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Review of the National Air Pollution Control Programme Austria ___________________________________________________ Final Report for European Commission DG Environment Specific contract 070201/2018/791186/SER/ENV.C.3 ED 11495 | Issue Number 4 | Date 06/03/2020

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Review of the National Air Pollution Control Programme – Austria

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

ED 11495 | Issue Number 4 | Date 06/03/2020

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

Ricardo Confidential Ref: Ricardo/ED11495/Issue Number 4

Ricardo Energy & Environment

Customer: Contact:

European Commission - DG Environment Natalia Anderson Ricardo Energy & Environment Gemini Building, Harwell, Didcot, OX11 0QR, United Kingdom

t: +44 (0) 1235 75 3055

e: [email protected]

Ricardo is certificated to ISO9001, ISO14001 and OHSAS18001

Customer reference:

070201/2018/791186/SER/ENV.C.3

Confidentiality, copyright & reproduction:

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 070201/2018/791186/SER/ENV.C.3 dated 29/11/2018 for the European Commission, however it reflects the views only of the authors, and the 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:

Hetty Menadue

Approved By:

Ben Grebot

Date:

06 March 2020

Ricardo Energy & Environment reference:

Ref: ED11495 - Issue Number 4

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Table of contents

1 Introduction ................................................................................................................ 4

Review of the National Air Pollution Control Programmes ................................................ 4

Methodology ...................................................................................................................... 5

NAPCP submission documents ........................................................................................ 6

2 Projected compliance with NECD emission reduction commitments .................... 9

Margin of compliance ........................................................................................................ 9

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

3 Findings of the in-depth NAPCP review ................................................................. 14

NAPCP overview (M) ...................................................................................................... 14

Executive summary (O) ................................................................................................... 14

The national air quality and pollution policy framework (M, O) ....................................... 14

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

national and EU obligations, compared to 2005 (M, O) .............................................................. 16

Projected situation assuming no change in currently adopted PaMs (M, O) .................. 18

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

2030, intermediate emission levels for 2025 and stakeholder consultation (M, O) .................... 19

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

implementation and review and responsible competent authority (M, O) .................................. 22

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

environment and associated uncertainties (where applicable) (M, O) ....................................... 24

4 Conclusions and recommendations ....................................................................... 27

Conclusions ..................................................................................................................... 27

Recommendations .......................................................................................................... 28

Appendices

Appendix 1 Completeness assessment

Appendix 2 Assessment of the risk of non-compliance

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Abbreviations BaP Benzo(a)pyrene

BAT Best Available Technique

BC Black Carbon

CH4 Methane

CO2 Carbon dioxide

EEA European Environment Agency

Eionet The European Environment Information and Observation Network

ETS Emissions trading system

EU European Union

GHG Greenhouse Gas

kt Kilo tonne

NAPCP National Air Pollution Control Programme

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

NECP National Energy and Climate Plans

NFR Nomenclature for Reporting

NH3 Ammonia

NMVOC Non-Methane Volatile Organic Compounds

NO2 Nitrogen dioxide

NOX Nitrogen oxides

O3 Ozone

PaMs Policies and Measures

PM10 Particulate matter 10 micrometres or less in diameter

PM2.5 Particulate matter 2.5 micrometres or less in diameter

RAG Red; Amber; Green [rating]

SCR Selective catalytic reduction [technologies]

SNCR Selective non-catalytic reduction [technologies]

SO2 Sulphur dioxide

WAM With Additional Measures

WHO World Health Organisation

WM With Measures

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1 Introduction

Review of the National Air Pollution Control Programmes

1.1.1 This report

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

(NAPCP) submitted to the European Commission by Austria on 31 July 20191.

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

and common format (Commission Implementing Decision (EU) 2018/1522)2 stipulated by Article 6 of

the Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants3,

hereafter referred to as the Directive or the NECD4. The NAPCP should demonstrate compliance with

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

achieved.

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

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

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

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

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

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

the NECD required under Article 11 of the NECD.

This report feeds into the horizontal review report under the contract which presents conclusions and

recommendations from the review at the EU-level. The horizontal report also contains, for each Member

State, an assessment of its risk of non-compliance with its emission reduction commitments, based on

a cross-analysis of the information provided in the NAPCPs and projection submissions under Article

10(2) of the NECD. This risk assessment is also presented in Appendix 2 to the present report, while

details on the methodology for that complete assessment are found in the horizontal report.

1.1.2 Objectives of the NAPCP review

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

the NECD. The scope of the NAPCP review includes:

The use of the NAPCP common format.

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

(M)).

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

added value this brings to the quality of the NAPCP.

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

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

1 A draft was submitted to the European Commission on 1 May 2019. Austria reports that the delay was necessary to use 2019 projections data for

the development of the NAPCP and to conduct a six-week consultation.

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

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

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

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

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

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

new NECD or simply the NECD.

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

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

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

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

commitments.

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

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

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

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

and coherence with climate and energy policy priorities).

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

predominantly the National Energy and Climate Plans (NECP).

Methodology

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

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

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

Figure 1-1 Overview of the NAPCP review methodology

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

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

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

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

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

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

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

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

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

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NAPCP completeness is rated according to a red-amber-green (RAG) rating (described in Appendix 1)

while the in-depth checks involve a series of questions with pre-defined responses to be chosen from,

designed to systematically determine the robustness and reliability of the evidence submitted.

NAPCP submission documents

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

gathered as part of the NAPCP initial screening.

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

Initial screening check Response Additional comment

Was the NAPCP submitted by 1 April

2019? No

The NAPCP was submitted after the

reporting deadline on 31 July 20195.

Was the common format used? Partially

The common format is used to reference an

accompanying report which contains the

relevant detail. The section numbering in the

NAPCP is not consistently aligned with the

numbering in the common format.

Information on additional PaMs was not

reported via the EEA-PaM tool. The

information was reported in a separate Excel

workbook using the layout of the common

format.

What is the length of the NAPCP? 10 pages

What language is the NAPCP

reported in? German

What language is the supporting

documentation reported in? German

How many external documents are

referenced or provided in the

NAPCP?

Two

An accompanying report (110 pages) and an

Excel workbook are provided containing the

detail of the NAPCP and information for the

additional PaMs considered and selected for

adoption.

Is it possible to identify the required

information in the external

documents (i.e. is the page and

chapter reference provided)?

Yes

Chapter references are provided in the

NAPCP, signposting to the relevant sections

of the accompanying report.

Can all external documents be

accessed? Yes

The report was included in the Austrian

submission and uploaded to the European

Environment Information and Observation

Network (Eionet)6.

5 A draft was submitted to the European Commission on 1 May 2019. Austria reports that the delay was necessary to use 2019 projections data for

the development of the NAPCP and to conduct a six-week consultation.

6 Eionet: Reporting obligation for National air pollution control programmes. URL: https://rod.eionet.europa.eu/obligations/753 [last accessed 20

December 2019].

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Completeness assessment

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

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

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

States. The results are presented in Appendix 1 to this review. To summarise, the NAPCP for Austria

includes the minimum content required for:

Policy priorities for emission reductions and other relevant policy priorities (2.3.1 of the NAPCP

signposts to section 2.1 of the accompanying report) and the responsible authorities involved (2.3.2

of the NAPCP signposts to section 2.2 of the accompanying report). Policy priorities for climate,

energy, industry and agriculture are set out in more detail as part of the coherence assessment

undertaken for the consideration of additional PaMs (section 6 of the accompanying report).

Progress made by current PaMs in reducing emissions (section 2.4.1 of the NAPCP signposts to

sections 4.1 and 4.2 of the accompanying report).

Progress made by current PaMs in improving air quality (section 2.4.2 of the NAPCP signposts to

section 4.3 of the accompanying report)

Current transboundary impacts (section 2.4.3 of the NAPCP signposts to section 4.3 of the

accompanying report but the detail is in Annex A8 of the accompanying report).

Projected emissions and emission reductions with existing measures (section 2.5.1 of the NAPCP

and section 5.1.6 of the accompanying report).

Details concerning the PaMs considered in order to comply with the emission reduction

commitments. Austria does not report information on additional PaMs via the EEA PaM-tool.

