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European Commission DG Environment

National Emission Ceilings Directive Review

Task 1 – In depth analysis of the NEC national programmes

Final Report

July 2005

Entec UK Limited

Certificate No. FS 13881

Report for Michel Sponar DG ENV-C.1 European Commission Avenue de Beaulieu 5 6/103B-1160 Brussels Belgium

Main Contributors Ben Grebot Katherine Wilson Mike Soldner Andriana Stavrakaki Nynke Venema Alistair Ritchie

Issued by

…………………………………………………………

Ben Grebot

Approved by ………………………………………………………… Alistair Ritchie

Entec UK Limited Windsor House Gadbrook Business Centre Gadbrook Road Northwich Cheshire CW9 7TN England Tel: +44 (0) 1606 354800 Fax: +44 (0) 1606 354810

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h:\projects\em-260\13000 projects\13636 ec necd review\amended final main & appendix d (12th july 2005)\13636 final report (july 05)_task 1 main.doc

European Commission DG Environment

National Emission Ceilings Directive Review

Task 1 – In depth analysis of the NEC national programmes

Final Report

July 2005

Entec UK Limited

Certificate No. EMS 69090

In accordance with an environmentally responsible approach, this document is printed on recycled paper produced from 100% post-consumer waste, or on ECF (elemental chlorine free) paper

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Glossary

AT AUSTRIA

BAU Business-As-Usual

BBAU Beyond Business-As-Usual

BE BELGIUM

CAFE Clean Air for Europe

CHP Combined Heat and Power

CCGT Combined Cycle Gas Turbines

CITEPA Centre Interprofessional Technique d’Etudes Pollution Atmospherique

CLE Current Legislation

CORINAIR CORe INventory for AIR emissions

DE GERMANY

Defra Department for Environment, Food and Rural Affairs

DK DENMARK

EEA European Environmental Agency

ELV Emission limit value

EPA Environmental Protection Agency

ES SPAIN

ETC/ACC European Topic Centre on Air and Climate Change

FI FINLAND

FGR Flue Gas Recirculation

FR FRANCE

GIS Geographic Information Systems

GR GREECE

IIASA International Institute for Applied Systems Analysis

IE IRELAND

IPPC Integrated pollution prevention and control

IT ITALY

LCP Large Combustion Plant

LU LUXEMBOURG

LV Limit value

MoE Ministry of Environment

MSC-W Meteorological Synthesising Centre - West

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NEC National Emission Ceilings

NFR Nomenclature For Reporting

NH3 Ammonia

NL NETHERLANDS

NOx Nitrogen Oxide

NRMM Non Road Mobile Machinery

PM Particulate Matter

PM10 Particulate matter of less than 10 µm diameter

PT PORTUGAL

SCLFD Sulphur content in liquid fuels Directive

SCR Selective Catalytic Reduction

SE SWEDEN

SED Solvent Emissions Directive

SNAP Selected Nomenclature for sources of Air Pollution

SNCR Selective Non-Catalytic Reduction

SO2 Sulphur dioxide

UK UNITED KINGDOM

UNECE United Nations Economic Commission for Europe

UNECE TFEIP UNECE Task Force on Emission Inventories and Projections (TFEIP)

UNFCCC United Nations Framework Convention on Climate Change

VOC Volatile organic compounds

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Executive Summary

This is the final report for a review being undertaken by Entec UK Limited for the European Commission of the National Emission Ceilings Directive (2001/81/EC). It presents a summary of the work carried out on Task 1 (‘In depth analysis of the NEC national programmes’). The main findings of the work are summarised below.

Progress to NEC Targets

On the basis of the emission projections presented in the national programmes and reported separately to the Commission under the NECD, only four Member States are currently projected to comply with all of their NEC targets by 2010 without the need for further actions beyond those already planned under business as usual policy commitments (Finland, Greece, Sweden and the UK). With additional measures, a further three Member States are projected to achieve all of their NEC targets (Belgium, Germany and Luxembourg). However, a number of Member States have not presented additional measures, and their potential impacts, in their national programmes so it is not possible to assess whether or not they can achieve their emission ceilings. Of the four NECD pollutants, the ceilings for VOCs and NOx, in particular, appear to be the most challenging.

Consistency of NEC national programmes with other submissions1

The comparison undertaken between the NEC national programmes and other submissions1 has revealed a varying level of consistency of reporting under different obligations as well as between Member States. It is important to note, however, that these different submissions are quite often prepared at different times, sometimes with gaps of two or more years. Therefore, the policies and measures presented and the assumptions behind the emission projections can be expected to change over time as more information becomes available and new priorities for action are identified.

Notwithstanding this, the key points from the comparison include:

• Although less than half of EU15 Member States have so far submitted plans or programmes under the Air Quality Framework Directive, these tended to be fairly consistent with the NECD programmes with respect to the policies and measures reported;

• The level of consistency between Member States’ NECD programmes and reports to the Monitoring Mechanism and UNFCCC varies considerably between countries. The greatest inconsistencies involve the policies and measures reported in each submission. A large proportion of measures reported in Member States’ greenhouse gas reports are also likely to reduce emissions of NECD pollutants and vice-versa. However, no single country has consistently reported all relevant measures in both submissions (although a few countries have reported a majority of relevant measures). This is an important issue

1 Plans and programmes reported under the Ambient Air Quality Framework Directive, the Monitoring Mechanism and to the UNFCCC (greenhouse gas mitigation), the LCPD and the CAFE baseline scenarios.

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as, by taking an integrated approach to meeting air quality and climate change targets, Member States can comply with their objectives in a much more cost effective manner;

• All EU15 countries that have submitted national plans under the LCPD have also presented the Directive as an existing policy in their NECD programmes although only Ireland has also presented some of the more specific technological measures that make up the plan. However, around the time that most NECD programmes were being prepared, Member States had not yet specified and/or decided how they were planning on implementing the LCPD at a site-specific level so specific measures would not have been known (with the exception of Ireland);

• A comparison between the CAFE baseline (with and without climate policies and with national energy projections) and NECD emission projections showed a huge level of variation, not just between each Member States’ figures but also between pollutants.

- SO2 - For all but one country (and scenario), the CAFE baseline emissions projections for 2010 are lower than the BAU NECD projections reported by each Member State (majority are within approximately 25%).

- NOx – The majority of Member States’ NECD emission projections are very similar to those reported in the CAFE baseline (generally less than 10% difference).

- VOC - For all but two countries, the CAFE baseline emissions projections for 2010 are lower than the NECD projections reported by each Member State (majority are within approximately 25%).

- NH3 – The variation between NECD and CAFE baseline projections is much greater for NH3 than for the other pollutants although the majority of differences are less than 20%; and,

• The comparison also further highlighted the lack of consistency of reporting of policies and measures in NECD programmes as very few countries have reported the majority of legislation considered for the CAFE baseline scenarios.

These comparisons have highlighted not only the inconsistencies between different submissions, but also the similarities with respect to the type of data reported, the sectors and even the pollutants targeted. The policies and measures reported in each of these submissions, including the NECD programmes, will generally have an impact on, and contribute towards, meeting all of the NECD ceilings. The reporting of these could potentially be combined for all relevant submissions although the greatest scope for potentially combining submissions in the future lies with greenhouse gas reporting to the Monitoring Mechanism. This is discussed later in Section 8 – ‘Proposals for guidelines for reporting’ .

Inter-comparison of NEC national programmes

The inter-comparison of the NEC national programmes further reinforces the conclusions of the European Environment Agency’ s initial assessment of the programmes (2004) with respect to the generally poor level of reporting and lack of consistency between Member States. This lack of consistency and limited availability of information makes any quantitative analysis almost impossible. It also highlights the need for guidelines for reporting to ensure a structured approach to preparing national programmes in the future. A

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more structured and detailed reporting format will enable a much more detailed inter-comparison to be carried out.

The key conclusions of the inter-comparison are summarised below:

• Majority of Member States have only reported a ‘with measures’ scenario and not also a ‘with additional measures’ emissions scenario;

• Key sectors targeted for emissions reductions by most Member States are energy, transport, industry, solvent use and agriculture;

• The level of reporting of key European Directives varies considerably between programmes;

• The majority of policy measures reported are regulatory and will be implemented at a national level by central Government; and,

• Very few Member States have reported the quantitative impact and/or costs of individual policies and measures.

The analysis of the policies and measures reported for each source sector highlighted the varying levels of action of each Member State in different sectors and at different geographical and institutional levels. This breakdown has identified the potential for Member States to take further action in certain areas. For the energy and transport sectors, the majority of Member States have reported a wide selection of policies and measures ranging from local transport plans to European legislation such as the LCPD, for example. The wide range and number of measures reported for the energy and transport sectors, which currently emit the bulk of European NOx emissions, is possibly indicative of the fact that the NOx emission ceilings appear to be the most challenging and are currently projected to be exceeded by several Member States in 2010. However, for other sectors such as agriculture and solvent use, the number and variety of policies and measures is lower even though these sectors are key sources of NH3 and VOC emissions, respectively. This could be a reflection of the effectiveness of specific legislation such as the Solvent Emissions Directive, for example, so further measures are not deemed necessary.

Emission projections

Most Member States appear to have used methodologies to calculate emission projections either consistent with or based on the requirements of the Directive. However, the sectoral scope of historic emissions and projections varies considerably between programmes.

The guidelines for reporting to the Convention on Long Range Transboundary Air Pollution (CLRTAP), which Member States are obliged to use for NECD reporting, specifically requests Member States to report, to the extent feasible, the uncertainty associated with emissions data and their underlying assumptions. However, very few Member States have addressed uncertainty in any great detail and only one country (France) has provided quantitative estimates of the uncertainty associated with its emission projections.

Proposals for additional essential questions for each Member State

A specific requirement of the technical annex for this study was the preparation of ‘proposals for additional essential questions to be asked by the Commission to the Member State on existing plans to ensure their conformity to the Directive and their consistency with

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other existing plans’ . The level of reporting and meeting the requirements of the NECD varies considerably between each programme. The key requirements of the NECD that have been consistently not met are the reporting of information on:

• Any anticipated changes in the geographical distribution of emissions; and,

• The socioeconomic assumptions behind the emission projections.

The majority of countries have also failed to report the quantitative impact of individual policies and measures reported in their national programmes. Several countries present the combined impact of groups of policies and measures rather than on an individual basis. No single country has met all of the requirements of the Directive.

Entec’ s proposals for additional essential questions for each Member State have been submitted to the Commission as a separate document with this report.

Political and administrative procedure of adoption of the NECD

An information request was prepared and sent out to all EU-15 Member States and/or Regions (in Belgium’ s case) that had prepared and submitted a national programme under the NECD. This included Ireland and the Walloon Region of Belgium even though only draft programmes have been prepared to date. By the 5 July 2005, all Member States had returned a completed information request.

In general, the NECD national programmes have been prepared by the national environmental Agency, Department and/or Ministry in co-operation with other relevant Governmental bodies for sectors such as energy, transport and agriculture. Very few countries have developed a specific procedure for monitoring and evaluation of the implementation of the programme. All but three of the countries (Denmark, Ireland and Sweden) have had independent assistance with preparing their national programmes. The majority of countries have also co-ordinated the development of their NECD programmes with other reporting requirements, most notably with their greenhouse gas/climate change commitments.

Aside from Italy, all other countries have carried out some form of consultation with other public bodies and/or relevant stakeholders and the public. A broad consensus was generally reached although some issues have arisen over the specific policies and measures that are likely to be implemented for each sector. Very few problems or barriers were encountered in relation to the political or administrative procedure for adoption of the national programmes.

Proposals for guidelines for reporting

The analyses carried out in this study have highlighted the generally poor level of reporting under the NECD as well as the general lack of consistency between the NECD programmes themselves and with other national plans and programmes. Entec’ s proposals for guidelines for reporting under the NEC Directive aim to improve the quality of reporting with respect to the requirements of the Directive and to improve the consistency of these programmes with those produced by other Member States and those produced under greenhouse gas emissions obligations. They are based on the requirements of the NECD, guidelines for reporting to CLRTAP and the implementing provisions of the EU greenhouse gas Monitoring Mechanism.

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An area for future investigation should be the development of a series of indicators for monitoring the progress of individual policies and measures, as well as overall progress of Member States, towards complying with their NECs. These could be based around those developed for the Monitoring Mechanism which must be submitted annually to the Commission along with their emission inventories.

A number of potential ways in which to reduce the reporting burden on Member States has been discussed including combining the reporting of emissions inventories to CLRTAP and the NECD, combining submissions (emission inventories and national programmes) under the NECD and the EU greenhouse gas Monitoring Mechanism and Member States submitting one combined emissions inventory/projection and/or list of policies and measures rather than separately for the NECD, LCPD, Solvent Emissions Directive, Air Quality Framework Directive and Monitoring Mechanism.

Recommendations

The recommendations of this task are presented in the separate summary report, which combines the summaries and recommendations of all 3 tasks together.

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Contents

1. Introduction 1

1.1 This Report 1 1.2 Project Summary 1 1.2.1 Background – The National Emission Ceilings Directive 1 1.2.2 Task 1 Scope and Objectives 2 1.3 Structure of the Report 2

2. In Depth Analysis of NEC National Programmes 5

2.1 Information sources and availability 5 2.2 National programme profiles 7

3. Consistency of NEC National Programmes with Other Submissions 9

3.1 Introduction 9 3.1.1 Summary of information reported in each submission 9 3.1.2 Timeline of reporting requirements 12 3.2 Air Quality Plans and Programmes reported under the

Ambient Air Quality Framework Directive (96/62/EC) 13 3.2.1 Introduction 13 3.2.2 Comparison 13 3.3 National Programmes for mitigating Greenhouse Gas

Emissions reported under the Monitoring Directive and its amendments and implementing provisions and to the UNFCCC 14

3.3.1 Introduction 14 3.3.2 Comparison 15 3.4 National Plans reported under the Large Combustion Plant

Directive (LCPD) 17 3.4.1 Introduction 17 3.4.2 Comparison 18 3.5 CAFE Baseline Scenario (RAINS Model) 19 3.5.1 Introduction 19 3.5.2 Comparison 21 3.6 Summary / Conclusions 24

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4. Inter-Comparison of NEC National Programmes 27

4.1 Progress to NEC Targets 27 4.2 Are measures proposed sufficient to meet NEC targets? 31 4.3 Scenarios Presented 32 4.4 In depth analysis of policies and measures reported by each

Member State 33 4.4.1 Sectors targeted for emission reductions 33 4.4.2 Types of policy measures presented 35 4.4.3 Summary of abatement measures presented 38 4.4.4 Overview of emission reductions of policies and measures 42 4.4.5 Costs 42 4.4.6 Implementing body, current status of implementation,

implementation timetable and procedures for monitoring and implementation 43

4.4.7 Sector by sector overview 43 4.5 Summary / Conclusions 68

5. In-depth Analysis of Projections Presented in each Programme 71

5.1 Methodologies for preparation of emission projections 71 5.2 Sectoral Scope 73 5.3 Uncertainty 76 5.4 Updated inventories and projections 79 5.5 Extent to which existing and additional measures to reduce

greenhouse gas emissions have been included in projections 81

5.5.1 Methodology 81 5.5.2 Summary 81 5.5.3 Austria 82 5.5.4 Belgium 83 5.5.5 Denmark 84 5.5.6 Finland 85 5.5.7 France 85 5.5.8 Germany 86 5.5.9 Ireland 87 5.5.10 Italy 87 5.5.11 Luxembourg 88 5.5.12 Netherlands 89 5.5.13 Portugal 90 5.5.14 Spain 90

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5.5.15 Sweden 91 5.5.16 UK 92 5.6 Summary / Conclusions 92

6. Political and Administrative Procedure of Adoption of the NECD National Programmes 95

6.1 Information request 95 6.2 Summary of political and administrative procedure of

adoption 95 6.3 Consultation 102 6.4 Recommendations 105

7. Proposals for Additional Essential Questions for each Member State 107

8. Proposals for Guidelines for Reporting 111

8.1 Standard of reporting 111 8.2 Member States’ comments on reporting 111 8.3 Consistency with greenhouse gas reporting 113 8.4 Guidelines for reporting 115 8.4.1 Information sources 115 8.4.2 Structure of guidelines 115 8.4.3 Discussion 117

9. References 123

Table 2.1 Availability of NEC national programmes and other submissions for EU15 Member States 6

Table 3.2 Summary of comparison between Member States’ NECD programmes and reporting under the Ambient Air Quality Framework Directive 14

Table 3.3 Summary of reports submitted under the NECD, Monitoring Mechanism and to the UNFCCC 16

Table 3.4 Summary of legislation considered for the CAFE baseline scenarios (IIASA, 2004a) 20 Table 4.1 Comparison of Member States projections and NEC targets 27 Table 4.2 Summary of sectors targeted for emission reductions in each national programme 33 Table 4.3 Level of reporting of European Directives in the NECD national programmes (EEA,

2004 and updated) 36 Table 4.4 Summary of types of policy measures presented in the national programmes (

� = 5

or less, ��

= 6-10 and ��

= more than 10 measures reported) 37 Table 4.5 Summary of abatement measures presented in the national programmes to comply

with the NEC targets 40 Table 4.6 Total potential impact on emissions and range of cost effectiveness of the policies

and measures reported for the energy sector 44

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Table 4.7 Summary of the key policies and measures reported by each Member State aimed at reducing emissions from the ENERGY sector 46

Table 4.8 Total potential impact on emissions and range of cost effectiveness of the policies and measures reported for the transport sector 50

Table 4.9 Summary of the key policies and measures reported by each Member State aimed at reducing emissions from the TRANSPORT sector 52

Table 4.10 Total potential impact on emissions and range of cost effectiveness of the policies and measures reported for industrial processes 55

Table 4.11 Summary of the key policies and measures reported by each Member State aimed at reducing emissions from the INDUSTRIAL sector 57

Table 4.12 Summary of the key policies and measures reported by each Member State aimed at reducing emissions from the SOLVENT USE sector 60

Table 4.13 Summary of the key policies and measures reported by each Member State aimed at reducing emissions from the AGRICULTURAL sector 63

Table 4.14 Summary of the key policies and measures reported by each Member State aimed at reducing emissions from the WASTE sector 66

Table 5.1 Summary of methodology used to calculate emissions projections in the national programmes 71

Table 5.2 Summary of sectoral scope of historic and projected emissions data presented in the national programme 74

Table 5.3 Summary of uncertainty presented in the national programmes 77 Table 5.4 Summary of information submitted to the Commission under the NECD (separately

to national programmes) 79 Table 5.5 Summary of links between NECD programmes (and projections) and measures to

reduce greenhouse gas emissions 81 Table 6.1 Summary of the political and administrative procedure of adoption of the NECD

national programmes 96 Table 6.2 Summary of the level of consultation that took place during the preparation of each

Member States’ national programme and any problems or barriers that were encountered 102

Table 7.1 Summary of Member States’ National Programmes and the extent to which they meet the requirements of the NECD (

� = information provided/requirement met, X =

no information provided/requirement not met and �

/X = only partially reported) 108 Table 8.1 Summary of comments received from Member States on how the reporting

procedure under the NECD could be improved (Section 4 of the information request) 112 Table 8.2 Recommendations taken into account in preparation of reporting guidelines 117 Table 8.3 Examples of priority indicators taken from Annex II of the Monitoring Mechanism

implementing provisions 119

Figure 3.1 Summary of relevant Member State reporting requirements up to 2010 12 Figure 3.2 SO2 - Comparison of CAFE baseline emissions for 2010 with Member States’ BAU

NECD emission projections (100% equates to each Member States’ NECD emission projections for SO2) 21

Figure 3.3 NOx - Comparison of CAFE baseline emissions for 2010 with Member States’ BAU NECD emission projections (100% equates to each Member States’ NECD emission projections for NOx) 22

Figure 3.4 VOC - Comparison of CAFE baseline emissions for 2010 with Member States’ BAU NECD emission projections (100% equates to each Member States’ NECD emission projections for VOC) 23

Figure 3.5 NH3 - Comparison of CAFE baseline emissions for 2010 with Member States’ BAU NECD emission projections (100% equates to each Member States’ NECD emission projections for NH3) 24

Figure 4.1 SO2 - BAU and BBAU emission projections as a proportion of each Member States’ NEC (100% equates to each Member States’ NEC for SO2) 29

Figure 4.2 NOx - BAU and BBAU emission projections as a proportion of each Member States’ NEC (100% equates to each Member States’ NEC for NOx) 29

Figure 4.3 VOC - BAU and BBAU emission projections as a proportion of each Member States’ NEC (100% equates to each Member States’ NEC for VOC) 30

Figure 4.4 NH3 - BAU and BBAU emission projections as a proportion of each Member States’ NEC (100% equates to each Member States’ NEC for NH3) 30

Figure 8.1 Proposed structure of guidelines (* = mandatory under the NECD) 116

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Appendix A Member State Analyses Appendix B Profiles of Member States national programmes & other submissions Appendix C Copy of Information Request Appendix D Information received from Member States – political & administrative procedure of

adoption of national programmes

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1. Introduction

1.1 This Report Entec UK has undertaken a project for the European Commission (Contract No. 070402/2004/383810/MAR/C1) to support the review of Directive 2001/81/EC, referred to as the National Emission Ceilings Directive (NECD). This report serves as a final report for the project and outlines Entec’ s progress and final conclusions for Task 1 of the contract (‘In-depth analysis of the NECD National Programmes’ ).

1.2 Project Summary

1.2.1 Background – The National Emission Ceilings Directive The objectives of the NECD are based on the Commission’s communication on a strategy to combat acidification (COM(97)88 final), which sought to set NECs for four pollutants causing acidification and eutrophication and ozone precursors. The NECs pay regard to critical levels and loads, in order to provide fuller protection for the environment and human health against their adverse effects. A key requirement of the Directive, as stated in Article 4, is that by 2010 Member States must limit national annual emissions of sulphur dioxide (SO2), nitrogen oxides (NOx), volatile organic compounds (VOCs) and ammonia (NH3) to the ceilings specified for each Member State, presented in Annex I of the directive.

The purpose of the NECs is to broadly meet Community-wide interim environmental objectives for the reduction of exceedences of critical loads of acid deposition and ground-level ozone critical levels for human health and vegetation.

Implementation of the NECD requires Member States to develop national programmes for the progressive reduction of the relevant pollutants, in addition to the provision of information on the likely impact of policy measures on emissions in 2010. The NECD further requires Member States to provide annually updated emission inventories and emissions projections for 2010, which will subsequently be made available to all other Member States.

Articles 9, 10 and 12 of the NECD set out the requirements for a review of the national emissions ceilings, incorporating further investigation of costs and benefits of achieving the ceilings. The Commission must report in 2004, 2008 and 2012 to the European Parliament and the Council on progress on the implementation of the ceilings and towards attaining the interim environmental objectives and the long-term objectives set by the Directive.

The Commission has decided to link the review of the Directive with the preparation of the Clean Air For Europe (CAFE) Thematic Strategy on air pollution, which is required under the Sixth Environmental Action Programme. Many of the projects commissioned under the CAFE Program will provide input to the NECD review.

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1.2.2 Task 1 Scope and Objectives Articles 6, 7 and 8 of the NECD set down the reporting requirements for Member States for their national programmes and emission inventories and projections. Member States are required by the Directive to inform the Commission of their national programmes for the first time by 31st December 2002. Under Article 6(2), the Directive states that national programmes should include:

‘..information on adopted and envisaged policies and measures and quantified estimates of the effect of these policies and measures on emissions of the pollutants in 2010. Anticipated significant changes in the geographical distribution of national emissions shall be indicated.’

The New Member States must prepare and submit national programmes under the NECD by 1 October 2006. Those Member States who submitted a programme in 2002 are required to ‘… update and revise…’ their national programmes, as required, by this date.

Task 1 of this NECD Review involves an in-depth analysis of the national programmes submitted to the Commission. This includes an inter comparison of the programmes themselves, an assessment of the consistency of the programmes with other plans and programmes (for example, national programmes for mitigating greenhouse gas emissions), an assessment of the methodology, quality and comparability of the emission projections and an assessment of the administrative and political procedure of adoption of the national programmes in each Member State.

Outputs from Task 1 include the results from each of the described analyses as well as proposals for additional essential questions for each Member State and proposals for guidelines for preparing national programmes under the NECD to ensure harmonisation for future rounds of reporting.

1.3 Structure of the Report The structure of this report is as follows:

• Section 2 describes Entec’ s assessment procedure and presents a profile of each national programme;

• Section 3 summarises the results of the comparison of the national programmes with other plans and programmes;

• Section 4 presents the inter comparison of the national programmes;

• Section 5 presents an in depth analysis of the emission projections reported by each Member State;

• Section 6 describes the political and administrative procedure of adoption of the NECD national programmes based on information gathered through an information request that was sent out to each Member State;

• Section 7 summarises Entec’ s proposals for additional essential questions for each Member State, based on the results of the comparisons; and

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• Section 8 describes Entec’ s proposals for guidelines for reporting under the NECD.

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2. In Depth Analysis of NEC National Programmes

2.1 Information sources and availability All of the national programmes submitted to date under the NECD (excluding Ireland, Greece and Belgium - Walloon Region) are available on the Commission’ s website2. The European Environment Agency has already produced an initial assessment of all NECD national programmes (excluding Belgium as only two of the three regions had submitted any information) submitted by 1st December 2003 (EEA, 2004). Since then, Ireland, Luxembourg and the Walloon Region of Belgium have prepared and submitted draft or final versions of their programmes to the Commission. For the purposes of this study draft versions have been assessed where final versions are not yet available. Greece has not yet submitted a national programme.

Task 1 involves an inter-comparison of the NEC national programmes with other submissions for each Member State. The Technical Annex of the Tender Specification details the following submissions for the NEC national programmes to be assessed against:

• air quality plans or programmes reported under the ambient air quality Directives (96/62/EC);

• national programmes to mitigate greenhouse gas emissions, reported under the Monitoring Mechanism and its implementing provisions and reporting requirements;

• national plans reported under the Large Combustion Plant Directive (LCPD);

• national plans reported under the VOC Solvents Directive; and

• CAFE baseline scenario available in the RAINS Model3.

Table 2.1 on the following page highlights the availability of the NEC national programmes and these other submissions listed above. However, no Member States are yet obliged to submit national implementation plans under the VOC Solvents Directive according to contact with the Commission Services (EC, 2004).

2 Available at: http://europa.eu.int/comm/environment/air/nationalprogr_dir200181.htm

3 Available online at: http://www.iiasa.ac.at/web-apps/tap/RainsWeb/index.html

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Table 2.1 Availability of NEC national programmes and other submissions for EU15 Member States

Aus

tria

Bel

gium

Den

mar

k

Finl

and

Fran

ce

Ger

man

y

Gre

ece

Irel

and

Italy

Luxe

mbo

urg

Net

herl

ands

Por

tuga

l

Spa

in

Sw

eden

Uni

ted

Kin

gdom

National programmes reported under the NECD

�

�

�

�

�

�

-

�

(draft only)

�

�

�

�

�

�

�

Air quality plans/programmes reported under the ambient air quality Directive (96/62/EC)

-

�

- - - - - - - - - - -

�

�

National programmes for mitigating GHG emissions reported under the Monitoring Directive and its amendments and implementing provisions and to the UNFCCC

�

�

�

�

�

�

�

�

�

�

�

�

�

�

�

National plans reported under the LCP Directive (2001/80/EC) - - -

�

�

- �

�

- - - - - -

�

National plans reported under the VOC Solvents Directive (1999/13/EC)

- - - - - - - - - - - - - - -

CAFE baseline scenario (RAINS Model)

�

�

�

�

�

�

�

�

�

�

�

�

�

�

�

Key:

�

Available

- Not Available

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2.2 National programme profiles The NEC national programmes were each assessed according to the following criteria:

1. General description of the plan and the data/information presented.

2. Pollutants included.

3. Scenarios presented – has more than one scenario been presented? For example, business as usual (BAU), beyond business as usual (BBAU) etc.

4. Sectoral scope – what level have emissions/projections/measures etc. been presented to? Have they been presented for each CORINAIR SNAP (Selected Nomenclature for sources of Air Pollution) or NFR (Nomenclature For Reporting) source sectors? What sectors have been targeted for emissions reductions?

5. Emission projections – summary of data presented. What methodologies have been used to make these projections? For example, have they followed the EMEP/CORINAIR guidebook? What assumptions have been made? To what extent have existing and additional measures to reduce greenhouse gas emissions been included in each Member States’ projections?

6. Measures – what measures have been presented? For which sectors? What types of abatement and policy measures have been presented? Have they quantified the potential emissions reductions and/or justified/provided evidence for these reductions? Have they quantified costs?

7. Implementing body?

8. Current status of implementation?

9. Implementation timetable?

10. Procedures for monitoring and implementation – how will it be enforced? How has the national programme been implemented? For example, have the public and/or stakeholders been consulted?

11. Are the measures proposed sufficient to meet that country’s NECD targets?

12. Uncertainty – has it been addressed and quantified? Has more than one scenario been presented to reflect the uncertainty in the projections?

13. NECD Requirements – have all requirements of the Directive been met?

• Article 6 paragraph 2 of the NECD: ‘national programmes should include information on adopted and envisaged policies and measures and quantified estimates of the effect of these policies and measures on emissions of the pollutants in 2010. Anticipated significant changes in the geographical distribution of national emissions should be indicated.’

• Article 8 paragraph 1 relating to emissions projections: ‘Member States shall…report their national emissions inventories and their emission projections for 2010...Emission projections shall include information to enable a quantitative understanding of the key socio-economic assumptions used in their preparation.’

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The aim of these assessments is to build on the EEA study (2004) as well as updating the analysis where Member States have submitted new or updated national programmes or provided further information since that study. For example, at the time of the EEA assessment, Belgium and Luxembourg had not yet submitted national programmes and Denmark has since submitted an updated national programme.

