consequently an outstanding requirement to provide information on how compliance will be achieved.

3. The WM scenario projects non-compliance, and no WAM scenario has been reported. There is consequently an outstanding requirement to provide information on how compliance will be achieved.

Points 2 or 3 above apply to many Member States. The analysis in the following sections indicates that the following 18 Member States have not provided projections which demonstrate how all of the emission reduction commitments will be met: Austria, Denmark, Estonia, Germany, Hungary, Ireland,




Italy, Latvia, Lithuania, Luxembourg, Malta, Poland, Portugal, Romania, Slovakia, Spain, Sweden and the United Kingdom.

3.3.1 Projected compliance with 2020 -2029 emission reduction commitments

Given that this review was conducted in 2019, there is very little time for Member States to address any projected non-compliance in 2020. For several Member States there is a clear shortcoming in their reporting because they do not provide a projections scenario which predicts compliance.

The table below presents the number of Member States reporting compliance with emission reduction commitments in 2020 under WM and WAM scenarios. The number of Member States reporting compliance under a WAM scenario is lower than for the WM scenarios because not all Member States reported WAM scenarios (not because the WAM projections are higher than the WM projections).

Table 3-4 The number of Member States reporting compliance with emission reduction commitments in 2020

SO2 NOX NMVOC NH3 PM2.5

Member States reporting compliance in 2020 under a WM scenario 27/28 22/28 21/28 16/28 23/28

Member States reporting compliance in 2020 under a WAM scenario 17/17 14/17 14/17 12/17 15/17

Compliance with emission reduction commitments in 2020 is considered on a pollutant by pollutant basis below, and shown in Figure 3-1 to Figure 3-5. The percentage values in the figure below indicate the projected margins of compliance (expressed as a percentage of the compliance threshold, defined as the maximum allowed emissions in a given year) for the WM scenario, and the WAM scenario where available. Negative values indicate exceedance of the compliance threshold.




Compliance with the SO2 2020-2029 emission reduction commitment in 2020

Poland projects non-compliance with the SO2 emission reduction commitment in 2020. The projections data is taken from the WM scenario, as Poland

did not submit a WAM scenario.

Figure 3-1 Comparison of SO2 projected emissions and emission reduction commitments for 2020, under both WM and WAM scenarios from the projections submission





Compliance with the NOX 2020-2029 emission reduction commitment in 2020

France projects non-compliance with the NOX emission reduction commitment in 2020 under the WM scenario, but provides a WAM scenario that

projects compliance.

Latvia, Lithuania and Romania project non-compliance with the NOX emission reduction commitment in 2020 under the WM scenario, and also project non-compliance under the WAM scenario.

Poland and Slovenia project non-compliance with the NOX emission reduction commitment in 2020 under the WM scenario, and did not submit a WAM scenario.

Figure 3-2 Comparison of NOX projected emissions and emission reduction commitments for 2020, under both WM and WAM scenarios from the projections submission





Compliance with the NMVOC 2020-2029 emission reduction commitment in 2020

Bulgaria projects non-compliance with the NMVOC emission reduction commitment in 2020 under the WM scenario, but provides a WAM scenario

that projects compliance.

Ireland, Malta and Romania project non-compliance with the NMVOC emission reduction commitment in 2020 under the WM scenario, and also project non-compliance under the WAM scenario.

Hungary, Italy and Poland project non-compliance with the NMVOC emission reduction commitment in 2020 under the WM scenario, and did not submit a WAM scenario.

Figure 3-3 Comparison of NMVOC projected emissions and emission reduction commitments for 2020, under both WM and WAM scenarios from the projections submission





Compliance with the NH3 2020-2029 emission reduction commitment in 2020

France and Lithuania project non-compliance with the NH3 emission reduction commitment in 2020 under the WM scenario, but provide a WAM

scenario that projects compliance.

Denmark, Estonia, Germany, Ireland and Latvia project non-compliance with the NH3 emission reduction commitment in 2020 under the WM scenario, and also project non-compliance under the WAM scenario.

Austria, Hungary, Sweden and the United Kingdom project non-compliance with the NH3 emission reduction commitment in 2020 under the WM scenario, and did not submit a WAM scenario.

Figure 3-4 Comparison of NH3 projected emissions and emission reduction commitments for 2020, under both WM and WAM scenarios from the projections submission





Compliance with the PM2.5 2020-2029 emission reduction commitment in 2020

Bulgaria projects non-compliance with the PM2.5 emission reduction commitment in 2020 under the WM scenario, but provides a WAM scenario that

projects compliance.

Denmark and Romania project non-compliance with the PM2.5 emission reduction commitment in 2020 under the WM scenario, and also project non-compliance under the WAM scenario.

Hungary and the United Kingdom project non-compliance with the PM2.5 emission reduction commitment in 2020 under the WM scenario, and did not submit a WAM scenario.

Figure 3-5 Comparison of PM2.5 projected emissions and emission reduction commitments for 2020, under both WM and WAM scenarios from the projections submission.





3.3.2 Projected compliance with 2030 onwards emission reduction commitments

Given that this review was conducted in 2019, Member States still have time to introduce additional PaMs to bring about significant impacts on the emissions projected to arise in 2030.

The table below presents the number of Member States reporting compliance with emission reduction commitments in 2030 under WM and WAM scenarios.

Table 3-5 The number of Member States reporting compliance with emission reduction commitments in 2030

SO2 NOX NMVOC NH3 PM2.5

Member States reporting compliance in 2030 under a WM scenario 18/28 10/28 14/28 9/28 13/28

Member States reporting compliance in 2030 under a WAM scenario 15/17 13/17 13/17 12/17 14/17

Compliance with emission reduction commitments in 2030 is considered on a pollutant by pollutant basis below, and shown in Figure 3-6 to Figure 3-10. The percentage values in the figure below indicate the projected margins of compliance (expressed as a percentage of the compliance threshold, defined as the maximum allowed emissions in a given year) for the WM scenario, and the WAM scenario where available. Negative values indicate exceedance of the compliance threshold.




Compliance with the SO2 2030 onwards emission reduction commitment in 2030

Denmark, Germany, Ireland and Spain project non-compliance with the SO2 emission reduction commitment in 2030 under the WM scenario, but

provide a WAM scenario that projects compliance.

Romania and Slovakia project non-compliance with the SO2 emission reduction commitment in 2030 under the WM scenario, and also project non-compliance under the WAM scenario.

Hungary, Poland, Slovenia and the United Kingdom project non-compliance with the SO2 emission reduction commitment in 2030 under the WM scenario, and did not submit a WAM scenario.

Figure 3-6 Comparison of SO2 projected emissions and emission reduction commitments for 2030, under both WM and WAM scenarios from the projections submission





Compliance with the NOX 2030 onwards emission reduction commitment in 2030

Bulgaria, Czechia, France, Germany, Greece, Latvia, Slovakia and Spain project non-compliance with the NOX emission reduction commitment in

2030 under the WM scenario, but provide a WAM scenario that predicts compliance.

Ireland, Lithuania, Malta and Romania project non-compliance with the NOX emission reduction commitment in 2020 under the WM scenario, and also project non-compliance under the WAM scenario.

Austria, Hungary, Italy, Luxembourg, Sweden, and the United Kingdom project non-compliance with the NOX emission reduction commitment in 2030 under the WM scenario, and did not submit a WAM scenario.

Figure 3-7 Comparison of NOX projected emissions and emission reduction commitments for 2030, under both WM and WAM scenarios from the projections submission





Compliance with the NMVOC 2030 onwards emission reduction commitment in 2030

Bulgaria, Czechia, Greece and Malta project non-compliance with the NMVOC emission reduction commitment in 2030 under the WM scenario, but


Ireland, Lithuania, Romania and Spain project non-compliance with the NMVOC emission reduction commitment in 2030 under the WM scenario, and also project non-compliance under the WAM scenario.

Hungary, Italy, Luxembourg, Portugal, Slovenia and the United Kingdom project non-compliance with the NMVOC emission reduction commitment in 2030 under the WM scenario, and did not submit a WAM scenario.

Figure 3-8 Comparison of NMVOC projected emissions and emission reduction commitments for 2030, under both WM and WAM scenarios from the projections submission





Compliance with the NH3 2030 onwards emission reduction commitment in 2030

Belgium, Bulgaria, Czechia, France, Germany, Latvia and Spain project non-compliance with the NH3 emission reduction commitment in 2030 under

the WM scenario, but provide a WAM scenario that projects compliance.

Denmark, Estonia, Ireland, Lithuania and Malta project non-compliance with the NH3 emission reduction commitment in 2030 under the WM scenario, and also project non-compliance under the WAM scenario.

Austria, Hungary, Italy, Luxembourg, Poland, Sweden and the United Kingdom project non-compliance with the NH3 emission reduction commitment in 2030 under the WM scenario, and did not submit a WAM scenario.

Figure 3-9 Comparison of NH3 projected emissions and emission reduction commitments for 2030, under both WM and WAM scenarios from the projections submission





Compliance with the PM2.5 2030 onwards emission reduction commitment in 2030

Bulgaria, Germany, Latvia and Spain project non-compliance with the PM2.5 emission reduction commitment in 2030 under the WM scenario, but


Denmark, Lithuania and Romania project non-compliance with the PM2.5 emission reduction commitment in 2030 under the WM scenario, and also project non-compliance under the WAM scenario.

Austria, Hungary, Italy, Luxembourg, Poland, Portugal, Slovenia and the United Kingdom project non-compliance with the PM2.5 emission reduction commitment in 2030 under the WM scenario, and did not submit a WAM scenario.

Figure 3-10 Comparison of PM2.5 projected emissions and emission reduction commitments for 2030, under both WM and WAM scenarios from the projections submission





3.3.3 Emission reduction trajectory

Article 4 of the NECD requires Member States to “take the necessary measures aimed at limiting their 2025 anthropogenic emissions of SO2, NOX, NMVOC, NH3 and PM2.5”, and that “… indicative levels of those emissions shall be determined by a linear reduction trajectory established between their emission levels defined by the emission reduction commitments for 2020 and the emission levels defined by the emission reduction commitments for 2030.”

Article 4 goes on to state that Member States may follow a non-linear reduction trajectory, but that where they cannot follow a linear reduction trajectory, “the reasons for that deviation as well as the measures that would bring the Member States back on their trajectory” must be reported. According to Annex III, Part 1, 1(d) to the NECD, an explanation of the reasons why the indicative emission levels for 2025 cannot be met without measures entailing disproportionate costs must be included in the NAPCP. This is a mandatory reporting requirement, but relevant only where a Member State projects to reduce emissions in a non-linear way between 2020 and 2030.

There are numerous Member States that according to the Article 10(2) projections predict emissions in 2025 which exceed the linear reduction between the compliance thresholds for 2020 and 2030. None of these Member States report detailed information on measures that will bring them back onto the linear reduction trajectory. However, in all cases where the linear reduction trajectory is exceeded in 2025, it is accompanied by non-compliance with either or both of the corresponding 2020-29 and 2030 onwards emission reduction commitments.

The important issue that arises is that Member States are reporting WAM scenarios (or WM if a WAM scenario is not reported) that do not show how they will comply with the emission reduction commitments in 2020 and 2030. Until these Member States report projections scenarios that comply with the emission reduction commitments, there is little value in assessing whether the projections comply with the linear reduction trajectory requirements.

For completeness, the table below shows Member States that are forecasting emissions in 2025 which are above the linear reduction trajectory for the WAM scenario, or the WM scenario where no WAM scenario has been submitted. In every case, this is accompanied by the exceedance of the emissions reduction commitment for 2020 and/or 2030, based on projections submitted under Article 10(2) of the NECD. The issue of exceeding the linear reduction trajectory may be addressed if the relevant Member States submit a WAM scenario that is compliant with the emission reduction commitments for both 2020 and 2030.




Table 3-6 Projection scenarios for which 2025 emissions projections exceed the 2025 linear reduction trajectory; and the year in which the emission reduction commitment is projected to be exceeded (based on Article 10(2) projections)

Member State SO2 NOX NMVOC NH3 PM2.5

Austria - - - WM (no WAM)

2020, 2030 -

Denmark - - - WAM

2020, 2030 WAM

2020, 2030

Estonia - - - WAM

2020, 2030 -

Hungary - WM (no WAM)

2030 WM (no WAM)

2020, 2030 WM (no WAM)

2020, 2030 WM (no WAM)

2020, 2030

Ireland - - WAM

2020, 2030 WAM

2020, 2030 -

Italy - - WM (no WAM)

2020, 2030 WM (no WAM)

2030 -

Lithuania - WAM

2020, 2030 WAM 2030

-

Luxembourg - - - WM (no WAM)

2020, 2030 -

Malta - WAM 2030

- - -

Poland WM (no WAM) 2020, 2030

WM (no WAM) 2020

WM (no WAM) 2020

WM (no WAM) 2030

WM (no WAM) 2030

Portugal - - WM (no WAM)

2030 - -

Romania - WAM

2020, 2030 WAM

2020, 2030 -

WAM 2020, 2030

Slovenia - - WM (no WAM)

2030 - -

Spain - - WAM 2030

- -

Sweden - - - WM (no WAM)

2020, 2030 -

United Kingdom - - - WM (no WAM)

2020, 2030 WM (no WAM)

2020, 2030

Notes: Emission reductions for Belgium, Bulgaria, Croatia, Cyprus, Czechia, Finland, France, Germany, Greece, Latvia, Netherlands and Slovakia follow a linear trajectory between 2020 and 2030.




Analysis of the NAPCPs14, as presented in Table 3-7 below, indicate that reasons for Member States not following a linear emission reduction trajectory have generally not been reported by the Member States. The list of Member States projecting the non-linear trajectory in the NAPCPs is different to the list of Member States projecting the non-linear trajectory on the basis of Article 10(2) projections. According to the projections in the NAPCPs, 11 Member States project to reduce emissions of at least one pollutant in a non-linear way between 2020 and 2030 (Austria, Belgium, Czechia, Denmark, Germany, Ireland, Latvia, Lithuania, Poland, Spain, United Kingdom). Of these, only 3 Member States (Austria, Poland, United Kingdom) have provided an explanation to support this. These explanations have focused primarily on technical limitations, with no discussion of alternative measures that would entail disproportionate costs.

Reporting on a non-linear trajectory is covered in section 2.8 of the NAPCP common format (‘Projected combined impacts of PaMs (‘With Additional Measures’ — WAM) on emission reductions, air quality and the environment and the associated uncertainties (where applicable)’). The review has found that Member States which did not develop a WAM scenario, did not provide any information on the trajectory of future emission reductions in their NAPCPs. Article 4(2) of the NECD requiring Member States to determine indicative 2025 emission levels and explaining the circumstances in which a non-linear trajectory can be followed, does not distinguish if the trajectory applies to WM and WAM projection scenarios. Thus, a Member State which does not follow a linear emission reduction trajectory under WM projections, and does not plan to adopt additional PaMs (i.e. no WAM scenario), should also explain the reasons for it. This has been identified as a limitation of the NAPCP common format.

Table 3-7 Information on non-linear emission reductions, reported as part of NAPCPs

Information on non-linear trajectory reported as part of NAPCPs Member State

Emission reductions follow a non-linear trajectory for at least one pollutant - explanation has been provided

AT, PL, UK

Emission reductions follow a non-linear trajectory for at least one pollutant - explanation is missing

BE, CZ, DE, DK, ES, IE, LT, LV

Emission reductions follow a linear trajectory - no explanation is required in the NAPCP

BG, FR, HR, SE, SI

No WAM scenario was provided thus no information on the linear trajectory was reported in the NAPCP

EE, CY, FI, NL, PT

3.3.4 Use of flexibilities

Article 5 of the NECD provides flexibilities that can be used by the Member States with respect to the reporting of national emission inventories (Article 5(1)) and cases where exceptional circumstances result in unplanned non-compliance with emission reduction commitments (Article 5(2) and 5(4)). These flexibilities relate to the assessment of compliance with emission reduction commitments and as such have not been relevant for the Member State reporting on air pollutant emission projections and NAPCPs in 2019. These flexibilities are more relevant in the context of historical emission inventories.

According to the NAPCP Guidance15, the flexibility mechanism described in Article 5(3) could have been taken into account in policy planning by the Member States and thus reflected in the content of the NAPCPs. Article 5(3) states that in specific cases, non-compliance with emission reduction commitments for one pollutant could be compensated by an equivalent emission reduction of another pollutant from Annex II of the NECD.

Information on the use of flexibilities is asked for in table 2.8.3 of the NAPCP common format and it is a mandatory content “where flexibilities are used”.

14 Review of the NAPCPs for Slovakia and Malta was not completed in time to be included in the analysis presented in this section of this report.

15 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2019.077.01.0001.01.ENG

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2019.077.01.0001.01.ENG




Only 4 Member States (Germany, Ireland, Poland and Slovenia) included in their NAPCPs information on the use of Article 5 flexibilities. All these Member States have already made, or plan to make, use of flexibilities under Article 5(1) concerning inventory adjustment. In addition, Poland referred to the use of flexibility under Article 5(2) concerning compliance with emission reduction commitments in cases of exceptionally cold winter or dry summer and Ireland referred to application of the Article 5(3) flexibility.

No Member State referred in its NAPCP to the flexibility offered by Article 5(4) which refers to circumstances that could not be foreseen (a sudden and exceptional interruption or loss of capacity in the power and/or heat supply or production system).

3.4 Quality of Member State projections

3.4.1 Overview

The following sections present the results from a quality assessment of each Member State projections submission.

There are cases where very limited information was included in the submission. Some additional information was provided by Member States during the review. However, for many Member States the review teams and lead reviewers had to make the quality assessment based on the limited information available to them at the time.

3.4.2 Method

The quality assessments were undertaken during the centralised review by lead reviewers. Completing the quality assessment during the centralised review alongside other lead reviewers ensured consistency in approach. Furthermore, as the centralised review was held after the desk review was completed, it was possible for the lead reviewers to draw on the detailed findings of the desk review, i.e. the individual recommendations and encouragements that are presented in the individual Member State projections review reports.

The quality assessment presented in the individual Member State projections review reports includes assessment results disaggregated by pollutant and by 2020 and 2030, i.e. there are ten ratings for each quality criterion. However, the results presented in this report are an aggregation or subsets of the results presented in the individual Member State reports to highlight certain features of the results.

3.4.3 Quality – by quality criteria

Table 3-8 below presents a summary of the quality assessments undertaken for each Member State. A more detailed consideration of each of the quality criteria is given in sections 3.4.4 to 3.4.8.

The data presented in Table 3-8 below represents an aggregation of the information presented in each of the individual Member State reports, where quality ratings are given according to different criteria for each pollutant and resolved into 2020 and 2030. For presentational purposes in this report, these ratings have been aggregated across the years and pollutants to give a single rating for each quality criterion for each Member State. The method used for this aggregation is as follows:

If 7 or more assessments (out of 10) were of one rating, this was chosen as the overall rating for a given Member State.

Where 6 or fewer of the assessments were of the same rating and two ratings were present, the worse of these two was chosen, hence presenting a conservative (risk-adverse) approach.

If all three ratings were present (and fewer than 7 out of 10 assessments were of one rating), then the most common of the two worst ratings was chosen hence presenting a conservative (risk-adverse) approach.

Completeness relates to the coverage of sources, and not whether the submission includes e.g. a WAM scenario. Comparability is not included in the table as the results do not provide particularly insightful information, but it is considered in more detail in section 3.4.5.




Table 3-8 Overview of quality of Member State projections

Member State

Transparency of reporting

Completeness of reporting

Consistency of projections

Accuracy of Projections

Additional Comments

Austria Minor Good Good Good The submission is generally of a good standard.

Belgium Major Good Major Minor Use of different versions of models for the historical emission estimates and the projections causes consistency issues.

Bulgaria Minor Minor Major Major The use of Tier 1 methodologies for key sources in the projections raises accuracy issues.

Croatia Major Major Major Major Issues are mainly associated with transparency, and completeness and consistency of NMVOC, NH3 and PM2.5 which then impact on accuracy.

Cyprus Major Minor Minor Minor

Major improvements are needed in terms of completeness, consistency and accuracy specifically for PM2.5 (the minor improvement ratings shown here reflect all pollutants, and hence the assessment for an individual pollutant is not evident). Other issues are generally associated with small sources.

Czechia Minor Major Major Minor Issues raised concern NH3 from agriculture, and more broadly the consistency between historical and projected estimates.

Denmark Good Good Good Good The submission is of a good standard.

Estonia Major Minor Minor Minor Other than transparency, there are only relatively small issues.