Information is reported using the common format (table 2.6.1). Descriptions are provided in the

accompanying report (section 6).

Additional details concerning the mandatory measures from Annex III Part 2 to Directive (EU)

2016/2284 targeting the agricultural sector to comply with the emission reduction commitments

(table 2.6.4 in an accompanying Excel workbook).

Individual PaMs or package of PaMs selected for adoption and the competent authorities

responsible (section 6 of the accompanying report).

For the projected impact on improving air quality under the WM scenario, the projected impact is

described qualitatively but the description does not cover the projected degree of compliance with EU

air quality objectives (section 2.5.2.1 of the NAPCP signposts to section 5.2 of the accompanying

report).

Emission projections under the WAM scenario in the NAPCP are only provided for pollutants where the

projected emission reductions are insufficient under the WM scenario (i.e. for 2030 onwards for NOX,

NH3 and PM2.5) (section 1.2.1 of 2.8 in the NAPCP; and section 7.1 of the accompanying report). Thus,

where projections have not been reported, it is because the emission reduction commitments may be

met with existing measures and therefore no change is expected compared to the emission projections

under the WM scenario. The extent to which the emission reduction commitments may be met with

existing measures is described in Section 2.2.

The date of the NAPCP projections and the inventory year for the data underpinning the projections are

also not reported. Projections are not provided for 2020 for any of the pollutants. For NOX and PM2.5,

emissions are reported for the 2005 base year, 2025 and 2030. For NH3, emissions are reported for

2030 only, showing that the projected emissions are not expected to meet the corresponding

commitment.

The NAPCP emission projections under the WAM scenario indicate that the projected emission

reductions are expected to follow a linear trajectory for all pollutants except NH3. A technical description

is provided to explain why this is the case.

The following optional content is provided:

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Competent authorities responsible for source sectors (section 2.2 of the accompanying report).

Graphics to portray current progress achieved (sections 4.1 and 4.2 of the accompanying report)

and projected impact on air quality improvements (section 4.3 of the accompanying report).

Progress in relation to a specific air quality zone concerning NO2 exceedances (section 4.3 of the

accompanying report).

Information on the data and methodologies used to describe transboundary impacts (Annex A8 of

the accompanying report).

An account of the uncertainties associated with the WM projections (section 5.1.7 of the

accompanying report).

Additional details concerning the optional measures from Annex III Part 2 to Directive (EU)

2016/2284 targeting the agricultural sector to comply with the emission reduction commitments

(table 2.6.4 in an accompanying Excel workbook).

Explanation of the choice of selected measures and an assessment of how selected PaMs ensure

coherence with plans and programmes set up in other relevant policy areas (section 1.1.2 of the

NAPCP).

The expected air quality improvement under the WAM scenario (in qualitative terms) (7.2 of the

accompanying report).

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2 Projected compliance with NECD emission

reduction commitments

Margin of compliance

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

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

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

to calculate the margin of compliance:

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

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

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

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

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

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

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

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

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

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

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

Figure 2-1 The margin of compliance

Example

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

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

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

is illustrated in the figure below.

200

250

300

350

400

450

500

550

2005 2010 2015 2020

Emission reduction commitment

(% of 2005 emission)

Compliance margin

Compliance threshold

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

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

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

emissions inventories.

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

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

“compliance threshold” i.e. the maximum emission that can be emitted by a Member State from 2020

and 2030 onwards, and still be compliant with the emission reduction commitment for a pollutant.

Projected emissions (under the WM and WAM scenarios) can be compared to the compliance

threshold, and the compliance margin expressed as a percentage of the compliance threshold.

Example

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

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

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

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

threshold.

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

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

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

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

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

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

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

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

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

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

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

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

accompanying horizontal review report.

Projected compliance and consistency with projections

submitted under Article 10(2)

Under the WM scenario, the NH3 emission reduction commitment for 2020-29 and for 2030

onwards is projected to be missed. The NOX and PM2.5 2030 commitments are also projected to

be missed.

Under the WAM scenario, projections are only reported for NOX, NH3 and PM2.5 for 2030

onwards. The 2030 onwards commitment for NH3 is projected to be missed but the respective

2030 commitments for NOX and PM2.5 are projected to be achieved.

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

in their NAPCP. Austria included 2019 projections in the NAPCP and does not report the year of the

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inventory data used to underpin the projections7. The projections data in the NAPCP is different to the

projections data submitted separately by the Member State under Article 10(2) of the Directive on 15

March 2019. The differences concerning the projected emission reductions under the WM scenario are

small (between 0.02 and 0.04 kt for the various pollutants and commitments). Overall, the differences

do not affect the expected extent to which Austria may meet its national emission reduction

commitments. The projections data submitted separately by the Member State under Article 10(2) of

the Directive does not include projections under a WAM scenario.

In Figure 2-2 and Figure 2-3, the emission reductions needed for 2025 are interpolated according to the

2020-29 and 2030 onwards commitments set out in the NECD. Additional information is included to

demonstrate the extent to which the projections meet the Member State commitments (shown, for each

of the pollutants, as the difference expressed in percentage points between the projected emission

reduction described in the NAPCP and the legal commitment). The percentage points do not represent

the extent to which total emissions projected (kt) compare to the emission reduction commitment (in

terms of kt of emissions).

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

follows:

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

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

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

21 percentage points.

NOX – The projections of NOX emissions under the WM scenario show that Austria can comply with

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

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

12 percentage points.

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

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

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

margin of 8 percentage points.

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

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

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

12 percentage points.

PM2.5 – The projections of PM2.5 emissions under the WM scenario show that Austria can comply

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

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

13 percentage points.

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

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

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

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

7 percentage points.

NOX – The projections of NOX emissions under the WM scenario show that Austria cannot comply

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

7 Member States are required to report the year (x-2 or x-3) for the inventory data used to underpin the emission projections (tables 2.5.1 and 2.8.1

of the common format).

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2030, compliance with the emissions reduction commitments is projected to be missed with a

margin of 1 percentage point.

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

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

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

achieved with a margin of 1 percentage point.

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

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

2030, compliance with the emissions reduction commitments is projected to be missed with a

margin of 26 percentage points.

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

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

2030, compliance with the emissions reduction commitments is projected to be missed with a

margin of 1 percentage point.

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

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

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

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

As the projections under the WM scenario demonstrate a gap in compliance with the NECD national

emission reduction commitments for certain pollutants, the NAPCP includes projections under a ‘With

Additional Measures’ (WAM) scenario. However, projections are only reported for NOX, NH3 and PM2.5,

as the three pollutants which are not projected to meet the respective commitments under the WM

scenario. Interpolated data is reported for the year 2025 for NOX and PM2.5 but not for NH3.

For all three pollutants, projections are not provided for the year 2020 to show progress towards the

2020-29 emission reduction commitments. It is understood that the 2020 emission reductions under the

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WM scenario will apply under the WAM scenario. However, only the data reported for the WAM scenario

is depicted in Figure 2-3.

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

NOX – The projections of NOX emissions under the WAM scenario show that Austria can comply

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

2030, compliance with the emissions reduction commitments is projected to be achieved with a

margin of 1 percentage point.

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

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

2030, compliance with the emissions reduction commitments is projected to be missed with a

margin of 9 percentage points.

PM2.5 – The projections of PM2.5 emissions under the WAM scenario show that Austria can comply

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

However, in 2030, compliance with the emissions reduction commitments is projected to be

achieved with a margin of 3 percentage points.

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

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

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

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

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

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

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3 Findings of the in-depth NAPCP review

NAPCP overview (M)

The NAPCP was submitted after the reporting deadline of 1 April 2019 (on 31 July 2019).

Austria uses the common format to reference the relevant section headings in an accompanying

report which contains the relevant detail.

The EEA-PaM tool is not used to report information on the additional PaMs considered and

adopted.

The NAPCP partially adheres to the common format specified by the Commission Implementing

Decision (EU) 2018/1522, pursuant to Article 6 of the NECD. While the NAPCP is reported using the

common format, information for the PaMs considered and selected for adoption was not reported to the

EEA-PaM tool. The information is partially reported in a separate Excel workbook in accordance with

the layout of the common format.