The information obtained from these assessments is relevant to both the comparison with other submissions (Section 3) and the inter-comparison of the NEC national programmes (Section 4). This analysis also forms the basis of Entec’ s proposals for additional essential questions for each Member State in Section 6 as it highlights where a Member State does not appear to meet one or more of the requirements of the NECD. A summary table and the individual Member State detailed assessments are presented in Appendix A.

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3. Consistency of NEC national programmes with other submissions

3.1 Introduction

3.1.1 Summary of information reported in each submission The matrix on the following page summarises the type of information contained within each submission assuming that all requirements, where relevant, have been met.

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Table 3.1 Summary of the type of information contained in each submission if all reporting and best practice requirements have been met

Are specific guidelines provided for format and scope of reporting?

Pollutants included

Sectoral scope

Summary of emissions projections

Assumptions behind projections

Scenarios presented

Information on abatement measures

Uncertainty

National programmes reported under the NECD

No – Article 6 of the NECD briefly sets out information that should be reported

SO2, NOx, VOC, NH3 Emissions for NFR/SNAP Level 1 source sector categories

Projections should be presented for 2010

Quantitative info on the key socioeconomic assumptions behind the projections should be provided

At least a BAU scenario. If ceilings are projected to be exceeded then further scenarios must be reported

Programmes must include info on current and future policies and measures. Their impact on emissions in 2010 must also be quantified

Level of uncertainty in data should be reported (in quantitative terms where possible)

Air quality plans and programmes reported under the ambient air quality Directives (96/62/EC)

Draft version – ‘Recommendations on plans or programmes to be drafted under the AQFWD (96/62/EC)’ (draft version, 2003) Summary report / questionnaire format available

To date reports have only been submitted under the 1st DD - SO2, NO2, PM10, Lead

Dependent upon reasons for exceedences of LV’s (generally transport or industry related)

Estimates of expected ambient air concentration of pollutants in 2005 and 2010 reported if LVs are likely to be exceeded

- No specific scenarios presented – generally just an indication of whether or not LVs are being, or will be, exceeded without further action

If an exceedence of an LV has been measured or is anticipated in the future then measures to reduce emissions from the source(s) responsible must be reported

Requirements for accuracy of data are specified

National programmes for mitigating GHG emissions reported under the Monitoring Directive and to the UNFCCC

Detailed guidelines available for preparation of national communications for submission to the UNFCCC. Article 3 of the Monitoring Mechanism sets out specific reporting requirements

Primarily CO2, CH4, N2O, HFC’s, PFC’s and SF6. Data on emissions of CO, SO2, NOx and VOCs should also be submitted

Countries must report using the Common Reporting Format (CRF)

Projections must be presented for the 6 greenhouse gases up to 2020 on a sectoral basis

Quantitative info on all of the socioeconomic assumptions behind the projections must be provided

A ‘with measures’ and ‘with additional measures’ projections must be must be provided

Detailed information on current and future measures must be provided including impacts on emissions and costs

Article 3.2 of the Monitoring Mechanism requires a sensitivity analysis to be carried out for the projections

National plans reported under the LCP Directive (2001/80/EC)

Recommended contents and structure for report including all table formats available

SO2, NOx, dust (PM) LCPs >50MWth licensed before 1 July 1987

Annual emission targets for 2008-2015, 2016-2017 and 2018 onwards must be provided for those plants included in the national plan

- - The measures that will be implemented to achieve the emission targets must be presented. The quantitative impact of these measures must also be reported

-

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Are specific guidelines provided for format and scope of reporting?

Pollutants included

Sectoral scope

Summary of emissions projections

Assumptions behind projections

Scenarios presented

Information on abatement measures

Uncertainty

CAFE baseline scenario (RAINS Model)

- SO2, NOx, VOC, NH3, PM10, PM2.5

RAINS source sectors – data also available broken down by SNAP and NFR source sector categories

2000-2020 Information available on abatement control scenarios, socio-economic assumptions (PRIMES model), fuel data and costs

3 scenarios presented (with and without climate policies and taking into account official national energy projections where available)

Abatement efficiency and future take up of abatement technologies available for each scenario. Costs info also available

-

National plans reported under the VOC Solvents Directive (1999/13/EC)4

No – Article 6 of the Directive sets out the type of information that should be reported

VOC Solvent use: all activities described in Annex I of the Directive when operated above specific thresholds (defined in Annex II)

Justification must be provided that existing installations will not exceed maximum allowed total annual emissions by 31 October 2007

- - Plans must include a list of current or future measures that will ensure the requirements of the Directive are met. Evidence that these measures will be enforceable and details of how the plan will be monitored must also be provided.

-

4 No Member States have yet submitted national implementation plans under the VOC Solvents Directive according to contact with the Commission Services (EC, 2004).

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3.1.2 Timeline of reporting requirements Member States have a series of reporting obligations up to 2010 under the NECD and related legislation. These are summarised in Figure 3.1 below.

Figure 3.1 Summary of relevant Member State reporting requirements up to 2010

2005 2006 2007 2008 2009 2010

National programmes 1 Oct National Emission Ceilings Directive (NECD) (2001/81/EC)

National emission inventories and emission projections for 2010 31 Dec 31 Dec 31 Dec 31 Dec 31 Dec 31 Dec

CLRTAP national emission inventories 15 Feb 15 Feb 15 Feb 15 Feb 15 Feb 15 Feb

Air quality plans and programmes reported under 1st Daughter Directive (Note 1)

Ambient Air Quality Directives (96/62/EC) Air quality assessment annual

reporting for 1st Daughter Directive (Note 1)

30 Sep 30 Sep 30 Sep 30 Sep 30 Sep 30 Sep

National programmes detailing emission projections and policies and measures to mitigate emissions

15 Mar 15 Mar 15 Mar EC GHG Monitoring Mechanism National emission inventories and

information on indicators 15 Jan 15 Jan 15 Jan 15 Jan 15 Jan 15 Jan

National plans

Member States are only obliged to submit national emission reduction plans under the LCPD for existing plants if they do not choose to adopt the Emission Limit Value (ELV) approach. National plans should have been submitted by November 2003 (EU-15).

Large Combustion Plant Directive (LCPD) (2001/80/EC)

Annual emission inventories 30 Sep 30 Sep 30 Sep 30 Sep 30 Sep 30 Sep

National plans

As with the LCPD, Member states are only obliged to submit national plans under this Directive if they do not choose to adopt the ELV approach. Once a plan has been submitted it must be resubmitted (updated if necessary) to the Commission every three years.

Solvent Emissions Directive (SED) (1999/13/EC)

Reporting on implementation of the Directive 30 Sep 30 Sep

Sulphur Content of Liquid Fuels Directive (SCLFD) (1999/32/EC)

Member States must submit a report to the Commission on the sulphur content of the liquid fuels covered by the Directive.

30 Jun 30 Jun 30 Jun 30 Jun 30 Jun 30 Jun

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2005 2006 2007 2008 2009 2010

Nitrates Directive (91/676/EEC)

Member States must submit a report to the Commission every 4 years including information on good agricultural practices, nitrate vulnerable zones, water monitoring and action programmes for these vulnerable zones.

30 Jun 30 Jun

Reporting on implementation of the Directive 31 Dec 31 Dec 31 Dec Water

Framework Directive (2000/60/EC) River basin management plans

Note 1: Attainment programmes must be prepared where there is a risk of the limit values being exceeded. There are also annual reporting obligations under the 1st, 2nd and 3rd Daughter Directives.

This summary of reporting obligations related to the NECD highlights the burden of reporting that Member States are faced with, particularly around the start and end of each year.

3.2 Air Quality Plans and Programmes reported under the Ambient Air Quality Framework Directive (96/62/EC)

3.2.1 Introduction Directive 96/62/EC provided the framework for a series of Daughter Directives, each containing the specific air quality limit and threshold values for the pollutants listed in the Framework Directive. Under the requirements of the Daughter Directives, Member States are requested to produce ‘attainment programmes’ for areas where the limit values will not be met without further action. These programmes must be made publicly available and submitted to the Commission. Up until the Draft Final Report (February 2005) air quality plans under the first Daughter Directive made available to Entec covered only Belgium (all regions), Sweden and the UK. To date (March 2005), Denmark, Germany and Spain have recently submitted air quality plans whilst Belgium, Sweden and the UK have reported new and/or updated plans.

A comparison was carried out to assess the consistency of reporting of policies and measures in Air Quality and NECD plans and programmes. All air quality plans received by the Draft Final Report stage (February 2005) were assessed. Due to the limited timescales of the study, it has been possible for only one additional plan (that submitted by Spain) to be included in the analysis. This comparison is presented on a country-by-country basis in Appendix B and summarised in Section 3.2.2 below.

3.2.2 Comparison A detailed comparison was undertaken between Member States’ NECD programmes and their air quality plans and programmes reported under the Air Quality Framework Directive.

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This information, on a country by country basis, is presented in Appendix B. The table below summarises the results of this comparison.

Table 3.2 Summary of comparison between Member States’ NECD programmes and reporting under the Ambient Air Quality Framework Directive

Belgium – Brussels Capital Region

Air quality plan refers to Brussels Capital Region’s air quality and climate change programme (submitted under the NECD) and the 81 measures it contains. Therefore, the two documents are entirely consistent.

Belgium – Flanders Region All of the policies and measures described in the air quality plan have also been presented in the NECD programmes for the Flanders Region and/or the Federal Authority (note: measures presented in the Federal Authority Plan apply to all regions of Belgium).

Belgium – Walloon Region No specific policies and measures have been presented in the air quality plan so it is not possible to check for consistency with the region’s NECD programme. Reference is made to the Walloon Air Plan which is still under discussion.

Spain Air quality plan presents some measures to reduce emissions of SO2 from a power plant. None of these measures have been included in Spain’s NECD national programme.

Sweden Air quality plan includes a number of policies and measures to reduce emissions of NO2 and PM10 predominantly aimed at transport. The majority of these have also been reported in Sweden’s programme under the NECD (note: Sweden’s air quality plan was submitted almost a year after their NECD programme and includes measures for PM10 which are not covered by the NECD).

UK The UK’s air quality plan presents a series of local, national and European policies and measures that are already in place to reduce emissions of SO2, NOx and PM10. Only the European policies and measures presented have also been reported in the UK’s NECD programme.

Belgium (Brussels Capital and Flanders) and Sweden have generally reported policies and measures consistently. None of the specific measures included in Spain’ s air quality plan have been reported in its NECD programme. Furthermore, the UK has reported a number of local and national policies and measures that have not been included in their NECD programme. Information on measures in the air quality plan for Belgium (Walloon) is not available.

3.3 National Programmes for mitigating Greenhouse Gas Emissions reported under the Monitoring Directive and its amendments and implementing provisions and to the UNFCCC

3.3.1 Introduction Member States have a series of reporting requirements set down in Decision No 280/2004/EC of 11 February 2004 concerning a mechanism for monitoring Community greenhouse gas emissions and for implementing the Kyoto Protocol. This has replaced Council Decision 93/389/EEC as amended by Decision 99/296/EC.

Article 2 of Decision 99/296/EC - now replaced by Article 3 Paragraph 2 of Decision No 280/2004/EC - requires Member States to produce, implement and periodically update

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national programmes for limiting and/or reducing their anthropogenic emissions by sources and enhancing removals by sinks of all greenhouse gases not controlled by the Montreal Protocol. Both include specific requirements for the reporting of all policies and measures, emissions projections and the assumptions and methodologies used.

Parties to the United Nations Framework Convention Climate Change (UNFCCC5) are required to submit national communications (in depth national programmes detailing actions to reduce emissions of greenhouse gases) approximately every 3-5 years. Annex I countries (including all of EU-15) submitted their third national communications between 2001-2003 and the fourth national communications are due in 2006.

To date (February 2005), all EU-15 Member States have submitted some information under the Monitoring Mechanism and national communications to the UNFCCC.

A comparison has been undertaken on the extent to which existing and additional policies and measures to reduce greenhouse gases have been taken into account in NEC emission projections (Section 5.5). A further comparison was carried out to assess the consistency of reporting of information in each of the programmes focussing on the sectors targeted for emissions reductions, socioeconomic assumptions behind the emission projections and more general aspects relating to the content of the programmes themselves (for example, the reporting of uncertainty). This is presented on a country-by-country basis in Appendix B and summarised in Section 3.3.2 below.

3.3.2 Comparison An in-depth comparison of the policies and measures presented in the NECD national programmes with those presented in each Member States’ reports to the UNFCCC and under the Monitoring Mechanism was undertaken and is presented in Section 5.5. This comparison highlighted the general lack of consistency between the two sets of reports. A large proportion of measures presented in Member States’ greenhouse gas/climate change programmes could result in considerable benefits for air quality and complying with their NECs (for NOx and SO2 in particular), yet very few have actually been reported in their NECD programmes. Overall (for EU15 excluding Greece), approximately 70% of policies and measures presented in Member States’ national communications to the UNFCCC could potentially have benefits (direct or indirect) for air quality. The majority of these measures impact upon emissions of SO2 and NOx, in particular, through improvements in energy efficiency and a cleaner more efficient transport system.

A detailed comparison was undertaken between Member States’ NECD programmes and their greenhouse gas reports under the Monitoring Directive and to the UNFCCC. This information, on a country by country basis, is presented in Appendix B. The comparison focussed on other areas of the different reports including the socioeconomic assumptions behind the emission projections, sectors targeted for emission reductions, emission projections, scenarios presented and the reporting of uncertainty. The table below, which was completed for each Member State (see Appendix B), summarises the general differences between the two types of reports.

5 http://www.unfccc.int/

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Table 3.3 Summary of reports submitted under the NECD, Monitoring Mechanism and to the UNFCCC

GHG Programme NECD programme

Socioeconomic assumptions

In general, detailed information is provided with respect to the socioeconomic assumptions behind the emission projections (for example, GDP, population, fuel prices, energy consumption).

Very few countries have reported any of the socioeconomic assumptions behind their emission projections. Some only report one or two parameters.

Several countries refer to separate documents where the information is contained. Others state that the scenarios used for their greenhouse gas emission projections have formed the basis for their emission projections.

Sectors targeted Main sectors targeted are residential & commercial, energy, waste, transport, industry, agriculture & forestry.

Main sectors targeted are energy, transport, agriculture, residential, solvent use, industry, petrol storage & distribution, waste incineration & recovery & NRMM.

Status of implementation

Generally reported for majority of policies and measures (adopted, implemented, planned or proposed).

Level of reporting varies considerably between programmes. Some clearly identify existing and additional measures whereas others do not make that distinction.

Implementing body

Generally reported for majority of policies and measures (wide range of bodies responsible).

Level of reporting of implementing body is relatively poor. Policies and measures implemented by central Government are generally much better reported than those implemented by other bodies.

Pol

icie

s an

d M

easu

res

Quantified impact Generally reported for majority of policies and measures (impact on emissions in 2010 minimum).

Level of reporting of quantitative impact of individual policies and measures is relatively poor for most countries. Very few countries report the impact of all, or at least most, of their policies and measures. Most countries tend to report overall impact of policies and measures.

Scenarios With measures and with additional measures. Varies considerably between programmes. Most countries report at least a ‘with measures/BAU’ emissions scenario. Very few, however, report the impact of additional measures.

Projections Generally reported for each individual greenhouse gas (CO2, at least) and, for some, broken down by sector (generally by IPCC source sectors or similar – energy (energy supply, industry & construction, transport & other energy), industrial processes, solvents & other products, agriculture, land use change & forestry and waste & others).

Generally reported for all four NECD pollutants. Majority of countries have presented emission projections broken down by sector although the sectoral split is not consistent between programmes and pollutants. Sectors generally reported include energy, transport, agriculture, solvent use & industry.

Uncertainty Very limited information reported with only a few countries reporting quantitative estimates of the uncertainty associated with their emission inventories and projections.

Very limited information reported with only France reporting quantitative estimates of the uncertainty associated with their emission projections.

The level of reporting with respect to the socioeconomic assumptions behind the emission inventories and projections, descriptions of each policy and measure and their quantitative impacts and the emission projections is generally much higher under European and International greenhouse gas reporting obligations than under the NECD. Greenhouse gas programmes tend to include clear descriptions of the policies and measures that are included in each scenario plus the body responsible for their implementation, their current status of implementation and a quantitative estimate of their potential impact. The level of

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consistency between different Member States’ greenhouse gas programmes is also generally much better.

Where the socioeconomic assumptions behind the emission projections have been reported in both greenhouse gas and NECD programmes and are easily comparable (ie. similar statistics and units), they were found to be consistent. The sectors targeted by both programmes also tended to be similar with policies and measures presented to reduce emissions from the energy, industry, transport, agriculture, waste, domestic and commercial sectors. The main differences are those sectors which are specifically aimed at reducing VOCs as the policies and measures proposed for these sectors tend to have no, or very little, impact on emissions of greenhouse gases. These include controls on solvent use and content and the distribution and storage of petrol.

The level of sectoral split of emission projections presented in each submission tends to be more consistent for greenhouse gases between Member States than for NECD pollutants, although projections are reported for very similar sectors for both sets of pollutants. These include energy, industry, solvent use, transport and agriculture.

An important point to note is that all parties to the UNFCCC are encouraged to submit a translation of their national communications in English (UNFCCC, 2000) to streamline the process of assessment and comparison and standardise the format for reporting. Only Spain has not reported to the UNFCCC in English. In contrast, programmes submitted under the NECD have been reported in several different languages, with only half submitted in English.

3.4 National Plans reported under the Large Combustion Plant Directive (LCPD)

3.4.1 Introduction Directive 2001/80/EC aims to reduce emissions of acidifying pollutants and ozone precursors and therefore its goals are directly in line with the NECD.

For existing plants (those licensed before 1 July 1987), Member States may choose, by 1 January 2008, to either:

• comply with the Emission Limit Values (ELV) set down in the LCPD; or

• produce and implement a national emission reduction plan.

National plans should reduce the total annual emissions of SO2, NOx and dust to the levels that would have been achieved by applying the ELVs in the LCPD to exisitng plants in operation in the year 2000, on the basis of each plant’ s operational performance averaged over the last five years of operation up to and including 2000. National plans should specify the measures that will be implemented to ensure that this is achieved.

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To date (March 2005), of the EU-15 Member States, Finland, France, Greece, Ireland and the UK have submitted national plans under the LCPD6. Spain is also intending to implement a national plan (Entec, 2004).

A comparison was carried out to assess the consistency of reporting of policies and measures and emission projections in plans and programmes reported under the LCPD and NECD. This is presented on a country-by-country basis in Appendix B and summarised in Section 3.4.2 below.

3.4.2 Comparison A detailed comparison was undertaken between Member States’ NECD programmes and, where submitted, their national plans reported under the LCPD. This information, on a country by country basis, is presented in Appendix B. Only Finland, France, Ireland and the UK have submitted national plans under the LCPD as well as NECD programmes. The comparison carried out between the two sets of programmes focussed on the emission targets calculated for the LCPD plan and the measures proposed for meeting them. As very few countries have presented detailed sectoral emission projections, limited comparisons could be carried out.

Finland For Finland the emissions target for existing LCPs from 2008 onwards is much lower than the projected emissions for 2010 from ‘energy generation’ . However, the LCPD plan only includes existing plants (pre 1987) > 50MWth and there are also various derogations available for plants to opt out of the plan. Finland’ s NECD programme does refer to the LCPD but at the time of its preparation the route by which the LCPD was to be implemented was undecided. Therefore, no specific, more technological, measures which have been presented in the LCP plan to reach their emission targets have been presented in the NECD programme.

Finland have recently re-submitted their LCPD plan to the Commission so this comparison will re-evaluated for the final report and any changes will be highlighted.

France France’ s plan under the LCPD does not describe any of the measures that will be taken to comply with their emission targets so a comparison cannot be undertaken with their NECD programme. Their NECD programme does, however, report the LCPD as an existing measure but also proposes a further tightening of the limit values as a potential additional measure.

Ireland The emission targets presented in Ireland’ s LCPD plan that are to be met from 2008 are consistent with the emission projections presented in their NECD programme. Ireland’ s NECD programme does report the LCPD as an existing measure but states that it is unclear whether or not an emissions reduction plan will be implemented to meet the requirements of the Directive for existing plants (Ireland’ s NERP was prepared several months after their

6 The Czech Republic and Slovenia have also submitted national plans under the LCPD.

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NECD discussion paper). The programme does, however, present a series of specific measures targeted at the power generation sector which have also been reported in Ireland’ s NERP. These include the use of flue gas desulphurisation, reduced sulphur content of fuel, improved energy efficiency and selective catalytic reduction (SCR). Therefore, the measures reported in both submissions are almost 100% consistent.

The only measure presented in the NECD programme relating to LCPs that has been quantified is the installation of SCR at one power plant by 2010 (reduction in NOx emissions of 8kt). Ireland’ s NERP estimates the installation of SCR and low-NOx burners at this plant will reduce emissions by approximately 16kt per annum between 2008-2015.

UK At the time of writing, the UK has recently provided a revised submission to the Commission in relation to its National Plan under the LCPD. This is currently being considered by the Commission.

The UK’ s NECD national programme does not report specific measures under the LCPD but does refer to the Directive as a policy to help comply with the NECD. However, at that time the route by which the UK was planning to implement the LCPD had not been decided so no more specific policies and measures could be reported.

3.5 CAFE Baseline Scenario (RAINS Model)

3.5.1 Introduction As part of the development of the Thematic Strategy on Air Quality under the CAFE programme, IIASA have developed a series of baseline emission scenarios using the RAINS model (IIASA, 2004). Three major emissions scenarios have been developed and are presented in RAINS WEB version August 2004 (Aug04):

• BL_CLE_Aug04: The Baseline scenario without climate policies. Uses "Energy and Transport - Trends to 2030" of DG Transport and Energy and Europe-wide consistent projections of agricultural activities without CAP reform.

• CP_CLE_Aug04: Climate policy scenario. Energy projection "with climate measures" developed with the PRIMES model. Incorporates to the maximum possible extent national perspectives, while maintaining Europe-wide consistency in assumptions about energy prices, electricity exports and imports etc. For agriculture, a revised version of Europe-wide consistent projections of agricultural activities without CAP reform is used.

• NAT_Aug04: Official national energy projections with climate policies and national agricultural projections (if supplied by Member States7). Assumptions for other countries are the same as in the Climate policy scenario (RAINS WEB, August 2004)

7 National energy pathways have been made available to IIASA for Belgium, Czech Republic, Denmark, Finland, France, Italy, Portugal, Slovenia, Sweden and the United Kingdom.

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National emissions data for these three scenarios is available disaggregated by several different source sector categories including SNAP Level 1 (all pollutants) and UNECE NFR (SO2, NOx and VOC only) categories. The scenarios themselves have been developed through a series of bilateral consultations between IIASA and the Member States and stakeholders and are available for all Member States.

The CAFE baseline scenarios consider a wide range of European and national legislation for reducing emissions of the four NECD pollutants. This legislation is summarised in the table below.

Table 3.4 Summary of legislation considered for the CAFE baseline scenarios (IIASA, 2004a)

Pollutant Legislation

SO2 • Large Combustion Plant Directive

• Sulphur Content of Liquid Fuels Directive

• Directives on quality of petrol and diesel fuels

• IPPC legislation on process sources

• National legislation and national practices (if stricter)

NOx • Large Combustion Plant Directive

• Auto Oil EURO Standards

• Standards for motorcycles and mopeds

• Legislation on non-road mobile machinery

• Implementation failure of EURO-II and II for HDVs

• IPPC legislation on process sources

• National legislation and national practices (if stricter)

VOC • Stage I Directive

• Directive 91/441 (carbon canisters)

• Auto Oil EURO Standards

• Fuel Directive (RVP of fuels)

• Solvents Directive

• Product Directive (paints)

• National legislation (for example, Stage II controls)

NH3 • No EU-wide legislation

• National legislation

• Current practice

A comparison was carried out comparing the emission projections for each pollutant reported by each Member State and presented in the CAFE baselines. The legislation considered for the CAFE baseline scenarios, presented in the table above, was compared with the policies reported

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in each Member State’ s NECD programme to highlight any potential inconsistencies between the two sets of emission projections.

3.5.2 Comparison Figures 3.2-3.5, below, present the 2010 emissions data for the three CAFE baseline scenarios as a proportion of each Member States’ BAU (‘with measures’ ) emission projections under the NECD so that 100% on each of the figures equates to that country’ s NECD projection. A value above this line means that the CAFE emissions data is higher than the NECD projection and vice-versa. The NAT_Aug04 scenario has only been compared where official national energy projections have been made available to IIASA (Belgium, Denmark, Finland, France, Italy, Portugal, Sweden and the UK).

SO2

Figure 3.2 SO2 - Comparison of CAFE baseline emissions for 2010 with Member States’ BAU NECD emission projections (100% equates to each Member States’ NECD emission projections for SO2)

0%

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AT BE DK FI FR DE GR IE IT LU NL PT ES SE UK

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BL_CLE_Aug04 (Aug04) CP_CLE_Aug04 (Aug04) NAT_Aug04 (Aug04)

The graph above shows that, for all but one country (and scenario), the CAFE baseline emissions projections for 2010 are lower than the BAU NECD projections reported by each Member State. To date (February 2005), no emissions projections have been reported by Spain. The majority of Member States’ emission projections are within approximately 25% of the projections included in the CAFE baseline scenarios. However, for some countries, such as Denmark and Greece for example, the emission projections differ by around 50%. Emission projections submitted by Greece under the NECD indicate that SO2 emissions in 2010 are likely to be less than 300kt although no specific figure was quoted. For the purposes of this study, 300kt was used as the likely level of emissions of SO2 in Greece in 2010. The only exceedence

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of a country’ s NECD emission projections is for the BL scenario for Luxembourg although this only equates to a difference of approximately 0.5kt.

With respect to the legislation taken into account in the CAFE baseline scenarios for SO2 (listed in Table 3.4), the majority of countries have reported the LCPD and SCLFD in their NECD programmes but the level of reporting of IPPC and Directives on fuel quality is much lower.

NOx

Figure 3.3 NOx - Comparison of CAFE baseline emissions for 2010 with Member States’ BAU NECD emission projections (100% equates to each Member States’ NECD emission projections for NOx)

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Figure 3.3 shows that, aside from Luxembourg, Greece and Sweden, the majority of Member States’ NECD emission projections for NOx are very similar to those reported in the CAFE baseline, generally less than 10% difference. CAFE emissions data for Sweden and Luxembourg are higher than that reported under the NECD with differences of approximately 34-42kt (23-35%) and 11-14kt (77-98%), respectively. The NAT_Aug04 scenario for Sweden is the closest to the figures reported under the NECD. For Finland, Italy, Portugal and the UK this is also the case. In contrast, for Belgium and Denmark, the emissions data under the NAT_Aug04 scenario shows the greatest differences to the projections reported under the NECD.

With respect to the legislation taken into account in the CAFE baseline scenarios for NOx (listed in Table 3.4), the majority of countries have reported the LCPD and Euro vehicle emission standards in their NECD programmes but the level of reporting of IPPC and legislation on NRMM is much lower.

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VOC

Figure 3.4 VOC - Comparison of CAFE baseline emissions for 2010 with Member States’ BAU NECD emission projections (100% equates to each Member States’ NECD emission projections for VOC)

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The graph above shows that, for all but two countries, the CAFE baseline emissions projections for 2010 are lower than the BAU NECD projections reported by each Member State for VOCs. The majority of country’ s emission projections are within approximately 25% of the projections included in the CAFE baseline scenarios. The biggest differences occur, as for all other pollutants, for Greece, with their NECD emission projections differing by almost 40%.

With respect to the legislation taken into account in the CAFE baseline scenarios for VOCs (listed in Table 3.4), the majority of countries have reported the Solvents Directive and Euro vehicle emission standards in their NECD programmes but the level of reporting of the Stage I petrol vapour recovery and Product Directives is much lower.

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NH3

Figure 3.5 NH3 - Comparison of CAFE baseline emissions for 2010 with Member States’ BAU NECD emission projections (100% equates to each Member States’ NECD emission projections for NH3)

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ject

ions


The variation between Member States’ NECD projections and the CAFE baseline scenarios is much greater for NH3 than for the other pollutants although the majority of differences are less than 20%. CAFE baseline emissions projections for eight countries are higher then the corresponding NECD projections whilst the remaining six are lower. The CAFE emissions projections under the NAT_Aug04 scenario tends to differ slightly less to the NECD projections than the other scenarios although the difference is relatively small. The biggest differences occur, as for all other pollutants, for Greece, with their NECD emission projections differing by over 25%.

There is no EU-wide legislation relating to agriculture that has been taken into account in the CAFE baseline scenarios (only national legislation and current practice - see Table 3.4).

3.6 Summary / Conclusions This comparison of the NECD national programmes with other submissions has revealed a varying level of consistency of reporting under different obligations as well as between Member States.

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• Although very few countries have so far submitted plans or programmes under the Air Quality Framework Directive, these tended to be fairly consistent with the NECD programmes with respect to the policies and measures reported. For example, the plan produced by the Brussels Capital Region of Belgium refers to the programme submitted under the NECD and all of the measures listed.

• The level of consistency between Member States’ NECD programmes and reports to the Monitoring Mechanism and UNFCCC varies considerably between countries. The greatest inconsistencies involve the policies and measures reported in each submission. A large proportion of measures reported in Member States’ greenhouse gas reports are also likely to reduce emissions of NECD pollutants and vice-versa. However, no single country has consistently reported all relevant measures in both submissions (although a few countries have reported a majority of relevant measures).

• All countries that have reported national plans under the LCPD have also presented the Directive as an existing policy in their NECD programmes although only Ireland has also presented some of the more specific technological measures that make up the plan. Around the time that the NECD programmes were being prepared, Member States had not yet specified and/or decided how they were planning on implementing the LCPD for existing plants so specific measures would not have been reported (with the exception of Ireland).

• A comparison between the CAFE baseline and NECD emission projections showed a huge level of variation, not just between each Member States’ figures but also between pollutants.

