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Luftförorenings- och klimatsekretariatet

AirClim

Det övergripande målet med verksamheten är att verka internationellt i syfte att minska utsläpp av luftföroreningar så att de kritiska belastningsgränserna för försurning, eutrofiering och marknära ozon inte överskrids och människors hälsa skyddas.

Lobbying Activity

Response to Evaluation of the National Emission reduction Commitments Directive

13 Mar 2024

On behalf of Air Pollution and Climate Secretariat (AirClim), we welcome the Call for evidence for National Emission Reduction Commitments Directive evaluation (2016/2284). Please find our comments below in the attached file. In its current form the NEC Directive will most likely fail to deliver on the ZPAP and other commitments. The NEC Directive will only deliver sufficient benefits if it sets targets which are ambitious enough and establishes effective mechanisms for achieving them. The NEC Directives goal should at least be aligned with the EUs air quality objectives set in the Zero Pollution Action Plan. In Europe, fine particulate matter air pollution (PM2.5) caused 412.000 premature deaths in 2020, and of these 238,000 were at the levels above WHO 2021 AQG for PM2.5 of 5 µg/m3 (EEA, 2022). The NEC targets have not managed to half the numbers of premature mortality in line with the ZPAP. Ozone caused about 20.000 premature deaths in the EU in 2018 (EEA, 2020), alongside its known effects specifically on the exacerbation of respiratory disease (WHO, 2021). Ozone is formed as photo-chemical reaction with ozone precursors such as Volatile Organic Compounds (VOCs), Nitrogen Oxides (NOx) and Methane. The reduction of precursor substances is thus necessary. The current NEC-Directive does not include methane, an important ozone precursor, which is a major shortcoming and has hampered methane emission reductions. This will have an impact on the ZPAP commitments It is noted that critical loads for eutrophication were exceeded in 61 per cent of all ecosystem areas. In 2020, under the baseline scenario of the European Commissions Third Clean Air Outlook, critical loads for nitrogen deposition were exceeded in 75% of the total ecosystem area of the 27 Member States (EU-27), constituting 1,082,200km2 (Figure 5 EEA, 2022). This represents a fall of only 12% since 2005. The zero-pollution action plan has set a 2030 target of a 25% reduction from 2005 levels, so this shows that the NEC directive has not been efficient enough in contributing to this target. Since 2005, ammonia emissions have only slightly decreased in many Member States and in some cases have increased. Many member states find it difficult to reach the targets for ammonia emissions in the NEC directive, but that is no reason to reduce ambitions. Rather, it is a sign that there is a lack of adequate sectoral legislation. The agriculture sector is the principal source of NH3, responsible for 93% of emissions. The NEC targets and implementation have not been enough to contribute to ZPAP and other commitments. The NECD sets limits on emissions from individual countries for sulfur dioxide, nitrogen oxides, nonmethane volatile organic compounds, PM2.5 and ammonia to be achieved by 2030. Notably, the emission reductions proposed use the year 2005 emissions as baseline. As reported by the European Environment Agency (EEA), emissions of all relevant components had already been reduced considerably by 2011. This makes the NEC rather unambitious relative to what has already been achieved. Furthermore, using 67% of MTFR as a goal makes the targets seem harder than they are, as we all know that there are many measures that are effective that are not technical. The modelling should also include zero emission zones, dietary changes and so on. We hope this will be included in the Impact Assessment. Furthermore, the Impact Assessment should include the latest health evidence.
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Response to Review of energy labelling requirements for solid fuel boilers

12 Dec 2023

On behalf of AirClim we welcome the revision of the Ecodesign Regulation for solid fuel boilers (EC 2015/1189). We have seen a steady increase in the use of biomass for heating and combined heat and power in recent years, and unless rapid regulatory action is taken to encourage consumers to make more sustainable choices, the forthcoming renewable energy targets, particularly in the buildings sector, are likely to drive even more solid fuel combustion. We start from the conclusions of the 2021 JRC report, which has clearly shown that the use of biomass for heating is a lose-lose choice, contributing to both the climate and biodiversity crises, two major concerns addressed by the European Green Deal. Residential solid fuel combustion is the dominant source of health- and climate-damaging pollutants in the EU: the sector is responsible for 58% of particulate matter (PM2.5), 37% of black carbon (BC) and 85% of benzo(a)pyrene (BaP) emissions in the EU. Our main input can be summarised as follows: Given the declining trend in sales and use and its dramatic climate and health impacts, coal-based boilers should be clearly banned by this regulation. The scope should be extended to 1MW to be consistent with Lot 1 & 2 and subject to on-site testing. The emission limit values, in particular for Particle Mass, should be aligned with the best available techniques (BAT) in the EU, i.e. the criteria for the German funding programme, down to 2,5 mg/Nm3. In addition, a limit value for particulate number (PN) should be added, as is the case for vehicles, with a threshold of 2x10^6/cm3, for Organic Gaseous Carbon, the limit should be decresased, down to, at least, 3 mg/Nm3 In the medium term, new solid fuel appliances should comply and be in line with the same emission limits (PM, PN and NOx) as the latest EURO standards for vehicles and trucks. Finally, we call for more realistic test procedures that take into account all particulate matter produced after combustion.
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Response to Ecodesign requirements for solid fuel local space heaters (review)