The NAPCP (10 pages) contains limited information. It references section headings in an accompanying

report (110 pages) containing the relevant detail and an Excel workbook (containing four tables with

information on the additional PaMs considered and selected for adoption). The complete submission

was made on 31 July 2019, after the reporting deadline of 1 April 2019. Of the two weblinks provided

in the NAPCP, both are in working order and are publicly available. The weblinks direct to an online

version of the NAPCP and information on the consultation activities undertaken for the development of

the NAPCP.

The title and date of the NAPCP for Austria are provided together with the authority responsible for its

development (the Federal Ministry of Sustainability and Tourism).

Austria reports that the current transboundary impact of its air pollutant emissions is low (section 2.4.3

of the NAPCP and section 4.4 of the accompanying report). There is no information on transboundary

consultation.

Executive summary (O)

Austria does not provide an executive summary.

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

Air quality policy priorities include precursors of O3, heavy metals, polycyclic aromatic

hydrocarbons (PAHs), NO2 and PM.

Climate change and energy policy priorities concern energy efficiency, reduction of thermal

demand of buildings, renewable energy sources and clean mobility. Relevant policy priorities for

industry and transport concern source emission controls and compliance with EU emission limit

values and standards.

Policy making and enforcement for air pollution is a federal government matter with involvement

at Länder level for targeted areas.

The NAPCP refers to the air quality policy priorities set out in section 2.1 of the accompanying report

which are described for precursors of O3, heavy metals, polycyclic aromatic hydrocarbons (PAHs), NO2

and PM. Air quality policy priorities do not relate to the World Health Organisation (WHO) guidelines.

The air quality policy priorities reported in the NAPCP generally target air quality pollutants where

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exceedances of EU limit values have occurred (according to the EEA factsheet for Austria)8. However,

the air quality priorities in the accompanying report do not cover BaP despite exceedances of the BaP

EU limit value in 2016 (particularly in Karnten Province) with 14.2% of the urban population exposed to

concentrations above the EU standards (as reported in the EEA fact sheet for Austria)8.

The NAPCP refers to other relevant policy priorities set out in section 2.1 of the accompanying report.

The corresponding section refers to energy efficiency, reduction of thermal demand of buildings,

renewable energy sources and clean mobility as the relevant policy priorities concerning climate change

and energy. A more detailed description of relevant climate and energy policy priorities is provided in

section 6 of the accompanying report as part of the coherence assessment undertaken for the additional

PaMs considered.

In section 6.1, climate change policy priorities include the EU ETS GHG emission reduction target and

a national non-ETS GHG emission reduction target. An overview of the national energy and climate

plan (NECP) and current progress towards finalising it shows that draft PaMs have been defined and

that a public consultation was underway at the time of the NAPCP submission..

For renewable energy, the priority is to achieve a 50% increase in renewable energy by 2030. It is

envisaged that this reduction could be achieved through 100% of domestic electricity consumption

coming from renewable sources by 2030 as well as replacing imported fossil fuels with renewable

energy sources in transport, buildings and manufacturing sectors (section 6.1.3 of the accompanying

report).

Energy efficiency policy priorities are determined by a federal climate and energy strategy which aims

to achieve 100% decarbonisation by 2050. The strategy aims to meet the 2030 Sustainable

Development Goals for energy efficiency, focussing on energy efficiency in building heating (section

6.1.3 of the accompanying report).

Other relevant policy priorities described are:

Transport policy priorities concern source emission controls and are also described in the context

of climate and energy policies (section 2.1 of the accompanying report).

For industry, relevant policy priorities concern source control by industrial activity and compliance

with emission limit values (section 2.1 of the accompanying report).

Policy priorities for agriculture are set out as part of the coherence assessment undertaken for the

consideration of additional PaMs and involves the reduction of NH3 emissions (in the context of the

Common Agricultural Policy) (section 6.3.1 of the accompanying report).

Policy making and enforcement for air pollution is a federal matter except for matters relating to

agriculture, heating (for buildings) and regional planning (provided that the regional planning is indirectly

relevant to air quality or is based on considerations relating to air quality). For these three exceptions,

competent authorities at Länder level are responsible for policy making and enforcement. The approach

reflects the decentralised governance system for these sectors and provides continuity with existing

governance systems. The role of the federal government overseeing air pollution matters will facilitate

coordination between these regional authorities. In turn, their involvement will contribute to achieving

policy coherence by ensuring sectoral policy priorities are factored into air pollution planning.

Emission inventories and monitoring is the responsibility of the Federal Environment Agency.

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

27/08/2019]

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Progress made by current PaMs in reducing emissions and

the degree of compliance with national and EU obligations,

compared to 2005 (M, O)

3.4.1 Progress made by current PaMs in reducing emissions

Current PaMs are described in section 4.1 of the accompanying report. All PaMs are provided

by sector, with a short description of the PaMs and the key emitting sectors.

Progress made by current PaMs in reducing emissions is presented by charts to show the

percentage reduction between 2005 and 2017 for the respective sectors reviewed (energy,

industry, buildings, transport, agriculture, waste and solvent use).

Progress by current PaMs is described for emission reductions (section 4.1 of the accompanying

report). Key emitting sectors are energy industries (SO2; NOX); industrial processes (SO2; and to a

lesser extent NOX and PM2.5); buildings (PM2.5); transport (NOX and PM2.5); the use of organic and other

products (NMVOC); and agriculture (NH3).

Current PaMs and relevant EU legislation which have led to significant emission reductions are

described individually, by sector:

Energy supply: the increased use of hydro, solar and wind energy (SO2 and NOX); retrofitting dry-

low NOX combustion chambers and selective catalytic reduction (SCR) technologies (NOX); use of

electric compressors in gas pipelines and storage tanks (NOX); compliance with petrol vapour

recovery legislation (NMVOC); and energy efficiency requirements under EU legislation (Eco-

design Directive and Energy Efficiency Directive) (SO2 and NOX).

Heating: support for heat and cooling infrastructure development (contributing to the phasing out of

older solid fuel boilers) (NMVOC and PM2.5); and support for district biomass heating installations

to replace individual older solid fuel heaters (PM2.5) (subject to strict emission controls).

Industry: Reduced cement production (NOX); compliance with BATC (introduction of filters,

selective non-catalytic reduction (SNCR) technologies, electrostatic precipitators for larger biomass

furnaces, wet scrubbers, replacement of old burners and using previously wasted heat) (NOX and

to a lesser extent PM2.5).

Non-road mobile machinery: EU limit values (Regulation (EU) 2016/1628) (NOX and PM2.5).

Buildings: emission controls for heating systems (Eco-design Directive); energy performance

certification schemes; Austrian Ecolabel for wood heaters; advice and public awareness raising;

fuel quality limits (PM2.5).

Transport: EURO vehicle standards; fuel quality standards; fiscal measures to promote low

emission vehicles; infrastructure to support electro-mobility; measures to support public transport

infrastructure, in particular targeted at rail; capacity extensions in rail infrastructure to support rail

freight; and advice, awareness raising, education and training and support for the expansion of

environmentally friendly mobility (NOX and PM2.5).

Agriculture: manure spreading techniques to reduce quantity of slurry applied; organic farming (to

reduce NH3 emissions as a result of reduced mineral fertiliser application); low intensity livestock

farming (no manure storage needed) (NH3); covered storage for liquid manure; provision of advice

and information to land managers on NH3 emissions and measures to reduce NH3 emissions.

Among the current PaMs relating to agriculture, the following are also listed in Part 2, Annex III to

the NECD:

o Low-emission manure spreading techniques;

o Low-emission manure storage systems; and

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o Ban on the burning of agricultural crop residues.

Solvent use: Emission controls concerning use (NMVOC).

Graphics are provided to show the attribution by sector for each pollutant in a series of pie charts

showing the total emissions in 2017 and the emission reduction achieved between 2005 and 2017 as

a percentage reduction for the respective sectors reviewed (energy, industry, buildings, transport,

agriculture, waste and solvent use).