- SO2 - For all but one country (and scenario), the CAFE baseline emissions projections for 2010 are lower than the BAU NECD projections reported by each Member State (majority are within approximately 25%).

- NOx - Majority of Member States’ NECD emission projections are very similar to those reported in the CAFE baseline (generally less than 10% difference).

- VOC - For all but two countries, the CAFE baseline emissions projections for 2010 are lower than the NECD projections reported by each Member State (majority are within approximately 25%).

- NH3 - Variation between NECD and CAFE baseline projections is much greater for NH3 than for the other pollutants although the majority of differences are less than 20%.

• The comparison also further highlighted the lack of consistency of reporting of policies and measures in NECD programmes as very few countries have reported the majority of legislation considered for the CAFE baseline scenarios. Confirmation should be sought from those Member States not reporting all of the legislation in Table 3.4 in their NECD programmes that it has all been taken into account in their emission projections.

It is important to note that these different submissions are quite often prepared at different times, sometimes with gaps of two or more years. Therefore, the policies and measures presented and the assumptions behind the emission projections can be expected to change over time as more information becomes available and new priorities for action are identified.

These comparisons have highlighted not only the inconsistencies between different submissions, but also the similarities with respect to the type of data reported, the sectors and even the pollutants targeted. Air quality plans and programmes reported under the Air Quality

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Framework Directive deal predominantly with reducing emissions of SO2, NOx and PM10 and the majority of policies and measures could potentially impact upon total national emissions thus linking into the NECD. The comparison between greenhouse gas and NECD programmes highlighted the overlapping of policies and measures with respect to the sectors they target and reduction in emissions of multiple pollutants. Both sets of programmes should also include information on the socioeconomic assumptions behind the emission projections and provide a ‘with measures’ and ‘with additional measures’ scenario. Several countries have actually based their NECD emission projections on their greenhouse gas scenarios reported under the Monitoring Mechanism and to the UNFCCC. For plans reported under the LCPD, the level of consistency was relatively limited as the NECD programmes have been prepared before the route by which the LCPD would be implemented in each country had been decided. However, the policies and measures that have been presented to meet the emissions reduction targets in each LCPD plan will play a major role towards each country meeting their NECs.

The policies and measures reported in each of these submissions, including the NECD programmes, will generally have an impact on, and contribute towards, meeting all of the objectives. The reporting of these could potentially be combined for all relevant submissions although the greatest scope for potentially combining submissions in the future lies with greenhouse gas reporting to the Monitoring Mechanism.

A review has already been undertaken by the EEA and Meteorological Synthesising Centre - West (MSC-W) of the emissions data reported to CLRTAP and under the NEC Directive (EMEP/EEA, 2004). One aim of the study was to review the comparability of the two inventories by checking the consistency of the emissions data reported. The review makes recommendations for further investigation of the potential for harmonising the NEC reporting deadline with the CLRTAP submission requirements. This recommendation has been made to look at the possibility of Member States/Parties to the Convention only producing one submission rather than two. The study also recommends improved co-ordination and co-operation between the Commission, UNECE and EEA to improve the reporting process.

The potential to combine or link-in NECD reporting with other submissions and improve consistency between submissions is explored in greater detail in Section 8 (Proposals for guidelines for reporting under the NECD).

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4. Inter-Comparison of NEC National Programmes

4.1 Progress to NEC Targets Table 4.1 below presents the emission projections included in each Member State’ s national programme or, where available, updated projections submitted to the Commission under the requirements of the NECD relative to that country’ s NEC target. BAU projections have been compared as well as BBAU projections if they are available. A positive value (also shaded) in the table indicates an exceedence of the emission ceiling and a blank cell indicates that no projections were available. Member States that are on course to achieve an emission ceiling without further actions have no obligation to present the impact of additional measures (BBAU).

Table 4.1 Comparison of Member States projections and NEC targets

SO2 (kt) NOx (kt) VOC (kt) NH3 (kt)

BAU1 BBAU2 NEC BAU1 BBAU2 NEC BAU1 BBAU2 NEC BAU1 BBAU2 NEC

Austria4 -7 39 +47 +38 to 43 103 +1 159 -13 66

Belgium3 +48 to 51

-45 to -46 99 +37 to

42 -9 to -19 176 +21 to

24 -12 to -18 139 -1.5 -2 74

Denmark3 +1 -2 55 +19 +10 127 -2 -4 85 +14 +9 69

Finland4 -13 110 -19 170 0 130 0 31

France3,4 +86 -14 375 +178 +30 810 -96 -97 1,050 +77 +17 780

Germany3,4 -11 -11 520 +73 -38 1,051 +197 -21 995 +35 -5 to -25 550

Greece4 -223 523 0 344 0 261 0 73

Ireland3 +0.1 -9 42 +29 +17 65 +11 +1 55 -6 -6 116

Italy3 -6 475 +67 990 -42 1,159 +14 419

Luxembourg3 -2 4 +3 -0.1 11 -2 -3 9 -1 7

Netherlands3,4 +20 -9 50 +29 +5 260 +35 -6 185 -1 -18 128

Portugal5 -15 to -21 160 -18 to

-30 250 +21 to 42 180 -5 to

-6 90

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SO2 (kt) NOx (kt) VOC (kt) NH3 (kt)

BAU1 BBAU2 NEC BAU1 BBAU2 NEC BAU1 BBAU2 NEC BAU1 BBAU2 NEC

Spain6 -330 746 +123 847 +128 662 +29 353

Sweden4 0 67 0 148 0 241 0 57

UK4 0 585 0 1,167 0 1,200 0 297

Total -449 to -458

-686 to -693 3,850 +556

to 573 +184 to 211 6,519 +272

to 296 -13 to -40 6,510 +141

to 142 -2 to +19 3,110

EC 15 -233 to -242

-470 to -477 3,634

+1,152 to

1,169

+780 to 807 5,923

+1,201 to

1,225

+889 to 916 5,581

Note 1: Business-As-Usual (BAU) – includes the impacts of implemented or due to be implemented policies and measures.

Note 2: Beyond Business-As-Usual (BBAU) – includes the impacts of additional / proposed policies and measures.

Note 3: Projections presented in the national programme.

Note 4: Projections submitted to the Commission under the NECD (separately to the national programme).

Note 5: Projections presented at ‘Workshop on plans and programmes under air quality and NEC Directives (Brussels, September 2004).

Note 6: No emissions projections were presented in the national projection. A comparison was undertaken between the CAFE baseline data (BL_CLE_Aug04) for 2010 and Spain’s NEC targets.

Although information in Table 4.1 for Belgium is presented at a country level, the implementation of NECD programmes is carried out a regional level and four individual programmes have been submitted to the Commission (the Federal Authority and the Walloon, Flemish and Brussels Regions). Belgium’ s NEC targets have been divided between the three regions and the transport sector. Each region is responsible for complying with its own emission ceilings whilst the transport emission ceiling applies to the whole of Belgium. The split of ceilings between the regions and the transport sector and each region’ s progress towards meeting them is described in detail in Appendix A2.

Figures 4.1-4.4 present, for each NECD pollutant, Member States’ projected emissions (BAU and BBAU) as a proportion of their emission ceilings so that 100% equates to the NEC. A projection which is greater than 100% of the NEC equates to an exceedence of the ceiling and vice-versa. Displaying the emission projections in this manner, as a proportion rather than an absolute value, makes it possible to compare across Europe the additional efforts that are still required to ensure each Member State complies with its NEC (‘level playing field’ ).

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Figure 4.1 SO2 - BAU and BBAU emission projections as a proportion of each Member States’ NEC (100% equates to each Member States’ NEC for SO2)

0%

20%

40%

60%

80%

100%

120%

140%

160%

AT BE DK FI FR DE GR IE IT LU NL PT ES SE UK EU14

% o

f NE

C

BAU Projections BBAU Projections

Figure 4.2 NOx - BAU and BBAU emission projections as a proportion of each Member States’ NEC (100% equates to each Member States’ NEC for NOx)

0%

20%

40%

60%

80%

100%

120%

140%

160%


% o

f NE

C


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Figure 4.3 VOC - BAU and BBAU emission projections as a proportion of each Member States’ NEC (100% equates to each Member States’ NEC for VOC)

0%

20%

40%

60%

80%

100%

120%

140%


% o

f NE

C


Figure 4.4 NH3 - BAU and BBAU emission projections as a proportion of each Member States’ NEC (100% equates to each Member States’ NEC for NH3)

0%

20%

40%

60%

80%

100%

120%

140%


% o

f NE

C


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4.2 Are measures proposed sufficient to meet NEC targets? Only Finland, Greece, Sweden and the UK are projected to comply with all of their NEC targets by 2010 without the need for further actions beyond those already planned under business as usual policy commitments (based on the most up to date emission projections). However, emission projections for both Sweden and the UK are identical to their emission ceilings for all pollutants and for 2 and 3 of the pollutants for Finland and Greece, respectively. Any slight increase in emissions will therefore result in an exceedence of the ceiling. The uncertainty associated with compiling emission projections could mean that the NEC(s) could potentially be exceeded. With additional proposed measures, Belgium, Germany and Luxembourg will also achieve all of their NECs.

SO2 Aside from Spain, which has yet to submit any emission projections for 2010, only 5 countries are projected to exceed their emission ceiling without further action (Belgium, Denmark, France, Ireland and the Netherlands). However, all 5 of these countries are projected to achieve their targets with additional efforts (BBAU). CAFE baseline emissions data for Spain for 2010 (BL_CLE_Aug04 scenario) was compared with Spain’ s emission ceilings to gain an idea of progress towards their targets. For SO2, Spain is projected to achieve its NEC by over 330kt. If this data is included in the total EU15 emissions, then the EC 15 emission ceiling from the NECD is projected to be achieved with relative ease (by approximately 6% and 13% under BAU and BBAU, respectively).

Figure 4.1 reinforces the fact that most Member States appear to be well on track towards meeting their SO2 emission ceilings with many countries not requiring the implementation of additional measures beyond those already planned. This is mainly driven by the level of European legislation focussing specifically on sulphur in fuels (for example, Directive 1999/32/EC) and the impact that this has already had, and will have in the future, on sulphur emissions, particularly in the energy and transport sectors. Furthermore, the LCPD is expected to have a significant impact on SO2 for some Member States.

NOx The situation for NOx is somewhat different with only 5 of the 14 countries (15 if including the CAFE data for Spain) projected to comply with their NOx emission ceilings in 2010 under a BAU scenario (Finland, Greece, Portugal, Sweden and the UK). CAFE baseline data for Spain indicates that it is likely to exceed its NEC for NOx if no further actions are taken (an exceedence of over 120kt). Under BBAU, the situation does not improve significantly with only a further 3 countries projected to now comply with the emission ceiling (a total of 8, just over 50%) although Italy has not yet presented a BBAU scenario. Unsurprisingly, the EC15 emission ceiling from the NECD (including the CAFE baseline data for Spain) is projected to be exceeded by a great extent, even under a BBAU scenario (over 15%/900kt).

Figure 4.2 highlights just how challenging the NOx NECs are, with several countries way above their emission ceilings even with the implementation of additional measures. Even those countries that are projected to comply with their NOx NEC will only just meet the target. Therefore, any slight increases in emissions could therefore result in an exceedence of the emission ceiling. NOx is a by-product of combustion and, unlike SO2, cannot be reduced simply through changing the fuel composition. Instead, technological changes are required to

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either alter the conditions for combustion thus reducing the formation of NOx (for example, waste gas recirculation, low NOx burners) or to remove NOx from the waste gases (for example, selective catalytic reduction).

VOC Figure 4.3 shows that most countries are on course to meet their VOC emission ceilings and the exceedences are relatively small compared to those for the NOx ceiling, for example (see figure 4.2). 6 countries are projected to exceed their VOC emission ceiling without additional measures (7 when comparing the CAFE data for Spain). With additional measures, 3 countries (Austria, Ireland and Portugal) are still projected to exceed the ceiling although Austria and Ireland only exceed the ceiling by 1kt. However, Austria and Portugal have not yet presented BBAU emission projections. As the ceiling is exceeded by a relatively small amount, Austria should be able to comply with its VOC ceiling without much additional effort. It is unclear if Ireland will be able to reduce its emissions by a further 1kt as the impact of additional measures have already been taken into account and emissions have been reduced by approximately 10kt.

The EC15 emission ceiling from the NECD (including the CAFE baseline data for Spain) is projected to be exceeded by up to 1,200kt (over 20%) even taking into account the impact of additional measures (over 15%/900kt). The EC15 NEC for VOC is almost 1,000kt less than the sum of each Member States’ emission ceilings. Comparing the EU15 total emission projections against the sum of each individual ceiling shows that under BAU this sum will be exceeded by almost 300kt. With additional measures, however, the sum of all Member States’ NECs will just be achieved.

NH3 Only 4 of the 14 countries that have submitted emission projections for 2010 are projected to exceed the emission ceiling for NH3 (Denmark, France, Germany and Italy). For Spain, the CAFE baseline data shows that the emission ceiling will also be exceeded by approximately 29kt. Under BBAU, Denmark and France still expect to exceed their NH3 emission ceilings (by 9kt and 17kt, respectively) and Italy has not submitted any BBAU projections. Both Denmark and France will have to implement further measures, beyond those already discussed in their national programmes, if they are to reduce their NH3 emissions sufficiently to comply with the NECs. No EC15 emission ceiling for NH3 has been specified in the NECD. However, comparing the total emissions projections against the sum of the individual NECs shows that, at an EU15 level, this is likely to be exceeded even with additional measures.

4.3 Scenarios Presented The majority of Member States have only presented a ‘with measures’ / BAU scenario although in several cases the policies and measures included in the projections are not entirely clear. France, Belgium (all regions), Germany, the Netherlands, Luxembourg (NOx and VOC only) and Ireland have all presented projections including the estimated impact of additional policies and measures. Although Denmark did not present the impact of additional measures in their national programme itself, reference was made to an additional document (Danish MoE, 2002) which included BBAU emissions projections, so these have been presented for comparison. Spain is the only country not to present any emissions projections for 2010 in its national programme.

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The different regions of Belgium (Brussels Capital and Flanders, in particular) have all presented emission projections for a number of different scenarios although they are not consistent between each of the regions. The programme for the Brussels Capital region presents a series of four BAU scenarios, each taking into account different assumptions including varying increases in the number of houses, changes in split of energy sources and growth in energy consumption. Emissions from transport in the region have also been presented for a series of different scenarios taking into account varying levels of transport growth and congestion. The programme for the Flanders Region presents emission projections for 3 different scenarios (excluding NH3): reference, planned and maximum feasible reduction scenario. Two different scenarios have been presented for transport.

As Finland, Greece, Sweden and the UK are the only countries that are on course to meet all of their emission ceilings by 2010 without the need for further actions they have no requirement to report BBAU emissions projections. However, emissions projections presented by each country for many of the pollutants (all for Sweden and the UK) are exactly the same as their emission ceilings. Any slight increases in projected emissions (through real increases in emissions, changes in methodology for making calculations and/or the level of uncertainty involved) will therefore result in an exceedence of the emission ceiling. For this reason, countries that are projected to only just comply with their emission ceilings should be encouraged to report additional measures that could be implemented and their quantitative impacts.

4.4 In depth analysis of policies and measures reported by each Member State

4.4.1 Sectors targeted for emission reductions The sectoral scope of the national programmes varies considerably between Member States with some presenting emissions and measures for a wide range of source sectors and sub sectors and others only presenting total national emissions. This is addressed in greater detail in Section 4.4.8. Table 4.2, below, summarises the sectors targeted for emission reductions by each Member State, as reported in its national programme.

Table 4.2 Summary of sectors targeted for emission reductions in each national programme

BAU (‘with measures’) BBAU (‘additional measures’)

Austria Energy (LCPs & SCIs1), Transport (road), Solvent Use, Waste Incinerators, Industry, Domestic (heating), & Agriculture.

No information provided.

Belgium – Federal Gov.

Domestic, Solvent Use, Transport (road, rail & ships), NRMM, Industry, Energy & Agriculture.

Federal Government plan only includes measures to be implemented between 2000-2003.

Belgium – Brussels

See Belgium – Federal Government. Transport (road), Solvent Use, Energy, Domestic, Industry, Petrol Storage & Distribution, Waste Incineration & Construction.

Belgium – Flanders

See Belgium – Federal Government.

Plus Petrol Storage & Distribution, Petroleum Refineries, Waste Incineration & Chemicals.

Energy (electricity sector), Chemicals, Iron & Steel, Industry & Refineries.

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BAU (‘with measures’) BBAU (‘additional measures’)

Belgium – Walloon

See Belgium – Federal Government.

Plus Waste Incineration & Recovery & Petrol Storage & Distribution.

Domestic & Commercial, Energy, Chemicals, Iron & Steel, Cement, Glass, Lime & Paper Industries, Solvent Use, Transport (road) & Waste Recovery.

Denmark Energy (energy supply & LCPs), Transport (road), Waste Incineration, Industry, Solvent Use & Agriculture.

Solvent Use, Energy, Transport (road) & Agriculture.

Finland Energy, Transport (road), Agriculture, NRMM, Industry & Domestic (wood burning stoves & fires).

No information provided (all ceilings expected to be met with BAU).

France Industry, Energy, Waste Incineration, Transport (road), NRMM, Petrol Storage & Distribution & Solvent Use.

Energy, Industry, Transport (road), NRMM, Domestic, Tertiary & Agriculture.

Germany Energy, Industry, Solvent Use, Waste (combustion, disposal & recycling), Petrol Storage & Distribution, Domestic, Transport (road) & Agriculture.

Transport (road), NRMM, Energy, Solvent Use & Agriculture.

Ireland Energy (LCPs), Transport (road), Industry, Residential/Commercial (S-content of coal), Solvent Use, NRMM, Petrol Storage & Distribution & Agriculture.

Energy (LCPs), Residential/Commercial, Transport (road), Industry, Petrol Storage & Distribution, Solvent Use & Agriculture.

Italy Energy (LCPs), Transport (road), NRMM, Petrol Storage & Distribution & Solvent Use.

Industry, Transport (road, maritime), Solvent Use, Energy & Agriculture.

Luxembourg Solvent Use, Agriculture, Petrol Distribution & Transport (road).

Solvent Use, Energy, Commercial/Institutional Combustion, Industry (metal works, cement & flat glass), Transport (road & air) & NRMM (agricultural engines).

Netherlands National programme focuses primarily on additional reduction measures rather than those that have already been, or a due to be, implemented.

Some specific sectors that are briefly mentioned include: Energy (LCPs), Industry, Transport (road), Domestic, Agriculture & Solvent Use.

Industry, Energy, Transport (maritime & road), Solvent Use & Agriculture.

Portugal Transport (road), Energy, Waste (packaging & landfill), Petrol Storage & Distribution, Solvent Use & Agriculture.


Spain Solvent Use, Energy, Industry, Petrol Storage & Distribution, Transport (road & aviation) & Agriculture (implemented measures).

Transport (road & promotion of other forms of transport), Solvent Use, Energy & Agriculture (planned or proposed measures).

Sweden Energy, Domestic (small scale wood burners), Solvent Use, Transport (road, aviation & maritime), NRMM & Agriculture.

Transport (road & pleasure boats), Domestic (small scale wood burners), NRMM, Solvent Use & Agriculture.

UK Industry, Solvent Use, Energy (LCPs), Transport (road).

No information provided (all ceilings expected to be met with BAU).

Note 1: Small Combustion Installations (SCIs)

Under BAU the majority of countries present measures relating to the key European Directives so, in general, the same sectors have been targeted. These include Energy (for example, LCPD), Transport (for example, EURO vehicle standards), Solvent Use (for example, Solvents Directive

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99/13/EEC), Industry (for example, IPPC) and Petrol Storage and Distribution (for example, Directive 94/63/EEC). However, as Table 4.2 on the previous page shows, not all Member States have presented measures targeting all of these sectors under BAU.

4.4.2 Types of policy measures presented In the initial assessment of the NECD national programmes by the EEA (EEA, 2004), the consistency of reporting of key European Directives which are already, or in the process of being, implemented varied considerably between each Member State’ s national programme. Table 4.3 on the following page, taken from the EEA report and updated to include information for Belgium, Ireland and Luxembourg which had not submitted a national programme at the time of the study, highlights this inconsistency in reporting. For example, only 5 Member States have reported the Directives relating to waste incineration (94/67/EC and 2000/76/EEC) yet 13 of the fourteen countries have presented the Solvents Emissions Directive (99/13/EEC) and 12 the LCPD (2001/80/EC) in their national programmes.

As Table 4.3 shows, the level of reporting of each of the Directives listed is not consistent between the programmes prepared for each of the regions of Belgium or by the Federal Government. No single Directive has been reported in all four of the Belgian programmes.

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Table 4.3 Level of reporting of European Directives in the NECD national programmes (EEA, 2004 and updated)

European Directives

Pol

luta

nts

affe

cted

Aus

tria

Bel

gium

Den

mar

k

Finl

and

Fran

ce

Ger

man

y

Irel

and

Italy

Luxe

mbo

urg

Net

herl

ands

Por

tuga

l

Spa

in

Sw

eden

UK

Num

ber

Rep

ortin

g

IPPC 96/61/EC All

�3, 4 �

�

�

�

�

�

7

Fuel sulphur content 1999/32/EC SO2

�1 �

�

�

�

�

�

�

�

�

�

11

Large Combustion Plant Directive 88/609/EEC now replaced by 2001/80/EC

SO2, NOx

�

�4 �

�

�

�

�

�

�

�

�

�

12

Quality of petrol & diesel fuels Directive 98/70/EC

SO2

�

�

�

�

�

5

Directives 94/67/EEC & 2000/76/EEC on waste incineration

SO2, NOx

�

�4 �

�

�

5

Petrol Storage & Distribution 94/63/EC

VOC

�3, 4

�

�

�

�

�

�

�

8

Limitation of emissions of VOCs from organic solvents 99/13/EEC

VOC �

�3, 4

�

�

�

�

�

�

�

�

�

�

�

13

EURO vehicle standards I-V 98/69/EC

SO2, NOx, VOC

�2 �

�

�

�

�

�

�

�

�

10

Labelling & limitation of solvents in products COM(2002)750

VOC

�1, 4

�

�

�

�

�

6

Notes: 1 – Directive referenced in Federal Government Programme, 2 – Brussels Capital Region, 3 – Flanders Region & 4 – Walloon Region.

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Additional measures presented in the national programmes predictably focus on the key emitting sectors which will play the most important roles in whether a country meets its emission ceilings or not. These include road transport (for example, incentivisation of cleaner technology/vehicles, promotion of sustainable transport), energy (for example, further reductions beyond the LCPD – installation of new technology), solvent use (for example, further restrictions on solvent use and contents of products) and agriculture (for example, best practice/guidance and improved manure management).

Table 4.4 below summarises the different types of policy measures presented in the national programmes.

Table 4.4 Summary of types of policy measures presented in the national programmes (�

= 5 or less,

�� = 6-10 and

�� = more than 10 measures reported)

Reg

ulat

ory

Eco

nom

ic

Vol

unta

ry

Agr

eem

ents

Fis

cal

Pro

mot

ion

&

Pub

licity

Info

rmat

ion

/ E

duca

tion

Gui

danc

e /

Bes

t Pra

ctic

e

Austria � � �

Belgium – Federal Gov. ��

Belgium – Brussels ��

Belgium – Flanders ��

Belgium – Walloon ��

Denmark ��

Finland ��

France ��

Germany ��

Ireland ��

Italy ��

Luxembourg � � � � ��

Netherlands ��

Portugal ��

Spain ��

Sweden ��

UK ��

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The scoring for the number of different types of policy measures reported in the programmes is based on those measures for which sufficient information has been provided to be able to classify them into one or more of the categories in the table on the previous page.

All countries have reported some regulatory policies in their national programmes. In general, these were those related to emission limit values (such as the LCPD, Euro vehicle standards) or regulations on the quality of fuel (such as the Sulphur Content of Liquid Fuels Directive). Fiscal policies and measures were also reported by all but 3 of the Member States; these generally included incentives for the introduction of new, cleaner technology such as power plant abatement equipment or vehicles fulfilling future Euro standards before they are legislatively required.

4.4.3 Summary of abatement measures presented Table 4.5 on the following page summarises the different types of abatement measures presented for reducing emissions to comply with the NEC targets.

The most popular types of abatement measures reported in Member States’ national programmes were those related to:

• Fuel quality (for example, the Sulphur Content in Liquid Fuels Directive);

• Emission limit values (for example, the LCPD and Euro vehicle emission standards);

• Energy efficiency (for example, measures to promote, financially or otherwise, energy efficiency measures in the residential, commercial and industrial sectors);

• Abatement technology (for example, the installation of selective catalytic reduction (SCR) at LCPs); and,

• Controls on solvent use and content (for example, the Solvents Directive).

A large proportion of measures reported (those aimed at improving energy efficiency, in particular) will also have impacts on greenhouse gas emissions as well as NECD pollutants so will be more attractive and cost effective to a Member State compared to other pollutant-specific policy and measures.

Only the Netherlands has included emissions trading as a possible future measure to reduce emissions of SO2 (industry, energy and refineries) and VOC (industry). The Netherlands has also developed a NOx emissions trading scheme for large installations in the industry, energy, refineries and waste processing sectors. Petrochemical plants, refineries and power plants > 20 MWth capacity will trade in permits based on emissions per unit of energy whereas permits for steel, aluminium, cement, saltpetre and phosphate plants as well as incinerators will be based on emissions per product unit. The offshore oil and gas industry is expected to join the scheme in 2009 (VROM, 2004). This trading scheme will be used to meet the industry-specific emission ceiling for NOx of 55kt by 2010, a reduction in emissions of approximately 40% (VROM, 2004a). The NOx Emissions Trading Bill has been considered by Parliament and will come into force in 2005 (VROM, 2005).

Aside from the Netherlands who have set emission targets for each key source sector (Industry/Energy/Refineries, Households, Services/Construction, Agriculture and Transport), three other countries have implemented, or are proposing to implement, sector specific emission ceilings. Ireland and Sweden have proposed setting ceilings for industry to reduce emissions of

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SO2. Belgium has set an emission ceiling for transport as well as for each Federal region in its approach to complying with the NECD. For the Flanders Region, these emission ceilings have then been further subdivided on a sector by sector basis. The overall transport emission ceiling for Belgium has also been split between each region.

A breakdown and analysis of the policies and measures reported for each key source sector is presented in Section 4.4.8.

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Table 4.5 Summary of abatement measures presented in the national programmes to comply with the NEC targets

Fue

l qua

lity

(incl

udin

g S

co

nten

t)

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4.4.4 Overview of emission reductions of policies and measures Very few countries have presented the impact that individual policies and measures have on emissions of SO2, NOx, VOC and NH3. The Belgium Federal Authority, Finland, Ireland, Luxembourg, Sweden and the UK have all quantified the impact of at least one of the policies and measures that have been presented in their national programmes. Germany, Portugal and the Netherlands have quantified the impact of the majority of measures reported. The consistency of reporting of measures, and the way in which they have been described, makes it impossible to carry out a comparison between countries.

The EEA study (2004) highlighted this lack of consistency and the problems encountered when trying to compare the effectiveness of different measures. Although the study tries to present the quantified impact of different measures, the majority of measures are only applicable to individual countries and are not consistent with those reported in other national programmes. Since the study was carried out, Belgium (all regions), Ireland and Luxembourg have prepared national programmes under the NECD. Although the programmes submitted by these three countries (for Belgium only the Federal Authority programme) do attempt to quantify the impact of some of their policies and measures their additional impact does not change the situation as reported by the EEA (2004):

• For SO2, the key policies and measures where the potential emission reductions have been quantified are still IPPC and the Sulphur in Fuels Directive (1999/32/EC). These are estimated to reduce emissions by almost 200kt;

• For NOx, the key policies and measures reported are those aimed at transport. Every national programme presents at least one measure aimed at reducing emissions from this sector. For those countries that have quantified the impacts of these measures, emissions are likely to be reduced by approximately 200 kt in total. Other important measures include IPPC, measures aimed at NRMM and the EURO vehicle emission standards;

• For VOC, the key policies and measures reported are the Solvent Products Directive (COM(2002)750) and, to a lesser extent, the Solvent Emissions Directive (99/13/EC), limits on wood combustion and policies aimed at the transport sector; and,

• For NH3, the key policies and measures reported are predictably those relating to agriculture.

However, this summary is based on a very small level of reporting by around half of the countries that have submitted a national programme and must therefore be approached with caution. The impacts of measures such as those aimed at the energy sector (for example, LCPD) or to improve energy efficiency (for example, climate change programmes) have been poorly reported by most Member States yet should have a significant impact on emissions across Europe.

A key area for improvement for the next round of reporting under the NECD in 2006 should be a quantitative assessment of each individual policy or measure presented so that a more accurate picture of the emission reduction potential can be gained.

4.4.5 Costs Very few countries have presented any information on the costs involved with implementing and complying with the NECD. Ireland and the UK have presented some information on the

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total costs involved with implementing the NECD. The UK is on course to meet all of its NECs without further measures so the estimated additional costs are zero (although there may be some costs for meeting the SO2 ceiling depending upon the implementation of the LCPD - ¼�-40 million per annum). Ireland has estimated the total costs of implementing the NECD to be ¼��million (from 1990 baselines) whilst the benefits (reduced impact on buildings, agriculture, vegetation and human health) outweigh this at ¼��PLOOLRQ� KHQFH� DQ� RYHUDOO� EHQHILW� RI� ¼��million. Finland’ s national programme simply states that additional costs to comply with the NECD are not expected as all of the ceilings are projected to be met without further action.

Luxembourg has calculated the cost of individual additional measures for reducing emissions of NOx and VOC in the form of a cost curve. The marginal cost of the additional measures presented to meet Luxembourg’ s NOx emission ceiling is ¼��NJ�� 7KH� 1HWKHUODQGV� KDYH�presented the cost (¼�NJ�� RI� VRPH� RI� WKH� SURSRVHG� DGGLWLRQDO�PHDVXUHV�� 7KHVH� YDU\� EHWZHHQ�¼��NJ��IRU�D�SURSRVHG�H[WHQVLRQ�WR�92&�3URGXFW�'LUHFWLYH��WR�¼��NJ�IRU�WLJKWHQLQJ�WKH�VWDQGDUGV�for central heating boilers and coal and oil fired process installations.