Finland Minor Minor Major Minor There are some issues regarding consistency between historical and projected estimates for all pollutants.

France -Minor Good Good Minor- The accuracy of projections was rated as good for SO2 and NH3 and requiring minor improvements for other pollutants. Transparency was rated as requiring minor improvements for all pollutants.

Germany Minor Good Good Good The submission is generally of a good standard.

Greece Major Minor Minor Major The use of Tier 1 methodologies for key sources impacts on accuracy.

Hungary Major Good Minor Major Some over and under-estimates and the use of Tier 1 methodologies for key sources impact on accuracy.




Member State





Additional Comments

Ireland Major Good Good Good The submission is generally of a good standard, but more supporting documentation is needed.

Italy Major Major Major Major

There are some omissions from the projections, particularly from agricultural sources of NOX, NMVOC, NH3 and PM2.5. This impacts on completeness and accuracy. There are also unexplained inconsistencies between the historical and projected estimates for all pollutants.

Latvia Minor Minor Good Major Issues raised are relatively minor, with the exception of the use of Tier 1 methodologies for key sources which impacts on accuracy.

Lithuania Major Good Minor Minor Issues raised are relatively minor, other than the need for improved documentation.

Luxembourg Major Major Major Major There is a particular lack of transparency. The projections are based on an old historical emissions inventory, causing numerous quality issues.

Malta Minor Minor Minor Major

All criteria were assessed as requiring minor improvements, with the exception of accuracy, which was rated as requiring major improvements for all pollutants due to the extensive use of Tier 1 methodologies.

Netherlands Major Minor Major Minor

Very limited information was provided in the IIR on projections, resulting in poor transparency of methods and underlying data. There are inconsistencies between the historical and the projected estimates in several source sectors.

Poland Major Good Minor Major

Insufficient information was provided on the methods and data used for estimating projections from the solvent & other product use and waste sectors. This results in poor transparency. Linear interpolation is used to determine 2020 emissions and some methods are not sophisticated enough, causing accuracy issues.

Portugal Major Good Major Major Inconsistency and accuracy issues were raised for several source sectors, and these have not been answered.

Romania Major Good Major Major There are inconsistencies between the historical and projected data and projections in the agriculture sector use a Tier 1 methodology.




Member State





Additional Comments

Slovakia Major Good Good Good The submission is generally of a good standard, but more supporting documentation is needed.

Slovenia Major Major Minor Minor The most important issues are associated with SO2.

Spain Major Minor Good Minor The most important issue raised is the need to improve the NMVOC projections.

Sweden Major Good Minor Minor Other than improvements needed to supporting documentation, there are only relatively minor issues associated with consistency and accuracy.

United Kingdom

Minor Good Good Minor The submission is generally of a good standard, but some minor improvements are needed in the supporting documentation and accuracy.

Notes: Minor = Minor improvements needed; Major = Major improvements needed – as detailed in Table 2-3. Each of the assessments presented above are an aggregation of 10 assessments made for each pollutant and 2020 / 2030 projections separately for each MS, as detailed in section 3.4.3.




The following sections consider each of the quality criteria in more detail.

3.4.4 Transparency

3.4.4.1 Transparency of projections

Table 3-8 above shows that the lack of transparency was the most significant quality issue of the projections review. The majority of Member States did not provide an IIR (or projections report) with sufficient detail on the methodologies used, key input datasets, assumptions etc. Some Member States reported no supporting information, and others only very limited information:

18 Member States (Belgium, Croatia, Cyprus, Estonia, Greece, Hungary, Ireland, Italy, Lithuania, Luxembourg, the Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden) provided no information on methodologies used in their IIRs, and the transparency of projections was identified as requiring major improvements.

9 Member States (Austria, Bulgaria, Czechia, Finland, France, Germany, Latvia, Malta and the United Kingdom) required minor improvements in transparency of projections as they provided some information on methodologies in their IIRs.

Only Denmark provided fully detailed projections methodologies assessed as being of a good standard.

This lack of transparency impacted on the ability of the review team to undertake the review in sufficient detail. Whilst it was possible to raise questions for the Member States to answer, it was not realistic to expect Member States to provide fully detailed descriptions of all methodologies etc. during the review. In some cases, the recommendation is therefore simply that the Member State should report a fully detailed projections chapter in their IIR, as currently nothing is reported. These recommendations are provided in the individual Member State projections review reports.

At the conclusion of the desk review there were unanswered questions from some Member States. However, this did not account for a large proportion of the total number of questions raised, and may be linked to the challenges that arose from the review timescales.

In general, Member States were responsive and supportive in trying to address the issues raised.

3.4.4.2 Conclusions

There is a clear need for almost all Member States to make substantial improvements to the reporting in their IIRs.

The purpose of documenting the methodologies is not only to support technical reviews, but also to allow the national inventory teams themselves to review their approaches, identify priorities for improvements, and then plan how those improvements can be made.

Improving the transparency of the reporting by documenting methods in the IIR etc. will require significant investment of time or resources by Member States that have no documentation. However, once completed it will be relatively easy to maintain and update, because the content describing projections methods and input data will not require complete redrafting each time a submission is made.

No major barriers to improving transparency have been identified, other than the need for investment in time or resources in writing the relevant sections for the IIR.

3.4.4.3 Recommendations

It is recommended that Member States review and substantially improve the information that they provide in their IIRs to support the projections data submission.

It is recommended that Member States follow the guidance provided in the CLRTAP Emissions Inventory Reporting Guidelines16 (2018 version of Annex II to the 2014 Reporting Guidelines), in compiling the projections chapter of their IIRs.

16 Available from: https://www.ceip.at/ms/ceip_home1/ceip_home/reporting_instructions/annexes_to_guidelines/





The content of the IIRs should not only explain methodologies, but also provide the more important input datasets, and outline any key assumptions that are being made. It would also be beneficial to identify shortcomings and document planned improvements.

It is further recommended that Member States use this information to review their approaches, identify priorities for improvements, and then plan how those improvements can be made.

3.4.5 Comparability

3.4.5.1 Comparability of projections

All Member States used the appropriate Nomenclature for Reporting (NFR) reporting format for their projections and made submissions in the Annex IV template. Definitions of source sectors and underlying activity data followed best practice across all of the Member States. Comparability is therefore assessed as being of a good standard for the vast majority of Member States.

The majority of Member States based their projections on the 2017 emissions inventory taken from the 2019 submission (year x-2), with most of the remaining Member States using 2016 from the 2018 submission (year x-3). These differences were not considered to be an issue. However, there were a limited number of Member States who used older historical data or datasets that had not been reported as official submissions. These were raised as comparability issues.

The projections submissions were compared across the Member States to see whether projected trends were similar. Outlier analysis was undertaken for the national totals for each pollutant. This involved comparing the trend of the projected national total for a given pollutant of one Member State with the other Member States as a whole. From this series of checks the following was concluded:

14 Member States (Cyprus, Czechia, Estonia, Germany, Italy, Latvia, Lithuania, Luxembourg, the Netherlands, Poland, Portugal, Romania, Slovakia and Slovenia) were identified as reporting an outlier trend for at least one pollutant for the period 2005-2020.

15 Member States (Belgium, Bulgaria, Croatia, Cyprus, Denmark, Germany, Greece, Hungary, Ireland, Lithuania, Luxembourg, the Netherlands, Portugal, Romania and the United Kingdom) were identified as reporting an outlier trend for at least one pollutant for the period 2020-2030.

However, many of the issues arising were explained as being due to country specific circumstances. This was particularly evident for issues in the industrial processes and product use sector. There were some which arose from the use of relatively simple methodologies, such as the use of a Tier 1 methodology, or using a driver (scaling factor for future years) which was not ideally suited to the specific source. These cases often overestimate projected emissions because the methods do not take into account reductions in emission factors that will arise from improved mitigation or control technologies. Examples include projected emissions of NMVOC from solvent use, NH3 from agriculture, and non-road transport and machinery for NOX and other pollutants. Individual recommendations were made for each of these cases in the Member State projections review reports, so that that Member States can address them prior to their next projections submission.

The variation of comparability across the pollutants did not indicate that any pollutant was particularly better or worse than the others.

3.4.5.2 Conclusions

In conclusion, comparability issues across the Member States were explained by either country specific circumstances (particularly noticeable in the industrial processes sector) or by the use of simple methodologies. In the latter case, individual recommendations were made to ensure that Member States improve their methodologies.

Addressing comparability issues will require investment from some Member States to improve their methodologies, and in particular changing from a Tier 1 to a Tier 2 approach for key sources. These types of improvements are often flagged by several quality criteria and are the improvement activities that Member States should give priority to. There can be challenges in obtaining datasets for Tier 2 approaches, but even a Tier 2 approach that includes expert estimates is typically more accurate than a Tier 1 approach.





It is recommended that Member States use Tier 2 methodologies for projections that are key sources where this is not prohibitively resource demanding. This should be a priority improvement.

It would also be helpful for Member States to include explanations of projections trends in the IIR, particular where these are substantially different to the majority of other Member States.

3.4.6 Completeness

3.4.6.1 Completeness of projections

Completeness of the submission can be assessed in different ways. The inclusion of a scenario that demonstrates compliance with all of the emission reduction commitments has been considered in section 3.3. This section considers whether the submitted projection estimates included emissions from all relevant sources.

Completeness across the Member States was generally of a good standard, with the review team identifying relatively few omissions, which typically related to small sources:

6 Member States (Bulgaria, Croatia, Czechia, Italy, Luxembourg and Slovenia) were assessed as requiring major improvements in the completeness of their projections.

9 Member States (Cyprus, Estonia, Finland, France, Greece, Latvia, Malta, the Netherlands and Spain) were assessed as requiring minor improvements in the completeness of their projections.

13 Member States (Austria, Belgium, Denmark, Germany, Hungary, Ireland, Lithuania, Poland, Portugal, Romania, Slovakia, Sweden and the United Kingdom) provided projections submissions that had a good level of completeness and followed best practice.

There were several examples of smaller NH3 and PM2.5 sources being omitted from projections, particularly in the agriculture sector. NMVOC projections from some industrial processes were also missing from some projection submissions.

However, the most widespread omission was for NOX and NMVOC from agriculture. This was caused by several Member States misunderstanding the need to include projections for these sources, even though they are not included for the purpose of demonstrating compliance with emission reduction commitments.

All of the completeness issues are easily resolved. Bringing the standard of completeness up to best practice may require Member States to use expert judgements in estimating the projections. However, this should not require a large investment of resources, particularly if the corresponding historical inventory is already at a good level of completeness.

3.4.6.2 Conclusions

Whilst significant improvements are needed for some Member States’ projections estimates, completeness for most Member States was assessed as being good or requiring minor improvements for the majority of Member States.

Addressing completeness issues is not likely to require major resources. However, it may be that work needs to be undertaken on the historical inventory as well as the projections estimates.


Member States are recommended to address any completeness issues raised in the review before their next projections submission.

Member States are also reminded to include NOX and NMVOC emissions from the agriculture sector in their submissions.

Most of the completeness issues are not expected to have major impacts on the projected national totals.




3.4.7 Consistency

3.4.7.1 Consistency of projections

Consistency can be assessed in several different ways. This review considered the following in order to determine whether there were any underlying issues:

The consistency between the historical inventory and the reference year data that is reported as part of the projections’ submission.

The consistency between the historical inventory and the projections, in terms of source coverage (this is linked to the completeness assessment above) and the use of notation keys.

The consistency of the trends with time observed for the historical inventory and the projections.

The consistency of methods and input data for different pollutants arising from the same source.

The consistency of activity data (such as GDP and population) used in the projections calculations with that reported in the draft National Energy and Climate Plans.

These checks resulted in the following ratings:

10 Member States (Belgium, Bulgaria, Croatia, Czechia, Finland, Italy, Luxembourg, the Netherlands, Portugal and Romania) required major improvements in the internal consistency of their projections.

8 Member States (Cyprus, Estonia, Greece, Hungary, Lithuania, Poland, Slovenia and Sweden) were identified as requiring minor improvements in their internal consistency.

10 Member States (Austria, Denmark, France, Germany, Ireland, Latvia, Malta, Slovakia, Spain and the United Kingdom) provided projections submissions that had a good level of internal consistency and followed best practice.

Several Member States reported reference year emissions which did not exactly match the emissions in the historical inventory. The most common reason given for this was that recalculations had been undertaken since the submission of the historical inventory. This is understandable, but it is necessary for the reference year to be consistent with a historical inventory submission.

There were relatively few inconsistencies found in the comparison of historical and projected trends and those which were identified typically had relatively small impacts on the projections. Numerous cases were identified where inconsistencies between the historical and projected estimates were caused by misallocations i.e. the emissions from the historical inventory are reported in a different (and incorrect) sector in the projections submission.

Methods across pollutants and within different years of the projections were found to be fully consistent for the vast majority of Member States. Of the few issues identified, most had a relatively small impact on the projections’ totals and were simple errors.

Consistency issues impacted the projected emissions of all pollutants, but NMVOC was noted to be affected more than other pollutants. This is because NMVOC emissions arise from a large number of different sources which need to be aggregated and reported in the correct way for the projections’ submission.

For many Member States there was inconsistency between the data used in the projections calculations and that reported with the draft National Energy and Climate Plans. Member States explained that this arose because datasets had been updated between the reporting of the submissions. Also, in some cases, the GDP datasets did not use the same units (GDP can be expressed as a figure that does or does not take inflation into account), making comparisons difficult.

3.4.7.2 Conclusions

Consistency was identified as requiring major improvements for a significant number of Member States. Many of the issues raised were associated with misallocations in the projections, and also sources in the historical inventory that were not included in the projections (see also completeness).

For a limited number of Member States, inconsistencies were identified between the reference year and the historical inventory. These were caused by recalculations and resulting “version” issues.




Many of the inconsistencies identified are easily corrected with some changes to the projections reporting e.g. correcting misallocations. These do not impact on the projections’ totals. However, there are some more significant issues that require consideration, such as the use of population or GDP data that is different to the data reported in the National Energy and Climate Plans. For some Member States, these changes could have significant impacts on the projections totals.


Member States are recommended to address any consistency issues raised in the review before their next projections submission.

Most of the consistency issues are not expected to have major impacts on the projected national totals, but it is likely that a limited number will.

3.4.8 Accuracy

3.4.8.1 Accuracy of projections

The assessment of accuracy was given particular attention during the review. Accuracy is one of the more complex quality metrics to assess because it is influenced by many different factors. For example, issues with completeness are likely to impact on accuracy, as they can result in an underestimate. Consistency issues may also give rise to a similar impact. The use of a Tier 1 method for a key source will impact on accuracy, but it is not always possible to determine whether it results in an under- or an over-estimate. For this reason, accuracy was the last of the quality metrics to be assessed.

To assess accuracy, the data provided in the projections submission, and the supporting documentation were reviewed. However, an additional check was also conducted. For many projections, the 2016 emission estimates from the 2018 inventory submission have been used for the projections reference year (year x-3). The 2018 inventory submission can be compared to the 2019 inventory submission (year x-2) to assess the impact of recalculations. This provides an indication of how the values for projections might change in future submissions. The impact of recalculations (and also whether the 2017 historical emissions were consistent with the projections), were taken into account when determining an accuracy rating. The ratings were determined as follows:

11 Member States (Bulgaria, Croatia, Greece, Hungary, Italy, Latvia, Luxembourg, Malta, Poland, Portugal and Romania) were assessed as requiring major improvements to accuracy.

12 Member States (Belgium, Cyprus, Czechia, Estonia, Finland, France, Lithuania, the Netherlands, Spain, Slovenia, Sweden and the United Kingdom) were assessed as using best practice for the majority of their emission projections calculations, with some minor areas of improvement required.

5 Member States (Austria, Denmark, Germany, Ireland and Slovakia) reported projections that were all evaluated as being at a level of accuracy that meets or exceeds best practice.

Given the importance of accuracy, Table 3-9 is included below, which shows the accuracy ratings for each Member State resolved by pollutant.

The dominant feature from the data in Table 3-9 is that there is variation across the Member States rather than pollutant. So, a Member State with a good accuracy for a given pollutant will typically have good accuracy for other pollutants. However, there is also some variation across the pollutants. SO2 is of a better accuracy than other pollutants across the Member States as a whole. The other pollutants are broadly comparable when considered across the Member States as a whole, although the accuracy of NH3 is slightly worse than the accuracy of NOX, NMVOC or PM2.5.

The most common causes of poor accuracy include:

The use of a Tier 1 methodology for a key category, or other methods which do not take into account the evolution of sources in future years, such as the introduction of mitigation and control technologies, and

Completeness issues (and inconsistencies between the historical inventory and the projections) which give rise to underestimates.




Table 3-9 Accuracy of projections for each Member State, by pollutant

2020 Projections 2030 Projections

Member State SO2 NOX NMVOC NH3 PM2.5 SO2 NOX NMVOC NH3 PM2.5

Austria Good Good Good Good Good Good Good Good Good Good

Belgium Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor

Bulgaria Minor Major Major Major Minor Minor Major Major Major Minor

Croatia Good Minor Major Major Major Good Minor Major Major Major

Cyprus Good Minor Minor Good Major Good Minor Minor Good Major

Czechia Good Minor Minor Major Minor Good Minor Minor Major Minor

Denmark Good Good Good Good Good Good Good Good Good Good

Estonia Good Minor Minor Minor Minor Good Minor Minor Minor Minor

Finland Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor

France Good Minor Minor Good Minor Good Minor Minor Good Minor

Germany Good Good Good Minor Good Good Good Good Minor Good

Greece Major Major Major Minor Major Major Major Major Minor Major

Hungary Minor Minor Minor Major Major Minor Minor Minor Major Major

Ireland Good Good Good Minor Good Good Good Good Minor Good

Italy Major Major Major Major Major Major Major Major Major Major

Latvia Minor Major Major Minor Minor Minor Major Major Minor Minor

Lithuania Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor

Luxembourg Major Major Major Major Major Major Major Major Major Major

Malta Major Major Major Major Major Major Major Major Major Major

Netherlands Good Minor Good Major Minor Good Minor Good Major Minor

Poland Major Major Minor Major Minor Major Major Minor Major Minor

Portugal Major Major Major Major Major Major Major Major Major Major

Romania Minor Major Minor Major Major Minor Major Minor Major Major

Slovakia Good Good Good Good Minor Good Good Good Good Minor

Slovenia Major Minor Minor Minor Minor Major Minor Minor Minor Minor

Spain Good Minor Minor Minor Minor Good Minor Minor Minor Minor

Sweden Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor

United Kingdom Minor Minor Minor Good Good Minor Minor Minor Good Good

Notes: Minor = Minor improvements needed; Major = Major improvements needed.




3.4.8.2 Conclusions

Accuracy varies significantly from Member State to Member State. Projections for SO2 are generally of better accuracy than those for other pollutants.

This suggests that there are no particular cross-cutting barriers (such as lack of guidance) to compiling projections to a good standard of accuracy. It is reasonable to conclude that every Member State could provide projections of good accuracy if they made the appropriate investment in the compilation process.

The most challenging barrier to overcome is to avoid the use of Tier 1 methodologies, or overly simple methods, for key categories. This may take a significant investment of time or resources if the Tier 1 method is also used in the historical inventory.

Incompleteness issues also impact on accuracy, but the majority of these should be relatively straightforward to address if the emissions are already included in the historical inventory.


Member States are recommended to ensure that Tier 2 or higher methods are used for key categories in their projections’ calculations.

Furthermore, Member States are recommended to ensure that all sources that are reported in the historical inventory are also included in the projections, and that this is transparently reported in accompanying documentation.

Specific recommendations have been made in the individual Member State projections review reports to support Member States in prioritising their improvements. In addition to improving transparency, addressing these accuracy issues are considered to be priority improvements.

3.4.9 Recommendations and Encouragements

3.4.9.1 Overview

Throughout the desk review, the review team raised questions for the Member States to answer. Some issues were answered to the satisfaction of the review team, and the issue was closed. However, for the majority of issues, the review team concluded that action is required to improve the quality of the Member States’ data or supporting documentation to meet best practice standards. So, issues were concluded with a recommendation or an encouragement. These recommendations and encouragements are provided to support the Member States’ inventory compilers in making improvements to their projections.

3.4.9.2 Number of Recommendations and Encouragements

The figures below present the number of recommendations and encouragements by Member State and by sector. The number of recommendations and encouragements should only be used as an approximate indicator of the efforts required to bring the projections submission up to a best practice level of quality. This is because recommendations vary hugely in terms of the potential impact on national totals and the effort required to address them. So, a simple count of the number of recommendations and encouragements should be used with extreme caution.