3.4.2 Progress made by current PaMs in improving air quality

Current progress towards improving air quality between the 1980s and the year 2017 is described

in qualitative terms in section 4.3 of the accompanying report. In 2017, exceedances with EU air

quality standards are reported for NO2, PM10 and O3.

Key PaMs which have contributed to air quality improvements are described for industry, district

heating, road transport and non-road mobile machinery. Air quality improvements have also

occurred as a result of emission reductions from neighbouring Member States.

Current progress towards improving air quality is reported for SO2, NO2 and NOX, PM10 and PM2.5, BaP

and O3 (section 4.3 of the accompanying report). Between 2015 and 2017, exceedances of EU air

quality standards are reported for NO2 (in seven areas) and PM10 (in one or two areas). For O3, the

number of days in exceedance has reduced significantly (0.03 days in exceedance per monitoring

station in 2016).

Progress is described in qualitative terms between the 1980s and the year 2017. Years where

significant improvements occurred are specified. Graphics are provided for selected areas where

challenges relating to air quality are identified.

Current PaMs are described at an individual level:

Installation specific abatement measures (SO2) (since 1999)

Use of low sulphur content energy sources in district heating (SO2) (since 1998)

Emission reductions from neighbouring Member States (SO2, PM2.5) (since the late 1990s)

Fitting catalysts to petrol passenger vehicles (NO2 and NOX) (since the late 1990s)

Speed restrictions and driving bans (NOX and NO2) (since 2006)

Fitting diesel particle filters to passenger vehicles (PM2.5) (between 2010 and 2017)

Reductions from non-road mobile machinery (PM2.5) (between 2010 and 2017)

PaMs are not described for BaP or O3. The main sources of BaP are identified as wood-fired domestic

heating and local conditions affecting dispersion. For O3, improved air quality is as a result of precursor

emission reductions achieved (concerning NOX and NMVOC emissions).

3.4.3 Current transboundary impact of national emission sources

The current transboundary impacts of PM2.5 and NOX (relating to ground-level O3) emissions from

Austria are described in Annex 8 to the accompanying report. Affected Member States are not identified

but the impact is low (below the one-digit percentage range)9.

Accordingly, consultation activities undertaken for the development of the NAPCP did not involve

neighbouring Member States.

9 Trans-small particulate matter, photo-oxidants, acidifying and eutrophic components. EMEP Status Report 1/2018. Norwegian Meteorological

Institute, 2018

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Projected situation assuming no change in currently adopted

PaMs (M, O)

All 2020-29 commitments except NH3 are projected to be achieved.

For 2030 onwards, only the SO2 and NMVOC commitments are projected to be achieved.

For each pollutant, a description is provided to outline the key measures driving the projected

emission reductions (section 5.1.6 of the accompanying report to the NAPCP).

For air quality, improvements to NO2 and PM10 concentrations are envisaged, but the impacts on

compliance with the respective EU limit values are not estimated. Ongoing exceedances are

foreseen for O3, despite the projected reductions of NOX and NMVOC.

As presented in Section 2.2, emissions have been reported for the 2005 base year, and emission

projections have been provided for 2020, 2025 and 2030 under a WM scenario (section 2.5.1 of the

NAPCP and section 5.1.6 of the accompanying report to the NAPCP).

The projections presented in the NAPCP are from the year 2019. The year of the inventory data

underpinning the projections is not reported but the qualitative descriptions included for each of the

NECD pollutants in the accompanying report shows that 2017 data is used.

All 2020-29 commitments except NH3 are projected to be achieved. For 2030 onwards, only the SO2

and NMVOC commitments are projected to be achieved. For NMVOC the commitment is projected to

be achieved by 1 percentage point, indicating there may a risk that the corresponding commitment will

not be met. For 2030 onwards, NOX, NH3 and PM2.5 commitments are not projected to be achieved.

For each pollutant, a description is provided to outline the key measures driving the projected emission

reductions, as follows:

SO2: Emission reductions are driven by the shift from fossil fuel to renewable energy sources.

NOX: The greatest reductions are expected from the transport sector and the expected increase in

electro-mobility as well as updates to heating installations and emission limits for non-road mobile

machinery.

NMVOC: Reductions are expected from the phasing out of older solid fuel boilers and road transport

(while increases are expected from solvent use).

PM2.5: The greatest reductions are expected from updates to heating installations (new boiler stock

and a reduction in the use of wood); and the use of particulate filters on diesel passenger vehicles.

NH3: Emissions are expected to increase because there has been a change from tethered to loose

barns for cattle in housing systems (which has led to an increase in liquid manure) and owing to

the use of urea as a fertiliser over a larger area compared to earlier years. Current measures

described to mitigate NH3 emissions are manure management and manure storage. Support for

organic farming and low intensity livestock farming is also described as a measure to reduce NH3

emissions (lower intensity farming).

The qualitative description of projected improvements in air quality covers SO2, NO2, PM10 and PM2.5,

and O3. SO2 and PM2.5 concentrations are expected to continue to be below the EU limit value.

Improvements to NO2 and PM10 concentrations are foreseen, but the impacts on compliance with the

respective EU limit values are not estimated. Ongoing exceedances are foreseen for O3, despite

expected reductions of NOX and NMVOC. Quantitative data is not provided to show the number of

expected compliant and non-compliant zones.

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Policy options considered to comply with emission reduction

commitments for 2020 and 2030, intermediate emission

levels for 2025 and stakeholder consultation (M, O)

12 PaMs are considered for adoption.

The PaMs cover the key emitting sectors, including agriculture, energy (supply and

consumption), industry and transport.

The PaMs target the key pollutants that represent challenges to emission reduction commitments

and air quality (NOX, NH3 and PM2.5).

The PaMs complement the policy priorities outlined by Austria.

For the PaMs targeting agriculture and industry, there is tendency towards voluntary policy

instruments, which will likely reduce the certainty with which the expected emission reductions

for these PaMs can be achieved.

3.6.1 Summary of the information reported

Austria does not report information on additional PaMs to the EEA-PaM tool as required by Commission

Implementing Decision (EU) 2018/1522. Information is reported in the accompanying report to the

NAPCP (section 6) and in the accompanying Excel workbook.

Austria has considered 12 additional PaMs across four sectors, as listed in the following tables. The

estimated emission reductions are reported at aggregate level according to the following groups:

1. Implementation of the Federal Government’s 2030 climate and energy strategy (five PaMs).

2. Agricultural activity (five PaMs) and further action relating to low-emission manure application on

arable land and grassland (beyond those grouped under ‘agricultural activity’) (one PaM).

3. Voluntary action by industry (one PaM).

The accompanying Excel workbook lists 13 PaMs in total. Compared to the information in the NAPCP

there is one additional PaM included in the transport package.

PaMs targeting agriculture will be confirmed as part of the forthcoming programming period of the

Common Agricultural Policy (CAP), covering 2021-2027. The PaMs described in the NAPCP are

expected to evolve with the plans for 2021-2027 programming period.

The descriptions of the PaMs are clear and are judged by the reviewers as reasonable. However, as

the emission reductions are not quantified for individual PaMs and the detail on the design of the PaMs

is limited, it is not feasible to confidently comment on whether the projected impacts on emissions are

realistic and achievable.

Agriculture (six individual PaMs)

Low emission livestock feeding strategies (to reduce NH3 emissions from manure)

Low emission animal housing systems (improved livestock management and production facilities)

Low emission manure storage systems (improved systems for animal waste management)

Low emission manure spreading (low-emission manure application on arable land and grassland)

Low emission use of mineral N fertilisers

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Agriculture (six individual PaMs)

Further promotion of measures (additional efforts concerning low-emission manure application on

arable land and grassland)

Energy (supply and consumption) (one package of two individual PaMs)*

The partial substitution for fossil-based oil heating systems in existing buildings by district heating

and renewable energy sources

Increasing the refurbishment rate for comprehensive thermal refurbishment in the building sector

Note: *All PaMs described for the energy sector will be implemented via the Federal Government’s

2030 climate and energy strategy

Industry (one individual PaM)

Voluntary action by industry: Installation of abatement technologies (Retrofitting deNOX technologies)

Transport (one package of three individual PaMs)*

Efficiency gains in vehicles, vessels and aircraft (the effects of the new EU fleet targets)

An increase in the share of cycle traffic and the increase in the field of electric cars beyond the EU

targets

Maintaining transport capacity in public transport

Note: *All PaMs described for the transport sector will be implemented via the Federal Government’s

2030 climate and energy strategy

3.6.2 Pollutants targeted and projected emission reductions

The additional PaMs target NOX, NH3 and PM2.5 as the three pollutants for which Austria is not expected

to meet the corresponding commitments. No other pollutants are targeted by the additional PaMs

considered.

