Ambient air quality and cleaner air for Europe. Recast

FEEDBACK ON AIR QUALITY REVISION OF EU RULES Submitted to https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12677Air-quality-revision-of-EU-rules Submitted on 14 March 2023 Submitted by Leonor Tarrason User type Academic/research Institution Organization NILU Organization size Medium (50 to 249 employees) Country of origin Norway Initiative Air quality - revision of EU rules NILU appreciates…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Air Pollution is a critical point to address and SUEZ supports the new revision and its alignment with the WHO recommendations. Reducing air pollution helps to put the EU on a trajectory to achieve zero pollution for air at the latest by 2050, in synergy with climate-neutrality efforts.

Recommendations on the New Air Quality Directive The European Non-Ferrous Metal (NFM) sector welcomes the new Proposal for an Air Quality Directive and the opportunities to provide feedback. The NFM sector is strongly committed to continuing lowering emissions of air pollutants for the benefit of human health and the environment.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Comments to the public consultation on the Commission proposal for ambient air quality standards March 2023 Key Points: • Future air quality limits must be assessed on the basis of a full risk assessment and risk management process. • Any new sector-specific measures need time to deliver their intended benefits before new air quality limits values could apply.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the opportunity to express our views and comments on the draft revision of AAQD. BeLOW please find some of our main points, while in the Attachement further comments on individual Articles can be found. Alignment of the future EU AQ standards with technical and economic feasibility must be a key principle of the Directive.

Filed in Czech · English published by the European Commission

On 26 October 2022, the European Commission presented its proposal to revise the EU Air Quality Directive (2008/50/EC). This Directive lays down methods for monitoring and assessing ambient air quality as well as limit values and objectives to prevent, reduce or at best avoid the impact of poor air quality on human health and the environment.

Filed in German · English published by the European Commission

Improving air quality and achieving ever-lower concentrations of pollutants is a fundamental ambition for the protection of citizens health by European, national, and local institutions. Anyway, reaching near-zero limits in a limited time, is extremely complex.

The European Copper Institute welcomes the opportunity to provide its feedback into the revision of the Directive 2004/107/EC and the Directive 2008/50/EC (Ambient Air Quality Directives). Copper plays a leading role in the EUs transition to a climate-neutral and digital economy.

The German energy industry represented by the Federal Association of Energy and Water Management (Bundesverband der Energie- und Wasserwirtschaft BDEW e.V.) has been working successfully to improve air quality for many years.

Filed in German · English published by the European Commission

European Commission Directorate-General for Environment 1049 Brussel BELGIUM Your ref.: COM(2022) 542 final 2022/0347 (COD) Oslo, 14.03.2023 Our ref. (incl. when replying): 2014/3343 Case officer: Scott Randall Proposal for a Directive of the European Parliament and of the council on ambient air quality and cleaner air for Europe Feedback from the Norwegian Environment Agency The Norwegian Environment Agency has…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

European Respiratory Society (ERS) Response to Consultation - EU Ambient Air Quality Directive The European Respiratory Society (ERS) appreciates the efforts made by the European Commission on the proposal for a revised EU Ambient Air Quality Directive (AAQD).

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on ambient air quality and cleaner air for Europe (recast). Please find detailed comments in the Attachment.

This comment was prepared by the EMEP-CCC, with input from the Chair of EMEP TFMM. The EMEP monitoring strategy specifies the requirements for the monitoring activities of the Parties to EMEP: https://unece.org/sites/default/files/2021-01/ECE_EB.AIR_144_Add.1-2001542%20%28E%29_0.pdf (valid for 2020-2029).

Deutsche Umwelthilfe (DUH) welcomes the fact, that the revision process of the Ambient Air Quality Directives (AAQD) resulted in a proposal of the European Commission to strengthen air quality standards in the European Union. Unfortunately, the draft of the Commission lacks ambition.

The European Cancer Organisation (ECO) welcomes the European Commission proposal on the Directive on ambient air quality and cleaner air for Europe. Clean air is vital for human health, and although the European Union (EU) has recorded worrying figures in this respect in recent years, ECO is pleased to note the joint efforts of the EU and national and local authorities to reduce the harmful impacts of air pollution…

With currently more than 21 million members, ADAC e.V. is the largest automobile club in Europe and the second largest in the world. The four letters in its name stand for an association which offers its members assistance, protection and advice around the clock and is a powerful stakeholder on all mobility issues.