Figure 3-11 below shows the recommendations, encouragements and total observations raised during the review by Member State. The number of observations is included in the figure, and represents the sum of the recommendations, encouragements and issues that were either not sent to the Member States (because they were resolved by the review team) or were explained by the Member States to the satisfaction of the review team. The recommendations and encouragements represent a relatively high percentage of the total number of observations, indicating that the questioning during the review was well targeted, with the vast majority identifying an action that the Member States needs to take to improve the projections submission.




Figure 3-11 Number of recommendations, encouragements and total observations, by Member State

For this review, encouragements were primarily associated with transparency, although there are also some encouragements concerning voluntary reporting. A lack of transparency was a major issue raised throughout the review, and as a result there are a significant number of encouragements for the majority of Member States.

However, for many Member States, the review has resulted in more recommendations than encouragements. This shows that there are wide-ranging issues that need to be addressed beyond a lack of transparency and voluntary reporting.

The number of recommendations and encouragements varies significantly between the Member States - the Member State with the most recommendations and encouragements has four times that of the Member State with the least number. There are recommendations for every Member State – even for those considered to report projections of good quality.

Figure 3-12 below presents the number of recommendations, encouragements and total observations, by sector. There is a relatively high number of issues raised for the agriculture sector and the national totals, particularly when compared to e.g. recent reviews of historical emissions inventories. This might be a consequence of the fact that Member States submitted more information on the agriculture sector, allowing the review to identify a larger number of detailed recommendations, rather than a small number of cross-cutting recommendations (such as the need to improve overall transparency) for sectors where little information was reported.

Cross-cutting issues were typically assigned to national totals. There is a relatively high proportion of these cross-cutting issues, compared to the reviews of historical emissions inventories. This may be because this is the first time that projections have been reviewed, and Member States were not fully aware of the level of detail required for reporting of projections. In addition, projections are more resource demanding to prepare than the historical emission estimates and require a good quality historical inventory as a starting point. The outputs of this review provide Member States with clear information on the improvements that need to be made to ensure good quality projections.

There was little information provided on the waste sector, because the projections are aggregated into a single line in the reporting template. Combined with the lack of transparency, this meant that the waste expert reviewers had limited information to review. Therefore, fewer recommendations and encouragements could be provided on this sector.

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Figure 3-12 Number of recommendations, encouragements and total observations, by sector

3.5 PaMs considered and selected for adoption

3.5.1 Overview

According to Annex III Part 1 of the NECD, Member States need to include in their NAPCPs the policy options considered to comply with their emission reduction commitments. Where available, the individual or combined impacts of the PaMs on emission reductions, air quality and the environment and the associated uncertainties should be included (Tables 2.6.1 and 2.6.2 of the NAPCP common format). For those PaMs selected for adoption, the Member States should report a timetable for adoption, implementation and review and the competent authorities responsible (Table 2.7.1 of the common format). Article 6 specifies that Member States shall include in their NAPCPs measures for the agricultural sector, laid down as obligatory in Part 2 of Annex III and may include measures laid down as optional in Part 2 of Annex III or measures having equivalent mitigation effect (Table 2.6.4 of the common format). On the basis of the content of these tables, the EEA have prepared an online PaM reporting tool (i.e. the EEA-PaM tool) for the Member States to use to meet their reporting obligations. The use of the EEA-PaM tool is mandatory according to the Commission Implementing Decision (EU) 2018/1522 laying out the common NAPCP format. The additional motivation behind the tool was to align as much as possible the PaM reporting with Member States reporting on the PaMs under the MMR Regulation17. An overview of the information reported by the Member States via the EEA-PaM tool is published on the EEA website18. For consistency with this publicly available dataset, this section of the report relies primarily on the information submitted via the EEA-PaM tool. Assessment of the PaMs presented in each NAPCP review report for individual Member States has been conducted using the full evidence available, as reported by the Member States in their NAPCPs and via the EEA-PaM tool.

17 Regulation (EU) No 525/2013 of the European Parliament and of the Council of 21 May 2013 on a mechanism for monitoring and reporting greenhouse gas emissions and for reporting other information at national and Union level relevant to climate change and repealing Decision No 280/2004/EC https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32013R0525

18 https://www.eea.europa.eu/data-and-maps/dashboards/overview-of-compliant-air-pollution-policies

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Additionality of PaMs reported in the NAPCPs and via the EEA-PaM tool

As stated above, the NECD includes an obligation, according to Annex III Part 1, 1(b), for the Member States to report on the PaMs considered and selected for adoption when any of the emission reduction commitments are projected to be missed. These PaMs should be additional to existing PaMs. Accordingly, the review examined whether the PaMs reported by the Member States in their NAPCP are indeed additional to existing PaMs by considering the following criteria:

Reported years of adoption and implementation: PaMs adopted before 2019, or for which the implementation start year was before 2019, were not considered as additional PaMs (unless justified by the description of PaM – see below);

Information on changes to existing PaMs: where an already adopted PaM has been modified, e.g. to increase a level of ambition, extend its scope to cover additional emission sources or extend its implementation timescales, reporting of a PaM as additional can be justified. Where information on the changes from existing PaMs was not provided, and it was clear that the PaMs were already adopted, such PaMs were considered as not additional;

Link of a PaM to EU legislation: as discussed in the later parts of this section of the report, PaMs which solely concern implementation of EU legislation (e.g. implementation of the IED) were sometimes reported by the Member States as additional PaMs. Such PaMs should have been included in the WM scenario projections and were judged in the review as not additional, unless a description was clear that a proposed PaM goes beyond the EU requirements.

Inclusion in WM and WAM scenarios: via the EEA-PaM tool, Member States were able to report on the projections scenario in which an impact of a given PaM on emission reductions was captured. Some PaMs were reported as included in the WM scenario or in both the WM and WAM scenarios. In such cases, this information has been considered alongside the information on adoption and implementation timescales and design of a PaM, to make a judgement on whether a PaM can be considered truly additional. The inclusion of an existing PaM in a WAM scenario but not in the WM scenario can be justified in cases where WM and WAM scenarios have been developed separately (i.e. WAM scenario was developed at a later stage than the WM scenario) and where the WM scenario was dated and did not reflect the impacts of the latest PaMs. However overall this type of information was missing from the evidence reported by the Member States.

The conclusions on the additionality of PaMs and any inconsistencies between the NAPCPs and reporting via the EEA-PaM tool are presented in the individual Member State NAPCP review reports.

This section of the report covers all PaMs reported by the Member States via the EEA-PaM tool. This includes any information on existing PaMs (e.g. as reported by Cyprus, France and Poland) and those PaMs judged in the review as not additional. This is to ensure consistency with the data published on the EEA website and to facilitate knowledge sharing on all PaMs reported as selected for adoption by the Member States across the various sectors.

Analysis in this section is based on 19 Member States which reported PaMs via the EEA-PaM tool (see earlier section 3.1.4). From the remaining 9 Member States:

2 Member States (Greece and Romania) did not submit a NAPCP.

1 Member State (Hungary) submitted its NAPCP too late for inclusion in the analysis of this report.

1 Member State (Italy) formally published their draft NAPCP on CDR but too late for inclusion in the analysis of this report.

1 Member State (Luxembourg) had not formally published their draft NAPCP on CDR to be included in the analysis of this report.

2 Member States (Austria and Bulgaria) did not report on their PaMs using the EEA-PaM tool despite the information being included in the main body of the NAPCP

2 Member States (Finland and Netherlands) did not consider additional PaMs for adoption (as they project to achieve all of their emission reduction commitments).




Given that the majority of the PaMs selected for adoption were due for adoption in 2019, it is unlikely that they will deliver the emission reductions required for Member States to comply with the 2020-2029 emission reduction commitments in 2020. This is due to the very short time available for the successful implementation (although this depends on the exact design of PaM). However, PaMs selected for adoption in the NAPCPs are likely to contribute to the attainment of 2020-2029 emission reductions commitments after 2020 (i.e. in the period from 2021 to 2029) and are important in the context of achieving compliance with the emission reduction commitments for 2030 onwards.

According to the projected compliance with the emission reduction commitments presented in their NAPCPs by the 19 Member States analysed in this part of the report, all Member States which submitted NAPCPs, with the exception of Cyprus, Finland and the Netherlands19, need to adopt additional PaMs in order to meet either the 2020-2029 and/or the 2030 onwards emission reduction commitments.

According to the information reported via the EEA-PaM tool, out of 547 single PaMs considered for adoption, 346 were selected for adoption (63% of the PaMs considered) and the remaining 201 were not selected for adoption. The proportion of considered PaMs that were subsequently selected for adoption varied significantly between Member States, with some countries selecting all PaMs considered with others taking forward none (Figure 3-13). It should be noted that for some Member States, the assessment of the NAPCPs revealed some inconsistencies between the information included in the EEA-PaM tool and the main body of the NAPCP, including on whether a PaM has or has not been selected for adoption. These inconsistencies are discussed in detail in Member State NAPCP review reports.

Figure 3-13 Number of PaMs selected for adoption per Member State based on the EEA-PaM tool

19 For Croatia, the NAPCP shows non-compliance with emission reduction commitment for NH3 in 2020-2029. However, using the 2005 emissions from the latest emission inventory and the latest projections (both submitted in 2019), Croatia projects to comply with all emission reduction commitments under WM scenario and thus would not be required to adopt additional PaMs




Notes: All PaMs reported by Cyprus are existing PaMs. All PaMs reported by France and Poland have been found in the review to be existing PaMs. For Latvia the draft NAPCP was analysed in this report in the meantime, a final NAPCP was submitted, but too late for inclusion in this analysis) thus explaining the lack of PaMs that have been selected for adoption. Ireland submitted their final NAPCP, however their submission of draft PaMs to the EEA-PaM tool was not updated upon finalisation of the NAPCP. The NAPCPs for Croatia, Poland and Slovenia state which PaMs were selected for adoption, however this is not reported in the EEA-PaM tool.

Figure 3-14 shows how many PaMs considered and selected for adoption are projected to reduce emissions of the five NECD pollutants as well as BC. This demonstrates that emissions of NOX and PM2.5 are targeted by the largest number of PaMs. On average, more than half of all PaMs considered have been selected for adoption, across all NECD pollutants20. A small proportion of PaMs considered for adoption (a total of 73, i.e. around 5% of all PaMs reported) have been reported to have an impact on emissions of BC.

Figure 3-14 Number of PaMs selected for adoption per pollutant

Notes: Each PaM can have more than one pollutant assigned to it, hence the total number of PaMs represented above is greater than the total number of PaMs reported by the Member States.

The pollutants for which achievement of emission reduction commitments is a challenge for the majority of the Member States are NH3, PM2.5 and NOX. The key challenge facing the Member States is to reduce emissions of these pollutants from the largest emission sources: agriculture (NH3); the road transport, combustion in commercial, institutional and household sectors (PM2.5 and NOX); and energy production and distribution (NOX)21. Figure 3-15 presents the number of PaMs considered and selected for adoption per sector, across the 19 Member States covered in this section of the report. The figure shows that the Member States have prioritised consideration and adoption of PaMs for the priority sectors contributing the largest share of emissions. More than half of the PaMs considered for the transport, agriculture and energy supply sectors have been selected for adoption. However, the figure indicates that more than half of the PaMs considered for adoption in the energy consumption sector (this represents emissions from combustion in commercial and institutional buildings as well as households) have not been selected for adoption by Member States. This is influenced primarily by the number of PaMs considered for this sector by Ireland and Latvia who have reported no PaMs selected for adoption

20 50% of PaMs reducing emissions of SO2, 63% of NOx, 62% of NMVOC, 58% of NH3 and 59% of PM2.5

21 Based on the sectors contributing the largest share of the total EU emissions in 2017 https://www.eea.europa.eu/data-and-maps/dashboards/necd-directive-data-viewer-2

https://www.eea.europa.eu/data-and-maps/dashboards/necd-directive-data-viewer-2

https://www.eea.europa.eu/data-and-maps/dashboards/necd-directive-data-viewer-2




in the EEA-PaM tool22, (together these Member States have considered 27 PaMs), as well as a relatively large number of PaMs not selected for adoption in this sector by Belgium (22 PaMs).

Figure 3-15 Number of PaMs selected for adoption per sector

Notes: Each PaM can have more than one sector assigned to it, hence the total number of PaMs represented above may be greater than the number of PaMs reported by the Member States.

3.5.2 Quality of reporting on the PaMs

Generally, the quality of the Member States reporting on the PaMs varied across the Member States and across the PaMs reported by a Member State.

When reporting via the EEA-PaM tool, the Member States had to provide the title of the PaM and an additional description. Both fields were completed by all Member States and often the descriptions provided further details to supplement the PaM title. In many instances however, the additional description was not extensive and did not provide specific information on PaM design and focus. In a limited number of cases, the description was simply a paraphrase of the PaM title without any additional information. This created challenges for the reviewers in making a judgement on whether a PaM reported is credible and associated emission reductions realistic. In some cases, additional information on PaMs has been included in the main body of the NAPCP but not reported via the EEA-PaM tool. The review has also found instances where PaMs reported in the NAPCP were inconsistent with the PaMs reported via the EEA-PaM tool (e.g. in terms of the overall number of PaMs, PaMs selected for adoption, projected emission reductions). As a result, the reviewers had to make judgements on the likelihood of the PaM achieving the projected emission reductions on the basis of very limited and/or inconsistent information.

The following shortcomings were identified in the descriptions of PaMs provided:

Sector to which the PaM will be applied and who and/or what will be targeted – a lot of PaMs have been reported as being applied to many sectors e.g. “energy supply, energy

22 Latvia’s submission to the EEA-PaMs tool was provided alongside the draft NAPCP. Ireland has not updated their submission to the EEA-PaM tool after submission of the final NAPCP.




consumption and cross-cutting” which impacts the extent to which reviewers were able to understand what exactly is being proposed. In a number of cases, it would have been useful for the description of the PaM to further specify who and/or what will be expected to comply with / be affected by a PaM reported e.g. for PaMs in industry, whether a PaM would apply to all industrial operators or only a subset, for PaMs in road transport, whether a PaM concerning deployment of electric vehicles assumes replacement of all new vehicles coming onto roads, or only vehicles of a certain type and/or age.

Planned uptake of the PaM – linked to the above, it would have been useful for the

descriptions of the PaMs to describe assumptions on the projected uptake of PaMs. For example, in the residential sector, if a PaM was assumed to be improving energy efficiency of buildings: the anticipated rate at which buildings will be modernised (i.e. how many buildings per year); in the road transport sector: how many vehicles of certain type / age will be replaced each year.

Anticipated emission reductions compared to business as usual – the impact on emission reductions can be reported by the Member States either for a single PaM or for packages of PaMs. The review has found examples where emission reductions were not quantified, while in principle it should have been possible to quantify them. Where the emission reduction was reported for a package of PaMs, it was not possible for reviewers to confidently conclude on whether the PaMs included in a given package could realistically lead to the reported emission reductions. Where emission reductions were reported at individual PaM level, the ability of reviewers to comment on credibility of the estimates was limited by a lack of information on the design of PaMs and their planned uptake. For these reasons, estimations of quantified reductions could also not be compared with similar PaMs selected for adoption by different Member States.

Uncertainty of emission reductions – very few Member States reported likely emission reductions from the PaMs in ranges. Best practice would be for Member States to account for uncertainties related to uptake and potential impacts and report the emission reductions as a range, reflecting worst- and best-case scenarios.

Type of policy instruments – many PaMs were reported against multiple policy instruments. While in principle this is valid as a PaM can make use of several different tools (e.g. combining fiscal support with awareness raising), it has often been difficult to clearly understand what is being proposed where multiple policy tools were coupled with a generic description of a PaM.

Timescales for implementation – in the majority of cases, Member States have reported 2019

or 2020 as the first year of implementation for a PaM, and 2030 as the end year of implementation. It has often been unclear whether, given the time of the NAPCP publication, it is feasible to start implementation of the PaMs already in 2019 or 2020. Where gradual phasing of implementation has been assumed, this was considered more credible.

Costs and benefits – as discussed later in this section, information on the costs of PaMs considered and selected for adoption have rarely been reported. Inclusion of the cost estimates would increase the confidence in the analysis that Member States have conducted in preparation of NAPCPs and planning for implementation and allow for sharing of best practices and information among Member States.

For some Member States, the details described above have been identified in the main NAPCP documents but have not been reported via the EEA-PaM tool.

3.5.3 PaMs selected for adoption per sector

This section discusses the findings from the horizontal review of PaMs selected for adoption per sector.

3.5.3.1 Energy supply

Energy production and supply is a significant source of SO2, NOX and PM2.5 emissions in many Member States, and in some cases also NMVOCs. This principally arises from the combustion of coal, natural gas, biomass and other solid fuels for the generation of electricity and heat to supply to consumers across other sectors, including domestic and industry.




The guidance for the development of NAPCPs highlights the importance for Member States to consider the EU Energy Union Strategy and Renewable Energy Sources objectives for this sector when developing the NAPCP.

Overview of PaMs

Additional PaMs targeting emission reductions from the energy supply sector have been considered by 18 Member States captured in this analysis and that reported via the EEA PaM tool (all except for Slovenia). Between 1 and 12 PaMs have been identified by each country. 8 Member States selected all PaMs that had been considered for adoption, 4 Member States reported that none had been selected and 6 Member States indicated that between 40% and 90% of the PaMs considered had been selected for adoption (Figure 3-16).

Figure 3-16 Member States which have considered and selected PaMs for adoption for energy supply

An overview of the energy supply sector PaMs selected for adoption is provided in Table 3-10. Member States considered a variety of individual or groups of PaMs. This summary focuses on single PaMs, whether reported individually or as part of a package of PaMs. To facilitate comparison, these have been mapped against the example categories of potential PaMs for the sector given in the guidance for the development of NAPCPs (2019/C 77/01)23. PaMs which fit more than one PaM category are listed as “Multi-category”. PaMs which do not fit any category but were nevertheless reported by the Member States for the energy supply sector are listed as “Other”. The table presents which Member States have reported a given category of PaM (rows in black). More detailed information on PaMs considered and selected for adoption by individual Member States is included in individual NAPCP review reports.

Not all Member States have considered or selected for adoption PaMs of all example types. This may be because such measures have already been adopted and are therefore not reported in the NAPCP.

23 Communication form the European Commission – Guidance for the development of 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 C77, 1.3.2019, p.1.




Table 3-10 PaMs relating to energy supply, selected for adoption by Member States

PaM category

and types

Selected for adoption

Considered but not selected for adoption

(number of PaMs, if >1)

Abatement technologies (retrofit of existing and installation of new)

Desulphurisation units or other abatement equipment on power plants

Implementation of BAT*

Modernisation or replacement of MCPs*

CY24, LT(2), SE PL, LV

Introducing stricter emission limit values than required under existing legislation (e.g. IED)

Stricter ELVs for LCPs, strengthen regulatory requirements to reduce emissions

Implementation of MCPD*

Limits for small combustion plant (0.2-1 MWth)

ELVs for solid fuelled boilers / wood burning stoves

UK, DE(2), DK, FR

DE, LV(3), PL

Fuel switching / quality standards

Ban / reduced use of fuel oil

Replace coal / biomass with less carbon intensive fuel

Renewable and alternative gases

Use of better-quality fuel / fuel standards

Waste to energy plant

CY(2), DE, ES(2), UK, PT, CZ, MT(2), SK

BE, UK, IE, LT, LV

Incentivising non-combustible renewable energy generation

Heat pumps, solar, geothermal or unspecified renewable heat generation

Wind, solar or unspecified renewable electricity generation

BE, CY(2), EE, ES(8), MT (3)

IE(4), LV

Energy efficiency measures

Energy efficiency strategies DE, CZ, SK, BE(2)

Multi-category

Combined heat and power

District heating

Replacement of old solid fuel or wood burning stoves

BE, DK(2), EE, ES, UK, LT, CZ, SK(3)

IE, LV(4), PT, SK

Other

Revision of fines

Improving monitoring and assessment for air quality LT(6), CZ, SK(2) HR, LV(2), PL

24 All PaMs reported by Cyprus are existing PaMs.




PaM category

and types




Improving institutional capacity

Awareness raising

Transitional National Plan for LCPs*

Fossil fuel plant closures

Notes: *A few of the PaMs identified as being “additional” by certain Member States, appear to be implementation of already approved EU legislation and should therefore be included as existing measures and not as additional measures. In some cases, the national PaM goes beyond the requirements of the EU legislation and so differentiation should be made between the existing and additional elements rather than being presented in combination.