The sum of expected emission reductions (kt) is reported for the two packages of PaMs together with

the two individual PaMs. The expected emission reduction is reported for the years 2025 and 2030 only.

A range is reported for the PaM considered for industry (0.7 - 0.8 kt). For the purposes of Table 3-1, the

median of this range is used.

The expected impact is provided for all the PaMs but not at an individual level. Table 3-1 presents the

total emission reductions estimated for all PaMs.

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

Pollutant 2025 2030

NOX 2.3 5.05

NH3 Not estimated 10.6

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Pollutant 2025 2030

PM2.5 0.5 0.82

With the additional PaMs, Austria could meet the 2030 commitments for NOX and PM2.5 (by 1

percentage point and 4 percentage points, respectively). In both cases, there may be a risk that the

corresponding commitments will not be met. As such, further additional PaMs could be considered to

achieve greater emission reductions for these pollutants. For NH3, the additional PaMs are expected to

contribute to emission reductions but they are insufficient for Austria to meet its commitment and so

further additional PaMs should be considered.

When comparing the total emission reductions estimated for PaMs considered for adoption (Table 3-1)

to the 2005 baseline, the PaMs are expected to achieve the following emission reductions in 2025 and

2030 (no emission reductions were estimated for 2020):

NOX: 1 percent in 2025 and 2 percent in 2030.

NH3: 17 percent in 2030 (no emission reductions were estimated for 2025).

PM2.5: 2 percent in 2025 and 4 percent in 2030.

All PaMs reported have been included in the WAM scenario and the emission reductions projected

under the WAM scenario correspond with the estimated emission reductions reported for the additional

PaMs.

3.6.3 Coherence between the PaMs considered and policy priorities

Coherence with the relevant policy priorities previously described (see Section 3.3 of this review) is

reflected in the consideration of additional PaMs. Particular attention is paid to climate change policy

priorities relating to the agriculture, energy and transport sectors.

3.6.4 Responsible authorities and timescales for implementation of PaMs considered

The PaMs considered will be implemented at federal level using national policy frameworks (Federal

Government’s 2030 climate and energy strategy and programming under the CAP). It is unclear how

the competent authorities at Länder level will be involved with the implementation of PaMs targeting the

agriculture sector and heating (for buildings), despite being identified as the responsible authorities for

policy making and enforcement in these sectors (Section 3.3).

If a PaM was in place before the projections underpinning the NAPCP had been produced, the impact

of the PaM should be reflected in the projections as a current PaM and form part of the WM scenario.

Implementation of the PaM targeting the installation of abatement technologies by industry was planned

to start in 2018. The description of the PaM refers to the likely adoption of such technologies by the

paper and cement industries in Austria. It is unclear how the PaM is additional and the reason for its

inclusion in the WAM scenario is unclear. Rather, the implementation period suggests that the PaM is

an existing measure. Furthermore, other than the description of the PaM which states it is a voluntary

action by industry, there is no information reported to show how the PaM will go beyond the application

of best available techniques to meet associated emission limit value ranges as required by the Industrial

Emissions Directive.

The implementation of the remaining PaMs is due to start in 2020. This allows around 10 years for the

PaMs to deliver the estimated emission reductions up to 2030, which is considered realistic.

The PaMs considered involve various policy instruments according to the sectors targeted:

A combination of economic instruments, education campaigns and regulatory intervention for

the transport and energy sectors via the Federal Government’s 2030 climate and energy

strategy.

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Voluntary source control measures for industry.

Economic instruments and education campaigns for the agriculture sector (under the CAP)

The Federal Government’s 2030 climate and energy strategy provides a credible framework for the

associated mix of policies to be implemented.

While the use of the CAP to implement PaMs targeted at the agriculture sector offers a credible

framework, it is not clear which measures will be supported under the forthcoming 2021-2027

programming period of the CAP as negotiations were ongoing at the time of the NAPCP submission.

This reduces the credibility of the PaMs described.

3.6.5 Details of the methodology for evaluation and selection of PaMs

No details are provided of the methodology for evaluation and selection of PaMs.

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

considered

Austria does not quantify the estimated costs and benefits of the additional PaMs considered.

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

PaMs considered

In qualitative terms, the additional PaMs are expected to contribute to air quality improvements for NO2

and PM2.5 but the impact on compliance with corresponding EU air quality standards is not described

(section 6.4 of the accompanying report). Despite the projected ongoing exceedances for O3, the

expected impact of the additional PaMs considered does not reflect the possible impact of NOX emission

reductions on O3 concentrations.

The projected impacts on the environment of the additional PaMs considered are not described.

The policies selected for adoption by sector including

timetable for adoption, implementation and review and

responsible competent authority (M, O)

All PaMs have been selected for adoption.

With the additional PaMs, Austria could meet the 2030 commitments for NOX and PM2.5. Meeting

these commitments will be dependent primarily on the implementation of the Federal

Government’s 2030 climate and energy strategy.

For NH3, the additional PaMs are insufficient for Austria to meet its commitment and further

additional PaMs are necessary. Moreover, there is uncertainty concerning the precise nature of

the PaMs selected as they are expected to evolve with the plans for 2021-2027 CAP

programming period.

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

All PaMs have been selected for adoption. Thus, the projected emission reductions from PaMs selected

for adoption is presented in Table 3-1. No further information is included in the NAPCP or in the

accompanying documents beyond what has been reported for the additional PaMs considered (section

6 in the accompanying report and the tables in the accompanying Excel workbook).

As such, Austria could meet the 2030 commitments for NOX and PM2.5 under the WAM scenario. For

NH3, the additional PaMs are expected to contribute to emission reductions but they are insufficient for

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Austria to meet its commitment and further additional PaMs are necessary to ensure compliance with

the requirements of the NECD.

Agriculture

No additional PaMs are selected to those included in Part 2, Annex III of the NECD.

Regarding the mandatory measures listed in Part 2, Annex III to the NECD, the national advisory code

of good agricultural practice to control NH3 is also included among the additional PaMs selected as the

code is in the process of being updated and the updates are expected to contain additional aspects.

The use of ammonium carbonate fertilisers is prohibited together with the incineration of agricultural

crop residues and waste, and of forest residues on land. These measures are existing and are not

expected to contribute to additional emission reductions under the WAM scenario.

Of the optional measures listed, measures to reduce NH3 emissions from livestock manure are included

among the additional PaMs selected. Austria does not intend to draw up a national nitrogen balance or

establish a national advisory code of good agricultural practices for the proper management of harvest

residue.

Analysis is included in the accompanying report to show the economic significance of small farms to

Austrian agriculture and the challenges these farms would face if required to construct low-emission

housing or comply with certain fertiliser application techniques. As such, it is reported that the additional

PaMs referred to in the NAPCP should only apply to farms above a defined situational or operating

threshold. For example, the slope of the land for slurry application on land, the number of animals

(livestock units), the area farmed (hectares), or the available farm labour force.

The agriculture sector is projected to be the key emitting sector of NH3 emissions up to 2030 under the

WM scenario. The PaMs described above are estimated to achieve a 17% reduction by 2030 compared

to the 2005 baseline year. However, this is insufficient for Austria to meet its national emission reduction

commitment and further additional PaMs are needed. Particularly as the projected emission reductions

for NH3 from selected PaMs rely on either compliance with a voluntary code of good agricultural practice

or on uptake of rural development measures which are expected to evolve in the forthcoming CAP

programming period (2021-2027). The voluntary nature of the PaMs makes the extent to which the

expected reductions will be achieved uncertain.