Filed in German · English published by the European Commission

Pegasor welcomes the revision of the European air quality directive and the target to update it to match the recommendations of WHO. Very important part of the revision is to include particle number (PN) monitoring as part of the routine monitoring requirements for environmental authorities. This will have a significant impact on the air quality and the safety of the people in urban environments.

The European Federation of Allergy and Airways Diseases Patients Associations (EFA) considers the revision of the EU Ambient Air Quality Directives (AAQD) as a crucial step to correct existing shortcomings and gaps in the current air quality legislative framework which lead to the development of allergy and respiratory disease and cause 300,000 deaths annually.

France Chimie does not express a view on the objectives of the Directive, but wishes to share the efforts made by the industry to reduce their air emissions and thus contribute to improving air quality. Chemistry is a major player in the French, European and global economy. The impact of its activities is real: the vast majority of production units emit pollutants by their air emissions.

Filed in French · English published by the European Commission

The European coal industry is subject to strict EU pollution control legislation and has successfully implemented this to meet some of the worlds highest standards. The coal sector has invested heavily in pollution control technologies and achieved impressive results for example, sulphur dioxide (SO2) and oxides of nitrogen (NOx) emissions from coal use in the EU have fallen by between 60% and 90% since 1990.

The FIA European Bureau is fully committed to clean mobility and supports the goal of progressively improving air quality in the European Union to levels no longer considered harmful to human health and natural ecosystems. However, and in view of establishing clear and achievable European requirements, the expression zero pollution objective should not be used in the Ambient Air Quality Directives.

Enel strongly welcomes the Commissions proposal for the revision of the Ambient Air Quality Directives, as air quality is the number one environmental and health problem in Europe and the quality of air Europeans breathe is still far from complying with European or international standards.

HSE PHMEHG strongly support the review of the revision of EU Ambient Air Quality Directives (AAQDs). Within EU, the standards are currently heterogeneous, and do create health inequities, and will urgently need to be rectified before full alignment with newly proposed WHO recommendations. HSE PHMEHG recommends: 1. The introduction of homogenous ambient air quality monitoring across Europe. 2.

Aurubis is a leading worldwide provider of non-ferrous metals. We process complex metal concentrates and diverse recycling raw materials. Aurubis is a global leader in copper recycling. We welcome the opportunity to comment on the revision of the Ambient Air Quality Directives. Air quality affects our health and our quality of life. Our industry is therefore fully committed to contributing to clean air.

Site relevance is high The site relevance of the Air Quality Directive, which has been revised for the first time since 2008 and is being developed in the direction of the most recent extremely stringent WHO recommendations of September 2021, is high. Where exceedances occur permanently, there is considerable pressure on the Länder governments to define air remediation areas in accordance with the IG-L.

Filed in German · English published by the European Commission

Transport & Environment (T&E) welcomes the proposal for a revised Ambient Air Quality Directive (AAQD). The proposal is a step in the right direction. However, more ambition is needed to protect European citizens from the dangers of air pollution (especially so in cities) and incentivise policies like low emission zones to accelerate the shift to zero emission transport.

Aggregates Europe - UEPG represents the aggregates industry companies that extract and supply quality construction raw materials in European countries, which are essential to meet demand. Aggregates Europe - UEPG supports the objectives to be achieved by the revision of this Directive, in particular with regard to the further reduction of particulate emissions.

The Federation of Aggregates (FdA) represents the interests of companies producing aggregates in Spain, both nationally and internationally. FdA supports the objectives to be achieved by the revision of this Directive, regarding the further reduction of particulate emissions.

The ÖAMTC is committed to clean mobility and supports the objective of gradually bringing air quality to levels that are no longer considered harmful to human health and natural ecosystems. However, for legally binding European requirements, the policy concept of the toxic-free environment chosen for this objective should not be applied.

Filed in German · English published by the European Commission

Revision of the Ambient Air Quality Directive January 2023 January 2023 Revision of the Ambient Air Quality Directive ClientEarth’s key recommendations to improve Commission Proposal COM/2022/542 ClientEarth welcomes the European Commission’s proposal for a recast Ambient Air Quality Directive (the “Proposal”) for its ambitious intentions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The revision of the Air Quality Directive and its daughter directives aims to merge them into one directive in order to bring EU air quality standards more in line with WHO recommendations, further improve the regulatory framework and provide more support to local authorities in their efforts to achieve cleaner air.