Policy instruments

According to the information reported via the EEA-PaM Tool, the types of policy instruments most commonly selected for adoption by Member States for PaMs targeting energy supply are regulatory, economic and planning instruments. There is reasonable consistency between Member States in the reported category of policy instruments for similar types of PaMs, and the identified instrument types are deemed appropriate for the types of PaMs.

Figure 3-17 Types of policy instruments used by Member States for PaMs selected for adoption in the energy supply sector (number of PaMs)

Notes: In many cases, individual PaMs are categorised as being of more than one policy type, so the numbers of

PaMs indicated in Figure 3-17 is greater than the number of PaMs selected for adoption for this sector.

Implementation periods

Several Member States have reported considering PaMs with an implementation start date prior to 2019 (16 PaMs in total) or during 2019 (9 PaMs). This suggests that these PaMs could already be in place, in which case they should not have been considered as “additional” PaMs. However, not all of these PaMs have been reported as being selected for adoption. It is not clear whether this is because they have been included as existing PaMs or if it has been decided not to implement them.

The majority of the PaMs reported as selected for adoption (35) have an implementation start year of 2020, with 9 PaMs with a later start year (2021, 2022, 2023 and 2025). 15 PaMs selected for adoption




have a reported implementation finish year before 2030; considering the nature of these PaMs (introducing stricter emission limits, switching fuel or fitting abatement) the positive effects of their implementation should continue in future years following implementation. The implementation for the rest of the measures is reported to apply up to 2030 or beyond.

The timeframes for implementation are technically feasible in view of the types of instrument used to implement the measures and the types of action required.

Quantification of expected emission reductions

PaMs considered and selected for adoption by Member States in the energy supply sector will reduce emissions of PM2.5, NOX, SO2, NMVOC, BC and NH3, in descending order of number of PaMs. Most PaMs are expected to affect more than one pollutant.

The impacts on emissions by PaMs in this sector have been quantified by a total of 16 Member States (Belgium, Cyprus, Czechia, Germany, Denmark, Estonia, Spain, France, Ireland, Lithuania, Latvia, Malta, Poland Sweden, Slovakia, United Kingdom).

Quantified emissions reductions have been reported for 34 PaMs considered for adoption (of which 22 PaMs were selected for adoption). Aside from some specific PaMs (e.g. fitting desulphurisation (Cyprus), phase out of coal and implementation of MCPD25 (Germany), strengthening regulatory requirements (France), PaMs related to changing heating methods in households (Slovakia)), the emissions reductions expected from PaMs selected for adoption are small (<1 kt/year). With these few exceptions, the emission reductions from individual PaMs selected for adoption in that sector by the Member States are small and represent only a small proportion of national emissions from energy supply. The largest emission reductions from the PaMs selected for adoption are projected for SO2, NOX, PM2.5 and NMVOC.

10 of the individually quantified PaMs are included in packages of PaMs. Of these, 3 are part of packages for which impacts on emission reductions have been reported also at package level.

There are 16 packages of PaMs considered for adoption for which quantified reductions have been reported (of which 12 packages have been selected for adoption). The quantified emission reductions reported for these packages represent a significant percentage of national emissions. However, in all cases these packages are reported as affecting other sectors in addition to energy supply (e.g. industry and domestic sector) and in most cases the PaM descriptions are very general (e.g. “industry measures”). For that reason, emission reductions from these PaMs cannot all be attributed to action on energy supply.

Further reductions can be expected from the other PaMs selected for adoption but for which no quantified reductions have been reported. The impact is likely to vary significantly between PaMs, Member State and pollutant.

Ranges of values have been reported for 9 single or packages of PaMs selected for adoption26, indicating uncertainty in the estimated reductions of between 2% and 100% (median of 14%).

Credibility of the PaMs

Are the PaMs credible?

There is an even distribution of types of PaMs ranging from very specific (e.g. fitting desulphurisation equipment or restricting operation of named power stations), to those applicable across a specific subcategory (e.g. emission limit values for small combustion plants) to very generalised (e.g. energy efficiency strategies). For the more generalised descriptions there is a higher uncertainty of the PaMs being able to achieve a specific emissions reduction.

25 Implementation of EU legislation is not considered an additional PaM and should have thus been reported as part of WM scenario.

26 Several Member States have not reported ranges when presenting emissions reductions. Some Member States report ranges for some PaMs and not for others, and some Member States report ranges for all PaMs.




Quantified emission reductions are provided for only a small proportion of PaMs and are insufficient to allow for validation via comparisons between countries. As the emission reductions expected to be achieved for the majority of PaMs have not been quantified there is a concern for their credibility.

Several PaMs proposed by different Member States relate to existing EU legislation (e.g. implementation of BAT under the IED and the MCPD). These PaMs should be included as existing PaMs instead of additional PaMs as has been done. This would result in lower emissions from the WM scenario, and less reduction in the WAM scenario, but the overall compliance gap from the commitments will be the same under the WAM scenario.

A minority of the PaMs have implementation periods starting, and in a small number of cases finishing, before 2020, which indicates that these PaMs may be incorrectly identified as additional PaMs and are rather existing PaMs. For the PaMs with implementation periods in future years, the implementation period in most cases is 2020 to 2030 or beyond, indicating a progressive implementation, which is considered to be technically feasible.

Are the PaMs technically feasible?

Based on the descriptions provided (although often limited), all of the PaMs selected appear to be technically feasible and relevant for the sector.

Do the PaMs reduce emissions from the largest emission sources?

PaMs selected for adoption by Member States are projected to reduce emissions of all NECD pollutants arising from energy supply. The majority of the PaMs are targeted at reducing PM2.5, SO2 and NOX, for which this sector is often a large contributor of emissions. The PaMs are projected to reduce emissions from the largest emission sources in this sector: energy generation from fossil fuels.

Are the timescales reported for the presented emission reductions realistic?

Quantified emissions reductions are presented only for a small number of individual PaMs. There is no common pattern, with some PaMs expected to only reduce emissions in 2020, other PaMs presented with a constant reduction in each of 2020, 2025 and 2030 and the remainder showing a varying reduction achieved in different years.

For the packages of PaMs for which quantified emissions reductions have been reported, the emission reductions for 2020 are relatively small, with larger reductions reported for 2025 and 2030, in all cases. This implies a staged uptake of the measures over the time period which would be expected considering the time it takes to implement new measures and realise the impacts.

3.5.3.2 Energy consumption

Many Member States have included PaMs relating to energy consumption, as reducing energy consumption leads to lower need for energy supply and therefore a reduction in emissions. Only a small proportion of the PaMs reported for energy consumption have also been reported against energy supply, despite the potential interrelationship, so in most cases a differentiation appears to have been made.

Similar to energy supply, the EU Energy Union Strategy, Renewable Energy Sources and Energy Efficiency objectives are relevant when developing the NAPCP for this sector.

Overview of PaMs

Additional PaMs targeting emissions reductions from the energy consumption sector have been considered by 17 Member States captured in this analysis and that reported via the EEA PaM Tool. Between 1 and 31 PaMs have been identified by each country. 8 Member States selected all PaMs that had been considered for adoption, 6 Member States reported that none had been selected and 3 Member States indicated that between 29% and 88% of the PaMs considered had been selected for adoption (Figure 3-18).




Figure 3-18 Member States which have considered and selected PaMs for adoption for energy consumption

An overview of the energy consumption PaMs selected for adoption is provided in Table 3-11. Member States considered a variety of individual or groups of PaMs for this sector. This summary focuses on the single PaMs, whether reported individually or as part of a package of PaMs. To facilitate comparison, these have been mapped against the example categories of potential PaMs for the sector given in the guidance for the development of NAPCPs, along with additional types of PaMs which do not fit this categorisation, or which cover multiple categories.


Table 3-11 PaMs relating to energy consumption, selected for adoption by Member States

PaM category

and types





Desulphurisation units on combustion plants

Integrated abatement in refineries

Replacement / renovation of boilers and heating equipment


LT, ES, SE, FR, SK(2)

BE, PL, IE, SI(2)



Limits for solid fuel boilers BE PL


Targeted restriction of solid fuel use

Charging for use of solid fuel appliances

Removal of tax relief on biofuels

Solid or liquid fuel quality requirements

BE, FR, SK LT(4), PL




PaM category

and types




Incentivising non-combustible renewable energy generation

Development and promotion of renewable heat generation

Development of distributed renewable electricity generation

Integration of renewable electricity in grid

ES(5), CY27, MT IE

Energy efficiency measures

Energy efficiency improvements in industry, residential buildings and tertiary sector

Renovation and upgrade of buildings

Energy efficiency investment support

Electricity tariffs

CY(2), DE(2), CY, BE(2), LT, ES(4), ES, MT(3), SK

BE(2),PT, IE, LV

Multi-category

Energy audits

Improvements in energy management

Information sharing and demonstrations

District heating and combined heat and power (CHP)

Phasing out / substitution of high emission boilers and stoves

BE(2), ES(2), LT, SE, SK

BE(10), LT(2), IE(4), LV(5), HR, Sl(3), SK

Other

Revision of taxes, tariffs and premiums

Improving air pollution and appliances inventories

Improving monitoring and assessment for air quality


Awareness raising, information support, demonstrations

Financial and methodological support

Periodic inspections or controls on boilers

Maintenance of heating systems

Smart meters

Research and innovation

BE(3), ES, LT(6), CZ, FR (2), MT(2), SK(2)

LT(2), BE(10), IE(7), PL(2), HR, LV(6), Sl(3)

Notes: *Several of the PaMs identified as being “additional” by certain Member States, appear to be implementation of already approved EU legislation and should therefore be included as existing measures and not as additional measures.





Policy instruments

According to the information reported via the EEA PaM Tool, the types of policy instruments most commonly selected for adoption by Member States for PaMs targeting energy consumption are economic, regulatory and information-based instruments.

Figure 3-19 Types of policy instruments used by Member States for PaMs selected to target energy consumption (number of PaMs)

Notes: In many cases, individual PaMs are categorised as being of more than one policy type, so the numbers of

PaMs indicated in Figure 3-19 is greater than the number of PaMs selected for adoption for this sector.

There is inconsistency between Member States in the reported category of policy instruments for similar types of PaMs, and for many PaMs several types of instrument are listed. Consequently, it is uncertain from the information reported in the EEA PaM tool whether there are clear plans in place to implement these PaMs or whether the identified instrument types are appropriate for the types of PaMs.


Several Member States have reported considering PaMs with an implementation start date prior to 2019 (39 PaMs in total) or during 2019 (13 PaMs). This suggests that these PaMs could already be in place, in which case they should not have been considered as “additional” PaMs. 21 of these PaMs have been reported as being selected for adoption. With the exception of Cyprus which reported 4 existing PaMs for the sector, it is not clear whether those which were not selected for adoption have been included as existing PaMs or if it has been decided not to implement them.

The majority of the PaMs selected for adoption (26) have an implementation start year of 2020, with 13 PaMs being selected for adoption with a later start year (2021, 2022, 2023, 2025 or 2028). 2 PaMs (to develop an inventory of appliances and to improve energy efficiency of street lighting) have a reported implementation finish year of 2022 and 1 PaM in 2029 (incentives for households to connect to a district heating network). The implementation for the rest of the measures is reported to apply up to 2030 or beyond.

The timeframes for implementation for the PaMs selected for adoption from 2019 onwards are technically feasible in view of the types of instrument used to implement the measures and the types of action required, and that the implementation finish dates allow for gradual take up over time.





PaMs have been considered and selected for adoption by Member States for energy consumption to target emission reductions of PM2.5, NOX, SO2, NMVOC, NH3 and BC, in descending order of number of PaMs. Most PaMs are expected to affect more than one pollutant.

The impacts on emissions by PaMs in this sector have been quantified by a total of 14 Member States (Belgium, Croatia, Cyprus, Germany, Estonia, France, Ireland, Lithuania, Latvia, Malta, Poland, Spain, Sweden, Slovakia).

Quantified emissions reductions have been reported for 65 individual PaMs considered for adoption (18 of which have been selected for adoption). 11 of individual PaMs selected for adoption are expected to result in emissions reductions greater than 1 kt/year. With a few exceptions (PaMs selected for adoption in Slovakia and France), the emission reductions from individual PaMs selected for adoption in that sector by the Member States are generally small and represent only a small proportion of national emissions from energy consumption. 5 of the individually quantified PaMs are included in packages of PaMs.

There are 14 packages of PaMs considered for adoption for which quantified reductions have been reported (9 of these packages of PaMs have been selected for adoption). . All of these packages except one, are reported as affecting other sectors in addition to energy consumption and in most cases these packages are very general (e.g. industry measures). The quantified emission reductions reported for these packages of PaMs represents a more significant percentage of national emissions, particularly from energy efficiency measures for Spain and cross-cutting measures for Germany. Spain has reported packages of measures achieving significant reductions for NOX and SO2 with the disadvantage of smaller increases in emissions of PM2.5, NH3 and NMVOC from the same package of measures. The reasons for these increases are not reported in the PaMs database and no other country has reported such increases for similar types of measure.

Further reductions can be expected from the other PaMs selected for adoption but for which no quantified reductions have been reported. The impact is likely to vary significantly between PaMs, Member State and pollutant.

Ranges of emission reductions have been reported for 6 PaMs overall. Due to the broader nature of the grouped PaMs there is a higher uncertainty, and therefore more reporting of ranges would have been expected. The indicated uncertainties range between less than 1 % and 50% (median of 10%).

There is insufficient quantified data or similarity between PaMs to compare between different Member States, and therefore it is not possible to validate the estimations provided through comparison.



The majority of the PaMs selected for adoption are described in a general way, such as improving energy efficiency in buildings and industry or increasing uptake of renewable energy. There are only a small number of PaMs reported to target energy consumption within a specific sector or application/technology. This allows greater flexibility for achieving the PaM, but this also risks there being higher uncertainty in the actual emissions reductions that will be achieved.

Quantified emissions reductions are provided for only a small proportion of PaMs and are insufficient to allow for validation via comparisons between countries. The scale of quantified emission reductions varies depending on the Member State (in terms of overall share of the total sector emissions). Credibility of these estimates must therefore be considered at a Member State level. For the majority of PaMs, however, the emissions reductions expected to be achieved have not been quantified which gives concern for their credibility and the extent to which they will contribute towards Member Sates meeting their emission reduction commitments.





Based on the descriptions provided (although often limited), the PaMs selected appear to be technically feasible and relevant for the sector.

Around a third of the PaMs selected for adoption have implementation periods starting before 2019, which indicates that these PaMs may be incorrectly identified as additional PaMs rather than existing PaMs. For the PaMs with implementation periods in future years, the implementation period in most cases is 2020 to 2030 or beyond, indicating a progressive implementation, which is considered to be technically feasible.


PaMs selected for adoption by Member States will reduce emissions of all NECD pollutants arising from energy consumption. The majority of the PaMs are targeted at reducing PM2.5, SO2 and NOX, for which this sector is often a large contributor of emissions. The majority of the PaMs in this sector concern energy consumption in buildings (primarily households) and industry and as such PaMs are expected to reduce emissions from the largest emission sources in this sector.


Quantified emissions reductions are presented only for a small number of individual PaMs. The PaMs show an increasing reduction between 2020, 2025 and 2030 corresponding to a gradual uptake from the reported implementation start year, which is assumed to be realistic.

3.5.3.3 Transport

Transport is a significant source of NOX and PM2.5 emissions in many Member States, and in some cases also SO2, NMVOCs and NH3. The main contribution to emissions is the combustion of fuels in engines and evaporative emissions. Emissions also arise from brake and tire wear (PM2.5), refuelling infrastructure (NMVOC) and abatement technologies (NH3 from selective catalytic reduction for NOX control).

The guidance for the development of NAPCPs (2019/C 77/01) highlights the importance of Member States to consider the EU Strategy for Low Emission Mobility, the National Policy Framework for the development of the market as regards alternative fuels in the transport sector, and the EU Urban Mobility Package objectives when developing the NAPCP for this sector.

Overview of PaMs

Additional PaMs targeting emissions reductions from transport have been considered by all 19 Member States captured in this analysis that reported via the EEA PaM Tool. Between 2 and 22 PaMs have been identified by each country. 10 Member States have selected all PaMs considered for adoption, 6 Member States reported that none had been selected for adoption and 3 Member States indicated that between 68% and 85% of the PaMs considered had been selected for adoption (Figure 3-20).




Figure 3-20 Member States which have considered and selected PaMs for adoption for transport

An overview of the transport sector PaMs selected for adoption is provided in Table 3-12. Member States considered a variety of individual or groups of PaMs. This summary focuses on single PaMs, whether reported individually or as part of a package of PaMs. To facilitate comparison, these have been mapped into categories of similar types of PaMs. These PaMs are predominantly targeted at road transport, with a small minority at other modes: shipping, rail, non-road mobile machinery, inland waterways and aviation (in order of number of PaMs considered). Therefore, unless specifically indicated otherwise the PaMs in Table 3-12 relate to road transport. Not all Member States have considered or selected for adoption PaMs of all example types. This may be because such measures have already been adopted and are therefore not reported in the NAPCP.

Table 3-12 PaMs relating to transport, selected for adoption by Member States

PaM category

and types





Software update for diesel cars

Retro-fitting tailpipe abatement (e.g. for NOX and/or PM) for HDVs / buses / vehicles

Vehicle tyres and aerodynamics

Support and promotion for lighter vehicles

Phasing out / scrapping old vehicles

Support for more efficient internal combustion engines

BE(3), CY28,DE(4),DK, ES, UK, SE(3), MT

EE(2), IE,LT(4),PT

Eco-driving initiatives

Eco-driving

No engine idling

Car ride sharing and short-term car rental

BE, LT, PT, MT(2)

EE(2)





PaM category

and types




Introducing stricter emission limit values than required under existing legislation

Update / enforce vehicle emission limits*

Emissions controls for shipping

BE(2), DE(2), DK(2), UK, FR

-


Diesel phase out / taxation change

Diesel and petrol phase out

Alternative fuel / natural gas infrastructure

Electrification of road vehicles and rail

Biofuels support

Switch from road freight to rail

Limit sulphur in marine fuels

BE, CY, DK, ES(3), LT(2), SE, CZ (3), FR(5), SK, MT(4)

BE, EE(2), IE(3), LT, LV(4), PL(3), PT, Sl

Public transport

Support and promotion for buses and public transport infrastructure

Greening of public transport and taxis

Bike sharing schemes

DK, LT(2), PT(2), MT(9)

EE, IE, LV(2)

Other

Greening the vehicle fleet / inland waterway vessels / maritime fleet / cruise ships / non-road mobile machinery / rail / aviation (different sources identified for different PaMs)

Establishing Low Emission Zones (LEZ)

Port air quality plans

Reducing traffic

Changes to vehicle taxation

Development of remote working and e-services

Road user charging

Parking policy

Public procurement of clean vehicles

Changes to spatial planning and mobility policy and planning

Promotion of modal shift, including cycling

Improving monitoring and assessment for air quality, including roadside technical inspections

Improving procedures for detection of manipulation of pollution abatement technologies

Improving institutional capacity; awareness raising

BE(10), DE(2), DK(2), ES(2), UK(6), LT(10), PT(2), SE(2), CZ, FR(11), SK, MT(12)

BE(2), EE(4), HR(2), IE, LT(2), LV(6), PL, SI(2)




Notes: *A few of the PaMs identified as being “additional” by certain Member States, appear to be implementation of already approved EU legislation and should therefore be included as existing measures and not as additional measures. In some cases, the national PaM goes beyond the requirements of the EU legislation and so differentiation should be made between the existing and additional elements rather than being presented in combination.

Policy instruments

According to the information reported via the EEA PaM Tool, the types of policy instruments most commonly selected for adoption by Member States for PaMs targeting transport are regulatory, economic and planning instruments.

Figure 3-21 Types of policy instruments used by Member States for PaMs selected to target transport (number of PaMs)

Notes: In many cases, individual PaMs are categorised as being of more than one policy type, so the numbers of PaMs indicated in Figure 3-21 is greater than the number of PaMs selected for adoption for this sector.

There is some variation between Member States in the reported category of policy instruments for similar types of PaMs, with variation mainly between whether similar PaMs are listed as being based on regulatory or fiscal and economic instruments. For the most part, the identified instrument types appear to be appropriate for the types of PaMs.