The programme submitted by the Brussels Capital Region of Belgium includes a summary of the costs involved, and budgets available, for setting up the programme itself and implementation of some of the measures. The programme for the Flanders Region of Belgium presents the marginal cost per kg of pollutant emitted for achieving some of the sectoral specific emission ceilings. These vary from ¼��– 37.74/kg for NOx and ¼��– 27.37/kg for SO2 for the electricity sector and ¼��NJ�IRU�12x and ¼��– 17/kg for SO2 for refineries (dependent upon the scenario).

4.4.6 Implementing body, current status of implementation, implementation timetable and procedures for monitoring and implementation The level of reporting on the implementing body and status of implementation was relatively poor, particularly for measures that have not yet been adopted or implemented. This has also made it difficult to judge which policies and measures have been taken into account in different emission scenarios presented in the national programmes (ie. is it an existing or additional measure?). Very few Member States indicate the implementing body for individual policies and measures unless they are to be implemented by central Government (generally implementation of European legislation). Less than 6 countries have reported on the procedures in place for monitoring and implementing the programme and even fewer have provided any information on the expected implementation timetable.

Further information relating to procedures for monitoring, evaluation and implementation of each national programme was collected as part of an information request sent out to each Member State (excluding Greece which has not yet submitted a national programme). The information request focused on the political and administrative procedure of adoption of the national programmes. This is discussed in greater detail in Section 6.

4.4.7 Sector by sector overview

Introduction A specific requirement of the technical annex was to carry out ‘a comparative assessment of possible actions to reduce emissions of air pollutants on the European, national and local level, in order to have a better idea of the relative margin of action of each institutional level from the local up to the European level’ . The following sections summarise the key policies and

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measures that have been reported for the energy, transport, industry, solvent use, agriculture and waste sectors as well as any information that has been provided on emission reductions and costs.

Energy Table 4.7 summarises the policies and measures reported by each Member State in their national programmes aimed at reducing emissions in the energy sector. The institutional level (local, national and European) at which policies and measures have been and/or will be implemented is also summarised along with any quantitative information that has been reported relating to the impact on emissions and associated costs.

All of the Member States have reported at least one policy or measure to reduce emissions from the energy sector and the majority have reported many more. The most commonly reported policies and measures are those aimed at:

• Large combustion plants (for example, LCPD and associated abatement technology such as SCR, SNCR, desulphurisation and low NOx burners);

• Improving energy efficiency at all levels, reducing energy consumption and increasing the use of renewable energy sources (for example, local, regional and national energy action plans, promotion of cleaner technology and financial incentives/disincentives); and,

• Stage I (Directive 94/63/EC) & II controls to reduce evaporative emissions from the storage, transport and distribution of petrol.

Table 4.6, below, summarises the total potential impact on emissions and the range of cost effectiveness of the policies and measures that have been reported by Member States for the energy sector. It is outside the scope of this study to review or verify this reported data.

Table 4.6 Total potential impact on emissions and range of cost effectiveness of the policies and measures reported for the energy sector

SO2 NOx VOC NH3

Potential emission reduction by 2010 (kt)9 Up to 260 Up to 130 Up to 43 Up to 14

Cost effectiveness (�� 1.2-35.5 (measures to reduce LCP &

refinery emissions)

0.2-177.9 (measures to reduce LCP &

refinery emissions)

2574 (offshore wind turbine plant) -

Note that only half of the fourteen Member States to have submitted national programmes under the NECD have reported the quantitative impact on emissions of one or more of their policies and measures aimed at the energy sector and even less have reported any information on the

9 Note: Portugal has reported the impacts of IPPC and LCPD as a single figure so it is not possible to determine the individual impacts of each Directive. The data presented in this table includes this combined figure.

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associated costs (cost effectiveness) 10. The figures for NOx do not take into account the NOx trading scheme that is expected to commence in the Netherlands during 2005. This is expected to reduce NOx emissions by as much as 40% from large installations in the industry, energy, refineries and waste processing sectors.

Based on the limited information available, the greatest potential emission reductions in the energy sector are for SO2 and NOx, which is unsurprising considering that power generation in 2000 in EU25 contributed over 50% and 20% of emissions, respectively (Amann et al, 2004). The most cost effective measures appear to be those aimed at reducing SO2 emissions through measures such as the LCPD, low sulphur coal and desulphurisation of waste gases. The only cost data available for VOC is misleading as the measure reported – the construction of an offshore wind turbine plant – will be aimed at reducing fuel consumption and, indirectly, reducing emissions of NOx and SO2.

With the exception of the different regions of Belgium, the majority of Member States have reported European and national legislation which will be implemented at a national and installation/plant level by central government and the relevant sub-sectors (for example, the electricity sector). Several countries have also reported programmes for promoting and improving energy efficiency which, although co-ordinated at a national level, will be implemented by local and regional authorities at a local level.

10 Denmark has provided some cost data for additional measures in a separate document to its national programme (Danish Ministry of Environment, 2002).

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Table 4.7 Summary of the key policies and measures reported by each Member State aimed at reducing emissions from the ENERGY sector

Description of policies and measures reported in national programme Estimated impacts in 2010 (kt) Costs (

�� Scale of implementation

Austria

� SO2 & NOx Emission Limit Values (ELVs) for small & large combustion plants � Limits on sulphur content of fuels � Policies & measures to increase use of renewable energy sources (regulatory & voluntary agreements) � Regulations on domestic heating � Reduced biomass incineration outside of specific facilities

No information provided No information provided National policy implemented by local & regional authorities & at a plant level

Belgium – Federal

� NOx ELVs for new boilers, generators & burners � Tax cuts to incentivise energy efficiency � Reduced sulphur content of fuel oil � Grants to promote use of cleaner fuels for residential combustion � Measures to promote renewable & alternative energy (regulatory, fiscal & voluntary agreements)

NOx - 2.5 - SO2 - 5.7 - -

No information provided All policies & measures implemented by Federal Government


� Promotion of energy efficiency (energy audits, invoices & certification, publicity, availability of information) � Directives on insulation & energy for housing & commercial buildings � Voluntary agreements with sectors to reduce energy consumption � VOC Stage II controls at service stations

Emissions reductions associated with different scenarios reported – however unclear which measures included in each scenario

Costs associated with individual policies & measures have not been reported

Unclear – most policies and measures are probably the responsibility of the regional authority. Energy efficiency measures will be implemented at a local level


� Technological measures to reach emissions ceiling for electricity sector (NOx - 12.5 kt & SO2 – 6 kt): low NOx burners, SCR, SNCR, low sulphur coal, wet scrubbing � Technological measures to reduce refinery emissions: switch to LNG, low NOx burners, catalytic crackers, desulphurisation unit � Stage I & II controls for petrol stations & terminals

No information provided on the quantitative impact of individual policies & measures

NOx – 1.54 / SO2 – 3.38 NOx – 177.9 / SO2 – 1.2 -

Most policies & measures implemented by federal &/or regional authorities at an installation/plant level. Voluntary agreement with electricity sector

Belgium – Walloon

� LCPD � Directive 2002/91/EC - improved energy performance of buildings � Stage I & II controls to reduce evaporative emissions from the storage, transport and distribution of petrol � Regulation of small combustion installations � Voluntary agreement with electricity sector � Good management energy action plans and promotion of renewables


No information provided Unclear – most policies and measures are probably the responsibility of the federal &/or regional authorities

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Denmark

� Energy action plan � Statutory order no. 885 to limit LCP emissions � Statutory order no. 808 (implementation of LCPD) � SCR at LCP � Desulphurisation unit at LCP � Offshore wind turbine plants

- - - NOx – 6.46 SO2 – 2.29 NOx – 0.23 / SO2 – 0.51 / VOC – 0.01

- - - NOx – 1.8 SO2 – 0.7 SO2 – 35.5 / NOx – 78.7 / VOC – 2574

All policies and measures have been, or will be, implemented by central government at a national &/or site level

Finland

� National climate strategy (including promotion of renewable energy sources & energy conservation programme) � LCPD � ELVs for domestic combustion � Energy taxation � Subsidies for energy generated from renewable sources & investment grants

SO2 – 20 / NOx – 20

No information provided11

European & national policy implemented at a national & local level

France

� LCPD � Ministerial decree, July 1997, relating to small combustion installations � Stage I & II controls to reduce evaporative emissions from the storage, transport and distribution of petrol � Tightening of LCPD requirements � Further controls on small combustion installations � Incentives for low NOx boilers � Promotion of improved energy efficiency

No information provided No information provided European & national policy implemented at a national & installation level

Germany

� Ordinance on small combustion installations � LCPD � Stage I & II controls to reduce evaporative emissions from the storage, transport

and distribution of petrol � Promotion of renewable energy sources & use of biomass for energy production � Combined Heat & Power Act � Energy Savings Act & Ordinance � National Climate Change Programme � Tightening of LCP ELVs

SO2 – 26 / NOx – 3 / VOC – 4 SO2 – 60 / NOx – 51 / VOC – 8 - - - - - NOx – 6

No information provided European & national policy implemented at a national & installation level

11 No additional measures are required to comply with the NECD so no additional costs are anticipated.

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Ireland

� Market liberalisation with increased Combined Cycle Gas Turbines (CCGT) & Combined Heat & Power (CHP) � LCPD � Installation of cleaner & more efficient technology at LCPs (including FGD, SCR, � Introduction of cleaner & more efficient LCPs � Programmes to promote & improve energy efficiency & use of renewables � Sectoral emission ceiling for electricity sector (currently voluntary, proposals to make it mandatory) � Reduced sulphur content of fuels � Stage I (implemented) & Stage II (planned) controls to reduce evaporative emissions from the storage, transport and distribution of petrol � Incentives for more efficient boilers & improved energy efficiency

90% reduction in SO2 emissions with FGD. 8 kt NOx reduction with installation of SCR at one LCP. Stage II controls on petrol storage & distribution estimated to reduce VOC emissions to 10% of Stage I levels.

No information provided for individual policies & measures

Most policies and measures have been, or will be, implemented by central government. Certain measures aimed at the electricity sector and specific LCPs are the responsibility of the Irish Electricity Supply Board (ESB), individual plants and the Solid Fuel Trade Group (SFTG). Several energy efficiency programmes have been co-ordinated by Sustainable Energy Ireland (Ireland’s national energy authority).

Italy

� LCPD � Stage I controls to reduce evaporative emissions from the storage, transport and distribution of petrol (Directive 94/63/EC) � Ministerial decree April 2001 requiring electricity & gas distributors to meet energy efficiency targets through end users � Draft law on reform & reorganisation of the energy sector – increased renewables � Regional programmes promoting renewable sources & energy efficiency

No information provided No information provided

National policy implemented by central government & electricity & gas distributors. Energy efficiency programmes implemented at a regional level

Luxembourg

� Grand Ducal Regulation October 1996 – Stage I controls to reduce evaporative emissions from the storage, transport and distribution of petrol � Primary & secondary measures to reduce emissions from combustion including air or fuel staging, flue gas recirculation, SCR & SNCR � Reduced sulphur content of fuels & desulphurisation � Low NOx burners & SCR � Promotion of renewable sources of energy

- - - NOx – up to 1.28 -

- - - NOx - Up to 38 -

European & national policy implemented at an installation level

Netherlands

� Action plan for SO2 emissions from industry, energy & refineries � NOx emission trading scheme SO2 – 30 NOx – 40% reduction

SO2 – 4 -

National policy implemented by central government and individual installations

Portugal

� Directive 2001/77/EC – promotion of use of renewable energy sources � Programme E4 – energy efficiency & endogenous energy resources � Improved management of electricity production & distribution � LCPD � Expansion plan for electricity supply – improved energy efficiency � Programme P3E – energy efficiency in buildings � Solar heated water programme � Directive 94/63/EC – Stage I controls to reduce evaporative emissions of petrol

- SO2 – 8-17 / NOx – 5-6 - IPPC & LCPD: SO2 – 80 / NOx – 25-26 / VOC – 21-22 / NH3 – 13-14 SO2 – 8-17 / NOx – 4-5 SO2 – 0.53 / NOx – 1.7 NOx – 0.8-0.96 VOC – 8.0-8.5

No information provided European & national policy implemented by central government & energy suppliers

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Spain

� National plan for electricity & gas networks – improved energy efficiency � Directive 94/63/EC – Stage I controls to reduce evaporative emissions of petrol � LCPD � Law 54/1997 – improved energy efficiency � Plan for promotion of renewable energies

No information provided No information provided National & European legislation implemented at a national level by central government & electricity & gas suppliers

Sweden

� Energy tax � NOx tax � Improved energy efficiency & use of renewables � Local climate investment programmes & information campaign � Quota based electricity certification scheme � Local energy advice � Introduction of new energy efficient technology � Tighter ELVs for domestic combustion

No information provided No information provided Local, regional & national policies and measures implemented by local, regional & national authorities

UK � LCPD No information provided No information provided for individual policies & measures12

European legislation implemented by central government at a plant level

12 Total estimated costs for complying with NEC’ s are zero for all pollutants except SO2 (¼�-40m dependent upon implementation of the LCPD).

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Transport Table 4.9 summarises the policies and measures reported by each Member State in their national programmes aimed at reducing emissions in the transport sector. The institutional level (local, national and European) at which policies and measures have been/will be implemented is also summarised along with any quantitative information that has been reported relating to the impact on emissions and associated costs.

The transport sector, along with the energy sector, is one of the most targeted sectors with respect to the number and variety of different implemented and planned policies and measures reported by each Member State. The most commonly reported policies and measures for reducing emissions from the transport sector are those aimed at:

• Reducing the sulphur content and improving the quality of petrol and diesel (for example, the Sulphur Content in Liquid Fuels Directive);

• Reducing vehicle usage (for example, through improvements in public transport and green travel plans); and,

• Reducing vehicle emissions (for example, EURO vehicle emission standards and promotion of cleaner vehicles and fuels).

Sweden, in particular, has implemented or is planning some of the most innovative measures for the reduction of emissions from transport including congestion charging, eco-labelling (for boat engines and NRMM) and an aviation charging scheme aimed at the LTO cycle which has been in place since 1998.

Table 4.8, below, summarises the total potential impact on emissions and the range of cost effectiveness of the policies and measures that have been reported by Member States for the transport sector. It is outside the scope of this study to review or verify this reported data.

Table 4.8 Total potential impact on emissions and range of cost effectiveness of the policies and measures reported for the transport sector

SO2 NOx VOC NH3

Potential emission reduction by 2010 (kt) Up to 107 Up to 236 Up to 88 Up to 0.06

Cost effectiveness (�� 4626 5-1814 464-465 -

Note that only half of the fourteen Member States to have submitted national programmes under the NECD have reported the quantitative impact on emissions of one or more of their policies and measures aimed at the transport sector and only one has reported any information on the associated costs (cost effectiveness)13.

13 Denmark has also provided some cost data for additional measures in a separate document to its national programme (Danish Ministry of Environment, 2002).

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Based on the very limited information available, the greatest potential emission reductions in the transport sector are for SO2, VOC and NOx, in particular, as would be expected. The cost data reported is very limited (only three measures for two countries) and is possibly not reflective of the true situation. For example, the only cost data available for SO2 is for the introduction of 70,000 electrical vehicles in Denmark by 2010 and the figure is particularly high. The costs associated with other, possibly more effective, policies and measures to reduce SO2 emissions, such as the Sulphur Content in Liquid Fuels Directive, for example, have not been reported by any Member State.

A wide range of policies and measures have been reported by Member States including European and national legislation that is the responsibility of central government (for example, EURO vehicle emission standards) and local and regional measures to encourage sustainable transport and reduce vehicle usage (for example, green travel plans). These have been, or will be, implemented by a range of local and regional bodies including individual organisations and road users.

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Table 4.9 Summary of the key policies and measures reported by each Member State aimed at reducing emissions from the TRANSPORT sector


��

Scale of implementation

Austria

� Range of policies & measures aimed at reducing emissions from the transport sector (regulatory, voluntary, research, infrastructure changes) No information provided No information provided Local, regional & national authorities

Belgium – Federal

� Grants for conversion to LPG � Improved access to underground parking for LPG vehicles � Tax incentives for purchase of EURO IV & LPG vehicles � Availability of ultra low sulphur fuel (50ppm) � Annex VI of the Protocol of Marpol 73/78 to reduce emissions from sea transport � Measures to reduce ship emissions (regulatory, economic & legal) � Modernisation of rail fleet � Series of indirect measures to reduce vehicle usage & improve, integrate & promote public transport � Legislation to reduce sulphur content of fuel for Non-Road Mobile Machinery (NRMM)

No information provided No information provided All policies & measures have been, or will be, implemented by federal & regional authorities at a national & regional level


� Measures to improve & promote public transport and travelling by foot or by bicycle � Measures to reduce vehicle use in Brussels (park & ride, parking taxation) � Legislation & incentives to improve vehicle maintenance & purchase & use of cleaner vehicles � Improved traffic management



Unclear – most policies and measures are probably the responsibility of the regional authority & have been, or will be, implemented at a local & regional level


� Action plan to incentivise purchase & use of cleaner vehicles � Action plan to reduce car use & promote public transport


No information provided Policies & measures implemented by regional authorities at a regional level

Belgium – Walloon

� Incentives for use of public transport � Increased taxation for most polluting vehicles � Green transport plans � Support for new technology


No information provided

Unclear – most policies and measures are probably the responsibility of the regional authority & will be implemented at a local &/or regional level

Denmark

� EURO I-V vehicle emission standards � EGR filter installation (heavy duty vehicles < 10 years) � Electrical vehicles (70,000 by 2010)

- NOx – 2.84 / VOC – 0.61 SO2 – 0.02 / NOx – 0.05 / VOC – 0.20

- NOx – 102.9 / VOC – 464.4 SO2 – 4625.9 / NOx – 1814.0 / VOC – 465.0

All policies and measures have been, or will be, implemented by central government

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��


Finland

� Directive 98/70/EC – quality of fuels � EURO Standards I-V � Promotion of public transport, walking & cycling � Improved efficiency of freight transport

Combined impact: NOx – 110 / VOC – 50 No information provided European & national policy implemented

at a local & national level

France

� EURO Standards I-V � Sulphur content in liquid fuels Directive � Reduced sulphur content of NRMM fuels No information provided No information provided European & national policy implemented

at a national level by central government

Germany

� Sulphur content in liquid fuels Directive � Ordinance on Road Traffic Licensing � Taxation to encourage purchase & use of cleaner fuels & vehicles � National programme on ground level ozone concentration reduction � Further reductions in ELVs & incentives for purchase of cleaner vehicles & technologies � Labelling initiative for NRMM

- - - - NOx – 46 / VOC – 2.5 NOx – 34 / VOC - 15

No information provided European & national policy implemented at a national level by central government

Ireland

� EURO I-V vehicle standards � NRMM Directive � Sustainable transport strategy � Incentivisation of cleaner vehicles � Introduction of sulphur free fuels across whole market by 2010 � National climate strategy – removal of incentive for ‘fuel tourism’ � Further intensification of shift to sustainable transport

- - - - - VOC – 8 -


European & national policy implemented at a national level by central government

Italy

� EURO vehicle emission limits � NRMM Directive � General Plan For Transport Policy – promotion of sustainable transport, incentives for use of cleaner vehicles & fuels & improved public transport � Interministerial decree March 1998 including: national car sharing programme, ecological Sundays, sustainable mobility & low-impact fuel initiative � 1997 Protocol to International Convention for Prevention of Pollution from Ships


National policy implemented by central government. Some transport initiatives will be implemented at a local &/or regional level

Luxembourg

� Agreement between car manufacturers & EC concerning CO2 emissions from cars � Progressive introduction of abatement technologies on vehicles � Reduced sulphur content of liquid fuels (1999/32/EC) � Further reductions in sulphur content of fuels � Shift of diesel towards petrol � Stricter ELVs � Reduced vehicle use thorough tax increases &/or regional planning � Regulation &/or taxation of air transport

No information provided No information provided European & national policy implemented at a national &/or regional level

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��


Netherlands

� Directive on quality of fuels � Directive on sulphur content of fuel oil for ships � Incentives for Euro IV & V uptake � Tighter standards for inland waterway shipping & incentives for cleaner engines � Non-technical measures to reduce vehicle usage � Improved maintenance, testing & regulation of private vehicles to reduce VOC emissions

- - NOx – 2 NOx – 1 - -

- - NOx – 5 - - -

European &/or national policy implemented by central government at a local, regional & national level

Portugal

� Directive 98/70/EC – quality of petrol & diesel � Directive 1999/32/EC & 2000/71/EC – sulphur content of fuels � EURO vehicle emission standards � Auto-oil programme � ACEA agreement on CO2 emissions from vehicles

SO2 – 2.9-3.2 SO2 – 29.4-31.0 SO2 – 5.1-6.2 / NOx – 29-31.1 / VOC – 5.3-5.5 SO2 – 0.03 / NOx – 3 / VOC – 1 / NH3 – 0.1 NOx – 5.2-6.2 / VOC – 2.1-4.7 / NH3 – 0.03-0.06

No information provided European policy implemented at a national level

Spain

� Directive 99/32/EC – reduced sulphur content of fuels � EURO vehicle emission standards � Urban mobility plans � National programme for the reduction of aviation emissions


National & European legislation implemented at a local, regional & national level by central government, public authorities & private organisations

Sweden

� EURO vehicle emission standards � Road transport taxation & incentivisation of cleaner vehicles � Congestion charging � Km based road user taxation � Waterway & port charging schemes � Eco-labelling for boat engines � Aviation charging scheme (landing & take-off) � ELVs for NRMM � Environmental classification scheme for NRMM


Local, national & European legislation implemented at a local, regional & national level by central government, public authorities & individual ports

UK

� Directive 98/70/EC – quality of petrol & diesel � Sulphur content of liquid fuel Directive � EURO vehicle emission standards

- SO2 – 63-67 -


European legislation implemented by central government at a national level

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Industrial processes Table 4.11 summarises the policies and measures reported by each Member State in their national programmes aimed at reducing emissions in the industrial sector. The institutional level (local, national and European) at which policies and measures have been/will be implemented is also summarised along with any quantitative information that has been reported relating to the impact on emissions and associated costs.

The most commonly reported policies and measures for reducing emissions from industrial processes are:

• Integrated Pollution Prevention and Control (IPPC) Directive; and,

• Primary and secondary abatement measures to reduce emissions during and after combustion (for example, SCR, SNCR, low NOx burners and limestone injection).

Many Member States have in fact reported the IPPC Directive as the sole measure for reducing emissions from industry.

Table 4.10, below, summarises the total potential impact on emissions and the range of cost effectiveness of the policies and measures that have been reported by Member States for reducing emissions from industrial processes.

Table 4.10 Total potential impact on emissions and range of cost effectiveness of the policies and measures reported for industrial processes

SO2 NOx VOC NH3

Potential emission reduction by 2010 (kt)14 Up to 110 Up to 28 Up to 22 Up to 14

Cost effectiveness ( �! "�#�$ 4 1.8-38 3 -

Note that only three of the fourteen Member States to have submitted national programmes under the NECD have reported the quantitative impact on emissions of one or more of their policies and measures aimed at the industrial sector and only three have reported any information on the associated costs (cost effectiveness). The figures for NOx do not take into account the NOx trading scheme that is expected to commence in the Netherlands during 2005. This is expected to reduce NOx emissions by as much as 40% from large installations in the industry, energy, refineries and waste processing sectors. The anticipated impact of SCR which may be installed at cement plants in Ireland (90% reduction in NOx emissions) has also not been included.

14 Note: Portugal have reported the impacts of IPPC and LCPD as one figure so it is not possible to determine the individual impacts of each Directive. The data presented in this table includes this combined figure.

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Based on the very limited information available, the greatest potential emission reductions in the industrial sector are for SO2. However, only one Member State (Portugal) has actually reported the anticipated impact on emissions of the IPPC Directive which is likely to have a significant impact on emissions of NECD pollutants. The cost data reported is very limited and is possibly not reflective of the true situation as no Member State has reported the anticipated costs associated with the implementation of the IPPC Directive.

The majority of policies and measures reported by Member States for industry will be implemented at an installation/site level although there may be some regulation at a national level by central government and/or agencies for policies such as IPPC.

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Table 4.11 Summary of the key policies and measures reported by each Member State aimed at reducing emissions from the INDUSTRIAL sector


%&


Austria

' Technical requirements & ELVs for iron & steel, sinter, non-ferrous metal, brick, gypsum & cement production facilities & foundries No information provided No information provided National policy implemented at a plant

level

Belgium – Federal No information provided

Belgium – Brussels No information provided


' Chemicals sector: low NOx burners & SCR ' Iron & steel sector: SCR, low NOx burners, wet scrubbers, emission optimised sintering ' Non-ferrous sector: low NOx burners, fuel switching, SCR, limestone injection, scrubbers ' IPPC Directive ' Sectoral emission ceilings ' Measures to reduce fugitive emissions from chemical & petrochemical sectors ' Review of permits in ferrous, non-ferrous, glass & chemicals sectors


Marginal cost of meeting sectoral NECs: Chemicals - NOx 14.57. Iron & steel – NOx 1.75-2.52. Non-ferrous – NOx 12.09.

Most policies & measures implemented by federal &/or regional authorities. Specific industrial sectors responsible for achieving their sector specific emission ceilings.

Belgium – Walloon

' Voluntary agreement with glass sector to reduce emissions ' Measures to reduce NH3 emissions from the chemical sector ' Environmental agreements with key industry sectors to reduce energy consumption and improve solvent management ' IPPC ' Primary & secondary measures for combustion (Low NOx burners, SCR etc.)


No information provided Unclear – most policies and measures are probably the responsibility of the regional authority

Denmark ' IPPC No information provided No information provided All policies and measures have been, or will be, implemented by central government

Finland No information provided

France

' ELVs for various industrial sectors ' Ministerial decree, March 2003, limiting emissions from glass production ' Measures to reduce emissions from iron & steel, cement & nitric acid manufacture No information provided No information provided


Germany

' Ordinance on emissions from the titanium dioxide industry ' Ordinance on installations subject to licensing No information provided No information provided All policies and measures have been implemented by central government

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Ireland

' IPPC ' SCR at cement plants ' Reduced sulphur content of fuels

90% reduction in NOx emissions with SCR


National policy implemented at a plant level

Italy ' IPPC No information provided No information provided National policy implemented at a plant level

Luxembourg

' Primary & secondary measures at cement & glass plants & industrial boilers <50MWth NOx – up to 2.0 NOx - Up to 38 Technological measures to be

implemented at an installation level

Netherlands

' Action plan for SO2 emissions from industry, energy & refineries ' NOx emission trading scheme ' Tightening of emission standards for industrial facilities <20 MWth ' VOC reduction plan or introduction of emission trading for industry

SO2 – 30 NOx – 40% reduction - -

SO2 – 4 - NOx – 2-6 VOC – 3

National policy implemented by central government and individual installations

Portugal ' IPPC IPPC & LCPD: SO2 – 80 / NOx – 25-26 / VOC – 21-22 / NH3 – 13-14

No information provided European policy implemented at a national & individual installation level

Spain ' IPPC No information provided No information provided European policy implemented at a national & individual installation level

Sweden ' SCR & SNCR for process furnaces No information provided No information provided Plant level technology changes

UK

' Integrated Pollution Control under Part 1 of the Environmental Protection Act ' IPPC No information provided No information provided for individual policies & measures

European legislation implemented by central government at a national & installation level

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Solvent Use The table on the following page summarises the policies and measures reported by each Member State in their national programmes aimed at reducing emissions in the solvent use sector. The institutional level (local, national and European) at which policies and measures have been/will be implemented is also summarised along with any quantitative information that has been reported relating to the impact on emissions and associated costs.

The most commonly reported policies and measures for reducing emissions from solvent use are:

• Solvent Emissions Directive (1999/13/EC); and,

• Potential implementation of a Solvent Product Directive limiting the use of, and solvent content of, specific products.

Very few Member States have in fact reported any other measures aside from these two policies.

Approximately half of the fourteen Member States to have submitted national programmes under the NECD have reported the quantitative impact on emissions of one or more of their policies and measures aimed at the solvents sector and only two have reported any information on the associated costs (cost effectiveness)15. Based on the available information, a total reduction in VOC emissions of up to 260 kilotonnes is possible although this figure is likely to be much higher if all Member States had estimated and reported the impact of the Solvent Emissions Directive. The maximum cost per kilogram of VOC abated that has been reported is approximately 44 ¼�NJ� EDVHG� RQ� WKH� LPSOHPHQWDWLRQ� RI� D� VHULHV� RI� WHFKQRORJLFDO� DQG� EHVW�practice measures in Luxembourg.

The majority of policies and measures reported by Member States for solvent use will be adopted at European and national level by central government but will be implemented at an installation/site level.


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Table 4.12 Summary of the key policies and measures reported by each Member State aimed at reducing emissions from the SOLVENT USE sector


()


Austria

* Reduced solvent content & installation of exhaust air filters * ELVs for facilities using VOCs No information provided No information provided National policy implemented at plant level

Belgium – Federal

* Measures to promote purchase & use of alternative, less polluting cleaning products * Royal Decree regulating solvent content of paints & varnishes No information provided No information provided All policies & measures implemented by Federal Government


* Legislation to reduce VOC emissions from dry cleaning, printing & car spraying industry & other sectors * Directive relating to product solvent content * Publicity to reduce product incineration



Unclear – most policies and measures are probably the responsibility of the regional authority


* Policy amendments aimed at reducing emissions from dry cleaning & car spraying * Federal measures to regulate paints * Adjustments to sectoral emission ceilings to comply with Solvent Emissions Directive


Not provided for individual policies & measures

Most policies & measures implemented by federal &/or regional authorities. Specific industrial sectors responsible for achieving their sector specific emission ceilings.