EuroHealthNet is a non-profit European partnership with a long-term commitment to promoting health equity in sustainable development, supporting measures to reduce pollution levels and improve health and wellbeing.

Entwurf einer neuen Luftqualitätsrichtlinie      Dipl.-Ing. [name removed] Wissenschaft, Technik und Umwelt Abteilung Umweltschutz, Anlagensicherheit, Verkehr T [phone removed] | E [email removed] Verband der Chemischen Industrie e.V.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Organization for Respiratory Health in Finland (RHF) promotes respiratory health and a good life for the people with respiratory disorder. The RHF calls as the member of EFA patient community on the EU to fully align the EU air quality standards with the 2021 recommendations of the WHO Air Quality Guidelines, to be achieved as soon as possible and certainly by no later than 2030.

In general, our industry supports the setting of air quality standards to prevent the build-up of excessive concentrations of pollutants. Clean air is important for human health and the environment. However, it should be noted that the WHO recommendations on which the revision of the Air Quality Directive is based focus only on health impacts, leaving out impacts on economic factors, etc.

This is a document containing recommendations from ACTRIS (and RI-URBANS) on the proposal for reviewing the EC Air Quality (AQ) Directives published on 26th October 2022. This document replaces the one uploaded on 08/02/2023 in the AQ Directive review.

VDMA expressly supports the efforts of the EU Commission to further improve air quality in the EU. Updating the EU air quality directives makes sense but must be carried out with the appropriate sense of proportion. Within the framework of this position paper, we have outlined various aspects and issues that must definitely be taken into account when drafting the legislative text.

Position of the WVMetalle A revision of the EU regulations on air quality is currently not necessary due the fact that there is no urgent need and more importantly it has proven to be successful. Additional-ly, the EU is already pursuing numerous legislative targets with a focus on air quality. Furthermore, there is no sufficient trade-off between health protection and other EU objectives.

Eurocities welcomes the opportunity to share feedback on the ambient air quality proposal. Our network represents more than 200 European cities in Europe, working to improve the health of their citizens and to better protect the environment. Air pollution is still a major threat for heath and biodiversity in cities, linked to the premature deaths of thousands of cities residents every year.

TNO fully supports the initiative of the European Commission to revise the air quality rules, as announced in the European Green Deal and its zero-pollution ambition for a toxic-free environment. We have aligned our suggestions with the document DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on ambient air quality and cleaner air for Europe (26.10.2022 COM (2022) 542 final 2022/0347 (COD)); $ 2.4 preferred…

ESMO Feedback - Proposal for Revising and Merging the EU Ambient Air Quality Directives The European Society for Medical Oncology (ESMO) - representing more than 28,000 oncology professionals from over 160 countries - welcomes the European Commission’s ambition to achieve zero air pollution by 2050 by revising and merging the Ambient Air Quality Directives.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Federation of German Industries (BDI) There is no urgent need for action to amend the existing and very successful EU Ambient Air Quality Directives now. At the same time, the EU is pursuing a large number of legislative projects that already contribute directly and indirectly to improving air quality.

This is a document containing preliminary recommendations from ACTRIS (and RI-URBANS) on this on the proposal for reviewing the EC Air Quality (AQ) Directives published on 26th October 2022. This document was elaborated by a group of experts from ACTRIS and RI-URBANS and we decided to send these preliminary comments now to adapt to the timing of the revision of the directive.

The Commission’s proposal to amend the Ambient Air Quality Directive will, in our initial assessment, repeat the mistakes made in previous years in air pollution control planning. The limits set for 2030 are unlikely to be met at many traffic- and industry-related measuring stations. Once again, federal states and municipalities in Germany may have to extend low-emission zones and introduce driving bans.

Filed in German · English published by the European Commission

Consultation Statement: Ministry of Traffic Baden-Württemberg The German State of Baden-Württemberg is in full alignment with the EUs zero pollution strategy. Ambitious limit values that are used as a step stone on the way to zero pollution in the revised Ambient Air Quality Directives (AQD) are seen as an effective tool to improving air quality.