12 Dec 2023

We start from the conclusions of the 2021 JRC report, which has clearly shown that the use of biomass for heating is a lose-lose choice, contributing to both the climate and biodiversity crises, two major concerns addressed by the European Green Deal. Residential solid fuel combustion is the dominant source of health- and climate-damaging pollutants in the EU: the sector is responsible for 58% of particulate matter (PM2.5), 37% of black carbon (BC) and 85% of benzo(a)pyrene (BaP) emissions in the EU. Most of these emissions come from small wood-burning appliances. Black carbon, a source of climate change, is particularly related to local space heaters.Being placed indoors obviously, they are a source of indoor pollution that leads to health problems, and we believe this revision should introduce provisions to curb indoor pollution, such as tests on air tightness. Lastly, we reckon that the manual load of stoves is far from being standardised and leads to very different emissions than those registered in lab testing, hence the need to improve testing methods. To overcome these problems, our main proposals can be summarised as follows: Given the declining trend in sales and use and its dramatic climate and health impacts, coal-based space heaters should be banned by this regulation. Building on the success of the electronic integrated thermostat, we believe it is now necessary to introduce a combustion air control (automated air regulation) as a compulsory feature, following the example of the German Blue Angel label. Emissions can and should be curbed with mandatory emissions-abating technologies, such as catalytic converters and electrostatic precipitators, which can abate more than 80% of the particulate mass and more than 95% of the number of particles. We support the introduction of stricter emissions limits, based on the best available technologies, for the following pollutants: particulate matter - 15 mg/m3 for log wood stoves and 10 mg/m3 for wood pellet appliances, Particle Number - as for 2x106/cm3 , Carbon Monoxide - as of 500mg/m3 and Volatile Organic Compounds - to 40 mgC/m3 for log wood fired heaters and to 10 mgC/m3 for wood pellet fired heaters. We support the introduction of emission limits of unregulated pollutants for Black carbon and Benzo(a)Pyrene. In the mid-term (from 2030), we believe that the emission limits should be aligned with those used by EU for new diesel vehicles or trucks (calculated as emissions per kWh). Furthermore, requirements should be in place, so stoves do not increase indoor air pollution with particles. We support third-party verification to ensure better consistency of lab data, as well as an update and improvement of the testing methods to align them with the real usage of the technology: partial and full load, different types of fuel, and inclusion of the ignition phase, among others. Lastly, we firmly oppose any change in the energy efficiency methodology and parameters concerning the energy content of wood.
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Response to Revision of EU legislation on end-of-life vehicles

27 Nov 2023

Overall, AirClim strongly supported the adoption of ambitious measures to tackle the continuing problem of 'missing vehicles'. AirClim also supports stricter requirements on the export of used vehicles, to avoid used vehicles which are not roadworthy, generate air pollution and present health risks are exported from the EU to third countries. In the proposal we believe that export requirements for used vehicles should be linked to emitted pollutants. Export to third countries need a limit (at least EURO V standards to be updated to higher standard continuously). All vehicles older than 5 years shall be tested before exportation in terms of road safety and pollutants. For those vehicles that do not fit these criteria there must be national scrappage schemes.
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Response to Fitness check of how the Polluter Pays Principle is applied to the environment

9 Dec 2022

The polluter pays principle (PPP) is an important tool for healthy environments. In its current form it is not ambitious enough and the cost of pollution in the form of health costs and degraded environments are mostly carried by others than the polluters. Air pollution and emissions impacting climate change are examples of pollutants where the emitters have not carried their own costs. Air pollution costs society billion of Euros in related health costs and these costs are carried by health care and ultimately the citizens. The external costs of climate change will be massive. Still the polluters continue to only pay a small, small proportion of its costs, if any. We welcome a fitness-check and a more ambitious proposal to the PPP.
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Response to Evaluation of the European Environment Agency for the period 2017-2021