Belgium – Walloon

* Solvents Directive (1999/13/EC) * Products Directive (paints, varnishes etc.) * Improved recovery of waste solvents


No information provided Unclear – most policies and measures are probably the responsibility of the federal and/or regional authorities

Denmark

* Statutory order no. 350 (implementation of 1999/13/EC) * Use of water based paints at car spraying workshops - VOC – 0.75

- VOC – 16.9



France * Solvent Emissions Directive No information provided No information provided European policy implemented by central government

Germany

* Ordinance on the limitations of emissions of highly volatile halogenated hydrocarbons * Directive 1999/13/EC * National programme on ground level ozone concentration reduction * Product Directive – solvent content of products

- - - VOC – 200

No information provided All policies and measures have been, or will be, implemented by central government

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()


Ireland

* Implementation of Solvents Directive (1999/13/EC) * Implementation of EU Decopaint Directive - VOC - up to 3kt


European policy implemented by central government

Italy

* Solvents Directive (99/13/EC) * Directive to limit solvents content of paints & varnishes No information provided No information provided European policy implemented by central government

Luxembourg

* Implementation of Directive 1999/13/EC * Measures to reduce VOC emissions from industrial processes including: good housekeeping, use of high volume low pressure spray guns, implementation of solvent products Directive, equipment improvements & adsorption filters

- VOC – up to 0.78

- VOC – up to 43.89 European policy & technological

measures to be implemented at an installation level

Netherlands

* VOC reduction plan or introduction of emission trading * VOC Products Directive * Proposal for extension to Product Directive

- VOC - 3 -

VOC – 3 - VOC - <1

European & national policy implemented by central government and individual installations

Portugal * Directive 1999/13/EC – limits on solvent use VOC – 15-17 No information provided European policy implemented at a national level

Spain * Directive 1999/13/EC No information provided No information provided European policy implemented at a national level

Sweden

* Legislation to reduce VOC emissions via reduced solvent usage, increased low-solvent products & other technical measures * Products Directive

Max VOC reduction 10% -

No information provided European & national legislation

UK * Solvent Emissions Directive (99/13/EC) VOC – approx. 35kt No information provided for individual policies & measures

European legislation implemented by central government at a national & installation level

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Agriculture The table on the following page summarises the policies and measures reported by each Member State in their national programmes aimed at reducing emissions in the agricultural sector. The institutional level (local, national and European) at which policies and measures have been/will be implemented is also summarised along with any quantitative information that has been reported relating to the impact on emissions and associated costs.

Member States have reported a relatively wide range of policies and measures aimed at reducing NH3 emissions from agriculture. The most commonly reported policies and measures are those aimed at:

• Reducing livestock density and number and changes in their feed;

• Improving management of manure and slurry; and,

• Improving, and ultimately reducing, the use of fertilisers.

Several Member States have also reported a series of action plans and best practice recommendations.

Over half of the fourteen Member States to have submitted national programmes under the NECD have reported the quantitative impact on emissions of NH3 of one or more of their policies and measures aimed at the agricultural sector but only two have reported any information on the associated costs (cost effectiveness)16. Based on the available information, a total reduction in NH3 emissions of up to 138 kilotonnes is possible. Estimates for the estimated impact on emissions of improved manure management are fairly consistent between Member States varying from 1.31 kt (Denmark) to 3-6 kt (Ireland). The maximum costs per kilogram of NH3 abated that have been reported are 1 ¼�NJ�LQ�WKH�1HWKHUODQGV�EDVHG�RQ�LPSURYHG�DSSOLFDWLRQ�of slurry to soil and 3.5-3.9 ¼�NJ� LQ�'HQPDUN� EDVHG� RQ� LQFUHDVHG� JUD]LQJ� RI� GDiry cows and improved manure management.

The majority of policies and measures reported by Member States for agriculture are national measures that will be adopted by central government but implemented at an individual farm level.


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Table 4.13 Summary of the key policies and measures reported by each Member State aimed at reducing emissions from the AGRICULTURAL sector


+,


Austria - Regulatory & financial policies & measures to reduce NH3 emissions No information provided No information provided National policy

Belgium – Federal

- Regulation of urea content of manure NH3 – 0.32 No information provided All policies & measures implemented by Federal Government

Belgium – Brussels Not applicable


- Manure storage covering - Low NH3 application - Low NH3 housing for new & existing plants - Improved manure processing - Livestock feed modification - Livestock reduction

- NH3 – 3.9 NH3 – 1.5 NH3 – 2.5 NH3 – 1.1 NH3 – 2.8

No information provided All policies & measures implemented by Federal & Regional Government

Belgium – Walloon

- Agricultural action plans to reduce NH3 emissions - Nitrate Directive - Improved manure management


No information provided

Unclear – most policies and measures are probably the responsibility of the federal and/or regional authorities implemented at a regional or national level

Denmark

- Ammonia Action Plan Statutory Order no. 604 - Increased grazing of dairy cows - Improved manure management

- NH3 – 3.30 NH3 – 1.31

- NH3 – 3.5 NH3 – 3.9


Finland - Agri-environmental support system No information provided No information provided Implemented by agricultural sector

France

- Reduced nitrogen content of cattle feed - Improved manure management - Reduced use of highly volatile fertilisers - Provision of information for farmers

No information provided No information provided National policy implemented by individual farms

Germany

- Fertiliser Ordinance - Range of measures planned for the agricultural sector including: CAP, recommendations for best practice, agri-environmental schemes, adaptation of Fertiliser Ordinance, adaptation of emission control legislation & promotion of organic farming

- NH3 – total impact = 40-60 No information provided


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Ireland

- Recommendations on nutrient management and code of good agricultural practice - Farm nutrient management plans - National Climate Strategy – reduction in fertiliser use - Application of BAT guidance as recommended by the Gothenburg Protocol - Fertiliser switching - CAP reform - Slurry management measures

- - - - - - - NH3 – 3-6


National policy implemented by individual farms

Italy - Code of good agricultural practice No information provided No information provided National measure implemented by agricultural advisors & individual farms

Luxembourg

- Directive 2000/25/EC – reduced emissions from agricultural machinery - Accelerated renewal of agricultural machinery fleet No information provided No information provided European & national policy implemented by individual farms

Netherlands

- Reducing NH3 emissions from fertiliser industry - Livestock farming & housing Decree - Changes in cattle feed - Improved slurry application to soil

NH3 – 2 NH3 – 24 NH3 – 10 NH3 – 6

- - - NH3 – 1

National policy implemented by central government & individual farms

Portugal - IPPC – regulation of intensive livestock farming NH3 – 6.11 No information provided European policy implemented at a national and individual farm level

Spain - CAP reform No information provided No information provided European policy implemented at a national and individual farm level

Sweden

- Action programme to reduce NH3 emissions - Improved manure management

NH3 – 13% reduction from 1995-2010 (approx. 7kt) -

No information provided National policy & measures to be implemented at an individual farm level

UK No information provided

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Waste The table on the following page summarises the policies and measures reported by each Member State in their national programmes aimed at reducing emissions in the waste sector. The institutional level (local, national and European) at which policies and measures have been/will be implemented is also summarised along with any quantitative information that has been reported relating to the impact on emissions and associated costs.

Very few Member States have reported any policies and measures for the reduction of emissions from the waste sector. For those that have, the majority of measures relate to ELVs for waste incinerators. Only Germany and Portugal have reported a series of policies and measures for reducing emissions from waste disposal and treatment. These include the Packaging Waste Directive (94/62/EC), the Landfill Directive (99/31/EC) and legislation relating to incineration and the biological treatment of waste. Only Germany has estimated the impact on emissions of one of its reported measures: ordinance on incinerators for waste and similar combustible material (reduction in NOx emissions of 5kt). No cost data has been reported. Note, some waste policies and measures may be less relevant to air emissions than others so may not have been reported by Member States.

The majority of policies and measures reported are national and European legislation which will be implemented by central government and at an incinerator level.

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Table 4.14 Summary of the key policies and measures reported by each Member State aimed at reducing emissions from the WASTE sector


./


Austria 0 ELVs for waste incineration No information provided No information provided National policy implemented at plant level

Belgium – Federal No information provided No information provided No information provided All policies & measures implemented by

Federal Government


0 NOx reduction in incineration plant 0 Regional waste incineration study



Unclear – most policies and measures are probably the responsibility of the regional authority


0 Emission ceiling for waste incineration 0 Federal measures to regulate NOx emissions from incinerators No information provided No information provided All policies & measures implemented by Federal & Regional Government

Belgium – Walloon

0 ELVs for the incineration of waste


No information provided Implemented by Federal Authority

Denmark 0 Statutory order no. 41 regulating incineration emissions No information provided No information provided All policies and measures have been, or will be, implemented by central government


France 0 Waste incineration Directive No information provided No information provided Implemented by central government

Germany

0 Ordinance on incinerators for waste & similar combustible material 0 Ordinance on installations for the biological treatment of waste 0 Act for promoting closed substance cycle waste management & ensuring environmentally compatible waste disposal 0 Increased co-incineration of waste in combustion plants subject to stricter ELVs

NOx – 5 - - -

No information provided All policies and measures have been, or will be, implemented by central government

Ireland 0 Regional waste management plans No information provided No information provided for individual policies & measures

Plans implemented at a regional level

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Italy No information provided

Luxembourg No information provided

Netherlands No information provided

Portugal

0 Packaging waste Directive (94/62/EC) 0 Directive 1999/31/EC – landfill Directive 0 Framework Directive - Ecodesign of end use equipment 0 New packaging Directive (under discussion)

No information provided No information provided European legislation implemented at a national level

Spain No information provided

Sweden No information provided

UK No information provided

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4.5 Summary / Conclusions Only four Member States are currently projected to comply with all of their NEC targets by 2010 without the need for further actions (Finland, Greece, Sweden and the UK). With additional proposed measures, a further three Member States will achieve all of their NEC targets (Belgium, Germany and Luxembourg). However, a number of Member States have not presented additional measures and their potential impacts in their national programmes so it is not possible to assess whether or not they can achieve their emission ceilings. Of the four NECD pollutants, the ceilings for VOCs and NOx, in particular, appear to be the most challenging.

The analysis described in the previous sections further reinforces the conclusions of the EEA study with respect to the general poor level of reporting and lack of consistency between Member States. This lack of consistency and limited availability of information makes any quantitative analysis almost impossible. It also highlights the need for guidelines for reporting to ensure a structured approach to preparing national programmes in the future. A more structured and detailed reporting format will enable a much more detailed inter comparison to be carried out. Entec’ s proposals for guidelines for reporting are presented in Section 8. The key conclusions of the inter-comparison are summarised below:

• Majority of Member States have only reported a ‘with measures’ scenario;

• Key sectors targeted for emissions reductions by most Member States are energy, transport, industry, solvent use and agriculture;

• The level of reporting of key European Directives varies considerably between programmes;

• The majority of policy measures reported are regulatory and will be implemented at a national level by central Government; and,

• Very few Member States have reported the quantitative impact and/or costs of individual policies and measures.

The analysis of the policies and measures reported for each source sector highlighted the varying levels of action of each Member State in different sectors and at different levels. This breakdown has identified the potential for Member States to take further action in certain areas. For the energy and transport sectors, the majority of Member States have reported a wide selection of policies and measures ranging from local transport plans to European legislation such as the LCPD, for example. The wide range and number of measures reported for these sectors, which currently emit the bulk of European NOx emissions, is possibly indicative of the fact that the NOx emission ceilings appear to be the most challenging and are currently projected to be exceeded by several Member States in 2010.However, for other sectors such as agriculture and solvent use, the number and variety of policies and measures is lower even though these sectors are key sources of NH3 and VOC emissions, respectively. This could be a reflection of the effectiveness of specific legislation such as the Solvent Emissions Directive, for example, so further measures are not deemed necessary.

The poor level of reporting on the implementing body for each individual policy and measure makes it difficult to carry out an assessment of the relative margin of action of each institutional level to reduce emissions at different geographical scales. The implementing body

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is generally only specified for those measures that are to be implemented by central Government rather than those that will be implemented at a more regional or local scale. The poor level of reporting of all of the policies and measures taken into account in each Member State’ s emissions projections also makes it difficult to judge the true level of action of each institutional level. As it is generally the Environmental Ministries or Departments for each country that prepare the national programme, then there appears to be a bias towards national, rather than local, measures although this could be expected as the NECD sets targets at a national level.

The wide range of policies and measures reported in each of the NECD national programmes could provide a useful tool for the next round of reporting for not only the New Member States submitting their first programmes under the NECD but also those that will be on their second round of reporting. Most countries will be aware of the more traditional policies and measures such as ELVs for LCPs, for example, but several, more innovative measures have been described for specific sectors such as the transport sector, for example. A comprehensive list of all policies and measures reported for each key sector could provide a useful ‘toolkit’ for the next round of reporting so that each country is aware of all of the possibilities for reduction before preparing their programme.

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5. In-depth Analysis of Projections Presented in each Programme

5.1 Methodologies for preparation of emission projections Annex III of the NECD sets down the specific requirements for preparation of emission inventories and projections under the NECD:

‘Member States shall establish emission inventories and projections using the methodologies agreed upon by the Convention on Long-Range Transboundary Air Pollution and are requested to use the joint EMEP/CORINAIR guidebook in preparing these inventories and projections.’

Parties to the Convention on Long Range Transboundary Air Pollution (CLRTAP), which includes all EU15 Member States, are required to use the UNECE Emission Reporting Guidelines – ECE/EB.AIR/80 (UNECE, 2003) in conjunction with the EMEP/CORINAIR Atmospheric Emission Inventory Guidebook17 (EEA, 2004c). The EMEP/CORINAIR Guidebook presents emission inventory methodology (including default emission factors) on a chapter-by-chapter basis with each chapter addressing a separate SNAP97 Source Sector, Sub-sector, Activity or Group of Activities.

The UNECE guidelines (UNECE, 2003) require Parties to the Convention to use the EMEP/CORINAIR Guidebook unless other national or international methods are judged to produce more accurate estimates as they provide better reflection of the national situation. If other methodologies are used then Parties should ensure that they are compatible with the EMEP/CORINAIR Guidebook and have been clearly documented.

Table 5.1 below summarises the methodologies used to calculate emission projections in each Member States’ national programme and/or updated emissions inventories and projections reported since the national programmes have been submitted.

Table 5.1 Summary of methodology used to calculate emissions projections in the national programmes

Austria No information has been provided on the specific methodology employed to calculate the emission projections. The basis for the production of the emission projections for the 2010 are the ‘energy scenarios to 2020’, which form the basis for projections of greenhouse gas emissions in the Austrian third national communication to the UNFCCC.


No emission projections presented.


The plan describes the main assumptions behind the emission projections. The methodology used to calculate the emission projections is not specified.

17 Referred to as the EMEP/CORINAIR Guidebook from this point onwards.

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Cost curves have been developed to set indicative emission ceilings for each sector except for iron and steel (only 2 installations). The RAINS model has been used to calculate emissions for the transport sector.

Belgium – Walloon

Emission projections presented in the paper were estimated from a model developed by an external expert (ECONOTEC). The model integrates the evolution of different activities or energy consumption with the penetration of modern techniques of production or emission abatement techniques. Planned policies have been taken into account in the model. The necessary data, such as investments envisaged, modifications in processes, and production were collected from the industries or from federations.

Emissions from road transport were estimated by using the COPERT III model. The annual fuel consumption (gasoline, diesel and LPG) was estimated from statistical data on fuel sales in the Walloon area. Emission conversion factors for fuels were given by COPERT III. INS provided statistics relating to the vehicle fleet, such as numbers, types and age of vehicles, and FEBIAC statistics aided on distinguishing the various categories of freight vehicles. An average number of km travelled per year was estimated by the average number of vehicle-km calculated for each type of vehicle and the number of these vehicles. These data were collected by the Ministry of Communications and Infrastructure and by the INS.

In agriculture the emissions in 2010 were estimated by SITEREM. The emissions were based on the evolution of three parameters; composition of livestock, use of agricultural land, and the quantities and types of manures applied on the soil.

Denmark The Danish EPA, in co-operation with National Environmental Research Institute, brought about the development of a series of ‘dynamic projection models’ for each of the four key source categories. A key input into these models (for NOx, SO2 and VOC emissions) are projections of energy consumption up to 2010.

Emission factors for LCPs are based on Danish power station assumptions concerning fuel sulphur content, sulphur retention in the ash and the degree of desulphurisation. Projections for industry predominantly include emissions from oil and gas extraction and solvent use. Emissions calculations for extraction of oil and gas are based on the joint EMEP/EEA Atmospheric Emission Guidebook.

Emissions from the domestic use of solvents have been estimated using the emission factors provided in the joint EMEP/EEA Atmospheric Emission Guidebook.

Road traffic emissions have been calculated through the use of the European COPERT III model which is currently used to produce the road traffic inventories for Denmark.

Denmark’s emissions projections for NH3 from agriculture focuses on three different sources: livestock manure, artificial fertilisers and sewage sludge spread on fields. Emissions have been calculated as activities multiplied by emission factors.

Finland Projections are based on the assumptions used in Finland’s Climate Change Strategy and have been calculated based on those carried out for the preparation of the NECD, data collected during the EIA of the Climate Strategy and data provided by expert institutes in Finland. The RAINS model was used to produce the actual projections.

France Emissions data has been prepared by CITEPA which calculates emissions using a methodology based on the CORINAIR system.

Germany Emissions projections have been prepared according to IPCC Guidelines for National Greenhouse Gas Inventories and the joint EMEP/CORINAIR Atmospheric Emission Inventory Guidebook.

Ireland National inventories and projections are prepared by the Irish Environmental Protection Agency (EPA) follow the requirements of the NECD utilising methodologies agreed upon by the Convention on Long Range Transboundary Air Pollution (CLRTAP) and set out in the joint EMEP/CORINAIR guidebook.

Italy The emissions projections presented in the national programme have been calculated using the RAINS model whilst the energy scenario was developed using the MARKAL (Market Allocation) model.

Luxembourg A ‘Reference Scenario’ (business-as-usual) was constructed by means of the EPM model (Emissions Projection Model). The EPM model is an energy demand and emissions forecasting model covering the key emitting sectors (a technology-economic simulation model – a ‘bottom-up’ model). Energy consumption and emissions are calculated for the base year, 2000. These are then projected into the future, on the basis of assumptions relating to various factors (eg. activity rates, emission factors, consumption and changes in market share of fuels). Emissions are categorised into 2 key groups: those relating to energy consumption and industrial process emissions.

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Netherlands The National inventories and projections have been prepared under the ‘4C Project’ (Four Ceilings, Foresee). An inventory of policy measures already adopted, planned and possible was prepared and the RIVM (the National Institute for Public Health and the Environment) was asked to calculate the impacts of 12 policy packages.

It is important to note that all emissions, forecasts and targets presented in the report are based on the ‘Netherlands territory method’. This method differs from the international guidelines for compiling inventories by including emissions from maritime shipping, which are not included under the scope of the NEC Directive.

Portugal National inventories and projections were prepared using methodologies set out in the joint EMEP/CORINAIR guidebook.

Spain No emission projections presented in the national programme.

Sweden No information has been provided on the methodology used to compile the emission projections.

UK No information has been provided on the methodology used to compile the emission projections.

Most Member States appear to have used methodologies either consistent with or based on the requirements of the Directive (where information is available). Some countries have based their emission projections directly on the methodology specified in the EMEP/CORINAIR guidebook (for example, Portugal) whilst others have employed existing European models, such as IIASA’ s RAINS model for example, which are consistent with the requirements of the Directive (and therefore the EMEP/CORINAIR Guidebook). The requirements for reporting under the CLRTAP (and NECD) allows countries to use national methodologies not based on the EMEP/CORINAIR guidebook if they are deemed to be more accurate. On the basis of the available information it is not possible to determine whether any countries who have used a methodology not based on the EMEP/CORINAIR guidebook have calculated their emissions in a manner consistent with the requirements of the Directive. The Netherlands, however, appear to use a methodology which takes into account emissions from international shipping. This is specifically not included under the NECD and should be excluded from the emissions projections.

5.2 Sectoral Scope Parties must submit national emissions of various pollutants (including SO2, NOx, VOC and NH3) broken down by the eleven main Selected Nomenclature for sources of Air Pollution (SNAP Level 1) source sector categories:

• 01 Combustion in energy and transformation industries;

• 02 Non-industrial combustion plants;

• 03 Combustion in manufacturing industry;

• 04 Production processes;

• 05 Extraction and distribution of fossil fuels and geothermal energy;

• 06 Solvent and other product use;

• 07 Road transport;

• 08 Other mobile sources and machinery;

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• 09 Waste treatment and disposal;

• 10 Agriculture; and,

• 11 Other sources and sinks.

Parties are also encouraged to submit more detailed emissions data (SNAP Level 2).

Most recently, the UNECE Task Force on Emission Inventories and Projections (TFEIP) have developed the Nomenclature For Reporting (NFR) source sector classification system in 2001 which is now the standard for reporting as specified in the UNECE Emission Reporting Guidelines – ECE/EB.AIR/80 (UNECE, 2003). These guidelines also specify the specific NFR sectors that should be reported to CLRTAP for each pollutant. Submissions under the CLRTAP should be presented in this format from the 2002 reporting round onwards. The correlation between the SNAP and NFR classification systems is detailed in the contents/index of the latest version of the EMEP/CORINAIR guidebook (EEA, 2004c). As the new system was only developed in 2001 and finalised in 2002 then the majority of national programmes should have been reported in the SNAP format. In contrast, updated inventories and projections submitted under the NECD should have been submitted in the NFR format.

Table 5.2 below summarises the sectoral scope of historic and projected emissions presented in each Member States’ national programme.

Table 5.2 Summary of sectoral scope of historic and projected emissions data presented in the national programme

Historic emissions data Emissions projections

Austria Although the plan does discuss changes in emissions for different sectors, emissions data (for 1998 and 2010) has only been presented at a national level.


Transport, industry (process and energy), tertiary and the domestic sector.

Total emissions from all sectors (excluding transport) and transport.


Historic and projected emissions have been presented for over 25 different sub-sectors including: electricity, refineries, iron & steel, non-metal industry, chemicals, ceramics, paints & varnishes, petrol stations, incineration, residential combustion, livestock, agricultural waste, fertilisers, car assembly and other smaller sources.

Belgium – Walloon

Electricity production, industry (broken down by sub-sector), residential, tertiary, transport, agriculture and waste.

Denmark Historic emissions for the 4 pollutants have been presented for 1985-2002 split by SNAP Level 1 source sector categories (combustion in energy industries, non-industrial combustion plants, combustion in manufacturing industry, production processes, extraction and distribution, solvent and other use, road transport, other mobile sources, waste treatment and agriculture).

Total national emissions.

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Finland Historic emissions for SO2 and NOx have been presented for 1980 to 2000 and 1987 to 2000 respectively, split into five main sectors: energy generation excluding housing and service buildings (split further into power plants and industrial); industrial processes; heating for housing and service buildings; transport (split further into road and other); and non-road machinery including farm machinery.

Historic emissions for VOCs have been presented for 1988 to 2000, split into seven main sectors: transport (split further into road, volatile and other); solvent use; industrial processes; heating for housing and service buildings; non-road machinery including farm machinery; fuel distribution; and other.

Historic emissions of NH3 are not presented, however estimates split the emissions by % into the following sectors: livestock farming; fur farms; chemical fertilisers; forest industry processes; and ‘other’.

Energy generation, traffic and NRMM, heating and wood-burning fires and stoves and industrial processes (SO2 and NOx). National total emissions for VOCs and NH3.

France Energy, industry, domestic and tertiary, road transport, agriculture, other transport and others.

Refining, combustion in industry, electricity production, domestic and tertiary, solvent use, production processes, animal manure, cultures with manure, waste disposal, district heating, road transport and other mobile sources (varied between pollutants).

Germany Broken down by IPCC sub-source sector codes (and corresponding SNAP codes). Main categories are energy, industrial processes, solvent use and agriculture.

Ireland Detailed breakdown by old NFR reporting format (main source sectors identical to CORINAIR SNAP format).

Breakdown by old NFR format (10 key source sectors).

Italy Split by key sectors and sub-sectors (for VOCs in particular) for historic emissions (1980-2001) and for projections to 2010.

These include, for NOx and SO2, fuel production and conversion, combustion in industry, domestic, transport, electricity generating plants and industrial processes.

For NH3, these include fertiliser production, different types of livestock, waste treatment and disposal, urea consumption and consumption of nitrogen fertilisers.

For VOCs, emissions from over 30 different sub sectors have been reported. The main sectors reported include fuel extraction, processing and distribution, solvent use, chemical industry, stationary source combustion, transport and miscellaneous sources.

Luxembourg Emissions data is presented for each of the key emissions sources categorised by the relevant SNAP Level 1 Code for 2000 and 2010.

Netherlands Industry, energy, transport, agriculture, services and construction and households.

Portugal SO2 and NOx emissions: Electricity generation, combustion in refineries, industry and construction (divided by type), manufacturing industry and transport.

NH3 and VOC emissions, in particular, available broken down by detailed SNAP source sector categories.

2010 emissions also presented for all pollutants by 4 main sectors (and further subdivided): energy supply, industry and construction, transport and ‘others’.

Spain National total emissions only. No projections presented.

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Sweden Historic (1990-2000) and projected (2010) emissions for SO2, NOx and VOCs have been presented in the programme broken down by key sector (electricity/heat production & refineries, other energy production (housing, services), energy production in industry, transport (road, sea, air, rail), processing machinery (soil, forests, fisheries, building, construction etc.) & military, industrial activities (industrial processes, commercial solvent use, petrol distribution etc.) and household use of products containing solvents.

UK National total emissions data and projections for each of the four pollutants have been presented for 1999 and 2010. No sectoral breakdown has been provided.

Note 1: Data from national programme

Note 2: Data submitted separately from the national programme under the reporting requirements of the NECD

The sectoral split of historic and emission projections varies considerably between programmes and three countries have only presented total national emissions data for 2010 (Austria, Denmark and the UK). Only 5 countries (Denmark, Germany, Ireland, Luxembourg and Portugal) have presented historic or projected emissions broken down by Level 1 or greater SNAP or NFR source sector categories and only 3 have presented them for both18 (Germany, Ireland and Luxembourg). Therefore, the majority of countries have not followed the reporting requirements under the CLRTAP (required by the NECD) relating to the sectoral split of emissions data.

5.3 Uncertainty Article 18 of the UNECE Emission Reporting Guidelines – ECE/EB.AIR/80 (UNECE, 2003) requires Parties to the CLRTAP to:

‘…estimate the uncertainties in its inventory, preferably in quantifiable terms, using the most appropriate methodologies available to it, taking account of guidance provided by the EMEP/CORINAIR Guidebook.’

Furthermore, Article 32 of the guidelines sets specific reporting requirements with respect to uncertainty:

‘When reporting emissions, the level of uncertainty associated with these data and their underlying assumptions should also be reported to the extent practicable. The methodologies used for estimating uncertainties should be indicated in a transparent manner. Parties are encouraged to report quantitative information on uncertainties, where this is available.’

The table below summarises the extent to which the uncertainty involved with emissions projections has been presented in the national programmes.

18 Portugal has presented detailed emissions data broken down by SNAP source sector categories for VOCs and NH3 only).

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Table 5.3 Summary of uncertainty presented in the national programmes

Austria Very limited discussion of the uncertainty involved with no quantitative estimates provided.


Uncertainty is not explicitly addressed in the programme but emissions projections are presented for 4 different scenarios for transport and other sectors. However, the scenario that is considered the most likely or realistic is not stated. No quantitative estimates have been provided.


Section 2 of the plan discusses the uncertainties involved and attempts made to minimise them for the Flanders Region. The Flanders Region aims to reduce uncertainty through the following activities:

• Improve availability of data and information;

• Inter-sectoral assessment of emissions reductions amongst different sectors;

• Development of an economic instrument to measure economic impact of policies; and,

• Monitoring of the emission reductions and efficiency of the measures and policies enforced.

Improved availability of data and information is planned for the following sectors:

• Vehicle assembly: mid 2003;

• Industrial use and production of paints: end 2003;

• Chemicals: mid 2004; and,

• Range of other sectors: end 2003.

The plan highlights the uncertainty involved with the emissions projections and, in particular, the impacts that potential policies and measures could have on emissions. The plan states that although the NOx programme should be sufficient to achieve the NOx ceiling, the uncertainties involved are so great that additional measures are necessary. The VOC programme also faces uncertainty because it is not yet technically feasible to achieve the targets and there are many uncertainties surrounding the projections, reductions in emissions that can be achieved through the existing measures and the economic feasibility of the scenario proposed in the plan for Flanders. Uncertainty may be up to 50% for projections from the chemicals sector.

Belgium – Walloon

Uncertainty has not been discussed in the national programme.

Denmark Very limited discussion of the uncertainty involved with no quantitative estimates provided.

Finland Uncertainty is discussed briefly in the national programme in a number of sections:

• Attention is drawn to the possibility of emissions reductions falling short of those projected in the National Climate Strategy, in the event that Finland decides to make extensive use of the Kyoto mechanisms. These mechanisms enable measures carried out outside Finnish borders or emissions trading to be used for emission credits. This could mean that Finland may not have to implement all of the measures proposed within the National Climate Strategy, and as such, related reductions in emissions of SO2 and NOx would also be limited.

• Potential ‘arithmetical uncertainty’ is identified to be associated with estimating transport emissions data. The calculation method used in drafting the NECD differs from the Finnish national road transport emission calculation system, which has been used in the national programme.

Uncertainty is also discussed briefly in the National Climate Strategy, which identifies a number of sources of uncertainty, including:

• growth rates of domestic electricity production in relation to imports;

• production growth rates of energy-intensive sectors, e.g. pulp and paper industry, manufacture of metals, chemical industry;

• modes of production used to cover the growth of electricity consumption;

• economic development (vehicle stock, demand for services, etc); and

• wood-felling targets.