SKR submits that: — SKR is in favour of updating the Ambient Air Quality Directive. It is urgent to have a high level of ambition. It is important to reach the WHO’s recommendations in the long term, but this requires that it can be met with reasonable measures and at a reasonable pace.

Filed in Swedish · English published by the European Commission

The average Historic Vehicle is taken out about 15 times a year, with historic cars travelling around 1,400km and historic motorcycles less than 900km per year. Considering this marginal use, their impact on air quality is negligible. Historic Vehicles are not for daily use and are thus not a part of the general transport mix in the context of the policy discussions on improving urban mobility.

IBERDROLA welcomes the Fit for 55 Package The Green Deal though the Fit for 55 Package offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient and non-polluting alternatives to enable decarbonisation and the achievement of EU climate objectives and solve EUs air pollution problem.

The Danish National Association for Information on Wood Smoke Pollution (LOB) reminds not to suppress informations regarding air pollution from burning wood in private stoves. The sources are clearly identified, local adverse conditions for spreading smoke are known as well as a multitude of health damages and their costs for society at large.

EU air quality limit values must (at least) be aligned with WHO Air Quality Guidelines and fulfilled by 2025. Hence, all EU directives and regulations that can improve air quality must be aligned to fulfill the WHO Air Quality Guidelines from 2025.

JAKOŚĆ POWIETRZA – PRZEGLĄD PRZEPISÓW UE Opinia Instytutu Spraw Obywatelskich Instytut Spraw Obywatelskich z zadowoleniem przyjmuje inicjatywę Komisji dotyczącą przeglądu dyrektyw w sprawie jakości powietrza atmosferycznego, mając nadzieję na pozytywny wpływ regulacji na jakość powietrza, środowiska i zdrowie obywateli.

Filed in Polish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

I am writing on behalf of 'Clean Air in London' (CAL) in response to this consultation on 'Air quality (AQ) - revision of EU rules'. Our most important point is to ask you please to ensure continuity and tightening of health, legal and environmental protections (see 2013 letter below for explanation).

SUEZ - GROUPE TOUR CB21 - 16, PLACE DE L’IRIS 92040 PARIS LA DÉFENSE CEDEX, FRANCE TEL [phone removed] WWW.SUEZ.COM DEPARTMENT OF INSTITUTIONAL AFFAIRS – EUROPE SUEZ response to the Ambient Air Quality Directives revision roadmap January 2021 Interest Representative Identification Number: 27799842497-69 Suez welcomes the opportunity to share its views on the upcoming revision of the Ambient Air Quality Directives.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The most fundamental impact of air pollution is on human health while it is also linked to the climate and biodiversity crises and planetary health. Air pollution is a global health challenge that affects us all. It increases the risk of heart disease, stroke, cancers, dementia and diabetes, causes new asthma cases in children, and damages nearly every organ of our bodies.

Citizens for Air welcomes the revision of the AAQDs. Standards We highlight the urgency of aligning the EU air quality standards with scientific knowledge, in particular with the forthcoming recommendations of the World Health Organisation (WHO), and to achieve that the AAQDs may ensure protection of the precautionary principle.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Veolia welcomes the initiative of the European Commission to revise rules regarding air quality as announced in the European Green Deal and its zero pollution ambition for a toxic-free environment. We support the need to draw on the lessons learnt from the Fitness Check of the Ambient Air Quality Directives.

The Clean Air Task Force (CATF), a climate and energy organization dedicated to decarbonizing the global energy system with staff in the US and Europe, welcomes the opportunity to provide feedback on the revision process of the Ambient Air Quality (AAQ) Directives. Air pollution has long been associated with detrimental impacts not only on human health but on overall ecosystems.

Brussels, 14 January 2021 EEB welcomes the publication of the European Commission’s roadmap on the inception impact assessment for the revision of the Ambient Air Quality Directives (AAQDs) and the opportunity to provide feedback to it. The roadmap includes some details on the Commission's understanding of the problem and possible solutions related to the revision of the AAQ Directives.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Federation of Allergy and Airways Diseases Patients' Associations (EFA) welcomes the initiative of the Commission to revise the Ambient Air Quality Directives. Air pollution remains the single largest environmental health risk in Europe, and a major cause of mortality responsible for around 400.000 premature deaths per year.