Energy consumption

As part of the Federal Government’s 2030 climate and energy strategy, additional PaMs targeting the

energy industry include greater use of renewable energy.

The description of PaMs is limited and it is unclear what the scale of action is expected to be. Further,

estimated emission reductions are reported at an aggregate level for PaMs targeting the transport and

energy sectors. While implementation is planned for a suitable timeframe, it is unclear how much of the

estimated emission reductions are expected to occur as a result of PaMs targeting the energy sector.

Energy supply

As part of the Federal Government’s 2030 climate and energy strategy, additional PaMs targeting

energy supply include updates to district heating systems and improved energy efficiency in buildings).

The description of PaMs is limited. As above, it is unclear what the scale of action is expected to be

and the estimated emission reductions are reported at aggregate level across sectors.

Transport

As part of the Federal Government’s 2030 climate and energy strategy, additional PaMs targeting the

transport sector include vehicle standards, improvements to public transport and greater cycling rates.

The description of PaMs is limited. As above, it is unclear what the scale of action is expected to be

and the estimated emission reductions are reported at aggregate level across sectors.

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Industrial Processes

NOX emission reductions are estimated for the voluntary application of abatement technologies adopted

by industry (retrofitting de-NOX technologies). The description of the PaM is vague and is based on

potential industry uptake in the paper and cement industries according to responses gathered in a

national survey. Uptake is voluntary and no further policy intervention is planned to facilitate uptake.

Further, as described in Section 3.6.4, the implementation period suggests that the PaM is an existing

measure.

The estimated emission reductions for this PaM are comparatively minor; thus, while the PaM is

assessed as having limited credibility, the effect on expected compliance with the national emission

reduction commitments is small.

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

Coherence is achieved with the draft NECP. As described previously, the implementation of the Federal

Government’s 2030 climate and energy strategy is among the PaMs included in the NAPCP. A reflection

of the ongoing discussions concerning the new CAP strategy 2021-2027 is included in the coherence

assessment for the PaMs selected which target agriculture.

Projected combined impacts of PaMs on emission

reductions, air quality and the environment and associated

uncertainties (where applicable) (M, O)

Under the WAM scenario, the 2030 NH3 commitment is projected to be missed. For NOX and

PM2.5, the expected emission reductions may be sufficient (section 1.2.1 of 2.8 in the NAPCP;

and section 7.1 of the accompanying report).

A linear trajectory is followed for all NECD pollutants except NH3. A technical description is

provided to explain why this is the case.

3.8.1 Likelihood of achievement of projected emission reductions

According to the projections included in the NAPCP, emission reductions for NOX and PM2.5 under the

WAM scenario for 2020 and 2030 are projected to meet the national emission reduction commitment in

the NECD. For 2030, the NH3 national emission reduction commitment in the NECD is projected to be

missed.

Austria has not reported emission projections for SO2 and NMVOC under a WAM scenario. This is

because the emission reduction commitments may be met with existing measures and therefore no

additional PaMs have been selected and no change is expected compared to the emission projections

under the WM scenario.

Under the WAM scenario, improvements are projected for NOX, NH3 and PM2.5 compared with the WM

scenario. Regardless, NH3 is projected to miss the respective 2030 commitment by 9 percentage points.

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

likely to be realised in practice are presented in Table 3-2.

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Table 3-2 Likelihood of achieving the projected emissions reductions (WAM scenario)

Do the PaMs selected for adoption target

the key emitting sectors?

Are the projected emission reductions for

2020 and 2030 likely to be achieved?

SO2 N/A.

No PaMs have been selected targeting

this pollutant.

N/A.

NOX Yes.

Additional PaMs targeting NOX emissions

cover emissions from the key emitting

sectors, including transport (including

vehicle standards, improvements to public

transport and greater cycling rates),

energy consumption (greater use of

renewable energy) and energy supply

(updates to district heating systems and

improved energy efficiency in buildings).

Yes.

The PaMs will be implemented via the

Federal Government’s 2030 climate and

energy strategy and this coherence

between policy priorities is considered a

sign of their credibility. NOX emission

reductions are estimated for PaMs

targeting the transport and energy sectors.

Implementation is planned for a suitable

timeframe.

NMVOC N/A.

No PaMs have been selected targeting

this pollutant.

N/A.

NH3 Yes.

Agriculture is the main source of NH3 in

Austria and the additional PaMs are

targeted to this sector.

No.

NH3 emission reductions are insufficient

for Austria to meet the 2030 onwards

commitment. The PaMs selected will be

implemented under the forthcoming CAP

programming period and as such the

precise nature of the PaMs described in

the NAPCP is uncertain until CAP

programming is complete.

PM2.5 Yes.

“Combustion in other sectors” (NFR 1A4)

is the main source of PM2.5. PaMs

selected target emissions from energy

supply (updates to district heating systems

and improved energy efficiency in

buildings)

Yes.

The PaMs will be implemented via the

Federal Government’s 2030 climate and

energy strategy and this coherence

between policy priorities is considered a

sign of their credibility. PM2.5 emission

reductions are estimated for PaMs

targeting the energy sector.

Implementation is planned for a suitable

timeframe.

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

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

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3.8.2 Deviation from the linear trajectory for 2025

A linear trajectory is followed for all NECD pollutants except NH3. The explanation provided refers to

changes to historical inventory data concerning cattle which have led to greater emissions than was

previously reported in addition to implementation of animal welfare standards which have led to greater

NH3 emissions (section 7.1.1 of the accompanying report). As such, the reduction target for 2020 cannot

be achieved in the short term which in turn means that the linear trajectory between the 2020-29 and

2030 commitments is not attainable for Austria.

However, the aim is to move closer to the linear trajectory as soon as possible. The need for urgent

action is stated in the accompanying report to the NAPCP.

It is expected that further emission reductions can be achieved with support from the current rural

development programme (RDP) 2014-2020 (building on policy priorities within the RDP for resource

efficiency and the reduction of GHG and NH3 emissions). Relevant measures supported by the RDP

include investment support for livestock buildings based on the state of the art technologies and the

purchase of machinery to reduce NH3 emissions from slurry application, land management support for

manure spreading to the soil, reduction of fertilisation intensities and support for organic practices

(involving no fertiliser application and reduced livestock intensities) as well as the integration of emission

control and resource efficiency into the Farm Advisory Service (information awareness campaign).

Despite support being available for these measures, uptake has been low. Continued support for these

measures is expected under the new programming period and additional efforts will be taken to increase

uptake, in particular with further training and guidance initiatives. At present, possible regulations at

federal level, such as a ban on non-stabilisation of urea or a requirement for immediate processing of

manure, are not yet foreseen.

3.8.3 Use of flexibilities

No information with regard to flexibilities is reported. Therefore, it is assumed that flexibilities are not

applicable.

3.8.4 Projected impacts on air quality and the environment.

The expected air quality improvement under the WAM scenario is briefly reported in qualitative terms

for NO2 and O3 as the two air quality pollutants with expected cases of non-compliance (7.2 of the

accompanying report). As reported under the WM scenario, improvements to NO2 and PM10

concentrations are expected, but the expected impacts on compliance with the respective EU limit

values are not estimated. Ongoing exceedances are expected for O3, despite expected reductions of

NOX and NMVOC.

The projected impacts on the environment are not reported.

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4 Conclusions and recommendations

Conclusions

Austria did not meet the reporting deadline, submitting its NAPCP after the 1 April 2019. The common

format established by the Commission Implementing Decision (EU) 2018/1522 has been used to

reference the detail provided in an accompanying report and Excel workbook. The EEA-PaM tool has

not been used however, but the detail concerning the additional PaMs selected for adoption is reported

according to the layout established by the common format.

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

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

Policy priorities for agriculture are set out as part of the coherence assessment undertaken for the

consideration of additional PaMs but are not included in the policy framework defined for the

NAPCP.

Under the WM scenario, projected improvements are not described in terms of the projected degree

of compliance with EU air quality standards for NO2 and PM10 and so it is unclear up to which year

exceedances are expected.