19 May 2022

Performance evaluation of the European Environment Agency Above all we, at the Air pollution and climate secretariat Airclim are happy for the work of the EEA in providing a platform for monitored levels of air pollutants and other environmental pollutants. We found the work informative, and it does help our work on an NGO level to find the necessary statistics for most if not all EU-countries. The comment below should thus be seen as an opportunity for improvement while we are overall happy for the work of EEA. Area of improvement: The health impact assessments of air pollutants do not follow the latest scientific evidence when it comes to the so-called concentration-response functions (CRFs). The scientific field has evolved acknowledging that most pollutants are more harmful than previously believed. This relates both to effects seen at lower levels than previously believed and that the effect per mass increment of pollutant is larger than previously believed. Moreover, the health effects are not only happening for mortality endpoints in an adult population but in all parts of the life course, especially during foetal and early life. This has been known by epidemiologists and is expressed by for example The international society for Environmental Epidemiology. But EEA do not include this in the assessments of societal costs of air pollutants. This most likely lead to a bias towards an underestimation of the true costs and ignoring susceptible populations such as children. This said, we once again want to express our gratitude of the important work of EEA. Air pollution and climate secretariat Airclim
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Response to Integrated Nutrient Management Action Plan

22 Apr 2022

We welcome the goal to halve nutrient losses. It will have great benefits through improved air quality, improved water quality, biodiversity and reduced N2O emissions. Halving NH3 emissions alone would bring health benefits that would outweigh the costs for reducing emissions(1). In the Farm to Fork strategy, a reduction of fertilizer use by 20 % by 2030 is mentioned. This is a good start, though we doubt that it will be enough to achieve the target. We believe national nitrogen budgets accompanied with national Nitrogen Use Efficiency (NUE) targets would be a holistic approach to improve overall nitrogen management in the member states. A nitrogen budget gives an overview of nitrogen flows between different pools. This great tool to direct efforts to where they are most needed, as well as avoiding pollution swapping. The concept of NUE describes the ratio of nitrogen in outputs to the nitrogen in inputs. This will vary depending on how system boundaries are set. We can see a benefit in having targets both at farm or field level, as well as for full-chain NUE for the entire country. Another approach that must be considered is a safe operating space for livestock. We find it hard to believe that the target can be achieved without a reduction of animal numbers, especially in areas where the concentrations of livestock are particularly high, where also nitrogen losses are at their highest. Developments in the Netherlands are a good example, where the government plan to cut livestock numbers by 30 % over the next seven years (2). This is a type of transition we would need to see in other regions with a high concentration of intensive livestock systems. A consequence of reducing livestock numbers, is a reduction of animal derived products. To minimize the risk of pollution leakage there is a need to simultaneously work for a change of diets. Worth considering is to apply the polluter pays principle to nutrient emissions. Conceivable measures to achieve this are taxes on livestock, animal products and fertilizers. The design of this type of tax must be done carefully, to avoid risks with emissions leakage and unreasonably high administrative costs. To increase acceptance, it is an advantage if the revenue can be returned to the farming sector, for example as investment funds for measures that further reduce nutrient losses. Some interesting examples are explored in a report by Deutsche Umwelt Hilfe (3). It is also appropriate to note all the legislation that already affects nutrient emissions. This includes the Nitrates Directive, the National Emission reduction Commitments Directive and the Common Agricultural Policy. In the latter case, it is important to ensure that the national strategic plans do not undermine the goal of reducing nutrient emissions. The current situation with Russia's war in Ukraine has led to sharply increased prices on fertilizers. However, as the price of several crops has developed in the same way, it is not certain that this will automatically lead to a reduction in the use of fertilizers. It is rather likely that the price increase will be passed on to consumers Finally, we want to say that we look forward to legislation that takes a holistic approach to improve nutrient management in the European Union. We especially want to emphasize the importance of maintaining the ambition in the Farm to Fork strategy. Not only to minimize harm to people and the environment. But also, as it builds resilience to food system when agriculture becomes less dependent on inputs. (1) Gu et al., Science 374, 758-762 (2021) (2) Dutch News 16 February 2022, https://www.dutchnews.nl/news/2022/02/cattle-herd-to-be-cut-by-30-over-next-decade-to-meet-nitrogen-targets/ (3) Ökonomische Instrumente für eine umwelt- und klimafreundliche sowie artgerechte Tierhaltung by Forum Ökologisch-Soziale Marktwirtschaft on behalf of Deutsche Umwelt Hilfe, August 2021 Link: https://www.clean-air-farming.eu/downloads-und-links
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Response to Revision of EU Ambient Air Quality legislation