Air quality - revision of EU rules Roadmap https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12677Revision-of-EU-Ambient-Air-Quality-legislation PTPZ- feedback The mission of Polskie Towarzystwo Programów Zdrowotnych, The Polish Society for Health Programs (PTPZ) is to create and manage best quality health programs and to support creation of health policies.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Bellona sincerely welcomes the taking into account of the points expressed in the previous contribution, including the recognition that current air quality standards were largely missing the WHO recommendations. However, it’s important to aim at a full alignment with WHO recommendation, rather than just a closer alignment.

Air quality in Europe is still far from complying with European or international standards. Especially in urban areas, air quality limits in Europe are widely exceeded for the three main pollutants (particulate matter or PM, ozone and nitrogen oxides or NOx).

Eurovent holds that gap between the AAQ Directives and the WHO guidelines on PM2.5 must be closed, that air quality data must be disseminated to the public more effectively, and that ambient air quality legislation must be complemented with policies addressing indoor air pollution as well. More information in the document attached.

Setting EU-wide limit values for air pollutants under Directive 2008/50/EC is, in the view of the ZDH, a necessary and meaningful task of EU policy. A successful pollution reduction policy requires, in addition to setting limit values, a consistent and uniform approach to ambient air measurement across Europe. In the view of the ZDH, there is considerable room for improvement.

Filed in German · English published by the European Commission

Cefic, the European Chemical Industry Council, founded in 1972, is the voice of large, medium and small chemical companies across Europe, which provide 1.2 million jobs and account for about 17% of world chemicals production.

Regarding the policy area 3 included in the roadmap document, we suggest to include the reference to the type of AQ monitoring station. Hence, we would suggest to replace the existing parragrah by this one, including the word "type": Policy area 3: strengthening of air quality monitoring, modelling and plans.

The European Respiratory Society appreciates the opportunity to input to the inception impact assessment on the revision of the ambient air quality directives which need updating. We support the most ambitious proposals available based on the latest cutting edge science on the health effects of air pollution. The case for the revision of the EU legislation to tackle air pollution is unequivocal.

EU legislation has been working as a driving force for better air quality in Europe. However, and despite improvements, with many EU member states undergoing infringement procedures, the lack of enforcement and stringent standards are undermining local efforts taken by cities.

Concawe welcomes the possibility to provide views on the inception impact assessment related to the upcoming revision of the ambient air quality directives. Concawe conducts its activities with objectivity and scientific integrity. In the complex world of environmental and health science, Concawe seeks to uphold three key principles: sound science, transparency and cost-effectiveness.

Response from NILU (www.nilu.no) to the European Commission’s Inception impact assessment regarding revision of the ambient air quality directives. We support the initiative to align the European standards with the WHO guidelines and to include into the Directives an explicit mechanism for adjusting air quality standards to technical and scientific progress. Today it is a slow process to change the directives.

Air pollution is the number one environmental health risk in the EU, causing both chronic and serious diseases such as asthma, cardiovascular problems and lung cancer. Air pollution is responsible for some 400 000 premature deaths every year in the EU and for damage to ecosystems and biodiversity through eutrophication, acidification and excess ozone levels.

The FIA European Bureau supports the endeavour of the European Commission to revise policies and legislation related to air quality from all sectors in the follow-up to the ambition set in the European Green Deal. Whilst the mobility sector is often singled out, there is a shared responsibility of all sectors to lower their impact on the environment.

The revision of the Ambient Air Quality Directives (AAQD) is urgently needed, as their adoption dates back more than a decade. Since then, evidence increased and new findings about correlations between air pollutants and health effects, especially resulting from exposure to concentrations below the limit values, have been confirmed.

Setting EU-wide limit values for air pollutants under Directive 2008/50/EC is, in the view of the ZDH, a necessary and meaningful task of EU policy. A successful pollution reduction policy requires, in addition to setting limit values, a consistent and uniform approach to ambient air measurement across Europe. In the view of the ZDH, there is considerable room for improvement.