No quantitative estimates have been provided.

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France The national programme highlights the potential for uncertainty within both projections of activity levels as well as emission factors. The national programme summarises the findings of the Optinec study, which evaluated the uncertainties associated with the emissions projections. Uncertainties were estimated from the orders of magnitude presented in the EMEP/CORINAIR guidebook for checking emissions inventories, taking account of uncertainty associated with projected activity levels and emission factors in 2010.

The uncertainties have been estimated for each pollutant: SO2 emissions (15%); NOx emissions (45%); VOC emissions (30%); and NH3 emissions (80%). The uncertainty levels are greatest for NOx and NH3, the pollutants for which France is expected to exceed the NECs even after additional measures.

Major sources of uncertainty are identified as forecasts of economic activity up to 2010, in addition to changes in the electricity market and revisions of the Common Agricultural Policy. The national programme goes on to identify reasons for discrepancies between the ‘Optinec’ forecasts and the IIASA forecasts for 2010.

Germany Very limited discussion of the uncertainty involved with no quantitative estimates provided.

Ireland Uncertainty is discussed very briefly in the ‘Inventories and Projections’ section of the discussion paper. Reference is made to the higher uncertainty associated with the compilation of inventories for NOx, VOCs and NH3 - the paper states that this is due to ‘…the use of inherently uncertain emission factors and often less robust activity data streams…’ In particular, compiling projections for solvent and other product use has been identified as most problematic. CAP reform (i.e. proposed changes in the CAP Medium Term Review) has been specifically excluded from the business as usual scenario because of the uncertainty associated with its potential impacts.


Italy Uncertainty has not been discussed in the national programme.

Luxembourg Uncertainty is referred to very briefly with respect to the emissions projections made for the reference scenario and the assumptions taken into account. The programme states that the data and assumptions used for calculating emissions in 2010 were ‘…the best available information at the time of preparation of the report’.


Netherlands Uncertainty is discussed throughout the national programme, in relation to the reduction potential of extra measures and the emissions inventories used. The main points are summarised below:

Transport: The report highlights the risk of a potential shift towards diesel powered cars, stating that TNO has estimated that an increase in the proportion of diesel from 20% to 40% would increase the NOx emissions from transport in 2010 by 3 kt.

An increased knowledge of emissions from HGVs has indicated that emissions from Euro II and Euro III HGVs have previously been underestimated by several tens of percentage points. These vehicles may have higher emissions in practice than under test conditions, which could add between 10 and 20 kt to the actual emissions of NOx from this sector. Similar uncertainty exists over impact of the discrepancy between test conditions and practice for vehicles compliant with Euro IV and V. The report also highlights the potential risk that the future use of SCR in diesel engines will increase NH3 emissions.

Agriculture: The report highlights a potential increase in emissions of NH3 of approximately 2 kt as a result of shifting chickens from batteries to deep-litter housing. The report states that NH3 emission forecasts for agriculture depend on the results of the Dutch request for a derogation under the EU Nitrate Directive, the abolition of livestock quotas and milk quotas and the expansion of the EU in 2004. The outcome of these matters could affect emission by 10 kt up or down.

Portugal Two emissions scenarios (low and high) have been presented to reflect uncertainty in economic growth. Uncertainty is discussed briefly for some emission factors and for agricultural land-use scenarios.


Spain Uncertainty has not been discussed in the national programme.

Sweden Uncertainty has not been discussed in the national programme. A brief reference is made to the uncertainty of projecting social and environmental development with respect to the need to keep the emissions projections under constant review. No quantitative estimates have been provided.

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UK The national programme highlights the uncertainty associated with the emission projections for 2010 and notes that further measures may be required in the future, as more information becomes available. The projections for SO2 and NH3, in particular, are identified as having high levels of uncertainty. Estimates for SO2 are likely to vary considerably as details have yet to be confirmed on how the LCPD will be implemented. Estimates for NH3 are associated with considerable uncertainty due to the wide range of agricultural and non-agricultural sources and the varying impacts of local conditions (eg. wind speed, temperature).


The guidelines for reporting under CLRTAP (and therefore the NECD) require countries to report the level of uncertainty (quantitatively where possible) associated with their emissions data. The extent to which uncertainty has been discussed varies considerably from those countries that have not addressed it at all (for example, Italy and Spain) to one that has quantitatively estimated the uncertainty involved with emission projections for each pollutant (France). In general, very few countries have discussed the uncertainty involved in calculating emission projections and inventories in any great detail and therefore do not appear to have followed the requirements for reporting.

5.4 Updated inventories and projections Aside from the emissions projections that must be presented in each national programme, Article 8 of the NECD requires Member States to report annually (by 31 December):

‘… their national emission inventories and their emission projections for 2010 established in accordance with Article 7 to the Commission and the European Environment Agency. They shall report their final emission inventories for the previous year but one and their provisional emission inventories for the previous year. Emission projections shall include information to enable a quantitative understanding of the key socio-economic assumptions used in their preparation.’

Table 5.4, below, summarises the type of information that has been reported to the Commission under the NECD separately to the national programmes themselves.

Table 5.4 Summary of information submitted to the Commission under the NECD (separately to national programmes)

Reporting format

Country Date submitted

Inventory Projections

Other information submitted

Austria December 2003 New NFR 2002

No projections provided – text states that projections in national programme are still correct.

-

Belgium January 2004 New NFR 2002 No projections provided. -

Denmark March 2003 Detailed NFR 2002

Submitted updated national programme -

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Reporting format

Country Date submitted

Inventory Projections

Other information submitted

Finland December 2003 Old NFR 2001 National total emissions Energy demand for 2010

France March 2004 New NFR 2002 National total emissions (current legislation)

Energy consumption data; electricity production and consumption; energy consumption data for the transport sector; and agricultural activity data (1990-2010)

Germany February 2004 New NFR 2002 Detailed projections – IPCC & corresponding SNAP codes

Energy consumption data for 1990-2000

Greece December 2003

SNAP Level 1 2001 National total projections -

Ireland December 2003 New NFR 2002

Submitted discussion document (draft national programme)

-

Italy No information submitted

Luxembourg No information submitted

Netherlands February 2004 New NFR 2002 Detailed old NFR (current legislation) -

Portugal February 2004 New NFR 2002 No information submitted Energy consumption data for transport and other sectors 1990-2002

Spain April 2004 New NFR 2002 No information submitted -

Sweden December 2003 New NFR 2002 National total projections

(current legislation) -

UK February 2004 New NFR 2002 SNAP Level 1 and Old NFR -

All but two of the Member States (Italy and Luxembourg) have reported some information to the Commission. Of the thirteen Member States that have provided some information, seven have presented updated emissions projections for 2010 and Denmark and Ireland have submitted versions of their national programme (updated and draft, respectively). The remaining four Member States have not submitted any emissions projections for 2010 although Austria’ s submission states that the emission projections for 2010 are unchanged to those in their national programme. In general, only total national emission projections have been presented although Germany (IPCC and corresponding SNAP codes), the Netherlands (detailed old NFR) and the UK (SNAP level 1 and old NFR) have presented more detailed projections. The majority of Member States, that did report their national inventories, submitted their data in the new NFR format; only Finland (old NFR) and Greece (SNAP level 1) submitted data in a different format.

Compared to the emissions data presented in the national programmes, the updated emissions projections submitted to the Commission do not significantly change the situation across Europe with respect to meeting NECs. The most significant development is that Greece, which is the only EU15 country yet to submit a national programme, currently expects to meet all of its emission ceilings. The only other changes are for the Netherlands and Sweden, which are now

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projected to meet the NH3 and NOx emission ceilings, respectively, without further actions. Sweden will therefore meet all of its NECs under a BAU scenario.

5.5 Extent to which existing and additional measures to reduce greenhouse gas emissions have been included in projections

5.5.1 Methodology A comparison was undertaken between the policies and measures reported in the NECD national programmes (see Appendix A) and those reported in each Member State’ s National Communications to the UNFCCC and information submitted to the Commission under the Monitoring Mechanism (summarised in UNFCCC (2002) and the EEA’ s assessments (EEA, 2004b), respectively). In theory, all policies and measures that will be implemented to comply with greenhouse gas agreements and impact upon emissions of NEC pollutants, should be reported in the NEC national programmes and taken into account in any projections, whether they have a positive or negative effect.

However, this comparison was not as simple as anticipated. In the majority of NECD national programmes the policies and measures have been described fairly generally or presented in groups of generic measures rather than identified independently. For example, several national programmes have referred to ‘energy efficiency’ measures but not specified exactly what measures will be taken. In contrast, the policies and measures reported under greenhouse gas agreements are described in much greater detail and at a finer scale.

Further information regarding the linkages between the preparation of an NECD national programme and reporting requirements under greenhouse gas commitments was also provided by Member States in response to the information request (Appendix D).

5.5.2 Summary The table below summarises the linkages between Member State NECD and greenhouse gas programmes including the extent to which policies and measures to reduce greenhouse gases have been taken into account in NECD emission projections.

Table 5.5 Summary of links between NECD programmes (and projections) and measures to reduce greenhouse gas emissions

Austria Brief reference to the National Climate Strategy. Programme states that measures to reduce climate change have been considered, where relevant, for each of the sectors and pollutants. Very few specific policies and measures to reduce greenhouse gases have been presented.


Combined programme for air quality and climate change therefore policies and measures to reduce emissions of both greenhouse gases and NECD pollutants have been reported.


Synergies between air quality and greenhouse gas objectives have not been assessed. Very few of the policies and measures reported in the programme could also have an impact on greenhouse gas emissions (mainly only transport measures).

Belgium – Walloon

Programme reports a number of measures that also appear to be reported in Belgium’s third national communication to the UNFCCC (for example, energy efficiency, industry agreements).

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Denmark Unclear to what extent measures to reduce greenhouse gas emissions, including the Danish Action Plan for implementing the targets of the Kyoto Protocol, have been taken into account in the emission projections. Programme presents a series of action plans aimed at the energy and agriculture sectors to improve energy efficiency which will also reduce greenhouse gas emissions. Measures are not consistent with those reported by Denmark to the UNFCCC.

Finland NECD programme is based on Finland’s National Climate Strategy. Projections of SO2 and NOx are based on full implementation of the Strategy so the programme is fully integrated with air quality and climate change commitments.

France Emission projections have been based on the energy scenario from the national climate change programme which was also used for France’s third national communication to the UNFCCC. Very few policies and measures reported under France’s greenhouse gas commitments have been presented in their NECD national programme.

Germany Programme presents a fairly comprehensive list of existing and additional policies and measures many of which will also have impacts on greenhouse gas emissions (including Germany’s Climate Change Programme itself).

Ireland Most of the policies and measures presented in Ireland’s discussion paper have also been presented in their third national communication to the UNFCCC.

Italy NECD national programme only briefly references the country’s climate change strategy or commitments and very few policies and measures that could also reduce emissions of greenhouse gases have been presented.

Luxembourg No specific reference to climate change commitments and very few policies and measures that could also reduce emissions of greenhouse gases have been taken into account in the ‘reference scenario’ (BAU). Some additional measures presented, but not quantified, will also have impacts on emissions of greenhouse gases (for example, aviation taxation, renewables, reduced fuel consumption).

Netherlands Emission projections have been based on ‘reference estimate greenhouse gases’ calculated under the Netherlands evaluation of national climate change measures. Socio-economic assumptions listed in the programme are based on those made within the national climate change programme. Programme states that a number of additional climate change measures have not been included in the projections made for the national programme as the specific measures had not been agreed at the time.

Portugal Only existing policies and measures presented, many of which also impact on greenhouse gas emissions and have been reported in Portugal’s third national communication to the UNFCCC (for example, renewable energy sources, improved energy efficiency). A number of existing and additional measures have been presented in Portugal’s national communication which could also impact upon emissions of NECD pollutants.

Spain No emission projections presented. Some measures have been presented that will also impact upon emissions of greenhouse gases (for example, improved energy efficiency, programme for reduction of aviation emissions).

Sweden A large number of the measures presented have also been reported to the UNFCCC including local climate investment programmes, information campaign on climate change and reducing energy consumption and an incentive scheme to promote more efficient technology.

UK The energy projections that form the basis of the emission projections take into account existing or planned policies and measures to reduce greenhouse gas emissions as presented in the UK Climate Change Programme. However, measures which have been listed in the Climate Change Programme as additional have not been included in the baseline projections.

5.5.3 Austria The Austrian national programme briefly references the National Climate Strategy and states that its implementation will enhance the policies and measures described for achieving its NEC’ s. It also states that measures to reduce climate change have been considered, where relevant, for each of the sectors and pollutants.

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Very few specific policies and measures that would reduce emissions of both greenhouse gases and NECD pollutants have been presented in the national programme. A series of regulatory and voluntary policies and measures to increase the use of renewable energy sources have been presented as well as various policies and measures for the transport sector. These include regulatory and voluntary measures, changes in infrastructure and research aimed at reducing emissions from road transport. Regulations on emissions from waste and biomass incineration, domestic heating and agriculture have also been presented. These policies and measures have also been reported under Austria’ s greenhouse gas commitments. However, many other measures are also presented that have not been reported in the NEC national programme yet are likely to have a significant impact on emissions of NEC pollutants. These include:

• energy related taxes;

• voluntary agreements and flexible instruments to bring about cost efficient greenhouse gas reductions in industry;

• energy efficiency programme to promote economic energy saving in industry; and,

• incentives to encourage cleaner vehicles and taxes/tolls to reduce vehicle activity.

These measures could all assist Austria in complying with its NEC targets for 2010.

5.5.4 Belgium

Brussels Capital Region The regional programme produced for the Brussels Capital Region of Belgium is a combined plan to tackle air quality and climate change therefore measures to reduce emissions of greenhouse gases and NECD pollutants have been reported.

Almost all of the additional policies and measures (>40 in total) presented for the transport and energy sectors will also have significant impacts on emissions of greenhouse gases. They are almost entirely consistent with those measures presented in Belgium’ s third national communication to the UNFCCC in 2002 (those measures relevant to Brussels are specified in the communication).

Flanders Region The programme makes reference to the relationship between measures to comply with the Kyoto Protocol and those for reducing emissions of NECD pollutants, SO2 and NOx in particular. The programme states that insufficient information is currently available to assess the synergies between air quality and greenhouse gas objectives however policy measures in the future could be co-ordinated to help achieve both.

Very few of the policies and measures presented in the national programme could also have an impact on emissions of greenhouse gases and have been presented in Belgium’ s third national communication to the UNFCCC (implementation of the IPPC Directive, measures to reduce vehicle use and promote cleaner vehicles). Belgium’ s third national communication to the UNFCCC contains a series of measures that could also have an impact on air quality. These include:

• Measures to improve energy efficiency in most sectors;

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• Promotion of CHP systems;

• Promotion of renewable energy sources; and,

• Improvements to agricultural policies.

Walloon Region The NECD programme for the Walloon Region does not make any specific references to the impacts it could have on emissions of greenhouse gases or to Belgium’ s climate change commitments. However, a number of the policies and measures reported will also have impacts on greenhouse gas emissions and similar measures have been reported in Belgium’ s third national communication to the UNFCCC. These include:

• Measures to improve insulation and energy efficiency of buildings;

• Action plans to reduce emissions from agriculture;

• Environmental agreements with industry to reduce CO2 emissions and energy consumption;

• IPPC Directive;

• Energy action plans;

• Plan for promotion of renewables; and

• Sustainable development and transport (including green travel plans, promotion of public transport and clean technology).

The national programme does not specify the exact policies and measures that may be implemented under some of the more general measures so it is not possible to directly compare them with the more specific policies and measures presented in Belgium’ s 3rd National Communication. There may be measures that have been reported under greenhouse gas commitments that have not yet been taken into account in the NEC emissions projections.

5.5.5 Denmark Denmark’ s NECD national programme presents a series of regulatory measures that will impact upon greenhouse gases and NECD pollutants including emission limits on incineration, LCPs, road vehicles and other engines. Energy and ammonia action plans (aimed at improving energy supply and efficiency) have also been reported.

It is not possible to compare these action plans with the measures reported in Denmark’ s 3rd National Communication to the UNFCCC and other sources, including ‘Proposal for a Climate Strategy for Denmark’ , as these submissions do not specifically report action plans. Instead they list each individual measure which may or may not be envisaged under the Energy and Ammonia Action Plans referenced in the NECD national programme. For example, over 20 different measures relating to energy use and efficiency are reported in Denmark’ s 3rd National Communication including CO2 quotas for electricity production, CO2 and energy taxes on heating fuels, tax on private sector energy consumption and grants for energy saving.

The only transport related measure reported in the NECD national programmes are the EURO I-V vehicle emission limit standards. However, six different measures aimed at the transport

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sector have been reported in the 3rd National Communication, all of which will have positive impacts on air quality (including improving the efficiency of road vehicles and promotion of cleaner forms of transport such as bicycles and public transport).

5.5.6 Finland Finland’ s NECD national programme is based on The National Climate Strategy and is therefore highly integrated with existing and additional measures to reduce greenhouse gas emissions. The National Climate Strategy presents a range of measures aimed at reducing emissions of greenhouse gases, but which also reduce SO2 and NOX (Syri et al., 2002). Projections of these pollutants for 2010 are based on the full implementation of the National Climate Strategy, under scenario ‘KIO2’ , which assumes ‘beyond business as usual’ (BBAU) energy taxation, technological developments, utilisation of renewable energy, extension of the natural gas network in South Finland and an increase in the generation of nuclear power.

The assumptions presented within the programme, such as those for population trends, economic growth, economic structural change, economic instruments and technology, are made on the same basis as those within the Finnish National Climate Strategy (2001). The emissions projections are primarily based on calculations made within the assessment of the environmental impacts of the National Climate Strategy and the environmental impact assessment of the strategy, with revisions made where more up-to-date information was available.

The NECD national programme refers heavily to the National Climate Strategy and some of the key measures relating to the energy sector from the Strategy are presented. These include the Energy Conservation Programme and a programme promoting renewable energy sources. Several measures for reducing emissions from transport through improving the efficiency of freight movements and promotion of public transport have also been presented.

Although the programme states that projections of SO2 and NOx are based on full implementation of the Climate Strategy, it is not entirely clear if all of the measures in the Strategy have been included as only some have been reported (energy and transport sectors, in particular). It is also not clear to what extent the Strategy has been accounted for in the emissions projections for NH3 and VOC as very few policies and measures have been presented that could reduce the level of emissions of these pollutants.

5.5.7 France The 2010 emission projections reported in France’ s national programme were presented in the Optinec study (CITEPA, 2002). Four energy scenarios were examined within this study. The scenario selected for the emissions projections is based on the ‘Programme National de Lutte Contre le Changement Climatique’ (the National Programme for the Fight against Climate Change) or PNLCC. This scenario takes into account energy consumption from the 3rd National Communication on climate change, which was adopted at the end of 2001, by the Interdepartmental Commission for the Greenhouse Effect. However, the activity data for electricity production, refining, steel production, glass production and road transport was corrected, to take account of information gathered during consultation with stakeholders.

No direct reference is made within the national programme to the consideration of the impact of measures to reduce greenhouse gas emissions. However, the Optinec study (CITEPA, 2002) states that the PNLCC scenario, on which the forecasts are based, assumes a reduction of 4.6% in CO2 emissions. Furthermore, in Annex B, within the discussion of additional measures for

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NOX, reference is made to demand management measures for transport that were included within the national plan to combat climate change. However, it is not clear whether these measures have been included within the baseline projections or not.

Very few policies and measures to reduce greenhouse gases have been reported in the national programme under ‘existing’ and ‘additional’ measures even though France’ s 3rd National Communication includes over 140 different policies and measures, a large proportion of which could have a significant impact on emissions of NECD pollutants. Policies and measures for the transport and energy sectors, in particular, appear to be relatively poorly reported.

5.5.8 Germany Germany’ s NECD national programme includes a fairly comprehensive list of the policies and measures already implemented and those that are proposed to ensure that the NEC targets are achieved. These include several key greenhouse gas reduction measures and Germany’ s National Climate Change Programme itself:

Existing • Renewable Energy Sources Act (Emeuerbare Energien Gesetz – EEG);

• Biomass Ordinance on Biomass Use for Energy Production (Biomasseverordnung – BiomasseV);

• Combined Heat and Power (CHP) Act (Kraft-Wärme-Kopplungsgesetz);

• Agreement between the German Government and Industries on promotion of CHP;

• Energy Saving Act (Energieeinsparungsgesetez – EnEG);

• Energy Saving Ordinance (Energieeinsparverordnung – EnEV);

• Mineral Oil Tax Act (Mineralölsteuergesetz) promoting less polluting fuels;

• Motor Vehicle Tax (Kraftfahrzeugsteuergesetz) promoting cleaner vehicles; and,

• National Climate Change Programme.

Additional • Promotion of cleaner vehicles and improved efficiency of use;

• Various measures for stationary sources including tighter emission limit values and increased co-incineration of waste in combustion plants; and,

• Various measures for agriculture including reduction of livestock densities, guidance for best practice and changes to the emission control legislation.

The national programme does not specify the exact measures that have been or will be implemented under the various Ordinances or Acts and the National Climate Change Programme itself, therefore it is not possible to compare with the policies and measures presented in Germany’ s 3rd National Communication. There may be measures that have been reported under greenhouse gas commitments yet have not been taken into account in the NEC emissions projections.

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5.5.9 Ireland The introduction to Ireland’ s NECD discussion paper refers to the need for policies and measures to reduce emissions ‘… to be integrated with policy delivery in the relevant sectors and with the policies and measures Ireland is employing to reduce greenhouse gas emissions’ . Most of the policies and measures presented in the NECD discussion paper have also been reported in Ireland’ s 3rd National Communication and reduce emissions of both greenhouse gases and NECD pollutants. These are listed below.

Existing • Market liberalisation: increases in capacity will be from high efficiency Combined

Cycle Gas Turbines (CCGT) and CHP leading to displacement of all heavy fuel oil by gas;

• Installation of cleaner more efficient technology at power plants;

• Introduction of cleaner more efficient power plants;

• Energy efficiency programmes;

• Renewable energy: target of approximately 10% of electrical output been set for the period 2000-2005;

• Sustainable transport strategy;

• Incentivisation of cleaner vehicles; and,

• Various agricultural measures including a Code of Good Agricultural Practice and the National Climate Change Strategy (reduced cattle numbers and fertiliser use).

Additional • Incentivisation of more efficient boilers to increase replacement of older boilers;

• Incentives for improved energy efficiency in the residential and commercial sectors;

• Further incentives for cleaner vehicles;

• Further intensification of the shift to sustainable transport;

• National Climate Strategy (removal of incentive for fuel tourism (foreign purchase of fuel in the state) through strategic setting of excise duty);

• Various agricultural measures including CAP reform (reduced cattle numbers).

Some additional measures to reduce greenhouse gases reported in the 3rd National Communication that have not been taken into account in the Irish discussion paper include a potential carbon tax and tradable permit scheme.

5.5.10 Italy Italy’ s NECD national programme only briefly references the country’ s climate change strategy or commitments and very few existing policies and measures that could also reduce emissions of greenhouse gases have been presented. The NECD national programme only presents a BAU emissions scenario and no measures to reduce emissions of greenhouse gases appear to have

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been included in the projections; only key European Directives appear to have been taken into account. Over fifty different policies and measures that have been implemented are presented in Italy’ s reports under its climate change commitments, many of which could also contribute to significant reductions in emissions of NECD pollutants. The majority of these are aimed at the energy and transport sectors to improve energy efficiency and management, increase the use of renewables, promote and incentivise cleaner technology and shift towards sustainable transport.

Many of the proposed additional measures presented in the national programme have been developed to also contribute towards Italy meeting its commitments under the Kyoto Protocol although no BBAU emission projections have been reported. For the transport sector these include the General Plan for Transport Policy (to promote sustainable and cleaner transport), National Operational Programme 2000-2006 (modal shift and sustainable planning) and the Interministerial Decree of 27 March 1998: Sustainable Mobility in Urban Areas (series of programmes to reduce the impact of road transport in urban areas). These measures have already been implemented and are presented as existing measures in Italy’ s greenhouse gas reports.

Other additional measures presented include the Ministerial Decree of 24 April 2001 requiring electricity and gas distributors to meet energy efficiency targets through end users, a Draft Law on reform and reorganisation of the energy sector, regional programmes promoting renewable sources and energy efficiency and a Code of Good Agricultural Practice. Further additional measures that have been proposed in Italy’ s greenhouse gas reports include further requirements for renewables, fuel and technology switching, cleaner vehicles and increased promotion of sustainable transport.

5.5.11 Luxembourg Luxembourg’ s national programme does not specifically reference its climate change commitments and very few policies and measures that could also reduce emissions of greenhouse gases have been taken into account in the ‘reference scenario’ (BAU). These include the agreement between car manufacturers and the EC concerning CO2 emissions and the progressive introduction of abatement technologies on road vehicles. Luxembourg’ s Strategie nationale de reduction des emissions de gaz a effet de serre (2000) presents six main groups of implemented and adopted measures targeting the energy supply, commercial and residential, transport and business sectors as well as fiscal cross-sectoral measures. The objectives of these measures are to increase the use of renewable energy sources, improve energy efficiency, promote new cleaner technology and sustainable transport and utilise international co-operation.

A series of additional technological and process measures (such as SCR, SNCR, FGR, and low NOx burners19) have been quantified and presented in the NECD national programme for reducing emissions of NOx and VOCs. Further additional measures have also been presented, although not quantified, and many of these will also be key measures for reducing emissions of greenhouse gases.

• Reduction in vehicle use through tax increases for fuels and/or mileage or via regional planning;

19 SCR – Selective Catalytic Reduction; SNCR – Selective Non-Catalytic Reduction; and FGR – Flue Gas Recirculation

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• Modal transfer/behavioural measures;

• Accelerated renewal of the agricultural fleet;

• Regulation or taxation of aviation;

• Reduced fuel consumption; and,

• Promotion of renewable sources of energy.

Additional measures have not been presented in Luxembourg’ s National Strategy for the reduction of greenhouse gases (2000).

5.5.12 Netherlands The emission projections presented in the national programme have been based on ‘reference estimate greenhouse gases’ calculated under the Netherlands evaluation of national climate change measures, and the socio-economic assumptions listed in the programme (and in Appendix A10.5) are based on those made within the national climate change programme. The programme states that a number of additional climate change measures have not been included in the projections made for the national programme as the specific measures had not been agreed at the time.

The impacts of a number of additional policies and measures have been quantified and presented in the national programme, some of which may also impact upon emissions of greenhouse gases. These include tighter standards for central heating boilers and process installations, cookers and boilers, incentives for cleaner vehicles and inland waterway engine modification and various agricultural measures. Other measures that have been presented but not quantified and assessed in the national programme include non-technical measures for road transport such as a mileage based tax and/or speed limit reduction.

The Netherlands 3rd National Communication to the UNFCCC (2002) presents detailed information on a series of implemented, adopted or planned measures predominantly focussing on the transport and energy sectors. Those that could also have an impact on emissions of NECD pollutants, but have not been presented in the national programme (although they may be included in the baseline), include:

• 5% renewables target for 2010;

• promotion of combined heat and power (CHP) plants;

• fuel switching for power production and improved energy efficiency at LCPs, in industry and agriculture;

• EU agreement with car manufacturers on fuel efficient cars;

• Promotion of fuel efficient cars through vehicle taxes and car labelling; and,

• Promotion of sustainable transport, fuel efficient driving and efficient freight movements.

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5.5.13 Portugal The introduction to Portugal’ s NECD national programme states that it is ‘necessary to consider the effect of the Portuguese National Emission Ceilings Plan (PTEN) in other policy instruments, such as the National Climate Change Programme (PNAC)’ . The national programme presents existing policies and measures that have already been implemented or are planned but no additional measures. The quantified impact of the majority of these measures has also been presented. Existing measures that have been reported in Portugal’ s national programme and 3rd National Communication to the UNFCCC include:

• Directive 2001/77/EC: promotion of electricity generation from renewable energy resources;

• Programme E4: promotion of energy efficiency and endogenous energy resources;

• Various measures aimed at the electricity network including an expansion plan for the electricity supply sector improving efficiency;

• Programme P3E: promotion of energy efficiency in buildings;

• Programme Solar Heated Water for Portugal; and,

• ACEA Agreement between EC and car manufacturers for fuel efficient vehicles.

Portugal’ s 3rd National Communication also includes a series of existing measures aimed at the transport sector that have not been presented in the national programme including improvements to, and promotion of, public transport and incentives to minimise the impact of road transport of goods. Additional measures that have been presented focus on further improvements in energy efficiency, increased use of renewables and new clean technologies.

5.5.14 Spain The Spanish NECD national programme does not present any emissions projections for 2010 therefore it is not possible to investigate the extent to which existing and additional measures to reduce emissions of greenhouse gases have been taken into account in projections. However, the programme does present implemented and proposed policies and measures to comply with the ceilings, some of which will also contribute towards reductions in emissions of greenhouse gases. These include:

• National plan for electricity and gas networks to improve energy efficiency and cleaner energy supply;

• Law 54/1997 to improve efficiency, reduce consumption and improve the quality of supply;

• Urban mobility plans to reduce vehicle use;

• National programme for reduction of aviation emissions (within the framework of the Kyoto Protocol);

• Common Agricultural Policy reform; and,

• Plan for the promotion of renewable energy sources.

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A number of other measures, not presented in the NECD programme, with synergetic effects on greenhouse gases and NECD pollutants are presented in Spain’ s 3rd National Communication to the UNFCCC. These include:

• Promotion of cleaner technologies, fuel switching, and improvements in domestic and commercial energy efficiency;

• Development and promotion of public transport and modernisation of transport fleet (aviation and road vehicles); and,

• Measures to reduce emissions from agriculture including controls on waste burning, a rural development plan and agro-environmental standards.