Several Member States have reported considering PaMs with an implementation start date prior to 2019 (52 PaMs in total) or during 2019 (36 PaMs), 1 PaM has a reported implementation end date of 2017 and 3 PaMs of 2019. This suggests that these PaMs could already be in place, in which case they should not have been considered as “additional” PaMs. However, not all of these PaMs have been reported as being selected for adoption. It is not clear whether this is because they have been included as existing PaMs or if it has been decided not to implement them. One considered PaM has a start year of 2030, but this has not been selected for adoption.

The majority of the PaMs selected for adoption (40) have an implementation start year of 2020 or 2021, with only 8 PaMs being selected for adoption with a later start year (2022, 2023, 2024 and 2025). 39 of the PaMs selected for adoption have a reported implementation finish year before 2030; considering the nature of these PaMs the positive effects of their implementation should continue in future years following implementation. The implementation for the rest of the measures is reported to apply up to 2030 or beyond.

A small number of the PaMs have an unrealistic implementation start year (e.g. last petrol car sold in 2030 with a start year of 2019, significant regulatory changes indicated with a start year of 2019).




However, the timeframes for implementation for the large majority of PaMs are technically feasible in view of the types of instrument used to implement the measures and the types of action required.


PaMs considered and selected for adoption by Member States for the transport sector will reduce emissions of NOX, PM2.5, NMVOC, SO2, NH3 and BC, in descending order of number of PaMs. Most PaMs are expected to affect more than one pollutant.

The impacts on emissions by PaMs in this sector have been quantified by a total of 17 Member States (Belgium, Croatia, Cyprus, Czechia, Germany, Denmark, Estonia, Spain, France, Ireland, Lithuania, Latvia, Malta, Poland Sweden, Slovakia, United Kingdom).

Quantified emissions reductions have been reported for 43 PaMs considered for adoption (of which 27 PaMs were selected for adoption). Apart from 13 PaMs, the emission reductions expected from individual PaMs in 2030 are small (<1 kt/year). The measures adopted by Cyprus and France and selected for adoption by Denmark are reported to lead to large reductions of NOX. For other pollutants and Member States the estimated quantified reductions are smaller and represent a smaller proportion of national emissions from the transport sector.

6 of the individually quantified PaMs are included in packages of PaMs.

There are 16 packages of PaMs considered for which quantified reductions have been reported (of which 11 have been selected for adoption). 4 of these packages are reported as affecting other sectors in addition to transport, although 2 of these are focused on the transport sector with cross-cutting indicated to reflect indirect implications (e.g. on energy supply due to transport electrification). Only one package is very general (“Climate and Clean Air Package”).

The quantified emissions reductions reported for these packages of PaMs represent a more significant percentage of national emissions, particularly of NOX. Due to the general nature of these groups of PaMs it is not possible to validate whether the quantified emission reductions are feasible.

Further reductions can be expected from the other PaMs selected for adoption, but for which no quantified reductions have been reported. The impact is likely to vary significantly between PaMs, Member States and pollutants, so a broad conclusion on the scale of the potential impacts cannot be drawn in this horizontal assessment.

Ranges of values have been reported for a small share of the emissions reductions reported for individual or packages of PaMs, indicating uncertainty in the estimated reductions of between 1% and 100% (median of 25%). This demonstrates that where estimated, the uncertainty in emission reductions is high.



There is an even distribution of types of PaMs ranging from very specific (e.g. Action on Non-Road Mobile Machinery via publicly funded infrastructure projects), to very generalised (e.g. transport strategies). The more generalised descriptions mean there is a higher uncertainty of the PaMs being able to achieve a specific emissions reduction.

As the emissions reductions expected to be achieved for the majority of PaMs have not been quantified there is a concern for their credibility and the extent to which the emission reduction commitments will be achieved.


Based on the names and types of PaMs, the PaMs selected appear to be technically feasible and relevant for the sector.

Around 60% of the PaMs selected for adoption have implementation periods starting, and in a small number of cases finishing, before 2020, which indicates that these PaMs may be incorrectly identified as additional PaMs rather than existing PaMs. For the PaMs with implementation periods in future years, the implementation period in most cases is 2020 to




2030 or beyond, indicating a progressive implementation, which is considered to be technically feasible.


PaMs selected for adoption by Member States will reduce emissions of all NECD pollutants arising from transport. The majority of the PaMs are targeted at reducing NOX and PM2.5, for which this sector is often a large contributor of emissions. While the majority of the PaMs are projected to reduce emissions from road transport which is commonly the largest emission source in this sector, not many Member States have considered PaMs for other modes of transport.


Quantified emissions reductions are presented only for a small number of individual PaMs. There is no common pattern, with some PaMs expected to only reduce emissions in 2020, other PaMs presented with a constant reduction in each of 2020, 2025 and 2030 and the remainder showing a varying reduction achieved in different years. Where quantified, the emission reductions are in most cases small for individual PaMs, so this could be achievable in 2020 if the PaMs are implemented as intended.

Except for PaMs and/or packages of PaMs reported by a few Member States, the emission reductions for 2020 are relatively small, with larger reductions reported for 2025 and 2030. This implies a staged uptake of the measures over the time period which would be expected considering the time it takes to implement new measures and realise the impacts.

3.5.3.4 Industrial processes

12 Member States have reported PaMs targeted towards reducing emissions from industrial processes. Half of the PaMs reported for industry have also been listed under energy supply and/or energy consumption. Energy production is a major source of emissions of SO2, NOX and PM2.5 in industrial sectors. Emissions also arise from the storage and handling of raw materials and products (NMVOC, PM2.5) and from the production processes (NOX, PM2.5, NMVOC, NH3).

Similar to energy production, the EU Energy Union Strategy and Renewable Energy Sources objectives are relevant when developing the NAPCP for this sector.

Overview of PaMs

Additional PaMs targeting emissions reductions from industrial processes have been considered by 12 Member States that reported via the EEA PaM Tool and are captured in this analysis. Between 1 and 15 PaMs have been identified by each country. 5 Member States selected all PaMs for adoption, 4 Member States reported that none had been selected and 2 Member States indicated that around 80% of the PaMs considered had been selected for adoption (Figure 3-22).




Figure 3-22 Member States which have considered and selected PaMs for adoption for industrial processes

An overview of the PaMs selected for adoption for industrial processes is provided Table 3-13. Member States considered a variety of individual or groups of PaMs. This summary focuses on single PaMs, whether reported individually or as part of a package of PaMs. To facilitate comparison, these have been mapped against the example categories of potential PaMs for the sector based on the guidance for the development of NAPCPs, along with other types of PaMs which do not fit this categorisation.


Table 3-13 PaMs relating to industrial processes, selected for adoption by Member States

PaM category

and types





Reduction of NMVOC leakage

Desulphurisation units and flue gas cleaning

Abatement in refineries and lime kilns

Replacement / renovation /maintenance of boilers and heating equipment


LT(7), SE(4), BE DE, LV(2), PL


Implementation of MCPD and IED*


SO2 cap for refineries

Move to lower BAT-AELs (achievable emission levels) for permit requirements

BE(2),UK, FR, MT

LV(3), LT, PL




PaM category

and types




Other

Solvent (VOC) limits for paints and coatings*

Reducing PM emissions from refineries

Restricting / reducing VOCs from industry

Regulate smaller sites

Replacement of biomass with gas

Revision of taxes, tariffs and premiums

Improving air pollution and appliances inventories

Improving monitoring and assessment for air quality


Improving enforcement and control

BE(2), UK(3), LT(6), FR(5)

UK, HR, LT, LV(2), PL

Notes:

*Several of the PaMs identified as being “additional” by certain Member States, appear to be implementation of already approved EU legislation and should therefore be included as existing measures and not as additional measures.

Policy instruments

According to the information reported via the EEA PaM Tool, the types of policy instruments most commonly selected for adoption by Member States for PaMs targeting industrial processes are source-based and regulatory instruments.

Figure 3-23 Types of policy instruments used by Member States for PaMs selected to target industrial processes (number of PaMs)

Notes: In many cases, individual PaMs are categorised as being of more than one policy type, so the numbers of PaMs indicated in Figure 3-23 is greater than the number of PaMs selected for adoption for this sector.




There is similarity between Member States in the reported category of policy instruments for similar types of PaMs and the identified instrument types generally appear to be appropriate for the types of PaMs.


Member States have reported considering PaMs with an implementation start date prior to 2019 (11 PaMs in total) or during 2019 (10 PaMs). This suggests that these PaMs could already be in place, in which case they should not have been considered as “additional” PaMs. 14 of these PaMs have been reported as being selected for adoption. It is not clear whether those which were not selected for adoption have been included as existing PaMs or if it has been decided not to implement them.

The majority of the PaMs selected for adoption (13) have an implementation start year of 2020. 8 PaMs selected for adoption have a later start year (2021, 2025 or 2027). 5 PaMs selected for adoption have an early reported implementation finish year (2018, 2020 or 2024). The implementation for the rest of the measures is reported to apply up to 2029, 2030 or beyond.

The timeframes for implementation for the PaMs selected for adoption from 2019 onwards are technically feasible in view of the types of instrument used to implement the measures and the types of action required, and that the implementation finish dates allow for gradual take-up over time.


PaMs considered and selected for adoption by Member States for industrial processes will reduce emissions of NOX, PM2.5, SO2, , NMVOC, BC and NH3 , in descending order of number of PaMs. Most PaMs are expected to affect more than one pollutant.

The impacts on emissions by PaMs in this sector have been quantified by a total of 9 Member States (Belgium, Cyprus, Germany, Spain, France, Lithuania, Poland, Sweden, United Kingdom).

Quantified emissions reductions have been reported for 19 individual PaMs considered for adoption (of which 18 has been selected for adoption), but majority of these PaMs are reported to achieve a reduction lower than 1 kt/year. Considering the small number of quantified individual PaMs presented and the small reductions projected, even when summing the reductions by pollutant per Member State, the overall estimated reductions remain small and represent only a small proportion of national emissions from industry. The exceptions are more significant emission reductions reported for some industrial PaMs by France, Germany and Poland

Only one of the individually quantified PaMs selected for adoption is included in a package of PaMs, for which quantitative reductions are not reported at package level.

There are 6 packages of PaMs for which quantified reductions have been reported, of which 4 have been selected for adoption. All of these packages are reported as affecting other sectors in addition to industrial processes and the description of the packages and PaMs included within these packages are very general (e.g. industry measures). Spain has reported a package of measures, also listed for energy supply and consumption, achieving significant reductions for NOX and SO2 with the disadvantage of smaller increases in emissions of PM2.5, NH3 and NMVOC from the same package of measures. No other country has reported increases for similar types of measure.

Further reductions can be expected from the other PaMs selected for adoption, but for which no quantified reductions have been reported. The impact is likely to vary significantly between PaMs, Member State and pollutant.

Ranges of values have been reported for 2 packages of PaMs only. Excluding the package reported by Spain due to large uncertainties and negative values reported, the indicated uncertainty ranges between 10% and 49% (median of 20%).

There is insufficient quantified data or similarity between PaMs to compare between different Member States, and therefore it is not possible to validate the estimations provided through comparison.






There is an even distribution of types of PaMs ranging from those targeted at a specific source (e.g. lime kilns, refineries), to those applicable for a specific pollutant (e.g. SO2 or NMVOCs) to very generalised (e.g. industrial roadmaps).

Quantified emissions reductions are provided for just over half of the individual PaMs. Where quantified estimates are provided, the values are small for the majority of the PaMs. Thus, with a few exceptions, where PaMs lack credibility this is unlikely to have a large impact on overall emission reductions that will be achieved in the sector.

Where no emission reductions from the PaMs have been reported, the review have found these PaMs as less credible.

Several PaMs proposed by different Member States relate to existing EU legislation (e.g. implementation of BAT under the IED and the MCPD). These PaMs should be included as existing PaMs instead of additional PaMs as has been done. This would result in lower emissions from the WM scenario, and less reduction under the WAM scenario, but the overall compliance gap from the commitments will be the same under the WAM scenario.


Based on the names and types of PaMs, the PaMs selected appear to be technically feasible and relevant for the sector.

Several PaMs have implementation periods starting before 2020, which indicates that these PaMs may be incorrectly identified as additional PaMs rather than existing PaMs. For the PaMs with implementation periods in future years, the implementation period in most cases is 2020 to 2030 or beyond, indicating a progressive implementation, which is considered to be technically feasible.

Do the PaMs intend to reduce emissions from the largest emission sources?

PaMs selected for adoption by Member States are projected to reduce emissions of all NECD pollutants arising from industry. Similar numbers of PaMs are targeted at reducing NMVOC, PM2.5, SO2 and NOX, for which this sector is often a large contributor of emissions, with only a small number for NH3 and BC.


Quantified emissions reductions are presented for just over half of individual PaMs. There is no common pattern, with some PaMs expected to only reduce emissions in 2020, other PaMs presented with a constant reduction in each of 2020, 2025 and 2030 and the remainder showing a varying reduction achieved in different years.

Where quantified, the emission reductions are in most cases small, so this could be achievable in 2020 if the PaMs are implemented as intended.

3.5.3.5 Agriculture

Agriculture is a significant source of NH3 and, to a lesser extent, of PM2.5 and NOX emissions. The NECD recognises in recital 21 that agriculture makes an important contribution to these emissions and that in order to reduce them, the NAPCPs should include measures applicable to the agricultural sector. It is further noted that the Common Agriculture Policy (CAP) can support Member State actions to reduce emissions of these pollutants.

Annex III, Part 2 to the NECD lists measures relating to the agricultural sector which have been proven to deliver NH3 and PM2.5 emission reductions, including both mandatory and voluntary PaMs. Under Article 6(2) of the NECD, Member States shall include measures from Annex III, Part 2 measures in their NAPCP, or other measures which can achieve equivalent mitigation effect.

However, as the NECD does not require that the NAPCP includes details on existing PaMs, and as the NAPCP common format covers reporting on PaMs in the agriculture sector in the section on PaMs




considered for adoption only, the already implemented Annex III measures are not systematically reported by Member States. Consequently, it was not always possible to determine if all mandatory (and voluntary) PaMs have been implemented in a given Member State.

Overview of PaMs

18 Member States that reported via the EEA PaM Tool, and of which information is taken into account in the analysis in this report, have considered additional PaMs targeting emission reductions from the agriculture sector (all except for Slovenia). Among these, 10 Member States selected all PaMs for adoption, 3 Member States selected between 20- 80% of the PaMs they considered for adoption and 5 Member States reported none as selected (Figure 3-24).

Figure 3-24 Member States which have considered and selected PaMs for adoption for agriculture

An overview of the agriculture measures selected for adoption is provided in Table 3-14. The table is structured according to Annex III, Part 2 measures which cover the majority of PaMs selected for adoption, owing to the comprehensive nature of the measures listed.

Of the Annex III, Part 2 measures, the ones most commonly selected for adoption by Member States are those which target NH3 emission reductions (detail provided in Table 3-14):

A1 - Items to control NH3 emissions for inclusion in a national advisory code of good agricultural practice: Considered by 12 Member States and selected by 8.

A3 – Approaches to reduce NH3 emissions from fertilisers: Considered by 14 Member States and selected by 9.

A4 – Approaches to reduce NH3 emissions from livestock manure: Considered by 12 Member States and selected by 8.

Despite being a mandatory measure, only Lithuania and Sweden reported a ban on ammonium carbonate fertilisers (Annex III, Part 2, A3) as an additional PaM selected for adoption and no Member States reported the adoption of a national NH3 budget as a selected measure in the EEA-PaM tool. However, it may be that these measures are already in place and therefore not necessarily reported in the NAPCP. Likewise, only 3 Member States have selected emission reduction measures to control emissions of PM2.5 and black carbon (voluntary measure, Annex III, Part 2, B).

Member States may exempt small and micro farms from the agricultural measures, to limit additional costs where possible and appropriate in view of the applicable emission reduction commitments. A total of 8 Member States reported the use of these exemptions (detail provided in Table 3-14). The expected impact of these exemptions on emission reductions is not required to be provided by Member States but is however expected not to be significant due to the small scale of operation of these farms.




Table 3-14 Measures in Annex III, Part 2 to the NECD relating to agriculture, selected for adoption by Member States

Annex III, Part 2 Selected for adoption


Exemption for small and micro farms

A1 - Member States shall establish a national advisory code of good agricultural practice to control ammonia emissions (mandatory), covering at least the following items:

Nitrogen management, taking into account the whole nitrogen cycle (A.1 (a))

ES, LT, MT, CZ, SK

EE, HR, PL SK

Livestock feeding strategies (A.1 (b)) DE, ES, LT, CZ, SK

EE, HR, IE, PL

SK

Low-emission manure spreading techniques (A.1 (c))

DE, ES, LT, SE, CZ, SK

EE, HR, IE, PL

LT, SK

Low-emission manure storage systems (A.1 (d)) CY, DE, ES, LT, SE*, CZ, SK

EE, HR, IE, PL

SK

Low-emission animal housing systems (A.1 (e)) CZ DE, ES, LT, SK

EE, HR, PL LT, SK

Limiting the NH3 emissions from use of inorganic/mineral fertilisers (A.1 (f))

CZ, ES, LT. SK

EE, HR, IE, PL

SK

A2 - Member States may establish a national nitrogen budget (optional)

National nitrogen budget (A.2) - - -

A3 - Member States shall prohibit the use of ammonium carbonate fertilisers (mandatory) and may reduce NH3 emissions by using the following approaches (optional):

Ban ammonium carbonate fertilisers (A.3) LT, SE EE, HR, PL

Replacing urea-based fertilisers by ammonium nitrate-based fertilisers (A.3 (a))

BE, CY, DK, ES, UK

IE, LV CY

Where urea-based fertilisers are still used, apply NH3 emission reduction methods as specified in the Ammonia Guidance (A.3 (b))

BE, CZ, DK, ES, UK

IE, LV

Replacement of inorganic fertilisers by organic fertilisers; ensuring that inorganic fertilisers still used are applied with due account to nutrient needs and existing nutrient contents in soil (A.3 (c))

BE, ES, LT, MT

LV, PL

A4 - Member States may reduce ammonia emissions from livestock manure by using the following approaches (optional)

Reducing emissions from slurry and solid manure application to arable land and grassland (according to nutrient requirements of the soil) (A.4 (a) (i))

BE, CZ, DE, ES, UK, MT, SK

EE, IE, LV, PL

EE, SK

Reducing emissions from slurry and solid manure application to arable land and grassland (according to soil conditions) (A.4 (a) (ii))

BE, CZ DE, ES, SK, UK

IE, LV, PL SK







Reducing emissions from slurry and solid manure application to arable land and grassland using a trailing hose, trailing shoe or via shallow or deep injection (A.4 (a) (iii))

CZ, DE, ES, SK

IE, PL SK

Reducing emissions from slurry and solid manure application to arable land and grassland by incorporating manure and slurry within time constraints (A.4 (a) (iv))

BE, CZ, DE, ES, SK, UK

LV, PL SK

Reducing emissions from manure storage outside of animal houses by applying recommended low emission storage systems or techniques (A.4 (b) (i))

CZ, DE, ES, UK, SK

EE, IE, LV DE, EE, ES, SK

Reducing emissions from manure storage outside of animal houses by covering stores for solid manure (A.4 (b) (ii))

CZ, DE, ES, SK, UK

IE, LV DE, ES, SK

Reducing emissions from manure storage outside of animal houses by ensuring farms have sufficient manure storage capacity to spread manure only during periods that are suitable for crop growth (A.4 (b) (iii))

CZ, DE, SK, UK

LV DE, SK

Reducing emissions from animal housing by applying recommended low-emission systems (A.4 (c))

BE, DE, DK, ES, LT, SK, UK

IE, LV BE, DE, DK, ES, SK

Reducing emissions from manure, by using low protein feeding strategies (A.4 (d))

DE, ES, SK, UK

IE, LV DE, ES, SK

B1- Member States may ban open field burning of agricultural harvest residue and waste and forest residue:

Ban open field burning of agricultural harvest residue and waste and forest residue (B1)

BE, CY, FR PL -

Exemptions to such a ban shall be limited to preventive programmes to avoid uncontrolled wildfires, to control pest or to protect biodiversity (B1)

BE, CY, FR - -

B2 – B4 - Member States may establish a national advisory code of good agricultural practices for the proper management of harvest residue (optional)

Improvement of soil structure through incorporation of harvest residue (B.2 (a))

ES, FR - -

Improved techniques for incorporation or alternative use of harvest residue (B.2 (b)) and B.2 (c)).