Filed in German · English published by the European Commission

FEEDBACK Inception impact assessment - Ares(2020)7689281 “Revision of the Ambient Air Quality Directives” WSM Wirtschaftsverband Stahl- und Metallverarbeitung e.V. (German Steel and Metal Processing Industry Association), representing the German steel and metal processing industry towards politics and economy, would like to take this opportunity to comment on the Inception impact assessment Ares(2020)7689281…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Comments on Inception Impact Assessment for Ambient Air Quality Directives Mary S. Booth Partnership for Policy Integrity January 14, 2021 Please accept this feedback on the Inception Impact Assessment (IAA) from the Partnership for Policy Integrity, a US-based NGO working with allies across Europe and the world for the protection and restoration of natural forests.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EURACOAL welcomes the aim of more effective pollution control policies. We support the UN Sustainable Development Goals and the aim of creating a cleaner environment in the EU. Current legislation already sets high standards and contributes to a cleaner planet for all.

Transport & Environment, Europe's leading clean transport campaign group, welcomes the European Commission’s plan to review the Ambient Air Quality Directives (AAQD). While EU clean air laws have driven stepwise reductions in toxic air pollution, the Second Clean Air Outlook clearly shows that current and planned policies remain insufficient, especially in cities.

Air quality remains a major health as well as environmental concern across the EU. Moreover, the particular impact on the population in a given region is also determined by topographical features. Transport is a major contributor to the problem, and the valleys along the main transalpine transport corridors are hotspots for exceedances of air quality limits, as described in the eighth Report on the state of the Alps…

The Commission states that it is unlikely that an implementation plan is needed as the Ambient Air Quality Directive already is in force, and that the implementation structures are already in place within the Members States with the competent authorities appropriately designated. We would like to state that, besides impact assessments, in our opinion an implementation plan is in fact very important.

According to the latest EEA's “Air quality in Europe - 2020 report”, a better air quality has led to a significant reduction of premature deaths over the past decade in Europe. EU, national and local policies and emission cuts in key sectors have improved air quality across Europe, the EEA report shows.

CEEP an organisation that represents the interests of the energy companies from Central Europe at the EU level, welcomes the possibility to provide feedback to the Commission’s Inception Impact Assessment on the revision of the Ambient Air Quality Directives (AAQD). Clean air is essential for the health of people and the environment.

ATMO France welcomes this initiative by the European Commission. The development of a strong social concern about air pollution and the evolution of technologies, scientific and epidemiological knowledge of the risk to health, including as an aggravating factor in the health crisis we are experiencing, and for the environment, fully justify the need to rapidly update EU air quality standards, in particular in…

Filed in French · English published by the European Commission

From Ecologists in Action, both diagnosis and policy objectives and choices are generally considered appropriate, in so far as: (1) the limit and target values of the Air Quality Directives do not ensure the protection of public health and the environment, as they do not comply with the WHO Guidelines; (2) failure to comply with the obligations arising from the Directives has no consequences for the responsible…

Filed in Spanish · English published by the European Commission

Outdoor air pollution causes ap- proximately 400,000 premature deaths in Europe every year according to the European Commission. In addition, it causes serious diseases for millions of Europeans. A pre- mature death due to air pollution means an average loss of ten years of living. Thereby, about 4 million life years are lost annually in the EU due to air pollution.

We welcome the opportunity to share our views on the revision of EU rules on air quality and measures to address air pollution. Air pollution continues to be a major health and environmental problem in Europe. Despite improvements in air quality over recent decades, countries and cities across Europe still struggle to meet EU limits, and a significant share of the EU population continues to be exposed to levels of…

The Association for Emissions Control by Catalyst (AECC) welcomes the opportunity to comment on the inception impact assessment on the revision of the Ambient Air Quality Directives. AECC fully supports the revision of the Ambient Air Quality Directives. Clean Internal Combustion Engines (ICEs) have a role to play in further reducing air pollutant concentrations in European cities.

January 2021 Consultation on inception impact assessment for the revision of the Ambient Air Quality Directives Feedback from ClientEarth Top Lines • • • • ClientEarth welcomes the start of the initiative to revise and strengthen the Ambient Air Quality Directives Legally enforceable air quality standards (“limit values”) fully aligned with the WHO recommendations should be the backbone of the revised Ambient Air…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The further improvement of air quality and thus the reduction of health burdens is to be welcomed. Because of the air chemical processes, the large-scale transport of pollutants, etc., certain air pollutants require, as a matter of priority, permanent and large-scale action. For example, reducing ozone requires a permanent and large-scale reduction of precursors.

Filed in German · English published by the European Commission

The Air Quality Directives set common methods for monitoring, assessing and informing about air quality in the European Union and set air quality targets to avoid, prevent or reduce harmful effects on human health and the environment as a whole. The steel industry supports a sustainable policy to protect humans and the environment from the harmful effects of pollutants.