5.5.15 Sweden Climate change policies and their synergies with air pollution have been discussed in the section of Sweden’ s national programme focussing on the energy sector. Sweden is committed to reducing emissions of greenhouse gases by a minimum of 4% by the period 2008-2012 (mean value). The national programme highlights the synergies between this commitment and those for reducing emissions of NOx, SO2 and VOC. 900 million Swedish kronar (over ¼��PLOOLRQ��has been invested (2002-2004) in local climate investment programmes, 90 million Swedish kronar (over ¼��PLOOLRQ��KDV�EHHQ�GHVLJQDWHG�IRU�DQ�LQIRUPDWLRQ�FDPSDLJQ�RQ�FOLPDWH�SUREOHPV�and how to reduce energy use and a further 540 million Swedish kronar (over ¼��PLOOLRQ��KDV�been invested in local energy advice to reduce consumption. Most recently, a new scheme to incentivise more efficient technology was implemented in 2003 with an investment of 325 million Swedish kronar (over ¼��PLOOLRQ�� Existing implemented or proposed measures are presented in the programme although it is not always clear if they have been taken into account in the emission projections. Many of these measures have also been reported under Sweden’ s climate change commitments (to the UNFCCC and under the Monitoring Mechanism to the EC). These include (all measures have been implemented unless otherwise stated):

• Energy and NOx tax;

• Environmental Code (1998:808): improved energy efficiency and use of renewables;

• Local Climate Investment Programmes;

• Quota based electricity certification scheme to increase the use of renewables;

• Local energy advice to reduce consumption;

• Introduction of new energy efficient technology through financial incentives;

• Increased replacement of old wood burners with new environmentally approved ones;

• Road transport taxation and incentivisation of cleaner vehicles;

• Congestion charging (proposed);

• Road user charging scheme for transport of goods (proposed);

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• Waterway charging scheme;

• ‘Swan’ eco-label for cleaner boat engines;

• Aviation charging scheme (landing and take-off); and,

• Agricultural Action Programme (proposed).

Other measures that have been implemented in Sweden and reported in Sweden’ s reports to the Monitoring Mechanism and the UNFCCC but not the NECD national programme include further measures for the transport sector through improved public transport and economical driving projects.

5.5.16 UK The emissions projections presented in the national programme are based on the UK energy projections from an Energy Paper prepared by the Department for Trade and Industry (DTI, 2000). These energy projections take into account existing or planned policies and measures to reduce greenhouse gas emissions including the voluntary agreement between the EC and ACEA to reduce car CO2 emissions, expansion of combined heat and power (CHP) systems, energy efficiency schemes20, the climate change levy and a commitment to increase use of renewables (10% of electricity generation by 2010). However, measures which have been listed in the UK Climate Change Programme as additional have not been included in the baseline projections.

Very few specific policies or measures that could reduce emissions of both greenhouse gases and NECD pollutants have been presented in the national programme (for example, IPPC Directive).

5.6 Summary / Conclusions The key conclusions of the in depth analysis of Member States’ NECD emission projections are summarised below:

• Most Member States appear to have used methodologies to calculate emission projections either consistent with or based on the requirements of the Directive.

• The sectoral scope of historic emissions and projections varies considerably between programmes; and,

• Very few Member States have addressed uncertainty in any great detail and only one country (France) has provided quantitative estimates of the uncertainty associated with its emission projections.

A comparison of Member States’ policies and measures reported in their NECD programmes with those reported under climate change commitments highlighted the general lack of consistency and/or reporting of measures prescribed for each obligation. It is unclear, for the majority of countries, the extent to which measures to reduce greenhouse gas emissions have been taken into account in their NECD emission projections. This is an important issue as, by 20 Energy Efficiency Best Practice Programme, Home Energy Efficiency Scheme and Energy Saving Trust.

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taking an integrated approach to meeting air quality and climate change targets, Member States can comply with their objectives in a much more cost effective manner. A study by the EEA (EEA, 2004d) looking at the ‘ancillary benefits of the Kyoto Protocol for air pollution in Europe’ , concluded that implementing the Protocol could reduce SO2, NOx and VOC emissions in Europe by 5-14%, 4-6% and 1-2%, respectively. Policies to reduce emissions of greenhouse gases can also result in significant savings in the costs of reducing emissions of air pollutants. The levels of reduction (costs and emissions) are dependent upon the mechanism by which the Protocol is implemented. There will also be further benefits to the environment through reduced population and vegetation exposure to ground level ozone (3-5%) and a reduction in exceedences above critical thresholds.

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6. Political and Administrative Procedure of Adoption of the NECD National Programmes

6.1 Information request An information request was prepared and sent out to all EU-15 Member States and/or Regions (in Belgium’ s case) that had prepared and submitted a national programme under the NECD. This included Ireland and the Walloon Region of Belgium even though only draft programmes have been prepared to date. The information request was sent out on 6 October 2004 with a return date specified for 27 October.

The information request focused on four key areas:

• Political procedure for preparing the national programme including its implementation, evaluation and co-ordination with other planning and reporting requirements;

• Consultation and the impact it had on the final programme;

• Problems/barriers encountered during the preparation and implementation of the national programme; and,

• The reporting requirements of the NECD and how they could potentially be improved. This information was collected to assess the general opinions of Member States towards the reporting process and the need for reporting guidelines (see Section 8.2).

A copy of the information request itself and a summary of Member States’ responses are available in Appendices C and D, respectively.

By the 5 July 2005, all EU-15 member States had returned a completed information request.

6.2 Summary of political and administrative procedure of adoption The table on the following page summarises the political and administrative procedure of adoption of the NECD national programmes based on information received from Member States.

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Table 6.1 Summary of the political and administrative procedure of adoption of the NECD national programmes

Authorities involved Implementation Evaluation / Monitoring Independent technical assistance

Co-ordination with other reporting requirements

Austria Federal Ministries, Environment Agency (EA) & local/regional representatives.

Varies according to the type of measure. Programme as a whole must be adopted by the Federal Government.

No formal procedure for evaluation is specified in the legislation. However, intention is to establish provisions for regular reporting.

Studies looking at feasibility & costs of measures have been carried out by independent contractors or the EA.

Development of NECD programme has been based on the energy scenario of the national Kyoto Strategy. Plans under the AQFWD have generally been focussed on PM10 and have not been taken into account in the NECD programme.


Ministries and Administrations dealing with energy, environment, transport, land-use planning & housing.

Content & implementation of the plan are set in the ‘Regional Law on Air’ (Brussels Government, 1999). The plan has no legal force.

Final prescription of the plan requests the IBGE to evaluate the impact of the measures every two years & report back to the relevant institutions, councils & finally the Brussels Government & Parliament.

An economical assessment of the technical measures presented in the plan has been carried out. A similar assessment will be carried out for measures relating to public awareness.

The plan addresses several obligations including the AQFWD, ozone depletion, fluorinated gases and climate change. Brussels Capital Region has no LCPs.


Prepared by Air Policy Section of the Flemish Environmental Administration. In co-operation with the Cabinet of the Minister for the Environment. Other relevant Ministries, Agencies & Administrations have also contributed.

Approved by the Flemish Government in December 2003.

A progress report will be prepared for 2005 including updated emission data and projections, status of measures and results of intersectoral comparison of possible measures.

Most of programme is based on sector specific studies carried out by independent contractors.

Flemish Climate Plan could not be included in NECD programme due to timing of their preparation. LCPD will be met through compliance with ELVs. Measures in the NECD programme are taken into account in air quality plans.

Belgium – Walloon

Ministries for environment, transport, land-use planning & housing. Directorate General for natural resources, environment, technology, research & energy.

NECD programme is an annex to the Walloon Plan for Air which forms the region’s main strategy for reducing air pollution. This was adopted in December 2003.

NECD monitoring procedure has not yet been determined but a monitoring, evaluation & revision procedure of the Air Plan has been prepared.

Programme has been developed with assistance of consultancy (ECONOTEC sprl) who have provided a set of abatement measures. For agriculture, a survey was carried out by another consultancy (SITEREM).

Programme incorporates synergies with greenhouse gas reduction measures and gradual closure of LCPs utilising the limited life derogation of the LCPD.

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Denmark Danish EPA, Ministry of Environment.

NECD programme is not an independent programme developed specifically for the Directive. Made up of series of parts developed for regulating specific sources.

NERI has developed, together with the EPA, emission modules for each sector. These are used to check, at regular intervals, if current legislation is sufficient to fulfil the requirements of the NECD.

No independent technical assistance has been utilised for the development for the programme.

Special reporting scheme to the NECD has been set up. This was found to be more resource efficient than to attempt to co-ordinate it with reporting under the Monitoring Mechanism and to the UNFCCC.

Finland Working group was set up within the Ministry of the Environment, with representatives from the Ministries of Finance, Agriculture & Forestry, Transport & Communications & Trade & Industry.

Programme was approved at a plenary session (September 2002) in accordance with section 26 of the Environmental Protection Act. It obliges relevant authorities to implement & monitor the programme for their specific sectors.

Ministry of the Environment is responsible for monitoring the programme & revising it when necessary. Each ministry will carry out their own periodic evaluation of the implementation of the programme within their own sector & send it to the Ministry of the Environment who will produce a summary report. This will set out further actions if required.

Working group received information on estimates, models & scenarios from experts at the Finnish Environment Institute (SYKE) & the Technical Research Centre of Finland (VTT).

Assumptions presented in the programme are based on those used in planning & monitoring the National Climate Strategy.

Same unit in the Ministry of the Environment is responsible for all three air pollution control programmes (NECD, LCPD & Air Quality Framework Directive).

France Ministries responsible for the environment, industry, agriculture, transport, housing, as well as the Agency in control of energy and transport.

Programme was adopted by Ministerial Decree of 8 July 2003 of the Ministry in charge of ecology, after arbitration by the Prime Minister. It has been/is being implemented by each of the Ministries concerned.

Each year an assessment of the plan must be presented in front of the National Council of Air, (placed near the Minister responsible for the environment). The last assessment was presented on May 24, 2005; the next assessment is envisaged in the first half of 2006.

Programme is based on a study carried out by CITEPA and INERIS. Analysis and results were discussed at meetings with the Ministries concerned (environment, industry, transport, agriculture, housing) and the ADEME (Environment and Energy Management Agency).

Programme is entirely consistent with the national policy to combat climate change and takes into account all measures approved within this framework.

Air quality LCPD plans have not been taken into account in the NECD Programme as they were not available at the time.

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Germany Co-ordinated by Ministry for Environment (BMU) including all relevant Ministries. EA (UBA) & Research Institute for Agriculture (FAL) also involved in its preparation.

‘Soft law’: programme is not legally or politically binding and is based on a ministerial decision. Programme is implemented by relevant public bodies.

Administrative order (33. BImSchV of 21.7.2004). This requires a legally binding annual review of the programme to be carried out (by the UBA).

The Energy-Industry Institute at the University of Cologne (EWI) and the PROGNOS AG compiled a study relating to future energy markets on behalf of the Federal Ministry for Economics & Technology (BMWiT) for the emission projections for 2010. Measures for agriculture were developed by the BMVEL.

A central data base stores emissions data & all the international inventory reporting obligations (including UNFCCC, UNECE, NEC). Aim of this is to take into account synergies, prevent differences between different reporting obligations & avoid double work. The emission calculations are based on the database of the emission inventory of the Federal Office for Environment Protection, which also serves the relevant reporting for the UNFCCC.

Ireland Department of the Environment, Heritage & Local Government developed the programme in consultation with other relevant Ministries & Agencies.

Programme has not yet been officially adopted. Should come into force end of 2004/early 2005 (formal Government Decision).

Will be monitored via Ireland’s national emissions inventory.

All work on programme has been conducted in-house. Some national data is currently under review by consultants.

Plans & programmes have been prepared separately but synergies between them have been identified. Emission projections in Ireland’s NECD programme & in reports under its climate change commitments have been based on the same energy scenario.

Italy Technical Committee made up of members of all the relevant Ministries and representatives of the Italian Regions.

Regulation transposing the NECD (DLgs 171/2004) also established the specific procedure for preparing the national programme. All measures will be adopted by means of ministerial decisions and actions. Relevant body will also be responsible for the monitoring and implementation of that measure.

A specific Committee has been set up that will be responsible for evaluating and monitoring the implementation of the plan. In addition, if necessary this Committee will be able to propose additional measures on top of those that have already been adopted.

ENEA (National Agency for new Technologies, Energy and the Environment) and APAT (Agency for Environmental Protection and Technical Services) are responsible for the preparation of emission inventories and projections (calculated using the RAINS-Italy model).

Programme is based on the same data and projections of the National Climate Strategy. In addition, both the programmes will be submitted and monitored by the same body (CIPE). Working group has been set up to ensure harmonisation and co-ordination of assessment activities and air quality management carried out by the Regions.

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Luxembourg Luxembourg EA. Presented to the public in a press conference held by the Secretary of State of the Environment Ministry. Has also been presented to Parliament environmental experts group.

No specific procedure is foreseen to evaluate and/or monitor the implementation of the plan.

Consultancy (Econotec, Liège/Belgium) has assisted the EA in developing the national programme.

No direct co-ordination has been carried out with other planning or reporting requirements.

Netherlands Ministries of economic affairs, transport, public works & water management, environment & agriculture. RIVM, industry representatives, organisations from relevant sectors & various institutes.

Programme was adopted at a public meeting of the Netherlands Parliament. NEC’s have been divided amongst the different industrial sectors and the programme addresses each sector in turn.

Netherlands has extensive monitoring & reporting system. The RIVM reports every year on the state of the environment (including NEC pollutants). In 2006, the national plan will be reviewed &, if necessary, updated.

Work was commissioned to RIVM (emission assessments), ECN (review of small sources of NOx), Novem (a review of the development of the playing field in Europe), KEMA (potential to reduce SO2 in the electricity sector and the cost effectiveness), CE (refineries) & TME (cost effectiveness of NOx and VOC reduction measures in various sectors).

Assessment of the ‘hitch-hike’ effect was carried out looking at reducing greenhouse gases & the impact this will have on emissions of NEC pollutants, and vice-versa. Similar people involved in the development of the NEC programme were also involved in the implementation of the LCPD. Some interaction was carried out with individuals working on the AQFWD.

Portugal Institute for the Environment (part of the Ministry of Environment and Spatial Planning).

1st version of the NECD programme (PTEN) was drafted & submitted by the end of 2002. A thorough review of PTEN has been conducted in 2004. Portuguese government has not taken a final decision yet concerning the need to a formal adoption of the Programme.

Studies carried out to set up PTEN described a preliminary approach concerning the way it should be monitored, namely identifying the main parameters to monitor & the responsible organisation. Same team which developed the initial studies will be responsible for carrying out the monitoring plan.

Technical analysis has been developed by external consultants including the New University of Lisbon (project leader) & the Research Centre for the Economics of Energy, Transport & the Environment (CEEETA).

PTEN 2002 was developed simultaneously with the National Climate Change Programme by the same project team. PTEN 2004 has been coordinated with Energy, Transport & Climate Change reviewed policies & programmes. Links with air emission inventories & LCPD.

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Spain Ministries of Environment, Transport, Economy, Fisheries, Treasury, Science & Technology & Health (plus specific Directorates within these Ministries).

Adopted by a Resolution of the General Secretary of the Ministry of Environment (September 11th, 2003) published in the Official Gazette on September 23rd, 2003.

Trends in air emissions are monitored and assessed by analysing data reported in the emissions inventory report submitted by Spain to the Secretariat of the Geneva Convention and the associated EMEP Program.

State Secretary of the Treasury (Ministry of the Treasury) produced a report containing fiscal measures and describing new features introduced in this area by the political agreement agreed in March 2003, in ECOFIN. All of these measures were taken into account in the drafting of the programme.

Programme was assessed by the Interministerial Group for the study of environmental directives or other regulatory instruments related to the environment.

Programme integrates all existing regulatory instruments, plans and programs which have an impact on abatement and control of air emissions.

Sweden Ministry of Environment & EPA. Programme was adopted through a bill to the Parliament on environmental targets Prop 2000/01:130. Governmental Decision was passed to send the programme to the Commission & an ordinance directed to the SEPA to implement the programme (SFS 2003:65).

Programme will be further evaluated before an updated version of the implementation plan is produced for 2006.

No independent technical assistance, economic analyses or policy advice was utilised during the development of the programme.

Programme was based on the energy, transport & agricultural scenarios for 2010 which were reported under the Monitoring Directive to the Commission and to the UNFCCC. Very limited co-ordination between the air quality Directives and the NECD. Programme also has strong connections with other Directives for more specific sources.

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UK All Government Departments and Devolved Administrations (Northern Ireland, Scotland and Wales). DEFRA leading its development.

UK’s obligations under the NECD have been transposed into national legislation. No separate national legislation relating to a national delivery programme.

UK’s emission inventories and projections are annually re-evaluated to assess whether or not their emission ceilings will be met. If they are projected to exceed their ceilings then further actions would be taken.

Regulatory and environmental impact assessment (REIA) & development of emission inventories & projections has been carried out by independent consultancies. Studies under other existing & ongoing Government contracts with independent consultants have also been taken into account in the programme’s development, monitoring and evaluation.

Integrated approach taken towards air quality including the AQFWD, IPPC, LCPD and NECD. Measures taken under greenhouse gas commitments are co-ordinated as far as possible. Emission projections take account of existing measures in the UK Climate Change Programme.

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In general, the NECD national programmes have been prepared by the national environmental Agency, Department and/or Ministry in co-operation with other relevant Governmental bodies for sectors such as energy, transport and agriculture. The implementation of the programmes can be split into two separate camps; those countries that see their NECD programme as a stand alone programme which has been developed specifically for the Directive and those that view it as a compilation of existing policies and measures which have already been developed for specific sectors. Those programmes which have been developed independently and specifically for the NECD tend also to have the greatest legal force and have been formally adopted by the national Government and/or relevant implementing bodies. Very few countries have developed a specific procedure for monitoring and evaluation of the implementation of the programme. Some countries have placed responsibility for this on each relevant sector, whereas others plan to annually re-evaluate their emission inventories and projections to keep track of progress. If an exceedence is likely to occur then further actions will be taken.

All but three of the countries (Denmark, Ireland and Sweden) have had independent assistance with preparing their national programmes. The majority of countries have also co-ordinated the development of their NECD programmes with other reporting requirements, most notably with their greenhouse gas/climate change commitments, although a comparison of policies and measures between these different submissions (Section 3) has highlighted several inconsistencies.

6.3 Consultation The table below summarises the level of consultation that has taken place and any problems or barriers that have arisen during the development and implementation of each Member States’ national programme.

Table 6.2 Summary of the level of consultation that took place during the preparation of each Member States’ national programme and any problems or barriers that were encountered

Consultation Problems / Barriers

Austria Consultations with the Austrian Chamber of Commerce and industry representatives for several sectors. Consensus on all of the measures has not yet been achieved.

Several problems with developing the programme. Issues over NECs themselves (absolute values), industry resistance & political & administrative issues (for example, highly fragmented responsibilities).


Some consultation was carried out with the Council for Environment and the Economic and Social Council although this was specifically for the climate section of the plan and not the air quality aspects.

No problems or barriers were encountered.

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All relevant industrial sectors were consulted on the proposals for the NECD. Stakeholders have been consulted through the advisory councils MINA and SERV. Consultation with stakeholders has continued during the whole NEC-process (technical preparations within the Commission, the Commission proposal, negotiations & drafting of the programme). Level of consensus varies between sectors with respect to the policies & measures to be implemented.

Several problems have been encountered including fragmented responsibilities for environmental policy (regional and federal authorities) and the tight timescales involved for preparation and submission of a national programme.

Belgium – Walloon

Some consultation was undertaken with stakeholders although the main aim of this was to gather information rather than to carry out an in depth analysis of the policies and measures included in the NECD programme.

A problem encountered during the development of the programme was the fact that several Directives had to be revised or adopted around the same time & there were issues over the choice of instruments which had to be taken according to the legislation.

Denmark National Agency for Forests and Nature and the National Environmental Research Institute, both within the Ministry of Environment, Danish Energy Agency & the Ministry of Traffic. No consultations were undertaken with industry or NGO’s. No major comments.

No problems or barriers were encountered in relation to the political or administrative procedure for adoption of the national programme.

Finland Key organizations were contacted at the start of the process. Working group circulated the draft programme for comments by email & was also available on the internet. Broad consensus amongst those that submitted comments.

No problems or barriers relating to the political or administrative procedure of adoption of the national programme were encountered.

France Programme was subject of a broad consultation (industries, environmental protection associations, local communities). It was subjected to the opinion of the higher Council of classified installations and presented in front of the National Council of Air; these authorities comprise representatives of NGO’s, industry, local communities etc. There were also a number of exchanges with industry during its development. Final programme available online.

Comments submitted were taken into account as far as possible. Programme was accepted at the time of its adoption by industry although there was no real consensus due to the constraints of the ceilings.

No problems or barriers relating to the political or administrative procedure of adoption of the national programme were encountered.

Germany Consultations with relevant trade associations were carried out at the start & end of the process. No major issues were identified.

No problems or barriers were encountered in relation to the political and administrative procedure for adoption of the national programme.

Ireland Public consultation process was undertaken between July-September 2003 with the aim of informing relevant stakeholders of the development of the emerging programme. The discussion document was made available via the internet. Main issue encountered was that the majority of sectors felt that they were already being sufficiently regulated & shouldn’t be targeted any further.


Italy No consultation has yet been carried out. The Italian legislation does not include a requirement for consultation with the public and/or stakeholders, but it may eventually be required.


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Luxembourg Team of various representatives has been regularly updated about the progress made with the programme. These include representatives from several other Ministries, of the "Chambre des Métiers" & from the industrial sector. Comments from these representatives have been taken into account as far as possible in the further development of the programme.


Netherlands In 2003, an inventory of relevant stakeholders was drawn up & the Director of the Ministry for Environment sent out a letter detailing the steps to be taken, the key deadlines & a request for an assessment of feasible reductions at an acceptable cost. Stakeholders were then invited to comment on the policy theory/policy framework that was to be used in allocating the ceilings to the sectors. Input was used in refining the theory.

A large symposium was held (September 2003) to discuss the concept of the policy paper. At the symposium, the State Secretary invited stakeholders to approach him directly if they felt unfairly treated. These meetings between the State Secretary & stakeholders took place in October.

Most stakeholders felt that the burden of responsibility had been shared equally.

No real problems or barriers were encountered during the development of the programme except for the tight timescales in which it had to be produced.

Portugal Sectoral meetings were held with industry stakeholders for information validation (and improvement of national inventories) & to increase awareness of involved parties, at the start of the process. Information was made available on the internet.

No problems or barriers were encountered in relation to the political or administrative procedure for adoption of the national programmes.

Spain Consultation has been ongoing with other relevant Government Ministries (Transport, Economy, Fisheries, Treasury, Science & Technology & Health).

All relevant inputs arising from the consultation process were included at different stages of the drafting of the Programme. Every new draft released was submitted for comments. The final draft was accepted by all of the Ministries consulted.

Updating the data available and taking into account the most recent policies and measures in calculations is a difficult and time consuming task due to the fact that a consultation process involving different Government Departments is required for adoption of the programme.

These issues have been resolved by strengthening co-operation between different Government Departments.

Sweden Draft proposed version of the national programme was sent out by SEPA to stakeholders in industry & NGO’s to inform them of the programme & give them an opportunity to submit comments (although none were received).


UK Consultation paper on the transposing legislation for the NECD & the national programme itself was sent out for consultation to the public, NGO’s, Industry, Consultancies etc. Full consideration was given to all consultation responses. A relatively broad agreement was achieved between stakeholders so no substantial changes to the national programme were required.

No problems or barriers were encountered in relation to the political or administrative procedure for adoption of the national programmes.

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Aside from Italy, all other countries have carried out some form of consultation with other public bodies and/or relevant stakeholders and the public. A broad consensus was generally reached although some issues have arisen over the specific policies and measures that are likely to be implemented for each sector. Very few problems or barriers were encountered in relation to the political or administrative procedure for adoption of the national programme. Some countries highlighted the tight timescales for reporting as an issue as well as problems relating to implementation where the responsibilities for parts of the programme are fragmented between several different bodies.

6.4 Recommendations The key recommendations for the future development of national programmes, based on the information received via the information request, are summarised below:

• Member States should involve all relevant Government departments, ministries and agencies during the preparation and development of their national programme;

• The actual programme itself should be adopted and implemented by central Government, not just the individual policies and measures reported;

• A specific procedure for monitoring and evaluating the implementation of the national programme and the individual policies and measures should be developed;

• Member States should be encouraged to utilise independent technical assistance for development of their national programme (for preparation and/or validation/verification of emission inventories and projections, in particular);

• Member States should co-ordinate, where possible, the development of their NECD national programme with other national plans and programmes to ensure consistency with respect to underlying assumptions (for example, energy scenarios), policies and measures and emission inventories and projections (where relevant); and,

• Member States should undertake consultation with relevant stakeholders at all stages of the process (programme preparation, implementation and review) to ensure transparency and acceptance of the programme. Consultation during the early stages of development will ensure that the emissions baseline, that forms the basis of the emission projections, is as accurate as possible. It will also improve the acceptance of the policies and measures proposed in the programme when it is eventually implemented.

These recommendations have been taken into account in Entec’ s proposals for guidelines for the reporting of national programmes under the NECD (see Section 8).

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7. Proposals for Additional Essential Questions for each Member State

Entec’ s proposals for questions for each Member State build on the ‘gaps’ identified in the EEA report and include those highlighted in our assessment of the national programmes including questions on:

• the additional measures to be taken, when relevant (if the projections are showing a risk of non attainment of the ceilings);

• the quantification of the impact of the proposed measures; and,

• the major inconsistencies between the various plans and reports.

Table 7.1 below summarises each Member State’ s national programme with respect to meeting the reporting requirements of the NECD and highlighting any inconsistencies with other national plans and programmes. For Belgium, where each Region is responsible for its own emission ceilings and has submitted independent programmes, separate sets of essential questions have been prepared for each Region. Entec’ s proposals for additional essential questions for each Member State have been submitted to the Commission as a separate document with this report.

From the available information, no inconsistencies have been discovered relating to emission projections or quantitative estimates of the impacts of different policies and measures reported in different submissions although this part of the comparison was fairly limited due to the poor level of reporting of disaggregated emission projections. A ‘?’ has been placed in the final column for each Member State as it is not clear, due to the lack of information reported in the NECD programmes, whether or not there are inconsistencies with other submissions relating to the policies and measures taken into account in the emission projections (in particular, legislation taken into account in the CAFE baseline scenarios and policies and measures reported to the Monitoring Mechanism and the UNFCCC). This may just be due to specific policies and measures not being reported in a programme but which have been taken into account in the actual emission projections themselves. However, it is recommended that each Member State provides some further clarification on the matter.

The level of reporting and meeting the requirements of national programmes under the NECD varies considerably between each programme. The key requirements of the NECD that have been consistently not met are the reporting of information on:

• Any anticipated changes in the geographical distribution of emissions; and,

• The socioeconomic assumptions behind the emission projections.

The majority of countries have also failed to report the quantitative impact of individual policies and measures reported in their national programmes. Several countries present the combined impact of groups of policies and measures rather than on an individual basis. No single country has met all of the requirements of the Directive in relation to national programmes.

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Table 7.1 Summary of Member States’ National Programmes and the extent to which they meet the requirements of the NECD (

1

= information provided/requirement met, X = no information provided/requirement not met and

1

/X = only partially reported)

Emission Projections?

Existing policies & measures

Additional policies & measures

Information on geographical distribution?

Information on socio-economic assumptions? BAU BBAU Presented? Quantified?

Emission Ceilings

projected to be achieved under

BAU?1 Presented? Quantified?

Emission Ceilings

achieved under BBAU?1

Status of Implementation

of policies & measures

Inconsistencies with other plans & programmes?

Austria X X

2

X

2

X X (NOx/VOC)

2

/X2

2

/X2 X (NOx/VOC)

2

?

Belgium - Br X

2

2

2

/X

2

X X (VOC)

2

X X (VOC)

2

/X ?

Belgium - Fl X X

2

2

2

X X (VOC/NOx)

2

X

2

2

?

Belgium - Wa X

2

/X

2

2

2

X X (SO2/NOx/ VOC)

2

X X (NOx for transport)

2

?

Denmark

2

2

/X

2

23 2

X X (SO2/NOx/ NH3)

2

/X3

2

/X3 X (NOx/NH3)

2

?

Finland

2

2

/X

2

N/A

2

2

/X

2

N/A N/A N/A

2

?

France X X

2

2

2

X X (SO2/NOx/ NH3)

2

2

/X4 X (NOx/NH3)

2

/X ?

Germany X X

2

2

2

2

X (NOx/VOC/ NH3)

2

2

2

2

/X ?

Greece4

2

2

Ireland X

2

/X

2

2

2

X X (SO2/NOx/ VOC)

2

2

/X5 X (NOx/VOC)

2

/X ?

Italy X

2

/X

2

X

2

X X (NOx/NH3)

2

X ?

2

/X ?

Luxembourg X X

2

2

2

/X X X (NOx)

2

2

/X

2

2

/X ?

Netherlands X X

2

2

X X X (SO2/NOx/ VOC)

2

2

/X X (NOx)

2

/X ?

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Emission Projections?

Existing policies & measures

Additional policies & measures

Information on geographical distribution?

Information on socio-economic assumptions? BAU BBAU Presented? Quantified?

Emission Ceilings

projected to be achieved under

BAU?1 Presented? Quantified?

Emission Ceilings

achieved under BBAU?1

Status of Implementation

of policies & measures

Inconsistencies with other plans & programmes?

Portugal X

2

2

X

2

2

X (VOC)

2

/X X ? X ?

Spain X X X X

2

X ? X X ?

2

/X ?

Sweden X X

2

/X6 X

2

X

2

2

/X X N/A

2

/X ?

UK X X

2

N/A

2

X

2

N/A N/A N/A

2

?

Note 1: The pollutants listed in the brackets are those for which the emission ceiling has been exceeded.