CY, FR - -

Improvement of the nutrient status and soil structure through incorporation of manure as required for optimal plant growth, thereby avoiding

CY, FR - -







burning of manure (farmyard manure, deep- straw bedding). (B.2 (d))

Notes: Sweden reported using the EEA PaM Tool that three PaMs are not relevant to the measures in Annex III, Part 2, however based on the detail provided and information reported in the NAPCP, the PaMs can be cross-referenced to the measures in Annex III, Part 2. France has not classified the agricultural PaMs according to Annex III Part 2 in the EEA-PaM tool. However, the review has found that the required agricultural measures listed in Annex III, Part 2 to the NECD and optional measures except for a national nitrogen budget and a low protein feeding strategy are part of existing measures already adopted and being implemented by France. Slovenia has not reported information on agricultural PaMs via the EEA-PaM tool however has reported implementation of measures A1, A2, A3 and A4 (b) in the NAPCP. All PaMs reported by Cyprus are existing PaMs.

Policy instruments

Member States have taken a varied approach to establishing the measures relating to agriculture set out in Annex III, Part 2. For example, when establishing a national advisory code of good agricultural practice to control NH3 emissions, some have reported the use of information or voluntary instruments (e.g. Cyprus and Sweden), while others have established a regulatory code (Germany), or a combination of both (Denmark and the UK).

According to the information reported via the EEA PaM Tool, the policy instruments most commonly used by Member States for PaMs targeting the agriculture sector are regulatory, economic and information ones.

Figure 3-25 Types of policy instruments used by Member States for PaMs selected to target the agriculture sector (number of PaMs)


In terms of implementation periods for the PaMs selected for adoption, Member States have reported implementation start years prior to 2019 for 7 PaMs, and 2019 for 23 PaMs. For 50 PaMs selected for adoption the implementation is reported to start in 2020, 2021 or 2023.

The extent to which 2019 is a feasible implementation start year is unclear from the descriptions provided, as follows:




Information and regulatory instruments are the most commonly used among those PaMs which will be implemented in 2019. Such policy instruments may be implemented in a short timescale, but emission reductions achieved will be dependent on changing farming practices as a result of the established information and education campaigns and compliance with the regulatory instruments established. The impacts of these measures are likely to be realised over longer timescales following implementation.

Source-based and fiscal instruments have not been commonly reported for PaMs selected for implementation in 2019. The PaM descriptions are not detailed enough to determine whether the expected emission reductions are feasible or not at source level.

The end of implementation ranges from 2019 up to 2030 or is unspecified. There are discrepancies between Member State reporting of implementation periods and the expected emission reductions. In some instances, the end of implementation was not reported by Member States, but the expected emission reductions were reported beyond the implementation period (reported up to 2030 and beyond). In contrast, 3 Member States reported PaMs with an end of implementation in 2019 (thus the PaMs are selected for adoption for the year 2019 only). In the case of 2 of these Member States the expected emission reductions were reported beyond the implementation period (reported up to 2030 and beyond).

It is unclear how the implementation periods reported are expected to overlap with the programming periods for the available EU funding instruments under the CAP. Only a few Member States refer to CAP funding (e.g. Lithuania and Sweden).


The majority of PaMs considered by Member States for agriculture target emission reductions of NH3.

The quantified emission reductions are often insufficient for Member States to meet their emission reduction commitments. Agriculture is also a significant source of PM2.5 but very few PaMs selected are targeted at this pollutant and only one Member State has reported the associated expected quantified emission reduction from the PaM selected for adoption.

The impact on emissions by PaMs in this sector have been quantified by a total of 15 Member States (Belgium, Croatia, Cyprus, Czechia, Germany, Denmark, Estonia, Ireland, Lithuania, Latvia, Poland, Spain, Sweden, Slovakia and United Kingdom).

Quantified emissions reductions have been reported for 31 individual PaMs considered for adoption (of which 17 has been selected for adoption). There are 16 packages of PaMs considered for adoption (of which 10 packages have been selected for adoption) for which quantified reductions have been reported. Some of these packages included PaMs for which emission reductions were also reported at individual PaM level. 6 packages are reported as solely concerning agriculture. Remaining 4 packages are also reported against other sectors thus the impact on emission reductions may not be solely attributed to the PaMs for agricultural sector.

Excluding Spain, Germany and United Kingdom which reported larger emission reductions (between 20 and 133 kt/year) for some of the PaMs, the estimated emission reductions associated with PaMs reported by other Member States for 2030 vary between 1 and 15 kt/ year per country. The three outliers relate to significant NH3 emission reductions reported at package level. It is not possible to determine which individual PaMs included are expected to deliver the significant share. This makes it difficult to assess their credibility. Lithuania and Sweden reported selecting for adoption PaMs with emission reductions less than 1kt / year.

Further reductions can be expected from the other PaMs selected for adoption but for which no quantified reductions have been reported.

Ranges of emission reductions have been reported for 1 individual PaM and 2 packages of PaMs. Due to relatively large number of packages of PaMs selected for adoption (compared to the number of individual PaMs), more reporting of ranges would have been expected. Where the estimated emission reductions are reported as a range, there is insufficient detail to determine what is the most likely level of emission reductions.

Due to an overall small number of PaMs for which emission reductions were reported, it is not possible to validate the estimations through comparison.




Very few PaMs selected for adoption are expected to deliver emission reductions for PM2.5. Where reported, the PaMs target NH3 emissions and deliver emission reductions of PM2.5 as a co-benefit. A few Member States also quantified emission reductions from this sector for SO2, NOX and NMVOC. As a share of the total estimated emission reductions for these pollutants, the reductions quantified for PaMs targeting the agriculture sector are comparatively minor.



The descriptions of PaMs provided in the EEA-PaM tool correspond with the measures described in Annex III, Part 2. There is a clear link between the PaMs and their intended purpose according to the detail included in the NECD. As such PaMs reported for the agriculture sector have generally been found credible in the review, despite the descriptions of PaMs often being very general. However, there were a few instances where the PaMs reported were not yet fully designed and it was not clear which specific actions will be taken to deliver the reported emission reductions. Such PaMs were judged as not credible.


The PaMs selected for adoption are derived from the measures listed in Annex III, Part 2 of the NECD which are considered technically feasible.

The implementation periods are considered to be technically feasible. Regulatory, economic and information provisions are the most commonly reported policy instruments. While such policy instruments may be implemented in a short timescale the attainment of emission reductions may take time.

The extent to which the expected emission reductions can be achieved in the immediate timeframe is unclear from the limited PaM descriptions reported by Member States. Emission reductions achieved will be dependent on changing farming practices and it is often unclear how the PaMs selected for adoption will drive this change.


Agriculture is the largest emitting sector of NH3 and, to a lesser extent, NOX and PM2.5. However, the PaMs are generally reported to reduce emissions of NH3 only. Very few PaMs selected for adoption are expected to deliver emission reductions for PM2.5. Where reported, the PaMs target NH3 emissions and deliver emission reductions of PM2.5 as a co-benefit.

The quantified expected emission reductions are often insufficient for Member States to meet their emission reduction commitments.


Member States have reported implementation start years prior to 2019, 2019 and up to and 2023. The end of implementation ranges from 2019 up to 2030 or is unspecified.

Expected emission reductions estimated for the PaMs selected for adoption are reported annually and for some PaMs and Member States are the same for 2020 and 2030. This reflects the ongoing nature of the measures but does not appear to reflect any changes in the scale of implementation. For some Member States the estimates vary across time.

3.5.3.6 Waste management

Compared to the sectors described above, waste management is a smaller contributor of PM2.5 (waste handling, open waste burning), NH3 (composting, anaerobic digestion, waste water treatment plants), NMVOC (waste incineration, open burning of waste, waste water treatment plants) and SOx and NOX (waste incineration) emissions. The major emissions from this sector are emissions of greenhouse gases such as CH4 (which is also an ozone-precursor), N2O and to a lesser extent CO2.

Consequently, PaMs intended to reduce emissions from the waste sector have only been reported as considered for adoption by 7 Member States (Belgium, Croatia, France, Latvia, Lithuania, Malta and Spain). Only Belgium, France, Malta and Spain selected for adoption PaMs specific to the waste management sector (see Table 3-15). All PaMs reported by Lithuania, Latvia and Croatia for the waste




sector were multisectoral PaMs, not specific to the waste sector (e.g. concerning assessment of air quality impact, development of emission inventories). Some PaMs reported by Lithuania for the waste management sector were in fact transport PaMs. These PaMs related to an introduction of a diesel vehicle scrappage scheme. While these PaMs could have an impact on waste generation and thus emissions from the sector, reporting them in the waste management sector in the EEA-PaM tool is not appropriate. Therefore, PaMs reported by Lithuania, Latvia and Croatia are not listed in the table below.

Table 3-15 PaMs relating to waste management sector, selected for adoption by Member States

PaM category

and types





Management of biogas leakage from sealed landfills: Coverage with oxidizing covers

ES -

Burning restrictions

Reduce the burning of green waste BE, ES, FR(2) -

Waste recycling and minimisation

Increase in separate collection of various waste types (paper, bio-waste, textiles, domestic cooking oil)

Renovation of composting infrastructure and promotion of domestic and community composting

Reduction of food waste

ES -

Other

Waste to Energy Facility MT

The policy instruments reported for the PaMs presented above are primarily information, planning and regulatory tools. For 13 PaMs, implementation is due to start in 2020, 2021 or 2023 and conclude in 2030 or beyond (no end date for implementation has been reported for 2 PaMs and for 1 PaM the end date is 2050).

Projected emission reductions were quantified by Spain only for the following packages of PaMs: reduction of emissions from burning pruning remains and measures related to waste recycling and waste minimisation. According to the information reported, the PaMs will contribute to reductions in PM2.5, NOX, SO2 and NMVOC emissions, but result in an increase in NH3 emissions.

Overall, the very few PaMs correctly reported as selected for adoption in the waste management sector have been found credible based on the descriptions and emission reductions reported. However, these PaMs will have a minor impact on emissions across the EU Member States because the waste sector is an overall small contributor to total emissions of NECD pollutants.

3.5.3.7 Cross-cutting and other PaMs

28 PaMs have been reported specifically as “cross-cutting”, and 11 PaMs as category “other”. “Cross-cutting” and “other” sector categories have also been reported by the Member States for PaMs considered and selected for the specific individual sectors. To avoid repetition with earlier sections, the summary below focuses on the PaMs reported only as “cross-cutting” or in the “other” category.

Overall, 12 Member States (Belgium, Czechia, Croatia, France, Germany, Ireland, Latvia, Lithuania, Portugal, Slovenia, Slovakia and United Kingdom) have reported “cross-cutting” and “other” PaMs considered for adoption. Of these, Croatia, Ireland, Latvia and Slovenia have not selected any for




adoption (keeping in mind that Latvia reported only a draft NAPCP). The PaMs selected for adoption by the remaining Member States relate to:

Enforcement, support and cooperation between the authorities (Belgium, Czechia, France, United Kingdom)

Awareness raising (Belgium, France, Lithuania, Portugal)

Research and improving expertise on air quality and air emissions (Belgium, Czechia, France)

Legislative amendments and plans in other policy areas (Czechia, Germany)

Development of plant-lined roads (putting plants near major pollution sources in cities) (Lithuania)

International cooperation to reduce air pollution (Czechia)

Revaluation of excise duty on petrol and diesel (Slovakia)

Emission reductions have been quantified by 3 Member States (Ireland, France, Slovakia) for 3 PaMs only. This is justified given that the PaMs are primarily designed to support implementation of sector-specific PaMs and/or improving information availability and awareness.

3.5.4 Assessment of costs and benefits of PaMs considered and selected for adoption

Information on the costs and benefits of PaMs considered and selected for adoption is an optional content asked for in table 2.6.3. of the NAPCP common format. 7 Member States reported some information on costs and benefits of PaMs considered and selected for adoption: Bulgaria, Croatia, Czechia, Denmark, Estonia, Slovakia and Sweden. In addition, Cyprus reported information on the costs of some of the already adopted PaMs. Cyprus, Czechia, Denmark and Slovakia used the EEA-PaM tool to report the cost data, with the remaining Member States providing this information in their individual NAPCPs. The cost information reported is summarised in Table 3-1629. The information reported in the NAPCPs was mostly limited to a single value, with very sparse detail provided on the timescales in which the costs will be incurred and the assumptions behind the estimates. As such it was not possible in the review to question the robustness of such estimates or to compare the ranges of costs reported by Member States for PaMs of a similar nature.

Table 3-16 Summary of the cost information provided on the PaMs considered and selected for adoption in NAPCPs

Member State

Information reported Costs of PaMs considered for adoption

Bulgaria Costs and benefits for 4 PaMs in the residential heating sector, reported against 6 specific actions assumed as part of these PaMs. Reported in the NAPCP but not in the EEA-PaM tool. Estimates provided for the period 2016 – 2030.

Costs are reported as absolute values as well as cost abated (EUR per tonne of PM2.5 reduced). Benefits minus costs are expressed in Net Present Value (NPV). Benefits to costs ratios are also estimated.

Costs for specific actions are:

Reconnection to gas: EUR 715 per tonne of PM2.5 reduced, 12 million EUR

New connection to gas: EUR 11,297 per tonne of PM2.5 reduced, 100 million EUR

Reconnection to district heating: EUR 1, 256 per tonne of PM2.5 reduced, 10 million EUR

New connection to district heating: EUR 3,733 per tonne of PM2.5 reduced, 28 million EUR

Fuel quality requirements: EUR 8,137 per tonne of PM2.5 reduced, no absolute costs

Switch to ecolabel stoves: EUR 4,806 per tonne of PM2.5, 276 million EUR.

29 Excluding information reported by Slovakia as the assessment of the NAPCP was not complete by the time of finalisation of this report.




Member State


All PaMs are reported to have a net benefit, with benefit to cost ratios of between 2.4 to 38.2.

Croatia Costs for 6 PaMs (3 agricultural and 3 cross-cutting PaMs). Reported in the NAPCP and not in the EEA-PaM tool. The timescale for the costs and benefits data is only presented for one PaM in the NAPCP (up to 2050).

Change in livestock nutrition and feed quality: 5.3 million EUR

Improving livestock facilities, systems of animal waste management and methods of organic fertiliser application: 120 million EUR

Complex agricultural infrastructure investments (drainage, irrigation etc.) to reduce the loss of nutrients due to leaching and as a result the usage of nitrogen and mineral fertilisers: 1 billion EUR

Support to increase the administrative, technical and management capacities of local communities: 5 million EUR

Preparing supporting documentation to secure additional financial resources for more effective implementation of air quality improvement action plans: 1 million EUR

Support for surveys regarding the planning of PaMs and monitoring of their effects on emissions and air quality: 1 million EUR

One PaM is reported to have a net benefit (cost / benefit ratio of 0.4) and two PaMs are reported to have a net cost (cost / benefit ratio of 9.2 and 222.2).

Cyprus Costs for 2 (existing) PaMs (one in industry and one in agriculture) reported in the EEA-PaM tool. Timescales for the costs are not provided.

Reduce energy consumption by promotion of energy efficiency measures in the industrial sector: 589 million EUR.

Further promotion of anaerobic digestion for the treatment and management of animal waste: 13 million EUR.

Czechia Cost information reported for 6 PaMs. Reported in the NAPCP and EEA-PaM tool. No timescales for the costs have been reported.

Additional emission reductions by 2030 from the public electricity and heat production: around 0.36 billion EUR (cost reported in the NAPCP is 10 billion CZK)

Replacement of heat sources in the residential stationary combustion sector: around 0.43 billion EUR (cost reported in the NAPCP is 12 billion CZK)

For the remaining 2 PaMs for which information on costs was reported, the costs were either estimated as a very broad range (‘within the interval of thousands to several millions of CZK’) or as no additional cost. For the remaining 2 PaMs the analysis of costs is yet to be conducted.




Member State


Denmark Costs reported in the EEA-PaM tool for 9 PaMs (3 in agriculture, 1 in energy supply, 5 in transport). Benefits assessed and provided in the NAPCP. Timescales are not provided in the EEA-PaM tool. However, as these are absolute costs, they are understood to reflect the costs throughout the whole implementation period. The implementation end year varies per PaM, with 2030 being the latest reported year.

Accelerated replacement of old wood burning stoves: 6.1 million EUR

Control of sulphur emissions from ships: 1.6 million EUR

Other measures within agriculture: 32 million EUR

Committee on ammonia reducing measures: 21.4 million EUR

Improved animal housing: 0.3 million EUR

Scrapping of old diesel cars: 20.5 million EUR

Environmental zones up to date: 5 million EUR

Enforcement and control of NOX fraud: 0.8 million EUR

Environmentally friendly cruise ships: 1.3 million EUR

Estonia Costs reported for the public and private sector for 24 additional PaMs across three sectors (10 in the energy sector; 11 in the transport sector; and 3 in the agriculture sector). Reported in the NAPCP and cross-referenced to in the EEA-PaM tool. Costs are reported as accumulated net cost between 2020 and 2030.

In agriculture, the costs are not split for the public and private sector and vary from 92.2 million EUR to a net benefit of 19.6 million EUR depending on the PaM. The total accumulated net cost between 2020-2030 is 92.4 million EUR.

In transport, the costs to the public sector vary from 348 million EUR to a net benefit of 453 million EUR depending on the PaM. In the private sector, all PaMs but one are reported to provide a net benefit (from 51 to 535 million EUR depending on the PaM). The total cost between 2020-2030 to the public sector is estimated at 961 million EUR and 1,917 million EUR for the private sector.

In the energy sector, all PaMs are associated with costs for both public and private sectors. For the public sector, costs vary from 0 to 577 million EUR. For the private sector, costs vary from 0 to 879 million EUR depending on the PaM. The total cost to the public sector between 2020-2030 is estimated at 1,449 million EUR and 1,913 million EUR for the private sector.

The full list of costs of individual PaMs are presented in the NAPCP review report for Estonia.

Sweden Cost and benefit estimates are reported for all agriculture PaMs, two of the industry PaMs. The information is in the accompanying report to the NAPCP and is not reported using the EEA PaM-tool.

The costs of the additional PaMs to limit NH3 emissions (from the agriculture sector) are estimated at approximately ~5.2 million EUR (55 million SEK) per year corresponding to approximately 2 kt in emission reductions.

The total costs of PaMs targeting NOX emissions could not be estimated. Where reported (for two PaMs only, affecting, industry), the annual costs were estimated at 28-47 million EUR (0.3-0.5 billion SEK) to deliver approximately 11-15.5 kt of NOX emission reductions.

The full list of costs of individual PaMs are presented in the NAPCP review report for Sweden.

When assessing the costs of PaMs, there are clear challenges linked to data limitations and uncertainties, meaning that it may not always be possible to include cost data in Member State reporting. However, lack of reporting on the costs of PaMs has the following implications:

On the NAPCP review: lack of acknowledgment of the costs of PaMs does not provide any reassurance that the costs of PaMs have been considered and funding for their implementation




secured. This then affects the extent to which credibility of the PaMs put forward by the Member States can be assessed. While it generally is extremely difficult to judge whether any reported costs are realistic (as these depend on the assumptions behind an individual PaM and national circumstances), analysis could have been conducted to demonstrate which PaMs are the most and least costly, if reporting on the costs was more complete. This could provide information in view of highlighting the most cost-effective PaMs. Analysis could also consider how costly the attainment of the NECD emission reduction commitments is expected to be for individual Member States and the EU as a whole.

On reporting to the Commission on disproportionate costs: lack of quantification of the costs and benefits of PaMs may limit Member State ability to justify to the Commission that introduction of additional PaMs in a certain timeframe may lead to disproportionate costs. Such reporting is required when a Member State diverts from a linear emission reduction trajectory or aims to apply a flexibility under Article 5(4).

On capacity building: lack of reporting on the costs and benefits of PaMs (particularly using the EEA-PaM tool) limits the scope for exchange of information on best practices in implementation of PaMs across the EU Member States. If reporting on costs (and benefits) was more complete, Member States could learn from and build on the experience of other Member States. The EEA-PaM tool could facilitate easy access to this information by the Member States and other stakeholders.

The ‘Guidance for the development of National Air Pollution Control Programmes'30 states that reporting

on projected cost-benefit estimates should be in line with reporting under Regulation (EU) No 525/2013 (EU Monitoring Mechanism Regulation (MMR)). The reporting under the MMR is intended to capture data on anticipated costs of PaMs before implementation (ex-ante) as well as actual costs following PaM implementation (ex-post). The number of Member States reporting the costs data on PaMs under the MMR has increased over the years (from 5 Member States reporting in 2015 to 10 Member States in 201731) but is still limited and not comprehensively reported for all PaMs.