CEWEP, the Confederation of European Waste-to-Energy (WtE) Plants, welcomes the initiative of reviewing the EU Air Quality standards and aligning them more closely with the recommendations of the World Health Organization.

The European Sea Ports Organisation (ESPO) and its members welcome Europe’s ambition to be the world’s first net zero emission area by 2050. Achieving the ambitions of the European Green Deal for 2030 and 2050 should be the driver of EU policy. This includes the goal of zero pollution by 2050. ESPO supports an assessment, and if motivated, a revision of the Ambient Air Quality Directives.

Air pollution is the number one environmental threat to health in the European region and globally, leading to 400,000 premature deaths and hundreds of billions of euros in health costs in Europe each year. There is a large body of evidence on how air pollution harms health. Poor air quality is a leading risk factor for chronic disease including heart and lung diseases or cancer.

The VCI represents the politico-economic interests of around 1,700 German chemical companies and German subsidiaries of foreign businesses. In 2019 the German chemical industry realised sales of over 198 billion euros (equal to 1/3 of the Europe-an chemical industry) and employed around 464,000 staff. We welcome the consultation of stakeholders about the roadmap for updating the Air Quality Directives.

The feedback (in the attachment) was prepared by members Slovenian Partnership for Environment and Health and Environmental Health working group within Plan B – the network of environmental NGOs from Slovenia. The process was coordinated and submitted by the leading partner Institute for Environment and Health. We highly support the revision of the Ambient Air Quality standards and directives.

Federation of German Industries e. V.: In BDI's view, a revision of the European ambient air quality directives is not necessary at present. 1. Preserving Europe as a business location: European industry is currently undergoing structural change and also has to cope with the effects of the pandemic. Corona and restrictions on business are leaving deep scars on employment and prosperity in the European member states.

Austrian Federal Economic Chamber (WKO) feedback on IIA - revision of AAQDs – EC air quality roadmap: We encourage the Commission to avoid, prevent or reduce harmful effects of poor air quality on human health and the environment. To substantially improve enforcement of the AAQDs, we recommend a change of strategy for “full effectiveness” in air quality policy.

Air pollution is the biggest environmental risk to health in the European Unión According to the World Health Organization (WHO), air pollution is the biggest environmental risk to health in the EU. 96% of EU citizens living in urban areas were exposed to levels of air pollutants considered by the WHO as damaging to health.

The BDSV considers it premature to revise the European Ambient Air Quality Directives: These requirements were introduced only a few years ago and are already a major challenge for EU Member States and industry. A tightening would therefore be a further burden. Rather, the EU should seek to ensure that all Member States first fully implement and apply the existing rules.

Filed in German · English published by the European Commission

As a member of the Carlos III Health Institute, the National Reference Laboratory (NLR) of the Spanish Air Quality Network (RECA) and therefore accredited in accordance with EN ISO/IEC 17025: 2017 for pollutants listed in Annex VI to Directive 2008/50/EC, I have some comments to make.

Filed in Spanish · English published by the European Commission

The Inter-Environnement Wallonie Federation (IEW) supports the Commission in its efforts to strengthen EU legislation on air quality. In particular, IEW supports the alignment of European limit values with WHO guidelines. Alignment with the 2006 guidelines is the minimum approach, ideally following the updated guidelines announced for the first half of 2021.

Filed in French · English published by the European Commission

No revision of the European Ambient Air Quality Directives: There is no need to revise the European Ambient Air Quality Directives. In its recent report on the review of these directives, the Commission concludes that the current legislation provides the necessary tools to address existing challenges. The Directives have effectively contributed to improving air quality and achieving high air quality standards.

Filed in German · English published by the European Commission

ZWE welcomes the Commission proposal to review the Ambient Air Quality Directives. End of life treatment of waste such as waste incineration release pollutants to ambient air. These pollutants, at certain concentrations, lead to health and environmental issues, as the World Health Organization has acknowledged.

The Industrial Association HKI sees the greatest potential for improving air quality in overcoming the blockade when replacing old appliances with more effective, combined biomass central and individual room heating. The announced Renovation Wave should, among other things, also target precisely there. Modernisation through innovative technology reduces particulate matter emissions by up to 90 percent.