Bellona response to EC consultation on the fitness check of the Ambient Air Quality Directives

Publish date: July 30, 2018

Around 500,000 Europeans die each year due to air pollution. In response to this, the European Commission has launched a ‘Fitness Check’ of its Ambient Air Quality Directives via a public consultation. Bellona has contributed to this consultation with the following key points.

EU Air Quality standards must be in line with the WHO’s Air Quality Guidelines

As the world’s leading health organisation, the WHO provides guidelines based on scientific evidence. These guidelines help to quantify an acceptable level of particular pollutants, such as NOx, particulate matter (PM10 and PM2.5), NO2, among others, in order to minimise their damaging impact on human health. It is important to note that generally the WHO suggests that there is no ‘safe-limit’ of air pollutants, given that “the lower the levels of air pollution, the better the cardiovascular and respiratory health of the population will be, both long- and short-term.”

Today, the EU’s air quality standards are set below the WHO’s guidelines, implying that the targeted levels of pollutions are suboptimal. Despite contributing to cleaner air within the Union, the end result of the current Ambient Air Quality Directives are still insufficient to provide clean and healthy air to its European citizens. Therefore, the EU should strive to align itself with the global authority on health in the short-term, while aiming for near-zero pollution in the long-term.

Air Quality Data must be more frequent and more localised

While the AAQ Directives have provided a boost in the availability of air quality data, more must be done to ensure citizens are aware of the potential health impact they face when outdoors. A recent exercise in Brussels demonstrated that air pollution is particularly high in the immediate vicinity of automobiles, yet this cannot be reflected without very localised and frequently updated data points. The monitoring of air quality via citizen initiatives should be promoted to address this substantial shortcoming.

The EU should use its power to standardise the measurement of Air Quality Data

Setting a minimum quantity of measurement stations, clear and user-friendly guidelines as to which data must be gathered and reported on, as well as a strengthening of cities’ observing and maintenance capacities will be key.

What is more, targeted investments are needed in digital infrastructure and support systems to enable the effective inputting of local data into national and EU levels, with a view to establishing a Digital EU Single Market for air quality data.

Subsidies should be removed for polluting activities

The economic impact of air pollution on public health is not properly accounted for in the cost of polluting activities. In the case of road transport, Bellona has calculated that if the exhaust emission-induced human health externalities were to be priced in, we would see a doubling in the average ICE’s sticker price to EUR 50,000. As such, unjustified subsidies for polluting activities should be removed to promote cleaner practices and products.

Stringent enforcement of the AAQ Directives is necessary

The existing limit values and the right to clean air have been a driver for court action against those who fail to meet these standards. Therefore, enforcement of air quality standards should continue to be pursued. Bellona encourages the European Commission to carry through with its ongoing legal action against several member states for failure to comply with these directives.

Bellona’s submission to the public consultation will be publicly available on the European Commission website.

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