The NAPCP projections reported under the WM scenario show that Austria is projected to miss its 2020-

29 or 2030 onwards emission reduction commitments for NH3. For NOx and PM2.5, Austria is projected

to miss its 2030 onwards emission reduction commitments. The NAPCP projections under a WAM

scenario have accordingly been provided for these pollutants in the NAPCP; however, projections under

a WAM scenario have not been submitted under Article 10(2). Accordingly, the risk assessment that

was conducted as part of the horizontal review (and factors in submissions for both the NAPCP and the

Article 10(2) projections) finds that Austria is at high risk of non-compliance for these pollutants (see

Appendix 2).

Furthermore, according to the NAPCP projections, Austria is not compliant with the requirements of the

NECD for NH3. The information provided for the additional PaMs considered and selected for adoption

shows that even with additional PaMs, Austria is projected to miss its national emission reduction

commitment for NH3 for 2020-29 and 2030 onwards. Further additional PaMs should build on the

existing and additional PaMs described, targeting the agriculture sector. Austria may want to consider

the use of different policy instruments to deliver greater and more certain emission reductions.

The most significant emission reductions for NOX and PM2.5 are dependent on the implementation of

the Federal Government’s 2030 climate and energy strategy which will cover:

Additional PaMs targeting NOX emissions cover emissions from the transport sector (including

vehicle standards, improvements to public transport and greater cycling rates), the energy industry

(greater use of renewable energy) and energy supply (updates to district heating systems and

improved energy efficiency in buildings).

Additional PaMs targeting PM2.5 emissions cover emissions from the transport sector (including

vehicle standards, improvements to public transport and greater cycling rates), the energy industry

(greater use of renewable energy) and energy supply (updates to district heating systems and

improved energy efficiency in buildings).

For NH3, the additional PaMs target the agriculture sector. Among the PaMs selected, it is expected

that the stepping up of ‘low-emission manure application on arable land and grassland’ will have the

greatest impact on NH3 emission reductions. Despite targeting the sector responsible for the highest

NH3 emissions, Austria is still not expected to meet the NH3 emission reduction commitment for 2020-

29 and 2030 onwards. As stated previously, further additional PaMs targeting this sector are required.

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Although Austria is expected to meet the NMVOC emission reduction commitments, to benefit air quality

by reducing concentrations of O3, Austria could further target NMVOC as a precursor of O3. Additional

PaMs could target solvent and other product use as the main source of NMVOC emissions in 2017.

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

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

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

as improvements to air quality.

Coherence between the NAPCP and the NECP is demonstrated with the inclusion of the

additional PaMs which are stated to be included in the final NECP.

A description of the non-linear trajectory projected for NH3 is provided. The description helps to

identify which PaMs are needed to address the projected non-compliance for this pollutant.

Regardless of the positive highlights, it is important to reiterate the findings from the risk assessment

which show that Austria is at high risk of non-compliance for NOx, NH3 and PM2.5 (see Appendix 2).

Recommendations

Recommendations are prioritised according to the following categories:

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

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

commitments.

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

commitments and provides the minimum content required by the common format but areas for

improvement to strengthen compliance have been identified.

3. Encouragements – where optional reporting and/or the NAPCP could be closer aligned with the

guidance document on preparation of initial NAPCPs to strengthen the quality of the NAPCP.

Ensuring compliance

For NH3, the additional PaMs are expected to contribute to emission reductions but they are

insufficient for Austria to meet its commitment and further additional PaMs are necessary. A

technical explanation is provided to explain why a non-linear trajectory is followed but this is

insufficient to explain why further PaMs have not been considered or selected for adoption. To

ensure compliance, further additional PaMs targeting NH3 emission reductions should be adopted.

Emission projections under a WAM scenario do not cover SO2 and NMVOC. For the pollutants

covered (NOX, NH3 and PM2.5), projections for the year 2020 are not reported. To ensure

compliance, Austria is required to provide information for all pollutants and commitment years under

the WAM scenario. Where no change is expected, this should be clearly reported and the relevant

emission projections under the WM scenario clearly referenced.

In view of the exceedances with air quality limit values for NO2 and PM10, the projected

improvements to air quality under the WM scenario should consider how the reported impacts are

expected to affect Austria's compliance with EU air quality standards.

Austria does not report to the EEA-PaM tool, rather reporting is done in Excel. To ensure

compliance, Austria is required to report to the EEA-PaM tool.

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Areas for improvement

Relevant policy priorities are not described for agriculture within the policy framework defined for

the NAPCP but are set out as part of the coherence assessment undertaken for the consideration

of additional PaMs. Consideration of relevant agriculture policy priorities within the policy framework

defined for the NAPCP is recommended to strengthen the coherence assessment undertaken for

the NAPCP.

To contribute to air quality improvements for O3, Austria could consider additional PaMs targeting

NMVOC as a precursor of O3. Additional PaMs could target solvent and other product use as the

main source of NMVOC emissions in 2017.

Encouragement

The consideration of additional PaMs would benefit from information on the impacts on air quality

and the environment and a quantification of the associated costs and benefits. This information

would strengthen the evidence base to support the selection of PaMs for all pollutants. It would also

provide insight as to why further additional PaMs were not considered to reduce NH3 emissions in

line with the national emission reduction commitment for this pollutant, and strengthen the

explanation provided as to why a linear reduction trajectory for NH3 is not followed for the projections

under the WAM scenario.

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Appendix 1 Completeness assessment

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

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

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

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

as presented in the table below.

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

Red No information provided for mandatory reporting requirement

Amber Evidence is incomplete or unclear to meet reporting requirement

Green Evidence is sufficient to meet reporting requirement

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

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

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

reduction trajectory is followed)

Table A1 - 2 Assessment of the NAPCP compliance screening with the minimum content requirements

Reference to the NAPCP common

format

RAG

Rating Explanation

2.1 Title of the programme contact

information and websites

Green All information requested by the common

format is provided, including the title, date of

publication, the responsible competent

authority (Federal Ministry of Sustainability

and Tourism) and website links to access

the information online.

2.3.1 Policy priorities and their

relationship to priorities set in other

relevant policy areas

Green Information to establish the relevant policy

priorities to the NAPCP is provided for air

quality, climate change and energy.

Transport policy priorities are provided in the

context of climate change and energy. Policy

priorities for climate, energy industry and

agriculture are set out as part of the

coherence assessment undertaken for the

consideration of additional PaMs (section 6

of the detailed report).

2.3.2 Responsibilities attributed to

national, regional and local authorities

Green The responsibilities and roles attributed to

authorities across all levels of governance is

reported.

2.4.1 Progress made by current PaMs in

reducing emissions, and the degree of

compliance with national and Union

emission reduction obligations

Green Progress made by current PaMs with

respect to emission reduction commitments

under the NECD is demonstrated.

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Reference to the NAPCP common

format

RAG

Rating Explanation

2.4.2 Progress made by current PaMs in

improving air quality, and the degree of

compliance with national and Union air

quality obligations

Green Progress in improving air quality in relation

to EU air quality objectives is described. The

PaMs delivering the improvements are not

described in detail but are referenced by the

NAPCP.

2.4.3 Where relevant, current

transboundary impact of national emission

sources

Green The transboundary impact of domestic

emissions is described in qualitative and

quantitative terms.

2.5.1 Projected emissions and emission

reductions (WM scenario)

Green Emission projections under a WM scenario

are provided with respect to the national

emission reduction commitments as

specified in the NECD.

2.5.2 Projected impact on improving air

quality (WM scenario)

Amber A qualitative description of projected

improvements in air quality is provided for

SO2, NOX, PM10, PM2.5 and O3. Projected

improvements are not described in terms of

the projected degree of compliance with EU

air quality objectives.

2.6.1 Details concerning the PaMs

considered in order to comply with the

emission reduction commitments

(reporting at PaM level)

Green Austria does not report via the EEA-PaM

tool. Information is reported using the

common format. Descriptions are provided in

the detailed report.

2.6.2 Impacts on air quality and the

environment of individual PaMs or

packages of PaMs considered in order to

comply with the emission reduction

commitments (where available)

N/A Information concerning the impact of

additional PaMs considered on air quality is

not available according to the information

reported by Austria.