14 Jan 2021

Air pollution is the number one environmental health risk in the EU, causing both chronic and serious diseases such as asthma, cardiovascular problems and lung cancer. Air pollution is responsible for some 400 000 premature deaths every year in the EU and for damage to ecosystems and biodiversity through eutrophication, acidification and excess ozone levels. Effective policy action to quickly and drastically reduce the health and environmental damage caused by air pollution is urgently required. The long-awaited revision of the Ambient Air Quality Directives provides a golden opportunity to ensure cleaner air and to achieve a high level of protection for citizens and ecosystems. Alignment of the EU air quality standards with scientific knowledge In order to ensure effective health protection, the revised Ambient Air Quality Directives (AAQD) should fully align EU air quality standards with the forthcoming World Health Organisation (WHO) air quality guideline recommendations that are expected to be adopted by the WHO in the first half of 2021. To ensure also effective protection of natural and semi-natural ecosystems, the revised AAQD should set standards based on critical loads and levels for the protection of the environment, as elaborated under the Convention on Long-Range Transboundary Air Pollution (CLRTAP), including adding a new air quality standard for critical ammonia concentrations. An explicit mechanism for adjusting air quality standards to scientific progress should be included in the revised AAQD. Rather than making the adaptation of the air quality standards subject to the ordinary legislative procedure, the revised AAQD should include a process that allow for an automatic adjustment of the air quality standards in light of new scientific evidence. Improving the air quality legislative framework Air quality standards in the form of binding limit values have been and will continue to be a key driver for reducing air pollution and improving air quality. Other forms of standards, such as exposure reduction targets or target values, can be useful as a complement to binding limit values. For example, target values can be useful as a temporary step for pollutants that are currently non-regulated (e.g. black carbon and ultrafine particles) - standards for these pollutants could initially be set as target values, but should eventually become limit values. Explicit access to justice provisions should be introduced in the revised AAQD in order to ensure adequate and timely access to justice and achieving a level playing field across the EU. As there are currently wide discrepancies in the national systems for sanctions and penalties in case of non-compliance, including a lack of effective remedies in several countries, there is a need to revise the provisions on penalties in the AAQD and introduce more detailed provisions for penalties. The revised AAQD could also include a list of criteria to be taken into account for the imposition of penalties and provide guidance on the level of sanctions. The revised AAQD should include provisions to harmonise rules on compensation for damages. Public information on air quality should be actively disseminated by authorities. Up-to-date and live data should be presented in an accessible and understandable way, using a harmonised system in all member states. The revised AAQD should also introduce harmonised information and alert thresholds for all air pollutants covered by the Directive. The revision of the AAQD should consider several improvements to the legal framework for monitoring, modelling and plans, including: • Increase the minimum number of PM2.5 stations and set clearer requirements for the proportion between different types of monitoring stations; • Require the installation of monitoring stations for black carbon, ultra-fine particles and ammonia; etc. (see enclosed file for full response).
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Response to Real-Driving Emissions in the EURO 6 regulation on emissions from light passenger and commercial vehicles (RDE3)

8 Dec 2016

The Air Pollution and Climate Secretariat (AirClim) welcomes the Commission’s proposal on the 3rd RDE package as a step in the right direction to tackle PM emissions from Gasoline Direct Injection cars and strengthen the RDE test procedure. However, we are particularly concerned by two issues: Firstly, the extension of RDE to measure PN emissions must be implemented without delay under the proposed timetable, i.e. 2017 for new types and 2018 for all new vehicles. Any slippage of either of these dates is unacceptable and would lead to delaying urgent investment needed to ensure the growing fleet of direct gasoline injection petrol cars meets the Euro 6 limit on the road. Secondly, both the actual RDE test results and the maximum declared values for manufacturers must be made available in the public database in line with the Commission proposal. Any weakening of these important provisions on access to data will seriously undermine RDE 3 and public information. There are orders of magnitude difference in emissions for vehicles fitted with gasoline particle filters and not, and drivers should be provided with this information. AirClim considers the current draft text of the proposed 3rd RDE package to be the minimum acceptable to be effective, and there must therefore be no further weakening of the text. There are several areas of potential improvements that should be made to the text, ideally now, or certainly before the 2nd step of RDE is introduced in 2020. These include: • Addressing ultra-fine particles - further work is needed to extend measurement to these emissions in order to include them by 2020 at the latest. • The approach used to account for higher cold-start emissions should be replaced with a more accurate weighting process of their fair share in an average urban trip. • The conformity factors should be reviewed annually.
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