3.5.5 Assessment of improvements in air quality and impacts on the environment

Impact of PaMs considered for adoption on air quality and the environment should, where available, be reported by the Member States in their NAPCPs. This information is required in sections 2.6.2 (impacts of individual PaMs or packages of PaMs considered for adoption), 2.8.4 (projected improvement in air quality under WAM scenario) and 2.8.5 (projected impacts on the environment under WAM scenario) of the NAPCP common format.

The review has found that impacts on air quality were generally not reported at individual PaM level. Projected impacts on air quality of the WAM scenario has been reported by a total of 13 Member States. The information varied from a qualitative description of impacts (Austria, Bulgaria, Croatia, Denmark, Lithuania, Slovenia), to modelling of future concentrations (Belgium, Czechia, Estonia, France, Germany, Poland, Slovakia and Spain). Where modelling of future changes in air quality has been conducted, Member States commonly included maps of future ambient air pollutant concentrations in their NAPCPs. Poland and Czechia also reported that they considered the changes in emissions from other countries with NECD commitments, and what impacts these are likely to have on the air quality within its territory. Further discussion of coherence of NAPCPs with air quality policy priorities is included in section 3.6.2.

No Member States have assessed the impacts of additional PaMs on the environment, using the indicators specified in the common format.

3.6 Coherence

The NECD includes the following provisions related to coherence of:

NAPCPs with other relevant plans and programmes established by virtue of the requirements set out in national or Union legislation.

30 See footnote 8

31 https://www.eea.europa.eu/publications/national-policies-and-measures-on-climate-change-mitigation

https://www.eea.europa.eu/publications/national-policies-and-measures-on-climate-change-mitigation




Selected policies and measures with plans and programmes set up in other relevant policy areas.

In this context, coherence means that NAPCPs and selected PaMs should be logical and consistent with existing plans and programmes and other policy areas. The key topics related to coherence and investigated in the review were:

Coherence in Member State reporting, specifically between NAPCPs and air emission projections reported under Article 10(2) of the NECD

Coherence of NAPCPs with air quality policy priorities

Coherence of NAPCPs with energy and climate change priorities and NECPs

3.6.1 Coherence of NAPCPs and air emission projections

For reporting of air pollutant emission projections under Article 10(2), the NECD specifies that projections need to be consistent with the inventory year x-3. When reporting on the NAPCPs in the common format, Member States were asked to report the date of emission projections and the year of the historical inventory used for their development (i.e. base year) (tables 2.5.1 and 2.8.1 of the common format). As discussed in section 3.2.1 of this report, the base year for projections presented in the NAPCPs has not been widely reported by the Member States in their NAPCPs.

In the review, consistency between projections reported in the NAPCP and submitted by Member States under Article 10(2) has been assessed for WM and WAM scenarios. This assessment comprised comparison of the reported date of projections, the base year (where available) as well as emission values.

As presented in Figure 3-26 below, for the WM scenario this assessment showed that:

8 Member States (Austria, Belgium, Cyprus, Czechia, Denmark, Germany, Latvia, Spain) based their NAPCPs on projections produced in 2019: these were the latest projection scenarios, consistent with the projections reported under Article 10(2) in 2019.

13 Member States (Bulgaria, Croatia, Estonia, Finland, France, Ireland, Lithuania, Netherlands, Poland, Portugal, Sweden, Slovenia and United Kingdom) based their NAPCPs on projections inconsistent with their 2019 submission under Article 10(2) (for these Member States the values of projected emissions in the NAPCP were found to be inconsistent with the projections reported under Article 10(2) in 2019 for at least one pollutant and year). In their NAPCPs, these Member States used either 2017 or earlier projections reported to the European Commission under Article 10(2), or an updated or interim version of projections which were not subject to official reporting requirements. Among those 13 Member States:

o For 7 Member States (Bulgaria, Croatia, Estonia, Finland, Netherlands, Sweden, United Kingdom) inconsistencies were judged as minor as they did not change the conclusions on the projected compliance with the emission reduction commitments.

o For 6 Member States (France, Ireland, Lithuania, Poland, Portugal, Slovenia), different conclusions on projected compliance with at least one emission reduction commitment can be drawn depending on the dataset used.




Figure 3-26 Consistency of WM scenarios between 2019 projections submitted under Article 10(2) and projections used in NAPCPs (number of Member States)

For the WAM scenario this assessment showed that:

Projections were found consistent for 6 Member States (Belgium, Bulgaria, Croatia, Czechia, Latvia, Spain)

For 6 Member States (Denmark, Estonia, France, Germany, Ireland and Lithuania) inconsistencies in projections were found. Of these, major inconsistencies (i.e. influencing conclusions on projected compliance) were found in 3 Member States (France, Ireland and Lithuania). The inconsistencies for the remaining Member States were found to be minor.

Consistency could not be assessed for the remaining 9 Member States (Austria, Cyprus, Finland, Netherlands, Poland, Portugal, Slovenia, Sweden, United Kingdom) as the WAM scenario was either not applicable (i.e. Member State was projected to meet all emission reduction commitments under WM scenario) or not reported with Article 10(2) projections (e.g. despite additional PaMs being considered and selected for adoption in the NAPCP).

The advantage of using the latest 2019 projections in the NAPCPs is that these projections are most likely to accurately reflect emission reductions achieved by current PaMs (under the WM scenario) and any recent methodological changes to the way the historical inventory and/or emission projections are compiled. Thus, the use of 2019 projections should in principle allow for more accurate planning and more informed consideration and selection of additional PaMs. In contrast, inconsistencies with the latest available air pollutant emission projections may affect the robustness of the NAPCPs developed on the basis of older sets of projections.

Even where Member States have used the latest projections in their NAPCPs, inconsistencies were noted in whether a WAM scenario was included in the submission. As already discussed in section 0, two Member States (Austria, Sweden) submitted final NAPCPs with PaMs selected for adoption and quantified emission reductions reflected in the WAM scenario but did not report a WAM scenario in their 2019 projections under Article 10(2). For Austria this discrepancy can be explained by the timing of preparation of emission projections and NAPCPs i.e. the NAPCP was finalised after the projection’s submission deadline of 15 March 2019. In contrast, Sweden explained that absence of the WAM scenario spans from their interpretation of the requirements that a WAM scenario is relevant if there are planned policies and measures with a realistic chance of being adopted. In Sweden this means that PaMs should be included in a government bill put forward to the parliament but not necessary adopted at the time. At the time of reporting of projections, Sweden considered the WAM scenario as not applicable. It is however unclear why the PaMs selected for adoption in the NAPCP were not reported in the WAM scenario with the projections.




3.6.2 Coherence of NAPCPs with air quality policy priorities

The emission reduction commitments set out in the NECD are intended to contribute to achieving the air quality objectives set out in Directive 2008/50/EC and Directive 2004/107/EC and air quality in line with the air quality guidelines published by the World Health Organisation32. Linked to this the NECD aims to facilitate improvements in air quality to levels that do not give rise to significant negative impacts on and risks to human health and the environment.

Article 6 of the NECD requires Member States to assess to what extent national emission sources are likely to have an impact on air quality in their territories (and neighbouring Member States) and consider compliance with air quality objectives as part of the preparation of their NAPCP. Annex III Part 1 of the NECD lists the following as a minimum content requirement for the NAPCP regarding air quality:

the progress made by current policies and measures in reducing emissions and improving air quality, and the degree of compliance with national and Union obligations;

policy options considered to meet the emission reduction commitments and to further improve the air quality, and where available the impact of the PaMs on air quality.

Consequently, the NAPCP common format required information on air quality policy priorities, progress made by current PaMs in improving air quality, projected improvement in air quality under WM and WAM scenarios and an assessment of how selected PaMs ensure coherence with air quality objectives in a Member States and, where appropriate, neighbouring Member States.

Overall Member States have clearly and accurately set out the air quality policy priorities in their NAPCPs. The information included on the key air quality challenges was mostly consistent with the technical assessment conducted by the EEA33 and covered the most important air quality pollutants for each Member State. Only in a few isolated cases has the review identified gaps in the descriptions of challenges provided in NAPCPs (e.g. due to lack of information provided by Member States in their NAPCP on known challenges related to benzo-a-pyrene and ozone concentrations).

Member States have typically referred to the EU air quality limit values, with only 7 Member States making a clear reference in their NAPCPs to WHO guidelines when describing their air quality policy priorities (Belgium, Czechia, Finland, Ireland Netherlands, Sweden and United Kingdom). Of these, Finland has clearly stated that it aims to achieve the WHO guideline values on air quality, and the United Kingdom stated their ambition to attain the WHO value for PM2.5. A further 5 Member States (Czechia, Denmark, Ireland, Latvia, Poland) have made some minor references to WHO guidelines in their NAPCPs.

The progress achieved by current PaMs in improving air quality has been demonstrated by the Member States through reporting on historical trends in ambient air quality pollutant concentrations and results of compliance assessment with EU limit values. This reporting is in line with the requirements of the NAPCP common format. In some cases, Member States have provided a reference or a weblink to the air quality plans in order to demonstrate what PaMs have been in place to date. Although there is no clear requirement in the NECD to report details of current PaMs, 6 Member States (Austria, Denmark, Estonia, Latvia, Lithuania and United Kingdom) have provided some description of the current PaMs relevant to air quality.

Overall, the review has been limited by a lack of information about the current PaMs with impacts on air quality in Member States. There was often very limited information on the key drivers behind the concentration values presented. Without information on current PaMs there is also limited scope for the Member States to learn about PaMs that other Member States have implemented and how effective they have been in improving air quality.

The PaMs considered and selected for adoption by the Member States will contribute to the overall improvement in air quality across Europe through reduction in emissions of NECD pollutants. The main benefits would come from the PaMs selected for adoption in the transport and energy consumption sector as these would apply primarily to urban areas, with higher population exposure. Generally, all Member States have claimed that impacts on air quality have been taken into account when selecting

32 https://www.who.int/airpollution/publications/aqg2005/en/

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

https://www.who.int/airpollution/publications/aqg2005/en/

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




PaMs for adoption. However, generally there has been limited evidence included in the NAPCPs to support such statements. Impacts of individual PaMs on air quality were generally not reported by the Member States.

There has also been no evidence that Member States have decided to adopt additional PaMs, beyond those required to meet the emission reduction commitments, in order to further improve air quality or meet air quality objectives. The only Member State who explicitly mentioned such considerations in the NAPCP was Finland. Whilst Finland projects to meet all emission reduction commitments, they have considered adoption of additional measures for road transport and small-scale wood burning to further improve air quality. However, these PaMs were not selected for adoption in the NAPCP.

The impacts on air quality of the PaMs selected for adoption (WAM scenario) have been assessed by 13 Member States:

7 Member States assessed the impacts quantitatively by modelling the projected impacts of PaMs on air quality (Belgium, Czechia, Estonia, France34, Germany, Poland and Spain)

6 Member States (Austria, Bulgaria, Croatia, Denmark, Lithuania, Slovenia) provided some qualitative description of the impacts. This varied in the level of detail and pollutant coverage depending on the Member State

4 Member States (Ireland, Latvia, Sweden and United Kingdom) provided no information on air quality impacts of the WAM scenario; although it should be noted that reporting of the impacts of the WAM scenario on air quality is an optional reporting requirement. The remaining 4 Member States (Cyprus, Finland, Portugal, Netherlands) did not provide a WAM scenario in their NAPCPs35.

Modelling of the impacts of PaMs considered and selected for adoption on air quality

6 Member States have modelled the impacts of PaMs selected for adoption on air quality. This box provides examples of the models used and impacts assessed.

Belgium

Impacts of the WM and WAM scenarios on air quality have been modelled using the Chimère model36 (11km x 7km resolution). The modelling assessed 2030 impacts of the WM and WAM scenarios on concentrations of NO2, PM10, PM2.5 and O3. Concentration maps were included in the NAPCP.

Czechia

Impacts of the WM and WAM scenarios on air quality have been modelled using the CAMx model37 (4.7 km x 4.7km resolution for the area of Czechia and Slovakia). The modelling assessed the impacts on PM10, PM2.5, NO2 and B(a)P compared to 2015 reference year. Concentration maps were included in the NAPCP. When analysing the air quality impacts of the two emission scenarios, the NAPCP also considers the impact of PaMs planned in a neighbouring country (Poland). Overall, it is projected that air quality concentrations will not exceed the limit values, other than in local hotspots which must be addressed by PaMs at local and regional level.

Estonia

Impacts of the WAM scenario on air quality have been modelled using the Estonian air quality management system Airviro38 (Eulerian air quality model, 1km x 1 km resolution). The modelling assessed impacts of emissions of five NECD pollutants from six different sectors (energy, industry, transport, solvents, waste and agriculture). The 2020 and 2030 air quality concentrations associated with emissions from individual sectors as well as for all sectors combined are presented.

34 Collective impact of PaMs on air quality is reported in section 2.6.2 of the common format covering impacts on air quality and the environment of individual PaMs or packages of PaMs considered, not in section 2.8.2 concerning the impacts of the WAM scenario.

35 Slovakia and Malta are not included as assessment of their NAPCPs was not completed by the time of finalisation of this report.

36 https://atmosphere.copernicus.eu/sites/default/files/2018-02/CHIMERE_Fact_Sheet.pdf

37 http://www.camx.com/

38 https://www.airviro.com/airviro/aqm/

https://atmosphere.copernicus.eu/sites/default/files/2018-02/CHIMERE_Fact_Sheet.pdf

http://www.camx.com/

https://www.airviro.com/airviro/aqm/




France

While the details of the model are not provided in the NAPCP itself, it is understood based on the supporting documentation referred to in the NAPCP that impacts of the WM and WAM scenarios on air quality have been modelled using the Chimère model39 (7km x 7km resolution across the territory of France). The modelling assessed the 2020 and 2030 impacts on PM10, PM2.5, NO2 and O3. Concentration maps were included in the NAPCP. Overall, it is projected that air quality concentrations will decrease in the territory of France, however the limit value for NO2 is projected to still be exceeded in 3 air quality zones in 2030 and the target value for O3 in 14 air quality zones.

Germany

Impacts of the WAM scenario on air quality have been modelled using the EURAD-Emission model40 (1km x 1km resolution). The modelling assessed 2030 impacts of the WAM scenario on concentrations of NO2, SO2, PM10, PM2.5 and O3. The assessment showed that concentrations for all air pollutants will decrease, with the exception for ozone. Concentration maps were included in the NAPCP.

Poland

Impacts of the WAM scenario on air quality have been modelled for 2025 and 2030 using a GEM-AQ model41 (variable resolution, for the region of Central Europe resolution is around 10km) and covered impacts on concentrations of PM10, PM2.5, SO2, NO2, NOX, and O3. For the purpose of the modelling, it has been assumed that emission reductions will be attained proportionally across all sectors. The same emission reduction factor was assumed for PM10 as for PM2.5. The modelling took into account the changes in emissions from other countries with NECD commitments. The results were presented in concentration maps and additionally in terms of population and vegetation exposure.

Spain

As in Belgium, the impact of the WAM scenario on air quality has been modelled using the CHIMERE model (10km x 10km resolution over the Iberian Peninsula). The NAPCP includes estimations of the concentrations of O3, NO2, SO2, PM10 and PM2.5 in the years 2020, 2025 and 2030 under the WM and WAM scenarios. The results were presented in concentration maps and additionally in histograms showing the percentage of the area in Spain affected by non-compliance with EU limit and target values.

3.6.3 Coherence of NAPCPs with energy and climate change priorities and national energy and climate plans (NECPs)

One of the objectives of the NECD as stated in Article 1(2) is to contribute to ‘enhanced synergies between the Union's air quality policy and other relevant Union policies, in particular climate and energy policies’. This objective is reflected in several places in the NECD:

With regard to national air pollutant emission projections, Annex IV Part 2 states that projections shall be consistent with GHG projections reported under Regulation (EU) No 525/2013.

According to Annex III Part 1 of the NECD, NAPCPs should include a description of the climate change policy framework in which context the programmes have been developed and an assessment of how selected policies and measures ensure coherence with plans and programmes set up in other relevant policy areas (i.e. including climate change and energy)

According to Regulation (EU) 2018/1999 of the European Parliament and of the Council on the Governance of the Energy Union, which entered into force on 24 December 2018, Member States are required to develop integrated National Energy and Climate Plans (NECPs) for the period 2021 to 2030. The draft NECPs were to be submitted to the European Commission by 31 December 2018, with the

39 https://atmosphere.copernicus.eu/sites/default/files/2018-02/CHIMERE_Fact_Sheet.pdf

40 https://atmosphere.copernicus.eu/sites/default/files/2018-02/EURAD_Fact_Sheet.pdf

41 Link to a general description of the model used by Poland has not been identified

https://atmosphere.copernicus.eu/sites/default/files/2018-02/CHIMERE_Fact_Sheet.pdf

https://atmosphere.copernicus.eu/sites/default/files/2018-02/EURAD_Fact_Sheet.pdf




final plans due a year later, by 31 December 2019. NAPCPs submitted on time could therefore ensure coherence with draft NECPs only, not with final ones. However, for NAPCPs submitted very late (in 2020), coherence with final NECPs should have been ensured.

The NAPCP guidance states that NAPCPs should ensure coherence with the draft NECPs and that Member States are encouraged to first take account of all PaMs planned for implementation under the draft NECPs, before proceeding to identification of additional measures in the context of the NECD. Timing for NECP and NAPCP preparation has led to difficulties in taking into account priorities and PaMs included in the draft NECP when finalising NAPCPs. In some instances, Member States have justified the delays in either finalising or submitting their NAPCPs by the need to align it with the draft or final NECP.

This review has attempted to determine the extent to which PaMs in the NAPCPs are coherent with the corresponding PaMs in the NECPs. Comparison was often not possible because the NECPs had not been available for all Member States at the time when the NAPCP was being assessed. Furthermore, the NECPs may have changed between the draft and final versions and the NAPCPs were likely using information from draft NECPs. Conclusions on the consistency between the data underpinning air pollutant emission projections and GHG emission projections submitted by the Member States with the draft NECPs have already been presented in section 3.4.7.2 of this report. For many Member States inconsistencies were found between the data used in the projections calculations and that reported with the draft NECPs.

Across all NAPCPs reviewed42, the energy and climate change policy priorities were generally well described as part of the policy framework. Member States have commonly referenced or summarised key provisions of the NECPs and other plans and strategies relevant to energy and climate change. The level of detail provided varied depending on the Member State, however the majority of the Member States included information on the key targets for reducing GHG, renewable energy and energy efficiency objectives.

Similarly, all Member States (except for France43 and Slovenia44) which considered or selected PaMs for adoption included in their NAPCPs some evidence to suggest that NECPs and relevant PaMs have been considered in development of the NAPCP and selection of PaMs for adoption. This was achieved through one or combination of the following elements:

Reflecting the impact of the climate change and energy policy on NECD pollutant emissions when calculating emissions projections (e.g. Belgium) or anticipating to do so in the next iteration of the NAPCP (e.g. Ireland).

Using a common dataset of key parameters for energy and climate modelling and NECD PaMs (e.g. Belgium, United Kingdom).

Including PaMs from NECP in the list of PaMs considered and selected for adoption (e.g. Austria, Croatia, Czechia, Denmark, Sweden).

Strengthening the PaMs included in the NECP so that they can deliver air emission reductions (e.g. in Spain where PaMs in the NECP were projected to impact negatively air pollution emissions reduction commitments under the NECD, minimum technical standards were introduced as further PaMs to ensure that the objectives of both NECP and NAPCP could be met).

Ensuring complementarity of the PaMs in NECP and NAPCP by quantifying impacts of climate and energy PaMs on air emission and of NECD PaMs on GHG emissions (e.g. United Kingdom).

However, the majority of Member States could have included in their NAPCPs a more systematic assessment of the links between the air and climate and energy policies, including synergies and trade-offs between them.

42 Review of the NAPCPs for Slovakia and Malta was not completed by the time of finalisation of this report and the results of their assessment are therefore not included in this section.

43 In the NAPCP submitted by France there is no mention of the NECP (neither in the climate and energy policy priorities nor the coherence assessment sections of the document).

44 In the NAPCP submitted by Slovenia it is not clear how the NECP has been taken into account.




4 Risk of non-compliance with emission reduction commitments

To determine the risk of non-compliance with emission reduction commitments, Member State projections submitted for the year 2019 under Article 10(2) of the NECD were assessed at Member State level by pollutant and by year of commitment, together with information provided in the NAPCP. Details of the methodology applied are reported in Section 0. The assessment considered the following:

Projected compliance with the emission reduction commitments according to projections (Article 10(2))

Quality of the projections data.

