European Environmental Bureau

Particle reduction plans in Europe - Implementation of the first Daughter Directive on Ambient Air Quality in Europe

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Courtesy of Courtesy of European Environmental Bureau

Untitled Document



This publication analyses the quality of national implementation of the first Air Quality Daughter Directive (1999/30/EC). The report is based on information from 15 NGOs (members of the EEB’s Clean Air Working Group), who provided data for PM10 concentrations in ambient air as well as information about air quality management plans from 30 cities in Europe.

The air pollution challenge

Air pollution in the European Union – particularly in urban areas – is a pressing problem as many people are exposed to high concentrations of pollutants. Recently published research carried out for the European Commission showed that air pollution levels of the year 2000 in Europe lead to almost 370,000 premature deaths per year. Furthermore, air pollution causes significant human suffering such as over 114,000 serious hospital admissions per year and affects the lives of millions of people, who need to take respiratory medication (CAFE 2005 a).

Most of the health effects related to air pollution come from long-term exposure to fine particles (PM2.5). These are tiny dust particles with a diameter of about 2.5 micrometers – about a thirtieth of a human hair. Furthermore biodiversity is affected in more than 60% of European ecosystems because of nitrogen deposition above the critical loads and serious damage is also caused by acid deposition (“acid rain”) and high levels of ozone concentrations (CAFE 2005 b).

Air quality directives

In order to reduce air pollution impacts on both people and ecosystems, the EU has adopted a series of air quality directives. The air quality Framework Directive (1996/62/EC) and its four Daughter Directives set limit or target values for the pollution concentration in ambient outdoor air, which are not to be exceeded anywhere in the European Union. The first limit values for coarse particles (PM10)1 as well as SO2 entered into force in 2005. These limit values are set in the first air quality daughter directive. According to the air quality directives, EU member states are obliged to monitor air quality throughout their territory and to draw up and implement air quality management plans. These plans have to reduce pollution concentration in order to meet the limit values by the time they enter into force.

Implementation problems However, already in the first quarter of 2005 many member states were breaching the standards for fine particles. PM concentrations are particularly high in urban areas. In many European cities the PM10 limit values were exceeded in the first half of 2005 – in Turin and Milan already in February, in Budapest already in March 2005.However, member states have reportedly been late in drawing up plans and programmes to improve air quality. In July 2004 the Commission had started infringement procedures against ten member states for not having submitted plans or programmes on time, or because the plans submitted were incomplete (CEC 2004a).

Focus of the survey

The survey focuses on one pollutant – PM10 – because in this case implementation problems are most evident and because the health impacts of particles are severe. We decided to focus our analysis more specifically on cities – because this is where particle pollution is worst, and this is also where most air quality management plans are made.

The report is meant to be a snapshot of the current implementation situation throughout the EU. It is not an exhaustive analysis covering all aspects of the implementation of this directive. But by analysing air quality data, plans and programmes and some background information from altogether 30 cities in 15 European countries, we can highlight some key problems with the implementation of the directive.


Given the serious health problems caused by fine and coarse particles member states clearly have not done enough to implement this directive and meet the legally binding limit values in 2005. Plans have been made too late in most cases, even though the problem should have been apparent since 2002 at least. Furthermore many plans are not concrete enough and lack dedicated financing, which makes it unlikely that the measures in the plans are going to be put into practice.

On the national level member states are putting in place initiatives to improve the performance of the car fleet, but at the same time some NGOs highlighted that in their countries much larger sums are invested in further road expansion and investment in road infrastructure takes priority over investment in other modes of transport.

Regarding the implementation of this directive it will be of utmost importance to make sure that the plans are effective and that the measures in the plans are implemented. It is the obligation of the member states to ensure good implementation at local level, but also to complement local policies with national policies that will actually help cities to reduce pollution.

Key findings

  • Most cities analysed in this report have been much too late in responding to the PM problem. Already in the years leading up to 2005 it should have been obvious that it will be difficult to meet the limit values without systematic air quality management. Between the years 2002 and 2004 96% of the cities analysed have recorded exceedances of the daily PM10 limit values plus margin of tolerance in at least one year.
  • 50% of these cities however did not make plans and programmes before the year 2005, even though they had exceedances in at least one year before this time. This is clearly against the requirements of the directive, which stipulates that plans and programmes have to be made in order to meet the legally binding limit values by 2005. Some cities, which have already exceeded the legally binding limits in the first half of 2005, have still not adopted any plans to reduce PM10.
  • The most popular measure is to charge for parking space and reduce car parking possibilities in the city (72%of plans and draft plans). On second place is the promotion of car sharing, cycling and walking (63%). The thrid place is shared by two measures: ‘reorganising the city to limit car use by providing better opportunities for walking, cycling and public transport’ as well as by ‘other type of traffic restrictions’ (both 59%). Low emission zones, which permanently restrict access of vehicles without particle filters would be very effective as regards air quality and could improve air quality quickly. This measure was only included in three plans and draft plans.
  • The city of Bristol comes out best in our evaluation and shows that cities can adopt good air quality management plans and adopt a systematic approach to air quality management. In April 2004 the city published a fairly wide-ranging air quality management plan, which is detailed and clearly written. Bristol’s air quality plan is intended to ‘top up’ the local transport plan so measures should be considered in conjunction with this. The local transport plan was already adopted in 2000. The local transport plan was already adopted in 2000. It resulted in increase in cycling of 27% and rail use of 19% in over three years (Bristol City Council 2004).
  • The implementation of the air quality management plans is crucial for the functioning of this directive. A plan on paper does not mean that it is implemented accordingly. When analysing plans it is important to consider, when and if the planned measures will enter into force. Even though most cities were late with making plans, not all measures contained in the plans are going to be introduced immediately. For example the low emmission zone included in the air quality plan for Berlin will not enter into force before 2008. In Düsseldorf on the other hand a low emmisssion zone should have been introduced in 2005. But organizational prerequisites by the federal government (adoption of a national car-labelling directive) are still missing, therefore it is not implemented yet.
  • The most critical problem regarding the implementation of the measures is the lack of dedicated financing. Dedicated financing has been missing for more than half of the plans analysed (61%). This is even the case for the otherwise very good air quality plan of Bristol, which means that some of the more ambitious elements of the plan are unlikely to be implemented. Eleven cities of our sample of plans and draft plans have foreseen to retrofit their bus fleet with particle filters. From these elven cities only three outline clearly how the measures will be financed. If the money needed for the measures in the plans is not clearly designated in the city budget, it is unlikely that they are put into place.
  • In addition to that most plans were not concrete enough. Only 38% of the plans project the likely air quality impact of measures and only 31% project when the pollution reduction will be achieved. However, the air quality impact of measures is not projected, it is impossible to judge objectively if these measures will be sufficient to meet the air quality limit values. Furthermore if it is not projected when the concentration reduction will be achieved, it is impossible to know, when the legally binding limit values will be achieved.
  • Ultimately member states are responsible to the Commission for meeting or not meeting the limit values anywhere in their territory. It is thus the obligation of the member states to put in place incentives, funding schemes or dissuasive penalties, which ensure that plans are made everywhere and that future plans are made on time (for example regarding the limit values for NO2, which will enter into force in 2010). They must make certain, that they contain sufficient measures to meet the limit values, the necessary projections and data to verify this, and that they are implemented so that plans are more than just a ‘wish list’. The Commission should investigate these points closely when assessing the implementation of this directive. Furthermore member states must complement local policies with national policies that will actually help cities to reduce pollution.

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