2.6.4 Additional details concerning the

measures from Annex III Part 2 to

Directive (EU) 2016/2284 targeting the

agricultural sector to comply with the

emission reduction commitments

Green Austria does not report via the EEA-PaM

tool. Information is reported using the layout

of the common format. Descriptions are also

provided in the detailed report.

2.7.1 Individual PaMs or package of PaMs

selected for adoption and the competent

authorities responsible

Amber Austria does not report via the EEA-PaM

tool. All PaMs considered are adopted by the

NAPCP. Descriptions are provided in the

detailed report (section 6) but these do not

cover the minimum content required by the

common format.

2.7.2 Assessment of how selected PaMs

ensure coherence with plans and

programmes set up in other relevant

policy areas

Green The accompanying report includes a

coherence assessment between the NAPCP

and the draft NECP.

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Reference to the NAPCP common

format

RAG

Rating Explanation

2.8.1 Projected attainment of emission

reduction commitments (WAM)

Amber Emission projections under a WAM scenario

are reported for NOX, NH3 and PM2.5 only.

For NOX and PM2.5, emissions are reported

for 2005 base year, 2025 and 2030. For

NH3, emissions are reported for 2030 only.

Where there are gaps in reporting, it is

because no change is expected compared to

the emission projections under the WM

scenario. The date of projections and the

inventory year for the data underpinning the

projections are not reported.

2.8.2 Non-linear emission reduction

trajectory

Green A linear trajectory is not followed for NH3. A

technical description is provided to explain

why this is the case.

2.8.3 Flexibilities N/A Flexibilities are not used.

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

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

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

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

reporting.

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

Green Evidence is sufficient to meet reporting requirement

White No information provided for optional reporting requirement or evidence is

incomplete or unclear to meet optional reporting requirement

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

Reference to the NAPCP common

format

RAG

Rating Explanation

2.2 Executive summary White No executive summary is provided.

2.3.1 Policy priorities and their

relationship to priorities set in other

relevant policy areas: Reference to WHO

guideline values

White Optional content to show how the WHO

guidelines have been incorporated in air

quality policy is not reported.

2.3.2 Responsibilities attributed to

national, regional and local authorities:

Source sectors under the responsibility of

the authority

Green Where relevant, the specific authorities

responsible for certain source sectors are

reported by the Member State.

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Reference to the NAPCP common

format

RAG

Rating Explanation

2.4.1 Progress made by current PaMs in

reducing emissions, and the degree of

compliance with national and Union

emission reduction obligations: Provision

of graphics

Green The descriptions provided are accompanied

by graphics.

2.4.2 Progress made by current PaMs in

improving air quality, and the degree of

compliance with national and Union air

quality obligations: Provision of graphics

and progress made in a specific air quality

zone

Green Progress is described with regards to a

specific sectoral issue and specific air quality

zones. Charts are included for NO2, PM2.5

and O3.

2.4.3 Methodologies and data used to

show the current transboundary impact of

national emission sources

Green The methodology used to derive the data is

outlined together with references.

2.5.1 Associated uncertainties of the

projected emissions and emission

reductions (WM scenario)

Green The associated uncertainties are outlined.

2.5.2 Quantitative data on the projected

impact on improving air quality (WM

scenario)

White Quantitative data is not provided.

2.6.1 Details about additional pollutants

concerning the PaMs considered in order

to comply with the emission reduction

commitments: Reporting of affected

pollutant(s) beyond the scope of the

NECD

White Additional PaMs target NOX, NH3 and PM2.5

only.

2.6.3 Estimation of costs and benefits of

the individual PaM or package of PaMs

considered in order to comply with the

emission reduction commitments

White Information on costs and benefits of the

PaMs considered is not reported.

2.6.4 Additional details concerning the

optional measures from Annex III Part 2 to

Directive (EU) 2016/2284 targeting the

agricultural sector to comply with the

emission reduction commitments

Green Measures to reduce NH3 emissions from

livestock manure are in place. None of the

other optional measures listed in Part 2,

Annex III of the NECD are adopted in

Austria.

2.7.1 Individual PaMs or package of PaMs

selected for adoption and the competent

authorities responsible: Reporting of

relevant comments arising from the

consultation and provision of interim

targets and indicators

White Comments from the consultation and interim

targets and indicators to monitor progress

are not reported.

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Reference to the NAPCP common

format

RAG

Rating Explanation

2.7.2 Explanation of the choice of

selected measures

White All PaMs considered are adopted by the

NAPCP.

2.8.4 Projected improvement in air quality

(WAM)

Green The expected air quality improvement under

the WAM scenario is reported in qualitative

terms.

2.8.5 Projected impacts on the

environment (WAM)

White The projected impacts on the environment

are not reported.

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

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

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

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

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

question is ‘not applicable’ (n/a).

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

Decision tree question Relevant

scenario

2020 – 2029

SO2 NOx NMVOC NH3 PM2.5

Can the Member State

achieve the emission

reduction commitments?

(projections submitted

under Article 10(2))

WM Yes Yes Yes No Yes

WAM NR NR NR NR NR

Are the projections

submitted under Article

10(2) considered to be of

good quality?

WM Yes Yes Partially Yes Yes

Are the NAPCP projections

consistent with the latest

projections submitted under

Article 10(2)?

WM Yes Yes Yes Yes Yes

WAM n/a n/a n/a n/a n/a

Does the NAPCP present

credible additional PaMs

selected for adoption?

WAM n/a Yes n/a No Yes

Is the margin of compliance

(percent of the compliance

threshold) likely to ensure

compliance with the

emission reduction

commitments? (projections

submitted under Article

10(2))

WM Yes

(28)

Yes

(20)

Yes

(10)

No (-12) Yes

(16)

WAM NR NR NR NR NR

Risk of non-compliance L L M H L

Additional comments on

high risk scores

The review concluded that there is a high risk of non-compliance

with the NH3 emission reduction commitment for 2020-2029.

This is driven by:

Austria projecting to miss its 2020-29 emission reduction commitment for NH3 by 12% under WM scenario.

Austria not including a WAM scenario with projections submitted under Article 10(2).

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Estimated emission reductions are not presented in the NAPCP for 2020-29 for the PaMs adopted that target NH3 emission reductions.

Risk of non-compliance with 2030 emission reduction commitments

Decision tree question Relevant

scenario 2030 onwards

SO2 NOx NMVOC NH3 PM2.5

Can the Member State

achieve the emission

reduction commitments?

(projections submitted

under Article 10(2))

WM Yes No Yes No No

WAM NR NR NR NR NR

Are the projections

submitted under Article

10(2) considered to be of

good quality?

WM Yes Yes Partially Yes Yes

Are the NAPCP projections

consistent with the latest

projections submitted under

Article 10(2)?

WM Yes Yes Yes Yes Yes

WAM n/a n/a n/a n/a n/a

Does the NAPCP present

credible additional PaMs

selected for adoption

(WAM)?

WAM n/a Yes n/a No Yes

Is the margin of compliance

(percent of the compliance

threshold) likely to ensure

compliance with the

emission reduction

commitments? (projections

submitted under Article

10(2))

WM Yes (11) No (-4) No (1) No (-30) No (-1)

WAM NR NR NR NR NR

Risk of non-compliance L H M H H

Additional comments on

high risk scores

The review concluded that there is a high risk of non-compliance

with the NOx, NH3 and PM2.5 emission reduction commitments for

2030. This is driven by:

Austria projecting to miss its 2030 emission reduction

commitments under the WM scenario

Austria not including a WAM scenario with projections

submitted under Article 10(2).

Austria has reported projections under a WAM scenario for NOx,

NH3 and PM2.5 as part of its NAPCP. According to the NAPCP

projections, under a WAM scenario, Austria is projected to meet

the 2030 NOx and PM2.5 with a margin of compliance of 1 and 3

percentage points, respectively. For NH3, it is projected to miss

the commitment. The PaMs presented in the NAPCP are credible

for NOx and PM2.5, but not for NH3.

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