Consistency between the projections submitted under Article 10(2) of the NECD and those included in the NAPCP.

Credibility of the PaMs selected for adoption.

Margin of compliance according to projections (Article 10(2)).

Findings from the risk assessment are shown in Table 4-1. Risks of non-compliance with emission reduction commitments are also presented by pollutant according to the number of Member States assessed (Figure 4-1 and Figure 4-2). A detailed account of the risk assessment conducted for 22 Member States is provided in Appendix B.

The assessment based on 22 Member States45 shows that for 2020-2029:

16 Member States are expected to be at high-risk of non-compliance with emission reduction commitments for NH3.

A high-risk of non-compliance with the emission reduction commitments is less common for NOX, NMVOC, and PM2.5 (9, 7 and 3 Member States, respectively).

Only 1 Member State was judged as being at a high-risk of non-compliance with the emission reduction commitment for SO2.

For 2030 onwards:

16 Member States are expected to be at high-risk of non-compliance with emission reduction commitments for NH3 (same number as for previous period commitment),

The number of Member States with a high-risk of non-compliance increases for the remaining pollutants compared to the 2020-2029 emission reduction commitments. 6 Member States are expected to be at a high-risk of non-compliance with emission reduction commitments for SO2, 12 for NOX, 11 for NMVOC and 11 for PM2.5.

45 Review of the NAPCPs for Slovakia and Malta was not completed by the time of finalisation of this report and the results of their assessment are therefore not included in this section.




Table 4-1 Assessment of the risk of non-compliance with NECD emission reduction commitments

2020-2029 2030 and beyond

SO2 NOX NMVOC NH3 PM2.5 SO2 NOX NMVOC NH3 PM2.5

Austria L L M H L L H M H H

Belgium L L L M L L L L M L

Bulgaria M H H H L L H H H L

Cyprus L M M L M M L M L H

Czechia L H H H L L H H H L

Germany L L L H L L M M M M

Denmark L L L H H H L L H H

Estonia M M M H M L M L H M

Greece - - - - - - - - - -

Spain L L M M L L L H M M

Finland M M M H M M M H M M

France M M M H M M M M H H

Croatia L L M M M L L M M M

Hungary - - - - - - - - - -

Ireland L L H H L M H H H L

Italy M H H H H -H H H H H

Lithuania M H H M M M H H H H

Luxembourg - - - - - - - - - -

Latvia L H L H L L H L H M

Malta - - - - - - - - - -

Netherlands L H M H M M H M H H

Poland H H H H M H H H H H

Portugal M H H H M H H H H H

Romania - - - - - - - - - -

Sweden L L L H L L H L H L

Slovenia M H M M M H M H H H

Slovakia - - - - - - - - - -

United Kingdom M M M H H H H H H H

High risk 1 9 7 16 3 6 12 11 16 11

Medium risk 9 5 10 5 10 6 5 6 5 6

Low risk 12 8 5 1 9 10 5 5 1 5

Not assessed 6 6 6 6 6 6 6 6 6 6

Notes: L indicates low risk, M indicates medium risk, H indicates high risk, - indicates that the risk of non-compliance was not assessed due to a lack of reporting or data limitations. Greece and Romania have not reported NAPCPs and Hungary and Luxembourg had not formally published their NAPCPs on CDR in time to be included in the




analysis of this report. For Italy and Latvia the results of the assessment are based on draft NAPCPs as final ones were not submitted in time for analysis in this report. For Malta and Slovakia, due to late submission of the NAPCP, the assessments were still ongoing at the time of finalisation of this report and are thus not presented here.

Figure 4-1 Risk assessment for 2020-2029 emission reduction commitments

Figure 4-2 Risk assessment for 2030 onwards emission reduction commitments

The main reasons why Member States have been assessed as being at a high-risk of non-compliance with the emission reduction commitments are:

The Member State projecting non-compliance with an emission reduction commitment under the WM scenario submitted under Article 10(2) projections, but not submitting a WAM scenario.

The Member State projecting non-compliance with an emission reduction commitment under the WM scenario as well as under the WAM scenario (despite selecting additional PaMs for adoption in the NAPCP).

The review of the quality of Member States projections found that projection methodologies require major improvements. Thus, the compliance with the emission reduction commitments projected on the basis of these projections is judged not to be reliable.




Low projected margin of compliance, below the thresholds set in the risk assessment methodology.

The outcomes of the assessment of credibility of the PaMs selected for adoption did not have a major impact on the results of the risk-assessment. This is because this was the second to last step of the risk assessment methodology, applicable only where a Member State projected not to meet an emission reduction commitment for a certain pollutant in the WM scenario (see section 2.5.2). In the majority of such cases the outcomes of the risk assessment have been concluded before reaching this step.




5 Conclusions and recommendations The main conclusions from the review are presented in the sections below. This covers conclusions on reporting, quality of Member State projections, NAPCPs and policies and measures selected for adoption, progress towards compliance and risk of non-compliance with emission reduction commitments. Key recommendations are then included in boxes at the end of each sub-section.

5.1 Reporting

Only 7 Member States submitted both their projections and NAPCPs in line with the deadlines set in the NECD. There were more delays for reporting of NAPCPs compared to reporting on projections.

All Member States met the mandatory content requirements when reporting emission projections in the Annex IV template (in terms of pollutants and years), although not all included reference year data. However, for many Member States the information on methodologies for preparation of air pollutant emission projections was very limited. Where available, it was often spread across multiple documents e.g. IIR, NAPCPs, separate methodology reports or other documents. The lack of complete reporting required the review team to pose numerous questions to the Member States. Two cases were identified (Sweden, United Kingdom) where the WAM scenario was not submitted with the projections, even though additional PaMs were selected for adoption in the NAPCP.

The depth of the projections review was also limited by the lack of detail provided in methodological descriptions. The Annex IV reporting template for emission projections requires projections reporting of aggregated source sectors. But understanding how the estimates are made is only possible if the methodological descriptions are detailed enough to include information on each of the sources contained within the aggregated source sectors that are reported. This issue is particularly evident for the highly aggregated sectors such as industrial processes and product use and waste. The depth of the review is also limited because there is no specific requirement to provide information on projections from combustion sources resolved by fuel type. Requiring this information to be reported in a systematic way, rather than relying on information in the supporting methodological descriptions, would support the review process and provide elements for improvements of future Member States’ submission. A common issue identified in the review was the misinterpretation of the reporting requirements for NOX and NMVOC emission projections from the agriculture sector (NFR code 3B and 3D). While these emissions do not count towards the national total for the purpose of checking compliance with national emission reduction commitments, the emissions must still be included in the projections reporting.

Out of the 24 NAPCPs analysed in this report, 22 Member States have either reported their NAPCPs in the common format or followed the heading structure it sets out. The majority of NAPCPs reviewed contained sufficient information to meet the mandatory reporting requirements set out in the NECD, with gaps more commonly identified where Member States did not use the common format and/or did not report via the EEA-PaM tool. Potential improvements to the NAPCP common format were identified during the review and are listed alongside other recommendations below.

The level of detail provided by the Member States on PaMs considered and selected for adoption varied considerably across the Member States. Generally, information about the PaMs reported via the EEA-PaM tool was limited; however additional information was sometimes included in the NAPCP or accompanying reports provided. Limited information on the assumed uptake of PaMs, specific actions they involve, and emission reduction expected often prevented the review team from making a confident judgement on whether the PaMs proposed in NAPCPs are credible, and associated emission reductions are realistic. In some cases, the review has identified that Member States have wrongly included an existing PaM (and / or including PaMs implementing EU legislation) as part of the WAM scenario in their NAPCP.




It is recommended that Member States:

As a priority, improve the documentation supporting the submission of emission projections data by following the appropriate CLRTAP guidance, specifically the 2018 version of Annex II to the 2014 CLRTAP Emissions Inventory Reporting Guidelines46. This provides the recommended structure and content of the projections chapter to be included in the IIR. As a minimum, information provided in the NAPCP and/or external projections methodology reports should be referenced in the IIR.

Report a WAM scenario with their projections, if additional PaMs have been selected for adoption in their NAPCPs. Consistency between the WAM scenario included in projections and NAPCPs should be ensured.

Ensure that implementation of all PaMs already adopted and being implemented (including those based on EU legislation) are included in the WM scenario. Where the PaM goes beyond EU legislation and/or expands either the scope or level of ambition of the existing PaM, it can be included in the WAM scenario.

Use the NAPCP common format and EEA-PaM tool when reporting their NAPCPs in the future. This will ensure that their reporting is complete and compliant with the minimum content requirements set out in the NECD.

Report more optional content, both within their NAPCP and projections, to improve the overall knowledge base and facilitate knowledge exchange between Member States (e.g. on costs of PaMs, sensitivity of emission projections, emissions of black carbon).

Provide more detailed descriptions of the PaMs and report further assumptions behind the estimated emission reductions (e.g. uptake, emission reduction efficiencies) via the EEA-PaM tool.

Where possible, provide descriptions of the current PaMs in the NAPCPs to facilitate knowledge exchange and to build a more comprehensive picture of the efforts by the Member States to reduce emissions of NECD pollutants.

It is recommended that the Commission, via CLRTAP, explores revising the Annex IV reporting template for projections included in the CLRTAP Emissions Inventory Reporting Guidelines to include more detailed reporting for the industrial processes and product use and waste sectors. Such disaggregation is already applied in reporting of historical emission inventories. It is also recommended that consideration is given to a long-term aim of reporting combustion source projections by fuel type.

It is recommended that the Commission considers the following changes to the NAPCP common format:

Replicate table 2.8.2 concerning non-linear emission reduction trajectory in section 2.5 of the common format, to ensure that Member States which do not report additional PaMs consider whether their emissions will follow a linear trajectory in the absence of additional PaMs.

In tables 2.5.1 and 2.8.1 on WM and WAM projections, include an additional row for Member States to report the year of the historical inventory on which the 2005 emissions and projections are based.

Make table 2.6.4 on details concerning the measures from Annex III Part 2 a standalone section of the common format. Break the first question into the following two separate questions: Has the PaM already been adopted? Is the PaM selected for adoption in the NAPCP? The third column in the table referring to section / page number can be deleted.

5.2 Quality of Member State projections

Many quality issues raised in the review were associated with misallocation of emissions sources in the projections, and exclusion from the projections of some small emission sources present in the historical

46 https://www.ceip.at/ms/ceip_home1/ceip_home/reporting_instructions/annexes_to_guidelines/





inventory. These typically had relatively small impacts on projected national total emissions of NECD pollutants. However, for a limited number of Member States, inconsistencies were identified between the emissions reported in the reference year in projection submissions and the values included for that year in the historical inventory. These inconsistencies may have a more significant impact on national totals.

Results of checks related to accuracy vary significantly across the Member States. Projections for SO2 are generally of better accuracy than for the other pollutants. Many of the accuracy issues raised are associated with the use of Tier 1 methodologies, or overly simple methods for estimating future emissions from key categories. Even with the information made available to the review team during the review, it was often difficult to determine the extent to which the use of simple methodologies affects the accuracy of projections.

Inconsistencies were noted between the activity data used in Member State air pollutant emission projections and that used to derive GHG projections reported with the draft National Energy and Climate Plans. In some cases, the review found significant differences in the data for basic parameters such as population or GDP in the two sets of projections. Aligning the data sources used for NECD and GHG emissions could have significant impacts on total national emissions.

Detailed recommendations and encouragements on the quality issues identified in the review were made in individual Member State projections review reports. Overall, it is recommended that Member States:

Implement improvements suggested in the individual Member States projections review reports before their next reporting of projections to the European Commission.

Follow Tier 2 or better methodologies for estimating emission projections for key emission sources.

Where not already done, use consistent activity data for the calculation of air pollutant emission and GHG emission projections

5.3 NAPCPs and policies and measures selected for adoption

Not all Member States used the latest set of projections and emissions from the latest historical emission inventory to inform the development of their NAPCPs. Where differences between the latest projections and those used in NAPCPs are large this can lead to different conclusions on compliance with emission reduction commitments.

Generally, Member States have clearly set out in their NAPCPs the policy priorities for air pollutant emission reductions and air quality, and outlined the progress made in reducing emissions and improving air quality to date. However, there has been no evidence to suggest that NAPCPs have been used by the Member States as a tool to introduce further PaMs than those solely required to meet emission reduction commitments (e.g. in order to contribute to further improvements in air quality).

Overall, where Member States have selected PaMs for adoption, they have prioritised consideration and adoption of PaMs for the sectors contributing the largest share of emissions (i.e. energy supply, energy consumption, transport and agriculture). Generally, across the sectors and based on the information reported, the PaMs selected for adoption appear to be technically feasible and relevant, with regulatory and economic policy instruments proposed most frequently. However, the review has frequently flagged that descriptions of the PaMs were minimal, with little or no information reported on the exact design of the PaMs, assumptions made and how the emission reductions were estimated. This limited the credibility of the PaMs presented in the NAPCPs. As a result, the review has often concluded that it is uncertain whether PaMs can be successfully implemented to deliver the projected emission reductions in the required timescales. Due to the lack of reporting on current PaMs, it was impossible for the review team to provide recommendations on potential further PaMs which Member States could consider to further reduce their emissions. As a general trend, the PaMs selected for adoption have been projected to reduce emissions to the levels just sufficient to meet the emission reduction commitments, leaving little margin for delays or difficulties in implementation of PaMs.




Almost all Member States who considered or selected PaMs for adoption included in their NAPCPs some evidence to suggest that energy and climate policy priorities, NECPs and relevant PaMs have been considered in the development of the NAPCP and selection of PaMs for adoption.

Despite the projected impact of additional PaMs selected for adoption, some NAPCPs continue to project non-compliance with emission reduction commitments.

Detailed recommendations and encouragements were made in individual Member State NAPCP review reports. Overall, it is recommended that Member States:

Use the latest available set of emission projections when considering PaMs for adoption in their NAPCPs. If the projections were updated during the preparation of the NAPCP and it is not possible to include the latest dataset, the NAPCP should acknowledge the differences between the projection scenarios and discuss how these may impact conclusions on compliance with emission reduction commitments.

Consider NAPCP as a tool to adopt PaMs which go beyond the emission reduction

commitments and contribute to air quality more generally.

Take a full account of the emission reductions that will be achieved by the PaMs included in the NECPs first, before considering further PaMs for adoption.

Take account of uncertainties when estimating emission reductions from the PaMs and report these in ranges reflecting the potential impacts.

Where the PaMs selected for adoption will contribute to meeting an emission reduction commitment by only a small margin, consider implementation of further PaMs to minimise the impact of potential uncertainties related to the quantification of emission reductions and PaM implementation. Closely monitor the implementation of newly adopted PaMs to ensure that projected emission reductions will be fulfilled.

Exchange experience and lessons learnt with other Member States on implementation of current PaMs as well as those selected for adoption in the NAPCPs (e.g. on a peer-to-peer basis).

It is recommended that the Commission:

Considers development of guidance for the Member States on how to calculate emission reductions of NECD pollutants from PaMs, building on the relevant content included in the existing guidelines for the preparation of NAPCPs and in line with the existing chapter on projections in the EMEP/EEA Guidebook. Such guidelines could include a dedicated section on reporting on PaMs to ensure that sufficient detail is provided for future reviews.

Facilitates further dialogue and knowledge exchange across the Member States on experience in planning and implementing PaMs for reducing emissions of NECD pollutants.

5.4 Progress towards emission reduction commitments and associated risk of non-compliance

19 Member States provided projections (WAM scenario, or WM where no WAM was reported) under Article 10(2) of the NECD that demonstrated non-compliance with emission reduction commitments for at least one pollutant. In such instances the NECD requires that ‘the emission reduction policies and measures contained in the national air pollution control programmes shall be updated within 18 months of the submission of the latest national emission inventory or national emission projections’. In the projections submitted under Article 10(2), non-compliance is most frequently projected for NH3 emission reduction commitments (both for 2020-2029 and 2030 onwards), followed by NMVOC, NOX and PM2.5.

Bar a few specific cases, meeting the SO2 emission reduction commitments is not considered a major issue across the EU.

Considering the quality of Article 10(2) projections and their consistency with the projections presented in the NAPCP, credibility of the PaMs selected for adoption and projected margin of compliance with emission reduction commitments, the review concluded that more than half of the Member States covered in this horizontal review report are expected to be at high-risk of non-compliance with 2020-29




and 2030 onwards emission reduction commitments for NH3. Around half of the Member States are also considered at high-risk of non-compliance with 2030 onwards emission reduction commitments for NOX, PM2.5 and NMVOCs.

Where a Member States projects non-compliance with one or more emission reduction commitments, it has to resubmit an updated NAPCP in no later than 18 months according to Article 6(4) of the NECD: The updated reporting should demonstrate how the Member State plans to meet the emission reduction commitments, and consider recommendations from this review with regard to reporting, as well as to the quality of projections and NAPCPs.

Where a review has concluded that a Member State is at a high risk of non-compliance with one or more emission reduction commitments, it is recommended that the Member State:

Review the evidence presented in Appendix B to this report to understand the underlying causes for a high-risk score.

Consider whether, given all information available to a Member State (which may not have been available to the reviewers), and any uncertainties in projected emissions, there is indeed a high risk of non-compliance with emission reduction commitments:

o If yes, the Member State should put in place measures to ensure that such risk is reduced. This may involve, among others, selecting further PaMs for adoption, re-designing PaMs already selected for adoption, putting in place measures supporting implementation of the PaMs, selecting indicators to monitor progress with implementation. It is recommended that these additional measures are documented in an updated NAPCP, subsequently reported to the Commission within 18 months according to Article 6(4) of the NECD.

o If no, the Member State should address the reasons why the review might have concluded on a high-risk in the next reporting round for air pollutant emission projections and NAPCPs. This would involve addressing any shortcomings identified e.g. on transparency of methodology for projections, clarity of assumptions behind the PaMs.




Appendix A Overall quality of air pollutant emission projections (scores used in the risk assessment)

Table A1 shows the projections quality ratings used in the assessment of risk of non-compliance with the emission reduction commitments. The way in which these results have been determined is presented in section 2.2.2. The results specifically represent the quality in the context of the likelihood and extent to which the projections might be recalculated in future submissions. “Major” improvements represent high likelihood and/or extent to which recalculations might be made in future submissions.




Table A1 Quality of projections for use in the assessment of the risk of non-compliance with emission reduction commitments

2020 Projections 2030 Projections Member State SO2 NOX NMVOC NH3 PM2.5 SO2 NOX NMVOC NH3 PM2.5

Austria Good Good Minor Good Good Good Good Minor Good Good

Belgium Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor

Bulgaria Minor Major Major Major Minor Minor Major Major Major Minor

Croatia Minor Minor Major Major Major Minor Minor Major Major Major

Cyprus Good Minor Minor Good Major Good Minor Minor Good Major

Czechia Minor Major Major Major Major Minor Major Major Major Major

Denmark Good Good Good Good Good Good Good Good Good Good

Estonia Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor

Finland Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor

France Good Minor Minor Good Minor Good Minor Minor Good Minor

Germany Good Good Good Minor Good Good Good Good Minor Good

Greece Major Major Major Minor Major Major Major Major Minor Major

Hungary Minor Minor Minor Major Major Minor Minor Minor Major Major

Ireland Good Good Good Minor Good Good Good Good Minor Good

Italy Major Major Major Major Major Major Major Major Major Major

Latvia Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor

Lithuania Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor

Luxembourg Major Major Major Major Major Major Major Major Major Major

Malta Major Major Major Major Major Major Major Major Major Major

Netherlands Minor Major Minor Major Major Minor Major Minor Major Major

Poland Major Major Major Major Minor Major Major Major Major Minor

Portugal Major Major Major Major Major Major Major Major Major Major

Romania Minor Major Major Major Major Minor Major Major Major Major

Slovakia Good Good Good Good Minor Good Good Good Good Minor

Slovenia Major Minor Minor Minor Minor Major Minor Minor Minor Minor

Spain Good Minor Minor Minor Good Good Minor Minor Minor Good

Sweden Minor Minor Minor Minor Minor Minor Minor Minor Minor Minor

United Kingdom Minor Minor Minor Good Good Minor Minor Minor Good Good

Notes: Good = No need for improvements have been identified; Minor = Minor improvements needed; Major = Major improvements needed.




Appendix B Risk of non-compliance: Member State level assessment Provided as a separate file

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