Note 2: Presented in a separate document for NOx only.

Note 3: Presented in a separate document.

Note 4: To date (March 2005), Greece has not yet submitted a national programme under the NECD. However, emission projections have been reported separately to the Commission in December 2003.

Note 5: Only the total impact of additional measures has been presented.

Note 6: Emission projections have been presented for all pollutants except for NH3.

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8. Proposals for Guidelines for Reporting

8.1 Standard of reporting The analyses described in Sections 3, 4 and 5 have highlighted the generally poor level of reporting under the NECD as well as the general lack of consistency between the NECD programmes themselves and with other national plans and programmes. No single country has met all of the requirements for reporting as laid out in the NECD (see Section 7).

This ties in with the key conclusions of the EEA study (EEA, 2004), that there is an explicit need for a structured reporting process to close the ‘gaps’ in reporting with respect to conformity to the Directive and consistency with other plans. A series of recommendations were outlined by the EEA study for meeting the requirements of the Directive and for ‘Good Practice’ (not obligatory). These are summarised below:

Requirements for meeting the Directive:

• A BAU and beyond BAU scenario should be reported;

• Impacts of policies and measures should be quantified;

• Changes in geographical distribution of pollutants should be reported (if there is no change this should be made clear); and,

• Socio-economic assumptions and model parameters must be reported.

‘Good Practice’ :

• Trends in key sectors should be disaggregated for projections (where possible, consistent with that used in emission inventories);

• Quantified uncertainty in emission projections should be reported; and,

• List relevant implementing body for each policy and the type of policy instrument.

The aim of guidelines for reporting under the NEC Directive will therefore be to improve the quality of reporting in terms of content relating to the requirements of the Directive and to improve the consistency of these plans with those produced by other Member States and those produced under other legislation. They should focus on the specific areas for improvement that have been highlighted by the EEA and in this study.

8.2 Member States’ comments on reporting From the individual country perspective, there is also an urge for a more structured reporting process to make preparing national programmes a more fluent process. The information request, described in the previous section (detailed information available in Appendix D), also gave Member States the opportunity to comment on the reporting requirements of the NECD and

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whether they felt that this provided sufficient guidance for preparing a national programme. A summary of their comments is available below in Table 8.1.

Table 8.1 Summary of comments received from Member States on how the reporting procedure under the NECD could be improved (Section 4 of the information request)

Austria Reporting is not considered a significant problem with respect to the process for establishing the national programme. We expect that an extension of reporting requirements may improve the situation mainly for the Commission (regarding comparability of programs) but not for Member States.

Belgium – Brussels Capital

Reporting requirements, as set out in the NECD, are not sufficiently clear to help produce a national programme. In particular, Article 6 of the NECD is not sufficient. IBGE suggests:

- to use Annex 4 of the Air Quality Framework Directive for the plan content;

- to use a DPSIR21 methodology for the plan structure; and,

- to integrate in a unique document all the plans concerning air and, if possible, climate.


Although the requirements were sufficiently clear, it could be useful to provide a more stringent framework for the programme to be prepared. This would facilitate the comparison of the programmes by the different member states and the (ambition level of the) measures each member state has to implement or has planned to take.

A series of recommendations have also been reported.

Belgium - Walloon

The reporting requirements, as set out in the NECD, were sufficiently clear to help produce the regional programme.

Denmark The requirements for reporting, as set out in the NECD, were not sufficiently clear to produce a national programme. Guidance from the Commission on reporting would be most welcome and would save time.

Finland There were no clear guidelines for reporting so preparing the programme in the timescales involved was very difficult.

France The requirements for reporting, as set out in the NECD, were sufficiently clear to produce France’s national programme. However, it would be useful for the programmes prepared by Member States to be comparable. A template would standardise the presentation of the programmes and ensure that the information required for their comparison is included.

A series of more general comments on the NECD itself have also been reported.

Germany The guidelines for reporting under the NECD do not fully define the Commission’s information needs and therefore the organisation of the programme is left, to a large extent, to the judgement of the Member State.

Ireland A more formalised template for reporting could potentially be introduced although this would clash to some extent with the subsidiarity required by any national programme.

Italy The requirements, as set out in the NECD, were not sufficiently clear to produce Italy’s national programme. Clearer rules concerning the methodologies, specified in Annex III of the NEC Directive, should be applied in drawing up emissions inventories and projections. The frequent changes introduced in such methodologies significantly affect the inventories creating uncertainties with projections, reduction gaps and consequently on national programme targets and measures.

This could be useful for simplifying the exchange of information among Member States.

21 Extract from presentation given by Gabriel Torres at the Workshop on Plans and Programmes on Air Quality and under the NECD, Brussels, September 2004: ‘In the plan, the "Drivers" are the power consumption and the industrial practices, "Pressures" are the atmospheric emissions of pollutants, the part "State" relates to the quality of the ambient air in Brussels, the "Impacts" are the influences of this quality of the air and, finally, the "Responses" are the actions which will be put in place between 2002 and 2010.’

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Luxembourg The requirements for reporting, as they are currently set out in the NECD, leave the Member States freedom to decide what information to include in their national programmes.

Netherlands A good starting point could be the development of a hierarchy of European regulations, or another methodology for decision making. For example, if the strict implementation of directive A results in problems with ceilings directive B, which one should be chosen? Going stricter than A may be necessary to realize B, but may also lead to issues of non-compliance with A. Whilst implementing A strictly, will mean non-compliance with B.

Portugal It is very important that the Commission provide some guidelines in order to clarify all of the information which should be considered and presented when setting up a NEC Programme. The format for reporting should also be harmonized in order to enable comparisons between Member State assumptions and results.

Spain The requirements for reporting, as set out in the NECD, were sufficiently clear to produce Spain’s national programme.

Sweden The requirements for reporting, as set out in the NECD, were sufficiently clear to produce Sweden’s national programme.

UK The requirements on Member States of the NECD itself are relatively clear. However, the current requirements for producing national programmes make a number of assumptions which are not necessarily valid and can lead to difficulties. The main problem is the assumption that there will be a separate programme devoted to the NECD. In the case of the UK, there is an integrated framework to deliver air quality improvements and the NECD is just part of the overall action to improve air quality.

It might be better if any revised NECD did not seek to identify a national programme identifying measures but rather included a requirement for the tracking of progress towards the ceilings identifying current levels, the forecast effect of current policies, and whether (and what) new policies would be needed to meet the obligations.

It is important that the design of reporting obligations is correct, so that there can be confidence that they will provide information necessary for compliance checking, and that no unnecessary obligations on Member States are created.

8.3 Consistency with greenhouse gas reporting Section 3.3.2 highlights the overall consistency, and inconsistency, between Member States’ NECD programmes and reports produced under greenhouse gas and climate change commitments. The scope of the different programmes and reports are very similar and there is considerable overlap between policies and measures and the sectors targeted for emission reductions. Therefore, to improve the ease by which programmes can be prepared and also compared, the development of any reporting guidelines for reporting under the NECD should aim to bring the information submitted in line with that reported under greenhouse gas and climate change commitments, as far as it is appropriate.

To ensure consistency with plans and programmes relating to greenhouse gas emissions, the implementing provisions and reporting requirements of the European greenhouse gas Monitoring Mechanism could be modified to apply to reporting under the NECD as well, thus bringing the two in line as far as possible.

Article 3.2 of the legislation (Decision No 280/2004/EC of 11 February 2004 concerning a mechanism for monitoring Community greenhouse gas emissions and for implementing the Kyoto Protocol) describes the reporting of information on policies and measures and emission projections and is most relevant to the NECD.

‘Member States shall, for the assessment of projected progress, report to the Commission, by 15 March 2005 and every two years thereafter:

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(a) information on national policies and measures which limit and/or reduce greenhouse gas emissions by sources or enhance removals by sinks, presented on a sectoral basis for each greenhouse gas, including:

(i) the objective of policies and measure;

(ii) the type of policy instrument;

(iii) the status of implementation of the policy or measure;

(iv) indicators to monitor and evaluate progress with policies and measures over time, including, inter alia, those indicators specified in the implementing provisions adopted pursuant to paragraph 3;

(v) quantitative estimates of the effect of policies and measures on emissions by sources and removals by sinks of greenhouse gases between the base year and subsequent years, including 2005, 2010 and 2015, including their economic impacts to the extent feasible; and

(vi) the extent to which domestic action actually constitutes a significant element of the efforts undertaken at national level as well as the extent to which the use of joint implementation and the clean development mechanism and international emissions trading, pursuant to Articles 6, 12 and 17 of the Kyoto Protocol, is actually supplemental to domestic actions, in accordance with the relevant provisions of the Kyoto Protocol and the Marrakech Accords;

(b) national projections of greenhouse gas emissions by sources and their removal by sinks as a minimum for the years 2005, 2010, 2015 and 2020, organised by gas and by sector, including:

(i) ‘with measures’ and ‘with additional measures’ projections such as mentioned in the guidelines of the UNFCCC and further specified in the implementing provisions adopted pursuant to paragraph 3;

(ii) clear identification of the policies and measures included in the projections;

(iii) results of sensitivity analysis performed for the projections; and

(iv) descriptions of methodologies, models, underlying assumptions and key input and output parameters.’

The final version of the implementing provisions under the EU greenhouse gas Monitoring Mechanism is due to be published soon (Herold pers comm., 2005) and sets out a more detailed description of the information to be submitted to the Commission including template tables for the reporting of data, sets of indicators for monitoring progress and parameters on projections that should be reported for each sector.

The implementing provisions refer to the requirements of the Kyoto Protocol and the guidelines for reporting to the UNFCCC (UNFCCC, 2000 & 2003). These guidelines set out the template for reporting of policies and measures including the type of information that should be provided for each measure. The reporting of policies and measures in Member States’ NECD national programmes was relatively poor so a more defined format, including specific requirements for the type of information to be reported for each measure, could be particularly beneficial. The guidelines for reporting to the UNFCCC and CLRTAP advise Parties to follow good practice when preparing emissions data so that they can ‘…improve transparency, consistency,

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comparability, completeness and accuracy’ . These principles should also be applied to reporting under the NECD to improve the level and consistency of reporting between Member States and with other national submissions, particularly those relating to greenhouse gases.

8.4 Guidelines for reporting

8.4.1 Information sources Entec’ s proposals for guidelines for reporting of national programmes under the NECD have been submitted to the Commission as a separate document with this report. They have been developed based on the following:

• Meeting the requirements of the NECD;

• Conclusions and recommendations of EEA initial assessment of Member State NECD national programmes (EEA, 2004);

• Analysis and conclusions from this study;

• Guidelines for reporting to CLRTAP (UNECE, 2003);

• Guidelines for reporting to UNFCCC (UNFCCC, 2000 & 2003);

• EU greenhouse gas Monitoring Mechanism implementing provisions; and,

• Discussions with EEA.

8.4.2 Structure of guidelines Figure 8.1, on the following page, describes the way in which Entec’ s proposals for guidelines for reporting of national programmes have been structured.

Recommendations relating to the political and administrative procedure of adoption of a national programme have been included in the proposed guidelines as required by the Technical Annex of this study. The recommendations for the preparation and adoption of a national programme have been based on the information received from the information request, summarised in Section 6.

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Figure 8.1 Proposed structure of guidelines (* = mandatory under the NECD)

1.1 Background Description of requirements of the Directive.

1.2 Purpose of these guidelines Sets out aims and objectives of the guidelines.

1.3 Scope Pollutants, timescales, sources and sectoral scope.

1.4 National programme content and structure

Provides a suggested structure for a national programme and the type of information to be reported.

1.5 Reporting

1.5.1 General General reporting issues

1.5.2 Executive summary Member States should provide an ES to a national programme.

1.5.3 Political and administrative procedure of adoption of a national programme

- Procedure of adoption of national programme Description of the information that should be reported.

- Authorities involved Recommendations relating to the involvement of all relevant parties in the development of the programme.

- Co-ordination with other reporting requirements Recommendations relating to the co-ordination of the NECD programme with other submissions.

- Stakeholder consultation Recommendations on stakeholder consultation.

1.5.4 Policies and measures* Sets out the type of information that should be reported for each

individual policy and measure and a format for reporting.

1.5.5 Emission inventories and projections*

- Principles of emission estimations Description of the principles that should be adhered to during the preparation of emission inventories and projections.

- Methodologies Sets out the methodologies that should be used for preparing emissions data including the sectoral scope and reporting of ‘with measures’ and ‘with additional measures’ scenarios.

- Completeness Describes procedures for dealing with gaps in data.

- QA/QC Procedures Sets out information that should be provided on validation and verification of emissions data.

- Uncertainty Sets out the procedures that should be carried out and described in the national programme relating to uncertainty.

1.5.6 Socio-economic assumptions*

Sets out the assumptions and parameters that should be reported (based on those described in Annex IV of the implementing provisions of the EU GHG Monitoring Mechanism).

1.5.7 Costs and benefits

Member States are encouraged to report the costs associated with individual policies and measures as well as the potential benefits for health and the environment from reducing emissions.

1.5.8 Geographical distribution of emissions* Specific requirement of the NECD.

1.5.9 Evaluation and monitoring of the national programme

Recommendations for the development of a specific procedure for monitoring and evaluating a national programme.

Annex A Nomenclature For Reporting (NFR) source categories

Annex B Reporting format for policies and measures

Annex C Socio-economic assumptions and model parameters to be reported

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8.4.3 Discussion

NECD requirements Under the current requirements of the NECD, Member States are only required to report information on policies and measures, emission inventories and projections, socio-economic assumptions and any potential changes in the geographical distribution of emissions (Sections 1.5.4, 1.5.5, 1.5.6 and 1.5.8 of guidelines). Entec’ s proposed guidelines address these requirements whilst also going beyond the current NECD to improve the consistency of national programmes between Member States and also with reporting under the greenhouse gas Monitoring Mechanism.

Improving the quality of reporting and the consistency between Member States The proposed guidelines have been prepared to ensure that all the requirements of the Directive are met by specifically defining the type of information that should be reported and, for policies and measures, providing a format for presenting it. This should ensure that the information submitted by Member States under the NECD will be much more consistent and comparable. The table below outlines how the recommendations made in the EEA study (EEA, 2004) have been accommodated for in the proposed guidelines for reporting.

Table 8.2 Recommendations taken into account in preparation of reporting guidelines

Requirements for meeting the NECD

A BAU and beyond BAU scenario should be reported

This is specifically requested in Section 1.5.5 of the guidelines particularly where an emission ceiling is projected to be exceeded or only just complied with (within 10%).

Impacts of policies and measures should be quantified

Section 1.5.4 of the guidelines sets out the type of information that should be reported for each individual policy and measure including the quantitative impact on emissions of each NECD pollutant. Annex B presents the tabular format for reporting this information. This information is in line with that which must be reported to the EU GHG Monitoring Mechanism and the UNFCCC.

Changes in geographical distribution of pollutants should be reported (if there is no change this should be made clear)

Section 1.5.8 of the guidelines specifically requests Member States to address this in their national programmes even if no changes are anticipated.

Socio-economic assumptions and model parameters must be reported

Section 1.5.6 of the guidelines specifically requests Member States to report quantitative information on the key socio-economic assumptions and model parameters behind its emission projections. Annex C sets out the specific assumptions and parameters that should be reported. This list is taken from the implementing provisions of the EU GHG Monitoring Mechanism.

‘Good practice’

Trends in key sectors should be disaggregated for projections (where possible, consistent with that used in emission inventories)

The guidelines specifically request Member States to report their emission inventories and projections for each pollutant broken down by the source sector categories as set out in the nomenclature for reporting (NFR). The full NFR sectoral breakdown is provided in Annex A of the guidelines.

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Quantified uncertainty in emission projections should be reported

Member States are specifically requested to undertake a sensitivity analysis of their emission projections defining a high, central and low scenario (in line with the implementing provisions of the GHG Monitoring Mechanism). Member States must also report the uncertainty associated with their inventories and projections providing quantitative estimates, where available.

List relevant implementing body for each policy and the type of policy instrument

Section 1.5.4 of the guidelines sets out the type of information that should be reported for each individual policy and measure including the implementing body for each policy and type of policy instrument. Annex B presents the tabular format for reporting this information. This information is in line with that which must be reported to the EU GHG Monitoring Mechanism and the UNFCCC.

Improving the consistency with greenhouse gas plans and programmes To improve the level of consistency of reporting with greenhouse gas plans and programmes relevant sections of the proposed guidelines have been based on the guidelines for reporting to the UNFCCC (UNFCCC, 2000 & 2003) and the implementing provisions of the Monitoring Mechanism. The following requirements of the proposed NECD guidelines have been developed in line with reporting under greenhouse gas obligations:

• In line with the reporting of national communications to the UNFCCC a proposed structure has been provided for setting up a national programme and Member States are requested to submit a translation of their programme into English;

• Member States are requested to include an executive summary with their national programme indicating whether or not its NECs are likely to be achieved;

• The information that should be reported for each policy and measure and the format in which it should be presented is identical to the way in which policies and measures are reported under greenhouse gas obligations;

• In line with greenhouse gas reporting of emission projections, Member States are requested to report a ‘with measures’ and a ‘with additional measures’ projection for each pollutant clearly identifying which policies and measures have been taken into account in which projection;

• Member States are requested to describe all QA/QC procedures that have been undertaken to verify and validate their emissions data;

• Member States are required to undertake a sensitivity analysis of their projections defining a high, central and low scenario;

• The uncertainties associated with the emissions inventories and projections should be reported including quantitative estimates; and,

• The socio-economic assumptions and model parameters behind the projections that Member States are requested to report with their national programme are identical to those in the implementing provisions of the Monitoring Mechanism.

Increasing the linkages between NECD and climate change reporting should lead to the promotion and increased consideration of measures that reduce both greenhouse gases and NECD pollutants.

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Monitoring progress towards meeting ceilings A further potential improvement in the reporting guidelines for national programmes under the NECD could be the inclusion of a requirement for Member States to report annually on a series of indicators to monitor progress towards the NECD. The EEA have identified a number of criteria for selecting indicators for monitoring air pollution (EEA, 2004e). Indicators should:

• Answer main policy questions and communicate meaningful messages for policy makers and implementers;

• Be comparable between countries; and,

• Be transparent regarding the data used; be informative to a general public; and, provide the best available scientific insights.

The implementing provisions of the greenhouse gas Monitoring Mechanism requires Member States to report annually with their emission inventories on a series of ‘priority’ , ‘additional’ and ‘supplementary’ indicators (specified in Annex II of the provisions). Examples of these indicators include: specific CO2 emissions of households (‘priority’ ), specific CO2 emissions of iron and steel industry (‘additional’ ) and carbon intensity of transport (‘supplementary’ ). Member States are also required to report every other year on indicators, listed in Annex III of the implementing provisions, to monitor and evaluate progress with policies and measures. Accompanying each of the lists in Annexes II and III is a description of the numerator and denominator required to calculate each indicator (see examples below).

Table 8.3 Examples of priority indicators taken from Annex II of the Monitoring Mechanism implementing provisions

Nomenclature in Eurostat energy efficiency indicators

Indicator Numerator / denominator

Guidance / Definitions

Total CO2 emissions, kt Total CO2 emissions as reported in the CRF

MACRO Total CO2 intensity of GDP, t/Mio Euro

GDP, Bio Euro (EC95) Gross domestic product at constant prices

CO2 emissions from passenger cars, kt

CO2 emissions from the combustion of fossil fuels for all transport activity with passenger cars.

TRANSPORT Specific CO2 emissions of passenger cars g/100km

Number of kilometres by passenger cars, Mkm

Number of vehicle kilometres by passenger cars.

A similar set of indicators could be developed for reporting under the NECD which, if prepared and submitted annually with emission inventories, would allow Member States and the Commission to monitor and compare progress towards the NECs. The simplest indicator that could be reported to monitor Member States’ progress towards achieving their NECs would be a Distance to Target Indicator (DTI) expressed as a % of the ceiling. This could be calculated annually by each Member State and for each pollutant by dividing latest national emissions of a

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pollutant by the NEC. This would provide a useful insight into how far each Member State is from their NECs and how much progress has been made on a year to year basis.

Many of the indicators required under the Monitoring Mechanism could in fact be adapted to be used for monitoring progress towards achieving the targets of the NECD. For example, the two indicators presented above could be modified for reporting under the NECD by changing CO2 emissions for emissions of NECD pollutants. Member States could report NOx, SO2 and possibly VOC emissions of passenger cars (expressed as g/100km) or total NOx and/or SO2 intensity of GDP (expressed as t/Mio Euro).

Reducing the burden of reporting The first annual LRTAP/NEC emission inventory review carried out by EMEP and the EEA has already identified the potential to harmonise and/or combine the reporting of emission inventories under the NECD and CLRTAP as some Parties/Member States report the same submission to both. The study recommended that the reporting of emission inventories under the NECD be moved to 15th February each year to coincide with reporting to CLRTAP. Another potential option could be that Member States report their NEC emission inventories to the Commission and EEA as required by the Directive (by December 31st each year). The Commission and/or EEA could then compile a Community report, similar to the process under the Monitoring Mechanism, which could be sent direct to CLRTAP. This would help to reduce the reporting burden on Member States.

The comparison of the NECD national programmes with other national plans and programmes highlighted the linkages and differences between the different submissions. There is a significant overlap of policies and measures reported in NECD national programmes and in plans and programmes reported under the LCPD, Air Quality Framework Directive and under greenhouse gas obligations (to the UNFCCC and the Monitoring Mechanism). In particular, a large proportion of policies and measures reported to reduce greenhouse gas emissions will also reduce emissions of NECD pollutants and vice-versa. The proposed guidelines also highlight how similar the two sets of submissions could be in the future as they have been based on the implementing provisions of the Monitoring Mechanism. The potential for combining reporting under the NECD and the Monitoring Mechanism could be hugely beneficial in reducing the reporting burden on Member States. One complete emission inventory for all pollutants could be submitted each year and national programmes including projections, policies and measures and other relevant information could also be combined. Although there are some clear differences between the two sets of submissions, combining the reporting of greenhouse gases and NECD pollutants could help to improve consistency between submissions and Member States.

Aside from the linkages between reporting under the NECD and to CLRTAP and the Monitoring Mechanism, all of the policies and measures reported in LCPD plans and the majority in air quality plans will also contribute towards a Member State achieving their ceilings under the NECD. Some technical measures in air quality plans, however, are aimed specifically at reducing particulate matter emissions such as particulate traps, for example, and will not reduce emissions of current NECD pollutants. The level of consistency of reporting of policies and measures between NECD national programmes and LCPD and air quality plans varied considerably between Member States. NECD national programmes, unsurprisingly, tended to include European and national level policies and measures such as the LCPD itself without outlining what specific measures would be required at a smaller scale (for example, on a plant-by-plant basis). In contrast, LCPD and air quality plans reported local and plant specific

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measures that have been, or will be, implemented to comply with the legislation. Although no emission reduction plans were submitted under the Solvent Emissions Directive within the timescales of this study, these plans should contain installation specific measures that have been or will be taken to reduce VOC emissions in accordance with the Directive.

A potential area for further investigation could be whether or not it would be feasible for Member States to report, in one submission, a full complement of policies and measures that have been, or will be, implemented to comply with the requirements of these Directives. This could be reported on a regular basis (for example, biannually) in a standard format such as that proposed in the draft guidelines. This submission would ensure consistency and transparency of reporting between submissions and provide a detailed insight into the level of action of each Member State in each sector. As well as policies and measures reported under the NECD, LCPD, Air Quality Framework and Solvent Emissions Directives, this submission could go even further and be combined with policies and measures reported under greenhouse gas obligations.

In addition to this, there is also the potential to synchronise and even combine the reporting of emission inventories and projections under the NECD, LCPD and possibly under the Monitoring Mechanism. A combined inventory would have to be sufficiently disaggregated to the level of detail required under the LCPD (for example, ‘new’ and ‘existing’ LCPs) or more detailed emissions for the sector could be provided as an attachment to the core inventory. The achievement of consistency in the sectoral disaggregation of the inventory would have to be investigated further, particularly if greenhouse gases were to be reported as well. Plans and programmes reported under the Air Quality Framework Directive deal with exceedences of ambient air concentration limit values rather than total emissions so this information would still have to be reported separately.

Information on costs and benefits of policies and measures The proposed reporting guidelines include a section on costs and benefits data, encouraging Member States to report on:

• the additional costs (in Euros) and cost effectiveness (¼�W� SROOXWDQW� DEDWHG�� RI�individual policies and measures in national programmes; and,

• the additional benefits for health and/or the environment associated with policies and measures in national programmes.

Although it could be beneficial to make this a mandatory requirement for reporting (for example, ex-post compliance costs could be useful for calibrating models and providing a better insight into the ‘real’ costs involved), the additional burden on Member States is likely to be high due to the amount of additional effort involved in developing good quality and transparent cost and benefit data.

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9. References

Amann, M., Bertok, I., Cofala, J., Gyarfas, F., Heyes, C., Klimont, Z., Schöpp, W. and Winiwarter, W. (2004) The CAFE Baseline Scenarios: Air quality and impacts. Presentation at the CAFE baseline dissemination workshop September 27, 2004, Brussels.

Danish Ministry of Environment (2002) Projection Models 2010, Danish emissions of SO2, NOx, NMVOC and NH3, technical report no. 414, National Environmental Research Institute, Ministry of the Environment, December 2002.

Defra (2003) Guidelines for the Measurement and Reporting of Emissions by Direct Participants in the UK Emissions Trading Scheme. June 2003.

DTI (2000) Department of Trade and Industry Energy Paper 68: Energy Projections for the UK, 2000.

EC (2004) Personal communication from Jesper Jorgensen, DG Environment, European Commission, 15 July 2004.

EEA (2004) An initial assessment of Member States' national programmes and projections under the National Emission Ceiling's Directive (2001/81/EC). European Topic Centre on Air and Climate Change (ETC/ACC) Technical Paper 2003/8 for the European Environment Agency, April 2004.

EEA (2003) Greenhouse gas emission projections for Europe. European Topic Centre on Air and Climate Change (ETC/ACC) Technical Paper for the European Environment Agency, 2003.

EEA (2004a) Reporting National Programmes under the National Emission Ceiling Directive. Presentation by Andreas Barkman (EEA) and Peter Taylor (ETC/ACC) at the Workshop on Plans and Programmes of Air Quality and National Emission Ceilings Directives, Brussels, September 2004.

EEA (2004b) Analysis of greenhouse gas emission trends and projections in Europe 2003. European Environment Agency, EEA Technical Report No 4/2004, October 2004. Available at: http://reports.eea.eu.int/technical_report_2004_4/en

EEA (2004c) EMEP/CORINAIR Emission Inventory Guidebook - 3rd edition September 2004 Update, European Environment Agency, September 2004.

EEA (2004d) Exploring the ancillary benefits of the Kyoto Protocol for air pollution in Europe, European Environment Agency, 2004.

EEA (2004e) Air Pollution in Europe 1990-2000, European Environment Agency, EEA Topic Report 4/2003, 2004.

EMEP/EEA (2004) Inventory Review 2004. Emission Data reported to CLRTAP and under the NEC Directive. EMEP/EEA Joint Review Report by the European Environment Agency & Meteorological Synthesising Centre - West (MSC-W), 2004.

Entec (2004) Review of the Large Combustion Plant Directive, draft final report for DG Environment, European Commission, December 2004.

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Finnish Government (2001) National Climate Strategy - Finland. Government report of 27 March 2001 to Parliament. Available online at: http://ktm.elinar.fi/ktm_jur/ktmjur.nsf/All/CCDA20C55C9000A7C2256A6400218CF2/$file/National%20Climate%20Strategy%20Finland_2001.pdf. Accessed September 2004.

Herold pers comm. (2005) Personal communication from Anke Herold, Oeko-Institut e.V., 29 January 2005.

IIASA (2004) CAFE baseline available from the RAINS Model. Published online at: http://www.iiasa.ac.at/web-apps/tap/RainsWeb/index.html Accessed November 2004.

IIASA (2004a) Baseline scenarios for the Clean Air For Europe (CAFE) Program, International Institute for Applied Systems Analysis, October 2004. Final report for DG Environment, European Commission.

Luxembourg (2000) Strategie nationale de reduction des emissions de gaz a effet de serre – First Part, May 2000.

Syri S, Karvosenoja N, Lehtilä A, Laurila T, Lindfors V, Tuovinen J-P (2002). Modelling the impacts of the Finnish climate strategy on air pollution. Atmospheric Environment 36: 3059-3069.

UNECE (2003) Air Pollution Studies No. 15 – Guidelines for Estimating and Reporting Emission Data under the Convention on Long-range Transboundary Air Pollution. Prepared by the Convention’ s Task Force on Emissions Inventories and Projections and the secretariat, United Nations Economic Commission for Europe, Geneva, 2003.

UNFCCC (2000) Review of the implementation of commitments and of other provisions of the convention – UNFCCC guidelines on reporting and review. Conference of the Parties, fifth session, 25 October – 5 November 1999. Published 16 February 2000.

UNFCCC (2002) 'Good practices' in policies and measures among parties included in Annex I to the Convention. Policies and measures reported by Parties included in Annex I to the Convention in their third national communications. United Nations Framework Convention on Climate Change, 17 October 2002.

UNFCCC (2003) Review of the implementation of commitments and of other provisions of the convention – UNFCCC guidelines on reporting and review. Conference of the Parties, eighth session, 23 October – 1 November 2002. Published 28 March 2003.

VROM (2004) Personal communication from Julia Williams-Jacobse, Ministry of Housing, Spatial Planning and the Environment, 10 November 2004.

VROM (2005) Personal communication from Marjan van Giezen, Ministry of Housing Spatial Planning and the Environment, 31 January 2005.

VROM (2004a) Press release: Decision on trade in NOx emissions rights submitted to Council of State. VROM International, Netherlands Ministry of Housing, Spatial Planning and the Environment, 18 October 2004. Available at: http://www2.vrom.nl/pagina.html?id=9186 Accessed 11 November 2004.

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