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30 November 2022
PREVENT, - Air Quality

Addressing air quality is crucial to public health and to protect people with allergy, asthma and COPD. Late October, the European Commission presented the much-awaited proposal on the Ambient Air Quality Directives, the framework that governs air quality in the EU. The proposal is a crucial milestone, taking the initial step towards the revision of the EU air quality standards, the first in almost 15 years.

The proposal falls under the overarching intention of the Commission to achieve zero pollution, a key pillar of the EU Green Deal of President Von der Leyen.

In EFA’s longstanding advocacy for clean air, our main ask is that the new EU standards be driven by the most up-to-date knowledge on the impact of air pollution on health, mainly reflected by the latest WHO Air Quality Guidelines.

Air quality as a major health threat in Europe

Air quality remains a serious concern for people in Europe, and a major threat to health and the environment, as the latest Eurobarometer survey reveals. This population concern arises despite clear and accessible information on air quality lacks in most countries. In fact, support for stronger EU air quality standards stands high overall.

The EFA patient community is one of the population groups most affected by air pollution. Breathing harmful pollutant particles can cause severe damage on the lungs, exacerbate disease symptoms, increase hospitalisations and even lead to death. In addition, air pollution has a considerable social and economic cost on patients, leading to rising medical needs and absence from school and work.

Therefore, in our longstanding advocacy for clean air, EFA’s main ask is that the new EU standards be driven by the most up-to-date knowledge on the impact of air pollution on health, mainly reflected by the latest WHO Air Quality Guidelines.

Revised proposal: a mixed bag filled with promising measures and grey areas

The Commission has provided updates to the current Air Quality Guidelines, while also introducing new elements that are important from an EFA perspective. Overall, while the revised proposal constitutes a step towards a positive direction, for EFA it is deceiving to see lack of leadership in proposing stronger ambition to protect health, further clarity, as well as rigorous implementation. Some of the key points are outlined below:

  • The health community including EFA expected a legislation that would align with science. The science informing the air quality legislation are the WHO Air Quality Guidelines (2021) on the pollutant limits. Instead of a aligning fully with the WHO guidelines, the Commission opts for closer alignment, including on hazardous pollutants such as PM2,5 and NO2. Notably, the proposal mentions that the level of alignment will be a ‘political choice’, suggesting strong political drivers in the debate on air quality, rather than health-based criteria.
  • The Commission does not instil urgency to comply with the levels. The timeline proposes limits to be achieved by 2030 (as an interim year), and a scope for full alignment by 2050. For EFA, this timeline postpones the meaningful measures for later. Moreover, post-2030, the target will be ‘full alignment with the 2021 WHO recommendations’. Such a provision offers no clarity on what would happen if the WHO guidelines are once again updated by then – possibly with recommendations for even lower limits.
  • The proposal establishes a regular review mechanism to ensure that the latest scientific evidence of air quality guides future decisions. This is a promising element, as long as it leads to swift legislative adjustments on the basis of latest science on the impact of air pollution on health. Such a presumption seems unlikely as the timeline itself is leaving people unprotected from health-damaging pollution levels in the decades to come.
  • While some requirements are established to monitor pollutants proven to damage human health, such as ultrafine particles and black carbon, the proposal fails to integrate them fully into the framework. On the one hand, the monitoring is limited to industrial supersites. On the other hand, measures to monitor Volatile Organic Compounds (VOCs) are limited to recommendations rather than mandatory monitoring.
  • Access to public information on air quality is a fundamental right and can support effective individual prevention and public health. The proposal includes two key points that are of particular interest to the EFA community:
    • The introduction of a national air quality index covering five dangerous pollutants with hourly updates is a positive development. However, it lacks details on access, and terms of refence around the information provided. for EFA, it should be clear that the index must be linked with the public information requirements, including the need for information to contain messaging targeted to vulnerable groups of the population, and instructions on how to use that information.
    • Information thresholds continue covering only ozone, leaving others uncovered. However, given that they are relevant to sensitive population and vulnerable groups, they must expand to other dangerous pollutants such as PM2,5, PM10 and NO2.
  • The proposal introduces completely new provisions on access to justice (for both individuals and organisations); and compensation for health damage due to exposure to air pollution. Having fought hard on these issues, at EFA we welcome these provisions as we consider them crucial for accountability, transparency and an empowered public. We are looking forward to seeing them being put to practice.

You can read the full revision proposal and the impact assessment (four parts) here.